2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
risk
values
for
the
Sunquest
Properties
(the
operator
on
the
BAAQMD
permit
for
the
landfill
gas
collection
system
and
flare
at
the
nearest
proposed
sensitive
receptors)
are
presented
in
Table
4.B-20
of
the
Draft
EIR.
While
methane
combusted
from
the
collection
system
burns
relatively
cleanly,
the
risk
values
in
Table
4.B-20
reflect
impurities
in
the
landfill
gas
from
constituents
such
as
benzene,
perchloroethylene,
and
vinyl
chloride.
Impact
4.B-
6
of
the
Draft
EIR
assesses
the
impacts
of
existing
stationary
sources
such
as
Sunquest
Properties
facilities
as
well
as
roadway
sources
and
railway
contributions
to
increased
cancer
risk
and
hazard
impacts
on
proposed
receptors
relative
to
BAAQMD
identified
criteria.
This
impact
was
determined
in
the
Draft
EIR
to
be
less
than
significant.
Hazard
impacts
from
the
off-gassing
of
landfill
gas
are
assessed
in
Section
4.G,
Hazards
and
Hazardous
Materials,
of
the
Draft
EIR.
Impact
4.G-2
of
the
Draft
EIR
found
that
soil
gas
and
vapor
intrusion
from
legacy
contamination
represent
a
significant
impact.
Mitigation
Measures
4.G-2f
through
4.G-2h
are
identified
for
all
development
scenarios
to
reduce
hazard
impacts
from
landfill
gas
to
a
less
than
significant
level,
which
include
installation
of
soil
vapor
barriers
and
gas
sensors.
There
is
no
evidence
to
suggest
that
radioactive
materials,
either
naturally
occurring
or
deposited,
exist
within
the
Baylands
Project
site.
The
risk
values
presented
in
Table
4.B-20
for
the
Kinder
Morgan
facility
and
other
stationary
sources
reflect
both
risks
associated
with
the
facilities
and
distance
to
the
nearest
sensitive
receptor.
The
BAAQMD-reported
property
line
(onsite)
cancer
risk
for
the
Kinder
Morgan
facility
is
26.4
excess
cancer
cases
per
million
while
the
BAAQMD-reported
property
line
(onsite)
cancer
risk
for
the
Bayshore
Chevron
Station
is
13.4
excess
cancer
cases
per
million.
Therefore,
the
property
line
(onsite)
risk
from
the
Kinder
Morgan
facility
is
greater
than
this
gasoline
station.
However,
the
distance
of
the
Kinder
Morgan
facility
from
the
nearest
proposed
sensitive
receptor
(approximately
1,300
feet)
results
in
a
lower
risk
than
the
distance
between
the
service
stations
which
are
closer
to
proposed
sensitive
receptors
(approximately
200
feet
away).
Emissions
from
the
Kinder
Morgan
Facility
are
primarily
the
result
of
vapor
loss
during
fuel
transfer
activities.
The
tanks
and
pipelines
have
very
limited
fugitive
emissions.
These
emissions
are
primarily
in
the
form
of
Reactive
Organic
Gases
(ROG),
which
are
not
a
localized
pollutant,
but
rather,
react
in
the
atmosphere
to
form
ozone
at
downwind
locations.
Consequently,
health
risks
from
emissions
at
this
facility
are
primarily
related
to
toxic
air
contaminants
in
the
fuel
and
not
from
ROG.
Brisbane
Baylands
Final
EIR
2.9.2-19
May
2015