Pier 36 - Environmental Assessment and FONSI

Environmental Assessment and

FONSI

for the

Pier 36 Demolition Project

San Francisco, San Francisco County, California

U.S. Army Corps of Engineers San Francisco District

September 2011

Pier 36 Demolition Project Army Corps of Engineers San Francisco District

September 2011 i

Table of Contents

1.0 Introduction

1.1 Purpose

1.2 Document Structure

2.0 Proposed Project

2.1 Project Description

2.1.1 Location

2.2 Authority

2.3 Purpose and Need for Proposed Action

3.0 Scope of Analysis

4.0 Proposed Action and Alternatives

4.1 Proposed Action (Agency-Preferred Alternative)

4.2 No-action Alternative

4.3 Alternatives Considered and Eliminated

5.0 Impact Assessment

5.1 Water

5.2 Habitat

5.3 Biological Resources

5.4 Air Quality

5.5 Geology and Soils

5.6 Noise

5.7 Recreation

5.8 Transportation

5.9 Aesthetics

5.10 Land Use

5.11 Utilities

5.12 Safety and Hazardous Materials

5.13 Cultural and Historic Resources

5.14 Irreversible Changes and Cumulative Effects

6.0 Summary of Indirect and Cumulative Effects from the Proposed Action

7.0 Environmental Compliance

8.0 Agencies Consulted and Public Notification

9.0 Mitigation Measures

10.0 Determinations and Statement of Findings

11.0 References

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Appendices

Appendix A: Environmental Compliance

A.1 NMFS Species List A.2 USFWS No Affect Determination A.3 NMFS Essential Fish Habitat Consultation A.4 NMFS BO Letter and ESA Incidental Take Statment A.5 SFRWQCB 401 Water Quality Certification A.6 BCDC Consistency Notification A.7 SHPO 106 Memorandum of Agreement

Appendix B: Finding of No Significant Impact

Appendix C: Avoidance and Minimization Measures C.1: Avoidance and Minimization Measures for Impacts to Water Quality

C.2: Avoidance and Minimization Measures for Impacts to Birds during Nesting Season C.3: Avoidance and Minimization Measures for Listed Species C.4: Historic Preservation Mitigation Measures

Appendix D: Sediment Testing Analytical Results

Appendix E: Agency and Public Participation

Appendix F: Preparers

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Figures

Figure 1: Pier 36 Project Vicinity Map Figure 2: Pier 36 Site Location Figure 3: Marginal Wharf Substructure Figure 4: Collapsed Wharf Extension Figure 5: Pier 36 and Marginal Wharf Section Demolition Plan Figure 6: Brannan Street Wharf Site Plan

Tables

Table 1: Special Status Species and Habitats Potentially Occurring in the Action Area Table 2: Pier 36 Demolition Project Emissions Analysis Table 3: Summary of Environmental Compliance

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Acronyms and Abbreviations

BA ..........................................Biological Assessment BAAQMD ..............................Bay Area Air Quality Management District BCDC .....................................Bay Conservation and Development Commission BMPs......................................Best Management Practices BO ..........................................Biological Opinion CAA .......................................Clean Air Act CCC........................................California Coastal Commission CD ..........................................Consistency Determination CDFG .....................................California Department of Fish and Game CCR........................................California Code of Regulations CEQ........................................Council on Environmental Quality CFR ........................................Code of Federal Regulations CNDDB..................................California Natural Diversity Database CO ..........................................Carbon Monoxide CO2 .........................................Carbon Dioxide CSLC......................................California State Lands Commission CWA .....................................Clean Water Act dBA ........................................A-weighted Decibels EA ..........................................Environmental Assessment EFH ........................................Essential Fish Habitat EIR .........................................Environmental Impact Report EIS..........................................Environmental Impact Statement ESA ........................................Endangered Species Act FONSI ....................................Finding of No Significant Impact GHG .......................................Greenhouse Gases HABS .....................................Historic American Building Survey HAER .....................................Historic American Engineering Record MHHW ..................................Mean Higher High Water MLLW ...................................Mean Lower Low Water MOA ......................................Memorandum of Agreement MSFCMA ..............................Magnuson-Stevens Fishery Conservation and Management Act N/A .........................................Not Applicable NEPA .....................................National Environmental Policy Act NHPA .....................................National Historic Preservation Act NMFS .....................................National Marine Fisheries Service NOX ........................................Nitrogen Oxides OSHA .....................................Occupational Safety and Health Administration PAHs ......................................Polycyclic Aromatic Hydrocarbons PCB ........................................Polychlorinated biphenyl PM2.5 ......................................Fine Particulate Matter PM10 .......................................Coarse Particulate Matter PRC ........................................Public Resources Code SAP ........................................Special Area Plan SHPO .....................................State Historic Preservation Officer

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SFBAAB ................................San Francisco Bay Area Air Basin SFRWQCB ............................San Francisco Regional Water Quality Control Board SO2 .........................................Sulfur Dioxide SOMA ...................................South of Market District USACE ..................................United States Army Corps of Engineers USC ........................................United States Code USEPA ...................................United States Environmental Protection Agency USFWS ..................................United States Fish and Wildlife Service USGS .....................................United States Geological Survey WRDA ...................................Water Resources Development Act

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1.0 INTRODUCTION

1.1 Purpose

The U.S. Army Corps of Engineers (USACE), in coordination with the Port of San Francisco, proposes to demolish and remove the existing, dilapidated Pier 36 along the San Francisco, California waterfront. This environmental assessment (EA) is written in compliance with the National Environmental Policy Act (NEPA) of 1969 (42 U.S.C. § 4321 et seq), as amended, the Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of the NEPA (40 C.F.R. §§1500-1508), and USACE Planning Regulations (Engineering Regulation (ER) 200-2-2). It presents an evaluation of the potential impacts associated with the proposed demolition and removal of the existing Pier 36 and reasonable alternatives to the proposed action.

1.2 Document Structure

Section 1.0 introduces the purpose and structure of this EA. Section 2.0 provides an overview of the proposed action, project location, and purpose and need. Section 3.0 describes the scope of the analysis in terms of space and time. Section 4.0 presents a detailed description of the proposed action, introduces alternatives to the proposed action evaluated in this document, and discusses additional alternatives that were considered but eliminated from further analysis.

Section 5.0 contains the impact assessment for the proposed action and alternatives to the proposed action. Section 6.0 summarizes the indirect and cumulative effects of the proposed action. Section 7.0 details additional environmental compliance requirements and actions associated with the proposed project. Section 8.0 identifies agencies and interested public that have been notified of the availability of this EA for review and comment. Section 9.0 describes mitigation measures associated with the proposed project and Section 10.0 summarizes USACE’s findings with regard to the potential level of impact of the proposed project. Finally, Section 11.0 contains document references.

2.0 PROPOSED PROJECT

2.1 Project Description

Pier 36 was originally built in 1909 for use as a freight rail facility for the Western Pacific Railroad to transport rail cars loaded with freight on barges across the San Francisco Bay to and from Oakland (San Francisco Planning Department 2011b). After the rail facility operation ceased in the 1960’s, the pier was used for ship repair, light-industrial, and warehouse for approximately 20 years (San Francisco Planning Department 2011b). Currently Pier 36 and its associated structures are in a state of disuse and disrepair. A timber wharf extension once constructed at the east end of the pier and used for the freight ferry operations has collapsed into the Bay. The warehouse structure is in a dilapidated condition from neglect, corrosion, and extensive vandalism. In 2004, the majority of the bulkhead wharf sections and the north apron of Pier 36 were condemned because of their severely deteriorated condition and lack of structural integrity (San Francisco Planning Department 2011b).

The USACE San Francisco District, in coordination with the Port of San Francisco, proposes to demolish and remove the existing, dilapidated Pier 36. The proposed action would involve deconstruction and removal of the existing Pier 36 warehouse, the pier structure and supporting

September 2011 2 piles, remnants of the collapsed wharf extension, and sections of the marginal wharf adjoining the pier to the San Francisco Embarcadero. The Pier 36 Demolition project would begin in January 2012 and is expected to take approximately five months to complete.

2.1.1 Location

Pier 36 is located in San Francisco City and County, California, on the San Francisco Bay waterfront. The pier sits four blocks south of the San Francisco Oakland Bay Bridge at a longitude and latitude of 122°23'13.34"W and 37°47'1.07"N (Figure 1).

Figure 1. Pier 36 Project Vicinity Map (USACE 2011a)

The Pier 36 site (San Francisco Assessor’s Block 9900, Lot 034, 036) is located between Pier 30- 32 and Pier 38 directly fronting the east side of waterfront street, the Embarcadero. The site is in proximity to the intersection of Brannan and Townsend Streets with the Embarcadero, within the South of Market (SOMA) district of San Francisco (Figure 2).

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Figure 2 – Pier 36 Site Location (San Francisco Planning Department 2011)

The project site contains the existing Pier 36; Pier 36 warehouse building; marginal wharf Sections 11a, 11, and 12; collapsed wharf extension debris; and the adjacent waters of the San Francisco Bay (the Bay). Pier 36 is approximately 200 feet wide by 740 feet long and extends perpendicularly from the Embarcadero. The existing deck, not including the collapsed wharf extension, is an approximately 86,000-square-foot, steel and concrete structure extending approximately 310 feet and supported on 350-to-400, 42-inch-diameter concrete cylinders (caissons). Atop this platform sits the concrete Pier 36 warehouse building of approximately 35,000 square feet. The collapsed wharf extension debris, which includes an additional 350-to- 400 creosote-treated piles, totals approximately 47,000 square feet of debris. Including the remnant piles and debris from the wharf extension that has collapsed into the Bay, the total square footage of the Pier 36 infrastructure is 133,000 square feet (3.24 acres) and the total number of existing caissons and piles is approximately 700-800 (half caissons and half remnant creosote-treated piles). Marginal (Bulkhead) wharf Sections 11a, 11, and 12 are constructed of concrete and steel and supported on a mixture of caissons and non-creosote-treated wood piles encased in concrete. Between the southern edge of Pier 32 and the northern edge of Pier 38, the marginal wharf is approximately 940 feet in length and 20 feet wide (18,800 square feet; see Figure 5).

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2.2 Authority

Authority for the proposed action was delegated to USACE in the Water Resources Development Act (WRDA) of 2007. Under section 5051 of this act, Congress authorized USACE to “carry out the project for repair and removal, as appropriate, of Piers 30-32, 35, 36, 70 (including Wharfs 7 and 8), and 80 in San Francisco, California, substantially in accordance with the Port’s redevelopment plan.”

2.3 Purpose and Need for Proposed Action

Pier 36 was originally constructed in 1909 and used for rail freight operations until 1960 after which it was industrially and commercially used until the 1980s. Subsequently, the pier has remained unoccupied and unmaintained. In 2004, the north apron of Pier 36 along with the majority of the marginal wharf structure between Piers 30-32 and Pier 38, was condemned because of severely deteriorated deck and pilings (Figure 3). Since then, the marginal wharf and pier have been fenced off from access because of the public safety risk posed by their instability.

Figure 3. Marginal wharf substructure (Port of San Francisco 2010)

The wharf extension at the end of the pier has collapsed, leaving approximately 47,000 square feet of wooden debris and 350-to-400 creosote-treated piles in an area of San Francisco Bay trafficked by commercial and recreational vessels (Figure 4).

Figure 4. Collapsed Wharf Extension (Port of San Francisco 2010)

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The proposed action is necessary to prevent potential damage to vessels from this navigational hazard and is consistent with the authority delegated to USACE by Congress in WRDA 2007 which allows for repair or removal, as appropriate, of specified piers along the San Francisco Waterfront including Pier 36 (see Section 2.2 - Authority). The action is proposed to be undertaken now in accordance with the needs expressed by the Port of San Francisco in their redevelopment planning efforts, as further mandated by the authority delegated in WRDA 2007.

Evaluation of the additionally specified piers for repair or removal, as appropriate, will be carried out in the future substantially in accordance with the Port’s redevelopment plans.

The primary objectives of the proposed action are to:

Eliminate the navigational hazard to commercial and recreational marine traffic posed by this unstable infrastructure and debris.

Achieve the elimination of these hazards in a manner consistent with the Port’s redevelopment plans

Additionally, the remnant pilings at the east end of Pier 36 are made of creosote-soaked timber that has the potential to leach petroleum contaminants into the water column which degrade water quality and are toxic to marine organisms. The proposed action provides a significant beneficial opportunity to remove this potential source of water quality contaminants and toxicity.

3.0 SCOPE OF ANALYSIS

The scope of this project analysis is limited in time and space by the reasonably foreseeable direct, indirect, and cumulative impacts of the proposed action. The action area for this analysis includes Pier 36, the collapsed wharf extension, the portions of marginal wharf Sections 11a, 11, and 12 between Pier 30-32 and Pier 38, and a 40-foot-wide work zone into San Francisco Bay along the perimeter of Pier 36 and the marginal wharf. Staging areas will be located on Pier 36 itself or on marine barges within the work-zone. The proposed action area, as calculated from aerial photography, is a total of approximately 6.50 acres (USACE 2011). For certain potential impacts, such as construction-related noise, the scope of analysis also includes adjacent commercial and residential properties surrounding the Pier 36 site. Additionally, the scope of analysis incorporates evaluation of potential cumulative impacts associated with future projects reasonably foreseeable to occur within the vicinity of the action area as of July 2011.

4.0 PROPOSED ACTION AND ALTERNATIVES

This section describes the proposed action and the no-action alternative, under which no new action would be taken. The agency-preferred alternative is identified. Other alternatives that have been considered and eliminated from further consideration are discussed.

4.1 Proposed Action (Agency-Preferred Alternative)

The agency-preferred alternative (proposed action) is to demolish and remove the existing Pier 36, collapsed wharf extension debris, and associated marginal wharf from the San Francisco Bay waterfront. The proposed action is expected to begin in January 2012, take approximately five months to complete, and would be conducted during normal working hours (7 AM to 6 PM).

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The proposed action would demolish and remove the existing 35,000-square-foot Pier 36 warehouse building, 86,000-square-foot concrete pier, approximately 350-to-400 supporting caissons, and 18,800 square feet of marginal wharf (including 178 feet of the southern end of Section 11a, the entire 353-foot Section 11, and 337 feet of the northern end of Section 12).

Additionally, the proposed action would remove approximately 47,000 square feet of debris, including the 350-to-400 remnant creosote-treated piles, that remains from the timber wharf extension, which has partially collapsed into the bay at the east end of the pier (Figure 5).

Prior to demolition, a survey of the Pier 36 warehouse building would be conducted for hazardous materials including but not limited to lead, asbestos, PCB- and mercury-containing equipment (including elevator equipment), hydraulic oils, and fluorescent lights. Any hazardous materials discovered would be abated from land according to federal, state, and local laws and regulations and appropriately handled and disposed of at permitted facilities. After proper abatement of any hazardous materials, demolition and removal of the existing Pier 36, collapsed wharf extension debris, and the identified sections of marginal wharf would be conducted from the water using a barge-mounted marine crane or from land using a crawler crane. It is expected that the following construction equipment would be used daily on site throughout the majority of the proposed action: six industrial concrete saws, two to three crawler cranes (one on land, one to two barge mounted), one excavator, one rubber-tired loader, two signal boards, two loaders or backhoes, two dump barges, and up to five dump trucks.

The Pier 36 warehouse building would be demolished followed by the Pier 36 platform and marginal wharf. The approximately 350-to-400 caissons supporting the pier would be removed

Figure 5. Pier 36 and Marginal Wharf Section Demolition Plan (Port of San Francisco 2011)

September 2011 7 using a derrick barge and excavator and, if structurally possible, by a crane that would be positioned on the existing deck of Pier 36 (using additional support plates). The caissons would be rocked back and forth to free the bell-shaped end and then lifted using the derrick or crane.

Caissons that break off would be removed to two feet below the mud line leaving any lower part of the bell in place. It is expected that approximately eight caissons per day would be removed.

The additional debris and 350-to-400 creosote-treated piles from the collapsed wharf extension would also be removed during the proposed action. The piles do not contain a bell-shaped end and many have already collapsed beneath the water surface, thus they are not expeced to require rocking and will be lifted out using the excavator and derrick barge. The piles would also be removed to at least two feet below the mud line.

During demolition, floating timber mats, formed by numerous pieces of timber joined together and then fixed in place with rope, would be deployed beneath the existing overwater structures to catch falling debris and prevent it from entering the water. Dump barges or dump trucks would be used to transport demolished materials and removed caissons and debris offsite to an authorized upland disposal site. Storage, maintenance, and equipment staging would be done in designated staging areas in a manner that will not result in a discharge of any substance into the Bay. As appropriate, staging areas would be located on Pier 36 or on barges within the 40-foot marine work zone. No staging or demolition actions will involve areas along the Embarcadero outside of the fencing currently in place to prevent public access to the instable infrastructure.

Fueling of marine-based equipment would take place offsite at marine fueling facilities or at designated locations adjacent to the project in accordance with the marine fueling best management practices (Appendix C). Fueling of land-based equipment would occur in staging areas or over pavement, and the location would be inspected after fueling to document that no spills have occurred. Although spills are unanticipated, spill response equipment would be stored onsite for immediate implementation in the event of any spill.

After demolition of Pier 36, all construction wastes, debris, sediment, rubbish, trash, fencing, and materials would be removed from the site and transported to an authorized disposal area in compliance with applicable federal, state, and local laws and regulations.

4.2 No-Action Alternative

Analysis of the No-Action Alternative is required under NEPA to provide a comparative baseline against which other alternatives can be evaluated.

Under this alternative, no action would be taken. The existing Pier 36 warehouse building, deck, supporting caissons, collapsed wharf extension debris and pilings, and marginal wharf would not be demolished or removed. The existing deteriorating infrastructure and debris would continue to pose the same level of navigational hazard to commercial and recreational marine traffic through the area. Pier 36 would remain condemned and fenced off from public access. Furthermore the existing creosote piles would remain and continue to degrade water quality and impact marine organisms.

4.3 Alternatives Considered and Eliminated

The existing Pier 36, marginal wharf, and collapsed debris are in deteriorated and unstable condition. Portions of these structures have been condemned and in their current state pose a

September 2011 8 navigational hazard to marine traffic in the area. Given this, the range of reasonable alternative actions involving these structures is limited to removal, repair/restoration, a combination of the two, or no action. Alternative actions considered but eliminated as potential alternatives to the Pier 36 Demolition project included:

Repair of the existing Pier 36 and marginal wharf in place (including or excluding the collapsed wharf extension);

Demolition of Pier 36 but repair of the existing marginal wharf;

Demolition of the Pier 36 warehouse and repair of the Pier 36 deck; and Complete demolition and reconstruction of Pier 36 and the marginal wharf.

Restoring Pier 36 in place through repair or replacement of the deteriorating infrastructure (including or excluding the collapsed wharf extension) was eliminated from further study because the extent and degree of damage to the deteriorating infrastructure makes repair of largely infeasible and replacement of the majority of the infrastructure in place would be cost prohibitive. Additionally, an objective of the proposed action is to eliminate the existing navigational hazard in accordance with the Port of San Francisco’s redevelopment plan. This plan calls for the removal of Piers 34 and 36 to create a public open space along the waterfront.

Pier 34 was removed in 2001 and repair of Pier 36 in place would not be in accordance with the Port’s stated redevelopment plan.

Similarly, demolition of the pier but repair of the marginal wharf was eliminated given that the marginal wharf is in extremely damaged condition making restoration (as opposed to complete replacement) infeasible. Demolition of the warehouse and reuse of the deck would include repair of the Pier 36 deck structure and the marginal wharf in place, which was eliminated as an alternative for the aforementioned reasons. Finally complete demolition and reconstruction of Pier 36 and the marginal wharf was eliminated because reconstruction of the structures would be cost prohibitive and outside of the scope of the project objective of eliminating the navigational hazard posed by the existing deteriorated infrastructure (i.e. demolition alone would meet this objective) and because this alternative would not be in accordance with the Port’s stated redevelopment plan.

Additionally, consideration was given to alternative methods of demolition such as demolition of the proposed infrastructure and debris entirely from land. Demolition and removal of the infrastructure and debris from land would require partial or full closure of the Embarcadero promenade and roadway adjacent to the project site for extended periods of time to allow cranes to work from land and for staging. This alternative was expected to cause significant impacts to transportation and recreation and to be cost prohibitive, thus it was eliminated from further study.

5.0 IMPACT ASSESSMENT

This section provides an assessment of potential impacts of the Agency-preferred alternative (proposed action) to environmental factors. Potential impacts are evaluated in relation to the No-action alternative. If an environmental factor is considered not applicable to the Agency-preferred alternative, the factor is followed by N/A.

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5.1 Water

( X ) Surface water or drainages: All portions of the project action area are within or over the waters of central San Francisco Bay. Water depths in the project area range from approximately 3 to 10 feet at Mean Lower Low Water (MLLW), and 9 to 16 feet at Mean Higher High Water (MHHW) (Fugro West, Inc. and Winzler & Kelly, 2009 as cited in USACE 2011).

The proposed action will remove approximately 4,570 square feet of caisson and timber pile fill and clear approximately 47,000 square feet of collapsed wharf extension debris and from the waters of the Bay. Additionally, the proposed demolition of the Pier 36 and Marginal wharf structures will remove 104,800 feet of shaded area (shadow fill) over the Bay. While the Port of San Francisco intends to create a pile-supported public open space in place of the existing Pier 36, the cumulative actions would still result in the net removal of pile fill and shadow fill.

The proposed action’s removal of fill and shadow fill will increase open surface water in the action area and restore ambient light wavelengths to those waters, respectively. Therefore the proposed action is not expected to adversely impact surface waters or drainages and is expected to indirectly benefit surface waters. Under the No-action alternative there would be no change in existing levels of fill and shadow fill in the action area.

( X ) Quality - temperature, salinity patterns, and other parameters: Demolition and removal actions associated with the proposed project will be conducted above and within waters of the central San Francisco Bay. There are no expected changes to temperature and salinity resulting from the proposed project. The removal of creosote treated piles will benefit water quality and supports the subtidal restoration recommendation of the San Francisco Bay Subtidal Habitat Goals project to remove or encapsulate creosote pilings. Similarly, since runoff from impervious Pier surface that enters the Bay without treatment can carry mobilized pollutants and particulates, the removal of this surface as part of the proposed action is also expected to benefit water quality.

Avoidance and minimization measures would be exercised throughout the proposed action to ensure no debris, rubbish, cement, concrete or concrete washings, oil or petroleum products, or other organic or earthen material from construction or associated activities impact Bay water quality. Prior to demolition, surveys of the Pier 36 warehouse building would be conducted for hazardous materials, and any hazardous materials discovered would be abated from land and appropriately disposed of at permitted facilities to prevent them from entering waters of the Bay.

During demolition, timber mats would be deployed beneath the existing above-water infrastructure to trap any falling debris before it enters the water. Dump barges or dump trucks would be used to transport demolished materials, removed caissons and piles, and debris offsite to an authorized upland disposal site. Storage, maintenance, and staging of equipment would be done in designated staging areas and in a manner that will not result in a discharge of any substance to the Bay. These proposed measures to avoid impacts to water quality are further detailed in Appendix C.1.

Furthermore, fueling of equipment would be conducted in a manner that prevents pollution of Bay waters. Fueling of marine-based equipment would take place offsite at authorized marine fueling facilities or at designated locations adjacent to the project. If fueling of marine-based equipment occurs adjacent to the project site, the marine fueling best management practices

September 2011 10

(BMPs) described in Appendix C.1 would be implemented to avoid discharge of pollutants to waters of the Bay. Fueling of land-based equipment would occur in staging areas over pavement, and the general fueling measures described in Appendix C.1 would be implemented ensure no pollution occurs. Although spills are unanticipated, spill response equipment would be stored onsite for immediate implementation to minimize the impacts of any accidental spills. At the completion of demolition, all construction wastes, debris, sediment, rubbish, trash, fencing, and materials would be removed from the site and transported to an authorized disposal area to prevent them from entering the Bay.

In addition to the proposed avoidance and minimization measures, pursuant to section 401 of the Clean Water Act (CWA; 33 U.S. Code 1251), USACE submitted an application to the San Francisco Bay Regional Water Quality Control Board (SFRWQCB) in July 2011 to obtain a 401 Water Quality Permit for the project. The SFRWQCB reviewed the application and issued a 401 Certification for the project on August 15, 2011(Appendix A.5). The USACE will comply with all provisions of the certification to ensure consistency with the SFRWQCB’s Water Quality Control Plan for the San Francisco Bay Basin.

Given the preventative measures to be implemented as part of the proposed action, no significant detrimental impacts to water quality are expected. Additionally, the proposed action will indirectly benefit water quality through removal of approximately 350-to-400 creosote-treated piles from the Bay and approximately 102,000 square feet of impervious surfaces that drain directly to the Bay. Pilings treated with creosote have the potential to release polycyclic aromatic hydrocarbons (PAHs), which degrade water quality and other beneficial uses of water (USEPA 2008 and others, as cited in USACE 2011).

Under the No-action alternative, there would be no removal action and the existing infrastructure, including creosote-treated pilings, would remain in place. There would be no potential for pollution from demolition activities. There also would be no benefits to water quality resulting from removal of 350-400 creosote-treated piles. The pilings would continue to act as a potential source of PAHs which degrade water quality.

( X ) Turbidity, suspended particulates: The proposed action involves removal of 350-to- 400 caissons supporting the existing Pier 36 and marginal wharf structure. Removal of these caissons has the potential to resuspend sediment in the immediate vicinity of the caisson being removed, temporarily increasing turbidity. Lifting of the collapsed debris and timber piles from the wharf extension at the end of the pier is expected to result in a negligible additional amount of sediment suspension. To remove the caissons, a barge-mounted derrick crane will grab a portion of the caisson, rock it from side to side to loosen it, and then pull the caisson out. The maximum volume of sediment disturbed by removal of a caisson will consist of a cylinder shaped volume equivalent to the outside diameter of the footing less the volume of the footing to the depth of the caisson. This volume has been calculated to be approximately 6.68 cubic yards of sediment per caisson. The calculated volume is likely an over estimate since much of the disturbed sediment will slough off back into the hole as the caisson is extracted as opposed to being resuspended. It is currently anticipated that a maximum of eight caissons will be removed on a daily basis. This equates to a maximum of approximately 54 cubic yards per day of resuspended sediment if it is assumed that the total volume of sediment will be resuspended.

Based on these calculations, removal of the approximately 350-to-400 caissons supporting the

September 2011 11 pier has the potential to result in disturbance and resuspension of approximately 3,000 cubic yards of sediment over the entire project. Resuspended sediment is expected to settle quickly remaining in suspension for a maximum of a few hours.

Sediment suspension can mobilize sediment-bound contaminants into the water column where they have the potential to become dissolved into the water itself. However, sediment samples taken at Piers 30/32 and 40 for standard dredging episodes in the vicinity of the project (Public Notice 01-01, USACE et al. 2001) were submitted for the full suite of physical, chemical, and biological analyses in accordance with the Inland Testing Manual guidance for testing dredged materials for in-Bay disposal (USEPA/USACE 1998). The samples indicated slightly elevated PAH’s but showed no exceedance of water quality standards in approved dilution models of water column chemical concentrations (USACE 2011) and did not exhibit chemical constituents of concern (Appendix D). Additionally, bioassay results passed regional and federal guidelines indicating a lack of biological toxicity.

Given the small potential volume of sediment to be disturbed by the proposed action it is expected to have a less than significant impact on turbidity. Given the fact that sediment samples taken in close proximity to the project action area did not exhibit chemical constituents of concern or biological toxicity, the proposed action and is not expected to mobilize sediment-bound contaminants into the water column. Therefore, turbidity-related impacts associated with the proposed action are expected to be less than significant.

Under the no-action alternative, no pilings would be removed, and turbidity and suspended particulate levels would remain unchanged from levels currently experienced within the project action area.

( X ) Substrate: Substrate within the proposed action area includes soft-bottom substrate such as Bay sand and mud, and hard-bottom substrate such as the caissons that support Pier 36 and the debris at the eastern end of Pier 36. Under the No-action alternative, the Pier 36 caissons, pilings, and debris would not be removed, and no changes to existing substrate conditions would occur.

The proposed action has the potential to affect both soft- and hard-bottom substrate. As described in the “Turbidity, suspended particulates” section, removal of the caissons supporting Pier 36 may temporarily disturb small quantities of Bay sand and mud substrate in the vicinity of the caissons being removed. The majority of the disturbed Bay sand and mud is expected to slough back into the holes formed by the caissons being removed, and any resuspended particles are expected to settle in close vicinity. No significant impacts to soft-bottom substrate are expected.

The hard-bottom substrate proposed for removal is a mixture of concrete caissons, wood debris, and creosote-treated wood pilings. Creosote has the potential to release PAHs, which can degrade substrate quality and be toxic to hard-bottom and sediment-dwelling species in the Bay (USEPA 2008 and others as cited in USACE 2011). Removal of the creosote-treated wood pilings is expected to be an indirect benefit to substrate as it will remove potentially toxic hard bottom substrate and a potential source of PAH’s to Bay sand and mud. Removal of the concrete caissons will result in a decrease in hard bottom substrate in the action area. However, there are numerous piers and wharfs with concrete support structures in the immediate vicinity of the action area. Given that similar hard-bottom substrate in the vicinity is abundant, removal of the

September 2011 12 existing concrete pilings supporting Pier 36 is not expected to be a significant impact. The proposed action would have indirect beneficial impacts to the substrate.

( X ) Currents, circulation, or drainage patterns: Circulation within the Bay, particularly the central portion of the Bay, depends on tides, river flow, winds, runoff, and bathymetry.

Current and wave patterns exhibited in the project area are largely generated by the tides interacting with bottom and shoreline configurations (USACE 2011). No changes in tides, river flow, winds, runoff, or bathymetry are expected as a result of the proposed action. The removal of the existing Pier 36 and marginal wharf structures would result in minor changes to the configuration of the shoreline within the action area, but given the highly developed nature of the San Francisco Bay Shoreline in the vicinity, the change is not expected to significantly alter current and wave patterns at the project site. Under the No-action alternative, there would be no changes to the shoreline configuration or any other factors related to currents, circulation, or drainage; therefore these conditions would remain unchanged.

( X ) Mixing zone (in light of the depth of water at the disposal site; current velocity, direction and variability at the disposal site; degree of turbulence; water column stratification; discharge vessel speed and direction; rate of discharge; dredged material characteristics; number of discharges per unit of time; and any other relevant factors affecting rates and patterns of mixing): There is no dredging associated with the Agency-preferred alternative and therefore the mixing zone would be the same as those experienced under the No-action alternative.

( ) Flood control functions: N/A

( X ) Storm, wave, and erosion buffers: The existing Pier 36 and marginal wharf are above-water structures that do not provide buffers against storms, waves, or erosion. Neither the proposed action nor the No-action alternative will affect storm, wave, or erosion buffers.

( X ) Erosion and accretion patterns: There are no changes anticipated to the existing erosion and accretion patterns in the project area under either the Agency-preferred or No-action alternative.

( ) Aquifer recharge: N/A ( ) Base flow: N/A ( ) Water supplies, conservation: N/A

5.2 Habitat

( X ) Aquatic Habitat: Historically the majority of San Francisco Bay consisted of tidal wetlands, however most of this habitat has been lost due to development within the Bay. Today, the action area includes open-water, soft-bottom subtidal habitat, and impervious (hard-bottom) surfaces associated with artificial structures along the waterfront. Water depths in the project area range from approximately 3 to 10 feet at Mean Lower Low Water (MLLW), and 9 to 16 feet at Mean Higher High Water (MHHW) (Fugro West, Inc. and Winzler & Kelly, 2009 as cited in USACE 2011). The open-water areas of the Bay provide habitat for marine invertebrates, fishes, birds, and marine mammals. Soft- and hard-bottom substrate within the action area provides

September 2011 13 habitat for benthic invertebrates such as barnacles, mussels, and tunicates, oligochaetes, polychaetes, amphipods, and crustaceans; submerged aquatic vegetation and macroalgae; and potential spawning substrate for Pacific herring (Clupea pallasi). Additionally, shadows created by the existing structures in the action area can provide cover habitat for a variety of fish species.

Based on eelgrass mapping by Merkel (2004, as cited in USACE 2011), there is no eelgrass in or near the action area and there are no known native oyster beds in the vicinity.

Activities associated with fishing, marinas, shipping, dredging, transportation, recreation, and industry within the San Francisco Bay have all had affects on aquatic habitat (California State Coastal Conservancy and Ocean Protection Council 2010). Filling of the shoreline and Bay has decreased the amount and complexity of aquatic habitat and degraded its condition (California State Coastal Conservancy and Ocean Protection Council 2010). The proposed project has the potential to impact aquatic habitat through mechanisms such as pollution, burial of habitat with suspended sediment, removal of structures that provide habitat, and change in habitat conditions such as shading.

The proposed action will be conducted in accordance with the BMPs, avoidance, and minimization measures referenced in the “Water Quality” section. These measures are expected to prevent any pollution of aquatic habitat. Impacts to soft-and hard-bottom benthic substrate habitat are discussed in the “Substrate” section and are not expected to be significant. Suspended sediment-related impacts to aquatic habitat would be as described in the “Turbidity” section and are expected to be temporary, minor, and less than significant. The proposed demolition of over-water structures will remove 104,800 feet of shading (shadow fill) over the Bay. While this would constitute a permanent removal of cover-habitat in the action area, the adjacent piers and wharves along the San Francisco waterfront will continue to provide cover habitat in the vicinity, and the change is expected to be beneficial to the benthic habitat through restoration of ambient light conditions. Similarly, the proposed action would take place during a portion of Pacific herring spawning season (which runs December 1 through February 28) and would remove a small amount of potential herring spawning substrate. However, there are numerous piers and wharfs with concrete support structures in the immediate vicinity of the action area, and the removal of creosote-treated piles is expected to benefit herring spawning habitat by removing a potentially-toxic substrate for egg adhesion.

Based on the BMPs, avoidance, and minimization measures to be implemented as part of the proposed project, the proposed action is not anticipated to have a significant impact on aquatic habitat. Additionally, the proposed action is expected to indirectly benefit aquatic habitat by increasing open-water habitat through the removal of fill as well as removing creosote-treated piles as potential source of PAHs which could degrade benthic habitat. Under the No-action alternative, Pier 36 and the related infrastructure would not be removed from waters of the Bay.

Existing aquatic habitat conditions would remain unchanged.

The San Francisco Bay, including the action area, is also classified under the Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA) as Essential Fish Habitat (EFH) for Pacific salmonids, coastal pelagic and Pacific groundfish fisheries. To ensure that the proposed action is conducted in a manner that protects EFH within the action area, USACE produced an EFH assessment (USACE 2011) and requested EFH consultation from the National Marine Fisheries Service (NMFS) to obtain EFH Conservation Recommendations. The NMFS provided

September 2011 14 formal consultation for EFH under the authority of and in accordance with the MSFMCA, on May 11, 2011 (Appendix A.3). NMFS determined that the proposed action would adversely affect EFH, but that the project measures proposed to avoid, minimize, mitigate, or otherwise offset the adverse effects to EFH were adequate, and that the project would also result in multiple beneficial effects to EFH. Given this determination, NMFS had no additional EFH Conservation Recommendations to provide. As such, no significant impacts to EFH are expected as a result of the proposed action.

( X ) Special aquatic sites (wetlands, mudflats, coral reefs, pool and riffle areas, shallows, sanctuaries and refuges, other): There are no wetlands, rocky shoreline, salt marshes, tidal marshes tidal flats, salt ponds, or other special aquatic sites within the proposed action area or the surrounding vicinity. Therefore, there would be no detrimental impacts to special aquatic sites under the Agency-preferred or No-action alternatives.

( X ) Terrestrial Habitat: The terrestrial areas at the project site are built on fill several feet above MHHW and have been highly modified by urban development along the Embarcadero.

These areas include commercial and high-density residential development, wharfs and piers, and high-use pedestrian and automotive transportation arterials. Vegetation is lacking other than ruderal plants that are found within cracks in the sidewalk or decks (USACE 2011). Terrestrial habitat within the action area is limited to structures that may serve as bird perches and nesting sites on the roof of the Pier 36 warehouse, along the edges of the pier, and on the remnant timber piles at the eastern end of the pier.

The proposed action, which includes removal of the warehouse, pier, and remnant piles in the action area, would result in a decrease in potential terrestrial habitat that could be used for bird perches and nesting sites. Given the developed nature of the terrestrial portions of the action area, the deteriorating state of the existing structures, and the potential these structures contain hazardous materials such as lead paint and asbestos, this terrestrial habitat is considered to be of relatively low quality. Additionally, there is an abundance of structures along the waterfront that could serve as nesting sites, perches, or habitat of equal or greater quality. Thus, the proposed removal of the structures within the action area is not expected to have a significant impact on terrestrial habitat. Under the No-action alternative, these structures would not be removed and there would be no change in existing terrestrial habitat conditions.

5.3 Biological Resources

( X ) Organisms: The aquatic habitat within the proposed action area supports a variety of organisms including marine invertebrates, marine plants, fishes, birds, and marine mammals. The terrestrial habitats within the action area also support birds as well as organisms commonly associated with developed urban waterfronts such as rodents. Potential impacts to species designated (or proposed for designation) as threatened or endangered under the federal Endangered Species Act (ESA), as well as other special status species are addressed in the “Threatened and Endangered Species” section below.

Common marine birds observed in the developed areas of the Central Bay include California brown pelican (Pelecanus occidentalis), western gull, surf scoter (Melanitta perspicillata), September 2011 15 western grebe (Aechmophorus occidentalis), double-crested cormorant (phalacrocorax auritus), and species of terns.

Invertebrates in the Bay include oligochaetes, polychaetes, amphipods, barnacles, mussels, tunicates, and crustaceans such as blackspotted shrimp (Crangon nigromaculata), California bay shrimp (Crangon franciscorum), slender rock crab (Cancer gracilis), and Dungeness crab (Cancer magister). Marine plants may include pondweed (Stuckenia pectinata), surfgrasses (Phyllospadiz torreyi), and widgeongrass (Ruppia maritima).

The fish community in the Central Bay is primarily dominated by sharks, skates, and rays, such as the brown smoothhound (Mustelus henlei) and leopard shark (Triakis semifasciata). Also present are the brown rockfish (Sebastes auriculatus), plainfin midshipman (Porichthys notatus), Pacific sardine (Sardinops sagax), Pacific herring (Clupea pallasi), and flatfishes such as the California halibut (Paralichthys californicus) and the speckled sanddab (Citharichthys stigmaeus). Marine mammal species that feed over soft bottom substrates such as those in the Central Bay include harbor seals (Phoca vitulina) and harbor porpoise (Phocoena phocoena), California sea lions (Zalophus californianus), and Gray whales.

Under the No-action alternative, there would be no impact to any organisms potentially occupying the action area. The proposed action has the potential to result in short-term, minor impacts to organisms occupying the action area directly through disturbance because of demolition activities or indirectly through effects on terrestrial and aquatic habitat. Potential impacts to terrestrial and aquatic habitat are discussed in the “Habitat” section, and no significant impacts are anticipated. The proposed action would be conducted during a portion of the avian nesting season (which runs March 1 through August 1), and to prevent significant impacts to bird species potentially using the Pier 36 infrastructure as nesting sites, the mitigation measures listed in Appendix C.2 will be implemented. Such measures include placing and maintaining bird deterrence netting or wiring as a barrier to nest establishment on structures and hazing or removal of any nests that are established to prevent egg laying. If nests with eggs are discovered, they will not be disturbed, and project biologists or other appropriate parties will be contacted to determine the way forward.

The proposed demolition and removal action will generate noise both terrestrially and within the water column. At certain levels, noise within the water column can harass or injure organisms, especially fish and marine mammals.