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Comment 33: This comment is also from a letter prepared by Smith Engineering and Management, and <br />states that encountering contaminated groundwater during Project excavation must be considered. The <br />comment states that the Draft EIR describes that the depth of groundwater is in the range of 24 to 33 feet <br />below ground surface (bgs), which is not consistent with the RWQCB No Further Action letter for the Project <br />site, which states that groundwater is at depths of 5.67 to 13 feet deep. In addition, the comment states <br />that The EIR needs to plan for protection of construction workers who may encounter contaminated <br />groundwater when excavation is conducted. Furthermore, the comment states that the letter was prepared <br />based on limited documentation regarding the Project. <br />Response 33: As described previously In Response 18, groundwater levels on the site have fluctuated <br />between 1986 and 2019. However, in the case that groundwater is encountered during Project <br />construction, it would be treated and discharged pursuant to RWQCB requirements. Also, as described in <br />Responses 14 and 16, the federal Occupational Safety and Health Act Safety and Health Regulations for <br />Construction contains requirements for construction activities, including health and safety plan(s). In addition, <br />the CalOSHA required Injury and Illness Prevention Program (IIPP) would maintain worker safety related <br />to potentially contaminated groundwater. Thus, implementation of construction pursuant to existing <br />regulations as ensured through the permitting process would reduce potential impacts related to <br />construction workers who may encounter contaminated groundwater when excavation is conducted to a less <br />than significant level. <br />75C-120 <br />