Site-Specific Health and Safety Plan (HASP) - Laschools.org

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APPENDIX G 

Health and Safety Plan (HASP) 

156

Site-Specific Health and Safety Plan (HASP) 

Proposed South Region High School #9 & Middle School #4, 

5246 Tweedy Boulevard, South Gate, California 

Prepared For: 

LOS ANGELES UNIFIED SCHOOL DISTRICT 

Office of Environmental Health and Safety 

1055 W 7 th St., 9 th Floor 

Los Angeles, California 90017 

Prepared By: 

Parsons 

100 WEST WALNUT STREET • PASADENA • CALIFORNIA 91124 

May 2008 

157

Prepared by: 

Reviewed by: 

Approved by: 

SITE-SPECIFIC HEALTH AND SAFETY PLAN 

Proposed South Region High School #9 and Middle School #4 

5246 Tweedy Boulevard, South Gate, California 

Timothy P. Wendler 

Project Engineer 

Prepared for 

Los Angeles Unified School District 


1055 W 7 th St., 9 th Floor 


Jerry Clark, CSP, CIH 

Health and Safety Manager 

Jim Goepel 

Project Manager 

May 2008 

Prepared by 

PARSONS 

100 WEST WALNUT STREET 

PASADENA • CALIFORNIA 91124 

Date 

Date 

Date 

158

LAUSD Proposed South Region High School #9 & Middle School #4 

TABLE OF CONTENTS 

i 

January 2007 

Site Specific Health & Safety Plan (HASP) 

ABBREVIATIONS AND ACRONYMS………………………………………………..…v 

1.0 INTRODUCTION ................................................................................................. 1-1 

1.1 PARSONS WORKPLACE HEALTH & SAFETY POLICY ................................ 1-1 

1.2 THE PROJECT HEALTH AND SAFETY PLAN (HASP) ................................... 1-2 

1.3 SUBCONTRACTOR SAFETY PLANS ............................................................................ 1-2 

2.0 PROJECT DESCRIPTION AND SCOPE OF WORK ......................................... 2-1 

2.1 SCOPE OF WORK ..................................................................................................... 2-1 

2.2 PROJECT SAFETY PLAN APPLICATION ........................................................ 2-1 

3.0 TEAM ORGANIZATION..................................................................................... 3-1 

4.0 ADMINISTRATIVE PHASE................................................................................ 4-1 

4.1 PROJECT SAFETY COMMITTEE ................................................................................ 4-1 

4.2 PROJECT ORIENTATION........................................................................................... 4-1 

4.3 AWARENESS CAMPAIGN .......................................................................................... 4-1 

4.4 STAKEHOLDER HASP ALIGNMENT MEETING......................................................... 4-2 

4.5 TRAINING................................................................................................................ 4-2 

4.6 AUDITS AND INSPECTIONS ...................................................................................... 4-3 

4.7 MEETINGS............................................................................................................... 4-3 

4.8 REPORTING AND MEASUREMENT............................................................................ 4-3 

4.8.1 Reporting....................................................................................................... 4-3 

4.8.2 Measurement................................................................................................. 4-3 

4.8.3 Incident Notification ..................................................................................... 4-4 

4.9 INCIDENT INVESTIGATIONS........................................................................... 4-5 

4.10 RESPONSIBILITY/IDENTIFICATION OF KEY LINE PERSONNEL.............. 4-6 

4.11 MEDICAL REQUIREMENTS AND WORKERS COMPENSATION................ 4-6 

4.11.1 Functional Capacity Exams (FCEs).............................................................. 4-6 

4.11.2 Substance Abuse and Alcohol Testing ......................................................... 4-7 

4.11.3 Medical Services and Panel of Physicians.................................................... 4-7 

4.11.4 Emergency Medical Response...................................................................... 4-8 

4.11.5 Workers Compensation Program.................................................................. 4-11 

4.11.6 Medical Surveillance Programs and/or Monitoring...................................... 4-12 

5.0 PRE-FIELD WORK PHASE................................................................................. 5-1 

5.1 RISK ANALYSIS AND SAFETY SPECIFICATION DEVELOPMENT ................................ 5-1 

5.2 DESIGN AND REMEDIAL ACTION REVIEW............................................................... 5-1 

5.3 PRE-BID MEETING................................................................................................... 5-2 

5.4 CONTRACTOR SAFETY EVALUATION ...................................................................... 5-2 

5.5 PRE-FIELD WORK MEETING ................................................................................... 5-2 

5.6 COMPETENT PERSON SUBMISSION REVIEW ............................................................ 5-2 

5.7 SUBCONTRACTOR SAFETY PLAN (SSP) SUBMISSION REVIEW ................................ 5-4 

5.7.1 Contractor Site-Specific Safety Plans........................................................... 5-4 

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December 2006 


5.8 MOBILIZATION/KICKOFF SAFETY MEETING ........................................................... 5-5 

6.0 REMEDIATION PHASE ...................................................................................... 6-1 

6.1 SITE RISK ANALYSIS............................................................................................... 6-1 

6.2 FIVE HAZARD CONTROL MEASURES – ORDER OF PRECEDENCE ............................. 6-4 

6.3 ACTIVITY HAZARDS ANALYSIS............................................................................... 6-5 

6.3.1 Chemical Hazards ......................................................................................... 6-7 

6.3.2 Physical Hazards........................................................................................... 6-7 

6.3 BIOLOGICAL HAZARDS ........................................................................................... 6-14 

6.4 SAFETY SYSTEMS ANALYSIS................................................................................... 6-19 

6.5 REMEDIATION SITE INSPECTION ............................................................................. 6-19 

6.6 DAILY SITE WALK CHECKLIST ............................................................................... 6-19 

6.7 SAFETY AND HEALTH ENFORCEMENT..................................................................... 6-21 

6.8 NOTICE OF VIOLATION OF SAFETY AND HEALTH REGULATIONS ............................ 6-21 

6.9 COMPETENT FIRST AID PERSON.............................................................................. 6-21 

7.0 SAFETY TRAINING ............................................................................................ 7-1 

7.1 PROJECT SAFETY ORIENTATION.............................................................................. 7-1 

7.2 PARSONSU SAFETY MODULES AND START TRAINING – ZERO INCIDENT TECHNIQUES 

............................................................................................................................... 7-1 

7.3 DAILY TOOLBOX SAFETY MEETINGS...................................................................... 7-5 

7.4 ACTIVITY HAZARDS ANALYSIS TRAINING.............................................................. 7-5 

7.5 REGULATORY TRAINING PROGRAMS ...................................................................... 7-5 

7.6 OSHA OUTREACH PROGRAMS ............................................................................... 7-5 

7.7 SPECIALIZED TRAINING AND ORIENTATIONS .......................................................... 7-6 

7.8 VISITOR TRAINING.................................................................................................. 7-6 

8.0 RECORDKEEPING AND POSTING................................................................... 8-1 

9.0 SAFETY AND HEALTH REQUIREMENTS...................................................... 9-1 

9.1 SAFETY AND HEALTH REQUIREMENTS.................................................................... 9-1 

10.0 LEVELS OF PROTECTION AND PERSONAL PROTECTIVE EQUIPMENT 

REQUIRED FOR SITE ACTIVITIES .................................................................. 10-1 

10.1 PERSONAL PROTECTIVE EQUIPMENT ...................................................................... 10-1 

10.1.1 Level D.......................................................................................................... 10-1 

10.1.2 Modified Level D.......................................................................................... 10-1 

10.1.3 Level C Protection ........................................................................................ 10-2 

10.2 SELECTION OF LEVELS OF PROTECTION AND ACTION LEVELS................................ 10-2 

10.3 EQUIPMENT NEEDS ................................................................................................. 10-5 

10.4 EQUIPMENT DISPOSAL ............................................................................................ 10-5 

11.0 FREQUENCY AND TYPES OF AIR MONITORING........................................ 11-1 

11.1 AIR MONITORING.................................................................................................... 11-1 

11.2 TYPES AND FREQUENCY OF AIR MONITORING........................................................ 11-1 

11.3 CALIBRATION AND RECORDKEEPING ...................................................................... 11-3 

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12.0 SITE CONTROL MEASURES............................................................................. 12-1 

12.1 SITE ORGANIZATION-OPERATION ZONES ............................................................... 12-1 

12.1.1 Exclusion Zone ............................................................................................. 12-1 

12.1.2 Contamination Reduction Zone .................................................................... 12-1 

12.1.3 Support Zone................................................................................................. 12-2 

12.2 SITE SECURITY........................................................................................................ 12-2 

12.3 SITE COMMUNICATION ........................................................................................... 12-2 

12.4 SAFE WORK PRACTICES.......................................................................................... 12-3 

13.0 DECONTAMINATION PROCEDURES ............................................................. 13-1 

14.0 SPILL RESPONSE PLAN .................................................................................... 14-1 

14.1 SPILL CONTAINMENT EQUIPMENT .......................................................................... 14-1 

14.2 SPILL CONTAINMENT PROCEDURES ........................................................................ 14-1 

14.3 SPILL REPORTING PROCEDURES.............................................................................. 14-2 

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iv 

December 2006 


TABLES 

1-1 Project Subcontractors 

3-1 Key Personnel 

3-2 Roles and Responsibilities 

4-1 Responsibilities of Key Personnel 

4-2 Medical Surveillance Requirements 

5-1 Competent Person Listing 

6-1 Hazardous Substances of Concern 

6-3 Suggested Frequency of Physiological Monitoring for Fit and Acclimated Workers 

7-1 Specialized Training and Orientations 

9-1 Competent Person and Activity Hazards Analysis Requirements 

10-1 Action Levels for VOCs 

10-2 Action Levels for Particulates 

11-1 Air Monitoring Equipment 

11-2 Measures to Minimize Potential Fire or Explosions from Combustible Gases 

EXHIBITS 

1-1 Parsons Workplace Health and Safety Policy 

5-1 Standard Pre-Field Work Safety Meeting Checklist 

5-2 Site Specific Risk Review Checklist 

5-3 Mobilization/Kickoff Safety Meeting Checklist 

6-1 Activity Hazards Analysis Form 

6-2 Activity Hazards Analysis Training Record Exhibit 

6-3 Remediation Safety and Health Inspection Checklist 

6-4 Notice of Subcontractor Violation of Safety and Health Regulations 

7-1 Employee/Subcontractor Training Acknowledgement 

7-2 Safety Meeting Sign-In Sheet 

12-1 Site Control Zones 

ATTACHMENTS 

1 Emergency Contacts, Incident Reporting Guidelines, and Map to Hospital 

2 HASP Orientation 

3 Activity Hazard Analysis Tables 

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ABBREVIATIONS AND ACRONYMS 

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December 2006 


ACGIH American Conference of Governmental Industrial Hygienists 

AHA activity hazard analysis 

AHERA Asbestos Hazard Emergency Response Act 

APR air-purifying respirator 

BTEX benzene, toluene, ethylbenzene, and xylene 

CCR California Code of Regulations 

Cal/EPA California Environmental Protection Agency 

Cal/OSHA California Occupational Safety and Health Administration 

CPR cardiopulmonary resuscitation 

COC chemical of concern 

DBA Decibals 

DEET N,N diethyl-meta-toluamide 

DHS Department of Health Services 

DOT Department of Transportation 

DTSC Department of Toxic Substances Control 

EPA United States Environmental Protection Agency 

ESLI End-of-service-life-indicator 

EV electron volt 

FHSR Facility Health and Safety Representative 

H2S hydrogen sulfide 

HASP Health and Safety Plan 

HEPA high efficiency particulate air 

HUD Department of Housing and Urban Development 

IDLH immediately dangerous to life or health 

IP ionization potential 

LAUSD Los Angeles Unified School District 

LBP lead-based paint 

LEL lower explosive limit 

MSDS material safety data sheet 

MA Milliamp 

NEC National Electric Code 

NIOSH National Institute for Occupational Safety and Health 

PAH polyaromatic hydrocarbons 

PCB polychlorinated biphenyls 

PEL permissible exposure limit 

PID photoionization detector 

PPE personal protective equipment 

PM project manager 

QA quality assurance 

QC quality control 

SHSO Site Health and Safety Officer 

SITE Proposed South Region High School #9 and Middle School #4 

TCA Trichloroethane 

TLV threshold limit value 

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ABBREVIATIONS AND ACRONYMS 

TWA time-weighted average 

USA Underground Service Alert 

UST underground storage tank 

V Volt 

VOC volatile organic compound 

Ft foot or feet 

Ppm parts per million 

vi 

December 2006 


164


1.0 INTRODUCTION 

1-1 

December 2006 


1.1 PARSONS WORKPLACE HEALTH & SAFETY POLICY 

Exhibit 1-1 – Parsons Workplace Health and Safety Policy 

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1-2 

December 2006 


1.2 THE PROJECT HEALTH AND SAFETY PLAN (HASP) 

The purpose of this health and safety plan (HASP) is to establish personnel protection standards 

and mandatory safety practices for all Parsons and subcontractor personnel involved with site 

investigation (including soil, soil gas, and groundwater), pilot testing, site remediation, and 

hazardous waste management activities at the Los Angeles Unified School District (LAUSD) 

Proposed South Region High School #9 and Middle School #4 (Site). The goal of this safety 

program is to conduct the entire project with zero accidents and incidents (this includes 

environmental releases, property damage and near misses). All task activities shall be designed 

for zero accidents. This plan provides guidance and site-specific information for field operation 

and provides for contingencies that may arise. All Parsons field team members and 

subcontractors are responsible for reading and conforming to this plan. All personnel must share 

responsibility in performing all work in such a manner and under such conditions to preclude or 

minimize the possibility of damage to property or injury to themselves or others. No employee 

will perform a project activity that he or she believes may endanger his or her health and safety 

or the health and safety of others. Carelessness or disregard of accepted safety, health, and fire 

protection standards will not be tolerated. Any field team member who does not comply with 

established safety procedures may be subject to immediate dismissal and future exclusion from 

the site. 

This Plan will be updated as conditions change or situations change, usually by addenda to the 

HASP. All Parsons and subcontractor personnel must understand and implement the HASP and 

any addenda. Parsons documents this by having employees sign an acknowledgement form 

stating that they understand the plan and its requirements. 

1.3 SUBCONTRACTOR SAFETY PLANS 

Parsons’ subcontractors must establish a safety program for their work and employees. Contract 

specifications require all subcontractors to accept Parsons HASP, but also prepare their own 

Subcontractor Safety Plan (SSP) for presentation to Parsons Project Manager and Division 

Safety Manager at least 10 days before site mobilization. At a minimum, subcontractor safety 

and health plans must meet the requirements of this HASP and provide safety equipment and 

safeguards suitable for the hazards involved. This HASP may not cover all potential hazards on 

the project and subcontractors must ensure that appropriate safety and health information is 

available for all project tasks. 

All HASP requirements for Parsons personnel (e.g., training, substance abuse screening, and 

incident reporting) also apply to subcontractor personnel and should be spelled out in the 

subcontractor’s safety plan (SSP). 

If a subcontractor is performing activities that require specialized training (i.e. confined space 

entry, excavation/trenching, scaffold use, HAZWOPER, etc.), then copies of training 

certifications must be provided for applicable employees and the supervisor. 

Subcontractor supervisors must possess the following certifications for applicable operations – 

HAZWOPER 8-hour Supervisor (29 CFR 1910.120(e)(4) - not to be confused with 8-hour 

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annual refresher), confined space entry [29 CFR 1910.146(j)], excavation competent person [29 

CFR 1926.651(k)] and scaffold competent person [29 CFR 1926.451(f)]. 

For this project, subcontractors will be directly hired by Parsons. 

The subcontractors directly hired by Parsons that may be working on the project include (Table 

1-1): 

Table 1-1: Project Subcontractors 

SUBCONTRACTOR WORK ACTIVITIES EVALUATION 

GRADE 

BC 2 Environmental Corp Drilling C 

Blainetech Groundwater Monitoring B 

G.E.M. (General 

Environmental Management, 

Inc.) 

Waste Management B 

Geovision Inc. Underground Utilities 

Surveys 

B 

Hydrogeospectrum Soil Gas Sampling and 

Analysis 

C 

Kehoe Drilling and soil sampling B 

Layne Christensen Company Drilling B 

Test America Analytical Corp Sample Analysis B 

Wagner Engineering and 

Survey 

Surveying Pending 

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December 2006 


2.0 PROJECT DESCRIPTION AND SCOPE OF WORK 

Parsons, in its contracted role with LAUSD is providing environmental investigation, 

remediation, and hazardous waste management activities at the Site for the work as specified in 

Master Services Agreement# 0800084. 

2.1 SCOPE OF WORK 

The Site is located near the corner of Tweedy Boulevard and Adella Avenue in South Gate, 

California. The Site is about 35 acres and consists of 35 industrial, commercial, and residential 

properties, designated as Parcels 1 through 39 (not including Parcels 21, 25, and 34, which do 

not exist, and Parcel 28, which is not part of the Site). It is bordered by the Los Angeles River to 

the east, residential neighborhoods to the north and south, and other industrial/commercial 

operations to the west. Due to a wide range of industrial activities that occurred at the Site, soil 

and groundwater contamination are present throughout a large portion of the 35-acre site. 

Various site investigations have been performed at the Site over the past 15 years. Previous 

investigations at the Site include investigations by ICF Kaiser (1989), Thorne Environmental 

(Thorne) (1990), Black and Veatch (1999), Miller Brooks Environmental (various dates), State 

Environmental (various dates), Alta Environmental (various dates), and Parsons (2002 and 

2003). 

Possible field activities include the following tasks: 

• Asphalt Cap Maintenance Work 

• Excavation 

• Groundwater Monitoring 

- Geophysical logging of wells 

- Well maintenance 

- Well abandonment 

- Well drilling/installation 

- Well development 

- Groundwater sampling 

- Aquifer pump testing 

• Groundwater Cleanup Pilot Testing 

• Soil Gas Sampling 

• Soil Gas Cleanup Pilot Testing 

• Drilling Boreholes and Soil Sampling 

• Surveying 

• Underground Storage Tank Removal 

• Hazardous Waste Management 

• Disposal of bulk liquids in subsurfaces (clarifiers, sumps, vaults, and a possible UST) 

2.2 PROJECT SAFETY PLAN APPLICATION 

This HASP and referenced documents applies to all locations, facilities, operations, and projects 

associated with contract work performed by Parsons and its subcontractors. Locations/sites 

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covered under this contract including the Proposed South Region High School #9 and Middle 

School #4 (the Site). 

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3.0 TEAM ORGANIZATION 

3-1 

December 2006 


The key Parsons personnel assigned to the LAUSD include a Project Manager (PM), a Field 

Team Manager, and a Site Health and Safety Officer (SHSO). The Parsons team assigned to the 

project, their responsibilities, and lines of authority are outlined below (Table 3-1). 

Table 3-1: Key Personnel 

Task Assigned Name 

Project Manager Jim Goepel 

Project Health and Safety Manager Josh Sacker, PG 

Pasadena Facility Health and Safety Kristin Guthrie 

Representative 

Field Team Manager Josh Sacker, PG 

Site Health and Safety Officer Kristin Guthrie 

The PM is directly responsible for the execution of all phases of this project. The PM also is 

responsible for planning, staffing, ensuring quality assurance/quality control (QA/QC), executing 

each phase of the work, coordinating with the client, interpreting data, and reporting. The PM 

will also ensure that each task and project is covered under this HASP. The PM will ensure 

preparation of an HASP addendum for tasks not covered in the HASP, including identification of 

specific site activity and/or conditions and preparation, review, and completion of an activity 

hazard analysis (AHA) for those activities. The PM will be responsible for ensuring that a 

subcontractor’s health and safety requirements are based on LAUSD, the California 

Occupational Safety and Health Administration (Cal/OSHA), and project health and safety 

requirements. The PM will communicate potential site hazards to all Parsons subcontractors. 

The Project Health and Safety Manager and Pasadena Facility Health and Safety Representative 

(FHSR) will be responsible for updating and revising the HASP, as needed. The PM and FHSR 

also are responsible for ensuring that all field team members meet health and safety training and 

medical monitoring requirements. 

The Field Team Manager and SHSO will support the PM for the specific work that will be 

accomplished at the Site and will be responsible for scheduling and coordinating the field 

activities at the Site. The Field Team Manager will assist the PM in the organization and 

execution of health and safety requirements for project tasks. The SHSO will ensure that all 

field activities are performed with strict adherence to Cal/OSHA requirements, this HASP, and 

any HASP addenda. The SHSO has the authority to stop work if actions or conditions are judged 

to be unsafe or not in conformance with this HASP or an addendum to the HASP. 

All LAUSD project team members are responsible for reading and conforming to this HASP. 

No employee shall perform a project activity that he or she believes may endanger his or her 

health and safety or the health and safety of others. Team members should report any unsafe or 

unhealthful situation or condition to the SHSO and/or field team manager. If a team member 

prefers, and if the concern is not an emergency, concerns may be reported anonymously to the 

Corporate Health and Safety Manager. 

Subcontractors are responsible for the health and safety of their employees. 

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Table 3-2 summarizes the responsibilities of selected roles for Parsons Project, Division, GBU 

and Corporate personnel related to the primary safety activities identified in this HASP. 

Table 3-2: Roles and Responsibilities 

171


4.0 ADMINISTRATIVE PHASE 

4.1 PROJECT SAFETY COMMITTEE 

4-1 

December 2006 


Depending on the size and type of project, a safety committee that includes representation from 

all project stakeholders shall be formed. If the project has less than five Parsons employees or 25 

subcontractors, then a Project Safety Committee will be handled at the Program or Facility level. 

The Program or Facility H&S Representative is responsible for communicating information from 

the Division Safety Manager conference call with the project personnel on a monthly basis. 

Review of the meeting minutes from the Division Safety Manager conference call will take place 

at times and locations to be determined and posted by the Project Manager on the safety 

billboard at least one week in advance. For this project, the Project Safety Committee will be 

handled at the Program level. 

4.2 PROJECT ORIENTATION 

The Project Safety Representative meets with new workers to review site procedures and 

requirements listed in the HASP Orientation (Attachment 2). Topics covered in the HASP 

orientation include: 

• Names of personnel responsible for site safety and health 

• Reporting emergencies, incidents and unsafe conditions 

• Emergency/evacuation plans 

• Safety, health and other hazards at the site 

• Review of all activities on site and related Activity Hazard Analyses (AHAs) 

• Proper use of personal protective equipment 

• Work practices by which a worker can minimize risk from hazards 

• Safe use of engineering controls and equipment on site 

• Acute effects of compounds at the site 

• Location of the written Hazard Communication Program and Material Safety Data 

Sheets (MSDS’s) 

• Decontamination procedures 

All personnel, including subcontractors and visitors, on a project must receive a HASP 

orientation prior to starting work or accessing the site and sign an acknowledgment form 

indicating they received and understood the orientation. Any individual who is unsure of any 

information presented in the orientation must request clarification. Individuals who do not 

participate in the orientation or refuse to sign the acknowledgment cannot work on or access the 

site. 

4.3 AWARENESS CAMPAIGN 

The project has established an awareness program consistent with the Parsons safety awareness 

campaign and its various elements (e.g., signs, posters, banners, and focus briefings). This 

program promotes worker awareness of safety goals and daily risks, hazards, and exposures in 

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the field. In addition to topics selected by corporate safety each month, the project will 

supplement the awareness program with information specifically applicable to the scope of work. 

Safety bulletin boards maintained by the Project Safety Representative are primary information 

points for the project awareness campaign. Bulletin boards are located at the Parsons field office 

at Parcel 2 and the Parsons office at 100 W Walnut Street, Pasadena, California. 

The Project Safety Representative may also provide training, presentations, or informational 

materials as part of the awareness campaign. 

4.4 STAKEHOLDER HASP ALIGNMENT MEETING 

A stakeholder PSP alignment meeting must be held. The following representatives will attend the 

meeting held before implementation of the next phase of field work: 

For calendar year 2008, safety committee members are as follows: 

• Chairperson – Josh Sacker, Program Health and Safety Manager 

• Jim Goepel, Program Manager 

• Kristin Guthrie, Facility Health and Safety Manager 

• Greg Beck, Parsons Industrial Division Safety Manager 

• Prudence Boczarski-Daniel, Los Angeles Unified School District 

Parsons will present the HASP and all stakeholders must concur with the approach outlined in 

the plan. The meeting will also include a review of stakeholder roles and responsibilities and 

elements of control appropriate to project risks. 

4.5 TRAINING 

The project has a comprehensive health and safety training program tailored to the scope of 

work. All employees receive a Project Orientation as outlined in Section 4.2 upon assignment to 

the project. All Parsons new hires shall receive a facility Employee Orientation within the first 7 

days of employment, provided by Human Resources, Facility Manager, Safety Representative 

and Staff Coordinator or their designee. Specific training topics for this project, as appropriate, 

will include: 

• 40-hour HAZWOPER and 8-hour annual HAZWOPER refresher – if applicable, 

specific language to be used shall state: All personnel engaged in hazardous 

substance removal or other activities that expose or potentially expose them to 

hazardous substances or health hazards shall receive appropriate training as 

required by 29 CFR 1910.120, including, but not limited to, initial 40-hour, 8-hour 

Supervisor and annual 8-hour refresher training. 

• Department of Transportation (DOT) - HM126F 

• Respiratory Protection 

• Lockout/Tagout 

• Confined Space Entry 

• Back Safety – lifting and carrying 

• Defensive Driving 

173

• Fall Protection 

• Electrical Safety 

4.6 AUDITS AND INSPECTIONS 


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December 2006 


The Project Safety Representative has implemented an audit and inspection program in 

conjunction with the GBU and corporate safety and quality assurance departments. The Project 

Manager, together with the Project Safety Representative or their designee, conduct a safety 

inspection each month. Office work areas (including trailers) are audited according to the 

corporate office audit standard. 

Additional information on audits and inspections during field activities is detailed in Section 6.5 

of this HASP. 

4.7 MEETINGS 

All project meetings of three or more people must begin with a safety topic. The meeting 

chairperson may present the safety topic or ask for a volunteer to open the discussion. In general, 

the “safety moment” is only one or two minutes long and is directly relevant to the work at hand 

or applicable to most individuals outside the workplace. 

Daily toolbox safety meetings are held with all personnel at the beginning of each shift to review 

current site conditions, incidents or injuries from the previous shift activities, safe or at-risk 

observations from the previous shift, activities planned for the current shift, anticipated hazards, 

engineering controls-work practices-PPE to protect against hazards and any additional safety 

topic or comments. Toolbox safety meetings shall be documented and signed by all individuals 

accessing the site using a Safety Meeting Sign-In Sheet. 

4.8 REPORTING AND MEASUREMENT 

4.8.1 Reporting 

To accurately measure performance and comply with corporate and regulatory requirements, 

Parsons utilizes an online safety reporting system to report monthly work hours, personnel 

injuries, property damage, environmental releases and near-miss incidents for its employees and 

subcontractors. A wallet card containing Incident Reporting Guidelines is also available online 

and included in Attachment 1. 

4.8.2 Measurement 

The Safety Manager and Project Manager establish and post a measurement system to provide 

indicators of safety performance, including the following metrics for the project: 

• Project start date 

• Days without a recordable injury – updated every Monday 

• Date of last OSHA recordable injury (if applicable) 

• Percent of safe observations from each monthly audit 

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Subcontractors must submit a monthly report of exposure hours (hours worked on the project, 

paid or unpaid) to the Parsons Project Manager within three days after the end of each month. 

The Project Manager compiles the figures and submits them to the Program Manager (or via the 

online safety reporting system if instructed by the Program Manager) by the first Friday of each 

month. Where necessary, estimated figures are acceptable. If a project involves air monitoring 

or personnel wearing any type of respirator, a monthly Field Project Report is also completed 

and submitted to the Division Safety Manager by the third calendar day after the end of each 

month. 

4.8.3 Incident Notification 

An incident is any unplanned or unexpected event involving a Parsons employee or 

subcontractor that results (or could have resulted in the case of a near-miss) in a personal injury, 

property damage or environmental release. Employees involved in or witnessing an incident or 

near-miss incident must immediately report it to the responsible supervisor or foreman, who in 

turn immediately relays the report to Parsons Project Manager, Jim Goepel (626) 440-6013. 

Near-miss incidents that could cause significant injury or loss of life must be immediately 

reported, in the same manner as an actual incident. No supervisor may decline to accept or relay 

a report of injury or significant near-miss incident from a subordinate. 

The Project Manager must ensure that all incidents are reported to the Global Business Unit 

(GBU) Safety Manager and other management personnel (as required) within four hours. The 

Project Manager (who has been trained on Parsons’ reporting requirements and Online Safety 

Reporting System) then prepares and submits the incident information. 

The GBU Safety Manager or their designee must notify the local OSHA office immediately if an 

accident involves the death of an employee or hospitalization of three or more workers. 

Emergency conditions are considered to exist if: 

• Any member of the field crew is involved in an accident, injury, or experiences 

any adverse effects or symptoms of exposure while on site. 

• A condition is discovered that suggests the existence of a situation more 

hazardous than anticipated (e.g. flammable atmospheres). 

• Concentrations of combustible vapors reach or exceed 10 percent of the LEL. 

• A fire or explosion hazard exists. 

• Concentrations of organic vapors measured in the worker breathing zone by a 

photoionization detector (PID) are above anticipated concentrations or unknown 

site situation arises. 

• A vehicle accident occurs. 

Preventive measures are listed below. 

• Site workers must maintain visual contact and should remain close together to 

assist each other during emergencies (use the buddy system). 

• During continual operations, on-site workers act as safety backup to each other. 

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• All field crew members should make use of all of their senses to alert themselves 

to potentially dangerous situations to avoid (e.g., presence of strong and irritating 

or nauseating odors). 

• Personnel will practice unfamiliar operations prior to performing them in the 

field. 

• Field crew members will be familiar with the physical characteristics of 

investigations and field demonstrations, including: 

− Wind direction in relation to contamination zones; 

− Accessibility to co-workers, equipment, vehicles and communication devices; 

− Communication signals and devices; 

− Hot zone locations (areas of known or suspected contamination); 

− Site access; and 

− Nearest water sources. 

• Personnel and equipment in the designated work area should be minimized, consistent 

with effective site operations. 

The discovery of any condition that would suggest the existence of a situation more hazardous 

than anticipated will result in the reevaluation of the hazard and the level of protection required, 

and may result in a temporary evacuation of the field team from the immediate work area. Such 

conditions may include an adverse effect or symptom of exposure experienced by a field team 

member, or the excess of the action levels for organic vapors and/or combustible vapors. If the 

action levels for organic vapors and/or combustibles are exceeded, procedures will be followed 

as stated in Section 10 of this health and safety plan. 

In the event that local Parsons management is not available during an emergency such as an 

injury to Parsons employees or contractor personnel, damage to facilities or operations, or threats 

against personnel or operations, Parsons personnel will contact the Parsons Emergency Contact 

Service. This hotline provides live telephone call support in English and Spanish 24-hours a day, 

7 days a week, and 365 days a year for immediate guidance and response when local 

management is not available. The telephone number for this service is located along with the 

other emergency numbers in Attachment 1. 

4.9 INCIDENT INVESTIGATIONS 

All incidents and significant near-miss incidents are investigated by an individual or team with 

training in accident investigation and root cause analysis. Subcontractors (if applicable) must 

investigate incidents involving their employees or activities and submit an investigation report to 

the Parsons Project Manager within 48 hours of an incident. 

In Parsons, the GBU Safety Manager investigates or assigns an investigator to each significant 

incident. The investigator submits a final investigation report using the online safety reporting 

system within 72 hours of the incident. The Project Safety Manager maintains the investigation 

file. 

176


4-6 

December 2006 


4.10 RESPONSIBILITY/IDENTIFICATION OF KEY LINE PERSONNEL 

A listing of the personnel that have the authority and responsibility for implementing the 

provisions of the Safety, Health, and Risk Program (SHARP) Management program are provided 

below (Table 4-1). 

Table 4-1: Responsibility of Key Personnel 

Project Name/Office: Proposed South Region High School #9 and Middle School #4 Remedial Investigation 

Address: 5246 Tweedy Boulevard, South Gate, California 

Telephone Fax Email 

323-563-2597 

Personnel/Title Contact Information 

Imants Reks – Parsons Executive Responsible for Project (315) 451-9560 

Jim Goepel - Project Manager (626) 440-6013 

Kristin Guthrie – Facility Health and Safety Representative (626) 440-3853 

Josh Sacker – Site Health and Safety Representative (626) 533-6033 

Prudence Boczarski-Daniel - Client Project Management (213) 893-7046 

The following is a description of the roles and responsibilities for this remedial investigation. 

The principle parties associated with this work are as follows: 

Los Angeles Unified School District – the LAUSD has the primary responsibility for all 

activities that occur at the Site. This will include oversight of all on-site activities including but 

not limited to health and safety and sampling of potentially impacted materials. LAUSD has 

contracted Parsons to perform investigation activities. 

Parsons – Parsons is the consultant and the representative for LAUSD on-site. Parsons will be 

responsible for the health and safety of its personnel. Parsons will be responsible for collection 

of samples and other related investigation activities. 

4.11 MEDICAL REQUIREMENTS AND WORKERS COMPENSATION 

In accordance with corporate requirements the Division Safety Manager has established and 

implemented the following medical requirements for the project: 

4.11.1 Functional Capacity Exams (FCEs) 

All personnel engaged in activities that results in the exposure to chemicals at or above the 

OSHA Permissible Exposure Limit (PEL) or wear a respirator for more than 30 days in a year, 

must comply with 29 CFR 1910.120(f) – Medical Surveillance. All personnel who wear a 

respirator must be medically qualified by a physician, trained and fit-tested on an annual basis, 

even if they are not required to participate in a medical surveillance program under 29 CFR 

1910.120(f). FCEs are not applicable for this project. 

177

4.11.2 Substance Abuse and Alcohol Testing 


4-7 

December 2006 


The Division Safety Manager administers required substance abuse tests, including random drug 

and alcohol testing. 

The project/client requires the following types of drug and/or alcohol testing: 

• Random – as deemed necessary by the Division Safety Manager 

• Post-incident – including property damage 

• Reasonable suspicion 

4.11.3 Medical Services and Panel of Physicians 

The Project Manager in conjunction with the Parsons Workers Compensation Analyst establishes 

a panel of medical providers for the project and selects medical facilities to treat non-emergency 

work-related injuries and illnesses, as follows: 

• Medical Direction 

In California, unless the employee has predesignated (see below), the employer controls 

medical direction for the initial visit. Thereafter, the employee may change treating 

physicians, but only within the Medical Provider Network(MPN). Selection of a treating 

physician shall be based on the physician's specialty or recognized expertise in treating 

the injured worker's injury or condition. Predesignation: if the employer provides 

nonoccupational group health coverage in a health care service plan or provides 

nonoccupational health coverage in a group health plan or health insurance policy the 

employee may notify his or her employer in writing prior to the date of injury that he/she 

wishes to be treated by his/her primary care physician who has previously directed 

his/her medical treatment, retains the employee's records including medical history, and 

agrees to be pre-designated. 

• Providers 

For life threatening/medical emergencies/after-hours at clinic, send the injured worker to 

the nearest hospital. Most likely, in the event of a medical emergency, emergency 

response will be summoned and the employee will be transported to nearest hospital (see 

Section 4.11.4). 

Otherwise, in the event of a work related injury that is not a medical emergency, it is 

PREFERABLE to send the injured worker to an industrial clinic. Listed below is an 

occupational clinic located near Parsons’ Pasadena office with whom Parsons has an 

established relationship, and an occupational clinic near the Site. 

178

Occupational Clinic in Pasadena: 

St. George's Medical Clinic 

1750 E. Colorado Blvd. 

Pasadena, CA 91106 

(626) 440-0097 

Occupational Clinic in South Gate: 

Technimed Vernon Industrial Medicine 

3364 E Slauson Ave 

Vernon, CA 90058 

323-584-7242 


4-8 

December 2006 


NOTE: Transportation to a medical facility for non-emergencies must be done by at least two 

(2) individuals (i.e. driver and observer). 

In the event of an emergency, the nearest hospital is: 

• St. Francis Medical Center, 3630 East Imperial Highway, Lynwood, CA 90262, 

• Emergency Room: (310) 900-4525 

• Main Number: (310) 900-8900 

See Attachment 1 for the route of travel to the facility. 

4.11.4 Emergency Medical Response 

When an emergency occurs, decisive action is required. Rapidly made choices may have farreaching, 

long-term consequences. Delays of minutes can create or exacerbate life-threatening 

situations. Personnel must be ready to respond to emergency situations immediately. All 

personnel will know their own responsibilities during an emergency, know who is in charge 

during an emergency, and the extent of that person's authority. This section outlines personnel 

roles, lines of authority, and communication procedures during emergencies. 

In the event of an emergency situation at the site, the Field Team Manager will assume total 

control and will be responsible for on-site decision-making. This individual has the authority to 

resolve all disputes about health and safety requirements and precautions. He is also responsible 

for coordinating all activities until emergency response teams (ambulance, fire department, etc.) 

arrive on site. 

The Field Team Manager and/or SHSO will ensure that the necessary LAUSD personnel, 

Parsons personnel, and agencies are contacted as soon as possible after the emergency occurs. 

All on-site personnel must know the location of the nearest phone and the location of the 

emergency phone number list. 

The project shall display posters/signs with emergency telephone numbers and locations of 

facilities in visible locations and at selected phone locations throughout the project area 

(including subcontractor facilities). 

179

Hospital Name St. Francis Medical Center 

Hospital Address 3630 East Imperial Highway 

Lynwood, CA 90262 

Hospital Telephone Number (310) 900-4525 

Ambulance Service 911 

Airlift Helicopter 911 

Directions From the worksite, 

Go west (right) on Chakemco Street 

Turn Left onto Atlantic Boulevard 

Turn Right on Imperial Highway 


4-9 

December 2006 


In the event of a work related injury that is not a medical emergency, it is PREFERABLE to send 

the injured worker to an industrial clinic (see Section 4.11.3). 

The sections below establish procedures and guidelines for emergencies. 

4.11.4.1 Guidelines for Pre-Emergency Planning and Training 

Employees must read this health and safety plan, and familiarize themselves with the information 

provided. Prior to project initiation, the SHSO will conduct a meeting with the field team 

members to review the provisions of this health and safety plan, the addenda, and to review the 

emergency response plan. Employees are required to have a copy of the emergency contacts and 

telephone numbers immediately accessible on site and know the route to the nearest emergency 

medical services. Emergency contacts, telephone numbers, and routes to the hospital are 

provided in Attachment 1 of this health and safety plan. 

4.11.4.2 Evacuation Routes and Procedures, Safe Distances, Alarms, and Places of 

Refuge 

In the event of emergency conditions, decontaminated employees will evacuate the area as 

instructed, transport decontaminated injured personnel, or take other measures to ameliorate the 

situation. Radios may also be used for communication in the event of an emergency to alert 

employees. Exact evacuation routes, safe distances, and refuge locations will be decided upon 

and posted by the field team prior to initiating work. Safe distances are determined based in the 

field and on the instance. 

Site alarms include: 

One horn blast = look this way; pay attention 

Three horn blasts, repeated = local evacuation, gather at field office for further instructions 

Five horn blasts, repeated = general site evacuation, gather off-site (north of site on Adella) 

180


4-10 

December 2006 


4.11.4.3 Decontamination of Personnel During an Emergency 

Procedures for leaving a contaminated area must be planned and implemented prior to going 

onsite. Decontamination areas and procedures will be established based on anticipated site 

conditions. If a member of the field crew is exposed to chemicals, the emergency procedures 

outlined below will be followed: 

• Another team member (buddy) will assist or remove the individual from the 

immediate area of contamination to an upwind location. 

• Precautions will be taken to avoid exposure of other individuals to the chemical. 

• If the chemical is on the individual's clothing, the clothing will be removed if it is 

safe to do so. 

• Administer first aid and transport the victim to the nearest medical facility, if 

necessary. 

If uninjured employees are required to evacuate a contaminated area in an emergency situation, 

emergency decontamination procedures will be followed. At a minimum, these would involve 

moving into a safe area and removing protective equipment. Care will be taken to minimize 

contamination of the safe area and personnel. Contaminated clothing will be placed in plastic 

garbage bags or other suitable containers. Employees will wash or shower as soon as possible. 

4.11.4.4 Emergency Site Security and Control 

For this project, the Field Team Manager (or designated representative) must know who is on 

site and who is in the work area. Personnel access into the work area will be controlled. In an 

emergency situation, only necessary rescue and response personnel will be allowed into the 

exclusion zone. 

4.11.4.5 Procedures for Emergency Medical Treatment and First Aid 

The following procedures will be implemented in the event of an emergency. 

Chemical Exposure 

In the event of chemical exposure (skin contact, inhalation, ingestion), the following procedures 

will be implemented: 

• Another team member (buddy) will assist or remove the individual from the 

immediate area of contamination to an upwind location. 

• Precautions will be taken to avoid exposure of other individuals to the chemical. 

• If the chemical is on the individual's clothing, the clothing will be removed if it is 


• If the chemical has contacted the skin, the skin will be washed with copious 

amounts of water, preferably under a shower. 

• Each crew will have, at a minimum, an ANSI-approved personal eyewash suitable 

for initial eye flushing while the injured person is moved to an emergency 

eyewash station or medical facility. 

181

Personal Injury 


4-11 

December 2006 


• If necessary, the victim will be transported to the nearest hospital or medical 

center. If necessary, an ambulance will be called to transport the victim. 

In the event of personal injury: 

• Field team members trained in first aid can administer treatment to an injured 

worker. 

• The victim will be transported to the nearest hospital or medical center. If 

necessary, an ambulance will be called to transport the victim. 

• The SHSO is responsible for the completion of the appropriate accident report 

form. 

Fire or Explosion 

In the event of fire or explosion, personnel will evacuate the area immediately and administer 

necessary first aid to injured employees. The SHSO will be responsible to alert all employees on 

the job site of the emergency. Personnel will proceed to a safe area and telephone the emergency 

support services designated in Attachment 1. A safe area (refuge location) is defined as an area 

free from the effects of the fire or explosion. A cellular phone will be used at the site. In the 

event of a fire or explosion, personnel will call the local fire department Note: call 911 in an 

emergency The non-emergency phone number for Station 147 is: (310-603-5255). The 

emergency contact numbers are provided in Attachment 1. Upon contacting the emergency 

support services, state your name, nature of the hazard (e.g., fire, high combustible vapor levels), 

the location of the incident, and whether there were any physical injuries requiring an 

ambulance. Do not hang up until the emergency support services personnel have all of the 

additional information they may require. 

4.11.5 Workers Compensation Program 

The Corporate Risk Management department establishes the appropriate workers compensation 

carrier. If a workers compensation loss occurs, the Corporate Workers Compensation Analyst 

(Donna Miller, 661-904-0978) handles all communication with the carrier. 

This project does not participate in an OCIP or project-specific insurance program. The workers 

compensation policy covering Parsons’ employees on this project is as follows: 

Effective Date: 1/1/08 – 1/1/09 

AIG (underwritten by American Home Assurance) 

Policy Number: 1593648 

P.O. Box 25977 

Shawnee Mission, KS 66225 

(619) 688-3771 

182


4.11.6 Medical Surveillance Programs and/or Monitoring 

4-12 

December 2006 


All personnel engaged in activities that results in the exposure to chemicals at or above the 

OSHA Permissible Exposure Limit (PEL) or wear a respirator for more than 30 days in a year, 

must comply with 29 CFR 1910.120(f) – Medical Surveillance. All personnel who wear a 

respirator must be medically qualified by a physician, trained and fit-tested on an annual basis, 

even if they are not required to participate in a medical surveillance program under 29 CFR 

1910.120(f). 

Based on the activities listed in Section 2.1, the following potential hazards or activities are 

associated with this project. As a result, medical surveillance will be required as listed below 

(Table 4-2): 

Table 4-2: Medical Surveillance Requirements 

Name/Job Classification Hazard/Activity Medical Surveillance/Training 

Josh Sacker/Field Team Lead 

Kristin Guthrie/Facility Safety Officer 

Fabrizio Mascioni/Field Team 

Member 

Daniel Saldana/Field Team Member 

Noise – Heavy Equipment 

Operation 

If noise exposures exceed 85 decibels over an 

8-hour time weighted average, an employee 

must participate in a Hearing Conservation 

Program. 

NA Chemical exposures – NA If an employee is exposed at or above the 

Permissible Exposure Limit (PEL) of a 

chemical for more than 30 days in a year, they 

must participate in a Medical Surveillance 

Program. 

NA Respirator use – NA Medical qualification, training and fit-testing 

must be received on an annual basis. If a 

respirator is worn more than 30 days per year, 

participation in a Medical Surveillance Program 

is required. 

Gregory H. Beck, Safety Manager, (732) 537-3502 administers the medical surveillance 

program. 

183


5.0 PRE-FIELD WORK PHASE 

5-1 

December 2006 


5.1 RISK ANALYSIS AND SAFETY SPECIFICATION DEVELOPMENT 

Procurement procedures require that a site-specific risk analysis be conducted before issuance of 

investigation and remediation RFPs. Using the pre-bid risk analysis checklist, the Project 

Manager leads this analysis, which documents existing exposures that may impact the work, 

surrounding facilities, equipment, workers, or the public at large. The analysis includes locating, 

documenting, and photographing items such as: 

• Overhead and underground power lines 

• Sewer and water utilities 

• Existing building interferences 

• Crane access ways 

• Traffic 

• Security 

• Fences 

• Water hazards 

• Existing geographical and environmental conditions 

• Investigation of Derived Waste (IDW) Disposal 

• Confined spaces 

Upon completion of the site risk analysis, high-risk activities are listed in the RFPs (as 

applicable), and bidders must describe controls and mitigation strategies in their proposals. The 

RFP notes that the list is representative and that the selected contractor must identify and control 

all work-related hazards. 

Pre-field work activities include a detailed analysis of the scope of work and safety specifications 

in the prime contract, Parsons’ project schedule and HASP, draft RFPs, and proposed 

subcontractor agreements. The Project’s standard safety specifications are given below. 

• Pre-Field Work Safety Meeting – Exhibit 5-1 

• Site Specific Risk Review Checklist – Exhibit 5-2 

5.2 DESIGN AND REMEDIAL ACTION REVIEW 

Periodic remedial action reviews are held in accordance with the project management plan. The 

Project Safety Manager participates in the review to ensure that safety issues are adequately 

addressed. During the remedial action review, the discussion focuses on how work is sequenced, 

184


5-2 

December 2006 


interferences with continuing operations, and safe work approaches. Specific activity hazards 

analyses conducted before the scheduled work can mitigate identified/presumed risks. 

5.3 PRE-BID MEETING 

Pre-bid meetings are required to ensure that bidders understand the RFP, including expectations 

for safety and health performance. Subcontractors must complete a Parsons Safety Evaluation 

package as outlined in Section 5.6, prior to attending a pre-bid meeting. During the pre-bid 

meeting, the Project Manager uses the Pre-Field Work Safety Meeting Checklist (Exhibit 5-1) to 

review project safety philosophy, principles, and Parsons requirements with all prospective 

bidders. Although this information is included in the RFP, the meeting reinforces the message. 

5.4 CONTRACTOR SAFETY EVALUATION 

Project procurement procedures require that all contractors (and any lower tier subcontractor) 

submit prequalification documentation for evaluation. The Procurement Manager or Division 

Safety Manager conducts the safety evaluation in accordance with the Parsons Contractor Safety 

Evaluation process and package posted on ParShare. 

For this project, there will be subcontractors directly hired by Parsons. 

5.5 PRE-FIELD WORK MEETING 

The Project Manager holds a pre-field work safety meeting before the subcontractor begins 

work. The meeting includes subcontractor representatives, contracts manager, and 

representatives from all disciplines, including safety. During the safety review, the meeting 

participants review specific safety site/area, pre-bid risk analysis, and competent person and sitespecific 

safety plan requirements. In addition, the Project Manager obtains a safety point of 

contact and emergency management information. The Mobilization/Kickoff Safety Meeting 

(Exhibit 5-3) is used by the Project Manager to document the meeting. 

5.6 COMPETENT PERSON SUBMISSION REVIEW 

Parsons and its subcontractors must identify OSHA-regulated and certified competent persons 

for work or tasks requiring that level of supervision. The Parsons personnel listed below will be 

assigned to the project and have the designated certifications. 

Name Job Title 40-hr 

HAZWOPER 

Josh Sacker Project Health 

and Safety 

Manager 

Table 5-1: Competent Person Listing 

8-hr HAZWOPER 

Supervisor 

April 3, 1989 February 10, 

2004 

8-hr HAZWOPER 

refresher 

expires 

Other training 

(i.e. excavation, 

confined space) 

May 30, 2009 Not Applicable 

185


Exhibit 5-1 – Standard Pre-Field Work Safety Meeting Checklist 

PARSONS 

Pre-Field Work Safety Meeting 

Date: Project/Location: 

Subcontractor 

Parsons Project 

Representative: 

Manager: 

Phone: Phone: 

Subcontractor Safety 

Parsons Safety 

Rep: 

Manager: 

Phone: Phone: 

The following items were identified and reviewed with the subcontractor. 

Health & Safety Medical 

Site-Specific Safety Plans/Model Program Substance Abuse Screening 

Competent/Qualified Person Documentation Emergency Procedures 

Safety Audits/Inspections Site Security 

Subcontractor Responsibilities Smoking Policy 

Site Orientation Requirements Medical Services Requirements 

5-3 

December 2006 


Mobilization/Kickoff Safety Meeting/Date Treatment Locations/Addresses/Phone List 

Crane Inspection Certification Other 

Personal Protective Equipment (PPE) 

Environmental Hazards 

Other 

Additional Notes/Comments: 

186


5-4 

December 2006 


5.7 SUBCONTRACTOR SAFETY PLAN (SSP) SUBMISSION REVIEW 

All subcontractors must submit safety programs to the Parsons Project Manager and Division 

Safety Manager for review before they begin work on site. The Plan will be reviewed for 

adequacy in accordance with the SSP template. 

For this project, there will be subcontractors directly hired by Parsons. 

5.7.1 Contractor Site-Specific Safety Plans 

At least 10 days before work begins, each contractor must submit two copies of its subcontractor 

safety program (SSP) to the Parsons Project Manager and Division Safety Manager for review. 

The Project Manager and Division Safety Manager review the SSP to ensure that it meets 

Parsons’ requirements. 

If a contractor needs assistance developing an SSP, an electronic copy of Parsons’ HAZWOPER 

Model SSP template is posted on ParShare. 

The SSP must address the following elements: 

• Responsibility 

• Compliance 

• Communication 

• Hazard assessment 

• Accident exposure and investigation 

• Hazard correction 

• Training and instruction 

• Recordkeeping 

The SSP must include applicable requirements of Parsons PSP and OSHA 29 CFR 1910/1926: 

• Scope of work evaluation that describes the sequence of work and associated hazardous 

activities. 

• Specific activity hazards analysis (AHA). 

• A project site employee orientation program that addresses location specific issues 

relative to safety and health. 

• A site-specific emergency action plan that includes a list of key management contacts 

with home office, project site, home, and cellular telephone numbers. 

• A site-specific medical emergency plan that lists qualified first aid personnel by name 

and includes copies of their current certificates. 

187


5-5 

December 2006 


• Key line management personnel, by name and position, who will enforce the SSP. 

• Key competent or qualified personnel by name and copy of current documentation 

identifying specific certified competency (e.g., scaffolding, excavations, and fall 

protection). 

• Written progressive disciplinary program for violations of safety procedures. 

• Trenching and shoring plan (if applicable). 

• HAZWOPER training documentation (if applicable). 

• Contractor task hazard planning. 

• Subcontractor weekly safety planning submission. 

• Contractor workers daily task safety planning. 

5.8 MOBILIZATION/KICKOFF SAFETY MEETING 

Project Managers conduct the Mobilization/Kickoff Safety Meeting on the first day of 

subcontractor mobilization in the field and at the work site. Exhibit 5-3 shows the checklist used 

for the safety portion of this meeting. The meeting includes the completion of a Site-Specific 

Risk Review Checklist (Exhibit 5-2) combined with a walkthrough of the work area to locate 

items on the pre-bid risk analysis checklist. 

Site-specific safety briefings will address the activities, procedures, monitoring, and equipment 

applicable to the site operations, as well as site or facility layout, potential hazards, and 

emergency response services at the site. Since this HASP covers many LAUSD tasks, for each 

field task (prior to mobilization), Parsons Task Manager should review the site hazards based on 

this HASP and site conditions and complete a activity hazard analysis form as part of the Site- 

Specific Training. This form is included in Exhibit 6-1. Additional topics that will be addressed 

at the safety briefings will include: 

• Names of responsible health and safety personnel; 

• Zero accident performance policy; 

• Anticipated site hazards (physical, chemical, and biological hazards); 

• Site contingencies and emergency procedures; 

• Exposure routes/risk; 

• Symptoms of exposure and exposure treatment for chemicals; 

• Use, care, maintenance, and limitations of personal protection equipment (PPE); 

• Decontamination procedures to be followed; 

• Location and use of safety equipment; 

• Review of planned site activities and specialized training necessary for personnel to 

perform their work with zero accidents; 

• Defined safety procedures to be followed during field activities; 

• Parson’s Mandatory Pre-drilling Protocol; and 

188


5-6 

December 2006 


• Emergency and evacuation procedures, including emergency hospitals and contact 

names/numbers. 

Documentation of site-specific safety training, including agenda and signatures of attending 

personnel, will be maintained on site. 

189

Date: Project or Location: 

Risk/Hazard Detail Present 

Employee Exposure Hazardous chemicals ______ 

Lead ______ 

Asbestos ______ 

UXO ______ 

PCB ______ 

Airborne contaminants 

(dust, mists, fumes) ______ 

Other (specify) ______ 

__________________ ______ 

Confined Space Confined space entry 

is required ______ 

__________________ ______ 

Control of Energy Lockout, blocking, 

other controls required ______ 

__________________ ______ 

Hazardous Waste Handling, removal or 

storage of hazardous 


__________________ ______ 

Crane Work Mobile cranes ______ 

Tandem lifts ______ 

Bridge cranes ______ 

Derricks ______ 

__________________ ______ 

Trenching and Trenching and 

Excavations excavations required ______ 

__________________ ______ 

Welding and Cutting Acetylene/gas cutting ______ 

Arc welding ______ 

Soldering and brazing ______ 

__________________ ______ 

Powered Industrial Forklift training is 

Trucks required ______ 

Aerial Lifts Hydraulic booms ______ 

Scissor lifts ______ 

Mobile scaffolding ______ 

__________________ ______ 

Scaffolding Scaffolding is required ______ 

Ladders Portable ladder use 


__________________ ______ 


Exhibit 5-2 – Site Specific Risk Review Checklist 

5-7 

December 2006 


Risk/Hazard Detail Present 

Caissons and Caisson or cofferdam 

Cofferdams work is required ______ 

__________________ ______ 

Marine or Over Work on or over water 

Water Work is required ______ 

Underwater (diving) 

work is required ______ 

__________________ ______ 

Process Safety Work is on or adjacent 

Management to operations involving 

listed highly hazardous 

chemicals ______ 

__________________ ______ 

Steel Erection Steel erection work 


__________________ ______ 

Traffic Control Work is on or near 

highways, road, or 

mass transit ______ 

__________________ ______ 

Personal Protective Work activities or work 

Equipment site requires hearing 

protection ______ 

Work activities or 

location requires using 

respirators ______ 

Work activities or 

location requires special 

protective clothing ______ 

__________________ ______ 

Public Exposure Work activities or 

location requires 

special precautions 

to protect the public 

__________________ ______ 

Other Exposures Other exposure or 

high-risk activities (list) 

__________________ ______ 

__________________ ______ 

__________________ ______ 

__________________ ______ 

__________________ ______ 

Notes: ________________________________________________________________________________________________ 

______________________________________________________________________________ 

Reviewed by: ____________________________ 

Title:__________________________________Date:____________________ 

190


5-8 

December 2006 


Exhibit 5-3 – Mobilization/Kickoff Safety Meeting Checklist 

Date: _______________________ Project/Location: 

PARSONS 

Mobilization/Kickoff Safety Meeting 

Parsons Representative: ___________________Subcontractor Representative: 

The following project site safety, health and security requirements, procedures, and hazards have been identified and 

reviewed with the Subcontractor. 

SSP/Emergency Planning/Response Plan 

Competent/Qualified Person 

Hazardous Materials/Waste 

Vehicle/Heavy Equipment 

Lockout/Tagout 

Electrical 

Fire Protection 

Hot Work/Welding/Cutting 

Fall Protection/Guardrails/ 

Scaffolding/Ladders 

Additional Project Concerns: 

Other Attendees: 

Name 

Title 

Demolition 

Personal Protective Equipment 

Cranes/Hoists/Annual Inspection Certificate 

Overhead Power Lines 

Confined Spaces (Permit/Non-Permit) 

Excavations/Trenching 

Site Security/Visitor Control/Public Exposure 

Process Safety Management (PSM) 

Permits (Excavation/Scaffolding/Demolition/Traffic/ 

Confined Space/etc.) 

Company 

191

6.1 SITE RISK ANALYSIS 


6.0 REMEDIATION PHASE 

6-1 

January 2007 


Before work begins, Project Managers lead a team that performs a risk analysis at each work site 

to identify hazards that require specific control measures. During weekly progress meetings, the 

Project Engineer and subcontractors submit written summaries of upcoming work tasks and 

associated risks and control measures to the Project Manager using Exhibit 6-1. The weekly 

summaries identify upcoming mobilization or demobilizations tasks, audits and inspections, 

competent person changes, training and new activities requiring an Activity Hazard Analysis 

(AHA). Subcontractors add activities to these summaries at least two weeks in advance of the 

work. Potential hazards are listed below. 

• Chemical exposures (Table 6-1) 

• Environmental – cold/heat stress, animals, insects, poisonous plants/vegetation 

• Hazardous material handling 

• Heavy equipment operation 

• Noise 

• Traffic 

The safety and health risk analysis presented in this section is for anticipated field activities. All 

tasks are expected to be performed using Level D protection levels. See Section 10 for details of 

PPE. Any future activities not included in this HASP will be addressed in task-specific 

workplans. 

Overall Hazard Rating for this Work: Low to Medium 

The following describes the potential major tasks and the potential health and safety hazards for 

each task. 

Task 1 – Asphalt Cap Maintenance Work: Hot mixed asphaltic concrete will be unloaded 

from a truck and applied with hand tools and a hand-operated vibratory compactor. 

Potential Hazards - Heavy equipment hazards from being struck by/against moving equipment; 

being caught and injured from moving equipment parts; lifting hazards from lifting and carrying 

materials; slip, fall, and trip hazards from walking on slippery and uneven surfaces; cuts, skin 

abrasions, and bruises from handling of sharp tools/objects; vibration hazards; potential 

exposures to hot asphalt material; and heat stress when working in a hot environment. 

Task 2 – Groundwater monitoring: Consists of geophysical logging of wells, well 

maintenance, well abandonement, well drilling and installation, well development, groundwater 

sampling, and aquifer pump testing. 

• Geophysical logging – Consists of lowering equipment into the well to record subsurface 

soil characteristics. 

192


6-2 

December 2006 


• Well maintenace – Consists of replacement of well vaults and other miscellaneous 

repairs. 

• Well abandonment - Abandonment consists of removal of the entire well casing by overdrilling 

then filling the open borehole with grout under pressure. 

• Well drilling and well installation - Consists of drilling boreholes using both a hollowstem 

auger rig and a dual air percussion rig, drilling through aquifers to final depth, 

logging, identification of aquifer boundaries, assembly and placement of well 

casing/screening, filling of annulus with gravel pack, and sealing of annulus. 

• Well development - Consists of using a bailer to remove gross fines that accumulate 

while surging/swabbing the well, followed by a submersible pump to remove additional 

fines while pumping the well at variable rates and durations. These procedures stabilize 

the filter pack and remove fines from the filter pack to allow representative groundwater 

samples to be collected. 

• Groundwater sampling and aquifer pump testing – Consists of opening monitoring well 

caps, measuring water levels with a water level meter, purging groundwater with an 

electric pump, and collecting groundwater samples. 

Potential Hazards - Heavy equipment hazards from being struck by or against moving 

equipment, mechanical parts, and drill rigs; being caught and injured from moving equipment 

parts; lifting hazards from lifting and carrying materials; slip, fall, and trip hazards from walking 

on slippery and uneven surfaces; traffic safety hazards from working near roadways and 

vehicles; cuts, skin abrasions, and bruises from handling of sharp tools or objects; noise hazards 

from working near a drill rig and other noise generating equipment; electrical hazards from 

improper use and handling of electrical devices; overhead hazards and excavation hazards 

(underground utilities); skin contact with contaminated soil or groundwater if groundwater is 

encountered during drilling; exposures to hazardous gases/vapor and particulates during well 

drilling and installation; and heat stress when working in a hot environment. 

Task 3 – Soil vapor sampling: This task includes opening monitoring well caps and collecting 

soil gas samples from various soil vapor monitoring points or installing temporary monitoring 

points using a Geoprobe®. Samples are collected using a calibrated flow meter and vacuum 

gauge. The actual samples are withdrawn from the moving sample stream using a glass syringe 

fitted with a disposable needle and Mininert TM gas-tight valve. Samples are analyzed 

immediately following collection, by direct gas injection into a laboratory-grade, field-operable 

gas chromatograph (by mobile laboratory). Alternatively, summa canisters may be used with 

analysis at an off-site laboratory. 

Potential Hazards - Heavy equipment hazards from being struck by/against moving equipment 

and vehicles; lifting hazards from lifting and carrying materials; slip, fall and trip hazards from 

walking on slippery and uneven surfaces; cuts, skin abrasions, and bruises during opening of 

well caps and handling of syringes, sharp tools/objects; improper work practices and procedures; 

hazardous vapor exposures during initial opening of the well cap and during vapor sampling; and 

heat stress when working in a hot environment. 

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Task 4 – Borehole drilling and soil sampling: Subsurface sampling will be conducted using 

both a hollow-stem auger rig and a dual air percussion rig and split spoon samplers containing 

brass or stainless-steel tube liners. For the hollow stem auger method, drilling progresses by 

rotating the auger into the ground for one auger section, and withdrawing the auger, until 

reaching the final depth. The dual air percussion method involves hammering steal casing (or 

pipe) into the ground, and samples are also collected using spilt spoon samplers. 

For both methods, the split spoon samplers are driven into the subsurface deposits in advance of 

the drill bit. This is accomplished by dropping a 140-pound hammer from 30 inches (multiple 

repetetions) to completely embed the sampler (18 inches or 24 inches). 


and drill rigs; being caught and injured from moving equipment parts; lifting hazards from lifting 

and carrying materials; slip, fall, and trip hazards from walking on slippery and uneven surfaces; 

cuts, skin abrasions, and bruises from handling of sharp tools/objects; traffic safety hazards from 

working near operating vehicles and roadways; noise hazards from working near noise sources; 

excavation hazards (underground utilities) and overhead utilities hazard; noise hazards from 

working near a drill rig and other noise generating equipment; exposures to hazardous 

gases/vapor and particulates during drilling and sampling; and heat stress when working in a hot 

environment. 

Task 5 – Surveying: Surveying may involve a site visit, visual observations of the site features, 

identifying underground utilities or obstructions, and/or placing stakes/markers at survey points 

(i.e. drilling or sampling locations). 

Potential Hazards – Lifting hazards from lifting and carrying materials; slip, fall, and trip 

hazards from walking on slippery and uneven surfaces; traffic safety hazards from working near 

roadways and operating vehicles; cuts, skin abrasions, and bruises from handling of 

tools/objects; and heat stress when working in a hot environment. 

Task 6 – Underground Storage Tank Removal: Underground storage tank removal involves 

excavation to uncover the UST and associated piping, monitoring of combustible gases and 

oxygen content using a combustible gas detector, removal/disposal of any residual liquid or 

sludge in the tank, decontamination and degassing of tanks and associated piping, 

washing/rinsing of tank, disconnecting/dismantling and removal of tank, backfilling of the tank 

with an inert solid such as concrete or grout (for in-place tank abandonment only), soil sampling, 

backfilling of the excavation, and disposal/recycling of the tank. 


and mechanical parts; being caught and injured from moving equipment parts; lifting hazards 

from lifting and carrying materials; slip, fall, and trip hazards from walking on slippery and/or 

uneven surfaces or near open excavation; traffic safety hazards from working near roadways and 

vehicles; cuts, skin abrasions, and bruises from handling of tools/objects; noise hazards from 

working near a excavator and other noise generating equipment; electrical hazards from 

improper use and handling of electrical devices; fire/explosion hazards from flammable 

gases/vapors in the tank; overhead hazards and excavation hazards (underground utilities and 

unstable, loose soils/cave-ins); exposures to hazardous gases/vapor and particulates during 

excavation; exposure to hazardous gases/vapors during UST removal; and heat stress when 

working in a hot environment. 

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Task 7 – Hazardous Waste Management: Abandoned hazardous substances will be 

characterized, incompatible wastes will be segregated and compatible wastes will be 

consolidated, and transported off-site for disposal. This task includes removal of hazardous 

waste containers, removal of liquids and solids from subsurface structures, decontamination of 

equipment used as hazardous waste management units, building walls, and surfaces, removal of 

hazardous wastes identified in solid waste debris piles, collection of foundry sands, and 

confirmation sampling. 

Potential Hazards - Heavy equipment hazards from being struck by/against moving equipment; 

being caught and injured from moving equipment parts; lifting hazards from lifting and carrying 

materials; slip, fall, and trip hazards from walking on slippery and uneven surfaces; cuts, skin 

abrasions, and bruises from handling of sharp tools/objects; traffic safety hazards from working 

near operating vehicles and roadways; overhead utilities hazard; fire/explosion hazards from 

accidental mixing of incompatible chemicals; exposures to hazardous gases/vapor and 

particulates during hazardous substance removal; collapse of unstable structures, and heat stress 

when working in a hot environment. 

Task 8 – Subsurface/Excavation: This task involves excavation to remove impacted soil and 

any work that is performed below ground surface. 

Potential Hazards - Before intrusive field activities are performed, efforts must be made to 

determine if underground utilities (i.e., sewers, and telephone, water, fuel, and electrical lines) 

will be encountered and, if so, where such underground installations are located. The Field 

Team Manager will ensure that all underground installations have been identified prior to any 

intrusive operations, including, but not necessarily limited to, contacting Underground Services 

Alert (USA) and compliance with Parsons Mandatory Pre-drilling Protocol. Precautions will be 

exercised when working near any overhead electrical lines. A minimum safe distance will be 

established by the SHSO in areas of overhead and underground power lines. 

All excavation will be performed under the supervision of a competent person. Cave-ins from 

unstable soil are always a concern during excavation and trenching. Barriers will be provided to 

prevent persons from accidentally falling into the excavation. 

An excavation or trench allowed for human entry that is deeper than 5 feet or in poor conditions 

will be shored, sloped, or benched in accordance with Title 8, CCR Section 1540-41. All shoring 

will be inspected daily at the beginning of the day by a competent person and after any event that 

could compromise the safety of an excavation (for example, rain, heavy equipment operation 

nearby, or an earthquake). 

Attachment 3 contains Activity Hazard Analysis (AHA) tables. 

6.2 FIVE HAZARD CONTROL MEASURES – ORDER OF 

PRECEDENCE 

Site hazards and hazards resulting from investigation and remediation activities are controlled 

using one or more of the control measures listed below. The order of precedence is as follows: 

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1. Engineer/design to eliminate or minimize hazards. A major component of the design 

phase is to select appropriate safety features to eliminate a hazard and render it fail-safe 

or provide redundancy using backup components. 

2. Guard the hazard. Hazards that cannot be eliminated by design must be reduced to an 

acceptable risk level by safety guards or isolation devices that render them inactive. 

3. Provide warnings. Hazards that cannot be totally eliminated by design or guarding are 

controlled through using a warning or alarm device. 

4. Provide special procedures or training. When design, guarding, or warnings cannot 

eliminate hazards, subcontractors must develop procedures, training, and audits to ensure 

safe completion of work. Training cannot be a substitute for hazard elimination when 

life-threatening hazards are present. Decontamination procedures will consist of dry 

decon procedures including brushing off of truck tires and shoes of personnel in the 

exclusion/contamination reduction zones. No decon will be required of personnel in the 

support zone unless these personnel enter the exclusion/contamination reduction zone. 

5. Provide personal protective equipment. To protect workers from injury, the last 

method in the order of precedence is the use of personal protective equipment, such as 

hard hats, gloves, eye protection, life jackets, and other protective equipment with the 

understanding that bulky, cumbersome, and heavy personal protective equipment is often 

discarded or not used, rendering this method ineffective without proper controls. The 

level of personal protective equipment for this project is Level D. Personal protective 

equipment that will be required for this project are a hard hat, safety glasses, steel toed 

boots, and reflective safety vest. In areas where noise levels may be elevated (i.e., near 

heavy equipment) hearing protection may be used. 

6.3 ACTIVITY HAZARDS ANALYSIS 

Parsons and its subcontractors are required to conduct an activity hazards analysis for all aspects 

of the work. The activity hazards analyses consist of the following three steps: 

• Identify the task and break it down into steps. 

• Identify the hazards associated with each step. 

• Identify the specific hazard control measure used for each step in accordance with the 

order-of-precedence method of control. 

The US Army Corps of Engineers website www.swl.usace.army.mil/safety/asaindex.html 

contains a library of sample AHAs that may be useful on projects. The Parsons PWeb should 

also be checked for AHAs. The Project Manager may use uses the following list as a guide in 

determining the investigation and remediation activity hazards analyses for various high-hazard 

operations and critical tasks. 

• Confined Spaces. Confined space work requires special consideration, evaluation, 

controls and applicable training for the entrant, attendant, supervisor and rescue 

personnel. Each space should be reviewed for regulatory compliance. 

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• Crane Operations. Consider special requirements for operations, maintenance, and 

heavy lifting operation. All lifts must be planned in accordance with the limitations of 

cranes being used. Critical lift plans are required when two cranes are used 

simultaneously. Crane operator certification is required when the boom length exceeds 

100 feet. 

• Fall Protection. Fall protection is required when employees are working more than six 

(6) feet above the normal work surface level. Consider how and where ladders, scaffold, 

work platforms, or lifts (including scissors or aerial lifts), roofing work and leading edges 

are used. Evaluate protective measures such as fall protection plans, use of personal fall 

arrest systems, and the work surfaces for slip and fall hazards and protection. 

• Field Activities. Many different types of activities occur in the field from excavations, 

groundwater sampling, soil sampling, liner installation, well installation and monitoring, 

and pump tests. A variety of hazards could be incurred with each activity such as 

biological, slip/trips/falls and lacerations. An activity hazard analysis is required for each 

different field activity to identify the hazards and controls. 

• Field Visit. When a field visit occurs, it may be before any field activities are taking 

place. However, there may still be hazards present such as walking or driving in fields 

with uneven terrain, poisonous vegetation, etc. Although personal protective equipment 

such as a hard hat and safety glasses may not be needed, sturdy work boots, long pants, 

long sleeve shirts and sunscreen may be necessary. 

• Heavy Equipment Operation. Evaluate the use of heavy equipment in operations such 

as site clearing, grading, drilling and excavation or lifting. Controls should include 

equipment alarms, use of qualified operators, equipment inspections, and any specific 

OSHA regulatory requirements. 

• Material Handling. Consider the size and weight of loads, the equipment to be used, 

how the equipment is set up and protected, and safety and maintenance inspections of 

material handling and rigging equipment. Also consider employee training in the use of 

the equipment or personal body mechanics when engaged in manual material handling 

activities. 

• Material Storage. Consider where materials and equipment will be stored on site. 

Implement measures to protect against chemical spills/releases, fire, vandalism and theft 

of tools, equipment, or materials. Also consider the hazards that may exist for workers 

when they are storing or retrieving those materials. 

• Mobilization/Demobilization. Conduct an initial site inspection for pre-job planning. 

The inspection should cover potential exposures such as the location of electrical lines, 

underground utilities, nearby structures, traffic conditions, site security needs, public 

exposures general liability, and other potential exposures. 

• Portable Hand and Power Tools. Evaluate the tools to be used and the ways that 

workers are protected from the hazards associated with the use of tools. Consider tool 

maintenance requirements; electrical requirements; the use of ground fault circuit 

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interrupters, grounding, extension cords, and tool inspection procedures; and employee 

training and PPE requirements. 

• Process Safety Management. At process sites where highly hazardous chemicals are 

stored or used, comply with special considerations and process safety management 

OSHA regulations. 

• Traffic Controls. Control measures include warning signs, flagmen, traffic stoppage and 

control, and unloading procedures. Internal traffic control plans should include ways to 

restrict the number of vehicles on site, the flow of vehicles accessing the site and driving 

through the site, haul roads, speed controls, subcontractor employee parking areas, 

merging of site traffic with local vehicle traffic, pedestrian controls in traffic zones, 

access by emergency and rescue vehicles and operator controls. 

• Vehicle Operation. Although driving a vehicle may be second nature to many 

individuals, there are many hazards and controls that need to be identified. Fatigue and 

distractions are two hazards that many individuals do not think about on a regular basis. 

Operating off-road vehicles such as an All-Terrain Vehicle (ATV) also require training. 

• Work Near/On Water. Analyze work hazards on a marine vessel (i.e. barge, dredge, 

pontoon boat, etc) or adjacent to (within 4 feet), in, or over water (including lakes, canals, 

dams, treatment plants, water tanks, clarifiers, and reservoirs). 

Exhibit 6-1 is a sample activity hazards analysis form. Exhibit 6-2 shows a training record to be 

completed and kept on file for each activity hazards analysis. 

6.3.1 Chemical Hazards 

A table of potential chemical hazards at the Site and their chemical properties is in Table 6-1. 

Chemical compounds at the Site may include, but may not be limited to, the listed compounds. 

6.3.2 Physical Hazards 

In addition to the hazardous substances potentially present at the Site, other physical hazards or 

hazardous conditions may be expected during the course of performing fieldwork, including 

excavation and data collection. As described above, these hazards include possible risks from 

injury while working around heavy, stationary or moving equipment; slip, trip, and fall hazards; 

excessive noise conditions; fire or explosion hazards; subsurface/excavation hazards; electrical 

hazards; electric power line clearance; heat stress; and urban violence and stray animals. 

The guidelines presented in this section are applicable to general types of equipment that may be 

used during this investigation. Individual equipment types or certain specialized equipment may 

require additional safety considerations or specialized training prior to its use. Should any 

specialized equipment be required during the performance of a task, the SHSO will ensure that 

operators receive appropriate training. The SHSO also will be responsible for ensuring that all 

equipment is routinely inspected and that any piece of equipment considered unsafe is not used 

until the unsafe conditions are corrected or repaired. 

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6.3.2.1 Support Vehicles 

Contractor/subcontractor personnel shall wear seat belts and obey posted speed limits on 

roadways within site area. Personnel shall comply with applicable state and local traffic 

regulations. Current or anticipated road conditions will be addressed at the daily safety briefings. 

No personnel shall ride in the bed of pickup trucks or stand on the side or ride on the fenders of 

support vehicles. Cell phones may not be used by a driver while a vehicle is in motion. Avoid 

other distractions as well. 

Personnel will conduct a “walk-around” inspection of the vehicle before moving it to ensure they 

do not drive over personnel or equipment. 

No personally-owned vehicles (POVs) will be driven into site exclusion zones, nor will 

contaminated equipment, personnel or material be transported in POVs. POVs must be left in 

support zones on site. Stunt driving, racing, and horseplay are prohibited and will be subject to 

disciplinary action. 

6.3.2.2 Heavy, Stationary or Moving Equipment 

Working with large motor vehicles could be a major hazard at the site. Injuries can result from 

equipment dislodging and striking personnel, and impacts from flying objects or overturning of 

vehicles. Vehicles and heavy equipment design and operation will be in accordance with CCR, 

Title 8, Sections 1590-1599. In particular, the following precautions will be used to help prevent 

injuries and accidents: 

• Before any subsurface work is initiated, verify that underground and above-ground utility 

clearances have been obtained. 

• Do not back up large motor vehicles unless the vehicle has backup warning lights and a 

reverse signal alarm audible above the surrounding noise level, or an observer signals it is 


• Motor vehicle cabs will be kept free of all nonessential items and all loose items will be 

secured. 

• All personnel working at and around heavy moving equipment must be informed of the 

locations of the kill switches. 

• When heavy equipment is left unattended, loads must be lowered, controls neutralized, 

power shut off, and brakes set. 

• Only qualified operators will be allowed to operate heavy equipment. 

When working near a drill rig, personnel shall be aware of snag hazards from rotating tools and 

pinch and crush hazards from suspended tools. No loose, dangling clothing will be allowed. 

Personnel will be aware of slip, trip and fall hazards from drilling equipment, tools, and well 

construction materials that may be lying on the ground in the vicinity of the drill rig. 

In addition to operator vehicle safety, traffic control hazards exist when working with moving 

vehicles, trucks, and heavy equipment. Project personnel will be aware of his or her 

surroundings at all times. Pedestrians should maintain a minimum clearance distance of ten feet 

or greater whenever possibile, since the operator’s attention is focused on the point of operation 

and significant blind spots are common. Eye contact with the operators of any vehicle or 

equipment must be made prior to walking near moving/operating vehicles or equipment to alert 

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them of your presence. Good traffic control is also important for protection of site personnel and 

the public. Trained flaggers will be provided to direct on-site traffic. Warning signs will be 

posted, as necessary, in areas requiring detours to prevent congestion. 

6.3.2.3 Slip, Trip, and Fall Hazards 

Site conditions may pose slip, trip, and fall hazards, such as: 

• Open excavation/trenches; 

• Slippery surfaces; 

• Steep or uneven grades; 

• Surface obstructions; and 

• Construction materials or debris. 

All field team members will be instructed to be cognizant of potential safety hazards and 

immediately inform the SHSO or the Field Team Manager about any new hazards. 

If the hazard cannot be immediately removed, actions must be taken to warn site workers about 

the hazard. The site will be kept in a neat, organized, and orderly fashion. Rubbish, trash, or 

debris generated by the project team shall be picked up and properly disposed of daily. Tools, 

equipment, and hoses will be properly stored when not in use. 

6.3.2.4 Excessive Noise Conditions 

Work on site may involve the use of heavy motorized equipment. The exposure of unprotected 

site workers to this noise during site activities may result in noise-induced hearing loss. 

Personnel exposed to noise above 85 decibals (dBA) must participate in a hearing conservation 

program. Heavy equipment can emit noise levels exceeding the CAL/OSHA 8-hr time-weighted 

average (TWA) limit of 90 dBA. Noise levels in the area of operating heavy equipment will be 

presumed to exceed the CAL/OSHA TWA, and hearing protection will be required. Foam 

earplugs will generally provide adequate protection. The SHSO will ensure that disposable foam 

earplugs are made available to, and are used by, all personnel in the vicinity of operating 

equipment or other noise sources. 

6.3.2.5 Fire or Explosive Hazards 

Gases and vapors from fuels that may have been released into soils may be flammable or 

explosive. Therefore, precautions will be taken when performing site activities to ensure that 

combustible or explosive vapors have not accumulated or that an ignition source is not 

introduced into a flammable atmosphere. 

Cal/OSHA standards for fire protection and prevention are included in CCR, Title 8, Sections 

1920-1928. Of particular concern are the following: 

• Adequate numbers and types of fire extinguishers; 

• Use of intrinsically safe (explosion-proof and non-sparking) equipment and tools where a 

spark could possibly provide a source of ignition for flammable vapors or dust; and 

• Monitoring for explosive atmosphere using combustible gas detectors (oxygen and lower 

exposure limit [LEL]). 

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6.3.2.6 Subsurface/Excavation Hazards 

Before intrusive field activities are performed, efforts must be made to determine if underground 

utilities (i.e., sewers, and telephone, water, fuel, and electrical lines) will be encountered and, if 

so, where such underground installations are located. The Field Team Manager will ensure that 

all underground installations have been identified prior to any intrusive operations, including, but 

not necessarily limited to, contacting Underground Services Alert (USA) and compliance with 

Parsons Mandatory Pre-drilling Protocol. Precautions will be exercised when working near any 

overhead electrical lines. A minimum safe distance will be established by the SHSO in areas of 

overhead and underground power lines. 

All excavation will be performed under the supervision of a competent person. Cave-ins from 

unstable soil are always a concern during excavation and trenching. Barriers will be provided to 

prevent persons from accidentally falling into the excavation. 

An excavation or trench allowed for human entry that is deeper than 5 feet or in poor conditions 

will be shored, sloped, or benched in accordance with Title 8, CCR Section 1540-41. All shoring 

will be inspected daily at the beginning of the day by a competent person and after any event that 

could compromise the safety of an excavation (for example, rain, heavy equipment operation 

nearby, or an earthquake). 

6.3.2.7 Electrical Hazards 

Some of the equipment used during this investigation will be powered by electricity. 

Maintenance and daily activities require personnel to use, handle, and control this equipment. 

Safe work practices must be strictly observed to avoid serious injury or death. According to 

CCR, Title 8, Section 1760, only qualified employees may work on or with exposed energized 

lines or parts of equipment, or in areas containing unguarded, un-insulated, energized lines or 

parts of equipment operating at 50 volts (V) or more. Qualified employees must be trained in 

accordance with CCR, Title 8, Section 1760 and certified as such by Parsons. Ordinary 120 V 

electricity may be fatal. Extensive studies have shown that currents as low as 10 to 15 milliamps 

(mA) can cause loss of muscle control and that 12 V may, on good contact, cause injury. 

Therefore, all voltages should be considered dangerous. 

General rules for electrical safety are as follows: 

• Only authorized and qualified personnel will perform electrical installations or 

repairs. 

• All electrical wires and circuits will be assumed to be “live,” unless it can be 

positively determined they are not. 

• Appropriate protective clothing will be worn by personnel performing electrical 

work. 

• All electrical equipment will be properly grounded and class-approved for the 

location. 

• Ground fault circuit interrupter receptacles and circuit breakers will be installed in 

all outdoor temporary circuits and wet locations, as well as where otherwise 

required by the National Electric Code (NEC) and CCR Title 8, Section 1760. 

• Electrical control panels will not be opened unless necessary. 

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• No safety device will be made inoperative by removing guards, using oversized 

fuses, or by blocking or bypassing protective devices, unless it is absolutely 

essential to the repair or maintenance activity, and then only after alerting 

operating personnel and the maintenance supervisor. 

• All power tools will have insulated handles, be electrically grounded, or be double 

insulated. 

• Fuse pullers will be used to change fuses. 

• Metal ladders, metal tape measures, and other metal tools will not be used around 

electrical equipment or overhead electrical lines. 

• Wires and extension cords will be placed or arranged so as to not pose a tripping 

hazard. 

6.3.2.8 Electric Power Line Clearance 

Extra precautions will be exercised when operating drilling rigs or other heavy motor vehicles 

equipped with booms near overhead electrical lines. Overhead or aboveground electric lines 

shall be considered “live” or active until a reliable source has documented them to be otherwise. 

The Field Team Manager and SHSO will confirm the assessment of overhead electric power 

lines prior to commencement of work. Equipment operation within 20 feet of an energized 

electric line is considered high hazard work and requires a specific AHA. Work within ten feet 

of an energized line is not permitted. 

6.3.2.9 Heat Stress 

Adverse weather conditions are important considerations in planning and conducting site 

operations. Hot weather can cause physical discomfort, loss of efficiency, and personal injury. 

These conditions are discussed further below. 

If the body's physiological processes fail to maintain a normal body temperature because of 

excessive heat, a number of physical reactions can occur. They can range from mild symptoms 

such as fatigue; irritability; anxiety; and decreased concentration, dexterity, or movement; to 

death. Medical help must be obtained for the more serious cases of heat stress. One or more of 

the following actions will help reduce heat stress: 

• Provide plenty of liquids. To replace body fluids (water and electrolytes) lost due 

to perspiration, each employee must drink 1 to 1.5 gallons of water or commercial 

electrolyte mix per day. Workers are encouraged to frequently drink small 

amounts, i.e. one cup every 15 to 20 minutes. 

• Field personnel are cautioned to minimize alcohol intake during off-duty hours. 

• Provide cooling devices (e.g., water jackets or ice vests) to aid natural body 

ventilation. These devices, however, add weight, and their use should be 

balanced against worker mobility. 

• Install portable emergency showers and/or hose-down facilities to reduce body 

temperature and to cool protective clothing. 

• In extremely hot weather, conduct non-emergency response operations in the 

early morning or evening. 

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• Ensure that adequate shelter is available to protect personnel against sun, heat, or 

other adverse weather conditions that decrease physical efficiency and increase 

the probability of accidents. 

• In hot weather, rotate workers wearing protective clothing. 

• Maintain good hygienic standards by frequent changing of clothing and daily 

showering. Clothing should be permitted to dry during rest periods. Workers 

who notice skin problems should immediately consult the SHSO. 

Heat-Related Problems 

• Heat rash: Caused by continuous exposure to heat and humid air, and aggravated 

by chafing clothes. Decreases ability to tolerate heat and is a nuisance. 

• Heat cramps: Caused by profuse perspiration with inadequate fluid intake and 

chemical replacement, especially salts. Signs include muscle spasms and pain in 

the extremities and abdomen. 

• Heat exhaustion: Caused by increased stress on various organs to meet increased 

demands to cool the body. Signs include shortness of breath; increased pulse rate 

(120 to 200 beats per minute); pale, cool, moist skin; profuse sweating; and 

dizziness and exhaustion. 

• Heat stroke: The most severe form of heat stress. Body must be cooled 

immediately to prevent severe injury and/or death. Signs include red, hot, dry 

skin; no perspiration; nausea; dizziness and confusion; strong, rapid pulse; and 

possibly coma. Medical help must be obtained immediately. 

Heat-Stress Monitoring 

Monitoring of personnel wearing impermeable clothing will begin when the ambient temperature 

is 70°F (21°C) or above. Monitoring frequency will increase as the ambient temperature 

increases or as slow recovery rates are observed (see Table 6-3). Heat-stress monitoring will be 

performed by a person with current first-aid certification who is trained to recognize heat-stress 

symptoms. For monitoring the body's recuperative capabilities in response to excess heat, one or 

more of the techniques listed below will be used. Other methods of heat-stress monitoring may 

also be used, such as the wet-bulb globe temperature index from the American Conference of 

Governmental Industrial Hygienists (ACGIH) (1994-1995) Threshold Limit Value (TLV) 

Booklet. 

To monitor the worker, measure: 

• Heart rate: Count the radial pulse during a 30-second period as early as possible 

during the rest period. 

− If the heart rate exceeds 110 beats per minute at the beginning of the rest period, 

the next work cycle will be shortened by one-third and the rest period will remain 

the same. 

− If the heart rate still exceeds 110 beats per minute at the next rest period, the 

following work cycle will be reduced by one-third. 

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• Temperature: Use a infared ear themometer* to measure the body temperature (or a 

clinical thermometer (3 minutes under the tongue) to measure the oral temperature) at the 

end of the work period (before drinking). 

− If body temperature exceeds 99.6° (37.6°C), the next work cycle will be reduced 

by one-third without changing the rest period. 

− If body temperature still exceeds 99.6°F (37.6°C) at the beginning of the next rest 

period, the following work cycle will be reduced by one-third. 

− No worker will be permitted to wear a semi-permeable or impermeable garment 

when body temperature exceeds 100.6°F (38.1°C). 

*NOTE: 

When using an ear thermometer rather than oral readings, be aware of the following: 

− Ear readings, although rapid and useful as a screening tool, are dependent on 

technique 

− Multiple readings may be used to increase accuracy 

− Ear readings may run 0.5 to 0.9 degrees higher than the equivalent oral 

temperature, depending on the unit and technique 

− Daily readings, before work begins, may allow a correction factor to be 

determined for the specific ear thermometer in use 

Table 6-3 

Suggested Frequency of Physiological Monitoring for Fit and Acclimated Workers a 

Adjusted Temperature b Normal Work Ensemble c Impermeable Ensemble d 

90°F (32.2°C) or above After each 45 minutes After each 15 minutes 

of work of work 

87.5° - 90°F (30.8°- After each 60 minutes After each 30 minutes 

32.2° C) of work of work 

82.5° -87.5° F (28.1°- After each 90 minutes After each 60 minutes 

30.8°C) of work of work 

77.5°-82.5° F (26.3.3°- After each 120 minutes After each 90 minutes 

28.1°C) of work of work 

72.5°-77.5°F (22.5°- After each 150 minutes After each 120 minutes 

26.3.3°C) of work of work 

a For work levels of 250 kilocalories/per hour. 

b Calculate the adjusted air temperature (ta adj) by using this equation: ta adj = ta °F + (13 x 

sunshine multiplier [i.e., 50 percent sunshine equals a .5 multiplier). Measure air temperature 

(ta) with a standard mercury-in-glass thermometer, with the bulb shielded from radiant heat. 

Estimate the sunshine multiplier by judging what percent of time the sun is not covered by 

204


6-14 

December 2006 


clouds that are thick enough to produce a shadow (100 percent sunshine - no cloud cover and a 

sharp, distinct shadow; 0 percent sunshine = no shadows). 

c A normal work ensemble consists of cotton coveralls or other cotton clothing with long sleeves 

and trousers. 

d Saranex ® , Poly-Coated Tyvek ® , etc 

6.3.2.10 Urban Violence and Stray Animals 

All contact with transient population, hostile persons, or stray animals will be avoided. If 

potentially violent situation arises, project personnel will immediately remove themselves from 

the situation and contact the police and the PM. 

All site work will be conducted during the day (during day light, prior to sunset). No one will be 

allowed to work alone. The buddy system will be utilized at all times. 

6.3 BIOLOGICAL HAZARDS 

Various biological hazards may be encountered at the Site. These hazards include insects, 

spiders, toxic mold, harmful plants, and pathogenic organisms or diseases such as hantavirus. 

Due to the location of the site (presence of homeless/transients), there also is a potential of 

encountering hypodermic needles and human wastes. Project personnel will avoid contact with 

these biological hazards. Sturdy work clothes and steel-toe safety shoes/boots will be worn by 

field personnel to defend against unanticipated biological hazards. 

6.3.3.1 Insect/Arachnid Bites and Stings 

Poisonous insects and insect-like creatures at the site may include red fire ants, bees (honeybees, 

bumble bees, wasps, and hornets), mosquitos, and spiders. 

Red fire ants may be observed, especially in the vicinity of existing monitoring wells. Do not 

stand on, place equipment on, or otherwise disturb the anthills. It is also advisable to place a 

four-foot square piece of plywood where personnel need to stand. An insect repellent may be 

used if it does not interfere with the desired sampling analyses. Tyvek ® suits can be worn or 

latex booties can be taped at the top to the pants of field personnel. Frequent self-checks for 

crawling ants should also be performed. 

Mild insect stings and bites should be treated by applying a baking soda paste or ice wrapped in a 

wet cloth. Do not pull out stingers with tweezers or fingers. Stingers should be gently scraped 

from the skin, working from the side of the sting, using your fingernail, the edge of a credit card, 

a dull knife blade, or other straightedge object. 

Equine encephalitis, an inflammation of the brain, can be carried by mosquitoes. Symptoms 

range from none to mild flu-like symptoms (fever, headache, sore throat) to rare infection of the 

central nervous system with sudden fever and severe headaches followed quickly by seizures and 

coma. In the more severe variety, the mortality rate is up to 60 percent, with permanent brain 

damage in many of the survivors. Field personnel must wear long-sleeved clothing and/or use a 

DEET (N,N-diethyl-meta-toluamide) containing insect repellent if they are working in areas of 

mosquito infestations. 

West Nile virus is spread by the bite of an infected mosquito, and can infect people, horses, 

many types of birds, and some other animals. Most people who become infected with West Nile 

virus will have either no symptoms or only mild ones. On rare occasions, West Nile virus 

infection can result in a severe and sometimes fatal illness known as West Nile encephalitis (an 

205


6-15 

December 2006 


inflammation of the brain). The risk of severe disease is higher for persons 50 years of age and 

older. There is no evidence to suggest that West Nile virus can be spread from person to person 

or from animal to person. 

Human illness from West Nile virus is rare, even in areas where the virus has been reported. The 

chance that any one person is going to become ill from a mosquito bite is low. You can further 

reduce your chances of becoming ill by protecting yourself from mosquito bites. To avoid 

mosquito bites, apply insect repellent containing DEET when you are outdoors. When possible, 

wear long-sleeved clothes and long pants treated with repellents containing permethrin or DEET 

since mosquitoes may bite through thin clothing. Do not apply repellents containing permethrin 

directly to exposed skin. If you spray your clothing, there is no need to spray repellent containing 

DEET on the skin under your clothing. Also, consider staying indoors at dawn, dusk, and in the 

early evening, which are peak mosquito biting times. 

The two poisonous spiders likely to be encountered are the Brown Recluse and the Black 

Widow. They are usually found in buildings, utility box or monitoring well covers, or piles of 

debris, rocks, wood, or leaves. These spiders are typically non-aggressive, and bite only when 

disturbed. The Brown Recluse is up to one inch long with a violin or “fiddle” shaped mark on 

the top of the head. It is generally brown, but more poisonous varieties may be pale-brown, 

reddish-brown, orange, or gray. The Black Widow is a smaller, bulbous black spider with a red 

or yellow hourglass-shaped mark on the underside. It weaves shapeless diffuse webs in 

undisturbed areas. 

Persons who are believed to have been bitten by a Brown Recluse or Black Widow spider should 

be immediately transported to a hospital. The spider should be collected for confirmation of the 

species. 

Reactions to a Brown Recluse spider bite may be nothing, immediate, or delayed, depending 

upon the sensitivity of the person bitten and the amount of venom injected. A small white blister 

often occurs at the bite site surrounded by a swollen area. Within 24 to 36 hours, the victim may 

experience fever, chills, restlessness, weakness, nausea, and joint pain. Within 24 hours, the bite 

site can erupt into a “volcanic lesion”, which produces a hole in the flesh due to damaged 

gangrenous tissue. The open wound may range in size from an adult thumbnail to the span of a 

hand, with recovery taking months, and sometimes requiring plastic surgery and skin grafts. 

Reactions to a Black Widow spider include intense pain at the site of the bite after approximately 

15 to 60 minutes, followed by profuse sweating, rigid abdominal muscles, muscle spasms, 

breathing difficulty, slurred speech, poor coordination, dilated pupils, and generalized swelling 

of face and extremities. Death may occur due to complications, but usually not from the bite 

itself. 

6.3.3.2 Poisonous/Spiny Plants 

The majority of skin reactions following contact with offending plants is allergic in nature and is 

characterized by general symptoms of headache and fever, itching, redness and a rash. 

A person experiencing symptoms of an allergic reaction to a plant should remove contaminated 

clothing; wash all exposed areas thoroughly with soap and water. Apply calamine or other 

poison ivy/oak/sumac lotion if the rash is mild. Seek medical advice if a severe reaction occurs, 

or if there is a known history of previous sensitivity. Oak/ivy/sumac cleanser can be used after 

site work or after potential exposure to reduce chances of irritation. 

206


6-16 

December 2006 


Personnel are advised to wear sturdy work clothes, including long-sleeved shirts and heavy work 

gloves as necessary to protect against skin punctures and irritations. 

6.3.3.3 Rodents 

Another potential biological hazard is contracting respiratory illness from rodent droppings. In 

the western U.S., hantavirus is carried by the deer mouse and may be transmitted to humans by 

contact with its saliva, urine, and feces. People become infected when the virus is inhaled, 

through breaks in the skin, by ingesting contaminated food or water, or by being bitten by an 

infected rodent. 

Although the chance of getting the virus is very low, the virus is extremely dangerous and may 

be fatal to those who are infected. The disease begins with non-specific flu-like symptoms that 

include fever, muscle aches, headaches, abdominal pain, nausea, vomiting, coughing, and 

shortness of breath. Progression of the disease leads to fluid in the lungs, heart irregularities, and 

kidney failure. The symptoms begin between three days and six weeks after exposure to rodents, 

and rapidly progress to severe lung problems and respiratory failure. 

Personnel should be aware that infected mice may be present in semi-rural settings and vacant 

buildings and should avoid activities that may disturb fresh or dried rodent excretions in such 

areas. Personnel will use high efficiency particulate air (HEPA) equipped air-purifying 

respirators when working in rodent-infested areas or when entering shed of buildings containing 

mice infestations. Vector control authorities should be contacted upon the discovery of an active 

infestation. 

6.3.3.4 Human Biological Waste/Bloodborne Pathogen Control 

A shovel should be used to remove the material from the work area. Chlorine bleach/disinfectant 

will be used to decontaminate the shovel. If project personnel is accidently pricked by a 

hypodermic needle, he/she will be immediately transported to the local emergency hospital for 

evaluation and treatment. The SHSO will contact the PM and an accident report will be 

prepared. 

207

Project Name & Number: 

Location: 

Exhibit 6-1 – Activity Hazards Analysis Form 

Parsons 

Activity Hazards Analysis 

6-17 


December 2006 


AHA No. Date: 

Page____ of _____ 

New: 

Contractor: Revised: 

Required Personal Protective Equipment Analysis by: Date: 

Superintendent/Competent Person 

Reviewed by: Date: 

Work Task/Activity: Approved by: Date: 

Job Step Potential Hazards Preventive or Corrective Measures Inspection Requirements 

Training Requirements: 

All assigned employees are required to familiarize themselves with the contents of this AHA before starting a work activity and review it with their Supervisor during their 

Daily Safety Huddle. 

208

JOB NUMBER 

AHA NUMBER 

JOB LOCATION 

NAME OF TRAINER: 

SUBJECTS COVERED: 

TRAINING AIDS USED: 

ATTENDEES (PLEASE SIGN NAME LEGIBLY): 

(Use additional sheets if necessary) 


Exhibit 6-2 

Parsons 

Activity Hazards Analysis Training Record 

DATE: 

6-18 

December 2006 


209

6.4 SAFETY SYSTEMS ANALYSIS 


6-19 

December 2006 


GBU Safety Managers use the safety systems analysis for field staff and subcontractors whose 

work requires that they be on site for over six months. The analysis provides management with a 

rating that reflects the safety and health program effectiveness. Appendix B to the SHARP 

Management manual provides the program, protocol, and methodology. 

6.5 REMEDIATION SITE INSPECTION 

The remediation site inspection is a protocol designed to identify and correct unsafe acts and 

conditions, as well as recognize safe work practices and accomplishments, in Parsons or 

subcontractors’ scope of work. The Project Manager or Project Safety Manager should develop 

standard safety checklists appropriate to the work being performed. Exhibit 6-3 is an example of 

a simple checklist to evaluate a project’s status. The Project Manager shall develop a checklist 

based on questions from the audit programs in Appendix B of the SHARP Manual. 

Inspections involve a daily or weekly walkaround of a project site that focuses on safety. The 

Project Manager or Project Engineer responsible for the work conduct inspections, accompanied 

by the Project Safety Manager as necessary. Daily walkarounds do not have to be documented, 

but once a week the Project Manager prepares an inspection report using Exhibit 6-3 and 

forwards it to the Project Safety Manager for maintaining in the project file. Items found to be 

out of compliance must be assigned to the responsible party for corrective action and the 

corrective action tracked to completion. Subcontractors shall be advised of noncompliance items 

using a Notice of Subcontractor Violation, included as Exhibit 6-4. 

6.6 DAILY SITE WALK CHECKLIST 

Depending on the scope of work, type of activities (i.e. low risk versus high risk) and duration of 

the project, the Project Manager or their designee may be required to conduct a daily safety site 

walk using the Remediation Safety and Health Inspection Checklist in Exhibit 6-3 to identify 

problem areas. Items found to be out of compliance must be assigned corrective action and the 

corrective action tracked to completion. 

The Parsons Field Team Leader or SHSO will conduct tailgate safety meeting on a daily basis. 

Prior to commencement of field activities, he will discuss the various tasks to be conducted that 

day, potential hazards, and control measures. Documentation of daily tailgate safety briefings, 

including agenda and signatures of attending personnel, will be maintained on site. For drilling 

activities, the daily safety briefing will address the requirements of Parsons’ Mandatory Pre- 

Drilling Protocol. 

210


Exhibit 6-3: Remediation Safety and Health Inspection Checklist 

Project: Date: 

Inspector: Time: 

6-20 

December 2006 


Any items that have been found deficient must be corrected before work or use. 

This checklist includes, but is not limited to, the following: 

Safe Access and Workspace 

Are safe access and adequate space for movement available for: 

Emergencies 

Work area 

Walkways and passageways 

Are ladders, stairways, and elevators properly located and functioning? 

Is protection provided for excavations and trenches? 

Is overhead protection provided for all areas of exposure? 

Is lighting adequate? 

Planning Work for Safety 

Are employees provided with all required personal protective equipment 

(PPE)? 

Have other contractors and trades been coordinated with to prevent 

congestion and avoid hazards? 

Is air monitoring necessary to determine whether any chemical exposure 

exists? 

Utilities and Services Identification 

Has the Parsons Drilling Protocol been followed? 

Have all utilities been identified by signs/markout? 

Have high voltage lines been moved or de-energized, or barriers erected to 

prevent employee contact? 

Sanitary Facilities 

Is drinking water available? 

Are toilet facilities adequate? 

Work Procedures – Materials Handling 

Is material handling space adequate? 

Is material handling equipment adequate and proper? 

Is material handling equipment in good condition? 

Are workers properly trained to operate equipment and handle hazardous 

materials? 

Yes No N/A 

211

6.7 SAFETY AND HEALTH ENFORCEMENT 


6-21 

December 2006 


Parsons and its subcontractors enforce all applicable requirements of OSHA 1910 and 1926 as 

well as EM 385.1, where applicable. In addition, subcontractors must comply with and enforce 

Parsons’ site requirements. 

Parsons and its subcontractors have written progressive disciplinary systems available for review 

in the respective Human Resources departments. 

6.8 NOTICE OF VIOLATION OF SAFETY AND HEALTH 

REGULATIONS 

The project has a formal notice of subcontractor violation of safety and health regulations 

program to ensure that violations are issued in an immediately dangerous to life and health 

(IDLH) situation or when the subcontractor repeatedly fails to comply with safety and health 

requirements. 

The notice (Exhibit 6-4) documents poor performance and requires a response from 

subcontractor senior management. The notice contains five distinct levels of discipline, from 

submission of a recovery plan to contract termination. 

6.9 COMPETENT FIRST AID PERSON 

The OSHA Regulations (29 CFR 1910.151 and 1926.50) state the employer shall ensure the 

ready availability of medical personnel for advice and consultation on matters of occupational 

health. In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible 

in terms of time and distance to the worksite (i.e. 4 minutes for activities that can be expected to 

result in an accident involving suffocation, severe bleeding, or other life threatening or 

permanently disabling injury or illness and 15 minutes for other types of injuries), which is 

available for the treatment of injured employees, a person who has a valid certificate in first-aid 

training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can 

be verified by documentary evidence, shall be available at the worksite to render first aid. Firstaid 

supplies must be accessible for immediate use and be of sufficient size and number to handle 

common first aid incidents. 

The Parsons CSHM States: “At least two employees on each shift must be qualified to 

administer first aid and CPR when a medical facility or physician is not accessible within five 

minutes of an injury to a group of two or more employees for the treatment of injuries.” 

The response time for Emergency Medical Services (EMS) when dialing 911 has been 

determined to be 5 minutes. Based on the activities provided in the Scope of Work (Section 2.1) 

and the list of Activity Hazard Analysis (AHA) included in Section 6.3, the project does not 

expect to have an exposure involving suffocation, severe bleeding, or other life threatening or 

permanently disabling injury or illness. However, the level of risk associated with each field 

effort will be evaluated on a case-by-case basis. If EMS cannot respond to the project in less 

than 15 minutes (or 5 minutes for a field effort with expected exposure to the risks listed above), 

then the project will require at least two individual on site at all times that work is being 

performed to have a valid certificate in CPR and first aid. 

212


6-22 

December 2006 


EMPLOYEE NAME FACILITY LOCATION CPR EXP. FA EXP. 

N/A NA NA NA 

The Parsons Corporate Health and Safety requirements for Parsons employee training and 

medical monitoring will be implemented for this project. All field team members will have 

completed the 40-hour basic health and safety training as specified by the California Code of 

Regulations (CCR), Title 8, Section 5192 and the 8-hour annual refresher training thereafter as 

specified in the regulation. All supervisory personnel on site will be required to have completed 

an 8-hour supervisor course as required in CCR, Title 8, Section 5192. 

In addition to the 40-hour course, all field employees will be required to have completed a 

minimum of 3 days on-site training under the supervision of a trained and experienced 

supervisor, not necessarily at the Site. If the training is received during the current study, the 

training will be documented on the Field Experience Documentation Form. Employees will not 

participate in field activities until they have been trained to the level required by their job 

function and responsibility. 

In addition to the 40-hour course, at least one person on the Parsons field crew will have 

completed Red Cross or an equivalent first-aid and cardiopulmonary resuscitation (CPR) course. 

All training documentation for Parsons personnel will be verified by the SHSO and maintained 

by the Pasadena facility health and safety representative (FHSR). 

For asbestos work, sampling and monitoring field personnel will have completed the Asbestos 

Hazard Emergency Response Act/Environmental Protection Agency (AHERA/EPA) Asbestos 

Building Inspection and Contractor/Supervisor training. All asbestos work, including abatement 

work, will be monitored by an AHERA/EPA asbestos certified asbestos technician under the 

direction of a Cal/OSHA certified site surveillance technician or an asbestos consultant. 

Lead-based paint (LBP) inspection and/or sampling will be conducted by those who have 

completed the EPA/Department of Housing and Urban Development (HUD) certification. State 

of California, Department of Health Services (DHS)-certified LBP assessor/inspector may be 

required for LAUSD work. 

All Parsons field team members will be on current medical monitoring programs in accordance 

with Cal/OSHA requirements (Title 8, CCR, Section 5192) and Parsons corporate policies. 

Listed below are additional health and safety training and medical monitoring requirements for 

this project. 

Training records of all site personnel, including training certificates of the hazardous waste 

removal contractor, will be available on-site for review by the regulatory agencies. 

213

Contractor Name: 

Address: 

Attention: 


6-23 

December 2006 


Exhibit 6-4 – Notice of Subcontractor Violation of Safety and Health Regulations 

Parsons 

Notice of Subcontractor Violation 

of Safety and Health Regulations 

This letter officially notifies you that you have been found to be in violation of the following Safety Regulations: 

on (date) ____________________, by . 

Confined Space Entry Lockout/Tagout Hot Work 

Knowledge of the 

environment 

Date: 

Personal Protective 

Equipment 

Awareness of warning 

alarms Evacuation routes Back-up Alarms 

Environmental/Hazardous 

Material Storage 

Assembly locations Fall Protection Scaffolding 

Trenching Safe Work Practices Security Practices 

Other: 

This/These violations occurred at the following locations: 

at the following times______________________________ and dates 

The name of the employees was/were 

under the supervision of . 

214


Parsons 

6-24 

December 2006 


Notice of Noncompliance with Safety and Health Regulations 

Under conditions of this enforcement procedure check all items that apply: 

_____ 1. You are being notified of this violation and should take corrective action to prevent a reoccurrence. The corrective 

action shall be documented to the Parsons Construction Management representative immediately. 

_____ 2. You must submit a plan for compliance to your Parsons Construction Management representative and the 

Construction Safety Manager within two days of receipt of this letter. The compliance plan must include the means 

or methods of compliance and the date that the requirements for compliance will be completed. Once compliance 

has been achieved, a follow up letter must be sent to the Parsons Construction Management representative and 

Construction Safety Manager. Failure to comply will result in disciplinary action against your Company. 

_____ 3. You are required to review the stated procedures with your Parsons Construction Management representative. 

Work may not commence on the site until the review is complete and the Subcontractor responds formally that the 

procedure is understood and will comply. 

_____ 4. You are required to review the stated procedures with your Parsons Construction Management representative. 

Work may not commence on the site until the review is complete and you must confirm formally the disciplinary 

action to be taken against the supervisor and employees. 

_____ 5. All work on the site will stop until the Parsons Construction Management representative reviews all the facts with 

the Subcontractor and determines if the contract between the parties will be terminated. 

cc: Issuing Construction Manager Representative 

Job File 

GBU Safety Manager 


Sincerely, 

___________________________ 

Parsons Representative 

215

TABLE 6-1: HAZARDOUS SUBSTANCES OF CONCERN 

Odor Ionization Physical 

Compound PEL a/ 

TLV b/ 

IDLH c/ 

Threshold d/ 

Potential e/ 

Description/Health 

(ppm) (ppm) (ppm) (ppm) (eV) Effects/Symptoms 

Arsenic 

(Inorganic, as As) 

0.01 mg/m 3f/ 

'(CCR, Title 8, Section 5214) 

g/ 

Benzene 1 

(CCR, Title 8, Section 5218) 

g/ 

Chlordane 

(alpha and gamma) 

Chlorodiphenyl (54% chlorine) 

(PCB, Aroclorâ-1248) 

0.5 mg/m 3 

(skin) 

0.5 

mg/m 3j/ 

(skin) 

Chromium metal 0.5 mg/m 3 

Chromium (II) and (III) 

Compounds (as Cr) 

Chromium (VI) 

(Water soluble compunds) 

__ 

Chromium (VI) 

(Water insoluble compunds) 

0.5 mg/m 3 

0.05 mg/m 3 

(ceiling) k/ 

____ 

0.01 mg/M 3 

0.01 mg/m 3 

0.5 

(skin) i/ 

0.5 mg/m 3 

(skin) 

0.5 

mg/m 3j/ 

(skin) 

0.5 mg/m 3 

0.5 mg/m 3 

0.05 mg/m 3 

5 mg/m 3 

NA h/ NA Silver-gray or tin-white, brittle, odorless solid. Causes ulceration 

of the nasal septum, dermatitis, gastrointestinal disturbances, 

nervious system degeneration, respiratory irritation, skin spots, 

and lung and lymphatic cancer. Mutagen, experimental teratogen, 

and carcinogen. 

500 4.7 9.24 Colorless to light-yellow liquid (solid




TLV b/ 

IDLH c/ 

Threshold d/ 

Potential e/ 



Lead 

as Pb 

________ 

as Cr 

Tetrachloroethene (PCE) 

(Perchlorethylene) 

0.05 mg/m 3 


g/ ________ 

0.012 mg/M 3 

0.05 mg/m 3 

Toluene 50 50 

(skin) 

1,1,1-Trichloroethane (TCA) 

(Methyl Chloroform) 

100 mg/m 3 NA NA Heavy, ductile, bluish-gray, soft metal. Irritates eyes. Causes 

weakness, exhaustion, insomnia, facial pallor, anorexia, lowweight, 

malnutrition, constipation, abdominal pain, gastritis, colic, 

constipation, gingival lead line, anemia, wrist and ankle paralysis, 

joint pains, tremors, low blood pressure, and kidney disease. 

Mutagen, experimental teratogen, and suspected carcinogen. 

25 l/ 25 150 5-50 9.32 Colorless liquid with a mild chloroform odor. Eye, nose, skin and 

throat irritant. Causes nausea, flushed face and neck, vetigo, 

dizziness, headaches, hallucinations, incoordination, drowsiness, 

coma, pulmonary changes, and skin redness. Cumulative liver, 

kidney, and CNS damage. In animals, causes liver tumors. 

Mutagen, experimental teratogen, and carcinogen. 

500 0.2-40 m/ 8.82 Colorless liquid with sweet, pungent, benzene-like odor. Irritates 

eyes and nose. Causes fatigue, weakness, dizziness, headaches, 

hallucinations or distorted perceptions, confusion, euphoria, 

dilated pupils, nervousness, tearing, muscle fatigue, insomnia, 

skin tingling, dermatitis, bone marrow changes, and liver and 

kidney damage. Mutagen and experimental teratogen. 

350 350 700 20-500 11.00 Colorless liquid with a mild chloroform-like odor. Irritates eyes 

and skin. Causes headaches, exhaustion, CNS depression, poor 

equilibrium, dermatitis, liver damage, cardiac arrhythmia, 

hallucinations or distorted perceptions, motor activity changes, 

aggression, diarrhea, and nausea or vomiting. Mutagen, 

experimental teratogen, and questionable carcinogen. 

Trichloroethene (TCE) 25 50 1,000 21.4-400 9.45 Clear, colorless or blue liquid with chloroform-like odor. Irritates 

skin and eyes. Causes fatigue, giddiness, headaches, vertigo, 

visual disturbances, tremors, nausea, vomiting, drowsiness, 

dermatitis, skin tingling, cardiac arrhythmia, and liver injury. In 

animals, causes liver and kidney cancer. Mutagen, experimental 

Vinyl Chloride 1 


g/ 

2/27/2007 2 

teratogen, and carcinogen. 

5 NA 260 9.99 Colorless gas (liquid




TLV b/ 

IDLH c/ 

Threshold d/ 

Potential e/ 



Xylene 

(o-, m-, and p-isomers) 

100 100 900 0.05-200 m/ 8.56 

8.44 (p) 

Colorless liquid with aromatic odor. P-isomer is a solid


7.0 SAFETY TRAINING 

7.1 PROJECT SAFETY ORIENTATION 

7-1 

December 2006 


The Parsons Project Manager, Project Engineer, or Project Safety Manager conducts the sitespecific 

orientation for all new Parsons staff and subcontractor management personnel. 

The Orientation takes approximately one hour to complete and consists of applicable owner, 

Parsons, and regulatory reference material, including: 

• Owner – Contractor Safety Program and Manual of Safety Regulations Handbook and 

security requirements 

• Applicable OSHA 29 CFR 1910 General Industry and 29 CFR 1926 Construction 

Regulations and others as required 

• Parsons applicable requirements, including items covered in Section 4.2 

• Subcontractor requirements 

All visitors must receive a brief orientation as described in Section 4.2, and be escorted by the 

Project Manager, Project Engineer, Project Safety Manager or a designee familiar with the 

potential hazards on the project. 

Subcontractors must conduct similar orientations for their staff and craft employees and must 

document all orientations using the Employee/Subcontractor Training Acknowledgement and 

sample form (Exhibit 7-1). The Project Manager maintains the orientation documents and 

acknowledgement forms. 

7.2 PARSONSU SAFETY MODULES AND START TRAINING – ZERO 

INCIDENT TECHNIQUES 

Consistent with Parsons corporate initiatives in safety training, the Project Manager will identify 

all applicable personnel (i.e. managers, engineers and supervisors, including subcontractor 

personnel), that shall be current in the completion of safety modules on ParsonsU and that should 

receive START (Supervisory Training in Accident Reduction Techniques) training to further 

Parsons’ goal of zero incidents. 

The GBU and Division Safety Manager serve as the certified trainers for periodic START 

training sessions for new personnel. They should be contacted if personnel need to receive 

training. 

219

Name of Trainer: 

Training Subject: 

Training materials used: 

Name of employee: 

Date of hire/assignment: 


Exhibit 7-1 

Parsons 

7-2 

December 2006 


Employee/Subcontractor Training Acknowledgement 

I, , hereby certify that I have received training as described above in the following areas: 

• Names of personnel responsible for site safety and health. 

• Safety, health or other hazards at the site. 

• The proper use of personal protective equipment. 

• The potential occupational hazards in general in the work area and associated with my job assignment. 

• Work practices by which a worker can minimize risks from hazards. 

• Safe use of engineering controls and equipment on the site. 

• Acute effects of compounds on the site. 

• Decontamination procedures. 

• General safety requirements indicate the safe work conditions, safe work practices and personal protective equipment 

required for my work. 

• The hazards of any chemicals to which I may be exposed and my right to information contained on material safety data 

sheets for those chemicals, and how to understand this information. 

• My right to ask questions, or provide any information to the employer on safety either directly or anonymously without 

any fear of reprisal. 

• Disciplinary procedures the employer will use to enforce compliance with general safety requirements. 

I understand this training and agree to comply with general safety requirements for my work area. 

Employee Signature 

Date 

220


Exhibit 7-2 - Safety Meeting Sign-In Sheet 

7-3 

December 2006 


Safety Meeting Presenter: _______________________________ Date: __________________ 

Current Weather Conditions: 

Temperature ( o F) = _____ Wind Direction = _______ Wind Speed = _________ 

Clear - Sunny – Cloudy – Rain - Snow Forecast = _________________________________ 

Current Site Conditions (circle as appropriate): 

Dry - Wet - Muddy - Frozen - Snow Covered - Other (describe) __________________________ 

1. Incidents or Injuries to report from Previous Day Activities: No ⁭ Yes ⁭ - explain below: 

______________________________________________________________________________ 

2. Safe and/or At-Risk Observations from Previous Day Activities:________________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

3. Activities Taking Place Today: __________________________________________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

3. Anticipated Hazards: __________________________________________________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

4. Engineering Controls-Work Practices-PPE to Protect Against Hazards: __________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

5. Additional Safety Topic or Comments: ____________________________________________ 

______________________________________________________________________________ 

221


7-4 

December 2006 


PRINTED NAME SIGNATURE COMPANY LAST 4 DIGITS 

OF SS # 

222

7.3 DAILY TOOLBOX SAFETY MEETINGS 


7-5 

December 2006 


Parsons and its subcontractors conduct daily toolbox safety meetings at the beginning of each 

week. These meetings include topics relevant to upcoming work and may include reviews of 

recent incidents on the project. The Project Manager is responsible for the toolbox safety training 

content and documenting and retaining attendance records using Exhibit 7-2. 

7.4 ACTIVITY HAZARDS ANALYSIS TRAINING 

When the activity hazards analysis is complete, the Parsons Project 

Manager/Engineer/Supervisor or subcontractor conducts a training session with all employees 

involved with the analyzed task. The training may be informal and at the site where the task is 

performed. Employees should be given an opportunity to provide input regarding task steps, 

hazards identified, and appropriate control measures. 

The Project Manager documents and maintains the activity hazards analyses using Exhibit 6-2. 

7.5 REGULATORY TRAINING PROGRAMS 

OSHA regulations require specific training in certain circumstances. Based on the scope of work 

and meetings with regulatory officials, the following training topics are provided on the project: 

• Hazard Communication – as per 29 CFR 1910.1200 

• General – all workers engaged in activities which are potentially exposed to hazardous 

substances and health hazards must be trained to meet 1910.120(e)(1). Annual 8-hour 

refresher training as per 29 CFR 1910.120(e)(3) is required for workers and supervisors 

must be trained to meet 29 CFR 1910.120(e)(4). 

• CPR/AED/First aid – provided to personnel based on project activities identified in the 

Scope of Work (i.e. life threatening) and EMS response time (i.e. less than 15 minutes). 

See Section 6.9. 

• Respiratory Protection Training – Any field employee required to use respiratory 

protection will have completed the respirator protection training and fit-testing in 

accordance with CCR, Title 8, Section 5144. 

• Signaling. 

• Power-operated hand tools 

The Project Manager determines the necessary training and coordinates the training with the 

Project Safety Manager. 

7.6 OSHA OUTREACH PROGRAMS 

When applicable, the project may use qualified instructors and online courses to conduct OSHA 

10-hour construction safety training. If applicable, supervisory staff must complete the 30-hour 

223


7-6 

December 2006 


course. Depending on the scope of work, similar requirements may be included in all 

subcontracts. Participants successfully completing the course receive a certificate of completion 

from OSHA. 

7.7 SPECIALIZED TRAINING AND ORIENTATIONS 

Project personnel receive specialized training on client rules and requirements as well as the 

unique tools, equipment, and procedures used to perform the work. The project budget includes 

funding for the following training (Table 7-1): 

Table 7-1: Specialized Training and Orientations 

Description Attendees Schedule 

General rules and safety 

requirements 

Behavior-based safety training Project managers, field personnel 

and routine subcontractors 

Behavior-based safety training Administrative personnel and nonroutine 

subcontractors 

Controlled substance and alcohol 

awareness training 

All workers assigned to the site Half-hour training session, provided to new 

employee on the first day of work at the site. 

Full day session (8-hours). 

Awareness training (1-hour), which can be 

provided by an individual that has received the 

one-day course. 

Supervisors When assigned to a client that requires 

substance abuse and alcohol testing. 

7.8 VISITOR TRAINING 

Site access by personnel making deliveries or performing repairs to utilities, public or 

government officials, visitors, or local residents will be limited to support areas only. These 

persons will not be required to comply with the training requirements as previously defined and 

the medical monitoring requirements described below. Exclusion Zone access will be limited to 

designated work, delivery, or observation areas to minimize any potential exposure to site 

chemicals. Site observation areas will be located upwind from predominant wind directions, and 

access to observation areas may be restricted by weather conditions or site activities. 

Site access for visitors will be limited to areas with no potential for exposure during routine 

operations. These personnel will be escorted on site and will be strictly prohibited from entering 

the Contamination Reduction Zone or Exclusion Zone. Authorization for limited site access will 

be determined on a case-by-case basis by the SHSO in consultation with the Project Health and 

Safety Manager and project manager. 

224


8-1 

December 2006 


8.0 RECORDKEEPING AND POSTING 

Parsons and its subcontractors must comply with the recordkeeping requirements of OSHA, 

Owner, Parsons Corporation, and this safety program, including: 

• OSHA 300 logs 

• Medical treatment and follow-up 

• Cranes 

• Heavy equipment inspection logs 

• Fall protection 

• Training 

• Inspections 

• Audits 

• Others as required 

The Project Manager is the official record keeper for files relating to Parsons employees. Each 

subcontractor maintains its files. 

The project displays OSHA posters in conspicuous places as required by OSHA, including one 

poster on the main bulletin board located at the Parsons’ offices in Pasadena, California. The 

OSHA 300 log for the project or the GBU shall be posted from February 1 – April 30 of each 

calendar year. 

225


9-1 

December 2006 


9.0 SAFETY AND HEALTH REQUIREMENTS 

9.1 SAFETY AND HEALTH REQUIREMENTS 

Table 9-1 represents OSHA, owner, and Parsons corporate regulations and requirements 

applicable to the project. Based on the most recent risk assessments, Parsons Project Manager 

and Project Safety Manager update the listed topics periodically. Training and other 

requirements are updated in this PSP as required by changes to Table 9-1. 

Parsons and its subcontractors are individually responsible for training their respective 

employees and for complying with all project requirements. Failure to comply could lead to 

disciplinary actions against Parsons employees and subcontractors or their employees. 

Table 9-1 – Competent Person and Activity Hazards Analysis Requirements 

Safety and Health Requirement 

OSHA 

Regulation 

EM 385-1-1 

Regulation 

Competent 

Qualified 

Person-Supv Training 

Required 

1. General Safety & Health 1926.20 01.A Yes Yes Yes 

2. Safety Training 1926.21 01.B.01 Yes Yes Yes 

3. Confined Spaces 1910.146; 1926.21 06.01 Yes; Supv Yes Yes 

4. Confined Space Permit System 1910.146 06.01 Yes Yes Yes 

5. First Aid and Medical 1926.23, 50 03.A Yes Yes Yes 

6. Fire Protection and Prevention 1926.24, 150-155, 352 09.A Yes Yes Yes 

7. Housekeeping 1926.25 14.C N/A N/A N/A 

8. Illumination 1926.26, 56 07.A Recommended N/A N/A 

9. Sanitation 1926.27, 51 02.A N/A N/A N/A 

10. Personal Protective Equipment 1926.28, 95-98, 100-107 05.A Yes Yes Yes 

11. Acceptable Certifications 1926.29 Yes Yes Yes 

12. Incorporation by Reference 1926.31 Preamble N/A N/A N/A 

13. Emergency Employee Action Plans 1926.35 01.E Recommended Yes Yes 

14. Noise Exposure 1910.95; 1926.52 05.C Yes Yes Yes 

15. Radiation Protection 1926.53, 54 Yes Yes Yes 

16. Gases, Vapors, Dusts and Mists 1926.1926.55 Yes Yes Yes 

17. Ventilation 1926.57, 353 Recommended Yes Yes 

18. Hazard Communication 1926.59 1.B.06 Yes Yes Yes 

19. Process Safety Management 1910.119; 1926.64 Yes Yes Yes 

20. Hazardous Waste Operations and 

Emergency Response 

1910.120; 1926.65 28.A Yes 

Supv – 8 hr 

Yes Yes 

21. Accident prevention signs and tags 1926.200 08.A N/A N/A N/A 

22. Signaling 1926.201 08.B Recommended N/A Yes 

23. Barricades 1926.202 N/A N/A N/A 

24. Material Storage 1926.250 14.B N/A Yes Yes 

AHA 

Required 

226


9-2 

December 2006 


Table 9-1 – Competent Person and Activity Hazards Analysis Requirements (Contd) 


OSHA 

Regulation 

EM 385-1-1 

Regulation 

Competent 

Qualified 

Person 

Training 

Required 

25. Rigging 1926.251 15.A Yes Yes Yes 

26. Waste Disposal 1926.252 14.D Yes Yes Yes 

27. Tools 1926.300-307 13.A N/A N/A Yes 

28. Gas Welding and Cutting 1926.350 10.A Recommended Yes Yes 

29. Arc Welding 1926.351 10.E Recommended Yes Yes 

30. Electrical 1926.400-415 11.E Yes Yes Yes 

31. General Electrical 1926.416 11.A Yes Yes Yes 

32. Lockout Tagout 1910.147; 1926.417 12.A Yes Yes Yes 

33. Lockout Tagout Permit System 1910.147 12.A Yes Yes Yes 

34. Maintenance of Electrical Equipment 1926.431 11A Yes Yes Yes 

35. Environmental Deterioration of 

Electrical Equipment 

1926.432 Yes Yes Yes 

36. Batteries/Battery Charging Equipment 1926.441 11.E N/A Yes Yes 

37. Scaffolding 1926.450-454 22.A Yes Yes Yes 

38. Aerial Lifts 1926.453 22.J and K Yes Yes Yes 

39. Fall Protection 1926.500-503 21.A Yes Yes Yes 

40. Cranes, Derricks, Hoists, Elevators and 

Conveyors 

1926.550 16.A Yes Yes Yes 

41. Motor Vehicles, Mechanized Equipment 1926.600-603 18.A Yes Yes Yes 

42. Powered Industrial Trucks (forklifts) 1910.178 Yes Yes Yes 

43. Site Clearing 1926.604 31.A N/A Yes Yes 

44. Marine Operations and Equipment 1926.606 16.F Yes Yes Yes 

45. Excavations 1926.650-652 25.A Yes Yes Yes 

46. Excavation Permit N/A N/A Yes Yes Yes 

47. Concrete and Masonry Construction 1926.700-706 27.A Yes Yes Yes 

48. Steel Erection 1926.750-761 and 

SENRAC 

Yes Yes Yes 

49. Underground Construction 1926.800 26.A Yes Yes Yes 

50. Caissons 1926.801 26.H Yes Yes Yes 

51. Cofferdams 1926.802 Yes Yes Yes 

52. Compressed Air 1926.803 26.I Yes Yes Yes 

53. Demolition 1926.850-860 inclusive 23.A Yes Yes Yes 

54. Power Transmission and Distribution 1926.950-960 inclusive 11.H Yes Yes Yes 

55. Rollover Protective Structures; 

Overhead Protection 

1926.1000-1003 inclusive N/A N/A Yes 

56. Stairways and Ladders Scope 1926.1050 21.A N/A Yes Yes 

57. S/L General Requirements 1926.1051 Yes Yes Yes 

AHA 

Required 

227


9-3 

December 2006 


Table 9-1 – Competent Person and Activity Hazards Analysis Requirements (Contd) 


OSHA 

Regulation 

EM 385-1-1 

Regulation 

Competent 

Qualified 

Person 

Training 

Required 

58. Stairways 1926.1052 21.E Recommended Yes N/A 

59. Ladders 1926.1053 21.D Yes Yes Yes 

60. Ladder/Stair Training 1926.1060 Yes Yes Yes 

61. Diving Scope 1926.1071-1072 30.A Yes Yes Yes 

62. Dive Team Quals 1926.1076 30.A.08 Yes Yes Yes 

63. Dive Safe Practices Manual 1926.1080 30.A.16 Yes Yes Yes 

64. Predive Procedures 1926.1081 Yes Yes Yes 

65. Procedures During Dive 1926.1082 30.A.15 Yes Yes Yes 

66. Post Dive Procedures 1926.1083 30.A.22 Yes Yes Yes 

67. SCUBA Diving 1926.1084 30.B Yes Yes Yes 

68. Surface-Supplied Air Diving 1926.1085 30.A.04 Yes Yes Yes 

69. Mixed-gas Diving 1926.1086 30.D Yes Yes Yes 

70. Liveboating 1926.1087 30.A.05 Yes Yes Yes 

71. Diving Equipment 1926.1090 30.E Yes Yes Yes 

72. Diving Recordkeeping Requirements 1926.1092 30.A.06 Yes Yes Yes 

73. Internal Traffic Control N/A 8.D N/A Yes Yes 

74. Traffic Movement Restriction Times N/A 8.C N/A Yes Yes 

75. Line Breaking 1910.119 and 1926.54 Yes Yes Yes 

76. Major Material Movements N/A N/A N/A Yes Yes 

77. Right-of-way Restrictions N/A N/A N/A Yes Yes 

78. Bicycles/Golf Carts N/A 18.D N/A Yes N/A 

79. IIPP/SSPP Cal 3203 Cal 3203 Yes Yes Yes 

AHA 

Required 

228


10-1 

December 2006 


10.0 LEVELS OF PROTECTION AND PERSONAL 

PROTECTIVE EQUIPMENT 

REQUIRED FOR SITE ACTIVITIES 

10.1 PERSONAL PROTECTIVE EQUIPMENT 

Engineering controls, primarily odor and dust suppressants, will be used to minimize exposures 

to hazardous materials. However, in conjunction with engineering controls, PPE will be used at 

this Site. 

The personal protection levels prescribed for the Site is OSHA Level D (no respiratory or 

chemical protective clothing), with a contingency for the use of Modified OSHA Level D 

(protective clothing with no respiratory protection) or OSHA Level C (protective clothing with 

use of air-purifying respiratory [APR] protection) as site conditions require. 

10.1.1 Level D 

Level D consists of the following: 

• ANSI-approved safety glasses; 

• ANSI-approved hard hat during activities with overhead hazards; 

• ANSI-approved steel-toed work boots; 

• Ear protection whenever near heavy equipment; 

• Work clothing as prescribed by weather; 

• Nitrile sampling gloves when handling samples; and 

• Heavy-duty cotton or leather work gloves when handling materials or equipment. 

10.1.2 Modified Level D 

Modified Level D consists of the following: 

• ANSI-approved safety glasses; 

• ANSI-approved hard hat during activities with overhead hazards; 

• ANSI-approved steel-toed work boots; 

• Ear protection whenever near heavy equipment; 

• Nitrile, neoprene, or PVC skid-proof boot covers or rubber steel-toed boots; 

• Outer and inner nitrile gloves; and 

• Disposable coveralls (i.e. poly-coated Tyvek ® coveralls or liquid, chemical 

resistant coveralls). 

229

10.1.3 Level C Protection 


10-2 

December 2006 


Level C protection consists of wearing a half-face or full-face APR with organic vapor/acid 

gas/P-100 filter combination cartridges. Both the respirators and chemical/filter cartridges must 

be approved by National Institute for Occupational Safety and Health (NIOSH). APR cannot be 

used under the following conditions: 

• Oxygen deficiency (ambient atmosphere contains less than 19.5 percent oxygen); 

• Immediately dangerous to life and health (IDLH) concentration; or 

• Chemicals of Concern (COCs) levels exceed designated maximum use 

concentrations. 

Individuals must wear a respirator that has been successfully fitted to their face. The SHSO will 

maintain fit test documentation on site. An improperly fitted respirator may leak and provides 

little respiratory protection. 

For use of APR, respirators must be equipped with NIOSH-approved end-of-service-lifeindicator 

(ESLI) for a specific COC or must use a cartridge change-out schedule developed for 

use for a particular COC (i.e. for use of NORTH respirators, a NORTH Respiratory Protection 

Service Life Estimation Table will be used). The cartridge change-out schedule is based on the 

concentration of the COC in the work area (air monitoring data). For this project, site personnel 

will dispose of the cartridge after each use (at the end of the day). 

In addition to the respiratory protection, Level C includes the following protective equipment: 

• Disposable coveralls, e.g., poly-coated Tyvek ® or liquid/chemical resistant 

clothing; 

• Inner and outer nitrile gloves; 

• ANSI-approved steel toe safety boots with disposable boot covers or rubber steel 

toe safety boots; 

• ANSI-approved hard hat during activities with overhead hazards; and 

• Ear protection whenever near heavy equipment. 

10.2 SELECTION OF LEVELS OF PROTECTION AND ACTION 

LEVELS 

A variety of potential COCs have been previously identified at the Site. Chemicals known to be 

present at the Site include volatile organic compounds (VOCs) such as benzene, toluene, 

ethylbenzene, and xylene (BTEX), metals, PCBs, and polycyclic aromatic hydrocarbons (PAHs). 

At this site, benzene will be the indicator compound used to determine levels of protection. The 

indicator is the COC at the site with the lowest permissible exposure limit (PEL). 

Detection of gases and vapor will be initially conducted using a PID instrument followed by 

colorimetric detector tubes/pump (e.g. Dräeger ® tubes). This may be supplemented with the use 

of personal air sampling pumps (personal and/or area monitoring), and air grab bag sampling to 

determine the specific chemical that may be present in the work area. Table 10−1 provides VOC 

action levels, appropriate responses/air monitoring requirements, and levels of protection. 

230

Concentration of 

Organic Vapors 

(In the Breathing 

Zone) 

0 to 1 ppm total VOCs 

above background 

(using PID) 

1 ppm to 5 ppm total 

VOCs above 

background 

(using PID) 

0.5 ppm to 5 ppm of 

benzene 

(using Dräeger ® tube) 

5 – 100 ppm total 

VOCs above 

background 

(using PID) 

> 100 ppm total VOCs 

above background 

(using PID) or 

5 ppm benzene 

(by Dräeger ® tube) 


Table 10-1 

Action Levels for VOCs 

Level of 

Respiratory 

Protection 

10-3 

December 2006 


Responses 

and 

Air Monitoring Requirements 

Level D Stay upwind from the source/area of COC. 

Level D or C Stay upwind from the source/area of COC. 

Conduct benzene Dräeger ® tube monitoring to 

confirm the absence of this COCs. If presence of 

benzene is detected above 0.5 ppm, upgrade to 

Level C respiratory protection and follow 

responses described below (0.5 to 5 ppm of 

benzene [using Dräeger ® tube]). Maintain 15 

minute exposure > 2.5 ppm at all times. 

Level C Stay upwind from the source/area of COC. 

Conduct benzene Dräeger ® tube monitoring every 

15 minutes. Confirm its presence and 

concentration using personal air sampling 

pumps/charcoal tube. At 5-ppm benzene on the 

Dräeger ® Level C 

tube, stop work and consult the PM. 

Stay upwind from source/area of COC; continue 

benzene Dräeger ® tube monitoring if the presence 

of this COC is found and conduct personal air 

sampling pumps/charcoal tube sampling to 

determine adequacy of respiratory protection. 

NA Stop work, evacuate the site, and consult the PM. 

When the total organic vapor concentration exceeds 1 ppm above background for 30 seconds 

within the breathing zone, benzene colorimetric tube monitoring will begin. If benzene is 

detected above its action level, all requirements of Cal/OSHA Benzene Standard, Title 8, CCR, 

Section 5218 will be implemented. All air readings will be collected in the breathing zone to 

determine the level of protection. 

231

Action levels for potential benzene contamination are as follows: 

• Level D protection shall only be used when: 


10-4 

December 2006 


− Total organic vapor readings on the PID are between 0 to 5 ppm above background, 

and benzene concentration is less than 0.5 ppm. 

• Level C protective ensemble must be donned when: 

− Total organic vapor readings in the breathing zone are 5 to 100 ppm above 

background for 30 seconds. 

− Benzene concentration as determined by colorimetric tube monitoring is between 0.5 

to 5.0 ppm. Confirmation sampling using personal sampling pump and charcoal tube 

is required to determine the actual presence and concentration of benzene. 

If total organic vapor readings in the breathing zone exceed 100 ppm for 30 seconds or more 

and/or the benzene Dräeger ® tube reading exceeds 5.0 ppm benzene, the SHSO will stop work 

and re-evaluate site conditions. 

If background information and planned site activities indicate a potential for significant levels of 

metals, PAHs, pesticides, or PCBs to be generated at the site, and dust control measures cannot 

be implemented during field activities, particulate monitoring will be conducted utilizing a real 

time monitor, such as a MiniRam. The action levels noted in Table 10-2 are based on half of the 

Cal/OSHA PEL for respirable dust (particulates). These action levels may be amended on a sitespecific 

basis depending on the COC, concentration, activities, etc. Any such site-specific 

amendment will be noted in the addendum to the HASP. Air samples will be collected using a 

personal sampling pump and appropriate filters to determine specific chemicals of concern. 

Concentration of 

Particulates 

(Sustained for > 1 min.) 

Table 10-2 

Action Levels for Particulates 

Level of 

Respiratory Protection 

Responses 

0 - 2.5 mg/m 3 Level D Stay upwind from the 

source/area of COCs; 

implement dust control 

2.5-5 mg/m 3 Level C Stay upwind from the 

source/area of COCs; 

implement dust control 

>5 mg/ m 3 To be determined by the PM 

based on additional monitoring 

data/evaluation 

Stop work, evacuate the site, 

and consult the PM for further 

evaluation. 

232

10.3 EQUIPMENT NEEDS 


10-5 

December 2006 


A health and safety kit will be kept by each field team. This equipment will be located in the 

area where the team is working or in the field vehicle. Included in this kit, each field team will 

have the following items readily available: 

• Copy of this health and safety plan and a separate list of emergency contacts; 

• First aid kit; 

• Eyewash bottle; 

• Paper towels; 

• Duct tape; 

• Water (for drinking and washing); 

• Plastic garbage bags; 

• Fire extinguisher; and 

• Earplugs. 

10.4 EQUIPMENT DISPOSAL 

All reusable PPE (such as hard hats and respirators), if contaminated, will be decontaminated in 

accordance with procedures specified in Section 13 of this health and safety plan. Contaminated 

single-use PPE (such as Tyvek® suits and protective gloves) will be properly disposed of 

according to site requirements. See section 13 for details regarding disposal. 

233


11-1 

December 2006 


11.0 FREQUENCY AND TYPES OF AIR MONITORING 

Air monitoring will be used to identify and quantify airborne levels of hazardous substances. 

Periodic monitoring is required during on-site activities. During work in contaminated areas, 

continuous monitoring will be required. The type of monitoring and equipment to be used is as 

follows: 

11.1 AIR MONITORING 

At this Site, measures will be taken to minimize personnel exposure and to implement protective 

actions. Direct reading instruments may be used to rapidly detect flammable or explosive 

atmospheres and certain gases and organic vapors. Direct reading instruments provide 

information at the time of sampling, thus enabling rapid decision-making. Gases and organic 

vapors will be monitored in the breathing zone and work area to determine the level of protection 

required. Integrated personal monitoring (8-hour TWA) with subsequent laboratory analysis 

may be warranted by site-specific conditions and is required by regulation to make an initial 

determination of potential airborne exposures. 

Metals, PAHs, and PCBs are not generally expected to present an inhalation hazard unless they 

are present in a particulate form or contained in dust generated during field activities. Site 

personnel will implement dust control measures at all times to prevent fugitive dust emissions 

and exposures to dust. Dust control measures may consist of watering the site, wetting 

construuction equipment (eg, buckets) lowering site speed limits, or using dust suppressants to 

keep the soil moist/wet. Previous air monitoring results have shown that metals (i.e. lead) are 

not a major inhalation hazard unless the metal is in the form of a fume, provided dust control 

measures are implemented. However, in areas where significant levels of metals, PAHs, or 

PCBs are suspected, air samples will be collected and analyzed using appropriate NIOSH or 

OSHA analytical methods. 

During site activities, air monitoring will be used to identify and quantify airborne levels of 

hazardous substances. Continuous monitoring is required during on-site activities. The types of 

monitoring and equipment to be used are identified in Table 11−1. 

11.2 TYPES AND FREQUENCY OF AIR MONITORING 

Prior to initiating a field task, the PM, Project Health and Safety Manager, and SHSO will 

determine the type and frequency of air monitoring necessary for the scheduled work. 

During field investigation activities, as shown in Table 11−1, the following instruments will be 

available to conduct air monitoring as appropriate: 

• PID instrument, either a Photovac MicroTIP ® or a MiniRae, or an equivalent instrument 

to monitor for organic vapors (lamp with ionization potential [IP] of 10.6 electronvolt 

[eV], unless the site is impacted with 1,1,1 trichloroethane [TCA] and/or other 

compounds with IP over 10.6 eV. If the site is impacted with 1,1,1 TCA or any other 

compounds with IP over 10.6 eV, a PID equipped with an 11.7 eV lamp will be used). 

• Combustible gas indicator (multi-gas detector instrument) to measure the concentration 

of combustible gases or vapors, and also toxic gasses such as hydrogen sulfide (H2S). 

• Benzene and other COC colorimetric detector tubes, or chemical specific instruments. 

• Personal sampling pumps with appropriate filters and/or sorbent media. 

• Summa canisters 

234

Type of 

Equipment 

Minimum 

Calibration 

Frequency 


Table 11-1 

Air Monitoring Equipment 

Parameter(s) to be 

Measured 

11-2 

December 2006 


Minimum 

Sampling/Monitoring 

Frequency 

Sampling/ 

Monitoring 

Locations 

PID 1/day Organic vapors Continuous Breathing 

Zone and 

Work Area 

Colorimetric 

Detector Tubes 

Combustible 

Gas Meter 

Personal 

Sampling 

Pump 

Prior to use 

flow check 

Benzene and 

COC 

1/day Oxygen, %LEL, 

H2S, and CO 

2/dayprior 

to and 

after use 

COCs – 

Cal/OSHA 

compliance 

monitoring; 

exposure 

monitoring 

If PID concentration is 

1 ppm or above, every 15 

minutes 

Breathing 

Zone and 

Work Area 

Continuous Excavation 

Face and 

Work Area 

When PID exceeds 5 

ppm and/or presence of 

benzene is detected on 

the Draeger ® tube. 

Collect at least 3 days of 

personal sampling data 

for each activity/similar 

task In areas where 

metals, PCBs, and other 

COC particulates have 

been previously found. 

Breathing 

Zone 

In boreholes, excavation and trenches with high organic vapor concentrations (> 100 ppm total 

VOCs above background), the excavation will be halted and re-evaluated for differing site 

conditions (see Table 10-1 for VOC action levels and response). This will help allow activities to 

be conducted safely in Level D. Site personnel will remain upwind of the boreholes and 

excavations at all times, unless air monitoring results determine that downwind activities are 

safe. 

235


11-3 

December 2006 


Table 11−2 highlights the measures used to minimize the potential for fires or explosions from 

combustible gases. 

Table 11-2 

Measures to Minimize Potential Fire or 

Explosions from Combustible Gases 

Combustible Gas Indicator Reading 

(% LEL) 

Level of Action 

Below 10% Continue Operation 

Above 10% Stop work, re-evaluate; 

consult FHSR and take 

appropriate corrective action, 

as determined by PM (i.e. 

ventilate boreholes and 

excavations ⎯ displace 

combustible gas with inert 

gas ⎯ dry ice pellets) 

11.3 CALIBRATION AND RECORDKEEPING 

The PID will be calibrated to 100 ppm isobutylene prior to use daily in accordance with the 

manufacturer’s specification. Personal sampling pumps will be calibrated with a primary flow 

meter (i.e. Gillibrator, Bio Flowmeter) prior to and after use. The operation of the PID and all 

personal sampling equipment will be used in accordance with manufacturer’s specifications. 

Equipment calibration will be recorded in the calibration log kept with the instrument and in the 

field notebook. Air monitoring results will be recorded in the field notebook. 

236


12.0 SITE CONTROL MEASURES 

12-1 

December 2006 


The following site control measures will be followed to minimize potential contamination of 

workers, protect the public from potential site hazards, and control access to the sites. Site 

control involves the physical arrangement and control of the operation zones and the methods for 

removing COCs from workers and equipment. The first aspect, site organization, is discussed in 

this section. The second aspect, decontamination, is considered in the next section. Site access 

will be coordinated with the LAUSD security located at the site. 

12.1 SITE ORGANIZATION-OPERATION ZONES 

The following organization-operation zones will be established on the site or around a particular 

site feature, as needed. 

• Exclusion Zone (Contamination Zone), 

• Contamination Reduction Zone, and 

• Support Zone. 

The Field Team Manager and/or SHSO will be responsible for establishing the size and distance 

between zones at the site or around the site feature, based on identified contamination. 

Considerable judgment is required to ensure that safe working distances for each zone are 

balanced against practical work considerations. 

Exhibit 12-1 shows the site control for a typical hazardous waste site. 

12.1.1 Exclusion Zone 

The exclusion zone includes the areas of drilling, excavation, hazardous waste removal, and 

other remedial activities. Within the exclusion zone, prescribed levels of PPE must be worn by 

all personnel. The hotline, or exclusion zone boundary, is initially established based upon the 

presence of actual wastes or apparent spilled material, or through air monitoring, and is placed 

around all physical indicators of hazardous substances. The hotline generally consists of an 

easily identifiable physical boundary (e.g., bright orange or yellow flagging attached to stakes), 

and may be readjusted based upon subsequent observations and measurements. This boundary 

will be physically secured and posted or well-defined by physical and geographic boundaries, 

such as: 

• Red tape/flagging indicates Danger/Hot Zone/Stay Out/Specifically trained and 

authorized persons only. 

• Yellow tape/flagging indicates Caution/Warm Zone/ Proceed with caution. 

Under some circumstances, the exclusion zone may be subdivided into zones based upon 

environmental measurements or expected on site work conditions. 

12.1.2 Contamination Reduction Zone 

If decontamination is required, a contamination reduction zone will be established between the 

exclusion zone and the support zone. This zone provides an area to prevent or reduce the 

transfer of hazardous materials that may have been picked up by personnel or equipment leaving 

the exclusion area. All decontamination activities occur in this area. The organization of the 

237


12-2 

December 2006 


contamination reduction zone, and the control of decontamination operations, are described in 

Section 13. 

12.1.3 Support Zone 

The support zone is the outermost area of the site and is considered a non-contaminated or clean 

area. The support zone contains the command post for field operations, first-aid stations, and 

other investigation and cleanup support. Normal work clothes are appropriate apparel within this 

zone. Potentially contaminated personnel, clothing or equipment are not permitted. 

12.2 SITE SECURITY 

Site security for investigation and remedial activities is necessary to prevent exposure of 

unauthorized, unprotected individuals in the work area. No unauthorized personnel shall be 

allowed within the fenced perimeter of the Site. Site access will be coordinated with the LAUSD 

security at the Site. Site security for specific tasks will be enforced by the SHSO or a designated 

alternate who will ensure that only authorized personnel are allowed in the work area and that 

entry personnel have the required level of PPE, are trained under the requirements of Title 8 

CCR 5192, and are on a current medical monitoring program. 

General site security also is necessary to protect site workers and LAUSD property from 

individuals who approach the site with intent to cause harm or damage. In the event that 

individuals approach the site with intent to cause harm or damage, handheld radios will be used 

to communicate the potential danger between the LAUSD security command post at the site and 

on-site workers. The LAUSD security personnel will contact the local police department, if 

necessary. On-site workers will take refuge in their work vehicle. 

12.3 SITE COMMUNICATION 

Internal site communication is necessary to alert field team members in the exclusion and 

contamination reduction zones to: 

• Emergency conditions; 

• Convey safety information; and 

• Communicate changes or clarification in the work to be performed. 

For internal site communication, the field team members will use prearranged hand signals (and 

responses). Radios may also be used for communication in the event of an emergency to alert 

employees. 

Site alarms include: 

One horn blast = look this way; pay attention 

Three horn blasts, repeated = local evacuation, gather at field office for further instructions 

Five horn blasts, repeated = general site evacuation, gather off-site (north of site on Adella) 

External site communication is necessary to coordinate emergency response teams and to 

maintain contact with essential offsite personnel. A telephone located at the LAUSD security 

guard station will be available for use for external site communication. In the event that the land 

238


12-3 

December 2006 


line telephone is unavailable, cellular telephones will be used. Note that a list of emergency 

contact telephone numbers is provided in Attachment 1. 

12.4 SAFE WORK PRACTICES 

To ensure a strong safety-awareness program during field operations, field personnel will be 

adequately trained for their particular tasks. In addition, standing work orders will be developed 

and communicated to all field personnel, as will the provisions of this health and safety plan and 

the appropriate addenda. 

Sample standing work orders for personnel entering the contamination reduction zone and 

exclusion zone are as follows: 

• No smoking, eating, drinking or chewing of tobacco or gum; 

• No matches or lighters; 

• No personal vehicles; 

• Check in/check out at access control points; 

• Use the buddy system; 

• Wear appropriate PPE; 

• Avoid walking through puddles or stained soil; 

• Upon discovery of unusual or unexpected conditions, immediately evacuate and reassess 

the site conditions and health and safety practices; 

• Conduct safety briefings prior to onsite work; 

• Conduct daily safety meetings; and 

• Take precautions to reduce injuries resulting from heavy equipment and other tools. 

239

N 

Exhibit 12-1 

SITE CONTROL ZONES 

PROPOSED SOUTH REGION 

HIGH SCHOOL #9 

AND MIDDLE SCHOOL #4 

SOUTH GATE, CA 

PARSONS 

LAUSD 

240


13-1 

December 2006 


13.0 DECONTAMINATION PROCEDURES 

An exclusion zone, contamination reduction zone, and support zone will be established, as 

needed, when field personnel are using PPE. Decontamination station layout will be made on a 

site-specific basis and will be based on the level of PPE used, the types of chemical hazards 

encountered, and the site conditions, including topography, wind direction, and traffic patterns. 

Defined site access and egress points will be established and personnel will enter and exit only 

through these points. Generally, persons assisting in the decontamination station may be in one 

level lower of respiratory protection than required in the work zone. 

If personnel are in Level D-modified protection (no respirator but using protective gloves and/or 

suits and other equipment), a portable decontamination station will be set up at the site. The 

decontamination station will include provisions for collecting disposable PPE (e.g., garbage 

bags); washing boots, gloves, vinyl rain suits, field instruments and tools; and washing hands, 

face, and other exposed body parts. Used PPE and disposable equipment will be double-bagged 

and placed in a municipal refuse dumpster on site. These wastes are not considered hazardous 

and may be sent to a municipal landfill. Any PPE and disposable equipment that is to be 

disposed of that is still reusable will be rendered inoperable before disposal in the refuse 

dumpster. 

Decontamination equipment may include: 

• Plastic buckets and pails; 

• Scrub brushes and long-handle brushes; 

• Detergent; 

• Containers of water; 

• Paper towels; 

• Plastic garbage bags; 

• Plastic or steel 55-gallon barrels; and 

• Distilled water. 

If personnel are in Level C protection (respirator and using protective gloves and/or suits and 

other equipment), a portable decontamination station will be set up at the site as described above 

for Level D-modified protection. In addition, personnel should inspect, clean and disinfect, 

repair, and properly store all respirators. 

Respirators should be inspected before and after each use. Respirators reserved for emergency 

use should be inspected on a monthly basis to ensure that they will perform satisfactorily. 

Thoroughly check all connections on respirators to ensure that gaskets and “O” rings are in 

place. Check for proper tightness. Check the condition of the facepiece assembly, the 

connecting air tube and headbands. Inspect rubber or elastomer parts for pliability and signs of 

deterioration. Maintain a record for each respirator inspection. Each inspection record should 

include inspection date, inspector’s name, and any unusual conditions or findings. 

Only a trained person with proper tools and replacement parts should work on respirators. No 

one should ever attempt to replace components or to make adjustments or repairs beyond the 

manufacturer’s recommendations. 

Follow manufacturers’ storage instructions that are always furnished with new respirators or 

affixed to the lid of the carrying case. In addition, these general instructions may be helpful: 

241


13-2 

December 2006 


• After respirators have been inspected, cleaned and repaired, store them to protect against 

dust, excessive moisture, damaging chemicals, extreme temperatures and direct sunlight. 

• Do not store respirators in clothes lockers, bench drawers or toolboxes. Either place them 

in wall compartments at workstations, in a work area designated for emergency equipment, 

or store them in the original cartons or carrying cases. 

• Draw clean respirators from storage for each use. Each unit can be sealed in a plastic bag, 

placed in a separate box, and tagged for immediate use. 

242


14.0 SPILL RESPONSE PLAN 

14-1 

December 2006 


Accidental spills, leaks, and releases may result when chemicals or potentially hazardous 

materials are brought onto or used on-site. If a spill or release occurs, the SHSO will take charge 

and initiate emergency procedures to protect the project personnel, the public, and the 

environment. The SHSO will contact the PM who will then contact the necessary LAUSD 

project personnel and other necessary personnel. If necessary, the PM will contact an emergency 

response contractor and the appropriate regulatory agencies. 

Prior to responding to a spill, site personnel and emergency response personnel will review the 

Material Data Safety Sheet (MSDS) with the SHSO and the Field Team Manager and identify 

the hazards so that proper precautionary measures can be taken, such as use of personal 

protective equipment. The emergency response personnel will eliminate the source and contain 

the spill by using absorbent material, patching/plugging and/or diking. Used absorbent materials 

will be properly disposed of as potentially contaminated/hazardous material. If evacuation is 

necessary to protect the public, appropriate project personnel, including local agencies, will be 

contacted. 

14.1 SPILL CONTAINMENT EQUIPMENT 

The following spill response equipment will be available: 

• Visqueen plastic sheeting 

• Absorbent materials in pillows, socks, sheets, or rolls 

• Patch and plug products 

• Protective Equipment and Clothing 

• Barrier tapes 

• 55-gallon Department of Transportation (DOT)-approved drums 

• Shovels, brooms, and dust pans 

14.2 SPILL CONTAINMENT PROCEDURES 

Upon discovery of a spill or leak, the affected area will be barricaded from unauthorized access 

to ensure safety of all personnel and the appropriate emergency response project personnel will 

be contacted immediately. The spill will be assessed with the SHSO and the Field Team 

Manager, MSDS and potential hazards reviewed and assessed, and the proper personal 

equipment and resources will be allocated to the spill response. If necessary, based on the 

severity of the spill, on-site personnel and nearby members of the public will be notified and 

evacuated during clean-up. The spill will be contained by using absorbent materials and diking 

procedures. Diking of spills in conjunction with the use of absorbent material can make the 

clean up more efficient. Absorbent material can be placed in a dike configuration to provide 

temporary containment. If a leak is involved, a patch or plug will be placed on the container to 

stop further release of chemicals into the environment. The affected soil will be excavated, 

segregated, and characterized through sampling/analysis for proper disposition. The spill/release 

incident will be documented on the Spill Reporting Form by the SHSO. 

243

14.3 SPILL REPORTING PROCEDURES 


14-2 

December 2006 


After the following three steps are taken, SHSO will report the release and/or discharge to the 

LAUSD. 

• Ensured the safety of site personnel and the public; 

• Contained and cleaned up the spill; and 

• Completed the release Spill Reporting Form. 

Based on these considerations, the LAUSD will be able to determine if the release is reportable. 

The SHSO will complete the Spill Reporting Form and submit it the PM. 

244

ATTACHMENT 1 

EMERGENCY CONTACTS, INCIDENT REPORT 

GUIDELINES, AND MAP TO HOSPITAL 

245

EMERGENCY CONTACTS 

In the event of any situation or unplanned occurrence requiring assistance, the appropriate 

contact(s) should be made from this list. For emergency situations, telephone or radio contact 

should be made with the site point of contact or site emergency personnel who will then contact 

the appropriate response teams. 

Contingency Contacts Telephone Number 

Nearest phone located at the work site Security Trailor on Parcel 5 

Eli Kassouf 323-564-2391 

Los Angeles County Fire Department 911 

Station 147, non-emergency 310-603-5255 

Lynwood Station 

Site Security/Police 323-563-5400 

Site Emergency Telephone Number 

Medical Emergency 

911 

Hospital Name St. Francis Medical Center 

Hospital Address 


3630 East Imperial Highway, 

Hospital Telephone Number 310-900-4525 

Ambulance Service 911 

Airlift Helicopter 911 

Directions 

Parsons Contacts 

From the worksite, 

Go west (right) on Chakemco Street 

Turn Left onto Atlantic Boulevard 

Turn Right on Imperial Highway 

Jim Goepel, Project Manager 626-440-6013 

Josh Sacker, Site Manager/ 626-440-6191 

Site Health and Safety Officer 

Parsons 24-Hour Emergency Service 866-727-1411 (toll free) 

LAUSD Contact 

Prudence Boczarski-Daniel 213-792-7606 

246

DIRECTIONS 

Start out going west on Chakemco St. toward Wright Rd. 

Turn right ontoAtlanticAve. 

Turn left onto Tweedy Blvd. 

Turn left onto Otis St. 

Turn right onto E. Imperial Highway 

St.Francis Medical Center 

3630 E. Imperial Highway 


(310) 537-7247 

FigureA-1 

HOSPITALROUTEMAP 

LAUSD 

Former South Gate Schools Site 

South Gate,California 

PARSONS 

Pasadena, California 

247

PARSONS – LAUSD 

Procedures following a Parsons/Subcontractor Incident 

Incident Definition: any unexpected or unplanned event that results 

in a personal injury requiring medical treatment beyond first aid, or 

property damage over $1,000. 

Near Miss Definition: near misses are incidents where no property was 

damaged and no personal injury sustained, but where damage and/or 

injury easily could have occurred. 

At the Scene: 

• Provide necessary medical attention to injured worker 

• Properly secure the scene for an effective investigation 

Within two (2) hours of an incident, notify the following: 

• Program Manager, GBU Safety Manager and Program Safety 

Manager 

If the incident results in a lost work day case or worse, the GBU 

President and GBU Safety Manager must be notified. 5/05 

Wallet Card 

(Print front and back on card stock and give to Parsons Personnel) 

PARSONS – LAUSD 

For all First Aid cases or Near Miss incidents, notify the Program 

Safety Manager and Program Manager by the Close of Business 

Submit an Accident Report Form https://pwebtools.parsons.com/safety 

• Document everything in the field log book. 

Contact Information: Office / Cell 

• GBU President – Michael Walsh (704) 558-4399 

• GBU Division Manager – Dean Harwood (704) 558-4056 

• GBU Safety Manager – Anthony Miller (704) 558-4079 

• Program Manager – Jim Goepel (626) 440-6013 

• Project Safety Mgr – Josh Sacker (626) 440-6191 

• Human Resources – Deborah Fiori : (704) 558-4008 

PARSONS Emergency Contact Numbers: (24-hour) 

• First Aid/Near Miss – Greg Beck: (732)537-3695; (908)887-1973 

• US/Canada: (866) 727-1411; International: (775) 326-4594 8/05 

248

ATTACHMENT 2 

SITE SPECIFIC HASP ORIENTATION 

249

Site-Specific Health and Safety Plan Orientation 

Project Name: LAUSD Proposed South Region High School #9 and Middle School #4 

Project Location: South Gate, CA 

Names of personnel responsible for site safety and health 

• Jim Goepel – Project Manager; Josh Sacker – Site Manager/Site Health and Safety Officer. See PSP 

Section 4.10 for contact numbers. 

• Emergencies - Call 911 and/or your Supervisor for emergencies. In the event of an evacuation, the 

primary assembly point is the Site security trailer. The secondary assembly point is directly north of 

the Site on Adella Ave. 

• Incidents – report all incidents (any unplanned or unexpected event that results in personal injury, 

property damage or environmental release) and “near-miss incidents” to your Supervisor and the Site 

HSO. Near-miss incidents COULD HAVE been an incident, but didn’t because of a slight change in 

conditions or luck. However, they have the same causal factors as an incident, so it is just important to 

investigate them for identifying solutions to prevent recurrence and share lessons learned. 

• Communications – the response for anyone from the general public (e.g. media, workers from adjacent 

properties, etc.) inquiring about the project is: “I’m sorry, but I’m not the right person to answer your 

question. If you contact the Los Angeles Unified School District Office of Environmental Health and 

Safety they will be able to help you”. 

Safety, health, and other hazards at the site 

• Chemical exposures, environmental (cold/heat stress, animals, insects, poisionous plants/vegetation), 

hazardous materials handling, heavy equipment operation, noise, and traffic. 

• Chemicals known to be present at levels that may exceed the Permissible Exposure Limit (PEL), and 

primary means of potential exposure. 

Proper use of personal protective equipment 

• Minimum PPE - hard hat, safety glasses with side shields, and steel toe work boots. Tinted safety 

glasses are not permitted during overcast weather, after sundown or inside buildings. 

• Hearing protection – during drilling. 

• High visibility vest/coat (with reflective stripes if working after dusk) is required when regularly 

exposed to vehicular traffic. Any high visibility vest/coat other than a traditional traffic vest must be 

pre-approved by the Safety Manager. 

Work practices by which the employee can minimize risk from hazards 

• Site Access Control – Check in at Site security trailer upon arrival at the site. 

• Training – Site-specific training (HASP review and sign off). Copies of the HASP and MSDS’s are 

available to all personnel. Daily safety meetings shall be documented and reviewed by all personnel 

working at the site, regardless of what time they arrive on site. 

• Contamination - Eating, smoking and applying cosmetics is not permitted in the work zone. Drinking 

water may be permitted in the work zone depending on site-specific conditions and the possibility of 

heat exhaustion. 

• Proper hygiene – wash hands and face before eating, drinking and smoking. 

• Monitoring – Section 11 of HASP 

250

• “Buddy System” –Use two-way radio for communicating and reporting emergencies. 

• Work permits – obtain any necessary work permits prior to beginning field work. 

Safe use of engineering controls and equipment on the site 

• Mobile equipment – use horns to alert others. Mirrors and back-up/travel alarm must be functional. 

Use a spotter when backing vehicles with blind spots and/or around equipment (i.e. pipe lines, etc). 

• Become familiar with subcontractors equipment. 

Acute effects of compounds at the site 

• Table 6-1 

Decontamination procedures 

• Work zones – equipment, PPE (e.g. coveralls, gloves, footwear) must be decontaminated or disposed 

before leaving the exclusion zone. Tyvek coveralls and gloves cannot be worn outside the exclusion 

zone, even if they are clean. Use boot wash stations when appropriate. Exclusion zones exist around 

the perimeter of intrusive activities. Support zones are at the perimeter of the exclusion zone. 

(01/05/07) 

251

ATTACHMENT 3 

ACTIVITY HAZARD ANALYSIS TABLES 

252


LAUSD Proposed South Region High 

School #9 and Middle School #4 

Location: 

South Gate, California 

Required Personal Protective 

Equipment: 

Work Operation: 

Operation of Motor Vehicle 

AHA No. 

0001 

Contractor: 

Parsons 

Parsons 



Wear seat belt at all times; make sure that clothing 

will not interfere with driving. 


Page 1 of 2 

Date: 

April 27, 2005 

Analysis by: 

R. Absolom 

AHA No. 0001 

New: 

Yes 

Revised: 


Date: 

April 27, 2005 

Approved by: Greg Beck Date: 

6/07/05 

Work Activity Potential Hazards Preventive or Corrective Measures Inspection Requirements 

Driving to and from the job 

site 

Vehicle Accident � All employees shall complete the ParsonsU safety 

module on Defensive Driving. 

� Plan your travel route and check maps for directions 

or discuss with colleagues. 

� Complete a Vehicle Inspection Report before 

driving and check for proper equipment/supplies. 

� Clean windows and mirrors as needed throughout 

the trip. 

� Have sun glasses available to reduce sun glare and 

wear as needed. 

� Follow vehicle maintenance schedule to reduce 

possibilities of breakdown while driving. 

Distraction while driving � Stop driving a vehicle, regardless of the speed (i.e. 

even 5 mph) or location (i.e. private road), when the 

potential of being distracted by conversation exists. 

� Drivers are prohibited from using communication 

devices (e.g., cell phones) while operating any motor 

vehicle. 

� Inspect all fluid level, air 

pressure in tires, adjust 

mirrors and seat positions 

appropriately, watch fuel 

level and fill up when level is 

low. 

253

Parsons 



Fatigue/Falling asleep � Get adequate rest prior to driving. 

� Pull over and rest/take a break, if experiencing 

signs/symptoms of fatigue or drowsiness. 

� Share driving duties with another person. 

Weather /Road conditions � Check road and weather conditions prior to driving. 

� Be prepared to adjust driving habits/speed, if road 

conditions change for the worse (i.e. rain, snow, 

fog, etc). 

� Travel during daylight hours, if possible. 

� Give yourself plenty of time to allow for delays due 

to construction, accidents or other unforeseen 

circumstances. 

� Use lights at night and lights/wipers during 

inclement weather. 

Page 2 of 2 

AHA No. 0001 


All drivers are required to have a current valid driver’s license and all vehicles must have the required State vehicle registration 

and/or inspection documents. It is company policy that all wireless device use, whether “hand-held” or “hands free”, is 

prohibited while driving any vehicle at any time as follows: for business use at any time; or for personal use during business 

hours; and as defined by law. 

All employees operating a Company vehicle are required to familiarize themselves with the contents of this AHA before 

starting a work activity. 

254


LAUSD Proposed South Region High School #9 

and Middle School #4 

Location: 


Required Personal Protective Equipment:: Hard 

hat, safety glasses with side shields, work boots, 

long pants and shirt. As stated below in the 

Preventative or Corrective Measures 

AHA No. 

0002 

Parsons 


Field Activities 

Page 1of 3 

AHA No. 0002 

Date: New: 

Contractor: Revised by: Janelle Bohn Date: 01/05/07 


Analysis by: Greg Beck Date: 9/30/05 


Work Operation: Field Activities, Surveying, 

Asphalt Cap Maintenance Work 

Approved by: Greg Beck Date: 9/30/05 


Mobilization/Preparation/Set-up Change in weather conditions Check weather forecast. Observe sky for signs of adversity. 

Rain Have proper PPE (i.e. rain gear, footwear, etc) Check PPE for abnormal wear and 

available. Be aware of slip hazards, puddles, 

etc. 

tear, rips, etc. 

Sunshine Have sunscreen (SPF > 15) available for Look for signs and symptoms of 

ultraviolet protection. Have sufficient drinking 

water for dehydration during warm weather. 

dehydration or heat exhaustion. 

Cold Weather Have warm clothes available for cold 

Look for signs and symptoms of 

temperatures. 

hypothermia or frostbite. 

Lightning Do not begin or continue work until lightning 

subsides for 20 minutes. 

High winds, dust storm Wear goggles if dust/debris is visible. 

Accessing the work location Fire Do not park vehicles in fields where vegetation Look under vehicle for sufficient height 

could catch on fire from the exhaust system. clearance from vegetation. 

Slips/trips/falls Visually determine the approximate location of Look for the safest route – avoid 

the desired point of destination and the slopes, low hanging branches, 

corresponding path of egress. 

gulleys, ditches, etc. 

255

Parsons 



Page 2of 3 

AHA No. 0002 


Accessing the work location (cont’d) Pollen Take medication (i.e. anti-histamine) to 

minimize allergic reaction to pollen. Wear dust 

Hidden objects (i.e. Barbwire 

fencing, irrigation ditch, 

abandoned utilities – conduit, 

pipes, etc) 

mask, if necessary. 

Use a walking stick or other object to survey 

the walking area in front of you. 

Look for objects that could be 

covered by vegetation, tall grass, etc. 

Streams Observe depth of stream and speed of current 

before proceeding through the stream. 

Walking on uneven or wet Wear steel toe rubber boots versus over-the- Survey access route for signs of 

terrain (i.e. slopes, leaves, shoe rubber boots when walking long hazards. 

covered objects, holes, distances. Use a walking stick or other object 

puddles, etc) 

for additional support/balance and to check for 

animal burrows/holes in high vegetation. 

Insects, rodents, animals, etc. Wear light colored clothing and/or Tyvek Look for ticks on light colored clothing 

coveralls for additional skin protection, if 

necessary. Apply bug repellant spray or lotion 

to exposed skin. 

after completing assignment. 

Vegetation Create a clear path or route with mechanical 

equipment, whenever possible. Wear 

appropriate PPE for the vegetation (i.e. Tyvek 

or Carhart coveralls, leather gloves, face 

shield, etc) for vegetation that could cause 

cuts/punctures and/or is higher than waist 

level. 

Struck by/against Wear appropriate personal protective Survey work area for overhead 

equipment (PPE) based on the surrounding hazards, flying debris/particulates or 

work environment (i.e. hard hat, safety splashes, vehicle traffic or heavy 

glasses, work boots, traffic safety vest, 

hearing protection, etc). 

equipment operation, loud noises, etc. 

256

Parsons 



Page 3of 3 

AHA No. 0002 


All personnel engaged in hazardous substance removal or other activities that expose or potentially expose them to hazardous 

substances or health hazards shall receive appropriate training as required by 29 CFR 1910.120(e), including, but not limited to, 

initial 40-hour, 8-hour Supervisor and annual 8-hour refresher training. 

Medical qualification, training and fit-testing must be received on an annual basis for individuals that wear a respirator. If an 

individual wears a respirator more than 30 days per year, or they are exposed at or above the Permissible Exposure Limit (PEL) 

of a chemical for more than 30 days in a year, then they must participate in a Medical Surveillance Program as required by 29 

CFR 1910.120(f). 

. 

. 

257


LAUSD South Region High School #9 and Middle 

School #4 

Location: 


Required Personal Protective Equipment 

Hard hat, steel toed work boots, safety glasses, 

hearing protection (as required), Level D clothing 

Parsons 


Ground Water Monitoring Well Installation and Sampling 

AHA No. 

0003 

Page 1of 5 

AHA No. 0003 

Date: New: 



Analysis by: Andrew D. Soos Date: 03/21/02 

Reviewed by: Susan Shelton Date: 03/21/02 

Work Task/Activity: Ground water monitoring 

well installation and sampling 

Approved by: Andrew D. Soos Date: 


General Chemical Potential chemical exposure can be found Wear proper PPE – latex inner glove and/or Check PPE for abnormal wear and tear, rips, etc. 

Exposure throughout the site. 

nitrile outer glove, Tyvek, and resporator (as 

needed and as shown in HASP) 

Monitor to determine exposure and Action 

Levels (If any, see HASP) 

Dust control measures such as wetting down of 

soil. 

Follow proper decontamination procedures 

when leaving the “exclusion zone” (see HASP) 

Practice good personal hygiene; wash up 

before eating, eat or drink in designated clean 

areas. 

Training (see HASP) 

Visual inpection of 

sampling/well site 

Uneven site surface (slips, trips, and falls) Worker attention to walking/working surface. 

Wearing appropriate safety footwear properly Check footwear for abnormal wear and tear, rips, 

(such as boots with ankle support, laces tied, 

proper soles, etc.) 

etc. 

258

Parsons 



Job Step Potential Hazards Preventive or Corrective Measures 

AHA No. 0003 

Inspection Requirements 

Visual inpection of Uneven site surface (slips, trips, and falls) Training (see HASP) 


(cont.) 

(cont.) 

Mobilization of drill Uneven site surface (rollover) Visual inspection of access route to sampling 

rig or excavator 

areas for soft spots, holes, rocks, etc. 

Operator training 

Rollover protection (cab or equivalent) 

Overhead power lines and structures Visual inpection of access route 


Breaking of soil Noise of operating equipment Wear necessary hearing protection (ear plugs, 

with drill rig or 

other powered 

equipment and 

digging to required 

depth for 

monitoring well 

ear muffs, etc.) while equipment is operating 

Overhead hazard Wear hard hat 

Open holes from excavation Use barricades around excavation (as 

required). 

Underground utilities Call 1-800 “Dig” hotline to have utility 

companies check site 

Pinch hazards of equipment Review Standard Operating Procedures (SOP) 

for equipment 

No loose clothing or jewelry while operating 

equipment 

Flying objects Wear appropriate PPE (such as safety glasses 

and hard hats. Goggles if a splash hazard. 

Face shield for a more severe exposure) 

Check PPE for abnormal wear and tear, rips, etc. 

Drilling 

Lifting augurs or other drilling equipment Follow proper lifting procedures to protect the 

(equipment 

back; try not to lift alone; use a winch or pulley if 

use/maintenance 

issues) 

possible 

Page 2of 5 

259

Parsons 




AHA No. 0003 


Drilling 

Lifting augurs or other drilling equipment Training 

(equipment 

use/maintenance 

issues) (cont.) 

(cont.) 

Equipment SOP 

Equipment becomes electrified (breaks Operator should not touch anything metallic and 

electric line whether under or above the stay motionless; when safe operator should 

ground) 

jump clear of vehicle without touching metal 

Do not approach vehicle 

Raising mast Inspect for overhead obstacles (20 foot 

minimum distance) 

Do not drive with mast up 

Traveling Leave engine off and with key removed when 

not in use 

All loose tools and objects secured 

Training 

Equipment SOP 

Excavated Contaminating other areas Store materials on an impermeable surface and 

soil/water storage 

tarpaulin; containerize liquids 

Open hole Use barricades around excavation (as 

required). Backfill, if possible 

Cave in, worker engulfment Store excavated materials > 3 feet from 

excavation edge 

Procuring sample Dropping pump Wear safety shoes Check shoes for abnormal wear and tear, rips, 

from well by 

bailing or pump 

etc. 

Spilling sample Wear protective gloves; clean up immediately Check gloves for abnormal wear and tear, rips, 

etc. 

Tripping over wire/hose Secure wires and hose; maintain clear path for 

access; safety shoes 

Lifting pump or sample Follow proper lifting procedures to protect the 


possible 

Page 3of 5 

260

Parsons 




Collection of liquid 

sample from 

surface body of 

water 

Field testing 

sample/excavation 

Packing sample 

for off-site 

shipment to lab 

Backfilling well 

site 

De-mobilization of 

drill rig 

Falling in When working over or near water, use life 

preserver, life buoy with rope, and boat 

Lifting sample Follow proper lifting procedures to protect the 


Slippery terrain; mud or uneven surfaces 

(slips, trips or falls) 

possible 

Worker attention to walking/working surface 

Wearing appropriate safety footwear properly 




Exposure to analytical chemicals Follow SOP with field kit or field instrument for 

handling analytical chemicals or instrument 

Accidental breakage of glass bottles Wear cut-resistant gloves during packaging of 

glass bottles 

Training 

Chemical exposure Wear necessary PPE (see potential chemical 

exposure section above and/or field kit SOP) 

Immediate clean-up of spills 

Worker engulfment (when hole is large Check excavation prior to backfilling 

enough to enter) 

Uneven site surface (rollover) Visual inspection of access route to sampling 




Overhead power lines and structures Visual inspection of access route 


Equipment contamination Decontamination (see HASP) 

Page 4of 5 

AHA No. 0003 

Check footwear for abnormal wear and tear, rips, 

etc. 

Check gloves for abnormal wear and tear, rips, 

etc. 

Check PPE for abnormal wear and tear, rips, etc. 

261

Parsons 



Page 5of 5 

AHA No. 0003 

Notes: 1. Uneven surfaces include the following: curbs, rocks, holes in ground, vegetation roots, rubble, debris, trash, ditches, berms, vegetation, broken pavement, loose 

objects, puddles, slippery areas, boxes, plastic bags etc. 

2. PPE – Personal Protective Equipment 

3. SOP – Standard Operating Procedure 

4. HASP – Health and Safety Plan 

5. Confined space entry is not part of this JSA 




All personnel engaged in hazardous substance removal or other activities that expose or potentially expose them to hazardous substances or health hazards shall receive 

appropriate training as required by 29 CFR 1910.120(e), including, but not limited to, initial 40-hour, 8-hour Supervisor and annual 8-hour refresher training. 

Medical qualification, training and fit-testing must be received on an annual basis for individuals that wear a respirator. If an individual wears a respirator more than 30 

days per year, or they are exposed at or above the Permissible Exposure Limit (PEL) of a chemical for more than 30 days in a year, then they must participate in a 

Medical Surveillance Program as required by 29 CFR 1910.120(f). 

262



School #4 

Location: 





Parsons 


Drilling and Soil/SoilGas Sampling 

AHA No. 

0004 

Page 1of 4 

AHA No. 0004 

Date: New: 



Analysis by: Andrew D. Soos Date: 01/15/03 


Work Task/Activity: Drilling assocaited with soil/soil 

gas sampling 

Approved by: Date: 


General Chemical Potential chemical exposure can be found Wear proper PPE – latex inner glove and/or Check PPE for abnormal wear and tear, rips, 

Exposure 

throughout the site. 





Dust control measures such as wetting down 

of soil. 





areas. 

Eyewash bottle or station to treat eye irritation 


etc. 

Visual inpection of 


Uneven site surface (slips, trips, and falls) Worker attention to walking/working surface. 

Wearing appropriate safety footwear properly Check footwear for abnormal wear and tear, 



rips, etc. 

263

Parsons 




AHA No. 0004 


Visual inpection of Uneven site surface (slips, trips, and falls) Training (see HASP) 


(cont.) 

(cont.) 

Mobilization of drill rig Uneven site surface (rollover) Visual inspection of access route to sampling 

or excavator 




Overhead power lines and structures Visual inpection of access route 


Breaking of soil with Noise of operating equipment Wear necessary hearing protection (ear plugs, 

drill rig or other 

powered equipment 

and digging to 

required depth (

Parsons 




AHA No. 0004 


Breaking of soil with Open holes from excavation Use barricades around excavation (as 

hand tool (cont.) 

required). 

Excavated soil Contaminating other areas Store soil on an impermeable surface and 

storage 

tarpaulin 

Open hole Use barricades around excavation (as 

required). Backfill, if possible 

Cave in, worker engulfment Store excavated spoils > 3 feet from 

excavation edge 

Procuring sample 

from excavator bucket 

and placing in sample 

container 

Struck by overhead hazards Wear hard hat 

Pay attention to equipment operator 

(equipment operator must pay attention to you 

too!) 

Do not position your body between equipment 

and a fixed point if possible 

Be in communication with each other (radio, 

hand signals or verbal communication) 

Field testing 

Exposure to analytical chemicals Follow SOP with field kit or field instrument for 

sample/excavation 

handling analytical chemicals or instrument 

Packing sample for Accidental breakage of glass bottles Wear cut-resistant gloves during packaging of 

off-site shipment to 

lab 

glass bottles 

Training 

Chemical exposure Wear necessary PPE (see potential chemical Check PPE for abnormal wear and tear, rips, 

exposure section above and/or field kit SOP) 

Immediate clean-up of spills 

etc. 

Backfilling excavation Worker engulfment (when hole is large 

enough to enter) 

Check excavation prior to backfilling 

De-mobilization of drill Uneven site surface (rollover) Visual inspection of access route to sampling 

rig 



Page 3of 4 

265

Parsons 




De-mobilization of drill 

rig (cont.) 

Uneven site surface (rollover) (cont.) Rollover protection (cab or equivalent) 

Overhead power lines and structures Visual inspection of access route 


De-mobilization of drill 

rig (cont.) 

Equipment contamination Decontamination (see HASP) 

Page 4of 4 

AHA No. 0004 

Notes: 1. Uneven surfaces include the following: curbs, rocks, holes in ground, vegetation roots, rubble, debris, trash, ditches, berms, vegetation, broken pavement, loose 

objects, puddles, slippery areas, boxes, plastic bags etc. 

2. PPE – Personal Protective Equipment 

3. SOP – Standard Operating Procedure 

4. HASP – Health and Safety Plan 

5. Confined space entry is not part of this JSA 









266



School #4 

Location: 





AHA No. 

0005 

Parsons 


Hazardous Waste Management 

Page 1of 13 

AHA No. 0005 

Date: New: 



Analysis by: Kay Chang Date: 09/04 


Work Task/Activity: Hazardous Waste 

Management 

Approved by: Date: 


General Chemical Potential chemical exposure can be found Wear proper PPE – latex inner glove and/or Check PPE for abnormal wear and tear, rips, 

Exposure 

throughout the site. 





Dust control measures such as wetting down 

of soil. 





areas. 

Eyewash bottle or station to treat eye irritation 


etc. 

Disposal of bulk Injuries and accidental spills from improper Provide drum handling training 

liquids in subsurfaces 

(clarifiers, sumps, 

vaults, and a possilbe 

UST) 

container and drum handling. 

267

Parsons 




Disposal of bulk 




UST) (cont.) 

Injuries and accidental spills from improper 

container and drum handling. (cont.) 

Conduct inspection of the integrity of drums 

and container before handling or moving. 

Check label; if unlabeled drums and 

containers, treat as hazardous waste until it is 

properly characterized 

Segregate and keep separate incompatible 

chemicals and substances. 

If drums and containers cannot be moved 

without leakage or rupture, place it them in 

oversized drums. 

Provide anti-static grounding of drums and 

metal containers 

Ensure material handling equipment is fitted 

with explosion containment devices or 

protective shields to protect workers. 

Do not move 

containers. 

pressurized drums or 

Confined Space Hazards 

When moving or opening containers or 

drums, use equipment and procedures to 

isolate the workers. 

Keep container or drum handling to a 

minimum. 

Provide spill containment in the immediate 

drum or container area. 

No manual lifting or handling of 

drums/containers to prevent muscular stress 

or strain or other injuries 

Provide confined space training. 

Page 2of 13 

AHA No. 0005 

268

Parsons 








UST) (cont.) 

Confined Space Hazards (cont.) Do not enter the sump, clarifier, tanks, 

equipment or any openings or vaults not 

intended for human occupancy. 

Provide “buddy” system at all times. 

If it is absolutely necessary to enter an area 

defined as confined space, follow permit 

required confined space procedures. 

� Continuous air monitoring for 

oxygen, combustible gases, 

hydrogen sulfide, and other 

hazardous gases that may be 

present in the space 

� Proper ventilation to obtain 

acceptable airborne concentration 

� Proper communication equipment 

� Proper personal protective 

equipment, 

� Ladder, tripod, and safety body 

harness for safe entry and egress 

� Adequate lighting 

� Warning signs and traffic cones 

� Any other equipment for entry into 

and rescue from confined space. 

Failure of on-site equipment Provide training on proper use of equipment 

Conduct daily inspection of equipment 

Page 3of 13 

Vehicle/equipment condition prior to use 

Proper equipment storage and use 

Presence and check availability of fire 

extinguisher 

AHA No. 0005 

269

Parsons 








UST) (cont.) 

Inhalation and dermal contact with 

hazardous substances 

Provide workers with proper skin, eye, and 

respiratory protection based on the exposure 

hazards present 

Review hazardous properties of site 

contaminants with workers and implement 

control measures before hazardous waste 

removal operations begin 

Slip, trip, and fall hazard 

Stay upwind at all times 

Keep all equipment, vehicles, and tools upwind 

Conduct site safety briefing to reinforce 

general site hazards 

Stay alert and be aware of your surroundings 

at all times 

Maintain firm footing 

Use "buddy" system 

Use proper ladder safety procedures. 

Watch for obstacles, uneven, and wet surfaces 

Maintain good housekeeping 

Heavy equipment hazards Maintain eye contact/communication with 

equipment operator when working in vicinity 

Check and ensure back-up alarms for 

backhoe and loaders are working 

Stay alert and aware of your surroundings at 

all times. 

Struck by protruding objects, liquid splash Wear hard hats, safety glasses with side 

shields and steel-toed safety boot at all times. 

Wear safety goggles when cleaning, 

decontaminating equipment, or working with 

liquids or potential splash or eye hazards 

Page 4of 13 

AHA No. 0005 

270

Parsons 








UST) (cont.) 

Struck by protruding objects, liquid splash 

(cont.) 

Provide eye wash station or sterile eye wash 

bottle for emergency eye wash 

Musculosketetal Disorders (MSD) Observe proper lifting techniques 

Obey sensible lifting limits (60 lb. Maximum 

per person manual lifting) 

Use mechanical lifting equipment (hand carts, 

trucks) or more than one person to move 

large, awkward loads. 

Sharp Objects Maintain all tools in a safe condition 

Keep guards in place during use 

Always cut away from body and hands 

Wear boots with steel toes and shanks 

Have a current tetanus booster as 

recommended by occupational physician 

Be extra cautious in areas containing sharp 

objects 

Presence and check content of first aid kit 

Caught in/between moving parts De-energize and lock-out/tag-out 

equipment/machinery before maintenance, 

service, or clean-up, disassembly and 

removal. 

Identify and understand parts of equipment 

which may cause crushing, pinching, rotating, 

or similar injuries 

Page 5of 13 

AHA No. 0005 

271

Parsons 








UST) (cont.) 

Caught in/between moving parts (cont.) Assure guards are in place to protect from 

these parts of equipment during operation 

Provide and use proper work glove when the 

possibility of pinching, or other injury may be 

caused by moving/handling objects 

Maintain all equipment in safe condition 

Flammable, explosive atmospheres Eliminate sources of ignition from the work 

area 

Prohibit smoking or sources of ignition 

Provide anti-static grounding. 

Provide ABC (or equivalent) fire extinguishers 

on-site in the immediate work area. 

Store flammable liquids in well ventilated 

areas 

Prohibit storage of flammable liquids in plastic 

containers 

Store combustible materials away from 

flammables 

Separate flammables and oxidizers by 20 feet 

minimum 

Heat stress Monitor for heat stress in accordance with 

health and safety procedures 

Provide fluids to prevent work dehydration 

Give frequent breaks 

Page 6of 13 

AHA No. 0005 

272

Parsons 








UST) (cont.) 

Conduct sampling for 

Waste 

characterization and 

surface contamination 

High noise levels (if near a noise source) Use hearing protection when exposed to 

excessive noise levels (greater than 85 dBA 

over an 8-hour work period) 


container and drum handling. 

Provide drum handling training 

Conduct inspection of the integrity of drums 

and container before handling or moving. 

Check label; if unlabeled drums and 

containers, treat as hazardous waste until it is 

properly characterized 

Segregate and keep separate incompatible 

chemicals and substances. 

If drums and containers cannot be moved 

without leakage or rupture, place it them in 

oversized drums. 

Provide anti-static grounding of drums and 

metal containers 

Ensure material handling equipment is fitted 

with explosion containment devices 

protective shields to protect workers. 

or 

Do not move 

containers. 

pressurized drums or 

When moving or opening containers or 

drums, use equipment and procedures to 

isolate the workers. 

Page 7of 13 

AHA No. 0005 

The need to raise your voice at 1 foot or shout 

at 3 feet is a sign hear protection is required 

273

Parsons 





Waste 



(cont.) 


container and drum handling. (cont.) 

Keep container or drum handling to a 

minimum. 

Provide spill containment in the immediate 

drum or container area. 

No manual lifting or handling of 

drums/containers to prevent muscular stress 

or strain or other injuries 

Confined Space Hazards Provide confined space training. 

Do not enter the sump, clarifier, tanks, 

equipment or any openings or vaults not 

intended for human occupancy. 

Provide “buddy” system at all times. 

Page 8of 13 

AHA No. 0005 

274

Parsons 



If it is absolutely necessary to enter an area 

defined as confined space, follow permit 

required confined space procedures. 

� Continuous air monitoring for 

oxygen, combustible gases, 

hydrogen sulfide, and other 

hazardous gases that may be 

present in the space 

� Proper ventilation to obtain 

acceptable airborne concentration 

� Proper communication equipment 

� Proper personal protective 

equipment, 

� Ladder, tripod, and safety body 

harness for safe entry and egress 

� Adequate lighting 

� Warning signs and traffic cones 

� Any other equipment for entry into 

and rescue from confined space. 



Waste 



(cont.) 

Failure of on-site equipment Provide training on proper use of equipment 

Inhalation and dermal contact with 

hazardous substances 

Conduct daily inspection of equipment 




Page 9of 13 

Vehicle/equipment condition prior to use 

Proper equipment storage and use 

Presence and check availability of fire 

extinguisher 

AHA No. 0005 

275

Parsons 



Review hazardous properties of site 

contaminants with workers and implement 

control measures before hazardous waste 

removal operations begin 

Slip, trip, and fall hazard 


Keep all equipment, vehicles, and tools upwind 

Conduct site safety briefing to reinforce 

general site hazards 

Stay alert and be aware of your surroundings 

at all times 

Maintain firm footing 

Use "buddy" system 

Use proper ladder safety procedures. 

Watch for obstacles, uneven, and wet surfaces 

Maintain good housekeeping 

Heavy equipment hazards Maintain eye contact/communication with 

equipment operator when working in vicinity 

Check and ensure back-up alarms for 

backhoe and loaders are working 



Waste 



(cont.) 

Heavy equipment hazards (cont.) Stay alert and aware of your surroundings at 

all times. 

Struck by protruding objects, liquid splash Wear hard hats, safety glasses with side 

shields and steel-toed safety boot at all times. 

Wear safety goggles when cleaning, 

decontaminating equipment, or working with 

liquids or potential splash or eye hazards 

Provide eye wash station or sterile eye wash 

bottle for emergency eye wash 

Page 10of 13 

AHA No. 0005 

276

Parsons 



Musculosketetal Disorders (MSD) Observe proper lifting techniques 

Obey sensible lifting limits (60 lb. Maximum 

per person manual lifting) 

Use mechanical lifting equipment (hand carts, 

trucks) or more than one person to move 

large, awkward loads. 

Sharp Objects Maintain all tools in a safe condition 

Keep guards in place during use 

Always cut away from body and hands 

Wear boots with steel toes and shanks 

Have a current tetanus booster as 

recommended by occupational physician 

Job Step Potential Hazards 

Be extra cautious in areas containing sharp 

objects 

Presence and check content of first aid kit 

Preventive or Corrective Measures Inspection Requirements 


Waste 



(cont.) 

Caught in/between moving parts De-energize and lock-out/tag-out 

equipment/machinery before maintenance, 

service, or clean-up, disassembly and 

removal. 

Identify and understand parts of equipment 

which may cause crushing, pinching, rotating, 

or similar injuries 

Assure guards are in place to protect from 

these parts of equipment during operation 

Provide and use proper work glove when the 

possibility of pinching, or other injury may be 

caused by moving/handling objects 

Page 11of 13 

AHA No. 0005 

277

Parsons 



Maintain all equipment in safe condition 

Flammable, explosive atmospheres Eliminate sources of ignition from the work 

area 

Prohibit smoking or sources of ignition 

Provide anti-static grounding. 

Provide ABC (or equivalent) fire extinguishers 

on-site in the immediate work area. 

Store flammable liquids in well ventilated 

areas 

Prohibit storage of flammable liquids in plastic 

containers 

Store combustible materials away from 

flammables 

Separate flammables and oxidizers by 20 feet 

minimum 

Heat stress Monitor for heat stress in accordance with 

health and safety procedures 

Page 12of 13 

AHA No. 0005 

Job Step Potential Hazards 

Provide fluids to prevent work dehydration 

Preventive or Corrective Measures Inspection Requirements 


Waste 



(cont.) 

Heat stress (cont.) Give frequent breaks 

High noise levels (if near a noise source) Use hearing protection when exposed to The need to raise your voice at 1 foot or shout 

excessive noise levels (greater than 85 dBA at 3 feet is a sign hear protection is required 

over an 8-hour work period) 

278

Exposures to hazardous particulates (i.e. 

silica, metals, and ash) 

Parsons 



Review hazardous properties of these 

particulates with workers and implement 

control measures before equipment and 

surface clean-up activities begin. 




Mist/wet the surfaces to suppress the visible 

dust. Watch for slippery surfaces to prevent 

trip, fall, and slip hazards. 


Keep all equipment, vehicles, and tools 

upwind 

Structurally unstable structure/building Inspection of structure/building by LAUSD 

structural engineer for structural integrity prior 

to entry. 

Receive clearance for entry from LAUSD 

structural engineer before entering potentially 

unstable building. 

Page 13of 13 

AHA No. 0005 









279

APPENDIX H 

Quality Assurance Project Plan 

280

SECTION 1 

INTRODUCTION 

This Quality Assurance Project Plan (QAPP) has been prepared for the site assessment 

activities being conducted at the Proposed South Region Middle School #4 and High 

School #9 for the Los Angeles Unified School District (LAUSD) in South Gate, 

California. The purpose of this QAPP is to present the organization, objectives, 

functional activities, and specific quality assurance (QA) and quality control (QC) 

activities in support of anticipated sampling activities. 

This QAPP incorporates the following references in establishing the project criteria: 

• Los Angeles Regional Water Quality Control Board (LARWQB), General 

Laboratory Testing Requirements for Petroleum Hydrocarbon Impacted Sites; 

• United States Environmental Protection Agency (USEPA), Guidance for the Data 

Quality Objectives Process (USEPA, 1994b); 

• USEPA, Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods, 

SW-846, Third Edition, Update III (USEPA, 1996); 

• American National Standards Institute/American Society of Quality Control 

(ANSI/ASQC E-4-1994), Specifications and Guidelines for Quality Systems for 

Environmental Data Collection and Environmental Technology Programs, July 

1994, (Draft); and 

• USEPA, Risk Assessment Guidance for Superfund, Volume 1: Human Health 

Evaluation Manual [Parts A, B, and C] (USEPA, 1989, 1991a, and 1991b). 

The procedures described herein will be performed in accordance with the guidance, 

regulations, and documents presented in the project statement of work. 

1.1 PROJECT DESCRIPTION 

The Site consists of a number of separate properties that comprise approximately 35 

acres. These properties have been used for a variety of industrial and commercial 

purposes, including metal foundries, a plating shop, machine shops, a pesticide 

formulation facility, and other similar uses. LAUSD is currently evaluating the Site as 

the location of a potential new school. The assessment work to be conducted at the Site 

will be performed under oversight from the Department of Toxic Substances Control 

(DTSC) of CalEPA. 

The initial phase of assessment work consisted of implementing a Site-Wide 

Groundwater Monitoring Plan (Parsons, 2003), which included the installation of 

approximately eight new groundwater monitoring wells, sampling groundwater from the 

1-1 

K:\Depts\Dept48\LAUSD\MSA WORK\QAPP\Draft Final QAPP to DTSC\QAPP for OU 1 RAP.DOC 

281

new wells and from about 70 previously installed wells, and abandonment of 

approximately nine wells. 

Investigative work at the Site was performed as part of a Remedial Investigation (RI) and 

involved the collection and analysis of soil, soil gas, and additional groundwater samples. 

This data was used to evaluate the nature and extent of chemicals of potential concern 

(COPCs), potential risks to human health and the environment, and ascertain the need for 

and scope of remedial action. The scoping for the RI was initiated upon completion of a 

Preliminary Endangerment Assessment (PEA), which was completed in February of 

2005. This QAPP is designed to support remedial investigation and remedial action 

activities. 

This QAPP supercedes the DTSC-approved QAPP (Parsons, 2001). 

The scope of work for the assessment includes collection and analysis of soil, soil gas, 

and groundwater samples. The data will be used to evaluate the nature and extent of 

potential impacts, related risks to human health and the environment, and the need for 

remedial action. The scope of work for remedial action activities is to collect 

confirmation and waste profiling samples. 

1.2 PURPOSE AND SCOPE OF QAPP 

This QAPP sets forth quality guidelines for all activities, products, and services and is 

designed to ensure that all activities are accomplished in an approved, prescribed manner 

by technically trained and competent staff. This document establishes the QA 

requirements and assigns responsibility to project personnel and subcontractors for 

ensuring that project objectives will be achieved. This QAPP consists of the QA 

program requirements that are responsive to all guidance documents referenced in 

Section 1. Quality requirements specified in this document are tailored to the needs of 

this assessment project. 

1.3 PROJECT OBJECTIVE 

The purpose of this assessment work is to characterize the nature and extent of COPCs at 

the site and identify whether the potential for significant adverse human or ecological 

impacts exist. The site characterization will support the evaluation of potential school 

use of the site. The purpose of remedial action work is to confirm that the remedial action 

objectives have been achieved in order to support a “No Further Action Determination” 

by DTSC. 

1.4 PROJECT ORGANIZATION AND RESPONSIBILITIES 

This project will be accomplished with project personnel and various subcontractors. 

Subcontractors will include drillers, surveyors, and analytical laboratory(s). The 

responsibilities of the positions relevant to project QA/QC are summarized below and 

displayed in Figure 1-1. 

1-2 


282

K:\Depts\Dept48\LAUSD\MSA WORK\Groundwater Monitoring Report - August 2004\Figures 

Parsons Health & Safety Officer 

Kristin Guthrie 

Parsons Field Manager 

Josh Sacker, RG 

Project Chemist 

Amanda Whitaker 



Prudence Boczarski-Daniel 

Parsons Project Manager 

Jim Goepel 

Parsons Deputy Project Manager 

Tim Wendler, PE 

Parsons QA Officer 

Amanda Whitaker 

Air Toxics 

Laboratory QA Officer 

Melanie Levesque 

Laboratory Project Manager 

Kyle Vagadori 

Test America 

Laboratory QA Officer 

Dave Dawes 

Laboratory Project Manager 

Sushmitha Reddy 

Figure 1-1 

Project Organization 

Chart 

PARSONS 

Pasadena, CA 

283

• Los Angeles Unified School District Project Manager (PM) – The LAUSD PM is 

directly responsible for overall project activities at the Site, and will serve as the 

primary point of contact to Parsons. 

• Parsons Project Manager – The Parsons PM reports directly to the LAUSD PM and 

exercises control over all project activities including field investigation, remedial 

action, and report writing activities. The Parsons PM is ultimately responsible for 

planning and staffing to meet project requirements, assuring adequate planning and 

execution of the health and safety plan, implementing the QAPP, by overseeing 

analytical data quality, data management and project requirements. The Parsons 

PM is also responsible for budget, schedule, and quality of technical memoranda, 

data packages, and reports. 

• Parsons Site Health and Safety Officer (SHSO) – The SHSO is responsible for 

approval and implementation of the project Health and Safety Plan. 

• Parsons Field Manager (FM) – The FM exercises project oversight of the field 

investigation/remedial action activities and reports to the project manager. The FM 

oversees the day-to-day progress of the investigation/remedial action, including 

manpower, scheduling, and compliance with the QAPP. The FM is also 

responsible to the PM for the conduct of site investigation/remedial action activities 

and the coordination and scheduling of subcontract support. Responsibilities of the 

FM include the following: 

- Supervising the field team, including field geologists, technicians, and 

subcontractors; 

- Correcting nonconformances identified in field methods; 

- Implementing field health and safety protocols, and interacting in field 

procedure training for all newly assigned field personnel; and 

- Ensuring compliance with the QAPP in handling and recording field 

samples. 

• Parsons QA Officer – The QA Officer reports to the Parsons PM and coordinates 

directly with the FM. The Project QA Officer is responsible for ensuring that 

sufficient QA procedures are developed for the project, that adequate quality 

controls are imposed to achieve the required level of QC and that the controls are 

implemented properly. Responsibilities of the QA Officer include the following: 

- Ensuring that project-required QA/QC procedures are clearly specified for 

field and laboratory activities; 

- Working directly with the PM, field personnel, and the laboratory's PM to 

ensure that chemical data collection and analytical procedures are adequate 

for the project-specified level of data quality; 

- Ensuring that system and performance audits are routinely performed by 

the subcontract laboratory; 

- Acting as the PM’s point of contact with the subcontract laboratory; and 

1-4 


284

- Ensuring adequate project preparation, quality review, and submittal of the 

data quality assessment (DQA) report. 

• Project Chemist - The Project Chemist reports to the PM and is responsible for 

implementation of the QAPP. Responsibilities of the Project Chemist include the 

following: 

- Ensuring that project-required QA/QC procedures are clearly specified for 

field and laboratory activities; 

- Working directly with the PM, field personnel, and the Laboratory's PM to 

ensure that chemical data collection and analysis procedures are adequate 

for the project-specified level of data quality; 

- Ensuring that timely audits of the subcontract laboratory are performed; 

- Ensuring adequate project preparation, quality review, and submittal of the 

DQA report. 

• Laboratory QA Officer - The Laboratory QA Officer is responsible for ensuring 

that sufficient QA procedures are applied to laboratory analyses. The Laboratory 

QA Officer is also responsible for ensuring that adequate laboratory controls are 

utilized for a high level of data quality, and that data program requirements and 

data quality objectives (DQOs) are met. Responsibilities of the Laboratory QA 

Officer include the following: 

- Initiating nonconformance reports and/or corrective actions as necessary; 

- Verifying completion of corrective actions for major nonconformances 

cited in audits; 

- Reviewing all statistical data to verify that the analytical laboratories are 

meeting stated QC goals; and 

- Coordinating with the Project Chemist and Laboratory PM. 

• Laboratory Project Manager - The Laboratory PM is responsible for 

implementation of the QAPP (for analytical control) and any laboratory 

subcontract. The Laboratory PM ensures that project-required QA/QC procedures 

for laboratory activities are adhered to for the project-specified level of data 

quality. The Laboratory PM acts as the primary point of contact between the 

subcontract laboratory and Parsons. 

1-5 


285

SECTION 2 

DATA QUALITY OBJECTIVES 

The objectives of collecting and analyzing environmental samples are to determine the 

distribution of chemicals of potential concern (COPCs) at the site. This QAPP has been 

developed for use in conjunction with sampling activities to be undertaken at the site, and 

describes the QA/QC procedures and protocols that will be used during sample analysis. 

The QAPP will serve as a controlling mechanism during the investigation/remedial 

action to ensure that a sufficient quantity of data is collected and that all data collected 

are valid, reliable, and defensible. (Note: the evaluation of historical data for usability 

will be addressed separately.) 

An effective QA program addresses DQOs for both field sampling and laboratory 

methods. The field QA efforts will focus on ensuring that samples are representative of 

the conditions in the various environmental media at the time of sampling. Fixed-based 

subcontract laboratory QA efforts will be aimed primarily at ensuring that analytical 

procedures provide sufficient accuracy and precision to reliably quantify contaminant 

levels in environmental samples. The subcontract laboratory will also ensure that 

analyzed portions are representative of each sample. 

DQOs are developed in general accordance with the seven-step DQO process presented 

in USEPA (1994b) guidance for each field effort and included in the work plan for that 

effort. 

2.1 ANALYTICAL DATA QUALITY LEVELS 

The analytical levels for this project’s DQOs will conform to the two USEPA-defined 

categories of data. These data categories are defined below: 

Screening Data - Screening data are generated by rapid, less precise methods of analysis 

with less rigorous sample preparation. Sample preparation steps may be restricted to 

simple procedures such as dilution with a solvent, instead of elaborate 

extraction/digestion and cleanup. Screening data provide probable analyte identification 

and approximate quantification. 

Definitive Data - Definitive data are generated using rigorous analytical methods, such as 

approved USEPA reference methods. Data are analyte-specific, with confirmation of 

analyte identity and concentration. Methods produce tangible raw data (e.g., 

chromatograms, spectra) in the form of hard-copy printouts or computer-generated 

electronic files. Data may be generated at the site or at an off site location, as long as the 

QA/QC requirements are satisfied. For the data to be definitive, either analytical or total 

measurement error must be determined. Results of fixed-based laboratory analyses of 

samples collected at the site under this QAPP will be considered definitive data. 

2-1 


286

Screening data and definitive data quality levels will be used as indicated below: 

• Screening analyses will be used for screening air in worker breathing zones for 

health and safety purposes. This category may also be used to select sample 

portions for further analysis. For example, soil sample headspace may be screened 

to determine if laboratory analyses are required. 

• Definitive analyses will be used to satisfy the requirements for site 

characterization. Definitive data acquired during the investigation will be used to 

evaluate COPCs. 

2.2 DATA QUALITY ASSESSMENT CRITERIA 

DQA criteria will be used to evaluate the quality of the field sampling efforts, field 

screening results, and fixed-base laboratory results for compliance with project DQOs. 

The DQA criteria are expressed in terms of analytical precision, accuracy, 

representativeness, completeness, and comparability (PARCC). Procedures used to 

assess data accuracy and precision are in accordance with USEPA's (1996) Test Methods 

for Evaluating Solid Waste: Physical/Chemical Methods, SW-846. 

2.2.1 Precision 

Precision is the measure of variability among individual sample measurements under 

prescribed conditions. The relative percent difference (RPD) between primary and field 

duplicate samples, laboratory sample duplicate (SD) pairs, and matrix spike/matrix spike 

duplicate (MS/MSD) sample results demonstrate the precision of the sampling and/or the 

analysis within the batch of samples. When the laboratory control sample (LCS) results 

meet the accuracy criteria (USEPA, 1996), results are also believed to be precise, and 

represent the historical precision among the sample batches of the laboratory, 

independent from the sample matrix. This is based on the LCS being within control 

limits in comparison to LCS results from previous analytical batches of the same methods 

and matrices. Precision will be expressed in terms of RPD between the values resulting 

from primary and duplicate sample analyses. RPD is calculated as follows: 

where: 

RPD = [(x1 - x2)/X][100] 

x1 = analyte concentration in the primary sample, 

x2 = analyte concentration in the duplicate sample, and 

X = average analyte concentration of the primary and the 

duplicate sample = (x1 + x2)/2 

Acceptable levels of precision will vary according to the sample matrix, the specific 

analytical method, and the analytical concentration relative to the method detection limit 

(MDL). For field duplicate samples, the target RPDs are ≤ 70 percent for soil samples 

and ≤ 35 percent for groundwater samples. If the concentration of either duplicate is less 

than five times the practical quantitation limit (PQL), a control limit of ± 2xPQL will be 

compared against the range of the duplicate pair. The laboratory shall have procedures in 

place for establishing and updating precision control limits. Typical control limits for 

2-2 


287

precision range from zero to the historical mean plus three standard deviations. An RPD 

within the control limit indicates satisfactory precision in a measurement system. 

2.2.2 Accuracy 

Accuracy is a measure of the closeness of a reported concentration to the true value. 

Accuracy is expressed as a bias (high or low) and is determined by calculating percent 

recovery (%R) from MS/MSDs, LCSs, and surrogate spikes. MS/MSD and surrogate 

spike recoveries indicate accuracy relevant to a unique sample matrix. LCS recoveries 

indicate accuracy relevant to an analytical batch lot, and are strictly a measure of 

accuracy conditions in preparation and analysis independent of samples and matrices. 

The %R of an analyte, and the resulting degree of accuracy expected for the analysis of 

spiked samples for QC, are dependent upon the sample matrix, method of analysis, and 

the compound or element being measured. The concentration of the analyte relative to 

the detection limit of the method is also a major factor in determining the accuracy of the 

measurement. 

Accuracy expressed as %R is calculated as follows: 

where: 

%R = [(A-B)/C] x 100 

A = measured concentration in spiked sample, 

B = measured sample concentration (without spike), and 

C = concentration of spike added. 

The laboratory shall have procedures in place for establishing and updating accuracy 

control limits. Typical control limits for accuracy are based on the historical mean plus 

or minus three standard deviations. 

2.2.3 Completeness 

Completeness is defined as the percentage of laboratory measurements judged to be valid 

on a method-by-method basis. Valid data are defined as all data and/or qualified data 

considered to meet the DQOs for this project. Data completeness is expressed as percent 

complete (PC) and should be ≥ 90 percent. The goal for meeting analytical holding times 

is 100 percent. At the end of each sampling event, the completeness of the data will be 

assessed. If any data omissions are apparent, new samples will be collected and 

reanalyzed for the parameter in question, if feasible. Laboratory results will be 

monitored as they become available to assess laboratory performance and its effect on 

data completeness requirements. When appropriate, additional samples will be collected 

to ensure that laboratory performance meets PC requirements. 

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PC is calculated as follows: 

Where: 

NA 

PC = X100 

NI 

NA = Actual number of valid analytical results obtained, and 

NI = Theoretical number of results obtainable under ideal conditions. 

2.2.4 Comparability 

Comparability expresses the confidence with which data from one sample, sampling 

round, site, laboratory, or project can be compared to those from another. Comparability 

during sampling is dependent upon sampling program design and time periods. 

Comparability during analysis is dependent upon analytical methods, detection limits, 

laboratories, units of measure, and sample preparation procedures. 

Comparability is determined on a qualitative rather than quantitative basis. For this 

project, comparability of all data collected will be ensured by adherence to standard 

sample collection procedures, standard fixed laboratory analytical methods, standard 

field measurement procedures, and standard reporting methods, including consistent 

units. For example, concentrations will be reported in a manner consistent with general 

industry practice (e.g., soil data will be reported on a dry-weight basis). 

In addition, to support the comparability of fixed-base laboratory analytical results with 

those obtained from previous or future testing, all samples will be analyzed by 

USEPA-approved methods, where available. The USEPA-recommended maximum 

permissible sample holding times (Table 2-1) for organic parameters will not be 

exceeded. Whenever EPA methods are not appropriate or available, recognized methods 

published by American Standard for Testing and Materials (ASTM) or other recognized 

organizations with appropriate expertise will be used. 

All analytical standards will be traceable to standard reference materials. Initial 

instrument calibrations shall be first order linear, and shall be checked at the frequency 

specified for the methods. 

2.2.5 Representativeness 

Representativeness expresses the extent to which collected data define site chemical 

impact. Where appropriate, sample results will be statistically characterized to determine 

the degree to which the data accurately and precisely represent a characteristic of a 

population, parameter variation at a sampling point, a process, or an environmental 

condition. Sample collection, handling, and analytical procedures are designed to obtain 

the most representative sample possible. Representative samples will be achieved by the 

following: 

• Collection of samples from locations that are most likely to be representative of site 

conditions (based on site scoping, previous results, statistically random sample, 

etc.); 

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• Use of appropriate sampling procedures, including proper equipment and 

equipment decontamination; 

• Use of appropriate analytical methods for the required parameters and adequate 

practical quantitation limits (PQLs); and 

• Analysis of samples within the required holding times. 

Sample representativeness is also affected by the portion of each sample chosen for 

analysis. The laboratory will adequately homogenize all samples prior to taking aliquots 

for analysis to ensure that the reported results are representative of the sample received. 

Because many homogenization techniques may cause loss of contaminants through 

volatilization, homogenization will not be performed for any volatile organic compound 

(VOC) method analyses. 

2.2.6 Sensitivity 

The concentration of any one target compound that can be detected and/or quantified is a 

measure of sensitivity for that compound. Sensitivity is instrument-, compound-, 

method-, and matrix-specific. The definitions of terms relating to sensitivity and DQOs 

are presented in Section 6.2. 

2.3 LABORATORY QA OBJECTIVES 

The selected laboratory will provide a copy of the laboratory quality assurance plan 

(QAP). The QAP shall define internal laboratory procedures for QA/QC and shall 

include descriptions of the following: 

• QA policies and objectives; 

• Organization and personnel; 

• Document control; 

• Analytical methodology standard operating procedures (SOPs); 

• Data generation; 

• Sample custody, preservation and tracking; 

• Data recording, reduction, review, reporting, and validation for both hard copy and 

electronic formats; 

• Security; 

• Documentation of client-specific requirements; 

• QA audits; 

• QC; and 

• Non-conformance/corrective action report (NC/CAR) procedures. 

The laboratory QAP must be approved by the Parsons PM prior to the initiation of 

analyses on this project. 

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2.3.1 Laboratory Standard Operating Procedures 

The laboratory must maintain SOPs for all analytical methods and laboratory operations. 

The format for SOPs must conform to the following references: 

• USEPA (1996) Test Methods for Evaluating Solid Waste, Physical and Chemical 

Methods, SW846, 3rd Edition, Update IIB, Section One; 

• USEPA (1995) “Good Automated Laboratory Practices,” in Principles and 

Guidance to Regulations for Ensuring Data Integrity in Automated Laboratory 

Operations; and 

• USEPA (1992) Quality Assurance Technical Information Bulletin, Creating SOP 

Documents. 

All SOPs must have a unique identification number that is traceable to previous revisions 

of the same document. 

2.3.2 Demonstration of Capability, Analyst Training 

The laboratory QA department personnel shall maintain records documenting the ability 

of each analyst to perform applicable method protocols. Documentation will include an 

MDL study with other annual and quarterly checks for each method and analyst. In 

addition, internal, blind performance evaluation (PE) samples for each method and matrix 

demonstrating overall laboratory performance must be submitted semi-annually. 

2.3.3 Laboratory Internal Audits 

At a minimum, the laboratory QA department personnel shall perform an annual internal 

(systems) audit. The internal audit will document compliance with all QAP methods, 

policies, and procedures. Corrective action must be implemented where required. 

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Table 2-1 

Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times 

LAUSD, South Gate, California 

Name Analytical 

Methods 

Matrix Container a/ 

Preservation b/ 

Minimum Sample 

Volume or Weight Maximum Holding Time 

Chloride, Nitrate, SW9056 or Water P, G 4 

Sulfate 

E300.0 

o C 50 ml 28 days for Cl - , and SO4 -2 ; 

48 hours for NO3 - 

Total Organic Carbon SW9060 or Water G, Teflon® - lined cap HCl to pH

Name 

Semi-Volatile Organic 

Compounds 

Table 2-1 

Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times 


Analytical 

Methods 

Matrix Container a/ 

Preservation b/ 

Minimum Sample 

Volume or Weight Maximum Holding Time 

SW8270C Water GA, Teflon®-lined cap 4 o C, 

0.008% Na2S2O3 d/ 

2 liters 7 days until extraction and 40 days after 

extraction 

Soil T, G w/ Teflon® - lined 

cap 

a/ Polyethylene (P); glass (G); glass amber (GA), brass or stainless steel sleeves in the sample barrel (T). 

b/ No pH adjustment for soil. 

c/ All metals collected for a dissolved portion analysis will be filtered in the field prior to preservation. 

d/ Preservation with 0.008 percent Na2 S 2 O 3 is only required when residual chlorine is present. 

4 o C 8 ounces 14 days until extraction and 40 days after 

extraction 

K:\Depts\Dept48\LAUSD\MSA WORK\Soil Investigation\OU 1 RAP\Appendix\Appendix H - QAPP\Tables.doc 5/7/2008 

293

SECTION 3 

FIELD DATA REDUCTION, VALIDATION, AND REPORTING 

The following sections describe calibration of field analytical instruments and field data 

reporting, validation, reduction, and review. 

3.1 FIELD RECORD KEEPING 

Bound field logbooks will be maintained by the field supervisor and other team members 

to provide a daily record of significant events, observations, and measurements during 

the field investigation/remedial action. All entries will be signed and dated. All 

information pertinent to the field survey and/or sampling will be recorded in the 

logbooks. The logbooks will be bound, with sequentially numbered pages. Waterproof 

ink will be used in making all entries. Entries in the logbook will include, at a minimum, 

the items listed below: 

General information: 

• Names and titles of author and assistants; 

• Date and time of entry; 

• Physical/environmental conditions during field activity; and 

• Purpose of sampling activity. 

In order to provide complete documentation of the sampling event, detailed records will 

be maintained by the field scientist. At a minimum, these records will include the 

following information: 

• Sample location (facility name); 

• Sample identification; 

• Sample location map or detailed sketch; 

• Date and time of sampling; 

• Sampling method; 

• Field observations of sample appearance and sample odor; 

• Weather conditions; 

• Sampler's identification; and 

• Any other relevant information. 

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3.2 CALIBRATION PROCEDURES AND FREQUENCY FOR FIELD TEST 

EQUIPMENT 

Instruments and equipment used to gather, generate, or measure environmental data will 

be calibrated according to manufacturer’s specifications with sufficient frequency to 

ensure accuracy and reproducibility of results. 

3.3 REVIEW OF FIELD RECORDS 

Field record review is an ongoing process. Field team leaders will be responsible for 

ensuring that proper documentation is recorded during each site's sampling activities. 

Field records include logbooks, log forms, and any documentation, whether electronic or 

hardcopy, that is used to record data, observations, assumptions, or other information in 

the field. The sections below describe the items used for evaluation. 

3.3.1 Completeness of Field Records 

The check of field record completeness will ensure that all requirements for field 

activities in the work plan have been fulfilled, complete records exist for each field 

activity, and the procedures specified in the work plan (or approved as field change 

requests) are implemented. Field documentation will ensure sample integrity and provide 

sufficient technical information to recreate each field event. The results of the 

completeness check will be documented, and environmental data affected by incomplete 

records will be identified in the technical report. 

3.3.2 Identification of Valid Samples 

The identification of valid samples involves interpretation and evaluation of the field 

records to detect problems affecting the representativeness of environmental samples. 

For example, field records can indicate if unanticipated environmental conditions were 

encountered during field activities. Records should note sample properties such as 

clarity, color, and odor. Photographs may show the presence or absence of obvious 

sources of potential contamination (during sampling). Judgments of sample validity will 

be documented in the technical report, and environmental data associated with poor or 

incorrect field work will be identified. 

3.3.3 Identification of Anomalous Field Test Data 

Anomalous field data will be identified and explained to the extent possible. Anomalous 

data will be assessed for usability and explained in the technical report. 

3.3.4 Accuracy and Precision of Field Data and Measurements 

The assessment of the quality of field measurements will be based on instrument 

calibration records and a review of any field corrective actions. The accuracy and 

precision of field measurements will be discussed. 

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3.4 FIELD DATA VALIDATION 

The Project Chemist will review 100 percent of all screening data prior to reporting. 

Screening data will constitute all analytical method results from analyses performed in a 

field laboratory environment. The Project QA Officer will determine if DQOs for field 

data have been met, and also will calculate the percent complete (PC) for field data 

results. 

At a minimum, the review of screening data will focus on the following topics: 

• Holding times; 

• Method blanks; 

• Field instrumentation calibration and detection limits; and 

• Completeness of data 

Field data will be validated using the procedures described below: 

• Routine checks (e.g., looking for errors in identification codes) will be made during 

the processing of data. 

• Internal consistency of a data set will be evaluated. This step will involve plotting 

the data and testing for outliers. 

• Checks for consistency of the data set over time will be performed. This can be 

accomplished by comparing data sets against gross upper limits obtained from 

historical data sets, or by testing for historical consistency. Anomalous data will be 

identified. 

• Checks may be made for consistency with parallel data sets. An example of such a 

check would be comparing data from the same volume of soil. 

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SECTION 4 

FIELD QC SAMPLES 

As a check on field sampling, QA/QC samples will be collected during each sampling 

event. Definitions for field QA/QC samples are presented below. 

4.1 FIELD DUPLICATES 

A field duplicate is defined as a second sample collected independently at the same 

sampling location during the same sampling event that produced the primary sample. 

While such samples are not true duplicates, the results serve to indicate whether the 

contamination in the matrix is uniform. The laboratory will be unable to distinguish 

which samples are field duplicates. Each of the field duplicates will be uniquely 

identified with a coded identifier, which will be in the same format as other sample 

identifiers. Duplicate sample results are used to assess the precision of the sample 

collection process. Field duplicates will be collected at a minimum frequency of 1 per 20 

samples (per the USEPA, Region 9 guidance). 

4.2 BLANKS 

Equipment blanks consist of ASTM Type II water (or equivalent) poured into or pumped 

through the sampling device following decontamination. This blank is transferred to a 

sample bottle appropriate for the analysis and transported to the laboratory. The 

equipment blank samples shall be analyzed for the same laboratory parameters as the site 

samples (including VOCs, metals, hexavalent chromium, cyanide, 1,2,3- 

trichloropropane [TCP], 1,4-dioxane, and TPH-gasoline [TPH-g]). Equipment blanks are 

used to measure contamination introduced to a sample set from inadequately 

decontaminated sampling equipment. An equipment blank will be collected once per 

sampling episode. 

Trip blanks are used to measure potential contamination of samples by volatile organic 

compounds during transport. The trip blank consists of a vial filled by the laboratory 

with ASTM Type II water, shipped to the field, and returned to the laboratory in a cooler 

that contains samples for volatile organic compounds. A trip blank shall be included in 

every cooler containing samples for analyses for VOCs (Method SW8260B) and 

analyzed for VOCs. A trip blank shall be included in every cooler containing samples for 

analyses for TPHg (Method SW8015) and analyzed for TPH-g (SW8015). 

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SECTION 5 

SAMPLING PROTOCOLS 

Detailed soil and groundwater sampling protocols are provided in the draft Site-Wide 

Groundwater Monitoring Plan (GWMP) (Parsons, 2003). Soil gas sampling protocols are 

provided in the Remedial Investigation Workplan (Parsons, 2005). These sampling 

protocols will also be implemented during Supplemental Site Investigation (SSI) and the 

RAP. 

5.1 SAMPLE CONTAINERS 

The laboratory will provide sample containers, labels, chain-of-custody forms, and 

coolers to the project site. Properly cleaned sample containers must be used so that no 

target compound contamination occurs from contact with the sample container. The 

laboratory will provide documentation attesting to the cleanliness of the containers 

following their cleaning procedures. A certificate of cleanliness will be provided for any 

commercially purchased sample containers. 

It is equally important to use preservative reagents that are free of target analytes or other 

contaminants. The laboratory will provide documentation attesting to the purity and 

quality of the reagents being provided. 

Table 2-1 lists the types of sample containers, sample volumes, methods of preservation, 

and holding times for each parameter. Field team members will ship or courier samples 

directly to the laboratory at the end of each sampling day, which will enable the 

laboratory to analyze the samples within the specified holding times. 

5.2 SAMPLE CONTAINMENT, PRESERVATION, AND LABELS 

Sample containers and preservatives defined in Table 2-1 will ensure compatibility with 

USEPA protocols and will minimize breakage during transportation. Sample labels will 

be affixed to each container to identify the sample number, collector's name, date and 

time of collection, location of sampling point, analyses requested, and preservatives 

added. 

5.3 FIELD SAMPLE IDENTIFICATION 

A sample numbering system will be used to identify each sample collected during field 

investigations, including all field QC samples. The numbering system will be a tracking 

mechanism to allow retrieval of information about a particular location and to ensure that 

each sample is uniquely numbered. A listing of sample numbers will be maintained by 

the field team leader. 

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5.4 SAMPLE CHAIN-OF-CUSTODY 

Sample custody begins in the field at the time of collection and continues throughout the 

laboratory analytical process. Chain-of-custody forms will be prepared at the time of 

sample collection and will accompany the samples to the laboratory and through the 

laboratory sample processing. Chain-of-custody forms will be completed for each cooler 

in a shipment of samples to track the samples and provide a written record of all persons 

handling the samples. The following information for each sample will be documented on 

the Chain-of-custody form: 

• Unique sample identification; 

• Date and time of sample collection; 

• Source of sample (including name, location, and sample type); 

• Designation of MS/MSD; 

• Analyses required; 

• Name(s) of collector(s); 

• Custody transfer signatures, and dates and times of sample transfer from the field to 

transports and to the laboratory; and 

• Bill of lading or transported tracking number (if applicable). 

Shipments will be sent by common carrier for overnight delivery, and a bill of lading will 

be prepared. The shipping bill number will be recorded on the chain-of-custody form. 

Bills of lading will be retained as part of the permanent documentation. 

5.5 LABORATORY CUSTODY PROCEDURES 

Laboratory sample custody procedures must be presented in the laboratory QAP and 

approved by the project manager prior to shipping any samples to the laboratory. To 

facilitate the documentation of sample custody, the laboratory will track the progress of 

sample preparation, analysis, and report preparation. Samples received by the laboratory 

will be checked carefully for label identification, chain-of-custody forms, and any 

discrepancies. The laboratory will also note and record cooler temperatures, physical 

damage, incomplete sample labels, incomplete paperwork, discrepancies between sample 

labels and paperwork, broken or leaking containers, and inappropriate caps or bottles. 

The laboratory will send signed facsimile copies of all chains-of-custody and sample login 

receipt forms to the field manager (FM) within 24 hours of sample receipt in the 

laboratory. All discrepancies and/or potential problems (e.g., lack of sample volume) 

will be discussed immediately with the FM. 

The laboratory sample custodian will provide a report to the FM of any problems 

observed with any of the samples received. This report will also document the condition 

of samples, sample numbers received, corresponding laboratory numbers, and the 

estimated date for completion of analysis. Written permission must be received from the 

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FM before sending any samples originally scheduled to be analyzed at its facility to 

another laboratory. Analyses will not be performed on samples whose integrity has been 

compromised or is suspect, without prior approval from the FM. 

5.6 SAMPLE HANDLING 

Laboratory sample custody will be maintained by the procedures detailed in the 

laboratory QAP. 

• If the chain-of-custody and samples correlate, and there has been no tampering 

with the custody seals, the "received by laboratory" box on the chain-of-custody 

form will be signed and dated. 

• The samples will be logged into the laboratory information management system in 

such a manner that tracking the status of the samples (extraction, analysis dates) 

can be readily accomplished. 

• Water samples will be stored in a secured area at a temperature of approximately 4 

± 2 degrees Celsius (°C) for all analytical fractions except for metals. Soil samples 

may be stored at lower temperature (as applicable) until analyses commence. 

Samples must be stored in coolers separate from those used to store analytical 

standards, reagents, and/or QC samples. 

• Volatile samples will be stored separately from other samples. A storage blank 

must be present in the cooler storing volatile samples and analyzed weekly at a 

minimum. Results of storage blank analyses must be maintained by the QA 

department. Corrective action is required if analyses provide evidence of cross 

contamination. 

• The original chain-of-custody form will accompany the laboratory report submittal 

and will become a permanent part of the project records. 

• Data generated from the analysis of samples also must be kept under proper 

custody by the laboratory. 

Disposal of sample containers and remaining sample material will be the responsibility of 

the laboratory. Samples should be disposed of appropriately when all analyses and 

related QA/QC work are completed (Section 15). 

5.7 LOGGING SOIL BORINGS 

Boring logs will be prepared in conformance with ASTM Method D2488. Boring logs 

will record the following sampling information: boring number and location; sample 

identification numbers; date and time; sample depth; lithologic description in accordance 

with the Unified Soils Classification System (USCS); description of any visible evidence 

of soil impacts (i.e., odor, staining); and organic vapor readings. Soils will be described 

as follows: 

• Soil moisture: Soils will be described as wet, moist, or dry per ASTM Method 

D2488. 

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• Soil color: Soil colors will be described as black, dark gray, gray, dark brown, 

brown, tan, grayish brown, reddish brown, brownish gray, olive brown, or olive 

gray utilizing a Munsell color chart. 

• Mottling presence and degree: Mottling is a variable shading or spotting of color, 

often an indicator of a fluctuating water table. If mottling is apparent, soils will 

be described as faintly or brightly mottled. 

• Soil texture: The major component (clay, silt, sand, or gravel) will be 

determined. Sand sizes and degree of rounding will be estimated by comparison 

to a sand size index card which utilizes a standardized scale. A Unified Soil 

Classification will be assigned. 

• Penetration-resistance: Blow counts (N-value) per one foot of sample will be 

utilized to determine the penetration-resistance. 

• Soil structure: Structure will be characterized as varved or laminated, bedded, 

stratified, blocky, plating, massive, cemented. 

Other qualifiers that may be utilized include desiccation cracks, liquifaction, and coarse 

silt lenses. 

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SECTION 6 

FIXED-BASE LABORATORY ANALYTICAL PROCEDURES 

Application of a specific analytical method depends on the sample matrix and the 

analytes to be identified. Methods for each of the parameters likely to be included in the 

analytical program, as well as detection limits, are discussed in the following subsections. 

All analytical methods are USEPA-approved. Samples will be maintained for an 

extended period before disposal to allow review of data and to maintain the option of 

reanalysis if the results are suspect. Samples will be maintaind under a laboratory 

internal chain of custody system, in order to retain sample integrity documentation. 

6.1 ANALYTICAL METHODS 

Analytical procedures will follow established USEPA method protocols. All approved 

methods are presented in Table 6-1. The referenced methods are defined in the USEPA 

Test Methods for Evaluating Solid Waste, Physical and Chemical Methods, SW846, 3rd 

Edition, Update III (1996). Whenever SW-846 methods are not appropriate, recognized 

methods from source documents published by USEPA, ASTM or other organizations 

with appropriate expertise will be used. 

Table 6-1 

Analytical Methods 

Site Assessment 

LAUSD Proposed Southeast Learning Complex 

Parameter Analytical Method a/ 

Semivolatile Organic Compounds 

SW8270C 

(SVOCs) 

Volatile Organic Compounds(VOCs) SW8260B 

Chlorinated Herbicides 

Organochlorine Pesticides 

SW8151A 

SW8081A 

Polychlorinated Biphenyls (PCBs) SW8082 

Metals (calcium, magnesium, potassium, 

SW6010B 

sodium) (ICP/AES) 

Other Metals (ICP/MS) SW6020 

Mercury SW7470A 

Hexavalent Chromium SW7199A 

Total Organic Carbon SW9060 

Total Organic Compounds in Vapor TO-15 

Methane, Ethane, Ethene 

Moisture Content 

RSK-175SOP 

c/ ASTM D2216 

1,2,3-Trichloropropane (TCP) Modified 8260B SIM 

1,4-Dioxane Modified 8260B SIM 

Total Petroleum Hydrocarbons – 

gasoline (TPHg) 

SW8015 

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A column test procedure for determining sorbed hexavalent chromium is included as 

Appendix A. 

6.2 DETECTION AND QUANTITATION LIMITS 

This section describes the terms, definitions, and formulas that will be used for detection 

and quantitation limits. 

6.2.1 Method Detection Limit 

The method detection limit (MDL) is the lowest concentration at which a specific analyte 

in a matrix can be measured and reported with 99-percent confidence that the analyte 

concentration is greater than zero. MDLs are experimentally determined and verified for 

each target analyte of the methods in the sampling program. Instrument-specific MDLs 

are analyzed in accordance with 40 CFR Part 136. The lab will spike at a level equal to 

the lowest calibration standard. In order to maintain reporting consistency, if multiple 

instruments are used for the same method, the lab will report down to the highest MDL 

between all instruments so that all MDLs for a given analyte are at or below the reported 

MDL. MDLs are verified quarterly with a spike at ½ of the low calibration standard. 

Since MDLs are verified quarterly and in accordance with California Department of 

Health Services Environmental Laboratory Accreditation Program (ELAP) policy on 

Method Detection Limits, annual MDL studies are not performed unless a problem is 

identified during the quarterly verification process. MDLs are based on the results of 

seven matrix spikes at 2 times the estimated PQL, and are statistically calculated in 

accordance with the Title 40, Code of Federal Regulations Part 136 (40 CFR 136), 

Appendix B. The standard deviation of the seven replicates is determined and multiplied 

by 3.14 (i.e., the 99-percent confidence interval from the one-sided student t-test). Where 

practicable, MDLs must be lower than the risk-based criteria determined for the project. 

The MDLs to be used are intended to allow that both nondetected and detected target 

compound results will be usable to the fullest extent possible for the project. An MDL 

check sample, an interference-free MS with all method target compounds, must be 

analyzed following the MDL study to determine if reasonable MDL concentrations have 

been achieved. The MDL check sample should be at a concentration of approximately 

two times the MDL. If any target compound is not recovered, the MDL study must be 

repeated. In this case, the repeated MDL study should be performed with a higher 

concentration, based on the analyst's judgment, of the target compounds which failed in 

the MDL check sample. The MDLs shall be verified quarterly by running a standard at 

½ the concentration of the lowest standard of the initial calibration. If the verification 

analysis shows lack of adherence to the determined MDLs, then the MDL study shall be 

repeated. 

6.2.2 Sample Quantitation Limit 

Sample quantitation limits (SQLs) are defined as the MDL multiplied by the dilution 

factor (DF) required to analyze the sample, and corrected for moisture or sample size. 

These adjustments may be due to matrix effects or to the high concentrations of some 

analytes. For example, if an analyte is present at a concentration that is greater than the 

linear range of the analytical method, the sample must be diluted for accurate 

quantitation. The DF raises the reporting limit, which then becomes the SQL. Because 

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the reported SQLs take into account sample characteristics and analytical adjustments, 

they are the most relevant quantitation limits for evaluating nondetected chemicals. 

6.2.3 Detection Limit Goals 

To define analytical data reporting limits that meet project DQOs, potential risk-based 

screening criteria were identified. Risk-based preliminary remediation goals (PRGs) for 

residential soil, California and Federal MCLs and tap water PRGs were reviewed to 

identify potential action levels that may be applicable to the site and achievable by the 

laboratory. PQLs supplied by the laboratory are compared against Table 6-2 action 

levels. PQLs for vapor analysis (TO-15) are supplied in Table 6-3. Since soil gas 

samples will be analyzed by TO-15, screening criteria are not appropriate and will not be 

included in Table 6-3. 

6.2.4 Practical Quantitation Limit 

The practical quantitation limits are the lowest matrix-specific concentrations that can be 

reliably achieved within specified limits of precision and accuracy during routine 

laboratory operating conditions. All sample results will be reported at or above the MDL 

for each analyte. All results above the MDL, but below the PQL, will be qualified in the 

data deliverable from the laboratory with a “J” flag. The “J” flag will denote the sample 

result as below the PQL. Where practical, MDLs must be lower than the risk-based 

criteria determined for the project. Laboratories must verify the PQLs by analyzing a 

standard at or below the PQL when performing the initial calibration curve. 

Reporting limits are the lowest reported concentration provided on the sample-analysis 

data report, after corrections have been made for sample dilution, sample weight, and (for 

soils and sedimnts) amount of moisture in the sample. Reporting limits can be as low as 

the MDL or exceed the PDL, depending on the matrix effects encountered during the 

analysis. The reporting limit is the value that indicates whether the analytical DQOs 

have been achieved for that sample. 

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Table 6-2 

Practical Quantitation Limits 

Los Angeles Unified School District Proposed South Region Highschool #9 and Middle School #4 

Method/Analyte a/ 

PQL c/ 

Organochlorine Pesticides (SW8081A) (µg/L) h/ 

Water b/ 

MCL (Fed.) d/ MCL (CA) e/ 

PRG f/ 

(µg/L) (µg/L) (µg/L) (µg/kg) i/ 

Soil 

PQL PRG g/ 

a-BHC 0.05 w/ NA NA 0.011 1.7 90 

b-BHC 0.05 w/ NA NA 0.037 1.7 320 

d-BHC 0.05 NA NA NA 1.7 NA 

g-BHC (Lindane) 0.05 0.2 0.2 0.052 1.7 440 

4,4'-DDD 0.1 NA NA 0.28 3.3 2400 

4,4'-DDE 0.1 NA NA 0.2 3.3 1700 

4,4'-DDT 0.1 NA NA 0.2 3.3 1700 

Aldrin 0.05 w/ NA NA 0.004 1.7 29 

Dieldrin 0.1 w/ NA NA 0.0042 3.3 30 

Endosulfan I 0.05 NA NA 220 1.7 3.70E+05 

Endosulfan II 0.1 NA NA 220 3.3 3.70E+05 

Endosulfan Sulfate 0.1 NA NA NA 3.3 NA 

Endrin 0.1 2 2 11 3.3 1.80E+04 

Endrin Aldehyde 0.1 NA NA NA 3.3 NA 

Heptachlor 0.05 k/ 0.4 0.01 0.015 1.7 110 

Heptachlor Epoxide 0.05 k/ 0.2 0.01 0.0074 1.7 53 

Methoxychlor 0.5 40 40 180 17 3.10E+05 

Toxaphene 5 k/ 3 3 0.061 170 440 

Chlordane 1 2 NA 0.19 50 1.60E+03 

Polychlorinated Biphenyls (SW8082) (µg/L) (µg/L) (µg/L) (µg/L) (µg/kg) (µg/kg) 

Arochlor 1016 1 k/ 0.5 0.5 0.96 67 6300 

Arochlor 1221 1 k/ 0.5 0.5 0.034 67 220 

Arochlor 1232 1 k/ 0.5 0.5 0.034 67 220 

Arochlor 1242 1 k/ 0.5 0.5 0.034 67 220 

Arochlor 1248 1 k/ 0.5 0.5 0.034 67 220 

Arochlor 1254 1 k/ 0.5 0.5 0.034 67 220 

Arochlor 1260 2 k/ 0.5 0.5 0.034 130 220 

Table6-2rev4.xls 

(µg/kg) 

Page 1 of 8 

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Table 6-2 




PQL c/ 

Water b/ 


PRG f/ 

Soil 

PQL PRG g/ 

Chlorinated Herbicides (SW8151A) (µg/L) (µg/L) (µg/L) (µg/L) (µg/kg) (µg/kg) 

2,4 D 10 70 70 360 5000 6.90E+05 

2,4 DB 20 NA NA 290 10000 4.90E+05 

2,4,5 T (Silvex) 20 NA NA 360 10000 6.10E+05 

2,4,5 TP 10 50 50 290 5000 4.90E+05 

Dalapon 30 200 200 1100 15000 1.80E+06 

Dicamba 20 NA NA 1100 10000 1.80E+06 

Dichloroprop 20 NA NA NA 10000 NA 

Dinoseb 3 7 7 36 1500 6.10E+04 

MCPA 100 w/ NA NA 36 50000 6.10E+04 

MCPP 100 w/ NA NA 36 50000 6.10E+04 

Volatile Organic Compounds (SW8260B) (µg/L) (µg/L) (µg/L) (µg/L) (µg/kg) (µg/kg) 

1,1,1,2-Tetrachloroethane 1 w/ NA NA 0.43 1 3.00E+03 

1,1,1-Trichloroethane 1 200 200 790 1 7.70E+05 

1,1,2,2-Tetrachloroethane 1 j/ NA 1 0.055 1 380 

1,1,2-Trichloroethane 1 j/ 5 5 0.2 1 840 

1,1-Dichloroethane 1 NA 5 810 1 5.90E+05 

1,1-Dichloroethene 1 j/ 7 6 0.046 1 54 

1,1-Dichloropropene 1 NA NA NA 1 NA 

1,2,3-Trichlorobenzene 1 NA NA NA 1 NA 

1,2,3-Trichloropropane 5 v/ NA 0.005 l/ 0.0016 5 k/ 1.4 

1,2,4-Trichlorobenzene 1 70 70 190 1 6.50E+05 

1,2,4-Trimethylbenzene 1 NA NA 12 1 5700 

1,2-Dibromo-3-chloropropane 5 k/ 0.2 0.2 0.048 5 450 

1,2-Dichlorobenzene 1 NA 600 370 1 3.70E+05 

1,2-Dichloroethane 1 k/ 5 0.5 0.12 1 350 

1,2-Dichloropropane 1 j/ 5 5 0.16 1 350 

1,2-Ethylene Dibromide 1 k/ 0.05 0.05 0.00076 1 6.9 

1,3,5-Trimethylbenzene 1 NA NA 120 1 2.10E+04 

1,3-Dichlorobenzene 1 NA NA 5.5 1 1.30E+04 

1,3-Dichloropropane 1 k/ NA 0.5 0.081 1 82 

1,4-Dichlorobenzene 1 j/ NA 5 0.5 1 3.40E+03 

2,2-Dichloropropane 1 NA NA NA 1 NA 


Page 2 of 8 

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Table 6-2 




PQL c/ 

Water b/ 


PRG f/ 

Soil 

PQL PRG g/ 

2-Butanone (MEK) 10 NA NA 1900 10 7.30E+06 

2-Chlorotoluene 1 NA 140 l/ 120 1 1.60E+05 

2-Hexanone 10 NA NA NA 10 NA 

4-Chlorotoluene 1 NA NA NA 1 NA 

4-Methyl-2-Pentanone (MIBK) 10 NA 120 l/ 160 10 7.90E+05 

Acetone 10 NA NA 610 10 1.60E+06 

Benzene 1 j/ 5 1 0.41 1 670 

Bromobenzene 1 NA NA 20 1 2.80E+04 

Bromochloromethane 1 NA NA NA 1 NA 

Bromodichloromethane 1 NA NA 0.18 1 1.00E+03 

Bromoform 1 NA NA 8.5 1 6.20E+04 

Bromomethane 1 NA NA 8.7 1 3.90E+03 

Carbon Disulfide 10 NA NA 1000 10 3.60E+05 

Carbon tetrachloride 1 k/ 5 0.5 0.17 1 240 

Chlorobenzene 1 100 70 110 1 1.50E+05 

Chloroethane 1 NA NA 4.6 1 3.00E+03 

Chloroform 1 w/ NA NA 0.16 1 240 

Chloromethane 2 w/ NA NA 1.5 2 1.20E+03 

Cis-1,2-Dichloroethene 1 70 6 61 1 4.30E+04 

Cis-1,3-Dichloropropene 1 w/ NA NA 0.081 1 82 

Dibromochloromethane 1 w/ NA NA 0.13 1 1.10E+03 

Dibromomethane 2 5 NA NA 2 NA 

Dichlorodifluoromethane 1 NA 1000 l/ 390 1 9.40E+04 

Di-isopropyl ether (DIPE) 2 NA 2 u/ NA 2 5 u/ 

Ethyl tert-butyl ether (ETBE) 2 NA 2 u/ NA 2 5 u/ 

Ethylbenzene 1 700 700 1300 1 2.30E+05 

Hexachlorobutadiene 1 w/ NA NA 0.86 1 6.20E+03 

Isopropylbenzene (Cumene) 1 NA 770 l/ 660 1 1.60E+05 

m/p-Xylene 1 NA NA 1400 1 1.40E+06 

Methyl tert-butyl ether (MTBE) 1 NA 13/5 m/ 5 1 NA 

Methylene chloride 5 j/ NA 5 4.3 5 8.90E+03 

Naphthalene 1 NA NA 6.2 1 5.60E+04 

n-Butylbenzene 1 NA NA 61 1 1.40E+05 


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Table 6-2 




PQL c/ 

Water b/ 


PRG f/ 

Soil 

PQL PRG g/ 

n-Propylbenzene 1 NA NA 61 1 1.40E+05 

o-Xylene 1 10,000 1750 1400 1 1.40E+06 

p-Isopropyltoluene 1 NA NA NA 1 NA 

Sec-Butylbenzene 1 NA NA 61 1 1.10E+05 

Styrene 1 100 100 1600 1 1.70E+06 

Tert-Butylbenzene 1 NA NA 61 1 1.30E+05 

Tertiary amyl methyl ether (TAME) 2 NA 2 u/ NA 2 5 u/ 

Tertiary butyl alcohol (TBA) 10 NA 10 u/ NA 10 20 u/ 

Tetrachloroethene 1 5 5 1.1 1 5.70E+03 

Toluene 1 1000 150 720 1 5.20E+05 

Trans-1,2-Dichloroethene 1 100 10 120 1 6.30E+04 

Trans-1,3-Dichloropropene 1 w/ NA NA 0.081 1 82 

Trichloroethene 1 5 5 1.6 1 2.80E+03 

Trichlorofluoromethane 1 NA 150 1300 1 3.90E+05 

Vinyl Acetate 10 NA NA 410 10 4.30E+05 

Vinyl chloride 0.5 k/ 2 0.5 0.02 1 22 

1,2,4-Trichlorobenzene 10 NA NA 190 10 6.50E+05 

Modified 8260B SIM (µg/L) (µg/L) (µg/L) (µg/L) (µg/kg) (µg/kg) 

1,4-Dioxane 2 NA 3 l/ 6.1 NA NA 

1,2,3-Trichloropropane 0.005 NA 0.005 0.0056 NA NA 

Semivolatile Organic Compounds (SW8270C) (µg/L) (µg/L) (µg/L) (µg/L) (µg/kg) (µg/kg) 

1,2-Dichlorobenzene 10 NA NA 370 700 3.70E+05 

1,3-Dichlorobenzene 10 w/ NA NA 5.5 700 1.30E+04 

1,4-Dichlorobenzene 10 w/ NA NA 0.5 700 3.40E+03 

2,4,5-Trichlorophenol 10 NA NA 3600 700 6.10E+06 

2,4,6-Trichlorophenol 10 w/ NA NA 6.1 700 4.40E+04 

2,4-Dichlorophenol 10 NA NA 110 700 1.80E+05 

2,4-Dimethylphenol 10 NA NA 730 700 1.20E+06 

2,4-Dinitrophenol 50 NA NA 73 3500 1.20E+05 

2,4-Dinitrotoluene 10 NA NA 73 700 1.20E+05 

2,6-Dinitrotoluene 10 NA NA 36 700 6.10E+04 

2-Chloronaphthalene 10 NA NA 490 700 4.90E+06 

2-Chlorophenol 10 NA NA 30 700 6.30E+04 


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Table 6-2 




PQL c/ 

Water b/ 


PRG f/ 

Soil 

PQL PRG g/ 

2-Methylnaphthalene 10 NA NA NA 700 NA 

2-Methylphenol 10 NA NA 1800 700 3.10E+06 

2-Nitroaniline 50 w/ NA NA 2.1 3500 3.50E+03 

2-Nitrophenol 10 NA NA NA 700 NA 

3,3-Dichlorobenzidine 20 w/ NA NA 0.15 1400 k/ 1.10E+03 

3-Nitroaniline 50 NA NA NA 3500 NA 

4,6-Dinitro-2-methylphenol 50 NA NA NA 3500 NA 

4-Bromophenyl phenyl ether 10 NA NA NA 700 NA 

4-Chloro-3-methylphenol 20 NA NA NA 1400 NA 

4-Chloroaniline 50 NA NA 150 3500 2.40E+05 

4-Chlorophenyl phenyl ether 10 NA NA NA 700 NA 

4-Methylphenol 10 NA NA 180 700 3.10E+05 

4-Nitroaniline 10 NA NA NA 700 NA 

4-Nitrophenol 50 NA NA 290 3500 4.90E+05 

Acenaphthylene 10 NA NA NA 700 NA 

Acenapthene 10 NA NA 370 700 3.70E+06 

Anthracene 10 NA NA 1800 700 2.20E+07 

Benz (a) anthracene 10 w/ NA NA 0.092 700 k/ 620 

Benzo (a) pyrene 10 k/ 0.2 0.2 0.0092 700 k/ 62 

Benzo (b) fluoranthene 10 w/ NA NA 0.092 700 k/ 620 

Benzo (g,h,i) perylene 10 NA NA NA 700 NA 

Benzoic acid 100 NA NA 1.50E+05 7000 1.00E+08 

Benzyl alcohol 20 NA NA 1.10E+04 1400 1.80E+07 

Bis (2-chloroethyl) ether 10 w/ NA NA 0.0098 700 k/ 210 

Bis (2-chloroethoxy) methane 10 NA NA NA 700 NA 

Bis (2-chloroisopropyl) ether 10 w/ NA NA 0.27 700 2.90E+03 

Bis (2-ethylhexyl) phthalate 10 w/ NA NA 4.8 700 3.50E+03 

Butyl benzylphthalate 10 NA NA 7300 700 1.20E+07 

Chrysene 10 w/ NA NA 9.2 700 6.20E+04 

Dibenz (a,h) anthracene 10 w/ NA NA 0.0092 700 k/ 62 

Dibenzofuran 10 NA NA 24 700 2.90E+05 

Diethyl phthalate 10 NA NA 2.90E+04 700 4.90E+07 

Dimethly phthalate 10 NA NA 3.60E+05 700 1.00E+08 


Page 5 of 8 

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Table 6-2 




PQL c/ 

Water b/ 


PRG f/ 

Soil 

PQL PRG g/ 

Di-n-butylphthalate 10 NA NA 3600 700 6.10E+06 

Di-n-octylphthalate 10 NA NA 730 700 1.20E+06 

Fluoranthene 10 NA NA 1500 700 2.30E+06 

Fluorene 10 NA NA 240 700 2.60E+06 

Hexachlorobenzene 10 k/ 1 1 0.042 700 k/ 300 

Hexachlorobutadiene 10 w/ NA NA 0.86 700 6.20E+03 

Hexachlorocyclopentadiene 10 50 50 260 700 4.20E+05 

Indeno (1,2,3-cd) pyrene 10 w/ NA NA 0.092 700 k/ 620 

Isophorone 10 NA NA 71 700 5.10E+05 

Naphthalene 10 j/ NA 170 l/ 6.2 700 5.60E+04 

Nitrobenzene 10 w/ NA NA 3.4 700 2.00E+04 

n-Nitrosodi-n-propylamine 10 w/ NA NA 0.0096 700 k/ 69 

n-Nitrosodiphenylamine 10 NA NA 14 700 9.90E+04 

Pentachlorophenol 50 1 1 0.56 3500 3.00E+03 

Phenanthrene 10 NA NA NA 700 NA 

Phenol 10 NA NA 2.20E+04 700 3.70E+07 

Pyrene 10 NA NA 180 700 2.30E+06 

Metals (SW6010B) (mg/L) o/ 

(mg/L) (mg/L) (mg/L) (mg/kg) p/ 

Calcium 0.1 NA NA NA 15 NA 

Magnesium 0.1 NA NA NA 10 NA 

Potassium 1 NA NA NA 100 NA 

Sodium 1 NA NA NA 100 NA 

Metals (SW6020) (mg/L) o/ 

(mg/L) (mg/L) (mg/L) (mg/kg) p/ 

Aluminum 0.05 NA 1/0.2 m/ 36 10 7.60E+04 

Antimony 0.015 0.006 0.006 0.015 1.5 31 

Arsenic 0.001 0.05 0.05 4.50E-05 1 q/ 0.39 

Barium 0.02 2 1 2.6 2 5400 

Beryllium 0.005 0.004 0.004 0.073 0.5 150 

Cadmium 0.005 0.005 NA 0.018 0.5 37 

Chromium (Total) 0.01 0.1 0.05 0.11 1 210 

Cobalt 0.05 NA NA 2.2 5 4700 

Copper 0.025 1.3 r/ 

(mg/kg) 

(mg/kg) 

1.3 s/ 1.4 2.5 2900 

Iron 0.1 NA 0.3 l/ 11 10 2.30E+04 


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Table 6-2 




PQL c/ 

Water b/ 


PRG f/ 

Soil 

PQL PRG g/ 

Lead 0.003 NA NA NA 0.3 400 

Manganese 0.015 NA 0.05 m/ 0.88 1.5 1800 

Molybdenum 0.02 NA NA 0.18 2 390 

Nickel 0.05 NA 0.1 0.73 5 1600 

Selenium 0.005 0.05 0.05 0.18 0.5 390 

Silver 0.01 NA 0.1 m/ 0.18 1 390 

Thallium 0.001 0.002 0.002 0.0026 1 5.5 

Vanadium 0.05 NA 0.015 l/ 0.26 5 550 

Zinc 0.02 NA 0.5 m/ 11 5 2.30E+04 

Hexavalent Chromium (SW7199A) (ug/L) (ug/L) (ug/L) (ug/L) (ug/kg) (ug/kg) 

Hexavalent Chromium 0.3 w/ NA NA 0.16 40 200 

Cold Vapor Atomic Absorption (mg/L) (mg/L) (mg/L) (mg/L) (mg/kg) (mg/kg) 

Mercury (SW7470A/7471A) 0.0005 0.002 0.002 0.011 0.25 23 

Anions (SW9056) (mg/L) (mg/L) (mg/L) (mg/L) (mg/kg) (mg/kg) 

Chloride 1 NA 250 t/ NA 1 NA 

Nitrate 1 10 45 NA 1 NA 

Sulfate 1 NA 250 t/ NA 1 NA 

Methane, Ethane, Ethene (RSK-175SOP) (mg/L) (mg/L) (mg/L) (mg/L) (mg/kg) (mg/kg) 

Methane 0.05 NA NA NA NA NA 

Ethane 0.05 NA NA NA NA NA 

Ethene 0.01 NA NA NA NA NA 

Total Organic Carbon (SW9060) 1 NA NA NA 100 NA 

a/ Methods: SW - U.S. Environmental Protection Agency (EPA). 1995b. Test Methods for Evaluating Solid Waste: 

Physical/Chemical Methods, SW-846, (3rd Edition, including Updates I, II, III and IIIA). USEPA Methods for the Analysis of Water and Wastes (1993) 

b/ Water PQLs should meet tap water PRGs as the project threshold value. When PQLs cannot detect down to tap water PRGs, California MCLs (when available) will be used as 

the project threshold value. If California MCLs are not available, then federal MCLs become the project threshold. 

c/ PQL = Practical Quantiation Limit 

d/ MCL (Fed) = Federal Maximum Contaminant Level for drinking water 

e/ MCL (CA) = Primary California Maximum Contaminat Level for drinking water (Title 22 CCR) 

f/ PRG = Preliminary Remediation Goal for Tap Water (EPA Region 9) (USEPA, 2002) 

g/ PRG = Preliminary Remediation Goal for Residential Soil (EPA Region 9) (USEPA, 2002) 

h/ µg/L = microgram per Liter 

i/ µg/kg = microgram per kilogram 

j/ PQL is greater than the tap water PRG but less than MCL. Project DQOs met since MCL is regulatory threshold for potentially triggering further action. 

k/ This PQL although above the PRG represents the lowest possible detection limit for this compound and will be used as the project threshold value. 


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Table 6-2 




PQL c/ 

Water b/ 


l/ Action Level (AL) = health-based advisory levels established by the California Department of Health Services (DHS) for 

chemicals in drinking water for which primary MCLs have not been adopted. 

m/ Secondary California Maximum Contaminant Level for drinking water (Title 22 CCR) 

n/ ICP = Inductively coupled plasma spectroscopy 

o/ mg/L = milligram per Liter 

p/ mg/kg = milligram per kilogram 

q/ The soil PQL for arsenic is greater than the residential soil PRG, but less than naturally occuring background levels of arsenic in soil. 

r/ Lead and copper are not regulated by MCLs, but in a Treatment Technique for water pipeline systems. 

s/ California Action Level (Title 22 CCR) 

t/ California Secondary Maximum Contaminat Level for drinking water (Title 22 CCR) 

u/ Required MDL identified in LARWQCB's letter "Leaking Underground Storage Tanks Program-Updated Laboratory Testing Requirements" dated June 22, 2000. 

v/ Low Level Method (DHS) will be used to achieve a PQL lower than the PRG. 


PRG f/ 

Soil 

PQL PRG g/ 

Page 8 of 8 

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Table 6-3 

Comparison of Field and Fixed Laboratory Reporting Limits with Site-Specific Soil-Gas 

Preliminary Remediation Goals (PRGs) for an Unrestricted Land Use Scenario 



COPC a/ 

Soil Gas PRG 

(Unrestricted 

Land Use) 

b/ c/ 

Carcinogenic- or 

Noncarcinogenicbased 

PRG d/ 

Fixed 

Laboratory 

Field 

Laboratory 

RL (µg/L) 

Field 

Laboratory 

(µg/m 3 ) RL (µg/m 3 ) 

RL (µg/m 3 ) 

VOLATILE ORGANIC COMPOUNDS 

1,1,1,2-TETRACHLOROETHANE 2.59E+02 C 1.400E+01 0.1 100 

1,1,1-TRICHLOROETHANE 1.74E+06 NC 2.80E+00 1 1000 

1,1,2,2-TETRACHLOROETHANE 3.31E+01 C 3.50E+00 0.1 100 f/ 

1,1,2-TRICHLORO-1,2,2-TRIFLUOROETHANE 5.50E+05 NC 3.90E+00 0.5 j/ 

500 j/ 

1,1,2-TRICHLOROETHANE 1.15E+02 C 2.80E+00 0.1 100 

1,1-DICHLOROETHANE 1.17E+03 C 2.00E+00 0.1 100 

1,1-DICHLOROETHENE 5.17E+04 NC 2.00E+00 1 1000 

1,2,4-TRICHLOROBENZENE 5.46E+03 NC 1.50E+01 1 j/ 

1000 j/ 

1,2,4-TRIMETHYLBENZENE 5.30E+03 NC 2.50E+00 1 j/ 

1000 j/ 

1,2-DIBROMOETHANE 3.55E+01 C 3.90E+00 0.1 j/ 

100 j/ 

1,2-DICHLORO-1,1,2,2-TETRAFLUOROETHANE -- -- 3.60E+00 0.5 j/ 

500 j/ 

1,2-DICHLOROBENZENE 1.66E+05 NC 3.00E+00 1 j/ 

1000 j/ 

1,2-DICHLOROETHANE 7.73E+01 C 2.00E+00 0.1 100 

1,2-DICHLOROPROPANE 1.83E+02 C 2.30E+00 0.1 100 

1,3,5-TRIMETHYLBENZENE (MESITYLENE) 5.32E+03 NC 2.50E+00 1 j/ 

1000 j/ 

1,3-BUTADIENE 4.18E+01 C 1.10E+00 0.1 j/ 

100 j/ 

1,3-DICHLOROBENZENE 2.62E+03 NC 3.00E+00 1 j/ 

1000 j/ 

1,4-DICHLOROBENZENE 1.77E+02 C 3.00E+00 0.1 j/ 

100 j/ 

4-ETHYLTOLUENE -- -- 2.50E+00 0.5 j/ 

500 j/ 

ACETONE 2.28E+05 NC 4.80E+00 1 1000 

BENZENE 6.00E+01 C 1.60E+00 0.1 j/ 

100 j/ 

BENZYL CHLORIDE 3.81E+01 C 2.60E+00 0.1 100 

BROMODICHLOROMETHANE 8.65E+01 C 3.40E+00 0.1 100 

BROMOFORM 4.92E+03 C 5.20E+00 1 1000 

BROMOMETHANE 4.06E+03 NC 2.00E+00 1 1000 

CARBON DISULFIDE 5.57E+05 NC 1.60E+00 1 j/ 

1000 j/ 

CARBON TETRACHLORIDE 4.37E+01 C 3.20E+00 0.1 100 

CHLOROBENZENE 8.11E+05 NC 2.30E+00 1 1000 

CHLOROETHANE 1.49E+03 C 1.30E+00 0.5 500 

CHLOROFORM 3.06E+02 C 2.50E+00 0.1 100 

CHLOROMETHANE 8.40E+02 C 4.20E+00 0.1 j/ 

100 j/ 

cis-1,2-DICHLOROETHYLENE 2.83E+04 NC 2.00E+00 1 j/ 

1000 j/ 

cis-1,3-DICHLOROPROPENE 1.28E+02 C 2.30E+00 0.1 100 

K:\Depts\Dept48\LAUSD\MSA WORK\Soil Investigation\OU 1 RAP\Appendix\Appendix H - QAPP\Table6-3 - Compare RLs and PRGs .xls Page 1 of 3 

313

Table 6-3 





COPC a/ 

Soil Gas PRG 

(Unrestricted 


(µg/m 3 ) 

b/ c/ 



PRG d/ 

Fixed 

Laboratory 

RL (µg/m 3 ) 

Field 

Laboratory 

RL (µg/L) 

Field 

Laboratory 

RL (µg/m 3 ) 

DIBROMOCHLOROMETHANE 1.61E+02 C 4.30E+00 0.5 500 

DIBROMOMETHANE -- -- 1.40E+01 0.5 j/ 

500 j/ 

DICHLORODIFLUOROMETHANE 7.73E+03 NC 2.50E+00 0.5 j/ 

500 j/ 

ETHANE -- -- 1.23E+04 

e/ e/ 

ETHENE -- -- 1.15E+04 

e/ e/ 

ETHYLBENZENE 1.70E+03 C 2.20E+00 0.1 100 

HEXACHLORO-1,3-BUTADIENE 9.71E+01 C 2.20E+01 0.5 j/ 

500 j/ 

ISOPROPYLBENZENE (CUMENE) 3.44E+05 NC 2.46E+00 1 j/ 

1000 j/ 

M,P-XYLENE (SUM OF ISOMERS) 5.68E+05 NC 4.34E-01 0.5 j/ 

500 j/ 

METHYL BUTYL KETONE (2-HEXANONE) -- -- 8.30E+00 1 1000 

METHYL ETHYL KETONE (2-BUTANONE) 3.87E+06 NC 1.50E+00 1 1000 

METHYL ISOBUTYL KETONE (4-METHYL-2-PENTANONE) 2.40E+03 NC 2.10E+00 1 1000 

METHYLENE CHLORIDE 1.64E+03 C 1.80E+00 0.1 100 

NAPHTHALENE 6.20E+01 C 1.05E+01 0.1 j/ 

100 j/ 

O-XYLENE (1,2-DIMETHYLBENZENE) 5.24E+05 NC 2.20E+00 0.5 j/ 

500 j/ 

PROPANE -- -- 1.80E+04 0.5 j/ 

500 j/ 

STYRENE 8.34E+05 NC 2.20E+00 1 1000 

TETRACHLOROETHYLENE (PCE) 3.23E+02 C 3.40E+00 0.1 100 

TOLUENE 2.25E+05 NC 1.90E+00 1 1000 

trans-1,2-DICHLOROETHENE 5.77E+04 NC 2.00E+00 1 1000 

trans-1,3-DICHLOROPROPENE 1.28E+02 C 2.30E+00 0.5 500 

TRICHLOROETHYLENE (TCE) 9.12E+02 C 2.70E+00 0.1 100 

TRICHLOROFLUOROMETHANE 5.24E+05 NC 2.80E+00 1 j/ 

1000 j/ 

VINYL ACETATE 1.51E+05 NC 7.20E+00 1 j/ 

1000 j/ 

VINYL CHLORIDE 2.07E+01 C 1.30E+00 0.1 100 

XYLENES, TOTAL 5.68E+05 NC 2.08E+00 1 1000 

1,2,3-TRICHLOROPROPANE g/ 

8.03E-01 C 1.20E+01 0.1 j/ 

100 j/ 

SEMI-VOLATILE ORGANIC COMPOUNDS 

2-METHYLNAPHTHALENE 1.35E+04 NC 1.00E+00 h/ 

1 j/ 

1000 j/ 

ACENAPHTHYLENE 2.30E+05 NC 1.00E+00 h/ 

1 j/ 

1000 j/ 

ANTHRACENE 1.36E+06 NC 1.00E+00 h/ 

1 j/ 

1000 j/ 

NAPHTHALENE 6.20E+01 C 1.00E+00 h/ 

0.1 j/ 

100 j/ 

PHENANTHRENE 1.24E+06 NC 1.00E+00 h/ 

1 j/ 

1000 j/ 


314

Table 6-3 





COPC a/ 

Soil Gas PRG 

(Unrestricted 


(µg/m 3 ) 

b/ c/ 



PRG d/ 

Fixed 

Laboratory 

RL (µg/m 3 ) 

FIXED AND BIOGENIC GAS 

OXYGEN (O 2) -- -- -- 

CARBON DIOXIDE (CO 2) -- -- -- 

METHANE -- -- -- 

OXYGENATES i/ 

Field 

Laboratory 

RL (µg/L) 

DI-ISOPROPYL ETHER (DIPE) -- -- -- 1 j/ 

ETHANOL -- -- -- 1 j/ 

ETHYL TERTIARY BUTYL ETHER (ETBE) -- -- -- 1 j/ 

tert-AMYL METHYL ETHER (TAME) -- -- -- 1 j/ 

tert-BUTYL ALCOHOL (TBA) -- -- -- 1 j/ 

tert-BUTYL METHYL ETHER (MTBE) 6.28E+03 C -- 0.1 j/ 

OTHER 

1,4-DIOXANE 1.66E+02 C 7.21E+00 1 j/ 

HYDROGEN SULFIDE 5.85E+03 NC -- 

Field 

Laboratory 

RL (µg/m 3 ) 

e/ e/ 

e/ e/ 

e/ e/ 

1000 j/ 

1000 j/ 

1000 j/ 

1000 j/ 

1000 j/ 

100 j/ 

1000 j/ 

e/ e/ 

a/ 

COPC = chemical of potential concern. 

b/ 

PRG = preliminary remediation goal based on an unrestricted land use scenario calculated per Parsons, 2004b. 

c/ 

ppmv = parts per million by volume. 

d/ 

NC = PRG based on noncarcinogenic effects; C = PRG based on carcinogenic effects. 

e/ 

A field meter will be used to semi-quantitatively screen for carbon dioxide, ethane, ethene, hydrogen sulfide, and methane, and then any 

positives would be confirmed by the field lab (with selective confirmation by the fixed lab). 

f/ 

Bolded values are greater than their respective PRGs. 

g/ 

This RL is for separate analysis (in addition to TO-14A/TO-15) that will be performed at locations where 1,2,3-TCP is detected by the mobile lab. 

h/ 

These RLs are for analytes analyzed via the TO-13 method at selected locations based on historical results. 

i/ 

Oxygenates will be identified as Tentatively Identified Compounds by the Fixed Laboratory. 

j/ 

This COPC is not on the DTSC/RWQCB list of analytes. The identification and quantification would be based on a one-point standard. 


315

SECTION 7 

LABORATORY QC SAMPLES AND CRITERIA 

Laboratory QC data are necessary to determine the precision and accuracy of the 

analyses, confirm matrix interferences, and demonstrate target compound contamination 

of sample results. QC samples will be analyzed routinely by the analytical laboratory as 

part of the method QC procedures. The contract laboratory Quality Assurance Program 

Manual (QAPM) describes its QA system. At a minimum, the laboratory must prepare 

and analyze a method blank, a laboratory control sample (LCS), a laboratory sample 

duplicate, and a continuing calibration standard with each batch of samples. A matrix 

spike/matrix spike duplicate (MS/MSD) shall be analyzed with each batch, providing 

sufficient sample was provided to the laboratory by the sampling team. If there is not 

sufficient sample for MS/MSD, the laboratory will prepare and analyze the LCS in 

duplicate. In this manner, a measure of the precision pertaining to the specific analytical 

batch can be determined. 

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316

SECTION 8 

LABORATORY DATA REVIEW, REDUCTION, AND REPORTING 

The following sections describe the project minimum requirements for laboratory data 

review, reduction, and reporting. The laboratory through its QAP and SOPs shall specify 

the personnel performing each function. 

Level IV documentation is to be provided for all data (see Section 14). 

If multiple dilutions are performed, the results of each dilution are to be reported. 

8.1 REVIEW PROCEDURES FOR DEFINITIVE DATA 

The laboratory review of definitive data shall be a four-step process involving an 

evaluation by the analyst, a peer review, an administrative review, and a QA review. A 

checklist to document each of the review processes will be required and must be included 

as part of the final data deliverable. All steps are described below. 

The analyst shall review 100 percent of all definitive data prior to reporting. The 

establishment of method detection and control limits shall be verified. Any control limit 

outside the acceptable ranges specified in the analytical methods shall be identified. Any 

trends or problems with the data shall be evaluated. The absence of records supporting 

the establishment of control criteria or detection limits shall be noted and explained. 

Analytical batch QC, calibration check samples, initial and continuing calibrations, 

corrective action reports, the results of reanalysis, sample holding times, and sample 

preservations shall be evaluated. 

Samples associated with out-of-control QC data shall be identified in the data package 

case narrative, and an assessment of the utility of such analytical results shall be made. 

The check of laboratory data completeness must be documented and will ensure that: 

• All samples and analyses specified in the chain-of-custody have been processed; 

• Complete records exist for each analysis and the associated QC samples; and 

• Procedures specified in this QAPP have been implemented. 

An analyst other than the original data processor shall be responsible for performing a 

peer review of all steps of the data processing. One hundred percent of all data shall be 

reviewed. All input parameters, calibrations, and transcriptions will be checked. All 

manually input, computer-processed data will be checked. Each page of checked data 

shall be signed and dated by the verifier. 

8-1 


317

Continuing calibrations shall be compared to the initial calibration curve to determine 

that the analytical system is performing within acceptable range. QC sample results 

(LCSs , laboratory duplicates, and MS/MSD) shall be compared against stated 

acceptance criteria for accuracy and precision. QC data must meet acceptance levels 

prior to processing the analytical data. If QC standards are not met, the cause shall be 

determined. If the cause can be corrected without affecting the integrity of the analytical 

data, processing of the data shall proceed. If the resolution jeopardizes the integrity of 

the data, reanalysis shall be performed, if still within holding time. If the holding time 

will be exceeded, the decision regarding reanalysis will be made upon conferring with the 

Parsons PM or his designee. 

An administrative review will be performed by the laboratory project manager on each 

data deliverable package. The review will ensure that all requirements of the laboratory 

and the data deliverables have been met and are complete. 

A review of at least 10 percent of all data deliverable packages by a laboratory QA 

officer must take place prior to the administrative review and final release of the data 

deliverable. The data packages will be randomly selected for review. 

8.2 LABORATORY DATA REPORTING FLAGS 

The following qualifiers must be used by the laboratory when reporting sample results. 

Qualifier Description 

J The analyte was positively identified, the quantitation is an estimation, 

and/or the analyte was positively identified but the associated 

numerical value is greater than the SQL but less than the PQL. 

U The analyte was analyzed for, but not detected. The associated 

numerical value is at or below the MDL. 

B The analyte was found in an associated blank, as well as in the sample. 

8.3 ASSESSMENT OF DATA USABILITY 

The Project Chemist will assess data usability and apply data qualifiers to the analytical 

results based on adherence to method protocols and laboratory-specific QA/QC limits. 

8.3.1 Data Usability Assessment 

The laboratory deliverable will include the following information: 

• Case narratives; 

• Chain-of-custody forms; 

• Summary of results by sample; 

• Holding times; 

• Sample temperatures during shipping and storage; 

• Summary of QC results (method blanks, equipment blanks, laboratory duplicates, 

LCS, MS/MSD, etc.); 

8-2 


318

• Instrument run logs; 

• Initial calibration data, raw and processed; 

• Continuing calibration data, raw and processed; 

• Raw data for all sample runs and QC runs; 

• Summary of method detection limit determination, showing the seven individual 

runs, their mean, and their standard deviation, but not including their raw data; and 

• Surrogate spikes recoveries. 

Data qualifiers are applied to analytical results during the data usability assessment, 

based on adherence to method protocols and QA/QC limits. 

The validation guidelines are defined in Tables 8-1 and 8-2 and were developed in 

accordance with the National Functional Guidelines for Organic Data Review (USEPA, 

1994a). Expanded criteria for the data usability guidelines were developed where 

professional judgment is recommended within the USEPA guidelines. QC guidelines are 

those specified in the analytical method protocols. 

8.3.2 Data Reporting Qualifiers 

The following definitions provide explanations of the USEPA (1994a) qualifiers to be 

assigned to analytical results during data validation, as defined in Table 8-1. The data 

qualifiers described are applied to organic results. 

Qualifier Description 

The analyte was analyzed for and is not present above the reported sample 

U 

quantitation limit. 

J The analyte was analyzed for and was positively identified, but the 

associated numerical value may not be consistent with the amount actually 

present in the environmental sample. The data should be considered as a 

basis for decision making and are usable for many purposes. 

R The data are rejected as unusable for all purposes. The analyte was 

analyzed for, but the presence or absence of the analyte was not verified. 

Resampling and reanalysis are necessary to confirm the presence or 

absence of the analyte. 

UJ The analyte analyzed for was not present above the reported sample 

quantitation limit. The associated numerical value may not accurately or 

precisely represent the concentration necessary to detect the analyte in the 

sample. 

8.3.3 Assessment of Usability 

Data usability will be assessed by the project chemist based on validation results to 

determine the project PARCCs. The project chemist will perform data validation on at 

least ten percent of the data, selected at random. In addition, targeted data validation and 

evaluation will be performed on any result that appears to be unusual or outside the 

expected range. Any limitations on data use will be expressed quantitatively to the extent 

practicable. The outcome of this data review will be a data set appropriate to support 

8-3 


319

project-specific DQOs. A DQA will be written, summarizing the findings of the data 

review, and providing an assessment of overall data quality and usability. 

8-4 


320

Table 8-1 Flagging Conventions for Data Evaluation and Validation of Organic Methods 


Quality Control Check 

Holding Time 

Evaluation 

Holding time exceeded for extraction or 

Flag 

J positive results 

Samples Affected 

Sample, MS/MSD 

analysis by > 2 times 

R non-detects 

Holding time exceeded for extraction or J positive results 

analyses by < 2 times 

UJ non-detects 

a/ 


Sample Preservation Sample not preserved J positive results 



Temperature Blank >8°C 

J positive results (except PCBs) 

UJ non-detects (except PCBs) 

All samples in same cooler 

>20°C (Volatile Compounds) 

R all results 

All samples in same cooler 

Tune Ion abundance criteria J positive results 

All associated samples in analysis 

Set critical ions as defined in the NFG 

UJ non-detect results 

batch 

b/ R all positive results and non-detects All associated samples in analysis 

batch 

Initial Calibration 

(ICAL) 

GC/MS: c/ 

RRF d/ 2X control criteria R all positive results and non-detects Compound in all associated samples 

(ICAL) (continued) 

GC: 

in analysis batch 

e/ 

For multi-component target compounds, at 

least 3 peaks used with a RT f/ window of 

±0.07 minutes each 

%RSD 



Compound in all associated samples 


g/ linearity: 

Correlation coefficient of curve < 0.995 J positive results 


but > 0.990 



Correlation coefficient of curve < 0.990 R all positive and non-detects 

Calibration Verification 

(CCAL) 

%RSD > 20% 

If %RSD >2X control limit 

GC/MS: 

%D h/ ≥25% and RRF≥0.05 



R all positive and non-detects 








321



Quality Control Check Evaluation Flag Samples Affected 

Calibration Verification If %D is >2X control criteria R all positive results and non-detects Compound in all associated samples 

(CCAL) (Continued) 


RRF 0.990 

Correlation coefficient of curve < 0.990 



R all positive and non-detects 



%D >15% 





If %D is > 2X control criteria R all positive results and non-detects Compound in all associated samples 


Laboratory Control Sample LCS or LCSD single compound: 

(LCS) and Laboratory Control %R UCL 

associated samples. 

i/ but < 150%. J positive results 

Spiked compound only in all 

% R > 30% but < LCL 

No qualification for non-detects associated samples. 

j/ J positive results 




% R >UCL and >150% R all positive results good/non-detects Spiked compound only in all 


If > 50% of all LCS or LCSD spiked 

compounds are out of control: 

RPD k/ R all positive results and non-detects All detected spike compounds in all 

>control limit 


samples 

All detected spike compounds in all 

samples 

Method Blank Multiply value by 5, common lab 

contaminants multiply by 10 l/ 

U flag reported results < calculated 

value 

All samples in extraction batch 

Equipment Blank Convert to soil units, if applicable, multiply 

by 5, common lab contaminants multiply by 

10 b/ 

U flag reported results < calculated All samples, same field team, matrix 

value 

and date (water) or all samples, same 

field team, matrix (soil) 

Trip Blank Convert to soil units, if applicable, multiply 

by 5, common lab contaminants multiply by 

10 b/ 

U flag reported results < calculated All volatile samples shipped in the 

value 

same cooler 


322




Matrix Spike/Matrix Spike MS or MSD single compound: 

Affected compound in native sample 

Duplicates (MS/MSD) %R UCL but < 200% J positive results 


% R 

No qualification for non-detects MS/MSD 

m/ > 10% but < LCL J positive results 



MS/MSD 

% R >UCL and >200% R all positive results and non-detects All compounds in native sample 

If > 50% of all MS or MSD spiked 


R all positive results and non-detects All compounds in native sample 

When sample conc. is >4X spike conc. No evaluation required None 

RPD > control limit J positive results 


No qualification for non-detects MS/MSD 

Surrogates 

If 2 or more surrogates from the same 

GC/MS SEMI-VOA 

chemical family group: 

%R > UCL 


All associated compounds in sample 

%R < LCL and ≥ 10% J positive results 



Any one < 10% J positive results 

R non-detects 


GC Methods n/ and GC/MS 

VOA 

%R > UCL J positive results All compounds in associated sample 

%R < LCL and ≥ 10% J positive results 


All compounds in associated sample 

%R < 10% J positive results 


R non-detects 

Internal Standards (IS) RT change > UCL from daily CCAL o/ R all positive results and non-detects All associated compounds in sample 

(GC/MS) IS extracted ion area counts -50% to J positive results 


+100% of last CCAL 


Retention Time Windows Analyte peak not within RTW Report positive result as non-detect, All affected compounds 

(RTW) 

(professional judgment should be 

used prior to eliminating detections) 

Second-Column Confirmation Primary and confirmation results do not 

agree within a factor of 50 percent. 

J positive results All affected compounds 

Field Duplicates RPD > 35% water or soil 

Discuss impacts in data quality 

assessment report 

Field duplicate pair 


323




Breakdown check (DDT) 

(SW8080A) 

Breakdown check (Endrin) 

(SW8080A) 

% Breakdown for DDT > 20% J positive DDT, DDE, and DDE 

results 

R non-detects for DDT if DDD and 

DDE are positive 

%Breakdown for Endrin > 20% J positive endrin, endrin aldehyde, 

and endrin ketone results 

R non-detects for endrin if endrin 

aldehyde and endrin ketone are 

positive 

Samples following the last in control 

standard 

Samples following the last in control 

standard 

a/ MS/MSD = Matrix spike/matrix spike duplicate. k/ RPD = Relative percent difference. 

b/ NFG = National Functional Guidelines. l/ Common lab contaminants: methylene chloride, acetone, 2-butanone, and phthalates. 

e/ GC/MS = Gas chromatograph/mass spectroscopy m/ %R = Percent recovery. 

d/ RRF = Relative response factor. n/ Number of surrogates varies with method. Pesticides and PCBs are surrogate specific 

e/ GC = Gas chromatography and are evaluated as independent chemical family groups. 

f/ RT = Retention time. o CCAL = Continuing calibration 

s/ RSD = Relative standard deviation 

h/ %D = Percent difference. 

i/ UCL = Upper control limit. 

j LCL = Lower control limit. 


324

Table 8-2 Flagging Conventions for Data Evaluation and Validation of Inorganic and Wet Chemistry Methods 



Holding Time Holding time exceeded for digestion or J positive results 

Sample only 

analysis by < 2 times 

UJ non-detected results 

exceeded by > 2 times 


R non-detects. 

Sample only 

Sample Preservation Sample preservation requirements not met J positive results 

UJ non-detects for all methods except 

mercury 

R mercury non-detects 

Sample only 

Temperature Blank >8°C J positive results 


Samples in same cooler 

Initial (Multipoint) Calibration Correlation coefficient of curve < 0.995 J positive results 


but > 0.990 


batch 

Correlation coefficient of curve < 0.990 R positive results 


Calibration Standard Check Recovery above UCL 

R non-detects 

batch 

a/ or below LCL b/ R positive results 


Calibration Verification: ICV 

R non-detects 

batch 

c/ , 

CCV d/ 

ICP/GFAA, WET Chemistry: 

%R e/ between 75-89% 




batch for ICV 

or 111-125% 

Hg: 

K:\Depts\Dept48\LAUSD\MSA WORK\Soil Investigation\OU 1 RAP\Appendix\Appendix H - QAPP\Tables.doc 

5/7/2008 

No qualification for non-detects with 

111-125%R 

%R < 75% R positive results Samples after failed CCV until 

next in control CCV 

%R > 125% R positive results 

Samples after failed CCV until 

No qualification for non-detects next in control CCV 

J positive results Samples after failed CCV until 

%R between 65-79% or 121-135% 

next in control CCV 

%R between 65-79% UJ non-detects 

%R < 65% R positive results All associated samples in analysis 

batch 

%R > 135% R positive 

No qualification for non-detects 

Interference Check Sample (ICS) %R > UCL J positive results All associated samples in analysis 

325




ICS Continued (ICP Only) %R between 50-79% 



batch 

%R < 50% 


R positive results 


Laboratory Control Sample LCS or LCSD single analyte: 

(LCS) and Laboratory Control %R UCL but < 150% J positive results 


No qualification for non-detects associated samples. 

% R > 30% but < LCL J positive results 




% R >UCL and >150% R all positive results and non-detects Spiked compound only in all 


If > 50% of all LCS or LCSD spiked R all positive results and non-detects All compounds in all associated 


RPD 

samples 

g/ > control limit J positive results 

All detected spike compounds in 

Blanks: MB 

No qualification for non-detects all samples 

h/ , ICB i/ , CCB j/ If the absolute value of the blank is U flag reported results < calculated All samples in digestion batch 

>MDL, then multiply value by 5, convert values 

(MB) 

to soil units if applicable 

All samples in analysis batch 

(ICB, CCB) 

Equipment Blank If the absolute value of the blank is U flag reported results < calculated All samples, same field team, 

>MDL, then multiply value by 5, convert values 

matrix and date (water) or all 

to soil units if applicable 

samples, same field team, matrix 

(soil) 

Matrix Spike/Matrix Spike MS or MSD single compound: 

Duplicates (MS/MSD) 

%R UCL but < 200% 


Affected compound in native 

No qualification for non-detects sample MS/MSD 

% R > 10% but < LCL 




sample MS/MSD 

% R >UCL and >200% R all positive results and non-detects All compounds in native sample 

If > 50% of all MS or MSD spiked 


R all positive results and non-detects All compounds in native sample 


5/7/2008 

326



Quality Control Check 

MS/MSD Continued 

Evaluation Flag Samples Affected 

When sample conc. is control limit J-positive results 


No qualification for non-detects sample MS/MSD 

Serial Dilution (ICP Only) If concentration is > 50 times MDL and % J positive results 

All samples in digestion batch if 

MSA 

difference > control limit 


analytical spike not performed 

k/ (GFAA Only) MSA not done 



Sample only 

MSA spike levels inappropriate 



Sample only 

r ≤0.995 



Sample only 

Field duplicates RPD > 35% water or soil Discuss in data quality assessment 

report 

Field duplicate pair 

a/ UCL = Upper control limit. j/ CCB = Continuing calibration blank. 

b/ LCL = Lower control limit k/ MSA = Method of standard addition. 

c/ ICV = Initial calibration verification. 

d/ CCV = Continuing calibration verification. 

e/ %R = Percent recovery. 

f/ Exceptions occur when the historical control limits are below or above the maximum/minimum %R value. When this occurs, the historical control limit 

takes precedence. Data are qualified as unusable only after the historical control limit is exceeded. 

g/ RPD = Relative percent difference. 

h/ MB = Method blank. 

i/ ICB = Initial calibration blank. 


5/7/2008 

327

SECTION 9 

QA REPORTS 

At monthly intervals beginning with the initiation of sampling activities, the laboratory 

will submit an internal QA report that documents laboratory-related QA/QC issues to the 

contractor’s project manager. These reports will include discussions of any conditions 

adverse or potentially adverse to quality, such as: 

• Responses to the findings of any internal or external systems or performance 

laboratory audits; 

• Any laboratory or sample conditions that necessitate a departure from the methods 

or procedures specified in this QAPP; 

• Any missed holding times or problems with laboratory QC acceptance criteria; and 

• The associated corrective actions taken. 

Submittal of QA reports will not preclude earlier contractor notification of such problems 

when timely notice can reduce the loss or potential loss of quality, time, effort, or 

expense. Appropriate steps will be taken to correct any QA/QC concerns as they are 

identified. The QA reports and a summary of the laboratory QA/QC program and results 

will be included in the final project report. 

9-1 


328

SECTION 10 

CORRECTIVE ACTION 

The following procedures have been established to assure that conditions adverse to data 

quality are promptly investigated, evaluated, and corrected. Adverse conditions may 

include malfunctions, deficiencies, deviations, and errors. 

When a significant condition adverse to data quality is noted at the laboratory, the cause 

of the condition will be determined, and corrective action will be taken to prevent 

repetition. Condition identification, cause, reference documents, and corrective action 

planned will be documented and reported to the contractor QA officer by the laboratory 

QC coordinator. Following implementation of corrective action, the laboratory QC 

coordinator will report the actions taken and their results to the contractor project 

manager and QA officer. A record of the action taken and results will be attached to the 

data report package. If samples are reanalyzed, the assessment procedures will be 

repeated, and the control limits will be reevaluated to ascertain if corrective actions have 

been successful. 

Implementation of corrective action is verified by documented follow-up action. All 

project personnel have the responsibility, as part of the normal work duties, to identify, 

report, and solicit approval of corrective actions for conditions adverse to data quality. 

Corrective actions will be initiated in the following instances: 

• When predetermined acceptance criteria are not attained (objectives for precision, 

accuracy, and completeness); 

• When the prescribed procedure or any data compiled are faulty; 

• When equipment or instrumentation is determined to be faulty; 

• When the traceability of samples, standards, or analysis results is questionable; 

• When QA requirements have been violated; 

• When designated approvals have been circumvented; 

• As a result of systems or performance audits; 

• As a result of regular management assessments; 

• As a result of intralaboratory or interlaboratory comparison studies; and 

• At any other instance of conditions significantly adverse to quality. 

10-1 


329

Laboratory project management and staff, such as QA auditors, document and sample 

control personnel, and laboratory groups, will monitor work performance in the normal 

course of daily responsibilities. 

The laboratory QC coordinator or designated alternate will audit work at the laboratory. 

Items, activities, or documents ascertained to be compliant with QA requirements will be 

documented, and corrective actions will be mandated in the audit report. The contractor 

QA officer and laboratory QC coordinator will log, maintain, and control the audit 

findings. 

The contractor QA officer and laboratory QC coordinators are responsible for 

documenting all out-of-control events or non-conformance with QA protocols. A 

nonconformance report will summarize each nonconformance condition. The laboratory 

will notify the contractor project manager or QA officer of any laboratory QA/QC 

nonconformances upon their discovery. Copies of all field change requests and 

corrective action forms will be maintained in the project files. A stop-work order may be 

initiated by the contractor if corrective actions are insufficient. 

10-2 


330

SECTION 11 

AUDITS 

This section describes participation in external and internal systems audits. 

11.1 SYSTEM AUDITS 

System audits review laboratory operations and the resulting documentation. An onsite 

audit ensures that the laboratory has all the personnel, equipment, and internal SOPs 

needed for performance of contract requirements in place and operating. The system 

audits ensure that proper analysis documentation procedures are followed, that routine 

laboratory QC samples are analyzed, and that any nonconformances are identified and 

resolved. 

11.1.1 Internal Audits 

The laboratory must conduct internal system audits on a periodic basis. The results of 

these audits will be documented by the Laboratory QA Officer, and the laboratory will 

provide the Project Chemist and Task Manager with the results of these internal audits. 

11.1.2 External Audits 

The Project QA Officer or Task Manager may conduct an external onsite system audit of 

the laboratory prior to the performance of project samples. This audit would evaluate the 

capabilities and performance of laboratory personnel, equipment, and procedures. It also 

documents the measurement systems and identifies deficiencies to be corrected by the 

laboratory. The QA Manager acts on audit results by documenting deficiencies and 

informing the Task Manager of the need for corrective action. The Task Manager may 

suspend operations until problems are resolved. If conditions adverse to quality are 

detected, or if the Task Manager requests additional audits, additional unscheduled audits 

may be performed. 

In addition to this audit of the laboratory, various state and/or federal agencies may 

conduct an audit prior to the commencement of the project, and may conduct additional 

audits as deemed necessary. The frequency and schedule of any such audits will be 

established by the auditing agency and coordinated directly with the laboratory. 

11.2 PERFORMANCE AUDITS 

Laboratory performance audits may be conducted to determine the accuracy and 

implementation of the QAPP by the Project QA Officer or designee at any time during 

field sampling and analysis. Unplanned audits may be implemented if requested by the 

PM. In addition to in-house performance audits, the laboratory must also participate in 

interlaboratory performance evaluation studies for different state or federal agencies. 

The Project QA Officer will act to correct any laboratory performance problems. 

11-1 


331

SECTION 12 

PREVENTIVE MAINTENANCE 

All instrumentation shall be maintained in a manner that produces consistent, quality data 

and that prevents possible limitations on analytical capacity in the laboratory. 

12.1 PROCEDURES 

Equipment, instruments, tools, gauges, and other items requiring preventive maintenance 

will be serviced in accordance with the manufacturers' specified recommendations and 

written procedures developed by the operators. 

12.2 SCHEDULES 

Manufacturers' procedures identify the schedule for servicing critical items to minimize 

downtime of the measurement system. It will be the responsibility of the individual 

operator assigned to a specific instrument to adhere to the instrument maintenance 

schedule and to promptly arrange any necessary service. Servicing of the equipment, 

instruments, tools, gauges, and other items will be performed by qualified personnel. 

The laboratory will establish logs to record maintenance and service procedures and 

schedules. All maintenance records will be documented and will be traceable to the 

specific equipment, instruments, tools, and gauges. Records produced for laboratory 

instruments will be reviewed, maintained, and filed by the operators at the laboratories. 

12.3 SPARE PARTS 

A list of critical spare parts will be requested from manufacturers and identified by the 

operator. These spare parts will be stored for availability and use in order to reduce 

downtime due to equipment failure and repair. 

12-1 


332

SECTION 13 

SECURITY 

All access to the laboratory must be secured and controlled. The laboratory must have 

controlled access to sample storage and data handling areas. All computer systems must 

be electronically secured with a system of write access that can be fully documented with 

an audit trail. All laboratory visitors must sign in and out of the building and be escorted 

while on site. 

13-1 


333

SECTION 14 

DATA DELIVERABLES 

The deliverables required for this project are in both hard-copy and electronic format. 

These formats are described below. 

14.1 HARDCOPY DATA DELIVERABLES 

Complete Level IV data packages are required. Hard-copy reporting of analytical results 

is defined in Table 14-1. The laboratory will be expected to provide data results (PDF 

format) in 10 working days and full Level IV packages 20 workings days from the time 

of receipt of samples. 

14.2 ELECTRONIC DATA DELIVERABLES 

To facilitate data handling and management, laboratory data may be entered into a 

computerized format. All data entered into the electronic data files will correspond 

identically to the data contained in the original laboratory reports and other documents 

associated with sampling and the laboratory hardcopy data deliverable packages. The 

format of the electronic data deliverable will be arranged between the Parsons data 

manager and the laboratory data management personnel. 

14-1 


334

Table 14-1 

Required Laboratory Deliverables by Analytical Technique 

LAUSD 


Deliverable GC/MS GC ICP IC 

Case Narrative X X X X 

Cross Reference of Parsons Sample Number, X X X X 

Laboratory Sample Number, and Analytical Batch 

Chain-of-Custody Form X X X X 

Results Summary for each sample and blank X X X X 

Tentatively identified compounds for each sample X 

and blank 

Laboratory control sample results - Identity of X X X X 

spiked analytes, amount spiked, amount 

recovered, % recovery, acceptance criteria 

Surrogates recovery X X 

MS/MSD recoveries X X X X 

Instrument performance check (tuning) X 

Initial calibration data X X X X 

Interelement correction factors X 

Interference check X 

Linear range determination X 

Continuing calibration data X X X X 

Second column calibration data X 

End-of-run sequence calibration verification X X X 

Internal standards areas and retention times X X 

Reconstructed ion chromatograms for each X 

sample, blank, spiked blank, and standard 

Chromatograms X 

Quantitation report for each sample listing all X X X X 

target analytes 

Raw and background subtracted mass for each X 

target analyte 

335

Table 14-1 

Required Laboratory Deliverables by Analytical Technique 

LAUSD 


Deliverable GC/MS GC ICP IC 

Mass spectra of TICs with library spectra of three X 

best fit matches 

Raw data and instrument printouts X X X X 

Copies of sample preparation work sheets X X X X 

Copies of run logs X X X X 

336

SECTION 15 

FINAL SAMPLE DISPOSITION 

Upon completion of all required analyses and acceptance of the data reported, the 

laboratory will be responsible for proper disposal of any remaining samples, sample 

containers, shipping containers, and Styrofoam or plastic packing materials in 

accordance with sound environmental practice, based on the sample analytical results. 

Unused samples and containers found to be nonhazardous generally will be disposed 

after 90 days following completion of the analysis. At 90 days, the laboratory will 

contact the Project Chemist to obtain approval for the samples to be disposed. In cases 

where the data package meets the project QA/QC requirements and no apparent 

anomalies are present in the data set, the Project Chemist may authorize the laboratory to 

dispose of the samples at an earlier date. The laboratory shall maintain proper records of 

waste disposal and shall have disposal company contracts on file for inspection. 

All raw and processed data generated during the analysis of project samples must be 

stored for a period of five years. Revised copies of the applicable SOPs and QAPs must 

also be maintained and available should the data be required. Should the laboratory go 

out of business, all original records related to project samples shall be provided to project 

personnel. 

15-1 


337

SECTION 16 

SUBCONTRACT LABORATORY SERVICES OTHER THAN THE PRIME 

LABORATORY 

The laboratory will assume responsibility for providing all analytical services specified in 

the laboratory subcontracting agreement. Should it be agreed in writing that the 

laboratory may use an additional subcontract laboratory facility, the primary laboratory 

will supply to the Task Manager the SOPs, MDL studies, and QA plans from the other 

laboratory that is used. The laboratory will be responsible for communicating all 

analytical guidelines and QC requirements of the project to this laboratory. Both QA 

Officers will monitor the data from each subcontract laboratory and correct any QC 

nonconformance. 

16-1 


338

SECTION 17 

REFERENCES 

American National Standards Institute/American Society for Environmental Programs. 

1994. “Specifications and Guidelines for Quality Systems for Environmental Data 

Collection and Environmental Technology Programs.” ANSI/ASQC E-4-1994. 

July (Draft). 

ASTM, 2000. D2488-00 Standard Practice for Description and Identification of Soils 

(Visual-Manual Procedure). 

Code of Federal Regulations Title 40, Part 136 (40 CFR 136) Appendix B. 

LARWQB. General Laboratory Testing Requirements for Petroleum Hydrocarbon 

Impacted Sites. 

Parsons, 2001. Draft Final Quality Assurance Project Plan for Los Angeles Unified 

School District, South Gate, California. October. 

Parsons, 2003. Draft Phase 1 Site-Wide Groundwater Monitoring Plan (GWMP), Former 

South Gate Schools Site, South Gate, California. October 29. 

Parsons, 2005. Draft Remedial Investigation Soil Sampling Workplan. Proposed 

Southeast Learning Complex Site. Ocotober. 

U.S. Environmental Protection Agency (USEPA). 1989. 1991a, and 1991b (Parts A, B, 

and C). Risk Assessment Guidance for Superfund, Volume 1: Human Health 

Evaluation Manual. 

USEPA. 1992. Quality Assurance Technical Information Bulletin, Creating SOP 

Documents. 

USEPA. 1994a. National Functional Guidelines for Organic Data Review. 

USEPA. 1994b. Guidance for the Data Quality Objectives Process, September. 

USEPA. 1995. Good Automated Laboratory Practices, in Principles and Guidance to 

Regulations for Ensuring Data Integrity in Automated Laboratory Operations. 

USEPA. 1996. Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, 

SW-846, (3rd Edition, Update III). 

USEPA 1999. EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5). 

USEPA. 2002. Region 9 Preliminary Remediation Goals (PRGs) 2002. October. 

17-1 


339

APPENDIX A 

COLUMN TEST FOR DETERMINING SORBED HEXAVALENT 

CHROMIUM 

340

APPENDIX A 

COLUMN TEST FOR DETERMINING SORBED HEXAVALENT CHROMIUM 

Heavy concentrations of hexavalent chromium have been found on one of the parcels of 

the Los Angeles Unified School District site in South Gate. In order to determine 

potential approaches to clean up the site it is necessary to know whether the hexavalent 

chromium is present only in the dissolved form in the groundwater or it is also sorbed on 

soil particles. If the hexavalent chromium is present in the sorbed form, its presence 

could potentially be of much greater duration. 

In the saturated zone water is present both free flowing among the solid particles and in 

pores and cavities within the particles. Thus, when the sample of soil is filtered, a 

significant amount of the hexavalent chromium may still be present as dissolved 

hexavalent chromium. The dissolved hexavalent chromium in the pores contains the 

same concentration of hexavalent chromium as the groundwater. In order to assess 

whether all the hexavalent chromium is dissolved or some of it is adsorbed, it is 

necessary to leach all the hexavalent chromium out of the soil. In so doing the dissolved 

hexavalent chromium will leach out first, followed by the sorbed material. 

The testing to determine if a significant amount of hexavalent chromium is present as 

dissolved material consists of determining if the total amount of hexavalent chromium 

recoverable from the soil exceeds the amount which would be present in the water 

retained by the soil. 

Procedure 

1. Collect a sample of saturated zone soil and a sample of the groundwater 

preferably from the same boring and at the same depth. Both samples must be 

taken from a location known to contain hexavalent chromium. 

2. Filter the groundwater and determine the concentration of hexavalent 

chromium in the groundwater. 

3. Take a 1 – 5 gram sample of the soil and place it in a tared glass dish to 

determine the water content of the soil. Weigh the dish with the sample and 

subtract the weight of the dish to determine the exact weight (W1) of the 

sample. Do not use aluminum pans because hexavalent chromium, if present 

in significant concentrations in the soil, will corrode the aluminum. 

4. Dry the soil at 100 – 105 o C to constant weight. Determine the weight of the 

dry sample (W2) by subtracting the weight of the dish from the weight of the 

dish with the dry sample. 

5. Determine the weight of the water in the sample by subtracting the dry weight 

of the sample from the wet weight of the sample (W1 – W2). If one assumes a 

341

specific gravity of 1 for water, then the weight and the volume of water are 

numerically equal. 

6. Take a glass column equipped with a stopcock at the bottom (such as a buret), 

and place a glass wool plug at the bottom of the column. 

7. Weigh out a 50 gram sample (W3) of the wet soil and transfer it into the 

column above the glass wool plug. 

8. Compact the soil in the column as much as possible. 

9. Add 100 mL laboratory pure water to the top of the column, open the 

stopcock, and collect the effluent from the column. 

10. Wait for the water to nearly pass entirely through the column. If the water 

coming off the column is colored (any shade of yellow through rust) do not 

collect any sample for analysis, just collect the total effluent. When the water 

is no longer colored, start collecting the samples for analysis at 100 mL 

intervals. 

11. Repeat steps 9 and 10 until hexavalent chromium is no longer detected in the 

1 mL taken for testing. 

12. Pass a maximum of 500 mL before setting the collected samples for testing 

for hexavalent chromium. Run the last collected fraction first. If it shows 

hexavalent chromium, don't bother with testing the other samples. If it doesn't 

show hexavalent chromium, continue testing the samples in reverse order. 

13. When hexavalent chromium is no longer detectable in the leachate, measure 

the total volume (VL) of water that was passed through the column, and 

determine the hexavalent chromium concentration in the combined leachates 

(CL). 

14. Determine the volume of water held by the sample in the column 

V = W3 x [(W1 – W2)/W1] 

15. Determine the concentration of the hexavalent chromium in the water that was 

held by the sample 

C = CL x VL/V 

16. If the determined hexavalent chromium in step 14 is significantly greater than 

the concentration of the hexavalent chromium in the groundwater, then a 

significant contribution is due to adsorbed hexavalent chromium. If the 

determined hexavalent chromium in step 14 is approximately equal to or is 

342

smaller than the concentration of the hexavalent chromium in the 

groundwater, then there is no adsorption effect. 

343

APPENDIX I 

Transportation Management Plan 

344

TRANSPORTATION MANAGEMENT PLAN 

for 

Proposed South Region High School #9 

and Middle School #4 Sites 

Operable Unit 1 

Remedial Action Plan 


Prepared For: 



1055 West 7 th Street, 10 th Floor 


August 2008 

345

Prepared by 

PARSONS 

100 WEST WALNUT STREET • PASADENA • CALIFORNIA 91124 

TABLE OF CONTENTS 

TRANSPORTATION PLAN ................................................................................I-1 

Project Overview.................................................................................................I-1 

Project Coordination ...........................................................................................I-1 

Drivers ................................................................................................................I-1 

Training...............................................................................................................I-2 

Equipment...........................................................................................................I-2 

Project Schedule and Truck Staging...................................................................I-2 

Truck Loading .....................................................................................................I-3 

Truck Routing......................................................................................................I-3 

Dry Truck Decontamination ................................................................................I-3 

DOT Certifications...............................................................................................I-3 

Manifesting .........................................................................................................I-3 

Placarding...........................................................................................................I-4 

Traffic Control .....................................................................................................I-4 

Transportation Route ..........................................................................................I-4 

Spill Contingency and Spill Mitigation Plan .........................................................I-5 

Communication...................................................................................................I-6 

Figures 

I-1 Site Vicinity Map 

I-2 Parcel Location Map 

I-3a Off-Site Truck Transportation Route – Kettleman Hills 

I-3b Off-Site Truck Transportation Route - TRS 

I-4 On-Site Truck Transportation Route 

346

TRANSPORTATION PLAN 

This transportation plan describes waste transportation activities associated with 

the Operable Unit 1 of Los Angeles Unified School District (LAUSD) South 

Region High School #9 and Middle School #4 (Site) soil removal project located 

in South Gate, California (Figure I-1). Operable Unit 1 consists of soil and soil 

gas in Parcels 1 through 4, 29 through 33, and 35 through 39 (Figure I-2). The 

area surrounding the Site is used for a variety of purposes including industrial, 

commercial and residential use. Residential neighborhoods are located 

immediately north and south of the Site. The area to the west of the Site 

includes industrial and commercial operations, including an auto body shop, a 

wheel polishing facility, an electrical supply company, and restaurants. The Los 

Angeles River is located at the eastern boundary of the Site. 

The tentatively proposed off-site waste disposal facilities are the Chemical Waste 

Management Kettleman Hills Facility located in Kettleman City, California to 

accept TSCA waste, RCRA-Hazardous Waste and California Hazardous Waste 

for disposal, and Thermal Remediation Solutions (TRS) located in Azusa, 

California for Non-Hazardous Waste for disposal. This Transportation Plan may 

require updating following final selection of off-site disposal facilities (and any 

import soil sources). 

Project Overview 

This Transportation Management Plan supports proposed soil removal activities 

for OU1 to be implemented by the LAUSD (and its contractors) under a voluntary 

cleanup agreement (VCA) with the Department of Toxic Substances Control 

(DTSC). An estimated soil volume of 29,920 cubic yards will be excavated and 

transported for off-site disposal with duration of 26 weeks. The waste 

transportation contractor (“waste transporter”) will be responsible for profiling, 

manifesting, placement of truck tarps, and transporting the impacted soil and any 

other waste to the disposal facility. Stockpile sampling, waste characterization, 

soil loading, dust suppression, truck decontamination, and traffic control will be 

performed by other contractors performing remedial activities. The soil contains 

elevated concentrations of arsenic, lead, various other inorganic, PAHs, PCBs, 

several VOCs, and TPH. 

Project Coordination 

The waste transporter will provide a Project Manager to coordinate and manage 

all activities related to waste transportation throughout the project. The Project 

Manager will be responsible for implementing the Scope of Work including all 

aspects of the Site Specific Health and Safety Plan. 

Drivers 

The waste transporter will provide the necessary trucks to the project site each 

operating day for the duration of the transportation phase to complete the off-site 

I-1 

347

emoval of impacted soils. Waste transportation on the project is anticipated to 

occur on business days between hours of approximately 7:00 am to 4:00 pm 

throughout the project duration. It is anticipated that trucks will be on-site for up 

to 1 hour for staging/loading and will be at the disposal facility for up to 1 hour for 

offloading. 

Training 

The waste transporter will ensure that all drivers staffed for this project will have 

all the necessary DOT training, licenses and permits to complete the 

transportation phase of the project. Documentation will be provided by the 

waste transporters to the LAUSD indicating that truck drivers for this project have 

been recently road tested and tested for dumping procedures. The Project 

Manager for the waste transporters will participate in weekly staff safety meetings 

and, as necessary, tailgate safety meetings. 

Equipment 

Drivers will cover loaded trailers with solid one-piece tarps during transport of all 

soils off the Site. The waste transporter(s) will maintain a consistent truck fleet for 

the duration of the project. This ensures consistent transportation procedures 

and minimizes training. As part of the transport contractor requirements: 

1. All trucks will have been inspected by the California Highway Patrol. 

2. Every driver will perform and record daily safety inspections. 

3. Trucks also will be subject to monthly terminal inspections; and 

4. Trucks are to be serviced and thoroughly inspected every 30 days. 

The waste transporter will maintain documentation of these inspections and 

maintenance records, and will make them available to the LAUSD upon request. 

Project Schedule and Truck Staging 

The waste transporter will stage empty trucks in a consistent location at the Site. 

Truck drivers will be provided truck route map(s) (Figures I-3a and I-3b) to each 

facility along with specific route directions at the beginning of the project. Maps 

and directions will be available on-site for the duration of the project. 

The proposed locations of the temporary soil storage area are shown on Figure I- 

4. The proposed location of the load-out and staging areas will generally be 

adjacent to soil excavation areas as identified in Figure I-4. On a daily basis, the 

waste transporter will provide a truck schedule with the total expected number of 

truck loads that are expected to cycle through each disposal facility for each work 

day (i.e., this will approximately equate to the number of trucks loaded for each 

work day). 

I-2 

348

Truck Loading 

No excavated material shall extend above the sides or rear of the truck. Prior to 

covering/tarping the soil shall be wetted by spraying with mist inhibitors. The 

truck shall be completely covered/tarped prior to leaving the site. The exterior of 

the truck shall be cleaned off prior to the truck leaving the site. 

Truck Routing 

The waste transporter will route trucks to and from the site as described in the 

“Transportation Route” section of this plan. Trucks will use established public 

roads that accommodate daily commercial truck traffic. Truck arrivals and 

departures will be staggered to minimize traffic impacts in the project area. The 

on-site truck route may be modified based on field conditions. 

Dry Truck Decontamination 

Trucks will be manually dry brushed to remove loose soil from transportation 

trailers or trucks in the Truck Loading Areas prior to leaving the work area or as 

directed by the on-site Project Manager. As necessary, exterior contamination 

will be removed by dry brushing until bulk visible contamination is removed. If 

necessary, additional truck decontamination areas will be located near the exit 

onto the public roadways. 

DOT Certifications 

The waste transporter will maintain all DOT certifications and maintain copies of 

certifications for the duration of the project. The waste transporter will transport 

waste soils in accordance with all local, County, State, and Federal regulations 

(49 CFR Parts 100 to 177). 

Manifesting 

The waste transporter or, at the discretion of the LAUSD, the remediation 

contractor, will provide Uniform Hazardous Waste Manifests for the generator’s 

(LAUSD, or designee) signature. For non-hazardous waste transport and 

disposal, a non-hazardous waste manifest, bill of lading, or generator-approved 

equivalent will be used. Each load transported from the project site will be 

manifested. 

The waste transporter’s (or remediation contractor’s) Project Manager will be 

responsible for on-site management of manifests. The manifests will be preprinted 

with generator’s information for signature by the LAUSD or their assigned 

agents. Manifests will be presented to the LAUSD or the LAUSD’s designated 

agent for signature 48 hours in advance of the shipping date/time. As an 

alternative, the manifest may be hand carried to the Site to obtain signatures of 

the LAUSD or their designated agents if these arrangements are acceptable to 

LAUSD. All efforts will be made to avoid waste shipment delays caused by 

manifests not being provided for signature in advance. 

I-3 

349

Trucks entering the receiving facility will have manifests signed by landfill 

personnel and the appropriate copies archived at the facility and the generator’s 

copies forwarded to the waste transporter with certified weight tickets and 

invoices. 

All appropriate records that document transportation of waste will be maintained 

on-site and provided to the LAUSD, including the following: manifests, bills of 

lading, weight tickets, waste analyses or waste profile sheets, certifications of 

final treatment/disposal signed by the responsible disposal facility official, and 

land disposal notifications. 

Classification/profiling of waste prior to manifesting shall be the responsibility of 

the waste transporter (or remediation contractor). 

Placarding 

Trucks will have placards displayed according to DOT regulations. 

Traffic Control 

Traffic control to manage truck traffic during loading operations will be provided 

by the remediation contractor. Traffic control measures in public roadways will 

be in compliance with City of South Gate requirements. On-site traffic control 

measures will include signs, cones, and delineators, as necessary to route trucks 

through the staging and loading area and then off Site. Transport drivers will 

follow the on-site traffic control plan and/or instructions from traffic control 

personnel during staging, loading, ingress, and egress activities. The proposed 

location of truck entrance and exit will be at the intersection of Tweedy Blvd and 

Atlantic Ave (see Figure I-4). Traffic control, if necessary, will be used at the 

ingress/egress and staging areas and will consist of personnel with handheld 

sign(s) indicating slow/stop. Trucks will be coordinated and routed in a manner 

that avoids truck traffic on surrounding residential streets. Trackout of dirt onto 

public roadways will be minimized by implementing effective decontamination 

vehicle procedures. On a daily basis, a street sweeper will be used in Tweedy 

Boulevard east of Atlantic Boulevard as a secondary measure to control track out 

of soil onto the public roadway. 

Transportation Route 

The Project Manager will instruct all drivers on the specific haul routes and 

alternate routes prior to commencing transport activities at the site. The 

transport route(s) will be strictly adhered to with no exceptions. Should the route 

be closed due to inclement weather or other emergency road conditions, the 

transport driver will contact the Project Manager with the information and the 

Project Manager will provide an alternate route until original route is available. 

The transportation route(s) consists of primary surface streets, Highways and 

improved roads that allow access to end dump trucks and trailers. 

The tentatively proposed off-site waste management facilities are the Chemical 

Waste Management Kettleman Hills Facility located in Kettleman City, California 

I-4 

350

to accept TSCA Waste, RCRA-Hazardous Waste, RCRA and TSCA Waste, and 

Non-RCRA California Hazardous Waste, and Thermal Remediation Solutions 

(TRS) located in Azusa, California for Non-Hazardous Waste. This 

Transportation Plan may require updating following identification of off-site 

remedial soil management facilities (and any import soil sources). For the 

purposes of this plan, on-site and off-site transport truck routes have been 

identified to both Ketteman Hills and TRS. The designated transportation route is 

described below and in Figures I-3a and I-3b. 

From the Site to Chemical Waste Management Kettleman Hills Facility 

Directions Distance (miles) Total Distance (miles) 

1: Exit the site at Adella Ave & Tweedy Blvd 

2: Turn RIGHT (west) onto Tweedy Ave 0.2 0.2 

3: Turn RIGHT onto Atlantic Ave 0.3 0.5 

4: Slight RIGHT at Rayo Ave 0.5 1.0 

5: Turn RIGHT at Firestone Blvd 0.4 1.4 

6: Slight RIGHT to merge onto I-710 N toward Pasadena 4.8 6.2 

7: Take I-5 N exit on the LEFT toward Los Angeles 0.4 6.6 

8: Continue to follow I-5 N 178 184.6 

9: Take exit 309 for CA-41 S 0.4 185 

10: Turn LEFT (South) at CA-41 S 2.8 187.8 

11: Turn RIGHT (North) at Old Skyline Dr 1.7 189.5 

12: Proceed to facility entrance (35251 Old Skyline Road) 

From the Site to TRS 

Directions Distance (miles) Total Distance (miles) 

1: Exit the site at Adella Ave & Tweedy Blvd 

2: Turn RIGHT (west) onto Tweedy Ave 0.2 0.2 

3: Turn RIGHT onto Atlantic Ave 0.3 0.5 

4: Slight RIGHT at Rayo Ave 0.5 1.0 

5: Turn RIGHT at Firestone Blvd 0.4 1.4 

6: Slight RIGHT to merge onto I-710 N toward Pasadena 5.7 7.1 

7: Take the Pomona Fwy E/CA-60 E exit toward Pomona 1.1 8.2 

8: Merge onto CA-60 E/Pomona Fwy 7.6 15.8 

9: Take the exit onto I-605 N 6.1 21.9 

10: Take exit 25 for Live Oak Ave toward Irwindale 0.2 22.1 

11: Keep RIGHT at the fork to continue toward Live Oak 1.2 23.3 

Ave and merge onto Live Oak Ave 

12: Continue on Arrow Hwy 2.1 25.4 

13: Turn LEFT at Vincent Ave 0.5 25.9 

14: Turn RIGHT at W Gladstone St

Communication 

Truck drivers will have CB Radios or cellular phones for accessibility during 

project activities. The transportation coordinator will have direct access to each 

driver at all times via one or both modes of communication. 

I-6 

352

APPENDIX J 

Cost Estimate for Remedial Alternatives 

358

Table J-1 

South Region High School #9 and Middle School #4 Operable Unite (OU) 1 

Alternative 2 (Excavation and Off-Site Disposal) 

Summary of Cost Estimate 

CLEANUP - Operable Unit 1 (North of Tweedy Blvd) Quantity (1) 

Project Plans and Design 

Units Cost per Unit Total Cost 

Additional Remedial Investigation 0 LS $ 50,000 $ - 

Remedial Investigation/Health Risk Assessment Reporting 0 LS $ 100,000 $ - 

Feasibility Study/Remedial Action Plan 

Plans 

0.5 LS $ 100,000 $ 50,000 

Site Survey 50 hours $ 185 $ 9,250 

Excavation & Grading Plans/Specs 1 LS $ 25,000 $ 25,000 

Erosion Control Plan 1 LS $ 5,000 $ 5,000 

RDIP 1 LS $ 50,000 $ 50,000 

Environmental QA/QC Plan 1 LS $ 8,000 $ 8,000 

Public Participation (meetings, fact sheets, etc.) 250 hours $ 150 $ 37,500 

Permitting 

Subcontractor Submittals 

1 LS $ 15,000 $ 15,000 

Execution Plan Development & Review 1 LS $ 7,000 $ 7,000 

Health & Safety Plan 1 LS $ 5,000 $ 5,000 

Subcontractor QA/QC Plan 

Subcontractor(s) Mobilization/Site Preparation 

1 LS $ 5,000 $ 5,000 

Mobilization 1 LS $ 25,000 $ 25,000 

Perimeter Air Monitoring System Installation / 3 Months Operation 3 Sta $ 3,500 $ 10,500 

Temporary Fencing & Delineation (6' Chn Lnk - rented) 500 LF $ 10 $ 5,000 

Dust Control 45 Daily $ 850 $ 38,250 

Stormwater Pollution and Prevention Plan 1 LS $ 25,000 $ 25,000 

Erosion Control / Stormwater Setup 1,000 Snd Bgs $ 10 $ 10,000 

Clearing & Grubbing (with Disposal) 2 acre $ 10,000 $ 20,000 

Concrete and Asphalt Removal (removal and disposal) 5,000 tons $ 50 $ 250,000 

Survey / Stake Excavation Plan 

Abandonment & Replacement of Groundwater Wells 

100 hours $ 300 $ 30,000 

Abandonment of one "C" zone and seven "A" zone wells 370 LF $ 73 $ 27,133 

Labor 160 hours $ 100 $ 16,000 

Driller Subcontractor (7 "A" Zone Wells 1 "C" Zones Well) 370 feet $ 75 $ 27,750 

Labor 160 hours $ 100 $ 16,000 

Permitting 

Shoring & Dewatering 

16 per permit $ 200 $ 3,200 

Design 1 LS $ 25,000 $ 25,000 

Parcel 38 (2) - Soldier Pile shoring for 30 ft excavation 3,600 SF $ 40 $ 144,000 

- Leave steel in place 220 Ton $ 900 $ 198,000 

- Dewatering 1 LS $ 25,000 $ 25,000 

Parcel 39 (3) - Soldier Pile shoring for 30 ft excavation 9,000 SF $ 40 $ 360,000 

Parcel 39 (4) - Trench Box shoring for 10 ft excavation 1 LS $ 25,000 $ 25,000 

Parcel 29 (5) - Trench Box shoring for 10 ft excavation 

Excavation & Disposal 

1 LS $ 25,000 $ 25,000 

Excavation of Impacted Soils (unsaturated only) 47,610 ton $ 15 $ 714,150 

Export Soils/Waste Characterization 79 1/500 CY $ 500 $ 39,675 

Excavation of Sloped/Non-Impacted Soils with Stockpile Mgmt (6) Loading, Transportation & Off-Site Disposal 

13,900 ton $ 17 $ 236,300 

RCRA - Land ban (0%) - ton $ 198 $ - 

RCRA / TSCA - Direct Landfill 2,273 ton $ 198 $ 449,955 

Non-RCRA (Cal) 4,485 ton $ 100 $ 448,500 

RCRA&TSCA - Direct Landfill 233 ton $ 240 $ 55,800 

Non Hazardous 40,620 ton $ 56 $ 2,274,720 

Confirmation Survey 70 hours $ 185 $ 12,950 

Field Labor (cleanup field effort, 4 FTEs, 26 weeks) 4,160 hours $ 100 $ 416,000 

Air Monitoring Samples (Cr6+, Arsenic, PM10) 

Utility Protection 

55 3/Sta/Day $ 120 $ 6,600 

(7) 

Parcel 38 1 LS $ 10,000 $ 10,000 

Parcel 39 1 LS $ 10,000 $ 10,000 

Adella Avenue 1 LS $ 20,000 $ 20,000 

General 

Confirmation Sampling (Total SF) 

1 LS $ 10,000 $ 10,000 

Soil Gas Sampling 1 LS $ 25,000 $ 25,000 

Bottom Sampling 

200 1/500 sf $ 250 $ 49,927 

Sidewall Sampling (1 sample for shallow excavation [>15ft], 2 samples for 116 samples $ 250 $ 29,000 

J-1 

359

Table J-1 

South Region High School #9 and Middle School #4 Operable Unite (OU) 1 

Alternative 2 (Excavation and Off-Site Disposal) 



Geotechnical Engineering Consultant 


Review of Test Results and Plans 80 hours $ 120 $ 9,600 

Field Oversight 160 hours $ 120 $ 19,200 

Compaction Testing 

Backfill & Compaction 

1 LS $ 25,000 $ 25,000 

Field Oversight 1 LS $ 25,000 $ 25,000 

Import Soil (LAUSD, DTSC Specifications) (8) 47,610 ton $ 23 $ 1,095,030 

Soil Import Geotechnical / Chemical Analysis 20 1/2000 CY $ 1,000 $ 19,838 

Parcel 38 Backfill with gravel up to 18 ft bgs (9) 1,500 CY $ 50 $ 75,000 

Backfill & Compaction (import soil and sloped/non-impact soil) 59,260 ton $ 15 $ 888,900 

Contingency Measures 

Field Labor and Oversight (all contingency measures) 440 hours $ 120 $ 52,800 

Vapor Monitoring Wells (7 sets of multiple screened wells) 420 linear ft $ 100 $ 42,000 

Groundwater Monitoring Wells (2 "A"-zone wells) 90 linear ft $ 100 $ 9,000 

Impermeable Vertical Vapor Membrane (materials & application) 9,000 sq. ft $ 5 $ 45,000 

Installation of SVE Piping (10) 

350 linear ft $ 75 $ 26,250 

Construction of Treatment Pad, including Utilities (10) 

1 LS $ 20,000 $ 20,000 

Site Restoration 

Interim Cover - Hydroseed 1 LS $ 200,000 $ 200,000 

Regrade Site 11,095 SY $ 3 $ 29,586 

Demobilization 1 LS $ 25,000 $ 25,000 

Closure Report (includes compaction report) 1 LS $ 150,000 $ 150,000 

GENERAL CLEANUP - Operable Unit 1 (North of Tweedy Blvd) $ 9,088,364 

General Conditions 

Project Management/Construction Administration/Technical Eval. 15 % $ 1,363,255 

Escalation 5 % $ 454,418 

Contingency 15 % $ 1,363,255 

Markup Total $ 3,180,927 

TOTAL GENERAL CLEANUP COSTS POST MARKUP $ 12,269,292 

Notes: 

(1) Estimated quantities (i.e., number of units) used are based on the current understanding of site condition; during implementation of the remedy, 

actual ( ) quantities p may vary due to the field conditions or logistical gconsiderations encountered during remediation. p ( g ) p p 

6 feet apart (not 6 feet on-center), and wood lagging will be installed on soldier piles to a depth of 30 feet along a 120 ft section. Steel beams will be 

left in place after the excavation ("sacrificed"). For excavation to 30 ft bgs (below "A1" zone groundwater occurring at ~19 ft bgs) at Parcel 38, 

dewatering will be required. For cost estimating, it is a assumed dewatering will involve pumping, containment, and disposal of 11,000 gallons of 

"A1" zone groundwater. 

(3) Soldier piles will be as described above (30-inch dia boreholes at 6 ft spacing, with steel I-beams to 65 ft bgs, and lagging to 30 ft bgs), except 

that the steel I-beams will be removed from the 30-ich dia boreholes (steel will be re-used), and lagging will be installed along a 300 ft section. 

(4) Trench box shoring will be installed to allow excavation to 10 ft bgs along a 100 ft section of the property. 

(5) Trench box shoring will be installed to allow excavation to 10 ft bgs along a 100 feet section of the property. 

(6) Non-impacted soil excavated during the remedial action, including soil excavated to allow sloping back of the excavation, will be used as backfill 

to restore the site to final grade. 

(7) Utility protection assumes only temporary "in-place" protection of underground utilities will be required, but does not include re-routing of 

underground utilities. Utility protection in Adella Avenue includes an active gas line within the excavation footprint and, therefore, this utility protection 

has a highest associated cost. 

(8) Backfill costs include placement of approximately 800 cy of cement bentonite slurry at the base of the 30-foot deep excavation at Parcel 39. 

(9) Due to the complications of backfilling between 30 and 18 ft bgs (i.e., below the "A1" groundwater), it is assumed gravel will be used as backfill 

from the excavation bottom (30 ft bgs) to 18 ft bgs. 

(10) Under Installation of SVE Piping" and "Construction of Treatment Pad", does not include capital costs for purchase of treatment systems (other 

than installation of piping runs) or costs for operation and maintenance of SVE treatment system. 

J-2 

360

Table J-2 

South Region High School #9 and Middle School #4 Operable Unit (OU) 1 

Alternative 3 (Excavation, On-Site Stabilization, Off-Site Disposal) 



Project Plans and Design 


Additional Remedial Investigation 0 LS $ 50,000 $ - 

Remedial Investigation/Health Risk Assessment Reporting 0 LS $ 100,000 $ - 

Feasibility Study/Remedial Action Plan 0.5 LS $ 100,000 $ 50,000 

Treatability Study 

Plans 

1 LS $ 20,000 $ 20,000 

Site Survey 50 hours $ 185 $ 9,250 

Excavation & Grading & On-site Treatment Facility Plans/Specs 1 LS $ 40,000 $ 40,000 

Erosion Control Plan 1 LS $ 5,000 $ 5,000 

RDIP 1 LS $ 50,000 $ 50,000 

Environmental QA/QC Plan 1 LS $ 12,000 $ 12,000 

Public Participation (meetings, fact sheets, etc.) 250 hours $ 150 $ 37,500 

Permitting 

Subcontractor Submittals 

1 LS $ 30,000 $ 30,000 

Execution Plan Development & Review 1 LS $ 12,000 $ 12,000 

Health & Safety Plan 1 LS $ 8,000 $ 8,000 

Subcontractor QA/QC Plan 

Subcontractor(s) Mobilization/Site Preparation 

1 LS $ 8,000 $ 8,000 


Perimeter Air Monitoring System Installation / 3 Months Operation 3 Sta $ 3,500 $ 10,500 

Temporary Fencing & Delineation (6' Chn Lnk - rented) 500 LF $ 10 $ 5,000 

Dust Control 60 Daily $ 850 $ 51,000 

Stormwater Pollution and Prevention Plan 1 LS $ 30,000 $ 30,000 

Erosion Control / Stormwater Setup 1,500 Snd Bgs $ 10 $ 15,000 

Clearing & Grubbing (with Disposal) 2 acre $ 10,000 $ 20,000 

Concrete and Asphalt Removal (removal and disposal) 5,000 tons $ 50 $ 250,000 

Survey / Stake Excavation Plan 

Abandonment & Replacement of Groundwater Wells 

100 hours $ 300 $ 30,000 

Abandonment of one "C" zone and seven "A" zone wells 370 LF $ 73 $ 27,133 

Labor 160 hours $ 100 $ 16,000 

Driller Subcontractor (7 "A" Zone Wells 1 "C" Zones Well) 370 feet $ 75 $ 27,750 

Labor 160 hours $ 100 $ 16,000 

Permitting 

Shoring & Dewatering 

16 per permit $ 200 $ 3,200 

Design 1 LS $ 25,000 $ 25,000 

Parcel 38 (2) - Soldier Pile shoring for 30 ft excavation 

3,600 SF $ 40 $ 144,000 

- Leave steel in place 220 Ton $ 900 $ 198,000 

- Dewatering 1 LS $ 25,000 $ 25,000 

Parcel 39 (3) - Soldier Pile shoring for 30 ft excavation 

9,000 SF $ 40 $ 360,000 


1 LS $ 25,000 $ 25,000 


Excavation & Disposal 

1 LS $ 25,000 $ 25,000 

Excavation of Impacted Soils (unsaturated only) 47,610 ton $ 15 $ 714,150 

Export Soils/Waste Characterization 79 1/500 CY $ 500 $ 39,675 

Excavation of Sloped/Non-Impacted Soils with Stockpile Mgmt (6) Loading, Transportation & Off-Site Disposal 

13,900 ton $ 17 $ 236,300 

RCRA - Land ban (0%) - ton $ 198 $ - 

TSCA - Direct Landfill 533 ton $ 198 $ 105,435 

Non-RCRA (Cal) (7) 4,561 ton $ 100 $ 456,113 

RCRA&TSCA - Direct Landfill - ton $ 240 $ - 

Non Hazardous (7) 42,715 ton $ 56 $ 2,392,026 

Confirmation Survey 70 hours $ 185 $ 12,950 

Field Labor (cleanup field effort, 4 FTEs, 33 weeks) 5,280 hours $ 100 $ 528,000 

Air Monitoring Samples (Cr6+, Arsenic, PM10) 

On-Site Stabilization 

70 3/Sta/Day $ 120 $ 8,400 


RCRA Soil Processing 2,200 ton $ 27 $ 59,400 

Cal-Haz Soil Processing 1,990 ton $ 29 $ 57,710 

Confirmation Sampling 42 1/100 ton $ 500 $ 20,950 

J-3 

361

Table J-2 





Utility Protection 


(8) 

Parcel 38 1 LS $ 10,000 $ 10,000 

Parcel 39 1 LS $ 10,000 $ 10,000 

Adella Avenue 1 LS $ 20,000 $ 20,000 

General 

Confirmation Sampling (Total SF) 

1 LS $ 10,000 $ 10,000 

Soil Gas Sampling 1 LS $ 25,000 $ 25,000 

Bottom Sampling 200 1/500 sf $ 250 $ 49,927 

Sidewall Sampling (1 sample for shallow excavation [

Table J-2 




(6) Non-impacted soil excavated during the remedial action, including soil excavated to allow sloping back of the excavation, will be 

used as backfill to restore the site to final grade. 

(7) For costing purposes, it was assumed that the RCRA-hazardous waste would be stabilized to California-hazardous waste levels and 

that California-hazardous waste would be stabilized to non-hazardous waste. This would be dependent upon the results of the 

treatability testing 

(8) Utility protection assumes only temporary "in-place" protection of underground utilities will be required, but does not include rerouting 

of underground utilities. Utility protection in Adella Avenue includes an active gas line within the excavation footprint and, 

therefore, this utility protection has a highest associated cost.. 

(9) Backfill costs include placement of approximately 800 cy of cement bentonite slurry at the base of the 30-foot deep excavation at 

Parcel 39. 

(10) Due to the complications of backfilling between 30 and 18 ft bgs (i.e., below the "A1" groundwater), it is assumed gravel will be 

used as backfill from the excavation bottom (30 ft bgs) to 18 ft bgs. 

(11) Under Installation of SVE Piping" and "Construction of Treatment Pad", does not include capital costs for purchase of treatment 

systems (other than installation of piping runs) or costs for operation and maintenance of SVE treatment system. Construction of 

concrete pad includes cost for installation of underground water line and electrical conduit to pad. 

J-5 

363

APPENDIX K 

Responses to DTSC Comments on 

the Draft OU 1 RAP 

364

RESPONSES TO COMMENTS FROM DTSC DATED JULY 22, 2008 

DRAFT OPERABLE UNIT 1A REMEDIAL ACTION PLAN 

PROPOSED SOUTH REGION HIGH SCHOOL #9 AND MIDDLE SCHOOL #4, SOUTH GATE (#304440) 

Comment 

Number 

Comment Response 

Comments from Joe Hwong, P.G. C. HG. General Comments 

1 Since OU4 is newly added to the Operable Units at the Site, its 

cover area should be clearly defined in the revised RAP. In 

addition, Figures 1-2 and 2-1 should be re-drawn to depict 

OU4's boundary. 

2 Figure 3-1 - If Area OU1B does no longer exist during future 

remedial activities, DTSC recommends it be removed from the 

OU1A RAP and Figure 3-1. 

3 Incorporate the DTSC Geologist's comments in the revised 

OU1A RAP. 

Comments from Bruce Garbaccio, P.G. General Comments 

1 The RAP discusses volumes of soil to be segregated as RCRA 

waste, California Hazardous, TSCA waste, and non-hazardous 

waste. DTSC recommends that a map be included that shows 

the areas with each waste type. 

2 Confirmation Sampling - The text (Sections 5.3 and 7.6.2) 

describes confirmation sampling procedures. They indicate a 

sampling rate of 1 per 500 square feet will be collected. DTSC 

concurs with the strategy for the bottom samples, which gives 

Page 1 of 2 

(7/28/08) 

Response – Information regarding OU 4 has been detailed and 

appropriate changes made in the revised RAP to Figures 1-2 and 2-1 to 

reflect the location of the OU 4 boundary. In addition, newly 

designated OU 5 (Tweedy Boulevard west of Adella Avenue) has been 

depicted. 

Response – Comment noted. The revised RAP, including Figure 3-1, 

has been modified to remove reference to Areas A and B. 

Response – Responses to the DTSC Geologist’s comments have been 

incorporated in the revised OU 1 RAP. 

Response – A map outlining the locations of different waste types has 

been added to the revised RAP and is included as Figure 5-1. This is an 

estimate based on available site characterization data. Also note that a 

portion of the waste is classified as both a TSCA waste (because of 

PCBs) and as a RCRA waste (because of metals). The waste estimates 

in the revised RAP have been revised to reflect this. 

Response – Additional soil confirmation samples will be collected at a 

rate of one sample per 20 to 30 of linear feet of sidewall. Figure 5-2 has 

been revised to reflect additional confirmation sampling at Parcel 29. 

This includes new samples 029-PC054 through 029-PC076. 

365

one sample per approximately 22 by 22 foot area. However, 

DTSC recommends that sidewall samples be collected at a rate 

of 1 sample per 20 to 30 linear feet of sidewall. Based on the 

spacing shown on Figure 5-2, the spacing is good in all areas 

except for the excavation on the east side of Parcel 29. They 

should add a few samples there. 

Page 2 of 2 

(7/28/08) 

366

(9/3/08) 

RESPONSES TO COMMENTS FROM DTSC DATED AUGUST 29, 2008 

FINAL OPERABLE UNIT 1 REMEDIAL ACTION PLAN 


Comment 

Number 


Comments from Joe Hwong, P.G. C. HG. General Comments 

1 Because use of school-base scenario for soil gas 

cleanup goals, a land use covenant is required 

and included in the RAP. 

Response – The RAP has been modified to indicate that land use controls will be 

implemented. The following text has been incorporated into a new subsection 7.10 

Land Use Controls. 

“Upon completion of soil removal activities and prior to school occupancy, the 

LAUSD will, under DTSC oversight, establish appropriate temporary land use controls 

at three sub-areas within OU 1 (see Figure 7-3). The three areas consist of the safety 

buffer zone on Parcel 39 (see Section 5.3), a small area in the central portion of Adella 

Avenue, and portions of Parcels 29 and 30 adjacent to Burtis Street. These land use 

controls may be necessary because soil gas VOCs in these areas may not achieve 

unrestricted-use cleanup levels because of off-Site sources (Parcel 39 and 29/30) and 

the need for flexibility in addressing critical underground utility protection issues 

(Adella Avenue). These three areas will achieve soil gas cleanup levels that are 

protective of school-based receptors including staff and students. It is intended that 

these land use controls will be temporary measures to ensure that the land use in these 

three areas remain as currently designed without prior notification to the DTSC until 

such time as the regulatory agencies address the identified offsite sources. 

Specifically, the controls will specify that land use in these three areas remain as 

currently designed until it can be determined that conditions are protective of an 

unrestricted (residential) land use. If DTSC-approved post-cleanup soil gas 

confirmation sampling at Adella Avenue meets the unrestricted use soil gas RGs, then 

no land use controls will be required in this area. 

Any proposed changes to the land use in these three areas would be subject to DTSC 

approval. Additional details regarding these land use controls, including a legal 

description of each sub-area, will be documented in the O&M Plan.” 

Page 1 of 5 

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(9/3/08) 

2 Details soil gas monitoring wells construction 

and sampling frequency and their action levels 

during the O & M plan will be required after the 

excavation activities are completed. 

Comments from Bruce Garbaccio, Geologist General Comments 

1 Section 7.6.2 Confirmation Sampling - They 

should reference EPA Method 5035 for field 

preservation in this section. The text indicates 

the rate of sampling for bottom samples, but 

does not for sidewall samples. 

2 Figure 5-1 Soil Hazardous Waste 

Classifications - They have included a map 

showing areas with waste designation for 

disposal (TSCA, RCRA, Cal-Haz, etc.) as we 

had requested. 

3 Figure 7-1 Bottom Confirmation Sampling 

Locations – The proposed bottom confirmation 

sampling looks good. 

4 Figure 7-2 Sidewall Confirmation Sampling 

Locations – The proposed sidewall 

confirmation sampling looks good with a few 

exceptions. Based on Figure 7-2, the spacing 

between 033-PC-001 and -013 is approximately 

40 feet. The spacing between 033-PC-028 and 

-031 is approximately 48 feet. The spacing 

Response – Comment noted. The O&M Plan will include well construction 

information, soil gas sampling frequency, and specific action level language. 

Response – The RAP has been modified to reflect the use of EPA Method 5035 for 

field preservation. In addition, the following sentence has been added to indicate the 

rate of sampling for sidewalls. (Note: this sentence appeared in Section 5 and will also 

be included in Section 7.) 

“Per DTSC (2008e) request, sidewall samples will be collected at a rate of one sample 

per 20 to 30 linear feet of sidewall, where safety considerations and accessibility 

allow.” 

Response – Comment noted. No changes to the RAP are required. 

Response – Comment noted. No changes to the RAP are required. 

Response – Comment noted. Figure 7-2 of the RAP has been modified to include the 

requested additional sidewall confirmation sampling. 

Page 2 of 5 

368

(9/3/08) 

between 033-PC-064 and -065 is approximately 

56 feet. The spacing between 033-PC-004 and 

-091 is approximately 72 feet. GSU staff 

recommends that additional samples be 

collected between each of these pairs of 

proposed samples. 

Comments from Bill Bosan, Toxicologist General Comments 

1 Page 1-3, Section 1.1 (Objectives of the RAP): 

There are two sets of cleanup goals for OU1, 

residential-based soil cleanup goals (metals, 

SVOCs and PCBs) and school-based cleanup 

goals (VOCs). In addition to the O&M Plan, a 

land use covenant will be required because the 

soil gas cleanup levels were based on a schoolbased 

scenario. Alternatively, if the Parcel 38 

VOCs were to be remediated to unrestricted use 

RGs, then almost the entire site could be 

cleared for unrestricted land use, with the 

exception of the southern-most portion of 

Parcel 39, which would be the only area that 

would be restricted and have an associated 

covenant and O&M Plan. 

2 Page 4-1, Section 4.1.2.3 (Exposure 

Assumptions and Pathways): Please see 

Comment No.1.HERD recommends deleting or 

re-wording the last sentence of the first 

paragraph, as it will lead to confusion in its 

discussion of less and more protective cleanup 

goals. 

3 Page 5-10, Section 5.3 (Recommended 

Remedial Action Alternative): The third 

Response –Comment noted. The RAP has been revised to reflect the need for 

temporary land use controls (see response to Joe Hwong Comment #1). 

Please note that land use controls may also be required on a small portion of Adella 

Avenue (benzene) and a small portion of Parcels 29 and 30 (PCE). The need for and 

extent of any land use controls in these areas will be evaluated during post-removal 

confirmation soil gas sampling. 

Response – The RAP has been revised to remove the last sentence of the first 

paragraph of Section 4.1.2.3. 

Response – Comment noted. The RAP has been revised to more clearly state that this 

methodology will not be applied to arsenic and PAHs. In addition, the text has been 

Page 3 of 5 

369

(9/3/08) 

paragraph states that a statistically derived 

residual COC concentration will be calculated 

and compared to the RG to demonstrate 

compliance. This is not appropriate for arsenic 

and PAHs (B(a)P-TEs), as the cleanup goals for 

these chemicals are upper-bound, not to exceed 

values; consequently, individual confirmation 

sample results must be compared directly to the 

cleanup goals for compliance. Estimating a 

95% UCL may not be appropriate for soil gas 

VOCs, as the issue is extent and the resulting 

95% UCL may dilute a potential high 

concentration with NDs. 

4 Page 7-11, Section 7.4.1 (Air Monitoring): The 

following community or fence line action levels 

should be included in the Table on Page 7-11. 

Chemical Name Community Action Level 

Benzene 60 µg/m3 

Naphthalene 9 µg/m3 

PCE 35 µg/m3 

1,3,5-Trimethylbenzene 6 µg/m3 

1,2,4-Trimethylbenzene 6 µg/m3 

PCBs 0.1 µg/m3 

Arsenic 0.03 µg/m3 

A paragraph should be added discussing the 

SCAQMD Rule 403 and the fence line action 

level of 50 µg/m3 as being health protective for 

all non-volatile constituents being remediated. 

modified to reflect that calculating a 95% UCL would require DTSC concurrence to 

ensure that the results are representative and that elevated soil gas concentrations are 

not inappropriately diluted. 

“At the discretion of the District and in consultation with DTSC, a statistically derived 

residual COC concentration will be calculated and compared to the RG to demonstrate 

compliance. This approach will not be utilized for arsenic and PAHs given that the 

RGs represent upper-bound allowable concentrations. The methods used to calculate 

a 95-percent upper confidence limit (UCL) concentration are outlined in the DTSC 

(2008c)-approved Risk Protocol Document (Parsons, 2007c). DTSC will be consulted 

about any specific application to ensure that sufficient data exists to calculate a UCL, 

the results are representative, and that elevated concentrations are not inappropriately 

diluted out.” 

Response – The requested Community Action Levels have been added to the RAP. In 

addition, the following text has been added to Section 7.4.1 of the RAP. 

“As discussed in Section 6, requirements of SCAQMD Rule 403 will be met, including 

fence line air monitoring to ensure that there are no adverse impacts to the 

surrounding community. Community action levels (fence line) have been established 

and are shown on the table. The 50 µg/m 3 fence line action level is considered health 

protective for other non-volatile constituents being remediated.” 

Page 4 of 5 

370

(9/3/08) 

5 Page 7-13, Section 7.5.2 (VOC Monitoring): 

Use of a PID will not be sufficient to evaluate 

the fence line action levels for VOCs presented 

in Comment No. 4. Actual upwind and 

downwind air samples will be required to show 

that off-site receptors have not been impacted 

by VOC removal activities. If IH methods can 

not achieve the detection limits proposed, then 

EPA methods should be used, such as collection 

of samples in Summa canisters and analysis of 

VOCs using EPA Method TO-15. If VOCimpacted 

soil will be stockpiled on site, 24-hour 

samples should be collected to demonstrate no 

off-site impacts from VOC off-gassing from the 

stockpile. 

6 Page 7-15, Section 7.6.2 (Confirmation 

Sampling): The fourth paragraph states that 

sufficient time (minimum of 48 hours) will be 

allowed for re-equilibration before soil gas 

confirmation samples are collected. Given that 

30 feet of backfill is proposed for Parcels 38 

and 39, 48 hours will not be sufficient for reequilibration 

of the soil. HERD recommends 

installation of multi-depth, semi-permanent soil 

gas probes and collection of soil gas 

confirmation samples 1-month and 2 months 

post-backfilling. This will not be an issue for 

Parcel 39, where on-going VOC monitoring 

will be part of the O&M Plan. 

Response – Comment noted. The following text has been added to the RAP. 

“Upwind and downwind fence line air samples will be collected on a daily basis using 

Summa canisters (for VOCs) and high-volume particulate air samplers (for PCBs, 

arsenic, and lead). The purpose of this sampling is to demonstrate that there are no 

unacceptable off-Site (community) impacts as a result of air emissions. . Air samples 

will be collected for an 8-hour duration, although 24-hour duration samples will be 

collected on any days that impacted soil is stockpiled (overnight) on-Site. The locations 

of the upwind and downwind air sampling will be determined based on the results of 

daily monitoring of the on-Site meteorological station Air samples will be analyzed 

using EPA Method TO-15 to achieve the reporting limits listed in the preceding table. 

Air sampling will be performed on all days that impacted soil is being excavated, 

stockpiled, and/or transported from the Site. Any changes to this approach must be 

approved by DTSC.” 

Response – Comment noted. The RAP has been revised to indicate that semipermanent 

soil gas probes will be installed following backfill and that soil gas 

confirmation samples will be collected two weeks and one months post-backfill. Note 

that this applies to Adella Avenue, Parcel 38, and Parcels 29/30. The last sentence of 

the fourth paragraph of Section 7.6.2 has been revised to: 

“Soil gas confirmation samples in VOC-impacted areas will be collected two weeks 

and 1 month following the completion of backfill activities. The locations of multidepth, 

semi-permanent soil gas probes will be determined in the field in consultation 

with DTSC. This includes post-removal VOC confirmation sampling on Adella 

Avenue, Parcel 38, and Parcels 29/30 (PCE). Post-closure soil gas monitoring at 

Parcel 39 will be documented in the O&M Plan.” 

Page 5 of 5 

371

Internal Review Draft (9/8/08) 

RESPONSES TO COMMENTS FROM DTSC DATED SEPTEMBER 5, 2008 

OPERABLE UNIT 1 REMEDIAL ACTION PLAN 


Comment 

Number 


Comments from Ken Chiang, Scientist General Comments 

1 Compliance with H&SC sec. 25356.1(e): The 

RAP shall include a nonbinding preliminary 

allocation of responsibility among all 

identifiable potentially RPs from liability. The 

RAP did not include such info as legally 

required in H&SC. 

2 Compliance with title 22, division 4.5, chapter 

39, section 67391.1(b) for land use covenant 

(LUC): LUC is a legal document for land use 

controls, to be recorded with County 

Recorder/Clerk. When LUC is proposed, the 

limitations or controls shall be clearly set forth 

and defined in the RAP/RAW. The RAW/RAP 

shall also specify that the limitations will be 

incorporated into an appropriate LUC and shall 

include a description of the implementation and 

enforcement provisions, including but not 

limited to frequency of inspections and 

reporting requirements. The RAP did not 

comply with the requirements (as to LUC, 

implementation and enforcement provisions). 

The RAP discussed TEMPORARY land use 

controls (LUCs), but no where LUC was 

mentioned. No implementation and 

enforcement provisions were included either. 

Even if confirmation sampling results show no 

Response – A current list of potentially responsible parties within OU 1 will be 

included in the RAP as new Appendix M (attached). Please note that this is a 

preliminary list and may be revised based on future information. 

Response – As discussed in Section 7.10 of the RAP, the District anticipates that the 

Parcel 39 land use controls (i.e. Land Use Covenant) will be temporary in nature. The 

District intends to enter into the appropriate land use covenant (LUC) with the DTSC 

to ensure that the land use restrictions are fully enforceable. It is also the District’s 

intent to fully define the scope of the LUC once post-removal confirmation sampling is 

complete. The District would like to achieve unrestricted-use (residential) cleanup 

goals in all areas of OU 1, with the exception of a small area on Parcels 29 and 30 

where RI sampling results indicated concentrations of PCE exceeding residential RGs 

but less than school-based RGs. 

The District intends to clean up other VOC-impacted areas of OU 1, including 

Parcel 38, 39, and Adella Avenue, to unrestricted-use RGs. Data collected during the 

RI indicated that soil concentrations exceed unrestricted-use RGs at Parcel 38, 

although soil gas concentrations were less than unrestricted-use RGs. The presence of 

sub-surface utilities beneath Adella Avenue may preclude full removal of all impacted 

soil due to health and safety concerns. Thus, the potential application of school-based 

cleanup standards in these areas will be based on the results of post-removal soil gas 

confirmation sampling. If unrestricted-use RGs are achieved, then no LUC would be 

necessary. 

Given that the exact scope of the LUC cannot be accurately determined until post- 

Page 1 of 4 

372


exceedence of residential standards, LUC will 

be required (because school base standard was 

used in cleanup). The LUC may be terminated 

after a 5-year review if site conditions continue 

to meet termination criteria. 

3 Cadmium: CHHSL is 1.7 ppm while our 

cleanup level is 35 ppm. The toxicologist 

justification should be included in the RAP. 

4 Reference back to other reports (e.g., FS and 

RI): All RAP-specific information (waste 

volume, cost estimates) should be detailed in 

the RAP, not just using reference to RI or FS 

reports. Cost estimate for Alt 2 should be 

detailed in the RAP, not just referring back to 

FS reports. 

removal confirmation sampling is completed, the District cannot currently define the 

exact footprint of the land use covenant. To address the comment, the District 

proposes to add the following language to the first paragraph of RAP Section 7.10: 

“The land use controls in these areas will be enforced through the District entering 

into a land use covenant to be recorded with the Country Recorder/Clerk. The land 

use covenant shall comply with provisions of Title 22, Division 4.5, Chapter 39, 

Section 6739.1(b) and shall specifically indicate that land use within the affected areas 

cannot be changed from the current design without the prior concurrence of DTSC. 

Inspection and reporting requirements to document that the land use has not changed 

will be developed in conjunction with the DTSC and specified in the O&M Plan.” 

Response – The published cadmium CHHSL (Cal/EPA, 2005) is based on utilization 

of an oral slope factor that has been withdrawn. The remedial goal listed in Table 4-2 

of the RAP is consistent with current toxicological assumptions utilized by 

DTSC/HERD. Although CHHSLs have no regulatory significance, the following 

language will be added as a footnote to RAP Table 4-2 (OU 1 Remedial Goals): 

“The cadmium soil RG is consistent with the provisional residential CHHSL (DTSC, 

2008h) of 37 mg/kg, which is based on cadmium being carcinogenic via the inhalation 

pathway.” 

The following will be added to Section 9 (References): 

DTSC (2008h). E-mail Communication from Bill Bosan (DTSC) to Joe Hwong 

(DTSC) and Jim Goepel (Parsons) Re: South Gate Cadmium Soil Remedial Goal. 

August 28. 

Response – Waste volume information is presented in Figures 3-1 and 5-1 from the 

RAP. Additional information from the OU 1 FS will be included as new Appendix L. 

Detailed cost information for both Alternatives 2 and 3, including a list of specific 

assumptions (including waste volumes), is provided in Appendix J of the RAP. No 

changes to the RAP are required. 

Page 2 of 4 

373


5 Depth specific cleanup levels for VOCs: Depth 

specific cleanup levels for each VOC should be 

included in the RAP and CEQA initial study. If 

not, the 5-footer cleanup levels should be used 

for all depths. 

6 H&SC sec. 25356.1(d)(3): DTSC shall not 

select remedial action measures which use 

offsite transport and disposal of untreated 

hazardous substances or contaminated materials 

if practical and cost effective treatment 

technologies are available. For soil VOC 

contamination, SVE system is a proven cost 

effective and efficient technology. 

Justifications for why SVE was not 

recommended should be included. 

Response – Table 4-2 includes depth-specific soil gas cleanup levels that were derived 

using the Johnson & Ettinger model. No changes to the RAP are required. 

Response – Soil vapor extraction, along with various other technologies, was evaluated 

as part of the OU 1 Feasibility Study and screened from further consideration. This is 

because SVE did not meet one of the primary Remedial Action Objectives, which is to 

remediate OU 1 soils and soil gas in a timely manner (see first bullet on page 1-2 of the 

RAP). The District is required to achieve environmental clearance to allow for school 

opening by September 2012. As discussed in Section 2.4.5 of the OU 1 FS, application 

of SVE, especially in the presence of an off-Site source (e.g., at Parcel 39), would have 

resulted in a greatly extended cleanup duration and thus could delay or preclude the 

school from being built. 

In addition, as discussed in Section 2.4.5 of the OU 1 FS, the nature of the Parcel 38 

petroleum hydrocarbon impacts (i.e., mostly non-volatile constituents), would not have 

been amenable to a stand-alone SVE approach. Furthermore, the relatively small 

VOC-impacted soil volumes at Parcel 38 and at Adella Avenue are more well suited to 

a soil excavation and removal remedy when scheduled is considered.. 

To address the comment, the text at the beginning of Section 5.2.2 of the RAP will be 

modified as follows: 

“A comprehensive evaluation of various cleanup technologies including SVE was 

performed during the OU 1 FS. These technologies were screened from further 

consideration because they would not meet the RAO of achieving cleanup in a timely 

manner. Technologies retained for further consideration included mechanical soil 

excavation, ex situ soil stabilization, and off-Site disposal. These technologies were 

combined into the following remedial alternatives:” 

Page 3 of 4 

374


7 A minimum of three alternates were evaluated: 

Alt 2 and Alt 3 are essentially identical, at least 

similar. We need at least one other different 

alternative (e.g., SVE system). The RAP needs 

to justify why SVE was not included as an 

acceptable alternative. 

Response – As discussed in the response to Comment #6, SVE was not included as an 

acceptable alternative because it did meet the screening RAO of achieving cleanup in a 

timely manner. No other technically feasible/implementable cleanup technologies 

were identified for evaluation as a remedial alternative due to the aggressive project 

construction schedules. This includes various containment technologies and in situ 

cleanup approaches, which would not be acceptable because they would leave waste in 

place. The RAP will be modified to include the new text outlined previously in 

response to Comment #6. 

Page 4 of 4 

375

APPENDIX L 

Waste Characterization 

376

OPERABLE UNIT (OU) 1 

HAZARDOUS WASTE VOLUME ESTIMATE 

The impacted soils within OU 1 have been classified as RCRA-hazardous waste (RCRA 

waste), non-RCRA California hazardous waste (California-hazardous waste), TSCAhazardous 

waste (TSCA waste), RCRA and TCSA (representing waste that is both 

RCRA waste due to metals and TSCA due to PCBs), or non-hazardous waste (nonhazardous 

waste) for off-Site disposal. The RCRA waste was estimated based on the 

TCLP results in accordance with USEPA regulations. California waste was determined 

based on the TTLC and STLC results in accordance with Cal/EPA regulations. The 

TSCA waste was determined based on concentrations of PCBs exceeding 50 mg/kg. The 

RCRA and TCSA waste was determined based on waste exceeding both TCLP criteria 

and the threshold of 50 ppm for PCBs. For soil samples that did not have leaching test 

results, an assumed correlation between the leachable concentration and total soil 

concentration was used to estimate the leaching results (Tables L-4 and L-5). 

Based on the above classification and assumption, impacted areas of OU 1 were 

delineated as RCRA, California, and TSCA wastes. The spatial distribution is shown on 

Figure L-1. The estimated waste volumes are shown on Tables L-1 through L-3. The 

impacted soils (31,740 cy) within OU 1 were classified as: 

RCRA wastes – 1,315 cy 

Non-RCRA California hazardous waste – 2,990 cy 

TSCA waste – 200 cy 

RCRA & TSCA waste – 155 cy 

The remainder of the impacted soil is classified as non-hazardous waste with an 

estimated volume of 27,080 cy. 

L-1 

377

Table L-1 

Estimate of Hazardous Waste Volume (OU 1) 

Object ID Haz Type Area (sf) 

Alternative 2 

Depth (ft) 

Volume (cy) 

Limited 

Stabilization 

Alternative 3 

Volume (cy) 

#1 RCRA 750 9 250 To Cal-Haz 250 

#2 RCRA 450 4 67 To Cal-Haz 67 

#3 Cal-Haz 780 2 58 To Non-Haz 58 





#8 Cal-Haz 2450 4 363 



#11 Cal-Haz 2520 2 187 



#14 RCRA 3200 2 237 To Cal-Haz 237 

#15 RCRA 435 9 145 To Cal-Haz 145 

#16 Cal-Haz 1040 2 77 



#19 Cal-Haz 600 9 200 

#20 Cal-Haz 1050 2 78 

#21 Cal-Haz 5100 4 756 

#22 RCRA 1665 10 617 To Cal-Haz 617 

ALTERNATIVE 2 ALTERNATIVE 3 

RCRA Total: 1315 To Cal-Haz 1315 

Cal-Haz Total: 2990 To Non-Haz 1330 

Source: 

1) All tables in Seciton 3 of the RI Report (Parsons, 2008a) 

2) Figure 3-5 from the RI Report (Parsons, 2008a) 

Table L-2 

Estimate of TSCA Waste Volume 

Object ID Areas Depth (ft) Volume (cy) 

A 180 9 60 

B 1904 2 141 

Total TSCA Waste: 201 

Table L-3 

Estimate of RCRA & TSCA Waste Volume 

Both RCRA and TSCA Waste: 154 

378

Sample Location 

Sample 

Date 

Sample 

Depth (ft 

bgs) 

PSG35-7 2/9/2001 2.5 13000 mg/kg 21000 ug/L 

PSG35-7 2/9/2001 4.5 6500 mg/kg 3000 ug/L 

PSG35-6 1/26/2001 0.5 200 mg/kg 53 ug/L 

PSG35-4 1/26/2001 0.5 250 mg/kg 22 ug/L 

PSG35-8 1/26/2001 0.5 340 mg/kg 7800 ug/L 

PSG35-8 2/7/2001 2.5 7.5 mg/kg 100 ug/L 

PSG35-8 2/7/2001 4.5 9 mg/kg 180 ug/L 

PSG35-9 2/7/2001 0.5 180 mg/kg 1800 ug/L 

PSG35-9 2/7/2001 2.5 5.3 mg/kg 53 ug/L 

PSG33-12 1/26/2001 0.5 300 mg/kg 400 ug/L 

PSG33-20 1/26/2001 0.5 590 mg/kg 630 ug/L 

PSG33-22 1/26/2001 0.5 160 mg/kg 12 ug/L 

029-PS056 5/14/2008 0.5 2000 mg/kg 3300 ug/L 

029-PS056 5/14/2008 3 2500 mg/kg 9300 ug/L 

029-PS055 5/13/2008 0.5 940 mg/kg 1800 ug/L 

129-PS060 5/13/2008 0.5 1200 mg/kg 1800 ug/L 

029-PS060 5/13/2008 3 280 mg/kg 58 ug/L 

029-PS060 5/13/2008 5 340 mg/kg 140 ug/L 

029-PS060 5/13/2008 15 2.5 mg/kg 39 ug/L 

029-PS062 5/13/2008 0.5 310 mg/kg 1500 ug/L 

029-PS062 5/13/2008 3 470 mg/kg 4300 ug/L 

TCLP Concentrations 

(ug/L) 

Table L-4 

Correlation between TCLP and Total Concentration 

100000 

10000 

1000 

100 

10 

TCLP Threshold: 5000 ug/L 

Corresponding Tot Conc: 3065 mg/kg 

Lead 

TCLP vs. Total Lead Concentrations 

y = 1.3717x + 795.49 

R 2 = 0.7143 

1 

1 10 100 1000 10000 100000 

Total Lead Concentrations (mg/kg) 

379

Sample Location 

Table L-5 

Correlation between STLC and Total Concentration 

Sample 

Date 

Sample 

Depth (ft 

bgs) 

PA33-25 2/16/2001 0.5 280 mg/kg 1800 ug/L 

PA33-27 2/16/2001 2.5 1100 mg/kg 48000 ug/L 

PSG33-36 2/13/2001 0.5 250 mg/kg 25000 ug/L 

PSG35-3 2/13/2001 2.5 710 mg/kg 13000 ug/L 

PSG35-4 1/26/2001 0.5 250 mg/kg 4200 ug/L 

PSG35-6 1/26/2001 0.5 200 mg/kg 3900 ug/L 

PSG35-8 1/26/2001 0.5 340 mg/kg 7800 ug/L 

PSG35-9 2/7/2001 0.5 180 mg/kg 1800 ug/L 

PA37-11 2/7/2001 0.5 280 mg/kg 1700 ug/L 

029-PS056 5/14/2008 0.5 2000 mg/kg 15000 ug/L 

029-PS056 5/14/2008 3 2500 mg/kg 30000 ug/L 

029-PS055 5/13/2008 0.5 940 mg/kg 52000 ug/L 

129-PS060 5/13/2008 0.5 1200 mg/kg 44000 ug/L 

029-PS060 5/13/2008 3 280 mg/kg 7200 ug/L 

029-PS060 5/13/2008 5 340 mg/kg 4200 ug/L 

029-PS062 5/13/2008 0.5 310 mg/kg 42000 ug/L 

029-PS062 5/13/2008 3 470 mg/kg 49000 ug/L 

STLC Concentrations 

(ug/L) 

100000 

10000 

STLC Threshold: 5000 ug/L 

Corresponding Tot Conc: 209 mg/kg 

Lead 

STLC vs. Total Lead Concentrations 

y = 27.067x 0.9766 

R 2 = 0.4014 

1000 

100 1000 10000 

Total Lead Concentrations (mg/kg) 

380

APPENDIX M 

List of Potentially Responsible Parties 

382

OU 1 Remedial Action Plan 

Table M-1 

POTENTIALLY RESPONSIBLE PARTIES 

OPERABLE UNIT 1 

LAUSD PROPOSED SOUTH REGION HIGH SCHOOL #9 AND MIDDLE SCHOOL #4 

SOUTH GATE, CALIFORNIA 

Potentially Responsible Party (PRP) Parcel 

1. AUDIO AMERICA, INC. 33, 35 

2. BEVERLY E. BARR 38 

3. IRWIN M. BARR 38 

4. BUNDY INDUSTRIES, INC. 38 

5. PAUL FELDMAN, individually and as trustee for the PAUL FELDMAN 

TRUST 

38 

6. LINDA B. GOODBAN 3 

7. WILLIAM D. GOODBAN, individually and as partner of GOODBAN & 3 

RODGERS INVESTMENTS, a general partnership 

8. GLORIA GORDILLO 39 * 

9. JOSE GORDILLO 39 * 

10. RAFAELA GORDILLO 39 * 

11. RUBEN GORDILLO 39 * 

12. ANGELA K. KOSHT 32 

13. STANLEY J. KOSHT, as trustee of the TRUMAN L. KOSHT and 

STANLEY J. KOSHT TRUST and d/b/a/ PYRAMID DIE CASTING 

32 

14. PETER LATNER, individually and d/b/a B&L LEASING 30 

15. DOROTHY B. LINDLIEF (formerly known as (“f/k/a”) DOROTHY B. 

CEPEK), individually and as trustee of the DOROTHY B. CEPEK TRUST 

23, 36 

16. RONALD S. MOBLEY, individually and doing business as (“d/b/a”) 2 

ACCURATE WELD TESTING LAB 

17. MOON INTERNATIONAL, INC. (f/k/a MOON MANUFACTURING CO.) 30 

18. ELIZABETH MORRIS 3 

19. THAINE R. MORRIS 3 

20. MP ASSOCIATES, INC. 3 

21. PACIFIC BELLOWS CORPORATION 4 

22. GERARDO H. PAGINI, individually and d/b/a BEST IRON WORKS 30 

23. RAMONA G. PAGINI, individually and d/b/a BEST IRON WORKS 30 

24. JOSEPH A. PALMQUIST, individually and as trustee of the JOSEPH A. 

PALMQUIST TRUST 

31 

25. PALMQUIST TOOLING, INC. 31 

26. DAVID J. PIER 3 

27. POZAS BROTHERS TRUCKING CO. 1 

28. EVERETT T. REYNOLDS, individually and d/b/a RET MANAGEMENT 29 

29. MIREYA SUAREZ, individually and d/b/a BEST IRON WORKS 30 

30. NELSON SUAREZ, individually and d/b/a BEST IRON WORKS 30 

31. TZENG LONG U.S.A., INC. 29 

* The PRP is associated with an off-Site source that has impacted Parcel 39. 

Please note that this is a preliminary list and may be revised based on future information. 

383

Site-Specific Health and Safety Plan (HASP) - Laschools.org

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