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Dana Parry -3- SMP 3 - SMP and Protocols 27 June 2019 The SMP summarizes the constituents of concern (COCs) for the identified waste pits at the site and the soil screening levels established in the Excavation and Materials Management Plan (EMMP) for remediation of WU1 on Parcel B and in the WU1 Plan Addendum for remediation of the WU1 Sliver on the Site. Screening levels include arsenic, total petroleum hydrocarbons, and other constituents of concern (COCs). The SMP contains Subsurface Construction Management Protocols for site-specific scenarios in the following elements of the SMP: • Construction Impact Mitigation Measures • Previously Unknown Waste Pits • Visibly Stained or Odorous Soil • Waste Characterization i. Soil Excavated form Waste Pits ii. Excavated Visibly Stained or Odorous Soil iii. Excavated Soil with Surface Glass and Concrete iv. Other Potential On -Site Reuse Soils • Verification Sampling • On -Site Reuse Soils • Confirmation Sampling Import Fill • Personal Protection/Safety Procedures • Reporting These protocols also mention without defining implementation for dust and odor control measures, decontamination measures, and stormwater pollution prevention measures to mitigate potential impacts during subsurface disturbance activities. Several protocols refer the SMP -user to specific sections of other site reports. Some of these referenced reports are included in the SMP Appendices as well as listed in the above -provided Table of SMP -Related Site Reports. Discussion of confirmation sampling and stockpilemanagement are included in the scenarios. Regional Water Board Comments QGeneral Comments 1. Regional Water Board staff concur with the proposed confirmation sampling densities for discrete sidewall samples of 1 sample per 50 linear feet at half the depth of excavation face, bottom confirmation samples collected from 50 -foot centers for areas greater than 2,500 -square feet, and the minimum of one bottom sample and one sidewall sample per excavation face. 2. During the 25 April 2019 meeting at the Regional Water Board offices in Rancho Cordova, the SMP was proposed by Earl James, project consultant from EKI, as a "comprehensive" site -wide soil management plan that would include Regional Water Board staff concerns and a proposed site visit to walk the entire site and discuss areas of concern with Mr. James. However, during the site visit on 30 April 2019 Regional