2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
market.
The
centrifugal
action,
the
force
of
the
plasma
gas,
and
the
water-cooled
walls
work
together
to
generate
a
durable,
homogenous,
vitrified
waste
form
coupled
with
the
safe
confinement
of
the
hazardous
feeds
and
high
organic
removal
efficiency.
This
technology
has
been
applied
to
treat
wastes
completely
while
achieving
maximum
volume
reduction
(Womack
1999).
Waste
streams
that
have
shown
substantial
benefit
from
the
PACT
process
are
low-level
nuclear
waste,
paints,
pharmaceutical
sludges,
pyrotechnics,
military
chemical
agents,
blast
media,
and
solvents.
Common
features
among
these
wastes
are
the
presence
of
heavy
metals
and
often-heterogeneous
mixtures
of
organic
materials,
soils,
metals,
and
water
(Womack
1999).
The
PACT
system
meets
all
of
the
U.S.
Environmental
Protection
Agency’s
(USEPA)
requirements
for
air
emissions
through
high-temperature
treatment
and
system
design.
Pilot-scale
tests
were
performed
for
the
USEPA
Superfund
Program
on
wastes
from
Silverbow
Creek,
the
Montana
Pole
plant
in
Butte,
Montana
and
the
US
Army
Proving
Grounds
in
Aberdeen
Maryland
(Womack
1999).
The
STAR
system
is
a
self-sustaining
treatment
for
active
remediation
based
on
principles
of
smoldering
combustion
that
uses
the
contaminants
as
the
fuel.
It
can
be
used
below
ground
surface,
that
is
in-situ
or
in
chambers
on
the
ground
surface
that
is
ex-situ
.
The
advantages
to
the
STAR
system
as
compared
to
excavation
and
disposal
include
less
environmental
impact,
greater
efficacy,
safer,
quicker,
and
therefore
more
cost
effective
(Thompson
and
Grant
2014).
The
STAR
system
has
been
used
effectively
on
contaminants
in
the
vadose
zone,
i.e.,
above
groundwater,
and
below
groundwater.
It
is
effective
on
hydrocarbon
contaminated
soils,
sludges,
and
oily
wastes,
and
has
effectively
been
used
on
a
37-acre
cresol
manufacturing
facility
in
New
Jersey
(Thompson
and
Grant
2014).
This
comment
requests
that
unspecified
earlier
comments
be
noted.
Responses
to
each
comment
provided
in
the
BBCAG
letter
are
provided.
The
comment
presents
several
opinions,
but
does
not
provide
factual
evidence
supporting
those
opinions.
The
remediation
of
the
landfill
in
compliance
with
Title
27
and
geotechnical
specifications
to
achieve
desired
grade
and
elevations
for
the
proposed
development
and
to
minimize
contact
with
leachate
will
also
be
developed
to
minimize
ground
settlement.
In
addition,
the
City
will
require
compliance
with
California
Building
Code
requirements
standards
related
to
grading
and
ground
settlement
as
part
of
its
planning
review
process.
See
5
for
discussion
of
compliance
with
the
law
as
mitigation
under
CEQA.
Brisbane
Baylands
Final
EIR
2.9.1-70
May
2015