Site-Specific Health and Safety Plan (HASP) - Laschools.org
Site-Specific Health and Safety Plan (HASP) - Laschools.org
Site-Specific Health and Safety Plan (HASP) - Laschools.org
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(9/3/08)<br />
between 033-PC-064 <strong>and</strong> -065 is approximately<br />
56 feet. The spacing between 033-PC-004 <strong>and</strong><br />
-091 is approximately 72 feet. GSU staff<br />
recommends that additional samples be<br />
collected between each of these pairs of<br />
proposed samples.<br />
Comments from Bill Bosan, Toxicologist General Comments<br />
1 Page 1-3, Section 1.1 (Objectives of the RAP):<br />
There are two sets of cleanup goals for OU1,<br />
residential-based soil cleanup goals (metals,<br />
SVOCs <strong>and</strong> PCBs) <strong>and</strong> school-based cleanup<br />
goals (VOCs). In addition to the O&M <strong>Plan</strong>, a<br />
l<strong>and</strong> use covenant will be required because the<br />
soil gas cleanup levels were based on a schoolbased<br />
scenario. Alternatively, if the Parcel 38<br />
VOCs were to be remediated to unrestricted use<br />
RGs, then almost the entire site could be<br />
cleared for unrestricted l<strong>and</strong> use, with the<br />
exception of the southern-most portion of<br />
Parcel 39, which would be the only area that<br />
would be restricted <strong>and</strong> have an associated<br />
covenant <strong>and</strong> O&M <strong>Plan</strong>.<br />
2 Page 4-1, Section 4.1.2.3 (Exposure<br />
Assumptions <strong>and</strong> Pathways): Please see<br />
Comment No.1.HERD recommends deleting or<br />
re-wording the last sentence of the first<br />
paragraph, as it will lead to confusion in its<br />
discussion of less <strong>and</strong> more protective cleanup<br />
goals.<br />
3 Page 5-10, Section 5.3 (Recommended<br />
Remedial Action Alternative): The third<br />
Response –Comment noted. The RAP has been revised to reflect the need for<br />
temporary l<strong>and</strong> use controls (see response to Joe Hwong Comment #1).<br />
Please note that l<strong>and</strong> use controls may also be required on a small portion of Adella<br />
Avenue (benzene) <strong>and</strong> a small portion of Parcels 29 <strong>and</strong> 30 (PCE). The need for <strong>and</strong><br />
extent of any l<strong>and</strong> use controls in these areas will be evaluated during post-removal<br />
confirmation soil gas sampling.<br />
Response – The RAP has been revised to remove the last sentence of the first<br />
paragraph of Section 4.1.2.3.<br />
Response – Comment noted. The RAP has been revised to more clearly state that this<br />
methodology will not be applied to arsenic <strong>and</strong> PAHs. In addition, the text has been<br />
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