2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
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
for
discussion
of
the
remediation
review
and
approval
process.
The
RWQCB,
which
has
regulatory
authority
for
remediation
of
has
not
approved
any
specific
remediation
technologies
to
date.
The
RWQCB
Conditional
Approval
Letter
dated
May
9,
2002,
which
was
specific
to
regarding
the
Conceptual
Remedial
Action
Plan
(Burns
&
McDonnell
2002),
sets
forth
eight
requirements,
including
but
not
limited
to
proposing
and
implementing
deed
restrictions
that
properly
address
the
residual
contamination.
Human
health
risk
assessments
are
used
to
derive
cleanup
goals
and
direct
remedial
actions
of
impacted
media
based
on
specific
land
uses,
since
cleanup
goals
can
be
to
either
residential
standards
or
to
commercial/industrial
land
use
standards.
See
for
discussion
of
the
remediation
review
and
approval
process.
Based
on
the
land
uses
determined
by
the
City
of
Brisbane
to
be
appropriate
for
the
Baylands,
the
RWQCB
and
DTSC
will
oversee
human
health
risk
assessments
that
will
form
the
basis
for
risk-based
cleanup
goals
that
would
be
used
in
updated
RAPs.
The
State
regulatory
agency
reviewing
and
ultimately
providing
approval
of
the
human
health
risk
assessments
and
update
RAPs
would
determine
whether
deed
restrictions
to
limit
uses
to
those
indicated
in
the
RAPs
were
warranted
based
on
the
cleanup
goals.
It
has
been
well
documented
in
the
literature
and
through
experience
at
individual
UST
release
sites
that
petroleum
fuels
(including
TPH
and
VOCs)
naturally
attenuate
in
the
environment
through
adsorption,
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).
Brisbane
Baylands
Final
EIR
2.9.2-86
May
2015