2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
refers
is
a
discussion
of
risk-based
cleanup
levels
proposed
by
MACTEC
for
OU-
1
in
2009
that
were
not
adopted
by
the
DTSC.
See
for
discussion
of
the
remediation
review
and
approval
process.
Based
on
the
land
uses
approved
by
the
City
of
Brisbane,
updated
human
health
risk
assessments
will
be
prepared.
These
human
health
risk
assessments
will
then
be
used
by
the
RWQCB
and
DTSC
to
set
site-specific
risk-based
cleanup
goals
for
the
Baylands.
The
Draft
EIR
text
to
which
this
comment
refers
is
a
discussion
of
risk-based
cleanup
levels
proposed
by
MACTEC
for
in
2009.
See
for
discussion
of
the
remediation
review
and
approval
process.
An
updated
risk
assessment
for
the
site
will
be
required
by
the
regulatory
agencies
prior
to
approval
of
remedial
action
plans
and
development
of
the
Baylands
Project
site.
The
risk
assessment
would
include
calculation
of
risk-based
cleanup
goals
for
the
future
intended
use
of
the
site
as
a
whole
or
for
each
area
impacted
by
constituents
and/or
chemicals
of
concern.
The
risk
assessment
will
be
reviewed
and
ultimately
approved
by
the
regulatory
agencies
based
on
the
regulatory
standards
in
place
at
the
time
of
such
review
and
approval.
See
5
for
discussion
of
compliance
with
the
law
as
mitigation
under
CEQA.
This
comment
mischaracterizes
the
recommendations
of
the
Draft
EIR.
See
for
discussion
of
the
remediation
review
and
approval
process.
Pursuant
to
the
requirements
of
Draft
EIR
Mitigation
Measure
4.G-2a,
site
remediation
and
landfill
closure
will
be
required
to
meet
the
standards
set
by
the
RWQCB
and
DTSC,
which
are
the
state
agencies
having
regulatory
authority
over
remediation
and
landfill
closure
within
the
Baylands.
See
also
5
for
discussion
of
compliance
with
the
law
as
mitigation
under
CEQA.
The
term
“clean
soil”
is
a
common
term
used
in
the
construction
industry
to
denote
soils
that
are
free
of
rubble
and
construction
debris.
As
used
in
the
Draft
EIR,
it
refers
to
the
20
to
30
feet
deep
layer
of
soil
used
as
final
cover
over
the
landfill
to
prevent
human
contact
with
refuse
from
residential;
commercial;
industrial
activities
including
shipyard
waste;
and
construction
rubble,
tires,
and
sewage.
The
statement
in
the
Draft
EIR
to
which
this
comment
refers
simply
notes
that
in
2011,
Geosyntec
developed
guidance
for
screening
of
fill
materials
to
be
used
for
landfill
soil
cover.
Thus,
such
guidance
did
not
exist
prior
to
2011.
See
for
discussion
regarding
the
remediation
review
and
approval
process.
Imported
soil
materials
will
be
required
to
be
sampled
for
specific
constituents
of
chemicals
of
concern
relative
to
the
source
of
the
import.
In
addition,
the
number
of
samples
that
would
be
collected
would
correspond
to
Brisbane
Baylands
Final
EIR
2.9.1-36
May
2015