2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
impacts
of
providing
drainage
facilities
for
the
Baylands
have
been
analyzed
as
part
of
proposed
Project
site
development.
Monitored
Natural
Attenuation
is
a
remediation
strategy
for
groundwater
contamination
and
is
discussed
in
the
Hazards
and
Hazardous
Materials
section
of
the
Draft
EIR
on
page
4.G-83.
A
description
of
the
environmental
investigation
and
cleanup
activities
at
the
Recology
site
is
located
in
the
Draft
EIR
Hazards
and
Hazardous
Materials
chapter
on
page
4.G-54
and
4.G-55.
See
also
for
a
discussion
of
prevention
of
cross
contamination.
The
appropriate
process
for
ensuring
site-specific
analysis
and
implementation
of
BMPs
is
set
forth
in
Mitigation
Measure
4.H-
1a,
which
requires
that
“prior
to
issuance
of
a
grading
permit,
an
applicant
for
any
site
specific
development
project
to
be
constructed
within
the
Project
Site
shall
file
a
Notice
of
Intent
to
the
RWQCB
to
comply
with
the
statewide
General
Permit
for
Discharges
of
Storm
Water
Associated
with
Construction
Activities
and
shall
prepare
and
implement
a
SWPPP
for
construction
activities.”
The
BMPs
would
be
implemented
on
a
site-specific
basis
and
in
consideration
of
local
conditions
such
as
existing
contaminated
materials,
and
would
be
conducted
in
coordination
with
the
overseeing
agencies,
RWQCB
or
DTSC.
These
activities
would
be
adequate
to
minimize
any
offsite
transport
of
contaminants
such
that
an
individual
NPDES
permit
beyond
what
is
already
required
under
the
Construction
General
Permit
would
not
be
necessary.
In
addition,
construction
activities
would
be
required
to
adhere
to
the
City
of
Brisbane’s
Municipal
Regional
Stormwater
Permit
Order
No.
2011
-0083
Provision
C.3
as
well
as
all
provisions
of
the
Erosion
and
Sediment
Control
Plan.
With
implementation
of
these
existing
regulatory
requirements
both
at
the
state
and
local
level,
the
potential
for
construction
activities
to
result
in
significant
water
quality
impacts
would
be
reduced
to
less
than
significant
levels.
To
clarify
the
site-specific
nature
of
the
SWPPP,
Mitigation
Measure
4.H-1a
is
revised
to
read
as
follows:
Mitigation
Measure
4.H-1a:
Prior
to
issuance
of
a
grading
permit,
an
applicant
for
any
site
specific
development
project
to
be
constructed
within
the
Project
Site
shall
(1)
file
a
Notice
of
Intent
to
the
RWQCB
to
comply
with
the
statewide
General
Permit
for
Discharges
of
Storm
Water
Associated
with
Construction
Activities
and
shall
prepare
and
implement
a
site-specific
SWPPP
for
construction
activities
on
the
Project
Site
in
accordance
with
the
NPDES
General
Construction
Permit
and
the
(2)
demonstrate
compliance
with
the
City
of
Brisbane’s
Municipal
Regional
Stormwater
Permit
Order
No.
2011-0083
Provision
C.3.
The
site-specific
SWPPP
shall
include
all
provisions
of
the
Erosion
and
Sediment
Control
Plan
submitted
as
part
of
grading
and
construction
permits.
In
addition
to
meeting
the
regulatory
requirements
for
the
Brisbane
Baylands
Final
EIR
2.9.1-95
May
2015