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

(9/3/08)
RESPONSES TO COMMENTS FROM DTSC DATED AUGUST 29, 2008
FINAL OPERABLE UNIT 1 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 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.”
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