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Health and Safety Plan • •Page 3 STOCKTON PROMENADE PROPERTY June 12,2008 WKA No.7345.05 2.1 Inhalation Exposure Subsurface soil investigations were conducted to evaluate the distribution of petroleum hydrocarbons and dieldrin in site soils. Laboratory analysis of selected soil samples yielded detected concentrations of petroleum hydrocarbons ranging from 1.4 milligrams per kilogram (mg/kg)to 4,700 mg/kg and detected concentrations of dieldrin ranging from 0.020 mg/kg to 0.510 mg/kg. The Occupational Safety and Health Administration(OSHA)has established maximum exposure limits for dieldrin for the purpose of reducing the risk of human exposure to potentially harmful constituents. The OSHA 8-hour time-weighted-average(8-hr TWA)permissible exposure limit (PEL)for dieldrin is 0.25 mg/m'. There are currently no OSHA PELs listed for TPHd or TPHmo. The American Council of Governmental Industrial Hygienists(ACGIH)has established a Threshold Limit Value(TLV)of 0.25 mg/m'for dieldrin,which defines the concentration at which an individual can reasonably be exposed to dieldrin without experiencing adverse health effects. In addition,the ACGIH has proposed a TWA TLV of 15 mg/m'for TPHd particulate and 100 mg/m'for total hydrocarbons as vapor and aerosol. No TLV has been established for TPHmo. A photoionization detector(PID)will be used to assess the air quality surrounding the excavation of petroleum hydrocarbon affected soils. If the PID readings indicate the presence of chemicals in the worker-breathing zone,work will be halted in the affected area. The Project Manager will be notified and work in the affected area will not resume until instructed by the Project Manager. Potential exposure to dieldrin by inhalation and dermal contact will be assessed based on the presence of visible dust resuspended from locations characterized as containing dieldrin. Visible dust shall not be resuspended from soil characterized as containing dieldrin. Resuspension of dust shall be prevented through appropriate application of water. 2.2 Dermal Contact and Ingestion During excavation and removal of the contaminated soils,incidental dermal exposure to soil containing COCs is a secondary exposure concern. The dermal exposure pathway can be controlled with the use of appropriate personal protective equipment(PPE)and the institution of