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HomeMy WebLinkAboutPD Comments Table (2)Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 1 CHEVRON TANK FARM PROJECT Comments on the EIR Draft Project Description Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses GENERAL COMMENTS County Jeff Oliveira 1 Cover page Thinking we should title the project “Chevron Tank Farm Remediation and Redevelopment Project” County Jeff Oliveira 2 Universal comment Order of the PD sections seem confusing and counter intuitive. Need to reorganize order of the subsections to make the flow of the PD smoother and easier to follow. Should start with an Introduction, followed by Location, Background/History, Setting, then get into the body of the PD (starting with the remediation project, followed by the City and County development options). As it reads now, it seems disconnected. County Jeff Oliveira 3 Universal comment In general, the PD is very narrative and to detailed. I think we need to break up the discussions with bullet lists, tables, etc. Although this is a technical project, the language should be geared towards a reader with general knowledge. Technical information should be in an appendix for reference, and the body of the PD should be written with the reader in mind. This comment translates to every section in the PD. Have added bullets and tables as needed. Technical language has been updated. Detail needed for environmental review. There will be an Executive Summary. County Jeff Oliveira 4 Universal comment I noticed that color graphics were included on even-numbered pages. Color graphics should be on odd pages, with a blank page following to ensure that printed documents have color graphics on their own page. County Jeff Oliveira 5 2-1 1st Get rid of the term “underutilized”…it’s a value statement. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 2 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses County Jeff Oliveira 6 2-1 2nd Add a reference to a graphic after introducing the Flower Mound so the reader knows where it is. Type-o in the last sentence…”in order to break up and access this material.” County Jeff Oliveira 7 2-1 4th First sentence could be removed. Should start the paragraph off with a discussion on how we ended up with 2 lead agencies. County Jeff Oliveira 8 2-3 2nd Edit first sentence to read “This EIR evaluates the remediation project which would occur under County jurisdiction, as well as both the City and County development options with suitable alternatives.” City Brian Leveille 9 Transp. Comment: It may be helpful to list Remediation as a phase for clarity. City Utilities Division 10 2-39, 2-39, 2-43 The draft states that “…grading and remediation would take 2.5 years” pg. 2-37), and development would take place “…over a 25-year period” page 2-39) or “…in five development phases in 20-25 years” (page 2- 43). 1) Are these concurrent activities (i.e. would any development schedule overlap the remediation schedule)? 2) Would the annexation take place with the approval of the project prior to remediation activities? Chevron Team 11 2-1 1 Project site is 332 acres not 340 acres based on County Assessor’s information (correct globally). Chevron Team 12 2-1 3 Change “commercial and industrial land uses” to “business park or service commercial” This change was not made as it does not reflect the proposed uses appropriately. Chevron Team 13 2-1 4, line 1 Please change first sentence to read: “There are additional areas that could be developed on the Project Site; Sentence has been revised by City and County comments. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 3 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Chevron Team 14 2-1 4, line 6 The City has already authorized to negotiation of a DA. They have not however approved or adopted a DA. Chevron Team 15 2-1/2-3 The principal purpose of dual processing is to allow Chevron to move forward with remediation in a manner that does not limit the development alternatives. The Development Agreement and subsequent annexation are subject to negotiation with the City, and may extend over a considerable length of time. However, permitting and completion of the entire grading plan in the County requires a submittal of a development project. Chevron Team 16 The EIR needs to address the Restoration Plan at some level. It should incorporate as objectives on-site mitigation and the concept of functional increase rather than a strict “in-kind” ratio for replacement. Another consideration is including at least the flood management components. To the degree that Chevron is willing to commit to incorporating the grading aspects, those should be included in the project description. Bill 17 n/a n/a Please add the Project Objectives that we sent along a few months back to the PD in an appropriate location. Part of Section 1. Introduction Bill 18 n/a n/a Please add a history/chronology of the City, County, and airport land use area planning process (e.g., when the project site was first identified by the City for annexation, evaluation by the City in the AASP, etc.) to an appropriate location of the PD. Bill 19 n/a n/a I think it would be helpful to outline in an appropriate section of the PD how the AASP has been, for the most part, guiding the applicant’s development proposal and to discuss, and even bullet out, those areas where their proposal is not entirely consistent with the AASP. Bill 20 2-1 1 Please add a regional level location graphic. 2-1 is a macro, 2-2 is micro, and it would be good to have one that shows the project site in the context of the City, airport, etc. Reference the new graphic in the text. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 4 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 21 2-3 1 Somewhere in this paragraph I think it would be helpful to add a discussion describing the other reason Chevron is pursuing dual City/County) CEQA and land us permit processing (i.e., if they do obtain a Development Agreement with the City and annexation is imminent, they would also like to obtain a CUP/grading permit from the County so that they can start the remediation/grading process while the City is still working on the annexation process. This way when annexation is complete they will be ready to go, having completed remediation, with the City Development Scenario.) Bill 22 n/a n/a In general I find it helpful if figures that have been referenced for the first time, say on page 2, follow on page 3 or somewhere closely thereafter. In some instances, the reader needs to go digging for graphics. Bill 23 n/a n/a The section on hauling of NHIS to the Santa Maria Landfill is a bit thin. Please add a lot more detail as this will be a very important issue (use your Guad SEIR for guidance). Also, the discussion on hauling will need to outline hauling of hazardous material (or NHIS for that) to other landfills. Chevron has mentioned that they want these contingencies covered in the EIR. Bill 24 n/a n/a Some graphics (e.g., 2-5 and 2-6) are pretty grainy and hard to read at the 11x8½ size and may be better as 11x17. If you have to squint to read road names and other key features, this is probably a good litmus test. Perhaps some the hazy graphics can remain 11x8½ if lettering of key features is re-done. Some graphics were re-created, others should be printed 11x17. Bill 25 n/a n/a In general, the project description would benefit by some editing that taking the perspective of the layperson being exposed to this very technical and complex project for the first time. I’m sure that there are other comments by the review team regarding “pigging” and other terminology, but please also take a more holistic approach to addressing this comment. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 5 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 26 n/a n/a After having read draft project description, I felt that incorporation of sections of the applicant prepared materials may have been a bit too wholesale (particularly the remediation related materials). If you could please do an edit from the perspective of “objectifying” their work and removing any applicant-induced “conclusionary” statements that may lead the reader that what they’re proposing is a done deal. Bill 27 n/a n/a When referring to land use documents (e.g., AASP), please preface with the agency who owns that document (e.g., the “City’s AASP”). Bill 28 n/a n/a Both the City and the County Development Scenarios need to provide more detail relating to the sports fields. This may take coordination between MRS and Chevron and Chevron is going to need to decide what they are willing to include with these sports fields (e.g., lights, bleachers, etc.). Right now Chevron is trying to take the approach that they just want to get a blob on the site plan approved and then turn the sports fields” over the Cal Ripken Little League association. This won’t work because we need to look at the whole of the action and all that neat CEQA stuff. Bill 29 n/a n/a A large part of the remediation process involves restoration of habitat. Please include a description of the habitat restoration being proposed by Chevron – to a similar level of detail as the other proposed project components. The 75% Restoration Plan would be a good source for pulling pertinent information. Bill 30 n/a n/a Along the same lines as comment #28, a component of the proposed project is to try and put Tank Farm Creek back to an alignment and cross-section resembling its former state. This includes a new culvert under Tank Farm Road. This all should be described as well. Bill 31 n/a n/a I’m sure you’ve done this, but please re-review Chevron’s kick-off meeting power point for ideas, graphics, and information that will help round-out and complete the project description. Bill 32 n/a n/a Please include the Grading Plan, Roadway layout, and Tract Map plates as graphics. Also, the Chevron kick-off meeting powerpoint contains numerous cross-sections of the various types of caps proposed as part of remediation. These would make good graphics in the PD. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 6 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 33 n/a n/a Please include a description of the RWQCB’s perspective on the project i.e., due to Chevron’s collaboration on the SERRT and RTP there’s no Clean-up or Abatement Order, a tentative agreement has been reached on the approach outlined in the RAP, etc.). Bill 34 n/a n/a In an appropriate location please add a brief discussion of the exiting netting located over the various features that pose ecological risk. See Section 2.1.2 Current Conditions Bill 35 n/a n/a There are graphics that show proposed areas of disturbance as well as hydrological and restoration improvements. As part of Chevron’s proposed project, these should be shown and text should be included describing these aspects of the project. Bill 36 n/a n/a This may not be the appropriate section of the EIR, but somewhere, perhaps the Introduction, there needs to be a discussion (and likely a table) outlining the various permits required by other agencies such as the RWQCB and Environmental Health. Included in this discussion I think it would be good to bring to light the status of the RAP (i.e., it hasn’t been “approved” yet by the RWQCB), when and how it would be approved, and what would happen if other nasty materials (not covered in the RAP) are discovered and determined by the RWQCB to need to be remediated. “Approved” might not even be the right term - maybe it should be “certified”. Bill 37 n/a n/a Somewhere in this section, a listing of the critical documents prepared thus far (e.g., Risk Management Study, Feasibility Study, RAP, etc.) should be laid-out. In addition, describe how these documents relate to each other (how the FS lead to the RAP), how the RAP will eventually be ratified by the RWQCB through their own process depending on the conclusions reached in the EIR and on what project the City or the County approve. Section 1. Introduction Bill 38 n/a n/a The project description will get longer and more complex after responding to everyone’s comments. That’s okay, that’s typically how the County, and likely the City in this case, like it. Given that will be the case, I think that additional sub-headings pulling out individual topics of discussion will be warranted so that throughout the EIR process when we’re having to refresh our memories on the many facets of the project, we’ll be able to easily reference key discussions. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 7 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses 2.1 BACKGROUND AND CURRENT SITE OPERATIONS County Jeff Oliveira 39 2-3 Section 2.1 is a discussion of the project location and the current site setting. This should be reorganized into a separate location section with reference to the appropriate graphics. Existing setting should be separate too. County Jeff Oliveira 40 2-3 Section 2.1.1 Point of clarification…Was the site used to transport oil from the valley, or to the valley? County Jeff Oliveira 41 2-5 Section 2.1.2 Need to add a discussion of the Flower Mound, wetlands, Tank rings, currently paved areas (former recycling center), etc.…a complete characterization of the site. Chevron Team 42 2-3 1 The parcel numbers listed in our project description have since been changed. The correct numbers are: 076-351-037, -040, and -041, 076- 352-061 & 062, 076-381-021, 076-382-005, 076-383-001 & 002. Chevron Team 43 2-3 1 MRS should note the TTM’s prepared by RRM as information for the development alternatives Chevron Team 44 2-3 2.1, line 8 Use “ mobile home park “ instead of “trailer park”. In the following sentence place a period after the word “operations”, delete the word but” and capitalize the word “they”. Chevron Team 45 2-4 2.1.1, first line There were 21 tanks built during the original construction. Only 15 tanks were present in 1926. Chevron Team 46 2-4 6 The bottoms of reservoirs 2 and 7 were ripped by Unocal in the mid 1990s in an attempt to deter water accumulation within the bottom of the reservoirs. . Chevron Team 47 2-5 2.1.2, first line Delete the word “current” and replace with “existing” – these buildings are not currently being used. Chevron Team 48 2-5 2.1.2, line 6 Change the reference to a “trailer park”. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 8 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Chevron Team 49 2-5 2.1.2, 3rd paragraph, last line Chevron no longer occupies the buildings as they did when reports were submitted so references as existing field offices throughout the document should be removed or edited i.e. “and serve the ongoing operations” can be deleted. Chevron Team 50 2-6 2.1.2, 3rd paragraph, first line Add the word “recently” between the words - which and extended, or alternatively indicate the year the runway was extended. Chevron Team 51 2-6 2.1.2, 3rd paragraph, line 4 Give context to “originally proposed” to indicated that this was development shown in the AASP adopted in Aug., 2005 not a prior version of the current proposal. Chevron Team 52 2-6 2.1.2, 4th paragraph, 3rd line Change the word “traveling” to “visiting the site”. Chevron Team 53 2-5 Sec. 2.1.2, 2nd paragraph Include a discussion of the sewer line recently constructed along Tank Farm Road by the City of San Luis Obispo. Bill 54 2-3 1.5 between 1 and 2) Would be helpful to list the name and address of both Chevron entities constituting the project applicant (Bill Almas, Chevron Business…., and Marlea, Chevron Remediation….”). Bill 55 2-3 2 Last sentence, please use proposed instead of slated and demolition instead of decommissioning. Bill 56 2-4 1.5 between 1 and 2) Please add a brief description of whether oil flowed off-site during the 1926 fire, if so how much, low levels of detection by RWQCB on off-site properties (according to D. Kukol & K. Di Simone during last SERRT meeting), and why at this time it has been determined remediation not necessary off-site. RWQCB Communication stated they have no record of oil flowing out of the site Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 9 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 57 2-5 3 Figure 2-2 only references North Marsh and not other wetlands and grasslands mentioned in the sentence leading up to this reference. Did not see any other marsh/wetlands that are specifically named. There are other wetlands, but these are not named as the “north marsh” is. Wetlands delineation has been left for the impact baseline section of bio. Bill 58 2-6 3 Sentence 3 mentions safety zones. Either the text in this part of the PD or the graphic that is referenced should discuss what these safety zones are all about. This doesn’t have to be in detail, but generally. A more detailed discussion of safety zones could be referenced in whatever section of the EIR it will show up in later. Bill 59 2-6 3 Last sentence. I think I mentioned this in the general comments, but PD should include list of proposed AASP amendments. In this case of this part of the PD, maybe it could reference a more detailed list and discussion in Section 2.5.1.1. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 10 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses 2.2 PROPOSED REMEDIATION ACTIVITIES County Jeff Oliveira 60 2-6 Section 2.2 Most of this discussion is background and history. Should be included in a separate Background/History Section. Not really, build up to the remediation project: Why cleanup levels set where they are. See comment #33. County Jeff Oliveira 61 2-9 2nd Sounds like this paragraph should be under a new subheading titled Regulatory and Jurisdictional Agency Involvement”. Be sure to include a discussion of each agency involved, related back to the efforts of the SERRT, and their role in the project. Overall, should stress agency review and oversight to ensure the readers know that the agencies have been involved at each step. County Jeff Oliveira 62 2-9 4th First sentence refers to “voluntary” process. Should delete references to voluntary” process. It gives the impression that Chevron wouldn’t be doing this project otherwise, when the agencies would be requiring this project regardless. County Jeff Oliveira 63 2-10 Section 2.2.1.1 1st paragraph Add “to ensure against off-site migration of petroleum products” at the end of the first sentence. County Jeff Oliveira 64 2-10 Section 2.2.1.1 2nd paragraph We talk here about monitoring, but leave out any reference to a response plan. What happens when monitoring results in discovery of something that needs attention? SERRT Agencies should provide information or Chevron RFI. Reopener and further action Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 11 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses County Jeff Oliveira 65 2-13 4th First sentence…are we referring to the Santa Maria land fill? Should be specific here. County Jeff Oliveira 66 2-13 5th Last couple of sentences refers to measures that should be required mitigation measures in the EIR. Applicant proposed mitigation. County Jeff Oliveira 67 2-14 End of Section 2.2.2 This section introduces the remediation project. In addition to introducing the OUs, it should also stipulate… “In addition to remediation of the operable units, site restoration also includes: Building and structural demolition Pipeline decommissioning Miscellaneous clean up Borrow area excavations Site grading, and monitoring Changed Section and subsections and added an introductory paragraph. County Jeff Oliveira 68 2-15 Universal comment: discussion under the Operable Units are very tech- y. Reader could easily get bogged down in details that could be in an appendix. Format is too narrative. Should be broken down into bullet points. For example, the 2nd paragraph discussing land use for for OU#1 could be done like this: Land Use Designations: Operable Unit #1 City County Detail needed for environmental review. Executive Summary will provide a summarized version. County Jeff Oliveira 69 2-15 3rd Abbreviation “bgs” used but not defined County Jeff Oliveira 70 2-15 6th Need a better discussion under Section 2.2.2.1 that makes it clear that each OU contains several AOCs. This could be done with formatting. As we continue to break up the site into more and more detailed areas, it can get confusing. Not all OUs contain AOCs. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 12 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses County Jeff Oliveira 71 2-23 Section 2.2.2.6 1st paragraph Delete “and it is possible that building demolition could precede implementation of the proposed Project.” This was a request that Chevron made that was denied. This is a good example of cut-and-paste from documents drafted by the applicant…we need to be careful about incorporating too much text from the applicant. County Jeff Oliveira 72 2-23 Section 2.2.2.6 Overall, this section contains a lot of impact assessment that should be in the body of the EIR analysis. This is a universal comment…need to keep impact assessment and mitigation recommendations out of the PD. This is applicant proposed mitigation or actions. County Jeff Oliveira 73 2-24 2nd Use of the word “pigged” is not defined until later County Jeff Oliveira 74 2-26 Section 2.2.2.8 Good example of a section that could be shortened Edited as appropriate, information appeared needed County Jeff Oliveira 75 2-28 6th Delete second sentence starting with “This abundance…” County Jeff Oliveira 76 2-31 2nd, 3rd First sentence states that the Flower Mound is 17.3 acres. The map says that the Flower Mound is 55.1 acres. First sentence in the 3rd paragraph states that the Flower Mound contains 328,250 cubic yards. This doesn’t match what is indicated in the Figure 2-8. Universal Comment: need to make sure all numbers in tables match the information in the maps and graphics County Jeff Oliveira 77 2-31 Flower Mound discussion Need to introduce the blasting procedures here. This is an important piece of the project and we should have details here about how blasting would occur. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 13 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses County Jeff Oliveira 78 2-33 Section 2.2.3.3 Too wordy. Should make use of Table 2-3. Hard to tell if this discussion is what is included in Table 2-3. Need to cross-reference and summarize. Keep the details in the Table 2-3, and just briefly summarize in narrative while referencing the numbers in the table. Edited some, however, this is different from Table 2.3. City Brian Leveille 79 2-36 2.2.4 Under Table 2.4 & 2.5, add “for remediation phase” to employee requirements and equipment requirements. Transportation comment. City Brian Leveille 80 2-37 2.2.4 Table 2-6, please clarify table. Transportation planner did not understand the chart. Specifically, please provide background on headings (Peak Trips Per Day, Average Daily Traffic, Peak Hour Trips). Transportation Comment. This table has been reworked to provide additional detail for each phase and to address only peak day and annual/total trips City Brian Leveille 81 2-39 2.2 Nat. Resources Comment: There needs to be some discussion about the long-term disposition of the open space portions of the property. I suggest the following or something like it: “The long-term ownership and management of the property is uncertain at this time, however, it is expected that the open space portions of the property will be deed- restricted or otherwise dedicated to open space uses in perpetuity. The City of San Luis Obispo has indicated an interest in both fee or easement ownership, provided that the site remediation has been accepted as complete by the jurisdictional agencies and some form of management endowment has been, or could be, created. Other possibilities are continued Chevron ownership together with a managing entity, or some form of nonprofit organization ownership.” Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 14 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses City Utilities Division 82 2-23 Building and Structure Demolition. 4th paragraph. Both City and County require diverting 50 percent of demolition debris which could be mentioned here. This will be included as mitigation or regulatory requirements in the appropriate impact section of the EIR City Utilities Division 83 2-27 Utilities. “The Contractor would be responsible for determining the adequacy of water supply and for making any upgrades to the supply infrastructure.” It is not clear what activities are being described here. It sounds as though it has not been determined what water supply or infrastructure is needed to support the project’s remediation efforts. It is also unclear whether any contaminated water would be a product of the remediation effort and how it would be disposed. Public Utilities Section of the EIR will analyze this. Chevron Team 84 2-6 1 The opening paragraph requires revision. It reads as though the remediation will include actions concerning deep soil and groundwater. The overall findings of the SERRT and RTP need to be discussed, and that those documents have focused the remediation and restoration efforts to a few essential elements that can be shown in a bullet list, with more detailed discussion in the subsequent text. In that context Figure 2- 5 is somewhat misleading. It is accurate as a reflection of the entire site characterization, but not as to the elements relevant to remediation. Chevron Team 85 2-13 2.2.1.2, 5th paragraph Insert the word “Internal” as the first word of the first sentence. In the 3rd line insert the word “proposed” prior to “Tank Farm Road crossing”. Chevron Team 86 2-15 2 Area “OU1” should be identified as “service commercial” not commercial” and only occurs in the northwest operations area not the entire northwest portion of the project site. Chevron Team 87 2-20 After bullets, 1st line Delete “were identified” Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 15 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Chevron Team 88 2-20 4th full paragraph, line 2 Delete the word “original” and use “existing” Chevron Team 89 2-22 4th paragraph Delete last sentence. “Land use restrictions may also be required on adjacent Betita property……. This was included in the RAP, is this changing and if so, how would the Betita property be remediated? Chevron Team 90 2-23 2.2.2.6, 1st paragraph, line 2 The word “historical” should be changed to “former” in describing the tank farm operations. Chevron Team 91 2-23 2.2.2.6, 1st paragraph Chevron personnel have already been removed from the site. Chevron Team 92 2-23 2.2.2.6, 5th paragraph, 4th line This should read 4 inches. Chevron Team 93 2-25 4th paragraph, last line properly disposed of or recycled.” Delete “by Chevron” at the end of the sentence. Chevron Team 94 2-34 2 Insert the word “area” after the word stockpile and after the word paved” in the 1st sentence. Chevron Team 95 2-38 3 The geosynthetics will accommodate up to 2-feet of settlement in the reservoir. The resulting strain in the geosynthetic is less than 6-inches. Chevron Team 96 2-39 1 In the last sentence, the covenant will be finalized prior to title transfer or transfer of ownership. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 16 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 97 2-6 2 This may be a good location to insert discussion of off-site release of oil and contaminants as a result of 1926 fire and subsequent site activities. Per RWQCB, there is no record of offsite releases. Bill 98 2-6 2 After reading this paragraph, I got to thinking it would be helpful to the layperson and others to specify (maybe using a table) if this stuff (e.g., PCB’s, PAH’s, etc.) is super bad, not so bad, concentrations identified by regulators as exceeding thresholds vs. concentrations identified on the site, and even examples of what these things are typically found in e.g., pesticides, paint thinner, whatever). Not really the role of the PD to characterize the levels of contamination at the site. This will be done in the hazards/risk section of the EIR Bill 99 2-7 n/a This is an example of a figure with somewhat fuzzy labeling that could be improved. Some figures have been recreated. Bill 100 2-9 5 This section seems it would be best concluded with a discussion and a bulleted list of all the key plans guiding remediation/restoration and the applicant’s proposal and any others that are discussed in subsequent sections of the PD. Per General Comment #36 above, this may be a good location to provide a very brief summary of what these plans entail or cover. See Section 1.0 Introduction Bill 101 2-10 2 References to Attachment A begin here. Is seems that Attachment may become on Appendix in the DEIR. This is okay as a long as the there’s a specific reference to the actual graphic and the reader doesn’t have to go digging through 15 figures. Also, it may be worthwhile to pull key graphics from “Attachment A” and include them in the PD. There are many graphics in Section 2. The attachment has a TOC to facilitate locating figures. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 17 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 102 2-10 3 First sentence, refer the reader to the more detailed discussion of long- term monitoring and caps in later sections of the PD. Bill 103 2-11 n/a Figure 2-4: The airport overlay feature drowns out the most of the important underlying features and the project site itself is a little too hard to pick up. Graphics should be a little more user friendly (e.g., tone down airport overlay, beef-up project site boundary, etc.) Bill 104 2-13 1 Include birds as well in first sentence. Bill 105 2-13 2 Sentence two: Is it okay to use solid asphaltic hydrocarbon as common earth backfill? Why wouldn’t they haul this off-site as non-hazardous hydrocarbon impacted soil (NHIS)? This is the Applicant Proposed project blessed by the SERRT. Impact section will determine if this is acceptable or not. Bill 106 2-13 5 Sent 1: Access routes (add “to the project site”) have been chosen….. This refers to internal routes within the site. Bill 107 2-13 5 Add figure and/or reference to figure showing Tank Farm Road and proposed routes on site and crossing TF road. Bill 108 2-13 5.5 Good location to include additional sub-heading (e.g., Off-site hauling of material) Bill 109 2-13 6 Non-hazardous Hydrocarbon Impacted Soil (NHIS). Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 18 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 110 2-13 6 This paragraph/section should include much more detail on the hauling component of the project (e.g., approximate quantities of NHIS and other materials, routes to SML with figures showing routes, Chevron’s request to use other facilities besides SML and their location and proposed routes, type of trucks, will the trucks be covered, time of day they’ll be hauling, etc.). See Guad SEIR for hauling discussion level of detail. Bill 111 2-14 2 Good location for generic cap cross-section figure reference. Figures showing cap cross sections have been added. Not all cap descriptions have cross section figures on the Chevron info. Bill 112 2-14 4 A point of first referencing something like the Feasibility Study, please list its complete title followed by an abbreviated version of the title in parenthesis if that’s the choice for following references. Bill 113 2-14 n/a Table 2-1: Table should include “n/a” instead of “-“and also include spelling-out of LNAPL in footnotes. Bill 114 2-15 2 Sentence one should reference appropriate land use figure. Bill 115 2-15 3 End of Sent 4: 28 feet bgs…. Should include figure reference. Bill 116 2-16 1&2 After “AOC#1” references please specify whether both on- and off-site. I think it should be off-site. Bill 117 2-16 5 End of sentence 2, provide reference to a figure showing a “cap”. Cap figures have been added. AOC#2 does not have a cap cross section figure in the Chevron info. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 19 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 118 2-16 5 Last sentence – refer to Attachment A comment above. The figure that is vaguely referenced here would likely be helpful to have in the body of the PD. Cap figures have been added. AOC#2 does not have a cap cross section figure in the Chevron info. Bill 119 2-17 n/a Might be better as an 11x17. Some figures have been increased to 11x17 size. Bill 120 2-18 1 Last sentence: please reference a figure. Bill 121 2-18 5 Sent. 1: Add……future commercial development “for both the City and the County”. Also, reference appropriate figures at the end of this sentence. Bill 122 2-19 4 Sent. 2: This is a confusing sentence, please re-word or elaborate. Bill 123 2-20 1 In discussions of OU’s, please always use their number. Bill 124 2-20 2 Sent. 1: delete “were identified”. Bill 125 2-20 4 Sent 4: Add “of” Bill 126 2-20 6 Sent 1: Reference section of PD that describes NHIS disposal. Bill 127 2-21 2 Sent 2: Provide clarifying discussion describing whether or not wetlands would be on top of cap(s) or not. Bill 128 2-21 2 Sent 4: Reference section of PD that describes NHIS disposal. Bill 129 2-21 3 Spell-out VPFS if it hasn’t already earlier in PD. Also, below this “fairy shrimp” is used. Please be consistent throughout. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 20 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 130 2-21 5 Sent. 1: Instead of “The proposed Project” please state “The remediation of OU #4/AOC #3”…. Bill 131 2-22 3 Sent. 1: Would be good to reference figure showing OU#5 monitoring wells. Bill 132 2-22 3 Sent. 3: List the reservoirs where the LNAPL is located. Bill 133 2-22 3 Sent. 4: Instead of “property” please use “Project Site”. Check throughout. Bill 134 2-22 6 In this paragraph it would be good to note that Chevron has no remediation plans off-site and to also reference the section regarding off- site contamination that I’ve asked be included in the PD. See comment #97 an #89. Bill 135 2-23 1 Chevron is out of the buildings in the NW Operations area and has been now for over a year. Please edit all references to Chevron personal being removed from the site….. throughout the PD Bill 136 2-23 Last bullet After “Other Areas” please include “(e.g., list one or two)” Bill 137 2-24 2 Provide a layperson friendly discussion before using the term “pigging”. You can describe the process and say “known as “pigging””. Bill 138 2-26 n/a Show areas of “Miscellaneous Cleanup” on a figure. Bill 139 2-26 3 Second to the last sentence reads weird. Bill 140 2-27 2 Show Staging areas on a figure and reference figure. Bill 141 2-27 n/a Sub-heading “Utilities” should probably be something like “Construction Water Supply” Bill 142 2-27 6 Remove reference to employees needing to be moved in Sent. 1 and provide a reference to the proposed location of the project site. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 21 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 143 2-28 1 Sentence 2: Use “Project Site” instead of “the Tank Farm” and please check the rest of the PD for alternative uses such as these. Bill 144 2-29 n/a Figure 2-7 maybe better as an 11x17. Bill 145 2-31 2 Provide a better introduction to the Flower Mound (e.g., The area referred to in Figures xx and xx as the Flower Mound is an area proposed by Chevron to be used for…………) Bill 146 2-32 1 North Marsh instead of North Wetland Bill 147 2-32 6 Last sentence references “importing topsoil from off-site sources”. There should be a separate section dedicated to Chevron’s proposal on this that describes where these sources are likely to be located (tying into trucking and numerous issues such as AQ, Safety, and Noise), quantity, etc. Would be picked up in detail under the issue areas. Bill 148 2-34 1 Sentence 2 sounds like it was written by Chevron (e.g., ….so a small amount of hydrocarbon residue ….would not be problematic), please edit. Bill 149 2-34 2 First sentence should read “A secondary stockpile location has been identified on the south side of Tank Farm Road…..” and a figure reference would be helpful. Bill 150 2-34 3 Please re-word to sound less like it was written by Chevron. Bill 151 2-34 Bullets Why is only Borrow Area #2 referenced and what about the Flower Mound? The FM will be needed for assessing visual impacts. Bill 152 2-36 1 Use Project Site instead of San Luis Obispo Tank Farm, use “shows” instead of “presents” and “requirements” instead of “spreads”. These type of inconsistencies make the PD read like it was written by numerous people. Bill 153 2-37 3 Add “-“ to semiannually. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 22 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 154 2-38 8 “proposed Project” might read better if it is “Proposed Project” throughout. Bill 155 2-39 1 Change Tank Farm property to Project Site and search throughout for any other such uses. 2.3 CITY DEVELOPMENT PLAN County Jeff Oliveira 156 NA City Brian Leveille 157 2-40 2.3.1 Should areas shown for right of way (14 acres) also include bike paths? City Brian Leveille 158 2-42 2.3.1 Transportation commented that nothing was found describing phasing shown in Figure 2-10. Are they proposing to widen Tank Farm in phases? Phasing is shown in Figures, no additional detail has been provided. City Brian Leveille 159 2-43 2.3.2 Transportation commented, second and third paragraphs under this section seem contradictory. We should make this more clear that remediation would have already occurred prior to construction phases and the equipment listing under table 2-7 is only for the site development phases. City Brian Leveille 160 2-44 2.3.3 Transportation commented, “Is the Table 2-8 consistent with the rates used in the AASP?” No rates were found after checking the AASP and the AASP EIR City Utilities Division 161 2-39 City Development Plan. Related to question 1 above (refer to general comments), this section includes the language “after closure.” Would all proposed development occur after the proposed remediation activities are complete? Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 23 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses City Utilities Division 162 2-40 (last bullet) The City would provide water, recycled water, sewer, and public services… The City completed the installation of a sewer trunk line in Tank Farm Road along the property’s frontage. Chevron would extend the water and recycled water mains and utilities to the developable areas.” Similar text is included a few places, see below. City Utilities Division 163 2-43 and 2-44 City Development Option Operations. This section states “Water use rates are based on water use factors provided by the City of San Luis Obispo Utilities Department.” If the consultant utilizes the attached table for the applicable portion of Table 2-8 this will be a true statement. Our estimate of 72.06 AFY are lower than the estimate in the draft and we included demand for the Recreation land use type. Another land use type for streetscape could also be added if the acreage was known. It would be a portion of the 14 acres identified as “Streets” within Table 2- 12. Not sure about this comment. The number used is applicant provided and more conservative. Analysis in the corresponding issue area of the EIR should take care of this. City Utilities Division 164 2-44 Similar to my comment above on page 2-40, page 2-44 under Table 2-8, The City would provide water, recycled water, sewer, and public services… The City completed the installation of a sewer trunk line in Tank Farm Road along the property’s frontage. Chevron would extend the water and recycled water mains and utilities to the developable areas.” Chevron Team 165 2-39 2.3, 3rd Add “limited retail” to the list of allowable uses Chevron Team 166 2-43 2.3.1, top The City option does not “require” a Development Agreement. Chevron is seeking this. Chevron Team 167 2-43 2.3.2, 1st The meaning of this paragraph is unclear. How does “arranging” to use the site determine the phasing? Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 24 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Chevron Team 168 2-43 2.3.2, 3rd, second sentence Change the word “achieved” to “completed”. There appears to be a word missing, the sentence should end “with each phase of construction”. Bill 169 n/a n/a Sheet C-8 of the applicant’s proposal includes shows the Santa Fe Road extension. Please provide more detail on this and other roadway improvements as well as accompanying figures where appropriate. Bill 170 2-39 1 First Sent., instead of “after closure” say “upon completion of remediation”. Bill 171 2-39 2 Project Site instead of Tank Farm Bill 172 2-39 3 Project Site instead of property (please also check this throughout the PD and look for other uses like “site”). Would just like to see consistency. Bill 173 2-39 6 Airport AASP is redundant Bill 174 2-39 6 Be more specific than “AASP compliments”. Also see Tank Farm in last sentence (use Project Site). Bill 175 2-39 8 Sent. 3: clarify that it was “originally proposed in the AASP” Bill 176 2-40 2 “9 acres of developable area” Bill 177 2-40 n/a Pretty much throughout this entire section additional figure references would be helpful. Bill 178 2-40 3 Would be good to use a table to show both number included in this paragraph as well as others. Bill 179 2-40 4 Retail Space information is probably best suited in first bullet describing Business Park. Bill 180 2-40 4th bullet Add discussion regarding Chevrons Cal Ripken plans or refer to another section of the PD where this ends up getting more flushed out. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 25 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 181 2-40 Last bullet Add Road to Tank Farm. Bill 182 n/a n/a Sheet C-8 of the applicant’s proposal includes shows the Santa Fe Road extension. Please provide more detail on this and other roadway improvements as well as accompanying figures where appropriate. 2.4 COUNTY DEVELOPMENT OPTION City Brian Leveille 183 2-45 2.4.1 The AASP is a City Document, but if developed in County we would bring it up to date with current info. Chevron Team 184 2-45 2.4.1, 2nd Cattle grazing is anticipated to continue in open space areas under either the City of County alternatives. Chevron Team 185 2-45 2.4.1, 1st bullet Add “including limited retail sales” Chevron Team 186 2-45 2.4.1, last paragraph The AASP is a City document. The AASP will be amended by the City, subsequent to adoption of the plan by the County. Bill 187 n/a n/a Applicant Figure C-3 shows the location of the proposed wastewater treatment facility. Please include a figure showing the WWTF and also include details of this piece of infrastructure (e.g., will there be ponds, is it an enclosed system, will it be housed in a building, etc.?). These are all questions that will come up and need to be addressed at some point. If Chevron is serious about the County scenario being viable, they need to flush (pardon the pun) this out further. APPLICANT RFI— This is all we have. Bill 188 2-44 4 Last sentence: should end with “to serve the County Development Scenario” Bill 189 2-44 5 Project Site instead of former……. Bill 190 2-45 2 Last sentence ends with Chevron opinion/language (i.e., “which is more suitable for development”), please edit. Bill 191 2-45 3 Project Site instead of Tank Farm Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 26 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Bill 192 2-45 3 Add figure reference. Bill 193 2-45 4 Would cattle grazing be included in the City Development Scenario as well? I don’t remember seeing this discussed. Bill 194 2-45 4th bullet Add figure reference Bill 195 2-45 5 A Development Agreement is not part of the County option. Bill 196 2-46 1 Project Site instead of Project area Bill 197 2-46 n/a With respect to water use rates shown in table, is the operation of a WWTF under the County Scenario taken into consideration? Bill 198 2-46 n/a Table 2-10: I think it will raise questions if there isn’t a similar table shown in the City Scenario. 2.5 PROJECT PERMITTING REQUIREMENTS County Jeff Oliveira 199 2-47 Section 2.5 Should included a subheading for “Other Agency Permit Requirements” and summarize all of the other permits needed. City Brian Leveille 200 2-47 Page 2-47, second paragraph, end of line 3: Replace “difficult to develop” with “is considered inappropriate for development”… City Brian Leveille 201 2-49 2.5.1.1 Add that elimination of the collector road also includes removal of underlying planned utilities. Transportation comment. City Brian Leveille 202 2-49 2.5.1.1 Provide more detail on proposed amendments to the Bicycle Plan. Transporation comment RFI NOT SURE ABOUT THIS— Agencies should provide? Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 27 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses City Brian Leveille 203 2-50 2.5.1.5 The City does not have a CUP requirement for grading. Grading would only be approved in conjunction with approved construction plans. We should probably add the required Architectural Review Commission ARC) entitlements which would be required for public improvements to start, and then subsequent development phases and/or individual proposed buildings would require architectural review. City Brian Leveille 204 2-52 2.5.2.4 There is no proposed development agreement with the County City Utilities Division 205 2-49 Add a bullet under the second bullet related to the Unocal Collector that states “Realigning the sewer trunk line located within the collector street’s right of way to avoid the environmentally sensitive northwest area;” or similar language. City Utilities Division 206 2-50 “The City would provide water, recycled water, sewer…” City Utilities Division 207 2-50 Pre-Zoning and Annexation. Similar to my comments above, “With annexation, the City would provide water, recycled water, sewer, and public services… The City completed the installation of a sewer trunk line in Tank Farm Road along the property’s frontage. Chevron would extend the water and recycled water mains and utilities to the developable areas.” Chevron Team 208 2-47 2.5.1.1,2nd Adoption of the proposed plan for the Chevron Tank Farm property will require concurrent and/or subsequent amendment of the AASP. The City of San Luis Obispo has agreed to be the lead agent in accomplishing the required amendment. Chevron Team 209 2-47 2.5.1.1, 4th Typo – change “Plane” to “Plan” Chevron Team 210 2-49 Table 2-12 Insert AASP after the word “existing” in the title of the Table Chevron Team 211 2-50 2.5.1.5 Should this paragraph differentiate the “development grading” from the remediation grading? Chevron Team 212 2-51 2.5.2.2, 3rd Re-word 1st sentence so the “adjacent” property is identified as the parcel west of the former operations area. Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 28 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses Chevron Team 213 2-52 2.5.2.3 See comment on pg 2-50, 2.5.1.5, above. Chevron Team 214 2-52 2.5.2.4 This comment as written is applicable to the City not the County and therefore seems misplaced 215 2-47 4 Plan instead of Plane 216 2-49 n/a I would be helpful to show at least the significant proposed Specific Plan Amendments on a figure and reference these figures. 217 2-49 Bullet 2 Project Site instead of property 218 2-49 Bullet 8 This is confusing in that I don’t know what is trying to be conveyed. 219 2-49 Bullet 9 Show and reference plan. 220 2-50 1 “It is understood” sounds like applicant writing. 221 2-50 2 Add TTM graphics and reference 222 2-50 5 Project Site instead of site 223 2-50 5 Sent. 4: revise per comment above. 224 2-50 7 Sent. 2: add “financial” after long-term 225 2-50 7 Project Site instead of property Chevron Tank Farm EIR Draft Project Description Comments SWCA Environmental Consultants 29 Respondent Comment No. Page No. ¶ No. City/County/Applicant Comments MRS Responses 226 2-51 n/a Please add discussion of sports field somewhere in the County project discussion. This section is for permits needed, Recreational fields are discussed under the proposed County Project. 227 2-52 1 Sent. 2: should be San Luis Obispo Area Plan 228 2-52 1 Sent 3: state why development is being moved from the NW corner (i.e., so as to avoid sensitive habitat….). 229 2-52 2 Please reference tract map figures somewhere in this paragraph. Added, but low quality. Will need to be reworked. 230 2-52 4 This may be the location to include the detailed description of the WWTF referenced in the General Comments above. Depending on the WWTF’s design, this could be a point of interest to the SLOCRA as well as others. APPLICANT RFI Kim Murry* KM-09 Please change Operable Units to something that makes more sense to the lay person? The document references the RAP, Execution Plan and a number of other studies that rely on this nomenclature. It would be very difficult to change that at this stage. All other edits by Kim Murry were submitted under separate cover and have been addressed in the document.