land uses approved by the City of Brisbane for the Baylands. The updated RAP will address potential exposure pathways and all relevant constituents of concern. The specific remedial activities that will be permitted within the Baylands will be determined by the RWQCB as the designated regulatory agency for OU-2 based on the updated human health risk assessment, which will provide risk-based cleanup goals that are protective of human health and the environment. Thus, the Draft EIR concluded that impacts would be less than significant.

BBCAG-233

[See page 5-137 for the original comment] See Response BBCAG-215. The former Brisbane Landfill contains refuse from residential; commercial; industrial activities including shipyard waste; and construction rubble, tires, and sewage.

The fill materials underlying the former railyard (the 218-acre site west of the railroad tracks) are documented as comprised of earthquake rubble and were filled from 1906-1914 (Draft EIR Appendix B). The site east of the railroad tracks remained San Francisco Bay until the 1930s when demand for a landfill for municipal waste led to the gradual filling of this portion of the San Francisco Bay and by extension the creation of land. The completion of US Highway 101 in the 1950s delineated the eastern boundary of the landfill (Draft EIR Appendix B).

The third paragraph on page 4.G-90 is revised to read as follows.

Former landfill operations resulted in the disposal of 12.5 million cubic yards of non-hazardous domestic, industrial, and shipyard waste at the Brisbane Landfill from between 1930 to and 1967 from residential, commercial, industrial activities including shipyard waste, as well as construction rubble, tires, and sewage. The thickness of the current soil cover ranges from a few feet to over 30 feet in some locations and soil movement or grading could take place in areas where the soil cover remains shallow. OU-1 still overlies a plume of VOC-impacted groundwater. Contaminants at OU-2 are widespread over the former railyard, with metals impacts in soil occurring in fill materials sitewide. Bunker C fuel impacts in soil and groundwater are limited to areas where fueling operations and disposal took place.

BBCAG-234

[See page 5-137 for the original comment] No factual evidence is included in this comment to support its conclusions. Regulatory authority for landfill closure rests with the RWQCB, which will determine the specific activities to be employed for landfill closure to meet Title 27 requirements. See Master Response 5 for discussion of compliance with the law as mitigation under CEQA and Master Response 13 for discussion of the Title 27 landfill closure review and approval process. The Draft EIR text referenced in this comment addresses the potential for reasonably foreseeable upset or accident conditions to result in a release of hazardous materials.