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HomeMy WebLinkAbout11_Sec4.6_HazardsHazardousMater 4.6 Hazards and Hazardous Materials 4.6HAZARDS AND HAZARDOUS MATERIALS This section describes the potential adverse impacts on human health and the environment due to exposure to hazardous materials or conditions that could be encountered as a result of implementation of the proposed project. Hazardous materials include, but are not necessarily limited to, inorganic and organic chemicals, chemical reagents and reaction products, solvents, mercury, lead, asbestos, radioisotopes, fuels, oils, paints, cleansers, pesticides, and biohazardous substances that are used in activities such as laboratory research, biotechnology manufacturing, and building and grounds maintenance. Hazardous materials use at biotechnology centers generate hazardous by-products that must eventually be handled and disposed of as hazardous wastes. For the purposes of this analysis, hazardous materials include inorganic and organic chemicals and products containing such substances as defined by California laws and regulations, radioactive materials, and biohazardous materials. Potential effects include those associated with contaminated sites and the potential exposure to hazardous materials used, stored, transported, or disposed of during construction activities (such as exposure to asbestos or lead as a result of building demolition) or Genentech operations. Potential impacts to water quality from construction-related surface water runoff that could contain hazardous materials and/or from groundwater dewatering during construction or operation of the proposed project are discussed in Section 4.2 (Flood and Inundation Hazards) of the MEIR. Impacts related to toxic air contaminants that could be emitted during operation of the project are discussed in Section 4.3 (Air Quality) of the MEIR. Seismic activity that poses a potential hazard to the project site is discussed in Section 4.5 (Geology and Soils) of the MEIR. Data used to prepare this section was taken from various sources, including information provided by Genentech, the Genentech website, San Mateo County Environmental Health Department? Environmental Health Division (SMCEHD) records (including hazardous materials inventory), and the following reports prepared by Environmental Data Resources, Inc. in March 2006: (1) City Directories dating back to 1990, (2) Aerial Photographs dating back to 1946, (3) Historical Topographic Maps dating back to 1913, and (4) a report of hazardous materials sites located within a half-mile of the ?center? of the Genentech Campus (approximately ?1000 Grandview Drive?), also referred to as MEIR Study Area. Full bibliographic entries for all reference materials are provided in Section 4.6.4 (References) of this chapter. No comment letters related to hazardous materials or wastes were received in response to the December 9, 2005, Revised Notice of Preparation (NOP) circulated for the project. In addition, no comments were received at the public scoping meeting held January 17, 2006. The NOP and comment letters are included in Appendix A of the MEIR. 4.6-1 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis 4.6.1Existing Conditions Definitions Hazard A hazard is any situation that has the potential to cause damage to human health and the environment. The risk to human health and the ecological environment is determined by the probability of exposure to hazardous material and severity of harm such exposure would pose. That is to say, the likelihood and means of exposure, in addition to the inherent toxicity of a material, are used to determine the degree of risk to human health or the ecosystem. For example, a high probability of exposure to a low toxicity chemical would not necessarily pose an unacceptable human health or ecological risk, whereas a low probability of exposure to a very high toxicity chemical might. Various regulatory agencies, such as the U.S. Environmental Protection Agency (EPA), State Water Resources Control Board and the Regional Boards, the California Department of Toxic Substances Control (DTSC), and state and federal Occupational Safety and Health Administrations (OSHA) are responsible for developing and/or enforcing risk-based standards to protect the public and the environment. Hazardous Material The term ?hazardous material? is defined in different ways for different regulatory programs. This MEIR uses the following definition of a hazardous material, provided in Sections 25501 (o) of the California Health and Safety Code: Any material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. ?Hazardous Materials? include, but are not limited to, hazardous substances, hazardous wastes, and any material which a handler or the administering agency has a reasonable basis for believing that it would be injurious to the health and safety of persons or harmful to the environment if released into the workplace or environment. By convention, most hazardous materials are thought to be hazardous chemicals, but certain radioactive and biohazardous materials, as defined here, are also hazardous. A ?hazardous waste,? for the purposes of this analysis, is any hazardous material that is abandoned, discarded, or recycled, as defined by Section 25124 of the California Health and Safety Code. In addition, hazardous wastes occasionally may be generated by actions that change the composition of previously nonhazardous materials. The criteria that characterize a material as hazardous include ignitability, toxicity, corrosivity, reactivity, radioactivity, or bioactivity. Hazard vs. Risk Workers and general public health are potentially at risk whenever hazardous materials have been used or where an exposure to such materials could occur as a result of the presence of unidentified fill materials or historic uses of a site. Inherent in the setting and analyses presented in this section are the concepts of the ?hazard? of these materials and the ?risk? they pose to human health and the ecological environment. Exposure to some chemical substances may harm internal organs or systems in the human 4.6-2 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials body, ranging from temporary effects to permanent disability, or death. Hazardous materials that result in adverse effects are generally considered ?toxic.? Other chemical materials, however, may be corrosive, or react with other substances to form other hazardous materials, but they are not considered toxic because organs or systems are not affected. Because toxic materials can result in adverse health effects, they are considered hazardous materials, but not all hazardous materials are necessarily ?toxic.? For purposes of the information and analyses presented in this section, the terms hazardous substances or hazardous materials are used interchangeably and include materials that are considered toxic. Acute vs. Chronic Health Effect Whether a person exposed to a hazardous substance would suffer adverse health effects depends upon a complex interaction of factors to determine the effects of exposure to hazardous materials: the exposure pathway (the route by which a hazardous material enters the body); the amount of material to which the person is exposed; the physical form (e.g., liquid, vapor) and characteristics (e.g., toxicity) of the material; the frequency and duration of exposure; and the individual's unique biological characteristics, such as age, gender, weight, and general health. Adverse health effects from exposure to hazardous materials may be short-term (acute) or long-term (chronic). Acute effects can include damage to organs or systems in the body and possibly death. Chronic effects, which may result from long-term exposure to a hazardous material, can also include organ or systemic damage, but chronic effects of particular concern include birth defects, genetic damage, and cancer. In the case of pathogenic (disease-causing) organisms or biohazardous materials, for transmission to humans to occur, the pathogen must be present in sufficiently high numbers to cause infection, and contact with the organism must occur. Historical Use Topographic Maps Historical topographic maps dating back to 1913 were reviewed to assist in determining if past uses within the MEIR Study Area involved hazardous materials. Table 4.6-1 provides a summary of these past uses. Aerial Photographs Historical aerial photographs dating back to 1946 were reviewed to determine past uses at the proposed project site. Table 4.6-2 provides a summary of these past uses. Genentech Policy, Practice, & Performance Genentech engages in the research, development, manufacture, and marketing of biotechnology products for serious or life-threatening diseases, including commercialization of those products. Research at Genentech focuses primarily on three areas of medicine: oncology, immunology and tissue growth and repair. 4.6-3 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis Table 4.6-1 Historical Topographic Map Information 1913 The proposed project site is primarily vacant undeveloped land. Several small structures are depicted along the eastern edge of the site along the San Francisco Bay. Two to three additional small structures are located further inland north of the San Bruno Canal; a small roadway originating west of the proposed project site leads to these structures. Land immediately adjacent to the proposed project site is also primarily vacant and undeveloped. 1947 The proposed project site is primarily vacant undeveloped land. A small roadway around the perimeter of the site, as well as one or two through the site, is now present. The San Bruno Canal is not designated. Several additional small structures are now present south and east of the proposed project site. The project site area is designated as Point San Bruno, and Oyster Point is now designated further north of the proposed project site. Land immediately adjacent to the proposed project site is also primarily vacant and undeveloped. 1956 The proposed project site is primarily vacant undeveloped land, however, is now designated as being occupied by the California National Guard. A larger roadway now leads to the center of the site where fifteen small structures are depicted. Another large roadway traverses south of the proposed project site along the San Francisco Bay to an area where a complex of large structures now exists. The project site area is still designated as Point San Bruno, and Oyster Point is now designated further north of the proposed project site. A “channel” and “spoil area” are designated in the San Francisco Bay south-southeast of the proposed project site. Land immediately adjacent to the proposed project site to the north and east is still primarily vacant and undeveloped. 1956 The proposed project site appears similar to the way it did in 1956, however, the large roadway that led to the center of tothe site is now shorter, and fourteen of the fifteen small structures are no longer present. The now shorter roadway leads 1968 to the one remaining structure that is designated as a “Radio Tower.” The proposed project site area is still designated as being occupied by the California National Guard. The large roadway that traversed south of the proposed project site along the San Francisco Bay is also now shorter and some of the previous structures part of the complex have been replaced with new structures slightly north. Other features in the immediate vicinity of the proposed project site are similar to how they were in 1956, except that a “marina” now occupies the area just south of Oyster Point (north of the proposed project site). Land immediately adjacent to the proposed project site to the north and east is still primarily vacant and undeveloped. 1956 The roadways and structures that occupied the proposed project site in the 1956–1968 topographic map are present. The toproposed project site area is still designated as being occupied by the California National Guard. A new large roadway 1973now appears along the western and northern perimeter of the site. Additionally, several large structures now occupy the western and northern areas of the proposed project site. Areas of the San Francisco Bay and San Bruno Canal, located south of the site, are now occupied by land. This land cuts through the “channel” that is designated to exist in the San Francisco Bay, and the San Bruno Canal is no longer present. Land at the northern end of the site also now occupies a larger area where water previously occurred. Land immediately adjacent to the proposed project site to the north and east are now occupied by structures and roadways. 1993 The proposed project site appears similar to the way it does today. It is occupied by a similar network of roadways and structures that exist at the Genentech facility. The area is still designated as Point San Bruno, and Oyster Point and the Marina are present further north. Areas surrounding the proposed project site are also fully developed. SOURCE: Environmental Data Resources, Inc., EDR Historical Topographic Map Report, March 22, 2006. Environmental, Health and Safety (EHS) Protection Policy In striving to conduct their business in an environmentally responsible manner and protect the health and safety of their employees, Genentech adheres to an Environmental, Health and Safety (EHS) Protection Policy that includes policy objectives in each of the following areas: Workplace Safety (conduct operations in a manner that fosters safety) Environmental Protection (employ practices to reduce reliance on hazardous materials) Integration into Business Decisions Compliance (comply with EHS regulations) Emergency Preparedness 4.6-4 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials Table 4.6-2 Historical Aerial Photograph Information 1946 The proposed project site is primarily vacant undeveloped land. A large roadway leads to the center of the site which is occupied by several small structures. Another large roadway traverses south of the proposed project site along the San Francisco Bay to an area where a complex of large structures exists. Land immediately adjacent to the proposed project site to the north is still primarily vacant and undeveloped. Land located further east is occupied by large roadways and structures. 1956 The proposed project site and surrounding areas appear similar to the way they were in 1946, except that the roadway leading to the center of the site is now longer and ends at a larger complex of smaller structures. Similarly, the large roadway that traverses south of the proposed project site along the San Francisco Bay now leads to a denser complex of buildings. Areas to the north and east are similar to the way they were in 1946. 1965 The proposed project site is now further developed with large building complexes, parking lots and a few water towers. The development is primarily growing along the southern and eastern ends of the proposed project site. Several parcel of graded vacant land are also now present. Several new roadways also now appear at the northern end of the site. Areas to the north and east are similar to the way they were in 1956. 1973 The majority of the proposed project site is developed with roadways, buildings, parking lots and a few water towers. Large parcels of graded vacant land exist at the center, northeastern and southern areas of the site. Areas to the north and east are also more developed with structures and roadways. 1982 The proposed project site appears similar to the way it does today. It is occupied by a similar network of roadways and structures that exist at the Genentech facility. Areas surrounding the proposed project site are also fully developed. 1993 The proposed project site appears similar to the way it did in 1982, except with a few additional structures present. It is occupied by a similar network of roadways and structures that exist at the current Genentech facility. Areas surrounding the proposed project site are also fully developed. SOURCE: Environmental Data Resources, Inc., EDR Historical Topographic Map Report, March 22, 2006. Supply Chain Management (encourage suppliers, contractors, and partners to comply with EHS regulations, and minimize the use of toxic chemicals and the generation of hazardous wastes) Industry Responsibility (standards to assure biological agents do not adversely affect human health or the environment) Continuous Improvement Employees Hazardous Materials Practices Hazardous materials used by Genentech principally relate to research, development and manufacturing of biotechnology products, and could include the following: Solvents used for cleaning, extraction, or other laboratory and production activities Reagents (chemical starting materials) Chemical reaction products, which may have unknown compositions Radioisotopes (radioactive elements used to stimulate or trace chemical reactions) Infectious agents, including bacteria, viruses, and other medical wastes Test samples (e.g., specimens such as blood, tissue, soil, or water), prior to use in a testing procedure Wastewater neutralization chemicals Chemicals used to clean process equipment Genentech?s manufacturing processes use recombinant DNA (rDNA) technology to grow medicinal proteins from cells. Depending on the size and complexity of the protein, the manufacturing process uses biological materials. Because of the low environmental and health risk associated with 4.6-5 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis manufacturing proteins with biological materials, there are no standard requirements to manage biological wastes in a particular manner. Biological waste effluents at Genentech facilities are currently inactivated through either heat or chemical processes. In recent years Genentech has become involved in small molecule and antibody conjugation research and development activities. These programs, common in the biopharma sector, frequently involve newly developed chemicals for which there is limited research and data regarding hazardous properties and effects. Genentech takes a conservative approach by managing these substances as toxic even if they have not been proven to be toxic. Genentech incorporates specific containment and ventilation design features into laboratories intended for small molecule or antibody conjugate research, and provides appropriate personal protective equipment for lab workers in these areas. Maintenance of the Genentech Campus, as well as proposed construction activities, also requires the use of hazardous materials. Examples of hazardous materials involved in vehicle, grounds, and building maintenance, or used on construction sites, include the following: Fuels (gasoline and diesel) Oils and lubricants Antifreeze Cleaners, which may include solvents and corrosives in addition to soaps and detergents Paints and paint thinners (latex) Freons (refrigerants) Pesticides and herbicides Genentech has a variety of programs in place to ensure ongoing compliance with regulatory requirements governing the management of hazardous materials. Genentech has a combined Storm Water Pollution Prevention Plan and Spill Prevention Control and Countermeasure Plan to manage the potential risks associated with an accidental release of hazardous materials to storm drains. Stormwater is monitored regularly consistent with regulatory requirements. The Genentech Chemical Hygiene Plan describes the company?s laboratory safety program, and applies to all employees engaged in the use of hazardous chemicals in laboratories. The Chemical Hygiene Plan sets forth requirements and accountability for the proper labeling of all laboratory chemicals, the provision of appropriate training for lab personnel, the provision of appropriate protective equipment, and the implementation of periodic inspections. Genentech has a comprehensive Biosafety Program designed to protect employees against occupationally-acquired infections, to prevent environmental releases of biohazardous materials and wastes, and to ensure compliance with regulations and guidelines applicable to biological materials. The Biosafety Program consists of several components, including the Genentech Institutional Biosafety Committee, the Biosafety Manual, the Medical Surveillance Program, and the Bloodborne Pathogens Program (including Exposure Control Plan). Genentech has a comprehensive Laboratory Waste Management Guide providing detailed information and resources to laboratory personnel regarding the precise protocols for management of laboratory waste streams that may be hazardous, including radioactive waste, biohazardous waste, laboratory chemical waste, and non-chemical solid wastes. In addition, Genentech has created an Institutional Biosafety Committee and a Radiation Safety Committee to oversee compliance efforts and practices where biohazardous and radioactive materials may be used, 4.6-6 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials as well as a Research and Process Development EH&S Oversight Committee to oversee all EH&S issues pertaining to research laboratory and process development activities Genentech has an Injury & Illness Prevention Program, as well as a Hazard Communication Program, to ensure that employees are aware of any workplace hazards as well as the applicable hazardous materials management requirements. EH&S training courses are provided to employees based on their job duties and responsibilities pertaining to hazardous materials and/or wastes. Genentech maintains a company ?intranet?, on which the EH&S Department maintains all relevant company programs, procedures, standards, and general information and resources for employees. In addition to the EH&S information available on Genentech?s intranet, the company maintains a database of MSDS? for chemicals used onsite that is accessible by all employees. Genentech?s Health Services Department manages a Medical Surveillance Program to identify individuals? health conditions that warrant special attention for work exposures and to detect early possible effects of potentially harmful work exposure. Personal monitoring devices (such as dosimetry badges, finger rings, organic vapor monitors, sampling tubes and cartridges and direct reading instruments) are employed to conduct work area and employee monitoring. The following describe hazardous materials located or potentially located at the Genentech Campus in broad categories: general chemicals, underground storage tanks, hazardous materials sites, infrastructure (e.g., asbestos, lead, polychlorinated biphenyls, and mercury), radioactive materials, and biohazardous materials. General Chemicals Many chemical materials, some hazardous, are used for research and production activities, as well as facilities maintenance, during the course of daily operations at Genentech. Virtually all of the buildings on the Genentech Campus contain commercial products (e.g., cleaners, copier toners, etc.) that could be considered ?hazardous materials? under regulatory definitions. Non-household-type hazardous materials used in research laboratories include chemical reagents, solvents, radioisotopes, and biohazardous substances. Process equipment may be cleaned using chemicals such as potassium hydroxide and phosphoric acid. Onsite wastewater neutralization systems may use sulfuric acid and sodium hydroxide. Diesel fuel is used across the Genentech Campus for emergency power generators. For certain product lines, Genentech uses Tetramethylammonium chloride (TMAC) to extract medicinal proteins out of the water at the end of a production process. Some forms of TMAC waste streams are considered to be hazardous by California, but not by other jurisdictions. In terms of weight, TMAC is the largest single hazardous waste stream produced by Genentech. During 2004, Genentech produced 329 metric tons of TMAC hazardous waste as a result of using a chemical material to extract medicinal proteins from water at the end of a production process for certain product lines. Genentech?s South San Francisco Campus uses alcohol-based solvent products, primarily for production cleaning purposes. These products include are alcohol wipes solution (70 percent alcohol/30 percent water) and reagent alcohol. The solvent types represented are ethanol, methanol and iso-propanol. 4.6-7 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis Maintenance units, including grounds, custodian services, and pest management use a wide variety of commercial products formulated with hazardous materials. These include fuels, cleaners and degreasers, solvents, paints, lubricants, pesticides and herbicides, adhesives, and sealers. Underground Storage Tanks (USTs)/Hazardous Materials Sites The potential exists for buildings or sites that would be affected by project development to have been contaminated by hazardous substances as a result of former uses of the sites, leaks from unidentified USTs, or unidentified buried debris that could contain hazardous substances or hazardous by-products. Contaminated soils, building materials, and/or groundwater pose potential hazards to construction workers, Genentech staff, and nearby employees if not managed and remediated safely. According to the Environmental Data Resources Report, which lists whether or not any USTs occupy the proposed project site, there are either active or inactive USTs at Genentech. Additionally, the proposed project site is listed as a hazardous materials site in the Report. A more detailed discussion of this is provided below under the summary of the Environmental Data Resources Report findings. Infrastructure Asbestos Asbestos, a naturally occurring fibrous material, was used for years in many building materials for its fireproofing and insulating properties. Loose insulation, ceiling panels, and brittle plaster are potential sources of friable (easily crumbled) asbestos. In addition, underground utility tunnels may also contain asbestos. Non-friable asbestos is generally bound to other materials such that it does not become airborne under normal conditions. Any activity that involves cutting, grinding, or drilling during building renovation or demolition or relocation of underground utilities could release friable asbestos fibers unless proper precautions are taken. Inhalation of airborne fibers is the primary mode of asbestos entry into the body, making friable materials the greatest potential health risk. Asbestos-related health problems include lung cancer and asbestosis. In accordance with Sections 25915 through 25916 of the California Health and Safety Code, a facility- wide inventory of locations of asbestos-containing building materials must be maintained and annual facility -wide notification of locations containing asbestos must be provided. Appropriate signs are posted when asbestos-containing materials are disturbed during construction or renovation at facility locations, in accordance with State and Bay Area Air Quality Management District regulations. Lead Lead is a naturally occurring metallic element. Among its numerous uses and sources, lead can be found in paint, water pipes, solder in plumbing systems, and soils around buildings and structures painted with lead-based paint. In 1978, the federal government required the reduction of lead in house paint to less than 0.06 percent (600 parts per million). However, some paints manufactured after 1978 for industrial uses or marine uses legally contain more than 0.06 percent lead. Because some structures within the MEIR Study Area were constructed prior to 1978, wall surfaces and other building materials may contain lead-based paints, which can pose a risk of exposure due to chipped or peeling paint, or from renovation 4.6-8 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials or demolition of buildings or building materials that contain lead. Excessive exposure to lead (even low levels of lead) can result in the accumulation of lead in the blood, soft tissues, and bones. Polychlorinated Biphenyls (PCBs) PCBs are organic chemicals, usually in the form of oil, that were formerly used in electrical equipment, including transformers and capacitors, primarily as electrical insulators. Some PCB-containing electrical equipment (e.g., transformers and capacitors) may still be present within the MEIR Study Area. In addition, some fluorescent light ballasts that contain PCBs could also be present in existing buildings that would be demolished or renovated under the proposed project. Nearly all ballasts manufactured prior to 1979 contain PCBs. Ballasts manufactured after July 1, 1978, which do not contain PCBs, are required to be clearly marked "No PCBs." PCBs, which are highly persistent in the environment, can cause various human health effects, including liver injury, irritation of the skin and mucous membranes, and adverse reproductive effects. PCBs are also suspected human carcinogens. In California, PCB-containing materials must be disposed of as hazardous waste. Mercury Elemental mercury is an insoluble, liquid, inorganic metal. It is commonly used in laboratory and medical equipment such as thermometers and manometers (used for measuring pressure). Other uses include electrical equipment and some water pumps. Mercury liquid evaporates very slowly if exposed to air. At certain levels of exposure, mercury vapors are toxic and can cause kidney and liver damage. It is possible that elemental mercury may be present in research laboratory sink traps, in cupboard floor spaces, or in sewer pipes if there have been any historical accidental spills or releases prior to the adoption of more stringent environmental regulations pertaining to hazardous waste disposal. If such spills or releases had occurred, exposure could result in the event of building renovation or demolition. Radioactive Materials Radioactive substances contain atoms that spontaneously emit radiation from the transformation of unstable atomic nuclei, which result in chemically different substances that may or may not be radioactive. Radioactive atoms are called ?radionuclides? or ?radioisotopes.? Because radioactive materials emit ionizing radiation, their presence can be detected easily. Researchers and health care professionals take advantage of this easy detectability by using radioactive materials to study various biochemical functions in animals and humans. Radiopharmaceuticals (radioisotopes or drugs containing radioisotopes) are also used in medicine and research. Limited types and quantities of radioisotopes are also used in research laboratories. All radioisotopes used on the project site are stored in sealed containers designed to prevent release of radioactive materials to the environment. Exposure to ionizing radiation can result in adverse human health effects that range from short-term mild symptoms (such as sunburn) to serious illness or death, depending upon the amount and concentration of the radioactive source and the duration of the exposure. The extent to which exposure would result in any adverse effects depends on the radioisotope and the amount and duration of exposure. 4.6-9 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis For wastes that are longer-lived, the final disposal depends on the hazard class of the low-level radioactive waste (LLRW). Genentech collects, prepares, and packages all radioactive waste for shipment and disposal. Genentech generates radioactive waste classified as Class A waste. Class A is waste that is usually segregated from other waste classes at the disposal site. Genentech uses a licensed radioactive waste broker (Philotechnics) to transport all radioactive waste to licensed disposal facilities. The two primary disposal facilities used by Genentech are the Energy Solutions facility in Salt Lake City, Utah and the Pecos facility located in Richland, Washington. Biohazardous Materials By statutory definition, biohazardous materials include biohazardous laboratory wastes and biologic specimens such as human or animal tissue, as defined by Section 117635 of the California Health and Safety Code. Genentech has developed programs, practices, and procedures for monitoring, routine inspection, reporting, and waste management to reduce community and worker exposure to potential hazards associated with medical wastes and biological hazards. Activities that could create biohazardous aerosols are conducted in biosafety cabinets, which filter all released air to remove biohazardous materials. Biosafety cabinets are tested annually in accordance with regulatory requirements. Regulations specify that medical waste is stored in refrigerated facilities for not more than 90 days and that such waste is properly packaged and labeled. Medical waste may also be rendered noninfectious through steam sterilization. Genentech uses a medical waste transporter (e.g., Stericycle) to transport and treat all medical wastes, which are subsequently disposed of in municipal landfills. Disposal of Hazardous Materials Generated On-Site The Genentech Campus is registered with the U.S. Environmental Protection Agency (EPA) as a generator of hazardous waste. Genentech does not store (for longer than 90 days) or dispose of hazardous chemical waste on site. In most cases, the waste is picked up from a collection location or generator site where the recycling or disposal process for that waste is managed. Before the waste is collected, it must be packaged and labeled properly, which includes segregating incompatible materials, and placing them in appropriate sealed containers. Chemical wastes are further segregated by type, and consolidated, bulked, or compacted before a licensed hauler transports them from the Genentech Campus to permitted off-site facilities for incineration, treatment, recycling, or other disposal. Hazardous waste is disposed of at licensed disposal facilities in California and other states. While municipal landfills were once the most common destination for hazardous waste, federal (1984 Amendments to the Resource Conservation and Recovery Act [RCRA]) and state (Hazardous Waste Control) law now bans their use for many of the most commonly generated hazardous wastes. Alternative treatment and disposal technologies, including incineration and recycling, are now more common methods of disposing of hazardous wastes. 4.6-10 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials Hazardous Materials Transportation Requirements Genentech contracts with licensed hazardous waste transporters to transport hazardous wastes sent off site for treatment or disposal at licensed hazardous waste facilities. Hazardous materials are routinely transported by truck or rail. The U.S. Department of Transportation (USDOT), Office of Hazardous Materials Safety, prescribes strict regulations for the safe transportation of hazardous materials, as outlined in Title 49 of the Code of Federal Regulations. In California, the California Highway Patrol (CHP) has the primary responsibility for enforcing federal and state regulations and responding to hazardous materials transportation emergencies. Specifically, Section 31303 of the California Vehicle Code requires that when hazardous materials are transported on state or interstate highways, the highway(s) that offer the shortest overall transit time possible shall be used. Transportation of hazardous materials along any city or state roadways within or near the facility is subject to all hazardous materials transportation regulations established by the California Highway Patrol. Genentech's Compliance History According to Genentech's 2004 Corporate Environmental Performance Report, Genentech?s South San Francisco facility received four Notices of Violation (NOVs) during 2004 as follows: One wastewater NOV was received for low pH in wastewater discharged to the sewer system. This exceedance was discovered during routine monitoring performed by Genentech. A root cause analysis was conducted, and the cause of the exceedance was determined to be improper operation of a particular piece of equipment. The users of that equipment were re-trained on proper operation and drain disposal. Two wastewater NOVs were received for exceeding sulfide limits in wastewater discharged to the sewer system. These exceedances were discovered during routine monitoring by the local government. A root cause analysis was conducted, and although several potential causes were ruled out, no exact cause was conclusively determined. The facility continues to monitor for potential recurrence. One air emissions NOV was received for exceedance of usage limits of solvent products in cleaning operations. The facility was permitted to use 23,820 pounds (lbs) in a 12 month period, and used 26,749 lbs in the period 4/1/2003 through 4/1/2004. This resulted in a fine of $1,000. The facility evaluated its operations and concluded that the original permit limit was inadequate to meet recent expansions in production at the facility. The facility applied for and was granted a higher limit for solvent usage in its air permit. The facility also improved its system for tracking solvent usage, to prevent exceedances in the future. Hazardous Materials Summary (2005) Table 4.6-3 below outlines hazardous materials quantities utilized at the existing Genentech Campus for the year 2005. 4.6-11 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis Table 4.6-3 2005 Hazardous Materials Summary at Genentech by Campus Lower Campus Upper Campus Middle Campus West Campus Total (Pounds (lbs.)) 551,600 lbs. 62,500 lbs. 270,000 lbs. 11,500 lbs. Non-Waste Materials Reported* Combustible 345,600 lbs. 54,000 lbs. 135,200 lbs. 11,500 lbs. a Flammable 37,600 lbs. 7,500 lbs. 73,700 lbs. 0 lbs. Corrosive 180,300 lbs. 4,300 lbs. 53,000 lbs. 0 lbs. b Reactives 220 lbs. 15 lbs. 1,500 lbs. 0 lbs. c Toxics 52,000 lbs. 1,500 lbs. 40,300 lbs. 0 lbs. Radioactives (Curies [Ci]) 0.01 Ci 943 Ci 2,800 Ci 0 Ci Waste Categories Hazardous Waste-Aqueous 26,900 lbs. 20 lbs. 16,400 lbs. 0 lbs. d Hazardous Waste-Flammable 3,200 lbs. 0 lbs. 38,000 lbs. 0 lbs. Hazardous Waste-Lab pack 11,100 lbs. 950 lbs. 3,900 lbs. 0 lbs. e Medical Waste 3,500 lbs. 1,500 lbs. 5,000 lbs. 0 lbs. Radioactive Waste 700 lbs. 700 lbs. 4,100 lbs. 0 lbs. f Broken Glassware Waste (Campus-Wide) 3,000 lbs. SOURCE: Harnish 2005 Liquids listed in pounds (lbs.) assumes 1 Gallon = 10 lbs. * Materials listed with multiple hazards are subtotaled under each hazard class. For example, 1 lb. Sodium azide would be included as 1 lb. under both the toxic and reactive classifications. Due to this overlapping reporting, the quantities for each category cannot simply be added together to derive the total aggregate quantity of hazardous materials. The ?total? row reflects the true total of materials on each campus neighborhood on any given day, without double-counting for overlapping categories. Thus, in the ?total row, 1 lb. Sodium azide would be reflected as 1 lb. a. The combustible classification includes 50,115 gallons (501,150 lbs.) of diesel fuel in aboveground tanks used for emergency generation. b. Includes both acids and bases. c. Includes explosives, Class 3/4 Oxidizers, Class 2/3 Water Reactives, and other highly reactive materials. d. Aqueous waste typically contains 50% toxics. e. Lab-pack waste typically contains 40% toxics, 40% flammables, 15% corrosives, and 5% reactives. f. Radioactive waste is estimated from 2005 Waste Manifests totaling 5,500 lbs. for the year for all of the South San Francisco campus. It is assumed that 75% of radioactive waste is generated from the Middle Campus and the remaining waste is generated equally between the Lower and Upper Campus Labs. Environmental Data Resources (EDR) Report Environmental Data Resources (EDR) performed a records check in March 2006 of federal, state, and county hazardous waste lists compiled pursuant to Section 65962.5 of the Government Code, as required by Public Resources Code Section 21092.6, including, but not limited to, the Leaking Underground Storage Tanks (LUST) List, the Hazardous Waste Substance List (Cortese list), the Emergency Response Notification System (ERNS), and registered small or large hazardous waste generators. The records check was done for the approximate address of ?1000 Grandview Drive?, however was reviewed for the following addresses that were a part of the EIR Study Application (filed in September 2005 with the City of South San Francisco): 1. 1 DNA Way 2. 342 Allerton Avenue 3. 410 Allerton Avenue 4. 444 Allerton Avenue 4.6-12 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials 5. 400-428 Grandview Drive 6. 448 Grandview Drive 7. 425 Grandview Drive 8. 560 Forbes Boulevard 9. 301 East Grand Avenue 10. 345 East Grand Avenue According to the EDR, the Genentech, Inc. property located at 460 Point San Bruno Boulevard is included on the following lists: (1) federal list of RCRA large quantity generator of hazardous wastes; (2) the California Water Resources Control Board?s list for having a waste discharge system; (3) the California Facility Inventory Database, which lists active and inactive UST locations; and (4) the Air Resources Board?s Emissions Inventory Data list for sites with toxics and criteria pollutant air emissions. Additionally, the portion of the Genentech facility located at 1 DNA Way was listed as having registered above ground storage tanks (AST). The portion of the Genentech facility located at 1200 Grandview Drive was listed by San Mateo County as being a hazardous waste generator. Overall, the EDR Report identified the following as being located within -mile of 1000 Grandview Drive: 1 RCRA Large Quantity Generators (LQG) of hazardous wastes 8 RCRA Small Quantity Generators (SQG) of hazardous wastes 6 Emergency Response and Notification System (ERNS) sites 521 Hazardous Materials Incident Report System (HRMIS) sites 1 Toxic Substances Control Act (TSCA) list 9 Facility Index System (FIS) list 2 California Water Resources Control Board?s list 2 Cortese list 3 Leaking Underground Storage Tank (LUST) list 2 California Facility Inventory Database (FID) for USTs 4 Historical Registered UST Database 3 Statewide Environmental Evaluation and Planning System (SWEEPS) UST list 6 California Hazardous Material Incident Report System 23 San Mateo County Hazardous Waste Sites list 14 HANET list 5 Air Resources Board?s Emissions Inventory Data EMI list The following three LUST cases located within -mile of the proposed project site have all been closed: (1) Tornberg Enterprises located at 1776 Grandview Drive; (2) United Parcel Service located at 657 Forbes Boulevard; and (3) Yellow Freight System, Inc. located at 201 Haskins Way. More generally, based on the historical industrial use of the area, it is possible that soil and/or groundwater contaminated with petroleum hydrocarbons, metals, solvents, or other industrial materials could be encountered during construction activities. Known historical contamination includes leaks from underground storage tanks, which have been managed effectively in accordance with regulatory requirements. Low concentrations of ammonia were discovered in soil and groundwater under a building on lower campus, for which the Regional Water Quality Control Board issued a "No Further Action" letter in 2003. Naturally occurring asbestos in serpentine rock is known to be present in the middle 4.6-13 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis campus area, and possibly other areas on campus. If any contaminated soil and/or groundwater is encountered during construction, it will be managed in accordance with mitigation measure 4.6-1 and all applicable regulatory requirements Emergency Response Genentech?s Emergency Response Procedures Genentech emergency response procedures are outlined in Genentech?s Integrated Contingency Plan, incorporating the Core Plan: Emergency Response Procedures at Genentech?s South San Francisco Site. This document outlines reporting, assessment, commencement of the Incident Command System, Plan implementation, training, clean-up, decontamination, and follow-up actions in the event of an accidental release or other emergency involving hazardous materials. This document is maintained on file at the San Mateo County Health Department?Environmental Health Division (SMCEHD). Principal responsibility for emergency response at Genentech lies with the First Alert Team (FAT). The FAT is staffed by members from the Corporate Facilities Services, Security, EH&S, and Occupational Health Services groups. South San Francisco Fire Department Emergency Response According to the City of South San Francisco Fire Department (SSFFD), the City does not have any specific emergency responses unique to Genentech. The SSFFD responds to emergencies based on incident type and adjusts response depending on the circumstances on the scene at the time of the incident. 4.6.2Regulatory Framework The management of hazardous materials and hazardous wastes, including chemicals, radioactive materials, and biohazardous materials, is subject to numerous laws and regulations at all levels of government. These laws apply to research activities, operations and maintenance work, and other activities at the Genentech site. Summaries of federal and state laws and regulations related to hazardous materials management are presented below. California law allows for certain hazardous materials regulatory programs, including those pertaining to USTs, hazardous materials storage, and hazardous materials management, to be delegated to local agencies. Federal Federal and state laws require detailed planning to ensure that hazardous materials are properly handled, used, stored, and disposed of, and, in the event that such materials are accidentally released, to prevent or to mitigate injury to health or the environment. Primary federal agencies with responsibility for hazardous materials management include the Environmental Protection Agency (EPA), Department of Labor (Federal Occupational Health and Safety Administration [OSHA]), Department of Transportation (DOT), and Nuclear Regulatory Commission (NRC). Major federal laws and issue areas include the following statutes (and regulations promulgated thereunder): 4.6-14 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials Resource Conservation and Recovery Act (RCRA) Hazardous and Solid Waste Amendments Act (HSWA) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Superfund Amendments and Reauthorization Act (SARA) Emergency Planning and Community Right-to-Know (SARA Title III) State Primary state agencies with jurisdiction over hazardous chemical materials management are the Department of Toxic Substances Control (DTSC) and the Regional Water Quality Control Board (RWQCB). Other state agencies involved in hazardous materials management are Cal/OSHA, the Department of Industrial Relations (State OSHA implementation), State Office of Emergency Services (OES?California Accidental Release Prevention implementation), California Department of Fish and Game (CDFG), California Air Resources Board (CARB), California Highway Patrol (CHP), State Office of Environmental Health Hazard Assessment (OEHHA?Proposition 65 implementation) and California Integrated Waste Management Board (CIWMB). Hazardous chemical and biohazardous materials management laws in California include the following statutes (and regulations promulgated there under): Hazardous Waste Control Law Safe Drinking Water and Toxic Enforcement Act of 1986 ("Proposition 65?) Carpenter-Presley-Tanner Hazardous Substances Account Act Hazardous Waste Management Planning and Facility Siting ("Tanner Act") Hazardous Materials Release Response Plan and Inventory Law of 1985 (Business Plan Act) California Medical Waste Management Act Local The primary local agency, known as the Certified Unified Program Agency (CUPA), with responsibility for implementing federal and state laws and regulations pertaining to hazardous materials management is San Mateo County Health Department, Environmental Health Division. The Unified Program is the consolidation of six state environmental regulatory programs into one program under the authority of a CUPA. A CUPA is a local agency that has been certified by Cal EPA to implement the six state environmental programs within the local agency's jurisdiction. This program was established under the amendments to the California Health and Safety Code made by SB 1082 in 1994. The six consolidated programs are: Hazardous Materials Release Response Plan and Inventory (Business Plans) CalARP Hazardous Waste (including Tiered Permitting) Underground Storage Tanks Above Ground Storage Tanks (SPCC requirements) UFC Article 80 HMMP and HMIS As the CUPA for the County of San Mateo, the San Mateo County Health Department, Environmental Health Division maintains the records regarding location and status of hazardous materials sites in the 4.6-15 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis county and administers programs that regulate and enforce the transport, use, storage, manufacturing, and remediation of hazardous materials. By designating a CUPA, San Mateo County has accurate and adequate information to plan for emergencies and/or disasters and to plan for public and firefighter safety. A Participating Agency (PA) is a local agency that has been designated by the local CUPA to administer one or more Unified Programs within their jurisdiction on behalf of the CUPA. The City of South San Francisco Fire Department maintains a special program that regulates hazardous materials through disclosure and risk management plans as well as above ground storage tank referral in cooperation with the County of San Mateo. Thus, the City of South San Francisco Fire Department is a PA with the San Mateo County Health Department, Environmental Health Division as the CUPA. Regulations Medical Waste Regulations The United States Department of Health and Human Services (USDHHS), Centers for Disease Control and Prevention, and National Institutes of Health prescribe containment and handling practices for use in microbiological, biomedical, and animal laboratories. All Genentech laboratories follow the mandated hygienic practices. Based on the potential for transmitting biological agents, the rate of transmission of these agents, and the quality and concentrations of biological agents produced at a laboratory, Biosafety Levels are defined for four tiers of relative hazards. Biosafety Level 1 is for the least hazardous biological agents, and Biosafety Level 4 is for the most hazardous biological agents. Biosafety Levels for infectious agents are based on the characteristics of the agent (virulence, ability to cause disease, routes of exposure, biological stability, and communicability), the quantity and concentration of the agent, the procedures to be followed in the laboratory, and the availability of therapeutic measures and vaccines. Federal and state laws, such as the Animal Welfare Act, specify standards for record keeping and the registration, handling, care, treatment, and transportation of animals. Such laws are enforced by the U.S. Department of Agriculture and the California Department of Health Services (DHS). Further, Genentech programs, practices, and procedures previously described for monitoring, routine inspection, reporting, and waste management have been developed to reduce potential community and worker exposure to hazards associated with the use of animals in research. Medical wastes must be managed as a biohazardous material, in accordance with Section 117635 of the California Health and Safety Code. The management of biohazardous materials must comply with USDHHS guidelines and DHS regulations pertaining to such materials. Biohazardous medical waste is generally regulated in the same manner as hazardous waste, except that special provisions apply to storage, disinfection, containment, and transportation. The DHS Medical Waste Management Program enforces the Medical Waste Management Act and related regulations. 4.6-16 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials RadioactiveMaterialsRegulations The Atomic Energy Act (42 U.S.C. Sections 2011?2259) (AEA) ensures the proper management of source, special nuclear, and by-product material. The AEA, and the statutes that amended it, delegate the control of nuclear energy primarily to the Department of Energy, the Nuclear Regulatory Commission, and the United States Environmental Protection Agency (EPA). The California Radiation Control Law (California Health & Safety Code Sections 114960?114985) is a regulatory program designed to provide for compatibility with the standards and regulatory programs of the federal government and integrate an effective system of regulation within the state. The program regulates sources of ionizing radiation and establishes procedures for performance of certain regulatory responsibilities with respect to the use and regulation of radiation sources. These laws and regulations govern the receipt, storage, use, transportation, and disposal of sources of ionizing radiation (radioactive material) and protect the users of these materials and the general public from radiation hazards. The use of radioactive materials at the Genentech site is specifically subject to the conditions of a radioactive materials license issued and administered by the Radiologic Health Branch of the DHS. Genentech administers and monitors facility compliance with license requirements. Radioactive materials licensing requirements include routine inspection and monitoring of areas where radioactive materials are used to ensure that surfaces are not contaminated with radioactivity above background levels. Under the radioactive materials license, renovation or demolition of facilities using radioactive material requires decommissioning of the facilities. This involves radiation testing and conducting decontamination and waste handling activities in accordance with applicable regulations. Operational and Disposal Regulations Worker Safety The California Occupational Safety and Health Administration (Cal/OSHA) and the federal Occupational Safety and Health Administration are the agencies responsible for ensuring worker safety in the handling and use of chemicals in the workplace. In California, Cal/OSHA assumes primary responsibility for developing and enforcing standards for safe workplaces and work practices. Hazardous Waste Handling Cal-EPA and DTSC regulate the generation, transportation, treatment, storage, and disposal of hazardous waste under RCRA and the California Hazardous Waste Control Law. Both laws impose ?cradle-to-grave? regulatory systems for handling hazardous waste in a manner designed to protect human health and the environment. Asbestos Regulations The Clean Air Act regulates asbestos as a hazardous air pollutant, which subjects it to regulation by BAAQMD under its Regulation 11, Rule 2. OSHA also regulates asbestos as a potential worker safety hazard. These rules and regulations prohibit emissions of asbestos from demolition or construction activities, require medical examinations and monitoring of employees engaged in activities that could 4.6-17 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis disturb asbestos, mandate precautions and safe work practices to reduce the potential for release of asbestos fibers, and require notice to federal and local government agencies prior to renovation or demolition activities that could disturb asbestos. Lead Regulations Because of its toxic properties, lead is regulated as a hazardous material. Lead is also regulated as a toxic air contaminant. State-certified contractors must perform inspection, testing, and removal (abatement) of lead-containing building materials in compliance with applicable health and safety and hazardous materials regulations. Hazardous Materials Transportation The USDOT prescribes strict regulations for the safe transportation of hazardous materials, including requirements for hazardous waste containers and licensed haulers who transport hazardous waste on public roads. Emergency Response to Hazardous Materials Incidents California has developed an Emergency Response Plan to coordinate emergency services provided by federal, state, and local government and private entities. Response to hazardous materials incidents is one component of this plan. The State Office of Emergency Services administers the plan, which coordinates the responses of other agencies, including Cal-EPA, CHP, California Department of Fish and Game, the Regional Water Quality Control Board (RWQCB), and the Radiologic Health Branch of the DHS. Genentech will continue to implement the plan at the site, in cooperation with the South San Francisco Fire Department. 4.6.3Project Impacts and Mitigation Methodology The analysis in this section focuses on the use, generation, disposal, transport, or management of hazardous or potentially hazardous materials at the Genentech Campus. The volume of hazardous waste generated by various Genentech activities is quantified for the year 2005, as described in Table 4.6-3. Disposal options, the probability for risk of upset, and the severity of consequences to people or property associated with the increased use, handling, transport, and/or disposal of hazardous materials associated with implementation of the proposed project are analyzed. In order to determine if implementation of the proposed project has the potential to result in development of a site that is included on a list of hazardous material sites, EIP staff reviewed the EDR Report. 4.6-18 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials Thresholds of Significance The following thresholds of significance are based on Appendix G of the 2006 CEQA Guidelines. For purposes of this MEIR, implementation of the proposed project could result in potentially significant impacts from hazards and hazardous materials if the project would result in any of the following: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. 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. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances or waste within one-quarter mile of an existing or proposed school. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area. For a project within the vicinity of a private airstrip, would the project resulting in a safety hazard for people residing or working in the project area. Impair implementation of or physical interference with an adopted emergency response plan or emergency evacuation plan. Expose people or structures to a significant risk of loss, injury or death involving wild land fires, including where wild lands are adjacent to urbanized areas or where residences are intermixed with wild lands. Impacts and Mitigation Measures Threshold Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impact 4.6-1 Implementation of the proposed project would not expose Genentech employees or the nearby public to significant hazards, due to the routine transport, use, disposal, or storage of hazardous materials (including less- chemical, radioactive, and biohazardous waste). This is considered a than-significant impact. Implementation of the proposed project will result in the development of additional laboratories and other research facilities that would use, store, or require the transportation and disposal of hazardous materials. While the amount and type of hazardous materials may vary over time with changes in research and additions to hazardous materials lists, the general range and type of hazardous materials used on-site is not expected to substantially change upon implementation of the project. Genentech will continue to use materials, some of which are considered hazardous, during the course of daily operations. These hazardous materials include many of the inorganic and organic chemicals, chemical reagents and reaction products, solvents, mercury, lead, asbestos, radioisotopes, biohazards, fuels, oils, paints, cleansers, and pesticides that are currently used in laboratory research, building and grounds maintenance and vehicle 4.6-19 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis maintenance. In addition, the proposed project would result in an increase in the number of individuals that work and visit the facility, which would increase the number of individuals potentially exposed to hazardous materials. The individuals most at risk due to increased hazardous materials use associated with implementation of the proposed project would be those employees who work at locations where hazardous materials are found, such as laboratories, production and maintenance facilities, or construction sites. Whether a person exposed to a hazardous substance at one of these locations would suffer adverse health effects depends upon a complex interaction of factors to determine the effects of exposure to hazardous materials: the exposure pathway (the route by which a hazardous material enters the body); the amount of material to which the person is exposed; the physical form (e.g., liquid, vapor) and characteristics (e.g., toxicity) of the material; the frequency and duration of exposure; and the individual's unique biological characteristics, such as age, gender, weight, and general health. Adverse health effects from exposure to hazardous materials may be short-term (acute) or long-term (chronic). Acute effects can include damage to organs or systems in the body and possibly death. Chronic effects, which may result from long-term exposure to a hazardous material, can also include organ or systemic damage, but chronic effects of particular concern include birth defects, genetic damage, and cancer. Off-site hazardous materials exposure would only reasonably occur through limited circumstances such as accidental spill or release during transport or use. Use of Chemical Materials State, federal, and local regulations and Genentech programs, practices, and procedures, including the use of safety equipment, ensures that the potential for worker and/or public exposure to hazardous materials less than significant from improper or unsafe activities, or from accidents, is , as demonstrated in the following discussion. To reduce the potential for exposure to airborne chemicals, workers take standard precautions, such as working under fume hoods when using chemicals that could present exposure hazards. The chemical fume hood is a critical health and safety control in the laboratory setting, ensuring an adequate level of protection from the possible harmful affects of chemicals. Laboratory fume hoods are generally a box- like structure open on one side. Air is drawn through the fume hood and discharged to an exterior exhaust system through the roof of the facility. In addition, some fume hoods are equipped with air cleaning devices. Proper use of fume hoods keeps indoor laboratory toxic air contaminants below the suggested guidelines of the American Conference of Governmental Industrial Hygienists (Threshold Limit Values) and OSHA legal limits (Permissible Exposure Levels). To prevent exposure through skin contact, Genentech requires that protective clothing, such as laboratory coats, gloves, and safety glasses be worn while handling hazardous materials. In addition, proper washing after handling chemicals is required. Eating, drinking, and smoking are prohibited in laboratories and other areas where hazardous materials are used. These procedures are disclosed to all staff that work with hazardous materials, and this training increases the safety awareness of Genentech employees and further reduces the risks of exposure to hazardous chemicals through inhalation, absorption, ingestion, and injection. Should an accident occur that could cause an individual to be 4.6-20 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials exposed to a hazardous material, required emergency equipment, including fire extinguishers, eyewashes, and safety showers, are also available. Cal/OSHA requires all institutions that use hazardous materials to implement a Hazard Communication Program and train employees that use hazardous chemicals in the safe use of those materials. Genentech implements all safety procedures and conducts safety programs to ensure that these procedures are consistently followed. Genentech will continue to implement these (or equivalent) programs, practices, and procedures and, as needed, these programs could be expanded. Title 8 of the California Code of Regulations (Section 3203 of the General Industry Safety Orders) also requires every California employer to have a written Injury and Illness Prevention Program to provide a safe and healthful workplace. OSHA mandates methods of documenting, investigating, and controlling accidents that result in skin penetration. Evidence presented during OSHA rule-making procedures indicates that these programs and methods are effective in reducing the number and severity of injuries and illness in the workplace. Use of Radioactive Materials Radioactive materials use at Genentech is monitored to ensure consistency with the requirements of the radioactive materials license, which articulates standards to maintain exposure levels below applicable legal standards, thereby protecting users of radioactive materials. Like all hazardous materials, the effects of the routine use of radioactive materials are limited to areas where exposure may occur and decreases substantially with distance. For this reason, the individuals most at risk would be those specially trained in the use of radioactive materials, which would reduce the likelihood for accidental exposure through improper handling techniques. Furthermore, all individuals who handle radioactive waste are required to wear a personal monitor that determines their cumulative exposure to radiation. If the monitor indicates that established safety levels might be exceeded, the individual will not be exposed to potential sources of radiation until the monitor indicates that safety levels can be maintained. In accordance with strict regulatory guidelines, Genentech collects, prepares, and packages its radioactive waste which is then transported by Philotechnics to a regulated radioactive waste disposal facility. The two primary disposal facilities used by Genentech are the Energy Solutions facility in Salt Lake City, Utah and the Pecos facility located in Richland, Washington. Genentech?s programs, practices, and procedures for handling radioactive materials in compliance with all established regulatory requirements would less than significant ensure that the potential for significant health and safety hazards remains . Use of Biohazardous Materials In handling biohazardous materials, Genentech follows guidelines promulgated by the USDHHS that determine the level of safety precautions that must be used for four tiers of relative hazards. Biosafety Level 1 is for the least hazardous biological agents, and Biosafety Level 4 is for the most hazardous biological agents. Biosafety Levels for infectious agents are based on the characteristics of the agent (virulence, ability to cause disease, routes of exposure, biological stability, and communicability), the quantity and concentration of the agent, the procedures to be followed in the laboratory, and the availability of therapeutic measures and vaccines. Biosafety Level 1 agents pose minimal or no known 4.6-21 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis potential hazard to individuals and the environment. Biosafety Level 2 agents are considered to be of ordinary potential hazard and may produce varying degrees of disease through accidental inoculation, but may be effectively contained by ordinary laboratory techniques and specific laboratory equipment. Biosafety Level 3 agents pose more substantial risks, and work with these agents must be conducted in contained facilities for which air flow is directed into the laboratory and access is controlled separately from public areas. Occupational and public safety is protected by selecting the appropriate biological and physical containment levels for each biological material handled. As discussed in ?Use of Chemical Materials,? standard microbiological practices, such as limiting facility access, washing hands after handling, decontaminating work surfaces, wearing gloves and other safety equipment, using biosafety cabinets, and proper disposal, reduce risks resulting from exposure to biohazardous materials. Current state testing, monitoring, and disposal regulations and EH&S programs pertaining to the management of biohazardous materials, including infectious agents, would further ensure that the risks associated with less than significant the use of biohazardous substances remain . Disposal of Hazardous Materials Genentech disposes of hazardous wastes in compliance with Titles 8, 14, 17, and 22 of the California less than significant Code of Regulations, which ensures that impacts remain . Spent hazardous materials generated on a daily basis in research, production, and maintenance facilities are placed in special containers and are kept in ventilated accumulation areas out of normal use patterns. These hazardous wastes are collected and accumulated in designated, secured areas designed to prevent accidental release to the environment. Wastes are transported off site by licensed hazardous waste transporters to permitted hazardous waste disposal facilities, and emergency response procedures for all on-site storage sites are included in the Genentech Integrated Contingency Plan. Biohazardous wastes are managed in the same way, though separately. Radioactive waste is collected, prepared, and packaged by Genentech, then transported by a radioactive waste broker to a licensed radioactive waste disposal facility. Summary While the proposed project would result in the development of additional laboratories and other research facilities that would use, store, or require the transportation and disposal of hazardous materials, as well as a limited increase in the average population that could be exposed to hazardous materials risks, compliance with Genentech programs, practices, and procedures and safety standards related to the use, disposal, and transport of hazardous materials and wastes, and the safety procedures mandated by applicable federal, state, and local laws and regulations (RCRA, California Hazardous Waste Control Law, and principles prescribed by the USDHS would ensure that risks resulting from the routine use of less than significant hazardous materials and disposal of hazardous wastes remain . In addition, safety programs reduce the risk of exposure to biohazardous and chemical hazardous materials by establishing protocols to safely handle and store hazardous substances, which ensures that a less-than-significant impact would occur. Genentech ensures that their facilities are in compliance with 4.6-22 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials the California Code of Regulations (Title 17) and conditions of the radioactive materials license, and the utilization of radiation use authorizations and ongoing training regarding radiation safety also reduce the risks from radiation-related use or disposal on-site, thereby ensuring that a less-than-significant impact would occur. In addition, the CHP and USDOT strictly regulate hazardous materials transportation to and from the site. Although implementation of the proposed project would expose more people to potential hazards, safety procedures mandated by federal and state laws and regulations, as previously described, as well as the continuation of existing (or equivalent) Genentech programs, practices, and procedures would ensure that the use, transport, or disposal of hazardous materials does not expose employees, visitors or the nearby public to significant health or safety risks. As part of implementation of the proposed project, federal and state law, as well as all Genentech procedures for handling hazardous wastes, would be extended to all new facilities developed under the proposed project. The potential impact of increased less hazardous chemical, radioactive material, and biohazardous material use at Genentech would remain than significant . No mitigation is required. Impact 4.6-2 Implementation of the proposed project would not expose construction workers or Genentech employees to a significant hazard through the renovation or demolition of buildings, or relocation of underground less-than- utilities, that contain hazardous materials. This is considered a significant impact. Demolition of existing buildings could release hazardous materials if lead-based paint or asbestos- containing materials are present in the structure(s). Any activity that involves cutting, grinding, or drilling during building renovation or demolition, or relocation of underground utilities, could release friable asbestos fibers and/or lead dust unless proper precautions are taken. As noted in Section 4.6.3 (Existing Conditions), all applicable federal and state rules and regulations must be followed when asbestos- containing materials are disturbed during construction or renovation. The notification of federal and local government agencies is required prior to beginning any renovation or demolition that could disturb asbestos, as well as the use of precautions and safe work practices to eliminate or reduce the potential for release of asbestos fibers, and medical examinations and monitoring of employees engaged in activities that could disturb asbestos. Similarly, there are programs directed at reducing lead exposure to a less- than-significant level through education, inspection, testing, and removal. Genentech has a comprehensive asbestos management program that includes regular surveys, annual notifications, and signage in appropriate locations, as well as making information regarding the locations of asbestos on its campus available to all employees through the company's intranet. Buildings demolished during construction activities could also contain biohazardous materials, including medical wastes. Genentech?s programs, practices, and procedures and current state testing, monitoring, and disposal regulations pertaining to the management of biohazardous materials, including medical waste, eliminate or reduce the potential for biohazardous substances to be present in fixtures or building materials removed during demolition. In addition, the radioactive materials license requires testing and implementation of decontamination and waste handling activities in accordance with applicable regulations when facilities using radioactive materials are decommissioned for purposes of renovation or 4.6-23 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis demolition. Compliance with federal and state health and safety laws and regulations, as well as following existing (or equivalent) Genentech programs, practices, and procedures, would ensure that this impact less than significant remains. No mitigation is required. Threshold 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. Impact 4.6-3 Implementation of the proposed project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials less-than-significant into the environment. This is considered a impact. The precise increase in the amount of hazardous materials transported to or from the Genentech facility as a result of implementation of the 2006 FMPU cannot be definitively predicted due to varying research needs over time, which cannot be anticipated as part of this programmatic document, and changes in the classification of hazardous materials. Nonetheless, the following discussion focuses on the potential nature and magnitude of risks associated with the accidental release of hazardous materials typically used on site. Off-Site Transportation of Hazardous Materials While Genentech programs, practices, and procedures specifically govern receipt of hazardous materials at Genentech, the USDOT Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials, as described in Title 49 of the Code of Federal Regulations, and implemented by Title 13 of the California Code of Regulations. Transportation of hazardous materials along any City or state roadways within or near Genentech is also subject to all hazardous materials transportation regulations established by the California Highway Patrol pursuant to the California Vehicle Code and the South San Francisco Fire Department (SSFFD). The transportation of hazardous materials can result in accidental spills, leaks, toxic releases, fire, or explosion. Licensed vendors bring hazardous materials to and from the Genentech facility, and manifests are completed and maintained by Genentech for all hazardous waste that is transported in connection with Genentech activities. The DTSC also maintains copies of Genentech?s waste manifests. In conformance with legal requirements, incoming radioactive material is monitored and recorded for each acquisition. Genentech's Shipping & Receiving Department processes and delivers all incoming radioactive materials to users. Hazardous waste shipments could occur as frequently as several times per week, barring unusual circumstances, such as laboratory demolition. As previously mentioned, Section 31303 of the California Code of Regulations requires that when hazardous materials are transported on state or interstate highways, the highway(s) that offer the shortest overall transit time possible shall be used, and as required by federal and state laws, all other all hazardous materials transportation regulations must be followed, such as USDOT regulations for packaging and handling hazardous materials to prevent accidental spills of hazardous materials during transit. Compliance with all applicable federal and state laws, as well as 4.6-24 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials Genentech programs, practices, and procedures related to the transportation of hazardous materials will less- continue to reduce the likelihood and severity of accidents during transit, thereby ensuring that a than-significant impact would occur. On-Site Transportation of Hazardous Materials In addition to transport of hazardous materials to and from the Genentech facility, the movement of hazardous materials also occurs among Genentech facilities (within buildings, from room to room, within hallways, and up and down stairwells and elevators). Accidents could occur as these materials are moved about the facility, and exposure of employees could occur through fire or explosion. Genentech's various business units exercise appropriate practices to prevent against the risks of accidental spills or releases of hazardous materials during internal transfers and movement of these materials. If a spill occurs, the Genentech First Alert Team (FAT) would be immediately notified. If required, the area of potential affect would be isolated and evacuated as appropriate in accordance with the Integrated Contingency Plan to reduce the potential for human exposure and to allow for prompt and effective cleanup by the Genentech FAT, an emergency response contractor, or the appropriate regulatory agency. The consequences of spills as a result of a fall or dropping a container would depend on whether the hazardous material was released, the specific hazards associated with the material, the facility design, and the availability of emergency response equipment. In addition to health impacts associated with direct contact from an accidental spill, indirect impacts could also occur. Spills that occur on permeable surfaces may be difficult to decontaminate and may require complete removal of the surface. In areas without adequate ventilation, including partially enclosed outdoor areas, such as walkways, stairwells, or courtyards, vapors from released volatile materials could be trapped in stagnant air pockets, and persons entering these areas after such a spill could be subject to health hazards associated with such vapors. In these instances, all individuals would be evacuated from the affected area until the vapors dissipate to safe levels as determined by the Genentech FAT. To reduce the likelihood and severity of accidents during on-site transit, all applicable federal and state laws and existing Genentech programs, practices, and procedures related to the transportation or cleanup of hazardous materials (in the event of an accidental release) will continue to be implemented to ensure less-than-significant that a impact would occur. These laws, regulations, programs, practices, and procedures include training regarding the handling of hazardous wastes and fully developed emergency response programs. In summary, Genentech facility plans outline the procedures to follow in case of an emergency involving hazardous materials. Hazardous Materials Storage Most hazardous materials stored on-site present little risk of upset. Hazardous materials are stored in laboratories in designated secured areas designed to prevent accidental release to the environment. Hazardous materials used for research are generally stored in laboratories in small, individual containers. In the unlikely event of an accidental release, these small storage volumes limit potential consequences to the individual laboratory in which they are stored. Compliance with all applicable federal and state laws and existing Genentech programs, practices, and procedures related to the storage of hazardous materials 4.6-25 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis will continue to be implemented to maximize containment (through safe handling and storage practices described above) and to provide for prompt and effective clean-up if an accidental release occurs, less-than-significant thereby ensuring that a impact would occur. Hazardous Materials Use Hazardous materials use would present a slightly greater risk of accident than hazardous materials storage. However, for those employees that work with hazardous materials, the amount of hazardous materials that are handled at any one time is relatively small, reducing the potential consequences of an accident during handling. Further, Genentech would continue to comply with federal and state laws and existing Genentech programs, practices, and procedures to eliminate or reduce the consequence of hazardous materials accidents. For example, staff who work around hazardous materials will continue to wear appropriate protective equipment, and safety equipment is routinely available in all areas where hazardous materials are used. Major hazardous materials accidents are extremely infrequent, and additional emergency response capabilities are not anticipated to be necessary to respond to the potential incremental increase in the number of incidents that could result from implementation of the proposed project. Continued compliance with all applicable federal, state, and local laws and regulations pertaining to the transport, use, disposal, and handling of hazardous waste, as well as following Genentech programs, practices, and less than significant procedures, would ensure that this impact remains . No mitigation is required. Impact 4.6-4 Implementation of the proposed project would not create a significant risk of exposure of Genentech employees and construction workers to contaminated soil or groundwater. Implementation of mitigation measure, less than significant MM 4.6-1 would ensure this impact remains . While some Genentech facilities are included on lists and databases compiled by applicable federal, state, and local agencies pursuant to Government Code Section 65962.5, these sites consist of registered active or inactive USTs and hazardous materials storage locations, rather than contaminated sites (e.g., soil or groundwater). All on-site USTs conform to applicable federal, state, and local regulations and are registered and permitted by the SSFFD. In the event that USTs are uncovered or disturbed, they would be closed in place or removed. While removal could pose health and safety risks, such as the exposure of workers, tank handling personnel, and the public to tank contents or vapors, the potential risks, if any, would be reduced by managing the tank according to established guidelines for investigation and closure of USTs, as well as cleanup of sites contaminated by leaking USTs, to ensure that a less-than-significant impact would occur. Based on the historical industrial use of the area, it is possible that soil and/or groundwater contaminated with petroleum hydrocarbons, metals, solvents, or other industrial materials could be encountered during construction activities. Known historical contamination includes leaks from underground storage tanks, which have been managed effectively in accordance with regulatory requirements. Low concentrations of ammonia were discovered in soil and groundwater under a building on lower campus, for which the Regional Water Quality Control Board issued a "No Further Action" letter in 2003. Naturally occurring 4.6-26 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials asbestos in serpentine rock is known to be present in the middle campus area, and may be present in other locations as well. It is possible that contamination could exist in localized areas as the result of pesticide or herbicide use during routine landscape/turf maintenance practices or in association with the removal or disturbance of older underground utilities or unidentified buried debris. The use of pesticides is governed by the State Department of Pesticide Regulation. With respect to other potential sources of soil contamination, such as underground utilities or other unidentified buried debris, specific procedures would be followed in the unlikely event that contaminated soil is discovered during construction activities to ensure that the risk of exposure to Genentech employees or construction workers remains less than significant. If required during construction activities, dewatering could result in the withdrawal of contaminated groundwater. If the groundwater contains contaminants above regulatory levels, the water could present a hazard to people or the environment unless properly managed. However, contractors would implement best management practices during construction dewatering to avoid exposure of Genentech employees or construction workers to potentially contaminated groundwater, such as groundwater testing, containment of contaminated groundwater in storage tanks for subsequent treatment and/or disposal, and/or the provision of release response information. In addition, subject to Section 13263 of the California Water Code, the Regional Water Quality Control Board issues Waste Discharge Requirements to control discharges (including groundwater) to land or water, and MM 4.6-1 would require that Genentech follow specific procedures in the unlikely event that contaminated groundwater is discovered during construction activities to ensure that the risk of exposure to Genentech employees or construction workers remains less than significant. The following mitigation measure shall be implemented throughout the proposed project planning horizon: MM 4.6-1 While not expected to occur on-site, if contaminated soil and/or groundwater is encountered during the removal of on-site debris or during excavation and/or grading activities, the construction contractor(s) shall stop work and immediately inform the appropriate Genentech representative. An on-site assessment shall be conducted to determine if the discovered materials pose a significant risk to the public or construction workers. If the materials are determined to pose such a risk, a remediation plan shall be prepared and submitted to comply with applicable legal requirements to assure the proper handling and management of contaminated soil and/or debris, and the protection of human health and the environment for the new building. Soil remediation methods could include, but are not necessarily limited to, excavation and on-site treatment, excavation and off-site treatment or disposal, and/or treatment without excavation. Remediation alternatives for cleanup of contaminated groundwater could include, but are not necessarily limited to, on-site treatment, extraction and off-site treatment, and/or disposal. The construction schedule shall be modified or delayed to ensure that construction will not inhibit remediation activities and will not expose the public or construction workers to significant risks associated with hazardous conditions. less than significant Following MM 4.6-1 would ensure that this impact remains by providing specific procedures to follow in the event that contaminated soil and/or groundwater is discovered. 4.6-27 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis Threshold Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Impact 4.6-5 The proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one- no impact quarter mile of an existing or proposed school. There would be . There are no existing schools within one-quarter mile of the MEIR Study Area. There are existing and planned child centers within the MEIR Study Area, but no schools. The MEIR Study Area is located in an area zoned for industrial uses only. Thus, no school can be proposed within one-quarter mile of the no impact MEIR Study Area. There would be . No mitigation is required. Threshold Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. Impact 4.6-6 Implementation of the proposed project would not result in construction of facilities on a site containing hazardous materials, and thus would not create a significant hazard to the public or environment. Following less than significant MM 4.6-1 would ensure that this impact remains . The EDR Report identifies the locations of known hazardous materials sites on-site based upon a review of federal, state, and county hazardous waste lists and databases pursuant to Government Code Section 65962.5. The lists and databases include, but are not limited to, the Department of Toxic Substances Control Hazardous Waste and Substances Site List (Cortese List), the Resource Conservation and Recovery Act (RCRA) database, and the California Hazardous Material Incident Report System (CHMIRS). These lists and databases contain information about asbestos waste, underground storage tanks, photoprocessing chemicals, PCBs, unspecified solvent and organic mixture wastes, unspecified aqueous solution, metal sludge, other hazardous materials monitored by statute or regulation, known releases of hazardous substances, and locations where radioactive or other hazardous materials are stored or used. There are no listed contaminated soil or groundwater sites on-site; however, there are on-site active or inactive USTs included on the lists and databases, as well as locations where hazardous materials are stored and/or used. These USTs conform to applicable federal, state, and local regulations and are registered and permitted by the SSFFD. If future UST-related cleanup were determined to be necessary, all work would be performed in accordance with appropriate guidelines of the regional Underground Storage Tank Program. All non-UST hazardous waste storage locations are managed in accordance with all applicable federal and state laws, such as RCRA and the California Hazardous Waste Control Law, as well as with all existing Genentech programs, practices, and procedures described in Section 4.6.3 (Existing Conditions) and Section 4.6.4 (Regulatory Framework). Following MM 4.6-1 would ensure that less than significant this impact remains . No mitigation is required. 4.6-28 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials Threshold For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area. Impact 4.6-7 The proposed project is located within an airport land use plan; however, the proposed project would not result in a safety hazard for people residing no impact or working in the project area. There would be . The MEIR Study Area is located within two miles of the SFIA. Both the existing and the proposed Genentech R&D Overlay District areas are within the San Francisco International Airport Flight Zone and are subject to the Federal Aviation Administration (FAA) Airport Height Limits established in the San Mateo County Airport Land Use Plan. In addition to FAA standards, the 2006 FMPU keeps a maximum building height limitation of 150 feet above ground level on buildings within the MEIR Study no impact Area, which is in compliance with the FAA standards. There would be . No mitigation is required. Threshold For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area. Impact 4.6-8 The proposed project is not located in the vicinity of a private airstrip. no impact There would be . no impact No private airstrips are located in the vicinity of the MEIR Study Area. There would be . No mitigation is required. Threshold Impair implementation of or physical interference with an adopted emergency response plan or emergency evacuation plan. Impact 4.6-9 Implementation of the proposed project would not impair implementation of, or physically interfere with, an adopted emergency response or emergency evacuation plan. Implementation of mitigation measures MM less than 4.6-2(a) and 4.6-2(b) would ensure this impact remains significant . Construction and operation activities associated with development under the proposed project could potentially affect emergency response or evacuation plans due to temporary construction barricades or other obstructions that could impede emergency access on-site. However, through implementation of MM 4.6-2(a), multiple emergency access or evacuation routes would be provided on-site to ensure that in the event one roadway or travel lane is temporarily blocked, another may be utilized. Furthermore, ongoing coordination between Genentech and local agencies pursuant to MM 4.6-2(b) would ensure that roadway or travel lane closures will be coordinated with emergency response personnel to ensure that individual development projects under the 2006 FMPU would not impair implementation of, or physically interfere with, emergency response and evacuation efforts. 4.6-29 Genentech Corporate Facilities Master EIR Chapter 4 Environmental Analysis The following mitigation measures shall be implemented throughout the 2006 FMPU planning horizon: MM 4.6-2(a) To the extent feasible, the project applicant shall maintain at least one unobstructed lane in both directions on the site?s roadways. At any time only a single lane is available, Genentech shall provide a temporary traffic signal, signal carriers (i.e., flagpersons), or other appropriate traffic controls to allow travel in both directions. If construction activities require the complete closure of a roadway segment, Genentech shall provide appropriate signage indicating alternative routes. MM 4.6-2(b) To ensure adequate access for emergency vehicles when construction projects would result in temporary lane or roadway closures, the project applicant shall consult with the South San Francisco Police and Fire Departments to disclose temporary lane or roadway closures and alternative travel routes. Following MM 4.6-2(a) and MM 4.6-2(b) ensures that impacts associated with emergency response or less than significant evacuation would remain by providing multiple emergency access or evacuation routes and coordinating roadway or travel lane closures with emergency response personnel. Threshold Expose people or structures to a significant risk of loss, injury or death involving wild land fires, including where wild lands are adjacent to urbanized areas or where residences are intermixed with wild lands. Impact 4.6-10 The proposed project would not expose people or structures to a significant risk of loss, injury or death involving wild land fires. There no impact would be . The MEIR Study Area is highly developed, and no wildlands are intermixed within this urbanized area. The MEIR Study Area is bordered by developed land to the north, east, and south. To the west is the San Francisco Bay. No wildlands are directly adjacent to the MEIR Study Area. The closest wildlands no area, San Bruno Mountain County Park, is located approximately one mile away. There would be impact . No mitigation is required. 4.6.4References Dyett & Bhatia, 2005. Draft Genentech Central Campus Ten-Year EIR Study, November. Environmental Data Resources. Inc. 2006. EDR Historical Topographic Map Report, Years 1913 through 1993, March 22. ???. 2006. The EDR Aerial Photo Decade Package, Years 1946 through 1998, March 22. ???. 2006. The EDR?City Directory Abstract, Years 1990 through 2005, March 23. ???. 2006. The EDR Radius Map with GeoCheck, March 22. Genentech. n.d. Core Plan: Emergency Response Procedures at Genentech?s South San Francisco Site. ???. 2004. Genentech?s Corporate Environmental Performance Report. http://www.gene.com/gene/about/environmental/pdf/environ-report.pdf, Accessed March 2006. 4.6-30 Genentech Corporate Facilities Master EIR 4.6 Hazards and Hazardous Materials ???. 2006. Website: http://www.gene.com. Accessed March 2006. Harnish, Jim. 2005. Written communication from Mintier & Associates to EIP Associates, Memorandum dated December 22. Marshall, Keith. 2006. E-mail communication between City of South San Francisco Fire Department and EIP Associates, March 3. 4.6-31 Genentech Corporate Facilities Master EIR