2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
This
comment
mischaracterizes
the
conclusions
of
the
Draft
EIR,
which
do
not
assert
that
groundwater
contamination
is
“harmless.”
It
has
been
well
documented
in
the
literature
and
through
experience
at
individual
UST
release
sites
that
petroleum
fuels
naturally
attenuate
in
the
environment
through
absorption,
dispersion,
dilution,
volatilization,
and
biological
degradation.
This
natural
attenuation
slows
and
limits
the
migration
of
dissolved
petroleum
plumes
in
groundwater.
The
biodegradation
of
petroleum,
in
particular,
distinguishes
petroleum
products
from
other
hazardous
substances
commonly
found
at
commercial
and
industrial
sites
(SWRCB
2012).
The
characteristics
of
UST
releases
and
the
California
UST
Program
have
been
studied
extensively,
with
individual
works
including:
(a)
Lawrence
Livermore
National
Laboratory
report
(1995),
(b)
SB1764
Committee
report
(1996),
(c)
UST
Cleanup
Program
Task
Force
report
(2010),
(d)
Cleanup
Fund
Task
Force
report
(2010),
(e)
Cleanup
Fund
audit
(2010),
(f)
State
Water
Resources
Control
Board
site
closure
orders,
and
(g)
State
Water
Resources
Control
Board
Resolution
2009-0081
(SWRCB
2012).
In
general,
these
efforts
have
recognized
that,
depending
on
concentrations
and
threats
to
drinking
water
supplies,
many
petroleum
release
cases
pose
a
low
threat
to
human
health
and
the
environment
(SWRCB
2012).
The
State
Water
Board
believes
it
is
in
the
best
interest
of
the
people
of
the
State
that
unauthorized
releases
be
prevented,
and
requires
such
releases
to
be
cleaned
up
to
the
extent
practicable
in
a
manner
that
protects
human
health,
safety,
and
the
environment.
The
State
Water
Board
also
recognizes
that
the
technical
and
economic
resources
available
for
environmental
restoration
are
limited,
and
that
the
highest
priority
for
these
resources
must
be
the
protection
of
human
health
and
environmental
receptors.
Program
experience
has
demonstrated
the
ability
of
remedial
technologies
to
mitigate
a
substantial
fraction
of
a
petroleum
contaminant
mass
with
the
investment
of
a
reasonable
level
of
effort.
Experience
has
also
shown
that
residual
contaminant
mass
usually
remains
after
the
investment
of
reasonable
effort,
and
that
this
mass
is
difficult
to
completely
remove
regardless
of
the
level
of
additional
effort
and
resources
invested
(SWRCB
2012).
See
for
discussion
of
the
remediation
review
and
approval
process
and
for
discussion
regarding
the
adequacy
of
existing
studies
for
use
in
the
Draft
EIR.
Please
also
see
Remediation
to
the
standards
set
by
the
DTSC
and
RWQCB
is
required
prior
to
physical
development
within
the
Project
Brisbane
Baylands
Final
EIR
2.9.1-58
May
2015