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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 />

Page 3 of 5<br />

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