>
2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
Draft
EIR
contains
an
assessment
of
hazard
impacts
from
the
former
landfill
in
Section
4.G
,
Hazards
and
Hazardous
Materials
.
Pages
4.G-4
through
4.G-18
of
the
Draft
EIR
documents
33
studies,
reports
and
monitoring
efforts
conducted
between
1977
through
2011
that
cumulatively
represent
baseline
5
studies
under
CEQA
with
respect
to
contamination
from
the
former
landfill
as
well
as
other
historical
on-
site
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
pages
4.G-86
through
4.G-103
of
the
Draft
EIR.
Mitigation
Measure
4.B-1
of
the
Draft
EIR
includes
a
menu
of
dust
control
measures
relative
to
air
quality
impacts
from
generation
of
fugitive
dust
from
construction
activities
that
require
“Building
pads
shall
be
laid
as
soon
as
possible
after
grading
unless
seeding
or
soil
binders
are
used”
in
addition
to
other
BAAQMD-identified
dust
control
measures.
The
four
development
scenarios
would
each
result
in
removal
of
existing
soil
piles
within
the
former
landfill,
reducing
the
need
for
operational
fugitive
particulate
management.
Mitigation
Measure
4.B-1
of
the
Draft
EIR
includes
a
menu
of
dust
control
measures
identified
by
the
BAAQMD
to
reduce
fugitive
particulate
emissions
during
Project
Site
development
construction.
BAAQMD
recommends
the
implementation
of
all
Basic
Construction
Mitigation
Measures
as
mitigation
for
dust
and
exhaust
construction
impacts.
The
BAAQMD
2011
CEQA
Air
Quality
guidelines
identify
these
measures
as
Best
Management
Practices
for
fugitive
dust
from
construction
and
include
implementation
of
Best
Management
Practices
in
the
District’s
threshold
of
significance
for
construction
dust
impacts
relative
to
CEQA.
Chapter
5,
Alternatives
,
notes
that
the
No
Project
No
Build
Alternative
would
have
no
construction-related
fugitive
dust
impacts.
However,
the
Draft
EIR
also
notes
that
existing
contaminated
soils
would
remain
and
the
former
landfill
would
not
undergo
formal
closure
under
the
No
Project
No
Build
alternative.
The
Draft
EIR
contains
an
assessment
of
hazard
impacts
from
the
former
landfill
in
Section
4.G
,
Hazards
and
Hazardous
Materials
.
Hazard
impact
4.G-2
on
pages
4.G-97
addresses
soil
gas
and
vapor
intrusion
from
legacy
contamination
in
the
Baylands
area
and
identifies
this
potential
as
a
significant
impact.
Mitigation
Measures
4.G-2f
through
4.G-2h
would
be
required
for
all
development
scenarios
to
avoid
a
significant
impact.
Because
landfill
gas
is
primarily
a
combustion
hazard
and
not
a
criteria
or
5
Baseline
is
the
existing
physical
conditions
at
the
time
of
the
NOP
for
the
purposes
of
impact
assessment
under
CEQA.
Brisbane
Baylands
Final
EIR
2.9.1-9
May
2015