2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
Page
4.C-46
of
the
Draft
EIR
describes
the
SWPPP
mandate,
which
is
not
voluntary.
The
Draft
EIR
also
references
additional
requirements
and
performance
standards
such
as
on-going
maintenance,
including
identification
of
funding
for
long-term
monitoring,
maintenance
and
practical
applications
such
as
litter
collection
and
removal
that
would
be
required
to
be
established
prior
to
advancing
buildout
of
the
Baylands.
Mitigation
Measure
4.C-1e
require
s
the
SWPPP
to
ensure
“no
reduction
in
water
and
environmental
quality.”
The
South
Disposal
Area
is
discussed
in
greater
detail
in
the
Draft
EIR
on
pages
4.G-9
and
4.G-10.
During
an
investigation
in
1990,
the
former
railyard
was
separated
into
three
areas
of
concern
based
on
the
constituents
detected
in
the
soil
matrix
and
groundwater.
These
three
areas
were
labeled
as
(1)
the
north
area,
(2)
turntable
and
oil
tank
areas,
and
(3)
south
disposal
area.
The
south
disposal
area
is
described
as
a
former
solid
waste
disposal
area
and
was
characterized
by
elevated
concentrations
of
metals.
Regardless
of
what
may
have
been
disposed
at
this
location
or
what
years
such
disposal
may
have
occurred,
the
Draft
EIR’s
characterization
of
soil
contaminants
accurately
describes
conditions
in
the
baseline
year.
No
evidence
or
documentation
is
provided
to
support
the
assertion
in
the
comment.
Table
4.G-5
contains
an
accurate
list
of
the
maximum
detected
concentrations
of
constituents
in
groundwater
from
monitoring
wells
in
during
sampling
conducted
in
2008
and
reported
in
2010,
representing
baseline
conditions,
since
the
groundwater
contamination
remained
stable
between
2008
and
2010.
This
comment
refers
to
a
recommendation
cited
in
the
Draft
EIR
by
Burns
&
McDonnel
in
2002
that
a
silica
gel
cleanup
procedure
should
be
used
on
all
Total
Petroleum
Hydrocarbon
(TPH)
as
gasoline
within
Silica
gel
cleanup
is
used
for
cleanup
of
sample
extracts
containing
polynuclear
aromatic
hydrocarbons,
derivatized
phenolic
compounds,
organochlorine
pesticides,
and
PCBs,
using
silicic
acid
(silica
gel)
to
separate
hydrocarbons
and
polars.
The
term
“total”
petroleum
hydrocarbons
(TPH)
is
a
standard
term
used
in
the
oil,
refinery,
environmental,
and
regulatory
industries.
TPH
encompasses
the
totality
of
the
carbon
chain
ranges
from
C2-C55.
TPH
as
gasoline,
abbreviated
as
TPH-g,
represents
the
carbon
chain
range
C6-C12
(ALS
Environmental).
The
requirement
of
the
RWQCB
to
use
a
silica
gel
cleanup
procedure
on
all
TPH-g
samples
was
included
in
its
response
to
comments
to
the
proposed
2002
Conceptual
Remedial
Action
Plan.
See
13
for
discussion
of
the
remediation
review
and
approval
process.
The
RWQCB,
which
has
regulatory
Brisbane
Baylands
Final
EIR
2.9.1-53
May
2015