ARCHIVED REPORTS_2019 SOIL MGMT PLAN (JULY-REVISED)

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EKI B90047.00 Page 7 Former Pilkington North America Site Lathrop, California • Other COCs Not Including Arsenic and TPH: The more conservative of the following screening criteria for direct exposure will be used for other COCs, not including arsenic and TPH. o U.S Environmental Protection Agency (“EPA”) Regional Screening Levels (“RSLs”) for soil for commercial/industrial land use1 (U.S. EPA, 2018); and o Department of Toxic Substances Control (“DTSC”)-Modified Screening Levels for soil for commercial/industrial land use (“DTSC-SLs”) (DTSC, 2019). 1.5 Site Redevelopment Activities As shown on Figure 1-3, the proposed Site redevelopment includes the construction of the following buildings for commercial/industrial use: (a) an expansion of the rail dock facility on the southeast corner of the main building, (b) a 752,000 +/- sf building in the eastern portion of the Site that will be part of Kraft Heinz’s expanded facility, (c) two buildings of approximately 58,500 sf each on the northwestern portion of the Site, and (d) a 87,500 +/- sf building in the northeast corner of the Site. The Site’s rail spur will be rerouted on-site to accommodate building construction. After redevelopment, the Site will be predominantly covered by buildings or hardscape with the exception of a stormwater detention basin in the southeast corner of the Site. Subsurface disturbance activities are expected to include trench excavations for utilities, completion of the stormwater detention basin, general grading, and other construction and earth moving activities associated with redevelopment of the Site. It is anticipated that any excavation or trenching for redevelopment activities will not extend below the groundwater table that was generally encountered between 12 and 16 feet bgs. Reuse of excavated materials occurred on the adjacent parcel to the south (Parcel B) and is expected at the Site as part of the redevelopment process. 1.6 Applicability of this SMP This SMP describes protocols to be implemented if previously unknown waste pits (e.g . similar to the North and South Waste Cells on Parcel B; see Section 2.2) or other areas of obvious soil impacts with potentially hazardous materials (e.g. similar to that observed in excavation for utility trench as documented in Attachment 3 Figure 16 to the Order (Appendix A); see Section 2.3) are encountered during subsurface disturbance activities that may be conducted as part of ongoing and future Site redevelopment. This SMP does not supersede other approved Site documents, rather, the requirements of this SMP shall be implemented in addition to any other required work plan or permit for the Site. 1 RSLs for commercial industrial land use where the target risk (“TR”) is 10-6 and the hazard quotient (“HQ”) is 1.