CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT

A project of the Pacific Studies Center

278-A Hope Street, Mountain View, CA 94041
Voice and Fax: 650-961-8918

<lsiegel@cpeo.org>

http://www.cpeo.org

December 29, 2016

Planning Commission
City of Alhambra
111 South First Street
Alhambra, California 91801
Dear Sirs/Mmes:
I appreciate the opportunity to comment on the draft Mitigated Negative
Declaration and Initial Study for the proposed development at 875 and 1111
South Fremont Avenue, in Alhambra. I have been asked to review this document
by the San Gabriel Valley Oversight Group.
This document provides the city with the opportunity to ensure that new
buildings on the property will be safe for future occupants. As a local elected
official myself, it gives me comfort to know that my city (Mountain View, California)
has the authority, will, and knowledge to require soil-gas safe construction on
our contaminated properties.
I am pleased that the Mitigated Negative Declaration contains the
following:
A vapor barrier and underlying passive vent system must be installed
beneath the proposed buildings in the affected area where the vapors are
remaining. The presence of vapor barriers combined with passive sub-slab
venting and engineered air flow inside the buildings will minimize the
potential exposure of workers to VOCs due to vapor intrusion to indoor air.

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This is a great start, but given the temporal and geospatial heterogeneity of
soil gas contamination, its important to require that mitigation be designed into
any regularly occupyable building on the property. In the absence of nearcontinuous sampling, I believe its important to require actions at 50% of allowable
exposure limits, because otherwise actions might be delayed until months after
exceedances occur.
In addition, I recommend the following, to reinforce the Water
Boards site oversight:
1. Indoor air sampling shall be conducted in each building once construction is
completed. Sampling shall occur once before occupancy and at least four times a
year for two years, and perhaps more often if sampling shows significant temporal
variation.
2. There shall be a contingency plan for reducing indoor air concentrations in each
building should any sampling event find indoor air concentrations above 50% of
the target indoor air concentrations. As GSA recommends on page 253 of the
draft mitigated negative declaration, this shall include active venting (the addition
of fans) and perhaps off-gas treatment.
3. The contingency plan shall also provide for an urgency response, including
temporary relocation of building occupants, should TCE indoor air concentrations
in any building exceed 50% of the Urgent Response Action level, as defined the
U.S. EPA Region 9's June 30, 2014 memo.
4. In addition to the recommended vapor barriers, elevator shafts shall be sealed
according to the requirements of Californias Vapor Intrusion Mitigation Advisory.
5. All permanent employees in the buildings shall be notified that the property is
subject to an environmental respons overseen by the Regional Water Quality
Control Board. We recently required such notice for a hotel development in
Mountain View, where I sit on the City Council. The people in buildings where
vapor intrusion is a potential threat have a right to know about that threat, and
notice can be provided in a way that does not trigger unjustified fear or panic.
6. All indoor air sampling results shall be made available to building occupants, as
well as the public at large. The City web site should provide a link to pertinent
documents on the Water Boards Geotracker web site.
The environmental regulatory agenciesthe LA Water Board, U.S. EPA,
and the California Department of Toxic Substances Controlare doing a good job
in Alhambra. But oversight is fragmented and the agencies are understaffed and
underfunded. Vapor intrusion could literally slip through the cracks. Hence, I

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believe it is the obligation of city officials to look out for your people by
incorporating detailed protections in your CEQA documents.
Sincerely,

Lenny Siegel
Executive Director
Cc: Curt Charmley, Los Angeles Regional Water Quality Control Board
Eric Sunada, San Gabriel Valley Oversight Group