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

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(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
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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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SECTION 7 LABORATORY QC SAMPLES AND
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