Attachment 3.8.3 - Appendix H3 Cleanup and Abatement Order No. R9-2021-0042.pdf — Chula Vista City Council, November 18, 2025

Appendix H3
Cleanup and Abatement Order No. R9-2021-0042

CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD

SAN DIEGO REGION
CLEANUP AND ABATEMENT ORDER NO. R9-2021-0042

AN ORDER DIRECTING ROHR AND GOODRICH CORPORATION

TO CLEAN UP OR ABATE THE EFFECTS OF WASTE DISCHARGED

FROM THE ROHR/GOODRICH NORTH CAMPUS PROPERTY,

CHULA VISTA, SAN DIEGO COUNTY
The California Regional Water Quality Control Board, San Diego Region (San Diego Water Board), finds that:

1. Legal
and Regulatory Authority. This Cleanup and Abatement Order (CAO) conforms to and implements (1) policies and requirements of the Porter-Cologne Water Quality Control Act (division 7, commencing with Water Code section 13000) including sections 13267 and 13304; (2) applicable state and federal regulations; (3) all applicable provisions of statewide Water Quality Control Plans adopted by the State Water Resources Control Board (State Water Board) and the Water Quality Control Plan for the San Diego Basin (Basin Plan) adopted by the San Diego Water Board including beneficial uses, water quality objectives, and implementation plans; (4) State Water Board policies and regulations, including Resolution No. 68-16, Statement of Policy with Respect to Maintaining High Quality of Waters in California (Resolution No. 68-16); Resolution No. 88-63, Sources of Drinking Water; Resolution No. 92-49, Policies and Procedures for Investigation, and Cleanup and Abatement of Discharges under Water Code Section 13304 (Resolution No. 92-49); California Code of Regulations (Cal. Code Regs.) title 23, chapter 16, article 11; and Cal. Code Regs., title 23, section 3890 et seq.; and (5) relevant standards, criteria, and advisories adopted by other s
tate and federal
agencies.

2. Basi
s for Cleanup and Abatement Order. Water Code section 13304 authorizes the San Diego Water Board to require dischargers to clean up or abate the effects of waste discharge(s) where the discharge creates or threatens to create a condition of pollution or nuisance.

3. Cleanup and Abatement Order No. 98-08. T
he San Diego Water Board
issued CAO No. 98-08 to Rohr, Inc., operating as BF Goodrich Aerospace Aerostructures Group, and its parent company, the BF Goodrich Company, in 1998. CAO No. 98-08 addresses the cleanup and abatement of wastes discharged from Rohr’s manufacturing operations located at 850 Lagoon Drive in Chula Vista, California (North Campus Property). CAO No. 98-08 includes directives to (1) conduct a site-wide environmental site assessment,
(2) conduct a comprehensive storm water runoff sampling program, (3) conduct a comprehensive storm water conveyance system investigation, (4) perform a site-wide data compilation and evaluation, and CAO No. R9-2021-0042 July 12, 2021
2 (5) conduct interim remedial actions. The first four directives are complete.

Inter
im remedial actions are currently underway at the off-property area known as Parcel H-3, pursuant to CAO No. 98-08.

This CAO supersedes CAO No. 98-08 except for the interim remedial actions that will occur at Parcel H-3, which will continue under CAO No. 98- 08 until complete. The Dischargers named in this CAO (see Finding 7) are required to submit reports pursuant to CAO No. R9-2021-0042. Upon completion of the interim remedial actions at Parcel H-3 and submittal of the Cleanup and Abatement Completion Report (see Directive B.1.c), the San Diego Water Board will determine if the directives in CAO No. 98-08 are satisfied and if the directives are met no further work will be required pursuant to CAO No. 98-08.

4. Scope of Cleanup and Abatement Order No. R9-2021-0042. This CAO addresses the cleanup and abatement of all wastes discharged to soil, soil gas, and groundwater from the North Campus Property manufacturing operations (Figure 1). This CAO provides the following definitions for “On- Property,” “Off-Property,” and “Site.”
a. On-Property refers to wastes discharged within the North Campus Property boundary (Figure 2). The approximately 82-acre North Campus Property is bounded by F & G Street Marsh and Lagoon Drive to the north, Bay Boulevard to the east, Marina Parkway to the west, and H Street to the south. The North Campus Property is planned for redevelopment and is separated into three parcels:

Parcels A, B, and C (Figure 2). Parcel A is approximately 15 acres and has been sold to PSIP Wohl Bay Boulevard, LLC (Owner). The new Owner plans to repurpose Building 29, potentially involving demolishing limited portions of the structure, and may demolish all or portions of Buildings 99 and 100 on Parcel A. Parcel A also includes the vacant properties to the north of Buildings 99 and 100 at 350, 360, 364, and 368 Bay Boulevard. Parcel B is subdivided into two parts: B-1 and B-2. Parcels B-1 and B-2 total
approximately 34 acres. Subject to a pending lot line adjustment, Parcel B-1 will be approximately 26 acres and Parcel B-2 will be approximately 8 acres. The potential buyer plans to demolish all the existing buildings on Parcel B. Parcel C is approximately 40 acres and
includes 11 buildings. Parcel C is currently not for sale. b. Off-Pr
operty refers to all adjacent areas outside the North Campus Property boundaries affected by the wastes discharged to soil, soil gas, and groundwater from manufacturing operations at the North Campus Property (Figure 3). The Off-Property area to the south of the North Campus Property includes H Street and the former South Campus Property. Cleanup and abatement of wastes discharged to this area must be coordinated with the cleanup and abatement activities currently underway at the former South Campus Property CAO No. R9-2021-0042 July 12, 2021
3 (pursuant to CAO No. R9-2014-0019). The Off-Property areas located north, east, and west of the North Campus Property include the F & G Street Marsh (a federally protected tidal marsh), railroad right-of-way, and Parcel H-3, respectively. Parcel H-3 will be redeveloped as part of the Chula Vista Bayfront Master Plan.1 As described in Finding 3, cleanup and abatement of wastes discharged to Parcel H-3 is currently underway as an interim remedial action pursuant to CAO No. 98-08 due to an accelerated redevelopment schedule.
c. Site refers to the On-Property and Off-Property areas where wastes were discharged to soil, soil gas, and groundwater from manufacturing operations at the North Campus Property. All wastes discharged to the Site must be identified and cleaned up or abated pursuant to this CAO.

5. Site History. Prior to Rohr’s occupancy in 1941, the Site had a variety of historical uses. In the 1920s, a facility just south of G Street and west of the railroad right-of-way (R&H Tyce/Pioneer Pyrophyllite) manufactured a cementitious material called Tycrete. The facility included a rotary kiln, laboratory, and paint shop. Businesses occupied parcels along Bay Boulevard beginning in the early 1950s that included aircraft parts manufacturing, refrigeration unit repair, storage, junkyards, and a veterinary hospital. The property immediately north of G Street was used for industrial purposes as early as 1918, when a magnesite ore processing company and aviation company occupied this area. The aviation company included three machine shops and a plating shop. To the west, where Building 61 is currently located, the City of Chula Vista operated a sewage treatment plant north of G Street from the late 1930s until the mid-1960s. There were two settling ponds at the current location of Building 61 from about 1944 to 1959 and two settling ponds west of Building 61 around 1965. Treated effluent was discharged to San Diego Bay via an outfall. In 1960-1962, the Unified Port of San Diego placed dredged fill from the bay along the historical shoreline on the western portions of Parcels B and C, Parcel H-3, and the areas west of the site.
2 6. Discharge of Waste. Since 1941, structural and engine components for use in the aviation and aerospace industry have been manufactured at the North Campus Property. Chemicals stored at the North Campus Property and used during manufacturing operations have been found in the soil, soil gas, and groundwater as reported in environmental investigation reports and groundwater monitoring reports. The chemicals discharged include, but are not limited to, volatile organic compounds (VOCs), metals, petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), and 1 Chula Vista Bayfront Project
2 Adrian Brown Consultants, 1998. ASTM Phase I Site Assessment, B.F. Goodrich Aerospace, 850 Lagoon Drive, Chula Vista, California. June 4.

CAO No. R9-2021-0042 July 12, 2021
4 polychlorinated biphenyls (PCBs) (chemicals of concern [COCs]). The discharge of these COCs to the environment constitutes a discharge of waste, as defined in Water Code section 13050, subsection (d).

7. Persons
Responsible for the Discharge of Waste. Beginning in 1941, Rohr Aircraft Corporation manufactured structural and engine components for use in the aviation and aerospace industry in Chula Vista, California. The company incorporated in 1969 as Rohr Corporation and subsequently became Rohr Industries in 1971, and Rohr, Inc., in 1992. The BF Goodrich Company acquired Rohr, Inc., in 1997, and Rohr, Inc., began operating as BF Goodrich Aerospace Aerostructures Group. Rohr, Inc., operating as BF Goodrich Aerospace Aerostructures Group, and Rohr, Inc.’s predecessors, including but not limited to Rohr Aircraft Corporation, Rohr Corporation, and Rohr Industries, Inc., are collectively referred to as “Rohr.” In 2001, BF Goodrich Company changed its name to Goodrich Corporation (Goodrich). On July 26, 2012, United Technologies Corporation (UTC) acquired the stock of Goodrich (Goodrich Acquisition). As a result of the Goodrich Acquisition, Goodrich became a wholly owned subsidiary of UTC and Rohr remained a wholly owned subsidiary of Goodrich. UTC combined Goodrich with Hamilton Sundstrand Corporation, including their respective affiliates and subsidiaries, to operate as a new business segment, referred to as UTC Aerospace Systems.

On November 26, 2018, UTC completed its acquisition of Rockwell Collins, Inc., through which it purchased all the company’s outstanding shares (the Collins Acquisition). As a result of the Collins Acquisition, Rockwell Collins became a
wholly owned subsidiary of UTC. Following the Collins
Acquisition, UTC re-branded UTC Aerospace Systems to begin operating as “Collins Aerospace.”
Most recently in 2020, UTC merged with Raytheon Company, at which time Raytheon Company became a wholly owned subsidiary of UTC. UTC then changed its name to Raytheon T
echnologies Corporation. Following each of
the above, Rohr, Inc., has remained the legal owner of the Property and a wholly owned subsidiary of Goodrich. Rohr and its related predecessor companies referenced above are collectively referred to as “Dischargers” in this CAO.

8. Benefi
cial Uses of Groundwater. The Site is located within the La Nacion Hydrologic Subarea (9.12) in the Lower Sweetwater Hydrologic Unit (9.10) of the Sweetwater Hydrologic Unit (9.00). The Basin Plan designates beneficial uses for waters of the state and establishes water quality objectives to protect these uses. Present and potential future beneficial uses of groundwater within the Lower Sweetwater Hydrologic Unit (9.10) include municipal and domestic supply (MUN), agricultural supply (AGR), and industrial service supply (IND). Water quality objectives to support the MUN use are more stringent than those for AGR and IND uses. The water CAO No. R9-2021-0042 July 12, 2021
5 quality objectives for MUN are the Maximum Contaminant Levels (MCLs)3 specified in Table 64444-A of Cal. Code Regs. title 22, section 64444.

9. Threat to Water Quality and Human Health. Since the late 1990s, the Dischargers conducted environmental investigations for soil, soil gas, indoor air, and groundwater at the Site pursuant to CAO No. 98-08. The results of these investigations indicate there is a threat to water quality and human health at the Site due to wastes discharged from the manufacturing operations at the North Campus Property.

Soil Investigations
Pursuant to CAO No. 98-08, soil investigations conducted at the Site have identified COCs in vadose-zone soil. The concentrations of these COCs exceed the respective Environmental Screening Levels (ESLs),4 which indicate they may leach into groundwater at concentrations impacting the MUN beneficial use and may pose a cancer risk and noncancer hazard to commercial/industrial and construction workers via ingestion, inhalation, and dermal exposures. ESLs were derived by the California Regional Water Quality Control Board, San Francisco Bay Region (San Francisco Bay Water Board), to provide conservative screening levels for over 100 chemicals found at sites with contaminated soil and groundwater. They are intended to help expedite the identification and evaluation of potential environmental concerns at contaminated sites.

Tables 1 through 3 list COCs in vadose-zone soil that exceed the ESLs, but do not represent a complete list of exceedances.
3 Maximum Contaminant Levels
4 Environmental Screening Levels
CAO No. R9-2021-0042 July 12, 2021
6 Table 1. COCs Exceeding ESLs for Potential Leaching to Groundwater Chemical of
Concern
Sample
ID Year
Depth
(feet
below
ground
surface
[bgs])
Maximum Soil
Concentration
(micrograms
per kilogram
[μg/kg])
Potential
Leaching to
Groundwater
ESL (μg/kg)
Trichloroethene
(TCE)
GB24 2021 1 110,000 85
cis-1,2-
Dichloroethene
(cis-1,2-DCE)
PB-150 2019 1 34,500 190
Vinyl Chloride PB-109 2017 2.5 4,600 1.5
1,1,1-
Trichloroethane
(1,1,1-TCA)
PB-033 2017 3 20,000 7,000
Tetrachloroethene
(PCE)
GB9 2021 1 7,700 80
Methylene
Chloride
GB9 2021 1 2,000 120
Table 2. COCs Exceeding ESLs for Direct Exposure to Commercial and Industrial Workers
Chemical
of Concern
Sample
ID Year
Depth
(feet
bgs)
Maximum Soil
Concentration
(μg/kg)
Cancer
Risk
ESL
(μg/kg)
Noncancer
Risk ESL
(μg/kg)
TCE GB24 2021 1 110,000 6,100 19
Lead PB-109 2017 2.5 21,000,000 380,000 320,000
PCB Aroclor
1242
GB49 2021 4 17,000 940 Not
applicable
PCB Aroclor
1248
UT-28 2013 1 44,000 940 Not
applicable
PCB Aroclor
1254
PB-109 2017 2.5 41,000 940 Not
applicable
PCB Aroclor
1260
GB81 2021 4 7,600 940 Not
applicable
CAO No. R9-2021-0042 July 12, 2021
7 Table 3. COCs Exceeding ESLs for Direct Exposure to Construction Workers
Chemical
of
Concern
Sample
ID Year
Depth
(feet
bgs)
Maximum Soil
Concentration
(μg/kg)
Cancer
Risk ESL
(μg/kg)
Noncancer
Risk ESL
(μg/kg)
TCE GB24 2021 1 110,000 130,000 18,000
Lead PB-109 2017 2.5 21,000,000 2,700,000 160,000
PCB
Aroclor
1242
GB49 2021 4 17,000 940 Not
applicable
PCB
Aroclor
1248
UT-28 2013 1 44,000 5,500 Not
applicable
PCB
Aroclor
1254
PB-109 2017 2.5 41,000 5,500 Not
applicable
PCB
Aroclor
1260
GB81 2021 4 7,600 940 Not
applicable
Groundwater Investigations
Pursuant to CAO No. 98-08, groundwater investigations at the Site have identified the presence of COCs within the three water-bearing zones at the Site:
· Zone A – extends to a depth of approximately 25 feet bgs. · Upper Zone B – extends approximately 25 to 55 feet bgs. · Lower Zone B – extends approximately 55 to 125 feet bgs.

The concentrations of these COCs exceed the (1) MCLs, which indicate they are impacting the MUN beneficial use in the three zones, and (2) vapor intrusion ESLs, which indicate they may pose a potential vapor intrusion risk to current and future building occupants.

Tables 4 through 7 list COCs that exceed the MCLs and ESLs, but do not represent a complete list of exceedances.

CAO No. R9-2021-0042 July 12, 2021
8 Table 4. COCs in Zone A Groundwater Exceeding MCLs
Chemical of
Concern
Sample
ID Year
Maximum
Groundwater
Concentration
(micrograms per liter
[μg/L])
MCL
(μg/L)
TCE HP57-7A 1993 300,000 5
cis-1,2-DCE HPNC-14 2001 160,000 6
Vinyl Chloride HPNC-06 2001 32,000 0.5
1,1,1-TCA HP57-
6B-17
1993 420,000 200
Table 5. COCs in Zone A Groundwater Exceeding Vapor Intrusion ESLs
Chemical of
Concern
Sample
ID Year
Maximum
Groundwater
Concentration
(μg/L)
Cancer
Risk ESL
(μg/L)
Noncancer
Risk ESL
(μg/L)
TCE HP57-7A 1993 300,000 7.5 22
cis-1,2-DCE HPNC-
14 2001 160,000 Not
applicable
21 Vinyl
Chloride
HPNC-
06 2001 32,000 0.14 400
1,1,1-TCA HP57-
6B-17
1993 420,000 Not
applicable
6,300
Table 6. COCs in Upper Zone B Groundwater Exceeding MCLs Chemical of
Concern
Sample
ID Year
Maximum
Groundwater
Concentration (μg/L)
MCL
(μg/L)
TCE HP18 2018 22,000 5
cis-1,2-DCE HP21 2018 3,600 6
Vinyl Chloride HP21 2018 730 0.5
CAO No. R9-2021-0042 July 12, 2021
9 Table 7. COCs in Lower Zone B Groundwater Exceeding MCLs Chemical of
Concern
Sample
ID Year
Maximum
Groundwater
Concentration (μg/L)
MCL
(μg/L)
TCE HP22 2018 2,200 5
cis-1,2-DCE HP22 2018 320 6
Soil Gas Investigations
Limited soil gas investigations were conducted at the North Campus Property in May 2018, September 2019, and August 2020. A comprehensive soil gas investigation must be conducted throughout the Site to evaluate the distribution and extent of the contamination and to evaluate vapor intrusion risks to future building occupants due to wastes discharged from the North Campus Property.

The May 2018 and August 2020 s
oil gas investigations were conducted at
Buildings 29, 99, and 100, located on Parcel A of the North Campus Property. The September 2019 soil gas investigation was conducted on Parcel B of the North Campus Property. These investigations assessed the presence of COCs in soil gas beneath building slabs and hardscape. The concentrations of certain VOCs exceeded the respective soil gas ESLs, which indicate they may pose a potential vapor intrusion risk to future building occupants. Table 8 lists VOCs that exceed the ESLs but does not
represent a complete list of exceedances.

CAO No. R9-2021-0042 July 12, 2021
10 Table 8. COCs in Soil Gas Exceeding ESLs
Chemical of
Concern
Sample
ID
Depth
(feet
bgs)
Maximum Soil Gas
Concentration
(micrograms per
cubic meter [μg/m3])
Soil Gas ESL
(μg/m3)
Benzene PB-V13 3 1,200 14
Ethylbenzene PB-V13 3 2,700 160
Carbon
Tetrachloride
PB-V02 3 320,000 68
Bromodichloro
-methane
PW-09 4.5 140 11
Chloroform B-29-
SV03-5’
5 39,000 18
1,1-DCA PB-V06 3 380,000 260
1,2-DCA PB-V03 3 2,500 16
PCE PB-V03 3 170,000 67
1,1,2-TCA PB-V06 3 630 26
TCE PB-V02 3 87,000,000 100
1,1,1-TCA PB-
V03,
PB-V06
3 1,000,000 150,000
Vinyl chloride PB-V06 3 120,000 5.2
Indoor Air Investigations
Limited indoor air investigations were conducted at the North Campus Property in September 2018 and February 2019. A comprehensive indoor air investigation must be conducted in buildings throughout the Site to evaluate the distribution and extent of the contamination and to evaluate vapor intrusion risks to current and future building occupants due to wastes discharged from the North Campus Property.

The September 2018 indoor air investigations were conducted at Buildings 29 and 1, located on Parcels A and B, respectively, of the North Campus Property. These investigations screened for the presence of TCE entering the buildings through potential vapor intrusion preferential pathways. Indoor air concentrations were measured using a direct-reading instrument. The concentrations are representative of concentrations at a given point in time and differ from time-weighted average concentrations collected over an 8- hour workday. TCE screening results were the following:

CAO No. R9-2021-0042 July 12, 2021
11 Building 29
· TCE concentrations reported ranged from 0.012 to 5.5 μg/m3 in the breathing zone.
· TCE concentrations of 1.6 and 352 μg/m3 were reported near two drains.
· TCE was reported at a concentration of 599 μg/m3 inside a crack in the slab.

Building 1
· TCE concentrations reported ranged from 0.12 to 6.8 μg/m3 in the breathing zone.
· TCE concentrations of 0.56, 2.0, and >107 μg/m3 were reported near utility trenches.

While the TCE concentrations in the breathing zone do not exceed the U.S.

Environmental Protection Agency (EPA) Region 9 Interim TCE Indoor Air Response Levels (RLs)5 for a commercial/industrial worker (8-hour workday), a comprehensive indoor air investigation must be conducted at Building 29. The rollup doors were open and indoor fans were operating when measurements were taken; TCE concentrations therefore may be biased low.

Indoor air screening was conducted again in February 2019 at the same locations. Doors and windows that are typically open were closed in February. TCE screening results for the February 2019 event were the following:

Building 29:
· TCE concentrations reported ranged from 1.5 µg/m3 to 114 µg/m3.

Concentrations reported at six locations in the former Maintenance Department exceeded the RL in the breathing zone.
· TCE was reported at a concentration of 9.6 μg/m3 for the drain where 352 μg/m3 was previously reported. A hole in the cover was welded shut following the September 2019 screening event. · TCE concentration of 121 μg/m3 was reported inside the crack in the slab.
5 California Department of Toxic Substances Control, Human and Ecological Risk Office Human Health Risk Assessment Note 5
CAO No. R9-2021-0042 July 12, 2021
12 Building 1:
· TCE concentrations reported ranged from 0.11 to 136 μg/m3 in the breathing zone. Concentrations reported at eight locations in the building exceeded the RL.
· TCE concentrations of 0.60, 0.92, and 600 μg/m3 were reported at the utility trenches previously monitored during the September 2018 screening event.

10. Potential Environmental Concerns. The North Campus Property is almost entirely paved with concrete and asphalt and has over one million square feet of office and industrial buildings. These improvements make it difficult to identify all discharges of waste in soil, soil gas, and groundwater beneath the North Campus Property.

Similar manufacturing operations were conducted at the North Campus Property and the former South Campus Property. There is a high probability that potential environmental concerns (PECs) will be encountered at the North Campus Property when the surface and subsurface structures are demolished (e.g., existing buildings, concrete, and foundations), similar to the PECs
found at the former South Campus Property6 (Exchange Parcel, H Street Extension, and the remainder of the South Campus Property).

11. Cleanup Levels Pursuant to Resolution No. 92-49. Resolution No. 92-49 sets forth the policies and procedures used during an investigation or cleanup of a discharge of waste and requires that cleanup levels be consistent with Resolution No. 68-16. Resolution No. 92-49 applies to the cleanup and abatement of the effects of waste discharged at the Site.

Resolution No. 92-49 requires that dischargers clean up or abate the effects of discharges in a manner that promotes the attainment of background water quality, or the best water quality that is reasonable if background water quality cannot be restored, considering all demands being made and to be made on those waters and the total values involved, beneficial and detrimental, economic and social, tangible and intangible. Any alternative cleanup level greater than background must (1) be consistent with the maximum benefit to the people of the state; (2) not unreasonably affect present and anticipated beneficial use of waters of the state; and (3) not result in water quality less than that prescribed in the Basin Plan and applicable Water Quality Control Plans and Policies of the State Water Board.

12. Conceptual Site Model. In May 2020, Rohr submitted a Conceptual Site Model (CSM) report for the North Campus Property to the San Diego Water Board in anticipation of issuance of this CAO. In October 2020, the San Diego Water Board provided written comments on the CSM, which will 6 Pursuant to CAO No. R9-2014-0019.

CAO No. R9-2021-0042 July 12, 2021
13 require revisions to the CSM report. Rohr is currently reviewing and considering the San Diego Water Board’s comments.

13. Data
Gap Assessment Reports. In November 2019 and May 2020, Rohr submitted Data Gap Assessment Reports for Parcel B and Parcel A – Building 29, respectively. Additional data gaps may be identified for Parcels A, B, and C based on the San Diego Water Board’s comments on the CSM report for the North Campus Property (Finding 12). Summaries of the Data Gap Assessment Reports are provided below:
a. Parcel B. The purpose of the data gap assessment for Parcel B was to support the sale of the parcel by (1) further investigating soil in the vicinity of former outfalls located along the historical shoreline and at the former Western Drainage Ditch, and (2) conducting a supplemental soil gas survey at former potential release areas.

Rohr concluded the following based on the results of the data gap assessment:
i. The soil investigation identified additional VOCs, metals, and PCBs in the vicinity of the former outfalls located along the historical shoreline.
ii. T
he soil gas survey identified the presence of potential residual VOCs including TCE, PCE, 1,1,1‐TCA, benzene,
toluene, ethylbenzene, and xylenes in the locations of their historical storage and use. The mobile laboratory conducted limited dilutions, given the elevated VOC concentrations in some of the samples. Therefore, some of the elevated
results reported may not be representative of actual field conditions. Accordingly, these analytical results should be considered semi‐quantitative and should be confirmed
through analysis by a fixed laboratory.
b. Parcel
A – Building 29. The purpose of the data gap assessment for Building 29 at Parcel A was to support development of a Human Health Risk Assessment (HHRA) and Soil Remedial Action Plan for this CAO. Additional soil and groundwater samples were collected to further investigate data gaps associated with historical environmental features. Rohr concluded the following based on the results of the data gap assessment:
i.

Arsenic was detected in soil at concentrations above the Groundwater Protection Level (GPL) at boring B29-07A.
ii. PCBs were not detected in soil at concentrations above the commercial/industrial California Department of Toxic
Substances Control screening levels (DTSC-SLs) at the
step-out borings.

CAO No. R9-2021-0042 July 12, 2021
14 iii. Analyti
cal results of soil and groundwater samples collected
at the reported locations of the former mills and lathes did not identify impacted areas associated with these former features.
iv. Analyti
cal results for borings B29-23 and B29-24 suggest
that there are sources of TCE in soil beneath the former Maintenance Department. The soil samples from these
borings
had TCE concentrations that were above the
commercial/industrial DTSC-SL and the
commercial/industrial ESL for the vapor intrusion-sand
scenario. TCE in the sample from boring B29-23 was also above the GPL.
v. TCE w
as present in Zone A and Upper Zone B groundwater
beneath the Former Maintenance Department at
concentrations that exceed the MCL.

14. Site Background Soil and Groundwater Cleanup Levels. In October 2019, pursuant to Resolution No. 92-49, Rohr submitted a technical analysis to the San Diego Water Board to identify the background cleanup levels for inorganic chemicals in s
oil and groundwater at the Site, which includes
Parcel H-3.7 The cleanup levels for inorganic chemicals in (1) soil must lead to attainment of background water quality in groundwater, and (2) groundwat
er must attain background water quality.

CAO No. R9-2021-0042 July 12, 2021
15 d. The stat
istical analysis techniques used for determining
background concentrations for hexavalent chromium in
groundwater for the South Campus Property used ProUCL Version

5.0.00. The analysis is directly applicable to current conditions, including assessing background groundwater conditions at the Site.

To support
this analysis, Rohr used ProUCL Version 5.0.00 and
Version 5.1 to assess an antimony soil data set for the South Campus Property. The same background result was produced for both ProUCL versions (0.392 milligrams per kilogram). As such, there are no technical differences in the statistical software used to develop these background concentrations.

15. Site Feasibility Study for Cleanup to Background Levels in Soil and Groundwater. As of the date of issuance of this CAO, Rohr has not prepared a feasibility study to determine if it is technologically and economically feasible to clean up the wastes in soil to the background cleanup levels. Rohr must prepare and submit this feasibility study to the San Diego Water Board to meet the requirements of Resolution No. 92-49.

In April 2020, pursuant to Resolution No. 92-49, Rohr prepared a feasibility study to determine if it is technologically and economically feasible to clean up the wastes in groundwater at the Site (includes Parcel H-3) to the background cleanup levels.
10 While Rohr concluded that it is infeasible
based on (1) the results of the site-specific trend analysis and (2) the presumed slow back-diffusion of VOC mass stored in fine-grained layers beneath the Site, the San Diego Water Board requires that Rohr confirm its conclusion by collecting additional data during implementation of the Site groundwater Remedial Action Plan (RAP) as required in Directive C.6.b. At a minimum, remediation performance monitoring data shall be used to reevaluate the technical feasibility and incremental cost benefit of remediating to background water quality conditions, including evaluating whether back-diffusion is a significant deterrent to reaching background water quality conditions.

Because Rohr determined it was infeasible to clean up to the background cleanup levels in its April 2020 feasibility study, Rohr proposed the 8 USEPA Region 9 Regional Screening Levels
9 San Francisco Bay Water Board Environmental Screening Levels 10 AECOM, 2020. Revised Alternative Cleanup Levels Report for the North Campus/Parcel H-3.

Rohr, Inc., North Campus Facility, Chula Vista, California. April 2.

CAO No. R9-2021-0042 July 12, 2021
16 alternative cleanup levels in Table 9; however, these levels have not been accepted by the San Diego Water Board as of the date of this CAO.

Table 9. Proposed Alternative Cleanup Levels for Site Groundwater Groundwater Zone Alternative Cleanup Level
Zone A MCLs, Notification Level (NL) for 1,4-
dioxane11, and California Toxics Rule (CTR)
criteria12 (only for point-of-compliance
monitoring wells located along the shoreline)
Upper/Lower Zone B MCLs, NL for 1,4-dioxane, and CTR criteria (only for point-of-compliance monitoring
wells located along the shoreline)

16. Parcel H-3. Parcel H-3 is located on filled tidelands surrounded by the North Campus Property, Chula Vista Marina, San Diego Bay, and the wetlands of the Sweetwater National Wildlife Refuge (Figure 1).
a. Site History. The Off-Property area that includes Parcel H-3 was reclaimed from San Diego Bay in 1960-1962 through the placement of dredged material from the Bay. In 1966, three warehouse buildings (Buildings 910, 911, and 912) were constructed in the fill area and leased to Rohr, which occupied the buildings until 1993.

Buildings 911 and 912 were within the footprint of what is now Parcel H-3. Building 910 was located just south of Parcel H-3. Rohr operations in these buildings included material storage, material cutting and rough-finishing, and small-parts fabrication. Rohr reportedly used a vapor degreaser at Building 912. During this timeframe, Rohr also operated a material storage yard to the east of the buildings that had a paint booth, welding booth, and wash bay with a grease interceptor pit. After Rohr vacated the buildings, they were leased to Eco Building Systems, Inc., and afterward AFS Industries, LLC. The above-grade structures of the warehouse buildings were demolished in 2008 and 2009. The building pads were removed in 2018 prior to importing fill at Parcel H-3.

Parcel H-3 also includes a triangular parcel in the northeast corner that was acquired by Rohr from the Port of San Diego in 1999 under the Relocation Agreement

13. The triangular parcel was used
for employee/contractor parking. The Unified Port of San Diego 11 California State Water Resources Control Board - Department of Drinking Water, Notification Level for 1,4-Dioxane
12 Water Quality Standards: Establishment of Numeric Criteria for Priority Toxic Pollutants for the State of California (California Toxics Rule)
13 Relocation Agreement - City of Chula Vista, Redevelopment Agency of the City of Chula Vista, San Diego Unified Port District, and Rohr, Inc., Operating as BF Goodrich Aerospace Aerostructures Group
CAO No. R9-2021-0042 July 12, 2021
17 acquired ownership of that triangular parcel in 2018 through an eminent domain process.
b. Conceptu
al Site Model. In September 2019, Rohr finalized the
Conceptual Site Model (CSM) report14 for Parcel H-3.

The releases of chlorinated VOCs and 1,4-dioxane at the North Campus Property have migrated in groundwater flowing to the west onto Parcel H-3 and extending towards the Chula Vista Marina.

Environmental features that appear to be sources of VOC migration include the former TCE/1,1,1-TCA aboveground storage tank, historical releases in the Oiler Shed area located at the southwest corner of Building 1, and possibly former vapor degreasers or other features in the northwest portion of the North Campus Property (Figur
e 4).

Seawater intrudes below less saline water in the western area of the groundwater plume, causing upward vertical gradients and upward VOC plume migration into the overlying freshwater zones.

Based on the presence of degradation products, reductive dechlorination and abiotic degradation are important mass removal mechanisms for chlorinated ethenes and ethane in groundwater.

However, given the abundance of silt/clay layers in contact with the VOC plumes, back-diffusion of VOCs
from these silts/clays along
flow paths is expected to sustain VOC concentrations and extend remedial timeframes. Figure 5 shows a schematic illustration of the CSM.
c. H
uman Health Risk Assessment. In March 2020, Rohr finalized the HHRA15 for Parcel H-3. The overall objective of the HHRA is to define the potential risks to human health from exposure to COCs within the Parcel H-3 boundaries.

As summarized in the CSM report for Parcel H-3, VOCs have migrated from the North Campus Property to Parcel H-3. Therefore, the primary medium of concern for Parcel H-3 is groundwater containing VOCs. Secondary impacted media include saturated soil in contact with VOCs in groundwater and soil gas containing VOCs that have volatilized from shallow groundwater. Potential human and ecological risks for areas downgradient of Parcel H-3 will be evaluated as part of the risk assessment for the North Campus Property and the other Off-Property areas.
14 AECOM, 2019. Conceptual Site Model Report - Parcel H3 and Offsite Areas. North Campus, Chula Vista, California. September 30.
15 AECOM, 2020. Human Health Risk Assessment - Parcel H3. North Campus, Chula Vista, California. March 13.

CAO No. R9-2021-0042 July 12, 2021
18 Parcel H-3 is proposed to be redeveloped as a hotel/convention center space with an attached pool/water park area. Based on the proposed Parcel H-3 redevelopment activities, potential future receptors at Parcel H-3 will include construction workers, landscape workers, utility workers, commercial workers, and hotel guests/recreational users.

Cumulative cancer risks and noncancer hazards for commercial workers and hotel guests potentially exposed to soil gas through the vapor-intrusion-to-indoor-air pathway are less than the DTSC target cancer risk level of 1x10-5 and target noncancer hazard index (HI) of 1. These results confirm the conclusions of the previous vapor intrusion investigations that no unacceptable health risk is anticipated for commercial workers or hotel guests of the future buildings through the vapor intrusion pathway, even under the conservative use of the maximum detected soil gas concentrations combined with a default attenuation factor of 0.03 to estimate indoor air concentrations.

For the Parcel H-3 West exposure area (Water Park), predicted construction worker and landscaper exposures based on maximum detected concentrations in saturated subsurface soil and groundwater in the Water Park exposure area resulted in noncancer HIs that exceed the target health goal of 1 and cancer risks that exceeded the acceptable risk level range of 1x10-6 to 1x10-4. Cancer risks were driven almost entirely by exposure to vinyl chloride and TCE in groundwater. Exposure to soil alone does not pose an unacceptable risk to construction workers or landscapers in this area. The reported risks and hazards in the Water
Park exposure area are driven by a single set of
groundwater sample results at boring locati
on H3-DP14 at the 10-
foot depth interval near the northwest property boundary. February 2020 sampling results confirm that the concentrations of VOCs measured at boring location H3-DP14 are anomalous, and the groundwater results from boring location HP-70 should supersede the concentrations measured in H3-DP14. These results also indicate that concentrations in shallow groundwater at boring location HP-70 are less than the health-based remediation goals for construction and landscape workers (discussed further below) and thus do not pose an unacceptable health hazard or cancer risk to construction and landscape workers. As such, the risk assessment for Parcel H-3 West indicates a noncancer target health goal less than 1 and an excess cancer risk within the acceptable risk level range of 1x10-6 to 1x10-4.

For the Parcel H-3 East exposure area (Resort Hotel and Convention Center), construction and landscape worker exposures based on maximum detected concentrations in saturated
CAO No. R9-2021-0042 July 12, 2021
19 subsurface soil and shallow groundwater resulted in noncancer HIs equal to or below the target health goal of 1 and excess cancer risks within the acceptable risk level range of 1x10-6 to 1x10-4. For both receptors, cancer risks exceeded the DTSC target risk level of 1x10-5 and were driven almost entirely by exposure to vinyl chloride in groundwater. Saturated soil and shallow groundwater do not exceed the target health goal, and cancer risks are within the acceptable risk level range of 1x10-6 to 1x10-4; however, the estimated excess cancer risks exceed the DTSC threshold risk level of 1x10-5. Cancer risks are driven almost entirely by exposure to vinyl chloride in groundwater. The maximum concentration of vinyl chloride of 7.1 μg/L was measured at boring location H3-DP1.

The only other detection of vinyl chloride in Parcel H-3 East was much lower (0.39 μg/L at boring location DP-465).

Health-based remediation goals for the primary risk drivers in groundwater (TCE and vinyl chloride) were calculated to be protective of construction workers (vinyl chloride: 3 µg/L and TCE:
34 µg/L) and landscape workers (vinyl chloride: 1 µg/L and TCE: 18 µg/L). These health-based remediation goals were exceeded at only two locations across the entire Parcel H-3. In the Parcel H-3 East exposure area (Resort Hotel and Convention Center), vinyl chloride at boring location H3-
DP1
exceeded the remediation goal
for construction worker and landscaper receptors and will be addressed with a Groundwater Management Plan (GM
P). In the
Water Park exposure area, health-based remediation goals for vinyl chloride and TCE were exceeded at boring location H3-DP14 for the construction and landscaper worker receptors. However, VOCs measured in boring location H3-DP14 are anomalous, and the groundwater results for samples collected from boring location HP- 70 supersede the results for boring location H3-DP14. TCE and vinyl chloride were not detected in the shallow groundwater sample collected at boring location HP-70 and, thus, the TCE and vinyl chloride in groundwater do not pose an unacceptable noncancer or cancer risk for construction and landscape workers in this area.

No other exceedances of health-based remediation goals were noted. Concentrations of site-related chemicals measured in saturated subsurface soil to a depth of 15 feet bgs and shallow groundwater indicate health risks for construction worker and landscaper exposures are expected to be much lower based on (1) the conservative assumptions inherent in the risk assessment process
, and (2) the fact that exposures are unlikely to occur at a single location across the exposure area.
d. Site
Background Soil and Groundwater Cleanup Levels. In
October 2019, pursuant to Resolution No. 92-49, Rohr submitted a technical analysis to the San Diego Water Board to identify the CAO No. R9-2021-0042 July 12, 2021
20 background cleanup levels for inorganic chemicals in soil and groundwater at the Site, which includes Parcel H-3. The cleanup levels for inorganic chemicals in (1) soil must lead to attainment of background water quality in groundwater, and (2) groundwater must attain background water quality.

The technical analysis concluded that the background levels for metals in soil and groundwater at the South Campus Property, as established in Addendum No. 2 to CAO No. R9-2014-0019, are applicable to Site. This conclusion is based on the following rationale:
i. The Sit
e and South Campus Property are contiguous parts
of the same manufacturing facility, and similar lithologic conditions occur at both locations.
ii. The statistical analysis techniques used for the South Campus Property background analysis follow the same
processes used in current statistical software.
iii. The statistical analysis techniques used for determining background concentrations for metals in groundwater at the South Campus Property used a recent version of the EPA- approved statistical software (ProUCL Version 5.0.00). The analysis is directly applicable to current conditions, including assessing background groundwater conditions at the Site. iv. The statistical analysis techniques used for determining background concentrations for hexavalent chromium in
groundwater for the South Campus Property used ProUCL
Version 5.0.00. The analysis is directly applicable to current conditions, including assessing background groundwater
conditions at the Site. To support this analysis, Rohr used ProUCL Version 5.0.00 and Version 5.1 to assess an
antimony soil data set for the South Campus Property. The same background result was produced for both ProUCL
versions (0.392 milligrams per kilogram). As such, there are no technical differences in the statistical software used to develop these background concentrations.

For all organic chemicals, the background soil and groundwater cleanup levels are non-detect concentrations. The detection limits for all organic chemicals in soil must not exceed the respective EPA Region 9 RSLs and the San Francisco Bay Water Board ESLs. The detection limits for all organic chemicals in groundwater must not exceed the respective MCLs.
e. Feasibility Study for Groundwater Background Cleanup Levels. In April 2020, pursuant to Resolution No. 92-49, Rohr CAO No. R9-2021-0042 July 12, 2021
21 prepared a feasibility study to determine if it is technologically and economically feasible to clean up the wastes in groundwater at the Site (includes Parcel H-3) to the background cleanup levels. While Rohr concluded that it is infeasible based on (1) the results of the site-specific trend analysis, and (2) the presumed slow back- diffusion of VOC mass stored in fine-grained layers beneath the Site, the San Diego Water Board requires that Rohr confirm its conclusion by collecting additional data during implementation of the Site groundwater RAP as required in Directive B.1.b. At a minimum, remediation performance monitoring data shall be used to reevaluate the technical feasibility and incremental cost benefit of remediating to background water quality conditions, including evaluating whether back-diffusion is a significant deterrent to reaching background water quality conditions.

Because Rohr determined in its April 2020 feasibility study that it was infeasible to clean up to the background cleanup levels, Rohr proposed the alternative cleanup levels in Table 10, however these levels have not been accepted by the San Diego Water Board as of the date of this CAO.

Table 10. Proposed Alternative Cleanup Levels for Parcel H-3 Groundwater
Groundwater Zone Alternative Cleanup Level
Zone A MCLs or risk-based cleanup levels
(whichever is lower), NL for 1,4-
dioxane, and CTR criteria (only for
point-of-compliance monitoring wells
located along the shoreline)
Upper/Lower Zone B MCLs, NL for 1,4-dioxane, and CTR
criteria (only for point-of-compliance
monitoring wells located along the
shoreline)
f. Interim Groundwater Remediation. In March 2020, Rohr finalized a groundwater feasibility study and RAP (FS-RAP) report16 for Parcel H-3. The objectives of the FS-RAP are to identify and implement an interim groundwater remedial alternative within Parcel H-3 to meet the following remedial action objectives: (1) protect human health, (2) reduce the flux of VOCs migrating from the North Campus Property to Parcel H-3, (3) remove VOC mass from groundwater beneath Parcel H-3, and (4) achieve MCLs in groundwater by working in concert with the remedy for the North 16 AECOM, 2020. Revised Groundwater Feasibility Study Report - Remedial Action Plan Interim Groundwater Remediation for Parcel H3. North Campus, Chula Vista, California. March 16.

CAO No. R9-2021-0042 July 12, 2021
22 Campus Property and the other adjacent off-site areas.

The select
ed remedial alternative for Parcel H-3 includes a
combination of the following remedial technologies to meet the remedial action objectives:
i. In Situ Chemical Reduction and Enhanced In Situ
Bioremediation. In situ chemical reduction (ISCR) and
enhanced in situ bioremediation (EISB) amendments were
inject
ed into Zone A and Upper Zone B groundwater to
create four permeable reactive barriers (PRBs). The
amendments consist of zero valent iron (ZVI), emulsified vegetable oil (EVO), and a commercial Dehalococcoides
(DHC) culture KB-1TM or equivalent.

The treatment areas are primarily focused on TCE
concentrations that exceed 5,000 µg/L. The barrier located near the property boundary of the North Campus Property (Barrier 1) will target Zone A and Upper Zone B groundwater to limit migration of TCE and other chlorinated VOCs from North Campus Property onto Parcel H-3. Barrier 2, located in the center of Parcel H-3, will target Upper Zone B
groundwater and intercept 10,000-μg/L TCE
isoconcentration contours with an estimated in situ VOC treatment period of 5 years. Barriers 3 and 4, located near the downgradient boundaries of Parcel H-3, will target Upper Zone B groundwater to limit migration of VOCs from Parcel H-3.
ii. Enhanced In Situ Bioremediation and Bioaugmentation.

EISB and bioaugmentation amendments were injected into
Zone A and Upper Zone B groundwater in a grid pattern to reduce contaminant mass directly within the inferred 10,000- µg/L TCE contours. The amendments consist of EVO and a
microbial consortium.
iii. Monitored Natural Attenuation. Monitored natural
attenuation will be implemented by monitoring existing and new monitoring wells to demonstrate plume stability and/or declining VOC and 1,4-dioxane concentrations within and near Parcel H-3.
iv. Engineered Controls. The HHRA identified one isolated area within Parcel H-3 where VOC concentrations in shallow groundwater may pose unacceptable risks to construction or landscape workers. In the Convention Center exposure area, vinyl chloride at H3-DP1 exceeded the remediation goal for construction worker and landscaper receptors. VOC
CAO No. R9-2021-0042 July 12, 2021
23 concentrations are expected to decline over time at this location as the remedy is implemented and through natural attenuation processes.

Potential risks to future construction and landscape workers will be managed through implementation of a GMP. The
GMP will be prepared to protect workers from possible
contact with chemicals in groundwater that may be
generated by dewatering for subsurface construction,
including excavation and utility placement. The GMP will describe appropriate dewatering control and discharge
requirements, including the engineered controls necessary to minimize worker contact with groundwater, and the
treatment technologies and methods required to meet
applicable discharge criteria specified in project permits and approvals. The GMP will be submitted to the San Diego
Water Board for review and approval.
g. Implement
ation Schedule. In March 2020, Rohr began
implementing the selected interim remedial alterative pursuant to CAO No. 98-08. Injections were completed in September 2020; however, additional injections will be conducted later once specific areas become accessible.
h. Interim Remedial Action Reporting. Rohr, as discussed in the F
S-RAP, will submit routine progress reports to the San Diego Water Board. These monitoring reports will document the implementation of remedial activities at Parcel H-3, including well logs, quantities and types of amendments injected into the subsurface, the sequence of amendment injections, monitoring results, and supporting data. Rohr will also submit Quarterly Monitoring Reports in accordance with Monitoring and Reporting Program No. R9-2008-0081 for In-Situ Groundwater Remediation Projects within the San Diego Region.
17 17. Need and Benefit of Technical and Monitoring Reports. The San Diego Water Board is authorized by Water Code section 13267 to require any person who has discharged, discharges, or is suspected of having discharged or discharging waste within the Region to prepare technical reports and monitoring reports. The technical and monitoring reports required by this CAO are needed to provide information to the Board regarding (a) the nature and extent of the discharge, (b) the nature and extent of nuisance conditions in s
tate waters created by the discharge, (c)
the potential for vapor risk to human health as a result of the discharge, and (d) appropriate cleanup and abatement measures, if needed, capable of 17 Order No. R9-2008-0081 - General Waste Discharge Requirements for In Situ Groundwater Remediation Projects within the San Diego Region
CAO No. R9-2021-0042 July 12, 2021
24 meeting cleanup levels consistent with Resolution No. 92-49. The technical and monitoring reports will enable the Board to understand the vertical and lateral extents of the discharge and provide information to determine which cleanup and abatement measures are necessary to bring the Site into compliance with Resolution No. 92-49 and ensure protection of human health. Based on the nature of the discharge and possible effects and consequences associated with the discharge at the Site, as described in the Findings above, the burden of providing the required technical and monitoring reports, including the costs, bears a reasonable relationship to the need for the reports, and to the benefits to be obtained from the reports.

As provided by Rohr, the estimated total cost associated with the implementation of the directives included in this CAO range from $18.7M to $26.8M and are described in Table 11:

Table 11. Estimated Costs for this CAO
Task Estimated Cost Range
Site Assessment and Investigation $2.2M to $3.8M
Remedial Action – Soil $4.0M to $6.0M
Remedial Action – Soil Gas $0.7M to $1.0M
Remedial Action – Groundwater $9.8M to $12.5M
Post-Remediation Site Monitoring $2.0M to $3.5M
Estimated Total $18.7M to $26.8M

18. California Environmental Quality Act Compliance. Interim remedial activities are ongoing at Parcel H-3 pursuant to Order No. 98-08. Issuance of this CAO is not subject to the California Environmental Quality Act (CEQA) because it can be seen with certainty that there is no possibility that issuance of this CAO may have a significant effect on the environment.18 This CAO directs the Dischargers to undertake corrective actions through implementation of remedial action plans, but the details of the remedial action plans are not yet known. The San Diego Water Board will evaluate compliance with CEQA when it considers approval of the Dischargers’ proposed remedial action plans.

19. Qualified Professionals. The Dischargers’ reliance on qualified professionals promotes proper planning, implementation, and long-term cost-effectiveness of investigations. Professionals must be qualified, licensed where applicable, and competent and proficient in the fields pertinent to the required activities. California Business and Professions Code sections 6735, 7835, and 7835.1 require that engineering and geologic evaluations and judgments be performed by or under direction of licensed professionals.
18 See Cal. Code Regs., title 14, section 15061(b)(3).

CAO No. R9-2021-0042 July 12, 2021
25 20. Cost
Recovery. Pursuant to Water Code section 13304, subsection (c), and consistent with other statutory and regulatory requirements, including but not limited to Water Code section 13365, the San Diego Water Board is entitled to, and will seek reimbursement for, all reasonable costs incurred by the Board to investigate unauthorized discharges of waste and to oversee cleanup of such waste, abatement of the effects thereof, or other remedial action, required by this or a subsequent CAO.

IT IS HEREBY ORDERED that (1) this CAO supersedes CAO No. 98-08 except for the performance of ongoing interim remedial actions at Parcel H-3, which will be conducted pursuant to CAO No. 98-08, and (2) pursuant to sections 13267 and 13304 of the Water Code, the Dischargers
must comply with the following
directives:

A. Cleanup o
r Abatement of Discharged Wastes. The Dischargers must
take all corrective actions necessary to clean up or abate the effects of the discharges to soil, soil gas, and groundwater at the Site.

1. Wast
es in soil at the Site must be cleaned up or abated in a manner that promotes attainment of background concentrations or alternative cleanup levels in groundwater and protects human health.

2. Wastes in groundwater at the Site must be cleaned up or abated in a manner that attains background concentrations or alternative cleanup levels approved by the San Diego Water Board.

3. Wastes in groundwater at the point-of-compliance wells located along San Diego Bay and Chula Vista Marina shorelines must be cleaned up or abated
in a manner that attains (a) background concentrations
in groundwater or (b) CTR water quality standards for human ingestion of water/seafood and risk-based concentrations protective of aquatic receptors.

4. Wastes in soil gas at the Site caused by soil and/or groundwater contamination must be cleaned up or abated in a manner that protects human health.

B. Off-Property Cleanup or Abatement. The Dischargers must clean up or abate discharges of waste to soil, soil gas, and groundwater that have migrated and continue to migrate from the North Campus Property to Off- Property areas. Remedial actions at the Off-Property areas, except for Parcel H-3, must be addressed in parallel with the cleanup or abatement of wastes discharged on the North Campus Property. Remedial actions at Parcel H-3 are being implemented prior to the other Off-Property areas due to an accelerated redevelopment schedule. The directives for Parcel H-3 and the other Off-Property areas are provided in this directive and Directive C, respectively. Directives associated with Parcel H-3 are as follows:

CAO No. R9-2021-0042 July 12, 2021
26 1. Parcel
H-3 Interim Groundwater Remedial Actions. Interim
groundwater remedial actions are underway at Parcel H-3 pursuant to CAO No. 98-08. The interim remedial actions must be capable of achieving MCLs in groundwater. The following reports are required under CAO No. R9-2021-0042:
a. Parcel H-3 Remedial Action Plan Progress Reports. The Dischargers must prepare monthly RAP Progress Reports.

RAP Progress Reports must be submitted to the San Diego Water Board for approval no later than 30 calendar days following the close of each month. The first RAP Progress Report must be submitted after the first full month of RAP implementation.

The Dischargers can propose an alternate schedule upon
completing the installation of the selected remedial alterative.

The proposed alternate schedule must be submitted in writing to the San Diego Water Board for Executive Officer approval.

Each progress report must include, but is not limited to, the following:
i. A detailed description of the remedial actions
conducted and any deviations from the activities
described in the RAP.
ii. Supporting information such as analytical laboratory reports and waste manifests.
iii. Remediation schedule updates.
iv. Conclusions and recommendations.
b. Parcel H-3 Groundwater Cleanup Levels Report. The
Dischargers must prepare a Parcel H-
3 Groundwater Cleanup
Levels Report that reevaluates the technological and
economic feasibility of cleaning up the wastes discharged in groundwater at Parcel H-3 to background groundwater
cleanup levels. At a minimum, remediation performance
monitoring data collected during the groundwater remedial actions at the Site shall be used to develop the background feasibility study. The Parcel H-3 Groundwater Cleanup Levels Report must be submitted to the San Diego Water Board (1) after 1 year of Groundwater RAP monitoring and data
collection, and (2) n
o later than 60 calendar days after the
San Diego Water Board has approved the report for the
last Groundwater RAP monitoring and sampling event in
the 1-year period.

CAO No. R9-2021-0042 July 12, 2021
27 The Parcel H-3 Groundwater and Soil Gas Remedial
Alternatives Report must include, but is not limited to, the following:
i. A summ
ary of the Feasibility Study, as described in
Finding 16.e, that evaluated the technological and
economic feasibility of cleaning up the wastes
discharged to groundwater at Parcel H-3 to background
groundwater cleanup levels and proposed alternative
cleanup levels.
ii. Identification of COC source areas and the lateral and vertical extents of COCs in groundwater and soil gas.
iii. Reevaluation of whether back-diffusion from the low- permeability silt/clay layers to more permeable sand
layers is a significant deterrent to reaching background water quality conditions.
iv. Reevaluation of whether it is technologically and
economically infeasible to reaching background water
quality conditions. If the San Diego Water Board
accepts the Dischargers reevaluation confirming it is
infeasible to clean up to background water quality
conditions, the Dischargers will implement the
alternative cleanup levels proposed in Finding 16.e.
c. Parcel H-3 Cleanup and Abatement Completion Report.

The Dischargers must prepare a Cleanup and Abatement
Completion Report verifying the completion of all cleanup activities in contaminated groundwater that have migrated from the North Campus Property to Parcel H-3. The Cleanup and Abatement Completion Report must be submitted to the San Diego Water Board for approval no later than 90
calendar days after the San Diego Water Board has
approved the Parcel H-3 RAP Progress Report for the last Groundwater RAP monitoring and data collection event.

The Cleanup and Abatement Completion Report must
demonstrate that (1) all corrective actions necessary to clean up
or abate the effects of the wastes discharged to
groundwater from the North Campus Property to Parcel H-3 have been completed, and (2) background concentrations or alternative cleanup levels have been met in groundwater beneath Parcel H-3.

C. Site Cleanup or Abatement (excluding Parcel H-3). The Dischargers must clean up or abate discharges of waste to soil, soil gas, and groundwater at the Site.

CAO No. R9-2021-0042 July 12, 2021
28 Discharges of waste from the North Campus Property to Parcel H-3 are being addressed separately due to an accelerated redevelopment schedule for Parcel H-3. The directives for Parcel H-3 are provided in Directive B.

Directives associated with the Site, excluding Parcel H-3, are as follows:

1. Updated C
onceptual Site Model Report. The Dischargers must
prepare an updated CSM Report for discharges of waste to soil, soil gas, and groundwater at the Site, excluding Parcel H-3, based on the San Diego Water Board’s October 2020 comments on Rohr’s CSM report submitted in May 2020.

In general, CSM Reports must be updated routinely when new information is obtained throughout the life of the project.

Development and refinement of the CSM Reports help identify potential investigation data gaps, which can ultimately support remedial decision-making.

The updated CSM Report must include, but is not limited to, the following:
a. A description of the Site, excluding Parcel H-3. The description must include the history, geology, hydrogeology,
environmental features, source areas, previous investigation and remediation activities, contaminant migration pathways, receptors of concern, and extent of COCs in soil, soil gas, and groundwater.
b. A graphical illustration of the environmental features, source areas, and contaminant migration/exposure pathways in soil, soil gas, and groundwater.
c. A flowchart showing
the primary/secondary sources and
release mechanisms, tertiary sources and release mechanism, quaternary sources and release mechanism, potential
exposure pathways, and receptors.
d. An identification and discussion of the site investigation data gaps associated with source identification, lateral and vertical extents of contamination, and potential threats to water quality and human health.

The updated CSM Report must be submitted to the San Diego Water Board for approval n
o later than 60 calendar days after
the date of this CAO.

2. Site I
nvestigation Data Gaps. The Dischargers must address the data gaps identified in the CSM Report. The following deliverables are required:

CAO No. R9-2021-0042 July 12, 2021
29 a. Site D
ata Gap Investigation Work Plan. The Dischargers
must
prepare a Site Data Gap Investigation Work Plan to
address the data gaps identified in the updated CSM Report.

The Site Data Gap Investigation Work Plan must be submitted to the San Diego Water Board for approval no later than 120 calendar days after the date of this CAO.

The Site Data Gap Investigation Work Plan must include, but is not limited to, the following:
i. A summary of the updated CSM Report described in
Directive C.1.
ii. A detailed description of all activities planned to address the data gaps.
iii. An implementation schedule.
b. Site Data Gap Investigation Report. The Dischargers must prepare a Site Data Gap Investigation Report that presents the findings of implementation of the Site Data Gap Investigation Work Plan. The Site Data Gap Investigation Report must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the last scheduled activity in the work plan is completed.

The Site Data Gap Investigation Report must include, but is not limited to, the following:
i. A detail
ed description of all activities completed to
address the data gaps.
ii. Supporting information such as boring logs, data tables, maps, and laboratory analytical data.
iii. Results, conclusions, and recommendations.

3. Site Human Health Risk Assessment. The Dischargers must prepare an HHRA for discharges of waste to soil, soil gas, and groundwater at the Site, excluding Parcel H-3. The HHRA must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the Board has approved the Site Data Gap Investigation Report.

The HHRA must include, but is not limited to, the following:
a. A summary of the updated CSM Report described in Directive C.1.

CAO No. R9-2021-0042 July 12, 2021
30 b. An assessm
ent of the potential risks to current and future
receptors due to the discharges of waste to soil, soil gas, and groundwater at the Site, excluding Parcel H-3.
c. An assessment of the potential risks to current and future building occupants due to vapor intrusion.
d. An assessment of the potential threat to receptors in San Diego Bay due to the migration of impacted groundwater from the North Campus Property.
e. The development of risk-based soil cleanup and/or soil gas mitigation/remediation levels for discharges of waste to vadose-zone soil and soil gas at the Site, excluding Parcel H- 3, to protect current and future receptors.

4. Site Soil and Soil Gas Feasibility Study. Pursuant to Resolution No. 92-49, the Dischargers must conduct a Site Soil and Soil Gas Feasibility Study that: (1) evaluates the feasibility of cleaning up wastes discharged to vadose-zone soil to cleanup levels that promote attainment of background water quality or to alternative cleanup levels, (2) evaluates a variety of remedial alternatives, (3) proposes a remedial alternative(s) capable of achieving the soil cleanup
levels in Directive C.4.a, and (4) proposes a remedial
alternative(s) capable of achieving the risk-based soil gas mitigation/remediation levels in Directive C.3.e. The following deliverables are required under this directive:
a. Site Soil Cleanup Levels Report. The Dischargers must prepare a Site Soil Cleanup Levels Report that evaluates the feasibility of cleaning up wastes discharged to soil at the Site, excluding Parcel H-3, to cleanup levels that will achieve background water quality or alternative cleanup levels. The Site Soil Cleanup Levels Report must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the Board has approved the Site HHRA.

The Site Soil Cleanup Levels Report must include, but is not limited to, the following:
i. Identification of COC source areas and the lateral and vertical extents of COCs in soil and soil gas.
ii. An evalu
ation of the potential for back-diffusion from the
low-permeability silt/clay layers to more permeable
sand layers.
iii. An evaluation of the technological and economic
feasibility of cleaning up the wastes discharged to soil CAO No. R9-2021-0042 July 12, 2021
31 at the Site, excluding Parcel H-3, to cleanup levels that promote attainment of background water quality.
iv. If
applicable, the Dischargers must develop a range of
alternative cleanup levels between cleanup levels that
promote attainment of background water quality
conditions and cleanup levels that promote attainment
of MCLs in groundwater. The alternative cleanup levels
must (1) be consistent with maximum benefit to the
people of the s
tate, (2) not unreasonably affect present
and anticipated beneficial uses of such water, and (3)
not result in water quality less than prescribed in the Water Quality Control Plans and policies adopted by
the State and Regional Water Boards. The
development of alternative cleanup levels is only
acceptable when it is technologically and/or
economically infeasible to clean up to levels that
promote attainment of background water quality.
b. Site S
oil and Soil Gas Remedial Alternatives Report. The
Dischargers must evaluate a variety of remedial alternatives and selects a remedial alternative(s) capable of achieving the soil cleanup and soil gas mitigation/remediation levels described in Directives C.4.a and C.3.e, respectively. The Site Soil and Soil Gas Remedial Alternatives Report must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the Board has approved the
Site Soil Cleanup Levels Report.

The Site Soil and Soil Gas Remedial Alternatives Report must include, but is not limited to, the following:
i. An evaluation of a variety of remedial alternatives
capable of effectively cleaning up or abating the
sources of COCs in (1) soil to achieve the background
cleanup levels or to achieve the selected alternative
cleanup levels, and (2) soil gas to achieve risk-based
cleanup levels that protect current and future receptors.

5. Site S
oil and Soil Gas Remedial Actions. The Dischargers must conduct remedial actions to address the wastes discharged to soil and soil gas at the Site, excluding Parcel H-3. The remedial actions must be capable of achieving the soil cleanup levels identified in the Site Soil and Soil Gas Feasibility Study and the soil gas mitigation/remediation levels identified in the HHRA. The following deliverables are required under this directive:
a. Site Soil and Soil Gas Remedial Action Plan. The
Dischargers must prepare a Site Soil and Soil Gas Remedial Action Plan (Soil RAP) for wastes discharged to soil and soil gas at the Site, excluding Parcel H-3. The Soil RAP must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the Board has approved the
Site Soil and Soil Gas Remedial Alternatives Report.

The Soil RAP must include, but is not limited to, the following:
i. A summary of the HHRA pertaining to the potential soil and soil gas risks to current and future receptors, and the development of risk-based cleanup levels, as
completed under Directive C.3.
ii. A summary of the Site Soil and Soil Gas Feasibility Study,
as completed under Directive C.4.
iii. A detail
ed description of all activities planned to
implement the remedial alternative(s) selected in the
Site Soil and Soil Gas Remedial Alternatives Report.
iv. An implementation schedule.
b. Site Soil and Soil Gas Remedial Action Plan
Implementation. The Dischargers must initiate
implementation of the Soil RAP for the Site, excluding Parcel H-3, no later than 60 calendar days after the Board has approved the Soil RAP.

The San Diego Water Board must be notified in writing of the Dischargers’ intent to implement the Soil RAP. Notification must be provided no later than 14 calendar days prior to implementation of the Soil RAP.
c. Site Soil and Soil Gas Remedial Action Plan Progress Reports. The Dischargers must prepare quarterly Soil RAP Progress Reports for the Site, excluding Parcel H-3. The Soil CAO No. R9-2021-0042 July 12, 2021
33 RAP Progress Reports must be submitted to the San Diego Water Board for approval no later than 30 calendar days following the close of each quarter. The first progress report must be submitted after the first full quarter of Soil RAP implementation.

Each quarterly Soil RAP Progress Report must include, but is not limited to, the following:
i. A detai
led description of the remedial actions
conducted and any deviations from the activities
described in the Soil RAP.
ii. Supporting information such as analytical laboratory reports and waste manifests.
iii. Remediation schedule updates.
iv. Conclusions and recommendations.
d. Site Soil and Soil Gas Remedial Action Plan Completion Report. The Dischargers must prepare a Site Soil and Soil Gas Remedial Action Plan Completion Report verifying the completion of all soil cleanup and soil gas
mitigation/remediation activities at the Site, excluding Parcel H-3. The Site Soil and Soil Gas Remedial Action Plan
Completion Report must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the San Diego Water Board has approved the Soil RAP
Progress Report for the last scheduled activity in the Soil RAP.

The Site Soil and Soil Gas Remedial Action Plan Completion Report must demonstrate that all corrective actions necessary to clean up or abate the effects of the wastes discharged to soil and soil gas at the Site, excluding Parcel H-3, have been completed and all final cleanup levels have been achieved.

6. Site Groundwater and Soil Gas Feasibility Study. Pursuant to Resolution No. 92-49, the Dischargers must conduct a Site Groundwater and Soil Gas Feasibility Study that (1) evaluates the feasibility of cleaning up wastes discharged to groundwater to cleanup levels that will achieve background water quality or alternative cleanup levels, (2) evaluates a variety of remedial alternatives, and (3) proposes a remedial alternative(s) capable of achieving groundwater cleanup levels and soil gas
mitigation/remediation levels. The following deliverables are required under this directive:

CAO No. R9-2021-0042 July 12, 2021
34 a. Site
Groundwater and Soil Gas Remedial Alternatives
Report. The Dischargers must prepare a Site Groundwater and Soil Gas Remedial Alternatives Report that evaluates a variety of remedial alternatives and selects a remedial alternative(s) capable of achieving background water quality or alternative cleanup levels in groundwater and the risk-based soil
gas mitigation/remediation levels identified in the HHRA.

The Site Groundwater and Soil Gas Remedial Alternatives Report must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the Board has approved the Site Soil and Soil Gas Remedial Action Plan Completion Report.

The Site Groundwater and Soil Gas Remedial Alternatives Report must include, but is not limited to, the following:
i. An evaluation of a variety of single and combined
remedial alternatives capable of effectively (1) cleaning up or abating the sources of COCs in groundwater to
achieve background concentrations or alternative
cleanup levels, (2) cleaning up or abating the sources
of COCs in groundwater at the point-of-compliance
wells located along the San Diego Bay and Chula Vista
Marina shorelines to achieve background
concentrations or CTR water quality standards, (3)
cleaning up or abating the sources of COCs in soil gas
to achieve concentrations that protect current and
future receptors, and (4) preventing continued migration of pollutants from the North Campus Property to the
Off-Site areas, San Diego Bay, and Chula Vista Marina.

Potential single or combined remedial alternatives must be evaluated based on effectiveness, implementability,
overall protection of human health, and cost.
ii. The Dischargers must select a single or combined
remedial alternatives from the options evaluated in
Directive C.6.a.i. The selected remedial alternative(s) must be capable of achieving the background
concentrations or alternative cleanup levels for all
waste constituents at all monitoring points and
throughout the zones
affected by the waste constituents
at t
he Site, excluding Parcel H-3.
b. Sit
e Groundwater Cleanup Levels Report. The Dischargers
must prepare a Site Groundwater Cleanup Levels Report that reevaluates the technological and economic feasibility of cleaning up the wastes discharged in groundwater at the Site, CAO No. R9-2021-0042 July 12, 2021
35 excluding Parcel H-3, to background groundwater cleanup levels. At a minimum, remediation performance monitoring data collected during the groundwater remedial actions at the Site shall be used to develop the background feasibility study.

The Site Groundwater Cleanup Levels Report must be
submitted to the San Diego Water Board (1) after 6 months of Groundwater RAP monitoring and data collection, and (2) no later than 60 calendar days after the San Diego Water
Board has approved the report for the last Groundwater
RAP monitoring and sampling event in the 6-month
period.

The Site Groundwater and Soil Gas Remedial Alternatives Report must include, but is not limited to, the following:
i. A summ
ary of the Feasibility Study, as described in
Finding 15, that evaluated the technological and
economic feasibility of cleaning up the wastes
discharged to groundwater at the Site to background
groundwater cleanup levels and proposed alternative
cleanup levels.
ii. Identification of COC source areas and the lateral and vertical extents of COCs in groundwater and soil gas.
iii. Reevaluation of whether back-diffusion from the low- permeability silt/clay layers to more permeable sand
layers is a significant deterrent to reaching background water quality conditions.
iv. Reevaluation of whether it is technologically and
economically infeasible to reaching background water
quality conditions. If the San Diego Water Board
accepts the Dischargers reevaluation confirming it is
infeasible to cleanup to background water quality
conditions, the Dischargers will implement the
alternative cleanup levels specified in Finding 15.

7. Site Groundwater and Soil Gas Remedial Actions. The
Dischargers must conduct remedial actions to address the discharge of waste to groundwater and soil gas at the Site, excluding Parcel H-

3. The remedial actions must be capable of achieving background concentrations or alternative cleanup levels in groundwater, background concentrations or CTR water quality standards at the point-of-compliance wells located along the San Diego Bay and Chula Vista Marina shorelines, and the risk-based
soil gas
mitigation/remediation levels proposed in the HHRA. The following are required under this directive:

CAO No. R9-2021-0042 July 12, 2021
36 a. Site P
ilot Tests. The Dischargers may conduct pilot tests, if needed, to confirm that the selected remedial alternative(s) in the Site Groundwater and Soil Gas Feasibility Study will be effective in achieving the groundwater cleanup and soil gas mitigation/remediation levels. If pilot tests are proposed, the Dischargers must submit the following to the San Diego Water Board:
i. A work plan for the pilot test that includes, but is not limited to, the purpose of the pilot test, field work
activities to be completed, and a description of
proposed performance monitoring activities
.
ii. A repor
t describing the completed field work activities in
the work plan, results, conclusions, and
recommendations.
b. Site Groundwater and Soil Gas Remedial Action Plan. The Dischargers must prepare a Site Groundwater and Soil Gas Remedial Action Plan (Groundwater RAP) for discharges of waste to groundwater and soil gas at the Site, excluding Parcel H-3. The Groundwater RAP must be submitted to the San Diego Water Board for approval no later than 90
calendar days after the Board has approved the Site
Groundwat
er and Soil Gas Feasibility Study.

The Groundwater RAP must include, but is not limited to, the following:
i. A summary of the HHRA pertaining to the groundwater
and soil gas risks to current and future receptors, and the development of risk-based cleanup levels, as
com
pleted under Directive C.3.
ii. A sum
mary of the Site Groundwater and Soil Gas
Feasibility Study, as completed under Directive C.6.
iii. A detailed description of all activities planned to implement the selected remedial alternative(s) in the
Site Groundwater and Soil Gas Feasibility Study.
iv. A detailed description of all activities planned to reevaluate the technical feasibility and incremental cost benefit of remediating to background water quality
conditions, including evaluating whether back-diffusion is a significant deterrent to reaching background water quality conditions.
v. An implementation schedule.

CAO No. R9-2021-0042 July 12, 2021
37 c. Site G
roundwater and Soil Gas Remedial Action Plan
Implementation. The Dischargers must implement the
Groundwater RAP no later than 60 calendar days after the Board has approved the Groundwater RAP.

The San Diego Water Board must be notified in writing of the Dischargers’ intent to implement the Groundwater RAP.

Notification must be provided no later than 14 calendar days prior to implementation of the Groundwater RAP.
d. Site G
roundwater and Soil Gas Remedial Action Plan
Progress Reports. The Dischargers must prepare quarterly Groundwater RAP Progress Reports. The Groundwater RAP
Progress Reports must be submitted to the San Diego Water Board for approval no later than 30 calendar days following the close of each quarter. The first progress report must be submitted after the first full quarter of Groundwater RAP implementation.

Each quarterly progress report must include, but is not limited to, the following:
i. A detailed description of the groundwater remediation and/or soil gas mitigation/remediation actions
conducted and any deviations from the activities
described in the Groundwater RAP.
ii. Supporting information such as analytical laboratory reports and waste manifests.
iii. Remediation schedule updates.
iv. Conclusions and recommendations.
e. Site Groundwater and Soil Gas Remedial Action Plan
Completion Report. The Dischargers must submit a Site
Groundwater and Soil Gas Remediation Action Plan
Completion Report verifying the completion of all Site
groundwater cleanup and soil gas mitigation/remediation activities, excluding Parcel H-3. The Site Groundwater and Soil Gas Remedial Action Plan Completion Report must be submitted to the San Diego Water Board for approval no later than 90 calendar days after the San Diego Water Board
has approved the Soil RAP Progress Report for the last
scheduled activity in the Groundwater RAP.

The report must demonstrate that:

CAO No. R9-2021-0042 July 12, 2021
38 i. All
corrective actions necessary to clean up or abate
the effects of wastes discharged to groundwater and
soil gas at the Site, excluding Parcel H-3, have been
completed and background concentrations or
alternative cleanup levels have been met.
ii. The groundwater concentrations at the point-of-
compliance wells located along the Chula Vista Marina
shoreline are protective of the three target receptors in San Diego Bay (Table 12). Protection of the three
target receptors must be demonstrated by (1)
comparing the groundwater concentrations to the CTR
water quality standards for human ingestion of
water/seafood, (2) comparing the groundwater
concentrations to risk-based concentrations protective
of aquatic receptors, and (3) running a final
groundwater chemical fate-and-transport model using
the latest post-remedial groundwater concentrations.

Table 12. Target Receptors in San Diego Bay
Beneficial Use Target Receptor(s)
Commercial and Sport Fishing Human Health
Shellfish Harvesting Human Health
Estuarine Habitat Benthic Community, Wildlife, Finfish
Marine Habitat Benthic Community, Wildlife, Finfish
Wildlife Habitat Wildlife
Rare, Threatened, or Endangered
Species Wildlife, Finfish
Preservation of Biological
Habitats of Special Significance Wildlife, Finfish
Spawning, Reproduction, and/or
Early Development Finfish
D. Groundwater Monitoring Program. The Dischargers must continue to implement the 2017 revised Groundwater Monitoring Program (2017 GMP)19 or implement the most updated GMP that supersedes the 2017 GMP. The goals of the GMP are to evaluate temporal changes in COC concentrations over time and to determine if groundwater plumes are decreasing in size and/or mass.
19 AECOM, 2017. Revised Groundwater Monitoring Program Modifications. North Campus, Chula Vista, California. June 21.

CAO No. R9-2021-0042 July 12, 2021
39 The GMP must be implemented pursuant to the sampling and analysis schedule presented in the 2017 Program or any subsequent groundwater monitoring program. Groundwater monitoring reports must be submitted to the San Diego Water Board for approval no later than 60 calendar days after conducting each groundwater monitoring and sampling event.

E. North
Campus Property Demolition. The Dischargers must submit a letter notifying the San Diego Water Board when all or some portion of the surface and subsurface structures at the North Campus Property will be demolished (e.g., existing buildings, concrete, and foundations). The letter must be submitted to the San Diego Water Board no later than 90 calendar days prior to the start date of the demolition and notification of completion of proposed demolition must be provided no later than 14 calendar days after completion.

F. Compliance Dates. The compliance dates for the requirements of this CAO are summarized in Table 13 below.

G. Modify or Suspend Soil, Soil Gas, and Groundwater Cleanup Activities.

The Dischargers may modify or suspend soil, soil gas, and groundwater cleanup activities only when authorized by the San Diego Water Board.

H. Penalty of Perjury Statement. All documents submitted to the San Diego Water Board must be signed by the Dischargers’ corporate officers or duly authorized representatives, and must include the following statement by the official, under penalty of perjury, that the report is true and correct to the best of the official’s knowledge.
“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations
.”
I. Document Submittals. Electronic Reporting Regulations require electronic submission of any report or data required by a regulatory agency from a cleanup site after July 1, 2005.
20 The electronic document submittals must
be uploaded on or prior to the regulatory compliance due dates set forth in this CAO or addenda thereto. To comply with these requirements, the Dischargers must upload documents and information to the GeoTracker database. The Dischargers must submit the required documents as follows:
20 Cal. Code Regs. title 23, chapter 30, division 3, and title 27, division 3.

CAO No. R9-2021-0042 July 12, 2021
40 1. GeoTr
acker. All information submitted to the San Diego Water Board in compliance with this CAO is required to be submitted electronically to the GeoTracker database21 under GeoTracker Global ID T10000001489 (North Campus) and T10000011095 (Parcel A). The Dischargers must upload the following minimum information to the GeoTracker database:
a. Reports. A complete copy of all work plans and assessment, monitoring, and cleanup reports, including the signed
transmittal letters, professional certifications, and all data presented in the reports in a text-searchable portable
document format (PDF), and converted to text-searchable format. Reports larger than 400 megabytes (MB) must be
divided into separate files at logical places in the report to keep the file sizes under 400 MB.
b. Site
Maps. A site map, as a stand-alone document, including
notes, legends, north arrow, and other data as appropriate to ensure that the site map is clear and understandable as a PDF file. When appropriate, the Dischargers should provide
required information on multiple site maps.
c. Laboratory Analytical Data. Analytical data, including geochemical data, for all soil, groundwater, soil gas, and indoor air samples in Electronic Data File (EDF) format. d. Locational Data. The latitude and longitude of all s ampling
locations for which data are reported in EDF.

Upon receipt of the required documents, the San Diego Water Board will use the upload date and time to determine compliance with the due dates specified in the CAO.

2. Othe
r Submittals. The San Diego Water Board may also request information or documents in hard copy and/or other appropriate media, including email.
a. Hard and Electronic Copies. If requested by the San Diego Water Board, the Dischargers must also provide the following to the Board: a hard copy of the complete document, a hard copy of the cover/transmittal letter, a hard copy of oversized drawings or maps, and an electronic copy of the complete document.
b. Email. If requested by the San Diego Water Board, the Dischargers must also submit a PDF copy of all documents including signed transmittal letters, professional certifications, 21 California State Water Resources Control Board - GeoTracker Data Management System CAO No. R9-2021-0042 July 12, 2021
41 and all data presented in the documents to
[email protected].

Upon receipt of the required documents, the San Diego Water Board will use the receipt date and time, and/or the email date and time to determine compliance with the due dates specified in the CAO.

J. Violation Reports. If the Dischargers violate any requirement of this CAO, or addenda thereto, they must notify the San Diego Water Board case manager by email as soon as practicable. The Board may, depending on violation severity, require the Dischargers to submit a separate technical report addressing the violation no later than five working days of the email not
ification.

K. Other Reports. The Dischargers must notify the San Diego Water Board in writing prior to any activities at the Dischargers’ facilities that have the potential to cause further migration of pollutants.

L. Provisions

1. Optional Document Submittals. The Dischargers may conduct parcel-specific investigations and may submit separate plans and reports for Parcels A, B-1, B-2, and C or combined documents (e.g., the soil FS and soil RAP) for consideration by the San Diego Water Board. Within 45 days of issuance of this CAO, the Dischargers must notify the Board in writing of their intent to submit separate or combined plans and reports, specifically identifying the parcels and phases for which separate or combined documents will be submitted and timelines for submittal, which shall be consistent with the deadlines set forth in this CAO.

2. Waste Management. The Dischargers must properly manage, store, treat, and dispose of contaminated media in accordance with applicable federal, s
tate, and local laws and regulations. The storage,
handling, treatment, or disposal of media associated with the assessment required by this CAO must not create conditions of nuisance as defined in Water Code section 13050, subsection (m).

3. C
ontract
or/Consultant Qualifications. The Dischargers must
ensure that all work plans and technical reports required under this CAO are prepared under the direction of appropriately qualified professionals. Reports submitted by the Dischargers must include a statement of qualifications and license numbers, if applicable, of the responsible lead professional and all professionals making significant and/or substantive contributions. The lead professional performing the engineering and geologic evaluations and judgments must sign and affix their professional geologist or civil engineer registration stamp to all work plans and technical reports submitted to the San Diego Water Board.

CAO No. R9-2021-0042 July 12, 2021
42 4. Laboratory
Qualifications. The Dischargers must ensure that all
soil and groundwater samples be analyzed by Environmental Laboratory Accreditation Program (ELAP)-certified laboratories using analytical methods approved by EPA for the type of analysis to be performed. ELAP only accredits for analytical test methods approved for regulatory purposes. If an analytical test method is not on the Field of Testing Sheet22, ELAP does not offer the method for accreditation.

The Dischargers must ensure that all soil vapor and air samples be analyzed by an appropriately certified laboratory.

5. Laboratory Analytical Reports. The Dischargers must ensure that any report presenting new analytical data include the complete laboratory analytical report(s). The laboratory analytical report(s) must be signed by the laboratory director and contain:
a. Complete sample analytical reports.
b. Complete laboratory quality assurance/quality control (QA/QC) reports.
c. A discussi
on of the sample and QA/QC data.
d. A transmittal letter that demonstrates the analytical work was supervised by the director of the laboratory and contains the following statement:
“All analyses were conducted at an Environmental Laboratory Accreditation Program-certified laboratory using methods approved by the U.S. Environmental Protection Agency.”

6. Analyt
ical Methods. The Dischargers must ensure that analytical methods used be identified in all technical and monitoring reports. If the Dischargers propose to use methods or test procedures other than those included in the most current version of EPA’s “Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-486” or Code of Federal Regulations, title 40, part 136, “Guidelines Establishing Test Procedures for the Analysis of Pollutants,” the methodology must be submitted for review and approved by the San Diego Water Board prior to use.

M. Notifications

1. Cost Recovery. Upon receipt of invoices, and in accordance with instruction therein, the Dischargers must reimburse the State Water 22 California State Water Resources Control Board - Environmental Laboratory Accreditation Program
CAO No. R9-2021-0042 July 12, 2021
43 Board for all reasonable costs incurred by the San Diego Water Board to investigate discharges of waste and to oversee cleanup of such waste, abatement of the effects thereof, or other remedial action, required by this
CAO and consistent with the annual
estimation of work.

2. Change of
Owner or Operator Reporting. The Dischargers must
notify the San Diego Water Board in writing of any changes in site occupancy or ownership associated with any portions of all the Property described in this CAO within 14 days of the change.

3. Appli
cable Permits and Permissions. The Dischargers must obtain all permits and access agreements needed to implement the requirements of this CAO. This CAO does not relieve the Dischargers of the responsibility to obtain permits or other entitlements to perform necessary assessment activities. This includes, but is not limited to, actions that are subject to local, s
tate, and/or federal discretionary
review and permitting.

4. Enfor
cement Discretion. The San Diego Water Board reserves its right to take any enforcement action authorized by law for violations of the terms and conditions of this
CAO.

5. Enforcement
Notification. Failure to comply with requirements of
this CAO may subject the Dischargers to enforcement action, including but not limited to administrative enforcement orders requiring the Dischargers to cease and desist from violations, imposition of administrative civil liability, pursuant to Water Code section 13268 in an amount not to exceed $1,000 for each day in which the violation occurs, or imposition of civil liability pursuant to Water Code section 13350 in an amount not to exceed $5,000 for each day in which the violation occurs, or referral to the State Attorney General for injunctive relief, and referral to the District Attorney for criminal prosecution. The Dischargers are jointly and severally liable for the entire amount of the administrative civil liability. The San Diego Water Board reserves the right to seek administrative civil liability from any or all the Dischargers.

6. Requesti
ng Administrative Review by the State Water Board.

Any person affected by this action of the San Diego Water Board may petition the State Water Board to review the action in accordance with Water Code section 13320 and Cal. Code Regs., title 23, section 2050. The State Water Board (Office of Chief Counsel, P.O. Box 100, Sacramento, California 95812) must receive the petition within 30 calendar days of the date of th
is CAO. Copies
of the laws and regulations applicable to filing petitions will be provided upon request.

CAO No. R9-2021-0042 July 12, 2021
44 Ordered by:
_____ ____________________ ________ ______________
DAVID W. GIBSON Date
Executive Officer
David W.

Gibson
Digitally signed by
David W. Gibson
Date: 2021.07.12
14:58:46 -07'00'
Water Boards
CAO No. R9-2021-0042 July 12, 2021
45 Table 13. Summary of Compliance Dates
Directive Requirement Due Date
B.1.a Parcel H-3 Remedial Action
Plan Progress Reports
Submit no later than 30
calendar days following the
close of each month.

Submit first RAP Progress
Report after the first full month
of RAP implementation.

B.1.b Parcel H-3 Groundwater
Cleanup Levels Report
Submit (1) after 1 year of
Groundwater RAP monitoring
and data collection, and (2) no
later than 60 calendar days
after the San Diego Water
Board has approved the report
for the last Groundwater RAP
monitoring and sampling event
in the 1-year period.

B.1.c
Parcel H-3 Cleanup and
Abatement Completion
Report
Submit no later than 90
calendar days after the San
Diego Water Board has
approved the Parcel H-3 RAP
Progress Report for the last
Groundwater RAP monitoring
and data collection event.

C.1 Updated Conceptual Site
Model Report
Submit no later than 60
calendar days after the date of
this CAO.

C.2.a Site Data Gap Investigation
Work Plan
Submit no later than 120
calendar days after the date of
this CAO.

C.2.b Site Data Gap Investigation
Report
Submit no later than 90
calendar days after the last
scheduled activity in the work
plan is completed.

C.3 Site Human Health Risk
Assessment
Submit no later than 90
calendar days after the San
Diego Water Board has
approved the Site Data Gap
Investigation Report.

C.4.a Site Soil Cleanup Levels
Report
Submit no later than 90
calendar days after the Board
has approved the Site HHRA.

C.4.b Site Soil and Soil Gas
Remedial Alternatives Report
Submit no later than 90
calendar days after the San
Diego Water Board has
CAO No. R9-2021-0042 July 9, 2021
46 Directive Requirement Due Date
approved the Site Soil Cleanup
Levels Report.

C.5.a Site Soil and Soil Gas
Remedial Action Plan
Submit no later than 90
calendar days after the San
Diego Water Board has
approved the Site Soil and Soil
Gas Remedial Alternatives
Report.

C.5.b
Site Soil and Soil Gas
Remedial Action Plan
Implementation
Implement no later than 60
calendar days after the San
Diego Water Board has
approved the Soil RAP.

Submit notification letter of the
Dischargers’ intent to
implement the Soil RAP no
later than 14 calendar days
prior to implementation of the
Soil RAP.

C.5.c
Site Soil and Soil Gas
Remedial Action Plan
Progress Reports
Submit no later than 30
calendar days following the
close of each quarter.

Submit first progress report
after the first full quarter of Site
Soil and Soil Gas RAP
implementation.

C.5.d
Site Soil and Soil Gas
Remedial Action Plan
Completion Report
Submit no later than 90
calendar days after the San
Diego Water Board has
approved the Soil RAP
Progress Report for the last
scheduled activity in the Soil
RAP.

C.6.a
Site Groundwater and Soil
Gas Remedial Alternatives
Report
Submit no later than 90
calendar days after the San
Diego Water Board has
approved the Site Soil and Soil
Gas Remedial Action Plan
Completion Report.

C.6.b Site Groundwater Cleanup
Levels Report
Submit (1) after 6 months of
Groundwater RAP monitoring
and data collection, and (2) no
later than 60 calendar days
after the San Diego Water
Board has approved the report
CAO No. R9-2021-0042 July 12, 2021
47 Directive Requirement Due Date
for the last Groundwater RAP
monitoring and sampling event
in the 6-month period.

C.7.b Site Groundwater and Soil
Gas Remedial Action Plan
Submit no later than 90
calendar days after the San
Diego Water Board has
approved the Site Groundwater
and Soil Gas Feasibility Study.

C.7.c
Site Groundwater and Soil
Gas Remedial Action Plan
Implementation
Implement no later than 60
calendar days after the San
Diego Water Board has
approved the Groundwater
RAP.

Submit notification letter of the
Dischargers’ intent to
implement the Groundwater
RAP no later than 14 calendar
days prior to implementation of
the Groundwater RAP.

C.7.d
Site Groundwater and Soil
Gas Remedial Action Plan
Progress Reports
Submit no later than 30
calendar days following the
close of each quarter.

Submit first progress report
after the first full quarter of
Groundwater RAP
implementation.

C.7.e
Site Groundwater and Soil
Gas Remedial Action Plan
Completion Report
Submit approval no later than
90 calendar days after the San
Diego Water Board has
approved the Soil RAP
Progress Report for the last
scheduled activity in the
Groundwater RAP
D Groundwater Monitoring
Reports
Submit no later than 60
calendar days after conducting
each groundwater monitoring
and sampling event.

E North Campus Property
Demolition Notification
Submit a notification letter no
later than 90 calendar days
prior to the start date of the
demolition.

Submit a notification letter no
later than 14 calendar days
CAO No. R9-2021-0042 July 12, 2021
48 Directive Requirement Due Date
after completion of the
proposed demolition.

L.1 Optional Document Submittal
Notification
Submit a notification letter no
later than 45 calendar days
prior to the intent to submit
separate or combined plans
and reports, specifically
identifying the parcels and
phases for which separate or
combined documents will be
submitted and timelines for
submittal, which shall be
consistent with the deadlines
set forth in this CAO.

San Diego Bay

NORTH CAMPUS

PROPERTY

G STREET

H STREET

SANDPIPER WAY

BAYSIDE WAY

LAGOON DRIVE

QUAY AVENUE

BAY BOULEVARD

MARINA PARKWAY
§¨¦
5 Chula Vista Marina
NOTES
1 . A L L L O C A T I O N S A N D D I M E N S I O N S A R E A P P R O X I M A T E 2 . A E R I A L I M A G E R Y S O U R C E : S A N D I E G O C O U N T Y , 2 0 1 7 R O H R , I N C . A C O L L I N S A E R O S P A C E C O M P A N Y , C L E A N U P A N D A B A T E M E N T O R D E R N O . R 9 - 2 0 2 0 - 0 0 9 9 C H U L A V I S T A , C A L I F O R N I A S I T E P L A N
F I G U R E 1
S C A L E : A S S H O WN
M A R C H 2 0 2 1
LEGEND
S I T E B O U N D A R Y
G I S F I L E P A T H : \ \ h a l e y a l d r i c h . c om \ sh a r e \ sd g _ c om m on\ 1 2 7 8 2 7 _ N or t h C a m pus\ G l ob a l \ G I S \ M a ps\ 2 0 2 1 _ 0 3 _ C A O \ 1 2 7 8 2 7 _ 0 1 9 _ 0 0 0 1 _ S I T E _ P L A N . m x d U S E R : d fm L A S T S A V E D : 8 / 7 / 2 0 2 0 1 2 : 0 7 : 1 5 P M 0 4 0 0 8 0 0
S C A L E I N F E E T
DRAFT

G STREET

H STREET

LAGOON DRIVE

BAY BOULEVARD

MARINA PARKWAY
§¨¦
5 B2
A
C
C
B1
99 100
29 1
54 22
50 1
61 79
78 107
115
114
112 118
113
55 NOTES
1 . A L L L O C A T I O N S A N D D I M E N S I O N S A R E A P P R O X I M A T E 2 . A E R I A L I M A G E R Y S O U R C E : S A N D I E G O C O U N T Y , 2 0 1 7 R O H R , I N C . A C O L L I N S A E R O S P A C E C O M P A N Y , C L E A N U P A N D A B A T E M E N T O R D E R N O . R 9 - 2 0 2 0 - 0 0 9 9 C H U L A V I S T A , C A L I F O R N I A O N - P R O P E R T Y A R E A S
F I G U R E 2
S C A L E : A S S H O WN
M A R C H 2 0 2 1
LEGEND
P A R C E L B O U N D A R Y
G I S F I L E P A T H : \ \ ha l e y a l d r i c h. c om \ sha r e \ sd g _ c om m on\ 1 2 7 8 2 7 _ N or t h C a m pu s\ G l ob a l \ G I S \ M a ps\ 2 0 2 1 _ 0 3 _ C A O \ 1 2 7 8 2 7 _ 0 1 9 _ 0 0 0 2 _ O N _ P R O P E R T Y _ A R E A S . m x d U S E R : d fm L A S T S A V E D : 3 / 1 6 / 2 0 2 1 4 : 2 4 : 1 8 P M 0 2 5 0 5 0 0
S C A L E I N F E E T
B1
29 P A R C E L D E S I G N A T I O N B U I L D I N G N U M B E R

SANDPIPER WAY
--------__ ........... ---
I
, ]r,
I'
NORTH

CAMPUS PROPERTY

G STREET

H STREET

SANDPIPER WAY

BAYSIDE WAY

LAGOON DRIVE

QUAY AVENUE

BAY BOULEVARD

MARINA PARKWAY
§¨¦
5 Chula Vista Marina

FORMER SOUTH

CAMPUS PROPERTY

RAILROAD RIGHT OF WAY
F & G

STREET MARSH
H-3 PARCEL
SDG&E

SUB STATION
San Diego Bay FUTURE PARK

DEVELOPMENT
NOTES
1 . A L L L O C A T I O N S A N D D I M E N S I O N S A R E A P P R O X I M A T E 2 . A E R I A L I M A G E R Y S O U R C E : S A N D I E G O C O U N T Y , 2 0 1 7 R O H R , I N C . A C O L L I N S A E R O S P A C E C O M P A N Y , C L E A N U P A N D A B A T E M E N T O R D E R N O . R 9 - 2 0 2 0 - 0 0 9 9 C H U L A V I S T A , C A L I F O R N I A O F F - P R O P E R T Y A R E A S
F I G U R E 3
S C A L E : A S S H O WN
M A R C H 2 0 2 1
LEGEND
S I T E B O U N D A R Y
H - 3 M A S T E R P L A N A P P R O X I M A T E B O U N D A R Y F U T U R E P A R K D E V E L O P M E N T G I S F I L E P A T H : \ \ ha l e y a l d r i c h. c om \ sha r e \ sd g_ c om m on\ 1 2 7 8 2 7 _ N or th C a m pu s\ G l ob a l \ G I S \ M a ps\ 2 0 2 1 _ 0 3 _ C A O \ 1 2 7 8 2 7 _ 0 1 9 _ 0 0 0 3 _ O F F _ P R O P E R T Y _ A R E A S . m x d U S E R : d fm L A S T S A V E D : 3 / 1 6 / 2 0 2 1 4 : 3 5 : 4 9 P M 0 4 0 0 8 0 0
S C A L E I N F E E T
DRAFT
#I #I #I #I
#I#I#I#I
#I
#I
#I#I#I

IMC FUEL

OIL AST
(1918-1954)

TRANSFORMER
(1918-1926)

DEBRIS PILES
(1945-1959)

SLUDGE PONDS
(1944-1959)

DIESEL UST

TCE/TCA
AST
R-LINE

PROCESS
LINES
C/D
-LINE

E/F-LINE

MACHINE
SHOP
AUTO
SHOP

DRAINAGE
DITCH
(1962-1968)

N/C SUMP
TYCE

BUILDINGS
(1959)

WASTEWATER

TREATMENT

PLANT (WWTP)

CHEMICAL

SERVICES EQUIPMENT

MAINTENANCE
AREA
OILER
SHED

CHULA VISTA

SEWAGE TREATMENT
PLANT (1945-1966)

CHULA VISTA

SEWAGEPUMP

STATION

CHEMICAL BATHS
<1974
SDG&E

MONTGOMERY

SUBSTATION
SALT
BATH C70

MAINTENANCE

DEPARTMENT

AES MACHINE
SHOPS (1926)

PIONEER

PYROPHYLITE/
R&H TYCE (1926)

MAINTENANCE
(1966)
BLDG 47

PAINT BOOTH
(1966)

FOUNDRY

STORAGE TANK
(1970)
V-1 DEGREASER
(NOT A PART)

WESTERN
FORMER

SLUDGE PONDS
(1965-1966)

F&G STREET MARSH
V-2 GREASER
V-3 GREASER
N. OILER

SHED UST
FORMER
FUEL
USTs

PRE-ROHR

CHULA VISTA

FORMER TRUCK

ENGINE REPAIR

DRAINAGE SWALE

HISTORICAL

PROCESS
LINE

H STREET SOIL

REMEDIATION
FORMER

FORMER RAILROAD SPUR
!
!
!
l

F U T U R E P A R K D E V E L O P M E N T
RADOS
798 F ST

THERMO KING
340 BAY

JACKSON'S

IMPORT AUTO
350-360 BAY

SAN DIEGO PUMPS
& COMPRESSOR
SUPPLY
368 BAY
§¨¦5
FORMER

LUMBER YARD
(1948)
FORMER

AGRICULTURE - CITRUS
(1948)
FORMER

AGRICULTURE - CITRUS
(1948)

H I J K
G
F
E
D
CB
A
208208
207207
206206
213213
212212
218218
217217
216216
220220
225225
204204
200200
209209
210210 214214
228228
228228
228228
228228
124124
125125
126126
229229
117117
227227
144144
226226
202202201201
219219
215215
219219
219219
219219
219219
205205
205205
203203
303303
303303
304304
304304
304304
304304
106106
106106
106106
106106
103103
108108107107
119119
109109
104104 105105
164164
163163
162162
161161
3-078243-07824
3-095963-09596
148148
147147
146146
145145
161161
302302
170170
171171
230230
231231
3-099783-09978
3-138883-13888
5(5-N/C)5(5-N/C)
6B6B 6A6A
55 1313 22
3-156163-15616
3-156153-15615
3-156173-15617116116
115115
150150
165165
224224
169169
172172
301301
300300
1414
102102
311
443
11 (1943-2000)
56 (1943-2000)
57 (1943-2000)
22 50
1 1
117
55 54
116
119
1 107
115 112
118
113
78 79
61 100
99 29
CAPPED

OCP-CONTAINING
SOIL
C A
B1
C
B2
PARCEL H3

G STREET

F STREET

H STREET

QUAY AVENUE
APN# 56702233
APN# 56701007
APN# 56702217
APN# 56702228
APN# 57133030
APN# 57133027
APN# 57133028
APN# 57133024
APN# 56702230
APN# 56702231
APN# 57133016
APN# 57133003
APN# 56702236
APN# 56702216
APN# 56702235
APN# 57133029
APN# 57133029
APN# 56702201
APN# 56702133
APN# 56702135
APN# 56702132
APN# 56702132

BAY BOULEVARD

BAYSIDE PARKWAY

MARINA PARKWAY
OUTFALL 1
OUTFALL 2

OUTFALL
2-WC-14

WESTERN DRAINAGE SWALE

SAN DIEGO & ARIZONA EASTERN RAIL ROAD WESTERN DRAINAGE SWALE

SAN DIEGO & ARIZONA EASTERN RAIL ROAD
G I S F I L E P A TH : \\h a l ey a l dr i ch . co m \s h a r e\s dg_ co m m o n\1 2 7 8 2 7 _ N o r t h C a m p u s \G l o b a l \G I S \M a p s \2 0 2 1 _ 0 3 _ C A O \1 2 7 8 2 7 _ 0 1 9 _ 0 0 0 4 _ H I S TO R I C A L _ E N V I R O N M E N TA L _ F E A TU R E S . m x d U S E R : df m L A S T S A V E D : 3 / 1 1 / 2 0 2 1 4 : 4 8 : 1 1 P M R O H R , I N C . A C O L L I N S A E R O S P A C E C O M P A N Y , C L E A N U P A N D A B A TE M E N T O R D E R N O . R 9 - 2 0 2 0 - 0 0 9 9 C H U L A V I S TA , C A L I F O R N I A H I S TO R I C A L
E N V I R O N M E N TA L F E A TU R E S F I G U R E 4
S C A L E : A S S H O W N
M A R C H 2 0 2 1
0 1 2 0 2 4 0 3 6 0 4 8 0
S C A L E I N F E E T
LEGEND
A P P R O X I M A TE L O C A TI O N S O F F O R M E R O U TF A L L S B Y Y E A R ( S O U R C E : A D R I A N B R O W N , 1 9 9 8 ) #I 1 9 4 0 s
#I
1 9 6 0 s
H I S TO R I C A L S H O R E L I N E , B Y Y E A R H I S TO R I C A L S H O R E L I N E , 1 9 4 4 H I S TO R I C A L S H O R E L I N E , 1 9 6 0 S D G & E 1 0 " F U E L L I N E ( A B A N D O N E D I N - P L A C E ) S TO R M W A TE R C O N V E Y A N C E S Y S TE M C U R R E N T
F O R M E R ( P R E - 1 9 9 8 )
F O R M E R V E S S E L S A N D V A U L TS U S T ( U N D E R G R O U N D S TO R A G E TA N K ) U V ( U N D E R G R O U N D V E S S E L ) A S T ( A B O V E G R O U N D S TO R A G E TA N K ) P A I N T B O O TH
D E G R E A S E R
V A U L T L O C A TI O N
F O R M E R M I L L S / L A TH E S
F O R M E R E X C A V A TI O N A R E A D E B R I S P I L E S
S L U D G E P O N D S
A S S E S S O R ' S P A R C E L B O U N D A R Y A N D N U M B E R F O R M E R S E W A G E TR E A TM E N T P L A N T O U TF A L L F U TU R E P A R K D E V E L O P M E N T P A R C E L H 3
F O R M E R B U I L D I N G F O O TP R I N T ! ! ! ! ! ! !
! ! ! ! ! ! !
! ! ! ! ! ! !
F O R M E R S H A L L O W S W A L E ( 1 9 4 8 ) F O R M E R " L U M B E R Y A R D " ( 1 9 4 8 ) F O R M E R " A G R I C U L TU R E - C I TR U S " ( 1 9 4 8 ) S I TE B O U N D A R Y
NOTES:
1 . A L L L O C A TI O N S A N D D I M E N S I O N S A R E A P P R O X I M A TE . 2 . S E E P A R C E L H - 3 C S M F O R H I S TO R I C A L E N V I R O N M E N TA L F E A TU R E S O N TH I S P A R C E L 3 . A E R I A L I M A G E R Y S O U R C E : S A N D I E G O C O U N TY , 2 0 1 7 APN# 56702236
118 B U I L D I N G N U M B E R ( G R A Y E D F O R F O R M E R ) ! ! ! ! ! ! ! !
!
!
!
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I D
r
[I I I I L
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I
I
I
I
I
t i
I
I
D
11 I
I
I
I
r(1'f
I)~,)_,
--====r --.
• 1r~
'
'
r n
' \
I \
I
\
\
\
\
' ' ' ' ' ' ' .................
r
' . .
l
....,,.
'·- rr rr
n
• I
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f"'l'
------------------------------ , • .... ►
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• 'RSfri:
l'?,:f f:j,
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~3 •.w:-~ 'iiH 'g'g_ 18-ID~
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11178'
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7-·. - .. - .. - .. - . -- .. - ·-- -. - . ·-. ·-. --·. - .. - .. - .. - .. - .. - ··- ··- ·-- I !
•
c
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r-----
1 I ____ _
r-----
1 I ____ _
c=

CJ CJ CJ
I_ ____ _.I
,---- .. I I
• ____ J ,---- ..

I I , ____ ..!
CJ

MONITORING
WELL

WASTE WATER

TREATMENT
PLANT

UTILITY CONDUITS /

CORRIDORS
(BELOW WATER TABLE)
FORMER

SHORELINE
F & G
STREET
MARSH
PIPE

BACKFILL
SAN

SEAWATERFRESHWATER
BAY
DIEGO

DREDGED FILL

BAYPOINT FORMATION

BAY DEPOSITS
USTs / SUMPS
/ VAULTS
PAINT

BOOTHSCURRENT

AND FORMER

PROCESS
LINES
FORMER
FLOOR
DRAINS

CURRENT STORM

DRAIN OUTFALL

STORM DRAIN

SURFACE

WATER RUNOFF

INFILTRATION
/ LEACHING
CAPPED

AGRICULTURAL
SOIL

ACCIDENTAL SPILLS /

LEAKS / DISCHARGES

FUGITIVE DUST

EROSION
VAPOR

DEGREASERS

CHULA VISTA

RV RESORT

FORMER ROHR

LEASED BUILDINGS

MARINE GROUP

BOAT WORKS

HISTORIC OUTFALL

UNDOCUMENTED
FILL

BAYFRONT
PARK
AST

SILTS / CLAYS

BACK DIFFUSION

STORM DRAIN

OUTFALL

DEGREASER
ROHR, INC., A COLLINS AEROSPACE COMPANY
CLEANUP AND ABATEMENT ORDER R9-2020-099

CHULA VISTA, CALIFORNIA
FIGURE 5

CONCEPTUAL SITE MODEL
J:\GRAPHICS\127827\127827-007 CSM NORTH CAMPUS 2020-0821.DWG MCELENEY, TERRICSM-NORTHCAMPUS 8/21/2020 2:56 PM Layout:Printed:

MARCH 2021
<:'.,,,,,,,,,. ..................
- -- --- c,->--'-,,..=------- __ .. ...... .....,.,,,,,..,,,,,. <..
\_

Chula Vista City CouncilNovember 18, 2025

Chula Vista City Council
November 18, 2025