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<br />Mitigation Measure HAZ-1 requires that a qualified consultant prepare a Soil Management Plan (SMP) to be used by <br />construction workers to remove and dispose of the areas of arsenic impacted soil. Mitigation Measure HAZ-1 requires <br />excavation of contaminated soils be completed pursuant to existing DTSC and RWQCB requirements, soils sampling <br />ensure all contaminated soils are removed, and that a certified hazardous waste hauler remove and transport all <br />arsenic impacted soil and other potentially hazardous materials per California Hazardous Waste Regulations to a <br />landfill permitted by the state to accept hazardous materials. Excavated soil containing hazardous substances would <br />be classified as a hazardous waste if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity <br />(CCR, Title 22, Division 4.5, Chapter 11, Article 3). The SMP would detail hazardous materials excavation and <br />disposal methods and requirements pursuant to the regulation of Title 8 of the California Code of Regulations <br />(CalOSHA) and DTSC that regulates the removal, transportation, and disposal of hazardous waste to protect human <br />health and the environment. The EIR determined that with implementation of Mitigation Measure Haz-1, impacts <br />related to hazards of the onsite contaminated soils would be less than significant. <br /> <br />Comparison of Impacts Associated with the Proposed Modified Project <br />Consistent with Original Project, the Modified Project would also involve demolition, excavation, and grading activities <br />that would disturb existing hazardous materials on the site. However, the subterranean parking for the Modified <br />Project would be 13,300 square feet smaller than the subterranean parking for the Original Project. Thus, less <br />excavation would occur, and no potentially increased impacts related to hazardous materials in excavation soils would <br />occur. The Modified Project would be required to implement Mitigation Measure HAZ-1, which would ensure that <br />excavation and disposal of contaminated soils and other potentially hazardous materials be completed pursuant to <br />existing DTSC, RWQCB, CalOSHA, and other applicable requirements that would reduce potential impacts to humans <br />and/or the environment from release of hazardous materials. With implementation of Mitigation Measure HAZ-1, <br />impacts related to hazards of the onsite contaminated soils from construction of the Modified Project would be less <br />than significant. No new or greater impacts related to hazards and hazardous materials would occur from <br />implementation of the Modified Project. <br /> Conclusion for Hazards and Hazardous Materials <br />Consistent with the Original Project, the Modified Project would involve handling of hazardous materials and <br />implementation of Mitigation Measure HAZ-1, which would reduce potential impacts to a less than significant level <br />such that no new or greater impacts related to hazardous materials would occur. Based on the foregoing, none of the <br />conditions identified in CEQA Guidelines Section 15088.5 that would trigger the need to prepare a recirculated EIR or <br />other environmental document exist. The Modified Project would not result in either a new significant environmental <br />impact or a substantial increase in the severity of a previously identified impact. <br /> <br />EIR Mitigation Measure <br />Mitigation Measure HAZ-1: Prior to issuance of a grading permit, a Soil Management Plan (SMP) shall be prepared <br />by a qualified hazardous materials consultant and shall detail procedures and protocols for excavation and disposal of <br />onsite hazardous materials, including: <br />• A certified hazardous waste hauler shall remove all potentially hazardous soils. Excavation of contaminated <br />soils shall be to the depth of approximately 0.5 feet below the existing ground surface in areas identified as <br />having arsenic impacted soils. In addition, sampling of soil shall be conducted during excavation to ensure <br />that all arsenic impacted soils are removed, and that residential Environmental Screening Levels (ESLs) for <br />residential uses are not exceeded. Excavated materials shall be transported per California Hazardous Waste <br />Regulations to a landfill permitted by the state to accept hazardous materials. <br />• Any subsurface materials exposed during construction activities that appear suspect of contamination, either <br />from visual staining or suspect odors, shall require immediate cessation of excavation activities. Soils <br />suspected of contamination shall be tested for potential contamination. If contamination is found to be <br />2-154