2.
Response
to
Comment
2.4
Master
Responses
to
Comments
of
the
landfill
will
be
reviewed
by
those
agencies
to
ensure
compliance
with
Title
27
requirements.
Because
Title
27
closure
of
the
former
Brisbane
Landfill
requires
a
discretionary
action
by
the
RWQCB,
approval
of
Title
27
landfill
closure
requires
environmental
review
pursuant
to
the
requirements
of
CEQA.
and
Remediation
Review
Process
Updated
human
health
risk
assessments
for
and
will
be
prepared
subject
to
DTSC
and
RWQCB
oversight
to
evaluate
development-specific
exposure
pathways
for
the
land
uses
approved
by
the
City
for
the
Baylands.
Human
health
risk
assessments
are
used
to
derive
cleanup
goals
and
direct
remedial
actions
of
impacted
media
based
on
specific
land
uses,
since
cleanup
goals
and
remediation
standards
can
be
based
on
residential
or
commercial/industrial
land
use
scenarios
4
(as
well
as
construction).
In
the
case
of
the
Baylands,
the
human
health
risk
assessments
for
and
will
evaluate
the
land
uses
approved
by
the
City
for
the
Project
site.
5
Typically,
the
RWQCB
and
DTSC
require
remediation
to
proceed
based
on
the
more
stringent
residential
scenario
standards,
applying
these
criteria
even
where
no
residential
use
is
proposed
if
it
the
regulatory
agency
determines
that
the
responsible
party
for
remediation
is
reasonably
capable
of
meeting
the
more
stringent
standard.
Where
the
regulatory
agencies
determine
responsible
party
for
remediation
is
not
reasonably
capable
of
meeting
the
more
stringent
residential-level
standard
for
non-residential
uses,
commercial/industrial
remediation
criteria
are
applied.
In
such
cases,
the
RWQCB
and
DTSC
will
require
deed
restrictions
to
ensure
that
residential
uses
cannot
be
proposed
at
a
later
date.
The
human
health
risk
assessments
will
entail
review
of
the
studies
completed
to
date,
and
propose
any
additional
specific
investigations
and
assessments
that
may
be
needed.
The
human
health
risk
assessments
will
also
provide
risk-based
cleanup
goals
that
are
protective
of
human
health
and
the
environment.
As
discussed
above,
the
level
of
site
cleanup
will
depend
on
the
land
uses
approved
by
the
City,
although,
as
noted
previously,
the
regulatory
agencies
will
require
cleanup
to
residential
levels
if
the
more
stringent
standard
can
be
reasonably
achieved.
The
human
health
risk
assessments
will
be
reviewed
and
approved
by
regulatory
agencies
for
and
and
will
ensure
that
(1)
the
site
can
be
developed
safely
and
(2)
the
site
is
safe
for
the
land
uses
approved
by
the
City.
4
5
See
for
discussion
of
the
risk
assessment
exposure
factors
used
in
residential
and
commercial/industrial
risk
assessments.
As
stated
in
a
May
13
e-mail
from
Vic
Pal
of
the
RWQCB
to
Steven
Johnson,
should
the
Baylands
EIR
be
certified
and
the
City
of
Brisbane
approve
specific
land
uses
for
the
Baylands,
remedial
approaches
and
plans
“will
be
developed
for
Water
Board
review
for
the
specific
exposure
scenarios.
The
Water
Board
is
aware
of
current
site
conditions,
and
reviews
of
ongoing
monitoring….
A
thorough
review
of
site
data
and
risk
assessment
will
be
accomplished
for
this
site
during
our
evaluation
of
remedial
alternatives
and
subsequent
requirements.”
While
this
e-mail
refers
specifically
to
the
DTSC
will
use
a
similar
process
for
Because
the
human
health
risk
assessment
upon
which
remediation
standards
and
identification
of
specific
remedial
technologies
will
be
based
is
dependent
on
the
land
uses
ultimately
approved
by
the
City
for
the
Baylands,
such
review
can
only
be
undertaken
after
such
land
uses
are
approved.
Brisbane
Baylands
Final
EIR
2.4-40
May
2015