TOSC Comments on Draft Environmental Impact
Report for the New South Coast County Golf Course Project
Chapter
3: Environmental Setting, Impacts and Mitigation Measures
B. Air
Quality
General – The project should adhere to newly promulgated standards
for particulate matter intended to protect sensitive receptors such as children and
the elderly since the project setting is in such close proximity (within one quarter
mile) to at least 10 schools and day care centers and over 1,000 single family residences.
That would mean that there should be no exceedances of the 24 hour maximum concentration
of 50µg/m3 and an annual average of 20µg/m3 for PM10. The PM2.5 standard remained
unchanged at 12µg/m3.
Impact 3B2: According to the DEIR project construction
and operation would result in the emission of criteria pollutants. Estimated nitrogen
oxides and particulate matter emissions would exceed air quality significance criteria.
The project would result in emission of 446 lbs/day of nitrogen oxides and nearly
4,600 lbs/day of PM10. Significance criteria for these pollutants are 100 lbs/day
and 150 lbs/day respectively. Despite mitigation measures there will be significant
unavoidable impacts during construction. These impacts are noted in the DEIR but
no risk assessment has been done to estimate the potential impact to human health,
particularly to the health of sensitive receptors such as children and the elderly.
In addition, it appears that previous risk assessments for the landfill have been
based on a gas collection efficiency of 95%. What is the basis for such high estimated
collection efficiency? If this is overestimated, what is effect on previous risk
estimates?
E. Geology
General – Due to the proximity to the
Palos Verdes Fault it would be wise to conduct the seismic study prior to project
approval. Ensuring the safety of nearby residents and children attending the schools
and day care facilities should be of paramount importance.
Similarly, the
slope stability study should also be conducted prior to project approval in order
to protect residents and children who spend so much time near the landfill. This
is particularly important since the project will include placement of a geotextile
liner and 220,000 cubic yards of fill material on top of the existing cover.
Existing
Cap: How will cap integrity be assured with the placement of the geotextile and
fill (3E-13)? How will project proponents prevent hazardous waste exposures?
Extent
of Refuse: The extent of refuse material, especially the hazardous waste, must be
determined prior to project approval. This is necessary to ensure proper maintenance
of the existing cap and to prevent hazardous waste exposures.
Irrigation rates:
These rates are theoretical and must be verified in the field. Actual application
rates are likely to be different and possibly higher.
Impact 3E3: The impact
of the project may potentially be catastrophic in the event of slope failure. Again,
slope stability and seismic evaluations should take place prior to project approval.
Impact
3E5: The impact of continued settlement may also be significant. It is possible
that settlement of the landfill may occur beneath the geotextile layer and added
fill without cracking at the surface. This could result in releases of VOCs and
potential human exposures since the cracking will not be visible at the surface.
How will this potential impact be addressed?
Impact 3E7: Who is responsible
for design of the new equestrian facility? Who will ensure that the facility is
designed to withstand anticipated settlement of the landfill and existing cover materials?
Will gas collection occur at the new equestrian center.
F. Hazards and Hazardous
Materials
General – The LACSD should wait for the outcome of the DTSC five
year review to ascertain if there are regulatory concerns about redevelopment of
this closed hazardous waste landfill. Due to the proximity of schools, day care
facilities, and residences it would be wise to ensure that the current status of
the cap and groundwater control systems are thoroughly evaluated. Any agency recommendations
for improvement of these systems should be implemented prior to construction activities.
VOC Emissions (3F-5) – Please explain the statistical methods and data used
to compare landfill VOC emissions to those of the ambient air. Why is this method
of comparison valid?
What evidence supports the contention that
the landfill gas collection system controls off-site migration? Would the South
Coast Air Quality Management District and DTSC support this contention?
Metals
(3F-9) – What are typical soils? What are typical metals concentrations? Typical
of what?
VOCs – What would be the source of tap water in runoff from the landfill?
While these chemicals are byproducts of chlorination, they were also widely used
in industrial applications and may have been disposed of in the landfill.
Semi-volatile
organic compounds (SVOCs) – What statistical methods and data were used to compare
background and downgradient samples? Why is this method of comparison valid?
Hydrocarbons (3F-11) – Please explain the rationale for excluding the 18
samples affected by landfill gas. These samples would appear to be representative
of existing landfill conditions and should therefore be included in any evaluation
of the nature and extent of contamination.
If VOC detections were not related
to the landfill, please explain their origin.
Please describe the hydrocarbon
distribution pattern mentioned on 3F-13.
What is the detection frequency for
pesticides and SVOCs? Does DTSC agree with this statement? Were these chemicals
disposed of in the landfill?
How will the Districts address off-site migration
of arsenic in groundwater?
Please explain this statement from 3F-17: In the
baseline risk assessment, risk associated with exposure to a small area of soil contamination
accounted for over 90% of the total risk to an on-site worker and future recreational
visitor. Does DTSC agree with this statement?
Where is the decrease in landfill
gas emissions (3F-18) documented?
What is the basis for assuming 95% gas collection
efficiency in the reasonable maximum exposure? This seems unrealistically efficient.
Why are different collection efficiencies assumed in the risk assessment and DEIR?
These should be consistent in order to allow for reasonable comparisons of exposures.
This is especially important if 90% of the cancer risk to off-site residents derives
from landfill gas emissions as stated in the DEIR.
Why is there such a dramatic
difference between the amount of hazardous waste generated in 2001 (a non-reporting
year) and 2002 (a reporting year) (3F-24)? What is the clarifier referred to on
page 3F-24?
Golf Course Chemical Studies
Please describe the
water quality management plan referred to on 3F-28 and 3f-30. How will this plan
ensure that surface water quality does not suffer?
What are the BMPs (Best
Management Practices) for golf courses? How will the operators ensure adherence
to these practices?
Residual Impacts
Impact 3F3: Construction
impacts must be factored into the proposed project and all risks assessed prior to
project approval.
Impact 3F4: Repairs to the cover and gas collection systems
will likely require HAZMAT certified workers due to the potential for exposure to
hazardous substances. How will this requirement be addressed?
G.
Hydrology and Water Quality
Surface Water Quality – Samples referred to in
the DEIR were last collected in March 1994. These results are now nearly 10 years
old. Do more recent data support the conclusion that the landfill does not affect
surface water quality? How are these data analyzed to evaluate this?
Groundwater
Quality – Groundwater contamination from the landfill appears to have migrated off-site.
Arsenic concentrations currently exceed federal Maximum Contaminant Levels. The
presence of arsenic at increasing concentrations is likely indicative of inadequate
hydraulic control of groundwater in the vicinity of Hawthorne Blvd. This gives cause
for concern about the burden of an addition of 220,000 cubic yards of soil and its
affect on the landfill cover and underlying wastes.
Project Impacts – This
section does not describe impacts of the golf course construction. How will these
impacts be accounted for and mitigated? How will differential settlement of the
geotextile/soil cover system affect surface and groundwater quality? What are the
specific BMPs necessary to minimize surface water impacts? What are the specific
Treatment Control BMP design standards cited on page 3G-13?
3I.
Noise
Mitigation Measure M-3I.1 – Who performs the sound level measurements?
Who decides when the acoustical barrier along the southwest boundary of the golf
course will be necessary? What say will residents have in this decision?
Impact
3I-2: Why should unavoidable noise impacts be acceptable to the public during construction
of the course?
Mitigation Measure 3I-8 and 3I-9: These measures appear to
be inadequate to mitigate the effects of ground borne noise and vibration. What
other measures can be implemented to more effectively mitigate the impacts?