Soil_Management_Plan.pdf

1725 Victory Boulevard, Glendale, California 91201 / P 818.246.2707 / F 818.246.3145 www.CitadelEHS.com

February 3, 2025

Bahareh Ertezaei Case Manager Department of Toxic Substances Control 9211 Oakdale Avenue Chatsworth, California 91311

CITADELRe: Project No. 1424.1006.0 Soil Management Plan Kinneloa Avenue Property (Site Code 300767)

159 South Kinneloa Avenue Pasadena, California 91107

This SMP has been prepared to satisfy the conditions of the Land Use Covenant (LUC) recorded between the City of Pasadena and DTSC for the Site, which requires DTSC approval of a SMP before any soil disturbing activities (i.e., borings, excavation, grading, removal, trenching, or earthwork) may occur.

If, after your review, you have any questions or require any additional information, please contact me by phone at (818) 246-2707 or by email at cjones@citadelehs.com.

Sincerely, CITADEL EHS

Cameron Jones, M.S., P.E.

Project Engineer, Engineering and Environmental Sciences

Enclosure

Dear Ms. Ertezaei:

Citadel EHS (Citadel) is pleased to provide the Department of Toxic Substances Control (DTSC) with this Soil Management Plan (SMP) for the Kinneoloa Avenue Property (Site Code 300747 / EnviroStor ID 19390051), located at located at 159 South Kinneloa Avenue, Pasadena, California 91107 (Site).

City of Pasadena 100 North Garfield Avenue Pasadena, California 91101

Soil Management Plan

February 3, 2025

Citadel Project Number 1424.1006.0

Kinneloa Avenue Property (Site Code 300767)

159 South Kinneloa Avenue Pasadena, California 91107 www.CitadelEHS.com

CITADEL PROJECT NO. 1424.1006.0

SOIL MANAGEMENT PLAN

CITY OF PASADENA

159 SOUTH KINNELOA AVENUE

PASADENA, CALIFORNIA 91107

FEBRUARY 3, 2025

Table of Contents

1.0 INTRODUCTION

1.1 Site Information

1.2 Background

1.3 Objective and Purpose

1.3 Health and Safety Plan

1.4 Stormwater Pollution Prevention

1.5 Temporary Fencing and Signage

1.6 Site Security

1.7 Environmental Monitoring

2.0 GEOLOGY/HYDROGEOLOGY

3.0 POTENTIAL AREAS OF CONCERN SUBJECT TO SMP REQUIREMENTS

4.0 PRELIMINARY SOIL CHARACTERIZATION

5.0 UNKNOWN SUBSURFACE STRUCTURES

6.0 SOIL DISTURBANCE MONITORING

6.1 Soil Monitoring (SCAQMD Rule 1166)

6.2 Nuisance Monitoring (SCAQMD Rule 402)

6.3 Dust Monitoring (SCAQMD Rule 403)

6.4 Soil Sampling and Laboratory Analysis

6.5 Laboratory Results Comparative Analysis

7.0 EXPOSURE MONITORING

7.1 Action Levels and Exposure Limits

8.0 CONTAMINATED SOIL MANAGEMENT

8.1 Soil Handling and Storage

8.2 Air Monitoring During Soil Staging

8.3 Stockpiling

8.4 Containerizing

8.5 SWPPP Best Management Practices

8.6 Decontamination Measures

8.7 Disposal

8.8 Transportation

8.9 Importation of Fill

9.0 REPORTING

10.0 REFERENCES

11.0 SIGNATURES

FIGURES

Figure 1 Site Location Map Figure 2 Development Site Plan with Area of Concern

APPENDICES

Appendix A SCAQMD Rule 1166 Appendix B SCAQMD Rule 402 Appendix C SCAQMD Rule 403

1424.1006.0 Soil Management Plan 1

1.0 INTRODUCTION

Citadel EHS (Citadel), on behalf of the City of Pasadena (City; Owner) and Michael Baker International (Michael Baker; Client) has prepared this Soil Management Plan (SMP) for the Kinneoloa Avenue Property (Site Code 300747 / EnviroStor ID 19390051), located at located at 159 South Kinneloa Avenue, Pasadena, California 91107 (Site; Figures 1 and 2). This SMP has been prepared in support of the proposed construction of the Pasadena Hydrogen Fueling Station (Facility) at the Site.

Previous environmental investigations at the Site have determined that impacts of contaminants of potential concern (COPCs); specifically, volatile organic compounds (VOCs) present in Site soils and soil vapor and semi-volatile organic compounds (sVOCs), heavy metals, petroleum hydrocarbons, and polycyclic aromatic hydrocarbons (PAHs) are present in Site soils.

The Site was further investigated under DTSC oversight and in 2001, the City executed a Land Use Covenant (LUC) identifying restrictions for future use and requiring notification to DTSC in the event that the soil is disturbed. This SMP has been prepared to satisfy the conditions of the LUC, which requires DTSC approval of a SMP before any soil disturbing activities (i.e., borings, excavation, grading, removal, trenching, or earthwork) may occur.

1.1 Site Information

The Site is located at 159 South Kinneloa Avenue, Pasadena, California. The Site consists of a single irregular-shaped parcel, identified by Assessor’s Parcel Number (APN) 5754-007-906, and is located on the west side of South Kinneloa Road. The Site is bounded on the west by Eaton Wash, a stormwater drainage channel, and to the north and south by adjacent commercial developments.

Across South Kinneloa Avenue to the east are nursery and garden supply retailers. At the time of this SMP preparation, the Site is currently vacant and is approximately 1.5 acres in size.

The City has proposed the construction of the Facility at the Site, consisting of a new hydrogen fueling facility to support the City’s new fleet of fuel-cell electric buses (FCE buses). The facility will have on- Site liquid storage of 18,000 gallons gross capacity, capable of fueling 50 FCEBs daily with a one-day reserve and potential to increase fueling capacity to support future expansion of the Transit Division’s hydrogen fleet and other City non-transit vehicles. The current plan does not include making the station available for public use; the station will only be used by City-owned vehicles. Hydrogen will not be made on-Site; it will be supplied by a third-party hydrogen supplier. The southern portion of the Site is pending future improvement plans and will not include habitable structures.

1.2 Background

The Site was undeveloped prior to the early 1940s. During the 1940s, approximately 20 buildings were constructed on-Site in association with a former machine manufacturing business by Vard, Incorporated (Vard). Vard ceased operation prior to 1947 and vacated the Site. The City acquired the Site in 1947. By 1970, the Site was vacant, with all buildings removed from the Site. A heliostat consisting of a tower and mirrors was installed in 2014 and operated by Edisun Heliostats. Aside from the heliostat installation, the Site has been continuously vacant since 1970.

A series of environmental investigations from 1989 to 2001 indicated that the underlying soil and soil vapor were impacted with petroleum hydrocarbons, VOCs, sVOCs, and heavy metals, specifically

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lead and cadmium. In November 1998, the City applied for and received a Brownfields Grant from the United States Environmental Protection Agency (USEPA) to further characterize the Site. A Brownfields Site Assessment Report (Ecology and Environment, Inc., 2001) was prepared which summarized the Site’s history and the results of the previous environmental investigations. The Brownfields Site Assessment Report determined that impacts of COPCs in shallow soil remained present and that contact with contaminated soil through inhalation, dermal contact, and/or ingestion poses a risk to human health.

In September 2001, the City executed a LUC. The LUC identifies the following restrictions:

Prohibited Uses:

A residence, including any mobile home or factory-built housing, constructed or installed for use and residential human habitation;

A hospital for humans;

A public or private school for persons under 21; or, A day care center for children.

Soil Management:

No activities that will disturb the soil shall be allowed on-Site without an appropriate SMP and Health and Safety Plan (HASP).

Any contaminated soil brought to the surface by grading, excavation, trenching, or backfilling shall be managed in accordance with all applicable provisions of state and federal law.

The Owner shall provide DTSC written notice at least 14 days prior to any building, filling, grading, mining, or excavating in the Site soils.

Department Access:

DTSC and its designees shall have reasonable right of entry and access to the Property for inspection, monitoring, and other activities consistent with the purpose of the LUC as deemed necessary by the DTSC in order to protect public health of safety, or the environment.

1.3 Objective and Purpose

The objective of this SMP is to establish policy and requirements for the grading, management, and disposal of soils generated during development activities, such as demolition, excavation, construction, and other general earthwork activities that might disturb potentially contaminated soils at the Site.

This SMP describes specific soil-handling controls required for complying with local, state, and federal oversight agencies; preventing unacceptable exposure to contaminated soil to workers and the general public; and preventing the improper disposal of contaminated soils. This SMP applies to soil-disturbing activities performed at the Site, which include excavation, grading, trenching, utility installation or repair, and any other Site work activities that will potentially bring contaminated soil to the surface. The SMP applies to such work regardless of the entity performing the work.

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The following personnel/entities will have authority over the various aspects of the planned onsite activities:

Organization

Personnel

Responsibilities

Owner City of Pasadena Overall site management and control

General Contractor TBD Site management; construction management; SMP implementation; Site security

Environmental Consultant

Citadel EHS

SMP implementation; South Coast Air Quality Management District (SCAQMD) Rule 1166 soil excavation monitoring and reporting; SCAQMD Rule 1166 permit;

SCAQMD Rules 402, 403, and 1166 oversight; soil sampling

Stormwater Management

TBD

Stormwater Pollution Prevention Plan (SWPPP) development and implementation

1.3 Health and Safety Plan

In accordance with the conditions of the LUC, a Site-specific HASP has been prepared by Citadel and has been submitted to DTSC for approval in conjunction with this SMP. The HASP will identify existing and potential hazards for workers at the Site during excavation activities and provide emergency procedures and identification of emergency facilities.

Subcontractors conducting the work will be responsible for preparing their own HASPs and for operating in accordance with the most current Occupational Safety and Health Administration (OSHA) regulations, including 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response and 29 CFR 1926, Construction Industry Standards as well as other applicable Federal, State and local laws and regulations.

1.4 Stormwater Pollution Prevention

For projects greater than 1 acre in size, or greater than 0.25 acres and part of a larger development, a SWPPP is required. The SWPPP will be developed by a Qualified SWPPP Developer and implemented by a Qualified SWPPP Practitioner on behalf of the Owner. The Owner will apply for the permit and submit the SWPPP to the Regional Water Quality Control Board through the SMARTS system prior to the initiation of development activities.

1.5 Temporary Fencing and Signage

Fencing with windscreen shall be installed around the perimeter of the Site to minimize wind-blown transport of soil and potential contaminants during earthwork activities. Access to the Site shall be restricted to work personnel, and Site gates shall be locked and secured when Site personnel are not present. Daily logs shall be recorded by the General Contractor to monitor personnel entering and leaving the Site. Appropriate warning signs regarding the ongoing construction shall be posted on the fence. A sign providing the SCAQMD telephone number for air quality complaints shall also be posted. The signs shall be written in English and Spanish.

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1.6 Site Security

The General Contractor shall be responsible for overall Site security, including controlling Site access, and restricting access by anyone other than work personnel and DTSC inspectors. The Site perimeter shall have a fence to prevent unauthorized entry. Site gates shall be monitored during work hours and locked when Site personnel are not present or after working hours.

1.7 Environmental Monitoring

The Environmental Consultant will be responsible for oversight of excavation and soil-disturbing activities in any contaminated areas encountered, to ensure proper handling and management of contaminated soils, and to ensure that all aspects of SCAQMD Rules 1166, 402, and 403 are followed.

2.0 GEOLOGY/HYDROGEOLOGY

Based on a review of available documents (Ecology and Environment, Inc., 2001 and Diaz ● Yourman & Associates, 2024), the Site is located in the Los Angeles Basin, a portion of the northernmost Peninsular Ranges Geomorphic Province of California, and is characterized by blocks encompassing coastal plains, synclinal basins, and uplifted hills that slope towards the sea. The Site is located on the Northeastern Block, a triangular wedge about 35 miles long that encompasses the San Gabriel Valley.

Site soils generally consist of approximately 29 feet of fill material, primarily composed of silty sands, clayey sands, and poorly-graded sands with some gravels and cobbles. The Site is underlain by Quaternary alluvium, primarily composed of floodplain and streambed deposits of unconsolidated gravel, sands, and silts.

Groundwater at the Site is approximately 200 feet below ground surface (bgs), and is not expected to be encountered during any investigation or development activities. The nearest surface water to the Site is Eaton Wash, which is directly adjacent to the western and southwestern property boundary.

Eaton Wash is a concrete-lined channel used for flood control.

3.0 POTENTIAL AREAS OF CONCERN SUBJECT TO SMP REQUIREMENTS

This SMP applies to Areas of Concern (AOCs) where COPCs are known or suspected to be present in soil at the Site. Previous environmental investigations have determined Site-wide impacts of COPCs are present at the Site. The AOC, as defined for this Site, encompasses the entirety of the Site. Refer to Figure 2 for a Site Plan with AOCs.

4.0 PRELIMINARY SOIL CHARACTERIZATION

As part of the investigation and remedial actions proposed as part of the overall development, various amounts of soil will be disturbed. Prior to the start of development activities, Citadel will perform a soil and soil vapor investigation to better delineate the Site-specific impacts of COPCs in soil and soil vapor. If impacted soil not previously profiled is identified during excavation activities, suspect soils will be segregated and sampled to determine the presence (or absence) of COPCs.

Soil sampling and laboratory analysis procedures are further described in Section 6.4.

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5.0 UNKNOWN SUBSURFACE STRUCTURES

Any construction debris or materials will be separated for proper identification and disposal. If any unknown subsurface structures such as underground storage tanks (USTs), clarifiers, vaults, conduit, asbestos-cement (Transite) pipe, piping, or construction debris, the following procedure will take place:

1. All work will stop in the immediate vicinity of the encountered structure.

2. The Owner, General Contractor, and Environmental Consultant (if not present on Site) will be immediately notified to observe if the structure is intact or has been damaged, potentially causing a release of contents into the subsurface.

3. The structure contents will then be sampled and analyzed for potential hazardous chemicals, followed by recommendations for proper disposal.

4. The Environmental Consultant will be present during the removal of any suspect or unknown subsurface structures encountered during excavation activities to visually observe the subsurface conditions following removal and collect soil samples from the excavation depth and sidewalls as necessary to evaluate the soil for the presence of COPCs.

5. If a UST is discovered, the City of Pasadena Fire Department – Hazardous Materials Section and the Los Angeles County Fire Department will be notified followed by the appropriate measures to remove the UST and residual contents.

The Environmental Consultant will be present during the removal of any suspect or unknown subsurface structures, if encountered, to visually observe the subsurface conditions following removal and collect soil samples from the excavation depth and sidewalls to evaluate the soil for the presence of COPCs.

6.0 SOIL DISTURBANCE MONITORING

This section outlines the requirements for soil monitoring, protocols for handling, transporting, and disposing of impacted soil, and appropriate regulatory notifications.

6.1 Soil Monitoring (SCAQMD Rule 1166)

Air Monitoring

At excavation sites where VOC-impacted or potentially impacted soil may be present, SCAQMD requires a Rule 1166 permit and Compliance Plan and continuous monitoring during excavation.

Refer to Appendix A for SCAQMD Rule 1166.

A soil monitor will be present onsite during excavation activities in the AOC to continuously monitor air emissions and record measurements using a direct reading organic vapor analyzer (OVA), or equivalent such as a PID. The OVA will be maintained in good working condition and calibrated on a regular basis per the manufacturer’s recommendations and at least once every three months.

Calibration of the OVA will be verified using certified calibration gas at the beginning of each working day with the procedures specified by the manufacturer. If a calibration gas other than hexane is used, each measured reading will be correlated to and expressed as hexane, using equivalency factors provided by the manufacturer. If inconsistent or erratic readings are experienced, or the OVA

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becomes otherwise inoperable, all excavation activities will cease until the OVA is repaired or replaced.

All monitoring shall be conducted by trained personnel who are proficient in the use of the OVA selected for use at the Site. Written records of OVA monitoring and required calibrations shall be kept in a format approved by the SCAQMD. The certification of all records shall be signed and dated on the day the measurements are observed.

All monitoring will be conducted at a distance no more than three inches above the soil surface using an OVA as previously described above. Monitoring will be initially conducted at a minimum frequency of one reading every 15 minutes. All readings will be taken no later than three minutes after each load of soil is excavated.

Action Response

Upon detection of VOC readings equal to or greater than 50 parts per million by volume (ppmv), excavation activities in the immediate vicinity will stop. A representative soil sample will then be collected by the environmental monitor for analysis as described in Section 6.4. Due to potential limited staging areas, excavation activities may continue in another location until the laboratory analysis has been completed. If impacted soil is encountered, the Environmental Consultant will alert the Owner and General Contractor to the condition. Appropriate responses may include Personal Protective Equipment (PPE) revisions, work stoppage or additional testing. Contaminated soil once excavated and stockpiled will be treated as VOC-contaminated soil at all times.

All VOC-contaminated soil below 1,000 ppmv shall be stockpiled, covered with plastic sheeting and stored separately from non-VOC-contaminated soil, or immediately loaded for transportation to a treatment or disposal facility.

All VOC-contaminated soil equal to or above 1,000 ppmv shall be placed in sealed containers within 15 minutes of excavation, or immediately loaded for transportation to a treatment or disposal facility.

The affected soil and working area shall be immediately sprayed with water or an approved vapor suppressant. The contaminated soil excavated shall be immediately placed in SCAQMD approved sealed containers equipped with vapor tight lids, or the soil shall be directly loaded in trucks, sprayed with additional water or approved vapor suppressants, covered, and transported immediately off site to an approved treatment facility.

Notifications

The Owner, General Contractor or Environmental Consultant will notify SCAQMD within 24 hours of the first detection of VOC measurements over 50 ppmv. Upon detection of VOC readings equal to or greater than 1,000 ppmv, SCAQMD shall be notified immediately or within one hour of detection.

Each new area or section of the project which involves excavation of soils with OVA measurements equal to or greater than 1,000 ppmv shall be a separate notification, with the area identified in the notification. A map of each section and each corresponding notification reference number and notification date shall be retained on site and shall be made available to SCAQMD personnel upon request and submitted with the final report.

The notification will be made by emailing the notification form to Rule1166Notifications@aqmd.gov.

A reference number will be faxed or emailed back or will be issued when the email notification is received.

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All email notifications shall be followed by mailing the notification form to the SCAQMD postmarked within 48 hours. The reference number will be retained as proof of compliance with this requirement.

All VOC-contaminated soil removed from the Site will comply with SCAQMD Rule 1166, including the following:

Be transported to an approved treatment/disposal facility. It will be the responsibility of the Contractor to ensure that the receiving treatment/disposal facility has received approval from the appropriate environmental oversight agencies to handle and treat contaminated soils.

When loading is completed and during transportation, no excavated material will extend above the sides or rear of the truck or trailer.

Prior to covering/tarping, loaded contaminated soil will be wetted by spraying with mist inhibitors.

The truck or trailer will be completely covered/tarped prior to leaving the Site to prevent particulate emissions to the atmosphere.

The exterior of the trucks (including the tires) will be cleaned off prior to the trucks leaving the excavation site, as needed.

The Client, or their authorized representative, will maintain records of storage, treatment and disposal for all VOC-contaminated soil removed from this Site, in accordance with SCAQMD Rule 1166.

Hydrocarbon Contaminated, Stained, or Odorous Soil Monitoring

If soil encountered is visually or physically observed showing dark staining or strong odor, samples will be collected and analyzed as described in Section 6.5. If soil containing significant amounts of hydrocarbons is encountered notification will be made to the appropriate authorities. Hydrocarbon contaminated soils will be disposed of in accordance with local, state, and federal laws.

Stockpiling of VOC-Contaminated Soil

Stockpiling VOC-impacted soil is described in section 8.3 and subject to the following additional procedures.

During excavation, the only exposed VOC-contaminated soil shall be restricted to the immediate working area of the site or stockpile. All other portions of the stockpile shall be covered with plastic sheeting, with seams, which overlap a minimum of 24 inches, and are secured with duct tape.

Any exposed VOC contaminated soil surfaces (work face) shall be kept moist with water or other approved suppressants at all times and shall be re-covered during periods of inactivity longer than one hour. At the end of each working day, all stockpiles shall be completely covered and securely anchored to prevent any exposure of soil to the atmosphere. Once covered with plastic sheeting, stockpiles shall remain undisturbed until removed from site.

Daily inspections shall be conducted of all covered VOC contaminated stockpiles to ensure the integrity of the plastic cover. Such inspections shall include a visual inspection of all seams and plastic cover surfaces. Any holes, tears, or any other potential sources of fugitive VOC emissions shall be repaired immediately. Daily records shall be maintained of all inspections.

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Disposition of Soil

All excavated VOC-contaminated soil shall be removed from the Site within 30 days of its excavation.

All VOC-contaminated soil removed from the Site shall comply with the following:

Be transported to an approved treatment/disposal facility. It will be the responsibility of the Contractor to ensure that the receiving treatment/disposal facility has received approval from the appropriate environmental oversight agencies to handle and treat contaminated soils.

When loading is completed and during transportation, no excavated material will extend above the sides or rear of the truck or trailer.

Prior to covering/tarping, loaded contaminated soil will be wetted by spraying with mist inhibitors.

The truck or trailer will be completely covered/tarped prior to leaving the Site to prevent particulate emissions to the atmosphere.

The exterior of the trucks (including the tires) will be cleaned off prior to the trucks leaving the excavation site, as needed.

Monitoring and Records Keeping

To document soil monitoring activities during soil disturbance, a daily log will be maintained to document the field screening activity along with results from the direct reading instrument. This log will be provided at the end of each day to the General Contractor. Records of treatment/disposal of VOC-contaminated soil shall be maintained on-Site during the excavation and later maintained for a period of two years after the completion of the excavation project. The records shall be made available to SCAQMD personnel upon request.

Once issued, the Compliance Plan is subject to further review by the SCAQMD and may be revoked if excavation activities are found in violation of plan conditions or SCAQMD's Rules and Regulations.

Failure to comply with one or more of the conditions contained within this plan constitutes a violation of SCAQMD Rules 221 and 1166.

6.2 Nuisance Monitoring (SCAQMD Rule 402)

SCAQMD Rule 402 prohibits the discharge, from any source, of air contaminants or other material that cause injuries, nuisance, or annoyance to the public and on-Site workers. This can include odor, vapors, smoke, particulates, or other contaminants. Refer to Appendix B for SCAQMD Rule 402.

6.3 Dust Monitoring (SCAQMD Rule 403)

SCAQMD requires that Rule 403 for Fugitive Dust be followed to reduce the amount of particulate matter entrained into ambient air as a result of normal construction activities. This rule is intended to limit the emissions of fugitive dust or particulate matter from a variety of activities and sources such as construction sites, bulk material hauling, unpaved parking lots, and disturbed soil in open areas and vacant lots; this rule applies to any activity or man-made condition capable of generating fugitive dust. The Environmental Consultant or a Site Supervisor will provide field personnel trained in Rule 403 procedures to monitor and mitigate fugitive dust emissions in accordance with Rule 403.

Refer to Appendix C for SCAQMD Rule 403.

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SCAQMD Rule 403 requires that fugitive dust generated during any activity or man-made condition such as excavation, demolition, construction, and soil disturbance, shall be prevented, reduced or mitigated.

As part of all earth moving and construction/demolition activities, disturbed surface area, or heavy and light duty vehicular movement, no person shall cause or allow the emissions of fugitive dust from any active operation, open storage pile, or disturbed surface area such that:

o The dust remains visible in the atmosphere beyond the property line of the emission source; or o The dust emission exceeds 20 percent opacity (as determined by the appropriate test method included in the Rule 403 Implementation Handbook) if the dust emission is the result of movement of a motorized vehicle.

All on-Site activities shall be conducted utilizing the best available control measures included in Table 1 of the Rule, to minimize fugitive dust emissions from each dust source type, such as high-pressure water sprayers, fire hoses, and water trucks where applicable.

Track-out shall not extend to 25 feet or more in cumulative length from the point of origin of an active operation. Notwithstanding this, all track-out shall be removed at the conclusion of each workday or evening shift.

No person shall conduct an active operation with a disturbed surface area of five or more acres, or with a daily import or export of 100 cubic yards (CY) or more of bulk material without utilizing at least one of the five measures listed in the rule at each vehicle egress from the Site to a public paved road.

6.4 Soil Sampling and Laboratory Analysis

Upon detection of VOC measurements in soil using a portable hand-held OVA of greater than 50 ppmv, or stained or odorous soil, the soil will be segregated on-Site for characterization and disposal determination.

Stockpiled or binned soil shall be collected using a composite sample technique. Each stockpile of approximately 250 CY or less, or rolloff bin will be portioned into four areas of equal volume, and one sample shall be collected from each quadrant at approximately one to two feet below surface. A minimum of four discrete soil samples will be collected if collecting in-Situ samples. Additional samples may be collected per specific landfill requirements.

The soil samples will be placed into glass sampling jars, and securely closed for transport. Each of the four samples will be assigned the same identification, distinguished by the letters a, b, c, and d. The soil samples will then be placed in sealed plastic bags and placed in a cooler with ice. The soil samples will be delivered via courier to a state-certified environmental laboratory, in an iced cooler using chain-of-custody documentation.

Soil analyses may include the following methods:

Total Petroleum Hydrocarbons, full carbon chain (TPH-cc) by USEPA Method 8015B;

VOCs by USEPA Method 8260B;

sVOCs by USEPA Method 8270;

PAHs by USEPA Method 8270 Selected Ion Monitoring (SIM);

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Title 22 Metals by USEPA Method 6010B/7471A; and, Soluble Threshold Limit Concentration (STLC) / Toxicity Characteristic Leaching Procedure (TLCP), as applicable.

6.5 Laboratory Results Comparative Analysis

Reported COPC concentrations for soil will be compared to the San Francisco Bay Regional Water Quality Control Boards (SFBRWQCB) Environmental Screening Levels (ESLs) for construction worker exposure, and DTSC Human and Ecological Risk Office (HERO) Note 3 Screening Levels (DTSC SLs) and the USEPA Regional Screening Levels (USEPA RSLs) for commercial/industrial exposure. Reported metal concentrations and 23 VOCs and SVOCs identified as potential State or Federal hazardous constituents1 will be compared to Hazardous Waste Criteria Total Threshold Limit Concentrations (TTLC) and analyzed for STLC and TCLP for waste disposal, if required.

7.0 EXPOSURE MONITORING

If stained or odorous soil or fumes are encountered during excavation, work should stop in that area and the Environmental Consultant be notified.

The following substances are known or suspected to be on-Site due to the Site history. The primary hazards of each are identified as follow:

Substances Concentration Primary Hazards TPH Various Ingestion, inhalation, skin

VOCs Various Ingestion, inhalation, skin sVOCs Various Ingestion, inhalation, skin PAHs Various Ingestion, inhalation, skin

Heavy Metals Various Ingestion, inhalation, skin, eye contact

Total Petroleum Hydrocarbons

A complex blend of petroleum-derived normal and branched-chain alkane, cycloalkane, alkene, and aromatic hydrocarbons and may include benzene and its derivatives, sulfur, and naphthalene.

TPH may cause serious health concerns by prolonged exposure in contact with skin. Repeated exposure to TPH may cause skin dryness or cracking. Breathing of high vapor concentrations may cause dizziness, light-headedness, headache, nausea, and loss of co-ordination. Continued inhalation may result in unconsciousness.

Volatile Organic Compounds

VOCs include a variety of chemicals, some of which may have short- and long-term adverse health effects. Health effects include eye, nose, and throat irritation, headaches, loss of coordination, nausea, and damage to liver, kidney, and central nervous system. Some organics are known to cause cancer in humans.

The Environmental Consultant will monitor on-site worker exposure to airborne contaminants during Site activities. Measurements should be taken within the breathing zones of workers. A PID will be

1 CCR T22:66261.24 and 40 CFR 261

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used to monitor changes in exposure to VOCs. The PID shall be calibrated daily in the field and undergo annual maintenance including calibration by a certified provider.

Semi-Volatile Organic Compounds

The health effects of a specific sVOC depend on its chemical nature and on the degree of exposure, which can occur through a combination of ingestion, respiration, and skin absorption. Health effects now associated with specific sVOCs include allergic symptoms, retarded reproductive development, and altered semen quality with phthalates.

Polycyclic Aromatic Hydrocarbons

PAHs are a class of chemicals that occur naturally in coal, crude oil, and gasoline. They also are produced when coal, oil, gas, diesel, wood, garbage, and tobacco are burned. PAHs enter the body through inhalation, ingestion, and in some cases, passing through the skin. Human health effects from environmental exposure to low levels of PAHs are unknown. Large amounts can irritate eyes and breathing passages. Several PAHs and some specific mixtures of PAHs are considered to be cancer causing chemicals.

Heavy Metals

Typically, the main threats to human health from heavy metals are associated with exposure to lead, cadmium, mercury and arsenic. Cadmium compounds are currently mainly used in re-chargeable nickel-cadmium batteries. Recent data indicate that adverse health effects of cadmium exposure is primarily in the form of kidney damage but possibly also bone effects and fractures. The general population is primarily exposed to mercury via food, fish being a major source of methyl mercury exposure, and dental amalgam. The general population does not face a significant health risk from methyl mercury, although certain groups with high fish consumption may attain blood levels associated with a low risk of neurological damage to adults and a risk to the fetus in pregnant women The general population is exposed to lead from air and food in roughly equal proportions. Children are particularly susceptible to lead exposure due to high gastrointestinal uptake and the permeable blood-brain barrier. Recent data indicating that there may be neurotoxic effects of lead at lower levels of exposure than previously anticipated. Exposure to arsenic is mainly via intake of food and drinking water, food being the most important source in most populations. Long-term exposure to arsenic in drinking water is mainly related to increased risks of skin cancer, but also some other cancers, as well as other skin lesions such as hyperkeratosis and pigmentation changes.

Occupational exposure to arsenic, primarily by inhalation, is causally associated with lung cancer.

7.1 Action Levels and Exposure Limits

If strong odors are encountered during excavation, work in the area should stop and the Environmental Consultant contacted immediately to assess the area for the potential presence of COPCs. Appropriate responses may include PPE revisions, additional testing, or continuous air monitoring.

TPH and VOCs:

According to OSHA (29 CFR 1926.55 Appendix A, Footnote (A (3)), the composition of TPH varies greatly and thus a single Threshold Limit Value (TLV) for all types of these materials is not applicable.

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The OSHA Permissible Exposure Limit (PEL2) for compounds commonly present in TPH-impacted soil is listed below; these concentrations must not be exceeded when working in areas where these hazardous compounds may be present:

VOCs: 25 ppmv PEL

The OSHA Short Term Exposure Limit (STEL)3 for compounds commonly present in TPH-impacted soil is listed below; these concentrations must not be exceeded when working in areas where these hazardous compounds may be present:

Toluene: 150 ppmv STEL

The OSHA Ceiling Limit (CL)4 for compounds commonly present in TPH-impacted soil is listed below;

these concentrations must not be exceeded when working in areas where these hazardous compounds may be present:

Xylene: 300 ppmv CL

If these concentrations are exceeded and cannot be controlled by local methods, an evacuation of the immediate area and possibly the Site will be ordered.

8.0 CONTAMINATED SOIL MANAGEMENT

Methods for contaminated soil management will be determined based on the waste profiling method used. Pre-characterized soil can be directly loaded into trucks for disposal. If soil is not pre-characterized, it would be necessary to stockpile or containerize in bins onsite for sampling and characterization prior to offsite disposal. A combination of methods may be warranted if unanticipated conditions are encountered during excavation activities.

8.1 Soil Handling and Storage

Contaminated soil at the Site should be properly stored to minimize additional exposure to human receptors and the environment. During soil handling, dust generation should be minimized, which may require the application of water during excavating and loading activities. Care should be taken to not overapply water such that runoff will occur. Additionally, soil excavated from the deeper portions of the excavation may be wet and should be mixed with dryer soil prior to loading to prevent dripping soil. Where dripping occurs, the impacted soil will not be accepted by most disposal facilities and could result in releases of contaminated liquids to public roadways. Care should be taken to minimize or eliminate spillage of soil during loading activities. Soil spillage during loading should be promptly removed and placed in the appropriate truck, stockpile, or bin for disposal.

8.2 Air Monitoring During Soil Staging

If field screening identifies VOC concentrations of 50 ppmv or greater when measured at a distance of three inches from the surface of stockpiled or containerized material, then the notification and

2 Defined as the maximum permitted 8-hour time-weighted average concentration of an airborne contaminant.

3 Defined as a 15-minute time-weighted average exposure concentration which is not to be exceeded at any time during a workday even if the 8-hour time-weighted average is below the PEL.

4 Defined as the maximum concentration of an airborne contaminant to which an employee may be exposed at any time.

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monitoring requirements specified in SCAQMD Rule 1166 and described in Section 6.1 shall be implemented for stockpiled and containerized soil.

8.3 Stockpiling

Soil material will be placed into roll-off containers or into managed and covered stockpiles if the material is identified as contaminated soil and stockpiled if clean. If the soil needs to be temporarily stockpiled before being placed in trucks for off-Site disposal, the contractor shall place soil on visqueen or another impervious surface and cover the stockpile with visqueen. The stockpile will be managed to not allow storm water to come in contact with the soil and to not emit fugitive dust. The contractor shall implement best management practices (BMPs) for stockpile management in accordance with their approved construction storm water permit to eliminate runoff of sediment from the stockpile. This may include the use of plastic sheeting, sand or gravel bags and placement of fiber wound straw wattles around the edge of the stockpile.

During stockpiling of soils, fugitive emissions will be mitigated by spraying the stockpiles with water or other suppressant and keeping the stockpiles covered when not in use. Additional control measures are listed in Table 1 of SCAQMD Rule 403.

If soil is segregated and stockpiled on-Site prior to disposal, collect samples per the following guidelines:

Up to 1,000 CY – one sample per 250 CY.

1,000 – 5,000 CY – Four samples plus one sample per 500 CY.

Greater than 5,000 CY – 12 samples for the first 5,000 CY and one sample per 1,000 CY thereafter.

Additional samples may be collected per specific landfill requirements.

8.4 Containerizing

If the soil is temporarily containerized in roll-off bins before being transported offsite for disposal, the contractor should use plastic liners in the bins to prevent leakage of dust control water, retained groundwater, or other liquids. Additionally, the bins should be covered, either by rigid lids or plastic sheeting. The contractor should implement BMPs for container management in accordance with their approved construction storm water permit, if applicable.

8.5 SWPPP Best Management Practices

Erosion control, also referred to as soil stabilization, is a source control measure that is designed to prevent soil particles from detaching and becoming transported in the storm water runoff. Erosion control BMPs protect the soil surface by covering and/or binding the soil particles. All inactive soil disturbed areas on the Site, and most active areas prior to the onset of rain, must be protected from erosion. Soil disturbed areas may include relatively flat areas as well as slopes. Inactive areas include areas of construction activity that have been disturbed but are not currently being worked on and are not scheduled to be re-disturbed for at least 14 days. In addition to the soil management practices described above, temporary erosion control/soil stabilization measures shall be implemented as needed, including installing perimeter sediment controls along the Site perimeter as active drain inlets and sediment basins, and applying hydraulic mulch to graded slopes or pads that will be inactive for a long period of time. The objective of implementing these temporary measures is to prevent any potentially contaminated soil from entering in the storm water runoff.

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Sediment controls are structural measures that are intended to complement and enhance soil stabilization/erosion control measures and reduce sediment discharges from construction areas.

Sediment controls are designed to intercept and filter out soil particles that have been detached and transported by the force of water. Temporary sediment control measures shall be implemented onsite as required. These may include sediment traps, check dams, fiber rolls, and gravel bag berms.

Visible sediment tracking onto public and private streets from the Site shall be inspected and swept regularly and prior to a rain event, to prevent potentially contaminated soil from entering storm drains and receiving waters.

Tracking control BMPs shall be implemented throughout the duration of the project, at all access (ingress/egress) points to the Site where equipment or trucks laden with contaminated soil may track sediment from the Site onto public or private roadways.

Wind erosion control BMPs shall be implemented throughout the duration of the project on all disturbed soils on the Site that are subject to wind erosion, and when significant wind and dry conditions are anticipated. The objective of wind controls is to prevent the transport of potentially contaminated soil from soil-disturbed areas of the Site, off-site by wind. Wind erosion control BMPs may include dust control measures such as construction watering, and wind screen fencing in the perimeter of the Site.

8.6 Decontamination Measures

PPE and sampling equipment used by on-Site personnel when working with potentially contaminated soil shall be collected in appropriate storage containers for disposal in accordance with applicable regulatory guidelines. These may include PPE such as gloves, ear plugs, or disposable face masks;

and sampling equipment such as glass/polyethylene jars, and Encore samplers.

Tracking control BMPs are an additional form of decontamination, as they prevent uncontrolled removal of potentially contaminated soil from the Site and shall be implemented at all access (ingress/egress) points to the Site where equipment or trucks laden with contaminated soil may track sediment from the Site onto public or private roadways.

8.7 Disposal

Contaminated soil will be directed to an approved landfill. The following facilities are approved for non-hazardous soils impacted with metals, VOCs or petroleum hydrocarbons following the completion of the profiling process. Other landfills or soil recycling facilities may be acceptable and can be used.

Chiquita Canyon Landfill located at 29201 Henry Mayo Drive, Castaic, California 91384

Waste Management Simi Valley Landfill located at 2801 North Madera Road, Simi Valley, California 93065

Mecca Remediation Facility located at 62150 Gene Welmas Way, Mecca, CA 92254

Soil Safe of California located at 12328 Hibiscus Road, Adelanto, California 92301

Soils having VOCs in excess of 50 ppmv, per the Rule 1166 requirements, are not eligible for disposal at the Chiquita Canyon Landfill and must be taken to a location outside of Los Angeles County.

The following facilities are approved for hazardous waste disposal following the completion of the profiling process.

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Kettleman Hills Waste Management Facility located at 35251 Old, Skyline Road, Kettleman City, California 93239

McKittrick Waste Management Facility located at 56533 Highway 58 West, McKittrick, California, 93251

Clean Harbors Buttonwillow Landfill Facility located at 2500 Lokern Road, Buttonwillow, California, 93206

U.S. Ecology Beatty, P.O. Box 578, 11 miles south of Beatty on Highway 95, Beatty, Nevada 89003

Upon receipt of laboratory results during onsite monitoring, revised treatment and disposal options will be provided to the Owner and Contractor, if required.

Soil shall not be transported off-Site prior to completion of waste profiling and execution of proper waste manifests in accordance with Department of Transport (DOT) regulations. Waste profiling may occur prior to excavation using in-situ soil data, may be based on soil samples collected from stockpiled or containerized soil, or a combination of methods. Manifests will require signature by an authorized representative of the generator.

8.8 Transportation

A loading and staging area shall be identified to facilitate the loading of trucks, and/or for staging stockpiles and/or roll-off bins for storing potentially contaminated soil. Ingress and egress routes for delivering bins to the specific staging areas will be defined by the general contractor when the staging area is identified. Ingress and egress routes will be provided to the waste hauler by the general contractor to allow for efficient delivery of trucks and roll-off bins to the staging area and removal of trucks and bins.

During transport, trucks and roll-off bins containing soil shall be covered per DOT regulations. The loaded trucks will proceed directly to the designated disposal facility. For contaminated soils, the transportation company will be responsible for having proof of valid hauler registration with the California Environmental Protection Agency (CalEPA) and shall ensure that all vehicles are properly registered, operated, and placarded in compliance with local, state, and federal requirements.

Loading and transporting of soil shall be conducted in such a manner that the generation of dust is minimized. Dust suppression will be managed through the application of water spray and/or suspending loading activities. If at any time dust emissions are observed to be causing adverse effects off-Site, the contractor’s project manager (PM) will suspend field activities until the problem is corrected.

The transportation contractor will be required to follow Spill Response Guidelines in compliance with Federal regulations 49 CFR 172.602. The transportation contractor will ensure that each driver is equipped with an Emergency Response Guidebook and is properly trained to respond to an emergency. The on-Site PM will observe the contaminated soil loading and other related activities and will follow the requirements of the HASP. The excavation contractor will be responsible for ensuring that transportation activities are in accordance with this SMP and their Health and Safety Program.

8.9 Importation of Fill

During the course of earthwork activities (i.e., borings, excavation, grading, removal, and trenching), in support of investigation and redevelopment, significant quantities of soil may be removed from the

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Site. Restoration and regrading of the ground surface may be accomplished through the use of imported fill material.

Import material intended for use on-Site will be verified as clean in accordance with the DTSC Information Advisory, Clean Imported Fill Material Fact Sheet (Clean Fill Advisory). The Clean Fill Advisory provides guidelines ensuring that imported material is free from contaminants that could pose environmental or health risks. Source areas for import material will be selected in accordance with the Clean Fill Advisory.