2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
former
Schlage
Lock
facility,
groundwater
was
remediated
using
pump
and
treat
technology
in
1995
through
1998
and
was
replaced
with
in-situ
treatment
of
groundwater,
and
a
soil
vapor
extraction
and
treatment
system
was
installed
in
1999
and
operated
through
2008.
Volatiles
and
solvents
in
groundwater
would
have
been
remediated
using
the
pump
and
treat
technology.
The
in-situ
groundwater
treatment
applied
to
the
groundwater
underlying
consisted
of
enhanced
reductive
dechlorination
and
was
found
effective
when
the
chlorinated
solvents
were
at
high
concentrations
in
the
groundwater
and
less
effective
when
the
chlorinated
solvents
were
at
lower
concentrations
in
the
groundwater.
Although
no
current
groundwater
use
has
been
identified
and
no
plans
for
future
groundwater
use
have
been
proposed,
in
its
review
of
groundwater
contamination
related
to
the
Kinder
Morgan
tank
farm
site,
the
RWQCB
determined
that
the
potential
for
future
groundwater
use
in
the
vicinity,
including
for
drinking
water
from
deeper
water-bearing
zones,
should
not
be
precluded.
Therefore,
applicable
water
quality
objectives
for
tank
farm
groundwater
remediation
included
drinking
water
standards,
which
are
the
more
stringent
of
United
States
Environmental
Protection
Agency
and
State
of
California
primary
maximum
contaminant
levels.
Cleanup
to
this
level
will
protect
all
existing
and
potential
future
beneficial
uses
of
groundwater
(RWQCB,
2008).
Additionally,
as
is
under
the
oversight
of
the
DTSC,
cleanup
of
the
affected
media
will
be
overseen
and
approved
by
DTSC.
See
for
discussion
of
the
remediation
review
and
approval
process
and
for
discussion
regarding
the
adequacy
of
studies
for
use
in
the
Draft
EIR.
As
part
of
the
remediation
of
the
DTSC
will
review
existing
studies
for
and
require
preparation
of
a
human
health
risk
assessment
based
on
the
land
uses
determined
by
the
City
of
Brisbane
to
be
appropriate
for
the
Baylands.
The
DTSC
will
then
set
risk-based
cleanup
goals
appropriate
those
land
uses.
Remediation
and
achievement
of
the
risk-based
cleanup
goals
set
by
the
DTSC
for
will
be
required
prior
to
any
development
within
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
Brisbane
Baylands
Final
EIR
2.9.2-85
May
2015