2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
DTSC
is
the
regulatory
agency
with
oversight
of
remediation
within
this
portion
of
the
Project
site.
Although
the
groundwater
extraction
and
treatment
system
has
been
inactive
since
2008,
DTSC
has
approved
using
this
system
to
process
purge
water
and
rinsate
from
ongoing
investigations.
This
portion
of
the
Project
site
will
require
remediation
to
the
risk-based
health
standards
to
be
imposed
by
DTSC
for
this
area.
Prior
to
development,
the
groundwater
extraction
and
treatment
system
will
be
decommissioned
with
the
approval
of
the
regulatory
agency,
should
the
cleanup
goals
for
groundwater
already
be
met;
although
it
is
not
uncommon
for
such
systems
to
remain
in
place
post
development.
The
comment
does
not
raise
a
significant
environmental
issue
relevant
to
the
Draft
EIR’s
analysis
or
conclusions.
Historic
exposures
of
employees
are
not
indicative
of
existing
soil
and
groundwater
conditions
in
the
2010
baseline
year,
nor
are
they
an
impact
of
proposed
Project
site
development.
The
comment
does
not
raise
a
significant
environmental
issue
relevant
to
the
Draft
EIR’s
analysis
or
conclusions.
Plant
3
was
part
of
the
Schlage
Lock
facility
outside
of
the
Baylands
Project
site
in
San
Francisco.
The
Schlage
Lock
facility
was
expanded
by
the
acquisition
of
Plant
2
in
1942,
Plant
1-X
in
1946,
and
lastly
Plant
3
in
1950.
Schlage
Lock
was
acquired
by
Ingersoll-Rand
Corporation
in
1974.
The
manufacturing
process
included
stamping
and
machining
metal
alloys;
deburring
brass,
bronze,
nickel,
silver
and
steel
parts;
and
cleaning
brass
and
bronze
parts
with
Safety
Kleen
150,
a
petroleum
naphtha
solvent.
The
parts
were
electroplated
using
a
non-chrome
clear
coat
process
to
prevent
corrosion.
Zinc
dichromate
was
formerly
used
in
the
electroplating
process.
In
1980,
Plant
3
was
sold
to
Pacific
Lithograph
Company.
It
used
products
containing
trichloroethane
and
stoddard
solvent
in
lithographic
processing.
Pacific
Lithograph
declared
bankruptcy
in
January
1984.
Pacific
Lithograph
was
acquired
by
Touch-Plate
International
Corporation,
a
subsidiary
of
Schlage
Lock,
in
November
1995
through
bankruptcy
(DTSC).
No
factual
evidence
is
provided
to
support
the
assertion
made
in
the
comment.
During
the
site
investigations
and
remedial
activities
conducted
on
the
various
portions
of
the
site,
the
full
suite
of
analytes
has
been
run
by
laboratories
for
constituents
in
the
soil
matrix,
soil
vapor,
and
groundwater
underlying
the
site.
Remediation
to
date
has
focused
on
those
constituents
that
have
impacted
the
media
with
the
greatest
detected
concentrations.
Remediation
techniques
are
not
surgical,
and
constituents
other
than
those
targeted
in
remediation
activities
also
are
remediated
through
excavation,
extraction,
and
enhanced
reduction
remedial
techniques.
Brisbane
Baylands
Final
EIR
2.9.1-51
May
2015