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Dana Parry - 6 - 27 June 2.019 treatment may be considered for future excavated wastes that exceed screening levels at the Site under appropriate conditions and with an approved work plan. 9. Section 2.1 for Construction Impact Mitigation Measures lists dust control measures, decontamination measures, and stormwater pollution prevention measures but doesn't provide any detail or description of the measures. Describe or reference attachment containing mechanisms, strategies, devices, techniques would be used to achieve dust control and the other measures at the site. For example, water for dust control should be applied at a rate that prevents run-off and discharge to the storm drain or waters of the State. 10. In section 2.4.3 -Characterization of Excavated soil with Surface Glass and Concrete section of the SMP describes using excavated soil that contains glass cullet but excluding waste materials similar to those in the North and South Waste Cells. Please clarify this section to indicate how the presence or absence of waste materials is to be determined. 11. The Reporting sections indicate that general excavation and soil handling and on-site reuse of soils that did not trigger the requirements of this SMP will not be reported to the Regional Water Board. Just as the areas where waste is found are documented, it is also important to document areas where waste was not found in the conceptual site model as well as potential future deed restriction or land use covenant. The Reporting sections need to be updated to include Regional Water Board notification and concurrence. 12. The SMP indicates that transport manifests and disposal documentation will be maintained. Regional Water Board staff request all transport manifests and disposal documentation be submitted with a brief summary describing the source location of the waste. 13. The Personal Protection/Safety Procedures section indicates that a more extensive contractor health and safety plans would be required for excavation and management of waste pits like the North and South Waste Cells, visibly stained or odorous soil or stockpiles characterized as hazardous waste. The development of a comprehensive SMP to address potential sitewide conditions should include appropriate and applicable health and safety plans that adequately address site specific conditions as requested. The North and South Waste Cells represent potential site conditions that aren't covered in this SMP. Please update the contractor health and safety plan to include these potential conditions and maintain a complete the health and safety plan onsite. 14. Include a Table of Contact Information in the SMP that provides the contact information and specific roles and duties for the project participants including the consultants, contractors, owner(s), and agency representatives involved with investigation, management, and oversight of the residual waste materials at the Site. 15. Regional Water Board staff recommend designating an SMP field coordinator and project manager to help ensure the procedures and protocols of the SMP are implemented with appropriate oversight. 16. Figure 1-2 is dated May 2019 but shows site features from before development of Parcel B. Current Parcel B site features include a large warehouse and stormwater retention