2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
limitations
are
universal
and
as
such
are
not
specific
to
the
Baylands
Project
site
or
the
studies
undertaken
for
the
Draft
EIR.
Some
laboratory
analytical
equipment
can
detect
concentrations
of
constituents
below
parts
per
billion.
While
there
may
be
potential
effects
due
to
exposure
to
constituents
that
have
not
been
determined,
the
state
of
the
existing
science
errs
on
the
side
of
conservatism
to
account
for
unknowns
as
contaminated
sites
are
remediated.
Data
is
compared
to
threshold
values
determined
by
regulatory
agencies
to
be
conservatively
protective
of
human
and
ecological
health.
Data
is
used
in
risk
assessments
to
provide
direction
for
remediation
that
is
both
protective
of
human
and
ecological
health
and
feasible.
Science
is
not
static;
this
is
reflected
in
the
annual
updates
to
regulatory
agency
threshold
values
and
guidance.
Technology
is
not
static
as
reflected
in
more
precise
laboratory
and
field
instruments
and
innovative
remedial
techniques.
See
for
discussion
regarding
the
adequacy
of
existing
studies
for
use
in
the
Draft
EIR
and
5
for
discussion
regarding
compliance
with
the
law
as
mitigation
under
CEQA.
See
for
discussion
regarding
the
adequacy
of
existing
studies
for
use
in
the
Draft
EIR.
See
for
discussion
of
the
remediation
review
process
and
regarding
the
adequacy
of
existing
studies
for
use
in
the
Draft
EIR.
Pursuant
to
the
requirements
of
Regulation
8,
Rule
34,
USEPA
40CFR
Part
60
725(b)(2)(i)
and
40CFR
Part
62.14356
(a)(1),
a
gas
collection
system
was
installed
in
1991
on
the
landfill
(Draft
EIR
Appendix
B).
The
existing
landfill
gas
control
system
has
been
operational
since
2002.
The
flare
station
operates
a
single
flare
7
hours/day
(to
comply
with
emission
control
limits)
with
a
destruction
efficiency
of
98
percent
and
a
temperature
of
1400
degrees
Fahrenheit
(Draft
EIR
Appendix
B).
Test
results
from
2001
indicate
generation
of
methane
gas
decreased
from
140
SCFM
in
1992
to
approximately
40
SCFM
in
2001
and
VOCs,
as
measured
with
an
OVA,
were
ND
(Draft
EIR
Appendix
B).
To
ensure
the
landfill
gas
control
system
continues
to
meet
operational
material,
weekly
monitoring
of
the
flare
station,
monthly
monitoring,
and
adjustment
of
the
landfill
gas
extraction
wells,
and
quarterly
monitoring
of
emissions
is
performed.
Repairs
are
performed
during
monitoring
visits
and
as
needed
and
are
documented
in
monthly
reports.
As
part
of
its
requirements
for
Title
27
landfill
closure,
the
RWQCB
will
review
the
adequacy
of
the
existing
landfill
gas
control
system
to
collect
and
combust
methane
and
other
landfill
gases
pursuant
to
Title
27
standards.
Based
on
that
Brisbane
Baylands
Final
EIR
2.9.1-32
May
2015