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Dana Parry - 4 - 27 June 2019 Water Board staff were prevented by Mr. James from inspecting the western portion of the Site leaving staff's expected assessment of outstanding issues or concerns for the western portion out of this SMP document. Therefore, the scope of this SMP is limited to soil management for the eastern portion of the Site. The SMP mainly contains site information for the eastern portion of the Site. While the intent of the SMP was to be a comprehensive site -wide soil management plan, site features and areas of concern on the western portion of the site including a former oil water separator, furnace, active transformers, active water treatment plant storage basin, and a recently asphalted parking lot covering an area of potentially buried waste for disposal. In addition, the SMP shows two new buildings proposed for the northwestern portion of the Site and will need a separate SMP if the western portion of the site is not included in this SMP. 3. While the intent of the SMP was to be a site -wide soil management document, the SMP does not supersede any other approved Site permit requirement(s) nor work plan requirement(s) documents. Rather, the SMP should be implemented in addition to applicable Site permit requirements, work plan requirements, or other approved Site documents, such as the 4 February 2019 Stormwater Pollution Prevention Plan for Designated Remainder, Kier & Wright Civil Engineers & Surveyors. Please include a statement in the SMP indicating that its requirements shall be implemented in addition to any other required work plan or permit requirements for the Site rather than to supersede other approved Site documents. All waste management at the site should be performed in accord with applicable laws and regulations, as well as regulatory agency directives. <Specific Comments 4. Section 1.0 Introduction and Section 1.6 Applicability of this SMP both contain the following sentence which refers the SMP -user to an attachment and figure in an Order contained in the Appendix of the SMP: This SMP describes protocols to be implemented if previously unknown waste pits (e.g. the North and South Waste Cells on Parcel 8) or other areas of obvious soil impacts with potentially hazardous materials (e.g. as observed in excavation for utility trench as documented in Attachment 3 Figure 16 to the Order (Appendix A)) are encountered during subsurface disturbance activities that may be conducted as part of ongoing and future Site redevelopment. There are many references throughout the SMP that direct the SMP -user to a portion of different reports that have been generated for site conditions, but these references make finding the desired information cumbersome for the SMP -user and may result in the SMP -user accessing the wrong information. For references to information contained in one of the numerous reports for the other waste areas, the SMP would be more useful in the field if the referenced information were included as attachments to the SMP that could then be easily referenced and accessed when needed. The following table shows reports for waste and soil management protocols and procedures that have been developed and implemented for site-specific areas of waste remediation at the site: