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Section 3.5
Hazards and Hazardous Materials
3.5 HAZARDS AND HAZARDOUS MATERIALS
This section describes the existing potential for hazards on the project sites and surrounding
areas, identifies applicable plans and policies related to hazards and hazardous materials,
evaluates associated impacts for significance under applicable criteria, and assesses project
consistency with the 2004 LRDP EIR (UCSD 2004b). Hazards and hazardous materials issues
are addressed in Section 4.6 of the 2004 LRDP EIR. Subsequent to the certification of the 2004
LRDP EIR, however it was determined that the project sites have the potential to contain
munitions debris (MD), munitions and explosives of concern (MEC), and/or unexploded
ordnance (UXO) due to historic training activities at the former Camp Matthews property.
Accordingly, investigations of former Camp Matthews test ranges (including areas within the
UCSD campus) were conducted to assess related potential issues (ACOE 2005, Parsons 2007).
A site-specific investigation was also conducted at the CTRI site in September/October 2010 by
HydroGeoLogic, Inc. (HGL 2011), to assess potential hazards related to the potential occurrence
of MEC and UXO. In addition, soil testing for potential contaminants including California Title
22 metals, total petroleum hydrocarbon (TPH), and pentachlorophenols (PCPs) was conducted at
the CTRI site in 2010 by Group Delta Consultants (GDC 2010a). This section addresses
potential construction-related impacts to human health and ecological health for the CTRI and
ECRA project in light of the listed investigations, with the referenced HGL and GDC reports
included in Appendix F of this EIR.
The proposed reclassification of Restoration Lands to Ecological Reserve would be done under
an LRDP Amendment to be considered for approval at the time the CTRI/ECRA project is
considered for approval, and would allow permanent preservation of the reclassified area, in
accordance with the 2004 LRDP EIR. There would be no hazards implications associated with
the proposed LRDP Amendment; therefore, it is not discussed further in this section.
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3.5.1 Existing Setting
Historic Background
As noted in Sections 4.4, Cultural Resources, and 4.6, Hazards and Hazardous Materials, of the
2004 LRDP EIR, UCSD property was occupied by the U.S. Marine Corps (Camp Matthews) and
the U.S. Army (Camp Callan) prior to the property’s transfer to the UC system. Areas formerly
covered by Camp Matthews include the eastern and south central portions of the UCSD campus,
which are heavily developed but interspersed with small, undeveloped areas. The project sites
are situated near the southern limits of former Camp Matthews and near several ranges
associated with the camp (Figure 3.5-1, Former Camp Matthews Ranges Within Proximity to
CTRI and ECRA Project Sites). Former Camp Callan was situated west of Camp Matthews and
those areas are also highly developed.
The U.S. Marine Corps established Camp Matthews in 1918 on an area of approximately
3,875 acres leased from the City of San Diego.
By 1927, the land lease was reduced to
approximately 363 acres and covered a rifle range, referred to as the Marine Corps Rifle Range
La Jolla. The primary purpose of the camp was to provide weapons training and qualifications at
its firing ranges to Marines in the San Diego area, particularly new recruits assigned to the
Marine Corps Recruit Depot (MCRD) in San Diego. The Marines also loaned use of the range to
various naval ship detachments, the California National Guard, and the U.S. Reserve Corps. The
number and use of military ranges slowly increased through the 1930s. By 1937, the Marines
Corps Rifle Range La Jolla had expanded to 544 acres on what would later become a portion of
the UCSD property. The ranges were expanded further during World War II, and in 1942 the
overall facility was named Camp Calvin B. Matthews. Also during World War II, all MCRD
recruits were trained in the use of firearms at the Camp Matthews firing ranges, with a peak of
100,000 Marines reached in 1943 (Kyle Consulting 2004). Under pressure to establish UCSD,
Congress passed legislation in 1962 directing the Navy to convey the Camp Matthews property
to the UC system. Thereafter, the Marines established a new firing range at Marine Corps Base
Camp Pendleton (completed in 1964), and in the summer of 1964 the last shot was fired at Camp
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CLINICAL AND TRANSLATIONAL RESEARCH INSTITUTE (CTRI) AND EAST CAMPUS RECREATION AREA (ECRA) EIR
Figure 3.5-1
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Matthews during a farewell ceremony.
Section 3.5
Hazards and Hazardous Materials
The property was quitclaim deeded to the UC in
September 1964 (ACOE 2005).
Historic Site Use
The CTRI and ECRA sites are located within the historic boundaries of Camp Matthews Range
Complex No. 1 for four areas that contain possible MEC: Ranges A, D, E, and F (refer to
Figure 3.5-1). Range A was a 1,000-yard rifle range between 1918 and 1964, used primarily for
small-arms firing, and for artillery use from 1930-1931. Range D was a 300-yard rifle range,
used primarily for small-arms firing between 1924 and 1964, with rifle grenades and anti-tank
rockets fired from 1950-1964. Range E, a 600-yard rifle range, was the largest of the rifle ranges
within the complex at approximately 1,000 feet wide. Used primarily for small-arms firing
between 1940 and 1964, Range E was the location of the last shots fired at Camp Matthews.
Range F was in use between 1945 and 1949, and consisted of a 500-yard rifle range with
65 targets (Parsons 2007). Potential constituents in small arms and rifle ranges may include
aluminum, antimony, chromium, copper, iron, lead, and/or tungsten. Areas adjacent to the CTRI
site were developed by UCSD in association with Thornton Hospital between 1991 and 1993,
with no known documentation to suggest that MEC was encountered during associated
construction. As indicated in Figure 3.5-1 and as evidenced on and around the UCSD campus,
several of the areas within the described ranges remain undeveloped, including portions of the
CTRI and ECRA sites and vicinity (refer to Figure 2-1). In addition, while construction of I-5 in
1964-65 removed former range lands in the vicinity of the CTRI site, there are no known records
indicating that MD, MEC, or UXO were encountered during freeway construction
(Parsons 2007).
Surrounding Land Uses
Existing campus development primarily surrounds the project sites (refer to Figures 1-2 and 2-1).
Specifically, the existing East Campus Medical Center (including Thornton Hospital) and the
Science Research Park are to the east, and the East Campus Parking Structure is between the
CTRI and ECRA sites. Adjacent uses to the north (of the CTRI site) and west (of the ECRA
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site) include undeveloped open space and a sports (baseball) complex. Portions of existing
Parking Lot P702 and Voigt Drive are adjacent to the ECRA site on the east and north,
respectively, with the Preuss School UCSD located just north of Voigt Drive. The I-5 corridor is
located immediately west of the CTRI site, with West Campus located beyond the freeway rightof-way. The closest off-campus development (Scripps Memorial Hospital) occurs along Voigt
Drive, approximately 150 and 600 feet north of the ECRA and CTRI sites, respectively.
Potential for Munitions on UCSD Campus and Project Sites
The 2004 LRDP EIR acknowledged the possibility for military-related hazardous materials
remaining on the campus (see pages 4.6-7 through 4.6-12 of the 2004 LRDP EIR). In that
analysis, it was determined that the military camps used fuel and other hazardous materials as
part of their every-day training. In addition, due to the historic use of Camp Matthews, the 2004
LRDP EIR acknowledged that there is also the possibility of remaining ammunition shells
(classified by the military under ordnance) on UCSD property (Phillips 1998). It was unknown
whether a thorough clean-up was conducted across the entire campus, as no documentation
existed during the preparation of the 2004 LRDP EIR to indicate if the former Camp Matthews
area had been completely inspected and cleared for remaining ammunition prior to its transfer to
the UC system. In 1964, the Defense Surplus Sales Office authorized a salvage contractor to
reclaim the metals in the target butts (ACOE 2005). The salvage contractor removed and sifted
through 1,190 truckloads of soil to find lead pieces to melt and reuse for other purposes. Despite
those salvage operations, bullet particles and several 3.5-inch inert practice rockets have been
found during excavations for development projects on the UCSD campus and surrounding offcampus areas. Some of the sites on which the ranges existed still remain undeveloped today,
including a few areas located immediately west and east of I-5, such as the Pepper Canyon and
east campus canyon areas, respectively. Consequently, the possibility for any remaining shells
was unknown at the time the 2004 LRDP EIR was prepared.
A Preliminary Assessment Report was prepared by the ACOE in 2005. As part of the report
preparations, two staff members from the ACOE conducted a field investigation to visually
inspect the undeveloped lands in the former Camp Matthews area.
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concluded that the potential does exist for munitions debris and constituents to be present
(ACOE 2005). Due to the potential for munitions debris on the east campus of UCSD and
proposed development of a previously undeveloped area, the ACOE prepared a site-specific
MEC construction safety support plan to be implemented during construction of the East
Campus Graduate Student Housing project (located on a previously undeveloped area northeast
of the I-5/La Jolla Village Drive interchange). Construction support activities for that project
commenced in October 2005 and continued through December 2005. Fourteen inert (practice)
rockets were recovered during those construction support activities. Other munitions recovered
during the noted construction included fragments of mortars, rifle grenades and several other
practice rockets.
A follow-up Site Inspection Report (Site Inspection) on the Camp Matthews range complex as a
whole was also commenced by the ACOE in 2005, with the final report prepared by Parsons in
2007. The Camp Matthews range complex (referred to as Range Complex No. 1) includes
14 training ranges, one maneuver area, and the location of a 1945 ammunition truck explosion
(Parsons 2007). The Site Inspection included a qualitative reconnaissance (i.e., visual inspection
on foot) and munitions constituents sampling effort. As such, ACOE contractors conducted ten
miles of qualitative reconnaissance of undeveloped and/or remote portions of the Camp
Matthews site (on and off campus) where munitions debris have previously been encountered or
were documented during the preparation of the 2004 Preliminary Assessment Report, and/or
where munitions constituents were considered likely to be present. The developed portions of
the UCSD campus were not walked or sampled as part of the Site Inspection (Parsons 2007). In
conjunction with the described reconnaissance, soil and sediment samples were collected from
eleven locations on the Camp Matthews range complex. These efforts included a field survey in
the western portion of the CTRI site, as well as one associated soil sample from an undeveloped
area near the southern CTRI boundary (Sample No. FCM-IA-SS-02-04). No surveys or samples
associated with the Site Inspection were conducted within the ECRA site. The Site Inspection
stated that munitions debris and/or MEC exposure could exist on or around undeveloped portions
of the complex. Specifically, for the on-site CTRI survey/sediment sample, it was noted that
“MD in the form of small arms projectiles (.30- and .45-caliber) were found on the ground near
sample FCM-IA-SS-02-04.” (Parsons 2007).
Based on the described information, the Site
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Inspection concluded that the potential exists for subsurface MEC, as well as observed lead and
arsenic levels, to pose a human health risk from exposure to contaminated soil, as outlined below
(Parsons 2007).
Laboratory analysis of the soil and sediment samples collected during the Site Inspection
determined that the concentrations of arsenic and lead exceed their respective screening levels in
some locations. Specifically, observed levels of lead (310 milligrams per kilogram [mg/kg]) and
arsenic (6.7 mg/kg) in the CTRI site sample (No. FCM-IA-SS-02-04) exceeded the associated
screening thresholds. Soil testing of samples taken from areas not suspected of containing MEC
also identified elevated levels of arsenic, suggesting that arsenic levels may be naturally high in
portions of the study area (Parsons 2007). A screening-level risk assessment and screening-level
ecological risk assessment were also performed as part of the Site Investigation to evaluate the
health and ecological risks associated with the soil constituents identified in the samples. Both
studies determined that there is a potential for health risks due to munitions constituents
(specifically, lead, arsenic, chromium, copper, zinc, and 2,4-dinitroluene) that warrants further
investigation.
Although future investigation will be conducted by the ACOE to better
characterize and delineate the potential contamination by munitions constituents and possible
presence of MEC, immediate removal was not recommended for Camp Matthews Range
Complex No. 1 (Parsons 2007).
Based on noted soil sampling/testing results, an additional investigation was conducted at the
CTRI site in September/October 2010 to further assess potential hazards related to the potential
occurrence of MEC and UXO (HGL 2011). The ECUP portion of the CTRI site was not
evaluated in this assessment due to the fact that the ECUP is completely developed and paved,
and the proposed project would not entail any grading or other disturbance activities that would
potentially encounter hazardous materials (with the proposed ECUP improvements to be
constructed on existing paved areas). This investigation included the following efforts: (1) a
“surface sweep” of the entire site using magnetometers (instruments used to measure the
strength/direction of magnetic fields) to detect magnetic anomalies; (2) testing in six shallow
trenches with magnetometers to detect anomalies below the trench bottoms (which extended to
maximum depths of approximately two feet); and (3) testing in five borings with a specialized
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magnetometer (a “borehole gradiometer”) to detect anomalies at three-foot intervals to a total
depth of six feet (with the MEC most likely to be encountered not capable of penetrating to
greater depths, HGL 2011). Based on these investigations, the HGL report concluded that: (1) no
MEC or UXO items were discovered on the surface, nor were any such items specifically detected
at depth; (2) numerous magnetic anomalies were detected during surface sweeps (although none
were investigated to positively determine if they were associated with MEC items); (3) MEC
items on the surface could potentially have been overlooked in some portions of the site due to the
presence of dense vegetation; and (4) the potential exists for the subsurface occurrence of MEC in
locations where trenching or borehole testing was not conducted (HGL 2011).
In addition to the site-specific munitions-related investigation conducted at the CTRI site by
HGL (2011), geotechnical/soil testing was also conducted on site to determine if contaminated
soils are present (GDC 2010a, 2010b). Based on these analyses, it was determined that the site is
underlain by formational material (i.e., native soil) of the Scripps formation, as well as alluvium,
colluviums, and undocumented fill material. Samples were collected from 5 boring and 11 test
pit locations throughout the site. All samples were analyzed for the presence of numerous
contaminants, including California Title 22 metals, TPH, and PCPs.
Observed levels of
contaminants including TPH (as diesel fuel), lead, and arsenic were above the associated human
health screening levels, and are considered potential environmental conditions requiring
remediation. No portions of the CTRI site have been used for agriculture, livestock, or related
activities, and the amount of weed abatement (involving the use of pesticides or agricultural
chemicals) has been nominal; thus, contamination due to such sources is not expected.
While no site-specific investigation has been conducted for the ECRA site (including qualitative
surveys/testing as part of the previously described Site Investigation [Parsons 2007]), it is
assumed that similar conditions related to the potential occurrence of MD, MEC, UXO, TPH,
lead, and arsenic are potentially present. This conclusion is based on the location of the ECRA
site relative to the CTRI site and the previously described former military ranges (refer to Figure
3.5-1), as well as the partially developed/undeveloped nature of the ECRA site. The ECRA site
has not been used for agriculture, livestock, or related activities, and the amount of weed
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abatement (involving the use of pesticides or agricultural chemicals) has been nominal; thus,
contamination due to such sources is not expected.
Regulatory Framework
In California, hazards and hazardous materials are regulated extensively under federal and state
laws and regulations, which are designed to protect human health and the environment. Federal
regulations set the minimum thresholds, while state laws and regulations may be more stringent
than federal standards. The following regulations are relevant to the MD/MEC/UXO issue on
the project sites. Other non-relevant regulations pertaining to hazards and the use, transport, and
disposal of hazardous materials on the UCSD campus are summarized in Section 4.6 of the
2004 LRDP EIR.
Federal Law
The EPA is responsible for enforcement and implementation of federal laws and regulations
pertaining to hazardous materials. Applicable federal regulations are contained primarily in
Titles 29, 40, and 49 of the CFR. Management of hazardous materials is collectively governed
by the Resource Conservation and Recovery Act of 1976 (RCRA); the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA); and the
Superfund Amendments and Reauthorization Act of 1986 (SARA). The federal Hazardous
Waste Act regulates the transport of hazardous materials. A hazardous material is defined by
these laws as a substance, pollutant, or contaminant that, due to its quantity, concentration, or
physical and chemical characteristics, poses a potential hazard to human health and safety or to
the environment, if released.
These laws and associated regulations include specific
requirements for facilities that generate, use, store, treat, and/or dispose of hazardous materials.
In 1980, Congress enacted the CERCLA, commonly known as Superfund, to respond to threats
posed by uncontrolled releases of hazardous materials into the environment.
This statute,
amended by SARA in 1986, established the process for undertaking remedial actions at inactive
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waste sites containing hazardous materials, as well as reporting requirements for releases of
hazardous materials.
In 1986, Congress also established the Defense Environmental Restoration Program (DERP),
which directed the Secretary of Defense to carry out a program of environmental restoration at
facilities under the jurisdiction of the Secretary. In 1990, the EPA issued a revised National
Contingency Plan and designated the Department of Defense (DoD) as responsible for
environmental cleanup under CERCLA for properties that were formerly owned by, leased to, or
otherwise possessed by the Secretary of Defense. Those lands are referred to as Formerly Used
Defense Sites (FUDS) and the executive agent for the program is the U.S. Army. The ACOE is
the organization within the Army that manages and directs the program’s administration and
oversees the environmental cleanup procedures at FUDS on behalf of the Army. As the program
administrator on FUDS, the ACOE is responsible for developing a work plan to guide
remediation efforts for each site. All proposed remediation activities conducted under the DERP
for FUDS must be consistent with the National Contingency Plan and CERCLA. The previously
described Site Inspection was conducted as a FUDS project (No. J09CA11001).
The DoD also established the Military Munitions Response Program within the DERP in 2001.
In addition to defining the requirements for responses at its Military Munitions Response
Program sites, the DoD established a requirement to identify all locations other than operational
ranges requiring military munitions response.
Investigation of the Camp Matthews site,
including areas within the UCSD campus, was initiated in 2004 under this program
(ACOE 2005).
State Law
State regulations applicable to hazardous substances are indexed in Title 22 of the California
Code of Regulations (CCR). The California Department of Toxic Substances Control (DTSC) is
responsible for implementing RCRA on behalf of the EPA, as well as California’s own
hazardous waste laws, which are collectively referred to as the Hazardous Waste Control Law.
Both laws impose “cradle to grave” regulatory systems for handling hazardous waste in a manner
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that protects human health and the environment. The DTSC has delegated some of its authority
under the Hazardous Waste Control Law to county health departments and other Certified
Unified Program Agencies (CUPA), including the San Diego County Department of
Environmental Health (DEH).
The DTSC is authorized under the State’s Superfund statute, the Carpenter-Presley-Tanner
Hazardous Substances Account Act (the Act) (Health and Safety Code Section 25300, et seq.), to
order and/or oversee the cleanup of contaminated sites and threatened hazardous substances
releases. Under the Act, the DTSC publishes a list of hazardous substance release sites selected
for response action, known as the Cortese list. Sites that meet the listing criteria include active
sites and annual work plan sites where the DTSC is actively involved in the remediation, either
in a lead or support role. All actions carried out in response to hazardous substance releases or
threatened releases at listed sites must comply with the response action requirements of the Act.
The DTSC also considers and approves work plans for removal actions at listed sites. Any
responsible party implementing an approved work plan must submit a completion report to the
DTSC for review and approval once the removal action is fully implemented. In this case, the
ACOE is responsible for preparing and implementing the work plan for the UCSD Camp
Matthews FUDS site, and will endeavor to seek concurrence from the DTSC on the work plan.
UCSD Policy and Procedures
To address the potential for chemical and/or ordnance contamination within Camp Matthews
boundaries on the UCSD campus, performance standards are implemented to ensure proper site
assessment, analysis, and remediation of potential site contamination from former military
activities in accordance with all applicable federal, state, and local laws. These standards are
described in UCSD’s Site Development Guidelines and Procedures (i.e., guidelines and
procedures) and specifically contained in the contractor specifications for development projects
within the Camp Matthews, Camp Callan, Camp Elliott, Mount Soledad, and Nimitz Marine
Station boundaries. The guidelines and procedures outline the basic steps to consider during the
preparation of CEQA documents and for conducting construction of campus development on
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prior military lands (UCSD 2009a). The actions discussed in the guidance follow all applicable
requirements, as defined in California Health and Safety Code, Division 20, Chapter 6.8,
Section 25319.5, to determine if known or potentially hazardous substances exist at a proposed
project site which would pose a threat to public health or the environment. Key elements of the
UCSD guidance are the UCSD Soils Management Policy, PPM516-27, and Formerly Used
Defense Site Awareness Program, PPM516.27.1 (UCSD 2009a).
For projects within the Camp Matthews boundaries, UCSD will conduct a records search to
determine which, if any ranges, occur on the project site. A site assessment is then conducted,
depending on the extent of development that exists on the project site. Fully developed areas, in
which native soils have been excavated to known coordinates, re-compacted, and contain a major
built structure, receive a lower level of evaluation than partially developed and undeveloped
areas, where minimal to no grading has occurred and existing structures are minor.
The
following actions or combination of actions will be considered for each proposed project site
where a determination is made that the potential exists for UXO, MD, or MEC. The specific
action or actions to be undertaken would be determined based on the level of risk identified
during evaluation of the specific project site.
1. Magnetometer Study – to identify any subsurface, metal anomalies.
2. Soils Management Policy – to collect soil samples at an industry standard frequency for
known historical constituents.
3. Construction Support – to observe grading operations using a certified UXO technician
for depths at which UXO may be found.
4. FUDS Awareness Program – to raise awareness for UCSD staff and contractors working
within the defined Camp Matthews boundaries.
5. Restrictions on soil export, import, and reuse.
The Soils Management Policy consists of collecting soil samples in accordance with industrystandard guidelines, analyzing samples for MEC using EPA-approved methods, and reporting
the results as part of the project geotechnical investigation. Regulatory approved sampling
protocol, employed by an independent contractor with a Registered Geologist on staff, produces
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quantitative results.
Section 3.5
Hazards and Hazardous Materials
For qualitative measurements, UCSD Environmental Health & Safety
(EH&S) Department staff may collect soil samples using EPA-approved methods.
Any
detection of explosives or California Toxic Metals will be addressed and may be submitted to the
ACOE and the DTSC for further discussion. Detections of petroleum hydrocarbons may be
submitted to the RWQCB depending on the final disposition of the soils.
Field and analytical results produced during the site evaluation stage will be compared to the
ACOE screening criteria, with any observations in excess of the screening criteria addressed by
EH&S on a case-by-case basis to assess risk to human health and the environment.
If a
determination is made during the site evaluation process that there is the potential for UXO or
MEC on site, construction support will be discussed with the ACOE or a qualified UXO
contractor.
Otherwise, precautions will be taken as outlined in the FUDS Awareness Program, which
instructs people to not touch any suspected munitions-like objects and requests that people call
campus police with a description of the debris. UCSD authorities would then close off or
temporarily guard the area to eliminate chance encounters until the proper removal procedures
are implemented.
UCSD also implements a number of policies related to the routine use, storage and disposal of
hazardous materials associated with activities such as medical services and research efforts. A
summary of hazardous material categories and typical applications for hazardous material use
and disposal on campus is provided in Tables 4.6-1 and 4.6-2 of the LRDP EIR (UCSD 2004b),
with similar materials anticipated to be used at the CTRI facility. Hazardous material use at the
ECRA site would be limited to construction-related materials (e.g., vehicle fuels), as well as
landscaping chemicals (e.g., pesticides/herbicides). Specific UCSD policies related to hazardous
material use, as described in the 2004 LRDP EIR, include the campus-wide Emergency
Management Plan (EMP, UCSD 2009a) and Hazardous Materials Business Plan (HMBP). The
County of San Diego Department of Environmental Health Unified Program Facility Permit for
the UCSD Main Campus is #HK07-102535. This permit includes the HMBP requirements
found in California Health and Safety Code Division 20 Chapter 6.95. The EMP addresses
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planned responses to emergency situations within the campus, including hazardous material
spills. The focus of this plan is to decentralize the organization for on-campus emergency
response, with the campus divided into a number of small emergency response regions. Each
region includes appropriate materials and personnel to provide initial response after an
emergency event, with subsequent coordination with the main campus Emergency Operations
Center to provide additional direction. The UCSD HMBP has been prepared and implemented
pursuant to applicable State and County requirements, and includes pertinent information
regarding the location of campus facilities that use/store hazardous materials, as well as related
(and required) employee training and emergency response procedures.
Additional UCSD policies/programs regarding hazardous material use, storage and disposal are
associated with Occupational Safety and Health Administration (OSHA) and California OSHA
(Cal-OSHA) requirements for workplace and employee safety, and include the UCSD Health
and Safety Policy, Safety Committees, Laboratory Safety Plan, Biosafety Handbook, Radiation
Safety Manual, and Laser Safety Manual. All of these policies, plans and programs are intended
to provide guidance for safe practices related to hazardous materials/activities at UCSD.
Specific elements include requirements for appropriate containment/secondary containment of
hazardous materials, as well as emergency spill-response procedures such as provision/
maintenance of emergency response directions, fire extinguishers, spill kits, safety showers/
eyewashes and first-aid kits (with additional description provided in Section 4.6.1.6 of the 2004
LRDP EIR).
UCSD also supports an Emergency Response Team (ERT) that is on duty 24 hour a day and
7 days a week. The ERT responds to approximately 300 calls per year, involving incidents such
as small chemical spills and identification of chemicals in campus laboratories. The rapid
response capability provided by the UCSD ERT allows the successful resolution of most minor
on-campus incidents involving hazardous materials, and reduces the associated requirements for
911 emergency services from the City of San Diego (refer to Section 3.7, Public Services, for
additional information).
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Hazards and Hazardous Materials
3.5.2 Thresholds of Significance
Significance thresholds from Appendix G of the state CEQA Guidelines are identified for
hazards and hazardous materials issues in the 2004 LRDP EIR. A significant adverse impact is
identified in this project-specific analysis if the proposed project would result in any of the
following:
(1) Create a significant hazard to the public or the environment through reasonably
foreseeable upset and accident conditions involving the release of hazardous materials
into the environment;
(2) Activities located on a site which is included on a list of hazardous materials sites
compiled pursuant to Government Code Section 65962.5 and would create a significant
hazard to the public or the environment; or
(3) Impair implementation of or physically interfere with an adopted emergency response
plan or emergency evacuation plan.
3.5.3 Environmental Impacts and Mitigation
Hazards and Hazardous Materials Issues 1 and 2 Summary
Would implementation of the proposed project result in the release of hazardous materials into
the environment through reasonably foreseeable accidents or result in activities located on a
listed hazardous materials site creating a significant hazard to the public or environment?
Impact: Project construction could encounter
MEC (i.e., lead and arsenic) and MD associated
with historic small arms training at Camp
Matthews, as well contamination from diesel fuel
Mitigation: 2004 LRDP
Measures Haz 4B and Haz 4C
Significance
significant
Significance After Mitigation: Less than
significant
Before
Mitigation:
Potentially
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Impact Analysis
Pursuant to 2004 LRDP EIR Mitigation Measure Haz-4B, an assessment of potential hazards has
been performed by the UCSD EH&S Department for the main CTRI project site during the
project planning phase since the project sites, along with other properties on the East and West
Campuses of UCSD, are listed on the DTSC Cortese List as the UCSD Camp Matthews site.
Based on the previously described Site Assessment (Parsons 2007) and site-specific evaluations
(HGL 2011; GDC 2010a; GDC 2010b), development of the CTRI site (excluding the ECUP) and
ECRA site would disturb areas that have the potential to contain MD, MEC (i.e., lead and
arsenic), and/or UXO due to historic small arms military training activities at Camp Matthews, as
well as soils contaminated with TPH (as diesel fuel). Observed levels of on-site contaminants
including TPH (as diesel fuel), lead, and arsenic were determined to be above the associated
human health screening levels, and are considered potential environmental conditions requiring
remediation.
In addition to potential impacts caused by on-site soil contamination, a site-specific investigation
was conducted at the main CTRI site to further assess potential hazards related to the potential
occurrence of MD and UXO. While no MD or UXO items were discovered on the surface or
specifically detected at depth, numerous magnetic anomalies were observed (HGL 2011).
Accordingly, the investigation concluded that surface and subsurface MD items could potentially
be present, and recommended associated monitoring during site excavation (HGL 2011). Similar
recommendations would be extended to the ECRA site because of its location relative to the
CTRI site and the previously described former military ranges (refer to Figure 3.5-1). Because
of the extent of possible contamination related to past use of the project sites for military training
operations, UCSD is in contact with the ACOE to have the ACOE assist in overseeing and
implementing soil clean-up activities during project construction (UCSD 2011a).
Based on the above discussion, the potential exists for the occurrence of contaminants at the
CTRI and ECRA sites that could result in significant impact related to the release of hazardous
materials and disturbance of a known hazardous materials site during project development.
Specifically, this includes MD, MEC, UXO, TPH, lead, and arsenic, as well as any additional,
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currently unknown, contaminates that may potentially be present at one or both sites. Minimum
standards for the management of soil excavated from the CTRI and ECRA sites are contained in
the San Diego Regional Water Quality Control Board Conditional Waiver No. 8 Discharges of
Solid Wastes to Land (RWQCB 2008). According to the Site Development Guidelines and
Procedures, “the appropriate application must be submitted to RWQCB, and approval must be
received (a three-month process at minimum) prior to any further disposition of the soils. This
applies to on-site and off-site locations where contaminated soil is deposited.”
The noted conditions would be addressed through implementation of mitigation measures Haz-4B
and Haz-4C from the 2004 LRDP EIR (UCSD 2004b), discussed below, and the implementation
of proper remediation techniques as overseen and possibly implemented by the ACOE or an
ACOE contractor. These measures require that removal and/or remediation of all contaminants
that may potentially pose a risk to human health or the environment be completed prior to
construction, and pursuant to all applicable regulations.
Specifically, this would include
appropriate evaluation, categorization, and use/disposal of on-site soils, pursuant to the previously
described UCSD Site Development Guidelines and Procedures (2011b) that will be included in the
contractor specifications for the CTRI and ECRA project.
Pursuant to UCSD procedures, the ACOE has been engaged to provide assistance to the campus
during the remediation effort. Several options are being considered for the remediation effort,
including off-site and/or on-site treatment by the ACOE (or a qualified ACOE contractor). The
ACOE contractor would provide ACOE with UXO support for the areas in which excavation for
the projects would be performed. Initially the ACOE contractor would walk the sites and
perform a visual survey of the areas UCSD has defined for building construction. The ACOE
contractor would also provide support during the excavation phase of the project. Prior to
excavating the soil in the areas proposed for construction, the ACOE contractor would perform a
site characterization to identify the locations of lead-contaminated soil. Site characterization
would include further sampling and analysis of project soils to determine the nature and extent of
contamination. Depending on the concentration of lead in the soil, UCSD may be able to reuse
some of the soil on site.
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The proposed method to address the lead-contaminated soil is to mechanically separate any
metallic debris, followed by chemical treatment to stabilize the lead in the soil and render it nonhazardous. The treatment technology of interest relies on the chemistry of the lead and its
reaction with treatment chemicals that can be mixed with the lead-bearing soil either in place, or
when the material is excavated. Options include off-site disposal or on-site placement depending
on whether or not the concentration of lead triggers California or RCRA hazardous waste rules.
An alternative method, such as excavating the material and transporting to a permitted facility
for disposal, may also be employed. The final determination on treatment methodology would
be made in consultation with UCSD.
In addition, as part of the described LRDP EIR mitigation measures and related UCSD policies, the
project contractor(s) would be provided in their specifications from UCSD the FUDS Awareness
Program to make sure they are aware of the UCSD procedures in the event that MD/UXO/MEC is
inadvertently encountered. In the event that such items are encountered during construction of the
proposed project, UCSD procedures would prevent risks to humans or the environment.
Specifically, the contractor(s) would immediately contact UCSD campus police and EH&S staff in
accordance with UCSD policies described above. Depending on the material encountered, EH&S
may contact the ACOE, implement construction support, and/or contact the San Diego Bomb
Squad. Examples of construction support include the implementation of engineering controls to
prevent health and environmental exposure and detonation of any UXO, disposal of any inert
materials unearthed during project construction, and visual monitoring/inspection during project
grading/excavation operations as recommended in the HGL investigation (HGL 2011).
If
MD/MEC/UXO items are observed during construction support operations, project construction
would be temporarily suspended and a qualified technician would direct removal action procedures
and safety precautions in accordance with established procedures. All procedures for dealing with
MD/UXO/MEC issues would be accomplished in accordance with the ACOE’s Basic Safety
Concepts and Considerations for Ordnance and Explosives Operations (ACOE 2004). Grading
would not proceed until the site was cleared or deemed safe to resume construction activities.
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With implementation of the above efforts as part of, and in conformance with, mitigation
measures Haz-4B and Haz-4C from the 2004 LRDP EIR and contractor specifications, potential
project-related impacts from the release of hazardous materials would be less than significant.
Mitigation Measures
During construction of the CTRI and ECRA projects, implementation of following LRDP
mitigation measures, combined with the UCSD Site Development Guidelines and Procedures
that will be included with the contractor specifications, will reduce project impacts related to the
potential release of hazardous materials to below a level of significance:
Haz-4B
If contamination exists on a proposed project site and if it poses a risk to human
health or the environment, actions shall be taken prior to any construction, pursuant to
applicable regulations, to remove or otherwise remediate the contamination through
appropriate measures such as natural attenuation, active remediation, and engineering
controls. Assessment and remediation activities shall incorporate the following
conditions:
i. All assessment and remediation activities shall be conducted in accordance with a
work plan which is approved by the regulatory agency having oversight of the
activities.
ii. It may be necessary to excavate existing soil within the project site, or to bring fill
soils into the site from off-site locations. At sites that have been identified as
being contaminated or where soil contamination is suspected, appropriate
sampling is required prior to disposal of excavated soil. Contaminated soil shall
be properly disposed at an approved off-site facility. Fill soils also shall be
sampled to ensure that imported soil parameters are within acceptable levels.
iii. Caution shall be taken during excavation activities near existing groundwater
monitoring wells, so that they are not damaged. Existing groundwater monitoring
wells may have to be abandoned and reinstalled if they are located in an area that
is undergoing redevelopment.
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Section 3.5
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In the event that USTs, not identified in consultation with EH&S, or undocumented
areas of contamination are encountered during construction or redevelopment
activities, work shall be discontinued until appropriate health and safety procedures
are implemented. Either the DEH or the RWQCB, depending on the nature of the
contamination, must be notified regarding the contamination.
Each agency and
program within the respective agency has its own mechanism for initiating an
investigation. The appropriate program (e.g., the DEH Local Oversight Program for
tank release cases, the DEH Voluntary Assistance Program for non-tank release
cases, the RWQCB for non-tank cases involving groundwater contamination) will be
selected based on the nature of the contamination identified. The contamination
remediation and removal activities will be conducted in accordance with pertinent
regulatory guidelines, under the oversight of the appropriate regulatory agency.
Hazards and Hazardous Materials Issue 3 Summary
Would implementation of the proposed project impair implementation of or physically interfere
with an adopted emergency response plan or emergency evacuation plan?
Impact: Construction of the proposed CTRI
project could require temporary lane closure(s)
on Medical Center Drive North during
associated roadway widening activities.
Mitigation: 2004 LRDP EIR Mitigation Measure
Haz-6A
Significance Before Mitigation: Potentially
significant
Significance
significant
After
Mitigation:
Less
than
Impact Analysis
Construction of the CTRI facility would primarily occur on site in an area that is set back from
adjacent roadways, although the proposed widening of Medical Center Drive North would
require temporary lane closure(s) along this roadway. While facilities located along Medical
Center Drive North (including hospital facilities) typically use this road (along with other
segments of Medical Center Drive) for access from main/local roadways (e.g., Voigt Drive),
alternative routes are available. Specifically, access to facilities along Medical Center Drive
North can be accessed by other local roadway combinations, including Campus Point Drive and
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Medical Center Drive East, South and West (refer to Figure 2-1). Accordingly, while alternative
access would be available as described, the potential exists that project construction could
temporarily impact emergency evacuation routes in the project area. Under current campus
procedures, multiple emergency access or evacuation routes are provided to ensure emergency
response services are not impaired or interfered with in the event of a temporary roadway closure
and/or changes in campus traffic patterns. The potential for significant impacts exists, however,
because of the proximity of Medical Center Drive North to critical care facilities such as
Thornton Hospital. Emergency room access, taken from Campus Point Drive/Medical Center
Drive, would be maintained at all times during proposed construction at the CTRI site.
Construction of the ECRA facility would not entail any associated road or lane closures, with no
related impacts to emergency response or evacuation plans.
Mitigation Measures
LRDP Mitigation Measure Haz-6A would be implemented to ensure that impacts to emergency
evacuation routes during construction of the CTRI project are less than significant.
Haz-6A
In the event that the construction of a project requires a lane or roadway closure,
prior to construction the contractor and/or Facilities Design and Construction
(FD&C) shall ensure that the UCSD Director of Fire and Life Safety is notified. If
determined necessary by the UCSD Director of Fire and Life Safety, local
emergency services will be notified of the closure by the Director of Fire and Life
Safety.
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3.5.4 Cumulative Impacts and Mitigation
Hazards and Hazardous Materials Cumulative Issue Summary
Would implementation of the proposed project have a cumulatively considerable
contribution to a cumulative hazards and hazardous materials impact considering
past, present, and probable future projects?
Cumulative Impact
Significance
Project Contribution
Exposure of people and structures to
wildland fires.
Less than significant
Not cumulatively considerable
Cumulative impacts associated with hazards and hazardous materials are discussed in Section
4.6.4 of the 2004 LRDP EIR. The proposed CTRI and ECRA projects are consistent with the
2004 LRDP, as stated in Section 2.0 of this Tiered EIR; therefore, its cumulative impacts were
accounted for in the 2004 LRDP EIR. The 2004 LRDP EIR concluded that impacts associated
with hazards or hazardous materials are site-specific conditions that would not result in
cumulative impacts and LRDP implementation would not contribute considerably to those
impacts. Cumulatively significant wildland fire hazard impacts were identified; however, the
LRDP’s contribution was not considerable.
With regard to wildfire hazard, both the City and the campus have policies to manage fire risk.
According to the 2004 LRDP EIR, however, residents and structures will continue to be at risk
due to the regional potential for wildland fires that exists. For this reason, the 2004 LRDP
concluded that there is the potential for significant wildland fire hazard as the region experiences
increased development.
Campus development, including the proposed project, would not
contribute considerably to the risk of wildland fires because it would not occur in areas prone to
wildfires and would not create a new development edge near wildfire-prone areas. The campus
is in an urbanized area and does not interface with large expanses of undeveloped land from
which wildfires can spread. In addition, the project design will be reviewed by the campus Fire
Marshall to ensure that fire prevention measures, such as fire hydrants, sprinkler systems and
other features, have been properly integrated into the design to minimize risk. The campus
would also continue to implement the UCSD Emergency Operations Plan (UCSD 2009a) and
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campus-wide fire-prevention programs, which are mandated by state and federal law. As such,
the proposed project would not contribute considerably to this cumulatively significant impact
(refer to Section 3.7 of this Tiered EIR for additional discussion of fire hazards).
3.5.5 CEQA Checklist Items Adequately Addressed in the 2004 LRDP EIR
The following evaluation provides a discussion of those CEQA issues that were adequately
addressed in the 2004 LRDP EIR, and therefore do not require further analysis in this Tiered
EIR. The significance criteria referred to in this analysis are taken from Appendix G of the State
CEQA Guidelines, which were used in the 2004 LRDP EIR.
Would implementation of the proposed project result in a significant hazard to the public
or the environment through the routine transport, use or disposal of hazardous materials?
The UCSD campus is registered with the EPA as a large-quantity generator of chemical
hazardous waste, but the disposal of such wastes does not take place on campus. A detailed
discussion of the types and quantities of hazardous materials and wastes used at and generated by
UCSD is provided in Section 4.6.1.1 in the 2004 LRDP EIR (specifically Tables 4.6-1 and
4.6-2). The campus contracts with licensed hazardous waste transporters to ensure that all
hazardous wastes generated by the campus are transported off campus for treatment or disposal
at licensed hazardous waste facilities. Although the proposed CTRI project would involve the
transport, use, and disposal of standard types of research-related hazardous materials (as
previously discussed), it is an addition to an existing medical center/research complex (i.e., the
East Campus Medical Center), and would not introduce new or additional hazardous materials
beyond those already in use. The ECUP portion of the CTRI project would not require the
installation of underground storage tanks (USTs), although the proposed new ECUP facilities
would utilize existing USTs to provide diesel fuel for equipment (potentially including a
1,500-kW, 12-kV emergency generator). In addition, the proposed project (including both the
CTRI and ECRA sites) could include activities associated with hazardous materials during
general maintenance, landscaping, and construction. UCSD would continue to require
compliance with safety regulations, guidelines, and policies applicable to all hazardous materials
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associated with the project during activities including vehicle/equipment fueling, maintenance,
landscaping, and construction. As a result, the project’s contribution to the amount and type of
hazardous materials handled on campus and transported to/from campus would not be
substantial, due to the type of uses proposed and the procedures already in place to address the
use, disposal, and transport of such materials.
With regard to hazardous materials or waste potentially generated during construction, no
buildings would be demolished as part of the project, although pavement and other minor
structures would be demolished to make way for the proposed development. Based on these
conditions and the recent age of asphalt and concrete paving materials to be removed, there is
little to no potential to encounter hazardous chemicals, lead-based paints, mercury or asbestoscontaining materials (ACM) during demolition activities. Therefore, no special treatment or
remediation activities would be required. Where soil would be excavated or fill material placed
on site, UCSD and its contractors would follow the Site Development Guidelines and Procedures
(UCSD 2009a) implemented by the campus which provide specific soil export/import and
relocation guidelines that require soils to be clear of harmful contamination, as approved by
EH&S staff. In the event that soil contamination is encountered during construction, appropriate
health and safety procedures would be implemented in accordance with all applicable laws.
Therefore, potential impacts from the transport, use, and disposal of hazardous materials during
proposed project construction would be less than significant.
Would implementation of the proposed project result in activities that emit hazardous
emissions or handle hazardous materials within one-quarter mile of an existing or proposed
school?
The proposed ECRA project would not entail the handling of hazardous materials or the
generation of hazardous emission, with no associated impacts to existing or proposed schools.
While the proposed CTRI project would require the handling of hazardous materials as
described, no proposed facilities/operations would entail hazardous emissions. No schools exist
within one-quarter mile of the CTRI project site, with the closest schools including: (1) the
Preuss School UCSD, located on campus approximately 0.3 mile northeast of the CTRI site; and
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(2) La Jolla Country Day School, located off campus approximately 0.6 mile east of the CTRI
site. Based on the described conditions, no hazardous emissions would be produced or materials
handled in large quantities within one-quarter mile of any schools, with associated projectrelated impacts less than significant.
Would implementation of the proposed project result in an aircraft safety hazard?
The campus is not located within two miles of a public airport, public use airport, or private
airstrip, but it is located within approximately two miles of Marine Corps Air Station (MCAS)
Miramar. The DoD has established Accident Potential Zones (APZs) for MCAS Miramar,
which define the areas that would be more likely to be affected by aircraft accidents. UCSD,
including the project site, is not located within any APZs for MCAS Miramar. Therefore,
development of the campus under the 2004 LRDP, including the proposed project, is not
anticipated to increase aircraft safety hazards.
Would implementation of the proposed project expose people or structures to a significant risk
of loss, injury or death involving wildland fires?
The coastal influence on temperature and humidity is important in determining the frequency of
critical fire weather in San Diego County. Generally speaking, structures west of I-5 (where
most of the campus lies) are rated lower in terms of fire hazard severity due to favorable
geographic proximity to the coast, as compared to locations further east where the potential for
fire hazard jumps up quickly. Although on the east side of I-5, the project sites are located
immediately east of the freeway and are still within favorable geographic proximity to the coast.
Nevertheless, the UCSD campus, and the project sites specifically, feature open space containing
vegetation that could be susceptible to wildland fires. Studies of the campus fire risk determined
that there are very few areas on campus exposed to a high life-safety or property-loss risk due to
wildfires. Specifically, these areas include: (1) the Campus Services Complex off of Voigt Drive
(west of I-5); (2) Che Café/Revelle Provost Office off of Scholars Drive; (3) Pepper Canyon
vicinity near Gilman Drive (north of Villa La Jolla Drive); (4) Marshall College Apartments; and
(5) Seaweed Canyon area in the SIO portion of campus (UCSD 2004b). These areas have been
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identified as higher risk primarily as a result of their proximity to parklands and/or older woodframed construction buildings.
The project sites are located adjacent and in proximity to
undeveloped canyons containing natural vegetation, but are not located in any of the fire-prone
areas specifically identified above.
The proposed CTRI project, like all new buildings on campus, would include sprinklers and would
maintain the existing appropriate access/egress routes for fire fighting and evacuation, as described
in Section 2.0 of this Tiered EIR. The campus Director of Fire and Life Safety is responsible for
campus-wide fire prevention and provision of services such as plan review and construction
inspections to ensure conformance with California building and fire codes, and would be
responsible for reviewing and approving plans for this project. The UCSD Director of Fire and Life
Safety meets regularly with the City of San Diego Deputy Fire Chief to maintain a site plan/access
plan which will adequately serve the campus. The proposed project would comply with all fire
safety regulations and code requirements to ensure that the potential for wildland fires is less than
significant. Refer to the Section 3.7 of this Tiered EIR for additional details.
3.5.6 References
Group Delta Consultants (GDC).
2010a.
Environmental Soils Testing UCSD Clinical and Translational Research Institute,
La Jolla, California. November 19.
2010b.
Geotechnical Investigation Clinical and Translational Research Institute, La Jolla,
California. December 3.
HydroGeoLogic, Inc (HGL).
2011.
Summary of Munitions and Explosives of Concern (MEC)/Unexploded Ordnance
(UXO) Construction Support Fieldwork for Soils Sampling and Testing for 4466
CTRI. March 30.
Kyle Consulting.
2004.
A Cultural Resource Inventory Update and Recommendations for the University of
California at San Diego and Scripps Institution of Oceanography. Prepared by
Kyle Consulting for HELIX Environmental Planning, Inc. April.
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Parsons.
2007.
Final Site Inspection Report, Former Camp Calvin B. Matthews Site, La Jolla, CA,
September.
Phillips, Roxana.
1998.
Review of a History of U.S. Army Camp Robert E. Callan and U.S. Marine Corps
Camp Calvin B. Matthews.
Unpublished report on file at the South Coastal
Information Center, San Diego State University. September.
Regional Water Quality Control Board (RWQCB).
2008.
General Conditional Waiver 8 – Discharges of Solid Wastes to Land. Available at:
http://www.waterboards.ca.gov/sandiego/board_decisions/waivers/docs/
University of California, San Diego (UCSD).
2011a.
Personal communication between Mr. Brad Werdick, UCSD Director of Physical
and Community Planning; and Mr. Trent Simpler E.I. Project Manager, SPA-PMME, US Army Corps of Engineers. August.
2011b.
Site Development Guidelines and Procedures for University of California, San
Diego. August.
2009a.
UCSD Emergency Operations Plan.
Available at: http://www-bfs.ucsd.edu/
emerg/ucsdemp.htm
2004a.
Long Range Development Plan. September.
2004b.
Long Range Development Plan Environmental Impact Report.
September.
U.S. Army Corps of Engineers (ACOE).
2005.
Preliminary Assessment, Camp Calvin B. Matthews. March.
2004.
Basic Safety Concepts and Considerations for Ordnance and Explosives
Operations.
1999.
Inventory Project Report (INPR), University of California at San Diego (Formerly
Camp Matthews), La Jolla, CA, Site No. J09CA1110. August 17.
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