2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
As
discussed
site
remediation
and
Title
27
landfill
closure
will
consider
potential
exposure
pathways
related
to
the
former
landfill,
and
the
land
uses
determined
by
the
City
to
be
appropriate
within
the
Baylands;
and
human
health
risks
associated
with
site
contamination
in
relation
to
those
land
uses
to
develop
risk-based
cleanup
goals.
The
remedial
action
for
the
former
Brisbane
Landfill
will
be
required
to
address:
(1)
lack
of
a
low
permeability
engineered
landfill
cap
compliant
with
Title
27,
(2)
the
presence
of
leachate
and
the
requirement
to
prevent
any
increases
in
leachate
that
exceed
any
regulatory
thresholds,
(3)
hydrologic
connectivity
to
groundwater
and
surface
water,
primarily
the
Central
Drainage
Channel,
(4)
ongoing
consolidation
of
refuse
and
Bay
Muds,
and
(5)
control
of
landfill
gas.
As
required
by
Title
27
CCR
21190,
long-term
maintenance
to
ensure
the
integrity
of
the
final
cover
system
of
the
former
Brisbane
Landfill
is
required.
The
landfill
cover
will
require:
(1)
excavation
and
removal
of
approximately
3.7
million
CY
of
soil,
(2)
excavation
and
stockpiling
of
approximately
5
million
CY
of
soil,
(3)
relocation
of
approximately
41,500
CY
of
refuse
to
achieve
grade
elevations
for
placement
of
the
foundation
layer
and
low
hydraulic
conductivity
layer,
and
then
(4)
construction
of
the
2-foot
foundation
layer,
(5)
placement
of
low
hydraulic
conductivity
layer
at
depths
for
building
pads,
utility
corridors
and
designated
open
spaces,
and
(6)
replacement
of
stockpiled
material
on
the
surface
to
bring
the
former
landfill
to
final
development
grades.
Extensive
grading
is
required
to
achieve
elevations
conducive
for
planned
development
of
the
Baylands
Project
site,
including
designated
open
spaces,
in
part
because
landfill
closure
must
adhere
to
Title
27
CCR
21190
requirements
for
landfills.
Preventing
contact
with
wastes
in
the
landfill
by
placing
clean
materials
with
low
hydraulic
conductivity
layer
on
top
of
the
landfill
is
the
best
method
available
to
achieve
this
requirement.
The
impacts
of
site
grading,
and
mitigation
measures
to
avoid
and
minimize
these
impacts,
are
addressed
throughout
the
Draft
EIR
as
part
of
the
analysis
of
construction
impacts
for
air
quality,
greenhouse
gas
emissions,
noise
and
traffic,
and
are
also
addressed
in
the
Aesthetics
section
in
terms
of
the
visual
effects
of
proposed
final
grades.
A
total
of
1.7-acres
of
saltwater
marsh
and
1.4-acres
of
freshwater
marsh
wetlands
were
identified
as
being
potentially
impacted
by
proposed
site
grading
(Draft
EIR
Appendix
B).
The
saltwater
marsh
wetlands
are
located
along
the
existing
landfill
drainage
channel
and
the
presence
of
leachate
seeps
has
reduced
the
sustainability,
function,
and
potential
for
successful
habitat
development.
The
freshwater
marsh
wetlands
are
primarily
located
along
the
railyard
area
and
developed
due
to
man-made
drainage
ditches
and
depressions.
The
freshwater
wetlands
have
been
compromised
due
to
the
elevated
concentrations
of
heavy
metals,
hydrocarbons,
and
petroleum
by-products.
Brisbane
Baylands
Final
EIR
2.9.1-65
May
2015