Exhibit_A-5_-_Revised_Soil_Management_Plan.pdf

REVISED SOIL

MANAGEMENT PLAN

Richard J. Donovan Correctional Facility Otay Mesa, California 92179

APN 646-040-20

December 5, 2024

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D Exhibit A-5

PREPARED FOR

California Department of Corrections and Rehabilitation 9838 Old Placerville Road, Suite B Sacramento, California 95827

PREPARED BY

Weaver Consultants Group of California, LLC 1 Technology Drive, Suite C515 Irvine, California 92618-5302

Project No. 5989-300-02-01

REVISED SOIL

MANAGEMENT PLAN

Richard J. Donovan Correctional Facility Otay Mesa, California 92179

(APN 646-00-040-20)

December 5, 2024

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

December 5, 2024 Project No. 5989-300-02-01

Mr. Ewan Moffat, P.G., C.Hg.

COUNTY OF SAN DIEGO

DEPARTMENT OF ENVIRONMENTAL HEALTH

Site Assessment & Mitigation Program 5500 Overland Avenue, Suite 170 San Diego, California 92123

Revised Soil Management Plan Richard J. Donovan Correctional Facility

Otay Mesa, California

(APN 646-040-20)

Dear Mr. Moffat:

Attached is the Revised Soil Management Plan (SMP) for inert fill materials illegally imported to Assessor Parcel Number 646-040-20-00, which is partly occupied by the Richard J. Donovan Correctional Facility, in Otay Mesa, California. If you have any questions about the SMP, please do not hesitate to contact the undersigned at (949) 296-0977 Ext. 111 or at dsiren@wcgrp.com

Respectfully submitted, WEAVER CONSULTANTS GROUP OF CALIFORNIA, LLC

Deke Siren, P.G., C.Hg.

Project Manger

DCS:sh Enclosure P:\1477_CDCR_RJ Donovan\006_Response to LEA February 2024 Ltr\Revised SMP\Revised SMP_2024-12-05.docx

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

TABLE OF CONTENTS

Page TABLE OF CONTENTS .............................................................................................................. i LIST OF FIGURES ...................................................................................................................... ii LIST OF ABBREVIATIONS AND ACRONYMS ................................................................... iii

1.0 INTRODUCTION

1.1 BACKGROUND INFORMATION

1.1.1 Location and History

1.1.2 Initial Investigation - Avocet, 2017

1.1.3 Conceptual Plan - Avocet, 2017

1.1.4 Current Status

1.1.5 Contaminants of Potential Concern

1.2 SMP OBJECTIVES

1.3 SOIL SCREENING LEVELS

1.4 APPLICABILITY

1.5 CONTACTS

2.0 SOIL MANAGEMENT AND RELATED PROCEDURES

2.1 STANDARD CONSTRUCTION PROCEDURES

2.2 WORKER AND SITE SAFETY

2.3 FIELD SOIL SCREENING

2.4 IN-SITU SOIL CHARACTERIZATION

2.5 EXCAVATION, STOCKPILING, AND DUST CONTROL

2.6 STOCKPILE SAMPLING

2.7 CONFIRMATION SOIL SAMPLING

2.8 TRUCK LOADING

3.0 RECORD KEEPING AND REPORTING

REFERENCES

FIGURES

APPENDIX A: EXAMPLE FIELD FORMS

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

LIST OF FIGURES

Figure No. Title

1 Site Location Map 2 Site Vicinity 3 Conceptual Fill Map 4 Profile A-A’

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

LIST OF ABBREVIATIONS AND ACRONYMS

APN Assessor’s Parcel Number CalEPA California Environmental Protection Agency CDCR California, Department of Corrections and Rehabilitation CHASP Community Health and Safety Plan CoPC contaminant of potential concern DTSC California Department of Toxic Substances Control DTSC-SL DTSC-modified Screening Level EPA U.S. Environmental Protection Agency ESL Environmental Screening Level HASP Health and Safety Plan mg/kg milligram per kilogram OVA organic vapor analyzer PCB polychlorinated biphenyl PID photoionization detector PPE personal protective equipment RSL Regional Screening Level SDC Site Designation Committee SDCoDEH San Diego County Department of Environmental Health SFBRWQCB San Francisco Bay Regional Water Quality Control Board SMP Soil Management Plan SVOC semivolatile organic compound TPH total petroleum hydrocarbons TPH-d total petroleum hydrocarbons as diesel TPH-g total petroleum hydrocarbons as gasoline TPH-o total petroleum hydrocarbons as oil VAP Voluntary Assistance Program VOC volatile organic compound WCG Weaver Consultants Group of California, LLC

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

1.0 INTRODUCTION

This revised Soil Management Plan (SMP) specifies the procedures to be followed prior to, during, and after excavating or otherwise disturbing inert fill materials illegally placed on property owned by the California Department of Corrections and Rehabilitation (CDCR) in unincorporated San Diego County, northeast of Otay Mesa, California. The inert fill is located in the northeast corner of Assessor’s Parcel Number (APN) 646-040-20-00, a 406-acre parcel partially occupied by CDCR’s Richard J. Donovan Correctional Facility (RJ Donovan Facility). The locations of the RJ Donovan Facility and the inert fill area (the site) are shown in Figure 1, and a site plan is presented in Figure 2. Weaver Consultants Group of California, LLC (WCG), the successor in interest to Avocet Environmental, Inc. (Avocet)1, prepared this revised SMP on behalf of CDCR, which is preparing to stabilize the inert fill materials per Avocet’s November 27, 2017 Conceptual Plan for the Inert Fill (conceptual plan), which was approved by the San Diego County Department of Environmental Health (SDCoDEH), Solid Waste Local Enforcement Agency (LEA) in a letter dated March 21, 2018.

The subject revised SMP supersedes the January 19, 2024 SMP and is submitted pursuant to a February 13, 2024 conference call with the LEA. As documented in LEA’s subsequent letter dated February 21, 2024, CDCR was asked to update the SMP to include the following:

1. Describe the management of construction debris (i.e., crushed concrete and asphalt) and management of large pieces of concrete removed from fill proposed to be removed from the site. Will the debris management be similar to the soil management described in the January 19, 2024 Soils Management Plan, including stockpiling, loading, and transport to an approved recycling facility or landfill? If so, identify which section(s) will be identical for the management of construction debris and large pieces concrete removed from fill.

2. Describe management of other non-soil inert waste such as glass and plastic removed from fill, if encountered. If approach is similar to item 1 above, response can be included in item 1 response.

3. The April 7, 2017 Community Health and Safety Plan was prepared for implementation of the site investigation. Either update the 2017 CHSP or submit a stand alone CHSP for the implementation of the Concrete Debris Removal and Slope Stabilization project.

4. Provide professional engineer stamped project drawings, including re-grading of delineated fill area to stabilize existing slopes against erosion and slide risk, which as described in documents will not be less than 3:1 ratio.

1 On June 1, 2024, Avocet became part of Weaver Consultants Group, LLC (www.wcgrp.com) and is now Weaver Consultants Group of California, LLC.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan http://www.wcgrp.com/

5. Provide copy of final project-specific specifications as mentioned under General Notes item 1 on unstamped Drawing C01.

6. An initial deposit of $736.00 with the previously provided LEA application form 990.

The subject revised SMP is submitted with the intention of addressing LEA’s Comments 1 and 2 (Section 2.0 below). LEA’s other comments will be addressed in separate submittals.

1.1 BACKGROUND INFORMATION

Background information considered relevant for SMP purposes includes the site’s location and history, the results of the subsurface investigations conducted to date, the site’s current status, and the contaminants of potential concern (CoPCs) for soil management purposes.

1.1.1 Location and History

The RJ Donovan Facility and the inert fill site are located approximately 16 miles southeast of downtown San Diego, 2 miles north of the Mexican border, and 1.1 miles south of Lower Otay Reservoir. Lower Otay Reservoir is owned by the City of San Diego and drained by the Otay River, which passes within 3,000 feet to the northwest of the site enroute to its outfall in San Diego Bay. The site and much of the RJ Donovan Facility are located within the boundary of the San Diego National Wildlife Refuge (Otay-Sweetwater Unit).

On a more local basis, the site is on the west side of Alta Road, approximately 1 mile north-northwest of the intersection of Alta Road and Donovan State Prison Road (Figure 1) in the “buffer” around the RJ Donovan Facility to the south. The area around the site is undeveloped, undisturbed land with a cover of native vegetation, apart from the unpaved and unauthorized upper and lower access roads (Figure 2) to the privately owned Mr. Melvyn Ingalls parcels (Ingalls properties). The Ingalls properties are “land locked” in that they are not accessible from a public road and there is no easement for the “upper access road” across CDCR’s property (Figure 2).

Moreover, the Ingalls properties are not served by any utilities, although water was provided via an unauthorized pipeline, which also passes through CDCR property. Signage at the entrance to these access roads identifies the address of the Ingalls property as 405 Alta Road. As shown in Figure 2, the site is bordered by the Ingalls properties and an undeveloped parcel owned by the County of San Diego (APN 646-04-15-00) to the north, an Otay Water District property (APN 648-010-23-00) and another County of San Diego property (APN 646-04-15-00) to the east, and undeveloped portions of the subject CDCR parcel to the south and west.

In terms of topography, the site is located on the top and the northeasterly descending flank of a northwest-trending ridgeline (Figures 1 and 2). The natural topography has been modified by the illegal placement of fill materials, creating two relatively flat pads. Much of flat pads and the adjacent easterly descending slopes have been covered by crushed concrete. Vegetation on the areas covered by crushed concrete is generally sparse, but elsewhere the fill is moderately well vegetated by grasses and native weeds.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

The only known utilities in the vicinity of the site are an underground sanitary sewer line and the underground, unauthorized potable water line mentioned above. The sewer line, which includes a sewer lift station, appears to service the nearby George F. Bailey and East Mesa Juvenile Detention Centers and trends in an east-west direction immediately south of the site. The water line transects the site to service the Ingalls properties. The approximate alignments of these utilities are shown in Figure 2.

1.1.2 Initial Investigation - Avocet, 2017

On December 31, 2015, the LEA received a complaint referral from the County of San Diego Watershed Protection Program that the Ingalls properties was operating an unauthorized mobile home park and that imported fill had been illegally dumped on the south-adjoining CDCR property (LEA, March 25, 2016). The LEA investigated the complaint on January 6 and 25, 2016 and, based on its findings, issued Notice and Order No. 2016-02 to CDCR for two violations, one for the disposal of solid waste without having a solid waste facility permit, and the second for operating a solid waste facility without a solid waste facility permit (LEA, March 25, 2016).

Pursuant to these violations, Avocet assessed the inert fill site in accordance with a work plan (Avocet, November 3, 2016) approved by the LEA (LEA, December 16, 2016). Avocet conducted the assessment in April 2017 and documented it in a report dated July 12, 2017. In brief, the assessment involved 33 trenches, most of which were excavated through the entire thickness of the inert fill until underlying, native soil was encountered. Avocet identified five different types of imported fill materials, fill types Af1 through Af5. The locations of the trenches and the limits of the different fill types are shown in Figure 3, and a cross section through the filled area is presented in Figure 4. Representative samples of the fill materials were analyzed for a wide range of common contaminants, including asbestos; however, the reported concentrations, where detectable at all, were not of concern. Based on the assessment, Avocet estimated that the inert fill covers approximately 4.8 acres, with a volume of approximately 44,000 cubic yards (Avocet, July 12, 2017).

1.1.3 Conceptual Plan - Avocet, 2017

CDCR’s working assumption prior to Avocet’s July 12, 2017 assessment report had been that it would remove the inert fill and dispose of it in a local landfill. However, a preliminary cost estimate based on the larger-than-expected fill volume indicated this would cost on the order of $4 million. On August 30, 2017, the SDCoDEH, LEA, CDCR, and Avocet met to discuss the results of the assessment and options for the disposition of the fill material, one of which was to leave it in place. At this meeting, the LEA concurred that the fill essentially is inert and uncontaminated and, with the possible exception of the concrete/asphalt debris on the surface of a portion of the fill area, could probably be left in place. As County of San Diego departments other than the LEA would need to be consulted about leaving the fill in place, including possible permitting requirements, the LEA requested that CDCR submit a conceptual plan for managing the inert fill.

On November 27, 2017, Avocet submitted a conceptual plan that proposed leaving most of the inert fill onsite. The goal of the conceptual plan was to remove, to the extent practical, Fill

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

Types Af1 and Af5 and stabilize Fill Types Af2, Af3, and Af4 in such a way as to minimize erosion and the visual impact of leaving them in place. The conceptual plan was approved by the LEA in a letter dated March 21, 2018.

1.1.4 Current Status

After approving the conceptual plan in 2018, the LEA indicated that CDCR should request oversight from the California Environmental Protection Agency (CalEPA), Site Designation Committee (SDC). CDCR submitted the request on August 7, 2018, but on October 12, 2018, the SDC responded via email that based on Avocet’s July 12, 2017 assessment report, the inert fill site did not appear to be a “hazardous material release site” as defined by Health and Safety Code, Division 20, Chapter 6.65, Section 25260. As such, SDC indicated it had no jurisdiction and recommended that CDCR withdraw its request for CalEPA oversight, which CDCR did, and oversight remained with the LEA.

On February 13, 2020, Avocet submitted grading plans and specifications to the LEA based on the conceptual plan. Following this submittal, the LEA informed CDCR that oversight was being transferred to SDCoDEH. After DEH received the project from the LEA, it was suggested that CDCR enroll in DEH’s Voluntary Assistance Program (VAP). Following CDCR’s enrollment in the VAP, CDCR and SDCoDEH had several conference calls to bring SDCoDEH up to date on the project. Following a conference call with County of San Diego, Planning and Development Services Section on November 5, 2021, it was determined that no other permits were needed from the County of San Diego and that CDCR could proceed with implementing the conceptual plan as detailed in the grading plans and specifications.

1.1.5 Contaminants of Potential Concern

Based on the findings of the investigation conducted by Avocet and consistent with SDC’s October 18, 2018 email to CDCR, the area in which inert fill has been illegally deposited is not a “hazardous material site,” based on contaminant concentrations, where detectable, being negligible. As such, there are no site-specific CoPCs; however, the inert fill will be closely monitored for indications of contamination during the planned grading and stabilization activities and fill suspected of being impacted will be segregated and characterized to determine whether it can be reused onsite, i.e., incorporated into the stabilized fill, or must be transported offsite for disposal.

1.2 SMP OBJECTIVES

The purpose of this SMP is to ensure that the inert fill at the site is stabilized safely and in accordance with the plans approved by the LEA and the DEH. Specific objectives are as follows:

• Provide soil management and disposal options in compliance with federal, state, and/or local requirements.

• Ensure that proper waste characterization and management activities are conducted during site work.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

• Procedures are in place to minimize the potential for workers involved in grading activities to be unexpectedly exposed to impacted soil.

• Soil disturbed during grading is properly evaluated in terms of whether it is suitable for onsite reuse or should be transported offsite to an appropriate disposal or recycling facility.

To evaluate the inert fill in the context of onsite reuse, common contaminant concentrations, if any, will be compared to both commercial/industrial and residential screening levels.

Notwithstanding that the site will be left undeveloped as part of the open space around the RJ Donovan Facility. The screening levels (detailed in Section 1.3) will be applied as follows:

Onsite Soil Disturbed During Stabilization

No residential screening levels exceeded Disturbed soil can be reused onsite or exported for unrestricted offsite reuse

Residential screening levels exceeded but no commercial/industrial screening levels exceeded

Disturbed soil can be reused onsite or transported offsite for disposal or treatment

Commercial/industrial screening levels exceeded Disturbed soil should be transported offsite for disposal or treatment

1.3 SOIL SCREENING LEVELS

To evaluate disturbed soil in the context of onsite reuse or unrestricted offsite reuse, contaminant concentrations, if any and excluding arsenic, will be compared to commercial/industrial or residential screening levels developed by California Department of Toxic Substances Control (DTSC), the U.S. Environmental Protection Agency (EPA), and the San Francisco Bay Regional Water Quality Control Board (SFBRWQCB). In order of preference, WCG proposes to screen disturbed soil as follows:

• With the exception of arsenic, contaminant concentrations will be compared to the latest residential or commercial/industrial DTSC-modified Screening Levels (DTSC-SLs). As of the date this SMP, the most recent DTSC-SLs were published in June 2020.

• If DTSC-SLs are not available, and again with the exception of arsenic, contaminant concentrations will be compared to the latest EPA residential or commercial/industrial Regional Screening Levels (RSLs). As of the date this SMP, the most recent RSLs were published in November 2021.

• Concentrations of total petroleum hydrocarbons (TPH) as gasoline (TPH-g), as diesel (TPH-d), and as oil (TPH-o) will be compared to the latest SFBRWQCB Environmental Screening Levels (ESLs) for direct exposure. As of July 2019, these ESLs are as follows:

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

SFBRWQCB ESLs for Direct Exposure (Units are milligrams per kilogram or mg/kg)

Residential Shallow Soil

Commercial/Industrial Shallow Soil

Construction Worker

TPH-g 430 2,000 1,800 TPH-d 260 1,200 1,100 TPH-o 12,000 180,000 54,000

• As naturally occurring arsenic concentrations throughout the western United States are typically well above DTSC-SLs and EPA RSLs, arsenic concentrations will be compared to the accepted southern California background range of up to 12 mg/kg (Chernoff, et al., 2008).

The screening process above is intended to be conservative and simple to implement without having to seek SDCoDEH approval during the grading process.

1.4 APPLICABILITY

This SMP and the procedures herein apply only to grading that involves the removal or disturbance of soil within specific “project limits.” Activities that could involve excavation include removing concrete fill spread over most of the site and more general site grading as part of the stabilization process for the inert fill. For SMP purposes, project limits are defined as the lateral and vertical extent of the planned grading activity. Nothing in this SMP requires excavation of contaminated soil, if any, to depths or areas beyond the project limits.

1.5 CONTACTS

The following persons are familiar with environmental conditions at the site and can be contacted if there are any questions about this SMP or if conditions other than those anticipated in this SMP are encountered in the field.

Contact Affiliation Telephone Numbers

Michael Maeda CDCR Office: (279) 223-2759 Cell: (909) 703-9912

Deke Siren, P.G., C.Hg. WCG Office: (949) 296-0977 Ext. 111 Cell: (714) 742-3355

Philip Miller, P.E. WCG Office: (949) 296-0977 Ext. 102 Cell: (949) 933-6380

California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

2.0 SOIL MANAGEMENT AND RELATED PROCEDURES

General SMP procedures include screening disturbed soil for indications of contamination, characterizing suspected impacts, and managing disturbed soil with confirmed impacts.

2.1 STANDARD CONSTRUCTION PROCEDURES

Nothing in this SMP should be interpreted as relieving contractors or any other entity of their responsibly to follow standard construction procedures that may or may not be related to the environmental condition of the inert fill. Examples of such responsibilities include, but are not limited to, site safety, security of exclusion zones, construction dust control, construction stormwater management, evaluating excavation stability, and the like. In particular, this SMP requires that, in accordance with state law, Underground Service Alert of Southern California, aka DigAlert, must be notified a minimum of two full days prior to any intrusive work at the site so the appropriate utility companies have the opportunity to mark the locations of subsurface infrastructure, if any, beneath the site. DigAlert may be notified by telephone by dialing 811 or

(800) 422-4133 or online at www.newtinb.digalert.org/direct.

2.2 WORKER AND SITE SAFETY

The subject grading will be conducted in accordance with an updated version of the site-specific health and safety plan (HASP) prepared by Avocet for work at the site (Avocet, March 28, 2022).

The HASP identifies the potential chemical and physical hazards that may be encountered at the site, as well as the “generic” hazards associated with working in proximity to drilling, earthmoving, and other mechanized equipment. It also specifies the measures to be taken to avoid or minimize these hazards. The identification of potential chemical hazards is based on the types and concentrations of chemicals potentially present in the subsurface based on the types of operations known to have been conducted at and around the site. The identification of potential physical hazards is based primarily on the type(s) of investigation equipment expected to be used during the subsurface investigation, the potential for encountering and damaging subsurface or overhead utilities, and the potential hazards posed by external factors such as temperature. Based on the identified hazards, the HASP specifies the minimum level of personal protective equipment (PPE) to be worn (Level D), the type(s) of monitoring to be conducted, the circumstances under which the minimum PPE will be upgraded, and other protective measures. The HASP also provides emergency contact information and the route to the nearest hospital with an emergency room.

All field personnel are required to review the HASP prior to any fieldwork involving possible exposure to the potential chemical or physical hazards and sign a HASP Distribution Record form to acknowledge that they have reviewed it and agree to abide by its requirements. Subcontractors providing onsite services will have the option of following WCG’s or their own HASP, provided it is at least as stringent. A copy of the HASP will be kept onsite during all field activities.

Besides the HASP, the subject grading will also be conducted in accordance with a revised site-specific Community Health and Safety Plan (CHASP). The CHASP (Avocet, April 7, 2017) was

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan http://www.newtinb.digalert.org/direct previously prepared at the request of the LEA to ensure that public health was protected during the 2017 site investigation (Section 1.1.2). The primary purpose of the CHASP is to promote a safe work environment relative to the public by reducing the potential for community exposures to potential hazards and nuisances. The CHASP specified general control measures to be followed, including dust control and stormwater Best Management Practices (BMPs), to minimize hazards to the surrounding community. The CHASP also provides emergency contact information and the route to the nearest hospital with an emergency room. A copy of the revised CHASP will be kept onsite throughout the fieldwork for reference, as necessary.

2.3 FIELD SOIL SCREENING

Screening will be conducted whenever potentially impacted soil is disturbed within the project limits (Section 1.4). Field screening disturbed soil for indications of contamination will involve visual and olfactory observation and screening for organic vapors using a properly calibrated photoionization detector (PID) or equivalent organic vapor analyzer (OVA). Indications of potential contamination might include, but not be limited to, the following:

• Soil discoloration or staining when compared to the natural color of soil exposed elsewhere within the project limits.

• Saturated or excessively moist soils when compared to the natural moisture content of soil exposed elsewhere within the project limits.

• Odors in ambient air when soil is disturbed. It is noted in this regard that soil should not be held close to the nose to determine whether odors are present.

• Elevated PID/OVA readings indicating the presence of organic vapors.

• Soils containing pieces of pipe, tile, or other debris that may be asbestos-containing material.

This SMP requires that if any of the above conditions are encountered, the soil disturbing activity be suspended and that contractor personnel notify WCG immediately.

2.4 IN-SITU SOIL CHARACTERIZATION

If impacted soil is encountered or suspected during grading, it may be appropriate, prior to disturbing additional soil, to collect one or more representative in-situ soil samples for laboratory analysis to assess whether and what type(s) of contamination may be present. The scope of in-situ soil sampling is highly dependent on the location-specific conditions, but in general, samples for laboratory analysis should be collected, preserved, and managed in accordance with industry-standard procedures, including sample chain of custody. The types of analyses to be conducted are similarly highly dependent on the location-specific conditions, but based on the site’s history, soil sample analyses should, at a minimum, include:

• TPH with carbon-chain speciation using EPA Method 8105M CC

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• Volatile organic compounds (VOCs), including fuel oxygenates, using EPA Method 5035/8260B

• Title 22 metals using EPA Method 6010B/7471A

Additional analyses, such as for polychlorinated biphenyls (PCBs), semivolatile organic compounds (SVOCs), and/or organic lead, may be warranted based on the conditions observed at the site and the results of the analyses listed above.

2.5 EXCAVATION, STOCKPILING, AND DUST CONTROL

If impacted soil, soil suspected of being impacted, and/or other debris is excavated, it should be stockpiled on heavy-duty polyethylene sheeting until it has been characterized to determine whether it can be reused onsite or must be transported offsite for treatment or disposal. Stockpiles of contaminated soil must also be covered with heavy-duty polyethylene sheeting or other covering to minimize emissions to the atmosphere for any period of inactivity lasting more than one hour.

As good practice, WCG recommends that stockpiles of potentially contaminated soil be covered and managed as contaminated until sampling and analysis shows otherwise. The following provides general and generic guidance on excavation, segregation, and related dust control procedures.

• During excavation, potentially impacted soil, when encountered, should be segregated, to the extent practical, from soil judged to be “clean.” Obviously stained/odorous/impacted soil should be “surgically” removed and stockpiled separately. Segregation may be based on the soil’s appearance, PID readings, or similar.

• If during excavation foreign objects such as construction debris and/or other non-soil inert wastes (i.e. concrete, asphalt, glass, and plastic) should be found, they should be segregated, to the extent practical. Once removed, debris and/or other wastes will be temporarily stored onsite until they are characterized, as needed, and either recycled or disposed of at an appropriate offsite facility.

• Potentially impacted soil with different characteristics should be segregated and stockpiled separately in discrete stockpiles. This may result in additional stockpile assessment costs but can prevent cross-contamination between stockpiles, resulting in more soil than necessary having to be transported offsite.

• To minimize the potential for a small volume of contaminated material to impact a large stockpile, resulting in increased disposal costs, the size of any individual stockpile should be limited to no more than 200 cubic yards.

• Impacted soil or suspected impacted soil should be stockpiled on 10-mil polyethylene sheeting and covered with the same to minimize potential

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan contaminant volatilization to the atmosphere or dispersion via wind or precipitation. Adjoining sheets of polyethylene should overlap by at least 3 feet.

• Stockpile covers should be weighted down with sandbags or similar to prevent the cover being blown off or damaged during windy conditions.

• Covered stockpiles should be surrounded, as necessary, by straw rolls, straw bales, or similar to minimize the potential for eroded sediment to be transported beyond the stockpile area.

• Covered stockpiles should be inspected on a weekly basis and the covers repaired, replaced, adjusted, or supplemented. An example of a “Stockpile Inspection Record” form is included in Appendix A to this SMP.

• If odors or dust are detectable at the site boundary during the placement or removal of contaminated soil stockpiles, the “active” stockpile surface should be misted or lightly sprayed with water to minimize dust generation and odors in ambient air.

Misting or lightly spraying newly cut and exposed soil surfaces may also be appropriate.

It is noted that if impacted soil has been characterized in situ (Section 2.4) and the ultimate disposition of the impacted material has been established, excavated material may be “direct loaded” into trucks for offsite disposal or treatment, thereby bypassing the stockpiling process.

2.6 STOCKPILE SAMPLING

Stockpiled soil, including soil thought to be “clean,” should be sampled to obtain representative data and determine its ultimate disposition. To ensure the analytical results are representative, samples should be collected at multiple locations and at different depths into the stockpile.

Samples should not be collected less than 6 inches into the stockpile to help avoid potentially underestimating VOC concentrations. The number of stockpile samples to be collected may differ depending on the intended disposition of the excavated soils (onsite reuse versus offsite disposal), and different soil disposal facilities may have different requirements in terms of the number of samples to be analyzed and the analytical parameters. In broad terms, however, the number of stockpile samples collected for analysis should be proportional to the volume of the stockpile.

Guidance on the minimum number of stockpile samples to be collected is as follows:

• Collect a minimum of one discrete sample for every 50 cubic yards in stockpiles up to the maximum recommended volume of 200 cubic yards.

• Analyze each of the discrete stockpile samples for VOCs, including fuel oxygenates, using EPA Method 5035/8260B.

If the stockpiled material appears to be uniform, the discrete stockpile samples may be combined into a single composite sample for analysis for TPH and Title 22 metals using EPA Methods 8015M CC and 6010B/7471A, respectively; however, the discrete samples should be

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Bid Number C5613351-D composited in and by the analytical laboratory, as opposed to in the field. Moreover, the unused portions of the discrete samples should be refrigerated at the laboratory until the results of the composite sample analyses have been received and evaluated so that the discrete samples can, if warranted, be analyzed individually. Additional analyses, such as for PCBs, SVOCs, and organic lead, may be warranted based on the conditions observed at the site and the results of the analyses listed above.

The results of the stockpile sample analyses will be compared to the screening levels specified in Section 1.3. If the concentrations of any contaminant exceed commercial/industrial screening levels, the stockpiled soil will be transported offsite for disposal or treatment. However, if the screening process indicates that a large volume of soil must be transported offsite for disposal, it may be appropriate to develop less conservative, site-specific, risk-based screening levels for regulatory agency approval.

2.7 CONFIRMATION SOIL SAMPLING

On completion of an excavation from which impacted soil has been removed, confirmation soil samples will be collected from the floor and/or sidewalls to assess residual contaminant concentrations prior to the excavation being backfilled. The scope of the confirmation sampling effort will be highly dependent on the location-specific conditions, but in general, samples for laboratory analysis will be collected from the floor and sidewalls of the excavation, preserved, and managed in accordance with industry-standard procedures, including sample chain of custody. At a minimum, one confirmation soil sample for every 30 linear feet of sidewall and every 1,000 square feet of floor area will be collected for analysis. The types of analyses to be conducted are similarly highly dependent on the location-specific conditions, but based on the site’s history, the analyses will, at a minimum, include:

• TPH with carbon chain speciation using EPA Method 8105M CC

• VOCs, including fuel oxygenates, using EPA Method 5035/8260B

• Title 22 metals using EPA Method 6010B/7471A

Additional analyses, such as for PCBs, SVOCs, and organic lead, may be warranted based on the conditions observed at the site and the results of the analyses listed above.

2.8 TRUCK LOADING

If impacted soil cannot be utilized onsite, it should be transported offsite for treatment or disposal.

When loading trucks with impacted material for offsite treatment or disposal, the following general procedures should be followed:

• Mist or lightly water the impacted soil when placing it in trucks or bins.

• Minimize “drop heights” when loading trucks or bins.

• Impacted soil in trucks should be covered with tarpaulins or similar prior to leaving the site.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

• Prior to leaving the site, trucks and bins should be thoroughly inspected, particularly truck wheels and undercarriages, to ensure there is no loose dirt that may fall off onto public streets.

• Public streets near the site used by trucks transporting impacted soil offsite should be inspected on a daily basis for debris and/or dust accumulations and swept, as necessary.

Trucks and bins may be filled with stockpiled material or direct loaded once an impact has been confirmed and characterized. Proper documentation related to material transported offsite will be maintained, including hazardous and nonhazardous waste manifests, bills of lading, scale tickets, and disposal facility receipts.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

3.0 RECORD KEEPING AND REPORTING

All of the records mentioned in the preceding sections of this SMP will be maintained for inclusion in a report to be prepared on substantial completion of the stabilization effort. At a minimum, the report will include the following:

• A summary of relevant background information and narrative descriptions of field and laboratory procedures.

• Summaries of the soil impacts and other debris encountered at the site, if any, and their ultimate disposition, including location information, estimated volumes, in-situ characterization data (if any), the volume of soil removed, the results of confirmation soil sample analyses, and the disposition of the removed soil. If the removed soil is reused onsite, its approximate onsite location should also be documented to the extent practical.

• A summary of post-stabilization site conditions and an evaluation of potential hazards, if any, that could be encountered by future site occupants or workers involved in site maintenance or other activities that could involve soil disturbance.

Tables, figures, and appendices, as necessary. Tables will include summaries of analytical data, the volumes of soil exported and their ultimate dispositions, and the volumes of soil imported to the site. Figures will show excavation locations. Attachments to the site redevelopment report will include stockpile management data, laboratory analytical reports, waste manifests, and the like.

Respectfully submitted, WEAVER CONSULTANTS GROUP OF CALIFORNIA, LLC

Deke Siren, P.G., C.Hg.

Project Manager

Signed and sealed December 5, 2024

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

REFERENCES

Avocet Environmental, Inc., November 3, 2016, Work Plan for Initial Investigation of Illegal Fill, APN 646-040-20, Richard J. Donovan Correctional Facility, Otay Mesa, California.

Avocet Environmental, Inc., April 7, 2017, Community Health and Safety Plan, Environmental Services, APN 646-040-20, Richard J. Donovan Correctional Facility, Otay Mesa, California.

Avocet Environmental, Inc., July 12, 2017, Illegal Fill Site Assessment, APN 646-040-20, Richard J. Donovan Correctional Facility, Otay Mesa, California.

Avocet Environmental, Inc., November 27, 2017, Conceptual Plan for the Inert Fill, APN 646- 040-20, Richard J. Donovan Correctional Facility, Otay Mesa, California.

Avocet Environmental, Inc., March 28, 2022, Health and Safety Plan, Environmental Services, Richard J. Donovan Correctional Facility, Otay Mesa, California, APN 646-040-20.

Avocet Environmental, Inc., January 19, 2024, Soil Management Plan, Richard J. Donovan Correctional Facility, Otay Mesa, California, APN 646-040-20.

California Department of Toxic Substances Control (DTSC), June 2020 “Human Health Risk Assessment Note 3, DTSC-Modified Screening Levels (DTSC-SLs).”

California Department of Corrections and Rehabilitation (CDCR), August 7, 2018, Request for Consolidations of Oversight, Richard J. Donovan Correctional Facility Assessor Parcel Number 646-040-20, Otay Mesa, California.

California Environmental Protection Agency-Site Designation Committee (SDC), October 12, 2018, Application for Designation of Administering Agency: CDCR APN 646-040-20-00.

Email to CDCR.

Chernoff, G., W. Bosan, and D. Oudiz, 2008, “Determination of a Southern California Regional Background Arsenic Concentration in Soil,” prepared for California Department of Toxic Substances Control.

San Diego County Department of Environmental Health, Solid Waste Local Enforcement Agency (LEA), March 25, 2016, Notice and Order 2016-02 for Accessor Parcel Number (APN) 646-040-02-00. Letter to CDCR.

San Diego County Department of Environmental Health, Solid Waste Local Enforcement Agency (LEA), December 16, 2016, Work Plan for Investigation Activities on the State of California, Department of Corrections and Rehabilitation Property with Assessor Parcel No. 646-040-02-00. Letter to CDCR.

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San Diego County Department of Environmental Health, Solid Waste Local Enforcement Agency (LEA), March 21, 2018, Conceptual Plan for Inert Fill on the State of California, Department of Corrections and Rehabilitation Property with Assessor Parcel No. 646-040- 02-00. Letter to CDCR.

San Diego County Department of Environmental Health, Solid Waste Local Enforcement Agency (LEA), February 21, 2024, letter regarding Concrete Debris Removal and Slope Stabilization Project, Notice and Order No. 2016-02, Compliance Order for APN 646-040- 20-00, Alta Road (ST CA), 405 Alta Road, San Diego, CA 92154, SWIS# 37-CR-0128.

Letter to CDCR.

San Francisco Bay Regional Water Quality Control Board (SFBRWQCB), July 2019, “Environmental Screening Levels.”

U.S. Environmental Protection Agency, November 2021, “Regional Screening Level (RSL) Summary Table (TR=1E-06, HQ=1) November 2021,” at https://semspub.epa.gov/ work/HQ/400750.pdf.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D Exhibit A-5 https://semspub.epa.gov/work/HQ/400750.pdf https://semspub.epa.gov/work/HQ/400750.pdf

Figures

California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

APPROXIMATE LIMITS OFINERT FILL SITE

STATE OF CALIFORNIA DEPARTMENT OFCORRECTIONS AND REHABILITATIONAPN 646-040-20-00

Copyright:© 2013 National Geographic Society, i-cubed

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FIGURE 1

SITE LOCATION MAP

INERT FILL SITERJ DONOVAN CORRECTIONAL FACILITY

PREPARED FOR

STATE OF CALIFORNIADEPARTMENT OF CORRECTIONSAND REHABILITATION

SCALE

CAL I FORN IA

SITE LOCATION

0 2,000 4,000

FEET

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

SEWER LIFTSTATION

Unnamed Drainage

O'NEIL CANYON

APN 648-010-23-00OTAY WATER DISTRICT"ROLL RESERVOIR"

APN 646-040-13-00COUNTY OF SAN DIEGO

APN 646-040-15-00COUNTY OF SAN DIEGO

APN 646-040-07-00INGALLS PROPERTIES

APN 646-040-08-00INGALLS PROPERTIES

APN 646-040-16-00OTAY WATER DISTRICT

APN 646-040-14-00OTAY WATER DISTRICT

ALTA ROAD

APN 646-040-20-00STATE OF CALIFORNIA

APN 648-010-32-00COUNTY OF SAN DIEGO

APPROXIMATE LIMITS OFINERT FILL SITE

UPPER ACCESS ROAD

LOWER ACCESS ROAD

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SCALE

0 200 400

FEET

EXPLANATION

APPROXIMATE EXTENT OFINERT FILL SITE

K

KS APPROXIMATE LOCATIONOF SANITARY SEWER LINE

K

KW APPROXIMATE LOCATIONOF WATER LINE

PARCEL BOUNDARY

VERNAL POOL

REFERENCE:USGS AERIAL PHOTOGRAPHDATED: OCTOBER 2014

FIGURE 2

SITE VICINITY

INERT FILL SITERJ DONOVAN CORRECTIONAL FACILITY

PREPARED FOR

STATE OF CALIFORNIADEPARTMENT OF CORRECTIONSAND REHABILITATION

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

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480485495

APN 646-040-15-00 (COUNTY OF SAN DIEGO)

APN 646-040-20-00 (STATE OF CALIFORNIA)

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T24-A T19-A

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EXPLANATION

V:\1477_CDCR_RJ Donovan\1477_5989-300-02-01\001_1477_5989-300-02-01_Conceptual_Fill_Map.dwg\09/17/24

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Af1 AND Af5: CRUSHED CONCRETE

Af2, Af3, AND Af4: INERT SOIL FILL

Af6: BROWN SANDY SILT (ML) - FILL DERIVED FROM ONSITE NATIVE

MATERIAL

Tof: OTAY MESA FORMATION, FANGLOMERATE FACIES - REDDISH-BROWN, ARGILLACEOUS, MATRIX-SUPPORTED CONGLOMERATE - BEDROCK, WITH

LOCAL OCCURRENCES OF TOP SOIL (TAN AND KENNEDY, 2002)

GEOLOGIC CONTACT, DASHED WHERE APPROXIMATE

DIRT ROAD

PROPERTY LINE

TRENCH LOCATION (NOT TO SCALE)

SCALE

0 100 200 FEET

TRACE OF GEOLOGIC PROFILE SECTION

SANITARY SEWER LINE (APPROXIMATE)

WATER LINE (APPROXIMATE)

ARTIFICIAL FILL (Af)

NATIVE MATERIAL

NOTE: 1-FOOT CONTOUR INTERVALS

BACKGROUND SAMPLES

SOURCE: CONTOURS FROM

AEROTECH MAPPING. DATED

09/23/2016.

FIGURE 3

CONCEPTUAL FILL MAP

INERT FILL SITE

RJ DONOVAN CORRECTIONAL

FACILITY

PREPARED FOR

STATE OF CALIFORNIA

DEPARTMENT OF

CORRECTIONS

AND REHABILITATION

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

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FIGURE 4

PROFILE A-A'

INERT FILL SITE

RJ DONOVAN CORRECTIONAL FACILITY

PREPARED FOR

STATE OF CALIFORNIA

DEPARTMENT OF CORRECTIONS

AND REHABILITATION

HORIZONTAL SCALE

0 40 80 FEET

2X VERTICAL EXAGGERATION

EXPLANATION

CROSS SECTION LOCATION MAP

N

Af1 AND Af5: CRUSHED CONCRETE

Af2, Af3, AND Af4: INERT SOIL FILL

Tof: OTAY MESA FORMATION, FANGLOMERATE FACIES - REDDISH-BROWN, ARGILLACEOUS, MATRIX-SUPPORTED CONGLOMERATE - BEDROCK, WITH

LOCAL OCCURRENCES OF TOP SOIL (TAN AND KENNEDY, 2002)

GEOLOGIC CONTACT, DASHED WHERE APPROXIMATE

ARTIFICIAL FILL (Af)

NATIVE MATERIAL

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

Appendix A Example Field Forms

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

STOCKPILE INSPECTION RECORD SITE NAME:

SCAQMD RULE 1166 VOC-CONTAMINATED SOIL ADDRESS:

CITY:

Date Inspector Nature of Cover Condition of Cover

Seams Overlap and Secure?

Conditon of Seams Comments

Inspector: Please visually inspect all seams and plastic cover surfaces. Note any holes, tears or any other potential sources of fugitive emissions. Note any repairs or other mitigation measures.

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California Department of Corrections and Rehabilitation (CDCR) Revised Soil Management Plan

Bid Number C5613351-D

APPENDIX A: Example Field Forms