HomeMy WebLinkAbout1996-08-13; City Council; 13774; Child care study phase I report & proceed phase IIr. z e. 9 <; 3 t
CITY OF CARLSBAD - AG dDA BILL
AB# /$i?yq DEPT. HD. b -:
REPORT ON PHASE I OF THE CHILD CARE
TO PHASE I1
MTG.W?~L CITY ATTY. - STUDY AND REQUEST TO PROCEED
DEPT. PLN r# CITYMGR :
RECOMMENDED ACTION:
Accept Phase I of the Child Care Study and authorize staff to proceed to Phase I
will include an analysis of the economic issues associated with child care use:
industrial zones.
ITEM EXPLANATION:
In January 1996, Council directed staff to prepare a three-phased study examining ir
associated with locating child care in industrial zones. A consulting firm, David J.
and Associates (DJP), was engaged to conduct the first phase of the study ar
health and safety issues. This analysis has now been concluded. Per Council d
staff is reporting DJP’s analysis of the health and safety risks related to child
industrial areas as well as potential mitigation measures recommended by the consu
Council agrees with these conclusions, staff will proceed to Phase II. In this segl
the study, DJP will provide an analysis identifying and evaluating the economic imy
locating child care in the industrial areas. Staff will present the resul
recommendations of the economic analysis to Council prior to beginning Phase Ill.
final stage, staff will analyze the land use implications of locating child care in in
zones based on data generated from the first two phases of the study. Recommen
will then be presented to the Council for consideration and inclusion in the Chi1
Ordinance.
Upon review of the consultant’s conclusions, staff agrees that the health and safe
associated with child care uses in industrial zones can be mitigated to an acceptab
under the following conditions:
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1. If the child care facility is operated by a company to serve on-site employees 1
2. If the child care facility is located at least 1,000 feet (or more) from t
boundaries, or owners of all property within 1,000 feet of the proposed chi
facility agree not to use acutely hazardous materials or other materials with p
off-site impacts;
3. If the sponsoring company legally agrees to not using acutely hazardous mate
other substances likely to endanger children within 1,000 of the child care facil
4. If the owner of the child care facility installs an emergency plan that determi
children can be safely evacuated from the child care facility within five minutc
agrees to conduct quarterly evacuation drills in support of the plan; and
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5. If the owner of the child care facility agrees to inform clients who use the on-s
care services of the elevated level of risk associated with the surrounding ir
environment.
More detailed information is provided in the attached memo, dated July 25,
Consultants from David J. Powers and Associates will be present at the Council me
respond to questions on their analysis.
ENVIRONMENTAL IMPACTS:
This analysis is considered exempt from CEQA review per Section 15306 because
qualifies as a study to gather information leading to an action not yet approve
adopted, or funded. Full environmental review will be conducted upon the child ca
ordinance prior to public hearings.
FISCAL IMPACT:
The fiscal impacts for both phases of the DJP contract totaled $45,415. If
determines that there are unmitigable health and safety risks, the study will be terr
with the cost at this point of $36,965.00. If Council determines that mitigation measu
acceptable, the study could proceed to Phase II at an additional expense of $8,4f
These funds were previously allocated from Council contingency funds in January.
EXHIBITS:
1. Memo to the Fire Chief from the Fire Marshal, dated 7/29/96
2. Executive Summary, excerpted from Child Care Facilities in Industrial Areas
3. Child Care Facilities in Industrial Areas, David J. Powers and Associates, Inc
previously distributed. (This report is on file in the Planning
Department, the City Clerk's Department, and the Main and
Branch City Libraries.)
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July 25, 1996
TO: FIRE CHIEF
FROM: Fire Marshal
ANALYSIS OF CHILDCARE REPORT
Following is report of staffs review of the childcare study results submitted by David J.
Powers and Associates @JP) on July 25, 1996. The review was performed by Fire Marshal Mike Smith and Senior Planner Adrienne Landers. It discusses the most significant findings and recommendations resulting from the study.
ISSUE:
Should the City proceed to phase two of the childcare study to determine any economic impact that would result due to the presence of childcare in Carlsbad’s industrial zones?
RECOMMENDATIONS:
Staff recommends that the City proceed to the economic phase of the study based upon the finding that compliance with the specific requirements listed below will mitigate the health and safety risks associated with childcare in the industrial zones to an acceptable level.
BACKGROUND:
On January 8, 1996, the consulting firm, David J. Powers and Associates, was engaged to conduct a study of the safety and economic issues associated with childcare uses in Carlsbad’s industrial zones, and to submit a report of the findings of the study. Staff received the second draft of phase one of the report on July 25, 1996, and finds that except for a small number of editorial flaws, and the need for additional treatment in one task area the report is sufficiently complete to allow us to proceed. The consultant has agreed to make the necessary corrections prior to submittal for Council review.
The consultant’s tasks in phase one of the study were to identify and evaluate the health and
safety risks associated with childcare in industrial zones, and to propose measures that might mitigate those risks. Phase one also included an analysis of childcare needs and availability in all four quadrants of the City. Our plan was to complete the second phase of the study, which would analyze the economic impact of childcare presence in the industrial zones, if it was determined by Council that health and safety risks could be adequately mitigated.
FINDINGS
The DJP Report indicates that the risks associated with childcare uses in the industrial zones are probably not as serious as staff suspected, based upon the present character of the businesses operating there. Furthermore, the report states that distancing childcare from hazardous sites by means of a buffer of 1,000 feet in all directions, provides considerable protection from exposure. Although the buffer will guarantee only six to 3
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seven minutes for evacuation in a worst case scenario, a gaseous plume emanating from an accidental release will typically dilute in air over this distance, to a concentration that is unlikely to cause serious harm.
The researchers carefully point out that while the risk presented to childcare by the
relatively light industrial uses currently operating in Carlsbad is not as great as it would be with a presence of heavy industry, it is greater than that experienced in commercial zones. Staff finds this to be one of the more significant outcomes of the report. It should be clearly understood that it is possible to mitigate a considerable amount of the risk associated with this mix of use, but we cannot assure that the level of safety in industrial childcare facilities will be equivalent to that found in the commercial environment. Although we are not compelled to require this equivalency, staff suggests that all stakeholders, particularly
parents should be aware of the disparity.
Staff also finds that based on the information provided by the consultant, specially designed safe rooms for sheltering purposes are not be desirable since they would require air supply treatments that would be unable to prevent intrusion of the entire range of
airborne materials that could be accidentally released in the industrial zone. Dependency upon this technology could create a false expectation of protection, since the decision to shelter-in-place rather than evacuate would have to be based upon specific knowledge of the characteristics and quantity of the material released. A proper alternative would be to identify areas within the facility which can be quickly adapted to afford short term protection for occupants until the risk has passed.
SPECIFIC REQUIREMENTS FOR CONDITIONAL USES:
Upon review of the consultant’s treatment of the various study tasks, and in consideration of the conclusions offered by the research team, staff suggests that the health and safety risks associated with childcare uses in industrial zones can be mitigated to an acceptable level, and therefore childcare uses can be permitted in industrial zones under the following
conditions:
1. The Childcare facility is owned by a business entity whose business operation is ordinarily permitted in the industrial zone.
entity, and the ordinary work sites of those employees or tenants lie within the boundaries of the property on which the childcare facility exists.
2. The childcare service is provided to employees or tenants of the business
3. The owner of the childcare facility is legally capable of maintaining the
property 1 ,OOO feet in all directions from the property line of the childcare facility, free of Hazardous Materials (AHM), and free of other ordinary hazardous materials which by virtue of their chemical characteristics, physical state, or volume would, in the event of accidental release, threaten the health or safety of the occupants of the childcare facility.
4. The Owner of the child care facility installs an emergency plan that all children
can be safely evacuated from the child care facility within five minutes, and agrees
to conduct quarterly drills in support of the plan.
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5. The Owner of the childcare facility agrees to inform clients who use the on- site childcare services of the elevated level of risk associated with the
surrounding industrial environment.
ITEMS REQUIRING FURTHER DISCUSSION OR STUDY
Industrial emissions The DJP Report was unable to conclude that ambient air quality would be harmful to children occupying a childcare facility in an industrial zone. It is generally accepted that
difficulties as a result of chemical exposure. However, the researchers were unable to
determine whether or not the ambient air in Carlsbad’s industrial zones is of a quality that would present a significant hazard. Air quality is monitored throughout the County by the Air Pollution Control District, but only at a few sites. However, industrial emitters of
pollutants are constrained by permits and procedures designed to minimize pollutant discharge.
This issue has not been addressed by other agencies that are currently pennitting.chi1dcare uses in industrial areas. According to the researcher’s compiling this report, analysis of the issue would require sophisticated research methods which could not be accommodated without considerable expense. Therefore, staff suggests that any further research in this area should be undertaken by state or local air quality management agencies.
Future of the industrial areas The DJP Report suggests that the current character of the industrial zones in Carlsbad do not present the level of risk associated with heavier industries such as semi-conductor
fabrication facilities, large manufacturers, or refineries. Therefore industry and childcare
can likely coexist without undue impact, one upon the other. However, should the character of the industrial areas move in that direction it is reasonable to assume that a childcare presence will in some way impact the ability of these businesses to locate, expand or even operate without considerable oversight and CEQA review. Because this translates into financial impact, this issue should be included in the scope of the economic impact
study.
children are sensitive receptors and therefore vulnerable to a host of physiological
MIKE SMITH
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EXECUTIVE SUMMARY
The City of Carlsbad has been developing a Child Care Ordinance intended to address the provision of child care services in all areas of the City, Some of the issues of concern identified
by the City during this process are related to the potential safety concerns of locating child care
facilities near industrial uses.
The question of whether child care centers should be located in planned industrial areas or near
acutely hazardous materials is a complicated issue. One of the basic questions to be addressed
by City staff, the Planning Commission, and City Council when considering the approval of a
new child care facility is whether its physical location provides a “safe” environment for
children. Children are generally considered more sensitive to chemical exposure than adults anl
a critical concern in or near industrial areas are potential impacts to children from the relatively
higher frequency of use, storage and transport of hazardous materials by industry.
Hazardous Materials Risks in Industrial Areas
This study provides a broad-based evaluation of industrial facilities currently operating in the
locating in Carlsbad. The potential for off-site impacts from accidental releases is discussed fo~
seven industry types including: 1) pharmaceuticals and biotechnology; 2) golf club
manufacturing; 3)semiconductor fabrication; 4)electronics platingkircuit board and computer
electronics manufacturing; 5) chemicals manufacturing; 6) analytical instnunents/medical
apparatus; and 7) plastics and plastics products manufacturing. The risks of accidental release
impacting an off-site population, such as a child care center, for the seven industry types range
from relatively low for golf club manufacturers to relatively higher for chemical manufacturing
facilities. Most industries would present a medium level risk.
The study uses descriptive, rather than quantitative, values to evaluate off-site risks to sensitive
subpopulations in part because chemical use in the industrial areas of Carlsbad is likely to chang
significantly. Currently, approximately 65 percent of the Planned Industrial areas in Carlsbad
have not been developed. In addition, hazardous materials use in most industries changes over
time as a part of normal economic development. Existing facilities change the types and amow
of chemical use as a routine part of business. New industry can use larger quantities of
hazardous materials than existing uses, or more toxic materials.
Hazardous Materials Risks in Commercial Areas
In addition to the evaluation of hazards within industrial areas, this study briefly compares the
levels of risk in locating a child care facility in commercial versus industrial areas. There are
commercial businesses that use hazardous materials that can cause impacts in the event of an
accidental release. The types of commercial uses present in Carlsbad that would be most likely
to result in offsite impacts to a child care center include auto servicing facilities, swimming
pools, and pool and spa supply businesses. Transportation related incidents, particularly near
Interstate 5, are also a concern in commercial areas.
City’s industrial areas, as well as the types of industrial facilities that may be interested in
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Typically the difference in risks between industrial and commercial areas is the difference in the
amount of chemicals used and stored by facilities in each land use area. The level of risk from
the smaller research and development facilities and small-scale manufacturing plants currently
found in the Planned Industrial areas of Carlsbad lies somewhere in between heavy industrial
uses, such as refineries and large chemical manufacturers, and general commercial uses.
Evacuation and Shelter in Place Measures
Potential measures to protect children from an accidental release of toxic substances were also
examined. These techniques include reducing children’s exposure in the event of an accidental
release through evacuation or sheltering in place, and measures taken by industry to prevent
accidental releases. Evacuation of potentially exposed populations (both adult employees and
children) can reduce public health effects due to accidental releases of toxic chemicals. The
major drawback to evacuation as a response option is the time necessary for its implementation.
Since children may not understand evacuation alarms, are less responsive than adults, and cannc
respond without assistance, the time period needed for evacuation is longer, increasing the
exposure duration and the potential for health impacts. Due to the special characteristics of
children, sheltering may be more appropriate than evacuation as a first response option for the
releases of hazardous materials which are quickly contained and have lower toxicities. In industrial
settings, specifically designed shelter room features can significantly reduce indoor air
concentrations for some types of release incidents. However, these rooms cannot eliminate
exposures to all released gases, particularly since scrubber and filtration systems are necessarily
designed for specific chemicals and cannot protect against all chemicals. Specifically designed
shelter rooms are not currently an appropriate measure to insure protection of children from
nearby accidental releases of airborne hazardous materials.
Child Care Needs Update
A Child Care Needs Assessment completed in 199 1 by International Child Resource Institute,
identified shortfalls in the child care supply in Carlsbad. An update of population trends and
actual child care supply in 1995 revealed that the child care supply has grown significantly over
the last five years. The overall ratio of child care spaces to population has increased from 0.13 t
0.19 and the projected number of child care spaces has exceeded projected needs in two of four
quadrants in the City.
Conclusions and Recommendations
Advances in the containment and handling of hazardous materials have greatly reduced the
chance of an accidental release of these substances, but have not totally eliminated risk. If child
care facilities are located in planned industrial areas, children may be exposed to accidental
releases of acutely hazardous materials. In the event of an accidental release, acutely hazardous
materials can pose a significant health risk to children on or near a release site.
It is difficult to accurately predict potential impacts to child care facilities, even on a case-by-
case basis. Each facility evaluation requires a great deal of information and careful analysis.
The gathering of the specific information required for a risk assessment is expensive and can be
difficult to obtain voluntarily from surrounding industries. Addressing each child care facility o
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new hazardous materials user on an individual basis would be time-consuming and expensive for
the City and Applicant alike.
One possible option for allowing child care within the industrial area, which would provide for
the safety of children while maintaining the industrial area for primarily industrial uses, would be
to allow on-site child care where a buffer can be established between the child care center and
activities using acutely hazardous materials. This option would not require costly modeling
studies and would take some of the uncertainty out of the development review process, Under
except for on-site facilities within a larger industrial development.
Child care centers could be allowed with a conditional use permit if: 1) they are operated by a
company to serve on-site employees only; 2) are limited in size to the number of children that
could be safely evacuated within five minutes (as the number of children in the child care facility
increases the effectiveness of the evacuation becomes more important); and 3) are at least 1,000
feet (or more) from the site boundaries, or adjacent property owners legally commit not to use
specified quantities of acutely hazardous materials or other materials, such as ammonia or
flammable materials, with potential off-site consequences. The sponsoring company would also
have to commit to not using acutely hazardous materials (above prescribed amounts), or other
substances likely to endanger the children. This scenario does not preclude the possibility that
some companies may be required to provide more rigorous documentation related to their use of
hazardous materials, but it should limit the requirements, This would allow companies to have
on-site child care for their employees where there was a limited potential for impacts from and to
nearby industries. In addition, allowing only on-site child care facilities wvuld allow parents tv
evacuate their children in the event of a hazardous situation.
Another action which the City should consider would be to modify the zoning ordinance to
prohibit child care facilities within 1,000 feet (or more) of users of specified quantities of acutely
hazardous materials, whether within the planned industrial area or adjacent commercial or
residential areas.
Allowing only on-site child care facilities of limited size in the industrial zones would reduce the
problems associated with the potential evacuation of children in the event of an accidental release
of acutely hazardous materials, whether &om an nearby industrial facility or during
transportation and unloading. In addition, maintaining safety buffers between industrial users of
acutely hazardous materials and child Care facilities would greatly reduce the likely concentration
of an accidental release plume and allow greater time to implement an evacuation, if required.
Using an established safety buffer distance will avoid costly risk assessment studies for
individual facilities that may have to be updated as industrial uses arid processes chatlge. It
would also reduce some of the uncertainties related to whether a particular child care conditional
use permit would be approved, or conversely, whether new acutely hazardous material use would
be permitted. Allowing on-site child care within the planned industrial areas of Carlsbad under
these conditions provides a balance between providing child care facilities near employees’
places of work and maintenance of the integrity of the City’s Planned Industrial areas.
this option the City would continue to prohibit child care centers within planned industrial weas
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Study Report
CHILD CARE FACILITIES Ih
INDUSTRIAL AREAS
Prepared for
THE CITY OF CARLSBAD
Prepared by
DAVID J. POWERS AND ASSOCIATES, INC.
In Association with
ENVIRON
Gruen Gruen + Associates
July 1996
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TABLE OF CONTENTS -
E'XECUTIVESUMMARY ..................................................... i
I. INTRODUCTION .......................................................
11. SENSITIVITY OF CHILDREN TO CHEMICAL EMISSIONS ...................
A. Factors Influencing the Sensitivity of Children ...........................
B. Potential Adverse Health Effects from Acute Exposures to
Selected Industrial Chemicals ........................................
C. Sensitivity of Children to Different Types of Health Effects from Chemical
Exposure .........................................................
111:. EVALUATION OF HAZARDOUS MATERIALS RISKS .......................
A. Definition of Hazardous Materials and Acutely Hazardous Materials .........
1. Hazardous Materials .........................................
2. Acutely Hazardous Materials ...................................
B. Definition of Risk and Risk Assessment ................................
1'. DefinitionofRisk ........... _. ...............................
2. Risk Assessment and Risk Management ......................... 1
C. Overview of the Risk Management and Prevention Program ............... 1
IV. HAZARDOUS MATERIALS AND POTENTIAL IMPACTS ................... 1
A. Methods for Selecting Industry Types ................................. 1
B. Industry Types ................................................... 1
C. Hazardous Materials and Risks of Accidental Releases By Industry Type ..... 1'
1. Pharmaceuticals and Biotechnology ............................ 1
2. Golf Club Manufacturing ..................................... 1
3. Semiconductor Fabrication .................................. .2
4. Electronics Platingcircuit Board and Computer
Electronics Manufacturing ................................... .2
5. Chemicals Manufacturing ................................... .2
6, . Analytical InstrumentslMedical Apparatus , , . I ....... I .......... I 2
7. Plastics and Plastic Products Manufacturing ..................... -2
D. Seismic Hazards ................................................. .2
E. Relative Risk of the Industry Types .................................. .2
V. POTENTIAL HAZARDOUS MATERIALS RELEASE WITHIN COMMERCIAL
ZONES ............................................................... 2~
A. Businesses that Use Hazardous Materials in Commercial Zones ........... .2'
B. Potential Hazards fkom Transportation Accidents ....................... .3
C. Seismic Hazards ................................................. .3
D. Comparison of Risks in Commercial Areas Versus Planned Industrial Areas : ,3
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TABLE OF CONTENTS (cont.)
VI . ACCIDENTAL RELEASE PROTECTION MEASURES ....................... 33
A . Measures to Decrease Exposure in the Event of an Accidental Release ....... 33
1 . Evacuation ................................................ 33
2 . Shelter in Place ............................................ 34
B . Prevention of Accidental Releases .................................... 35
VI1 . CHILD CARE AVAILABILITY UPDATE .................................. 37
VI11 . CONCLUSIONS AND RECOMMENDATIONS ............................. 42
A . Conditional Use Permit Conditions and Siting Considerations .............. 44
OPTION 2: On-site Child Care in Planned Industrial Areas With Buffer ... 44
IX . GLOSSARY .......................................................... 47
X . REFERENCES AND PERSONS CONTACTED .............................. 49
APPENDIX A EVALUATIONS OF HAZARDS IN INDUSTRIAL AND
COMMERCIAL AREAS
APPENDIX B CHILD CARE NEEDS UPDATE
APPENDIX C CHILD CARE SITING ORDINANCES FROM SAN DIEGO AND
MOUNTAIN VIEW. CALIFORNIA
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EXECUTIVE SUMMARY
The City of Carlsbad has been developing a Child Care Ordinance intended to address the
provision of child care services in all areas of the City. Some of the issues of concern identified
by the City during this process are related to the potential safety concerns of locating child care
facilities near industrial uses.
The question of whether child care centers should be located in planned industrial areas or near
acutely hazardous materials is a complicated issue. One of the basic questions to be addressed
by City staff, the Planning Commission, and City Council when considering the approval of a new child care facility is whether its physical location provides a “safe” environment for
children. Children are generally considered more sensitive to chemical exposure than adults and
a critical concern in or near industrial areas are potential impacts to children from the relatively
higher frequency of use, storage and transport of hazardous materials by industry.
Hazardous Materials Risks in Industrial Areas
This study provides a broad-based evaluation of industrial facilities currently operating in the
City’s industrial areas, as well as the types of industrial facilities that may be interested in
locating in Carlsbad. The potential for off-site impacts from accidental releases is discussed for
seven industry types including: 1) pharmaceuticals and biotechnology; 2) golf club
manufacturing; 3)semiconductor fabrication; 4)electronics platingkircuit board and computer
electronics manufacturing; 5) chemicals manufacturing; 6) analytical instnunents/medical
apparatus; and 7) plastics and plastics products manufacturing. The risks of accidental release
impacting an off-site population, such as a child care center, for the seven industry types range
from relatively low for golf club manufacturers to relatively higher for chemical manufacturing
facilities. Most industries would present a medium level risk.
The study uses descriptive, rather than quantitative, values to evaluate off-site risks to sensitive
subpopulations in part because chemical use in the industrial areas of Carlsbad is likely to changt
significantly. Currently, approximately 65 percent of the Planned Industrial areas in Carlsbad
have not been developed. In addition, hazardous materials use in most industries changes over
time as a part of normal economic development. Existing facilities change the types and amounl
of chemical use as a routine part of business. New industry can use larger quantities of
hazardous materials than existing uses, or more toxic materials.
Hazardous Materials Rkks in Commercial Areas
In addition to the evaluation of hazards within industrial areas, this study briefly compares the
levels of risk in locating a child care facility in commercial versus industrial areas. There are
commercial businesses that use hazardous materials that can cause impacts in the event of an
accidental release. The types of commercial uses present in Carlsbad that would be most likely
to result in offsite impacts to a child care center include auto servicing facilities, swimming
pools, and pool and spa supply businesses. Transportation related incidents, particularly near
Interstate 5, are also a concern in commercial areas.
111 .. .
Typically the difference in risks between industrial and commercial areas is the difference in the
amount of chemicals used and stored by facilities in each land use area, The level of risk from
the smaller research and development facilities and small-scale manufacturing plants currently
found in the Planned Industrial areas of Carlsbad lies somewhere in between heavy industrial
uses, such as refineries and large chemical manufacturers, and general commercial uses.
Evacuation and Shelter in Place Measures
Potential measures to protect children from an accidental release of toxic substances were also
examined. These techniques include reducing children’s exposure in the event of an accidental
release through evacuation or sheltering in place, and measures taken by industry to prevent
accidental releases. Evacuation of potentially exposed populations (both adult employees ~INJ
children) can reduce public health effects due to accidental releases of toxic chemicals, The
major drawback to evacuation as a response option is the time necessary for its implementation.
Since children may not understand evacuation alarms, are less responsive than adults, and cannot
respond without assistance, the time period needed for evacuation is longer, increasing the
exposure duration and the potential for health impacts. Due to the special characteristics of
children, sheltering may be more appropriate than evacuation as a first response option for the
releases of hazardous materials which are quick& contained and have lower toxicities. In industrial
settings, specifically designed shelter room features can significantly reduce indoor air
concentrations for some types of release incidents. However, these rooms cannot eliminate
exposures to all released gases, particularly since scrubber and filtration systems are necessarily
designed for specific chemicals and cannot protect against all chemicals. Specifically designed
shelter rooms are not currently an appropriate measure to insure protection of children from
nearby accidental releases of airborne hazardous materials.
Child Care Needs Update
A Child Care Needs Assessment completed in 199 1 by International Child Resource Institute, ,
identified shortfalls in the child care supply in Carlsbad. An update of population trends and
actual child care supply in 1995 revealed that the child care supply has grown significantly over
the last five years. The overall ratio of child care spaces to population has increased from 0.13 to
0.19 and the projected number of child care spaces has exceeded projected needs in two of four
quadrants in the City.
Conclusions and Recommendations
Advances in the containment and handling of hazardous materials have greatly reduced the
chance of an accidental release of these substances, but have not totally eliminated risk. If child
care facilities are located in planned industrial areas, children may be exposed to accidental
releases of acutely hazardous materials. In the event of an accidental release, acutely hazardous
materials can pose a significant health risk to children on or near a release site.
It is difficult to accurately predict potential impacts to child care facilities, even on a case-by-
case basis. Each facility evaluation requires a great deal of information and careful analysis.
The gathering of the specific information required for a risk assessment is expensive and can be
difficult to obtain voluntarily from surrounding industries. Addressing each child care facility or
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new hazardous materials user on an individual basis would be time-consuming and expensive for
the City and Applicant alike.
One possible option for allowing child care within the industrial area, which would provide for
the safety of children while maintaining the industrial area for primarily industrial uses, would be
to allow on-site child care where a buffer can be established between the child care center and
activities using acutely hazardous materials. This option would not require costly modeling
studies and would take some of the uncertainty out of the development review pxocess. Under
&is option the City would continue to prohibit child care centers within planned industrial areas
except for on-site facilities within a larger industrid development.
Child care centers could be allowed with a conditional use permit if: 1) they are operated by a
company to serve on-site employees only; 2) are limited in size to the number of children that
could be safely evacuated within five minutes (as the number of children in the child care facility
increases the effectiveness of the evacuation becomes more important); and 3) are at least 1,000
feet (or more) from the site boundaries, or adjacent property owners legally commit not to use
specified quantities of acutely hazardous materials or other materials, such as ammonia ox
flammable materials, with potential off-site consequences. The sponsoring company would also
have to commit to not using acutely hazardous materials (above pxescribed amounts), or other
substances likely to endanger the children. This scenario does not preclude the possibility that
some companies may be required to provide more rigorous documentation related to their use of
hazardous materials, but it should limit the requirements, This would allow companies to have
on-site child care for their employees where there was a limited potential for impacts fiom and to
evacuate their children in the event of a hazardous situation.
Another action which the City should consider would be to modify the zoning ordinance to
prohibit child care facilities within 1,000 feet (or more) of users of specified quantities of acutely
hazardous materials, whether within the planned industrial area or adjacent commercial or
residential areas.
Allowing only on-site child care facilities of limited size in the industrial zones would reduce the
problems associated with the potential evacuation of children in the event of an accidental. release
of acutely hawdous materials, whether fiom an nearby industrial facility or during
transportation and unloading, In addition, maintaining safety buffers between industrial users of
acutely hazardous materials and child care facilities would greatly reduce the likely concentration
of an accidental release plume and allow greater time to implement an evacuation, if required.
Using an established safety buffer distance will avoid costly risk assessment studies for
individual facilities that may have to be updated as industrial uses and processes change. It
would also reduce some of the uncertainties related to whether a particular child care conditional
use permit would be approved, or conversely, whether new acutely hazardous material use would
be permitted. Allowing on-site child care within the planned industrial areas of Carlsbad under
these conditions provides a balance between providing child care facilities near employees’
places of work and maintenance of the integrity of the City’s Planned Industrial areas.
nearby industries. In addition, allowing only on-site child care facilities would allow parents to
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I. INTRODUCTION
This report provides a focused evaluation of public and health and safety issues related to
locating child care facilities within industrial areas in Carlsbad. This study was prompted by
implementation of recommendations contained in the 199 1 Carlsbad Child Care Needs
Assessment and Recommendations Summary Report prepared by the International Child
Resource Institute (ICRI), and the subsequent application for an on-site child care facility in an
industrial area of Carlsbad. In addition to the evaluation of hmds within industrial a-as, this
study addresses the relative level of risk in commercial areas and changes in child care supply in
Carlsbad since the 1991 Child Care Needs Assessment.
The City of Carlsbad contains a mix of industrial users regulated under various hazardous
materials laws, including pharmaceutical and biotechnology fms, golf club manufacturing,
electronics platingkircuit board and computer electronics manufacturing, chemicals
manufacturing, analytical instruments/medical apparatus manufacturing, and plastic products
manufacturing. Under the current General Plan, 2,174 acres of the City are designated for
industrial uses. Approximately 35 percent of this area is currently developed. As of May 1996,
45 1 facilities in Carlsbad have hazardous materials permits and three use acutely hazardous
materials1. Figure 1 shows the bound&es of the City of Carlsbad. Figure 2 shows the location
of the “PI” (Planned Industrial) areas within the City.
Additional and different use of hazardous materials by new companies or existing facilities can
be anticipated to occur as part of the normal economic development of the industrial areas.
Existing facilities change processes, production levels, and chemical use as a routine part of
business. New industry that moves into the industrial areas of the City could potentially use
larger quantities of hazardous materials and might even store materials outside, a situation which
can limit containment of an accidental release of hazardous materials.
There are several approaches that could be taken by the City of Carlsbad to address the siting of
child care facilities and industrial facilities near each other. Some options include: 1) prohibit
child care on any site designated for industrial uses; 2) limit child care within the industrial area
to on-site facilities, provided for employees who work on the same site; 3) allow child care in the
industrial area with restrictions; 4) limit child care in all areas of the City based on the proximity
to acutely hazardous materials users; and 5) allow child care within the industrial area without
restrictions. The purpose of this report is to provide additional information to the Administration
and Council of the City of Carlsbad, to assist them in selecting the appropriate option for their
city. This in & a comprehensive analysis of hazardous materials issues in Carlsbad, nor does it
evaluate a range of child care issues.
‘Three firms use quantities of acutely hazardous materials that are greater than “threshold planning
quantities” as defined in Chapter 6.95 of the California Health and Safety Code.
Child Care in Industrial Areas Page :
This study report will focus on four specific areas:
Sensitivity of children to chemical emissions;
0 Industry types in Carlsbad and hazardous materials issues associated with these
industries;
0 Potential for hazardous materials releases in commercial areas where child care facilities
are currently allowed;
Evacuation and shelter-in-place procedures and impacts on the provision of public safety
services in the event of an accidental release of hazardous materials.
An additional topic area, the ambient (or background) air quality in Carlsbad was also researched
as a part of this study. Specific air quality information is not available for Carlsbad, as reflected
in the letter report in Appendix A. Individual companies that emit airborne contaminants are
regulated by the Air Quality Management District. While individual permit information would
be available, ambient concentrations in the industrial area could only be determined through
modeling or sampling and testing. Since no regulatory agency maintains a monitoring station in
Carlsbad, information on localized background air quality does not exist.
This study has been prepared by David J. Powers & Associates under contract with the City of
Carlsbad. Gruen Gruen + Associates provided an update on child care supply within the City.
ENVIRON, a specialized firm of chemical engineers, toxicologists, and air quality specialists,
prepared the technical evaluations upon which this analysis is based. Both of these
subconsultants’ reports are included in their entirety in the Appendices.
The authors would also like to acknowledge Eriksen-Rattan Associates, a local Fire and Building
Code consulting firm based in San Diego, for review of information in the evacuation and
shelter-in-place discussion.
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This study report will focus on four specific areas:
0 Sensitivity of children to chemical emissions;
0 Industry types in Carlsbad and hazardous materials issues associated with these
industries;
@ Potential for hazardous materials releases in commercial areas where child care facilitie!
are currently allowed;
0 Evacuation and shelter-in-place procedures and impacts on the provision of public safeq
services in the event of an accidental release of hazardous materials.
This study has been prepared by David J. Powers & Associates under contract with the City of
Carlsbad. Gruen Gruen + Associates provided an update on child care supply within the City.
ENVIRON, a specialized fm of chemical engineers, toxicologists, and air quality specialists,
prepared the technical evaluations upon which this analysis is based. Both of these
subconsultants’ reports are included in their entirety in the Appendices.
The authors would also like to acknowledge Eriksen-Rattan Associates, a local Fire and Buildir
Code consulting firm based in San Diego, for review of information in the evacuation and
shelter-in-place discussion.
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11. SENSITIVITY OF CHILDREN TO CHEMICAL EMISSIONS
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Public agencies, such as the California Air Resources Board, recognize that children, in
general, are more susceptible to the effects of outdoor air contaminants than adults2. Becausc
they are recognized as a sensitive population, facilities that are used by children, such as
schools and day care centers, are considered “sensitive receptors” under various state and
federal regulations. Under these regulations, the proximity of sensitive receptors to sources (
effects be prepared or, even that a proposed source of chemical emissions not be located on a
particular site. In a risk assessment prepared under these requirements, risk is characterized
by determining the nature and magnitude of a possible exposure and comparing the exposure
to established “exposure limits” or standards. Risk assessments are discussed in more detail
Section III., Evaluation of Hazardous Materials Risks.
One of the most obvious aspects of the greater vulnerability children have to risks from
accidental releases of hazardous substances is their limited mobility. Children generally can no^
remove themselves from the area of impact. This issue is specifically addressed in Section VI.,
Accidental Release Protection Measures.
In addition, however, there is a widely held view in the health care community that children are
more sensitive to physical health impacts from many substances. This section is based on an
evaluation of short-term exposure risks prepared by Dr. Jill Ryer-Powder, a toxicologist at
ENVIRON. The evaluation itself is included in Appendix A under Task 1E.
A. Factors Influencing the Sensitivity of Children
Children are generally considered more sensitive to chemical exposure than healthy adults.
This is due to several factors. The first factor is that children have a higher respiratory rate
per body weight than do adults. Because of their respiratory rate relative to their body size,
children actually absorb a higher dose of a chemical than an adult, given the same
concentration of a chemical in the air.
Another factor is the difference in metabolism between adults and children. Chemicals often
are metabolized into either less toxic or more toxic chemicals in the body. Mechanisms that
detoxify chemicals may not be as efficient in children as in adults. In addition, mechanisms
that produce more toxic chemicals in the body may be more efficient in children, if certain
enzymes are more active. In other words, substances can have greater toxic effects in
children’s bodies.
chemical emissions may require that an assessment of the risk of potential adverse health
A third factor that has been cited as a difference between children and adults is the distance
between the point of inhalation and the point of absorption into the body (i.e. , the nose or
mouth to the bottom of the lungs where the blood and oxygen mix). This distance is far less
in a child, so that they would receive chemicals into their blood stream much faster than
adults.
2John Holmes, Chief Research Division, California Environmental Protection Agency, Air Resources
Board, written communications to Mike Smith, Fire Marshal, City of Carlsbad, June 14, 1995.
Child Care in Industrial Areas pat
B. Potential Adverse Health Effects from Acute Exposures to Selected Industrial
Chemicals
As discussed above, children represent a sensitive subpopulation with regard to the risk for
adverse health effects from exposure to chemicals. This is due, among other factors, to their
higher respiratory rate and lower body weight. There are no child-specific exposure limits,
standards, or guidelines for acute exposures, however.
Because child-specific exposure limits or standards for acute exposures have not been developed,
the basis for the various available standards which have been established was evaluated to assess
whether these limits would be protective of children. The following available health-based acute
exposure limit standards were reviewed:
0 The California Air Pollution Control Officer's Association acute reference
exposure levels (RELs)
0 The California Occupational Safety and Health Administration, Federal OSHA,
and the American Conference of Governmental Industrial Hygienists short-term
exposure limits (STELs) and Ceiling limits
0 The American Industrial Hygiene Association emergency response planning
guidelines (ERPGs)
0 The National Research Council emergency exposure guideline levels (EEGLs),
and Short-term Public Emergency Guidance Levels (SPELGs)
0 The National Institute for Occupation Safety and Health Immediately Dangerous
to Life and Health (IDLH) limits
0 The United States Environmental Protection Agency's Level of Concern (LOC)
Based upon a review of these regulatory standards and guidelines, it was found that the exposure
limits which may be protective of children include acute reference exposure levels (RELs),
emergency exposure guideline level-1 (ERPG-1 s), and Short-Term Public Emergency Guidance
Levels (SPEGLs). The other standards and guidelines reviewed are most likely not adequately
protective of children. The basis for each of these standards is discussed in detail in Appendix A.
C. Sensitivity of Children to Different Types of Health Effects from Chemical
Exposure
Acute exposure to chemicals can cause health effects, including irritation, central nervous system
depression, organ effects, and burning injuries to the eyes, skin, respiratory tract and stomach.
To illustrate how the exposure limits are used, and to show the range of impacts from different
kinds of chemicals, four chemicals represented on chemical inventories of existing industries in
Carlsbad are discussed in the following section, based upon these potential types of health
effects. Two of the standards and guidelines that are most likely protective of children are listed
for each of these four chemicals in Table 1.
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The four chemicals chosen for evaluation differ in their endpoints of toxicity. Chlorine is an
irritant, toluene is a central nervous system depressant, carbon tetrachloride can damage the livt
and kidneys, and hydrogen fluoride can cause burns on body tissues.
TABLE 1
Exposure Levels for Four Industrial Chemicals
Adverse Health Effects, Emergency Exposure Guideline Levels, and Acute Reference
Chemical
0.2-0.4 ppm 0.07 ppm 1 PPm* Irritant Chlorine
Odor Threshold REL4 ERPG-13 Health Effect
Toluene Central Nervous I 50ppm 1 9.8 ppm 1 0.16-37 ppm
System Depression -1
Carbon
Effects Tetrachloride
Liver and Kidney 20ppm I 0.13 ppm I 96ppm
Hydrogen
* ppm = parts per million
Fluoride
0.04-0.13 ppm 0.17 ppm 5 PPm Caustic Injuries
Irritants
There is’no available data to evaluate the potential for increased sensitivity to irritants in
children. However, it is likely that children would be more sensitive to respiratory irritants thar
would adults due to children’s more rapid respiratory rate.
Central Nervous System Depressants
Solvents, like toluene, are typical central nervous system depressants. Solvents would be an
example of a class of chemical that would have a greater effect on children due to an increased
dose. Since children have a more rapid respiratory rate and lower body weight than adults, theq
would inhale an increased dose.
Chemicals Causing Target Organ Damage
Carbon tetrachloride is an example of a chemical that causes target organ damage through the
formation of a toxic metabolite from enzymes in the body. It is not known whether there is a
difference in activity or number of the toxifying enzymes in children. It is therefore not known
whether children would be more susceptible to the toxic effects of carbon tetrachloride. Again,
however, children would receive a higher dose of the chemical than adults, which may render tl
children more sensitive than adults to the same air concentration.
3The maximum concentration below which nearly all individuals would experience no more than mild,
temporary adverse health effects or perceive an objectionable odor.
4Defined as levels of exposure at or below which adverse health effects are not anticipated.
Child Care in Industrial Areas Pagc
Caustic Chemicals
Because of the smaller anatomy of a child (i.e., distance between point of inhalation and contact
of chemicals with the bloodstream), a caustic chemical may cause more damage in a child than
an adult.
~ ~~ ~~~ ~ ~ ~~~
Conclusion: It is likely that exposure to selected industrial chemicals would cause more
physical damage in a chJd than in an adult. Should the City decide to allow child care near
industrial users, it is assumed that some level of site-specific risk analysis would be done, both
for the child care facility and for any future use of hazardous materials near it. The most
relevant standards for evaluating potential risks to children to be used in such an assessment
would be the ERPG-1 and REL guidelines, in that they would be most protective of children.
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111. EVALUATION OF HAZARDOUS MATERIALS RISKS
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A. Definition of Hazardous Materials and Acutely Hazardous Materials
1. Hazardous Materials
"Hazardous materials" are defined by the California Health and Safety Code as "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 work place or the environment." The term "hazardous materials" includes
several subcategories of chemicals designated by California Code and U.S. Federal Code as
hazardous due to potential health effects resulting from short term or long term exposures when
released into air, water, or soil, or from direct contact.
All businesses located in San Diego County that use or store certain minimal amounts of
hazardous materials are required to file a "Business Plan'' with the County Department of
Environmental Health. This agency acts as the local Administering Agency under the Californi
Health and Safety Code'. Each of the Business Plans must contain a list of chemicals and
associated quantities, a site map showing where they are stored, an onsite emergency response
plan, and a description of the training employees receive.
2. Acutelv Hazardous Materials
For the purposes of this study, hazardous materials which.are of particular concern for the siting
of a child care facility within an industrial area are the subcategory chemicals that, if accidental]
released to air, could cause health effects due to acute (short-term) exposures. "Acutely
Hazardous Materials" (AHMs), as defined by California Health and Safety Code (Chapter 6.95,
Section 25532), are substances that have the greatest potential to pose a hazard to public health
and the environment in the event of accidental release. Note that this does not include expZosivl
or flammable materials, as such.
B. Definition of Risk and Risk Assessment
1. Definition of Risk
A simple definition of risk is the chance of encountering harm or loss. With respect to hazard01
materials, risk is generally perceived by the public as the chance or probability of injury, diseasc
or even death resulting from human exposure to hazardous substances.
Risk can be characterized in qualitative or quantitative terms. Qualitative, or descriptive, terms
that can be used include high, medium, and low. Quantitative terms are based on numerical
estimates and statistical calculations. They include probabilities, such as one in one million, an(
'Quantities that require preparation of a Business Plan are: more than 55 gallons (liquid), 500 pounds
(solid) or 250 cubic feet (gas) of a hazardous material, or over the threshold planning quantity of an extremely
hazardous material as defined by the Federal Code of Regulations (Chapter 6.95, Article 2, Section 25532).
Child Care in Industrial Areas Page
estimates of the distance from a source or area around a facility that is vulnerable to exposure to
hazardous materials at levels greater than established health standards.
There are many different types of risk in everyday life and and society has varying attitudes
toward those risks. Considered in a vacuum, without taking into consideration the various
circumstances which may also bear on a particular decision, it is easy to say that only the lowest
level of risk is acceptable. It is usually advisable to evaluate all available information, however,
in order to understand what the real nature of a particular risk may be, and what methods for
reducing it are available.
The risk of an accidental release of a chemical impacting a population is a function of the
likelihood of the release occurring and the health consequences of such an event. Many types of
releases could involve a hazardous substance, but the potential for it to actually injure someone
would be very low. For example, a liquid release that spills on the ground could be cleaned up
before coming in contact with anyone other than trained personnel. A gaseous chemical kept in
very small quantities could be released into the air, but disperse so quickly that it is diluted
before it can affect anyone. The particular characteristics of a chemical can determine how far
and fast it will disperse, as well as how severely it would affect human health.
An important aspect of risk is associated with the quantity of the hazardous material. While
ammonia as a household cleaner is kept in small quantities, ammonia kept in very large
quantities for industrial purposes (as a refrigerant, for example) can be considered a potentially
significant risk to people off-site. Other factors which influence the level of risk from an
accidental release in a particular situation include weather (wind speed, in particular), terrain, and
the manner in which a hazardous material is stored and handled.
As discussed in the previous section on the sensitivity of children, the type of human health risk
can also vary. Physical impacts can range from irritation to injury to death. Impacts can differ
between healthy adults, the elderly, persons with health problems, and children. Of greatest
concern is the situation where the human health consequences of a release are high, and the
likelihood of such a release occurring is considered medium or high.
2, Risk Assessment and Risk Management
The chance, or probability, of an accidental release of hazardous materials causing harm can be
calculated using established methods known as risk assessments. Risk assessment can be used to
help public agencies make decisions about whether the risks associated with an accidental release
at a particular site are acceptable. An assessment evaluates whether a release from a particular
source could impact human “receptors” at specific locations based on the particular conditions
for that site.
In a risk assessment, “risk” is characterized by determining the nature and magnitude of a
possible exposure to a particular chemical and comparing the exposure to established standards.
Several of these standards were previously discussed in Section II., Sensitivity of Children to
Chemicals. The factors, or types of information considered in a risk assessment are shown on
Figure 3.
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RISK: A chance of encountering harm or
loss; hazard; danger.
Factors that influence risk include:
toxicity
the kinds of chemicals used’
‘mobility (solid, liquid,
gas, vapor pressure)
the quantities (amount) used
0 the types of processes and
-equipment
/ wind speed and
direction
the environment
\temperature
~ i the proximity of ,industrial surrounding land uses
to the source y;::::;:
sensitive populations
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FIGURE 11
Risk assessments can address both on-site risks to employees (or other occupants of the site) and
off-site risks to the community. An off-site consequence analysis is a type of risk assessment
that looks at the potential health consequences to populations beyond the boundaries of a facility.
Depending on its location, a child care facility might be impacted as either an on-site or off-site
consequence. The critical issues are how far away the source of the release is from the child care
facility and how much of the chemical is released. These are the major factors that will
determine what the concentration is when it reaches the children (or other receptors), and
whether that concentration would exceed the exposure standard.
Risk Management is the planning for and implementation of measures that might reasonably be
expected to reduce the risk of adverse consequences from accidental hazardous materials
releases. Measures to reduce risks or hazards that can be adopted by particular businesses
include changes in the physical design of the facility, operating methods, processes, materials, or
accidental release prevention. Regulatory agencies have also adopted increasingly rigorous
requirements for storing, transporting, and using hazardous substances.
C. Overview of the Risk Management and Prevention Program
California’s Risk Management and Prevention Program is the result of a state regulation
designed to prevent or mitigate the impacts that may result from the accidental release of acutely
hazardous materials. This is done by identifying manufacturers and handlers of Acutely
Hazardous Materials (AHMs) and then predicting which geographic locations may be affected by
potential releases of AHMs. If off-site consequences are predicted, then the program requires the
user consider changes in equipment, training programs, operating and maintenance procedures,
mitigation systems, and emergency response plans. A Risk Management and Prevention
Program (RMPP) generally includes an analysis of the facility’s accident history, a study of the
history of equipment at the facility, an analysis of the facility design and operations procedures, a
hazard and operability study, a seismic analysis, an analysis of preparedness for external events,
and an off-site consequence analysis.
The regulation requires that administering agencies, such as county environmental health and
safety departments, prioritize the potential hazards of the use of hazardous materials and
establish a timetable for companies to submit RMPPs for review. The timetable requires that
companies with the highest potential hazards submit RMPPs within the first wave of submittals.
Companies with a lower potential for hazards would submit RMPPs later in the process, or may
not be required to submit RMPPs at all, if hazards can be shown to be minimal. Thus, where in
the schedule of submittals a particular company’s RMPP is required, is an indication of its
potential hazard.
The County of San Diego, which is the local administering agency for the City of Carlsbad, uses
a “screening” or prioritization process to determine whether a facility which uses acutely
hazardous materials will be required to complete an RMPP, The screening process considers the
relative risks associated with a facility should an acutely hazardous materials accident occur.
This process considers the type and quantity of materials used, facility design and safety
measures, the proximity of sensitive land uses (such as child care centers, schools, residences,
frequency of safety inspections at a facility, Education and training of employees is also key in
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COMPARISON OF THE BUSINESS PLAN, CALIFORNIA RMPP,
AND OTHER ENVIRONMENTAL AND SAFETY PROGRAMS
-~...flC”“- ”i
BUSINESS PLAN
All Hazardous Materials
Users File with San Diego
County Department of
Environmental Health
Key Elements:
Site Plan
On-site Emergency
Employee Training
Name of Emergency
~ List of Waste Generated
0 List of Chemicals
Response Plan
Contact
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RMPP (State)
0 Handlers of Acutely
Hazardous Materials in
amounts greater than
“Threshold Planning
Quantities” may be
Required to prepare an
RMPP based on priorities
set by the Administering
Agency (San Diego
County)
Key Elements:
0 Accident History
Design, Operating and
Maintenance Controls
Detection, Monitoring and
Automatic Control Systems
Implementation of
Additionai Steps
Inspection Program
Hazard and Operability
Off-site Consequence
Study
Analysis
OTHER PROGRAMS
Risk Management Plans-
RMPs (Federal-EPA)
Occupational Health &
Safety Administration
Process Safety Management (OSHA)
(PSW
Regional Air Quality Control 1
Program
Boad-Toxic Hot Spots 1
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FIGURE
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and hospitals)6, meteorological conditions, and may also include an onsite inspection of the
facility. Facilities are reevaluated on a periodic basis, approximately every five years. Thus a
facility that uses acutely hazardous materials that was not required to prepare an RMPP during its
initial screening, could be required to prepare an RMPP if a sensitive use, such as a child care
facility subsequently locates nearby.
The RMPP program is in various stages of completion in different counties in California. Thus,
not all RMPPs that have been requested by administering agencies have been completed, or are
currently available for public review, In addition, not all RMPPs that may be requested have
been requested at this time. However, RMPPs that are available have been prepared by those
industries which are considered to have the highest potential for off-site impacts within their
particular county.
The San Diego County Department of Environmental Health was contacted in order to obtain
RMPPs for the industry types selected for the Carlsbad Child Care Study. No RMPPs were
available for companies located in Carlsbad, although one for a pharmaceutical company is
currently being prepared. RMpPs from San Mateo County and Santa Clara County were also
reviewed to supplement information available in RMPPs from San Diego County. Only RMPPs
for the semiconductor fabrication, electronics plating, and chemicals manufacturing industry
types were available for review in the three counties listed above. RMPPs for other industry
types were either not yet available, or companies in those categories were not currently selected
for the RMPPs process.
A comparison of the California Risk Management and Prevention Program and other
environmental and safety programs is shown on Figure 4.
_____~~~
%ection 25534.1 of the State of California Health and Safety Code (Chapter 6.95) requires that the
proximity of schools, residential areas, hospitals, long-term-health care facilities, and child day care facilities be
considered as part of the RMPP process. “Proximity” is not specifically defined in this section, however
Administering Agencies often use standards in the State Public Resources Code (Sections 2 1 15 1.4 & 2 1 15 1 .S) or
Sections 4230 1.6 and 42301.7 of the Health and Safety Code that apply to schools. These regulations address
facilities that may emit hazardous or acutely hazardous air emissions materials and are located within one-quarter
mile (1,340 feet) or 1,000 feet of schools.
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IV. HAZARDOUS MATEFUALS AND POTENTIAL IMPACTS
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The following discussion is based upon a review of industry types in Carlsbad prepared by
ENVIRON. This review included consultation with the Carlsbad Fire Department and the San
Diego County Department of Environmental Health, and examination of technical references.
The ENVIRON report is included in Appendix A under Task 1 A.
The hazardous materials used by each industry type in Carlsbad which may be of concern for th
siting of a child care facility are identified and discussed below. The identification of these
hazardous materials is based upon a review of available Risk Management and Prevention Plan
(RMPPs) for each industry type and various reference materials. This section also contains a
qualitative evaluation of the risks of accidents for selected industry types. More detailed report
prepared by ENVIRON on these topics are included in Appendix A, under Tasks lB, lC, lD,
and 1F.
A, Methods for Selecting Industry Types
In order to begin this study, the City of Carlsbad Fire Department prepared a list of the
predominant industry types currently in Carlsbad and those considered most likely to locate in
Carlsbad. The names of some companies within each category were also provided. In order to
evaluate and augment this information, the following sources were reviewed:
San Diego County Department of Environmental Health hazardous materials lists for tht
companies whose names where provided by the Fire Department.
0 The San Diego County's Risk Management and Prevention Program selection list.
0 Carlsbad Chamber of Commerce business activity directories.
0 Industry and processing descriptions from reference texts. (Sax 1987, Parker 1989,
Austin 1984, Hyer 1990, Grayson 1985, EOP 1987)
0 World Wide Web company descriptions for Carlsbad companies.
Based on analysis of the above sources, and discussions with companies concerning their
products and processes, the original list was refined to select and define the industrial categorie
to be analyzed in this study. Identification of industries considered likely to locate in Carlsbad j
the future was based solely on information provided by City staff.
B. Industry Types
Industry types were evaluated included industries with a current presence in Carlsbad and those
the City thought most likely to locate in Carlsbad in the future. The analysis focuses on those
industries considered likely to use or store hazardous materials, which might result in an
accidental release of concern . [Note: There is no implication that these industries or companies
selected for the current study.
are themselves considered particularly likely to have such a release.] Seven industry types were
1 Child Care in Industrial Areas Page
These industry types are:
a pharmaceuticals and biotechnology
golf club manufacturing
e semiconductor fabrication
a electronics platingkircuit board and computer electronics manufacturing
a chemical manufacturing
a analytical instruments and medical apparatus
a plastics and plastic products manufacturing.
Each of these industries, the reason for selection and grouping of the industry types, and a
description of their status in Carlsbad are described below.
It should be noted that although the predominant industries and industrial processes located in
Carlsbad are identified, this report does not include &l industries in Carlsbad, not even all
industries which may use hazardous chemicals. Nor, by its nature, can it include all industries
that may locate in Carlsbad in the fbture.
C. Hazardous Materials and Risks of Accidental Releases By Industry Type
Depending on the products manufactured and processes used, different industries and individual
companies within categories of industrial types may use different hazardous chemicals. Due to
the variability of chemicals that may be used from company to company within an industry, this
list is not inclusive of all chemicals. However, it should include most major hazardous chemicals
and chemical categories of concern with a potential for off-site impacts within a given industry.
Based on a review of available RMPPs and the U.S. Environmental Protections Agency’s
Accidental Release Information Program (ARIP), ENVIRON analyzed the potential for impacts
from accidental releases for each of the selected industry types. The potential impacts, including
the distance within which potential off-site “concentrations of concern” can be expected are
discussed in this section7.
Available RMPPs were reviewed to evaluate which industries had the potential for off-site
impacts. It is important to note that the potential for off-site impacts occurring in the event of an
accidental release are a function of: 1) the amount of chemical stored at that particular facility; 2)
how they might be released; and 3) the meteorological conditions at the time of the release.
RMPPs analyze the maximum off-site impacts that would occur in a worst-case release under
meteorological conditions considered likely to maximize off-site impacts. Therefore,
information in the RMPP can be used to establish a worst-case scenario’.
7 “Concentration of concern” might be understood as a radius of potentially significant impact. It refers to
the distance from a source within which a substance is concentrated enough to be a potential risk. The term,
concentration of concern, is defined in the RMPP program for each chemical. It generally refers to either one-tenth
the level immediately dangerous to life and health (IDLH), or the emergency planning response guidelines (ERPG)
level two or three.
‘Worst-case scenario refers to conditions that would result in maximum off-site concentrations of hazardous materials following an accidental release from a specific source, Under these conditions, a maximum
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1. Pharmaceuticals and Biotechnolo?
The pharmaceutical and biotechnology industries have been categorized as a single grou
for the purposes of this study. Pharmaceuticals are defined to include drugs and
medicinal products and ancillary products such as dietary supplements, vitamins, and
deodorants. Biotechnology is defined as the use of biological agents and living cells in
engineering applications and chemical processing. Pharmaceuticals can be produced
through using biotechnology, such as fermentation and extraction from living cells, as
well as through traditional chemical synthesis. Hence, although biotechnology can be
used for processing unrelated to pharmaceuticals (e.g., beer production), the
biotechnology industry in Carlsbad is related primarily-to pharmaceuticals development
and the hazardous materials used by each industry type overlap. Therefore, the two
industries have been grouped into one industrial category for the purposes of this study.
Based on a survey of the pharmaceutical and biotechnology companies in Carlsbad, this
industrial category is understood to be currently represented in Carlsbad by research and
development and small scale production of drugs, medical reagents, food supplements,
and cosmetics. Research. facilities and laboratories predominate, but pilot and small scal
production is also present. A few companies surveyed also mentioned the possibility of
expanding to larger scale manufacturing. Both chemical synthesis and bioprocessing are
used in development and production by Carlsbad pharmaceutical and biotechnology
companies.
Pharmaceutical producers and biotechnology companies can use and store a variety of
substances for their processes. Based on release histories for pharmaceutical
manufacturers in the ARIP database, chemicals and chemical categories used by this
industry type which have a history of release include ethylene oxide, halogenated organil
gases, organic solvents, toxic gases, and acidic and caustic liquids9. Carlsbad companies
in this industry use several specific volatile acutely hazardous materials, including
acrylonitrile, ammonia, benzyl chloride, chlorine, chloroform, epichlorohydrin,
formaldehyde, hydrazine, hydrogen chloride gas, and hydrogen sulfide. Sulfuric acid anc
acrylamide, although less volatile, are also stored in significant quantities.
Pharmaceutical manufacturers also often store pharmaceutical compounds such as
narcotics that are highly toxic in small doses. These were not evaluated here. In
addition, biologically active agents have not been considered in this analysis.
Although there are a wide variety of hazardous materials used by pharmaceutical and
biotechnology companies in Carlsbad, most are stored in relatively small quantities or ar'
not very volatile, so a release with a potential for impacting off-site populations is less
likely. However, hydrogen chloride gas and ammonia are gaseous and are stored in
larger quantities.
amount of material would be released under weather conditions that would maximize impacts.
9 Examples of halogenated organic gases include dichloromethane, organic solvents include methyl
isobutyl ketone, methanol, and toluene, toxic gases include chlorine and ammonia, and acidic and caustic liquids
include sulfuric acid, hydrochloric acid, and sodium hydroxide.
Child Care in Industrial Areas Page 1
Potential Impacts Based on a Review of RMPPs
(Pharmaceuticals and Biotechnology)
Although there are several pharmaceuticalhiotechnology companies in Carlsbad, only
one pharmaceutical company is currently required to submit an RMPP. That RMPP is
not yet available for public review. An off-site consequence analysis has been completed
for the one other pharmaceuticalhiotechnology company on the San Diego County
RMPP selection list. The analysis indicated that concentrations of concern of propylene
oxide may occur up to 700 feet from the point of release.
As with all other companies and industry types, the magnitude and existence of these
impacts are directly related to the types and amounts of acutely hazardous materials
handled. Based on a review of hazardous materials stored by Carlsbad pharmaceutical
companies and accidental release histories for the industry fiom the ARIP database, there
is the potential for public impacts from accidental releases from some companies of this
industry type, particularly those who store large quantities of toxic gases, such as
hydrogen chloride, chlorine, and ammonia.
Risks of Accidental Releases
(Pharmaceuticals and Biotechnology)
For this industrial category, the ARIP database was searched for releases by companies in
the following categories: 1) medicinal chemicals and botanical products, 2)
pharmaceutical preparations, 3) in vitro and in vivo diagnostic substances, 4) biological
products, except diagnostic substances, and 5) perfumes, cosmetics, and other toilet
preparations.
According to the ARIP database, several accidental releases of hazardous chemicals have
been reported at pharmaceutical/ biotechnology companies since 1986. Only the
pharmaceutical preparations and perfumes/cosmetics/toilet preparations categories had
reported releases. A total of approximately 30 releases were reported, nine having on-
site impacts, and two having public impacts". Chemicals released include chlorine,
sodium hydroxide, ammonia, ethylene oxide, halogenated organics, hydrochloric acid,
organic solvents, and sulfuric acid.
As discussed above, the volatile acutely hazardous chemicals handled in larger quantities
by Carlsbad companies include hydrogen chloride gas and ammonia. Based on this
information and the accidental release reports provided by Carlsbad and the ARIP,
accidental releases from the pharmaceutical/ biotechnology industry group have the
potential for off-site impacts. The chemicals which appear to have the most potential for
accidental release and off-site impact for this industry are hydrogen chloride gas,
ammonia, chlorine, and halogenated organics.
*o''Impacts'7 listed in the AMP database are defined to include injuries, hospitalizations, and deaths. Required
evacuations or instructions to shelter-in-place are also listed as impacts in this database.
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2. Golf Club Manufacturing
CarIsbad is home to several golf club manufacturing companies. Based on a survey of 2
few of these companies, golf club manufacturing in Carlsbad is primarily composed of
the assembly of golf club components, shaft manufacturing, and research and
development. Processes may include chemical processing, forging, extrusion, drawing,
powder metallurgy, bonding, grinding, painting and detailing, coating, and cleaning.
Based on records from the San Diego County of Environmental Health, the hazardous
materials used by golf club manufacturers in Carlsbad include non-toxic gases (e.g.,
nitrogen, oxygen, argon), organic solvents (e.g., acetone), and halogenated solvents. Nc
AHMs were listed as used or stored in the database provided from the county. Also, no
incidents of accidental releases are recorded in USEPA's nationwide ARIP database for
manufacturing of sporting and athletic goods. However, based on a survey of a few
Carlsbad companies, at least one golf club manufacturer is involved in graphite and
titanium processing and coating for shaft development and production.
Potential Impacts Based on a Review of RMPPs
(Golf Club Manufacturing;)
No companies in this category are listed on the San Diego County selection list.
in this category from the RMPP selection list may indicate that, based on the chemicals
used and amounts handled, the county does not believe that existing companies in this
category pose a significant hazard to off-site communities. Thus, while it is possible tha
certain companies that fall into this category may have the potential for accidental
releases that have off-site impacts, the probability is considered low.
Therefore, no RMPPs were reviewed for this industrial category. Exclusion of compani
Risks of Accidental Releases
(Golf Club Manufacturing;)
No incidents .of accidental releases are recorded in USEPA's ARIP database for the SIC
classification relevant to this industrial category, manufacturing of sporting and athletic
goods. However, based on a survey of a few Carlsbad companies, at least one golf club
manufacturer is involved in graphite and titanium processing and coating for shaft
development and production. Therefore, in an attempt to ensure that operations that mal
be occurring at the Carlsbad facility are fully considered, the ARIP database was searche
for accidental releases related to processing of graphite and titanium. Based on this
search, it is considered possible that toxic gases (e.g., ammonia, boron trichloride), acidi
liquids (e.g., hydrofluoric acid, sulfixic acid, nitric acid, chromic acid), and other toxic
liquids (e.g., sodium cyanide solutions) may be used in the golf club manufacturing
industry. The purpose of this phase of the research is to evaluate the implications of
possibZe hazardous materials use in the industrial areas. It is important to note that not
all operations identified and listed below are taking place, or are likely to take place, at
facilities in Carlsbad. In order to be conservative, a broader range of industrial operation
was evaluated than is likely to occur in golf club manufacturing.
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Certain metal processing facilities were identified in the database as having release
histories. No public off-site impacts were reported. Chemicals released included
hydrofluoric acid, potassium hydroxide, and ammonia. A total of 24 releases were
reported for metal coating, engraving and allied services, none of which appeared to be
specifically related to sporting goods manufacturing. Chemicals released include cyanide
compounds (e.g. sodium cyanide, nickel cyanide), nitric acid, chromic acid, hydrochloric
acid, sulfuric acid, ferric chloride, and boron trichloride.
No AHMs were listed as being currently stored by golf club manufacturing facilities in
Carlsbad. In addition, no accidental releases are reported in the ARIP database for
sporting and athletic goods manufacturers. Finally, no accidental releases even from ,
possibly related classifications resulted in public impacts. Therefore, the risk of
accidental releases actually resulting in public impacts that may be of concern for the
siting of a child care facility from this industry type are relatively low. However, as
several AHMs may be used in metal processing and coating for this industry, there is still
some minimal potential of off-site impacts being possible in the future.
3. Semiconductor Fabrication
Semiconductor fabrication is the processing of semiconductor materials (e.g., silicon,
gallium-arsenide) and use of solid-state technology to produce electronic and optical
devices such as integrated circuits, solar cells, photo diodes, and semiconductor lasers.
Processes include crystal growth, oxidation, etching, photolithography, ion implantation,
chemical vapor deposition, metal plating, testing, and encapsulation (packaging). Based
the Fire Marshal, there are currently no large scale semiconductor fabrication facilities in
Carlsbad. However, based on conversations with City staff, there may be semiconductor
fabrication operations interested in locating in Carlsbad in the future.
Semiconductor fabrication facilities utilize a variety of toxic chemicals in their processes
and store these chemicals in large quantities. Hazardous materials used include toxic
gases, acidic and caustic liquids, organic solvents, halogenated solvents, and alkyl metals.
Several AHMs used by this industry include chlorine, ammonia, fluorine, sulfur dioxide,
hydrogen fluoride gas, hydrogen chloride gas, arsine, phosphine, diborane, boron
trifluoride, boron trichloride, phosphorous trichloride, phosphorous oxychloride, sulfuric
acid, hydrofluoric acid, nitric acid, and tellurium.
on a survey of Carlsbad companies provided by the Fire Department and discussions with
Potential Impacts Based on a Review of RMPPs
(Semiconductor Fabrication)
There are two semiconductor fabrication facilities on the San Diego County RMPP
screening list, one of which has an RMPP in its public comment period. Because this is
such a small base for a meaningful evaluation, other County databases were checked.
Several RMPPs were available for semiconductor fabrication facilities in Santa Clara
county.
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In the RMPPs reviewed in San Diego County and Santa Clara County, off-site impacts
were predicted for several chemicals, including ammonia, chlorine, boron trifluoride, arsine, diborane, hydrogen chloride, nitrogen tnfluoride, and phosphine. The distances
fiom a hazardous materials source within which a substance could be concentrated
enough to be a risk to human health, were predicted to be up to 900 feet from the point 0:
the chemical release, and over 700 feet beyond the facility boundaries".
It appears that semiconductor manufacturing facilities have the potential to cause off-site
impacts in the event of an accidental release under worst-case situations. Certain
mitigating measures, such as the requirements of restrictive flow orifices (RFOs) for
valves on gas and pressurized liquid cylinders can significantly reduce such impacts.
However, even with such mitigation measures, available information would suggest that
accidental releases at semiconductor manufacturing facilities can result in off-site
impacts.
Risks of Accidental Releases
(Semiconductor Fabrication)
The ARIP database was searched for releases from the classification which includes the
manufacturing of semiconductors and related devices. The category of metal coating,
engraving, and allied services was also searched for releases specifically related to the
semiconductor industry. Nine releases were reported for the semiconductor category, tw
having on-site impacts, and none having off-site impacts. The chemicals with on-site
impacts were nitric acid and chlorine. Other released chemicals included nitrogen oxide
sulfuric acid, hydrofluoric acid, hydrogen fluoride, acetic acid, and phosphoric acid. Fiv
releases .related to the semiconductor industry for the coating and engraving processing
category were reported, none with public impacts. However, one release resulted in on-
site impacts. The chemicals released were tetrachloroethylene and boron trichloride.
To supplement the accident reports from the ARIP database, ENVIRON reviewed releas
histories from RMPPs for a few semiconductor facilities in Santa Clara County. Several
releases of sulfuric acid not recorded in the ARIP database were found during this revie1
none with off-site impacts.
4. Electronics PlatindCircuit Board and Computer Electronics Manufacturinp
For the purposes of this study, this category is defined to include electronic plating
processing for the production of circuit boards and other electronic components (not
including semiconductor fabrication). Processes include chemical treatment, plating,
heating, coating, etching, cleaning, and photo processing. This is a broad industrial
category with a current presence in Carlsbad.
Electronics plating facilities involved in the manufacturing of circuit boards and
computer electronics use and store several of the same hazardous materials as
~~~ ~
"It is important to note that these analyses were conducted using a worst case accident scenario.
I Child Care in Industrial Areas Page
semiconductor fabrication facilities (e.g., sulfuric and nitric acid). Hazardous materials
used by this industry type include the following: acidic and caustic liquids such as
sulfuric acid, sodium hydroxide, and hydrochloric acid; organic solvents; halogenated
organics; metal salts and metal cyanides. However, no AHMs were listed by the one
company in this industry for which the San Diego County Department of Environmental
Health provided hazardous materials information.
Potential Impacts Based on a Review of RMPPs
(Electronics PlatingKircuit Board and Computer Electronics Manufacturing;)
Several RMPPs were reviewed to determine potential off-site consequences of an
accidental release. Although several companies within this industry group are located in
Carlsbad, none of these facilities are on the San Diego County RMPP selection lists.
Five electronics plating/circuit board and computer electronics manufacturing companies
in San Diego County are on the County’s RMPP selection list and one was available for
review. Because this is such a small base for a meaningful evaluation, RMPPs were also
reviewed from Santa Clara County.
The available off-site consequence analysis from San Diego County indicated that
impacts from an accidental release of ammonia gas codd occur at a distance up to 1,000
feet from the point of release. An off-site consequence summary for a company located
in Santa Clara County also indicated that estimated impacts from accidental releases may
occur out to approximately 1,000 feet from the point of release.
Risks of Accidental Releases
(Electronics PlatingKircuit Board and Computer Electronics Manufacturing;)
To determine the risks of accidental release fiom this industrial category, the ARIP
database was searched for releases from several relevant codes. The categories searched
include the following: 1) printed circuit boards, 2) electronic capacitors, 3) electronic
resistors, 4) electronic coils, transformers, and other inductors, 5) electronic connectors,
6) electronic components, 7) electronic equipment and supplies, 8) electronic computers,
9) computer storage devices, 10) computer terminals, and 1 1) computer peripheral
equipment. The category for [Metal] coating, engraving, and allied services was also
searched for releases specifically related to the electronics plating industry. In an effort to
include all activity that may be related to the electronics platingkircuit board and
computer electronics manufacturing industrial type, a broad range of activities was
included in the search. Approximately 20 accidental releases were reported in the
following categories: printed circuit boards, electronic connectors, electronic
components, electronic computers, computer storage devices, computer terminals,
computer peripherals, and metal coating. No off-site impacts, such as injuries or
hospitalization, were reported in the AMP database, however. Chemicals released
included hydrofluoric acid, sulfuric acid, nitric acid, sodium hydroxide, hydrogen
chloride, chlorine, ammonia, halogenated organics, organic solvents, hydrogen peroxide,
and nitrogen dioxide.
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To supplement the histories listed in the ARIP database, ENVIRON reviewed accident
lists for companies in Carlsbad provided by the San Diego County DEH. Several release
of hydrogen chloride, nitric acid, sulfuric acid, and acid waste were listed in the RMPPs,
histories from RMPP reports for Sslnta Clara County and reviewed hazardous materials
B but no history of off-site impacts were found.
Although no off-site impacts were listed for any of the past releases listed in this indusw
group, there were a number of accidental releases for companies which have occurred in
this industry group. Therefore, it appears that this industry group has the potential to
cause off-site impacts from accidental releases.
5. Chemicals Manufacturing
Chemicals manufacturing is the development and production of industrial chemicals.
Processes can vary widely, but include chemical synthesis, neutralization, separations,
mixing, and heating. In Carlsbad, companies that manufacture chemicals produce
industrial gases and specialty chemicals for the semiconductor and electronics industries
and medical reagents and pharmaceutical chemicals. For the purposes of this study,
however, medical reagent and pharmaceutical processing is addressed in the
pharmaceuticals and biotechnology industrial category. Thus, only one facility in
Carlsbad is currently included in the chemicals manufacturing category analyzed for this
report.
This industry type includes a broad range of chemical processes. Thus there are large
quantities of many hazardous chemicals used and stored by companies in this category.
AHMs used by an industrial gas manufacturer in Carlsbad include sulfuric acid,
hydrogen chloride gas, and phosphorus oxychloride. Other AHM's used throughout the
industry with a history of accidental release include chlorine, ammonia, phosgene,
hydrogen fluoride, hydrogen chloride, sulfur dioxide, sulfur trioxide, bromine, boron
trifluoride, phosphorus oxychloride, ethylene oxide, chloroform, nitric acid, nitric oxide
Potential Impacts Based on a Review of UPPs
(Chemicals Manufacturing;)
There are several chemicals manufacturers and suppliers in San Diego County. One
company that primarily supplies specialty gases for the semiconductor industry is locate
in Carlsbad. The one Carlsbad company in this industry type was screened out of the
RMPP analysis and, according to company representatives, risk modeling performed fo~
their current operations indicated no off- site impacts.. Seven companies in this industrj
category are on the San Diego County RMPP selection list, of which three are available
for public review. Santa Clara County also has a few completed RMPPs from chemical
suppliers. It is important to note that chemical manufacturing covers a wide range of
considered in that context.
A review of the off-site consequences in RMPPs for two industrial gas suppliers and tw
chemical distribution centers in San Diego County and Santa Clara County indicate thal
potential activities. Therefore, any generalizations in this industry group must be
Child Care in Industrial Areas Page
off-site concentrations of a worst-case accidental release of some hazardous chemicals
may exceed concentrations of concern up to 5,000 feet from the point of release. As the
storage amounts and release conditions can vary significantly between manufacturers and
releases, that distance should not be used to define an impact area for.the entire industry.
However, it does illustrate that the chemicals manufacturing group has a particularly
significant potential to cause off-site impacts.
Risks of Accidental Releases
(Chemicals Manufactwin&
Based on analysis of search results from the ARIP database, this industrial category was
found to have the highest risk of accidental release and public impact of all the industry
types selected in this study. Due to the large amount of information generated, database
searches were limited to the following relevant categories: 1) alkali compounds and
chemicals, and 5) chemical preparations. In these search categories, approximately 30
releases with public impacts were reported. Impacts included up to 50 members of the
public injured, up to 30 hospitalized, up to 3,700 evacuated, and up to 360 sheltered-in-
place. The release of chlorine and hydrogen chloride gas resulted in the largest
incidences of public impacts. Other chemicals whose releases resulted in public impacts
included sulfur dioxide, ammonia, phosphorous, xylene, 2-nitropropane, phosgene,
hydrochloric acid, and carbon tetrachloride. Again, it is important to note that facilities
found reported in these database searches included very large chemical plants, as well as
smaller manufacturing facilities, such as those found in Carlsbad.
Based on the large number of accidental release incidents reported for this industry and
the magnitude of public impacts, the & of future accidental releases with public
impacts for this industry should generally be considered very high. Therefore, any
proposal for the siting of a child care facility near a company in this industry should be
carefully evaluated.
chlorine, 2) industrial gases, 3) industrial inorganic chemicals, 4) industrial organic
6. Analvtical InstrumentsMedical ApDaratus
Several companies in Carlsbad produce specialty analytical instruments and medical
apparatus, such as respirators and other life support systems. Research, development, and
manufacturing processes are represented.
Hazardous materials used by this industry category include chlorine, hydrogen sulfide,
sulfur dioxide, ethylene oxide, hydrogen peroxide, mercuric oxide, cadmium oxide,
potassium cyanide, halogenated organics (e.g., dichlorodifluoromethane, benzyl
chloride), and nitric acid. However, no AHMs were listed by the one company in this
industry for whom hazardous materials information was provided by DEH.
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Potential Impacts Based on a Review of RMPPs
(Analytical Instruments/Medical Apparatus)
Although there are several Carlsbad companies in this category, none are listed on the
San Diego County RMPP selection lists. Only one company in this industrial category il
San Diego County is listed on the selection list, but no RMPP is currently available.
Therefore, no RMPPs were reviewed for this industrial category. Due to the status of thc
handling of hazardous materials by companies of this industry type may not generally
pose the same off-site hazard as the semiconductor fabrication, electronics plating/circuil
board and computer electronics manufacturing, and chemicals manufacturing industries.
Risks of Accidental Releases
(Analytical Instrurnents/Medical Apparatus)
The ARIP database for the SIC code category for manufacturing instruments and related
products'*, reveals that approximately 30 accidental releases of hazardous chemicals hav
been reported for companies of this industry type.since 1986. One release of potassium
cyanide and cuprous cyanide resulted in a shelter-in-place notification; other releases dic
not result in off-site impacts. Other chemicals released included chlorine, hydrogen
sulfide, sulfur dioxide, ethylene oxide, hydrogen peroxide, mercuric oxide, cadmium
oxide, potassium cyanide, halogenated organics (e.g., dichlorodifluoromethane, benzyl
RMPP process for companies of th~s industry category, it may be inferred that the
chloride), and nitric acid.
As no AHMs were listed by the one company in this industry for whom hazardous
materials information was provided by DEH, the risk of accidental releases of concern fc
the siting of a child care facility from the existing company in Carlsbad may not current1
be large. However, based on the number of releases reported by this industry in the AN
database, the reported public impact, and the types of chemicals handled by companies i
this industry, this industry has the potential for releases with impacts to off-site
populations.
7. Plastics and Plastic Products Manufacturing
Plastics and plastic products manufacturing processes can include polymerization
reactions, drying, mixing with solvents, molding, extrusion, heating, and solvent
recovery. Carlsbad is home to a few plastics and plastic product manufacturers.
Plastics and plastics products manufactures may use and store a variety of hazardous
materials. There is a wide range of possible activities in this category. Companies whic
fabricate products from material manufactured elsewhere may have minimal potential
risk.
"Results for the Standard Industrial Classification (SIC) code subcategories of search and navigation equipme
and photographic equipment and supplies were excluded from the analysis.
Child Care in Industrial Areas Page
Based on AMP accident reports, the acutely hazardous materials used by this industry
may include monomers (e.g., vinyl acetate), toxic gases (e.g., carbon disulfide, chlorine,
fluorine, hydrogen chloride, nitrogen dioxide, ammonia, bromine), organic oxides
(ethylene oxide, propylene oxide), hazardous liquids (e.g., sulfixic acid, hydrogen
peroxide, hydrogen fluoride), organic solvents (e.g., phenol, formaldehyde), organic
cyano compounds (e.g., toluene diisocyanate (2,4) and (2,6)), and halogenated organics
(e.g., chloroform, trichloro acetyl chloride). Other hazardous chemicals used by this
industry which have at least one reported accidental release which resulted in public
injuries or evacuation include toluene, sodium hydroxide, ethylene, ethane, and
methacrylic acid. No hazardous materials information for Carlsbad companies in this
category was provided by the DEH.
Potential Impacts Based on a Review of RiWPPs
(Plastics and Plastic Products Manufacturing;)
There are several plastics and plastic products manufacturing companies in Carlsbad and
San Diego County. However, the only company in this category on the San Diego
County RMPP selection list, located outside of Carlsbad, was screened out of the process
and is not required to perform the analysis. Therefore, no RMPPs were reviewed for the
plastic products category and the potential for off-site impacts of accidental releases from
this industry type are considered to be likely less than that of the other industry types with
available RMPPs.
Risks of Accidental Releases
(Plastics and Plastic Products Manufacturina)
The following two categories were searched to determine the number and character of
accidental releases for this industry type: 1) rubber and plastic products and 2) plastic
materials and resins. Approximately 240 releases were reported for the two categories.
No public impacts were reported for rubber and plastic products manufacturing.
However, for plastic materials and resins manufacturing, seven releases resulted in public
impacts, including evacuation of up to 300 members of the public, injuries of up to 9
people, and hospitalization of up to 5 people. Chemicals whose releases resulted in
public impacts include phenol, formaldehyde, toluene, vinyl acetate,
polytetrafluoroethylene, ethane, ethylene, styrene monomer, methacrylic acid, and
sodium hydroxide. Other acutely hazardous materials released by companies in this
industrial category include toxic gases (e.g., carbon disulfide, chlorine, fluorine, hydrogen
chloride, nitrogen dioxide, ammonia, bromine), organic oxides (ethylene oxide, propylene
oxide), hazardous liquids (e.g., sulfuric acid, hydrogen peroxide, hydrogen fluoride),
organic solvents, organic cyano compounds (e.g., toluene diisocyanate (2,4) and (2,6)),
and halogenated organics (e.g., chloroform, trichloro acetyl chloride). It is important to
note that the companies that fall within the codes include all rubber and plastics
processing facilities, including, for example, large tire manufacturers. Therefore, the
number of releases listed here may not be representative of releases that would be
expected from small plastics processors.
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Based on the significant number of accidental releases from this industry type and
particularly the number of releases with public impacts, the risks of accidental release foI
this industry, as a whole, are quite high. However, companies who do not manufacture
plastic, but only fabricate plastic products, may have decreased risks.
D. Seismic Hazards
Earthquakes present special challenges for accidental release prevention. A strong seismic even1
can result in accidental releases of hazardous materials from 1) upset of gas cylinders that have
not been properly secured; 2) physical damage to pipelines containing liquids or gases; 3)
inadvertent mixing of incompatible chemicals due to breakage or “sloshing” of open process
tanks; and 4) breakage of unbaffled, storage tanks. In addition, a loss of electric power can affec
chemical scrubber or sprinkler operation, reducing the protection afforded by those systems.
Offsetting these’ risks, larger hazardous occupancies (“H occupancies in the building code) may
have automatic shutoffs or backup emergency power. Requirements for backup systems do not
apply to all chemical users that can have off-site consequences--just the largest and most
hazardous. Other hazards associated with strong to severe earthquakes include large fires fueled
by broken gas lines that may or may not involve chemicals. Sprinkler systems within buildings
also may break or not function properly, as the result of an earthquake.
Compounding the risks of chemical releases and fires involving hazardous materials is the realit
that in the event of a strong or severe seismic event where there is widespread damage, public
safety personnel will be overextended and unable to respond to all emergency calls. Emergency
response can also be slowed by damaged or blocked roadways and bridges.
For these reasons, various engineering controls, including backup emergency power, seismic tie.
downs, fail-safe valves, and reduced flow orifices on acutely hazardous gas containers are often
employed by industry. Requirements for seismic safety measures may be required as part of the
RMPP process or under local ordinances. Some measures are also included in the Uniform Fire
and Building Codes. Strong seismic events have the potential for creating extremely hazardous
conditions in industrial areas, as well as throughout the City.
E. Relative Risk of the Industry Types
It is very difficult to definitively rank industry types by level of risk. As discussed previously ir
Section II., Evaluation of Hazardous Materials Risks, the risks of an accidental release resulting
in an off-site impact to people are strongly dependent on factors such as the type and amount of
chemicals used, the safety practices used at the facility, and the engineering controls required by
local jurisdictions.
At the request of City Staff, a comparative ranking of risk was made for each of the industry
types discussed previously. This ranking is based upon the types and amounts of chemicals usec
by each industry type and available predicted off-site impact distances listed in the RMPPs that
were reviewed. A risk ranking of 0, 1 or 2 was given to each industry type. The rank “0”
represents the lowest risk and the rank “2” represents the highest risk. It should be noted that th
highest comparative ranking does not imply or predict dangerous conditions; it is only a relative
ranking of the listed industries. These comparative rankings are listed in Table 2.
Child Care in Industrial Areas Page :
This ranking system is a best attempt to qualitatively compare the risks of facilities currently
located in Carlsbad or likely to locate in Carlsbad. As noted previously, the risks of an
accidental release from a particular facility are dependent on many factors and can vary from the
generalized rankings for the industry types shown above.
Perhaps even more important, this relative ranking is based on information currently available.
Significant changes in a particular industry, significant growth in a particular company in
Carlsbad, and anumber of other factors could change the comparative risks.
TABLE 2
Relative Risk of Selected Industry Types
Industry Type
1 Pharmaceuticals and Biotechnology
2 Chemical Manufacturing
Comparative Risk
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Electronics PlatingKircuit Board and 1
Computer Electronics Manufacturing
Semiconductor Fabrication 1
Analytical InstrumentsMedical Apparatus 1
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Plastic Products Manufacturing
0 Golf Club Manufacturing
1
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Conclusion: The greatest potential risks for releases effecting offsite populations from the
current or likely industry types found in Carlsbad are associated with chemical manufacturing.
Some industrial uses evaluated, especially those associated with golf club manufacture, would
pose limited risks to a child care facility within close proximity. However, risks of off-site
impacts can vary widely between individual facilities. In addition, hazardous materials use by
industry changes over time and new industrial developments could significantly change the
types and quantities of chemicals used within the designated industrial areas.
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V. POTENTIAL HAZARDOUS MATERIALS RELEASE WITHIN
COMMERCIAL ZONES
In most communities, including Carlsbad, child care facilities are routinely allowed in
commercial zones. Nevertheless, there are a number of potential hazards to children in
commercial zones. A child care facility located on a major street is more at risk from automobil
accidents than a facility on a local street, for example. This section was prepared based upon a
focused evaluation of potential risks from hazardous materials in commercial areas prepared by
ENVIRON. This evaluation is included in Appendix A under Task 2.
A. . Businesses that Use Hazardous Materials in Commercial Zones
The use of hazardous chemicals and the risks of accidental releases of those chemicals are not
confined to industrial areas. Businesses located in commercial areas which may handle
hazardous materials were identified based on a review of the Business Classification Listing of
the Carlsbad Chamber of Commerce. These business types include auto servicing, photography
laboratories, printers, publishers, and swimming pool and spa services. Photography labs,
publishers, and printers may handle organic solvents, inks, and alkaline and acidic liquids.
Swimming pools and swimming pool and spa servicing companies may handle calcium
hypochorite (solid), sodium hypochlorite (liquid), muriatic acid (also known as hydrochloric
acid), and even chlorine gas. Finally, auto service stations handle organic compounds and liquic
and gaseous petroleum products in large amounts. Therefore, there is a potential for releases of
hazardous materials from some commercial activities, particularly from auto servicing and
swimming pool and spa servicing activities. The types of hazardous materials most commonly
used or stored in some commercial businesses are listed in Table 3, below.
TABLE 3
Commercial Uses and Commonly Associated Hazardous Materials
I Commercial Use I Hazardous Materials Commonly Used* I -
Auto Servicing Fuels, oils, solvents, weldinghtting gases,
paints
Dry Cleaners
Fuels, oils, solvents Gas Stations
Solvents
Solutions containing silver, corrosive liquids Photography Laboratories I I
PrintersPublishers
Corrosive liquids (acids), oxidizers, possibly Swimming Pools and Swimming Pool and
Solvents, inks, corrosive liquids
Spa ServicelSupply chlorine gas
*Note: Some of the hazardous materials listed above, such as inks, do not pose an airborne offsite hazard to near1
receptors. Oxidizers and acids pose an airborne hazard if mixed.
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B. Potential Hazards from Transportation Accidents
Hazardous materials are routinely transported over fieeways and other transportation arteries.
This transport can result in releases of hazardous materials in areas of the City other than in
industrial parks. Transportation related releases of hazardous materials can occur as a result of
collisions, vehicle over-turnings, railroad grade crossing accidents, and equipment failure.
Studies indicate accident rates for trucks on urban highways and roadways range from 0.49 to
13.92 per million vehicle miles traveled. Approximately 80 percent of the hazardous materials
incidents on roadways and all resulting fatalities were highway-related.
In California, 2,130 hazardous materials transportation incidents were reported during 1992 and
1993 for all modes of transportation (e.g., rail, highway, water) (USDOT 1994). The four
hazardous material classes involved in the highest number of incidents were
flammable/combustible liquids, corrosive materials, combustible liquids, and poisonous
materials. The four classes resulting in the highest percentage of injuries were corrosive
materials, flammable/combustible liquids, poisonous gases, and poisonous materials. The top
fifty materials with reported incidents include sulfuric acid, hydrochloric acid, sodium hydroxide,
toluene, ammonia solutions, ammonia gas, and tetrachloroethylene.
Data from a few studies on truck accident rates indicate that freeway and non-freeway routes
have similar accident rates per mile traveled. Since all of these categories of transportation
arteries pass through commercial and residential areas of Carlsbad, there is likely a similar
potential for accidental releases of hazardous materials from transportation accidents in
commercial and residential areas as well as in industrial areas. In fact, since there is likely far
more movement of hazardous materials along Interstate 5 then along the roads that run through
the Carlsbad industrial zones, the risks due to transportation accidents in the commercial zones
adjacent to Interstate 5 would be higher than in the industrial zone.
Since national and Carlsbad-specific transportation statistics indicate a large number of incidents
involving hazardous chemicals occur during transport of those chemicals, risks from releases of
chemicals along transportation arteries should be considered. The major transportation arteries
in Carlsbad which access industrial areas include Interstate 5, El Camino Real, Palomar Airport
Road, and College Boulevard.
Based on the Carlsbad Fire Department's records, approximately 25 hazardous materials releases
that have occurred on public roadways or due to transportation incidents were reported to the fire
department over the past five years. Hazardous materials involved include gaseous and liquid
fuels and hydrochloric acid. In contrast, total incidents in the Carlsbad industrial areas, both
related and unrelated to transportation, totaled only nine in the past five years. It should be
noted, however, that most of the areas designated for planned industrial use were vacant during
this period. [Approximately 82 percent of planned industrial areas were vacant in 1994, although
the amount of vacant land in industrial areas is now closer to 65 percent.]
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C. Seismic Hazards
Strong earthquakes have the potential for creating hazardous conditions in commercial areas, as
well as in other areas of the City of Carlsbad. With respect to the risks of chemical releases
followhg a seismic event, several types of releases can be anticipated to occur. Accidental
releases of hazardous materials in commercial areas can occur as the result of inadvertent mixin
of incompatible chemicals due to breakage of containers on store shelves, physical damage to g,
pipelines causing fires that can reach chemical storage areas, and upset of gas cylinders that hav
not been properly secured. As noted previously, the types of businesses in commercial areas th;
have the greatest potential for off-site consequences are auto servicing and swimming pool and
spa servicing businesses.
As discussed in Section III., 'Evaluation of Hazardous Materials Risks, the risk of an accidental
release having off-site consequences and the extent of those impacts is determined in part by tht
characteristics of the particular chemical and the quantity that could be released. Since a larger
number and larger quantities of acutely hazardous materials are used in industrial areas than
commercial areas, the risk of accidental releases following a strong seismic event resulting in of
site consequences would generally be greater in industrial areas than commercial areas.
D. Comparison of Risks in Commercial Areas Versus Planned Industrial Areas
As noted previously, hazardous materials which can cause off-site impacts if accidently released
industrial and commercial areas is the difference in the amount of chemicals used and stored by
facilities in each area. Thus, a heavy industrial area with large manufacturing facilities (such as
refineries and large chemical manufacturing plants or large semiconductor fabrication plants)
would generally have much greater risks of off-site impacts from accidental releases than a
typical commercial area. Smaller research and development facilities and small-scale
manufacturing plants, such as those primarily found in the Planned Industrial areas of Carlsbad
this time would lie somewhere in between heavy industrial uses, such as refineries, and general
commercial uses.
Risks from transportation-related accidental releases exist in most commercial areas located nea
major transportation corridors as well as in industrial areas. For those commercial areas near
Interstate 5, risks from transportation related releases of hazardous materials may be equal to or
greater than those in the partially developed industrial areas. Another factor which further
complicates this comparison is that commercial properties may be much smaller than industrial
are present in both commercial and industrial areas, Typically the difference in risks between
sites, and the buildings are usually closer together.
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Conclusion: There are commercial businesses that use hazardous materials that can cause
impacts in the event of an accidental release. Typically the difference in risks between
industrial and commercial areas is the difference in the amount of chemicals used and stored
by facilities in each land use area. A heavy industrial area with large manufacturing facilities
would generally have much larger risks of off-site impacts from accidental releases than a
commercial area. Smaller research and development facilities and manufacturing plants,
would lie somewhere in between heavy industrial uses and general commercial uses. The
types of commercial uses that would be most likely to result in offsite impacts to a child care
center would include auto servicing facilities, swimming pools, and pool and spa supply
businesses,
In particular, potential risks from transportation accidents may actually be equal to or greater
in commercial areas near Interstate 5 than elsewhere in the City, due to the number of trucks
using this transportation corridor.
Apart from transportation-related incidents, there appears to be a greater likelihood of an
accidental release of hazardous materials having an off-site impact in a fully developed
industrial area containing the industry types evaluated in this report, than in a commercial
area. This difference be even greater if larger industrial facilities locate in Carlsbad in the
hture.
Child Care in Industrial Areas Page 32
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VI. ACCIDENTAL RELEASE PROTECTION MEASURES
Potential measures to limit exposures of children to an accidental release of toxic substances CN
be grouped into two general categories: 1) measures taken by industry to prevent accidental
releases; and 2) measures to reduce exposures to children in the event of an accidental release.
The discussion below on evacuation and shelter in place was prepared based in part upon
information supplied by ENVIRON, which is contained in Appendix A under Task 1 H.
A. Measures to Decrease Exposure in the Event of an Accidental Release
Two measures that are most often used to reduce or avoid potentially adverse health effects in th
event of an accidental release of a toxic chemical are evacuation and sheltering. Evacuation is
the removal of potentially exposed populations from the impacted area, and sheltering is the
protection of potentially exposed populations by keeping them indoors for the duration of high
outdoor concentrations. Although each of these options may be effective in certain release
situations, each may be more or less appropriate depending on: 1) the properties of the chemical
released; 2) the circumstances of the release; 3) potential outdoor concentrations; and 4)
characteristics of the potentially exposed populations. Several issues relating to the evaluation 01 these exposure mitigating options for a child care facility are discussed below.
1. Evacuation
Evacuation of Potentially exposed populations has the longest history of use for reducing public
health effects due to accidental releases of toxic chemicals. The major drawback to evacuation as
a response option is the time necessary for its implementation. Evacuation can eliminate
potential health effects ifnotification & evacuation can both occur in less than the time
necessary for the emitted contaminant to travel from the accidental release source to the
potentially impacted population. However, if evacuation requires a longer time or if the
chemical’s travel time is very short, it is not as effective but may still reduce health effects by
reducing the exposure duration.
Pollutant travel times can vary significantly depending on the characteristics of the chemical and
the plume. Meteorological conditions at the time of the release, including the wind speed,
temperature, atmospheric stability, and precipitation conditions also affect plume travel times.
As an example, a computer modeling study for the City of Mountain View, in Santa Clara
County, indicated that a plume of chlorine gas accidentally released would reach a child care
center 1,000 feet from the source in 20 minutes if the wind speed were 3 miles per hour (mph).
At a wind speed at 10 mph, the plume was modeled to reach the center in 6 minutes. To put that
information in a local context, wind speeds around Carlsbad average approximately 9 mph13, so
the time available to respond to an accidental release could be very short.
Since children may not understand evacuation alarms, are less responsive than adults, and cannot
respond without assistance, the time period needed for evacuation is longer, increasing the
possible exposure duration and the potential for health impacts. The nature of a child care
13Wind speeds for Long Beach and San Diego (city center) were used as representative of the Carlsbad
area.
Child Care in Industrial Areas Page 33
facility, with a concentration of children, also triggers a different priority response. Public safety
personnel responding to an emergency would generally need to assume that greater assistance
was necessary for children, limiting their ability to deal with other areas, Evacuation of large
child care facilities can be a particular problem.
For one type of child care, on-site facilities, a slightly different set of circumstances can be
assumed. If the facility only serves children with parents on the site, then evacuation does not
have to be accomplished by a limited number of adult staff trying to manage fiightened children
or non-mobile infants. Particularly if the parents themselves are trained in how to evacuate their
own children, and if the number of children present can be removed quickly, the logistics of
evacuation may be more manageable.
2. Shelter in Place
Due to the problems with evacuation, in-place sheltering has received increasing attention as an
accidental release response option. Sheltering of potentially exposed populations in indoor areas
can reduce exposures and, therefore, health impacts of toxic chemical releases. This is because
air concentrations of pollutants indoors can be significantly reduced from those outdoors and the
time needed to implement sheltering is generally less than that of evacuation.
The effectiveness of a building in reducing air-borne concentrations decreases as the duration of
an accidental release increases. Therefore, shelter in place mitigating options are better suited
for short-term releases and those where the likelihood ofjre or explosion are minimal.
Sheltering mitigation measures can consist of as little as a notification system alerting potentially
exposed populations to stay inside with the windows closed for the duration of the incident, or
can be as great as the implementation of special responses and shelter room features. Responses
often include taping around doors, windows, and vents to prevent air leakage, and sheltering in a
room furthest from the source of the release. Specifically designed shelter room features may
significantly reduce indoor air concentrations for some release incidents. Room features can
include a separate air supply system designed to keep the room under positive pressure, a
scrubber and filtration system at the air intake, seals and weather stripping, emergency supplies
including food and water, and access to an outside door in case evacuation becomes necessary.
However, these features cannot eliminate potential exposures to all released gases in a modern
industrial areas, particularly since scrubber andjltration systems are necessarily designed for
spec@c chemicals and cannot protect against all chemicals.
3. ComDarison of the Effectiveness of Evacuation and Shelter-in-Place
Selection of an appropriate exposure mitigation measure for children must account for the
mobility of children and the effectiveness of each measure in reducing exposure and health
impacts. Evacuation has the potential to eliminate health effects, but its effectiveness is highly
dependent on the pollutant travel time and population response time. Factors as unpredictable as
wind direction may significantly change its value at any particular point in .time. Alternatively,
sheltering does not require the same level of organization and time necessary for evacuation
during a release event, but may not be effective for many accidental releases.
Child Care in Industrial Areas Page 3
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ConcZusion: Due to the special characteristics of children, sheltering may be more appropriate
than evacuation as a first response option for the releases of hazardous materials which are
quickly contained and have lower toxicities. However, neither option is entirely viable for all
situations and all possible chemicals used by a variety of industries. Therefore, an in-depth study
of the characteristics of potential releases effecting a specific proposed child care facility location
would be necessary to determine the most appropriate response options for possible release
scenarios.
The decision to evacuate or shelter in place must be made quickly by a designated emergency
response team as part of previously developed emergency planning procedures. Training based
on the in-depth studies of the characteristics of potential releases, as discussed above, and
adequate knowledge of the nature of the accidental release, would be required for public safety
(Fire and Police) personnel designated to make these types of emergency response decisions. A
potential consequence of under estimating the severity of a release would be that public safety
in place
personnel could be required to perform a rescue operation of children and staff that had sheltered
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1 B. Prevention of Accidental Releases
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As discussed in previous sections, Business Plans and RMPPs prepared for industrial facilities
identify measures to reduce the likelihood of chemical releases and off-site con~equences’~.
Engineering and processing controls, such as fail safe shut off valves and sensors, and employee
training can greatly reduce the risk of an accidental releases.
Additional measures, beyond minimal Uniform Fire and Building Codes requirements, that could
be employed at industrial facilities in the Carlsbad area are as follows:
0 Adoption of components of “Model ” Toxic Gas Ordinances. Toxic Gad5 Ordinances
(TGO) have been adopted in a number of California cities, These ordinances were
originally developed to address the storage and use of toxic gases, such as ammonia and
arsine, in earthquake prone California. Some of the provisions of model TGOs have
are that TGOs classify more gases as toxic than the Uniform Fire and Building Codes,
they require seismic shut offs, and specify lower trigger quantities.
7 _I since been incorporated into the Uniform Fire and Building Codes. Important exceptions
1 -
0 Specific Engineering Controls. Seismic shut off valves for toxic gases and reduced flow
orificesI6 (RFOs) to reduce the amount of gas released.
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- I4Note: The Uniform Fire and Building Codes also include provisions for back-up emergency systems for
specified ‘‘Hazardous Occupancies” (H6 and H?). The requirements depend upon the specific chemical and
quantities stored or used.
”Toxic gases are variously defined by the U.S. Department of Transportation, the Uniform Fire and
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Building Codes, and local ordinances.
16These devices are increasing used by industry to meet requirements in the Uniform Fire and Building
Codes to limit a accidental release to one-half the “Immediately Dangerous to Life and Health” (IDLH) level .
Prohibition of outdoor storage and use of hazardous materials where there is a potential
exposure hazard to a child care or similar facility.
a Installation of treatment and containment systems in buildings to prevent the release of
airborne contaminants with engineering controls beyond what is required in the Uniform
Codes. For example, installation of isolation valves in ammonia refrigeration systems.
Adequate sprinkler systems to control Jires that could potentially produce toxic smoke.
For example, installing sprinklers in smaller facilities or utilizing higher sprinkler
density.
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Conclwion: Virtually all of these measures represent increased costs and additional regulatory
burdens, both for the effected companies and the oversight agencies. Many of the specific
measures would be virtually impossible to impose on a case-by-case basis by the City,
particularly for companies that did not require RMPP’s, since the City does not issue the
hazardous materials permits.
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VII. CHILD CARE AVAILABILITY UPDATE
The following discussion is based upon an updated review of child care services in Carlsbad
conducted by Gruen Gruen + Associates (April 1996). This review was undertaken to document
changes in the provision of child care services since a comprehensive analysis was completed in
1991. The complete review is included in Appendix B.
Information for this research was obtained fiom:
0 “Carlsbad Child Care Needs Assessment and Recommendations Summary Report”
prepared by the International Child Care Resource Institute for the City of Carlsbad,
January 1991,
1990 U.S. Census data.
The Childcare Resource Service, a department of the YMCA of San Diego County.
0 San Diego Association of Governments (SANDAG) Series 8 demographic data.
To quanti@ the availability of child care spaces, the City of Carlsbad was divided into four
quadrants. Palomar Airport Road separates the north and south while El Camino Real separates
the east and west (see Figure 5). The Planned Industrial areas in the City are located within the
northwest, northeast, and southwest quadrants and are identified on Figure 5 as the focused study
area.
Comparison of the number of available child care spaces to the population in 1990 and 1995 will
help to better understand the potential supply of child care in Carlsbad. Child care was not
compared to employment because accurate employment estimates are not available at the sub-
County level.
As shown on Table 4, the January 1991 report prepared for the City of Carlsbad indicated that
there were a total of 997 licensed and 350 unli~ensed’~ (recreational) child care spaces in
Carlsbad in 1990. Population data supplied by the City of Carlsbad indicates that in 1990 there
were approximately 10,187 children in the City. This suggest that in 1990 there was an average
of 0.10 licensed child care spaces per child, and 0.13 total child care spaces per child. By 1995
the number of child care spaces had increased significantly. Data supplied by the City suggests
that in 1995 there were about 11,923 children aged 12 and under.
l7 “Unlicensed” generally includes spaces provided in schools, which are exempt fiom licensing.
Child Care in Industrial Areas Page 37
NORTHEAST NORTH
SOUTHEAST
rn = rn I Approximate Focused Study Area
CHILD CARE NEEDS ASSESSMENT QUADRANTS FIGURE 5 I
38
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39
Information provided by the YMCA’s Child Care Resource Service suggested that there were
1,294 licensed child care spaces and 992 unlicensed (recreational) spaces. This infers a ratio of
0.1 1 licensed spaces per child in 1995, and 0.19 total spacesI8.
This suggests that during the 1990 to 1995 period there was a total increase of 939 child care
spaces (297 licensed and 642 unlicensed). During the same period the population of children
aged 12 and under increased by 1,736. This summary appears to suggest that the availability of
child care in Carlsbad increased significantly during this time period. Although it is impossible
to quantify the change in employment that occurred in the City, a significant amount of industrial
would have affected the demand for child care.
development occurred during this period, A substantial increase in employment in the City
Comparison to 1991 Needs Assessment
The 199 1 “Carlsbad Child Care Needs Assessment and Recommendations Summary Report’’
prepared by the International Child Care Resource Institute (ICRI) for the City of Carlsbad stated
that by 1995 there would be demand for an additional 400 licensed child care spaces in Carlsbad.
As shown on Table 5, the Child Care Needs review suggests that since the 1991 study, 297
licensed child care spaces have been added to the supply in Carlsbad. In other words, there exists
a deficit of 103 licensed spaces over what was estimated to be needed by ICRI in 1991. Also, the
1991 study did not identify the addition of unlicensed spaces. Between 1991 and 1995 there has
been an increase from 350 to 992 unlicensed spaces: an increase of 642 spaces.
TABLE 5
Comparison of Estimated 1995 Needs to Available Child Care
Existing Licensed Child
Child Care Spaces Licensed Child Care Spaces 1990* Quadrant
Estimated Licensed Estimated
Need 1995” 1995T
~~ ~
Northwest
224 430 330 Southeast
202 161 36 Southwest
141 174 99 Northeast
727 632 532
TOTAL 997 1,397 1,294
‘Source: International Child Care Resource Institute, 199 1
Surplus c
(Deficit:
95
41
(3 3)
(206)
(103)
?Source: Gruen Gruen + Associates
‘8NOTE: The number of child care spaces available in 1990 and 1995 was obtained from the “Carlsbad
Child Care Needs Assessment and Recommendation Summary Report” and the YMCA’s Childcare Resource
Service, respectively. Gruen Gruen + Associates did not independently verify these estimates.
Child Care in Industrial Areas Page 40
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Conclusion: Total child care spaces increased significantly between 1991 and 1995. New
spaces added (licensed and unlicensed) exceeds the total additional spaces anticipated as
Carlsbad, as well, although the exact number of jobs is not known. While it is not possible to
accurately correlate both the supply and demand, the increase in supply has exceeded the
population increase, but w not have kept up with employment-related demand.
necessary by the 199 1 study. There has been a significant increase in industrial development in
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VIII. CONCLUSIONS AND RECOMMENDATIONS
The question of whether child care centers should be located in planned industrial areas or near
acutely hazardous materials is a complicated issue. One of the basic questions to be addressed
by City staff, the Planning Commission, and City Council when considering the approval of a
new child care facility is whether its physical location provides a “safe” environment for
children. Although there are a number of safety concerns for child care facilities, such as traffic
circulation and access, a critical concern in or near industrial areas are potential impacts to
children from the relatively higher frequency of use, storage and Qmspofl of JUS materia\
by industry.
Advances in the containment and handling of hazardous materials have greatly reduced the
chance of an accidental release of these substances, but have not totally eliminated risk. If child
care facilities are located in planned industrial areas, children may be exposed to accidental
releases of acutely hazardous materials. In the event of an accidental release, acutely hazardous
materials can pose a significant health risk to children on or near a release site.
The other element in this land use equation is the industrial sector itself. While this study has no
evaluated the economic aspects of introducing a sensitive’population into the industrial areas,
there are cost implications for some companies. In addition to the expense of providing
additional protection, some industrial firms fear that the liability and negative public image of
creating such a risky situation may be even more costly. A minor accidental spill that causes
adults to temporarily evacuate their place of employment is perceived very differently than a
toxic spill that endangers infants and small children.
In addition to the uncertainties of expense and public perception, many industries are subject to
significant changes in technology, involving major differences in the types of hazardous
materials they use. Without some assurance of being able to respond to changing technology,
many types of businesses may be reluctant to commit to a new site or a major expansion. This
issue cannot be emphasized enough: there is no reliable mechanism for predicting what
hazardous materials a particular business may want or need to use in the future.
It is difficult to accurately predict potential impacts to child care facilities, even on a case-by-
case basis. Each facility evaluation requires a great deal of information and careful analysis.
The gathering of the specific information required for a risk assessment is expensive and can be
difficult to obtain voluntarily from surrounding industries. Addressing each child care facility or
new hazardous materials user on an individual basis will be time-consuming and expensive for
the City and Applicant alike. In the City of Santa Clara, preparation of an administrative Draft
Environmental Impact Report (EIR) for a school and day care facility near a semiconductor
fabrication facility has cost the applicant over $100,000 and the EIR is not yet complete. There
have also been considerable costs to the City in terms of staff time and a great deal of very
adverse publicity.
An alternative approach to completing risk assessments or entire Environmental Impact Reports
for individual facilities is to establish safety buffers based upon the potential risks for impacts
from nearby categories of sources. Several cities in California have used this approach to
address the potential siting of child care centers and industries that use acutely hazardous
Child Care in Industrial Areas Page 42
materials within proximity of each other, Two ordinances relating to land use regulations for
child care facilities, one from the City of San Diego and a second fiom the City of Mountain
View, are contained in Appendix C. Both ordinances use a buffer based on state regulations, as
described below.
State regulations that deal with distances between acutely hazardous materials users and sensitive
uses (such as child care facilities) reference either a 1,000 foot radius or a one-quarter mile radius
(1,320 feet). These distances offer standards for establishing safety buffers that have been
applied in other cities and could also be applied in Carlsbad. Although these buffers are not
absolute safety thresholds, they would provide minimal time for evacuation if there was an
accidental release of toxic gas. In addition, an accidental release of a toxic gas would be less
concentrated at the greater distance. [These standards are also used by the San Diego County
Department of Environmental Health in their screening and prioritization process when
determining whether an facility which uses specified quantities of acutely hazardous materials
needs to prepare a RMPP.]
Several options available to the City of Carlsbad for locating child care facilities in or near the
City’s planned industrial area were identified based upon the results of this study and a review of
child care siting ordinances in other cities. Child care facilities that could potentially be
permitted in industrial areas include either on-site or independent facilities. On-site facilities
would be of limited size in order to enswe that the children could be removed quickly, without
impeding other evacuation or emergency response efforts, and would be permitted as part of a
larger industrial facility. Only children with one or more parents working at the on-site facility
could be cared for at that location. Independent child care centers are not restricted to use by
parents in the vicinity of a facility.
Some options for locating child care facilities within the planned industrial area are discussed
briefly below.
OPTION 1 : No child care centers within planned industrial areas. The zoning ordinance
would continue to limit child care facilities within designated Planned Industrial
areas of Carlsbad. Child care centers would continue to be encouraged in other
areas of the City.
OPTION 2: On-site facilities allowed within planned industrial areas at appropriate sites.
Child care facilities would continue to be prohibited within planned industrial
areas with the exception of on-site facilities used only by employees. The number
of children using an on-site facility would be limited to 25, or less. Nearby
industrial users (within 1,000 feet) would have to agree to not use acutely
hazardous materials or materials with potential off-site consequences. Parents
would be available to assist with evacuation in the event of an accidental release
of hazardous materials or earthquake.
OPTION 3: Child care facilities (both on-site and independent facilities) allowed in the
planned industrial area with restrictions. The zoning ordinance would be
hazardous materials users. Special emergency planning procedures that address
modified to prohibit child care facilities w;th;n 1,000 feet (or more) of acutely
Child Care in Industrial Areas Page 43
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the special needs of children and limits on the number of children using the
facility may be required. Nearby iudustrial users would have to agree to not use
acutely hazardous materials or other materials with potential off-site
consequences.
OPTIUN 4: Child care facilities allowed in the planned industrial ureus without restricfions.
Based on current assumptions about the sensitivity ofchildren to hazardous
materials, the potential for impacts to human health within the planned industrial areas would increase if child care facilities were permitted without restrictions
within the industrial are= of Carlsbad. This change in conditions would require
subsequent additional California Environmental Quality Act (CEQA) review of
hazards to human health.
As stated in the Carlsbad General Plan, “Land use controls are necessary to ensure development
compatible with the community and to preserve the health, safety and welfare of its citizens.”
The recommendation provided below, which would allow limited child care in industrial areas
and also provide a buffer in other areas, is consistent with provisions of the current general plan
and would provide a framework for modifications to the zoning ordinance and development
review process.
I Recommendation: Adopt Option 2: Oo-site Child Care in Planned Industrial Areas with
Buffer. I I I
A. Conditional Use Permit Conditions and Siting Considerations
OPTION 2: On-site Child Care in Planned Industrial Areas With Bufler
One option for allowing child care within the industrial area, which wouid provide for the
safety of c,hildren while maintaining the industrial area for primarily industrial uses,
care and activities using acutely hazardous materials. This option would not require
costly modeling studies and would take some of the uncertainty out of the development
review process. Under this option the City would continue to prohibit child care centers
in planned industrial areas, except for on-site facilities within a larger industrial
development. Child care centers could be allowed with a conditional use permit if: 1)
they are operated by a company to serve on-site employees only; 2) are limited in size
to the number of children that can be safely evacuated in five minutes; and 3) are at least
1. ,000 feet (or more) from the site boundaries, or owners of all property within 1,000 feet
of the proposed child care facility legally commit not to use acutely hazardous materials
or other materials (such as ammonia or large quantities of flammable materjals stored
Y would be to allow on-site child care where a buffer can be established between the chiM
aboveground), with potential off-site consequences. The sponsoring company would also
have to commit to not using AHMs, or other substances likely to endanger the children.
This would allow companies to have on-site child care for their employees where there
was a limited potential for impacts from and to nearby industries. In addition, allowing
only on-site child care facilities would provide the means for parents to evacuate their
children in the event of a hazardous situation.
Child Care in Industrial Areas Page 44
The recommendation would be to limit the number of children at an on-site child care
facility to approximately 25. This number may be too high for certain facilities and
circumstances. A higher number may be viable in some circumstances. A basic
assumption in allowing on-site child care is that parents can assist in evacuating their own
children'in an emergency. Techniques for responding to accidental releases developed
for adults will not suffice for a child care facility. The recommendation is based on a
number of concerns, including:
In an emergency, the parents of all of the children must be able to all get
into the facility immediately, through a limited number.of entrances; Each parent must be able to find hisher own child quickly, among the
larger group of children, which means being abfe to visually survey the
entire group;
room to room quickly, without getting in each other's way or endangering
the other children;
I If the facility has multiple rooms, the parents must be able to move from
0 The staff must be familiar with the identity of all of the parents;
The parents and staff must be abfe to remove all of the children
immediately, again through a limited number of doors;
parents are frightened and panicky.
The emergency procedures must work even when both children and
A company proposing an on-site child care facility would be responsible for providing
the buffers on-site, or obtaining a legal commitment from neighboring property owners to
not use AHMs as long as the child care facility is in existence. This relieves the City of
the responsibility of unilaterally imposing a restriction on industrial users. The project
sponsor would also be responsible for proposing a project that includes adequate
provision for protecting the children under the specific site conditions, including meeting
relevant noise standards, a physical site layout that is appropriate for the use, and an
operations plan that ensures expeditious warning and evacuation procedures are in place.
It should be noted that while a 1,000 foot buffer zone wouId reduce the scope of the risk
analysis required for a proposed facility, some CEQA analysis will still be necessary to
determine whether the site would be impacted by other hazardous materials used jn the
area that are not classified as AHMs. In addition, hture industrial facilities proposed
near such child care centers might also require additional CEQA analysis beyond what
would currently be require.d,
Under this option, there would need to be a reciprocal provision where new on-site child
care centers and acutely hazardous materials users would not be allowed to located within
1,000 feet of one another, The implications of this restriction would be to limit some
industrial land as to the uses it could accommodate.
Y
Coordination with the County would be required to implement this option. Specifically, the
County would need to notify the Planning Department promptly of changes to Business Plans
that involve the use of acutely hazardous materials above threshold planning quantities. In
addition, the City of Carlsbad would need to inform the Department of Environmental Health of
Child Care in Industrial Areas Page 45
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proposed child care facilities and obtain feedback on potential implications for nearby industrial
users.
The conditional use permit process would give adjacent property owners and industrial facilities
the opportunity to provide input on the proposed use and allow special conditions to be required
or odors.
While this report has not included a comprehensive analysis of potential impacts to child care
ordinance amendment similar to that found in Appendix C from the City of San Diego. This
zoning ordinance modification would prohibit child care facilities within 1,000 feet (or more) of
users of specified quantities of acutely hazardous materials, whether within the planned industrial
area or in commercial or residential. axeas- Given the proximity of planned residential and
commercial property (where child care facilities may be located) to industrial areas, it would be
appropriate to consider making the 1,000 foot buffer between child care and AHMs mandatory
throughout the City.
to minimize any potential problems, including the possibility of nuisance complaints due to noise
from hazardous materials citywide, the City may also want to consider adopting a zoning
3
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Conclusion: Allowing only on-site child care facilities of limited size would reduce the
problems associated with the potential evacuation of chiIdren in the event of an accidental
release of acutely hazardous materials, whether from an industrial facility or during
transportation and unloading. In addition, maintaining safety buffers between industrial users
of acutely hazardous materials and child care facilities would greatly reduce the likely
concentration of an accidental release plume and allow greater time to implement an
evacuation, ifrequired. Using established safety buffers wilt avoid costly risk assessment
studies for individual facilities that may have to be updated as industrial uses and processes
change. It would also reduc.e some of the uncertainties related to whether a particular child
care conditional use permit should be approved or, conversely, whether new acutely
hazardous'material use would be permitted. Allowing on-site child care within the planned
industrial arm of Carlsbad under these conditions is a balance between providing child care
facilities near employees' places of work and maintenance of the integrity of the City's
Planned Industrial areas,
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IX. GLOSSARY
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acutely hazardous materials Acutely hazardous materials are defined in Section 25532 of the
California Health and Safety Code. Acutely hazardous materials
are substances that have the greatest potential to pose a hazard to
public health and the environment in the event of accidental
release.
ARlP The U.S. Environmental Protection Agency’s Accidental Release
Information Program. The ARIP database includes information 0:
accidental chemical releases reported to the EPA fiom 1986 to
1994.
CEQA California Environmental Quality Act
“concentration of concern”: The distance fiom a hazardous materials source within which a
substance could be concentrated enough to be a risk to human
health. It generally refers to specific health standards such as one-
tenth the level immediately dangerous to life and health (IDLH) 01
the emergency planning response guidelines (ERPG) level two or
three.
ERPG Emergency planning response guideline levels established by the
American Industrial Hygiene Association.
hazardous materials Hazardous materials are defined by the California Health and
Safety Code as “any material that, because of its quantity,
concentration, or physical or chemical characteristics, poses a
or to the environment if released into the work place or the
environment.”
significant present or potential hazard to human health and safety
IDLH “Immediately Dangerous to Life and Health” levels for specific
chemicals established by the National Institute for Occupational
Safety and Health..
off-site consequences Off-site consequences are possible impacts of an accidental
hazardous materials release that occur beyond the boundaries of a
facility.
off-site impact As related to hazardous materials releases, off-site impacts include
injuries, hospitalizations, and deaths. Federal databases also may
count evacuations or shelter-in-place notifications as off-site
impacts.
Child Care in Industrial Areas Page 4;
RMPP Risk Management and Prevention Program. Requirements of the
Risk Management and Prevention Program are contained in
Chapter 6.95 of the California Health and Safety Code.
risk The chance, or probability, of encountering harm or loss.
sensitive receptor A facility or particular land use that is used by populations that
may have limited mobility or greater sensitivity to airborne
pollutants. Sensitive receptors include schools, residential areas,
hospitals, long-term health care facilities, and child care facilities.
sensitive subpopulation Groups within the general population that are more sensitive to
exposure to chemicals or air pollutants (i.e., children, persons with
respiratory problems)
threshold planning quantity Specified “threshold planning quantities” of acutely hazardous
materials are listed in the Code of Federal Regulations (Title 40,
Part 355). Facilities using acutely hazardous materials which are
equal to or greater than these quantities must register with the local
administering agency (San Diego County) and may be required to
prepare a Risk Management and Prevention Program.
Worst-case scenariohelease: An analysis of the potential off-site concentrations of hazardous
materials following an accidental release which uses the following
assumptions: 1) the maximum amount of chemical would be
released and 2) the release would occur when meteorological and
air dispersion conditions (e.g., wind, temperature) would maximize
off-site impacts.
Child Care in Industrial Areas Page 48
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X. REFERENCES AND PERSONS CONTACTED
American Conference of Governmental Industrial Hygienists (ACGIH). 1989. Hazard
Assessment and Control Technology in Semiconductor Manufacturing. Lewis
Publishers, Inc. Chelsea, Michigan.
American Industrial Hygiene Association (AIHA). 1988. Emergency Response Planning
Guidelines.
Austin, G.T. 1984 Shreve 's ChemicaZ Process Industries. Fifth Ed, McGraw-Hill Book
Company. New York.
California Air Resources Board. 1984. Report of the Committee Regarding the Review of the
AAQS for Hydrogen SuEJide. Memorandum fiom CARB to G. Dum.
California Environmental Protection Agency (Ca1EPA)- Office of Environmental Health Hazar,
Assessment. 1995. Technical Support Document for The Determination of Acute
Toxicity Exposure Levels for Airborne Toxicants. January.
California Environmental Protection Agency (CalEPA). 1995. The Determination of Acute
Toxicity Exposure Levels of Airborne Toxicants. January.
California State Department of Health. 1969. Recommended Ambient Air Qua@ Standards.
Pp, HS-3,
Casarett & Doull's Toxicology. 1996. The Basic Science of Poisons. Fifth Edition. Editor Curti:
D. Klassen, Ph.D. McGraw-Hill.
Center for Chemical Process Safety (CCPS). 1995. Guidelines for Chemical Transportation
Risk Analysis. American Institute of Chemical Engineers. New York,
Chelton, C.F. Glowatz, M. and Mosovsky, J.A. 1991. Chemical Hazards in the Semiconductor
Industry. IEEE Transaction on Education. Vol. 34. No. 3. August.
Executive Office of the President (EOP). 1987. Standard Industrial ClassiJication Manual.
Office of Management and Budget. National Technical Information Service. Spingfield,
Virginia. PB 87-100012.
Grayson, Me 1985# Kirk-Othmer Concise Encyclopedia of Chemical Technology. John Wiley &
Sons. New York.
Hackney et al. 1978. Experimental Studies on Human Health Eflects ofAir Pollutants. VI.
Short-term Physiological and Clinical Effects of Nitrogen Dioxide Exposure. Arch. Env.
Health 33:176-181.
Child Care in Industrial Areas Page 49
Hyer, W.C. ed. 1990. Bioprocessing Safety: Worker and Community Safety and Health
Considerations. American Society for Testing and Materials. Philadelphia.
Jones et al. 1990. Airways Response ofAsthmatics afrer a 30 Minute Exposure, At Resting
Ventilation, to 0.25ppm NO, or 0.5ppm SO,. Am. Rev. Resp. Dis. 142:758-762.
Kleinman et al. 1983. EHects of O.2ppm Nitrogen Dioxide on Pulmonary Function and
Response to Bronchoprovocation in Asthmatics. J. Toxicol. Env. Health 12:s 15-826.
Lester et al. 1963. Effects of Single and Repeated Exposures of Humans and Rats to Vinyl
Chloride. Am. Ind. Hyg. Assoc. J. 3:265-275.
Linn et al. 1985. Eflects of Exposure to 4 ppm Nitrogen Dioxide in Health and Asthmatic
Volunteers. Arch. Env. Health 40(4):234-239.
National Institute for Occupational Safety and Health. 1993. Pocket Guide to Chemical
Hazards. U.S. Government Printing Office, Washington, D.C.
National Research Council, Committee on Toxicology. 1986. Criteria and Methods for
Preparing Emergency Exposure Guidance Level (EEGL), Short Term Public Emergency
Guidance Level (SPEGL) and Continuous Exposure Guidance Level (CEGL) Documents.
National Academy Press, Washington, D.C.
Orehek et al. 1976. Effect of Short-term, Low Level Nitrogen Dioxide with Respiratory
Symptoms and Pulmonary Function in Children. Am. J. Epidemiol. 132:204-219.
Parker, S.P. ed, 1989, Dictionary ofSccientPc and TechnicaZ Terms. Fourth Ed. McGraw-Hill
Book Company. New York.
San Diego County Air Pollution Control District (SDCAPCD). 1996. Smog and Climate Zones
in the Sun Diego Region. Letter from Cinthya Martinez to A. Stuart. April 22.
Sax, N.I. and Lewis, R. J. 1987. Hawley's Condensed Chemical Dictionary. Eleventh Ed. Van
Nostrand Reinhold Company. New York.
USDOT. 1994. Biennial Report on Hazardous Materials Transportation Calendar Years I992 -
1993. Research and Special Programs Administration. Report to Congress.
USEPA, FEMA, and USDOT. 1987. Technical Guidance for Hazards Analysis: Emergency
Planning for Extremely Hazardous Sustances. December 198 1.
Persons Contacted
Jim Blamey, Santa Clara County Department of Environmental Health
George Carson, Hazardous Materials Specialist, Santa Clara County Dept. of Environmental
Health
Mike Dorsey, $an Diego County Dept. of Environmental Health
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Mary Eriksen-Rattan, President, Eriksen-Rattan Associates
Tracy Hein-Silva, Contra Costa County Hazardous Materials Division
Mahmood Hossain, San Diego County Air Pollution Control District
Dirk Jenson, San Mateo County Department of Environmental Health
Adrienne Landers, Senior Planner, City of Carlsbad, Planning Department
Clark Miller, National Institute for Chemical Studies
Larry Monette, Hazardous Materials Specialist, Santa Clara Fire Department
Wendy Palmram, San Diego County Dept. of Environmental Health
Pamela Raptis, San Diego County Dept. of Environmental Health
Mike Redgrave, California Air Resources Board
Mike Smith, Fire Marshal, Carlsbad Fire Department
LeAnne Williams, Hazardous Materials Specialist, San Diego County Dept. of Environmental
Health
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I APPENDIX A
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EVALUATIONS OF HAZARDS IN INDUSTRIAL
AND COMMERCIAL AREAS
ENVIRON
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Ms. Michelle Yesney
David J. Powers & Associates
1885 The Alameda, Suite 204
San Jose, California 95 126
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I Re: Task IA of the Carlsbad Child Care Study: Evaluating Industry Types
Dear Nora:
This letter report details ENVIRONS analysis and conclusions concerning task 1A: Evaluating I Industry Types, of the Carlsbad Child Care Study. This task includes the selection of industry
types that may be of concern when considering siting of a child care facility in Carlsbad
industrial areas. The industry types selected for this study are described and the methods used to
select these industry types are outlined in this letter. -.
Methods of Selecting Industry Types
ENVIRON received a list of the predominant industry tfpes currently in Carlsbad and likely to
locate in Carlsbad horn the City of Carlsbad Fire Department. The names of a few existing
companies to be studied within each category were also provided. To evaluate and augment the
list of industry types provided, ENVIRON reviewed information from the following sources:
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8 San Diego County Department of Environmental Health hazardous materials lists for the
companies whose names were providsd by the Fire Department.
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8 The San Diego County’s Risk Management and Prevention Program selection list.
0 Carlsbad Chamber of Commerce business activity directories.
8 Industry and processing descriptions fiom reference texts. (Sax 1987, Parker 1989,
Austin 1984, Hyer 1990, Grayson 1985, EOP 1987)
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AdmrmdhPBlEs.aaad~Crarp.Ir
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Marketplace Tower 5820 Shellmound Street Suite 700 Eme~y~illc, California 94608 USA Te]: (510) 655-7400 Fax: (510)
Ms. Yesney -2- July 17, 1996
World Wide Web company descriptions for several Carlsbad companies.
Based on analysis of the above sources and discussions with companies concerning their
products and processes, ENVIRON refined the original list to select and defrne the industrial
categories to be analyzed in this study. Identification of industries likely to locate in Carlsbad in
the future was based solely on information provided by the Fire Department.
Industry Types
Industry types were selected to include all industries with a current presence or potential future in
Carlsbad that were likely to use or store hazardous materials which might result in an accidental
release of concern. Seven industry types were selected for the current study. These industry
manufacturing, 3) semiconductor fabrication, 4) electronics plating/ circuit board and computer
electronics manufacturing, 5) chemical manufacturing, 6) analytical instruments and medical
apparatus, and 7) plastics and plastic products manufacturing. The definition of each of these
industries for the purposes of this study is described in the following paragraphs. The reason for
selection and grouping of the industry types as well as a description of the industry's status in
Carlsbad are also included below.
Pharmaceuticals and Biotechnology
We have categorized the pharmaceutical and biotechnology industries as a single group for the
purposes of this study. As described in Sax (1 987), pharmaceutical is "a broad term that includes
not only all types of drugs and medicinal and curative products but also ancillary products and
tonics, dietary supplements, vitamins, deodorants, and the like." Biotechnology is defined as the
use of biological agents and living cells in engineering applications and chemical processing.
Pharmaceuticals can be produced through techniques which employ biotechnology, such as
Hence, although biotechnology can be used for processing unrelated to pharmaceuticals (e.g.,
beer production), the biotechnology industry in Carlsbad is related primarily to pharmaceuticals
development and the hazardous materials us&d by each industry type overlap. Therefore, we
have grouped,the two industries into one industrial category for the purposes of this study.
There are currently several pharmaceutical and biotechnology companies in Carlsbad. Based on
a survery of a few of these companies, this industrial category is currently represented by
research and development and small scale production of drugs, medical reagents, food
supplements, and cosmetics. Research facilities and laboratories predominate, but pilot and
small scale production is present. A few companies surveyed also discussed the possibility of
expanding to larger scale manufacturing. Both chemical synthesis and bioprocessing are used in
development and production by Carlsbad pharmaceutical and biotechnology companies.
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categories include the following: 1) pharmaceuticals and biotechnology, 2) golf club
fermentation and extraction Erom living cells, as well as through traditional chemical synthesis.
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I Ms. Yesney -3- July 17,1996 ' GoZfClu6 Manufacturing
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Carlsbad is home to several golf club manufacturing companies. Based on a survey of a few of
these companies, golf club manufacturing in Carlsbad is primarily composed of the assembly of
golf club components, shaft manufacturing, and research and development. Processes may
include chemical processing, forging, extrusion, drawing, powder metallurgy, bonding, grinding
painting and detailing, coating, and cleaning.
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Semiconductor Fabrication
Semiconductor fabrication is the processing of semiconductor materials (e.g. silicon, gallium-
arsenide) and use of solid-state technology to produce electronic and optical devices such as
integrated circuits, solar cells, photodiodes, and semiconductor lasers. Processes include crystal
growth, oxidation, etching, photolithography, ion implantation, chemical vapor deposition, metal
plating, testing, and encapsulation (packaging). Based on our survey of Carlsbad companies
provided by the Fire Department and discussions with the Fire Marshal, there are currently no
large scale semiconductor fabrication facilities in Carlsbad. However, there may be
semiconductor fabrication operations in Carlsbad in the future.
Electronics Plating/ Circuit Board and Computer Electronics Manufacturing
For the purposes of this study, this category is defined as electronic plating processing for the
production'of circuit boards and other electronic components (not including semiconductor
and photoprocessing. This is a broad industrial category with a current presence in Carlsbad.
Chemicals Manufacturing
Chemicals manufacturing is the development and production of industrial chemicals. Processes
can vary widely, but include chemical synthesis, neutralization, separations, mixing, and heating.
In Carlsbad, chemicals manufacturing companies produce industrial gases and specialty
chemicals for the semiconductor and electronics industries and manufacture medical reagents and
pharmaceutical chemicals. For the purposes of this study, medical reagent and pharmaceutical
processing is considered under the pharmaceuticals and biotechnology industrial category. Thus,
only one facility in Carlsbad is currently incliided in this category.
Analytical InstrumentdMedical Apparatus
Several companies in Carlsbad produce specialty analytical instruments and medical apparatus,
such as respirators and other life support systems. Research, development, and mandacturing
processes are represented.
fabrication). Processes include chemical treatment, plating, heating, coating, etching, cleaning,
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Plastics and Plastic Products Manufacturing
This industrial category can be subdivided into two subcategories: 1) plastic materials and resins
manufacturing and 2) plastic products manufacturing. Plastic materials and resins manufacturing
processes can include polymerization reactions, drying, compounding, molding, extrusion,
heating, and solvent recovery. Plastic product manufacturing is more limited, consisting
Ms. Yesney -4- July 17,1996
primarily of molding and extrusion processes. Based on business activity listings and
discussions with Carlsbad companies in this category, this industrial category in Carlsbad is
represented by a few plastic product manufactures who are not involved in plastic materials and
resins manufacturing.
Closing
Based on information provided by the City of Carlsbad, County of San Diego and other available
resources, ENVIRON refined the list of industry categories to be considered in the current study.
The ;Idustrial groups listed above should include the industries more highly represented in the
Carlsbad industrial areas and those the city feels are likely to locate in the industrial areas in the
future. Only industries which are likely to be of concern in the siting of a child care facility due
to the hazardous materials use are included. Hazardous materials used by each industry type and
other issues of concern for the child care facility siting will be addressed in subsequent sections
of this letter.
Note that although the predominant industries and industrial processes located in Carlsbad
should be identified in this section, it does not include all industries in Carlsbad which may use
hazardous chemicals. Nor, by its nature, can it include all industries that locate in Carlsbad in the
future.
Sincerely,
Associate, Air. Sciences -
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References
Austin, G.T. 1984. Shreve's Chemical Process Industries. Fifth Ed. McGraw-Hill Book
Company. New York.
Executive Office of the President (EOP). 1987. Standard Industrial Classification Manual.
Office of Management and Budget. National Technical Information Service.
Springfield, Virginia. PB 87- 1000 12.
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Ms. Yesney -5- July 17,1996
Grayson, M. 1985. Kirk-Uthmer Concise Encyclopedia of Chemical Technology. John Wiley i
Sons. New York.
Hyer, W.C. ed. 1990. Bioprocessing Safit-y: worker and Community Safety and Health
Considerations. American Society for Testing and Materials. Philadelphia.
Parker, S.P. ed. 1989. Dictionary of Scientific and Technical Terms. Fourth Ed. McG~aw-
Hill Book Company. New York.
Sax, N.I. and Lewis, R. J. 1987. Hawley's Condensed Chemical Dictionary. Eleventh Ed.
Van Nostrand Reinhold Company. New York.
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fiNVIRON
July 17,1996
Ms. Michelle Yesney
David J. Powers & Associates
1885 The Alameda, Suite 204
San Jose, California 95 126
Re: Task 1B of the Carlsbad Child Care Study: Identification of Hazardous Materials
Use by Industry Type .
Dear Ms. Yesney:
This letter report details ENVIRON’s analysis and conclusions concerning task 1B of the
Carlsbad Child Care Study: Identification of Hazardous Materials Use by Industry Type. The
hazardous materials used by each industry type in Carlsbad’ which may be of concern for the
siting of a child care facility are discussed. The metliods used to identify the hazardous material
of concern are also&scribed.
Methods of Identifying Hazardous Materials Information
To identify the hazardous materials of concern for the industries selected in Task 1 A, ENVIRON
-.
used several sources. The sources are listed and described h this section.
0 San Diego Counfy Department of Environmental Health (SDCDEHJ hazardous materials
lists. SDCDEH provided lists of hazardous materials used by companies in Carlsbad for
most of the selected industry types. The companies’ names were provided by the
Carlsbad Fire Department. Industries for which hazardous materials information was
provided include the foIlowing: 1) pharmaceutical and biotechnology; 2) golf club
manufacturing; 3) electronics plating circuit board and computer electronics
manufacturing; 4) analytical instruments/ medical apparatus; and 5) chemicals
manufacturing. Lists of the hazardous materials inventory and wastes for each company
were provided in this source. Hazardous materials were either identified by specific
name or chemical class (e.g halogenated organic waste). No materials that were
considered proprietary by the companies were included.
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Ipredominant industry types in Carlsbad are identified in the letter repon On Task 1A.
” -. ,;-
Ah dAPPSI Lmnnmnd Sosncn Crag. Inc
arketplace Tower 5820 Sheilmound Strcct Suite 700 Erneryvillc, California 94608 * USA Tcl: (510) 655-7400 Fax: (510)
Ms. Yesney -2- July 17, 1996
e Available Risk Management and Prevention Programs (WPP)for each industry.
ENVIRON reviewed available RMPPs to identify hazardous chemical use for the
industries selected in this study. To determine which industries had RMPPs available,
ENVIRON reviewed an RMPP selection list from San Diego County and spoke to
officials in San Mateo County and Santa Clara County. Many RMPPs were not
available since the program is not yet complete. No RMPPs were available for Carlsbad
companies, and many companies in relevant industries were screened out of the RMPP
process. As a result, ENVIRON reviewed RMPPs only for the semiconductor
fabrication, chemicals manufacturing, and electronics plating industries.
e US. Environmental Protection Agency's (USEPA 5) Accidental Release Information
Program (ARIP). The ARIP database is provided by the Right-To-Know Network and
stores information of accidental chemical releases reported from 1986 to 1994.
ENVIRON searched the database by Standard Industrial Classification (SIC) codes for
accidental releases report for each selected industrial category. The SIC system classifies
all industrial activity into SIC categories (e.g. manufacturing of plastic materials and
resins). Several relevant SIC codes were searched for each industrial type selected for
this study to determine potential hazardous chemicals use. Note that this database only
provides information on reported releases. It is not an inclusive list of all releases that
have occurred. Further discussion of this database will be provided in the letter report for
Task 1F; Qualitative Evaluation of the Risks of Accidents for Various Industry Types.
e Industry andprocessing descriptiomfiom reference texts. ENVIRON reviewed several
reference texts and articles for hazardous materials information. These texts include
Chelton et.al. (199 l), ACGIH (1 989), Sax (1 987), Parker (1 989), Austin (1 984), and
Grayson (1985).
0 Discussions wifh companies in each induspial category, ENVIRON contacted a few
companies in Carlsbad in each of the selected industrial categories to discuss their
products, processes, and hazardous materials use.
&
Based on the above sources, ENVIRON identified hazardous materials of concern for the siting
of a child care facility near companies in each of the selected industrial categories. The
hazardous materials identified are discussed below.
Hazardous Materials By Industry Type
"Hazardous materials" are defined by the California Health and Safety Cod2 as "any material
*Chapter 6.95, Article 1, Section 25501.
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that, because of it 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 work place or the environment." The term "hazardous materials" includes
several subcategories of chemicals designated by California Code and U.S Federal Code as
hazardous due to potential health effects from short term or long term exposures fiom releases
into air, water, or soil, or from direct contact. For the purposes of this study, hazardous material2
which are of particular concern for the siting of a child care facility within an industrial area are
chemicals that may be accidentally released to air, can travel in a short time period to offsite
areas, and may cause health effects due to acute exposures. One subset of the hazardous
materials classification of importance for this study is "Acutely Hazardous Materials" (AHM) as
defined by California Health and Safety Code3 to include all "Extremely Hazardous Substances"
listed in the Code of Federal Regulations4. Note that this does not include explosive or
flammable materials, as a class.
Depending on the products manufactured and processes used, different industrial types and
companies may use different hazardous chemicals. Hazardous chemicals of concern for off-site
impact for each industry are discussed below. To limit the listing provided here to a manageable
form and provide the most important information, general categories of hazardous materials used
by each company are described. In addition to general categories, specific relatively volatile5
Acutely Hazardous Materials, less volatile AHMs stored in larger quantities, and hazardous
chemicals with a significant release history are listed.6 Due to the variability of chemicals that
inclusive. However, it should include most major hazardous chemicals and chemical categories
of concern for potential offsite impacts for the given industry.
Pharmaceutical/lBiotechnology
Pharmaceutical producers and biotechnology companies can use and store a variety of substances
for their processes. Based on release histories for pharmaceutical manufactures in the ARIP
database, chemicals and chemical categories used by this industry type which have a history of
release include ethylene oxide, halogenated organic gases (e.g. dichloromethane, chloroform),
organic solvents (e.g. methyl isobutyl ketone,-methanol, toluene), toxic gases (e.g. chlorine and
ammonia), and acidic and caustic liquids (e.g. sulfuric acid, hydrochloric acid, sodium
hydroxide). CLlsbad companies in this industry use several specific volatile acutely hazardous
may be usxi from company to company within an industry, thls list is not intended to be
~~~~~~ ~ ~ ~ ~ ~~~ ~
3Chapter 6.95, Article 2, Section 25532.
4CFR 40. Part 355. Appendix A.
'For the purposes of this report, "relatively volatile" is intended to mean chemicals with vapor pressures greater
than or equal to 1 mmHg.
6The release histones of chemicals and industrial categories are discussed in Section 5.
Ms. Yesney -4- July 17, 1996
materials, including acrylonitrile, ammonia, benzyl chloride, chlorine, chloroform,
epichlorohydrin, formaldehyde, hydrazine, hydrogen chloride gas, and hydrogen sulfide. Sulfuric
acid and acrylamide, although less volatile, are also stored in significant quantities. Note that
pharmeceutial manufacturers often store esoteric pharmeceutical compounds (i.e. narcotics) that
are highly toxic in small doses. These were not evaluated here. In addition, biologically active
agents, such as viruses, have not been considered in this analysis.
Although there are a wide variety of hazardous materials used by pharmaceutical and
biotechnology companies in Carlsbad, most are stored in relatively small quantities or are not very volatile, so a release with adverse effects to off-site populations is less likely. However,
hydrogen Chloride gas and ammonia are gaseous and are stored in larger quantities.
Golf Club Manufacturing
Based on records from the SDCDEH, the hazardous materials used by golf club manufacturers in
Carlsbad includes non-toxic gases (e.g. nitrogen, oxygen, argon), organic solvents (e.g. acetone),
and halogenated solvents. No AHMs were listed as used or stored in the database provided from
the county. Also no incidents of accidental releases are recorded in USEPA's ARIP database for
the applicable Source Identification Classification (SIC), manufacturing of sporting and athletic
goods. However, based on a survey of a few Carlsbad companies, at least one golf club
manufactuie is involved in graphite and titanium processing and coating for shaft development
and production. Therefore, ENVIRON searched the ARlP database for accidental releases
related to processing of graphite and titanium. Based on this search, toxic gases (e.g. ammonia,
boron trichloride), acidic liquids (e.g. hydrofluoric acid, sulfuric acid, nitric acid, chromic acid),
and other toxic liquids (e.g. sodium cyanide) may be used in the golf club manufacturing
industry. Please note that according to the SDCDEH listings, these chemicals are not used by
companies in Carlsbad.
Semiconductor Fabrication
Semiconductor fabrication facilities utilize a variety of toxic chemicals in their processes and
store these chemicals in large quantities. Hazaradous materials used include toxic gases, acidic
and caustic liquids, organic solvents, halogenated solvents, and alkyl metals. Several accutely
hazardous materials used by this industry include chlorine, ammonia, flourine, sulfur dioxide,
hydrogen flo&ide gas, hydrogen chloride gas, arsine, phosphine, diborane, boron triflouride,
boron trichloride, arsenous trichloride, phosphorous trichloride, phosphorous oxychloride,
sulfiric acid, hydroflouric acid, nitric acid, and tellurium (Chelton 1991, ACGIH 1989).
According to the Carlsbad Fire Department there are currently no large semiconductor
fabrication facilities in Carlsbad so no discussion of current hazardous materials usage by this
industry in Carlsbad is given here.
Electronics Plating/ Circuit Board and Computer Electronics Manufacturing
Electronics plating facilities involved in the manufacturing of circuit boards and computer
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electronics use and store severd of the same hazardous materials as semiconductor fabrication
facilities. Hazardous materials used by this industry type include the following: toxic gases such
a~ chlorine, hydrogen Chloride, ammonia, nitrogen dioxide: acidic and caustic liquids such as
sulfuric acid, sodium hydroxide, and hydroflouric acid; organic solvents; halogenated organics;
and hydrogen peroxide. However, no AHMs were listed by the one company in this industry for
whom SDCDEH provided hazardous materials information.
Analytical InstrumentWMedical Apparatus
Based on ARIP database reports, hazardous materials used by this industry category include
chlorine, hydrogen sulfide, sulfur dioxide, ethylene oxide, hydrogen peroxide, mercuric oxide,
cadmium oxide, potassium cyanide, halogenated organics (e.g. dichlorodiflouromethane, benzyl
chloride), and nitric acid. However, no AHMs were listed by the one company in this industry
for whom hazardous materials information was provided by SDCDEH.
Plastics and Plastic Products Manufacturing
Plastics and plastics products manu€actures use and store a variety of' hazardous materials. Based
monorners,(e.g. vinyl acetate), toxic gases (e.g. carbon disulfide, chlorine, fluorine, hydrogen
chloride, nitrogen dioxide, ammonia, bromine), organic oxides (ethylene oxide, propylene
dxide), hedous liquids (e.g. sulfuric acid, hydrogen peroxide, hydrogen fluoride), organic
solvents (e.g. phenol, formaldehyde), organic cyano compounds (e.g. toluene diisocyanate (2,4)
and (2,6)), and halogenated organics (e.g. chloroform, trichloro acetyl chloride). Other
hazardous chemicals used by plastic materials and resin mandactures which have at least one
reported accidental release that resulted in public injuries or evacuation include toluene, sodium
hydroxide, ethylene, ethane, and methacrylic acid. Further discussion of the accidental release
histories of the two subcategories of this industry will be provided in the letter report for task 1F.
No hazardous materials information for Carlsbad companies in this category was provided by the
SDCDEH.
Chemicals Manufacturing
This industry type includes a broad range of Ehemical processes. Thus there are large quantities
of many hazardous chekcals used and stored by companies in this category. AH"S used by an
industrial gasmanufacturer in Carlsbad include sulfuric acid, hydrogen chloride gas, and
phosphorus oxochloride. Other AHM's used throughout the industry with a history of accidental
release include chlorine, ammonia, phosgene, hydrogen fluoride, hydrogen chloride, sulfur
dioxide, sulfur trioxide, bromine, boron trifluoride, phosphorus oxochloride, ethylene oxide,
chloroform, nitric acid, nitric oxide.
The hazardous materials used by each selected industry type are identified in this letter report.
Implications for the siting of a child care facility due to the use of these material including
potential offsite concentration and accidental release history are discussed in subsequent letter
reports.
on MP accident repofis, the accutely hazardous materials used by hs industry may include
Ms. Yesney -6- July 17, 1996
/f$f2l&
Sincerely,
' Beth Libicki, Ph.D. A&& Associate, yL. s Air Sciences
References
American Conference of Governmental Industrial Hygienists (ACGIH). 1989. Hazard
Assessment and Control Technology in Semiconductor Manufacturing. Lewis Publishers,
Inc. Chelsea, Michigan.
Austin, G.T. 1984 Shreve's Chemical Process Industries. Fifth Ed. McGraw-Hill Book Company. New York.
Chelton, C.F. Glowatz, M. and Mosovsky, J.A. 1991. Chemical Hazards in the Semiconductor
Industry. IEEE Transaction on Education. Vol. 34. No. 3. August.
Grayson, M. 1985. Kirk-Othmer Concise Encyclopedia of Chemical Technology. John Wiley
& Sons. New York.
Parker, S.P. ed. 1989. Dictionary of ScientHc and Technical Terms. Fourth Ed. McGraw-
Hill Book Company. New York. -
Sax, N.I. and Lewis, R. J. 1987. Hawley's Condensed Chemical Dictionary. Eleventh Ed. Van Nostrand Reinhold Company. New York.
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b €NVIRON
8
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Ms. Michelle Yesney
David J. Powers & Associates
1885 The Alameda, Suite 204
San Jose, California 95 126
1 Re: Task 1C of the Carlsbad Child Care Study: Evaluation of Available Risk
I Management and Prevention Plans and
Task 1D: Potential Off-site Concentrations of Hazardous Materials
Dear Ms. Yesney: I This letter report details ENVIRONS analysis and conclusions concerning tasks 1B and 1 C of
I the Carlsbad Child Care Study. The availability of Risk Management and Prevention Plans
RMPPs) far each industry and ENVIRON's review of the available RMPPs are detailed'. The
implications of this ._ review as far as potential off-siteimpacts from accidental releases are also :
I discussed. " - .. -. .
<.
1 The RMPP Program: Background, Requirements and Prioritization
California's Risk Management and Prevention Program is-the result of a state regulation
designed to prevent and, if possible, mitigate the impacts that may result from the accidental
release of acutely hazardous materials. This is done by identifving manufacturers and handlers s of AcuteIy Hazardous Materials (AHMs) and then predicting which geographic locations may be
affected by potential releases of AHMs. An RMPP generally includes an analysis of the facilitiez
accident history, a study of the history of equipment at the facility, an analysis of the facility I design and operations procedures, a hazard and operability study, a seismic analysis, an analysis
of preparedness for external events, and an off-site consequence analysis. The proximity of the
facility to sensitive populations, including day care centers, must be considered in the analyses.
Sensitive populations are generally identified and potential impacts in the event of an emergency
release are often provided in the off-site consequences analysis section. If off-site consequences
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I 'As the federal Risk Management Prom (RMP) requirements were being written as this project occurred
I and analysis of these requirements is out of the scope of this work, evaluation of the RMP and its impact on the
study conclusions was not performed.
-. " ?=
AOmv.nd&PBl€mmunmdSu.raGnup.Inr
Marketplace Tower 5820 Shellmound Street Suite 700 Emeryville, California 94608 USA Tcl: (510) 655-7400 Fax: (51(
Ms. Yesney -2- July 17, 1996
are predicted, then the program requires the recommendation of changes in equipment, training
programs, operating and maintenance procedures, mitigation systems, and emergency response
plans2.
The regulation requires that administering agencies, such as county environmental health and
safety departments prioritize the potential hazards of the use of hazardous materials and establish
a timetable for companies to submit RMPPs for review. The timetable requires that companies
with the highest potential hazards submit WPs within the first wave of submittals. Companies
with a low potential for hazards would submit WPs later in the process, or may not be
required to submit RMPPs at all, if hazards can be shown to be minimal. Thus, where in the
schedule of submittals a company’s RMPP is required is an indication of its potential hazard.
New or modified facilities that propose to handle AHMs in the quantities requiring RMPP
consideration must either, obtain an exemption from the RMPP program, or, complete the RMPP
analyses and implement all programs and activities contained therein, prior to commencing
operations.
The RMPP program is in various stages of completion in different counties. Thus, not all
RMPPs that have been requested by the administering agency, have been completed, or are
currently available for public review. In addition, not all RMPPs that may be requested have
been requested at this time. However, RMPPs that are available or available from public
comment are from those industries with the highest potential for off-site impacts.
To determine the availability of RMPPs for the industry types selected for the Carlsbad Child
Care Study, ENVIRON contacted officials at the Environmental Health Departments of San
Diego County, San Mateo County, and Santa Clara County. San Diego County provided a list of
facilities selected for RMPP submittal, and Santa Clara County and San Mateo county discussed
the selection process and availability of RMPPs, but did not provide the RMPP selection list for
review.
In order to describe which RMPPs are available, and which industries have RMPPs on file, we
discuss the range of RMPPs available in the three counties discussed above. Only WPs for
the semiconductor fabrication, electronics plating, and chemicals manufacturing industry types
were available for review by ENVIRON. RMPPs for the other industry types were either not yet
available or companies in that industry were not currently selected for the RMPPs process. No
RMPPs were yet available for Carlsbad companies, although one for a pharmaceutical company,
is currently being prepared.
..
2California Health and Safety Code. Chapter 6.95. Article 2. Section 25534 - 25541.
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Potentia1 Impacts By Industry Type
Based on a review of available RMPPs, ENVIRON analyzed the potential for impacts of
accidental releases for the selected industry types. The potential impacts, including distances to
potential off-site concentrations of concern3 are discussed in this section. For industry types wi~
no available RMPPs, information concerning the potential accidental release impacts was
inferred from the RMPP prioritization status.
ENVIRON reviewed the RMPPs to evaluate which industries had the potential for off-site
impacts. It is important to note that the potential for off-site impacts occurring in the event of a
accidental release are a function of the amount of chemical stored, the release scenario, and the
meteorological conditions at the time of the release. RMPPs analyze the maximum off-site
impacts that would occur in a worst-case release under meteorological conditions designed to
maximize off-site impacts. Therefore, the evaluation of the RMPP results will provide an
analysis designed to provide conservative and health-protective results.
PharmaceuticalllBiotechnology
Although there are several pharmaceutical/ biotechnology companies in Carlsbad, only one
pharmaceutical company is currently submitting an RMPP. That RMPP is not yet available for
public review. The off-site consequence analysis for the only other pharmaceutical/
biotechnology company on the San Diego County RMPP selection list indicated that estimated
concentrations greater than or equal one tenth the IDLH (IDLW10)4 may occur out to
approximately 700 feet from the point of an accidental release of propylene oxide. No
pharmaceutical/ biotechnology companies have available RMPPs in Santa Clara or San Mateo
counties. However, a few companies in San Mateo County are in the submittal process.
As with all other companies and industry types, the magnitude and existence of impacts are
directly related to the types and amounts of acutely hazardous materials handled. Based on a
review of hazardous materials stored by Carlsbad pharmaceutical companies, accidental release
histories for the industry from the ARIP database, discussed in other letter reports, and the
available off-site consequence analysis, there is the potential for public impacts from accidental
releases from some companies of this industry type, particularly those who store large quantities
of toxic gases, such as hydrogen chloride, chlorine, and ammonia.
3The term, concentration of concern, is defiaed in the RMPP program for each chemical. It generally refers to either one-tenth the level immediately dangerous to life and health (IDLH) or the emergency planning
response guidelines (ERPG) level two or three.
4See the letter report on Task 1E for a detailed discussion ofthe concentration of concern levels.
Ms. Yesney -4- July 17, 1996
Semiconductor Fabrication
As discussed in the letter report for Task 1 A, there are currently no large semiconductor
fabrication facilities in Carlsbad. There are two semiconductor fabrication facilities on the San
Diego County RMPP screening list, one of which has an RMPP in its public comment period.
Several RMPPs were available for semiconductor fabrication facilities in Santa Clara County.
ENVIRON reviewed the off-site consequence analysis for a few of these WPs to determine
the potential off-site impacts and distances to concentration Levels of Concern (LOCs) in the
event of an accidental release. Off-site impacts were predicted for several chemicals, including
ammonia, chlorine, boron trifluoride, arsine, diborane, hydrogen chloride, nitrogen trifluoride,
and phosphine. The distances to off-site impacts were predicted to be up to approximately 900
feet fkom the point of the chemical release, and over 700 feet beyond the facility boundary. It is
important to note that the analyses were conducted using a worst case accident scenario,
predicted distances were reduced to within the facility boundary for several cases.
Based on this review it appears that semiconductor manufacturing facilities have the potential to
cause off-site impacts in the event of an accidental release under worst-case situations. Certain
mitigating measures, such as the requirements of restricted flow orifices (RFOs) for gas and
pressurized liquid cylinders can mitigate off-site impacts and are required by the Toxic Gas
Ordinance in Santa Clara County. San Diego County does not currently require the use of RFOs.
However, even with such mitigation measures, available information suggests that accidental
releases at semiconductor manufacturing facilities have the potential to result in off-site impacts.
Electronics Plating/Circuit Board and Computer Electronics Manufacturing
Several companies within this industry group are located in Carlsbad. However no facilities in
Carlsbad are on the San Diego County RMPP selection lists. Five electronics plating/ circuit
board and computer electronics manufacturing companies in San Diego County are on the RMPP
selection list and one RMPP is available in its public comment period. Santa Clara County has a
few completed RMPPs for this industry category also. ENVIRON reviewed several RMPPs to
determine potential off-site consequences of an accidental release. The available off-site
consequence analysis fiom San Diego County indicated that impacts fiom an accidental release
of ammonia gas may occur out to approximately 900 feet. An off-site consequence summary
fiom Santa Clara County indicated that estimated impacts from accidental releases may occur out
to approximately 1000 feet fiom the point of release. However, specific information for the
Santa Clara company was not available as the technical off-site consequence analysis was not
available for review. As an additional note, as this industry type uses many of the Same
chemicals as semiconductor fabrication facilities, off-site impacts may be expected to be similar.
Chemicals Manufacturing
There are several chemicals manufacturers and suppliers in San Diego County. One company
that primarily supplies specialty gases for the semiconductor industry is located in Carlsbad.
Seven companies in this industrial category are on the San Diego County RMPP selection list, of
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which three are available for public review. It is important to note that chemical mandacturing
covers a wide range of potential activities. Therefore, any generalizations in this industry group
must be considered in that context. The Carlsbad company was screened out of the RMPP
analysis and, according to company representatives, modeling of air concentrations that may occw in the event of an emergency release, performed by that company for their current operations, indicated no off-site impacts. This information could not be verified by ENVIRON.
Santa Clara County also has a few completed RMPPs fiom chemicals suppliers.
ENVIRON's review of the off-site consequences fiom two industrial gas suppliers and two
chemical distribution centers in Santa Clara county and San Diego county indicate that off-site
concentrations of a worst-case accidental release of some hazardous chemicals may exceed
concentrations of concern up to 5000 feet fiom the point of release. As the storage amounts and
release conditions can vary significantly between manufacturers and releases, the concentrations
and distances listed above should not be used to define an impact area for the entire industry.
However, this analysis shows that industries within the chemicals mandacturing group have the
potential to cause off-site impacts.
Analyticai InstrumentdMedical Apparatus
Although there are several Carlsbad companies in this category, none are listed on the Sari Diego
County R"P selection lists. Only one company in this industrial category in San Diego
County is listed on the selection list, but no RMPPs are currently available. Therefore, no
RMPPs were reviewed for this industrial category. Due to the status of the RMPP process for
companies of this industry category, it may be inferred that the handling of nazardous materials
by companies of this industry type may not generally pose the same off-site hazard as the
semiconductor fabrication, electronics plating/ circuit board and computer electronics
manufacturing, and chemicals manufacturing industries.
Plastics and Plastic Products Manufacturing
There are several plastics and plastic products manufacturing companies in Carlsbad and San
Diego county. However, the only company in this category on the San Diego County RMPP
selection list, located outside of Carlsbad, w& screened out of the process and is not required to
perform the analysis. Therefore, no RMPPs were reviewed for this industrial category and the
potential for off-site impacts of accidental releases fiom this industry type are likely less than
that of the other industry types with available RMPPs,
Goif Club Manufacturing
No companies in this category are listed on the San Diego County selection list. Therefore,.no
RMPPs were reviewed for this industrial category. Exclusion of companies in this category from
the RMPP selection list may indicate that, based on the chemicals used and amounts handled, the
county does not believe that companies in this category pose a significant hazard to off-site
communities. Thus, while it is possible that certain companies that fall into this category may
have the potential for accidental releases that have off-site impacts, the probability is low.
Ms. Yesney -6- July 17,1996
Closing
As discussed above, ENVIRON reviewed available RMPPs for the semiconductor fabrication,
electronics plating circuit board and computer electronics mandacturing, and chemicals
manufacturing industries. Review of these RMPPs indicated that accidental releases under
worst-case scenarios from these industries may have off-site impacts. No RMPPs were reviewed
for the other industries selected for this study, as none were found to be available.
Sincerely,
Associate, Air Sciences
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€NVIRON
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Ms. Michelle Yesney
David J. Powers & Associates
1885 The Alameda, Suite 204
San Jose, California 95 126
I
Re: Task 1E of the Carlsbad Child Care Study: EEects of Short-Term Exposure I Dear Ms. Yesney:
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This letter is a report of ENVIRONS analysis and conclusions concerning Task 1E of the
Carlsbad Child Care Study: Effects of Short-Term Exposure. The purposes of this task are the
following:
0 Identify the most prominent and reliable sources of information on individual exposure
0 Collect and summarize the recommended exposure limits and action levels for 4
limits and coinmunity action levels for short-term exposures
l representative chemicals
0 Discuss the factors that can cause children to be more sensitive to some chemicals than
1 adults
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Evaluate four chemicals that are representative of chemicals used in industries in
Carlsbad to determine if there are any specific reasons to believe that children would be
more sensitive than adults with regard to health effects.
L
Each of these subtasks will be discussed in the following sections of this letter.
Basis of Exposure Limits
Children represent a sensitive subpopulation with regard to the risk for adverse health effects
from exposure to chemicals. This may be due, among other factors, to their higher respiratory
rate (OEHHA 1995). There are no child-specific exposure limits, standards, or guidelines for
acute exposures. In this task, we evaiuate the basis for the available acute exposure limits to 0
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Adi.lurdAPtllEm"G-I=
Marketplace Tower 5820 Shellmound Street Suite 700 Emeryvillc, California 94608 USA Tel: (510) 655-7400 Fax: (5
Ms. Yesney -2- July 16, 1996
assess whether these limits would be protective of children. Below is a list of available health-
based acute exposure limits. Following the list is an assessment of whether these limits are
considered to be protective of children.
0 The California Air Pollution Control Officer’s Association (CAPCOA) acute reference
exposure levels (RELs)
0 The California Occupational Safety and Health Administration (California OSHA),
Federal OSHA, and the American Conference of Governmental Industrial Hygienists
(ACGIH) short-term exposure limits (STELs) and Ceiling limits
0 The American Industrial Hygiene Association (AIHA) emergency response planning
guidelines (ERPGs)
0 The National Research Council (NRC) emergency exposure guideline levels (EEGLs),
and Short-term Public Emergency Guidance Levels (SPELGs)
0 The National Institute for Occupation Safety and Health (NIOSH) Immediately
Dangerous to Life and Health (IDLH) limits
0 The United States Environmental Protection Agency’s (USEPA’s) Level of Concern
(LOCI
THE CALIFORNIA AIR POLLUTION COhTROL OFFICER’S ASSOCUTION (CAPCOA) ACUTE REFERENCE
EXPOSURE LEVELS (ELS)
The CAPCOA lists RELs for use in their Air Toxic Hot Spots program (CAPCOA 1993). RELs
are levels of exposure at or below which a specified adverse health effect is not anticipated
(CAPCOA 1993). RELs are developed using laboratory animal data and account for potentially
increased sensitivity in humans as compared to laboratory animals and the large range of
sensitivities $thin the human population (CAPCOA 1993). These RELs are based on a one-
hour averaging time.
In January of 1995, the Office of Environmental Health Hazard Assessment (OEHHA) of the
California Environmental Protection Agency (Cal/EPA) prepared a draft Technical Support
Document for The Determination of Acute Toxicity Eiposure Levels for Airborne Toxicants
(Cal/EPA 1995). This support document presents a uniform, scientifically-based method for
deriving acute toxicity exposure levels applicable to the general public for hazardous substances
released into the air (Cal/EPA 1995). A margin of safety approach is used to estimate the levels
of exposure that may cause harm. This margin of safety accounts for the diversity within human
populations and any uncertainty related to the completeness and applicability of the available
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data. Each acute toxicity level is derivedfiom the most sensitive measure of toxicity and proteci
identifiable sensitive subpopulations by use of uncertainty factors. The lowest of the three acute
toxicity exposure levels is considered the Reference Exposure Level (REL). While health effect:
are not expected to occur at air concentrations below the EL, the REL may not protect
individuals with an idiosyncratic sensitivity (CaVEPA 1995).
THE CALIFORNIA OCCUPATIONAL SAFETYAND HEALTHADMINISTRATION (CALIFORNIA OSHA),
(ACG'IV SHORT-TERMAWOSURE LIMITS (STELS) AND CEILING LEVELS 0
The establishment of fifteen (1 5) minute short-term exposure limits (STELs) are aimed at
determining an air level below which workers could perform for 15 minutes without loss of
consciousness or loss of the ability to perform the tasks expected of them. The need to remain ir
an area where there is an unacceptable level of a chemical vapor may relate to the need to
stabilize a dangerous situation which might otherwise lead to greater danger to the exposed
individual or to others in danger of exposure (Casarett and Doull 1996). There are, therefore,
two issues. One is loss of consciousness; the second is the potential impairment of ability to
perform essential emergency procedures. Clearly, these levels are not set to protect children
from chemically induced adverse health effects.
FEDERAL OSHA, AND THE AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENiSTS
THE AMERICAN INDUSTRIAL HYGIENE ASSOCIATION (AI.) EMERGENCY RESPONSE PLANNING
GUIDELINES (ERPGS)
The Emergency Response Planning Guideline (ERPG) values are intended to provide estimates
of concentration ranges where one reasonably might anticipate observing adverse effects as
described in the definitions for ERPG-1, ERPG-2, and EWG-3 as a consequence of exposure to
the specific substance (AIHA 1988). The definitions are given below.
The ERPG-1 is the maximum airborne concentration below which it is believed that nearly all
individuals could be exposed for up to 1 hour without experiencing other than mild transient
adverse health effects or perceiving a clearly defined, objectionable odor.
The EWG-2 is the maximum airborne concentration below which it is believed that nearly all
individuals could be exposed for up to 1 hour without experiencing or developing irreversible or
other serous health effects or symptoms.which..could impair an individual's ability to take
protective action.
-
The ERF'G-3 is the maximum airborne concentration below which it is believed that nearly all
individuals could be exposed'for up to 1 hour without experiencing or developing life-
threatening health effects.
Ms. Yesney -4- July 16, 1996
The preface to AIHA’s ERPGs states that the values derived for ERPGs should be applicable to
most individuals in the general population. Since these values have been derived as planning and
emergency response guidelines, not exposure guidelines, they do not contain the safety factors
normally incorporated into exposure guidelines. Instead, they are estimates of the thresholds
above which there would be an unacceptable likelihood of observing the defined effects. The
estimates are based on the available data that are summarized in the documentation.
The documentation also states that in developing the ERPGs, human experience is emphasized to
the extent data are available. Most human experience, however, is based on occupational
incidents. Rarely is there data regarding air exposures to children. Since no safety factors are
incorporated into these guidelines, one cannot say that the ERPGs (when developed using adult
human data) are protective of children’s health.
The ERPG-2 and ERPG-3 levels are two levels of concern that are typically used in Risk
Management and Prevention Program Guidelines to define the concentrations of airborne acutely
hazardous material at levels that could cause irreversible acute health effects or death in a defined
geographical area.
THE EMERGENCY EXPOSURE GUIDELINE LEVELS (EEGLS) AND SHORT-TERM PUBLlC EMERGENCY
GUIDANCE LEVELS (SPEGLS)
An EEGL is defined by the National Academy of Sciences (1 986) as the ceiling concentration of
a substance in air that may be judged by the Department of Defense to be acceptable for the
performance of specific tasks during rare emergency conditions lasting for periods of 1-24 hours.
“Emergency” connotes an unexpected situation with potential for loss of life. EEGLs are
designed to provide guidelines for military personnel operating under emergency conditions that
are peculiar to military operations and for which regulatory agencies have not set standards.
The SPEGL is defined by the National Academy of Sciences (1 986) as a suitable concentration
for unpredicted, single, short-term, emergency exposure of the general public. In contrast to the
EEGL, the SPEGL takes into account the wide range of susceptibility of the general public.
From the definitions given above for EEGLs and SPEGLs, it is clear that the EEGLs do not
protect against health effects from acute exposure but rather guard against escape-impairing
performance. No uncertainty factors are used in setting these limits. These levels are not likely
to protect children due to the fact that they are set for adults and do no include uncertainty
factors. The SPEGLs, on the other hand, are likely to protect children. ..
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THE NATIONAL INSTITUTE OF OCCUPATIONAL HEALTH3 (i?..osf?3) IMMEDIATELY DANGEROUS TO LIFE
OR HEALTH (IDLH) LEVELS
IDLH values developed by the National Institute of Occupational Safety and Health (1990) were
designed for healthy workers. IDLHs are defined as the maximum level to which a healthy
worker can be exposed for 30 minutes and escape without suffering irreversible health effects or
escape-impairing symptoms. This level clearly will not protect against acute health effects in
children because (1) it is set based on a healthy adult worker and (2) it is set only to protect
against escape-impairing symptoms.
THE UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY ’S (USEPA’S) LEVEL OF CONCERN (LOC,
The USEPA defines its levels of concern as the concentration of an Extremely Hazardous
Substance above which there may be serious irreversible health effects or death as a result of
single exposure for a short period of time. The LOCs are calculated by dividing NIOSH’s IDLH
by 10 (IDLW10). (USEPA 1993) LOCs are typically used in Risk Management and Prevention
Program Guidelines to define the concentrations of airborne acutely hazardous material at levels
that could cause irreversible acute health effects or death in a defrned geographical area. Because
IDLHs are developed for a healthy worker, it is impossible to predict whether 1/10 of this value
is protective of children.
Summary of the Recommended Exposure Limits and Action Levels
Four chemicals representative of industries in Carlsbad were chosen on the basis of their
potential type of health effect. For example, health effects from acute exposures can, among
other effects, include initation, central nervous system depression, organ effects, and caustic
injuries to the eyes, skin, respiratory tract and stomach. Using the list of chemicals identified in
Tasks 1C and lD, i.e., chemicals associated with particular industries, we have chosen 4
representative chemicals. Table 1E. 1 presents these chemicals, the associated health effects fiom
acute exposure, the ERPG-1 , the REL, and the odor threshold (indicative of nuisance properties).
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Ms. Yesney -6- July 17, 1996
Table lE.1
~ Chemical I Health Effect I ERPG-l
~ ~~
Chlorine
~~ ~ 1 Initant 1-1 PPm
~ ~~
Toluene 50 PPm Central Nervous
System Depression
Carbon Tetrachloride
5 PPm Caustic Injuries Hydrogen Fluoride
Effects
20 PPm Liver and Kidney
1 Threshold
0.07 ppm . 0.2-0.4 ppm
9.8 ppm 0.16-3 7 ppm I/
0.13 ppm 96 ppm II
0.17 ppm I 0.04-0.13 ppm 11
Note that carbon tetrachloride was chosen to conservatively represent chlorinated compounds
identified in this study, as it is one of the more toxic chemicals in this class.
Factors Influencing the Sensitivity of Children
Children represent a sensitive subpopulation with regard to the risk for adverse health effects
from exposure to chemicals. This may be due to several factors. The first factor is that children
have a higher respiratory rate per body weight than do adults. According to the USEPA, the
average inhalation rate for a reference man is 20 meters cubed per day (m3/day) and the average
weight is 70 kilograms (kg). This equates to 0.25 rn31day-kg. The daily inhalation rate for
children ages 0.5 to 3 years is about 5.6 meters cubed per day. The weight that USEPA assumes
for a 0-6 year old is 15 kg. This equates to about 0.4 m3/day-kg. Children would therefore
receive a higher dose of a chemical than an adult given the same concentration of a chemical in
the air.
Another factor may be differences in metabolism between adults and children. Often times,
chemicals are metabolized into either less toxic or more toxic chemicals in the body. This
metabolism occurs because of the presence of enzymes in the body. If certain enzymes are not as
developed in children, detoxifying mechanisms may not be as efficient in children as adults. If
certain enzymes are more active in a child, toxifling mechanisms may be more efficient in
children.
Another factor may be the difference in the distance between the point of inhalation and the point
of absorption into the body (i.e., the nose or mouth to the bottom of the lungs where the blood
into their blood stream much faster than adults.
and oxygen mix). ns distance is far less in a child, therefore, they would receive chemicals
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Sensitivity of Children to Representative Chemicals
The four representative chemicals chosen for evaluation differ in their endpoints of toxicity.
Chlorine is an irritant, toluene is a central nervous system depressant, carbon tetrachloride can
damage the liver and kidneys, and hydrogen fluoride can cause burns to tissues.
Irritants
There is no available data to evaluate the potential for increases sensitivity to irritants in children.
However, it is likely that children would be more sensitive to respiratory irritants than would
adults due to children’s more rapid respiratory rate.
Central Nervous System Depressants
Solvents are typical central nervous system depressants. Solvents would be an example of a
class of chemical that would have a greater effect on children due to the increased dose. This
increased dose in children (over adults) is due to the rapid respiratory rate and lower body
weight.
Chemicals Causing Target Organ Damage .
Carbon tetrachloride is an example of a chemical that causes target organ damage through the
formation of a toxic metabolite fiom enzymes in the body. It is not known whether there is a
difference in activity or number of the toxieing enzymes in children. It is therefore not known
whether children would be more susceptible to the toxic effects of carbon tetrachloride. Again,
however, children would receive a higher dose of the chemical than adults which may render the
children more sensitive to the same air concentration than adults.
Caustic Chemicals
Because of the smaller anatomy of a child (i.e., distance between point of inhalation and contact
of chemicals $th the bloodstream), a caustic chemical may cause more damage in a child than
an adult.
Conclusions
The purpose of this task was to identify regulatory standards and guidelines pertinent to short
term exposures and to assess whether these guidelines are protective of children. We have
provided a list of the most prominent and reliable sources of information on individual exposure
limits and community action levels for short-term exposures and assessed which exposure limits
may be protective of children. Our analysis revealed the levels which may be protective of
children include RELs, ERPG-1 s, and SPEGLs. The other sets of levels are most likely not
Ms. Yesney -8- July 16,1996
protective of children. To give an idea ofthe levels that may be protective of children, we have
collected and summarized the RELs, EWG-ls, and odor thresholds for 4 chemicals that are
representative of chemicals used at industrial sites in Carlsbad.
As a part of this task, we discussed the factors that can cause children to be more sensitive to
some chemicals than adults. The most prominent factors include children's rapid respiratory rate
and low body weight. Other factors may include a less developed metabolic system and a shorter
respiratory tract.
Finally, we evaluated four chemicals that are representative of chemicals used in industries in
Carlsbad determined if there are any specific reasons to believe that children would be more
sensitive than adults with regard to health effects. These four chemicals included chlorine,
toluene, carbon tetrachloride, and hydrogen fluoride. Each chemicals also represents a specific
mechanisms of toxicity. Chlorine is. an irritant, toluene is a central nervous system depressant,
carbon tetrachloride causes liver and kidney injuries, and hydrogen fluoride is caustic. It is likely
that the child is more sensitive to the effects of these chemicals for different reasons depending
on the chemical's mechanism of toxic action.
~~~~
* eth Libicki, Ph.D.
rincipal & Y&%L Sc&"Dt';iQ
Jill Ryer-Powder, Ph.D., DABT
Manager of Health Sciences
References -
American Industrial Hygiene Association (AIHA). 1988. Emergency Response PIanning
Guidelines.
California Environmental Protection Agency (CaVEPA). 1995. The Determination ofAcute
Toxicity Exposure LeveIs of Airborne Toxicants. January.
Casarett & Doull's Toxicology. 1996. The Basic Science of Poisons. Fifth Edition. Editor Curtis
D. Klassen, Ph.D. McGraw-Hill.
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National Institute for Occupational Safe* and Health. 1993. Pocket Guide to Chemical
Hazards. U.S. Government Printing Office, Washington, D.C.
National Research Council, Committee on Toxicology. 1986. Criteria and Methods for
Preparing Emergency Exposure Guidance Level (EEGL), Short Term Public Emergency
Guidance Level (SPEGL) and Continuous Ejcposure Guidance Level (CEGL) Document5
National Academy Press, Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 1993. Handbook of Chemical Hazard
Analysis Procedures. Federal Emergency Management Agency. Washington, D.C.
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1 July 17, 1996
I Ms. Michelle Yesney
David J. Powers & Associates
I 1885 The Alameda, Suite 204
San Jose, California 95 126
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Re: Task 1F of the Carlsbad Child Care Study: Qualitative Evaluation of the Risks of
Accidents for Selected Industry Types
Dear Ms. Yesney:
Carlsbad Child Care Study: Qualitative Evaluation of the Risks of Accidents for Selected
Industry Types. The likelihood of an accidental release for each industry type in Carisbad' whici
determine the risks'<f.accidents are also described.
i may be of concern for the siting of a child care facili? are discussed. The methods used to :
Methods of Identifying Risks of Accidents
To determine the risks of an accidental release with potegial impacts outside of facility
boundaries (off-site impacts), ENVIRON reviewed several sources. The following paragraphs
list and describe those sources:
0 me US. Environmental Protection Agency's (USEPA 's) Accidental Release Information
Program (ARIP). The ARIP database is provided by the Right-To-Know Network and
stores information on accidental chemical releases reported from 1986 to 1994. ,
ENVIKON searched the database by Standard Industrial Classification (SIC) codes for
accidental release reports for each selected industrial category. The SIC system classifies
all industrial activity into SIC categories (e.g. manufacturing of plastic materials and
resins). Several relevant SIC codes were searched for each industrial type selected for
this study. The SIC codes searched are listed under each industrial category, below.,
inclusive list of all releases that have occurred.
Note that this database only provides information on reported releases. It is not an
'Predominant industry types in Carlsbad are identified in the letter report on Task IA.
*. ." '.j
AdmvondMBIEnmarrndSC".I~
arketplacc Tower 5820 Shellmound Street Suite 700 Erneryville, California 94608 USA Tel: (510) 655-7400 Fax: (510
Ms. Yesney -2- July 17, 1996
e The Carlsbad Fire Department's AccidentaI Release Database. ENVIRON reviewed
information provided by the Carlsbad Fire Department concerning accidental releases
occurring in Carlsbad over the past 5 years. A total of approximately 95 releases of
hazardous materials were reported in Carlsbad during this period. Nine of these releases
occurred in Carlsbad industrial areas. Of the nine releases, seven were of fuels, such as
gasoline and jet fuel, and one was of hydrochloric acid releaied in a transportation
incident. Only one release of an unknown non-fuel hazardous material was reported to
have occurred at an industrial facility, with no impacts beyond the room of the release
origin.
0 Available Risk Management and Prevention Programs (MPP) for each industry. As a
discussion of a facility's accidental release history is part of the RMPP process,
ENVIRON reviewed available RMPPs for the semiconductor fabrication, chemicals
mandacturing and electronics plating industries. Further description of the RMPP
program is provided in the letter report for tasks 1 C and 1 D.
0 San Diego County Department of EnvironmentaI HeaIth (SDCDEH) hazardous materials
lists. ENVIRON reviewed hazardous materials lists provided by the SDCDEH for
several companies in Carlsbad selected for this study. The conclusions of this review,
discussed in the letter report on task lB, were used to further identify potential risks in
Carlsbad. For further discussion of the information provided by the SDCDEH, see the
letter report on task 1B.
Risks of Accidental Releases by Industry Type
Through the above sources, ENVIRON qualitatively analyzed the risks of accidental releases of
concern for the siting of a child care facility for each selected industry types. A discussion of the
potential for accidental releases of hazardous materials for each industry is provided in this
section.
Pharmaceuti~al4Biofnology
For this industrial category, ENVIRON searched the AFUP database for releases by companies in
the following SIC categories: 1) medicinal chemicals and botanical products, 2) pharmaceutical
preparations, 3) in vitro and in vivo diagnostic substances, 4) biological product, except
diagnostic substances, and 5) perfumes, cosmetics,.and other toilet preparations. The SIC codes
corresponding to these industrial classifications are 2833,2834,2835,2836, and 2844, . ..
respectively. According to the ARIP database, several accidental releases of hazardous
chemicals were reported at pharmaceutical/ biotechnology companies since 1986.
Only the pharmaceutical preparations and perfiunes, cosmetics, and toilet preparations categories
had reported releases. A total of approximately 30 releases were reported, nine having on-site
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impacts2, and two having public impacts? Chemicals released include chlorine, sodium
hydroxide, ammonia, ethylene oxide, halogenated organics, hydrochloric acid, organic solvents,
and sulfuric acid.
As discussed in the letter report on task lB, the volatile acutely hazardous chemicals handled in
larger quantities by Carlsbad companies include hydrogen chloride gas and ammonia. No
releases of non-fuel hazardous chemicals were reported in Carlsbad industrial areas over the last
five years for this industry type.
Based on the chemicals handled by this industry type and the accidental release reports provided
by Carlsbad and the ARIP, accidental releases fiom the pharmaceutical/ biotechnology industry
group have the potential for off-site impacts. However, off-site impacts are not common. The
chemicals which appear to have the most potential for accidental release and off-site impact for
this industry are hydrogen chloride gas, ammonia, chlorine, and halogenated organics.
Gorf Club Manufacturing
No incidents of accidental releases are recorded in USEPA's ARIP database for SIC
classification relevant to this industrial category, manufacturing of sporting and athletic goods.
However, based on a survey of a few Carlsbad companies, at least one golf club manufacturer is
involved in' graphite and titanium processing and coating for shaft development and production.
Therefore, in an attempt to ensure that operations that may be occurring at the Carlsbad facility
are considered, ENVIRON searched the ARIP database for accidental releases related to
processing of graphite and titanium. Releases by companies in the following SIC categories
were searched: 1) carbon and graphite products, 2) minerals, ground or treated, 3) rolling,
drawing, and extruding of nonferrous metals, 4) nonferrous foundries (castings), 5) metal
forgings and stampings, and 6) [metal] coating, engraving, and allied services. The SIC codes
corresponding to these industrial classifications are 3624,3295,335,336,346, and 347,
respectively. It is important to note that not all operations occurring in these SIC codes are
taking place at the Carlsbad facilities. In order to be conservative, ENVIRON evaluated a
broader range of industrial operations than is likely to occur in golf club manufacturing.
SIC codes 331,336 and 347 had reported release histories. No public impacts were reported.
Three of these releases, listed under rolling, drawing, and extruding of nonferrous metals and
nonferrous foundries (castings), may have been related to titanium processing. Chemicals
released included hydrofluoric acid, potassium hydroxide, and ammonia. A total of 24 releases
were reported for metal coating, engraving and allied services, none of which appeared to be
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2We have defmed impacts to be injuries, hospitalizations, deaths, evacuations, or shelter-in-place, as listed in th
ARIP database.
3Since better information in not available, ENVIRON assumed that public impacts listed in the AMP database
generally occurred off-site.
Ms. Yesney -4- July 17,1996
specifically related to sporting goods manufacturing. Chemicals released include cyanide
compounds (e.g. sodium cyanide, nickel cyanide), nitric acid, chromic acid, hydrochloric acid,
sulfuric acid, ferric chloride, and boron trichloride.
No acutely hazardous materials were listed as stored by golf club manufacturing facilities in
Carlsbad. In addition, no accidental releases were reported in the ARIP database for sporting and
the Carlsbad Fire Department’s database for this industry type over the last five years. Finally,
no accidental releases from any possibly related SIC classifications resulted in public impacts.
Therefore, the risk of accidental releases actually resulting in public impacts that may be of
concern for the siting of a child care facility fiom this industry type are relatively low. However,
as several acutely hazardous materials may be used in metal processing and coating for this
industry, there is the potential of off-site impacts.
Semiconductor Fabrication
To determine the potential for accidental releases of hazardous chemicals by semiconductor
fabrication facilities, ENVIRON searched the ARIP database for releases from the SIC
classification for manufacturing of semiconductors and related devices, SIC code 3674. The SIC
category for Netal] coating, engraving, and allied services, SIC code 347, was also searched for
releases specifically related to the semiconductor industry. Nine releases were reported under
SIC code 3674, two having on-site impacts, and none having off-site impacts. The chemicals
with on-site impacts were nitric acid and chlorine. Other released chemicals included nitrogen
oxide, sulfuric acid, hydrofluoric acid, hydrogen fluoride, acetic acid, and phosphoric acid. Five
releases related to the semiconductor industry for the coating and engraving processing category
were reported, none with public impacts. However, one release resulted in on-site impacts. The
chemicals released were tetrachloroethylene and boron trichloride.
To supplement the accident reports fiom the ARIP database, ENVIRON reviewed release
histories from RMPPs for a few semiconductor facilities in Santa Clara county. Several releases
of sulfuric acid not recorded in the ARIP database were found during this review, with no off-site
impacts. Since no large semiconductor fabrication facilities are located in Carlsbad, no
discussion of accidental releases in Carlsbad for this industry is applicable here.
Although no off-site impacts were listed in the ARIP database and RMPP accident release
histories reviewed, due to the types of chemicals handled at these facilities and the on-site release
histories, companies in this industry group are at risk for havingaccidental releases that result in
off-site impacts.
athletic goods manufacturers and no non-fuel releases of hazardous chemicals were reported in
Electronics Plating/ Circuit Board and Computer Electronics Manufacturing
To determine the risks of accidental release from this industrial category, ENVIRON searched
the ARIP database for releases from several relevant SIC codes. The SIC categories searched
include the following: 1) printed circuit boards, 2) electronic capacitors, 3) electronic resistors,
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4) electronic coils, transformers, and other inductors, 5) electronic connectors, 6) electronic
components, 7) electronic equipment and supplies, 8) electronic computers, 9) computer storage
devices, 10) computer terminals, and 11) computer peripheral equipment. The SIC category foI
[Metal] coating, engraving, and allied services was also searched for releases specifically related
to the electronics plating industry. The SIC codes corresponding to these categories are 3672,
3675,3676,3677,3678,3679,3699,3571,3572,3575,3577, and 347, respectively. In an effor
to include all activity that may be related to the electronics plating/ circuit board and computer
electronics manufacturing industrial type, we included a broad range of activities in OUT search.
Many companies that are involved in these activities may not be related to circuit board and
computer electronics manufacturing. Therefore, a number of the reported releases may not be
related to this industry type. Approximately 20 accidental releases were reported in the
following categories: printed circuit boards, electronic connectors, electronic components,
electronic computers, computer storage devices, computer terminals, computer peripherals, and
metal coating. No off-site impacts were reported. Chemicals released include, hydrofluoric acic
sulfuric acid, nitric acid, sodium hydroxide, hydrogen chloride, chlorine, ammonia, halogenated
organics, organic solvents, hydrogen peroxide, and nitrogen dioxide.
To supplement the histories listed in the ARIP database, ENVIRON reviewed accident histories
from RMPP reports for Santa Clara County and reviewed hazardous materials lists for companie
in Carlsbad provided by the SDCDEH. Several releases of hydrogen chloride, nitric acid,
sulfuric acid, and acid waste were listed in the RMPPs, but no off-site impacts were found.
Although no off-site impacts were listed for any of the releases listed in this industry group, ther
were a number of accidental releases for companies in this industry group. Therefore, it appears
that this industry group has thepotential to cause off-site impacts from accidental releases.
Analytical InstrumentdMedical Apparatus
The ARIP database for the SIC code category for manufacturing instruments and related
products4, 38, reveals that approximately 30 accidental releases of hazardous chemicals have
been reported for companies of this industry type since 1986. One release of potassium cyanide
and cuprous cyanide resulted in a shelter-in-place notification; other releases did not result in ofl
site impacts. Other chemicals released included chlorine, hydrogen sulfide, sulk dioxide,
ethylene oxide, hydrogen peroxide, mercuric oxide, cadmium oxide, potassium cyanide,
halogenated organics (e.g. dichlorodifluoromethane, benzyl chloride), and nitric acid.
As no AHMs were listed by the one company in this industry for whom hazardous materials
information was provided by SDCDEH and no non-fuel releases for this industry type were
reported in Carlsbad, the risk of accidental releases of concern for the siting of a child care
4Results for the SIC code subcategories of search and navigation equipment and photographic equipment and
supplies were excluded from the analysis.
Ms. Yesney -6- July 17,1996
facility from companies in Carlsbad may not be large. However, based on the number of releases
reported by this industry in the ARIP database, the reported public impact, and the types of
chemicals handled by companies in this industry, this industry has the potential for releases with
impacts to off-site populations,
Plastics and PLastic Products Manufacturing
ENVIRON searched the following two SIC categories to determine the number and character of
accidental releases for this industry type: 1) rubber and plastic products and 2) plastic materials
and resins. The corresponding SIC codes are 30 and 2821, respectively. Approximately 240
releases were reported for the two SIC categories. No public impacts were reported for rubber
and plastic products manufacturing. However, for plastic materials and resins manufacturing,
seven releases resulted in public impacts, including evacuation of up to 300 members of the
public, injuries of up to 9 people, and hospitalization of up to 5 people. Chemicals whose
releases resulted in public impacts include phenol, formaldehyde, toluene, vinyl acetate,
polytetrafluoroethylene, ethane, ethylene, styrene monomer, methacrylic acid, and sodium
hydroxide. Other acutely hazardous materials released by companies in this industrial category
include toxic gases (e.g. carbon disulfide, chlorine, fluorine, hydrogen chloride, nitrogen dioxide,
ammonia, bromine), organic oxides (ethylene oxide, propylene oxide), hazardous liquids (e.g.
sulfuric acid, hydrogen peroxide, hydrogen fluoride), organic solvents, organic cyano compounds
(e.g. toluene diisocyanate (2,4) and (2,6)), arid halogenated organics (e.g. chloroform, trichloro
acetyl chloride). It is important to note that the companies that fall within the two SIC codes
listed above include all rubber and plastics processing facilities, including, for example, large tire
manufacturers. Therefore, the number of releases listed here may not be representative of
releases that would be expected from small plastics processors. No non-fuel releases were
reported for this industry type in Carlsbad.
Based on the significant number of accidental releases from this industry type and particularly
the number of releases with public impacts, the risks of accidental release for this industry, as a
whole, are quite high. However, companies who do not produce plastic materials, but only
process those materials to form plastic products, such Bs the companies located in Carlsbad, may
have decreased risks.
Chemicals Manufacturing
Based on analysis of search results from the ARIP database, this industrial category ha the
highest risk of accidental release and public impact of all the industry types selected in this study.
Due to the large number of search results, database searches were limited to the following
relevant SIC categories: 1) alkalies and chlorine, 2) industrial gases, 3) industrial inorganic.
chemicals, 4) industrial organic chemicals, and 5) chemical preparations. The SIC codes
corresponding to these categories are 2812,2813,2819,2869, and 2988, respectively. In these
search categories approximate 30 releases with public impacts were reported. Impacts included
up to 50 members of the public injured, up to 30 hospitalized, up to 3,700 evacuated, and up to
360 sheltered-in-place. The release of chlorine and hydrogen chloride gas resulted in the largest
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incidences of public impacts. Other chemicals whose releases resulted in public impacts include
sulfur dioxide, ammonia, phosphorous, xylene, 2-nitropropane, phosgene, hydrochloric acid, and
carbon tetrachloride. Again, it is important to note that facilities within these SIC codes include
very large chemical plants, as well as smaller manufacturing facilities, such as those found in
Carlsbad. The one non-fuel release reported in Carlsbad in the past five years was at a facility of
this industry type. However, there were no off-site impacts reported.
Based on the large number of accidental release incidents reported for this industry and the
magnitude of public impacts, the risks of future accidental releases with public impacts for this
industry, in general, is very high. Therefore, any proposal for the siting of a child care facility
near a company in this industry should be carefblly studied.
Conclusions
Based on review of the USEPA ARIP database, accidental release histories fiom the Carlsbad
Fire Department, RMPP reports, and hazardous materials reports provided by the SDCDEH, the
highest risk of accidental release resulting in public impact from an industry type selected for this
study is from chemical manufacturing. Risks are also associated with the plastics and plastic
products manufacturing, analytical instruments/ medical apparatus manufacturing, electronics
plating, semiconductor fabrication, and pharmaceutical/ biotechnology industries.
Comparatively lower risks are associated with golf club manufacturing.
Sincerely,
gd6Ph.D.
Principal /
Am ?!if& L. tuart
Associate, Air Sciences
References
Executive Office of the President. 1987. Standard Industrial Classification Manual. Office of
Management and Budget. National Technical Information Service. Springfield,
Virginia. PB 87-1 00012.
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July 16, 1996
Ms. Michelle Yesney
David J. Powers & Associates
San Jose, California 95126
1885 The Alameda, Suite 204
Re: Task 1G of the Carlsbad Child Care Study: Evaluation of Ambient Air Quality an
Impacts
Dear Ms. Yesney:
This letter is a report of ENVIRONS analysis and conclusions concerning task 1 G of the
Carlsbad Child Care Study: Evaluation of Ambient Air Quality and Impacts. The availability o
ambient air. quality data and discussion of the available data on the chemicals of concern for this
study are provided in this letter. Air quality standards-relevant to the study for identified G
chemicals are also iijted and discussed.
Sources of Ambient Air Quality Information
The California Air Pollution Control Districts monitor ambient air quality to determine
compliance with state and federal air pollution control guidelines. Data on criteria pollutants an
a variety of toxic pollutants is recorded at several monitoring stations throughout the state. In
San Diego County, air quality monitoring stations include Oceanside, Escondido, Del Mar, three
San Diego stations, Alpine, El Cajon, Chula Vista, and Otay Mesa: The closest station to
Carlsbad is Oceanside, which records data on criteria pollutants including nitrogen dioxide.
Toxic pollutant concentrations are only measured at El Cajon and Chula Vista in San Diego
County. Since no air quality data fiom Carlsbad is available, ENVIRON used air quality data
fiom Oceanside and Chula Vista to best represent concentrations in Carlsbad. Chula Vista was
chosen for toxics data because Carlsbad, Oceanside, and Chula Vista are near the coast, have
similar climates, and have similar air pollution influences. All three locations receive air
pollution born ocean breezes transporting air horn Las Angeles (SDCAPCD 1996)). El Cajon is
further inland and is impacted by air pollution transported fiom Sara Diego city.
Air quality information was obtained .from two sources. A description of the sources and
discussion of the data obtained for each are given here:
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Marketplace Tower 5820 Shellmound Street Suite 700 Erneryvillc. California 94608 USA Tel: (510) 655-7400 Fax: (5
Ms. Yesney -2- July 16, 1996
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0 Air Quality in San Diego County.’ 1994 Annual Report. The San Diego County Air
Pollution Control District produces a report each year containing information on the state
of air quality in San Diego County. This report contains average and maximum air
concentrations of criteria pollutants and the number of days state and federal standards for
those pollutants were exceeded. ENVIRON obtained air quality information on nitrogen
dioxide and sulfur dioxide as well as the ambient air quality standards from this report.
e The California Air Resources Board (CARB) air monitoring database. CARB provided
raw 1995 data on the 24-hour air concentrations of several toxic air contaminants at
monitoring stations around the state. ENVIRON analyzed the data at the Chula Vista
station to determine the maximum and average 24-hour concentrations. For days with
reported non-detected concentrations, ENVIRON assumed the concentrations were one
half the detection limit.
Ambient Air Quality Data on Identified Hazardous Materials
Based on the above sources, ENVIRON obtained information on background concentrations of
several of the chemicals discussed in this study, identified in previous letter reports. Available
air quality data for several identified hazardous materials are listed in Table 1. Note that air
quality dau is not available for all chemicals discussed in the study.
Table 1
Ambient Concentrations of Several Hazardous Chemicals
Chemical Name Location of Maximum Maximum Annual
Average Monitor 24-Hour I-Hour
Concentration Concentration Concentration
Formaldehyde
Chula Vista 5.6 ppb NA 1.6 ppb Toluene
Chula Vista 0.13 ppb NA 0.06 ppb Trichloroethylene
Chula Vista 0.2 ppb NA 0.06 ppb Styrene
Chula Vi. 3.9 ppb NA I .9 ppb
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These concentrations are several orders of magnitude lower than the levels of concern for short
term exposures discussed in the letter report for task 1 E. Therefore, background concentrations
of potentially emitted hazardous materials do not likely significantly add to the hazards of an
accidental release. However, since no air quality information is available specifically for
Carlsbad, and as information on a limited number of chemicals is available, this conclusion may
not be entirely valid. Also, no synergistic effects of elevated concentrations of multiple
pollutants have not been considered here. For pollutants that act as respiratory irritants, this may
be a significant issue.
Ambient Air Quality Standards
The Clean Air Act, last amended in 1990, required the promulgation of health based primary and
secondary national ambient air quality standards (NAAQS) for several criteria pollutants. In
response to this mandate, the U.S. Environmental Protection Agency (USEPA) established
standards for six pollutants: sulfur dioxide, particulate matter, nitrogen dioxide, carbon
monoxide, ozone, and lead. The State of California also established standards for these and a
few other pollutants. In most cases the California Ambient Air Quality Standards (CAAQS) are
more stringent than the national standards. Additional pollutants with California state standards
include sulfates, hydrogen sulfide, and vinyl chloride. Of the pollutants with federal or state
standards, riitrogen dioxide, sulfur dioxide, hydrogen sulfide, and vinyl chloride are the
chemicals of concern in the event of an accidental release fiom at least one industry selected for
the Carlsbad Child Care Study. Table 2 lists the federal and state ambient are quality standards
for these chemicals. No ambient air quality standards have been established by either the
USEPA or the State of California for the other chemicals identified in this study.
Table 2
National and State Ambient Air Quality Standards for Chemicals of Concern
I.
Standard
Federal Standards
Vinyl Chloride Hydrogen Sulfide Sulfur Dioxide Nitrogen Dioxide
- " 30 PPb 53 PPb Annual Average
24-Hour " 140 ppb " - 11 1-Hour I e I I I - I " I
State Stadrds
24-Hour
I 30 PPb 250 ppb 250 ppb 1 -Hour
10 PPb - 40 PPb -
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According to the San Diego County Annual Air Quality Report there were no exceedances of the
state or federal air quality standards at the San Diego County monitors for nitrogen dioxide and
sulfur dioxide. San Diego County does not perform monitoring for hydrogen sulfide and vinyl
chloride.
The federal and state Ambient Air Quality Standards were not established based on studies of the
impacts of chemicals in the air performed specifically on children. However, the ambient air
quality standards were established to be protective of sensitive populations (such as the elderly,
infants and young children, and people with respiratory ailments), and therefore, are likely
protective of children. The basis for each of these levels is provided in the following paragraphs.
. Nitrogen Dioxide
The CAAQS for nitrogen dioxide is based on evidence that this level is adequate to protect both
normal and sensitive groups against.lower airway effects. It is also designed to prevent
atmospheric discoloration (CaUEPA 1995). Although increased airway reactivity has been
observed in some studies of asthmatics following exposure to nitrogen dioxide concentrations of
0.25 ppm or lower (Kleinman et al, 1983; Jorres et al., 1990; Orehek et al., 1976), no clear dose-
response relationship has been established for effects observed at or below the CAAQS; and the
studies of asthmatics exposed to higher concentrations (up to 4 ppm) fail to show effects on
airway reactivity (Hackney et al., 1992: Linn et al., 1985). Therefore, the CAAQS appears to be
adequately protective against the lower airway effects of nitrogen dioxide (CalfEPA 1995), even
for sensitive subpopulations (including children).
Sulfur Dioxide
The CAAQS for sulfur dioxide aims to protect sensitive individuals (i.e., exercising asthmatics)
fiom lower respiratory effects fiom acute exposure. Based on a thorough review of the literature,
the Office of Environmental Health Hazard Assessment staff concluded that an exposure
concentration of 0.25 ppm of sulfur dioxide for 1 hour is comparable to a no observable adverse
effect level in sensitive individuals. This level is believed to protect asthmatic individuals
because adverse effects are consistently observed only at higher concentrations under conditions
of moderate exercise and there is an inconsistency in response to sulfur dioxide exposure at lower
concentrations (CaYEPA 1995). It is likely that asthmatics represent the most sensitive
subpopulation for sulfur dioxide exposure. The CAAQS is therefore likely to be protective of
children.
Vinyl Chloride
As no information was found on the basis of the CAAQS for vinyl chloride, the standard is
compared here to the 1 hour Reference Exposure Level @EL) established by California’s Office
of Health Hazard Administration. From a study of adult volunteers, the REL of 82,000 ppb was
calculated to protect against central nervous system effects (Lester et al., 1963). Since the
CAAQS is lower than the REL divided by an uncertainty factor of 100 (a typical value for an
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uncertainty factor used to account for serktive subpopulations), the CAAQS is likely protectiw
of children. As discussed above, no NAAQS is established for vinyl chloride.
Hydrogen Suifide
The CAAQS for hydrogen sulfide is based on an olfactory perception study by the California
State Department of Health (1969). The mean odor threshold (0.03 ppm) from this study was
selected as the CAAQS for hydrogen sulfide. This level was also reviewed by the California Ai
Resources Board and was found to be adequate for the protection of public health, including
protection against odor annoyance (CAB 1984). As discussed above, no NAAQS is establishel
for hydrogen sulfide.
Closing
Based on available air quality infomation, background concentrations of hazardous materials
potentially emitted fiom industry types studied here do not likely significantly add to the hazard!
of an accidental release. However, please note that no information on background concentration
is available for many of the chemicals identified in previous letter reports and no Carlsbad
specific air quality information is available. Also, a review of the ambient air quality standards
indicates the standard are likely protective of sensitive populations such as children.
Sincerely, &a eth Libicki, PbD.
Principal &a Amy L. s
Associate, Air_ Sciences
References
California Air Resources Board. 1984. Report of the Committee Regarding the Review of the
AAQS for Hydrogen Sulfide. Memorandum from CARB to G. DufQ.
California Environmental Protection Agency (CaVEPA)- Office of Environmental Health Hazan
Assessment. 1995. Technical Support Document for The Determination of Acute
Toxicity Exposure Levels for Airborne Toxicants. 3an~my.
Ms. Yesney -6- July 16,1996
California State Department of Health. 1969. Recommended Ambient Air Quality Standards.
Pp. HS-3.
Hackney et al. 1978. Experimental Studies on Human Health Eflects of Air Pollutants. VI.
Short-term Physiological and Clinical Effects of Nitrogen Dioxide Exposure. Arch. Env.
Health 33:176-181.
Jones et al. 1990. Airways Response of Asthmatics aJier a 30 Minute Exposure, At Resting
Ventilation, to 0.25ppm NO, or 0.5ppm SO,. Am. Rev. Resp. Dis. 142:758-762.
Kleinman et al. 1983. Eflects of 0.2ppm Nitrogen Dioxide on Pulmonary Function and
Response to Bronchoprovocation in Asthmatics. J. Toxicol. Env. Health 12:8 15-826.
Lester et ai. 1963. Eflects of SingIe.and Repeated Exposures of Humans and Rats to Vinyl
Chloride. Am. Ind. Hyg. Assoc. J. 3:265-275.
Lh et d. 1985. Efects of Exposure to 4ppm Nitrogen Dioxide in Health and Asthmatic
Volunteers. Arch. Env. Health 40(4):234-239.
Orehek et ai. 1976, Eflect of Short-term, Low Level Nitrogen Dioxide with Respiratory
Symptoms and Pulmonary Function in Children. Am. J. Epidemiol. 132:204-2 19.
San Diego County Air Pollution Control District (SDCAPCD). 1996. Smog and
Climate Zones in the San Diego Region. Letter from Cinthya Martinez to A. Stuart. April
22.
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Ms. Michelle Yesney
David J. Powers & Associates
1885 The Alameda, Suite 204
San Jose, California 95 126
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Re: Task 1H of the Carlsbad Child Care Study: Evacuation and Protection
Dear Ms. Yesney:
This is the first of several letter reports detailing the analysis and conclusions of ENVIRON’s
work for the Carlsbad Child Care Study. This letter report details our conclusions concerning
Task 1H: Evacuation and Protection, of the Phase 1 Revised Scope. Analysis of available
emergencgresponse plans and discussion of issues related to potential measures for reducing
exposures to children .- in the event of an emergency release are provided in this letter.
Emergency Response Plans
. ... -. .
The California Health and Safety Code requires that all facilities which handle hazardous
materials in amounts above certain general threshold qumtities prepare a Business Plan that
includes an Emergency Response Plan (ERP). Detailed Ems are also included in Risk
Management and Prevention Plans (RMPPs) which are required of companies who handle
acutely hazardous materials in amounts above chemical specific threshold quantities.’ To
evaluate the emergency response programs with respect to the consideration of evacuation and
protection procedures for sensitive populations, ENVIRON reviewed several ERP sections of
available Business - Plans and RMPPs. This section discusses this review and its implications.
Since the ERP portions of facility Business Plans are not available for public review, ENVIRON
reviewed a few ERP sections provided by the Fire Department which had been “sanitized” of
company-specific references. These ERPs generally contained procedures for mitigating a
hazardous materials release, such as how fires and spills will be handled, procedures for .
notification and evacuation of personnel, including a site map with evacuation routes, and
I ‘See the letter report on Tasks 1C and ID for a detailed discussion ofthe RMPP program.
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h~dAPBl~lLrnrclCnup.Inr
Marketplace Tower 5820 Shellmound Street Suite 700 Emeryville, California 94608 USA Tel: (510) 655-7400 Fax: (5
Ms. Yesney -2- July 17,1996
procedures for immediate notification of emergency response personnel such are the fire
Department and Hazardous Materials Management Division (HMMD) of the San Diego County
Department of Environmental Health (SDCDEH). Employee hazardous materials training
procedures and emergency personnel are also identified. None of the ERPs reviewed contained
information on off-site populations and evacuation or protection of off-site populations in the
event of an emergency release.
Since no Carlsbad companies currently have RMPPs available for public review, RMPP ERPs
for several facilities of the industry types represented in Carlsbad were reviewed. The RMPP
ERPs contained information similar to that provided in the ERPs created as part of the Business
Plan, but were generally much more detailed. Sensitive populations within a mile of the facility
were also identified, and the potential air concentrations in the event of an emergency release at
these sites were often provided in the off-site consequence analysis. Prodsions in the ERP for
notification and community responses such as evacuation and sheltering were generally included.
However, these provisions were generally not detailed, only identifying the emergency
responder(s) responsible for public notification and response decisions. Mechanisms for public
disco.urse about potential releases were also included in one ERP.
The Business Plan and RMPP ERPs reviewed in this evaluation did not provide specific
idormation on evacuation and protection procedures for off-site populations including sensitive
populations. The Business Plan ERPs provide no discussion of off-site population responses.
Although the RMPP ERPs identify sensitive populations and potential impacts to those
populations, detailed procedures for evacuation and sheltering exposure mitigation procedures
were not provided in the RMPPs reviewed. However, California Health and Safety Code2
requires the immediate notification of a school within one half mile of a release or threatened
release.
Issues Related to Potential Measures for Reducing Exposures to Children
Two measures that are often used to decrease the incidence of adverse health effects for
potentially exposed populations in the event of an emergency release of a toxic chemical are
evacuation and sheltering. Evacuation is the removal of potentially exposed populations from
the impacted area and sheltering is the protection of potentially exposed populations by keeping
them indoors for the duration of high outdoor concentrations. Although each of these options
may be effective in certain release situations, each may be more or less appropriate depending on
the properties of the chemical released, circumstances of the release, potential outdoor
concentrations, and characteristics of the potentially exposed populations. Several issues relating
to the evaluation of these exposure mitigating options for a child care facility are discussed in
this letter.
2Chapter 6.95. Article 1,25507,lO.
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Evacuation
Evacuation of potentially exposed populations has the longest history of use for reducing public
health effects due to emergency releases of toxic chemicals. The major drawback of the use of
evacuation as a response option is the time necessary for its implementation. Evacuation can
eliminate potential health effects if public notification and evacuation can be performed in the
time necessary for the emitted contaminant to travel fiom the accidental release source to the off
site population. However, if evacuation requires a longer time, it is not as effective but may still
reduce health effects by reducing the exposure duration.
Pollutant travel times can vary significantly depending of the characteristics of the chemical and
the plume, such as the plume release height, density, and reactivity. Meteorological conditions 5
the time of the release, including the wind speed, temperature, atmospheric stability, and
precipitation conditions also affect plume travel times. As an example, a computer modeling
study for the city of Mountain View, in Santa Clara County, indicated that a plume of chlorine
gas accidentally released would reach a child care center 1,000 feet from the source in 20
minutes if the wind speed were 3 miles per hour (mph). At a wind speed at 10 mph, the plume
was modeled to reach the center in 6 minutes (CMV 1995). Wind speeds around Carlsbad
average approximately 9 mph3 (NOM 1994), so the time available to respond to an emergency
release couid be very short.
In contrast, the minimum warning dissemination times to warn 25% to 90% of a population in
the event of a release are estimated to be 2 and 10 minutes, respectively. Evacuation times are
estimated to be up to 45 minutes for 90% of an alerted population (Noll, et.aZ. 1995). For a chilc
care facility, evacuation is an increasingly problematic first response option. Since children maJ
not understand evacuation alarms, are less responsive than adults, and cannot respond without
assistance, the time period needed for evacuation is increased, increasing the exposure duration
and the potential for health impacts.
Shelter-in-Place
Due to the prablems with evacuation, in-place sheltering has received increasing attention as an
accidental release response option. Sheltering of potentially exposed populations in indoor area
can reduce exposures and therefore, health impacts of toxic chemical releases. This is because air concentrations of pollutants indoors can be significantly reduced fiom those outdoors and the
time needed to implement sheltering is generally less than that of evacuation. Several studies
have been performed to measure or estimate the indoor/outdoor concentration ratios (the ..
concentration indoors due to outdoor sources divided by the outdoor concentration) for
particulate matter and gases for several types of buildings and air flow systems (Hayes 199 1 and
3Wind speeds for Long Beach and San Diego (city center) were used as representative of the Carlsbad area.
Ms. Yesney -4- July 17,1996
1995, Wallace 1996, Wilson 1995). Studies indicate that the indoor/outdoor ratio is highest for
well ventilated buildings with make-up air consisting of all outdoor air, is slightly lower for
buildings with open windows, and is very small for buildings with high-efficiency air filtration
systems. For example, Hayes (1 991) estimates that the indoor concentration of ozone can range
from as high as 82% of the outdoor concentration for well ventilated offices with 100% outdoor
make-up air, to 65% for homes with windows open, to 3% for offices with high-efficiency
heating, ventilation, and air conditioning (HVAC) air filtration systems. However, the decrease
in indoor concentrations can vary depending of the characteristics of the chemical under
these studies, the effectiveness of buildings in reducing air concentrations of released toxic
chemicals also depends on the building and air flow system characteristics.
The effectiveness of a building in reducing air concentrations can also decrease with the duration
of the release. Wilson (1 995) estimates that for a home with an infiltration rate of 0.5 air changes
per hour, the maximum indoor concentration of a toxic gas would be 2% of the initial outdoor
concentration for a release lasting 7.2 minutes. For a release lasting 12 hours, he estimates the
maximum indoor concentrations would be 50%. Therefore, shelter in place mitigating options
are better suited for short term releases and those where the likelihood of fue or explosion are
minimal.
Sheltering mitigation measures can consist of as little as a notification system alerting potentially
exposed populations to stay inside with the windows closed for the duration of the incident, to as
great as the implementation of special responses and shelter room features, Responses often
include taping around doors, windows, and vents to prevent air leakage and sheltering in a room
furthest from the source of the release. Specifically designed shelter room features may
significantly reduce indoor air concentrations for some release incidents. Room features can
include a separate air supply system designed to keep the room under positive pressure, a
scrubber and filtration system at the air intake, seals and weather stripping, emergency supplies
including food and water, and access to an outside doors in case evacuation becomes necessary
(CMV 1995, Sorenson 1995). However, these features cannot eliminate exposures to all released
gases, particularly since scrubber and filtration systems are necessarily designed for specific
chemicals and-cannot protect against all chemicals. Therefore, the use of specially designed
shelter rooms is likely a better alternative for on-site sheltering at a facility with a limited number
of known specific hazardous chemicals that may be accidentally released. It is not likely a good
option for responding to accidental releases of unspecified chemicals f'rom a variety of industry
types.
Conclusions
Selection of an appropriate exposure mitigation measure for children must account for the
characteristics of the children and the effectiveness of each measure in reducing exposure and
therefore, health impacts. Evacuation has the potential to eliminate health effects, but its
consideration, such as its density, particle size range, and reactivity with surfaces. Based on
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effectiveness is highly dependent on the pollutant travel time and population response time.
Alternatively implementation of sheltering exposure mitigating measures does not require the
same level of organization and time necessary for evacuation during a release event, but may no1
be effective for many accidental releases.
Due to the special characteristics of children, sheltering may be more appropriate then evacuatio
as a first response option for the releases of hazardous materials which are quickly contained anc
have lower toxicities. However, neither option is entirely viable for all release situations and
potentially released chemicals used by a variety of industries. The effectiveness of both options
is dependent on the hazardous material's characteristics, the response coordination, the
characteristics of the release, the meteorological conditions, and the building characteristics.
Therefore, in-depth studies of the characteristics of potential releases effecting a specific
proposed child care facility location are necessary to determine the most appropriate response
options for different release scenarios.
We hope the discussion presented here will provide the information necessary for your analysis
of evacuation and protection options for the Carlsbad child care study. We look forward to
working with you through the completion of the remaining study tasks.
Sincerely, . &i& Be Liblcki
Principal,
&- Associate, Air Sciences
A
References
City of Mountain View (CMV). 1995. Consideration of General Plan and Zoning Amendmenh
for Child Care Facilities and Location of Sensitive Uses and ExtrerneIyHazardous .
Materials. Council Report. March 28.
Hayes, S.R. 199 1. Use or an Indoor Air Quality Model (UQW to Estimate Indoor Ozone Level!
J. Air Waste Manage. Assoc. Volume 41. No. 2. pp. 16 1-1 70. February.
Ms. Yesney -6- July 17,1996
Hayes, S.R. 1995. Towards Greater Realism in Air Toxics Exposure Assessment. Air & Waste
Management Association. For Presentation at the 88th Annual Meeting & Exhibition.
San Antonio, Texas. 95-WP84B.02. June.
National Institute for Chemical Studies (NICS). 1995. Protecting the Public: A Conference on
Protective Actions During Chemical Emergencies. Conference proceedings. Charleston,
West Virginia. September 20 - 21.
National Oceanic and Atmospheric Administration (NOM). 1994. Annual CZimate Summaries.
World Wide Web: www.wrc.noaa.gov/oxnard/climate.
Noll, G.G. Hildebrand, MS. and Yvorra, J.G. 1995. "Site Management and Control." Chapter
5 of Hazardous Materials Managing the Incident. Fire Protection Publications.
Oklahoma State University. Stillwater, Oklahoma. ISBN 0-87939-1 1 1-1.
Sorenson, J.H. 1995. Protective Action Decision Making. Presented at NICS conference
"Protecting the Public: A Conference on Protective Actions During Chemical
Emergencies." September 20 - 2 1.
Wallace, L.' 1996. Indoor Particles: A Review. J. Air & Waste Management Assoc. Volume
46. pp. 98 - 126. February.
Wilson, D.J. 1995. Stay Indoors or Evacuate to Avoid Exposure to Toxic Gas? Reprint of
Emergency Preparedness Digest article for the WCS conference. "Protecting the Public:
A Conference on Protective Actions During Chemical Emergencies." September 20 - 21.
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Ms, Michelle Yesney I David J. Powers & Associates
1885 The Alameda, Suite 204
San Jose, California 95 126 I
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Re: Task 2 of the Carlsbad Child Care Study: Evaluation of Potential Hazards Within
Commercial Zones
Dear Ms. Yesney: 1 This letter report details our conclusions concerning Task 2 of the Carlsbad Child Care Study.
Potential hazards to child care facilities within commercial zones of the city, including hazards
fiom commercial activities and transportation accidents, are discussed in this letter.
I Sources of Informiiiion r *. I ENVIRON reviewed the following sources for information related to this task:
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Guidelines for Chemical Transportation Risk Analysis. (CCPS 1995). ENVIRON
reviewed highway accidental statistics compiled in this reference fiom a variety of
sources, ;nclud;ng Caltrans and the Federal Highway Administration.
Biennial Report on Hazardous Materials Transportation Calendar Years 1992-1 993.
(USDOT 1994). ENVIRON reviewed the transportation incident statistics fiom the US.
Department of Transportation's most recent biennial report.
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0 The US. Environmental Protection Agency's (USEPA'S) Accidental Release Information
Program (ARIP). The ARIP database is provided by the Right-To-Know Network and
stores information on accidental chemical releases reported fiom 1986 to 1994.
ENVIRON searched the database by Standard Industrial Classification (SIC) codes for
accidental release reports for trucking, including SIC codes 4212,421 3 and 4214. The
SIC system classifies all industrial activity into SIC categories (e.g. manufacturing of
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Ms. Yesney -2- July 16, 1996
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plastic materials and resins). Note that this database only provides information on
reported releases. It is not an inclusive list of all releases that have occurred.
e The Carlsbad Fire Department's Accidental Release Database. ENVIRON reviewed
information provided by the Carlsbad Fire Department concerning accidental releases
occurring in Carlsbad over the past 5 years.
e Business Classification Listing of the Carlsbad Chamber of Commerce. ENVIRON
e Carlsbad General Plan Land Use Map. ENVIRON reviewed the map of land use and
reviewed this listing to identify activities occurring in commercial areas of the city.
zoning for Carlsbad to determine the location of transportation arteries with respect to
commercial and industrial zones.
For the purposes of this analysis, ENVIRON reviewed the above sources for trends and general
information. Detailed analysis of more specific data was outside the scope of this analysis.
Activities in Commercial Zones
Based on a review of the Business Classification Listing of the Carlsbad Chamber of Commerce,
ENVIRON identified commercial activities in Carlsbad which may handle hazardous materials.
These activities include auto servicing, photography laboratories, printers, publishers, and
swimming pool and spa services. Photography labs, publishers, and printers may handle organic
solvents, inks, and alkaline and acidic liquids. Swimming pool and spa servicing companies may
handle chlorine gas. Finally, auto service stations handle organic compounds and liquid and
gaseous petroleum products in large amounts. Therefore, there is the potential for non-
transportation related releases of hazardous materials from commercial activities, particularly
from auto servicing and swimming pool and spa servicing activities.
Potential Hazardous of Transportation Accidents
To reach the industrial manufacturer, hazardous materials are transported over freeways and
other transportation arteries. This transport can lead to releases of hazardous materials in areas
other than in industrial parks. Transportation related releases of hazardous materials can occur
due to several failure.modes including collisions, vehicle over-turnings, railroad grade crossings,
and equipment failure (CCPS 1995). Studies indicate accident rates for trucks on urban .
highways and roadways range from 0.49 per million vehicle miles traveled to 13.92.
In California, 2,130 hazardous materials transportation incidents were reported during 1992 and
1993 for all modes of transportation (e.g. rail, highway, water) (USDOT 1994). Approximately
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80 percent of the incidents and all resulting fatalities and were highway related'. The four
hazardous material classes with the highest number of incidents were flammable/combustible
liquids, corrosive materials, combustible liquids, and poisonous materials. The four classes
resulting in the highest percentage of injuries were corrosive materials, flammable/combustible
liquids, poisonous gases, and poisonous materials. Many specific materials were involved in
incidents. A few of the top fi* materials with reported incidents which have been identified in
previous letter reports include sulfuric acid, hydrochloric acid, sodium hydroxide, toluene,
ammonia solutions, ammonia gas, and tetrachloroethylene.
Based on the Carlsbad Fire Department's records, approximately 25 hazardous materials release!
that may have occurred on public roadways or due to transportation incidents were reported to
the fire department over the past five years. Hazardous materials involved include gaseous and
liquid fuels and hydrochloric acid. In contrast, total incidents in the Carlsbad industrial areas,
both related and unrelated to transportation, totaled only nine in the past five years.
Since national and Carlsbad specific transportation statistics indicate a large number of incident:
involving hazardous chemicals occur during transport of those chemicals, risks from releases of
chemicals along transportation arteries should be considered. Based on the Carlsbad General
Plan Land Use Map, the major transportation arteries in Carlsbad which access industrial areas
include Interstate 5, El Camino Real, Palomar Airport Road, and College Boulevard. Since all c
these arteries pass through commercial and residential areas of Carlsbad and data from a few
studies on truck accident rates indicate that freeway and non-freeway routes have similar
accident rates (CCPS 1995), there is likely similar potential for accidental releases of hazardous
materials from transportation accidents in commercial areas of Carlsbad. In fact, since there is
likely far more movement of hazardous materials along Interstate 5 then along the roads that run
through the Carlsbad industrial zones, the risks due to transportation accidents in the comercia
zones adjacent to Interstate 5 may be higher than in the industrial zone.
Closing
Based on the business activities review and transportation accident data, there is the potential fol
the release of hazardous materials in Carlsbad commercial areas. Of particular concern are
transportation related incidents, as large quantities of hazardous materials may pass through
commercial areas.
'As no mode specific statistics were available by state, these percentages are based on U.S-wide statistics.
Ms. Yesney -4-
Sincerely,
&?fz2&* hari Beth Libicki, Ph.D.
Principal Am L.
Associate, Air Sciences
July 16,1996
References
Center for Chemical Process Safety (CCPS). 1995. Guidelines for Chemical Transportation
Risk Analysis. American Institute of Chemical Engineers. New York.
USDOT. 1994. BienniaI Report on Hazardous MateriaIs Transportation CaIendar Years
1992 - 1993. Research and Special Programs Administration. Report to Congress.
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€NVIR"ON
July 19,1996
Ms. Michelle Yemey
David J, Powers l!z Assockes
1885 The Alameda, Suite 204
San Jose, California 95 I26
Re: Response to Comments from the Cie of Carisbad
Dear Ms. Yaey:
The purpose of this letter is to respond the questions and comments by the City of Carlsbad .
concerning the Draft Study Report on "Child Care Facilities in Industrial Areas''. As we
discussed in our phone conversation of July 11,1996 we have prepared a cornparitive ranking of
the risks of industries in Carlsbad and a comparison of the risks of commercial and industrial areas. This lener should be used as a supplement to the original letter reports on Tasks I A-H
and 2.
Comparative Risk Ranking of Industry Typcs
The risks of accidental releases with off-site impacts can vary widciy bctween hilities in a
given industry as well as between industries. The comparative risk of a facility depends strongly
on the types and amounts of chelnicaIs used, the safety practices of the facility, and the
regulatory requirements of the area in which the facility. is located. Therefore, it is very difficult
to d industry types by level of risk. Baed on the types and amounts of chemicals used by
faciIities in each industry type in Carlsbad, available predicted off-site impact distances listed in
available RMPPs, RMPP availability, and the number and type of accidentai releases reported to
the Carisbad Fire Department and to the AMP database, ENVIRON gave each industry type in
this study a comparative risk ranking of 0,1, and 2. 0 represents the lowest risk and 2 represents
the highest-risk. Note that a comparative ranking does not imply danger, this is only a ranking of
one industry relative to the other industries listed. This does not imply that the industriis in
Carlsbad represent great or unacceptable risk. The comparative ranking of industries in Carisbad is provided in thc following table. -
I .. ... ... . -_ . ... -. -. . . 4.Lj4.VUI...mdhlN"<-h~ ...
Mnrkcrplnc.t'I'avc~, 58x0 Sltellmuund Strccr - Stlilc 700 Entrryvillc. Cjlihrnia 74BOX USA '1.~1: (510) 655-7400 ' Fax: (570) 655
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Industry Rankmg e
Chemicals Manufhxing 2
Pharmaceuticals/ Riatechnology 1
Electronics Plating/ Circuit Board and Computer I
Electronics Manufacturing
Semiconductor Fabrication 1
rhis ranking system is the best attcmpt to qualitatively compare the risks of facilities currently,
located in Carlsbad or likely to locate in Carlsbad. It is specific to .this study and does not
necessarily apply to kilities not currently located in Carkbad. Again, the risks of an accidental
rdme from a facility are dependent on many factom that are not necessary defined by the industrytype. t
Comparison of the Risks in Commercial Versus Industrial Areas
The use of toxic chemicals and the risks of accidental releases are not confined KO industrial
mas. As specified in thc letter repa on Task 2, commercial fwilities use! or store toxic
chemicals. Although the amount of chemicals hded by commercial facilities is generally
smaller than that handled by induskid facilities, some corn&$ users, specifically swie
pools and auto servicing centers, may use signifcant amounts of hazardous chcmicals such as
chlorine gas, Fiels, and soivents. In general, auto servicing centers are well controlled for the firc
hazards of stored fuels. However, there is thc potential for spills of large amounts of fuels during
truck unloading. Also, depending on the location of major transportation arteries, the risks iiom transportation related ~le~tses of hdous materials in commercial ams may be equal to or greater than those in industrial ai'leas. In Carlsbad, Interstate 5 runs through commercial areas,
increasing the potential of tfansporation related risks.
Typically the difference in risks between industrial and commercial arcas is based on the
difference in the amounts of chunicals used and stored by facilities in each area. Therefore, a
heavy industriaI area with large manufacNring fkilities may have much larger risks of accidental
releases with off-site impacts than a commercial area Lighter industria) arcas with a greatex
proportion of dl research and development facilities and pilot mirmrfacturing plants, such as
the Carlsbad industrial area, do not have the same risks as might be expected from heavy
industry. Therefore, the difference in risks of accidental releases in the Carisbad commercial and
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industrial areas may not be as great as the differences between a commercial area and a heavy
industrial iire8, particularly considering the location of Interstate 5. However, as discused in &e
first section of this letter, different types of industrial users in Carlsbad may have a hi&r risk of
accidental releases with off-site impacts.
we hope these COmeUb Clarify some Of the issues raised by the City of Catlsbad conekg the
Dd Study Report. Please let us know if you have and questions or comments concerning the
discussion here.
Sincerely,
L. &, e
S - Beth ibicki Ph,D.
Principal
&&-.
Associate, Air Sciences
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ENVIRON
July 19,1996
Ms.MicheIle Yesney
1885 The Alameda, Suite 204
San Jose, California 95 126
David J, Powers & Associates
Re: Response io Comments from the City'of Carisbad
Dear Ms. Yesney:
The purpose of this letter is to respond the questions and comments by the City of Carisbad
concerning the Draft Study Report on "Child Care Facilities in Industrial Areas". As we
discussed in our phone conversation of July 1 1,1996 we have prepared a comparitive ranking of
the risks of industries in Carlsbad and a comparison of the risks of commercial and industrial
areas. This lener should be used as a supplement to the original lener reports on Task 1 A-H
and 2.
Comparative Risk Ranking of Industry Types
The risks of accidental releases with off-site impacts canvary widcly bctween fkilities in a
given industry as well as between industries. The comparative risk of a facility depends strongly
on the types and amounts of chemic& used, the safety practices of the facility, and the
regulatory requirements of the area in which the facility. is located. Therefore, it is very difficult
to rank industry types by level of risk Bmed on the types and amounts of chemicals used by
faciIities in each industry type in Carlsbad, available predicted off-site impact distances listed in
available RMPPs, RMPP availability, and the number and type of accidental releases reported to
the Carlsbad Fire Department and to the AMP database, ENVIRON gave each industry type in
this study a comparative,risk ranking of 0,1, and 2. 0 represents the lowest risk and 2 represents
the highestrisk Note that a comparative ranking does not imply danger, this is only a ranking of
one industry relative to the otha industries listed. This does not imply that the industries in
Carlsbad represent great or unacceptable risk. The comparative ranking of industries in Carisbad
is provided in thc following table. - -
._. : ., - .. " ~. . . *&aUu,~"*-""k ... . .- -.
Markcrplnc- 'I'nwev 5820 Stwlinruund Strccr Suitu 7111) ~~~~~~vi]l~, (;librnia 34~b~ [rSA - *J'& (510) 655-7400 . r:xc (510) 65:
.. .. .
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~ ~-~~~
a I II ~~
ectronics Plating/ Circuit Board and Computer
-~~ ~
-~~~~~ ~ ~ " ~ ~~~~~~ ~ ~~ . .
This ranldng system is the best attempt to qualitatively compare the risks of facilities currently
located in Carlsbad or likely to locate in Carlsbad. It is specific to this study and does not
necessarily apply to fkcilities not currently located in Carkbad. Again, the risks of an accidental
release from a facility are dependent on many fmrs that are not necessary defined by the
;ndustrytype. b
Comparison of the Risks in Commercial Versus industrial Areas
The use of toxic chemicals and the risks of accidental releases are not confined to industrid rueas. As specified in thc letter report on Task 2, CoIUmercial fsilities use or store toxic
chemicals. Although the mount of chemicals handled by CoIMlercial facilities is generally
smaller than that handled by industrid facilities, some commcrciais usas, specifically swimming
pls and auto servicing centers, may use significant amounts of hazardous chcmids such as
chlorine gas, &Is, and solvents. In general. auto servicing centers are well controlled for the &E
hazards of stored fuels. However, there is thc potential for spills of large amounts of fuels during
truck unloading. Also, depending on the location of major transportation arteries, the risks fiom
transportation related releases of hazardous materials in commercial areag may be equal to or
greater than those in industrial areas. In Carlsbad. Interstate 5 runs through commercial ~IWS,
increasing the potential of tmnsporah'on related risks.
Typkdy the difference ;n risks between industrial and comme~~kd areas is based on the difference in the amoun~ of chemicals used and stored by facilities in each area. Thercforc, a
heavy industrial area with large manufacturing fkilities may have much larger risks of accidental
releases with off-site impacts than a commercial area. Lighter industrial arcas with a greater
proportion of dl research and development f;scilities and pilot manufacturing plants, such BS
the Carlsbad industriat area, do not have the same risks as might be expected fiom heavy
industry. Therefore, the difference in risfrs of accidental releases in the Carlsbad commercial and
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industrial areas may not be as great as the differences between B commercial area and a heavy
industrial area, particularly considering the location of 1nkrstat.e 5. However, as discussed in the
first section of this her, clifferaat types of industrial users in Carlsbad may have a higher risk of
accidental releases with off& impacts.
We hope these comments clarify some of the issues raised by the City of Carisbad concerning the
DroA Study Report. Pfease let 11s know if you have and questions or commurts concerning the
discussion here,
Sincerely,
&. - Beth ibicki, PkD. a
Principal
&&.
Akciate, Air Sciences
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I APPENDIX B
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CHILD CARE NEEDS UPDATE
GRUEN GRUENtASSOCIATES
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GRMN GRUEN + ASSMIATE!!
5360 Toscana Way G-211
San Diego, CA 921 22
Fax: (61 9) 453-5589
(61 9) 455-1450
MEMORANDUM
Date: April 11, 1995
To: Michelle Yesney
David Powers Associates
408/248-964 1
From: Tony Pauker
Subject: Carlsbad Child Care
cc: Paula Leard
Child Care Resource Service
FAX 6 19/47 1-2844
RECEIVED
APR 2 2 1936 mJm&AQ&E
INTRODUCTION AND PURPOSE
In order to help understand the demand for child care services and the potential demand for ch
care in industrial parks, we have conducted a brief review of the number of child care spac
compared to the population of the City of Carlsbad in 19!% and 1995. The purpose of this revit
is to quantify the potential need for placing child care facilities within industrial parks compar
to the likelihood that child care facilities will be located in the City proximate to industrial arc
without the need to change current City zoning.
Information for this research was obtained from:
“Carlsbad Child Care Needs Assessment and Recommendations Summary Report”
prepared by the International Child Care Resource Institute for the City of
Carlsbad, January 1991.
1990 U.S. Census data.
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I The Childwe Resource Service, a department of the YMCA of San Diego
County.
9 San Diego Association of Governments (SANDAG) Series 8 demographic data.
Childcare AvcrilabW in Carkbad
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BACKGROUND
In order to quantify the availability of child care spaces, the City of Carlsbad was divided into
four quadrants. Palomar Airport Road separates the north and south while El Camino separates
the east and west. (See attached map.)
The issue of allowing child care facilities to be located within industrial areas appears to be a
result of a request by Callaway Golf to locate a child care center within their manufacturing
facilities. Current zoning would not permit such a use within industrial zones, such as where
Callaway is located. However, child care is permitted on non-industrially zoned property such
land is available proximate to industrial areas and near the Callaway facility.
Comparison of the number of available child care spaces to population in 1990 and 1995 will help
to better understand the potential supply of child care near, but within, industrial parks in
Carlsbad. (Please note that we have not compared child care to employment because accurate
employment estimates are unavailable at the sub-County. level.)
AVAILABILITY OF 0 CARE
As shown on Table 1, the January 1991 "Carlsbad Child Care Needs Assessment and
Recommendations Summary Report" prepared by the International Child Care Resource Institute
for the City of Carlsbad indicated that there were a total of 997 licensed and 350 unlicensed'
(recreational) child care space in Carlsbad in 1990. Census data suggest that in 1990 there were
approximately 12,350 children in the City in 1990.' This suggest that there was an average of
0.08 licensed child care spaces per child in 1990 and 0.11 total child care spaces. In 1995 the
number of child care spaces increased significantly while the number of children aged 12 and
under did not increase as rapidly. SANDAG 1995 data suggests that in 1995 there were about
13,870 children aged 12 and under. Information provided by the YMCA's Child Care Resource
Service suggested that there were 1,294 licensed child care spaces and 992 unlicensed
(recreational) spaces. 'This infers a ratio of 0.09 licensed spaces per child in 1995, and 0.16 total
space^.^
1" Unlicensed" generally includes spaces provided in schools which are exempt from licensure.
'1990 Census identified popdation by age group, including ages 0-4 and 5-13. The number of children aged
12 and under was inferred from this data. Similarly SNAG 1995 population estimates included age groups 0-5,5-9
and 10-14.
3 NOTE: The number of child care space available in 1990 and 1995 was obtained from the "Carlsbad Child Care Needs Assessment and Recommendation Summary Report" and the YMCA's Childcare Resource Service,
respectively. Gruen Gruen + Associates has not independently verified these estimates.
@J GWEN GRUEN + ASSOCIATES
5360 Toswa Way. G-211
San Diego, CA 92122
Fax: (619) 453-5589 (6191 455-1450
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Childcore Availab~Uy in Carhbi
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GRUEN GRUEN + ASSOCIATES
Srr Diago. CA 921 22
5360 Toscana Way, G-211
(619) 455-1450 Fa: (6191 453-5589
Childcare Availability in Cartsbad
This suggests that during the 1990 to 1995 period there was a total increase of 939 child care spaces (297 licensed and 642 unlicensed). During the same period the population of children aged
12 and under increased by only 1,518. This summary appears to suggest that the availability of
child care in Carlsbad increased significantly during this time period. However, because accurate
employment data is unavailable at the subcounty level it is impossible to quantify the change in
employment that occurred in the City during the same time period. A substantial increase in
employment in the City could affect the demand for child care, especially in industrial parks.
Also, as shown on Table 1, the availability of child care increased in all quadrants of the City;
however, this summary does not provide any indication of if actual demand changed. There will
likely continue to be demand for child care in, not proximate to, work centers in the City.
COMPARISON TO NEEDS ASSESSMENT
The January 1991 “Carlsbad Child Care Needs Assessment and Recommendations Summary
Report” prepared by the International Child Care Resource Institute for the City of Carlsbad stated
that by 1995 there would be demand for an additional 400 licensed child care spaces in Carlsbad.
This study did not address the need for unlicensed (recreational) spaces.
As shown on Table 2, Gruen Gruen + Associates review suggests that since the 1991 study, 297
licensed child care space have been added to the supply in Carlsbad. In other words, there exists
a deficit of 103 spaces over what was estimated by ICRI. However, this data suggests a surplus
of 95 childcare spaces in the northwest and a deficit of 206 spaces in the southeast. Also, this
does not consider the addition of unlicensed spaces. Between 1991 and 1995 there has been an
increase from 350 to 992 unlicensed space; an increase of 642 spaces.
However, the reader is cautioned to consider two key factors when reviewing this information:
1. The 1991 study did not discuss estimated population increases in Carlsbad between
1991 and 1995. Therefore, it is impossible assess whether the increase in the
number of childwe spaces is commensurate with population growth.
2. While this data suggests that between 1991 and 1995 there was an increase of 939
child care spaces, the purpose of this review is not intended to insinuate whether
there exists unmet demand for childcare. Rather, the intent is only factually
document the change in the provision of child care. This review should not
construed as market assessment for the need for child care.
4% GRUEN GRUEN + ASSOCIATES
5360 Toscana Way. G-211
San Dmgo. CA 921 22
Fax: I61 91 453-5589
(619) 455-1450
Page 4
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ChiIdcare Av&@ in CarIsbad
TABLE 2
Comparison Of Estimated 1995 Needs to Available Child Care
Elgistins Licensed Child
care spaces
1990
Northwest 532
Northeast 99
Southeast 330
TOTAL 997
southwest 36
ICRI Estimated
Licensed Child
Need
1995
632
174
161
430
1,397
GG+A Estimated
Licensed Child
Care Space
1995
727
141
202
224
1,294
Surplus
or
(Deficit)
95
(33)
(206)
(103)
41
Source: Gruen Gruen + Associates.
ATTACIllMENTS
Carlsbad Map.
9 Child Care Resource Service Summary of Child Care in Carlsbad, by Quadrant,
April 8, 1996.
Population by Age in Carlsbad, 1990 and 1995.
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GRUEN GRUEN + ASSOCIATES
5360 Toscana Ww, G-211 San D+. CA 921 22 (619) 455-1450
Fa: I61 91 453-5589
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e Childcare Resource Service
3333 Camino del Ris South Suite 400 San Diego, CA 92\08-38;
Administration Referrals Fax
(619) 521-3055 1-800-48 1-2 15 I (619) 521-3050
April 15, 1996
TONY PAUKER
GRUEN GRUEN + ASSOCIATES
5360 Toscana Way G-211
San Diego, CA 92122
Dear Tony,
Enclosed is new information about child care in the city of
Carlsbad.
NORTHWEST QUADRANT: Licensed Family Child Care Homes
Child Care Centers 27 homes with 208 spaces (from birth to age 12)
8 centers with 7 infant spaces, 484 preschool spaces and
28 school age spaces
Head Start
1 full day program with 20 spaces and 1 half-day program with 68 spaces
Elementary Schools
4 schools have on site programs with 484 spaces
NORTHEAST QUADRANT:
Licensed Family Child Care Homes
Child Care Centers
Elementary Schools
21 homes with 141 spaces (from birth to age 12)
0
1 school has an on site program with 150 spaces
SOUTHWEST QUADRANT:
Licensed Family Child Care Homes
Child Care Centers
Elementary Schools
8 homes with 48 spaces (from birth to age 12)
2 centers with 16 infant spaces and 138 preschool spaces
1 school has an on site program with 150 spaces
SOUTHEAST QUADRANT:
Licensed Family Child Care Homes
Child Care Centers
Elementary Schools
33 homes with 224 spaces (from birth to age 12)
0
2 schools have on site programs with 120 spaces
This data information is from the CRS provider data base and the
from the faxed copy of April 8, 1996 due to an updated CRS list
and Community Care Licensing data. Enclosed please find an invoice for the research. Please let me know if there is anything else with which we can help you.
January 1996 Community Care Licensing list. These figures vary
Sincerely,
QJ& Pf %iw!l
Paula R. Leard North County Program Director
2-L ’ 0;
Nancy B. Mitchell
Resource and Referral Program Director
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APPENDIX C
CHILD CARE CENTER SITING ORDINANCES
CITY OF SAN DIEGO
CITY OF MOUNTAIN VIEW
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City of San Diego Buffer Requirement
E. CHILD CARE CENTERS
e. Buffer Requirement. No portion of a child care center may be located withi
thousand feet (1,OOO') of any known business that:
(1) Has or is required to have a health permit from the County of San
Hazardous Materials Management Division, excluding undergrounc
storage tanks, and handles acutely hazardous material above the Thn
Planning Quantities ("Pa) as defined by Division 20, Chapter 6.95, S8
25500 et. seq., of the California Health and Safety Code; or
(2) Handles compressed flammable gases in excess of one thousand five hu
(1,500) pounds; or
(3) Handles flammable liquids in excess of ten thousand (10,000) gallons.
The applicant is required to submit "Hazardous Material Substance Ap:
Form" executed by the County of San Diego Hazardous Ma
Management Division at the time of application.
Deviations from the hazardous materials separation requirements rn
permitted only upon issuance of a conditional use permit granted t
"Hearing Officer" in accordance with "Process Three," pursuant to Mur
Code Section lOl.O5lO(C)(l)(k). Issuance of a conditional use permit 1
based in part on a "Health Risk Assessment Study" to be submitted I
applicant.
I The buffer shall be measured from the adjacent property line of the pro
child care facility to the use, storage, or handling areas for the haza
material. Businesses may satisfy the above buffer requirements on-sit1
The applicant has the burden of proof in demonstrating compliance wi
buffer requirement. -
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AGENDA: March 28,1995
QTEGORY: Public Hearing
-~~ ~ ~
-1- DE",: Community Development
. ' TITLE Consideration of General Plan an
Amendments for Child Care Facij
the Location of Sensitive Uses an(
Extremely Hazardous Materials
RECOMMENDATION
1. Adopt a Negative Declaration of environmental significance.
2. Adopt A RESOLUTION APPROVING AN AMENDMENT TO THE GENERAL :
TEXT CONCERNING CHILD CARE FACILITIES.
3. Adopt RESOLUTIONS AMENDING THE SAN ANTONIO CENTER, SAN AN1
STATION, AND DOWNTOWN PRECISE PLANS, AND THE NORTH BAYSH(
PRECISE PLAN.
4. - Introduce AN ORDINANCE RELATING TO LAND USE REGULATIONS FOR (
CARE FACILITIES, to be read in title only, further reading waived, and set a secc
reading for April 11,1995.
FISCAL IMPACT
The Environmental Planning Commission is recommending a reduction in the appl
tion fees for child care centers and family child care homes. Use permit fees would bc
reduced from a range of $1,000 to $2,500 to a range of $50 to $150. Annually, the City
receives an average of one child care application, so the reduced fees would result in
maximum annual decrease of $2,350 to the General Fund. 1 BACKGROUND AND ANALYSIS
The Environmental Planning Commission has completed an extensive study of land 1 policies for family child care homes and child care centers, and the proximity of semi
uses and extremeIy hazardous materials. The purpose of the study is to promote chilc
in safe and appropriate locations. In particular, the Council asked the Commission tc I make final recommendations on an interim ordinance that prohibits child care cente industrial zones and is due to expire on May 12,1995. The Commission focused on z standards, while earlier the Child Care Committee made recommendations on impn 1 support for parents and child care providers. Themission is recommending the
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'AGENDA: March 28,1995
. PAGE 2
attached ordinance and resolutions that contain proposed General Plan, Precise F
Zoning Ordinance changes (refer to Attachment 5). If adopted, these changes wo:
Update the City's zoning standards on family child care;
Establish areas of the City where child care centers are encouraged; and
Prohibit child care centers in industrial zones and create safety buffers betwee
sensitive uses and extremely hazardous materials.
Before making their recommendations, the Planning Commission held Gumerou
meetings, including a Town Meeting on Child Care, workshops with the Child G
Committee and eight public hearings on possible land .use approaches.
On February 21, the City Council held a study session to discuss these zoning chaq
summary of questions and responses from the study session is given in Attache
March 28, the City Council will hold a public hearing on the Commission's recon
tions. Notice of the public hearing has been mailed to schools, child care operator
care facilities, major corporations, businesses within the 1,000' safety buffer, the Sa
Manufacturers Group, Mountain View Chamber of Commerce, the Child Care Cc
and many other interested individuals. An article about the child care study appe;
the March issue of The View.
Commission Findings and Recommendations
In making -their recommendations, the Commission tried to balance promoting d-
by eliminating zoning restrictions with retaining those zoning standards that ensx
compatibility with the district and surrounding residents. The land use standards
deviloped by the Commission are tailored to the unique circumstances in Mounti
View: the demand for child care, the types of housing, the location of districts and
transportation systems, and the types of industries.
SUDDIV and Demand
In gathering background for the child care study, the Commission found that the d
for additional child care services is primarily for after-school care at several elemen
schools and for specialized child care, like infant care. At the Town Meeting on Ch
with the supply of child care .in Mountain View.
Familv Child Care
they heard concerns about the quality and hours of child care services but few prob
The Commission found that family child care is appropriate in single-family neigh-
borhoods and is an important source of infant care. In multiple-family housing, lil
AGENDA: March 28,1995
PAGE 3
' ' apartments, family chI1.d care could have some negatlve effects on neighboring reside]
because of the shared walls, overhead units, Iimited parking and often minimal outdc
play areas. As a result, the Commission recommends allowing family child care as a
permitted use in single-family housing but establishing more stringent zoning regula.
in multiple-family housing, particularly for large family child care homes with 7 to
12 children.
Child Care Centers ..
One of the Commission's objectives was to encourage child care centers by zliminating
zoning application requirements wherever feasible. Child care centers located along
commute routes or near transit would be particularly beneficial because they would be
accessible to more families and help reduce traffic congestion. To promote child care il
these areas, the Commission recommends that child care centers be a permitted use in
C3 (Arterial Commercial) and PF (Public Facilities) Districts, in churches and in some a:
along San Antonio Road.
ChiId Care Centers in Industrial Zones
There were two hearings and extensive public testimony on the issue of child care in
industrial zones. In public testimony, companies opposed having child care in industr:
zones because of their potential liability, increased regulation and possible controversy
concluded that there are other districts available that are safer and more appropriate far
child care centers. They recommend that child care centers be prohibited in industrial
zones except on large sites serving employees of the company and located at least
1,000' from adjacent properties.
they introduced new hazardous materials near a child care center. The Commission .
Safe tv Buffer
In addition to addressing child care centers in industrial districts, the Commission
considered the potential impacts from extremely toxic materials to child care centers
located near industrial districts. Three schools and four child care centers are located ne:
to industrial zones that allow extremely hazardous materials. If there were an accident,
these extremely toxic materials pose a significant risk to sensitive groups, like children,
because they are physiologically more &herable and difficult to evacuate. The
Commission is recommending establishing a reciprocal 1,000' buffer zone between
sensitive uses and extremely hazardous materials because it reduces the risks by creating
more time for evacuation and lower concentrations of toxics. Several businesses would
become nonconforming, and the Commission is recommending that they be
grandfathered rather than amortized.
1. * AGENDA March 28,1995
' PAGE 4
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Issues and Options
Attachment 1 contains a table summarizing the major issues, the Commission's
recommendations and options that were considered by the Commission or preser
the Council. A memo prepared for the Council's earlier study session contains n
on the Commission's recommendations and 'the reasons behind their decisions (1
Attachment 3). The Council has also received a background binder containing PI
Commission reports and more analysis on most of the Qptiom fresentgd in he t<
Council may want more information on some of these options and can decide to
this issue to a study session and/or another public hearing (as presented-in the a1
section, No. 4). Several companies (that would become nonconforming if the 1,01
is adopted) have requested that the public hearing be delayed and that there be mc
discussion before a final decision is made on the safety buffer issue.
ALTERNATIVES
1. Adopt the attached ordinance and resolutions.
2. Adopt the attached ordinance and resolutions with modifications.
3. Direct staff to make modifications to the attached-ordinance and resolutions i
schedule another public hearing to consider the revisions.
4. Schedule another study session before taking action on the attached ordihanc
resolutions. Direct staff on additional information needed for the study sessi
Prepared by:
/d/?
Linda Lauzze
Senior Planner
Approved by: ,&-&U /7 I
'Elaine Costello
Community Development Direct
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@?3?9-
Kevin C. Duggan
City Manager
LL/CAM/860-3-13-95M/E
Attachments: Attachment 1-Major Issues and Options
Attachment 2-Study Session Questions and Responses
Attachment 3-Study Session Memo
Attachment 4-Negative Declaration
Attachment 5-Ordinance and Resolutions
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A'ITACHMENT 1
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SUMMARY OF ISSVES.AV .. RECOMMENDATIONS . .. ..
ISSUES - COMMISSION
RECOMMENDATIONS OPTION!
~ 1. ~arngy CM~ care
a. Should small family
with zoning standards. housing? .
pennit when it complies use in all multiple-family
with over the counter child care be a permitted
a. Allow as a pennitted use
b. For large family child
care homes, should the
City adopt standards for
concentration, parking,
traffic and noise In .
single-family homes?
c. Should large family child
care be allowed in
multiple-family units?
b. Adopt standards for
concentration and
parking only.
c. Prohbit large family child
care in multiplefamily
housing.
~~~
1. Allow as a pen
in dl multiple
housing withot
restrictions.
2 Allow as a pen:
if approved by 1
property owner
manager.
3. Allow as a con(
use.
4. Prohibit in somc
mutliple-family
I. Adopt no stand,
large family chi:
single-family hc
2. Adopt standard:
concentration, 1
traffic and noise
1. Allow large fam
care as a permit1
multiple-family
2. Allow large fam
care with a use 1
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OPTIONS
1. Do not allow child
centers as a permit
in any zoning dish
require. a use perrr
. zoning districts, in churches, and in sections
' : of the San Antonio 2. Allow child care as
Center and San Antonio permitted use in aj
Station Prease Plans. the areas recommc by the Commissior
the CN (Neighbor1 Commercial) distri
b. Should child care center
be allowed in industrial 1. Allow child care CE b. Prohibit child care centers
conditional use. when they are located on zoning districts? in industrial zones in industrial zones except
large sites at least 1,000'
from the property lines of 2. Establish a new zo!
and serve only where child care w
employees of .the be permitted and .
company. extremely hazard01
materials would be
prohibited. Child c
would then be prof
. in the remaining
industrial areas.
3. Prohibit child care I
. in industrial zones
-. some industrial art adjacent industrial sites
no exceptions.
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ISSUES
3. Safety Buffer
a. Should a safety buffer be
established between
sensitive uses and
extremely hazardous . .. , materials? $. . . . .,
b. What regulations should
be established for
businesses that would be
made nonconforming by
the buffer?
c. Should El Camino
Hosptial be exempt from
the 1,000' buffer
requirement?
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COMMISSION
RECOWATIONS . A. -, . .,: -
.._ . . ..-.. . . .. - . .. . . .- .~. - . . . -.- .. . .. - .. "_ .
a. ... Establish a safety buffer
. . qiremely .hazardous 'where sensitive Uses and
' &aterials would not be allowed within .. .\- 1,000' sf
each other.. .. -
.. , . ..
b. Grandfather the use with
no expansion possible,
but with no.amortization
period.
c. Exempt El Camino .
Hospital from the 1,000'
buffer standards.
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I., Do not create 2
* buffer.
1. - Amortize the
confofming us
timeframe of 5
to terminate tl
2 Reduce the nr
* nonconformir
businesses by 1
the definition
sensitive use t
include childr
the age of ninr
. would &mini
Crittenden Mi
School as a se~
so the Teledyn
would not be
non conf ormir
.1. Require the El
comply with tl
buffer. (This I
make it noncc
and there coul
expansion of t
of beds or the
used to steriliz
equipment).
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. - COMMXSSrON
ISSUES OPTIONS RECOMMENDAITONS
. -. . . . . . . . . . .- .. _. .._ ..I """."".. - -. "^"_ . . . - -.. . . . , ...-
. .. 1. 4. Application Fees
1 a. Should application fees
for child care facilities be
reduced or eliminated?
a. Reduce -the-use permit .'
.. fees to $50 for, family
child care;$ZOO for child
additional $50 if design
review is'required.
care ceni& bd'&' .
1. Retain existing
application fees.
2 Reduce all child ca
by 50 percent.
. .. .
' - .. 5. Child Care in North
Bayshore
Should the City actively
promote a child care'
center in the North
Bayshore area?
a. Actively promote a child
care center in Shoreline
Park or on the Crittenden
site.
1. Establish zoning th,
would permit child
in certain locations,
do not undertake a
further City particil
ll I 1 2. Direct further study
this issue. 111I
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ATTACHMENT 2
STUDY SESSION -QUESTIONS AND RESPONSE:
The City Council held a study session on February 21 to discuss the Environx
Planning Commission‘s recommendations on new child care standards.
following is a summary of the questions from the study session and respon!
those questions. The questions have been organized under general topics.
NotificatiodApproval for Family Child Care
1. who is notified, property owners or tenants, under the concenfration rule
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Zarge family child care homes in single-family dwellings?
Property owners would be notified. Notification of tenants is probably no1
needed because even if the single-fafnily home is rented, the property ow
likely to consult with the tenants in order to keep the house rented.
2. Why do smdl family child care homes in apartments need the approval o
surrounding provertw owners, rather than tenants‘and how is a “majority
surrounding properfy owners’’ defined?
The Planning Commission‘s intent was that apartment residents surrounc
the unit would be consulted, but the draft ordinance erroneously specified
property owners. The ordinance has been corrected and new text added to
that “residents of over 50 percent of the adjoining units” must approve tht
child care home.
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3.. How will permits be issued for small family child care in duplexes,
condominiums, and apartments?
This would be an over-the-counter, no fee permit (similar to zoning appro
for home occupation businesses licenses) where the City would ask for wi
verification that child care homes meets the ordinance standards
Implementation of Family Child Care Standards
4. How would the City enforce fhe requiremenf that small family child care
would need to be allowed by the lease in multiple-family housing?
The child care provider would submit a letter from the property owner or
. manager.
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5. How will the Cify enforce zoning standards for family child care, for example,
if more children are at fhe home thaf allowed by code?
This would be a violation of the zoning ordinance and the child care operator
would be notified. Continued non-compliance would result in a
misdemeanor, like other zoning violations.
Permitted and Provisional Locations
6. .. Could child care cenfers or family child care be locafed in apartment recreation rooms or similar locations not in an aparfmenf unif?
Child care centers are allowed with a use permit in all-residential zones,
including apartments districts, so could be allowed in recreation room with us
permit approval. By definition, family child care takes place in a residential
unit. If it were located in a recreation room, it would be defined as a child care
center and could be approved with a use permit. '
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7. What are the proposed standards for row housing or small lot single-family?
ROW housing is treated like townhomes and small lot single-family like other
detached single-family housing with private yards. Shared walls and/or sharer
outdoor areas are the key factors that distinguish the housing types and result
in stricter standards in. the proposed ordinance. These standards could be
refined further to address new types of housing, like small lot single-family, bu
the refinements would probably not be significant.
Child Care Center Zoning
8. Is the net result of the recommendations going. fo result .in more or fewer
areas for child care centers?
Geographically, the zoning changes would reduce the physical area available fo
child care because it would eliminate industrial districts. However, the net
result is more real opportunities for child care centers. Industrial areas have
never really been accessible to child care centers because of the difficulty of
making the necessary use permit findings to approve child care in industrial
zones. In commercial districts, the changes would open more areas for child
care.
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9. Why are child care centers not a permitted use in Neighborhood Comme (CN) disfricfs?
Neighborhood commercial centers often have limited parking and availa
sites for outdoor play areas. More review may be.necessary for these locat
so a use permit requirement was considered appropriate.
10. Are fhere isolated industrial areas where exfremely hazardous materials
be prohibited so fhat child care centers could be permitted?
There are industrial areas where there are currently no extremely hazardc
materials being used, including areas on the east and west sides of the No
Bayshore district, the triangular district between Highways 237 m-d 85, anc
Terra Bella Avenue district west of Shoreline. These areas are shown on
Figure 1.
Exception for Child Care in Industrial Zones
11. Why allow an exception for some types of child care? Would if actually bl
harder to evacuate children if their parents are working on the site?
The exception was proposed to create flexibility for child care centers in
locations that would not negatively affect adjacent businesses. Evacuation
be more difficult with parents on the site if children are evacuated to an 0:
safe room. Some parents may want to evacuate their children off-site and
resulting confusion could delay evacuation. ',
12. Could companies using extremely hazardous materials have a child care
center on site under this exception?
Only if the child care center was located 1,000' from the'extremely hazard0
materials on the site plus 1,000' from the property lines of adjacent busine
13. Would the child care centers only be open to employees working on the si]
to all employees of the company, men if they did not work at that site?
The ordinance would allow all employees of the company to use the child
service, even if they did not work at the site.
14. How many industrial sites could comply with the 1,000 distance requiremf
for an exception?
Three site might be able to comply with the exception standards: the Silicc
. Graphics campus and the Kaiser Sand and Gravel site in the North Baysho
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Companv Location
1. Raytheon 350 Ellis Street 2. Catalytica 430 Ferguson Drive 3. Aka Corporation 1015 Joaquin Road 1058 Huff Avenue 4. Symtron Corporation 1625 Plymouth Street
5. Air Products 465 v. Whisman Road
6. Dada International Circuits 2420 Charleston Road
7. Ramlor Circuits 918 Independence Avenue 8. Teledyne Components
9. Martex Circuits IO. Paafic Western System
11. Technitron 630 National Avenue 12 Unisil
13. Greyhawk Systems
14. Jasco Chemical . 1710 Wlla Street . '
15. El Camino Hospital . 2500 Grant Road
January, 1995
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and the GTE site in the Middlefield Road/Whisman Road industrial dist
These sites are shown on Figure 2. The Silicon Graphics site is the most
feasible. The Kaiser Sand and Gravel site would need the approval of se7
adjacent businesses and the GTE site is being considered for residential
redevelopment, so these may not be viable sites for child care.
El Camino Hospital
15. Why is El Camino Hospifal exempfed from fhe safefy buffer sfandards W.
they use exfrmely hazardous materials?
It is not feasible for the Hospital to create a 1,OOW buffer between the cherr
used to sterilize equipment and the patients. In addition, restricting the
Hospital could be more detrimental to the public health, safety, and welfa
than the risk from the limited extremely hazardous materials on this site
16. Can the Hospital use less toxic materials fo sterilize equipmenf?
The Hospital has stated that ethylene oxide is the only chemical available
safely sterilize the large amount of equipment used.by the Hospital. Less
alternatives are not available.
17. Can fhe extremely hazardous materials be relocizfed so fhaf fhey are 1,000'
sensitive uses surrounding fhe Hospital?
The Hospital is surrounded on three sides by sensitive uses and is on'a sq
parcel that is approximately 1,100' in each dimension. The sterilization r(
will be within 1,000' of at least one sensitive use no matter where they are
moved on the site. They are currently located towards the middle of the :
Definition of Acutely (Extremely) Hazardous Materials
18. How are the terms "acutely hazardous" and "extremely hazardous" used
the definition?
"Acutely hazardous" is the term used in State law and has been previous1
used in staff report and the interim ordinance. "Extremely hazardous" is
in Federal laws. Since the proposed definition in the ordinance reference:
Federal laws, the definition and ordinance have been changed to "extreml
hazardous materials" for clarification.
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1. Raytheon
2 Catalytica
3. Alza Corporation
4. Symtron Corporation 1625 Plymouth Street 5. Air Produrn 465 N. pnan Road
6. Davila Internationd circuits 2420 Charieston Road
7. Ramlor Circuits
8. Teiedyne Components 918 Independence Avenue
1300 Terra BeIla Avenue 9. Martex Circuits
IO. Pacific Western System 875,865 Maude Avenue 505 E. Evelyn Avenue 11. . Technitran 630 National Avenue
11 Unisil 405 National Avenue
13. Greyhawk Systems
14. Jassco Chemical
15. El Camino Hospital 2500 Grant Road
350 Ellis Street
430 Ferguson Drive
1015 Joaquin Road
1058 Huff Avenue
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January, 1995
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19. Can the definition of acutely hazardous materials be clarified concerning
amount of hazardous materials?.
New text clarifying the definition has been added to the draft ordinance a
underlined. The allowable amounts reference the City's Toxic Gas Orhi
and the Code of Federal Regulations, Ttle 40.
Scope of the Proposed Ordinance
20. Is there a character check for operators of family child care? .
The Planning Commission's recommendations only address land use issl
and would not regulate the quality of child care. The State ComZnunity C
Licensing Division is responsible for licensing family child care operators
the qualifications of the providers. They require a criminal record clearax
and a child abuse index check before issuing a license to &Id care providc
including fmly child care providers.
21. Can industrial businesses fhat sfarf a child care cmfer under the excepfiot;
rule, close the center whenever they want?
Yes, the City cannot require a company to continue operating a private CE
care center.
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1
I. CITY OF MOUNTAIN VIEW
1 MEMORANDUM
1 DATE: February 21,1995
TO: City Council
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FROM: Elaine Costello, Community Development Director -
SUBJECT: CHILD CARE STUDY
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INTRODUCTION
The purpose of this memo is to provide the City Council with a summary of th
issues and recommendations of the Environmental Planning Commission's CI
care study in preparation for the Council's study session. A Background Binder
the Commission's work is included with this memo. The Council is tentative17
scheduled to hold a public hearing on the Commission's recommendation on
March 28.
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SUMMARY .
COMMISSION'S RECOMMENDATIONS ..
The Environmental Planning Commission has compIeted their child care study
requested by the City Council. This report discusses the Commission's
recommendations to the Council on new land use policies for child care facilitie
hdountain New. The Planning Commission is recommending revisions to the
General Plan, zoning ordinance, and several precise plans to promote child care
safe and appropriate locations. The recommended ordinance and resolutions ax
attached to this report.
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The following summary presents the key recommendations of the Commission.
These recommendations are discussed in greater detail in subsequent sections of
report.
General Plan Amendments
I New policies w
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ould be added to the General Plan to improve information and
3upp~~ r rur curd care -providers a-nd parents, minimize application requirements
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and reduce application fees for child care centers. (These policies are described on
page 8 and Attachment 2).
Family Child Care Homes
Small Family Child Care Homes (I to 6 children)
Small family child care homes would be allowed without any permits in single
family detached housing.
'In duplexes, townhomes, and apartments, small family child care would be
allowed with an over-the-counter, simple permit if consistent with'the lease or
rental agreement and approved by the majority of surrounding residents. The
unit must be a ground level unit with at least one bedroom and 'direct access.
outdoors. There must be adequate outdoor play area available and maximum 0.
four children are allowed. If the home does not comply with these standards, a
conditional use permit is required.
Large Family Child Care Homes (7 to 12 children)
. In single family residential zones, large family child care would be allowed
without a use permit if the home meets standards for parking and concentratior
In duplexes and townhomes, a use permit would be required with a public
hearing before the Zoning Administrator. ..
Large family child care homes would be prohibited in apartments.
Child Care Centers
Child care centers would be a permitted use in the PF (Public Facilities) and C3
(Arterial Commercial) zoning districts, in churches, and sections of the San
Antonio Center, and San Antonio Station Precise Plan areas. Site and
Architectural Review would be required. If the center could not meet standards
for parking, adequate drop-off and pick-up areas, proximity to hazardous uses,
and location of outdoor play areas, a use permit would be required.
Child care centers would be allowed as a conditional use in more areas of the city
including the Downtown Precise Plan area.
. The building'areas of child care facilities would not be calculated as part of floor
area ratio (FAR) restrictions.
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Highly sensitive uses, such as child care centers, would be prohibited in
industrial zones with one exception. Cfiild care centers may be dlawed tkr
a use permit if they are operated by a corporation exclusively for employees
the center is located at least 1,000 feet from their property lines, or companic
adjacent sites agree not to use acutely hazardous materials.
Other Recommendations
A 1,000 foot safety buffer would be established between highly sensitive use
such as child care centers, and acutely hazardous materials. This would be ;
reciprocal provision where new child care centers and acutely hazardous
materials users would not be allowed to locate within 1,000 feet of ea& 0th~
Uses made non-conforming by this new provision would be grandfathered,
rather than amortized. El Camino Hospital would be exempted from this standard.
Fees for all child care applications would be reduced from a range of $1,000 -
$2,500 to a range of $50 - $100. .
The City should encourage a child care center in the North Bayshore area, E
on the Crittenden site or in Shoreline Park.
BACKGROUND
CHILD CARE STUDY
The Environmental Planning Commission has completed a land use study on
child care that was initiated by the City Council in 1993. The Council directed t
Commission to make recommendations on whether child care centers should
located in industrial zones and to develop long term land use solutions that
promote child care in safe locations. This study was prompted by several
applications for child care centers in industrial zones that demonstrated a need
for new zoning ,standards concerning this issue.
At that time, the Council also adopted a two-year interim ordinance to be in
effect while the Commission was completing their study. The interim ordinan
prohibits child care centers and similar sensitive uses in industrial zones or within 1,000 feet of acutely hazardous materials users. It expires in May, 1995.
The Interim Ordinance was adopted with the understanding that the
Commission's study would involve the full participation of child care provide]
Mountain View parents, and the business community. At the conclusion of th:
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comprehensive study, the Commission would make a final recommendation on
zoning ordinance amendments and whether the interim ordinance should become permanent.
The Environmental Planning Commission held numerous meetings and
workshops. These meetings focused on four areas;
Gathering background information on the demand for child care in the
community, the supply of child care facilities in Mountain View, and State regulations concerning child care and acutely hazardous materials;
Developing updated and simplified zoning provisions for small and large - family child care in residential districts;
Developing revised zoning standards and precise plan amendments that
promote child care centers in critical areas of the City, and;
Determining whether uses with populations that are particularly sensitive to
toxic chemicals, like child care centers, are .appropriate in industrial zones or
near acutely hazardous materials.
The Commission reviewed detailed information in publications and staff .
reports, listened to testimony from experts and the public, and after careful
consideration has made final recommendations to the City Council. Along with
this report, the Council received a Background Binder on the Child Care Study containing previous staff reports, meeting m.inutes, and major resource .i ’
materials used by the Commission.
The Environmental Planning Commission’s recommendations are contained in
the attached ordinance (Attachment 1) and five resolutions (Attachments 2 thru
6). The Ordinance contains zoning ordinance revisions, including standards for
highly sensitive uses and acutely hazardous materials. The resolutions include
General Plan amendments and amendments to the San Antonio Center, San
Antonio Station; Downtown, and North 3ayshore Precise Plans.
INTERIM CHILD CARE COMMITTEE
To supplement the Planning Commission’s land use considerations, the Council
also appointed an interim Child Care Committee. The purpose of the Child Care
Committee was’to develop private sector initiatives and publiclprivate
partnerships to support child care in the community. The Committee was
established for a limited time frame of about six months. Information was
gathered from child care providers, parents, and‘businesses to determine what
programs were needed to improve child care in Mountain View.
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In December, 1993, the Committee recommended the following programs that
were adopted by the C~uncil.
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prepare information packets for child care providers and for parents;
hold a "day in the park" appreaation event for family child care providers;
monitor available training for child care providers;
develop an automated telephone referral service;
hold a recognition potluck for child care providers;
hold annual child care forums;
appoint a task force to develop funding sources for after school child care,
and;
provide information on small business resources for child care providers.
The Citfs Community Services Department has completed a significant portic
of these programs. Information packets for parents and child care providers a
finished and being distributed through the Chamber of Commerce and City's
Community Development Department. (Packets were given to the Council la:
joint project with Palo Alto, Sunnyvale, Cupertino, and Mountain Mew. Ab0
40 children and adults from- Mountain View attended this event. The City is
continuing to monitor available training programs, like the Mervyn's Grant. Remaining programs will be implemented in the future. The Child Care
Committee's work complements the Commission's land use recommendatior
and completes a comprehensive review of child care issues in Mountain .. yew
PUBLIC PARTIaPATION
The Environmental Planning Commission has encouraged public participatio
in the Child Care Study by holding numerous workshops and meetings,
including:
a Town Meeting on Child Care with about 50 participants; - a joint workshop with the Child Care Committee to discuss.the Town
September). In July, Mountain View hosted a Day in the Park event that was a
Meeting and the comments and suggestions from those who attended;
a second joint workshop with the Child Care Committee to discuss child ca:
centers in industrial zones, including a presentation about hazardous
materials from the- City's Fire Department; and,
eight public hearings on the child care policies recommended by the
Commission.
5
There has been extensive public noticing for the Commission’s meetings on
child care. Notices were sent to the following groups:
Major industries including all those currently using acutely
Mountain View Chamber of Commerce.
Child care centers and large family child care homes.
Attendees of the Town Meeting on Child Care.
Child Care Committee and Ad Hoc Committee.
.. Santa Clara County Manufacturer’s Group..
Mountain View churches.
Parents of Mountain View Elementary Schools students through flyers in the
Other interested individuals.
Staff reports were also sent to many of these groups and there were
announcements of the meetings in the San Jose Mercury and other local papers.
ENVIRONMENTAL STATUS
hazardous materials and those within 1,000 feet of highly sensitive uses.
school newsletters.
The initial study found that there are no significant environmental impacts from
the proposed General Plan, Prease Plan, and zoning revisions. The proposed
. . regulations increase the safety of sensitive groups by providing a safety buffer from
accidental hazardous material releases. A Negative Declaration of environmental
impacts has been prepared and is attached (refer to Attachment 6). *.
ANALYSIS
INTRODUCTION
The Commission has completed an in-depth analysis of land use.standards for
family child care, provisions for larger child care centers, and policies for sensitive
uses and acutely hazardous materials. One of the main purposes of the Planning
Commission‘s child care study was to find ways to promote child care through
effective land use policies. The Commission found that this meant developing
balanced land use policies that encouraged child care facilities in some areas of the
city, while maintaining the integrity of the City‘s industrial, commercial, and
residential districts. Achieving this balance required that zoning restrictions be
eliminated in some areas and in other areas that new zoning standards be
recommended.
The Commission’s recommendations are tailored to the unique needs of the
Mountain View community. This report presents the Commission
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recommendations and key findings. Detailed information on the issues and o
considered by the Commission can be found in the Council's Background Binc
The Commission is recommending changes to 'the General Plan, zoning ordin
and several precise plans. This "Analysis" section is organized by these
recommendations and contains the following sections:
Child Care Supply and Demand
General Plan Amendments
Zoning Ordinance Revisions
Precise Plan Amendments
.. Other Commission Recommendations
CHILD CARE SUPPLY AND DEMAND -
There are currently 23 child care centers in Mountain View as shown on Figm and 2. These centers provide spaces for 1,406 children which is about75 percen
the child care spaces in the city. The remaining child care is provided by famill
care homes. Most of the existing child care spaces are for preschool age chi€dre:
One of the major findings of the Commission's child care study is that general1
there are sufficient child care facilities in Mountain View with two exceptions:
is a need for child care for school age children at their elementary schools and i
specialized child care, such as infant care. Information gathered by the 4C's Co
of Santa Clara County and the Child Care Committee shows that the greatest nc
for child care is at the City's elementary schools. In the Whisman and Mounta
View Districts, there were 57 more requests for'child care spaces at the element:
schools in 1993 than could be provided, but at child care centers not located at s
sites, there were 10 vacant spaces available. The Child Care Committee
recommended. establishing a task force to find funding for more child care capa
March, 1994. After the Council takes final action on the Planning Commission
recommendation, staff will prepare a report on initiating a task force for the
Council's consideration.
All of the elementary schools in Mountain View have child care provided on-:
except Whisman School. The demand for child care differs significantly betwec
these schools. In 1993, there were 60 students on the waiting list for child care a
Bubb School while there was no wditing list for child care spaces at Castro Schol
even though there were 170 more students at Castro School and the number of
available child care spaces was about the same. The difference in demand for cl
care at elementary schools in the Mountain View District suggests that there arc
variety of factors that influence demand and that it is not a simple quantitative
relationship. Demand can be affected by the quality of the program, household
incomes, cultural traditions, the location of the school, and similar factors.
at the City's elementary schools. The Council endorsed this recommendation 1
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I I b- .. CITY OF MOUNTAIN VIEW
.* -. LOCATION OF SCHOOLS
* *. ,,..*.'" AND CHILD CARE CENTERS
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Schools and Child Care Centers
. in Mountain View
Schools
A. Bubb Elementary School .
B. Landels Elementary School
C Slater Elementary School’ D. Castro Elementary School E. ” Monta Lorna Elementary School E Whisman Elementary School
G. Theuerkauf Elementary School
H. Graham Middle School
I. Crittenden Middle School J. -Mountain View High School
K. St. Athanasius School
L St. Joseph School
M. St. Francis High School
N. Springer Elementary School
Child Care Centers
1.
2. 3.
4.
5.
6.
7.
8.
9.
IO.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
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23.
YMCA Kid’s Place - Bubb School
YMCA Kid’s Place - Landels School ~ E1 Camino YMCA Preschool
YMCA Kid’s Place - Slater School
State Funded Preschool
YMCA Kid’s Place - Castro School
YMCA Kids Place - Monta Lorna School
YMCA Kids Place -Theuerkauf School
Mountain View Child Development
Mountain View Parent Nursey School
Kidstown Preschool
Southbay Christian Center .
Abracadabra Child Care Center
Abracadabra Extended Day Care
Mountain View Head Start
St. Tmothy‘s Nursery School.
St. Paul Lutheran Child Development
Primary PIus/Infant-Toddler Center
Hobbledehoy Preschool
Little Acorn School
Oaktree Nursery III
Walnut Grove Preschool
Western Montessori Day School
Revised January 1995
7b
Location
525 Hans Avenue
115 West Dana Streef
325 Gladys
505 Escuela Avenue
‘460 Thompson
.310 Easy Street 1625 San Luis Avent
1175 Castro Street
1701 Rock Street
3535 Truman Avenu
160 N. Rengstorff Av
1120 Miramonte Avc
1885 Miramonte Avt
1120 Rose Avenue
Location
525 Hans Street
115 West Dana S-beef 115 West Dana-Street
325 Gladys Avenue
325 Gladys Avenue
505 Escuela
460 Thompson Aver
1625 San Luis Avenc
750 San Pierre Way
1299 Bryant Avenue
180 N. Rengstorff Av
1134 Miramonte Ave
1120 Rose Avenue
253 Martens Avenue
253 Martens Avenue
2094 Grant Road
1075 El Monte Avem
333 Eunice Avenue
2321 Jane Lane
1667 Miramonte Ave
2100 University Avel
84 Murlagan Avenut
323 Moorpark Way
At the Tom Meeting on Child Care held las; year, most partidpants were concern
about better information networks and the quality of child care rather than the
quantity of available spaces. Comments gathered from.the Town Meeting indicate
that there may also be a need for specialized child care, such as infant and sick chi1
care.
The Commission found that simply increasing the supply of child care spaces may
. not completely address the child care needs. in this community. Child care solutio
for Mountain View will be different than surrounding communities. According t
the. 1990 Census, Mountain New has the lowest persons per household of any city
.in Santa Clara County (2.23 persons per household compared with an 'average of 2.
persons per household) and is one of two cities with the lowest percentage of
residents under the age of 18. This suggests that there are fewer families in
Mountain View than surrounding communities. The median family income in
Mountain View is among the lowest in the county, indicating that many families
may not be able to afford child care even if more spaces are provided. Land use
poliaes alone cannot address the affordability, quality, and specialized child care th
may be needed by this community.
GENERAL PLAN AMENDMENTS
The City's existing General Plan already contains policies supporting child care
facilities. The proposed new policies developed by the Commission recognizes the
vital role of child care providers, supports measures to improve information
systems, and seeks simpler and less costly application procedures for new child car(
centers. The proposed General Plan Amendments are contained in Attachment 2.
These new policies and objectives in the General Plan create a solid foundation for
the new zoning regulations recommended by the Commission and programs
suggested by the Child Care Committee.
ZONING ORDINANCE REVISIONS
The zoning ordinance revisions recommended by the Planning Commission are
contained in Attachment 1. The revisions include new definitions, provisions for
family child care, standards for child care centers, and locational requirements for
highly sensitive uses and acutely hazardous materials. A summary of child care
regulations in other Santa Clara County cities is provided in Attachment .7.
In considering possible land use options, the Commission weighed how to protect
the rights of surrounding property owners and the welfare of children, while making it easier for child care facilities to be established in Mountain View. Where there were potential impacts to surrounding property owners or possible adverse
affects on children, the Commission is recommending a use permit process or
prohibiting child care in those zones. The use permit process gives adjacent
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. property owners a chance to have input on the proposed use and allows speci;
conditions to be required that will minimize any future problems. Wherever
feasible, the Commissi.on recommends that child care be a permitted use to m
easy to establish child care faalities in those areas. The proposed zoning revis
will eliminate much of the current confusion over where child care facilities i
permitted and in what districts they are encouraged. I
I Definitions
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The recommended zoning revisions start with new or amended definitions. '
proposed definitions primarily clarify the types of dwelling units and child ca~
facilities. The definitions for dwelling units are a refinement of existing zonir
ordinance definitions and the child care definitions are .based on StatS law. Tl
definition for highly sensitive uses is a new and critical definition. This defir
is discussed in the section on the "Safety Buffer". I Family Child Care
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Family child care provides about one-fourth of the child care spaces in Mount
View. Family child care includes small family homes with 1 - 6 children and ll
family homes with 7 - 12 children. Children under the age of 10 who live at tt
residence are included in the maximum number of children allowed. Family
care homes are a particularly important source for infant care, providing 73 pe
of the infant spaces avaiIable in the city.
Currently, family child care is not distinguished from larger child care centers
City's zoning ordinance and a use permit is required for large family child care
homes. The zoning provisions are outdated and not consistent with State
legislation. The California Child Day Care Act preempts local regulation of fa1
child care in many areas. (A copy of this State law is attached to the August 3 s
report in the Background Binder). In general, family child care is considered a
residential use and has to be allowed in single-family residential homes and
districts, with only some minor restrictions allowed for large family child care
homes. The law does not specifically address whether this restriction applies tc
other types of housing, such as apartments. After careful review of the legislai
staff believes that the State legislation does not restrict regulation of family chil
care in other zoning districts and types of housing, such as apartment housing
commercial districts. The Commission is recommending stricter zoning regul
for family child care in multiple family housing because of the potential impac
adjacent residents.
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The Planning Commission received a letter from Child Care Law Center in Sax
Francisco that disagrees with the City's interpretation of the California Child D:
Care Act. At issue, is whether the City can adopt restrictions for family child ca
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multiplefamily housing. Abby Cohen, managing attorney at the Law Center,
maintains that State law limits the City's jurisdiction, even in multiple-family
housing. Our City Attorney's Office disagrees with this opinion.
Small Familv Child Care
State law specifies that cities must allow small family child care in single-family
residential dwellings, but communities can adopt their own regulations for
duplexes, townhomes, condominiums, or apartments. There are no restrictions o
smaU family child care in single family homes under the proposed ordinance
provisions. In duplexes, townhouses, and multi-family dwellings, the Commissic
is recommending some zoning standards to help assure an appropriate
environment for the children and compatibility with the surrounding Seighbors.
The Commission believes that good communication should be encouraged betwec
potential child care providers and their neighbors and landlords. The Commissio~
recommends that a simple, over the counter permit with no fee be required for
small family child care in duplexes, townhomes, and multiple family housing. Th
permit would be granted if the use meets the following standards:
1) The rental or lease agreement allows 'the use;
2) The majority of surrounding property owners or' homeowners association
approves the use;
3) There are no more than four children; ',
4) In apartments and condominiums, the unit is located on the ground level and.
has at least one bedroom and direct access outdoors; and,
5) There are adequate outdoor play areas available. .
If a small family child care home does not comply with these standards a use permi
would be required. A public hearing would be held by the zoning administrator
which would provide an opportunity for the child care provider, surrounding
residents, and. the property owner(s) to present information and viewpoints. If the
Zoning Administrator can make the required use permit findings, the child care
home would be approved with any appropriate conditions.
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Large - Familv Child Care
Large family child care homes can have up to twelve children. There could bl
than 12 children at the home, if children over the age of 10 live at the residenc
Because of the number of children, there is more likely to be an &pact on ad
properties from noise, parking, and traffic.
Studies in several cities generally have found that the impacts of large family
care Ere minimal in singlefamily residential neighborhoods. In single family
residential zones, State law requires that large family child care homes must b
approved if they meet adopted standards for spaang,.parking, traffic, and nois
Cities are prohibited from setting any other standards. Cities can require a use
permit, but approval must be based on satisfying these four standards and no
the proximity to acutely hazardous materials or because neighbors protested.
standards can be applied. For instance, a use permit could not be denied based
The Commission is recommending some standards for spacing and parking, 't:
traffic and noise. A use permit would be required only if the family child care
not comply with these standards and most child care homes can easily meet tl
requirements. A majority of cities in the county either do not have zoning
standards for. large family child care or also have adopted only spacing and par
requirements. The proposed requirements for large. family child care in single
family districts are:
1) One on-site parking space that can include driveway areas; and
2) That a new large family child care use not result in a residence being border'
more than one large family child care home, unless it is acceptable to that
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property owner.
In duplexes, townhomes, and apartments the impacts of a large family .child ca
homes can be substantial. Because of these potential impacts, the Planning
Commission is recommending stricter standards and procedures for large fami
child care in higher density housing. Apartments often have upper and Iower
and more than one shared wall. Noise travels more easily between units than
single family neighborhoods. This could be a major problem for occupants of I
units when there is a large family child care home above them. Typically parki
also in short supply in apartment housing. Some older apartments have mini
or no outdoor play areas for children. Duplexes and townhomes also have sha
walls and often less parking available than single-family homes.
The Planning Commission recommends that a conditional use permit be requi
for large family child care in duplexes and townhomes. This would require a p
hearing by the Zoning Administrator to allow input from surrounding residen
11
The Commission also recommends that large family child care be prohibited in
multiple-family housing, such as apartments or condominiums, because of the
potential for significant negative impacts on neighbors. Currently, there is one lar;
family child care home located in an apartment in Mountain mew. This use woul
be grandfathered under the proposed ordinance and could continue to operate
without restrictions.
Child Care Centers
The Planning Commission is recommending that child care centers be allowed in
some zones without a use permit in order to encourage more child care centers in
these areas. This would be an incentive for new child care centers to locate close to
jobs, along transit routes, or on existing school sites.
Currently, child care centers are required to have a use permit in all of the City's
zoning districts, including the Public Facilities district that covers schools. (Child
care centers are prohibited in industrial districts by the Interim Ordinance). Many
child care centers in Mountain View are located on school sites which are quality
environments for children, convenient for parents, and a compatible use with
surrounding properties. About half of the cities in the county allow child care
centers as a permitted use in commercial zones and many allow them as a permitte
use on school sites.
Under the proposed ordinance, child care centers would be permitted uses in the PI
(Public Facilities) and C3 (Arterial Commercial) zoning districts, as shown in Figure
3, and a permitted accessory use in all churches except those located in industrial
zones or within 1,000' of acutely hazardous materials. The 0 zone basically covers
El Camino Real and portions of San Antonio Road and Moffett Boulevard. Where
child care centers are allowed as permitted uses, they must provide adequate parkin/
from adjoining residential uses, and not be located adjacent to businesses that could
be a safety or health risk, such as gas stations. Site plan and architectural approval is
required by the proposed ordinance to assure compatibility with surrounding uses.
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and on-site drop-off and pickup areas, have outdoor play areas that are buffered
In all other zones child care centers would be a conditional use, except in industrial
(ML and MM), General Commercial (CG), and Flood Plain (F) districts. The CG
district is primarily located along Old Middlefield Road. This district is reserved for
heavy commercial uses, like automotive repair and equipment yards, that are
generally not compatible with child care centers.
The draft ordinance provisions clarify zoning regulations for child care centers by
clearly stating in which zones they are permitted, conditional, or prohibited uses.
The zoning revisions increasethe areas where child care centers are a permitted use.
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1 :: .CITY OF MOUNTAIN V +., . c- - *. I , I i=* <* 4 *- t
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Zones wh .- .- Child Care Cenl
would be a Permiffed 1
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These changes will encourage child care centers along major transit corridors and
transit hubs by allowing child care centers as permitted uses in these areas.
Zoning ordinance revisions recommended by the Commission also indudes somc
new parking standards for child care centers. The City's existing zoning ordinance
does not have specific parking standards for child care centers. This creates .
uncertainty for people who want to start child care centers in Mountain View and. are evaluating the feasibility of different sites. The parking standard recommendel
by the Commission requires one space per employee plus I space for every 15 . children for visitor parking and drop-off areas. This standard is in the middle rani
of parking standards in other Santa Clara County cities.
Child Care Centers in Industrial Zones -
Introduction
The question of whether child care centers should be located in industrial zones
' or near acutely hazardous materials is a complicated issue. There are credible
arguments on both sides of this question. This topic generated the most
discussion among the Commissioners. Last year, the Planning Commission
held two public hearings, reviewed two major staff reports, and heard from
experts on this issue.
When the question was first addressed by the City's Ad Hoc Committee in
November, 1992, they defined the issue as: ..
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The increasing demand for day care in industrially zoned areas
has created the need for a City policy that promotes a safe
environment for high-risk populations, such as child care and
senior care facilities, while balancing industry's right to: 1)
flexibility in expanding or changing their production process, 2)
economic viability, and 3) growth.
As pointed out by the Ad Hoc Committee, the question of whether child care cente
should be allowed in industrial zones has two parts: I) is it safe for children, and 2:
is it compatible with surrounding industries? In the past, when applications for
child care centers in industrial districts were received these questions were
addressed on a case-by-case basis through the conditional use permit process. This
process did not work well for either the City or the applicants. There was too mucl-
uncertainty whether the child care applications would be approved and no clear guidance on what might constitute an acceptable location in an industrial district.
Under these earlier use permit procedures, the City .received two applications for
child care centers in industrial districts: the Betty Peach application in the Whisma
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industrial district and an application from Lincoln Wescott for a child care ce:
the North Bayshore area. Both of these applications were difficult and promF
City Council to ask the Planning Commission to develop a better method of
regulating child care in industrial zones. The theoretical possibility of obtaini
pennit MMWQ~~ tke ~~@atlts tb spend the time, efiort, and money to app However, in the final analysis, the City could not make the legally required u!
permit findings that the location was safe for children and compatible with th
surrounding uses or the applicant dropped their application because of the ex
environmental analysis required.
Acutelv Hazardous Materials
There are different kinds of hazardous materials used in industrial processes.
of these are classified by Federal law as acutely hazardous materials because of
extreme toxicity. The semiconductor industry still uses highly lethal gases suc
phosphine and arsine. New biotech industries also use some extremely toxic
materials in their research. Both of these kind of businesses are found in Mol
View's industrial zones and constitute growing sectors of the local economy.
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Mountain View'sindustries are typical of the types of businesses found in mo!
industrial districts in Santa Clara County. There are Nnently 15 companies (I
sites) in Mountain View that use acutely hazardous materials as shown on
Figure 4. About 525 other businesses in Mountain View use hazardous
materials. Most of these businesses use only small amounts of hazardous
materials, such as photo developing chemicals in a photography studio,-and dl
not pose a risk to adjacent properties.
Advances in the containment and control of hazardous substances have great1
reduced the chance of an accident, but have not totally eliminated this risk. In
the event of an accident, acutely hazardous materials pose a.significant health
risk to people on or near the site.
In addition to accidents on-site where hazardous materials are used, problems
can also happen off-site during transport of these materials. The Federal Hazardous Material Transportation Act specifies packaging requirements, labeling, and similar safety measures. However, it is more difficult to control
transportation risks because there are more variables, such as accidents caused t
other drivers. The State Highway Patrol regulates the transport of hazardous
materials on highways. The City has no control over inspections or the
enforcement of transportation safety measures.
In the event of an accident releasing acutely hazardous materials, sensitive
populations will be more vulnerable than the general population. Infants,
14
Figure
00 .- 0- CITY OF MOUNTAIN VIEW
. *...-*'*. LOClimON OF
MATEfiLALS
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-* , *e* : . *.* 0 0 .* 0 A-YHAZARDOUS
1. Raytheon 350 Ellis Sweet
3. Alza Corporation 1015 Joaquin Road
4. Symtron Corporation 1625,Plymouth Street 5. ' Air products 465 N. Whisman Road 6. Davila International Circuits 2420 Charleston Road 7. Ramlor Circuits 918 Independence Avenue 8. Teledyne Components 1300 Terra Bella Avenue 9. Martex Circuits 875,055 Maude Avenue 10. Padflc Western System 505 E EveIyn Avenue 11. Technitron 630 National Avenue 12 Unisil 405 National Avenue 13. Greyhawk Systems
14. Jasco Chemical 1710 Villa Street
15. El Camino Hospital 2500 Grant Road
2. Catalytica 430 Ferguson Drive
1058 Huff Avenue
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children, the elderly, and people with health problems are defined as highly
sensitive groups for several reasons.
1) Thw groups are physiologically less tolerant of exposure to acutely
hazardous materials. Even minimal exposures may have serious health
consequences for children with less developed immune systems and small{
developing bodies, or to those whose health is already frail.
2) These populations are more difficult to evacuate or to move to safe locafior
on-site in the event of a toxic gas release. Infants and young children are le:
’ responsive to evacuation directions, and those who are elderly or ill may
have difficulty moving without help. .-
Commission Recommendation on Chiid Care in Industrial Zones
The recommended ordinance prohibits child care centers and other highly sen
uses within industria1 zones. (A definition of highly sensitive uses is given on
19). There is one exception. Child care centers can be allowed with a use perm:
they are operated by a company to serve employees and are at least 1,000’ from
site boundaries or adjacent property owners agree not to use acutely hazardous
materials. This would allow large corporations to have on-site child care for tl
employees when there was no impact to adjoining businesses.
The Commission reached this recommendation to ensure the integrity of the
industrial districts and the safety of highly sensitive groups. The Commission’:
recommendation is based on the results of their careful analysis, public testimc
and the following key findings.
A. Hazardous Materials Regulation. State legislation on hazardous materials
, does not directly limit the location of highly sensitive uses or acutely
hazardous materials, except for hazardous waste treatment or disposal
facilities which are not located in Mountain Gew. State regulations caII fc
adequate study or notification, but do not restrict the location of these uses
Local regulations adopted in the past 15 years have minimized the risk of
accidents from the handling or storing of hazardous materials. Mountain
View adopted a Hazardous Material Storage Ordinance in 1983 and a Toxic
Gas Ordinance in 1990. There have been very few spills, accidental release!
and other incidents with hazardous .materials since these ordinances were
adopted. The most serious accident was a toxic gas release from equipmen
failure on a tanker .while.making a-delivery in an industrial district.
15
B. Evaluating Risk. State legislation requires a Risk Management Prevention
Plan (RMPP) from companies that locate within 1,000' of a school and
allows the County Health Department to require a RMPP from other
companies that use substantial amounts of extremely hazardous materials
or are located near high-risk facilities, like schools and child care centers.
Currently, the County requires an RMPP from only a small percentage of
the companies using acutely hazardous materials. Only one Mountain
View company has been required to complete a RMPE out of 15 companies
using acutely hazardous materials. Some industries are concerned that
.. locating child care centers in industrial zones will result in surrounding
businesses being required to prepare an RMPP, which is expensive and
could increase their liability. The RMPP is essentially an information
document and the Health Department has no authority to require
companies to use any of the safety controls recommended in the document.
It is impossible to know all the risks from hazardous materials unless a risk
assessment has been prepared for industries around the child care center. Thi:
information will be expensive and may be difficult to obtain voluntarily from
surrounding industries.
There are still many unknowns about the new varieties of toxic materials that
are being used and developing safety measures to manage these new materials
is an evolving process. These types of unknowns make it difficult to
definitively evaluate the risk to child care centers in industrial zones.
The City has no control over the transport of hazardous materials.
However, the risk of an accident involving toxic materials is often greatest
when chemicals are moved between a truck and the building or storage .
tank. If child care centers are located in industria1 zones those children may
be more exposed to accidents because they are in an area .where trucks make
pick-ups and deliveries of hazardous materials..
An acceptable level. of risk is a subjective judgment. Even a low level of risk to
a child may be unacceptable to the parent.
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C. Evacuation. Available evacuation time varies significantly depending on
the wind speed and type of toxic material involved in the accident. In a
computer model of an accidental chlorine gas release, the plume of gas
reaches a child care center 1,000' away in about 20 minutes when the wind
speed is 3 miles an hour. If the wind speed is 10 miles per hour, the plume
would reach the center in 6 minutes. (Winds in Mountain View average 3
miles per hour in the morning and 10 miles per hour in the afternoon).
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Off-site evacuation is not a viable option for most large child care centers because using off-site transport services may not be reliable or quick enou
and the cost of maintaining adequate vehicles on-site is too high.
In-place evacuation to a “safe room” within a child care center would be i
most viable evacuation plan for most child care centers located within
industrial zones. Safe rooms are designed to be airtight, have easy manu;
automatic shut-off for air conditioning and heating systems, and ventilat
would switch to a filtered system with scrubbers that remove toxic materi
(refer to Figure 5). The rough estimate of the cost for a simple safe room i
’ $50,000 - $70,000, plus maintenance expenses.
D. Notification Systems. Establishing effective notification systems-in the ec
a toxic materials accident is difficult and subject to human error. The City
Department has found that they are often not notified immediately when
is an accident. The City of Richmond had an auto-dial notification systerr
was not very effective during a recent toxic gas accident. Richmond is no7
implementing a multi-faceted notification system funded by local industrj
child care centers were located in industrial zones, emergency notificatior
systems also should be-multi-faceted, but can probably never be made fool
proof.
E. Safety Measures for Child Care Centers. Child ‘care center can be made saf,
industrial zones by incorporating specialized safety measures, such as safe
rooms. These safety measures use well-tested and available technology. C
expert in toxic chemicals believes that child care centers can be designed to
safe in industrial zones, especially given Federal and local safety standards
toxic materials that minimize the risk of an accident.
E Benefits of ChiId Care. There are substantial benefits when child care is
located near jobs. ChiId care close to jobs helps reduce commute trips,
improves air quality, and is good for families. However, given the locatio:
of the City’s industrial districts, it is not crucial to locate child care within
these districts. In Mountain View, there are many other opportunities to
locate child care close to employments centers, transit hubs, and commute
corridors.
G. Demand for Child Care. The greatest need for additional child care in
Mountain View is for after-school programs at the city’s elementary schoo:
and for specialized child care, such as infant care. There are adequate space available in most other commercial child care centers.
17
. _.. '. ... . 0 ', . ._ ~. . . I . ..
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_. Figure 5
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Veniilatior
AudlofVisual
SafLmQm Schoot Princioal's
Office
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H. Concerns of Industry. Business is generally opposed to child care centers
industrial zones. The City's Chamber of Commerce, the Santa Clara Cou
Manufacturer's Group, and representatives of several companies in the
North Bayshore area testified at public hearings against child care centers
industrial districts (with the one exception included in the draft ordinanc
No businesses testified in favor.
Business is concerned that child care centers and similar uses will
compromise the integrity of industrial districts. When child care centers
.;. locate in industrial zones, surrounding businesses are confronted with
uncertainty about additional compliance requirements, the potential for
increased insurance costs and liability, a possible reduction in property
values, and public controversy when introducing new hazardous materi;
It was noted that industries need a reliable place to do business and
industrial zones should be reserved for compatible uses, just as residentii
zoning protects neighborhoods.
Given this information, the Commission recommends limiting child care
centers in industrial zones. While most Commissioners concluded that it is
possible to reduce the risk to highly sensitive groups using safety technology, t
Commission did not find it possible at this time to reduce the potential advers
impacts to businesses within an industrial district. .Under the proposed
ordinance, prohibiting child care in industrial zones will maintain the integril
of these districts for business and there will still be many other areas of the
community where child care centers are permitted and encouraged. . :.
Safety Buffer
Introduction
The Planning Commission is recommending that a-safety buffer be established
between sensitive uses and acutely hazardous materials. The draft ordinance
would create a 1,000' buffer between these uses. The safety buffer would provic
more time for evacuation if there were an accidental release of toxic gas and thc
generally would be less concentrated at a 1,000' distance.
The City Attorney has determined,(during the Council's consideration of the
massage parlor ordinance) that distance requirements to protect the public hea
safety, and welfare must be applied equally to all impacted uses. In the case of
sensitive uses and acutely hazardous materials, this means that if sensitive use
prohibited within 1,000 feet of acutely hazardous materials, then acutely hazarc
materials must be prohibited within 1,000 feet of sensitive uses.
18
The locations of sensitive uses and acutely hazardous materials are shown in .
Figure 6. The 1,000 foot safety buffer would make two existing businesses, a child
care center and a school non-conforming; Teledyne is within a 1,000 feet of
Crittenden Middle School and Pacific Western Systems is within 1,000 feet of
Western Montessori Day School. The 1,000 foot.restriction would also prohibit
new acutely hazardous materials from being used on approximately 100
properties within the City’s industrial districts. As shown on Figure 6, the actual area affected by the 1,000 foot restriction is only a small percentage of the Citfs
industrial districts.
The proposed ordinance will create a safety buffer for Slater Elementary School,
Landels Elementary School, Crittenden Middle School, the State Funded Pre
School, the Y2CA Kid’s Places at Landels and Slater schools, and Weste‘;n
Montessori Day School on Moorpark. It would prohibit new acutely hazardous
materials near these sensitive populations.
Two businesses. and two sensitive uses will become non-conforming if the 1,000 foo
safety buffer is adopted. The Planning Commission recommends that these non-
conforming uses be grandfathered which would allow them to continue
indefinitely, but the use could not be expanded. (Crittenden Middle School would
not be restricted since the City has no jurisdiction over public schools). The
alternative considered by the Commission was to axqortize the uses which would
require them to cease operation in 40 years or less. Since amortizing the uses would
negatively impact two business and a child care center, the Commission
recommends grandfathering these uses.
Definition of Highlv -~ Sensitive Uses
The proposed definition for highly sensitive uses in the draft ordinance is:
A facility that is principally intended to be occupied by more than 12
children under the age of 13 years, or non-ambulatory, physically
disabled, or mentally impaired senior citizens, and other populations
which would be difficult to evacuate in the event of an unauthorized
release or discharge of an acutely hazardous material and who are
general population.
physiologically more sensitive to exposure to toxic materials than the
Under this definition, small and large family child care homes, senior care homes
with 12 or fewer adults, and child care facilities for 12.or fewer children would not be
considered highly sensitive uses. These uses could locate within 1,000 feet of acutely
hazardous materials and acutely hazardous materials could locate within 1,000 feet
of these type of uses.
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CI" OF MOUNTAIN
0. . 8. -9 -
00 - Safety Buffer
" .- -0 0 Sensitive I: 0. ,...'." ,." c - **e " .- -- ,.*. -. 0
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..
uoncpw
Los AnDS
1 - 14 Acutely Hazardous Material
' * Child Care and Senior Care '
Users
Facilities > 12 1
January, 1995
19a
State law prohibits the City from restricting the location of family child care in sing,
family districts based on their proximity to acutely hazardous materials. So the Cig
cannot apply the 1,000 foot buffer to family child care in single family homes.
Another reason these small facilities are not defined as highly sensitive uses is that
evacuating small numbers of children or seniors from the site is easier than larger
groups. In addition, the locations of these type of'uses are often difficult to monitox
since City permits are usually not required. Large family child care homes open an(
close frequently and some of these homes are not licensed so there is no record of
their location. If family child care and small senior care facilities were defined as .
highly sensitive uses, this would further reduce the area available within industria'
zones for acutely hazardous materials and create more uncertainty for industrial
property owners and businesses. -
Under the proposed definitions and ordinance, small child care facilities with 12 or
. fewer children could not locate in industrial districts (except under the one
.. exception for company run centers on large sites). While these facilities would not
be defined as highly sensitive uses because they have less than 12 children, they
would be defined as child care facilities which are prohibited in industrial zones in
the draft ordinance.
The proposed definition would define elementary and middle schools as sensitive
uses, but not high schools. In Mountain View, high schools are not located near
industrial zones or acutely hazardous materials, with the exception of Saint Francis
High School near El Camino Hospital. High schools are also not included because
children at this age are not as physiologically sensitive to toxic materials and, are .
easier to evacuate than younger children.
The 1,000 foot Distance
The safe distance from a hazardous materials accident will depend on many
and velocity, and available evacuation routes. State legislation dealing with
distances between hazardous materials and sensitive uses reference either a 1,000
foot radius or a quarter mile (1,320 feet) radius. These distances are used for
notification requirements and potential impact area. The State laws offer a
reasonable standard, but are not intended to establish absolute safety thresholds.
The Planning Commission is recommending the 1,000 foot standard, because it
is an acceptable safety distance that is the least restrictive for child care centers
and businesses. A-wider buffer would provide more time for evacuation, but
would also create more non-conforming uses and more areas where child care
centers and some businesses could not locate.
. variables, including the amount and type of toxic materials, the wind direction
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The recommended ordinance also specifies that the 1,000 foot distance be me;
from the property line of the site, as typical for zoning standards. There is an
are located on very large or irregularly shaped sites. For example, with indus
located on large sites, the storage or use of hazardous materials could be 1,000
from their property lines and 2,000' from a child care center. For these situatic
buffer to be measured from the location of the actual uses, rather than the prc
line.
This exception procedure would affect the uses that are made non-conformint
the 1,000 foot safety buffer. Both of the industrial non-conforming uses are on
sites and could apply for a use permit to expand acutely hazardous material u]
portions of their sites that are not within the 1,000 foot buffer. Likewise, West
Montessori Day School could apply for a use permit to expand if the acutely
hazardous materials used at Pacific Western Systems were more than 1,000 fet the child care center. A church has also expressed interest in starting a child ti
center that would be affected by the proposed exception process. The church is
located on a large triangular lot and the child care center would be 1,000 feet f1
acutely hazardous materials site, but if measured from the property line the cc
would be prohibited.
exception procedure in the ordinance for situations where one or more of the
the draft ordinance contains a use permit procedure that would allow the I,OC
El Camino Hospital
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The Commission is recommending that El Camino Hospital be exempted fron
safety buffer regulations because of the potentially detrimental effects of restric
the Hospital. El Camino Hospital is located in a residential area and is surroul:
by highly sensitive uses. The Hospital site is within 1,000' of the YMCA, a chilc
center, a two convalescent hospitals, plus Saint Francis High School.
El Camino Hospital is an unusual use; it is both a-highly sensitive use and an
acutely hazardous materials user. The Hospital uses ethylene oxide gas to steri
hospital equipment and many patients would be defined as highly sensitive gr
It would be virtually impossible to implement the 1,000 foot distance requirem
between the toxic gases used in the- hospital and the patients. In addition, if the
proposed zoning regulations were applied to El Camino Hospital, the Hospital
emergency required an inaease, or change their procedures to introduce other
materials that could be more effective or needed for new strains of viruses. Th
-restriction could pose a greater risk to the public health, safety, and welfare thar
potential risk of a toxic gas accident.
would not be able to increase the amount of ethylene oxide stored on-site, even
21
PRECISE PLAN AMENDMENTS
introduction
The Commission is recommending amendments to San Antonio Center, San
Antonio Station, and Downtown Precise Plans to encourage child care centers in
those areas and amendment to the North Bayshore Precise Plan to clarify provisio:
for a potential Space Camp (refer to Attachments 3 thru 6). The locations of these
Precise Plan amendments is shown in Figure 7.
-One of the goals of the Planning Commission is to promote child care along major
commute routes, close to transit opportunities, and near employment and
commeraal centers. Child care facilities in these locations could help reduce traffic
congestion by making transit a more viable option for families and reducing the
miles parents drive to child care centers. It could also make child care more
accessible to families that depend on buses or trains for transportation.
In the Downtown and San Antonio Road areas there is a concentration of
commercial and office activity and connections ‘between bus and rail lines. The
proposed Precise Plan amendments will encourage child care centers in these areas
by making them a permitted use on many of the sites. The child care center would
be permitted if it complies with recommended zoning standards for parking,
center did not comply with those standards because special mitigation measures
may be required. Site and architectural approval would also be required of all child
care centers to ensure design compatibility. The proposed Precise Plan amendmen’t,
also make child care centers a conditional use in many areas where they are
currently prohibited.
San Antonio Center Precise Plan
location, and outdoor play areas. A conditional use permit would be required if tht
Amendments to this Precise Plan would make child care a permitted use on all of
the San Antonio Center site as shown in Figure 8. Property owners and managers
of the San Antonio Center will have the final choice whether to lease a space to a
child care center.
San Antonio Station Precise Plan ,
Under the proposed amendments, child care centers would be a permitted or
, conditional use in most of the San Antonio Station area. The San Antonio Station
area is shown in Figure 9. Child care centers would be a permitted use in Areas B
and D (between Showers Drive and California Street) and a conditional use in Area
C (San Antonio Circle loop). In area C there are access constraints and potential
noise impacts from surrounding roadways that may require special mitigation
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Figure 8 bfO"EW CALIF01
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conditions. Child care would not :be permitted in Area A (the Old Mill *
Condominiums) because this area is already completely developed *with housing.
In addition to the new use standards, the proposed San Antonio Station
amendments would exempt child care facilities from building area and floor area
ratio restrictions. This may encourage some developers to include child care as pa:
of their projects, if they are allowed additional building area to accommodate this
use.
Downtown Precise Plan
The Environmental Planning Commission and the Downtown Revitalization
Committee have considered amendments to the Downtown Precise Plan to
encourage child care in this area. The Downtown Precise Plan area is shown in
Figure 10.
A last &nute issue was raised by some of the downtown businesses concerning thc
possible negative affect of child care centers on businesses that sell alcohol. Researc
on this issue was forwarded to the Revitalization Committee and they have made i
recommendation to the Planning Commission. This recommendation is schedule
to go to the Planning Commission on March 1 and make a recommendation to the
Counal for the March 28 public hearing. A resolution for amendment of the
Downtown Precise Plan is not included at this time,.but will be included for the
Counal public hearing on March 28, after the Commission makes a
recommendation.
The proposed Downtown Precise Plan amendments unanimously recommended b
the Revitalization Committee would allow child care as a conditional use in most c
the Downtown, except Area 1 and in ground level spaces fronting Castro Street. In
the Castro Street commercial area it is important to maintain an active storefront
that creates an engaging shopping, entertainment, and dining environment. As a
result, child care facilities were not considered a viable alternative in these areas. In
the other areas, child care could be an appropriate use, depending on the location, SI
a use permit process is proposed.
North Bayshore Precise Plan
A space camp is a possibility as part of a cultural/education use on the Farmer’s
Field site within the North Bayshore Precise Plan (refer to Figure 11). The proposed
Precise Plan amendments would make the dormitory portion of the space camp a
provisional use, rather than a permitted use.
>:
This change is being suggested because the dormitory portion of the space camp
could be considered a sensitive use under the recommended definition of highly
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-1. Figure 1. ’
I SITE LOCATIONS 1
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sensitive uses, A conditional use permit process would allow the City to atta
'speaal conditions that would help ensure the safety of overnight campers. Ii
also allow the City to determine the best location for the dormitories, so they
located as far from nearby companies as possible. This will help ensure the si
campers and minimize any impacts on adjacent industries.
Most of a space camp would not be considered a highly sensitive use for the'
following reasons: .
Campers are predominantly teenagers and at least 9 years old, so they are
,. highly sensitive to toxics like younger children in child care centers.
e * There is a higher adult to student ratio than other uses such as schools or
care centers, so this will make evacuation safer.
8 At the North Bayshore site, potential space camp operators have indicated
buses will be used to shuttle campers from the space camp to NASA/Ame
other tour locations, so there will always be buses on-site or close-by in cas
. evacuation is needed.
A dormitory use is different from the daytime use because evacuation may bc
difficult. There will be fewer adults on-site at night to supervise an evacuatic
will be dark and difficult to see, and overnight campers may not response qui
effectively if an emergehcy wakes them up in the middle of the night. For th,
reasons, the Commission is recommending that the dormitories be made a
provisional use to clearly indicate in the Precise Plan that special condihons a
locations may be required.
OTHER COMMISSION RECOMMENDATIONS
Child Care Fees
Currently, application fees for child care centers in Mountain View can be
substantial. In addition to the $1,000 use permit fee, new child care centers COI
also be required to get sign approval ($EO), complete an environmental asses!
($200-$600), and go through design review with the Site and Architectural Re\
Committee ($300 - $1,500). The total zoning application fees can range from $1
$2500.
The Planning Commission is recommending reducing fees for child care faalii
a way to promote child care in Mountain View. The Commission recommend
reducing the conditional use permit fee for family child care to $50 and for chi1
centers reducing fees to $100 for a conditional use permit and $50 for design re
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A reduction in fees for child care centers will not have a significant affect on the City‘s revenues due to the low number of applications for new child care centers.
Other Recommendations
The Planning Commission recommends that a child care center be encouraged in
the North Bayshore area, either on the Crittenden site or in Shoreline Park. The
Commission is also recommending that the City’s phone listings include a child
care infarmation number, so that residents have an easy reference to find child care
information.
Programs Considered But Not Recommended -
The Environmental Planning Commission considered several other possible
programs to promote child care in Mountain View, but decided not to recommend
these to the City Council. The Commission is not recommending that the City hire
a child care coordinator. The Child Care Committee made this same
recommendation to Council. Most of programs recommended by the Child Care
Committee have been successfully completed by existing City staff.
The Planning Commission also considered the possibility of recommending child
care incentives or bonuses and development assessments. An analysis of these
programs can be found in the August 17, 1994 staff report in the Background Binder.
The Commission is not r6commending these programs because they would
encourage larger, more intense projects, place an unequal burden on new .
development, and may not be legally justified’given the existing demand for child -
care services.
CONCLUSION
The Environmental Planning Commission has completed an in-depth study of land
use policies for child care facilities. The Commission’s study involved the
participation of child care providers, parents, and industry. The General Plan
policies, zoning revisions, and precise plan amendments recommended by the
commission seek to balance the need for child care in the community with
compatibility and safety concerns.
The recommended changes clarify zoning regulations for child care centers by
clearly stating in which zones they are permitted, conditional, or prohibited uses.
The Commission’s recommendations will make it easier for child care centers to be
established in many areas of the city and will establish a safety buffer between highly
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sensitive uses and acutely hazardous materials. The Council will be reviewin1
taking action.on the Commission's recommended General Plan, zoning ordin
and precise plan revisions at the March public hearing.
Prepared by: Approved by: JAY7 Linda Lauzze fi,G&@
laine Costello
Development
Senior Planner Director of Community
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Nadine Levin
Assistant City Manager
~Qpy-
Kevin Duggan
City Manager
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Attachments: Attachment 1-Zoning Ordinance Amendments -?
Attachment 2-General Plan Amendments
Attachment 3-San Antonio Precise Plan Amendments
Attachment 4-San Antonio Station Precise Plan Amendmen
Attachment 5-North Bayshore Precise Plan Amendments
Attachment &Negative Declaration
Attachment 7-Summary of Child. Care Regulations
26
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CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
. INIm STUDY
L DESCRIPTION OFPROJECT
A. Project Etle and Address:
Consideration of General-Plan text amendments and zoning ordinance revisions mnCer family child care, child care centers, and acutely hazardous materials. This project 7
have a citywide affect.
B. Application Number: -
1408 - 05 Child Care/Haz Mat
C Lead Agency Name and Address:
City of Mountain View, Community Development Dept., P.O.Box 749, Mm Wew, CA
D. Contact Person and Phone Number:
Linda Lame, (415) 9036306
E Project Sponsor's Name and Address: *
city of Mountain View, Community Development Dept., P.O.Box 7450, Mm. View, CA
*.
F. General Plan Designation and Zoning:
Not applicable.
G. Project Description:
This project involves General Plan text amendmentsand zoning ordinance revisions th
update the Cityls zoning ordinance concerning family child care facilities, provides
simplified procedures for child care centers in certain zoning districts, generally proh
sensitive uses, such as child care centers, in industrial zones or within 1,OOO feet of am
hazardous materials, and prohibits acutely hazardous materials within 1,000 feet of
sqnsitive uses, such as child care centers.
H. Location of Project:
This project would have a citywide impact and affects most zoning districts within
Mountain View.
L Other Agencies whose Permits or Approval is Required: None
a
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