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Page 3 Health and Safety Plan and Soil Management Plan Gleason Park Apartments Property April 21, 2010 The DTSC presented approval of the PEA in a letter dated March 23, 2010.3 The referenced DTSC approval letter indicated that recording of a Land Use Covenant (LUC) will be required for the property, and that the LUC will require development of a Health and Safety Plan (HSP) and a Soil Management Plan (SMP) for future activities at the site. This document is intended to meet the LUC requirements for the HSP and SMP. . Considering multi-family residential use of the property the HHRA performed to evaluate lead risk at the site did not include exposure via ingestion of produce (i.e. vegetables, fruit) grown at the site. As such, vegetable gardening at the site is prohibited. ANTICIPATED FUTURE SITE ACTIVITIES AND POTENTIAL HAZARD Future site activities that could involve soil disturbance include site redevelopment construction, and future maintenance and underground utility work. Planned construction for the Gleason Park Apartments development includes soil excavation, soil compaction, underground utility trenching and installation, foundation construction, and landscape construction. Post- construction activities that could engage site soils could include repair or modification of underground utility lines, landscaping maintenance, and any future underground construction or improvement work. The results of environmental investigations at the site indicate that soils containing elevated concentrations of lead are present sporadically at the site to depths up to about five feet. Because no other analytes were detected at significantly elevated concentrations in soils during site assessment, lead has been considered the primary chemical of concern at the site. A low-level hazard exists for exposure of lead in soils; the primary exposure pathways of concern are inhalation, skin absorption, and incidental ingestion. Although export of materials from the property is not anticipated, any soils/subsurface materials removed from the site would require evaluation/testing to determine appropriate disposal methods. As indicated above,produce gardening at the site is prohibited. 2 Raney Geotechnical, Inc.; "Addendum to Draft Preliminary Endangerment Assessment, Gleason Park Property, APNs 149-262-09 through -17 and 149-262-01 through -19, E. Church, S. Stanislaus, and S. American Streets, Stockton, California";March 8, 2010; Raney Reference No. 3312-001.01. 3 Department of Toxic Substances Control; "Approval Gleason Park Preliminary Endangerment Assessment Addendum";March 23, 2010.