2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
See
for
discussion
of
the
adequacy
of
the
existing
studies
for
use
in
the
Draft
EIR.
See
also
for
discussion
of
the
remediation
review
and
approval
process.
Any
chemicals
found
in
a
previous
study
at
concentrations
potentially
constituting
a
health
risk
would
be
required
to
be
evaluated
in
updated
human
health
risk
assessments,
and
to
be
remediated
to
risk-based
health
standards
should
the
health
risk
assessment
determine
the
existence
of
a
health
risk.
The
first
environmental
assessment
of
fill
was
conducted
in
1982
and
included
collection
of
soil
and
groundwater
samples.
Groundwater
in
1982
was
submitted
for
analysis
of
semi-volatile
organic
compounds
(SVOCs)
in
addition
to
volatile
organic
compounds
(VOCs)
and
metals.
An
additional
investigation
was
conducted
in
1985.
Groundwater
in
1985
was
submitted
for
SVOCs,
VOCs,
and
metals;
SVOCs
were
not
detected.
Subsequent
investigations,
with
the
exception
of
the
Kleinfelder
1987
investigation,
focused
on
VOC
and
metals
contamination
in
soils
and
groundwater.
As
of
2010,
the
groundwater
monitoring
program
around
the
landfill
has
included
analysis
of
SVOCs
in
addition
to
VOCs,
metals,
and
other
constituents,
from
20
groundwater
monitoring
wells
and
two
leachate
wells.
SVOCs
were
not
detected
in
the
deep
groundwater
monitoring
wells,
were
detected
at
stable
concentrations
in
the
shallow
wells
and
at
trace
concentrations
in
the
leachate
monitoring
wells.
The
comment
provides
no
factual
evidence
to
support
the
claim
that
“the
characterization
of
the
landfill
is
incomplete.”
See
for
discussion
regarding
adequacy
of
the
existing
studies
for
use
in
the
Draft
EIR.
Kleinfelder
(1987,
1990)
concluded
the
shallow
groundwater
was
not
influenced
by
tidal
action,
and
deeper
groundwater
at
the
location
of
the
well
tested
appeared
to
have
some
discharge
to
the
Bay.
Therefore
the
conclusion
is
reached
that
tidal
influence
on
leachate
recharge
is
less
than
significant
because
the
solid
waste
received
by
the
landfill
was
placed
on
top
of
the
earthquake
rubble
that
was
placed
on
top
of
the
marine
sediments.
Because
the
former
landfill
ceased
operations
in
1967,
interactions
between
groundwater
and
leachate
would
have
been
apparent
by
the
time
of
these
studies
Groundwater
gradients
are
variable
depending
upon
onsite
location.
The
direction
of
groundwater
gradient
is
reported
as
radial
outward
from
the
center
of
the
northern
tank
farm,
north-northeast
toward
the
tree-lined
channel
in
the
northern
portion
of
the
site,
westward
along
the
eastern
portion
of
the
site
and
southeast
along
the
south
and
southeastern
portion
of
the
site.
Dr.
Lee
has
identified
the
limitations
of
the
state
of
existing
environmental
science
and
technology.
These
Brisbane
Baylands
Final
EIR
2.9.1-31
May
2015