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Mr. Marcus Pierce, Engineering Geologist Central Valley Regional Water Quality Control Board Subject: Diesel Impacted Soil Removal GENERAL DESCRIPTION OF PROPOSED REMEDIAL ACTIVITIES Upon approval of this work plan and the attached Accident Prevention Plan/Site Safety and Health Plan (Attachment C), remedial activities will be scheduled. The remedial activities will consist of subsurface utility locating, impact area pre-characterization, contaminated soil excavation, backfilling with clean borrow soil, and site restoration. The proposed excavation area will be properly marked prior to notifying Underground Service Alert about proposed subsurface excavation activities. A private underground subsurface utility locator will be contracted to determine if any underground utilities (water, sewer, telecommunications, cable television, electric and gas) or other obstructions are located within the proposed excavation footprint. Any subsurface utilities observed within the excavation footprint or in the parking area between the site buildings and the fence line along North Stockton Street will be marked with spray paint on the ground surface. After completion of subsurface utility clearance, a visual inspection will be conducted of the soil contamination and related soil staining. It is anticipated that the maximum depth of contamination will be approximately 2-feet bgs. Along with visually evaluating impacts, OTIE will collect pre-characterization soil samples to determine the vertical and the lateral extent of the diesel contamination. We anticipate collecting approximately 12 soil samples using a hand auger. Samples will be collected from approximately 2-feet outside the visible spill area boundary, and from within the spill area at depths ranging from 6 inches to 2 feet bgs. Soil samples will be collected in sterile glass containers, using a decontaminated hand auger. Soil samples will be submitted to an off-site laboratory having California Environmental Laboratory Accreditation Program (ELAP) and USACE ELAP certifications. Soil samples will be analyzed for total petroleum hydrocarbons- diesel (TPH-d) by EPA Method 8015-modified. It is our understanding that CVRWQCB has utilized a threshold of 100 milligrams/kilogram (mg/kg) for a diesel contaminated soil cleanup goal. The results of the soil sampling will be compared to that presumed cleanup goal. The lateral and vertical extent of the contaminated soil excavation area will be determined by the samples collected that are below 100 mg/kg. Samples below 100 mg/kg are presumed to be outside the contaminated soil area. In addition to the pre-characterization samples collected to determine the extent of soil contamination, a four point composite sample will also be collected for waste disposal characterization, submitted to a laboratory and analyzed for total petroleum hydrocarbons (TPH) by EPA Method 8015-modified, volatile organic carbons (VOCs) by EPA Method 8260B, California Title 22 metals by EPA Method 60106/7000, and polychlorinated biphenyls (PCBs) by EPA Method 8082. After receiving laboratory analytical data, a waste characterization profile will be submitted to an offsite licensed disposal facility. Upon approval of the waste profile (typically 7 days after submitting the profile), the soil excavation activities will be scheduled. We will notify the CVRWQCB of planned excavation activities at least one week prior to implementing them. Soil excavation, transport and disposal, backfilling and site restoration activities are anticipated to be completed during one working day. The TPH-d contaminated soil will be excavated using a backhoe and directly loaded onto an end dump truck, then transported and disposed under waste manifest in accordance with all applicable state and federal regulations. Immediately after soil excavation is completed and the contaminated soil has been transported offsite, two confirmation soil samples will be collected from the excavation bottom, and one sample will be Oneida Total Integrated Enterprises, LLC(OTIE) Page 2 of 5