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Home My WebLink AboutWTR XFER STATION 09-21-81DATE: TO: FROM: SUBJECT: September 21, 1981 Inter-Com William Huston, City Manager Mike Brotemarkle, Community Development Director County of Orange, Class I Industrial Waster Transfer Station Draft Environmental Impact Report 269 Circulation of the draft EIR starts the County process to consider development of such a facility. The City has until October 19, 1981 to respond with its concerns to this draft. A proposed final EIR would then be prepared and a County Planning Commission hearing scheduled. A Final EIR would have to be "Certified Complete" before further action. Attached is a copy of the Executive Summary and pertinent, graphics summarizing the EIR along with an analysis of potential areas of weakness in the.environmental document. I have included previous staff communications to the County expressing concerns which arose during preparation of the County's environmental document. Specific attention should be paid to the letter of Mr. Kenneth K. Hekimian, Ph.D. of Van Dorpe and Associates who is a recognized expert, consultant and university instructor in the field of waste disposal. Major points which should be pursued due to inadequate addressment in the draft EIR include: I. Land Use A. Will ultimately impact far greater number of persons than other sites. Site 17 has commenced construction of 83,132 square feet of new industrial condos and to the southwest a new industrial development of 81,250 sq. feet is underway. This should eliminate site 17'from consideration and reduce the environmental ranking of 16. II. Circulation Site 16 is not as convenient as the other sites for access to the 57 Freeway and, therefore, less desirable for ultimate disposal at BKK in West Covina. B. Traffic is already extremely congested in the immediate vicinity. County of Orange, Class I Industrial Waster Transfer Station Draft Environmental Impact Report 269 September 21, 1981 Page Two III. Economics Using the County's own figures, site 16 is 4th if ranked by cost. However, based on communication with Dave Christensen of the Irvine Company, the price used in the EIR comparisons is substantially below current market sales in the area. They estimate that a site such as proposed would cost $16.00 per square foot or a market value of $4,158,760.00 for site 16. The County GSA estimated a value of $2,600,000. This is $1,558,760.00 below what current sales would indicate. A possible 60% difference in the price would need closer analys4s and affect the cost comparisons in the EIR. IV. Need Tustin is a low volume producer of such wastes at 7%, yet is expected to bear the burden of environmentally damaging activity to solve the problems of other industrial areas. Further analysis is needed. V. Alternatives to BKK The document suggests that in the future alternatives may have to be selected to BKK but does not adequately address the suitability of the alternative transfer sites to such alternative Class I dump sites. VI. Current Ownership The Orange County Department of Education via Jean Hayes has indicated they have not been contacted concerning a potential sale and still intend to carry forward their proposal for a special education facility and central cafeteria operation. The EIR should address the relative merits of the two proposed public uses. Further, the impact of the State Law restrictions on sale of surplus school property, it's equity gains, low cost housing exemption and the financial impact on the Department of Education should be addressed in detail. VII. Procedural The EIR does not adequately address the issue of local control, zoning, use permits, imposition of local conditions, or the State, County, Local regulatory matrix on such a facility. Mitigating measures to offset financial service costs to local government encumbered with such a facility need to be addressed fully. County of Orange, Class I Industrial Waster Transfer Station Draft Environmental Impact Report 26g Recommendation Council direct a letter summarizing City of Tustin concerns be prepared for the Mayor's signature including the items discussed herein, brought forth in Council discussion or raised by public input. The Council encourage all citizen's, homeowners groups, business concerns or other interested party to also submit concerns to EMA, the City and/or Board of Supervisors regarding this facility. Council direct staff to ascertain the commitment level of the County Department of Education to their proposed project and their course of action assuming any potential acquisition by the County General Services Administration is proposed. MWB/dat $creencheck FIR Draft FIR Proposed Final FIR Final FIR (Submitted: fl/l 8/81) (Submitted: 8/1 #/81) (Approved: ) (Certified Complete: ) AUG 1 8 1981 L, .......... UUNTY ENVIRONMENTAL SERVICES DIVISION ORANGE COUNTY INDUSTRIAL WASTE TRANSFER STATION EIR 269 Prepared by PRC TOUPS 972 Town and Country Road P.O. Box .5367 Orange, California 92667 (71 t~) 83.5-t~t~t~7 Contact Person: Sylvia M. Salenius County of Orange General Services Agency 1300 South Grand Aves~ue P.O. Box 56~ Santa Aha, California 92702 ENVIRONMENTAL INFORMATION FOR USE BY THE COUNTY OF ORANGE, CALIFORNIA Contact Person: Robert Rusby (71~) 83~-3686 AUGUST 1981 L EXECUTIVE SUMMARY In an attempt to eliminate problems associated with the handling of industrial wastes in the Orange County area, the implementation of a Class I industrial waste transfer station within the County was proposed. Five sites were selected by the Orange County General Services Agency and the Environmental Management Agency for analysis (see Figure i). Chapter III of this l~nvironmental Impact Report (fiR) provides a detailed discussion of those issues and concerns which preceded this fir in the regulatory process. As proposed, the transfer station will consist of storage and minimum treatment facilities with a capacity for receiving 156,000 gallons of industrial waste by 1985, 219,500 gallons by 1990, and 342,800 gallons by the year 2000. Safety features designed into the transfer station include containment berms, which will border the entire site in order to prevent discharge of industrial waste to land, groundwater or surface waters, and an underground double liner containment system, which will consist of an underliner of clay, overlain with a layer of clean coarse sand to fine gravel, in addition to a second liner of asphalt pavement. The two impermeable layers provide protection for the underlying soil and groundwater. Figure 1 illustrates the double liner containment system. The transfer station prototype is shown in Figure 2. The following Executive Summary highlights those existing conditions, project- related impacts, and mitigation measures, as delineated in Chapter IV of this EIR, which differentiate the five candidate sites for the proposed Class I industrial waste transfer station. The information in this EIR will assist the Orange County Board of Supervisors in making a decision as to whether to proceed with the transfer station project, and should a decision be made to proceed, on which of the five sites to locate the facility. I-I ~X Z .< <. z X ~EuC~ .E ~ o~>, uJ X ~-x< ,o'., NURSERY ~ WICKES LUMBER AGRICULTURE AGRICULTUR£ CooRs ) DISTRI- · VACANT i~ BUTOR ~ FESCO ~ CITIES SERV ICE OFFICES POLYPIPE ~mr. ~.).. STEELCASE I~'~'-JOHN ST LUMBER MCKESSON C.EMIC GOLDEN WEST ~ PLASTICS := OFFICE CONDOS WEBER AMERICAN ~ PLYWOOD ~ DISPLAY - · COMPANY MARINE CORPS HELICOPTER BASE VACANT ! BU I LD I NG :m VACANT ~RUC IT ON~ ............ ~ ~.~ MILO BUSINESS EQUIPMENT PARK COMPANY VACANT VACANT FIGURE ~1~. EXISTING LAND USE, SITES I~ & 17 I.;.I Z O uu ]¥1Ol..-13N3~t Z 3AIJ.¥D3N ILl * *00 · *OeO * °0 '0' * · *0 'O* * * '0 o · o · · · · · · · · · 0o * 000- ' %N DORPE & ASSOCIATES -- ENGINEERS AND ARCHITECTS (714) 978-9780 1820 ORANGEWOOD, SUITE 107 ORANGE, CALIFORNIA 92668 September 16, 1981 Michael Brotemarkle Director Community Development Department City of Tustin 300 Centennial Way Tustin, California 92680 Re: Review of EIR for County of Orange Class 1 Industrial Waste Transfer Station Dear Mike: Pursuant to your authorization, we have completed a brief review of the two-volume Environmental Impact Report on the subject project. The Draft EIR (Volume 1) identifies the five (5) alter- native site locations (out of a possible 30 sites) for the proposed transfer station, which were selected earlier by the Orange County General Services Agency (GSA) and the Environmental Management Agency (EMA). The rational for the selection is discussed in the report by the GSA and the EMA in Volume 2 (Appendices). Sites 5, 20 and 21 are within the City of Anaheim and Sites 16 and 17 are within the City of Tustin. (The numbers used refer to the numbering system used in the County's earlier site analyses.) Based upon the analyses made, the EIR finds that Sites 16 and 17 are the two highest environmentally-ranked sites. In fact, the EIR states that the five sites can be ranked in the following order of descending preference: 16 and 17 (equal), 20, 5 and 21 [pg. IV-165, Vol. 1]. However, based upon cost considerations, the sites are arrayed in the following descending order of preference: 5, 21, 17, 16 and 20 [pg. IV-166, Vol. 1]. Site 5 is by far the least expensive site to acquire and mitigate ($526,000) for the proposed project, primarily because it is County-owned. At the other end of the scale, Sites 16, 17 and 21 are in the $2.8 to $3.4 million range, because they are prime industrial properties. Site 21 would cost slightly over $1.1 million. Nevertheless, the EIR clearly promotes Sites 16 and/or 17 as the "best" alternative location. Page 2 September 16, 1981 Review of EIR for County of Orange Based upon our brief review, we believe that the City of Tustin should oppose the certification of the EIR for the proposed transfer station on the following grounds: Land Use - Present State Law prohibits the siting of a hazardous waste disposal site within 2,000 feet of a resi- dence. Attempts to extend this exclusion to all hazardous waste facilities (including transfer stations) has not yet been approved in the State Legislature. However, the intent of the Law is clearly that such hazardous wastes should not be stored, treated, etc. near populated areas. .Moreover, the EIR clearly states that the owners of Site 17 have been granted approval for the development of industrial condominiums and that grading operations began in May, 1981 [pg. IV-150, Vol. 1]. In fact, construction was begun in August, 1981 and completion is expected early in 1982. Thus, Site 17 should be ruled out entirely. Site 16 should suffer a correspondingly reduction in environmental ranking because of the additional development on the adjoining parcel. Also, within one mile of site 16, almost 25,000 people (in 1995) would be affected, between 20 and 140 percent more people than any of the other 3 sites [pg. IV-160, Vol. 1]. Transportation - Since one of the stated goals of the transfer station is to process the waste prior to its being hauled to BKK, should not greater preference be given to Sites 5, 20 and 21, which are close to and/or adjoining the 57 Freeway which is the main access road to BKK. Traffic from Sites 16 and 17 would have to travel through the Newport Beach Freeway - Santa Ana Freeway interchange which is the most congested interchange in Orange County. Moreover, the traffic on the surface streets around Sites 16 and 17 is also extremely congested [pg. IV- 165, Vol. 1]. Cost - As stated above, the following costs have been computed: Site Land Acquisition Impact Mitigation Total Cost 5 0 $ 526,000 $ 526,000 16 $2,600,000 372,600 2,972,600 17 2,400,000 372,600 2,772,600 20 3,000,000 407,200 3,407,200 21 750,000 418,000 1,168,000 Clearly, economics is a strong deterent to Sites 16, 17 and 20. Page 3 September 16, 1981 Review of EIR for County of Orange Need - Volume reports from the BKK Landfill for the second half of 1979 showed that the top six hazardous waste gener- ating cities were [pg. 28, Vol. II]: 1. Irvine 32% 2. Orange~ 12% 3. Huntington Beach 10% 4. Santa Ana 8% 5. Placentia 8% 6. Anaheim 8% The industries in these 6 cities produced almost 80 percent of the total hazardous wastes generated in Orange County. These cities received the tax benefits derived from the industrial activities of the respective waste generatorsl The City of Tustin represented less than 7 percent, there- fore, why should Tustin bear the brunt of such an environ- mentally damaging activity as a hazardous waste transfer station. We conclude, after this brief review of the EIR, that the City of Tustin should vigorously protest the inadequacies of the EIR relative to the data presented for Sites 16 and 17. We believe that, with additional efforts on the part of the City, it is likely that both sites can be eliminated from further consideration. Should you desire our assistance in this endeavor, please call US. Very truly yours, cKeonnsneu~htanK~ Hekimian, Ph.D. KKH/mv March 26, 1981 CITY COUNCIL Donald J. Saltarelli, Mayor Richard B. Edgar, Mayor Pro-tern Ursula E. Kennedy James B. Sharp Ronald B. Hoesterey P.R.C. Toups P.O. Box 5367 972 Town and Country Road Orange, CA L Attn.: Mr.. Dwayne S. Meats Associate Environmental Planner. RE: LIQUID INDUSTRIAL WASTE TRANSFER STATION (FILE #2055) Dear Mr. Meats: In response to your' request for' information on the subject project the following information is provided: Water Supply Facilities 1. Will sufficient water' be available to serve each site? Yes. What are the locations of the existing water' supply facilities nearest to each site? 12" A.C.P. in Bell Avenue 12" A.C.P. in Red Hill Avenue 10" A.C.P. along the westerly bondary of site 17, with a proposed 10" A.C.P. across the southerly 1/3 of site 17 to the easterly property line of site 17. 3. Are any new facilities planned in the vicinity of the sites? No. Waste Water' Facilities 1. Which waste water' facilities would serve the proposed sites? A 24" sanitary sewer, in Bell Avenue and a 8" sanita~ sewer' in an easement adjacent to the southerly boundary of site 16 and 17. What is their estimated status in tems of existing and planned improvements and capacities? Both sewers are existing and have adequate capacity to serve normal use. Can service to such a project as proposed be assured? Assurance of service can be provided for quantity of flows generated under normal industrial operations. High generation of flows will require further study. All effluent composition must be reviewed and approved by the Orange County Sanitation District No. 7. City Center Centennial at Main _~u~n_, California 92680 (714) 544-8890 LIQUID INDUSTRIAL WASTE %RANSFER STATION March 26, 1981 Page 2 Also attached is a copy of a letter' to Orange County E.M.A., Environmental Analysis Division from the Tustin Community Development Department. This letter' outlines some additional concerns of the City. In a previous letter' to your firm, I indicated that the Tustin City Planning Agency and City Council have approved Tentative Tract No. 11707 which is located on site 17. The final tract map for this industrial condominium will most likely be approved and recorded in May, 1981. It is my understanding that site 16 has been acquired by the County of Orange School System to construct a school for' the mentally handicapped and also a warehouse facility. Ver~ truly yours, DIRECTOR OF PUBLIC WORKS/ CITY ENGINEER BL:db -253- .J June lg, 1980 Environmental Management Agency Environmental Analysis Division P.O. Box 4048 Santa Ana, California 92702 Attention Kenneth E. Smith, Manager SUBJECT: Hazardous Waste Transfer Station, Proposed Sites 16 and 17 In addition to the relevant issues identified under probable effects in fha June 16, 1980 Notice of Preparation~ the City of Tustin would point out the following concerns: The City intently reviews and scrutinizes all industrial operat;ons as to processing, handling, transport, storage, potential hazards involved and other impacts of suspected hazardous materials use, production or by-products due to an historical occurrence of ad- verse impacts. Due to the very nature of this use such review and concern would be more intensive. In late April, the City was informed of the intent of th9 Orange County Department of Education to purchase and develop Lots 3 and 3, north of Warner, south of Bell and west of Red Hill Avenue, adjacent to your potential sites. The proposed development v~uld consist of a special educaton school for the handicapped, district cafeteria, and food preparation facility and general administrative offices. 'They are currently starting preparation of plans, en- vlronmental analyses and zoning applicatons for submittal to the City. Red Hill Avenue~ currently functioning at [20~ of capacity at Red Hill and the Route 5~ Santa Asa Freeway is of lntense concern to the City. The lack of suitable north-south arterial highway capacity and the severe constraints predicted by the NEOCCS Study cause the City predictable concern. The potential health impacts of the use or any failure or mal- function which might effect health would be' of concern to Tustin. The further loss of additional property in this industrial area to governmental usage would cause concern for fiscal impact upon the City Center 300 Centennial Tusttn. California 92680 {714) 544-8800 -254- Environmental t/~nagement Agency June 19, 1980 page 2. City of Tustin. Your addressing and emphasizing of these Issues as well as those already identified is greatly appreciated. If you desire further information or input, please contact us, Michael W. Brotemarkle Co~nunity Development Director -255- April 6, 1981 POLICE DEPARTMENT Mr. Dwayne S. Hears PRC Toups 972 Town & Country Road Orange, CA 92667 Dear Mr. Meats After looking at the two proposed sites, it appears that the answers to your questions would be the same for both sites seeing that they are in the same area. At the present time, one to three Officers cover the area of the proposed sites. The number of Officers on duty in that beat area will depend on which shift and which day of the week we are using as frame of reference. Tustin has only one police station and that station is located approximately two miles from the proposed site, and our average emergency response time is 3.4 minutes. Depending on the type of wastes and their particular hazards, protective clothing and equipment would be necessary for that beat Officer and additional equipment may be necessary for any back-up Officers. At the present time, this equipment is not available. Depending on the size of your facility and the amount of traffic generated by it, additional personnel would be needed in the patrol and/or traffic divisions. Additionally, your proposed site is . within the landing path of the John Wayne Airport. This has significant impact on the potential for major disaster problems. Should an aircraft crash into a hazardous waste station the difficulty factor of preservation of life and property in such an incident would multiply astronomically. The preservation of life and property is the primary mission of a Police Department. Currently, the major crime problem in the area is co-,-erical burglaries primarily due to the industrial complex nature of the i~ediate area. There is also a substantial problem with traffic ¢onjestion from the industrial areas within our City as well as the industrial areas of the adjoining cities in the i-,-ediate vicinity.. Continued on page two City Canter 300 Cantennial Tustin, California 92680 -256- (714) 544-8890 Mr. Meats April 6, 1981 Page two Along with this, there is a considerable amount of traffic generated by the Marine Corps Air Station (helicopter) located one block east of the two sites. As a result of the heavy traffic, there is a considerable problem with motor vehicle accidents. This problem would be compounded by the vehicle activity generated by the waste transfer station. The seriousness of accidents occurring in the area may also increase due to the type of waste material being transported and the type of the vehicles used to transport it. General burglary prevention methods (i.e. good dead bolts and window locks, adequate alarm systems, good lighting, etc.) would help alleviate the burglary problem. As far as the traffic problem is concerned, the only major through street in the area is Redhill Avenue and it is the main access from these businesses and the Marine Base to the two freeways in this area. There are no alternate streets in the area to reduce the traffic flow which this area creates on Redhill Avenue. I must insist that such a facility not be located at site 16 and 17 in the City of Tustin, the dangers are far to great. hope this information will help you and if any further assistance is needed, do not hesitate to contact my office. Sincerely, Chief of Police CRT:sa cc: Co~nunity Development -257- NGE ORANGE COUNTY FIRE DEPARTMENT ].BO SOUTH WATER STREET P.O. BOX 86, ORANGE, CALIFORNIA 92666 (714) 538-3551 April 7, 1981 LARRY J, HOLMS CYPRESS IRVlNE LA PALMA LOS ALAMITOS PLACENTIA SAN JUAN CAPISTRANO TUSTIN VILLA PARK YORBA LINDA PRC Toups A Planning Reseamc_h Company P.O. Box 5367 972 Town & Country Road Orange, CA 92667 Attention: Subject: M~. Dwayne S. Meatus EIR for Liquid Indust-~ial Waste Transfer Station In response to your request on fire protection the Orange County Time Depa~.h~nt will provide protection for the area. The following stations will serve the site: STATION #37 14901 Red Hill Tustin, CA 1 Engine Company (1500 gpm) 3 on duty (men) Approximate response time - 3 to 5 minutes ST~LTION #21 1241 Irvine Tustin, CA 1 Engine Company (1500 gpm) 1 Engine Company (1250 gpm) 1 Paramedic Unit 1 100 ;~ria! ~dder Truck Approximate response time - 7 to 9 minutes 3 on duty (men) 33 fire suppression volunteers 2 on duty (men) 4 on duty (men) -271- SMOKE DETECTORS SAVE LIVES PRC Toups A Planning Research Co. Attn: Mr. Dwayne S. Meats April 7, 1981 Page Two STATION #28 17802 Gillette Ave. Irvine, CA 1 Engine Company (1500 gpm) 1 Super - Vac Approximate response tium - 7 to 9 minutes men on duty The site is located within the Tustin Industrial Complex and the fire hazard potential should not change significantly. There are two potential problems that must be addressed: Aboveground 'qnolding stations" shall be required to be diked to retain the capacity of the largest "holding station". Installation will be required to comply with applicable fire safety regulations within the adopted Fire Code with applicable city ordinances. A delayed response time may ocoasiona]ly occum from Stations ~21 and #37 because of the Sante Fe Railroad which lies between these two stations and the proposed site. , Should you need any further assistance feel free to contact this office. Sine,rely, Fire Protection Analyst -272-