2.
Response
to
Comment
2.4
Master
Responses
to
Comments
2.4.15
Master
Response
15,
Hazards
and
Hazardous
Materials:
Adequacy
of
the
Waste
Characterization
Used
in
the
Draft
EIR
Comments
A
number
of
comments
questioned
whether
the
waste
characterization
of
the
former
landfill
discussed
in
the
Draft
EIR
was
adequate,
and
requested
that
additional
studies
be
completed
before
the
EIR
is
certified.
A
number
of
other
comments
questioned
whether
characterization
of
contamination
within
the
former
railyard
(OU-1,
OU-2)
was
adequate,
and
requested
that
additional
studies
be
completed
before
the
EIR
is
certified.
Response
The
purpose
of
the
studies
conducted
to
characterize
waste
in
the
former
landfill,
was
(1)
to
address
the
potential
for
constituents
within
the
landfill
to
contaminate
groundwater
or
migrate
offsite,
(2)
to
identify
potential
pathways
of
exposure,
and
(3)
to
ultimately
provide
a
basis
for
designing
the
required
landfill
cap,
along
with
a
leachate
control
system
to
prevent
any
increases
in
leachate
that
would
exceed
any
regulatory
thresholds,
and
a
landfill
gas
collection
and
control
system.
The
purpose
of
the
studies
conducted
to
characterize
the
contaminants
within
the
former
rail
yard
(OU-1
and
OU-2)
was
to
provide
a
basis
for
analysis
of
human
health
risks
for
any
future
land
uses
that
may
be
approved
by
the
City
of
Brisbane.
Based
on
these
recognized
purposes,
the
programmatic
nature
of
the
Baylands
EIR,
CEQA’s
requirements
for
subsequent
environmental
review,
and
the
planning
and
remediation
review
processes
discussed
in
Master Response 13,
the
City
determined
that
the
existing
landfill
and
site
contamination
studies
prepared
to
date
were
adequate
to
characterize
existing
conditions
for
the
Baylands
EIR.
In
2005
7
,
CDM
was
retained
by
the
City
to
review
the
adequacy
of
existing
characterization
studies
of
the
former
landfill
and
railyard
on
the
Baylands
site.
CDM
concluded
that
these
studies
had
been
prepared
in
accordance
with
industry
standards,
and
therefore
were
adequate
for
use
in
an
EIR
to
be
prepared
for
proposed
Baylands
development.
CDM
undertook
additional
review
of
these
studies
(and
its
2005
report)
in
2013,
and
again
found
that
these
past
environmental
studies,
including
the
2012
Geosyntec
summary
report,
were
adequate
for
use
in
a
Draft
EIR.
Dr.
Lee’s
report,
which
is
cited
in
many
comments
as
indicating
the
existing
hazardous
materials
studies
prepared
for
the
Baylands
are
lacking,
concurs
with
CDM’s
conclusions,
and
finds
the
2005
CDM
assessment
to
be
adequate
and
to
have
been
conducted
in
conformance
with
existing
regulatory
laws
and
guidelines.
Indeed,
Dr.
Lee’s
primary
criticisms
are
targeted
at
the
limitations
of
existing
environmental
science
and
technology
to
identify
hazardous
chemicals
and
not,
as
many
comments
assert,
at
the
studies
conducted
to
assess
the
presence
of
hazardous
materials
within
the
Project
site.
7
Camp
Dresser
&
McKee
(CDM),
Final
Report
of
Findings,
Environmental
Engineering
Peer
Review,
Baylands
Remediation
Efforts
,
November
2,
2005.
This
report
can
be
found
as
part
of
the
reference
documents
used
in
preparation
of
the
Brisbane
Baylands
Draft
EIR.
Brisbane
Baylands
Final
EIR
2.4-44
May
2015
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