2.
Response
to
Comments
2.10
Individual
Responses
to
Comments
from
Individuals
(OEHHA)
Air
Toxics
Hot
Spots
Program
Guidance
1
,
and
the
BAAQMD’s
Health
Risk
Screening
Analysis
Guidelines
.
2
Impact
4.B-6
assesses
the
potential
impacts
of
existing
TAC
sources
(both
stationary
and
mobile)
on
proposed
sensitive
land
uses
using
methodologies
recommended
by
the
BAAQMD
in
its
2012
CEQA
Air
Quality
Guidelines.
Impact
4.B-6
identifies
a
less
than
significant
impact
based
on
this
BAAQMD
methodology.
With
regard
to
the
potential
for
unknown
chemical
contamination
of
the
Baylands
Project
site,
see
for
discussion
regarding
the
remediation
review
and
approval
process
and
for
discussion
regarding
the
adequacy
of
characterization
studies
for
use
in
the
Draft
EIR.
The
Draft
EIR
contains
an
assessment
of
hazardous
materials
impacts
from
the
former
uses
in
Section
4.G
,
Hazards
.
Pages
4.G-4
through
4.G-18
of
the
Draft
EIR
reference
33
studies,
reports
and
monitoring
efforts
conducted
between
1977
through
2011
that
cumulatively
represent
baseline
3
studies
under
CEQA
with
respect
to
contamination
from
the
former
landfill
as
well
as
other
historical
onsite
activities.
These
data
were
applied
in
the
assessment
of
hazard
impacts
4.G-1
through
4.G-7
from
historical
activities
on
the
Baylands
Project
site
detailed
on
Draft
EIR
pages
4.G-86
through
4.G-103.
While
there
is
always
potential
for
unknown
site
conditions
to
emerge,
the
history
of
subsurface
analysis
is
extensive
and
reflects
ample
due
diligence
with
respect
to
characterizing
potential
hazards.
Impact
4.B-7
assesses
the
potential
for
elevated
carbon
monoxide
(CO)
concentrations
using
methodologies
recommended
by
the
BAAQMD
and
modeling
worst-case
conditions
assuming
cumulative
roadway
volumes
during
the
PM
peak
hour
for
the
DSP-V
scenario
and
event.
Impact
4.B-7
identifies
a
less
than
significant
impact
based
on
Plan-specific
modeling
and
comparison
to
state
and
federal
CO
standards.
No
factual
evidence
is
provided
to
support
the
assertion
that
proposed
Baylands
development
would
result
in
accelerated
deterioration
of
San
Bruno
Mountain
State
and
County
Park,
as
well
as
the
San
Bruno
Mountain
trails
or
other
existing
city
recreational
facilities.
As
discussed
on
page
4.M-21
of
the
Draft
EIR,
the
DSP
and
DSP-V
scenarios
provide
for
park
and
recreational
land
in
excess
of
Brisbane
Municipal
Code
requirements
even
after
including
onsite
employment
generation
which
is
not
1
2
3
Office
of
Environmental
Health
Hazard
Assessment
(OEHHA),
2003.
Air
Toxics
Hot
Spots
Program
Guidance
Manual
for
Preparation
of
Health
Risk
Assessments
,
http://www.oehha.org/air/hot_spots/pdf/HRAguidefinal.pdf
Bay
Area
Air
Quality
Management
District
(BAAQMD),
2005.
BAAQMD
Health
Risk
Screening
Analysis
Guidelines
(http://www.baaqmd.gov/pmt/air_toxics/risk_procedures_policies/hrsa_guidelines.pdf)
,
June
2005.
Baseline
is
the
existing
physical
conditions
at
the
time
of
the
NOP
for
the
purposes
of
impact
assessment
under
CEQA.
Brisbane
Baylands
Final
EIR
2.10.14-2
May
2015