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

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(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.” Page 1 of 5 367
(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
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APPENDIX G Health and Safety Plan (
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Prepared by: Reviewed by: Approved
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LAUSD Proposed South Region High Sc
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• Fall Protection • Electrical
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4.11.2 Substance Abuse and Alcohol
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Hospital Name St. Francis Medical C
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Personal Injury LAUSD Proposed Sout
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Date: Project or Location: Risk/Haz
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6.1 SITE RISK ANALYSIS LAUSD Propos
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Project Name & Number: Location: Ex
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6.4 SAFETY SYSTEMS ANALYSIS LAUSD P
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6.7 SAFETY AND HEALTH ENFORCEMENT L
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Contractor Name: Address: Attention
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TABLE 6-1: HAZARDOUS SUBSTANCES OF
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TABLE 6-1: HAZARDOUS SUBSTANCES OF
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Name of Trainer: Training Subject:
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10.1.3 Level C Protection LAUSD Pro
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Action levels for potential benzene
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N Exhibit 12-1 SITE CONTROL ZONES P
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14.3 SPILL REPORTING PROCEDURES LAU
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EMERGENCY CONTACTS In the event of
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PARSONS - LAUSD Procedures followin
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Site-Specific Health and Safety Pla
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ATTACHMENT 3 ACTIVITY HAZARD ANALYS
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Parsons Activity Hazards Analysis O
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Parsons Activity Hazards Analysis F
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Project Name & Number: LAUSD South
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Parsons Activity Hazards Analysis G
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Parsons Activity Hazards Analysis G
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Parsons Activity Hazards Analysis D
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Parsons Activity Hazards Analysis D
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Parsons Activity Hazards Analysis H
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APPENDIX H Quality Assurance Projec
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new wells and from about 70 previou
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• Los Angeles Unified School Dist
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SECTION 2 DATA QUALITY OBJECTIVES T
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precision range from zero to the hi
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• Use of appropriate sampling pro
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Table 2-1 Requirements for Containe
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SECTION 3 FIELD DATA REDUCTION, VAL
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3.4 FIELD DATA VALIDATION The Proje
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SECTION 5 SAMPLING PROTOCOLS Detail
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FM before sending any samples origi
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SECTION 6 FIXED-BASE LABORATORY ANA
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the reported SQLs take into account
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Table 6-2 Practical Quantitation Li
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Table 6-3 Comparison of Field and F
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Page 215 and 216: APPENDIX A COLUMN TEST FOR DETERMIN
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Page 219 and 220: APPENDIX I Transportation Managemen
Page 221 and 222: Prepared by PARSONS 100 WEST WALNUT
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Page 254 and 255: Sample Location Sample Date Sample
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