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RV Circuits Page 2 9. No decision-making criteria are presented for selecting additional soil samples for analysis, nor for when samples that are analyzed for total metals may be analyzed for soluble concentrations. In addition, the analytical methods for additional procedures, must be specified, e.g., for soluble analysis. 10. The first column of"TABLE 2 REGULATORY GUIDELINES FOR VARIOUS METALS" should be labeled "Regulatory Guideline" or"Regulatory Standard." Health and Safely Plan Comments 11. The health and safety plan, in general, is inadequate. For example, it lacks any recognizable criteria for monitoring the potential hazards at the site. Examples include no heat stress monitoring protocol, and no discussion of how personal protection level upgrades and downgrades will occur. The entire plan should be reviewed and revised by an industrial hygienist with experience in hazardous substances investigations. 12. The "HAZARD EVALUATION" section of the health and safety plan should be revised to include a discussion of occupational exposure levels in relation to contamination levels known or suspected to be found at the site. 13. The health and safety plan should be revised to include a discussion about the decision-making protocols that will be used to upgrade or downgrade personal protection levels. Simply saying that it is the decision of the health and safety officer is inadequate. Each level of protection should be defined and the criteria for when that level of protection will be used based on health and safety monitoring for each hazard must be included. 14. The table discussing "Exposure systems" is incomplete. For example, the information presented about dust does not address the fact that the dust may contain toxic metals. Also, the plan lacks any criteria for deciding how dust will be measured/monitored in terms of what levels of personal protection will be used. Additionally, the plan lacks any information about adequate dust control procedures. 15. The table discussing"First aid" is also inadequate. For example, donning a respirator is not a means of first aid and would in fact result in greater pulmonary difficulty for someone who needs first aid due to a dust exposure.