2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
reference
quote
in
this
comment
attributed
to
paragraphs
on
page
4.G-3
of
the
Draft
EIR
does
not
actually
appear
in
the
Draft
EIR.
The
Draft
EIR
does,
however,
state
“Activities
within
a
site
can
result
in
spills
or
leaks
of
hazardous
materials
to
the
ground,
causing
soil
and/or
groundwater
contamination.
This
occurs
for
various
reasons,
due
to
(1)
activities
occurring
in
violation
of
regulatory
standards,
(2)
past
activities
that
occurred
prior
to
the
establishment
of
regulatory
standards
or
(3)
past
activities
that
occurred
legally
under
previous,
less
stringent
regulatory
controls
than
currently
exist.”
The
first
sentence
of
paragraph
two
states
“Exposure
to
some
chemical
substances
may
harm
internal
organs
or
systems
in
the
human
body,
ranging
from
temporary
effects
to
permanent
disability
or
death.”
The
three
paragraphs
on
page
4.G-3
explain
how
constituents
can
impact
media,
the
differences
between
risk
and
hazard
from
a
toxicity
perspective,
and
probability
of
exposure
and
severity
of
harm
due
to
exposure.
Those
paragraphs
do
not
refer
specifically
to
proposed
Baylands
development.
The
section
of
the
Draft
EIR
referenced
in
this
comment
does
not
discuss
“drilling,
pile
driving
or
moving
earth.”
Landfill
closure
pursuant
to
the
requirements
of
Title
27
necessitates
placement
of
an
impermeable
cap
on
the
former
landfill.
In
addition,
any
development
of
the
Project
site
will
involve
some
degree
of
grading.
Thus,
earth
movement
within
the
Baylands
is
unavoidable.
Because
site
remediation
will
be
required
prior
to
grading
activities,
and
the
fill
material
used
for
Title
27
closure
will
be
prohibited
from
creating
any
new
exposure
pathways
that
could
harm
public
health
or
the
environment,
site
grading
will
result
in
less
than
significant
hazardous
materials
impacts.
Any
drilling
needed
to
provide
for
adequate
building
foundations
will
be
required
to
comply
with
Title
27
and
the
requirements
of
the
RWQCB.
Such
drilling
will
be
required
to
avoid
permitting
the
movement
of
leachates
or
other
contaminants
into
the
groundwater
basin.
Any
pile
driving
activities
occurring
within
the
Baylands
will
be
regulated
so
as
to
minimize
vibrations
per
the
requirements
of
Mitigation
Measures
4.J-2a
and
4.J-2b.
As
a
result,
impacts
related
to
pile
driving
would
be
less
than
significant.
The
section
of
the
Draft
EIR
cited
in
this
comment
discusses
historic
investigations
and
assessments
onsite.
Existing
contamination
and
assessment
within
the
Project
site
are
addressed
in
the
Draft
EIR
on
pages
4.G-4
through
4.G-18.
An
overview
of
hazardous
materials
and
contamination
within
the
Baylands
is
presented
on
pages
4.G-20
through
4.G-55.
See
for
discussion
regarding
the
adequacy
of
existing
studies
for
use
in
the
Draft
EIR.
Brisbane
Baylands
Final
EIR
2.9.2-81
May
2015