IV.M. Environmental Safety - LA City Planning · 2013. 1. 17. · Unified Hazardous Waste and Hazardous Materials Management Regulatory Program (Unified Program) (Senate Bill 1082,

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

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WORKING DRAFT - Not for Public Review

Table of Contents M. Environmental Safety

1. INTRODUCTION ....................................................................................................... 1978

2. ENVIRONMENTAL SETTING ................................................................................... 1979 a. Regulatory Setting ................................................................................................ 1979 b. Existing Local Area Conditions (Outside the Project Site) .................................... 1979 c. Existing On-Site Conditions .................................................................................. 1989

(1) Emergency Procedures ................................................................................ 1990 (2) Hazardous Materials Use, Storage, and Management ................................. 1992 (3) Hazardous Waste ......................................................................................... 1998 (4) Asbestos and Lead-Based Paint .................................................................. 2001 (5) Polychlorinated Biphenyls ............................................................................ 2003 (6) Closed Landfill .............................................................................................. 2004 (7) Underground Storage Tanks ........................................................................ 2008 (8) Aboveground Storage Tanks ........................................................................ 2009 (9) Radio Frequency .......................................................................................... 2010

3. ENVIRONMENTAL IMPACTS .................................................................................. 2011 a. Methodology ......................................................................................................... 2011 b. Thresholds of Significance ................................................................................... 2012 c. Project Design Features ....................................................................................... 2013 d. Project Impacts ..................................................................................................... 2014

(1) Construction Impacts .................................................................................... 2014 (2) Operational Impacts ..................................................................................... 2016 (3) Impacts Under No Annexation Scenario ....................................................... 2022

4. CUMULATIVE IMPACTS .......................................................................................... 2023

5. PROJECT DESIGN FEATURES AND MITIGATION MEASURES ........................... 2023 a. Project Design Features ....................................................................................... 2023

(1) Hazardous Materials Use/Management ....................................................... 2023 b. Mitigation Measures ............................................................................................. 2024

(1) General ......................................................................................................... 2024 (2) Landfill Related ............................................................................................. 2025 (3) Hazardous Materials Use and Storage/Hazardous Materials

Management/Hazardous Waste/Asbestos/Polychlorinated Biphenyls/Underground Storage Tanks/Aboveground Storage Tanks ......... 2026

(4) Radio Frequency .......................................................................................... 2026

6. LEVEL OF SIGNIFICANCE AFTER MITIGATION .................................................... 2027

Table of Contents


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List of Tables

185 Hazardous Materials Regulatory Setting .............................................................. 1980

List of Figures

222 Location of Notable Hazardous Material Storage ................................................. 1995


Page 1978


IV. Environmental Impact Analysis M. Environmental Safety

1. Introduction

The following section addresses hazardous materials issues and is based upon the Environmental Safety Technical Report prepared by Camp Dresser & McKee Inc. (CDM) for the proposed Project, dated March 2010. The full text of the report is included as Technical Appendix O to this Draft EIR.

Hazardous materials include solids, liquids, or gaseous materials which because of their quantity, concentration or physical, chemical or infectious characteristics may: (1) cause or contribute to an increase in mortality or serious illness; or (2) pose a substantial present or potential harm to human health or the environment when improperly handled, used, transported, stored or disposed. This section addresses the following seven environmental safety issues: Hazardous Materials Use, Storage, and Management; Hazardous Waste; Asbestos (including asbestos containing material) and Lead-Based Paint; Polychlorinated Biphenyls; Closed Landfill; Underground Storage Tanks; Aboveground Storage Tanks; and Radio Frequency. See Section IV.G.2, Water Resources, for other related environmental safety issues such as surface water and groundwater quality.

The analysis of on-site hazardous materials assumes that the utilization of such materials would continue and potentially increase under the proposed Project. Hazardous waste generation projections under the proposed Project are based on the current hazardous waste generation rates of existing uses on the Project Site. Existing hazardous materials and hazardous waste programs currently in place on the Project Site are assumed to continue under the proposed Project.

Hazardous materials acquisition, use, handling and storage on the Project Site is undertaken by three separate sets of operators: (1) the Applicant; (2) the Applicant's tenants (i.e., long-term ground lessees); and (3) third-party vendors. Since all current tenants and third-party businesses on-site are compatible with the land use activities of the Applicant, the regulatory compliance issues discussed in this section with regard to the Applicant are no different than those for the tenants and third-party vendors. All these operators, by law, have primary responsibility (i.e., permitting, manifesting and remediation)

IV.M. Environmental Safety


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for their own activities. However, for convenience and efficiency, some wastes generated by tenants and third-party vendors may be stored and disposed of by the Applicant.

The analysis in this section assesses future hazardous materials acquisition, use, handling and storage site-wide, and does not differentiate between the types of on-site operators. However, specific operators are identified where their activities are under current regulatory review and control.

2. Environmental Setting

a. Regulatory Setting

Table 185 on page 1980 identifies and summarizes the major legislations which regulate each of the eight categories of hazardous materials addressed in this section. Table 185 also identifies the government agencies charged with the administration and enforcement of each major law. Remedies available to administering agencies to ensure enforcement of the legislation include, but are not necessarily limited to, the assessment of administrative and civil penalties, fines, and injunctions against violators.

The response to releases of hazardous materials is governed by a variety of Federal, State and local regulations and requirements including Title III of the Superfund Amendments and Reauthorization Act of 1986, the La Follette Bill of 1986, and the Waters Bill of 1985. The level of response required and the entities accountable for responding vary depending upon a number of factors, including the type and quantity of material released, the medium into which the release occurred, and the availability and training level of the facility's response team.

b. Existing Local Area Conditions (Outside the Project Site)

A computerized public records search of government databases was performed by Environmental Data Resources, Inc. (EDR) in July 2007. The search included areas on-site or within and up to 1.5 miles from the center of the Project Site and included information from databases on registered underground storage tanks, operators who are hazardous waste generators, former landfills, and sites with known hazardous materials release, amongst others. An explanation of each government list/database searched, along with the complete records search results, may be found in Appendix O to this Draft EIR.



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Table 185 Hazardous Materials Regulatory Setting

Issue Area and Relevant Legislation Administering Agency

Hazardous Materials Use, Storage, and Management

Federal/State Occupational Safety and Health Act This Federal/State legislation requires special training of handlers of hazardous materials, notification to employees who work in the vicinity of hazardous materials, acquisition from the manufacturer of material safety data sheets which describe the proper use of hazardous materials, and training of employees to remediate any hazardous material accidental releases. The California Division of Occupational Safety and Health also requires preparation of an Injury and Illness Prevention Program which is an employee safety program of inspections, procedures to correct unsafe conditions, employee training, and occupational safety communication.

California Division of Occupational Safety and Health

Emergency Planning and Community Right-to-Know Act (Title III of the Federal Superfund Amendments and Reauthorization Act) This 1986 Act established nationwide reporting and planning requirements for businesses that handle or store certain hazardous materials. The four programs created under Title III of the Federal Superfund Amendments and Reauthorization Act include planning for emergency response, reporting hazardous materials inventories, reporting leaks and spills, and annually reporting the total releases of specified toxic chemicals. As the toxic chemicals handled by the Project Site are below Title III of the Federal Superfund Amendments and Reauthorization Act thresholds, it is not required to comply with the annual reporting program. The other three programs overlap with the requirements under California’s Waters Bill and La Follette Bill, which are discussed below.

U.S. Environmental Protection Agency (EPA)

Waters Bill of 1985 (Business Emergency Plan/Hazardous Materials Business Plan) This State legislation requires facilities which meet minimum hazardous materials use/storage thresholds to file a Business Emergency Plan, or a Hazardous Materials Business Plan (as Business Emergency Plans are referred to by the County Fire Department), which includes a complete inventory of the hazardous materials being used and stored on a site. Employee training and emergency response plans and procedures for the accidental release of hazardous materials are also included in a Business Emergency Plan. These provisions are also required under Title III of the Federal Superfund Amendments and Reauthorization Act and are administered via maintenance of Business Emergency Plan/Hazardous Materials Business Plan.

L.A. County Fire Department (County Fire Department) and City of L.A.

Fire Department (City Fire Department)


Table 185 (Continued) Hazardous Materials Regulatory Setting


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La Follette Bill of 1986 (Risk Management Plan) This State legislation requires preparation of a Risk Management Plan for commercial operations which use hazardous materials at defined thresholds. The Risk Management Plan includes management, engineering and safety studies, and plans for physical improvements to minimize accidental hazardous materials releases. Implemented via fire inspections, plan checking, Business Emergency Plan/Hazardous Materials Business Plan disclosure requirements, and filing of the Risk Management Plan (updated every three years). Similar planning for emergency response is also required under Title III of the Federal Superfund Amendments and Reauthorization Act.

County Fire Department and City Fire Department

Unified Hazardous Waste and Hazardous Materials Management Regulatory Program (Unified Program) (Senate Bill 1082, 1994) The Unified Program consolidates and coordinates the six State programs that regulate business and industry use, storage, handling, and disposal of hazardous materials and wastes. The County Fire Department and the City Fire Department are both Certified Unified Program Agencies. The Project Site includes areas in unincorporated County of Los Angeles as well as areas that are in the City of Los Angeles. Although the Project Site operates under both County Fire Department and City Fire Department Certified Unified Program Agencies, the City Fire Department, which has jurisdiction over the City portion of the Project Site, has entered into an agreement with the County of Los Angeles for the County Fire Department to administer the hazardous waste components of the Unified Program. Under the Unified Program, the Project Site is required to submit several business information and hazardous materials inventory forms to the Certified Unified Program Agencies.


Comprehensive Environmental Response, Compensation and Liability Act and California Hazardous Substance Account Act These Federal and State legislations require reporting of certain releases of hazardous substances from certain facilities and set forth identification and response action requirements for designated sites. The Project Site is not a listed Federal or State Superfund site.

U.S. EPA, California EPA, California Department of Toxic Substances Control

Uniform Fire Code This local legislation regulates the type, configuration, and quantity of hazardous materials that may be stored within structures or in outdoor areas. Administered via regular site inspections and the issuance of notices of violation in cases of noncompliance.





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Safe Drinking Water and Toxics Enforcement Act (Proposition 65) This State legislation requires certain businesses which use hazardous materials to post public notice of any accidental hazardous materials releases, the release of or other known potential exposures to materials known to the State of California to cause cancer or reproductive toxicity and prohibits such businesses from releases into the environment at levels above identified risk levels.

L.A. County Department of Health Services

General Plan Safety Elements The General Plan Safety Elements of the City and County of Los Angeles represent the long-range emergency response plan for the City and County and seek to address the issues of protection of people from unreasonable risks associated with natural disasters (e.g., fires, floods and earthquakes), as well as reduce future losses of life, injuries and socioeconomic disruption from other safety issues including the management of hazardous materials.

City of L.A. and L.A. County

Hazardous Waste

Federal/State Occupational Safety and Health Act The Occupational Safety and Health Act regulations contain worker safety provisions with respect to hazardous waste management operations and emergency responses involving hazardous wastes. The hazardous waste provisions of Occupational Safety and Health Act are contained in the Hazardous Waste Operations and Emergency Response Standard. See also the discussion under Hazardous Materials Use and Storage, above.


Resource Conservation and Recovery Act and California Hazardous Waste Control Law These Federal and State legislations regulate the generation, transportation, treatment, storage and disposal of hazardous waste by "large-quantity generators" (1,000 kilograms/month or more) through a comprehensive life cycle or "cradle to grave" tracking requirements. These include maintaining inspection logs of hazardous waste storage locations, records of quantities being generated and stored, and manifests of pick-ups and deliveries to licensed treatment/storage/ disposal facilities. The Resource Conservation and Recovery Act also identifies standards for treatment, storage, and disposal. Both the Resource Conservation and Recovery Act and California Hazardous Waste Control Law require the preparation of hazardous waste reports by hazardous waste generators for submittal to the California Department of Toxic Substances Control which identify the nature and quantity of the hazardous waste being generated, along with the

California Department of Toxic Substances Control, L.A. County Department of Health

Services, County Fire Department, California Division of Occupational Safety and Health




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storage/treatment/disposal techniques being used. This requirement is administered via the filing of biennial reports with the California Department of Toxic Substances Control.

Hazardous Waste Source Reduction and Management Review Act of 1989 (Senate Bill 14) This State legislation requires generators of 12,000 kilograms/year of typical/operational hazardous waste to conduct an evaluation of their waste streams every four years and to select and implement viable source reductions alternatives. This Act does not apply to non-typical hazardous waste (such as asbestos and polychlorinated biphenyls).

California Department of Toxic Substances Control

Uniform Fire Code The Uniform Fire Code regulates hazardous waste storage facilities through regular site inspections. See also the discussion under Hazardous Materials Use, Storage, and Management above.


Asbestos and Lead-Based Paint

Toxic Substances Control Act of 1976 This Federal legislation phased out the use of asbestos and asbestos-containing materials in new building materials, and sets requirements for the use, handling, and disposal of asbestos-containing materials. New disposal standards for lead based paint wastes are being developed under Section 402(a)(1).

U.S. EPA

Federal/State Occupational Safety and Health Act This legislation regulates asbestos and lead-based paint as it relates to employee safety through a set of notification and corrective action requirements, warning signs and labels, controlled access, use of protective equipment, demolition/renovation procedures, housekeeping controls, training, and in certain cases, air monitoring and medical surveillance to reduce potential exposure. This legislation also requires contractors involved in asbestos and lead-based paint surveys and removal to be certified by California Division of Occupational Safety and Health. See also the discussion under Hazardous Materials Use, Storage, and Management, above. Lead exposure during construction activities is regulated by the Federal Occupational Safety and Health Act Lead Standard under 29 CFR 1926.62


California Hazardous Waste Control Law This State legislation lists asbestos as hazardous waste. See also the discussion under Hazardous Waste, above.


South Coast Air Quality Management District Rule 1403 This State legislation regulates asbestos as a toxic material

South Coast Air Quality




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and controls the emission of asbestos from demolition/renovation through requirements for surveying structures for asbestos-containing materials, procedures for the removal, handling, storage and disposal of asbestos-containing materials, and through standard record-keeping.

Management District

Connelly Warnings Act of 1988 This State legislation requires the preparation of an Asbestos Management Plan by owners of pre-1979 buildings known to contain asbestos-containing materials and establishes notification procedures for tenants and employees working in said buildings.


Residential Lead-Based Paint Reduction Act of 1992 (of the Housing and Community Development Act of 1992), Title X This federal legislation protects building occupants from the hazards associated with lead-based paint and contains all the EPA mandates for target housing owner and occupant notification and the regulation of lead-based paint activities occurring in target housing.

U.S. EPA

Safe Drinking Water and Toxics Enforcement Act (Proposition 65) This State legislation prohibits a business from knowingly exposing anyone to levels in excess of the 5 micrograms of lead per day. In addition to providing warning requirements, this prohibits discharge to land or water where lead can pass into a source of drinking water.

L.A. County Department of Health Services

Polychlorinated Biphenyls

Toxic Substances Control Act of 1976 This Federal legislation bans the manufacture of polychlorinated biphenyls and controls the use and disposal of existing polychlorinated biphenyls-containing equipment.

U.S. EPA

California Hazardous Waste Control Law In addition to the Toxic Substances Control Act of 1976, provisions relating to polychlorinated biphenyls are also contained in the California Hazardous Waste Control Law, which lists polychlorinated biphenyls as hazardous waste. See also the discussion under Hazardous Waste, above.


Closed Landfills

Resource Conservation and Recovery Act, Subtitle D This Federal legislation regulates landfill siting, operation, and closure (including identifying liner and capping requirements). Subtitle D is codified in Section 1058 of the State Water Code.

California, Integrated Waste Management Board




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Calderon Act of 1984 (Solid Waste Assessment Test and Solid Waste Air Quality Assessment Test) This State legislation requires the preparation of a Solid Waste Assessment Test and Solid Waste Air Quality Assessment Test for all landfill sites in California to determine whether a site contains hazardous waste leakage or air contaminants.

Los Angeles Regional Water Quality Control Board, L.A. County Department of Public

Works, South Coast Air Quality Management District

California Health and Safety Code Section 25221 et seq. (Hazardous Waste Disposal Land Use Statute) This State legislation requires that a builder who intends to construct residential or buildings of other specified uses, who knows or has reasonable cause to believe that a “significant disposal of hazardous waste” has occurred at or within 2,000 feet of the property, seek a determination from the California Department of Toxic Substances Control as to whether the property is a hazardous waste disposal or border zone property.


California Code of Regulations Section 21190 Pursuant to this State legislation, Solid Waste Local Enforcement Agencies have oversight of disposal site postclosure land use. For sites that ceased operating prior to January 1, 1988, if a significant change in postclosure land use is proposed, a postclosure land use proposal should be submitted to the Solid Waste Local Enforcement Agency to address compliance with this legislation.

Solid Waste Local Enforcement Agency, California Integrated Waste Management

Board, Los Angeles Regional Water Quality Control Board

Los Angeles County Building Code (Uniform Building Code Sections 110.3 and 110.4) This local code requires that permits will not be issued for buildings within 1,000 feet of fills containing decomposable materials unless the fill is isolated by approved natural or artificial protective systems or unless designed according to the recommendations of a licensed civil engineer. The code also prohibits the issuance of permits for buildings within 25 feet of active, abandoned, or idle oil or gas wells unless designed according to the recommendations of a licensed civil engineer and approved by the building official.

L.A. County Department of Public Works

City of Los Angeles Building Code, Division 71 (Methane Seepage District Regulations) The Citywide Methane Ordinance Map (A-20960) shows the Methane and Methane Buffer Zones in the City of Los Angeles and requires certain methane gas sampling and building mitigation systems for properties in those areas. Though portions of the Project Site are within the City, the Project Site is not within a methane or methane buffer zone. Methane requirements at the Project Site are implemented and enforced

L.A. County Department of Public Works




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by the L.A. County Department of Public Works.

Underground Storage Tanks

Resource Conservation and Recovery Act, Subtitle I This Federal legislation authorizes the EPA to issue regulations for new underground storage tank installations as well as strict standards for upgrading existing underground storage tanks, corrosion protection, spill and overflow protection, on-site practices and record-keeping, underground storage tank closure standards, and financial responsibility. The State underground storage tank laws have incorporated the Federal requirements, as discussed below. See also the discussion under Hazardous Waste, above.

U.S. EPA

California Code of Regulations and California Health and Safety Code This State legislation (State underground storage tank program) incorporates the requirements of the Resource Conservation and Recovery Act, Subtitle I, and sets registration and permitting requirements, construction/operational standards, closure requirements, licensing of underground storage tank contractors, financial responsibility requirements, release reporting/corrective action requirements, and enforcement. The State program also requires the installation of leak detection systems and/or monitoring of underground storage tank installations. Since 1998, all tanks have been required to include corrosion protection, leak detection, and spill/overflow devices.

L.A. County Department of Public Works, City Fire Department,

Los Angeles Regional Water Quality Control Board

Aboveground Storage Tanks

Aboveground Petroleum Storage Act This State legislative program was instituted in 1989 to regulate aboveground storage tanks which contain specified petroleum products with a storage capacity of 10,000 gallons or more or are subject to oil pollution prevention and response requirements under the Clean Water Act. The program requires the preparation of a Spill Prevention Control and Countermeasure Plan, the filing of biennial reports with the Regional Water Quality Control Board, and notification of the State Office of Emergency Services for certain spills or releases of 42 gallons or more of petroleum.

Los Angeles Regional Water Quality Control Board

County of Los Angeles Requirements The County Fire Department requires that all liquid hazardous material aboveground storage tanks have secondary containment measures and conform to seismic zone 4 requirements.

County Fire Department




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Resource Conservation and Recovery Act, Subtitle D This Federal legislation regulates landfill siting, operation, and closure (including identifying liner and capping requirements). Subtitle D is codified in Section 1058 of the State Water Code.

California, Integrated Waste Management Board

Calderon Act of 1984 (Solid Waste Assessment Test and Solid Waste Air Quality Assessment Test) This State legislation requires the preparation of a Solid Waste Assessment Test and Solid Waste Air Quality Assessment Test for all landfill sites in California to determine whether a site contains hazardous waste leakage or air contaminants.

Los Angeles Regional Water Quality Control Board,

Los Angeles County Department of Public Works, South Coast Air Quality Management

District

California Health and Safety Code Section 25221 et seq. (Hazardous Waste Disposal Land Use Statute) This State legislation requires that a builder who intends to construct residential or buildings of other specified uses, who knows or has reasonable cause to believe that a “significant disposal of hazardous waste” has occurred at or within 2,000 feet of the property, seek a determination from the California Department of Toxic Substances Control as to whether the property is a hazardous waste disposal or border zone property.


California Code of Regulations Section 21190 Pursuant to this State legislation, Solid Waste Local Enforcement Agencies have oversight of disposal site postclosure land use. For sites that ceased operating prior to January 1, 1988, if a significant change in postclosure land use is proposed, a postclosure land use proposal should be submitted to the Solid Waste Local Enforcement Agency to address compliance with this legislation.

Solid Waste Local Enforcement Agency, California Integrated Waste Management

Board, Los Angeles Regional Water Quality Control

Board

City of Los Angeles Requirements The City of Los Angeles Fire Department requires that all aboveground storage tanks containing more than 60 gallons of combustible materials have a form of secondary containment, and specifies containment provisions.

City Fire Department

Radio Frequency

Federal Communications Commission Requirements The Federal Communications Commission’s radio frequency safety regulations require that all transmitting sites in the United States have met all aspects of the Federal Communications Commission regulations as of September 1, 2000. The regulations set limits for human exposure for the following two groups; Occupational (Controlled) and General Population (Uncontrolled). As it relates to Occupational (Controlled) exposure, the current Federal Communications Commission regulations refer to requirements that

Federal Communications Commission, Federal Occupational Safety and Health

Administration




Page 1988



maintenance personnel be fully aware and exercise control when working in an area with a potential for radio frequency radiation exposure. The Federal Communications Commission exposure limits include Maximum Permissible Exposure (MPE) limits averaged over the body and averaged over time.

Source: Camp Dresser & McKee, Environmental Safety Technical Report, March 2010, and Matrix Environmental, 2010.

Immediately adjacent to the southwestern corner of the Project Site is the Sheraton Premier Hotel, which is listed in the Active Underground Storage Tank, Hazardous Substance Storage Container, Emissions Inventory Data, California Facility Inventory Database Underground Storage Tank, Statewide Environmental Evaluation and Planning System Underground Storage Tank , Facility Index System/Facility Identification Initiative Program Summary, Los Angeles County Hazardous Materials Site lists and Hazardous Waste Information System and Resource Conservation and Recovery Act Small Quantity Generators databases. The Sheraton site has underground storage tanks containing diesel fuel. Also located to the southwest of the Project Site is the Universal City Hilton and Towers. The Hilton site is listed on the Hazardous Waste Information System and Resource Conservation and Recovery Act Small Quantity Generators databases for organic liquid mixtures, latex wastes, and used oils. No violations were listed for these sites.

East of the Sheraton and Hilton sites, Anderson Video Co. and Pacific Photo Express Ltd. are listed on the Facility Index System/Facility Identification Initiative Program Summary and Resource Conservation and Recovery Act Small Quantity Generators databases. Pacific Photo Express Ltd. appears on the Hazardous Waste Information System database as a generator of photochemicals/photoprocessing wastes. No violations were listed for these sites. The Applicant has indicated that Anderson Video Co. is no longer located at this location.

Texaco, Inc., located at 100 Universal City Plaza was listed on the underground storage tank database. The Texaco Office Building, at 10 Universal City Plaza, is listed on the Leaking Underground Storage Tanks, Underground Storage Tank, CORTESE Hazardous Waste and Substances Status List, and Resource Conservation and Recovery Act Small Quantity Generators databases. Texaco’s site experienced groundwater contamination due to released hydrocarbons; the case has been closed since July 17,



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1996. Texaco is no longer at this location but the current owner of the property maintains an underground storage tank for an emergency generator at the site.

Under World Production, located at 100 Universal City Plaza, was identified by the Hazardous Waste Information System database for generating 0.3 tons of household waste.

Within 1/8 of a mile of the Project Site is the San Fernando Valley (Area 2) Crystal Springs Wellfield Area that is listed on the National Priorities List, Comprehensive Environmental Response, Compensation, and Liability Information System, Facility Index System/Facility Identification Initiative Program Summary, State Response Sites, Hist Cal-Sites, EnviroStor Database, Record of Decision, and Engineering Controls Sites List databases. This area has contaminated groundwater trichloroethylene and tetrachloroethylene) discovered in 1984.

c. Existing On-Site Conditions

Certain on-site activities, such as movie production, Universal Studios Hollywood, restaurant cleaning, grounds maintenance, and support facilities operation (power generation, air conditioning, etc.) involve the acquisition, use, storage and disposal of hazardous materials, while others emit air emissions that include hazardous constituents. Construction activities on-site may use hazardous materials. No notable source of radioactive materials is used or stored at the Project Site. Incidental radioactive materials at the Project Site include minor amounts associated with lithium-source exit lights and with an on-site X-ray machine.

The records search completed in July 2007 indicates that the site is listed on the aboveground storage tank database for 24,845 total gallons of aboveground storage tanks and on the Emergency Response Notification System database which records and stores information on reported releases of oil and hazardous materials, but the listing provided no further details. As discussed below, the site is also listed on the California Facility Inventory Database Underground Storage Tank and Statewide Environmental Evaluation and Planning System Underground Storage Tank databases for containing underground storage tanks and is listed under the Leaking Underground Storage Tanks database for a tank leak in 1987 (addressed by remedial action) and a gasoline release that is currently listed as undergoing “pollution characterization.” The Project Site is also listed on the California Hazardous Materials Incident Report System database for a broken water line in 2002. Additionally, the site is listed on the CORTESE Hazardous Waste and Substances Status List and Hazardous Waste Information System databases for latex wastes and organic solids. The Project Site is also listed as a solid waste disposal site on the Solid Waste Facilities/Landfill Facilities database; however, the current operator’s status for the



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site is “closed.” Also related to the closed landfill, the Project Site is also listed on the Solid Waste Assessment Test and Emissions Inventory Data databases. The Applicant is listed as a Resource Conservation and Recovery Act Large Quantity Generator, producing halogenated wastes, inorganic solid wastes, and organic liquid wastes. There are currently no violations noted.

Additionally, a tenant (Technicolor), which operates a film production and processing facility located at the northern corner of the Business Area (4050 Lankershim Boulevard), is listed as a Resource Conservation and Recovery Act Large Quantity Generator (i.e., the facility generates over 1,000 kilograms of hazardous waste). There are currently no violations noted. This tenant also appears in the CORTESE Hazardous Waste and Substances Status List and Leaking Underground Storage Tanks databases. The Leaking Underground Storage Tanks database indicates a current notice of violation and order to comply and is actively undergoing cleanup for groundwater contamination from a solvent release.

(1) Emergency Procedures

As part of the Applicant's Business Emergency Plan/Hazardous Materials Business Plan under the Waters Bill, the Applicant is required to identify a team of employees that are trained per regulatory requirements in hazardous materials response. Per the Applicant's Business Emergency Plan/ Hazardous Materials Business Plan, an Emergency Response Team has been established on the Project Site to respond to accidental hazardous materials spills. Outside contractors have been identified and are on call in the event of an emergency to augment the on-site response capability.

In the event of a release, the Applicant's Emergency Response Team would be responsible for the initial response. If the Applicant determines that on-site resources are insufficient to handle the response, the Certified Unified Program Agency (i.e., County Fire Department) and the State Office of Emergency Services would be notified.

In addition to responding to a release, the Applicant must comply with a complex set of reporting requirements, which in some instances require notification of the local Certified Unified Program Agency (i.e., County Fire Department and/or City Fire Department) and the State Office of Emergency Services.542 Once the County Fire Department and/or City

542 Notification to the State Office of Emergency Services is required immediately upon discovery of any spill or release of 42 gallons or more of petroleum (Health and Safety Code sec. 25270.8). In addition, if the Applicant determines that on-site resources are insufficient to handle the response, the State Office of Emergency Services as well as the Certified Unified Program Agency (i.e., County Fire Department), would be notified.



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Fire Department are notified, these agencies may respond to the incident, even if the Applicant has indicated that on-site resources are sufficient to handle the cleanup. The County Fire Department (also known as the Certified Unified Program Agency) could draw resources from their fire response personnel or members of the County Fire Department Hazardous Materials Unit, as well as the City Fire Department. Based on the type and magnitude of the emergency, the Applicant would notify the National Response Center, if warranted.

(a) Phase I, Preliminary Phase II, and Supplemental Phase II Environmental Site Assessment

In 2005, MWH Americas, Inc. performed a Phase I Environmental Site Assessment on an approximately 186-acre area in and around the Mixed-Use Residential portion of the Project Site.543 The findings of the Phase I Environmental Site Assessment identified the following potential environmental issues: asbestos, cesspools/septic tanks, closed landfill, compressors, electrical transformers, generators, hydraulic equipment, lead-based paint, paint shops, a buried debris area, and underground storage tanks.

To further evaluate the presence or absence of subsurface impacts associated with these potential issues, MWH Americas, Inc. performed a focused Preliminary Phase II Environmental Site Assessment on approximately 143 acres of the 186 acres studied in the Phase I Environmental Site Assessment.544 The Preliminary Phase II Environmental Site Assessment included collection and chemical analysis of surface and subsurface soil samples; completion of two exploratory test pit excavations in area of suspected buried debris along the hill slope between Denver Street and the northern house facades on Elm Street; construction and survey of 13 groundwater monitoring wells; and the collection and chemical analysis of groundwater. The results of the Preliminary Phase II Environmental Site Assessment indicated the absence of significant groundwater impacts and concluded that concentrations of soil contaminants were detected at concentrations below regulatory screening levels with the exception of arsenic and lead which both exceeded both

543 A Phase I was performed for this portion of the site in anticipation of future development (including a potential change to residential use).

544 The study area of the Preliminary Phase II Site Assessment was determined based on the potential environmental concerns identified during the Phase I Site Assessment and the proposed uses in those areas of the Project Site. The study area of the Preliminary Phase II Environmental Site Assessment did not include the northwestern portion of the Phase I Environmental Site Assessment study area (area west of Park and Jaws Lakes). Of the potential environmental issues identified in the Phase I Environmental Site Assessment, the closed landfill was not addressed in the Preliminary Phase II Site Assessment. The closed landfill is the subject of on-going periodic monitoring pursuant to applicable regulatory requirements.



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residential and industrial Preliminary Remediation Goals established by the EPA. In Southern California, naturally occurring levels of arsenic are commonly above the Preliminary Remediation Goals and the California Human Health Screening Levels.

To further investigate areas of interest identified in MWH Americas, Inc.’s Preliminary Phase II Environmental Site Assessment, URS conducted a Supplemental Phase II Environmental Site Assessment for the Universal Studios Back Lot Study Area. The Supplemental Phase II Environmental Site Assessment included the collection and analysis of soil samples, installation of groundwater monitoring wells, and groundwater sample collection and analysis from existing and new groundwater monitoring wells. The results of the Supplemental Phase II (in conjunction with the Preliminary Phase II Environmental Site Assessment results) indicated the absence of significant groundwater impacts and detected polychlorinated biphenyls, total petroleum hydrocarbons, and metals (arsenic, cadmium, lead, and vanadium) in soil at concentrations above regulatory screening levels ( Preliminary Remediation Goals or California Human Health Screening Levels).

The conclusions presented in the Phase I Environmental Site Assessment, Preliminary Phase II Environmental Site Assessment and Supplemental Phase II Environmental Site Assessment conducted at the site did not identify significant environmental issues, with the possible exception of certain soil samples having concentrations of metals and polychlorinated biphenyls in excess of residential California Human Health Screening Levels and/or residential Preliminary Remediation Goals. These results are being evaluated by the California Department of Toxic Substances Control, pursuant to the California Department of Toxic Substances Control’s Voluntary Cleanup Program, to further assess whether the presence of those materials pose a significant risk to human health or the environment, including as related to existing and potential future uses nearby. Should it be determined that the nature, location, and concentrations of those materials pose an unacceptable risk, various options to reduce the risk to an acceptable level will be identified under California Department of Toxic Substances Control oversight. Potential remedial options may include removal (excavation), treatment (in-situ or ex-situ), or other measures as appropriate.

(2) Hazardous Materials Use, Storage, and Management

Hazardous materials in solid, liquid, and gaseous forms are currently stored and used on the Project Site. Generally, hazardous materials use and storage are concentrated at facilities within the Studio and Entertainment Areas, with lesser use and storage associated with activities occurring within the Business Area. No notable source of radioactive materials is used or stored at the Project Site. Incidental radioactive materials



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at the Project Site include minor amounts associated with lithium-source exit lights and with an on-site X-ray machine.

Within the Studio Area there are: (1) hazardous materials stored and used at workshops including petroleum-based oils, greases and fuels, adhesives, glues, compressed gases, paints, solvents, acids, finish strippers, small quantities of acids, refrigerants, lead acid batteries, and cleaning products; (2) hazardous materials stored and used at vehicle maintenance facilities including fuels and oils in underground storage tanks, compressed gases, batteries, and small quantities of lubricants, coolants, solvents, cleaning materials and paints; (3) hazardous materials used and stored at attractions associated with Universal Studios Hollywood used in the operation, maintenance and cleaning of equipment and facilities; and (4) small amounts of commercial herbicides and pesticides stored for landscape support. Additionally, commercial applications of pest control materials occur periodically on-site by third-party pest control companies that are licensed by the State of California Department of Health Services. These third-party pest control companies store their landscaping supplies off-site.

Vehicle maintenance facilities are the primary areas in the Entertainment Area where hazardous materials are used and stored. These facilities are responsible for all maintenance and fueling of the tram and entertainment service vehicles used on-site. These facilities typically store and use fuels, oils, coolants, grease, solvents, aerosol sprays, paints, coatings, cleaning products and solutions, compressed gases, small amounts of acid and lead/acid batteries.

Operations located in the Business Area of the Project Site do not typically use or store hazardous materials in the quantities or varieties as the facilities described above. Typical hazardous material inventories of the buildings in this Area may include fuel for boilers/generators, lubricating oils, and cleaning products. Most materials are typically stored in containers of 55 gallons or less. Some tenants in the Business Area use and store corrosives, irritants, oxidizers and solvents for production processes. These materials are currently stored in aboveground containers and within appropriate enclosures (e.g., flammable liquid storage cabinets), which are clearly marked. One on-site tenant (Technicolor), located in the northern portion of the Business Area, operates a film production and processing facility. In accordance with all applicable regulatory requirements (i.e., Title III of the Federal Superfund Amendments and Reauthorization Act, Waters Bill, and Unified Program), Technicolor’s operations include full laboratory services such as motion picture film processing and film preservation and restoration. These services involve the use of a variety of chemicals and additives. For example, film processing consists of immersing the film in a series of chemical baths and washes, including the application of developer, which turns the latent image to metallic silver, a stop bath to stop the action of the developer, and fixer to make the image permanent. The precise procedure and mix of chemicals and additives used vary for different types of



Page 1994


processing. Hazardous materials associated with this tenant’s operations include: acids and acidic solutions, mixed solvents, paint solvents, halogenated solvents, oils, clarifier sludge, specialty chemicals (i.e. color developing agents), lead and dry cell batteries, small quantities of cleaning materials, aerosol spray paints, paints, lubricants, coolants and solvent. Refer to Figure 222 on page 1995 for locations of major hazardous material storage areas.

In June 2008, a fire on the Project Site destroyed several buildings and set areas, including the New York Street set area, the King Kong building, and a video vault. As a result, the King Kong building is no longer utilized for the storage of hazardous materials. The South Coast Air Quality Management District collected and analyzed air quality samples the day of the fire and the day after. Air samples collected within the fire zone and 200 yards downwind of the fire indicated hydrocarbon air contaminants and toxic air contaminants were below the short-term exposure thresholds set by health agencies for serious health effects. Air samples collected upwind and downwind from the surrounding area also indicated acceptable levels of air contaminants.545

Site operations are in accordance with all applicable regulatory requirements. Other hazardous materials frequently used in on-site areas such as the workshops and vehicle maintenance facilities are stored in appropriate enclosures (flammable liquid storage cabinets, where appropriate) which are clearly marked. Gas storage cylinders are stored with valve covers in place and restrained from movement. Stationary propane storage vessels are clearly labeled and protected by bollards.

Management includes the inventorying of hazardous materials storage, risk planning, employee training, and emergency response preparedness should a hazardous materials accident occur. Hazardous materials management is regulated through a wide array of Federal and State legislation. The Applicant is currently in compliance with the applicable legislative programs as discussed below.

545 South Coast Air Quality Management District. Laboratory Results of Samples Collected at Universal Studios Fire on June 1, 2008, available at: http://www.aqmd.gov/tao/AQ-Reports/Fires/ UniversalStudiosFire.htm, accessed November 13, 2009. Additional information can also be found in the South Coast Air Quality Management District article Normal Levels of Air Pollutants Measured in Neighborhoods, available at: http://www.aqmd.gov/news1/2008/UniversalStudiosFire.html, accessed November 13, 2009.

Figure 222Location of Notable Hazardous Materials Storage

Legend

Source: CDM and Rios Clementi Hale Studio, September 2010.

Property Boundary

TECHNICOLORBUILDING

4407 BUILDING4250

BUILDING5187

EARTHQUAKE

TRAMMAINTENANCEGARAGE BLDG.

5437

BUILDING6511

JURASSIC PARKPARKING STRUCTURE

Page 1995



Page 1996


(a) Federal Occupational Safety and Health Act and California Occupational Safety and Health Act

In compliance with Federal and State Occupational Safety and Health Act requirements, the Applicant: (1) has obtained from the manufacturers material safety data sheets which identify the types and handling requirements of hazardous materials used in given areas; (2) has conducted appropriate employee hazardous materials handling training and medical surveillance; (3) has trained a team of employees to appropriate Occupational Safety and Health Act-defined levels to remediate any hazardous materials accidental release; (4) has retained on-call contractors to provide additional remedial response, if necessary; and (5) has in place a written hazard communication program, known as the Chemical Management Plan, which provides employees with appropriate information regarding the safe handling, use, storage and disposal of hazardous materials.

(b) Waters Bill

Hazardous materials are stored and used on-site in excess of the reporting threshold for the Waters Bill. Therefore, a detailed hazardous materials inventory was prepared for the Project Site as part of the Hazardous Materials Business Plan in accordance with the requirements of the Waters Bill the Hazardous Materials Business Plan is on file with the County Fire Department and City Fire Department.

The Hazardous Materials Business Plan documents the established procedures (a Contingency Plan) to address threatened or actual releases of hazardous materials or hazardous waste, and includes a regular program of employee training for hazardous materials handling and potential releases, and an inventory of hazardous materials used on the Project Site.

In addition to the Contingency Plan described above, an Emergency Response Plan has been developed for the site that details potential emergencies (other than hazardous releases) and identifies appropriate emergency response procedures in the event of such emergency, including contacts with appropriate emergency response agencies.

The on-site tenant (Technicolor), located in the northern portion of the Business Area, also currently handles hazardous materials in excess of Waters Bill reporting requirements, and thus has also prepared a Hazardous Materials Business Plan. This tenant's Hazardous Materials Business Plan documents procedures addressing on-site threatened or actual releases of hazardous materials or hazardous waste; identifies the staff responsible for notifying the City Fire Department in the event of an accidental release; identifies the staff responsible for release response; describes alarm systems and evacuation procedures; identifies emergency medical facilities; describes preventative



Page 1997


measures, such as cabinet storage, safety equipment, and training; and describes release response and abatement procedures. This tenant also has a Consolidated Contingency Plan that addresses in detail both emergency and non-emergency incidents and outlines the procedures for appropriately responding to an emergency. Should a hazardous waste incident occur on-site, on-site personnel would respond pursuant to the Contingency Plan and Emergency Response Plan, and depending on the type and location of the spill, the City or County Fire departments may respond.

(c) La Follette Legislation

Under the La Follette Bill, facilities that store or utilize certain types and quantities of hazardous materials may be required to develop Risk Management Plans. Quantity thresholds as defined by La Follette are different for differing hazardous constituents. The types and/or quantities of regulated hazardous materials utilized on-site by either the Applicant, tenants, or third-party vendors are below the regulatory thresholds; therefore, the development of a Risk Management Plan is not currently, nor anticipated to be, required. In addition, any business handling hazardous materials (as defined in Section 25500 of California Health and Safety Code, Division 20, Chapter 6.95) is required to obtain a local fire department permit and register the business as a hazardous materials handler. The Applicant, as well as various tenants and third-party vendors do not currently utilize the types and/or quantities of any regulated hazardous materials that would require registration with the local administering agency, the County Fire Department and/or City Fire Department.

(d) Uniform Fire Code

Applicable hazardous materials used by the Applicant on-site are stored in accordance with regulatory requirements of the Uniform Fire Code. The Applicant has no outstanding notices of violation issued by the County Fire Department or City Fire Department associated with Applicant operations. However, there is currently an outstanding notice of violation (issued July 23, 1998) regarding underground storage tanks associated with a tenant’s (Technicolor’s) film production processes in the northern portion of the Business Area. These tanks were removed in the mid-1990s and the tanks were closed with regulatory oversight by the City Fire Department. Active soil remediation (soil vapor extraction) ceased in 2004, however, groundwater monitoring continues under Los Angeles Regional Water Quality Control Board oversight.



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(e) Safe Drinking Water and Toxics Enforcement Act (22 California Code Regulations § 12000 et seq.), commonly known as Proposition (Prop.) 65

On-site operations currently utilize hazardous chemicals included in the Prop. 65 list and thus could potentially expose individuals to such chemicals. Therefore, these operations are subject to the requirements of this Act. The Applicant complies with this Act by reporting all accidental releases of listed hazardous materials in accordance with applicable provisions. Moreover, the Applicant posts notices, as required, providing clear and reasonable warning to the public and to employees in areas where hazardous materials are stored and used. In addition, as part of the Applicant’s public notice program, posting includes placement of notices at all entrances.

(f) City and County of Los Angeles General Plan Safety Elements

Goals and objectives applicable to the proposed Project address minimizing the potential for injury, loss of life, property damage and disruption of the social and economic life due to the release of hazardous materials. Safety Element policies and programs would be implemented at the Project Site through Project compliance with statutory requirements and standards. As discussed in Section IV-A.1, Land Use, the Project is generally consistent with the goals and polices identified in the General Plan Safety Elements of both the City and County of Los Angeles. Refer to Section IV-A.1, Land Use for additional discussion of Project consistency with existing plans.

(3) Hazardous Waste

See the asbestos and lead-based paint, and polychlorinated piphenyl sections below for additional discussion of asbestos, lead-based paint, and polychlorinated biphenyl waste.

The Project Site generates Resource Conservation and Recovery Act, non- Resource Conservation and Recovery Act and universal wastes.546 The Applicant does not store hazardous wastes for more than 90 days but accumulates hazardous waste in Building 4250 prior to ultimate disposal by licensed contractors. With the exception of used oil, parts cleaning solution, and automotive batteries, which are picked up directly from the garages, all of the Applicant’s hazardous waste is shipped from the 90 days accumulation area at Building 4250. The types of waste accumulated in Building 4250 include, but are not limited to, asbestos, non-leaking polychlorinated biphenyls, universal waste, non-

546 “Universal” waste is waste that everyone produces. Universal waste includes batteries, fluorescent tubes, electronic devices and small electronic appliances that if not disposed of properly could harm the environment.



Page 1999


Resource Conservation and Recovery Act solid waste, non- Resource Conservation and Recovery Act liquid waste, Resource Conservation and Recovery Act liquid waste, waste paint-related materials, corrosives, isocyanates, and pyrotechnic and blank munitions.547 Typical operational hazardous wastes currently generated by the Applicant are hauled off-site by licensed contractors and sent to licensed waste treatment, disposal or recycling facilities that are permitted to receive the applicable waste (none of these facilities are located in the City or County). As most of the hazardous wastes generated by the Applicant are transported to resource recovery facilities where the energy content of the waste is recovered for beneficial use, landfill storage capacities are not a limiting factor.

In 2006, the Applicant generated a total of approximately 132,417 kilograms (approximately 291,317 pounds) of typical (i.e., non-asbestos and polychlorinated biphenyls) hazardous waste from eight different waste streams. In addition to the operational waste discussed above, with asbestos and polychlorinated biphenyl waste, the Applicant’s total waste generation in 2006 was approximately 133,959 kilograms (approximately 294,709 pounds).

The on-site tenant (Technicolor) located in the northern portion of the Business Area separately generates, accumulates, and manages hazardous waste. In 2006, this tenant generated a total of approximately 9,596 pounds and 347 gallons of hazardous waste from four different types of waste. Similar to the Applicant, this tenant also implements the hazardous waste management life cycle requirements, disposes all hazardous waste from a 90-day hazardous waste accumulation area located on a portion of Technicolor’s facility that fronts the Los Angeles River Flood Control Channel, and submits biennial hazardous waste reports to the California Department of Toxic Substances Control if any of the criteria under the California Hazardous Waste Control Law are met.

The Applicant is currently in compliance with applicable Federal and State legislative programs as discussed below.

547 Currently, the approved disposal methods used by the Applicant’s licensed contractors includes recycling (for universal waste, non- Resource Conservation and Recovery Act liquids, and waste paint-related materials), landfilling (for non- Resource Conservation and Recovery Act solids and asbestos), treatment (for Resource Conservation and Recovery Act liquids and corrosives), and incineration (for isocyanates, pyrotechnic, blank munitions and PCBs).



Page 2000


(a) Federal Occupational Safety and Health Act and California Occupational Safety and Health Act

The Applicant currently complies with the Federal Occupational Safety and Health Act and California Occupational Safety and Health Act hazardous waste staff training and transport requirements, including requiring Occupational Safety and Health Act certified training of all staff involved with the transporting of hazardous waste from generation locations within the Project Site to the central accumulation location within the Studio Area (i.e., Building 4250) for centralized storage.

(b) Resource Conservation and Recovery Act and California Hazardous Waste Control Law

Several users associated with the Project Site generate Resource Conservation and Recovery Act hazardous waste. With the exception of the waste generated by one on-site tenant (Technicolor) located in the northern portion of the Business Area, the Applicant performs hazardous waste management for the Project Site. The Applicant and this one on-site tenant are each classified as "large-quantity generators" (i.e., Resource Conservation and Recovery Act Large Quantity Generator sites) under the Resource Conservation and Recovery Act. Each is subject to the life cycle hazardous waste management requirements of the Resource Conservation and Recovery Act and complies with these requirements, including inspections of storage locations, and maintenance of the required manifests, inspection logs, and records. These records are subject to review by the Los Angeles County Department of Health Services and County Fire Department at any time, with financial penalties for non-compliance.

In addition to the typical operational Resource Conservation and Recovery Act waste, per the Resource Conservation and Recovery Act and the California Hazardous Waste Control Law, the Applicant currently disposes of asbestos-containing materials and replaced lighting ballasts not labeled as " polychlorinated biphenyl free" as hazardous waste. Biennial hazardous waste reports have been submitted to the California Department of Toxic Substances Control as required.

(c) Hazardous Waste Source Reduction and Management Review Act of 1989 (Senate Bill 14)

The Applicant has complied with the requirements of the Hazardous Waste Source Reduction and Management Review Act of 1989 (Senate Bill 14) and has implemented a number of hazardous waste reduction measures that have reduced typical/operational hazardous waste generated on-site. The Applicant has a Hazardous Waste Minimization Plan that outlines hazardous waste reduction measures for typical/operational hazardous waste.



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(4) Asbestos and Lead-Based Paint

Asbestos, asbestos-containing materials, and lead-based paint have occasionally been encountered on the Project Site during the demolition and renovation of existing buildings, and during the replacement of certain production lighting (as asbestos-containing materials are present in the insulation of some production light bulb wiring). The Toxic Substances Control Act of 1976 phased out the use of asbestos, asbestos-containing materials, and lead-based paint in new construction materials. Asbestos and lead-based paint, however, may be found on the Project Site in pre-1979 and pre-1978 construction (respectively), particularly within the Studio Area, as well as in certain production lights (the replacement of which occurs on an on-going basis). In 2006, the Applicant generated and disposed of approximately 1,442 kilograms (approximately 3,172 pounds) of asbestos and asbestos-containing materials, which was disposed of in approved Class III landfills (i.e., a facility that accepts non-hazardous solid waste, such as a municipal solid waste landfill). Although all lead-based paint debris is assumed hazardous until properly tested, to date, sample results have shown that lead-based paint debris at the Project Site has been at non-hazardous levels.548 Non-hazardous material containing lead-based paint is managed as construction debris. To date, the Applicant has surveyed all buildings and structures on the Project Site for asbestos and lead-based paint.549

Asbestos, asbestos-containing materials, and lead-based paint are regulated through a wide array of federal and state legislation. The Applicant currently complies with the applicable legislative programs as discussed below.

In addition, the Applicant has developed an Asbestos Management Plan to provide employees and contractors with the techniques and systems necessary to minimize the potential for release of asbestos-containing materials, as well as outline the actions to be taken in the event of accidental disturbance to asbestos-containing materials.550 The

548 The Applicant maintains a Lead-Based Paint Management Plan that details lead-based paint assessment procedures. Samples of lead-based paint at the site were collected by certified inspectors/assessors and analyzed in accordance with EPA and Department of Health Services protocols.

549 Since about 1999, as necessary (particularly prior to renovation or demolition of pre-1979 structures or if suspect materials are found), the Applicant has been requiring asbestos surveys at the Project Site. All the asbestos surveys for the Project Site were performed by certified asbestos consultants and all analytical services were by an accredited laboratory. The asbestos surveys were prepared in accordance with EPA’s NESHAP, 40 Code of Federal Regulations 61, Part M, and local requirements as set forth by the South Coast Air Quality Management District (Rule 1403). In 2007, a lead-based paint survey was performed by a DHS certified consultant in accordance with EPA and Department of Health Services protocols.

550 NBC/Universal, Environmental, Health & Safety, “Asbestos Management Plan”, September 2006.



Page 2002


Asbestos Management Plan, which was prepared by an asbestos consultant certified by the California Division of Occupational Safety and Health, provides specific guidelines, work practices, procedures, and protocols for employees and contractors to follow during construction projects and operation and maintenance activities conducted in proximity to asbestos-containing materials. In addition, the AMP contains procedures to deal with asbestos-related emergencies.

The Applicant also maintains a Lead-Based Paint Management Plan that details responsibilities, lead-based paint assessment procedures, work practices, training and record keeping associated with the handling of lead-based paint debris at the Project Site. In addition, per the Respiratory Protection in Construction Standard, the Applicant has a specific respiratory protection program whenever employees are required or choose to wear respirators.

To date, the Applicant has surveyed all buildings and structures on the Project Site for asbestos/ asbestos-containing materials and lead-based paint.

(a) Federal Toxic Substances Control Act

In accordance with the Toxic Substances Control Act, only non-asbestos and non-lead-based paint containing construction materials are used in new construction, and in the renovation of existing uses, on the Project Site.

(b) Federal Occupational Safety and Health Act and California Occupational Safety and Health Act

The Applicant has prepared an Illness Prevention Program for its facilities in compliance with the Federal Occupational Safety and Health Act and the California Occupational Safety and Health Act requirements. The Applicant's Injury and Illness Prevention Program is designed to implement the requirements of the Federal Occupational Safety and Health Act, California Occupational Safety and Health Act, South Coast Air Quality Management District Rule 1403 and the Connelly Warnings Act. The Applicant maintains a Lead-Based Paint Management Plan that details responsibilities, lead-based paint assessment procedures, work practices, training and record keeping associated with the handling of lead-based paint debris at the Project Site. In addition, per the Respiratory Protection in Construction Standard, the Applicant has a specific respiratory protection program whenever employees are required or choose to wear respirators.



Page 2003


(c) South Coast Air Quality Management District Rule 1403

The Applicant complies with this legislation, which controls the emissions of asbestos from demolition and renovation activities by specifying agency notifications, appropriate removal procedures, and handling and clean up procedures, through its existing Injury and Illness Prevention Program. The Applicant has surveyed all existing structures on-site, and conforms to applicable permitting requirements for the removal of asbestos-containing materials from these structures.

(d) Connelly Warnings Act (California Health and Safety Code § 25915 et seq.)

The Applicant complies with this legislation, which requires notification to employees and tenants who work in pre-1979 buildings know to contain asbestos-containing materials, through its existing Injury and Illness Prevention Program.

(e) Residential Lead-Based Paint Reduction Act of 1992, Title X

The Applicant complies with this legislation, which protects building occupants from the hazards associated with lead-based paint, through its existing Lead-Based Paint Management Plan.

(f) Safe Drinking Water and Toxics Enforcement Act (Proposition 65)

The Applicant, through its existing Lead-Based Paint Management Plan, complies with this legislation, which provides warning requirements and prohibits discharge to land or water where lead can pass into a source of drinking water.

(5) Polychlorinated Biphenyls

Polychlorinated biphenyls were used until 1979 as insulating fluids in electrical equipment, transformers, lighting ballasts and heavy switching gear. Most electrical transformers and oil filled switches on-site were retrofitted as part of a project which took place in 1985 to reduce polychlorinated biphenyls. Older transformers and switches containing polychlorinated biphenyls may still be encountered on the property. All lighting ballasts which are not clearly labeled as non-‐polychlorinated biphenyl are treated as polychlorinated biphenyls-containing and are handled, stored and disposed of in accordance with applicable regulations. Lighting ballasts are only replaced as needed. In



Page 2004


2006, the Applicant handled and disposed of (through the use of licensed contractors) approximately 100 kilograms (approximately 220 pounds) of polychlorinated biphenyl ballasts, which were disposed of using incineration.551 Polychlorinated biphenyl-containing materials are assumed present on the Project Site and are generally associated with studio operations within the Studio Area. In accordance with Toxic Substances Control Act of 1976, the Applicant currently uses only non-polychlorinated biphenyl containing electrical equipment in all new and replacement construction.

Polychlorinated biphenyls are regulated through federal and state legislation. The Applicant currently complies with the applicable legislative program as discussed below.

(a) Federal Toxic Substances Control Act

The Applicant currently uses only non-polychlorinated biphenyl containing electrical equipment in all new and replacement construction. Lighting ballasts not labeled as "polychlorinated biphenyl free" are treated as hazardous waste and handled, stored, and disposed of according to applicable regulations.

(6) Closed Landfill

A closed landfill, listed as a Solid Waste Landfill site, is located in the central portion of the site. The landfill is also listed as "closed" in the Solid Waste Information System database, which includes all active, closed, and inactive landfills. The landfill was licensed by the Los Angeles County Department of Health Services as a solid waste disposal facility. Filling began in the late 1920s and ceased around 1980. Based on anecdotal evidence, the landfill was initially used for depositing studio waste only, which was composed primarily of inert or slow-to-decompose material such as construction debris, quantities of prop discards made of mainly wood and plastic, and paper wastes. In later years, restaurant waste from the theme park was also reportedly deposited. No hazardous or potentially hazardous materials are known to have been disposed of at the former landfill site. Landfill activities ended around 1980. A final soil cap cover consisting of about two to six feet of clean silty and clayey sand fill (earth fill) has been placed over the landfill area. Since the closure of the landfill, roads, asphalt pavement, and buildings have been developed over approximately 50 percent of the landfill surface area. Natural vegetation covers the remaining undeveloped slope surface of the landfill site (northern portion). The

551 Presently, the only approved method of disposing polychlorinated biphenyls is incineration. The Applicant’s licensed haulers are currently disposing of polychlorinated biphenyl from the site under an agreement with a Toxic Substances Control Act-permitted facility in Port Arthur, Texas.



Page 2005


Collapsing Bridge Pond, which is a cement-lined water feature, lies directly adjacent to the northern edge of the landfill area. The landfill is currently in compliance with applicable regulations and programs, as discussed below.

(a) Resource Conservation and Recovery Act)

Subtitle D of the Resource Conservation and Recovery Act regulates landfill closures. The State of California administers Subtitle D requirements as contained in the California Code of Regulations and State Water Code. The closed on-site landfill ceased operations prior to current regulations; therefore, there is no formal closure or post-closure plan for the landfill.

(b) Calderon Act of 1984 (§ 13273 of the California Water Code)

The Calderon Act requires that a Solid Waste Assessment Test and Solid Waste Air Quality Assessment Test be prepared for all landfill sites in California to determine whether a site contains hazardous waste leakage or air contaminants. A Solid Waste Assessment Test Report was prepared for the closed landfill. The Solid Waste Assessment Test states that the lower levels of the landfill contain primarily inert material, with newer more readily decomposable materials found in the upper portions of the fill near its southerly boundary. Based on the background information, waste disposal history, and the analysis of surface and groundwater on, under, and within the area investigated, the Solid Waste Assessment Test concluded that no hazardous or potentially hazardous materials have been disposed of at the landfill.552 The Solid Waste Assessment Test indicated that monitoring results did not show any indication of leakage of hazardous material and that unsaturated zone and leachate monitoring indicated no leakage of hazardous materials.

Also per the requirements of the Calderon Act, a Solid Waste Air Quality Assessment Test Report was prepared.553 The Solid Waste Air Quality Assessment Test field testing revealed that: (1) monitored methane levels are below regulatory action levels; (2) some specified air contaminants (i.e., 1,1,1-trichloroethane, tetrachloroethylene and methylene chloride) were slightly above ambient levels, but below the Federal Occupational Safety and Health Act short-term exposure limit levels; and (3) no detectable increases in the remaining specified air contaminants were identified. Recent monitoring showed no detection of 1,1,1-trichloroethane, tetrachloroethylene, and methylene chloride.

552 Lockman & Associates, Solid Waste Assessment Test (SWAT) Final Report, June 29, 1988. 553 Lockman & Associates, Solid Waste Air Quality Assessment Test (SWAQAT) Final Report, September 1989.



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Based on numerous methane gas generation studies that have been conducted on municipal solid waste facilities, and based on site conditions, landfill age and the type of waste in the landfill, it is presumed that methane production from the on-site landfill is probably in decline.

(c) California Health and Safety Code Section 25221 et seq. (Hazardous Waste Disposal Land Use Statute)

Based on existing information pertaining to the closed on-site landfill, there is no evidence that a significant disposal of hazardous waste resulting in a significant existing or potential hazard to present or future public health or safety has occurred at the Project Site. The Solid Waste Assessment Test report and monitoring carried out at the landfill, and submitted to the Los Angeles Regional Water Quality Control Board, indicated no hazardous materials were disposed of at the landfill.

(d) California Code of Regulations

The closed on-site landfill ceased operations prior to current regulations; therefore, there is no formal closure or postclosure plan for the landfill. However, the County Department of Public Works is the Solid Waste Local Enforcement Agency for the California Integrated Waste Management Board regulations addressing postclosure land use activities and maintains periodic Closed Disposal Site Inspection Reports related to the landfill. On-site construction within 1,000 feet of the boundary of the disposal area is required to be designed to prevent gas migration into the building (27 California Code Regulations Section 21190(g)).

(e) Los Angeles County Building Code (Uniform Building Code Sections 110.3 and 110.4)

The Applicant complies with this section which applies to structures located within 1,000 feet of the landfill, through monitoring of all soil gas monitoring probes for explosive gas during the first and third quarters and monitoring of soil gas monitoring probes within a limited special studies area for explosive gas during the second and fourth quarters. Quarterly reports have been submitted in accordance with the County Department of Public Works requirements for monitoring and reporting of the methane collection and detection at the Project Site. According to the fourth quarter 2006 monitoring results, all buildings monitored are free from hazardous concentrations of landfill gas and can be safely occupied.

The design and construction of development occurring within 1,000 feet of the closed on-site landfill would be required to comply with Section 110.3 of the Los Angeles



Page 2007


County Building Code, which permits buildings or structures located within 1,000 feet of landfills containing rubbish or other decomposable material if the fill is isolated by approved natural or artificial protective systems or if the buildings or structures are designed according to recommendations contained in a report prepared by a licensed civil engineer. As required by the Los Angeles County Code permit process, proposed development within a 1,000 foot radius of a closed landfill would be designed and constructed according to the recommendations of a licensed civil engineer, and any methane mitigation recommendations would be subject to the review and approval of the County Department of Public Works. The County Department of Public Works has established landfill gas protection requirements, which includes details on site investigations, landfill gas protection systems, gas monitoring systems and programs, as well as contingency plan requirements.554 The County of Los Angeles may accept alternate engineering controls and monitoring parameters on a case-by-case basis.

See Sections IV.G.2, Water Resources – Groundwater and IV.F, Geotechnical, for additional discussion of the closed landfill.

(f) City of Los Angeles Building Code, Division 71 (Methane Seepage District Regulations)

Review of the Citywide Methane Ordinance Map (A-20960) indicates that the Project Site is approximately 4,000 feet at its closest point to any Methane or Methane Buffer Zones. However, Section 91.7108 (as amended by Ordinance No. 175,790) states that if the City of Los Angeles’ Department of Building and Safety determines that a hazard may exist from methane intrusion to an area outside of the defined boundaries, the City’s Department of Building Safety and the City Fire Department may enforce any or all of the requirements of Division 71 of Los Angeles Municipal Code (LAMC) on the Project Site.

Though portions of the Project Site are within the City of Los Angeles, methane requirements at the Project Site are currently implemented and enforced by the County Department of Public Works.

(g) South Coast Air Quality Management District Rule 1150.1

Currently the Project Site complies with Rule 1150.1 landfill monitoring regulations. According to the Compliance Plan, variable frequency of the discrete monitoring and

554 Los Angeles County Department of Public Works; “Landfill Gas Protection Policy”, paper presented at the Landfill Gas Assessment and Management Symposium, Ontario, California, April 8-9, 1998.



Page 2008


sampling events are required on a quarterly basis to monitor landfill emissions and the operation of the collection and control system. Details of the monitoring/sampling/reporting requirements are included in the quarterly compliance reports.

According to the first quarter 2008 South Coast Air Quality Management District Rule 1150.1 Compliance Report, there were no treated landfill gas flow limit or outlet concentration exceedances from the Tram Maintenance Garage landfill gas collection and treatment system. There were no exceedances of total organic carbon during this quarter at the subsurface refuse boundary probes (compliance probes) or in the ambient air samples and integrated landfill surface samples collected during this quarter.

(7) Underground Storage Tanks

There are seven underground storage tanks located on the Project Site that are owned and operated by the Applicant. Four of these underground storage tanks are located in the Studio Area and three are located in the Entertainment Area. The underground storage tanks range in size from 1,000 to 20,000 gallons. All of the currently active underground storage tanks contain petroleum-based fuels or motor oil. The combined underground storage tank capacity is approximately 85,000 gallons. No other tenant or third-party vendor maintains underground storage tanks on the Project Site.

Applicable laws require that all underground storage tanks be registered with the local enforcement agency; in the case of Universal City, the local enforcement agencies are the City Fire Department within the City portion of the Project Site, and the County Department of Public Works for the County portion of the Project Site.

All underground storage tanks have continuous interstitial monitoring systems, which are tested and certified annually. Specific underground storage tanks, as required by various regulations, undergo other tests annually (i.e., Static Pressure Decay tests, and Dynamic Back Pressure tests). The secondary containment systems for all underground storage tanks and associated piping on-site have passed all testing requirements as required by Senate Bill 989.

According to a records search conducted for the Project Site and information from the Applicant, several known releases from underground storage tanks were identified on the Project Site. From 1984 to 2006, 25 underground storage tanks, ranging in size from 250 to 15,000 gallons, were removed from the Project Site with applicable regulatory agency oversight. To the extent necessary, soil and groundwater remediation was performed, and confirmation soil sampling was conducted. Closure reports for the tank removals were submitted to the Los Angeles Regional Water Quality Control Board and/or Los Angeles Department of Public Works. All open and closed underground storage tank



Page 2009


case closures associated with the Applicant’s portion of the Project Site are combined under one case number, R-00211, which will remain open until a no further action is granted by the Los Angeles Regional Water Quality Control Board for the Project Site as a whole.

Additionally, the on-site tenant (Technicolor), located in the northern portion of the Business Area, maintained several underground storage tanks prior to May 2005. During the removal of some of these underground storage tanks in the mid-1990s, solvent leakage from one or more underground storage tanks appears to have occurred. A soil remediation and groundwater monitoring program was implemented. Active soil remediation ceased in July 2004 (per a Los Angeles Regional Water Quality Control Board request), however, groundwater monitoring continues. As of May 2005, all underground storage tanks associated with this on-site tenant have been removed.

(8) Aboveground Storage Tanks

The Applicant currently operates 199 aboveground storage tanks on the Project Site with a total capacity of approximately 54,846 gallons. Of the 199 aboveground storage tanks, approximately 66 contain diesel fuel, hydraulic oil, propane and other materials that are gaseous at standard temperature and pressure, muriatic acid, and fog fluid. The remainder of the aboveground storage tanks are related to transformers, elevator, and food grease storage. The active tanks range widely in size from 45 gallons to 11,000 gallons in capacity; most of the tanks have a capacity of less than 1,150 gallons. Of the aboveground storage tanks covered by the Clean Water Act, the largest is 11,000 gallons.

Operations of the on-site tenant (Technicolor), located in the northern portion of the Business Area, requires the storage of hazardous materials in aboveground storage tanks. This tenant currently operates eight aboveground storage tanks that contain sulfuric acid (1,264 gallons), ammonium hydroxide (350 gallons), ammonium thiosulfate (8,000 gallons), perchloroethylene (2,000 gallons), and acetic acid (6,000 gallons). Additionally, this tenant operates approximately 170 aboveground processing tanks.

All of the raw material aboveground storage tanks and the aboveground storage tanks containing motor oil or waste hydraulic oil have secondary containment that is constructed of concrete and epoxy, except for the perchloroethylene tanks, which have a stainless steel lining to contain spills. As required by 40 Code of Federal Regulations 112, the Applicant has prepared and maintains a Spill Prevention Control and Countermeasure Plan that describes the storage and usage of oil and petroleum products used in the Applicant’s operations at the Project Site. The intent of the Spill Prevention Control and Countermeasure Plan is to minimize the potential for accidental release of oil or petroleum products into or upon the navigable waters of the United States or adjoining shoreline. The Project Site is located in



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close vicinity of the Los Angeles River Flood Control Channel. The Applicant is not aware of any reportable release to navigable waters from tanks on-site.

As detailed in the Spill Prevention Control and Countermeasure Plan, the Applicant’s facilities include containment and/or diversionary structures for the prevention of accidental discharges. All aboveground storage tanks, foundations, and tank supports are visually inspected on a semi-annual basis by the Applicant’s Environmental, Health & Safety Department and on-site Emergency Response Team staff. If visual inspection indicates that there may be potential issues, corrective measures and/or additional inspections/testing are performed.

(9) Radio Frequency

Electric and magnetic energy move together (that is, radiates) through space at the speed of light. Together, electric and magnetic energy waves make up electromagnetic energy. The term electromagnetic field or radio frequency field is often used to indicate the presence of electromagnetic or radio frequency energy. A very important use for radio frequency energy is in providing telecommunication services. A few examples of telecommunication applications that use radio frequency energy includes radio and television broadcasting, radio communications for police and fire services, cellular telephones, amateur radio, microwave point-to-point links, and satellite communications. Microwave ovens are an example of a noncommunication use of radio frequency energy.555

Because radio frequency electromagnetic waves do not have enough energy to induce ionization (a process which strips electrons from atoms and molecules), they are characterized as “non-ionizing radiation.” Studies have shown that the primary health concern attributed to non-ionizing radiation results from exposure to very high levels of radio frequency radiation. Exposure to such high levels of radio frequency radiation can cause biological tissue to heat rapidly (also referred to as thermal effects), resulting in an increase in body temperature and tissue damage. Studies on low levels of radio frequency radiation exposure (levels lower than those that would cause thermal effects) have not shown conclusive evidence of biological effects. Although there has been no determination that low-level exposure to radio frequency radiation constitutes a human health hazard, the latest experimental findings are monitored by the standard-setting organizations to confirm

555 Health Physics Society, Kelly Classic, “Radiofrequency Radiation,” http://hps.org/hpspublications/ articles/rfradiation.html, last accessed August 16, 2007.



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their validity and determine whether changes in safety limits are needed to protect human health.556,557

There are no known sources of significant radio frequency energy currently present at the site.558 Currently, the existing antennas at the Project Site include receive-only satellite antennas and microwave point-to-point antennas. Receive-only antennas do not transmit energy; therefore, operation of receive-only antennas does not present a radio frequency safety concern. Typical microwave point-to-point antennas operate at a maximum power of 2 Watts, which does not represent an energy level that is a safety concern even for someone standing directly in front of the antenna.559

The Applicant currently has a Radio Frequency Radiation Safety and Health Program, which includes radio frequency safety training.

3. Environmental Impacts

a. Methodology

To evaluate potential impacts, existing and proposed on-site environmental safety concerns were identified, quantified, and compared against the established safety standards and regulations to determine if the proposed Project would result in environmental safety impacts. The analysis of the potential impacts regarding hazardous materials management, the generation and disposal of asbestos and lead-based paint, and the generation and disposal of polychlorinated biphenyl-containing materials was based on-

556 Federal Communications Commission, Office of Engineering and Technology. “Radio Frequency Safety,” http://www.fcc.gov/oet/rfsafety/rf-faqs.html, last accessed May 1, 2008.

557 The standard-setting organizations that have been involved in monitoring and investigating issues related to RF exposure, and the Federal health and safety agencies that the Federal Communications Commission has consulted with in adopting safety guidelines for evaluating radio frequency environmental exposure, include the EPA, U.S. Food and Drug Administration, the National Institute for Occupational Safety and Health, and Occupational Safety and Health Administration. In addition, the Federal Communications Commission guidelines for human exposure to radio frequency electromagnetic fields were derived from the recommendations of two expert organizations, the National Council on Radiation Protection and Measurements and the Institute of Electrical and Electronics Engineers.

558 RF Safety Solutions LLC. “RF Safety Report: An Analysis of RF Field Levels at the NBC Universal Property in Universal City, California,” December 2009 (This report is included as Appendix B to the Environmental Safety Technical Report prepared by Camp Dresser & McKee Inc. (CDM), dated March 2010).

559 Ibid.



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site evaluations, plans and information from the Applicant. The analysis of the potential radio frequency safety impacts associated with the placement of several satellite-uplink antenna systems and possibly a variety of wireless communication antennas (i.e., for two-way radio, fire, police and emergency service systems), including cellular systems at the Project Site was based on general information regarding radio frequency and a Project Site evaluation, including calculations, by a radio frequency safety expert.

Several Environmental Site Assessments for the Project Site, including a Phase I Environmental Site Assessment and a Preliminary Phase II Environmental Site Assessment prepared by MWH Americas, Inc. and a Supplemental Phase II Environmental Site Assessment prepared by URS were reviewed. The Environmental Site Assessments included review of historical maps and building permits, searches of hazardous materials databases, site reconnaissance, a collection and chemical analysis of surface and subsurface soil samples, and test pits in the areas of suspected buried debris to determine if any recognized environmental concerns exist on the Project site. For a more detailed description of these Environmental Site Assessments and their findings, please refer to Appendix O, Environmental Safety Technical Report, of this Draft EIR.

b. Thresholds of Significance

The City of Los Angeles CEQA Thresholds Guide (2006) requires a review of the project to determine whether construction or operation would result in the accidental release or explosion of a hazardous substance and the probable severity of the consequences to people or property that would result, as well as to determine whether health hazards may be created by increasing the frequency or severity of consequences from human exposure to hazardous materials or conditions. Based on the criteria set forth in the City of Los Angeles CEQA Thresholds Guide (2006), the determination of significance related to the risk of upset of hazardous materials, emergency preparedness, and human health hazards 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 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.



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

The Project was to expose people to a substantial risk resulting from the release or explosion of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards.

c. Project Design Features

In addition to compliance with all applicable laws, rules and regulations (also known as plans, programs and policies) associated with hazardous materials management, Project design, construction, and operations would occur in accordance with the following Project Design Features.

First of all, the Applicant’s current comprehensive policies and programs specifically related to hazardous materials and waste management would continue to be implemented.

As is currently the Applicant’s practice, all hazardous materials on the Project Site would be acquired, handled, used, stored, and disposed of in accordance with all applicable Federal, State and local requirements. Monitoring of the Applicant's hazardous materials management would be conducted by the County Fire Department and/or, as appropriate, the Los Angeles Fire Department, and other applicable regulatory authorities, as appropriate. Likewise, the disposal of on-site generated hazardous waste would occur in accordance with all applicable regulations.

In addition, existing design and construction requirements and management practices related to asbestos, ACMs, or LBP would continue at the Project Site in accordance with applicable Federal, State, and local regulations. The use of only non-polychlorinated biphenyl containing electrical equipment in all new and replacement construction would continue at the Project Site. Furthermore, should the California Department of Toxic Substances Control determine that the concentrations of metals and polychlorinated biphenyls in the eastern portion of the Project Site pose an unacceptable risk to the Project’s future residential population, various options to reduce the risk to an acceptable level would be identified under California Department of Toxic Substances Control oversight and implemented. Potential options that may be considered include removal (excavation), treatment (in-situ or ex-situ), or other measures, as appropriate.

Also, the design, construction, and operation of Project uses over, or in proximity of, the closed on-site landfill would occur in accordance with applicable Federal, State, and local regulations related to environmental safety.



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Finally, the proposed satellite-uplink antenna systems and variety of wireless communication antennas would be located and operated in accordance with applicable federal, state, and local regulations that would limit exposure of persons (particularly workers) to potential RF levels. In addition, the Applicant’s existing radio frequency Radiation Safety and Health Program would be updated and additional training given to maintenance personnel, as appropriate.

d. Project Impacts

(1) Construction Impacts

(a) Hazardous Materials Use, Storage, and Management

During on-site grading and building construction, fuel, and oils associated with construction equipment, as well as coatings, paints, adhesives, and caustic or acidic cleaners, could be used, handled, and stored on the Project Site. The use, handling, and storage of these materials could increase the opportunity for hazardous materials releases and, subsequently, the exposure of people and the environment to hazardous materials. However, compliance with the Applicant’s Project Design Features as well as existing regulations and plans at the Project Site during construction would reduce this risk. Therefore, a less than significant impact is anticipated.

(b) Hazardous Waste

There is the potential for on-site grading to increase the use, handling and storage of hazardous materials, and encounter contaminated soil; however, compliance with the Applicant’s Project Design Features as well as existing regulations and plans at the Project Site during construction of the Project would prevent exposure of people to substantial risk resulting from the release of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards. In addition, with implementation of mitigation specific to the potential discovery of contaminated soil during construction excavation and grading activities, potential hazardous materials impacts during construction would be minimized further. Therefore, no significant impact is anticipated.

(c) Asbestos, Lead-Based Paints, and Polychlorinated Biphenyls

Asbestos, asbestos-containing materials, lead-based paint, and polychlorinated biphenyls could be encountered during renovation and replacement activities from continued Project-wide maintenance or renovation activities. As handling and disposal of asbestos, asbestos-containing materials, lead-based paint, and polychlorinated biphenyls



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would be in accordance with the Applicant’s Project Design Features as well as all applicable laws and regulations, construction of the Project would not expose people (i.e., workers, park attendees, and the occupants of the initial phases associated with the development of the Mixed-Use Residential Area) 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. Therefore, no significant impact associated with asbestos, asbestos-containing materials, lead-based paint, or polychlorinated biphenyls is anticipated from construction of the Project.

(d) Closed Landfill

Construction of the Project in the area of the closed landfill would be undertaken in accordance with the Applicant’s Project Design Features as well as all applicable laws and regulations. However, construction still has the potential to expose people and the environment to potentially hazardous conditions (including explosive and toxic concentrations of landfill gas and leachate from the landfill), if encountered. With implementation of mitigation, potential impacts would be less-than-significant. No significant exposure of people to substantial risk resulting from the release or explosion of a hazardous material is anticipated.

(e) Underground Storage Tanks

Project-related grading could uncover or disturb existing known and unknown underground storage tanks, which could lead to soil and/or groundwater impacts and the potential exposure of people and the environment to hazardous materials. If underground storage tanks or impacted soils are encountered, existing comprehensive policies and programs specifically related to environmental safety would continue to be implemented. With implementation of the Applicant’s Project Design Features, which include specific measures in response to the potential discovery of contaminated soil during construction, excavation and grading activities, potential hazardous materials impacts during construction would be minimized. Therefore, a less than significant impact is anticipated.

(f) Radio Frequency

The proposed Project involves the construction and operation of several satellite-uplink antenna systems and possibly a variety of wireless communication antennas (i.e., for two-way radio, fire, police and emergency service systems), including cellular systems. There are no known sources of significant radio frequency energy currently at the site and the Project does not involve removal of any existing antennas. As potential radio frequency radiation is a result of energy from the operation of an antenna that transmits energy, the construction of the Project in itself would not result in a radio frequency safety hazard.



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Therefore, no significant impact associated with radio frequency is anticipated from the construction of the Project.

(g) Emergency Response

Construction of the Project could temporarily interfere with local and on-site emergency response. Local streets adjacent to the Project Site would be used for construction traffic; however, construction traffic would conform to all traffic work plan and access standards to allow adequate emergency access. Construction within the Studio/Entertainment/Business Areas would be intermittent, while construction within the Mixed-Use Residential Area is anticipated to be continuous over a shorter period. Implementation of construction traffic management plans and access standards would reduce the potential for the impacts on emergency response during construction of the Project, including reducing the potential for impacts to the proposed residential development during construction within the Mixed-Use Residential Area. Therefore, construction of the Project is not anticipated to significantly impair implementation of, or physically interfere with, any adopted or on-site emergency response or evacuation plans or a local, State, or Federal agency’s emergency evacuation plan. Therefore, no significant impact is anticipated.

(2) Operational Impacts

(a) Hazardous Materials Use, Storage, and Management

The Project has the potential to increase the acquisition, use, handling and storage of hazardous materials on-site. Through the expansion of existing facilities and development of new facilities, both the number of hazardous materials users and the quantity of hazardous materials being used could increase. With continued implementation of hazardous materials management by the Applicant, tenants or third-party vendors at the Project Site, in accordance with all applicable local, state, and federal laws and regulations relating to environmental protection and the management of hazardous materials, operation of the Project would be consistent with the goals, policies, and objectives of the City and County General Plan Safety Elements. Through continued compliance with applicable laws, as well as implementation of the identified Project Design Features, impacts associated with the use, storage, and management of hazardous materials would be less than significant.

(b) Hazardous Waste

With implementation of the Project, it is anticipated that hazardous waste generating activities could increase. However, continued implementation of the source reduction



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measures being developed by the Applicant under the Hazardous Waste Source Reduction and Management Review Act (i.e., Senate Bill 14) are anticipated to reduce the generation of the major typical operational hazardous waste streams. Due to the implementation of existing hazardous waste reduction efforts on-site,560 and the fact that the majority of typical/operational hazardous waste is conveyed to licensed treatment, disposal and resource recovery facilities, it is not anticipated that the Project would result in a significant increase in demand for hazardous waste landfill capacity.

Other potential environmental impacts related to the increased generation of hazardous waste are associated with potential releases of the materials. Hazardous waste releases may result in potential injury if exposure takes place and, if not mitigated, result in soil and/or groundwater impacts. Compliance with applicable regulations related to the handling, storage and disposal of hazardous waste would be particularly effective relative to proposed non-residential uses, which have a higher likelihood of involving notable amounts and types of hazardous materials/wastes than that of residential uses. Based on the above, no significant impact is anticipated.

(c) Asbestos and Lead-Based Paint

New on-site construction and/or renovation due to the Project would include use of commercially sold construction materials that are not anticipated to increase the occurrence of friable asbestos, asbestos-containing materials, or lead-based paint at the Project Site. Therefore, operation of the new development proposed at the Project Site is not anticipated to expose persons to friable asbestos or lead-based paint. In addition, per applicable regulations, new workers associated with the Project would be protected by worker safety requirements. With existing laws and regulations, as well as implementation of the identified Project Design Features, operation of the Project would not expose people (i.e., workers, park attendees, and the occupants of the initial phases associated with the development of the Mixed-Use Residential Area) 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. Therefore, no significant impact associated with asbestos, asbestos-containing materials, and lead-based paint is anticipated from operation of the Project.

560 Existing hazardous waste reduction efforts on-site include: substituting water-based coatings for solvent-based coatings, substituting citrus-based cleaners for solvent-based cleaners, implementing countercurrent wash methods for cleaning painting equipment, installing oil/water separator inlet screens to screen out solids; and broom-sweeping floors.



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(d) Polychlorinated Biphenyls

Due to the Project Design Features that calls for the elimination of polychlorinated biphenyls as a component of modern electrical facilities and fixtures, new development and the maintenance of electrical systems associated with that new development would not expose persons to polychlorinated biphenyls. The Applicant, on-site tenants and third-party vendors are anticipated to continue to comply with applicable laws in the future. As such, the operation of 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. Therefore, no significant human exposure to polychlorinated biphenyls is anticipated from the operation of the Project.

(e) Closed Landfill

Implementation of the proposed Project would result in the development of buildings and structures located within 1,000 feet of the closed on-site landfill. Only a small portion of the western edge of the Mixed-Use Residential Area extends within 1,000 feet of the closed landfill. In addition, the northeast portion of the Entertainment Area and the southeast portion of the Studio Area could include the expansion or redevelopment of existing uses located within 1,000 feet of the closed landfill. As the closed landfill is located in the portion of the Project Site that is located in Los Angeles County, methane requirements at the Project Site are currently implemented and enforced by the County Department of Public Works. The Los Angeles County Building Code indicates that permits will not be issued for buildings or structures located within 1,000 feet of landfills unless the fill is isolated by approved natural or artificial protective systems.

Though the Project Site is not in a Methane or Methane Buffer Zone, Section 91.7108 of the Los Angeles City Building Code states that if the City’s Department of Building and Safety determines that a hazard may exist from methane intrusion to an area outside of the defined methane boundaries, the Department of Building and Safety and City Fire Department may enforce any or all of the requirements of Division 71 of this code at a Project Site.

Operation of the Project in the area of the closed landfill would be undertaken in accordance with the identified project design features as well as all applicable laws and regulations. Therefore, operation of 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. Therefore, no significant impacts associated with the closed landfill are anticipated from operation of the Project.



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(f) Underground Storage Tanks

Expanded operations on the Project Site could require the installation and operation of additional underground storage tanks to accommodate increased hazardous materials demand. These additional underground storage tanks would be anticipated to contain hazardous materials similar to those utilized in existing studio/entertainment/business operations on the Project Site. This increase in the number of underground storage tanks on-site could potentially increase the potential for accidental releases and subsequent impacts to soil, surface water, and groundwater, as well as the potential for environmental and human exposure to hazardous materials. All new underground storage tanks at the Project Site would be installed in accordance with the identified project design features as well in accordance with federal, state, and local laws. Implementation of the identified project design features and continued compliance with applicable laws will minimize impacts to human health and the environment associated with underground storage tanks, and no significant impacts are anticipated.

(g) Aboveground Storage Tanks

Expanded operations on the Project Site could require the installation and operation of additional aboveground storage tanks for the storage of motor oil, vegetable oil, propane, and other substances. This increase in the number of aboveground storage tanks on-site could potentially increase the potential for accidental releases and subsequent impacts to soil and surface water, as well as the potential for environmental and human exposure to hazardous materials. New aboveground storage tanks installations on the Project Site by the Applicant, tenants or third-party vendors must conform to applicable regulatory requirements. The Applicant’s biennial report will be revised to incorporate any new aboveground storage tanks installed by the Applicant. In addition, the Applicant’s Spill Prevention Control and Countermeasure Plan would be updated to address any future aboveground storage tanks. Implementation of the identified project design features as well as compliance with these laws will minimize impacts to human health and the environment associated with aboveground storage tanks by ensuring that new tanks include secondary containment, as required. Therefore, no significant impacts are anticipated.



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(h) Radio Frequency

(i) Satellite-Uplink Antennas561

The types of satellite-uplink antennas proposed as part of the Project are known as “reflector” antennas. There are three basic antenna configurations being considered for installation:

A 2.4-meter-diameter antenna with a maximum input power of 125 Watts;

An 8.0-meter-diameter with a maximum input power of 200 Watts;

A 9.0-meter-diameter with a maximum input power of 200 Watts.

The primary safety and compliance issues to be considered when locating satellite-uplink antennas include the following:

If the maximum radio frequency field level is less than the Federal Communications Commission’s Maximum Permissible Exposure limit for General Population/Uncontrolled exposure, the installation is compliant with the Federal Communications Commission Regulations, and there is no concern over anyone getting into the beam of the antenna.

If the maximum radio frequency field level exceeds the Federal Communications Commission’s Maximum Permissible Exposure limit for General Population/Uncontrolled exposure, the installation must be made in a way that prohibits anyone from getting into the beam of the antenna.

With reflector antennas, such as the ones being considered, all of the energy is confined to a cylindrical beam. The highest radio frequency safety hazard would be present in the beam of the smallest (2.4-meter-diameter) antenna. For the proposed 2.4-meter-diameter antenna, the calculated average radio frequency field levels within the main beam is approximately 200 percent of the Federal Communications Commission’s Maximum Permissible Exposure limits for General Population (Uncontrolled) exposure when the system is operated at full power. The maximum calculated field level is four times higher than the average, or eight times the Federal Communications Commission’s Maximum Permissible Exposure limits for General Population (Uncontrolled) exposure, which also exceeds the Maximum Permissible Exposure limit for Occupational (Controlled) exposure.

561 Satellite-uplink antennas transmit energy from the ground, or “uplink” to the satellite.



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For the 8.0-meter-diameter antenna the calculated maximum radio frequency field level in the main beam slightly exceeds the Maximum Permissible Exposure limit for General Population (Uncontrolled) exposure. For the 9.0-meter-diameter antenna the calculated maximum radio frequency field level in the main beam is slightly below the Maximum Permissible Exposure limit for General Population (Uncontrolled) exposure. Because of their size and design (i.e., mounted with the lip of the reflector at least 5 feet above ground level), the beam of the larger antennas (such as the 8.0-meter- and 9.0-meter-diameter antennas) is normally not accessible to the general population without using a ladder or other mechanical device.

As the main safety consideration with the proposed types of antennas is at the area at the focal point of the antenna (the cylindrical beam area, or the area referred to as the “feed horn”) where the energy is concentrated, the safety hazard would be limited to maintenance personnel as the proposed satellite-uplink antennas would be located in areas of the Project Site where the general public would not have access. To perform maintenance on the antenna, the system would be shut off and locked out prior to maintenance activities. Therefore, the only time when energy would be outside the cylindrical beam would be if there was a leak in the waveguide transmission line.562 A leak or breaks at junction points could potentially cause a significant radio frequency safety hazard, particularly an eye hazard, for a distance up to about 3 feet from the leak point. Beyond the 3-foot area, no hazards would exist since the energy from the leak site would spread out and decrease rapidly with distance. Engineering controls would be included and safety procedures implemented that would address the discovery of a leak in the waveguide transmission line such that the potential radio frequency safety hazard to maintenance personnel would be less than significant.

In addition, the 2.4-meter-diameter antennas present a potential significant safety hazard to personnel as the calculated radio frequency field levels are too high to allow anyone other than a worker trained in radio frequency safety to get within the beam of the antenna.

Although the Applicant would continue to comply with applicable laws regarding the operation of radio frequency transmission equipment, there is the potential for the Project to expose people (specifically maintenance personnel) to a radio frequency hazard. With regulatory compliance and implementation of proposed mitigation measures, the potential radio frequency hazard would not result in a substantial risk resulting from the release or

562 Waveguide is a form of radio frequency “plumbing” used to conduct microwave frequency energy inside small rectangular or circular pipes made of copper. Breaks at junction points can become eye hazards for a distance up to about 3 feet from the leak point.



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explosion of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore, no significant human exposure to radio frequency energy or radiation is anticipated from the operation of the proposed satellite uplink antennas.

(ii) Wireless Services Antennas

Wireless services antennas are used for a broad variety of wireless services: cellular; PCS; paging; fire, police, and emergency services; and two-way radio. The antennas are either omnidirectional or they are directional. Omnidirectional antennas (commonly referred to as whip antennas), radiate equally over 360 degrees but have very little energy (only about 10 percent) directed upward or downward. Exposure concerns are limited to people who are within 20 feet of the antenna and at the same elevation. For example, if the bottom of the antenna is as little as 2 feet above a person’s head, the average radio frequency field level that person would be exposed to would be below the Federal Communications Commission’s Maximum Permissible Exposure General Population (Uncontrolled) exposure. Directional antennas (commonly referred to as sector antennas) do not have significant amounts of energy directed above or below the antenna and there is virtually no energy to the sides or behind these antennas. Since the energy is directed over less than 360 degrees, the safe zone extends out further than with omnidirectional (whip) antennas. The most common directional (sector) antennas cover either 120-degree or 90-degree beams. Virtually all the energy for sector antennas is in the forward region/direction, with very little energy downward (typically at an angle of 4 degrees). Exposure concerns for sector antennas extend out to about 50 feet at the same elevation.

Although the Applicant would continue to comply with applicable laws regarding the operation of radio frequency transmission equipment, there is the potential for the Project to expose people (specifically maintenance personnel) to a radio frequency hazard. With regulatory compliance and implementation of the proposed mitigation measures, the potential radio frequency hazard would not result in a substantial risk resulting from the release or explosion of a hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore, no significant human exposure to radio frequency energy or radiation is anticipated from the operation of the proposed wireless antennas.

(3) Impacts Under No Annexation Scenario

Most of the Mixed-Use Residential Area is proposed to be annexed to the City of Los Angeles, and portions of the Entertainment Area would be detached from the City, and as such, would be under the jurisdiction of the County. If annexation occurs, the appropriate lead agency’s policies and procedures would be applicable to the areas within the new City/County boundaries. While there are some differences between the policies



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and procedures of the respective jurisdictions, adherence to the policies and procedures of the applicable jurisdiction would mitigate any potential impacts. As such, impacts associated with the No Annexation scenario would be less than significant.

4. Cumulative Impacts

Development of the Project in combination with the related projects has the potential to increase the risk for an accidental release of hazardous materials. Environmental safety impacts of the Project would be unique to the site, not lending to cumulative effect in conjunction with related-projects. Each of the related projects would require evaluation for potential threats to public safety, including those associated with the use, storage, and/or disposal of hazardous materials, asbestos-containing materials, lead-based paint, polychlorinated biphenyls, and radio frequency would be required to comply with all applicable local, state, and federal laws, rules and regulations. Because environmental safety issues are largely site-specific, this evaluation would occur on a case-by-case basis for each individual project affected, in conjunction with development proposals on these properties. Therefore, with full compliance with all applicable local, State, and Federal laws, rules and regulations, cumulative impacts would be less than significant.

5. Project Design Features and Mitigation Measures

a. Project Design Features

(1) Hazardous Materials Use/Management

The following are the existing plans, programs and policies that address potential impacts from Project implementation due to the use, storage, and creation of hazardous materials:

Project Design Feature M-1: Prior to the issuance of any demolition permit or building permit for remodeling of existing buildings, the Applicant or its successor shall provide evidence to the City of Los Angeles or County of Los Angeles Department of Building and Safety, as applicable, that the demolition contract provides for a qualified asbestos abatement contractor/specialist to remove or otherwise abate or manage asbestos during demolition or renovation activities in accordance with all applicable federal, state and local regulations.

Project Design Feature M-2: Prior to the issuance of any demolition permit or building permit for remodeling of existing buildings, the Applicant or



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its successor shall provide evidence to the City of Los Angeles or County of Los Angeles Department of Building and Safety, as applicable, that the demolition contract provides for a qualified lead-based paint abatement contractor/specialist to remove or otherwise abate or manage lead-based paint during demolition or renovation activities in accordance with all applicable federal, state and local regulations.

Project Design Features M-3: The Applicant or its successor shall implement a soil management plan approved by the Department of Toxic Substances Control, pursuant to Department of Toxic Substances Control’s Voluntary Cleanup Program, or other applicable state or local regulatory agency providing oversight, to address potential contamination in soil in the Universal Village District area. The approved soil management plan shall include procedures for soil sampling and remedial options that may include removal (excavation), treatment (in-situ or ex-situ), or other measures, as appropriate.

Project Design Feature M-4: For development in the Business, Entertainment, and/or Studio Areas and to the extent applicable, for development in the Mixed-Use Residential Area, the Applicant or its successor shall submit to the County Fire Department, City Fire Department, and Los Angeles County Department of Public Works, and City Department of Building and Safety, as applicable, an updated emergency response and/or evacuation plan, as appropriate, to include operation of the Project. The emergency response plan shall include but not be limited to the following: mapping of evacuation routes for vehicles and pedestrians, and the location of the nearest hospital and fire departments.

In addition to the above Project Design Features, Project implementation shall occur in accordance with the following mitigation measures.

b. Mitigation Measures

(1) General

Compliance with all applicable laws, rules, and regulations associated with hazardous materials management during design, construction and operation would minimize impacts to human health and the environment. In addition, the following mitigation measure would further minimize potential hazardous materials impacts during construction:



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Mitigation Measure M-1: If soil contamination is suspected to be present, prior to excavation and grading, the South Coast Air Quality Management District’s Rule 1166 shall be implemented, as appropriate. If soil contamination is not suspected, but is observed (i.e., by sight, smell, visual, etc.) by a qualified professional during excavation and grading activities, excavation and grading within such an area shall be temporarily halted and redirected around the area until the appropriate evaluation and follow-up measures are implemented, as contained in South Coast Air Quality Management District’s Rule 1166, so as to render the area suitable for grading activities to resume. The contaminated soil discovered shall be evaluated and excavated/disposed of, treated in-situ (in-place), or otherwise managed in accordance with all applicable regulatory requirements.

(2) Landfill Related

Construction of all new development located within alluvium or non-engineered fill associated with the existing landfill footprint shall require the following mitigation measures:

Mitigation Measure M-2: As required by the Occupational Safety and Health Administration, Construction Worker Safety Plan shall be developed by each contractor working within the footprint of the landfill. The Construction Worker Safety Plan shall comply with the Occupational Safety and Health Administration Safety and Health Standards 29 Code of Federal Regulations 1910.120, the California Code of Regulations, Title 8, General Industry Safety orders, and U.S. Occupational Safety and Health Act. The Plan shall include requirements associated with potential exposure to landfill gases. In addition, construction personnel shall wear protective equipment and clothing and other safety equipment, as appropriate, in accordance with the Construction Worker Safety Plan and/or Project site-specific safety plans, as applicable.

Mitigation Measure M-3: Construction of all new development within 1,000 feet of the landfill shall be designed and constructed to prevent gas migration into the buildings in accordance with the recommendations of a licensed civil engineer. The recommendations shall be subject to the review and approval of the Los Angeles County Department of Public Works.

Mitigation Measure M-4: For areas of the Project Site in the City of Los Angeles, should the City’s Department of Building and Safety determine that a hazard may exist from methane intrusion due to proximity to the closed on-site landfill, construction of new



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development within 1,000 feet of the closed on-site landfill shall comply with the requirements of the Citywide Methane Ordinance.

Operation of development within 1,000 feet of the landfill, or development constructed with methane safety systems, shall require the following mitigation measure:

Mitigation Measure M-5: During operation, monitoring of methane safety systems shall occur in accordance with County or City requirements, as applicable.

(3) Hazardous Materials Use and Storage/Hazardous Materials Management/Hazardous Waste/Asbestos/Polychlorinated Biphenyls/Underground Storage Tanks/Aboveground Storage Tanks

Compliance with Project Design Features and all applicable laws, rules and regulations associated with hazardous materials management would minimize impacts to human health and the environment during construction and operation of the Project; therefore, no impact is anticipated and no mitigation is required.

(4) Radio Frequency

Mitigation Measure M-6: The Applicant or its successor shall locate and operate satellite-uplink antennas with an absolute minimum of 1 foot of separation between the eye level and all waveguide connections, waveguide components, and flexible waveguide. Exposure within 1 to 3 feet from waveguide shall be limited to less than one minute.

Mitigation Measure M-7: The Applicant or its successor shall develop and use a simple lockout, tagout procedure prior to the maintenance activities of satellite-uplink antennas (i.e., reflector antennas) to ensure that the high-power amplifiers cannot be energized while anyone is working on an antenna.

Mitigation Measure M-8: If a 2.4-meter-diameter antenna is installed so that the bottom lip of the antenna is less than 7 feet above ground, the Applicant or its successor shall install a barrier, such as a chain and stanchion barrier to be added in front on the antenna, to prevent access to the area directly in front of the antenna. As appropriate, the width of the restricted access area shall be 10 feet wide, to ensure that no access to the area is possible by leaning over the chain. The distance in front of the antenna shall be determined based on the minimum elevation angle and height of the bottom lip of the antenna



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above the ground. The bottom lip of the antenna shall be a minimum of 7 feet above ground level at the chain. In addition, a warning/notice sign shall be hung on each side of the enclosure.

As an alternative, 2.4-meter-diameter antenna(s) shall be mounted on a platform, with a chain and warning/notice sign on the platform stairs. The bottom lip of the antenna shall be a minimum of 7 feet above ground level.

Mitigation Measure M-9: The Applicant or its successor shall restrict access to the beam of the 2.4-meter-diameter antenna(s) only to workers trained in radio frequency safety.

Mitigation Measure M-10: Prior to operation of new antennas on the Project Site, the Applicant’s existing Radio Frequency Radiation Safety and Health Program shall be updated and additional training given to maintenance personnel, as appropriate.

6. Level of Significance After Mitigation

With implementation of the proposed mitigation measures, Project impacts would be less than significant.

Documents

IV.M. Environmental Safety - LA City Planning · 2013. 1. 17. · Unified Hazardous Waste and Hazardous Materials Management Regulatory Program (Unified Program) (Senate Bill 1082,