2.
Response
to
Comment
2.4
Master
Responses
to
Comments
indicates
that
additional
evaluation
of
potential
environmental
concerns
at
a
site
is
warranted
(RWQCB,
2013).
The
screening
level
risk
assessment
conducted
for
the
Kinder
Morgan
RAP
included
a
review
of
potential
sensitive
receptors
onsite
and
in
the
site
vicinity,
and
a
comparison
of
current
detected
petroleum
hydrocarbon
and
fuel
oxygenate
concentrations
to
the
appropriate
pathway-specific
ESLs
defined
by
the
RWQCB.
The
pathways
of
exposure
analyzed
for
the
site
in
the
2007
RAP
included
volatilization
from
groundwater
to
indoor
air
for
onsite
buildings,
direct
contact
with
soil
and
groundwater
by
site
construction/maintenance
workers,
ingestion
of
groundwater,
and
discharge
of
groundwater
to
sensitive
ecological
habitat
(LFR,
2007).
These
pathways
were
chosen
based
upon
the
site’s
existing
industrial
land
use.
The
RAP
concluded,
and
the
RWQCB
confirmed,
that
at
the
time
of
RAP
preparation
there
were
no
unacceptable
health
risks
for
the
identified
exposure
pathways
based
on
the
current
land
use.
In
April
2008,
the
RWQCB
approved
Order
No.
R2-2008-0019,
which
required
immediate
implementation
of
the
RAP,
with
the
purpose
of
remediating
soil
and
groundwater
contamination
caused
by
releases
from
the
facility
to
a
level
protective
of
human
and
environmental
health
and
beneficial
uses
of
water
resources
considering
current
and
reasonable
future
land
and
water
uses.
The
screening
level
risk
assessment
conducted
for
the
RAP
was
evaluated
by
the
RWQCB,
which
determined
that
the
screening
level
risk
assessment
was
appropriate
for
the
tank
farm
(RWQCB,
2008).
The
RWQCB
established
specific
groundwater
cleanup
standards
for
onsite
and
offsite
groundwater
that
is
impacted
by
petroleum
fuel
hydrocarbons
released
from
the
tank
farm
site.
Although
no
current
groundwater
use
has
been
identified
and
no
plans
for
future
groundwater
use
have
been
proposed,
the
RWQCB
determined
that
the
potential
for
future
groundwater
use
in
the
vicinity,
including
for
drinking
water
from
deeper
water-bearing
zones,
should
not
be
precluded.
Therefore,
applicable
water
quality
objectives
for
Tank
Farm
groundwater
remediation
include
drinking
water
standards,
which
are
the
more
stringent
of
United
States
Environmental
Protection
Agency
and
State
of
California
primary
maximum
contaminant
levels.
Cleanup
to
this
level
will
protect
all
existing
and
potential
future
beneficial
uses
of
groundwater
(RWQCB,
2008).
The
RWQCB
order
also
declared
that
an
updated
health
risk
assessment
would
be
required:
If
data
indicate
that
reasonable
potential
human
or
ecological
exposures
exist
as
determined
by
SFPP
or
RWQCB
staff;
Upon
presentation
of
a
credible,
specific
reuse/redevelopment
plan
to
the
RWQCB
and
SFPP
by
the
property
owner
for
areas
immediately
adjacent
to
the
site
where
potential
offsite
impacts
exist;
or
Upon
any
actual
or
proposed
material
change
to
the
facility
as
determined
by
SFPP
or
RWQCB
staff.
The
health
risk
assessment
prepared
in
the
2007
RAP
was
updated
in
a
2014
Remedial
Action
Effectiveness
Evaluation
by
comparing
the
2013
RWQCB
environmental
screening
levels
to
the
Brisbane
Baylands
Final
EIR
2.4-59
May
2015