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EIR Sec. 3.8 Hazards and Hazardous Materials]

Hazardous materials waste, PCE, and an abandoned oil well on-site. With homes and schools right up against elevated site.








  • Demolishing the 514 building, (old South Bay hospital) with known lead, mold asbestos, and medical toxic materials.

  • Excavating, grading and trenching over 31,000 cubic yards of soil, with known PCE and benzene contamination 

  • Grinding concrete onsite, construction and fugitive dust can escape, even with the mitigation plans 


All on an elevated site raised 30 ft. above street level, and 60 to 100 ft. above nearby homes and schools in all directions,

From the EIR:

Hazards and Hazardous Materials [EIR Sec. 3.8 Hazards and Hazardous Materials]

Soil Contamination.

"Construction of the proposed Project would involve the excavation of substantial amounts of soil and additional earthwork associated with trenching and grading..., Phase 1 would involve the excavation of approximately 20,000 cubic yards (cy) of soil, necessary to facilitate construction of the proposed subterranean service area and loading dock.

Phase 2 would include the excavation of approximately 11,000 cy of soil...”


"Soil disturbance during excavation, trenching, and grading at the Project site would result in the disturbance of potentially contaminated soil. Ground disturbing activities (e.g., excavation, trenching, and grading) during Phase 1 and Phase 2 would disturb PCE-contaminated soils, beginning with the excavation of the subterranean levels of the RCFE Building to a depth of 26 feet during Phase 1. Similarly, grading within the vacant Flagler Lot would also encounter PCE-contaminated soils. The soil samples on the vacant Flagler Lot ...had the great(est) concentrations of PCE on the Project site (Converse Consultants 2020; see Appendix G). "

Even the EIR recognizes these risks. Page 498 (3.8-4) of the DEIR states: “The effects of PCE on human health depend greatly on the length and frequency of exposure. Short-term, high-level inhalation exposure (i.e., in confined spaces) can result in irritation of the upper respiratory tracts and eyes, kidney dysfunction, and neurological effects. Long-term exposure (e.g., in confined spaces) can result in neurological impacts including impaired cognitive and motor neurobehavioral performance as well as adverse effects in the kidney, liver, immune system and hematologic system, and on development and reproduction (U.S. Environmental Protection Agency [USEPA] 2016).”


The selection of boring sites is inadequate. The only 30 foot boring, at B-1, which was known to be far away from where the main contaminants were found. Converse [Ref: 3.2.38] advised unequivocally: “Deeper borings in the locations where pollutants were found would yield even greater findings of more pollutants.”















Air Quality [EIR Sec. 3.2 Air Quality]


[Ref. S3.2.1.5 Sensitive Receptors]
"Sensitive receptors are populations that are more susceptible to the effects of air pollution than is the population at large. According to CARB, sensitive receptors include children less than 14 years of age, the elderly over 65 years of age, athletes, and people with cardiovascular and chronic respiratory diseases.

The majority of development within Redondo Beach and Torrance consists of residential uses, including large single-family neighborhoods and multiple-family apartments and condominiums (see Section 3.10, Land Use and Planning), all of which are considered sensitive land uses with regard to air quality.


Residential uses occur to the north, south, east, and west of the Project site as close as 80 feet to the Project site (i.e., to the extent of proposed construction activities)."


The EIR lists 11 schools within 300 ft. to 0.5 miles (2,640 feet) of the Project site.

SCAQMD daily pollution limits for particular matter are for sizes of 10 and 2.5 microns – PM10 and PM 2.5. Emissions for smaller particle sizes such as PM1.0, ultrafine particles, are also known to exist, but there are no standards for them - primarily because of the difficulty of monitoring and enforcing such a standard. It is well known, however, that substantial health effects occur as a result of PM1.0 inhalation.


Recent studies show the development of lung function in children is reduced with long-term exposure to particulate matter. Such particles penetrate deeper into lungs and might never be dislodged. The ravages of other ultrafine particles, such as the Covid-19 virus, for example, are linked to deep lung involvement. 

Some reference studies:

Function of PM2.5 in the pathogenesis of lung cancer and chronic airway inflammatory diseases 

Outdoor particulate matter (PM10) exposure and lung cancer risk in the EAGLE study

PM2.5 and Cardiovascular Diseases in the Elderly: An Overview 

Google E aerial of site and Torrance hom
Soil excavation.png
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