2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
Health
System
as
identified
in
Closure
and
Post
Closure
Plans.
The
remedial
activities
will
include
but
not
be
limited
to
the
following:
(1)
operations
and
maintenance
of
the
existing
Leachate
Seep
Collection
and
Transmission
System,
(2)
operation
and
maintenance
of
the
landfill
Gas
Collection
and
Control
System,
(3)
continued
groundwater,
surface
water
and
leachate
quality
monitoring
and
evaluation,
(4)
installation
of
a
final
cover
system
over
the
entire
landfill.
While
the
Draft
EIR
identifies
likely
technologies
that
might
be
employed
in
the
remediation
and
Title
27
closure
of
the
former
landfill,
because
the
RWQCB
has
the
ultimate
authority
to
determine
the
technologies
to
be
employed,
the
Draft
EIR
does
not
close
off
alternatives
beyond
“cap
in
place.”
A
federal
and
State
database
search
of
records
for
the
site
was
conducted
as
part
of
the
Draft
EIR
by
using
the
search
firm
Environmental
Data
Resources,
Inc.
No
federal
records
regarding
disposal
of
hazardous
materials
regardless
of
source
were
identified.
See
for
discussion
of
the
remediation
review
and
approval
process.
Because
the
land
uses
currently
proposed
for
are
different
than
those
originally
proposed
in
2002,
along
with
advances
in
technologies,
a
new
Remedial
Action
Plan
will
be
required.
The
RAP
for
will
be
required
to
meet
current
regulatory
requirements,
as
well
as
comments
received
from
the
regulatory
agency,
recognizing
changes
in
proposed
future
land
use
and
updated
risk-based
cleanup
levels
based
on
the
land
uses
determined
by
the
City
of
Brisbane
to
be
appropriate
within
the
Baylands.
See
for
discussion
regarding
land
use
compatibility
and
the
Kinder
Morgan
tank
farm.
The
potential
risk
identified
in
the
Draft
EIR
is
related
to
leaks
from
aboveground
storage
tanks
rather
than
unpredictable
catastrophic
events
such
as
lightning
strikes
and
train
derailments.
The
Kinder
Morgan
facility
has
secondary
containment
around
the
aboveground
storage
tanks
to
mitigate
leaks
and
the
tanks
are
integrity
tested
to
ensure
compliance
with
applicable
federal,
State,
and
local
regulations.
The
Draft
EIR
relied
on
the
regulatory
authority
and
responsibility
of
the
RWQCB
to
enforce
the
law,
including
compelling
Kinder
Morgan
to
comply
with
applicable
laws
and
regulations
for
the
protection
of
the
public
health
and
safety.
See
5
for
discussion
regarding
compliance
with
the
law
as
mitigation
under
CEQA.
See
for
discussion
regarding
land
use
compatibility
and
the
Kinder
Morgan
tank
farm.
Pursuant
to
the
requirements
of
CEQA,
the
Draft
EIR
analyzes
the
physical
Brisbane
Baylands
Final
EIR
2.9.2-88
May
2015