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AGE provided a Site Health and Safety Plan for the Project. Comments: The AGE Site Health and Safety Plan (SHSP) in the Hazard Evaluation table, identified gasoline/diesel fuels and VOCs as a hazard and indicated these COPCs as non detect and identified metals and other chemicals as a hazard at unknown to low detections. However, the hazard evaluation only evaluated one VOC, perch loroethylene (PCE) and hydrocarbon fuels. Metals listed previously as a hazard at unknown to low detection and other potential COPCs such as PCBs, both which were analyzed for and detected, were not discussed in the hazard evaluation. (Only one VOC and petroleum hydrocarbons were discussed in the hazard evaluation). Based on this, the hazard evaluation appears to be incomplete. There is no mention in the plan that personnel working on the project must be 40- hour HAZWOPER certified with annual updates. There is no signature page for field personnel to sign at the site acknowledging their understanding of the plan. ' m AYe, ; cotriio ; arch-23. 111 The email indicates that the LEA had reviewed the site investigation work plan for 500 E. Louise Avenue and wanted to bring a few issues to the attention of AGE: The following are the LEA comments: "Health and Safety Plan -The health[and]safety plan is not completely filled out. -All personnel onsite during the investigation must have 40 Hour HAZWOPER Certification and this must be mentioned in the health and safety plan. -Under section 5.0, Levels of protection are not specified. -Under section 6.0, Project Team Leader responsibilities are left blank. -Under section 9.0, intervals are not specified for the monitoring instruments. -Under section 9.0 names of appropriate staff are not filled in. -Under section 2.0 names of appropriate staff are not filled in. Investigation Work Plan -Under section 2.2 of the work plan you stated "if no more than 1 cubic yard of waste is encountered, then[then]excavations spoil waste will be considered de minimus." -Please explain what you mean by this statement, specifically the term "excavation spoil waste." -Note that if waste is excavated from the site, it cannot be back filled, it must be disposed of at a permitted disposal facility. You will need to state in your workplan how you plan to handle any hazardous waste in addition to solid waste that you encounter during the excavation. Comment: Wastes temporarily excavated during a Site Investigation at a WDS are typically placed back into the excavation from which they were removed in the reverse order excavated. The LEA/CalRecycle approves this exploratory trenching backfilling. -Under section 2.5 you stated that waste will be stored on-site and disposal alternatives will be evaluated based on soil and water analysis results. -Are you referring to analysis of the soil samples collected during the investigation, or is this referring to analysis of the waste removed from the site during the excavation? Please clarify. -Excavated waste will need to be tested to determine proper location for final disposal. If any other issues arise I will let you know as soon as possible." Comment: Typically wastes excavated during a site investigation are not required to be disposed of offsite, rather they are placed back into the excavation from which they were removed in the approximate reverse order they were excavated. During excavation, soils are kept separate from wastes, as possible (e.g., cover soil and/or native soils beneath wastes are separately stockpiled from wastes). Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 27