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Home My WebLink AboutPRR24176 Clifton Responsive Emails1 From:Scott McAlpin <smcalpin@trihydro.com> Sent:Thursday, June 13, 2024 12:51 PM To:Fortner, Kellie Cc:Mailloux, Michael; Beacom, James; Teague, Nick Subject:RE: RENEW: 2024-2025 City of SLO Construction Water Permit Attachments:ConstructionWaterPermit_v2024-25.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hi Kellie, The renewal application is attached for 276 Tank Farm Road. Please contact me for questions or invoicing. Thank you, ScoƩ McAlpin, PG Lead Project Geologist 142 Cross Street, Suite 200 San Luis Obispo, CA 93401 (989) 506-1105 (mobile) (307) 745-7474 (office) smcalpin@trihydro.com www.trihydro.com Sign up to receive industry updates in your inbox. CONFIDENTIAL INFORMATION: This electronic message is intended only for the use of the person or enƟty to which it is addressed and may contain informaƟon that is privileged and confidenƟal, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby noƟfied that any disseminaƟon, distribuƟon or copying of this informaƟon is STRICTLY PROHIBITED. If you have received this message in error, please immediately noƟfy the sender by either email or telephone. Please destroy the related message. Thank you for your cooperaƟon. From: Fortner, Kellie <kfortner@slocity.org> Sent: Tuesday, June 4, 2024 11:58 AM Cc: Teague, Nick <nteague@slocity.org> Subject: [**EXTERNAL**] RENEW: 2024-2025 City of SLO Construction Water Permit Be aware this external email contains an attachment and/or link. Ensure the email and contents are expected. If there are concerns, please submit suspicious messages to the Cyber Intelligence Center using the Report Phishing button. Current City of SLO Construction Water Permit Holders: 2 You are receiving this email because you currently hold an active Construction Water Permit that expires on June 30, 2024. If your project will continue to need recycled water past this date or if you have future projects within the City of San Luis Obispo, you will need to submit a new Construction Water Permit application attached to this email. Your application will be reviewed, and you will be instructed to submit $1260 payment to our Finance Department. All permits are valid July 1-June 30. Please note, any new water haulers added to a permit will require an inspection for the following prior to permit issuance: - Air gap separation OR backflow device - Non-potable or “do not drink” signage adhered to tank or truck - Hydrant wrench on hand Once all permit requirements are satisfied, new 24-25 vehicle tags will be issued along with the signed permit to be kept in each water hauler when in use. If you do not intend to apply for a new permit, please respond to this email. Thank you, Kellie Fortner Recycled Water Specialist Public Utilities 879 Morro, San Luis Obispo, CA 93401-2710 E kfortner@slocity.org T 805.783.7860 slocity.org Stay connected with the City by signing up for e-notifications 2024-25 RECYCLED WATER CONSTRUCTION WATER PERMIT This Construction Water Permit must be available for inspection. A copy must be retained in the transport vehicle. 2024-25 Fees: $ 1,260 Permit Valid July 1, 2023 through June 30, 2024 Annual Permit # Fees Paid: Approval: CUSTOMER INFORMATION Business Name Address Phone Number E-mail VEHICLE DESCRIPTION Make Model License # Type: Tank Truck, Trailer, or Other CONSTRUCTION SUPERVISOR Name Address Phone Number Email SITE/USE LOCATION Site/Location of project(s) CERTIFICATION I HEREBY CERTIFY UNDER PENALTY OF PERJURY THAT THE INFORMATION PROVIDED ON THIS APPLICATION AND IN ANY ATTACHMENT IS TRUE AND ACCURATE. I ALSO CERTIFY THAT I HAVE READ AND AGREE TO ABIDE BY ALL APPLICABLE PROCEDURES FOR USE OF RECYCLED WATER IN THE CITY. Signature of Water Customer Title Date Union Oil Company of California (Chevron Environmental Management Company (925) 842-2982 P.O. Box 1332, San Luis Obispo, CA 93406 James.Beacom@chevron.com Caterpiller Freightliner 660 34502Z2 MI BCI5632 Tank Truck Tank Truck Jorge Calvo c/o Entact, LLC. 865 Aerovista, Suite 230, San Luis Obispo, CA 93401 (713) 562-6810 jcalvo@entact.com 276 Tank Farm Road, San Luis Obispo, CA 93401 Pre-Execution Specialist 6/13/2024 1 From:Christian, Kevin Sent:Thursday, December 15, 2022 12:50 PM To:Stowe, Lala; Cohen, Rachel Cc:Curry, Krista; Codron, Michael; CityClerk Subject:Request to be placed on Advance Notice List regarding CEQA: PRR22294 Tsai - 276 Tank Farm Rd Attachments:PRR22294 Tsai - 276 Tank Farm Rd.pdf CDD, I meant to point out previously that part of the attached records request also asks to be placed on our advance notice list for “any and all notices issued under the CEQA and the Planning and Zoning Law.” This is contained on pages 5 – 7 of the request. Please add them to your list if they are not already there. My reading is that they not only desire advance notice for the 276 Tank Farm Rd. project but also any notices issued for CEQA. Kevin Christian Deputy City Clerk City Administration City Clerk's Office 990 Palm Street, San Luis Obispo, CA 93401-3218 E kchristi@slocity.org T 805.781.7104 slocity.org Stay connected with the City by signing up for e-notifications Ph: (626) 381-9248 Fx: (626) 389-5414 Em: info@mitchtsailaw.com Mitchell M. Tsai Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 VIA E-MAIL November 18, 2022 Teresa Purrington, City Clerk City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 Em: tpurrington@slocity.org RE: Public Records Act and Advance Notice List Request Regarding the 276 Tank Farm Road Project Dear City Clerk, On behalf of Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”) and its members, this Office requests that the City of San Luis Obispo City”) provide any and all information referring or related to the 276 Tank Farm Road Project (“Project”) pursuant to the California Public Records Act (“PRA”), Cal. Government (“Gov’t”) Code §§ 6250–6270 (collectively “PRA Request”). Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. The Southwest Regional Council of Carpenters is a labor union representing more than 50,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning and addressing the environmental impacts of development projects, such as the Project. I. PUBLIC RECORDS ACT REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 2 of 7 Southwest Carpenters is requesting any and all information referring or related to the Project. The Public Records Act defines the term “public record” broadly as “any writing containing information relating to the conduct of the public’s business . . . regardless of physical form and characteristics.” Gov’t Code § 6252(d). “Records” includes all communications relating to public business regardless of physical form or characteristics, including but not limited to any writing, picture, sound, or symbol, whether paper, magnetic, electronic, text, other media, or written verification of any oral communication. Included in this request are any references in any appointment calendars and applications, phone records, or text records. These “records” are to include, but are not limited to correspondences, e-mails, reports, letters, memorandums, and communications by any employee or elected official of the City concerning the Project. Please include in your response to this request the following examples of “records,” as well as any similar physical or electronic forms of communication: any form of writing such as correspondence, electronic mail records (“email”), legal and factual memoranda, facsimiles, photographs, maps, videotapes, film, data, reports, notes, audiotapes, or drawings. Cal. Government Code § 6252(g) (defining a writing to including “any record thereby created, regardless of the manner in which the record has been stored”). Responsive correspondence should include, inter alia, emails, text messages, or any other form of communication regardless of whether they were sent or received on public or privately-owned electronic devices “relating to the conduct of the public’s business.” Cal. Government Code § 6252(e); Citizens for Ceres v. Super. Ct. Ceres”) (2013) 217 Cal. App. 4th 889, 909; Citizens for Open Gov’t v. City of Lodi Lodi”) (2012) 205 Cal.App.4th 296, 307, 311; City of San Jose v. Superior Court (2017) 2 Cal. 5th 608, 625 (finding that a public employee or officer’s “writings about public business are not excluded” from the California Public Records Act “simply because they have been sent, received, or stored in a personal account.”) . This Office requests any and all information referring or related to the Project, including but not limited to: 1) All Project application materials; 2) All staff reports and related documents prepared by the City with City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 3 of 7 respect to its compliance with the substantive and procedural requirements of the California Environmental Quality Act, Public Resources Code § 21000 et seq., and the CEQA Guidelines, title 14, California Code of Regulations, § 15000 et seq. (collectively CEQA”) and with respect to the action on the Project; 3) All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the agency pursuant to CEQA; 4) Any transcript or minutes of the proceedings at which the decisionmaking body of the City heard testimony on, or considered any environmental document on, the Project, and any transcript or minutes of proceedings before any advisory body to the public agency that were presented to the decisionmaking body prior to action on the environmental documents or on the Project; 5) All notices issued by the City to comply with CEQA or with any other law governing the processing and approval of the Project; 6) All written comments received in response to, or in connection with, environmental documents prepared for the Project, including responses to the notice of preparation; 7) All written evidence or correspondence submitted to, or transferred from, the City with respect to compliance with CEQA or with respect to the Project; 8) Any proposed decisions or findings submitted to the decisionmaking body of the City by its staff, or the Project proponent, Project opponents, or other persons; 9) The documentation of the final City decision and approvals, including the final environmental impact report, mitigated negative declaration, negative declaration, or notice of exemption, and all documents, in addition to those referenced in paragraph (3), cited or relied on in the findings or in a statement of overriding City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 4 of 7 considerations adopted pursuant to CEQA; 10) Any other written materials relevant to the public agency's compliance with CEQA or to its decision on the merits of the Project, including the initial study, any drafts of any environmental document, or portions thereof, that have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the Project and either made available to the public during the public review period or included in the City 's files on the Project, and all internal agency communications, including staff notes and memoranda related to the Project or to compliance with CEQA; and 11) The full written record before any inferior administrative decisionmaking body whose decision was appealed to a superior administrative decisionmaking body prior to the filing of any litigation. Please respond within 10 days from the date you receive this request as to whether this request specifies identifiable records not exempt from disclosure under the PRA or otherwise privileged or confidential, and are therefore subject to disclosure. This Office understands that this time may be extended up to 14 days for unusual circumstances as provided by Cal. Government Code § 6253(c), and that we will be notified of any extension and the reasons justifying it. We request that you provide all documents in electronic format and waive any and all fees associated with this Request. SWRCC is a community-based organization. Please notify and obtain express approval from this Office before incurring any duplication costs. If any of the above requested documents are available online, please provide us with the URL web address at which the documents may be downloaded. If any of the requested documents are retained by the City in electronic computer-readable format such as PDF (portable document format), please provide us with pdf copies of the documents via email, or inform us of the location at which we can copy these documents electronically. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 5 of 7 In preparing your response, please bear in mind that you have an obligation under Government Code section 6253.1 to (1) identify all records and information responsive to our request or the purpose of our request; (2) describe the information technology and physical location in which the records exist; and (3) provide suggestions for overcoming any practical basis for denying access to the records or information sought. In responding to this request, please bear in mind that any exemptions from disclosure you may believe to be applicable are to be narrowly construed. Marken v. Santa Monica- Malibu Unif. Sch. Dist. (2012) 202 Cal. App. 4th 1250,1262; and may be further narrowed or eliminated by the adoption of Proposition 59, which amended article I, section 3(b)(2) of the California Constitution to direct that any “statute ... or other authority ... [that] limits the right of access” to “information concerning the conduct of the people’s business” must be “narrowly construed.” As for any records that you nonetheless decline to produce on the grounds of an exemption, please bear in mind that the case law under the Public Records Act imposes a duty on you to distinguish between the exempt and the non-exempt portion of any such records, and to attempt in good faith to redact the exempt portion and to disclose the balance of such documents. Please bear in mind further that should you choose to withhold any document from disclosure, you have a duty under Government Code section 6255, subd. (a) to “justify withholding any record by demonstrating that the record in question is exempt under express provisions” of the Public Records Act or that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” Finally, please note that you must retain and not destroy any and all records, notwithstanding any local record retention or document destruction policies. As the Court noted in Golden Door Properties, LLC v. Superior Court of San Diego County (2020) 53 Cal.App.5th 733 that a public agency “must retain ‘[a]ll written evidence or correspondence submitted to, or transferred from’ . . . with respect to” CEQA compliance or “with respect to the project.” II. ADVANCE NOTICE LIST REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 6 of 7 We also ask that you put this Office on its notice list for any and all notices issued under the CEQA and the Planning and Zoning Law. In particular, we request that the City send by mail or electronic mail notice of any and all actions or hearings related to activities undertaken, authorized, approved, permitted, licensed, or certified by the City and any of its subdivision for the Project, or supported, in whole or in part, through permits, contracts, grants, subsidies, loans, or other forms of approvals, actions or assistance, including but not limited to the following: Notices of any public hearing held in connection with the Project; as well as Any and all notices prepared pursuant to CEQA, including but not limited to: Notices of determination that an Environmental Impact Report EIR”) or supplemental EIR is required for a project, prepared pursuant to Public Resources Code Section 21080.4; Notices of availability of an EIR or a negative declaration for a project prepared pursuant to Public Resources Code Section 21152 and Section 15087 of Title 14 of the California Code of Regulations; Notices of approval or determination to carry out a project, prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of approval or certification of any EIR or negative declaration prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of exemption from CEQA prepared pursuant to Public Resources Code section 21152 or any other provision of law; and Notice of any Final EIR prepared pursuant to CEQA. This Office is requesting notices of any approvals or public hearings under CEQA and the California Planning and Zoning Law. This request is filed pursuant to California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 7 of 7 65092 requiring agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Please send notice by regular and electronic mail to: Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 Em: maria@mitchtsailaw.com Em: mitch@mitchtsailaw.com Em: reza@mitchsailaw.com Em: info@mitchtsailaw.com We look forward to working with you. If you have any questions or concerns, please do not hesitate to contact our Office. Sincerely, Mitchell M. Tsai Attorneys for Southwest Regional Council of Carpenters 1 From:Bryan Hulburd <bhulburd@covelop.net> Sent:Wednesday, August 23, 2023 4:38 PM To:'Soderberg, Sheila@Waterboards'; Johnson, Derek; Floyd, Aaron; vheger@meyersnave.com; Lindgren, Adam; Schwartz, Luke; 'Damien Mavis'; 'David Dixon'; 'Ranta, Owen'; 'Tulledge, Kim'; Stong, Nate; Kersten, Markie Cc:'Tryon, Thea@Waterboards'; 'Bishop, Greg@Waterboards'; 'Schroeter, Angela@Waterboards'; 'Niles, Dan@Waterboards'; 'Froelich, Sophie@Waterboards'; 'Lodge, Ryan@Waterboards'; 'Keeling, Matt@Waterboards' Subject:RE: Proposed City of San Luis Obispo Roundabout Attachments:Roundabout Risk Mitigation Plan_8-23-23.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hi Sheila – AƩached is the Risk MiƟgaƟon Plan (“Soil Management Plan”). If we cannot make the 8/31 date work (we were OK with Thea aƩending the meeƟng 30 mins late), then I will confirm with you by tomorrow if the 9/11 date works. In the meanƟme, could you please propose addiƟonal dates and Ɵmes that work for the Water Board team aŌer 9/11? Thank you for your assistance in coordinaƟng. Best, Bryan Bryan Hulburd Project Manager bhulburd@covelop.net From: Soderberg, Sheila@Waterboards <Sheila.Soderberg@waterboards.ca.gov> Sent: Wednesday, August 23, 2023 3:17 PM To: Bryan Hulburd <bhulburd@covelop.net>; djohnson@slocity.org; 'Floyd, Aaron' <afloyd@slocity.org>; vheger@meyersnave.com; adam@meyersnave.com; 'Schwartz, Luke' <LSchwart@slocity.org>; 'Damien Mavis' <dmavis@covelop.net>; 'David Dixon' <ddixon@rouxinc.com>; 'Ranta, Owen' <owenranta@chevron.com>; 'Tulledge, Kim' <Kim.Tulledge@chevron.com>; Stong, Nate <nstong@slocity.org>; mkersten@slocity.org Cc: Tryon, Thea@Waterboards <Thea.Tryon@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov>; Froelich, Sophie@Waterboards <Sophie.Froelich@Waterboards.ca.gov>; Lodge, Ryan@Waterboards <Ryan.Lodge@waterboards.ca.gov>; Keeling, Matt@Waterboards <Matt.Keeling@waterboards.ca.gov> Subject: RE: Proposed City of San Luis Obispo Roundabout Hi Bryan, I’m sorry, but as I thought you and I previously communicated, but not to the en Ɵre group of potenƟal meeƟng aƩendees, the August meeƟng date needed to be postponed. As I recall, several key personnel on your team and our team have only about a 15 minutes overlap on August 31 st, or were not available at all to meet at all that day. The next available Ɵme Central Coast Water Board staff could meet was on September 2 11th. When we spoke, you menƟoned key people on your team weren’t available September 11th, so we’d need to select a day the following week when they were available to meet. I completely recognize we’re trying to juggle at 10+ people’s schedules and it’s difficult to pivot to accommodate all poten Ɵal aƩendees. For context, the mid-to-late-September meeƟng date will also give us Ɵme here at the Central Coast Water Board to review the project-specific documents. Again, it is our desire to provide your project team meaningful feedback on the proposed construcƟon project. Thank you, Sheila Senior Engineering Geologist Central Coast Water Board 805/549-3592 From: Bryan Hulburd <bhulburd@covelop.net> Sent: Wednesday, August 23, 2023 2:27 PM To: Soderberg, Sheila@Waterboards <Sheila.Soderberg@waterboards.ca.gov>; nstrong@slocity.org; djohnson@slocity.org; 'Floyd, Aaron' <afloyd@slocity.org>; vheger@meyersnave.com; adam@meyersnave.com; 'Schwartz, Luke' <LSchwart@slocity.org>; 'Damien Mavis' <dmavis@covelop.net>; 'David Dixon' <ddixon@rouxinc.com>; 'Ranta, Owen' <owenranta@chevron.com>; 'Tulledge, Kim' <Kim.Tulledge@chevron.com> Cc: Tryon, Thea@Waterboards <Thea.Tryon@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov>; Froelich, Sophie@Waterboards <Sophie.Froelich@Waterboards.ca.gov>; Lodge, Ryan@Waterboards <Ryan.Lodge@waterboards.ca.gov>; Keeling, Matt@Waterboards <Matt.Keeling@waterboards.ca.gov> Subject: RE: Proposed City of San Luis Obispo Roundabout EXTERNAL: Thank you, Sheila. My understanding is that the City will be sending out a proposed agenda by end of day today. As we’ve been discussing, this meeƟng is solely to discuss the Tank Farm roundabout project – not the redevelopment plans of the Unocal property. We should also have the Soils Management Plan to your team today. AŌer you review the agenda, I expect you to understand that we can sƟll address many of the items proposed in the agenda without needing a detailed review of the SMP. Given how challenging it is to coordinate these mee Ɵngs and everyone’s schedules, we kindly ask that we please hold the meeƟng on August 31st as tentaƟvely scheduled – we will commit to geƫng you both deliverables by end of day today. Thank you for your understanding. Best, Bryan Bryan Hulburd Project Manager bhulburd@covelop.net 3 From: Soderberg, Sheila@Waterboards <Sheila.Soderberg@waterboards.ca.gov> Sent: Wednesday, August 23, 2023 2:13 PM To: nstrong@slocity.org; djohnson@slocity.org; Floyd, Aaron <afloyd@slocity.org>; vheger@meyersnave.com; adam@meyersnave.com; 'Schwartz, Luke' <LSchwart@slocity.org>; 'Damien Mavis' <dmavis@covelop.net>; Bryan Hulburd <bhulburd@covelop.net>; 'David Dixon' <ddixon@rouxinc.com>; Ranta, Owen <owenranta@chevron.com>; Tulledge, Kim <Kim.Tulledge@chevron.com> Cc: Tryon, Thea@Waterboards <Thea.Tryon@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov>; Froelich, Sophie@Waterboards <Sophie.Froelich@Waterboards.ca.gov>; Lodge, Ryan@Waterboards <Ryan.Lodge@waterboards.ca.gov>; Keeling, Matt@Waterboards <Matt.Keeling@waterboards.ca.gov> Subject: Proposed City of San Luis Obispo Roundabout Hi All, We have a tentaƟve meeƟng scheduled on August 31, 2023 from 2-3:30 pm at the Central Coast Water Board office to discuss the proposed roundabout project in the City of San Luis Obispo. As you are all aware, a por Ɵon of the roundabout is located on several parcels owned by Union Oil Company of California (Unocal). We would like to postpone this mee Ɵng and reschedule it for another date. Thank you to Bryan at Covelop for coordinaƟng your meeƟng request. Central Coast Water Board staff determined that we need specific informaƟon prior to meeƟng with all of you. The requested informaƟon is similar to what was discussed during our meeƟng on December 22, 2022. Specifically, we need to receive, and review, before we meet: 1. A meeƟng agenda (i.e., is this meeƟng only about the roundabout project? Or, is the intent to also discuss future residenƟal/commercial development plan[s] on the Unocal property and/or other proper Ɵes?); 2. A soils management plan (suggest renaming to be consistent with our prior request) for evalua Ɵng soil, sediment, and groundwater condiƟons that will be encountered during construcƟon. Because wastes may be encountered, Central Coast Water Board staff need to review and approve the soils management plan prior to beginning construcƟon. Please send these documents to us or let us know when we will receive them. AŌer we complete our review, Central Coast Water Board staff will be happy to meet with everyone and have a focused, project-specific discussion. Please note that there is a potenƟal for encountering shallow groundwater during construcƟon acƟviƟes. One way to manage encountered groundwater is to discharge the (treated) water to land, if site-specific condiƟons and requirements are met in the Central Coast Water Board’s General Waiver for Specific Types of Discharges (link Order No. R3-2019-0089 General Waiver for Specific Types of Discharges (ca.gov)). If this is an opƟon you are considering, we can beƩer explain the permiƫng process more thoroughly when we meet. Thank you. We look forward to hearing from you soon. Sheila Sheila Soderberg, P.G. | Senior Engineering Geologist Central Coast Regional Water Quality Control Board 895 Aerovista Place, Suite 101, San Luis Obispo, CA 93401-7906 Office Phone: 805.549.3592 Environmental Consulting & Management +1.800.322.ROUX rouxinc.com Risk Mitigation Plan ________________________________ TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION San Luis Obispo, California August 23, 2023 Prepared for: Covelop, Inc. Prepared by: Roux Associates, Inc. 555 12th Street, Suite 250 Oakland, California 94607 3957.0001S100/SMP 3374.0001S000 Site Mitigation Plan | ROUX | i Table of Contents 1. Introduction .................................................................................................................................... 2 2. Project Background & Current Conditions ..................................................................................... 4 2.1 Property Location and Description ...................................................................................... 4 2.2 Project Description ............................................................................................................... 4 2.3 Adjacent Site History & Environmental Assessment ........................................................... 4 2.4 Risk Based Screening Levels for Soil .................................................................................. 6 3.0 Soil Excavation, Handling, and Off-Hauling Mitigative Measures .................................................. 7 3.1 Site-Specific Health and Safety Plan ................................................................................... 7 3.2 Soil Excavation and Management ....................................................................................... 8 3.3 Soil Stockpiling and Storage ................................................................................................ 9 3.4 Soil and Groundwater Transport and Disposal .................................................................... 9 3.5 Dust Control ......................................................................................................................... 9 3.6 Decontamination of Equipment ......................................................................................... 10 4. Soil Characterization and Disposal .............................................................................................. 11 4.1 Four-Point Composite Sampling ........................................................................................ 11 4.2 Sample Analysis ................................................................................................................ 11 4.3 Offsite Disposal .................................................................................................................. 11 5. Groundwater Management .......................................................................................................... 13 6. Environmental Contingency Plan ................................................................................................. 14 6.1 Contingency Measures for Unanticipated Conditions ....................................................... 14 7. Site Security ................................................................................................................................. 15 Figures 1. Site Location Map 2. Interim Design Plan 3. Decision Flow Chart for Petroleum Hydrocarbon Impacted Soil Tables Table 1. Human Health and Ecological Risk Based Screening Levels Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Appendices A. San Luis Obispo Assessor Parcel Maps B. Figures from Historical San Luis Obispo Tank Farm Documents 3374.0001S000 Site Mitigation Plan | ROUX | 2 1. Introduction Roux Associates, Inc. (Roux), on behalf of Covelop, has prepared this Risk Management Plan (RMP) to be implemented during soil disturbing activities for a portion of Tank Farm Road at approximately 520 feet west of the existing intersection with Sante Fe Road, California (Site) (Figure 1). The project involves widening a portion of Tank Farm Road and construction of a roundabout. This RMP has been prepared to mitigate potential health and safety risks associated with soil disturbing activities proposed to be completed during the road construction at the Site. As part of a road construction proposed for the Site, the following soil disturbing activities are planned: clearing and grubbing (to five inches below ground surface [bgs]) associated with shallow general grading for road construction, utility trench excavations ranging from three to eight feet bgs, potential localized groundwater dewatering in utility trenches to facilitate subsurface construction, and potential soil off-hauling and groundwater management activities. A stormwater basin is proposed at the southeast corner of the roundabout. There will be no soil excavation required for the construction of this basin as the bottom will be at existing grade with imported soil used to create berms. It is Roux’s understanding that the project is located on land owned by four different entities: 1. Chevron owns the property northwest and south of the existing Tank Farm Road Assessor Parcel Numbers (APN) 076-381-021 Parcels 4 and 5, and 076-382-005 Parcels 6 and 7, respectively; 2. Covelop owns the property northeast of the existing Tank Farm Road (APN 053-421-006); 3. The City of San Luis Obispo owns Tank Farm Road east of the approximate center of the roundabout; and 4. The County of San Luis Obispo owns Tank Farm Road west of the approximate center of the roundabout. Copies of the parcel maps are provided in Appendix A. Preliminary construction plans indicate that the project will disturb approximately 8,300 cubic yards (13,400 tons) of soil during: clearing, grubbing, and general grading (90,900 square feet [sqft]); the utility trench excavations (up to 12,200 sqft); Excavated soil from the Project development may be reused as backfill for the roundabout project, disposed of at the Santa Maria Regional Landfill (SMRL), or soil from the Covelop and Chevron Sites may be reused at each of their respective sites. Site investigations conducted at the adjacent Chevron former San Luis Obispo petroleum tank farm identified extensive petroleum hydrocarbon impacts in soil and groundwater which may also be present in the planned work area of the Site. To determine potential health and safety risks, Roux reviewed the adjacent property history and accepted soil movement procedures as presented in Chevron documentation for the adjacent site, including: Final Remediation Action Plan (RAP) (Avocet, 2015), the Soil Remediation Endpoint Plan (Padre, 2018a) the Soil Segregation and Stockpiling Plan (Padre 2018b). Characterization and cleanup at the adjacent Chevron site is being overseen by the Central Coast Water Quality Control board (RWQCB). There is no known contamination at the APN 053-421-006 parcel which is east of the Chevron site and was never part of the Chevron operations. There is no known soil contamination in the existing roadway property, however it is assumed that groundwater impacts at the Chevron site underlay the roadway, as it bisects the Chevron site where there are documented groundwater impacts. Based on the proposed soil disturbing activities and the potential of presence of hazardous materials at the Site, this RMP includes the following sections: • Section 2.0 provides the Site background and history, environmental conditions at the Site, and a description of the project; 3374.0001S000 Site Mitigation Plan | ROUX | 3 • Section 3.0 presents mitigative measures to be implemented during excavation, handling and off- hauling of soil/fill material; • Section 4.0 presents characterization activities for the disposal of excavated soil/fill material; • Section 5.0 includes measures for handling and disposing of groundwater, if necessary; • Section 6.0 presents an environmental contingency plan; and • Section 7.0 presents responsibilities for Site security. 3374.0001S000 Site Mitigation Plan | ROUX | 4 2. Project Background & Current Conditions This section provides a description of the planned project, location, Site history based on the adjacent former San Luis Obispo Tank Farm, and a summary of the risk-based screening levels for soil developed for the adjacent SLO Tank Farm property. 2.1 Property Location and Description The Site is a portion of Tank Farm Road at approximately 520 feet west of the existing intersection with Sante Fe Road, California and includes portions of San Luis Obispo County Assessor’s Parcel Number Blocks 076-381-021 Parcels 4 and 5, and 076-382-005 Parcel 6 and 7, 053-421-006. The City of San Luis Obispo owns Tank Farm Road east of the approximate center of the roundabout and the County of San Luis Obispo owns Tank Farm Road west of the approximate center of the roundabout. The Site contains portions of the San Luis Obispo Tank Farm to the north and south of Tank Farm Road owned by Chevron, a portion of a parking lot to the Northeast owned by Covelop, and City and County of San Luis Obispo owned Road to the East and West, respectfully of the center of the roundabout. There are no buildings within the construction footprint of the proposed roundabout. 2.2 Project Description The project involves construction of a roundabout on a portion of Tank Farm Road. Soil disturbing activities related to the roundabout construction include clearing, grubbing, general grading and utility trench excavation. Soil excavations related to the roundabout construction, based on the 60 percent complete Tank Farm & Santa Fe Public Improvement Plans provided by Client, include approximately 8,300 cubic yards (13,400 tons) of soil to be removed during: clearing, grubbing, and general grading to lower the existing soil profile to make vertical space for the public improvement subgrade (90,900 sqft to five inches bgs); the utility trench excavations (up to 12,200 sqft and depths ranging from three to eight feet bgs). Excavated soil from the Project development may be reused as backfill for the roundabout project, disposed of at the Santa Maria Regional Landfill (SMRL), or soil from the Covelop and Chevron Sites may be reused at each of their respective sites. A preliminary plan showing the proposed roundabout construction is presented as Figure 2. Final structural drawings for the planned construction will be provided to the Contractor prior to the start of construction. 2.3 Adjacent Site History & Environmental Assessment From 1910 until the 1980s, the San Luis Obispo Tank Farm property was used for the storage of crude oil transported by pipeline. Storage facilities consisted of six earthen reservoirs ranging in capacity from 775,000 to 1,350,000 barrels1, and 21 steel ASTs, each with a capacity of 55,000 barrels. The reservoirs consisted of excavated circular depressions, which were lined with reinforced concrete. Between the reservoirs and ASTs, the Property had a total capacity of over 6 million barrels of petroleum. On April 7, 1926, lightning strikes ignited the vapors in four of the reservoirs and led to a fire at the Property. Despite fire suppression efforts, the fire from the initial lightning strikes spread to the other reservoirs and to 14 of the ASTs present at the time. Crude oil flowed out of the reservoirs and tanks and on to the surrounding ground. Over the four days after the lighting strike, all but a few thousand of the six million barrels of inventory had been released and spread across the San Luis Obispo Tank Farm property. Much of this oil burnt to petroleum coke, which is a black solid residue usually obtained from cracking (burning) in the refining 1 One barrel is equivalent to 42 gallons. 3374.0001S000 Site Mitigation Plan | ROUX | 5 process. To date, highly weathered and burned petroleum covers the ground in areas of the San Luis Obispo Tank Farm, particularly in topographically low points. After the fire, Union Oil resumed operations and reconstructed 10 ASTs and four of the reservoirs including Reservoir 4 in the south portion of APN 076-381-021 Parcel 4 and 5 northwest of the Roundabout. Reconstruction included adding additional fire breaks and containment areas around the reservoirs. During operations, arsenic-based herbicides were used for weed control, primarily in the northwest area of the San Luis Obispo Tank Farm. The four reconstructed reservoirs continued to be used for several decades, before being decommissioned between 1959 and 1976. The petroleum, petroleum impacted soil, and walls were removed from the reservoirs, but the reinforced concrete bottom in Reservoir #4 was left in place and then covered with between 5 and 10 feet of non-engineered backfill. The origin of this backfill was from soil removed from the Reservoir 4 that was stockpiled and sampled to confirm it met the site-specific screening levels. Figures from the Closure Summary Report North Property Soils – OU#3 and OU#4 (Trihydro, 2020) show test pit locations near the Site and surface expressions of pliable highly weathered crude oil adjacent to the Site to the northwest. Copies of these figures are presented in Appendix B. Since 2002, the human health and ecological risks associated with the San Luis Obispo Tank Farm have been analysed by Union Oil Company of California (Union Oil, now a subsidiary of Chevron) and regulatory agency representatives as part of the Surface Evaluation, Remediation, and Restoration Team (SERRT). The SERRT is a multi-agency collaborative stakeholder group that was convened to evaluate the potential impacts to human and ecological health from petroleum hydrocarbons and other chemical at the San Luis Obispo Tank Farm. The SERRT includes representatives of the Central Coast Regional Water Quality Control Board (RWQCB), the California Department of Fish and Wildlife (CDFW), San Luis Obispo County Environmental Services (SLOEHS), U.S. Army Corps of Engineers (USACE), U.S. Fish and Wildlife Services (USFWS), California Environmental Protection Agency – Office of Environmental Health Hazard Assessment (OEHHA), San Luis Obispo County District (APCD), County of San Luis Obispo, City of San Luis Obispo, and Union Oil (now a subsidiary of Chevron) and its environmental consultants. The following documents have been prepared that address human and ecological risk associated with the petroleum hydrocarbons and other contaminants of concern at the San Luis Obispo Tank Farm. • Baseline Human Health Risk Assessment (McDaniel Lambert, 2004); • Predictive Ecological Risk Assessment, Version 2.0 (BBL, 2004); • Risk Management Summary (BBL, 2005); • Feasibility Study (Avocet Environmental, 2007); • Remedial Action Plan (Avocet Environmental, Inc., 2007); • Project Execution Plan (Padre, 2007); • Environmental Impact Report (MRS Environmental, 2013); • Updated Human Health Risk Assessment (McDaniel Lambert, 2013); • Revised Remedial Action Plan (Avocet, 2015); • Human Health Risk Action Summary (McDaniel Lambert, 2015); • Soil Segregation and Stockpiling Plan (Padre, 2015); • Recommended Ecological Risk-Based Screening Levels for Soil and Sediment (ERM, 2017); and • Arsenic Background Re-evaluation Report (Intrinsik, 2017). Summaries of these documents can be found in the Soil Remediation Endpoint Plan (Padre, 2018). 3374.0001S000 Site Mitigation Plan | ROUX | 6 2.4 Risk Based Screening Levels for Soil Based on multiple documents to address human and ecological risk associated with petroleum hydrocarbons and other contaminants of concern at the San Luis Obispo Tank Farm, a set of Risk Based Screening Levels (RBSLs) for Soil were proposed (Padre, 2018). Table 1 below presents the proposed RBSLs for the Site and the basis for each constituent of potential concern (COPC). These RBSLs are based on the agency approved RBSLs for the San Luis Obispo Tank Farm site. The soil concentration values are presented below in milligrams per kilogram as dry weight. The values are subdivided between open space and development areas. Open space RBSLs are further subdivided between ecological and human-health based values. Since it is anticipated that petroleum hydrocarbon impacts that may be encountered at the site would be legacy contamination form past regional Tank Farm uses, the human-health based RBSLs shown below will be used for soil at the Site. These RBSLs are currently approved by the RWQCB for cleanup and restoration on the properties surrounding the Site and therefore using these values will provide consistency with currently occurring activities at the adjacent properties. The Development Area RBSLs will be used for soil below the planned project hardscape, and the Open Space RBSLs will be used for exposed soil at the Site. . Table 1. Human Health and Ecological Risk Based Screening Levels Constituent Open Space (within upper two ft outside of PPSH areas) (mg/kg, dry weight) Development Area (within upper four ft) (mg/kg, dry weight) Ecological1 Human Health2 Human Health3 Arsenic NA 12.54 12.54 Lead NA 1805 3205 TPH (C4-C40) 782 7,6196 41,2806 Benzene NA 4.06 1.86 Toluene NA 7,9006 5,9076 Ethylbenzene NA 606 316 Total Xylenes NA 21,7506 18,4206 PAHs NA 0.97 1.87 Notes: NA – Not applicable. mg/kg – milligrams per kilogram. 1 Based on BBL 2004, ERM 2017, most conservative Low Ecological Benchmark Value. 2 Based on McDaniel Lambert 2013, Intrinsik, 2015, recreator exposure scenario. 3 Based on McDaniel Lambert 2013, Intrinsik, 2015, intrusive construction worker exposure scenario. 4 Based on Intrinsik, 2017, revised background inflection point. 5 Based on McDaniel Lambert 2013, uHHRA/California Human Health Screening Levels (CHHSLs) or equivalent. 6 Human health risk-based screening levels based on uHHRA exposure parameters and Site-specific TPH fractions; recreator user Age-Dependent Adjustment Factors applied only to mutagens. 7 PAHs RBSL for recreator based on Northern California background Benzo(a)pyrene Equivalent Value (TEQ). 3374.0001S000 Site Mitigation Plan | ROUX | 7 3. Soil Excavation, Handling, and Off-Hauling Mitigative Measures Based on the elevated levels of petroleum hydrocarbons in the soil or fill material (referred to collectively as “soil” in this document) adjacent to the Site, excavation, soil handling and loading activities associated with the soil may require a contractor with the appropriate licenses and personnel training to handle hazardous waste (Contractor), if contamination is present. Soil samples must be submitted to a laboratory certified through the California Environmental Accreditation Program (ELAP). The Contractor will be responsible for profiling the waste for landfill acceptance and disposal of impacted soil excavated from the Site. Excavation, handling and loading activities for impacted soil will be conducted under the oversight of Roux. Following the completion of off-hauling activities associated with the soil at the Site, Roux will prepare an excavation completion report to document that the RMP was implemented during any soil moving activities at the Site. Excavation, handling and off-hauling of soil will be implemented using mitigative measures to protect human health for the following controls and site activities: : • Site-Specific Health and Safety Plan; • Soil Excavation and Management; • Soil Stockpiling and Storage; • Soil and Groundwater Transport and Disposal; • Dust Control; • Groundwater Management; and • Equipment Decontamination. A detailed description of each control or activity is provided in the sections below. 3.1 Site-Specific Health and Safety Plan A Site-specific Health and Safety Plan (HASP) will be prepared for field activities related to the excavation, handling and off-hauling of soil at the Site in accordance with 29 CFR 1910.120 Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER), and California Code of Regulations, Title 8, Section 5192. The HASP will be provided under a separate cover. The HASP will include guidelines and general requirements for all workers performing field activities involving contact with soil. The HASP shall serve as a general template for contractors performing work related to subsurface construction activities at the Site. The HASP attempts to identify all known potential hazards at the Site; however, Site conditions are dynamic and new hazards could appear. Therefore, the HASP shall serve as a general template for contractors performed work related to the construction of the proposed improvements at the Site. Each contractor will be required to prepare and implement an independent HASP that shall comply with 29 CFR 1910.120 OSHA HAZWOPER, 29 CFR 1926.62 OSHA Lead in Construction (as applicable) and the contractor’s own health and safety standard operating procedures (SOPs) to prevent exposure to potential hazardous constituents in soil. 3374.0001S000 Site Mitigation Plan | ROUX | 8 3.2 Soil Excavation and Management Soil encountered during construction excavation activities will be evaluated for the presence of discoloration/ staining. If discoloration/staining is observed, the potentially impacted soils will be segregated from the rest of the soil. In addition to visual observations, a photoionization detector (PID) will be used to further screen soils for organic vapors during excavation work. Note that these requirements do not apply to asphalt from the roadway or base rock below the road, which are considered recyclable materials. The PID will provide real-time data on the presence of potentially hazardous compounds. Soil screening procedures with a PID are as follows: • A soil sample will be placed into an unused re-sealable Ziplock plastic bag (or similar air-tight container) until the bag is approximately one-half full. • The bag will be sealed and soil crumbled by hand, if possible, while inside the bag and left to sit for least 2 minutes out of direct sunlight. • The container will be opened enough to allow the PID probe into the headspace of the plastic bag. • The sample will be considered as possibly impacted if the PID reading is 50 parts per million by volume (ppmv) or higher for 10 seconds or more. The site-specific RBSLs presented in Table 1 will be utilized during field activities when determining whether in-situ petroleum hydrocarbon-containing soil encountered in the field will be excavated and transported off- site for disposal, reused as backfill, or may remain in place. Table 1 will be followed for determining the appropriate course of action for soil indicated with suspect petroleum hydrocarbon impacts identified during the course of the project. The field geologist will utilize visual observations, odor, and soil screening using a photoionization detector (PID) in the identification of suspect soils. The decision flowchart included as Figure 3 presents the decision criteria that will be utilized during on-site remedial excavations to determine the appropriate action. The initial observations made in the field will proceed as follows: • Visible free oil – material requires off-site disposal; • Plastic/pliable material – material requires off-site disposal; • Asphaltic material – utilize Field Procedure to confirm, may be utilized on-site for fill material. Inert asphaltic material to be re-used only if it meets project geotechnical and/or other fill specifications. Submit representative samples of impacted soil for chemical analyses and compare to site specific RBSLs.. If in-situ soil meets the RBSL requirements, it may remain in-place. If soil requires excavation for another purpose (e.g., re-grading of area for restoration purposes) the soil will be stockpiled and transported off-site for disposal; o Discolored/odorous soil in-situ – discrete soil samples will be collected at a sufficient density across a potentially impacted area to identify the extent of impacted soil.; and o Discolored/odorous soil stockpile – one systematic composite soil sample will be collected for up to a maximum of 3,000 CY of stockpiled soil (see section 5.3 for details). The planned sampling frequency is in accordance with Santa Maria Landfill requirements for characterization of NHIS. Stockpiled soil will be divided into approximately equally-sized and spaced grid cells. One grab soil sample will be collected from each cell and homogenized into one composite soil sample. 3374.0001S000 Site Mitigation Plan | ROUX | 9 3.3 Soil Stockpiling and Storage Excavated soil shall be placed a a designed soil stockpile area and managed in accordance with the dust control requirements (section 3.5 and any permit requirements) and the Site Construction Storm Water Pollution Prevention Plan (SWPPP) which is not part of this RMP. Excavated soil that is known or suspected to be impacted shall be collected in a covered roll-off container or placed on hard scape or in a designated stockpiling area. If impacted soil is not placed on hardscape or on plastic sheeting, then a sufficient amount of underlying soil will need to be removing to ensure that no residual impacted soil is left behind. At minimum, plastic sheeting shall be 10-mil polyethylene sheeting or equivalent, such as Visqueen. Stockpiled soils shall be stored in accordance with the following: • Any saturated impacted soils (assumed to be excavated from approximately below 3 feet bgs) shall be stored on plastic sheeting or on hard scape and any runoff water contained. • When impacted stockpiled soils are not being handled, they shall be adequately covered and secured to control dust. 3.4 Soil and Groundwater Transport and Disposal The excavation contractor will be responsible for tracking soil removed from the site. Transportation will be coordinated in such a manner that at any given time, onsite trucks will be in communication with the Project operator. In addition, all vehicles will be required to maintain slow speeds (i.e., less than 5 mph) for safety and for dust control purposes on the Site. Prior to exiting the Project area, the vehicles will be cleaned to remove any loose soil from areas not covered or protected. The cleaning area will be set up as close to the loading area as possible so as to minimize the spreading of any loose soils. Prior to offsite transport, each truck will be inspected to ensure that the payloads are adequately tarped, the trucks are cleaned of excess loose soil, properly placarded (if applicable), and that the truck’s manifest (if applicable) or bill-of-lading has been completed and signed by the generator (or its agent) and the transporter. Soil will be transported to appropriate receiving facilities as determined by the waste classification. For any non-hazardous or hazardous soil or groundwater that needs to be removed from the Site appropriate licensed waste transporters will be required for off-site disposal. 3.5 Dust Control Dust control measures shall be implemented during dust-generating activities at the Site to protect the Contractor’s field personnel and to prevent and minimize dust emissions from the Site. Specifically, the implementation of dust control will prevent exposure to any hazardous constituents through inhalation of contamination particulates, dermal absorption and accidental ingestion from either direct or indirect cross- contamination activities. Dust control must also be maintained in accordance with any project specific permits. Dust control will be implemented at the Site by the Contractor and its subcontractors (as applicable when all dust-generating activities [i.e., excavation, drilling, soil loading and hauling] are being conducted at the Site). Visible dust generated during soil management activities shall trigger dust control techniques to be employed at the Site. Dust control techniques such as applying water to exposed areas shall be implemented where visible dust is generated. Stockpiled soil shall be kept covered during downtime periods or stored in soil bins with covers in order to prevent dust emissions. The inhalation potential for Site workers is anticipated to be low if dust control is implemented at the Site. 3374.0001S000 Site Mitigation Plan | ROUX | 10 3.6 Decontamination of Equipment Equipment used as part of excavation, handling and loading of impacted material at the Site shall be decontaminated before leaving the work zone and moving to a “clean” area (i.e., an area that does not contain impacted soil) and/or before it is removed from the Site. Equipment decontamination activities shall be implemented to remove, collect, and contain visible soil potentially containing hazardous constituents. Equipment shall be decontaminated using brooms, brushes, shovels and plastic scrapers or equivalent equipment. In addition, loose dirt will be scraped or swept off tires, treads, mud flaps, fenders and other accessible areas before leaving the Site. In the event that soil cannot be easily removed from equipment, a pressure washer may be used in a manner to prevent overspray from the decontamination area. All wastewater generated during decontamination shall be collected and held in drums or tanks for characterization and disposal. 3374.0001S000 Site Mitigation Plan | ROUX | 11 4. Soil Characterization and Disposal The project environmental consultant will conduct oversight activities during excavation, handling, and off- hauling of soil at the Site. The soil samples collected will characterize soil for disposal at an appropriate landfill. Analytical data from the soil samples will be used by the Contractor for waste profiling for disposal at an appropriate disposal facility. Soil disposal activities will be documented in the RMP Implementation Report. Table 1 (Section 2.4) presents the soil screening criteria for soil at the Site. Table 2 presents the Santa Maria Landfill acceptance criteria for soil being disposed of off-site. Soil can be replaced in the excavation if it meets reuse criteria or will be disposed of offsite if it is deemed as impacted. Soil characterization samples will be collected and analyzed as described in the following sections. 4.1 Four-Point Composite Sampling To determine if soils are suitable for reuse, a four-point composite sample shall be collected at the frequency of up to one four-point composite sample per 1,000 -3,000 cubic yards of soil (see section 5.3 for details). The four samples should be submitted to a laboratory for compositing. 4.2 Sample Analysis Samples shall be labelled, placed into a cooler with ice, and transported by courier to the appropriate California state certified laboratory under chain-of-custody documentation. Composite samples from soil generated at the Site shall be, at minimum, analysed for the following: • Volatile Organic Compounds (VOCs) and Total Petroleum Hydrocarbons (TPH) as gasoline (TPH- g) by EPA Method 8260B Note that samples for VOC analysis cannot be composited and a single sample out of the four must be designated for VOC analysis. • TPH as diesel (TPH-d) and TPH as motor oil (TPH-mo) by EPA Method 8015B/M • California Assessment Manual 17 (CAM 17) metals using Environmental Protection Agency (EPA) Method 6020B/7470A; • Polycyclic Aromatic Hydrocarbons (PAHs) by EPA Method 8270 4.3 Offsite Disposal If soils exceed the appropriate RBLS for soil, the following procedures shall be followed to appropriately dispose of soils offsite. The City of Santa Maria Utilities Department operates a Non-hazardous Hydrocarbon Impacted Soils (NHIS) Program at the Santa Maria Regional Landfill. The program accepts soil that is impacted, but not hazardous, and must be tested for a suite of analytical constituents to determine if it meets all of the regulated requirements. The analytical requirements for Clean Soil are: • California Assessment Manual 17 (CAM 17) metals using Environmental Protection Agency (EPA) Method 6020B/7470A; • Total Petroleum Hydrocarbons (TPH) using EPA Method 8015M; and • Flashpoint/ Ignitability using EPA Method 1010. The analytical requirements for the NHIS soil are the following analyses at a rate of 1 sample for the first 1,000 cubic yards and then one sample for each additional 3,000 cubic yards: • CAM 17 metals using EPA Method 6020B/7470A; o Soluble Threshold Limit Concentration (STLC) for metals if the Total Threshold Limit Concentration (TTLC) is not exceeded but total concentration exceeds the STLC value by 10 times; 3374.0001S000 Site Mitigation Plan | ROUX | 12 • TPH as gasoline range organics using EPA 8015M or 8260; • TPH as diesel range organics and motor/crude oil using EPA 8015M or 8270; • De-ionized Waste Extraction Test (DI WET) for Total Petroleum Hydrocarbons; • Volatile organic compounds (VOCs) using EPA Method 8260B; • Semi-volatile organic compounds (SVOCs) using EPA Method 8270C; • Organochlorine pesticides using EPA Method 8081A; • Polychlorinated biphenyls (PCBs) using EPA Method 8082; o STLC for PCBs is required if the TTLC concentration is between 1 milligram per kilogram (mg/kg) and 5 mg/kg; • Reactive Sulfides and Cyanide using SW 846, Section 7.3; • pH using EPA Method 9040/9045; and • Flashpoint/ Ignitability using EPA Method 1010. The NHIS acceptance criteria is provided in Table 2. Leachability • Soil samples with analytes on the STLC list with total metals concentrations equal to or greater than 10 times their STLC criterion shall be extracted with the WET leachability tests and the extracts analysed for those metals. • Soil samples with analytes on the TCLP list with total metals concentrations equal to or greater than 20 times their TCLP criterion shall be extracted with the TCLP test and the extract analysed for those metals. If concentrations exceed their specific STLC or TCLP criteria, the soil represented by those results will be considered hazardous waste. All generated wastes must be adequately characterized to ensure proper waste management and disposal to the appropriate disposal facility. If designated hazardous, such soils must be removed from the site within 90 days of the date excavation of the material was completed. 3374.0001S000 Site Mitigation Plan | ROUX | 13 5. Groundwater Management Based on shallow occurrence of groundwater at the Site, between 3 and 8 feet bgs, it is likely that groundwater will be encountered during excavation activities at the Site. If groundwater is encountered, localized dewatering may be necessary to complete construction activities. Groundwater generated during dewatering activities will be transferred to a drum or holding tank and sampled for potential contaminants. Non-impacted water may be re-used for dust control onsite based on project criteria such as the water volume collected during construction. Re-using non-impacted water on-site should also be approved by the RWQCB or SLOEHS. Impacted water will be transported and disposed of offsite or discharged to the sanitary or storm sewer. For onsite discharge, the Contractor may work with the City of San Luis Obispo to meet analytically requirements for discharge to appropriate City sanitary lines. If applicable, the Contractor, may obtain a NPDES permit from the RWQCB for ongoing discharge of groundwater associated with construction dewatering. 3374.0001S000 Site Mitigation Plan | ROUX | 14 6. Environmental Contingency Plan The Project Environmental Engineer, Scientist or Geologist shall inspect excavated and exposed soil at the Site as construction activities progress. If an inspection of the excavated and exposed soil indicates potential for unanticipated soil or groundwater impacts (i.e., soil staining or odors) in the excavations, the Contractor will suspend work immediately and follow contingency measures identified in Section 6.1. 6.1 Contingency Measures for Unanticipated Conditions The following tasks should be implemented during soil excavation if unknown historical subsurface features and/or unanticipated hazardous materials are encountered. Such materials may include unaccounted for underground storage tanks (USTs) and associated product lines, pipelines, sumps, and/or vaults, former monitoring wells, and soil with significant petroleum hydrocarbon odors and/or other stains or odors: • Stop work in the area where the suspect material is encountered, cover with plastic sheets and create an exclusion zone around the area; • Notify the General Contractor’s site safety officer and site superintendent. The General Contractor will request that Roux conduct a site inspection and will consult with Roux regarding appropriate follow-up actions in the suspect area. Roux will notify the property owner(s) of site conditions that indicate a material threat to human health or the environment; and, • Review the existing health and safety plan for revisions, if necessary, and have appropriately trained personnel on-site to identify and work with the affected materials, once directed by the General Contractor. If necessary, notifications will be performed and permits will be obtained prior to subsurface feature removals. If a UST, product line, sump or vault is found, the RWQCB will be notified, and a licensed tank removal contractor will be retained to properly remove and dispose of the UST. Proper permits and notifications should be in place prior to removal of the UST. If soil staining is observed, the affected soil will be placed in a separate stockpile on plastic sheets and covered with plastic sheets. Roux will complete soil sampling and analysis tasks for UST closure, in accordance with RWQCB guidelines. Roux will collect and analyze soil samples to determine the appropriate disposal procedures for the material, the extent of the impacted soil, and confirm that impacted material has been appropriately removed. Soil samples collected from beneath fuel pipelines, if any, will be collected beneath joints and elbows and at a frequency of one sample per 20 linear feet. Any unanticipated conditions observed will be documented in Roux’s RMP Implementation Report. 3374.0001S000 Site Mitigation Plan | ROUX | 15 7. Site Security During excavation activities, the contractor will be responsible for establishing an exclusion zone surrounding the excavation area. The purpose of this exclusion zone is to isolate the work zone and prevent unauthorized personnel from entering the work zone and potentially being exposed to hazardous constituents which may be present in excavated soil. In addition, this exclusion zone will prevent unauthorized personnel from entering the work zone while heavy equipment is in operation to ensure that field personnel are not unnecessarily exposed to the hazards of the equipment. In addition, the Contractor will be responsible for securing the work zone (i.e., open excavation areas, soil stockpiles, equipment staging areas, etc.) at the end of each work day throughout construction activities. RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX FIGURES 1. Site Location Map 2. 65% Interim Design Plan 3. Decision Flow Chart for Petroleum Hydrocarbon Contaminated Prepared for: Title: Compiled by: Prepared by: Project Mgr: File: Date: Project: Scale: FIGURE 1 SITE LOCATION MAP 276 TANK FARM ROADSAN LUIS OBISPO, CALIFORNIA COVELOP, INC. MM MM DD 22MAR2023 AS SHOWN 3957.0001S000 SLO TANK FARM FIGURES.DWG \\SRVOLCAFP1\OAKLAND SHARED\DIXON PROJECTS\SLO TANK FARM\05-ROUX DOCS\06-RMP\FIGURES\CAD\SLO TANK FARM FIGURES.DWGSITE SANTA FE ROAD TANK FARM ROADINTERIM DESIGN PLANSCALE: 1" = 150'ENCROACHMENT EXHIBITS FIGURE 2TANK FARM RD & SANTA FE RDROUNDABOUTCOVELOP0200'100'PROPOSED R/WEXISTING R/WEXISTING R/WPROPERTY LINE (TYP)NOTE:1. PROPOSED R/W DOES NOT INCLUDE AREA THAT MAY BE NEEDED FORWATERBOARD TREATMENT AND RETENTION REQUIREMENTSProjectClientPlot Date:15 June 2023 - 10:07 AMN:\US\San Luis Obispo\Projects\561\12579768\Digital_Design\ACAD 2020\Figures\12579768-GHD-0000-EXH-CI-0100-InterimEncroachment-County-City-Area.dwgPlotted By: Olivia Ramirez0Bar is one inch onoriginal size sheetApprovedDateAuthorDesignerProject DirectorProject No.DateFilename:Sheet No.This document and the ideas and designs incorporated herein, as an instrument of professional service, is the property ofGHD. This document may only be used by GHD’s client (and any other person who GHD has agreed can use thisdocument) for the purpose for which it was prepared and must not be used by any other person or for any other purpose.www.ghd.comTitle1"IssueNo.CheckedDesign CheckDrafting CheckProject ManagerConditions of UseScaleANSI BSizePRELIMINARYGHD Inc.1101 Monterey Street Suite 120San Luis Obispo California 93401 USAT 1 805 242 0461NORTHBIORETENTIONFACILITYPARCEL 5(PARCEL I)CONSTRUCTIONEASEMENTAPN 076-381-021AREA (12672 SF)PARCEL 4 (PARCEL J)CONSTRUCTIONEASEMENT AREAAPN 076-381-021(7108 SF)PARCEL 4 (PARCEL J)RIGHT OF WAYDEDICATION AREAAPN 076-381-021(5648 SF)PARCEL 5 (PARCEL I) RIGHT OF WAYDEDICATION AREAAPN 076-381-021(42431 SF)600 TANK FARMCONSTRUCTIONEASEMENT AREAAPN 053-421-006(17026 SF)600 TANK FARM RIGHT OFWAY DEDICATION AREAAPN 053-421-006(36602 SF)150'300'NPARCEL 6 (PARCEL H)CONSTRUCTION EASEMENT AREAAPN 076-382-005 (7137 SF)PARCEL 6 (PARCEL H) RIGHTOF WAY DEDICATION AREAAPN 076-382-005(11237 SF)PARCEL 7 (PARCEL G) RIGHTOF WAY DEDICATION AREAAPN 076-382-005(23342 SF)PARCEL 7 (PARCEL G)CONSTRUCTION EASEMENT AREAAPN 076-382-005 (13090 SF)FUTURE TEMPORARY STORMWATERRETENTION EASEMENT (20165 SF)LEGENDEXISTING R/WPROPOSED R/WCONSTRUCTION EASEMENTPROPERTY LINESCITY AREACOUNTY AREACOUNTY AREA - FUTURE STORMWATER RETENTION EASEMENTDRAINAGESWALE RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX TABLES 1. Site Location Map (imbedded in document) 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values BTEX - EPA Method 8260B or EPA Method 8021 Benzene 71-43-2 0.1 mg/Kg 100 µg/L Toluene 108-88-3 15 mg/Kg 15 µg/L Ethylbenzene 100-41-4 70 mg/Kg 70 µg/L Xylenes 1330-20-7 170 mg/Kg 170 µg/L TOTAL TPH - EPA Method 8015 or EPA Method 8260 (GRO only), TPH D.I. WET (mg/L) - EPA Method 8015/ DI WET GRO (C4-C12)68334-30-5 1000 mg/Kg 1 mg/L DRO (C13-C23)8006-61-9 15000 mg/Kg 5 mg/L ORO (C24-C36)68476-77-7 200000 mg/Kg 10 mg/L PCB's - EPA Method 8082 PCB 1016 12674-11-2 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1221 11104-28-2 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1232 11141-16-5 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1242 53469-21-9 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1248 12672-29-6 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1254 11097-69-1 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1260 11096-82-5 5mg/Kg, >1 mg/kg *0.1 mg/L Metals - EPA Method 6020,7471(Hg)/WET STLC Antimony 7440-36-0 500 mg/Kg or >150 mg/kg *15 mg/L Arsenic 7440-38-2 500 mg/Kg or >50 mg/kg *5 mg/L Barium 7440-39-3 10000 mg/Kg or >1000 mg/kg *100 mg/L Beryllium 7440-41-7 75 mg/Kg or >7.5 mg/kg *0.75 mg/L Cadmium 7440-43-9 100 mg/Kg or >10 mg/kg *1 mg/L Chromium III 7440-47-3 2500 mg/Kg or >50 mg/kg *5 mg/L Chromium VI 18540-29-9 500 mg/Kg or >50 mg/kg *5 mg/L Cobalt 7440-48-4 8000 mg/Kg or >800 mg/kg *80 mg/L Copper 7440-50-8 2500 mg/Kg or >250 mg/kg *25 mg/L Lead 7439-92-1 1000 mg/Kg or >50 mg/kg *5 mg/L Mercury 7439-97-6 20 mg/Kg or >2 mg/kg *0.2 mg/L Molybdenum 7439-98-7 3500 mg/Kg or >3500 mg/kg *350 mg/L Nickel 7440-02-0 2000 mg/Kg or >200 mg/kg *20 mg/L Selenium 7782-49-2 100 mg/Kg or >10 mg/kg *1 mg/L Silver 7440-22-4 500 mg/Kg or >50 mg/kg *5 mg/L Thallium 7440-28-0 700 mg/Kg or >70 mg/kg *7 mg/L Vanadium 7440-62-2 2400 mg/Kg or> 240 mg/kg *24 mg/L Zinc 7440-66-6 5000 mg/Kg or >2500 mg/kg *250 mg/L Volatile Organic Compounds - EPA Method 8260B or EPA Method 8021 1-Chlorohexane 544-10-5 N/A Title 22 or 100 x MCL*** 1,1-Dichloroethane 75-34-3 N/A 500 µg/L 1,1-Dichloroethene 75-35-4 N/A 70 µg/L 1,1-Dichloropropene 563-58-6 N/A Title 22 or 100 x MCL** 1 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values 1,1,1-Trichloroethane (TCA)71-55-6 N/A 20,000 µg/L 1,1,1,2-Tetrachloroethane 630-20-6 N/A Title 22 or 100 x MCL** 1,1,2-Trichloro-1,2,2-trifluoroethane (freon 113)76-13-1 N/A 120,000 µg/L 1,1,2-Trichloroethane 79-00-5 N/A 500 µg/L 1,1,2,2-Tetrachloroethane 79-34-5 N/A 100 µg/L 1,2-Dibromo-3-chloropropane 96-12-8 N/A 20 µg/L 1,2-Dichlorobenzene 95-50-1 N/A 60,000 µg/L 1,2-Dichloroethane (EDC)107-06-2 N/A 50 µg/L 1,2-Dichloropropane 78-87-5 N/A 500 µg/L 1,2,3-Trichlorobenzene 87-61-6 N/A Title 22 or 100 x MCL*** 1,2,3-Trichloropropane 96-18-4 N/A Title 22 or 100 x MCL** 1,2,4-Trichlorobenzene 120-82-1 N/A 500 µg/L 1,2,4-Trimethylbenzene 95-63-6 N/A Title 22 or 100 x MCL** 1,3-Dichlorobenzene 541-73-1 N/A Title 22 or 100 x MCL** 1,3-Dichloropropane 142-28-9 N/A Title 22 or 100 x MCL** 1,3,5-Trimethylbenzene 108-67-8 N/A Title 22 or 100 x MCL** 1,4-Dichlorobenzene 106-46-7 N/A 750 µg/L 2-Butanone (MEK)78-93-3 N/A Title 22 or 100 x MCL** 2-Chloroethylvinyl ether 110-75-8 N/A Title 22 or 100 x MCL*** 2-Chlorotoluene 95-49-8 N/A Title 22 or 100 x MCL** 2-Hexanone 591-78-6 N/A Title 22 or 100 x MCL** 2,2-Dichloropropane 594-20-7 N/A Title 22 or 100 x MCL** 4-Chlorotoluene 106-43-4 N/A Title 22 or 100 x MCL** 4-Isopropyltoluene 99-87-6 N/A Title 22 or 100 x MCL*** Acetone 67-64-1 N/A Title 22 or 100 x MCL** Benzene 71-43-2 100 µg/L Bromobenzene 108-86-1 N/A Title 22 or 100 x MCL** Bromochloromethane 74-97-5 N/A Title 22 or 100 x MCL** Bromodichloromethane 75-27-4 N/A 8,000 µg/L Bromoform 75-25-2 N/A 8,000 µg/L Bromomethane 74-83-9 N/A Title 22 or 100 x MCL** Carbon Disulfide 75-15-0 N/A Title 22 or 100 x MCL** Carbon tetrachloride 56-23-5 N/A 50 µg/L Chlorobenzene 108-90-7 N/A 10,000 µg/L Chloroethane 75-00-3 N/A Title 22 or 100 x MCL** Chloroform 67-66-3 N/A 600 µg/L Chloromethane 74-87-3 N/A Title 22 or 100 x MCL** cis-1,2-Dichloroethene 156-59-2 N/A 600 µg/L cis-1,3-Dichloropropene 10061-01-5 N/A 50 µg/L Dibromochloromethane 124-48-1 N/A 8,000 µg/L Dibromomethane 74-95-3 N/A Title 22 or 100 x MCL*** 2 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values Dichlorodifluoromethane (Freon- 12)75-71-8 N/A Title 22 or 100 x MCL** Dichlorofluoromethane 75-43-4 N/A Title 22 or 100 x MCL*** Dichlorotrifluoroethane 34077-87-7 N/A Title 22 or 100 x MCL*** Diisopropyl ether (DIPE)108-20-3 N/A Title 22 or 100 x MCL** Ethanol 64-17-5 N/A Title 22 or 100 x MCL** Ethyl t-Butly Ether (ETBE)637-92-3 N/A Title 22 or 100 x MCL*** Ethylbenzene 100-41-4 70 mg/L Ethylene dibromide (EDB)106-93-4 N/A 5 µg/L Hexachlorobutadiene 87-68-3 N/A Title 22 or 100 x MCL** Isopropylbenzene 98-82-8 N/A Title 22 or 100 x MCL** m,p-Xylene 179601-23-1 N/A total xylenes < 170 mg/L Methyl isobutyl ketone 108-10-1 N/A Title 22 or 100 x MCL** Methyl-tert-butyl ether (MTBE)2 1634-04-4 N/A 13 µg/L Methylene chloride 75-09-2 N/A 500 µg/L n-Butylbenzene 104-51-8 N/A Title 22 or 100 x MCL** n-Propylbenzene 103-65-1 N/A Title 22 or 100 x MCL** Naphthalene 91-20-3 N/A Title 22 or 100 x MCL** o-Xylene 95-47-6 N/A total xylenes < 170 mg/L Oxygenates - EPA Method 8260 VOC's N/A sec-Butylbenzene 135-98-8 N/A Title 22 or 100 x MCL** Styrene 100-42-5 N/A 10,000 µg/L t-Amyl Methyl Ether (TAME)994-05-8 N/A Title 22 or 100 x MCL*** t-Butyl Alcohol (TBA)75-65-0 N/A Title 22 or 100 x MCL** tert-Butylbenzene 98-06-6 N/A Title 22 or 100 x MCL** Tetrachloroethene (PCE)127-18-4 N/A 500 µg/L Toluene 108-88-3 15 mg/L total Xylenes 1330-20-7 170 mg/L trans-1,2-Dichloroethene 156-60-5 N/A 1,000 µg/L trans-1,3-Dichloropropene 10061-02-6 N/A 50 µg/L Trichloroethene (TCE)79-01-6 N/A 500 µg/L Trichlorofluoromethane (Freon-11)75-69-4 N/A 15,000 µg/L Vinyl acetate 108-05-4 N/A Title 22 or 100 x MCL** Vinyl chloride 75-01-4 N/A 20 µg/L Semi-Volatile Organic Compounds - EPA Method 8270 1-Methylnaphthalene 90-12-0 N/A Title 22 or 100 x MCL*** 1,2-Dichlorobenzene 95-50-1 N/A 60,000 µg/L 1,2,4-Trichlorobenzene 120-82-1 N/A 500 ug/L 1,3-Dichlorobenzene 541-73-1 N/A Title 22 or 100 x MCL** 1,4-Dichlorobenzene 106-46-7 N/A 750 µg/L 2-Chloronaphthalene 91-58-7 N/A Title 22 or 100 x MCL** 3 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values 2-Chlorophenol 95-57-8 N/A Title 22 or 100 x MCL** 2-Methylnaphthalene 91-57-6 N/A Title 22 or 100 x MCL** 2-Methylphenol 95-48-7 N/A Title 22 or 100 x MCL** 2-Nitroaniline 88-74-4 N/A Title 22 or 100 x MCL*** 2-Nitrophenol 88-75-5 N/A Title 22 or 100 x MCL** 2,4-Dichlorophenol 120-83-2 N/A Title 22 or 100 x MCL** 2,4-Dimethylphenol 105-67-9 N/A Title 22 or 100 x MCL** 2,4-Dinitrophenol 51-28-5 N/A Title 22 or 100 x MCL** 2,4-Dinitrotoluene 121-14-2 N/A 13 µg/L 2,4,5-Trichlorophenol 95-95-4 N/A 40,000 µg/L 2,4,6-Trichlorophenol 88-06-2 N/A 200 µg/L 2,6-Dinitrotoluene 606-20-2 N/A Title 22 or 100 x MCL** 3-Nitroaniline 99-09-2 N/A Title 22 or 100 x MCL*** 3,3'-Dichlorobenzidine 91-94-1 N/A Title 22 or 100 x MCL** 4-Bromophenyl-phenylether 101-55-3 N/A Title 22 or 100 x MCL** 4-Chloro-3-methylphenol 59-50-7 N/A Title 22 or 100 x MCL** 4-Chloroaniline 106-47-8 N/A Title 22 or 100 x MCL** 4-Chlorophenyl-phenylether 7005-72-3 N/A Title 22 or 100 x MCL*** 4-Methylphenol 106-44-5 N/A Title 22 or 100 x MCL** 4-Nitroaniline 100-01-6 N/A Title 22 or 100 x MCL*** 4-Nitrophenol 100-02-7 N/A Title 22 or 100 x MCL** 4,6-Dinitro-2-methylphenol 534-52-1 N/A Title 22 or 100 x MCL** Acenaphthene 83-32-9 N/A Title 22 or 100 x MCL** Acenaphthylene 208-96-8 N/A Title 22 or 100 x MCL** Aniline 62-53-3 N/A Title 22 or 100 x MCL** Anthracene 120-12-7 N/A Title 22 or 100 x MCL** Benzo(a)anthracene 56-55-3 N/A 10 µg/L Benzidine 92-87-5 N/A Title 22 or 100 x MCL** Benzo(a)pyrene 50-32-8 N/A 20 µg/L Benzo(b)fluoranthene 205-99-2 N/A Title 22 or 100 x MCL** Benzo(g,h,i)perylene 191-24-2 N/A Title 22 or 100 x MCL** Benzo(k)fluoranthene 207-08-9 N/A Title 22 or 100 x MCL** Benzoic acid 65-85-0 N/A Title 22 or 100 x MCL** Benzyl alcohol 100-51-6 N/A Title 22 or 100 x MCL*** Bis(2-chloroethoxy)methane 111-91-1 N/A Title 22 or 100 x MCL** Bis(2-chloroethyl)ether 111-44-4 N/A Title 22 or 100 x MCL** Bis(2-chloroisopropyl) ether 108-60-1 N/A Title 22 or 100 x MCL** Bis(2-ethylhexyl)phthalate 117-81-7 N/A 400 µg/L Butylbenzylphthalate 85-68-7 N/A Title 22 or 100 x MCL** Chrysene 218-01-9 N/A Title 22 or 100 x MCL** Di-n-butylphthalate 84-74-2 N/A Title 22 or 100 x MCL** 4 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values Di-n-octylphthalate 117-84-0 N/A Title 22 or 100 x MCL** Dibenzo(a,h)anthracene 53-70-3 N/A Title 22 or 100 x MCL** Dibenzofuran 132-64-9 N/A Title 22 or 100 x MCL*** Diethylphthalate 84-66-2 N/A Title 22 or 100 x MCL** Dimethylphthalate 131-11-3 N/A Title 22 or 100 x MCL** Fluoranthene 206-44-0 N/A Title 22 or 100 x MCL** Fluorene 86-73-7 N/A Title 22 or 100 x MCL** Hexachlorobenzene 118-74-1 N/A 13 µg/L Hexachlorobutadiene 87-68-3 N/A 50 µg/L Hexachlorocyclopentadiene 77-47-4 N/A 300 µg/L Hexachloroethane 67-72-1 N/A Title 22 or 100 x MCL** Indeno(1,2,3-cd)pyrene 193-39-5 N/A Title 22 or 100 x MCL** Isophorone 78-59-1 N/A Title 22 or 100 x MCL** n-Nitroso-di-n-propylamine 621-64-7 N/A Title 22 or 100 x MCL** n-Nitrosodimethylamine 62-75-9 N/A Title 22 or 100 x MCL** n-Nitrosodiphenylamine 86-30-6 N/A Title 22 or 100 x MCL** Naphthalene 91-20-3 N/A Title 22 or 100 x MCL** Nitrobenzene 98-95-3 N/A 200 µg/L Pentachlorophenol 87-86-5 N/A 17 µg/L Phenanthrene 85-01-8 N/A Title 22 or 100 x MCL** Phenol 108-95-2 N/A Title 22 or 100 x MCL** Pyrene 129-00-0 N/A Title 22 or 100 x MCL** Organochlorine Pesticides - EPA Method 8081A Aldrin 309-00-2 1.4 mg/Kg N/A Technical Chlordane 57-74-9 2.5 mg/Kg N/A 4,4'-DDD 72-54-8 1 mg/Kg N/A 4,4'-DDE 72-55-9 1 mg/Kg N/A 4,4'-DDT 50-29-3 1 mg/Kg N/A Dieldrin 60-57-1 8 mg/Kg N/A Endrin 72-20-8 0.2 mg/Kg N/A Heptachlor 76-44-8 4.7 mg/Kg N/A (g-BHC) Lindane 58-89-9 4 mg/Kg N/A Methoxychlor 72-43-5 100 mg/Kg N/A Toxaphene 8001-35-2 5 mg/Kg N/A Other Parameters 2 pH (EPA Method 9045B)2 < pH < 12.5 N/A Flashpoint (EPA Method 1010 (deg°F)) >140°F N/A Reactive Cyanide (SW 846 Ch.7 (mg/Kg))<250 mg/Kg N/A 5 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values Reactive Sulfide (SW 846 Ch.7 (mg/Kg))<500 mg/Kg N/A Fish Bioassay (96-hour Aquatic Toxicity)PASS N/A Specific Notes: 1. The SMRL NHIS Program does not allow any detectable MtBE, even though MtBE has a 100x the MCL limit of 1,300 µg/L 2. Data Results cannot be averaged * = Soluble Threshold Limit Concentrtion by WET method is required **No established MCL General Notes: If PQL and MDL >Acceptance Criteria, then PQL=Acceptance Criteria Should the constituent be non-detect (ND), the PQL or the MDL value will be used for averaging purposes. If total concentration > 100x the MCL, then run the DI WET and see if value < 100x the MCL. Must be accompanied by fish bioassay test. DI = deionized water N/A = Not Applicable MCL = maximum cotaminant limit STLC = soluble threshold limit concentration mg/Kg = milligrams per kilogram TTLC = total threshold limit concentration µg/L = micrograms per liter WET = waste extraction Test mg/L = milligrams per liter WET = waste extraction Test NHIS - Non-hazardous impacted soil 6 of 6 RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX APPENDICES A. San Luis Obispo Assessor Parcel Map B. Figures from Historical San Luis Obispo Tank Farm Documents RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX APPENDIX A San Luis Obispo Assessor Parcel Map CHVR-53046\2431951.2 Exhibit A-1 EXHIBIT A-1 EXISTING COUNTY PARCEL MAP DocuSign Envelope ID: 94CDDD5B-A58D-400A-961B-721F26A7C58A RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX APPENDIX B Figures from Historical San Luis Obispo Tank Farm Documents RESERVOIR 4 NORTHWEST AREA RESERVOIR 5 RESERVOIR 6 RESERVOIR 7 RESERVOIR 3 RESERVOIR 2 FORMER RECYCLING AREA T A N K F A R M R O A D NORTH MARSH OCCUPIED OFFICE STUCTURES FORMER FIRE SCHOOL LOCATION S:\GIS\1306_SLOTF-EMC_Work_Activities\1306.003_2013_Work_Activities\ArcMapDocuments\024_1306.003_Chevron_Pipelines.mxd\4/11/2014FIGURE 5 CHEVRON PIPELINES REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA EXPLANATION PROJECT AREA BOUNDARY CRUDE OIL PIPELINES OTHER UNDERGROUND PIPELINES APPROXIMATE SCALE FEET 0 500 1,000250 SEE FIGURE 6 FOR DETAIL NOTES: 1) LEACH LINES AND DRAIN LINES ARE SHOWN AS CRUDE OIL LINES ON THIS FIGURE FOR CLARITY. SIMILIARLY FOAMITE LINES ARE SHOWN AS WATER LINES DUE TO THEIR SIMILIAR FUNCTIONS DURING OPERATIONS. 2) UTILITY LOCATIONS ARE APPROXIMATE. ACTUAL LOCATION TO BE VERIFIED IN THE FIELD. 3) PORTIONS OF CRUDE OIL AND WATER LINES EXTENDING ALONG THE NORTH SIDE OF TANK FARM ROAD WERE REMOVED AS PART OF THE CITY'S SEWER PROJECT IN 2008. SUMMARY OF PIPELINE LENGTHS LENGTH (FEET) 25,125 258 914 38,263 9,177 TYPES CRUDE OIL LEACH LINE (SANITATION) DRAIN LINES WATER LINE FOAMITE REFERENCES: 1. AERIAL PHOTOGRAPH DATED FEBRUARY 4, 2008 2. GENERAL ARRANGEMENT SAN LUIS OBISPO TANK FARM, PRODUCERS PIPELINE, UNION OIL COMPANY OF CALIFORNIA, DRAWING No. UNKNOWN, DATED APRIL 3, 1950. GENERAL ARRANGEMENT SAN LUIS OBISPO TANK FARM NORTHERN DIVISION PIPELINE UNION OIL COMPANY OF CALIFORNIA, DRAWING No. D2A180, DATED JULY 30, 1981. ıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóRESERVOIR 4NORTHWESTAREARESERVOIR5RESERVOIR6RESERVOIR7RESERVOIR3RESERVOIR2FORMERRECYCLINGAREAS:\GIS\1306_SLOTF-EMC_Work_Activities\1306.004_SLOTF_2014_Support-EMC\ArcMapDocuments\002_1306.004_Wetlands_Fairy_Shrimp_Rare_Plant.mxd\12/9/2014FIGURE 12WETLANDS, FAIRY SHRIMP, ANDRARE PLANT HABITATSREMEDIAL ACTION PLANSAN LUIS OBISPO TANK FARMPREPARED FORCHEVRON EMCSAN LUIS OBISPO, CALIFORNIA05001,000250FeetApproximateScaleSOURCE: BIOLOGICAL RESOURCES MAPPING CONDUCTED BYPADRE AND WSP. FIELD STUDIES PERFORMED 2008.REFERENCE: AERIAL PHOTOGRAPH BY CENTRAL COAST AERIAL MAPPING.DATED MARCH 2, 2007EXPLANATIONSITE PROPERTY BOUNDARYıôóSOUTHERN CALIFORNIA WALNUTHOOVER'S BUTTON CELERYPURPLE NEEDLEGRASS GRASSLANDSLO (CAMBRIA) MORNING GLORYSLO MORNING GLORY (2003 SURVEY)SLO OWL'S CLOVERSLO SERPENTINE DUDLEYACONGDON'S TARPLANTDELINEATED WETLAND (SEE NOTE 1)PROTECTED FAIRY SHRIMPPRESENT (32.56 ACRES)PROTECTED FAIRY SHRIMPNOT PRESENT (71.80 ACRES)NOTE:THE WATERS OF THE U.S., INCLUDING WETLANDSUNDER US FEDERAL JURISDICTION SHOWN IN THISFIGURE WERE IDENTIFIED AND DELINEATEDCONSISTENT WITH DEFINITIONS OF WATERS OF THEUS PROVIDED AT 33 CFR 328.3 (A) (1-8) AND 33 CFR328.4 (B). FIELD DELINEATION PROTOCOLS FOLLOWTHE 1987 UPDATED AND ONLINE VERSION OF THEU.S, ARMY CORPS OF ENGINEERS WETLANDSDELINEATION MANUAL !( !( !( RESERVOIR 4 NORTHWEST AREA RESERVOIR 5 RESERVOIR 6 RESERVOIR 7 RESERVOIR 3 RESERVOIR 2 FORMER RECYCLING AREA BETITA PROPERTY 801 mg/kg 1,151 mg/kg 488 mg/kg WETLANDS IMPACTED BY ASPHALTIC CRUST T-8-0.5 T-2-0.5 T-17-0.5 S:\GIS\1306_SLOTF-EMC_Work_Activities\1306.003_2013_Work_Activities\ArcMapDocuments\031_1306.003_Summary_Environmental_Impacts.mxd\4/28/2013FIGURE 13 SUMMARY OF ENVIRONMENTAL IMPACTS REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA05001,000250 Feet Approximate Scale EXPLANATION TPH IN SOIL > 100 mg/kg EXTENT OF BTEX LIQUID CRUDE OIL. CAPABLE OF GENERATING "FREE" DROPLETS OF OIL. (EVALUATED FOR REMEDIATION IN FEASIBILITY STUDY) PLIABLE, HIGHLY WEATHERED CRUDE OIL. EVIDENCE OF RECENT PLASTIC FLOW. (EVALUATED FOR REMEDIATION IN FEASIBILITY STUDY) SOLID, FORMER CRUDE OIL PLIABLE, HIGHLY WEATHERED CRUDE OIL. NO EVIDENCE OF PLASTIC FLOW LNAPL OCCURANCE PROJECT AREA BOUNDARY TPH IN SOIL > 1,000 mg/kg !(SOIL SAMPLE SHOWING LEAD CONCENTRATION IN mg/kg REFERENCE: AERIAL PHOTOGRAPH DATED FEBRUARY 4, 2008. AREA OF ASENIC IMPACT (EVALUATED FOR REMEDIATION IN THE FEASIBILITY STUDY) AREA OF ARSENIC IMPACT TANK FARM ROAD EXISTING FENCE PROTECT-IN-PLACE NEW FENCE EXISTING FENCE REMOVE AND DISPOSE EXISTING FENCE PROTECT-IN-PLACE ASPHALTIC MATERIAL EXISTING WETLAND 0.068 Ac REMOVE ASPHALTIC MATERIAL ASPHALTIC MATERIAL ASPHALTIC LOCATION OF ROOF FOUNDATION ASPHALTIC MATERIAL EXISTING WETLAND 0.044 Ac REMOVE EXISTING UTILITY POLES PROTECT-IN-PLACE FORMER PUMP-HOUSE CONCRETE FOUNDATIONS REMOVE AND DISPOSE FORMER 10-INCH CRUDE-OIL LINE REMOVE AND DISPOSE NEW FENCE ABANDON FENCE CUT AND CAP WATERLINE EXISTING WETLAND 0.023 Ac REMOVE APPROXIMATE LOCATION OF FORMER CONCRETE FOUNDATION OF FORMER RESERVOIR WALL FORMER CRUDE-OIL PIPELINE CONCRETE FOUNDATION LIGHTNING TOWER No. 2 REMOVE AND DISPOSE 4" DIA. FIRE WATER DISTRIBUTION LINE CLEAR AND GRUB LINE EXISTING BARBED-WIRE FENCE REMOVE AND DISPOSE REMOVE AND DISPOSE BARBED-WIRE FENCE REMOVE AND DISPOSE EXISTING WETLAND 0.022 Ac REMOVEREMOVE AND DISPOSE EXISTING WETLAND 0.053 Ac REMOVE BARBED-WIRE FENCE REMOVE AND DISPOSE EXISTING WETLAND 0.316 Ac REMOVE TO CLEAR AND GRUB LINE WOOD FRAME TEST PLOT REMOVE AND DISPOSE WOOD FRAME TEST PLOT REMOVE AND DISPOSE REMOVE AND DISPOSE WOOD FRAME TEST PLOTS REMOVE AND DISPOSE CONCRETE FOUNDATION LIGHTENING TOWER No. 1 REMOVE AND DISPOSE EXISTING WETLAND .0125 Ac REMOVE EXISTING WETLAND PROTECT-IN-PLACE BARBED-WIRE FENCE REMOVE AND DISPOSE MONITORING WELL TMW-9 ABANDON EXISTING PROPANE CANON TO BE REMOVED BY CHEVRON REMOVE AND DISPOSE APPROXIMATE LOCATION OF EXPOSED WATER LINE REMOVE AND DISPOSE APPROXIMATE LOCATION OF FORMER TANK GAUGING CABLE CUT AND CAP CRUDE-OIL LINE EXISTING WETLAND .007 Ac REMOVE REFERENCE: TOPOGRAPHIC CONTOURS PROVIDED BY EDA, INC., DATED JULY 11, 2007. SCALE 0 120 240 FEET LEGEND V:\1212_Padre-Chevron_SLOTF\1212.001_Remedial_Design\031_1212.001_Reservoir_4_Demolition_Plan.dwg\05/13/14N FIGURE 35 RESERVOIR 4 (OU #3) DEMOLITION PLAN REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA TOPOGRAPHIC CONTOUR FENCEX 125 TREE / BRUSH LINE EXISTING MONITORING / SUPPLY WELL CUT/FILL LINE RIDGE LIMIT OF CLEAR AND GRUB WETLAND-PROTECT-IN-PLACE HYDROCARBON SURFACE EXPRESSION REMEDIATION REQUIRED HYDROCARBON SURFACE EXPRESSION - REMEDIATION NOT REQUIRED WETLAND-IMPACTED BY CONSTRUCTION TANK FARM ROAD EXTENT OF SURFACE EXPRESSION EXCAVATION ASPHALTIC MATERIAL EXISTING PG&E OVERHEAD ELECTRICAL PROTECT-IN-PLACE APPROXIMATE LOCATION OF FORMER CONCRETE FOUNDATION OF FORMER RESERVOIR WALL APPROXIMATE EXTENT OF GEOTEXTILE ASPHALTIC MATERIAL TMW-9 (TO BE ABANDONED) REFERENCE: TOPOGRAPHIC CONTOURS PROVIDED BY EDA, INC., DATED JULY 11, 2007. SCALE 0 120 240 FEET V:\1212_Padre-Chevron_SLOTF\1212.001_Remedial_Design\032_1212.001_Reservoir_4_Excavation_and_Geotextile_Placement_Plan.dwg\05/12/14N FIGURE 37 RESERVOIR 4 (OU #3) EXCAVATION AND GEOTEXTILE PLACEMENT PLAN REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA LEGEND TOPOGRAPHIC CONTOUR FENCEX 125 TREE / BRUSH LINE EXISTING MONITORING / SUPPLY WELL APPROXIMATE EXTENT OF GEOTEXTILE LIMIT OF CLEAR AND GRUB HYDROCARBON SURFACE EXPRESSION REMEDIATION REQUIRED HYDROCARBON SURFACE EXPRESSION - REMEDIATION NOT REQUIRED WETLAND - PROTECT-IN-PLACE WETLAND - IMPACTED BY CONSTRUCTION ıôóıôóıôóıôóıôóıôóıôóıôó ıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôó ıôóıôóıôó ıôóıôó ıôó ıôó ıôóıôó ıôó ıôó ıôóıôóıôóıôóıôó ıôó ıôó RESERVOIR 4 NORTHWEST AREA RESERVOIR 5 RESERVOIR 6 RESERVOIR 7 RESERVOIR 3 RESERVOIR 2 FORMER RECYCLING AREA S:\GIS\1306_SLOTF-EMC_Work_Activities\1306.003_2013_Work_Activities\ArcMapDocuments022_1306.003_Areas_of_Habitat_Impact.mxd\11/21/13FIGURE 46 AREAS OF HABITAT IMPACT REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA 0 500 1,000250 Feet Approximate Scale NOTE: CRLF = CALIFORNIA RED LEGGED FROG SOURCE: BIOLOGICAL RESOURCES MAPPING CONDUCTED BY RINCON CONSULTANTS INC., 2003. FIELD STUDIES PERFORMED MAY THROUGH SEPTEMBER 2003. REFERENCE: AERIAL PHOTOGRAPH BY CENTRAL COAST AERIAL MAPPING. DATED: FEBRUARY 4, 2008 EXPLANATION SITE PROPERTY BOUNDARY ıôó SOUTHERN CALIFORNIA WALNUT HOOVER'S BUTTON CELERY PURPLE NEEDLEGRASS GRASSLAND SLO (CAMBRIA) MORNING GLORY SLO MORNING GLORY (2003 SURVEY) SLO OWL'S CLOVER SLO SERPENTINE DUDLEYA CONGDON'S TARPLANT DELINEATED WETLAND PROTECTED FAIRY SHRIMP PRESENT (32.56 ACRES) PROTECTED FAIRY SHRIMP NOT PRESENT (71.80 ACRES) HABITAT IMPACT !! !! ! Total Project Disturbance Area STAGING AREA BORROW AREAS ACCESS ROUTE!! !! ! LEGEND PROPERTY BOUNDARY LINE PROJECT NAME: PROJECT NUMBER: DATE: SCALE IN FEET 0 100 200 ENVIRONMENTAL SCIENTISTSENGINEERS, GEOLOGISTS &associates, inc.3 FIGURE NN 1301-0307 April 2018 CEMC San Luis Obispo, CaliforniaSAN LUIS OBISPO TANK FARM FIELD ASSESSMENT MAP TEST PIT LOCATIONWITH APPROXIMATE DEPTH TO TPH-CONTAINING OR STAINED SOIL TEST TRENCH LOCATION WITH APPROXIMATEDEPTH TO TPH-CONTAINING SOIL RESERVOIR 4PLIABLE, HIGHLY WEATHERED CRUDE OILNO EVIDENCE OF PLASTIC FLOW (AVOCET,2015) PLIABLE, HIGHLY WEATHERED CRUDE OILEVIDENCE OF RECENT PLASTIC FLOW (AVOCET,2015) AVOCET CONSTRUCTION CONTROL LINE AS-BUILT EXCAVATIONS LIMITS EDGE OF CONCRETE NOTES 1. TOPOGRAPHIC CONTOURS PROVIDED BY RRM DESIGN GROUP DATED MARCH 2013. www.trihydro.com 1252 Commerce Drive Laramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 2. FIGURE CREATED BY PADRE ASSOCIATES, INC. AND MODIFIED BY TRIHYDRO CORPORATION. www.trihydro.com 1252 Commerce DriveLaramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 5 CLOSURE SUMMARY REPORT FIGURE CREATED BY AVOCET ENVIRONMENTAL, INC. AND MODIFIED BY TRIHYDRO CORPORATION. 1 42 5 5 5 5 5 5 5 5 5 5 5 4 4 4 3 3 3 3 5 5 5 5 5 5 5 5 4 4 4 3 5 5 5 5 5 5 5 5 4 4 4 4 4 4 4 4 5 5 4 4 4 3 4 4 6 5 5 4 4 4 3 3 3 5 5 5 5 4 4 3 5 5 5 4 4 5 5 5 4 4 4 5 5 4 4 5 4 4 6 4 4 34 4 3 34 3 33 8 33 3 33 4 42 4 43 54 54 53 4 43 6 5 5 3 3 3 3 3 3 3 3 66 3 751 642 532 43 43 3 3 3 4 4 4 4 4 4 4 4 4 4 4 3 2 3 4 4 4 4 3 3 3 4 2 4 4 4 4 4 5 4 4 5 5 4 2 4 4 4 5 5 4 4 5 5 5 4 3 2 5 5 5 5 4 5 4 5 5 5 4 3 3 5 5 6 7 4 6 5 3 3 5 5 5 3 3 3 4 5 6 6 4 6 5 4 4 4 5 5 3 3 3 2 5 6 6 4 6 5 5 4 4 4 4 3 3 3 3 5 6 6 4 6 5 5 4 4 3 4 4 3 3 3 4 6 6 5 6 5 4 4 3 3 4 4 4 3 4 6 6 5 6 5 4 4 3 4 4 4 4 4 4 6 6 5 6 5 5 4 4 4 4 4 5 4 5 6 6 5 6 5 5 4 4 4 5 5 5 4 5 6 6 6 6 5 5 5 4 4 5 5 5 4 5 6 6 6 6 5 5 5 4 4 5 5 5 4 4 6 6 6 6 6 5 5 4 4 5 5 5 5 5 6 6 5 7 6 5 5 4 4 5 5 5 5 5 6 6 5 7 6 5 5 4 4 5 5 5 5 4 6 6 6 6 6 5 5 4 4 5 5 5 4 4 6 6 5 6 6 5 5 4 4 5 5 5 4 5 6 6 6 6 6 5 5 5 4 5 5 6 4 5 6 6 6 6 5 5 5 5 5 6 6 6 4 5 6 6 5 6 5 5 5 5 5 6 6 6 4 5 6 6 6 6 5 5 5 5 5 6 6 6 4 5 6 6 6 6 5 5 5 5 5 6 6 6 5 5 6 6 6 6 6 5 6 6 5 6 6 6 6 5 6 6 7 5 5 5 6 5 5 6 6 6 6 5 6 6 7 5 5 5 6 5 4 6 6 6 6 5 6 6 8 5 5 5 6 5 4 6 6 6 6 5 6 6 7 5 5 5 6 6 5 6 6 7 4 5 6 6 7 6 5 5 6 6 5 6 7 7 4 6 7 6 7 6 5 5 7 7 4 7 7 8 4 5 6 7 7 6 6 5 4 4 7 7 5 7 7 7 4 5 6 5 8 6 6 5 4 4 7 7 5 7 7 7 5 5 6 5 9 6 5 5 4 5 6 7 6 6 7 6 6 6 6 5 5 6 6 5 5 6 6 7 6 6 5 8 6 6 5 5 5 5 5 5 5 6 5 4 6 7 6 5 5 5 6 6 4 5 6 4 5 8 6 6 5 6 5 6 6 6 6 6 8 7 6 7 7 1 CEMC SAN LUIS OBISPO, CA PROJECT NAME: PROJECT NUMBER:1301-0307 DATE:April 2018 SCALE IN FEET 0 80 160 ENVIRONMENTAL SCIENTISTSENGINEERS, GEOLOGISTS &associates, inc.5 FIGURE TANK FARM PROJECT SITE NN RESERVOIR 4FILL MAP AS-BUILT EXCAVATIONS LIMITS PROPERTY BOUNDARY LEGEND TANK FARM ROAD PAVED ROAD DIRT ROADS DEPTH OF FILL IN FEET5 FINAL GRADE CONTOURS EXCAVATION CONTOURS EDGE OF CONCRETE NOTES 1. EXCAVATION TOPOGRAPHIC CONTOURS PROVIDED BY CANNON DATED JUNE 2017. 2. FINAL GRADE TOPOGRAPHIC CONTOURS PROVIDED BY CANNON DATED OCTOBER 2017. www.trihydro.com 1252 Commerce Drive Laramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 3. FIGURE CREATED BY PADRE ASSOCIATES, INC. AND MODIFIED BY TRIHYDRO CORPORATION. C B AG H I J K L M N O P D EF CEMC SAN LUIS OBISPO, CA PROJECT NAME: PROJECT NUMBER:1301-0307 DATE:April 2018SCALE IN FEET 0 100 200 ENVIRONMENTAL SCIENTISTSENGINEERS, GEOLOGISTS &associates, inc.6A FIGURE TANK FARM PROJECT SITE NN REMEDIAL EXCAVATIONCONTOUR MAP AS-BUILT EXCAVATIONS LIMITS LEGEND DIRT ROADS EXISTING CONTOURS EXCAVATION CONTOURS PROPERTY BOUNDARY LINE RESERVOIR 4 A NOTES 1. EXISTING TOPOGRAPHIC CONTOURS PROVIDED BY RRM DESIGN GROUP DATED MARCH 2013. PIPELINES REMOVED PIPELINES LEFT IN PLACE ASPHALTIC FIELD TEST LOCATIONS LIQUID CRUDE OIL AND GROUNDWATER SEEPS 2. EXCAVATION TOPOGRAPHIC CONTOURS PROVIDED BY CANNON DATED JUNE 2017. www.trihydro.com 1252 Commerce Drive Laramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 3. FIGURE CREATED BY PADRE ASSOCIATES, INC. AND MODIFIED BY TRIHYDRO CORPORATION. 1 From:Bryan Hulburd <bhulburd@covelop.net> Sent:Thursday, March 14, 2024 10:01 AM To:'Quezada, Brenda'; Dietrick, Christine; McDonald, Whitney; Kersten, Markie; Schwartz, Luke; Stong, Nate; 'Damien Mavis'; 'Pat Arnold'; Lindgren, Adam; 'Heger, Viviana' Subject:RE: San Luis Obispo - Tank Farm Roundabout Developer Team Update Attachments:Chevron PFAS Testing Plan - 2024.02.09.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Attached is the most recent PFAS investigation plan. Page 31 of the PDF shows the proposed locations. Note – BG-7 is the location of the proposed stormwater basin in the current roundabout plans. Bryan Hulburd Project Manager 805-459-0753 bhulburd@covelop.net From: Bryan Hulburd <bhulburd@covelop.net> Sent: Thursday, March 14, 2024 9:05 AM To: 'Quezada, Brenda' <bquezada@meyersnave.com>; 'Dietrick, Christine' <cdietric@slocity.org>; 'McDonald, Whitney' <WMcDonal@slocity.org>; 'Kersten, Markie' <mkersten@slocity.org>; 'Schwartz, Luke' <LSchwart@slocity.org>; 'Stong, Nate' <nstong@slocity.org>; 'Damien Mavis' <dmavis@covelop.net>; 'Pat Arnold' <parnold@covelop.net>; 'Lindgren, Adam' <adam@meyersnave.com>; 'Heger, Viviana' <vheger@meyersnave.com> Subject: RE: San Luis Obispo - Tank Farm Roundabout Developer Team Update Below is what the City sent over previously for the upcoming meeting with Chevron:  Discussion of terms for the current roundabout right of way acquisition needs o Goal: Discuss City’s concerns with the current proposed draft Offer of Dedication and explore alternatives  Discussion of testing for compliance with Water Board requirements within the potential right of way area o Goal: Explain the planned extent of testing and anticipated outcomes for purposes of this project and understand Chevron’s concerns with this plan  Discussion of future plans and hopes for development in the Tank Farm area o Goal: Understand the big picture desires for this area of the City, as well as the implications of the current concerns regarding the Santa Fe/Tank Farm roundabout on these big picture desires Bryan Hulburd Project Manager 805-459-0753 bhulburd@covelop.net -----Original Appointment----- From: Quezada, Brenda <bquezada@meyersnave.com> Sent: Friday, January 26, 2024 11:33 AM To: Quezada, Brenda; Dietrick, Christine; McDonald, Whitney; Kersten, Markie; Schwartz, Luke; Stong, Nate; 'Damien Mavis'; 'Pat 2 Arnold'; bhulburd@covelop.net; Lindgren, Adam; Heger, Viviana Subject: San Luis Obispo - Tank Farm Roundabout Developer Team Update When: Thursday, March 14, 2024 8:30 AM-9:00 AM (UTC-08:00) Pacific Time (US & Canada). Where: Microsoft Teams Meeting Meeting recurring every two weeks on Thursdays at 8:30am. ________________________________________________________________________________ Microsoft Teams meeting Join on your computer, mobile app or room device Click here to join the meeting Learn More | Meeting options ________________________________________________________________________________ Arcadis of New York, Inc. 630 Plaza Drive Suite 200 Highlands Ranch Colorado 80129 Tel 718 446 0116 www.arcadis.com Page: 1/18 Dan Niles Engineering Geologist Central Coast Regional Water Quality Control Board 895 Aerovista Place, Suite 101 San Luis Obispo, California 93401 Subject: Revised Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California Dear Mr. Niles: At the request of Chevron Environmental Management Company (CEMC), and on behalf of Union Oil Company of California (Unocal1), Arcadis U.S., Inc. (Arcadis) has prepared this Revised Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan (Revised Supplemental Work Plan) to comply with the Central Coast Regional Water Quality Control Board’s (Regional Board’s) request for the former San Luis Obispo Tank Farm Project located in San Luis Obispo County, California (SLO Tank Farm or Site; Figure 1). This Revised Supplemental Work Plan was developed in response to the Regional Board’s letter rejecting the Supplemental Per- and Polyfluoroalkyl Substances Sampling Workplan (2023 Supplemental Work Plan; Arcadis 2023) dated October 23, 2023 (2023 Letter; Regional Board 2023). The 2023 Supplemental Work Plan was developed in response to the Water Board’s letter denial of a request for No Further Action (NFA) and request for a workplan addendum dated December 9, 2022 (2022 Letter; Regional Board 2022). A response to comments received in the 2023 Letter is included as Attachment A. Arcadis submitted a Per- and Polyfluoroalkyl Substances Sampling Results Investigation Report on January 21, 2022 (Arcadis 2022) to the Regional Board detailing results of an initial investigation that was conducted in accordance with the investigation activities outlined in the Per- and Polyfluoroalkyl Substances Sampling Work Plan (Work Plan; Arcadis 2020). CEMC concluded that the SLO Tank Farm Former Fire Training Area (FFTA) did not appear to be a source contributing to PFAS impacts observed in the downgradient off-site water supply wells nor the onsite water supply wells 1 The original Regional Board request received indicates the subject property as Former Unocal. Use of the term Union Oil is more appropriate as Unocal is a separate corporate entity. For the purposes of continuity with the Regional Board request Unocal is used throughout this Revised Supplemental Work Plan. ENVIRONMENT Date: February 9, 2024 Contact: Steve Rice Phone: 303.710.7537 Email: Steve.Rice@arcadis.com Our ref: 30083564 Mr. Dan Niles February 9, 2024 arcadis.com Page: 2/18 (WSW-NW and WSW-SW). This conclusion was based on the interpretation of the groundwater sampling and monitoring results, coupled with the historical records that the FFTA used firefighting foam that did not contain PFAS. Furthermore, the data collected and publicly available data suggested that upgradient sources, including the San Luis Obispo County Regional Airport (Airport), a 2018 Union Pacific Railroad Tie Fire, and potentially other unidentified/unconfirmed regional contributors, are impacting groundwater beneath the SLO Tank Farm. The 2022 Letter indicated that the Board believes presence of Perfluorohexanesulfonic acid (PFHxS) and Perfluorobutanesulfonic acid (PFBS) detected in groundwater monitoring wells near the FFTA suggests that PFAS-containing aqueous film-forming foam (AFFF) was used at the FFTA, despite documentation that non-PFAS-containing Foamite was used during the SLO Tank Farm operational period. The highest detections of PFBS and PFHxS compounds observed in groundwater were along the hydrogeologically upgradient eastern property boundary, adjacent to the Airport, indicating influence of off-site and upgradient sources. Known and potential off-site PFAS sources are discussed in further detail in Section 1.4 below. 1 SITE BACKGROUND The Site is located at 276 Tank Farm Road, south of the City of San Luis Obispo in western San Luis Obispo County, California (Figure 1). The Site is approximately 332 acres in size and is currently bordered generally by the Airport (southeast), light industrial development (west), agricultural and pastoral lands (south), light industrial (north, south, east, and west), and residential neighborhoods (east). The Site is divided into north and south sections by Tank Farm Road. 1.1 SITE HISTORY In 1910, Unocal constructed the Site as a central storage location for crude oil that was transferred via pipeline from the San Joaquin Valley and Santa Maria oil fields. At peak use, the maximum storage capacity for the Site was more than six (6) million barrels, comprising of six (6) large earthen reservoirs with capacities ranging from 775,000 to 1,350,000 barrels and 21 aboveground storage tanks (ASTs) with capacities of 55,000 barrels each. Operations at the Site gradually declined during the latter decades of the 20th century. In 1926, a lightning strike ignited a fire that ultimately burned most of the 6.3 million barrels of oil in inventory (this fire pre-dated the invention and use of PFAS-containing AFFF). After the fire, four (4) of the original reservoirs and ten (10) of the original ASTs were reconstructed. Reservoir locations are shown on Figure 5. Operations at the Site gradually declined during the latter decades of the 20th century. The Site was operational through the early 1980s, and by the late 1990s the Site was formally decommissioned. The remaining four reconstructed reservoirs were decommissioned between the 1950s and 1970s as follows:  Reservoir 5 (decommissioned in 1959)  Reservoirs 3 and 6 (1961)  Reservoir 4 (1976). For the ten (10) remaining or rebuilt ASTs, one (1) was removed in the early 1960s; eight (8) of the nine (9) remaining ASTs were removed in 1994; and the final AST (55524), which was used to store water for fire suppression, was removed in 2000 (Marine Research Specialists 2013). AST locations are shown on Figure 5. Mr. Dan Niles February 9, 2024 arcadis.com Page: 3/18 During a portion of the facility’s operational period, an area approximately 200 x 500 square feet (outlined in orange on Figure 5) that was part of the Northwest Operations Area of the site was used as an FFTA. The FFTA was used to practice extinguishing flammable-liquid fires using simulated process equipment, which were fed petroleum products from onsite tanks. Currently, the site is primarily characterized as open space, comprised of undeveloped grassland and wetland. Offices and a parking lot in the Northwest Operations Area, north of Tank Farm Road, are in use. Remediation activities in the past few years have included equipment removal, wetland restoration, and regrading. Remediation activities performed in 2019 at the FFTA included the removal of the firefighting trench, excavation of the top two (2) feet of soil, scarification and compaction of approximately one (1) foot of material beneath the excavated material, and the addition of a six (6) foot cap over the FFTA (Trihydro 2020). Groundwater monitoring is being conducted on a semi-annual basis, with a focus on impacts associated with petroleum hydrocarbons. 1.2 GEOLOGY AND HYDROGEOLOGY The Site is located within the Coast Ranges Geomorphic Province of California. The Site is situated at the western end of the San Luis Valley, which is a basin filled with Holocene-aged alluvium (Dibblee 2004). The bedrock of the Franciscan Formation unconformably underlies the alluvium and crops out at the northeastern corner of the Site. The alluvium thickness at the Site increases towards the southwest from 0 feet, where bedrock is exposed, to a maximum thickness of approximately 160 feet at the southwestern corner. Shallow groundwater zones have limited connectivity to the deeper groundwater zones (e.g., greater than 50 feet beneath ground surface [ft bgs]; Avocet 2011). Groundwater supply wells in the area are drilled and completed into the deeper zones. Stormwater from the east, north, and west flows into the SLO Tank Farm Site. A significant portion of the Site resides within a 100-year floodplain and has a history of flooding during major precipitation events (Avocet 2015). 1.2.1 SHALLOW AND DEEP SATURATED ZONES Avocet (2011) noted that the degree of hydraulic communication between the shallow, petroleum- impacted, and deep (>50 ft bgs) saturated zones, was evaluated based on aquifer tests performed along Tank Farm Road in 1992 and 1996. The aquifer tests used two purpose-built “water supply” wells installed within or immediately adjacent to petroleum-impacted soils. Testing before, during, and after the 24-hour aquifer tests determined that no contaminants had been drawn into the wells from the overlying impacted soils, despite 20 feet of drawdown. As such, the memo concluded that the connection between the shallow and deep (>50 ft bgs) saturated zones is limited (Avocet 2011). In addition, in 2001, multi-level probes were installed to evaluate vertical conductivity adjacent to petroleum impacted areas. Evaluation of the resulting data showed that there are no consistent upward or downward gradients within the aquifer above the resolvable level of about 0.003 feet per foot (ft/ft) (England Geosystem 2002). This data analysis supports a lack of hydraulic communication between shallow groundwater at the SLO Tank Farm and the deeper off-site supply wells located on properties downgradient and cross-gradient (Whitson Industrial Park Well 01 [screen interval 60 – 115 feet btoc], Holdgrafer & Associates Well 01 [screen interval unknown], and Copeland S. Properties Well 01 [screen interval 100 – 170 feet btoc]). Groundwater PFAS results from both on-site and off-site groundwater wells (including the off-site supply wells) are identified in Figure 2. 1.2.2 HISTORICAL WATER SUPPLY WELLS The March 31, 2015 Final Remedial Action Plan (2015 RAP) identified two (2) historical water supply wells in the Northwest Operations Area. The approximate locations of the wells were unable to be verified Mr. Dan Niles February 9, 2024 arcadis.com Page: 4/18 and “It is likely that the wells were abandoned many years ago and any other record of them has long since been lost” (Avocet 2015). The 2023 Letter requested that “a discussion of the final determination regarding location efforts for proper abandonment of these wells” be included in this Revised Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan. Historical records and well completion reports were reviewed to identify the status of the 12-inch diameter supply wells in the Northwest Operations Area. Additionally, geophysical subsurface investigations for these wells were completed as part of the Northwest Operations Area excavation and capping effort. The historical records review and subsurface investigations did not identify the presence of supply wells nor did they confirm proper abandonment of the wells. Additional historic record review is ongoing. Any new significant findings, or a revised factual timeline, will be presented in the investigation report as appropriate. 1.3 POTENTIAL ON-SITE FIREFIGHTING FOAM STORAGE AND USE AREAS Site activities that may be associated with foam storage and use include: (a) maintaining a firefighting system using water for suppression of petroleum-liquid fires and (b) the FFTA (outlined in orange on Figures 2 and 5), which historically stored non-PFAS containing Foamite. As noted in the 2023 Supplemental Work Plan, a fire occurred in 1926 that pre-dated use of PFAS-containing AFFF, which was first used in the 1960s by the US Navy but not available to general industry until the 1970s when National Fire Protection Association (NFPA) added the “military specification” (MILSPEC) to its design requirements for refineries (ITRC 2020). Therefore, no Site impacts from PFAS could be associated with the 1926 event. Site operations south of Tank Farm Road had ceased by 1961, when the last reservoirs south of the road were removed. Site areas that are identified for potential foam storage and/or use occur within the operational areas north of Tank Farm Road, particularly in the Northwest Operations Area. The investigation relating to potential releases of PFAS by Unocal operations is focused on the Northwest Operations Area. Since operations at the Site date back to 1910, interpreting the Regional Board’s 2020 Letter to investigate PFAS has required historical records review, which is still ongoing. The Regional Board states in its 2020 Letter “references describe training specifically for petroleum fires, which would likely have involved the use and/or storage of a class of fire suppressing materials known as “aqueous film forming foam” (AFFF), which generally contain PFAS.” Available historical records for the SLO Tank Farm (from 1937-1985) do not support the Regional Board’s generalized hypothesis. Historical records identified to date demonstrate a firefighting system that was designed to use products and techniques that pre-date the development and use of PFAS-containing AFFF: Specifically, records review suggests the following:  Historical records indicate that the facility had a PFAS-free “Foamite” firefighting system. No records or information have been located to support the use of PFAS-containing AFFF foams on property by Unocal.  An on-site water tank was present for use in fire suppression. The exact location of the water tank varied through the years.  The facility fire suppression system was designed to distribute water throughout the operational areas of the property. AST 55524, north of the Northwest Operations Area, was re-purposed to store water from on-site wells2; it was also the most recent water tank demolition in 2000. The 2 AST 55524 in earlier drawings (pre-1981) is listed as having a "floating roof". That indicated AST 55524 would have been used as a product tank. Later depictions (post-1981) show AST 55524 with a "cone wood" top, which would indicate use as a water tank. The actual transition date to use as a water tank is uncertain. Mr. Dan Niles February 9, 2024 arcadis.com Page: 5/18 water was distributed throughout the facility via a network of aboveground and underground pipelines. AST 55524 was used to store water for fire suppression, dating back to at least 1981, and was kept intact longer than other ASTs in the area (through 2000). As indicated in the Unocal fire suppression system engineering drawing (Unocal 1956/1981), a “fire pump” was formerly located southeast of the former AST 55524.  Foam tanks near tanks 55526, 55534, 55536, and 55538 were added to the Unocal fire suppression system engineering drawing in 1981 (Unocal 1956/1981). Except for AST 55534, the soils near these former foam tanks were regraded during subsequent remediation and restoration activities in 2018 (Padre 2019).  At four (4) locations within the northern tank farm, foam tanks and/or foam risers were positioned along the water distribution system (Unocal 1956, revised 1981). The Foamite distribution system for floating roof tanks was made popular with US patent US2548409 in 1951.  Numerous fire hydrants and risers were located along this distribution system.  Use of non-PFAS-containing foam powder (“Foamite”)3 was documented, and likely was the extinguishing agent between 1928-1977, as NFPA only added bulk fuel storage recommendations to consider PFAS-containing MILSPEC AFFF after 1972 committee reports. A drill in December 1977 used Foamite canisters and follow-up explained that no conversion to “liquid foam” had yet occurred.4  Site maps refer to storage of Foamite, which does not contain PFAS (patents for Foamite systems 1918-1960; Foamite Firefoam 1925). References to “Foamite lines” occur in maps as early as 1923 and 1928, and foam powder was noted in historical (1974) records as exceeding an age of 20 years.  Based on review of historic fire loss reports from the 1970s, the only fire at the SLO Tank Farm, between 1970 and 1980, occurred when a boiler fire box exploded on 9 Jan 1976. At the time, Foamite powder was still on-site. No record of the details of the 9 Jan 1976 fire response (if any) was located in archives, but a subsequent December 1977 drill used Foamite canisters as conversion to “liquid foam” had yet occurred.4 Foam tanks were added to engineering drawings in 1981, but no other identified records indicate any Foamite lines or other equipment was changed.  The lateral water distribution pipelines between the northern tank field are identified as Foamite (Unocal 1991).  The facility had an established FFTA on-site. A Unocal publication from Fall 1988 explaining that since 1980, week-long annual fire training occurred at a fire school in another state.5 3 To make Foamite, “a portion of the spent [licorice] root from the primary extractors is subjected to a secondary extraction with a 5 per cent solution of caustic soda under 100 pounds steam pressure for several hours. This secondary extract is evaporated to 12° Be, in which form it is known as Firefoam Liquid and is used as a foam stabilizer in the Foamite fire extinguisher. The solutions in this extinguisher have the following composition: the first, 11 parts aluminum sulfate and 89 parts water; the second, 8 parts sodium bicarbonate, 3 parts Firefoam Liquid (12° Be.), and 89 parts water. On mixing these solutions a tough, durable foam, which resists heat and mechanical abuse, is produced. This method of attacking fires has proved to be of great value in extinguishing oil fires and is now in almost universal use in the protection of oil tanks.” (Houseman PA and Lacey 1929) 4 Per 25 January 1978 fire drill critique, a 22 December 1977 San Luis Obispo Tank Farm drill used Foamite canisters as the SLO Tank Farm had not yet converted from foam powder to liquid foam concentrate. 5 See Unocal Fall 1988 issue of its publication, Seventy-Six, pages 30-35. Mr. Dan Niles February 9, 2024 arcadis.com Page: 6/18  Cessation of use of the FFTA is consistent with aerial photos that indicate that the FFTA was not in active use after 1978 (Attachment B of the previously submitted Supplemental Work Plan)  An additional water storage tank for fire suppression is currently present in the Northwest Operations Area, east of the parking lot, and south of the existing office buildings. The 10,000- gallon polyethylene tank was installed sometime between 2000 to 2015 after operations at the Site had ceased and after most petroleum infrastructure had been removed. The tank is connected to a system of hydrants across the Site (Avocet 2015) and is not associated with conveyance or use of AFFF for petroleum liquid fires. The tank is filled with water collected from a permitted on-site non-potable water supply well (WSW-NW). Given the above facts, there is no evidence to suggest that PFAS-containing AFFF was ever used by Unocal, or others, at the SLO Tank Farm. 1.3.1 FORMER FIRE TRAINING AREA Based on available records identified to date, the FFTA operated in the Northwest Operations Area until 1979 and was used to practice extinguishing flammable-liquid fires. Petroleum hydrocarbons were fed via buried metal pipes to practice fixtures in a concrete-and-asphalt-lined pit within the FFTA. The area consisted of several simulated sumps, flares, and tanks where personnel practiced techniques for extinguishing petroleum-fed fires fueled by off-specification gasoline and diesel fuel. Aerial photo interpretation indicates the FFTA was established sometime prior to 1947 and well maintained until 1978, after which time the area appears in a diminished state until 2003 where the FFTA is no longer visibly maintained. Newspaper articles are available for a few years, indicating that outside fire agencies held periodic fire training drills at the SLO Tank Farm in 1972 (Santa Maria Times 1972), 1976 (Five Cities Times-Press-Recorder 1976) and 1985 (San Luis Obispo County Telegram-Tribune 1985). It is unclear if these events included the Unocal employees or if these were situations of outside entities utilizing the SLO Tank Farm FFTA. Beginning in 1980, Unocal began annual fire training at an out-of-state fire school (Seventy-Six, Fall 1988, pages 30-35). In 2019, the concrete trench and underlying pipelines associated with the training area were removed from the SLO Tank Farm and transported to the Santa Maria Landfill for waste disposal. Removed pipelines were transported to Bedford Enterprises, Inc. to be recycled. The Northwest Operations Area was excavated to a depth of at least two (2) feet below original grade to remove arsenic impacted soil. The FFTA was then backfilled with clean material and is now capped with up to six (6) feet of clean fill (Trihydro 2021). 1.4 PREVIOUS PFAS INVESTIGATION At the request of the Regional Water Board, groundwater gauging and sampling activities were conducted on October 21-22, 2021, at the SLO Tank Farm. Ten (10) monitoring wells (MW-17, MW-19, MW-26, MW-41, MW-43, MW-49, MW-50, SLOW-12, SLOW-17, and SLOW-18) were gauged with a water level meter before sampling. In addition, though not identified in the Work Plan, the SLO Tank Farm’s water supply well southwest (WSW-SW) and its respective above ground storage tank (storage tank) were included in the PFAS gauging and sampling event. The SLO Tank Farm’s (WSW-NW) was then sampled during a separate mobilization on April 21, 2022. Representative groundwater sample locations selected (MW-41, MW-49, MW-50, SLOW-12, SLOW-17, SLOW-18, and WSW-NW) are located approximately 250 to 350 feet down- and cross-gradient of the FFTA, as shown on Figure 2. In addition, select monitoring wells around the east, south, and southwest perimeter (MW-17, MW-19, MW-26, MW-43, and Mr. Dan Niles February 9, 2024 arcadis.com Page: 7/18 WSW-SW) of the SLO Tank Farm were sampled to evaluate background groundwater conditions and the possibility of off-property influence moving on-site from the Airport (Figure 2). Concentrations of various PFAS compounds were detected in all monitoring wells (including perimeter and FFTA representative wells), the water supply wells, and storage tank samples collected, although SLOW- 12, SLOW-18, and MW-50 did not have any PFAS concentrations above the Limit of Quantitation (LoQ) (e.g., only “J-flagged” estimated values below the LoQ). The highest detected concentrations of PFAS compounds observed in groundwater at the Site were upgradient along the east and southeastern boundary of the SLO Tank Farm, downgradient of the adjacent Airport and adjacent to the tributary for the East Fork of the San Luis Obispo Creek. The analytical data for samples collected along the eastern property boundary demonstrate a similar PFAS distribution pattern compared to that from samples collected for the Airport investigation described below (i.e., dominated by PFHxS and Perfluorooctanesulfonic acid [PFOS]; Figure 2). For the areas downgradient of the FFTA, the concentrations of PFAS in the samples were so minimal that it is difficult to interpret the PFAS signature of the samples, but the signature appeared to also mimic the plume emanating from the Airport. 1.5 KNOWN AND POTENTIAL OFF-SITE SOURCES IDENTIFIED TO DATE CEMC continues to evaluate additional potential off-site sources of PFAS that could be impacting media at or beneath the SLO Tank Farm. Within one (1) mile of the SLO Tank Farm, industrial and commercial properties that are current potential sources of PFAS have been identified through desktop research and are shown in Figure 1. Facilities of greatest interest include:  San Luis Obispo Regional Airport (Geotracker Case ID T10000012768): The Airport is a known source of PFAS directly adjacent to the Site (Figure 1). Previous reports for the Airport identified it as a source of PFAS to both soil and groundwater in the area (Roux Associates 2022). The 2023 Airport Remedial Investigation Workplan identified groundwater flow “flowing to the northwest into the southeastern portion of the Airport-vicinity, then turning to the west and southwest further into the San Luis Obispo Basin” (Roux Associates 2023). The highest PFAS concentrations in soil and groundwater at the Airport are associated with the Airport’s fire station (CAL FIRE San Luis Obispo County Fire Station 21) on the northeastern side of the airport, approximately 5,000 feet east of the Site’s southeastern boundary. PFOS concentrations near the fire station were reported to be as high as 1,900 micrograms per kilogram (µg/kg) (at 10 feet bgs in boring NE-1C) in soil and 130,000 nanograms per liter (ng/L) in the perched groundwater sample at NE-1D (Roux Associates 2023). PFHxS was also present in the groundwater at the Airport with concentrations up to 790,000 ng/L reported at NE-1D. The recent private well sampling conducted by the Airport demonstrates the PFAS plume is migrating off-site, and potentially onto the southern boundary of the SLO Tank Farm, with PFOS concentrations in one private well as high as 910 ng/L (PW-04; Roux Associates 2022). The Airport Stormwater Drainage System Map indicates that stormwater collected from the current AFFF storage area, historical fire training area, and former stormwater retention basin is captured and routed to a detention basin (Outfall #6 – Figure 5) at the north end of runway 11-29 (Roux Associates 2022). The stormwater is then discharged to a drain outlet in the East Fork of the San Luis Obispo Creek. While the East Fork of the San Luis Obispo Creek provides a hydraulic barrier to surface water flow, groundwater flowing below the creek continues onto the Site, influencing concentrations under the SLO Tank Farm. In February 2023, the Airport investigation collected sediment and surface water to identify potential off-site sources emanating upstream from Acacia Mr. Dan Niles February 9, 2024 arcadis.com Page: 8/18 Creek onto the Airport. The sampling identified PFAS detections in surface water ranging from 74 to 140 ng/L for PFOS; and 72 to 87 ng/L for PFHxS within Acacia Creek and upstream of Tank Farm Road (Roux Associates 2023; Figures 3A and 3B).  Union Pacific Railroad (UPRR) Tie Fire (Geotracker Case ID T10000012125): The UPRR Tie Fire is a known source of PFAS discharge to an upstream tributary of Acacia Creek, which flows onto the SLO Tank Farm. On 16 May 2018, two local fire departments (San Luis Obispo City and San Luis Obispo Regional Airport6) released 300 gallons of 3 percent (%) AFFF C-303 Foam Concentrate into the draining area of the creek in response to a fire of five UPRR rail cars containing railroad ties (Figure 1). The drainage channel in which the fire suppressant wastewater/AFFF mixture flowed through is a tributary of Acacia Creek, which borders the Southeast SLO Tank Farm property boundary, adjacent to the Airport (Figure 5). Two (2) separate investigations have occurred, and a third investigation is pending. Surface water within the tributary to Acacia Creek was sampled as part of the initial response investigation. Laboratory results from the surface water collected in the incident area and downstream channel indicated elevated PFAS concentrations within the creek. Sample L3, located 100 feet downstream of the incident area was reported to contain PFBS, PFHxS, PFOS, and PFOA concentrations of 5,200 ng/L, 32,000 ug/L, 58 ng/L, and 1,800 ng/L, respectively. Sample L4 consisted of surface water from the incident area and was reported to contain PFBS, PFHxS, PFOS, and PFOA concentrations of 4.5 ug/L, 39 ug/L, 59 ug/L, and 1.7 ug/L, respectively (Arcadis 2018b).  San Luis Auto Salvage Yard: San Luis Auto Salvage Yard maintains an active industrial stormwater discharge permit (Attachment B; Envrionmental.com Compliance Group 2015) for indirect discharge into the flood control storm channel on the Site, upgradient from the three (3) off-site water supply wells identified by the Regional Board in a letter dated August 7, 2020 (2020 Letter; Regional Board 2020). The United States Environmental Protection Agency (USEPA) recently released guidance summarizing PFAS considerations for stormwater discharges from auto salvage yards, recognizing that there are many sources of PFAS in these types of facilities and PFAS are likely present in the discharge from this type of industrial operation (USEPA 2021a). PFAS have been documented as used in various parts of automobiles including in the car body, engines, electronics, environmental systems, fuel systems, interiors, steering systems, suspension/brakes, and transmission (Gluge et al., 2020). No testing has been previously conducted to determine if this facility is a source of PFAS to the area. Due to the known presence of PFAS in auto salvage operations and the permitted stormwater discharge onto CEMC property, CEMC proposes to sample stormwater flowing from the San Luis Auto Salvage Yard during a precipitation event (Figure 5).  Metal Finishing: The USEPA has recently recognized metal finishing as a PFAS point source category requiring PFAS monitoring in National Pollutant Discharge Elimination System (NPDES) permits per Preliminary Effluent Guidelines Program Plan 15 (USEPA 2021b). At least two metal fabrication facilities are in close proximity to both the Site and three (3) off-site water supply wells identified by the Regional Board in a letter dated August 7, 2020 (2020 Letter; Regional Board 2020). No publicly available testing has been conducted to determine if these facilities are a source of PFAS in the area.  Circuit Board and Electronic Manufacturers: PFAS are known to be used by the electronics industry in the production of printed circuit boards and many other electronic products (Gluge et 6 California Department of Forestry and Fire Protection (CAL FIRE) operates the fire station at the airport under contract with San Luis Obispo County. Mr. Dan Niles February 9, 2024 arcadis.com Page: 9/18 al., 2020). At least two printed circuit board and electronic manufacturing facilities are in close proximity to both the Site and the three water supply wells identified by the Regional Board in a letter dated August 7, 2020 (2020 Letter; Regional Board 2020). No publicly available testing has been conducted to determine if these facilities are a source of PFAS in the area.  SLO WWTP (Geotracker Case ID NPD100051582): The San Luis Obispo Wastewater Treatment Plant (WWTP) is located less than a mile to the northwest of the Site (Figure 1). In a State and Regional Water Board’s questionnaire (Order WQ 2020-0015-DWQ), the WWTP indicated they accept a continuous flow of wastewater from a metal fabrication facility. Perfluoropentanoic acid (110 ng/L) was detected in a 2021 wastewater sample (2100976-01, collected on 2/11/21; Oilfield Environmental & Compliance, Inc 2021). While the biosolids and wastewater effluent have been tested for PFAS and shown to be “non-detect” for most measured PFAS in 2021 analyses, the detection limits on these samples is relatively high (>10,000 nanogram per kilogram [ng/kg] for biosolids and >50 ng/L for liquid samples) and all precursor PFAS are not measured in the analysis (City of San Luis Obispo Public Utilities 2021).  City of San Luis Obispo Fire Training Site: The SLO Tank Farm’s 2015 Remedial Action Plan identified an off-site fire training area northwest of the Site. The training area was used by the City of San Luis Obispo Fire Department and located adjacent to the WWTP (Avocet 2015). Municipal fire stations have been implicated as sources of PFAS to the environment through historical and current use and storage of AFFF (Young et al., 2021 and MPART 2024). No publicly available testing has been conducted to determine if this facility is a source of PFAS in the area.  City of San Luis Obispo Wastewater Lift Station: A municipal lift station associated with the WWTP is located adjacent to the Northwest Operations Area’s western boundary. In 2023, a solicitation request to replace several fittings, check valves, and 81 linear feet of 8” diameter pipe was submitted (California Bid Network 2023). A description of the solicitation request stated, “This project will replace failing discharge pipes.” No testing has been conducted to determine if this facility is a source of PFAS in the area. Neither a record of release nor investigation of the failing discharge pipe to identify potential environmental impacts have been identified in the records review.  Automotive Body Shops: PFAS have been previously identified as used in weather resistant paint, as well as in automotive waxes and polishes (Gluge et al., 2020). At least two autobody shops are in close proximity to the Site as well as the three (3) off-site water supply wells identified by the Regional Board in a letter dated August 7, 2020 (2020 Letter; Regional Board 2020). No publicly available testing has been conducted to determine if these facilities are a source of PFAS in the area. Review and evaluation of additional potential off-site sources of PFAS will continue. Figure 6 shows all potential facilities identified to date within one (1) mile of the SLO Tank Farm, which includes approximately 140 industrial and commercial properties potentially associated with PFAS usage such as aerospace, electronics, chemical/pesticide manufacturing, automobile repair, painting and metal work and salvage, metal coating etc.. Mr. Dan Niles February 9, 2024 arcadis.com Page: 10/18 2 PROPOSED SAMPLING LOCATIONS All sampling points proposed as part of this investigation are identified in Table 1. All media (e.g., soil, groundwater, sediment) will be sampled as part of the investigation. Sampling is designed to address the area around the former FFTA with additional surface water and stormwater sampling locations to identify potential contributors of PFAS to the SLO Tank Farm. 2.1 SOIL INVESTIGATION Eleven (11) Soil samples (BG-1 through BG-11) will be collected to assess background concentrations in the vicinity of the Site, to determine if there are elevated PFAS concentrations in soil and potentially associated with off-site sources, as well as for comparison purposes to verify whether the FFTA is a source of PFAS in soil (Figure 5). Nine (9) soil boring (FFTA-1 through FFTA-9) locations are proposed at and/or near the FFTA. The locations were selected based on the former footprint of the FFTA, specifically beneath and around the former training trench. One soil sample location, FFTA-9, was selected after ongoing records review identified the historic (1976) boiler fire box explosion in the Northwest Operation Area. It is unknown what materials were used to suppress the 1976 explosion. Two (2) soil sampling horizons will be collected, inclusive of the first native horizon and the capillary fringe to address prior soil disturbances associated with surface soil remediation. A first native soil sample is expected to be collected from approximately 7 to 8 feet below current ground surface at the FFTA. Eleven (11) background soil sample locations will be collected (North / South / East property boundaries and off-site to the west [BG-11]) from areas undisturbed by former Unocal Site operations at three (3) horizon depths for comparison purposes. The sampled soil horizon depths will include surface soil, a soil horizon that matches the first native FFTA soil locations, and the capillary fringe. The background locations were selected such that any historic operations at the FFTA would not have impacted soil in these areas. The background location results will undergo statistical analysis using the procedure outlined in the Unified Guidance provided by the USEPA, 2009 (USEPA 2009) and the most current version of USEPA statistical software package ProUCL. Appropriate nonparametric or comparison methods will be used to establish representative background soil concentrations, independent of potential operational impacts, for the SLO Tank Farm. Upon review of patents, the major components of Foamite powder are aluminum sulfate, sodium bicarbonate, and caustic soda treated licorice root extract (Houseman PA and Lacey 1929). Based on this composition, aluminum levels will be measured in soil from the FFTA samples and compared against results from locations BG-1 through BG-11. If a Foamite inorganic signature is detected under or near the FFTA, then it will support the determination that this type of non-PFAS containing foam was used during training. 2.2 GROUNDWATER INVESTIGATION To increase the accuracy of groundwater flow data at the SLO Tank Farm property, including the FFTA, up to seven (7) temporary piezometers will be installed within the unconsolidated overburden (silty and lean clays with interbeds of fine-grained silty sand and poorly to well-graded sands and gravels) within and along the perimeter of the Site to support a Site-wide hydraulic gradient evaluation. Each piezometer will be gauged and surveyed. The resulting water level information will be used to prepare a contoured potentiometric surface map to evaluate current groundwater flow directions across the Site. Initial data will be included in the supplemental work plan report. Following installation and initial gauging at each Mr. Dan Niles February 9, 2024 arcadis.com Page: 11/18 location, the piezometers will be left in place and groundwater gauging data recorded quarterly for up to one (1) year to identify any seasonal changes in data collection. The piezometers will then be abandoned. In accordance with the Regional Board’s 2022 and 2023 Letters to further investigate PFAS in groundwater at the FFTA (Regional Board 2022; Regional Board 2023), Chevron proposes eight (8) vertical aquifer profiling (VAP) with hydraulic profiling tool (HPT) locations hydraulically downgradient and cross-gradient of the FFTA (VAP-1 through VAP-4, and VAP-10 through VAP-13 locations shown on Figure 5). HPT borings will initially be advanced to obtain continuous horizontal hydraulic conductivity (K) profiles through alluvium and to determine specific VAP sampling intervals (high permeability zones). The HPT data will be reviewed nightly by the Arcadis project geologist to make informed decisions about subsequent VAP sampling intervals. The target VAP sampling intervals will be intentionally biased toward more permeable zones, where groundwater will be more readily available for sampling. Following completion of the HPT investigation, VAP step-outs will then be drilled at each of the eight (8) locations down- and cross-gradient from the FFTA to collect groundwater samples. Groundwater samples will be collected at five (5) or ten (10)-foot intervals from the water table to approximately 40 feet (or the bedrock interface) at three (3) of eight (8) downgradient/cross-gradient locations. The target groundwater sampling intervals and frequency will be determined based on HPT results, as discussed above. Five (5) of the eight (8) downgradient VAP-HPT locations will be advanced to approximately 20 feet below the top of the bedrock interface or until refusal (estimated total depth of 50 to 75 feet below native ground surface), with samples collected at five (5) or ten (10)-foot intervals. The FFTA downgradient VAP-HPT transect (VAP-1 through VAP-4) will be installed with approximately 80 linear feet of spacing between locations. In addition to the eight (8) borings near the FFTA, an additional three (3) VAP-HPT borings (VAP-5 through VAP-7 locations shown on Figure 5) will be advanced in a transect north and east (upgradient) of the FFTA, oriented generally perpendicular to groundwater flow. Furthermore, two (2) additional VAP/HPT locations will be advanced along the southeast property boundary (VAP-8 and VAP-9; Figure 5) to establish what, if any, concentrations and relative abundance/patterns of individual PFAS in shallow groundwater that may be flowing onto and across the Site from the Airport. These additional locations will be similarly drilled to approximately 20 feet below the top of the bedrock interface or until refusal (estimated total depth of 35 to 50 feet below current ground surface). Proposed groundwater evaluation locations for background and the FFTA are shown on Figure 5. If results of the potentiometric surface map identify a groundwater flow direction that is different from expected, the three (3) perimeter groundwater investigation locations (VAP-5, VAP-6, and VAP-7) may be modified. Additionally, vertical hydraulic conductivity will be evaluated by advancing a step-out location through alluvium to the bedrock interface at each of the thirteen (13) VAP-HPT borehole locations. Undisturbed soil cores will be collected by Shelby tube (or equivalent) and submitted for laboratory vertical permeability and geophysical parameter analysis. If possible, drilling will be conducted without the addition of drilling fluids. If drilling fluids are required based on drilling conditions, then fluorescein dye will be added to the drilling fluids. During subsequent groundwater sampling, the tracer dye will be used to visually confirm when unimpacted native groundwater enters the borehole. The tracer dye would be used to identify the dilution of groundwater by drilling fluids and if correction factors/groundwater purging is required to collect a representative sample. Any use of fluorescein dye as a drilling fluid additive will be in accordance with Central Coast Regional Water Board Order R3-2019-0089. Mr. Dan Niles February 9, 2024 arcadis.com Page: 12/18 2.3 SEDIMENT AND SURFACE WATER INVESTIGATION In accordance with the Regional Board’s 2022 Letter to investigate PFAS in sediment (Regional Board 2022), Chevron proposes eight (8) sediment and surface water sampling locations at the various creeks and surface drainages that enter or cross the SLO Tank Farm property. The locations were selected based on creek flow paths and property entry points. One (1) location was selected based on its downstream proximity to the Airport stormwater outfall #6 and drain outlet location (Figure 5). Sediment and surface water samples collected will inform whether detectable concentrations of PFAS in sediment and surface water may be from upgradient/upstream surface water flow direction either leading towards the FFTA or traversing the creek along the southeast property boundary. Though surface water samples were not specifically requested by the Regional Board, results of sediment and surface water sampling will expand the dataset collected during the Airport’s investigation of sediment and surface water in Acacia Creek (Figures 3A and 3B). In addition to expanding the Airport investigation dataset, results will be used to identify possible PFAS contamination from Airport runoff and during flooding events that frequently occur at the Site. Proposed sediment and surface water sampling locations are shown on Figure 5. Sediment samples will be collected from the upper 0 to 6 inches of native creek bed sediment using dedicated Push Core Lexan tubes. The tube will be driven with a straight vertical entry into the top 6 inches of native sediment at the pre-determined locations. The tube will then be capped with a PFAS-free high-density polyethylene (HDPE) liner on either end. An alternative approach may be used depending on field conditions, including use of a stainless-steel scoop or trowel if the creeks are not flowing. All equipment will be thoroughly decontaminated, or single use, in accordance with Arcadis’ PFAS guidance documents (Arcadis 2021; Attachment E of the 2023 Supplemental Work Plan). 2.4 STORMWATER INVESTIGATION A stormwater outfall from the adjacent San Luis Auto Salvage Yard (Figure 5) was identified during review of potential off-site sources of PFAS (Environmental.com Compliance Group 2015). Due to the outfall’s proximity to the off-site supply wells and potential for PFAS conveyance onto the Site, Arcadis proposes the collection of one stormwater sample immediately downstream of the stormwater outfall, on CEMC property. A stormwater sample will be collected from location SW-1 (Figure 5) within four hours of the start of discharge from a Qualified Storm Event (QSE) rain event, which is defined as “any precipitation event that produces a discharge for at least one drainage area and is preceded by 48 hours with no discharge from any drainage area. Weather and precipitation forecasts will be tracked to identify potential QSEs. When targeting a QSE for stormwater sampling, the appropriate team member will weekly consult the National Oceanographic and Atmospheric Administration for weather forecasts. These forecasts can be obtained at http://www.srh.noaa.gov/. If weekly forecasts indicate potential for significant precipitation, the weather forecast will be closely monitored during the 48 hours preceding the event (California Stormwater Quality Association 2014). An exact sampling date is thus unknown for the planned stormwater sample collection following work plan approval. Sampling will be performed in accordance with the Arcadis-Chevron PFAS Field Sampling Guidance (Arcadis 2021; Attachment E of the 2023 Supplemental Work Plan). Mr. Dan Niles February 9, 2024 arcadis.com Page: 13/18 3 SAMPLING METHODOLOGY Arcadis’ PFAS sampling guidance provides PFAS-specific instructions on how to sample various environmental media for analysis of PFAS consistent with the Interstate Technology Regulatory Council’s (ITRC’s) Site Characterization Considerations, Sampling Precautions, and Laboratory Analytical Methods for PFAS (Attachment D of the 2023 Supplemental Work Plan). These instructions include restrictions on the use of materials that can introduce PFAS through cross-contamination. Soil sampling will be performed in accordance with the PFAS Sampling and Analysis Guidance for Chevron Corporation (Arcadis 2021; Attachment E of the 2023 Supplemental Work Plan). VAP groundwater PFAS sampling will be performed via a low-flow sampling method using either a stainless- steel or peristaltic pump and HDPE and silicone tubing, in accordance with the September 2020 California State Water Quality Control Board PFAS Sampling Guidelines for Non-Drinking Water (California State Water Quality Control Board 2020), Arcadis guidance on PFAS Sampling Procedures (Arcadis 2018a), Low-Flow Groundwater Purging for Monitoring Wells and the Arcadis-Chevron PFAS Field Sampling Guidance (Arcadis 2020; Attachment E of the 2023 Supplemental Work Plan), and Arcadis’ Technical Guidance Instruction for VAP sampling with considerations for PFAS substances (Arcadis 2022b; Attachment F of the 2023 Supplemental Work Plan). Water quality parameters, which include dissolved oxygen (DO), conductivity, temperature, pH, and turbidity, will be measured through a flow cell (Table 2 below). Samples will be centrifuged by the analytical laboratory if the final recorded turbidity parameter is above 10.0 nephelometric turbidity units (NTU). Sediment and surface water sampling will be performed in accordance with the PFAS Sampling and Analysis Guidance for Chevron Corporation (Arcadis 2021; Attachment E of the 2023 Supplemental Work Plan), updated to incorporate the Board request to use (draft) EPA Method 1633. The samples will be shipped by priority overnight to Eurofins Lancaster Laboratories (Eurofins) in Lancaster, Pennsylvania. Table 2. Field Parameter List Applicable to Groundwater Samples From each groundwater investigation location, undisturbed soil cores will be collected from the native formation for vertical permeability testing and geophysical parameters to assess hydraulic properties and the potential for vertical PFAS migration. At each selected groundwater investigation location, an undisturbed soil core sample will be collected by advancing Shelby Tubes (or equivalent). Continuous soil cores will be collected from the unconsolidated aquifer. The soil core samples will be submitted to a certified laboratory for analysis of vertical permeability and geophysical parameters listed in Table 3 below. Field Parameters Depth to Water DO Temperature Electrical Conductivity pH Turbidity Mr. Dan Niles February 9, 2024 arcadis.com Page: 14/18 Table 3. Vertical Permeability and Geophysical Parameters Applicable to Groundwater Investigation Locations 3.1 QUALITY ASSURANCE/QUALITY CONTROL As part of the field quality assurance/quality control (QA/QC), matrix spike/matrix spike duplicate (MS/MSD) samples, field blanks, equipment blanks, and field duplicate samples (Table 1) will be collected in accordance with the Quality Assurance Project Plan (QAPP) requirements (Attachment H of the 2023 Supplemental Work Plan), updated to accommodate the Board request to use (draft) EPA Method 1633. 4 LABORATORY ANALYSES The proposed sampling analyte list and their target reporting limits for PFAS analytes are shown in Table 4. At the request of the Regional Board, the constituent list to be tested for has been updated to match the State Water Board’s December 6, 2022, “Target Reporting Limits” table (2023 Letter; Regional Board 2023). PFAS analysis will be completed using EPA draft Method 1633 unless noted otherwise. Three PFAS compounds (10:2 Fluorotelomer sulfonic acid, Perfluorooctadecanoic acid, and Perfluorohexadecanoic acid) requested by the Regional Board cannot be analyzed by draft Method 1633 and will therefore be analyzed using EPA method 537 Version 1.1 modified. No other compounds will be reported using EPA method 537 Version 1.1 modified besides the three compounds identified previously. The laboratory will provide a Level IV fully documented data deliverable. Environmental Standards, Inc. will perform a third-party data validation and data usability summary report. A QAPP provides data quality objectives and additional QA/QC protocols to be used in data collection activities. The QAPP will be used during the project execution and data evaluation and was provided in Attachment H of the 2023 Supplemental Work Plan. The QAPP will undergo updates prior to the field investigation to accommodate the Board request to use (draft) EPA Method 1633 in conjunction with the three compounds being analyzed by EPA method 537 Version 1.1 modified. Parameters Vertical permeability in accordance with ASTM International (ASTM) standard test method ASTM D5084 Porosity in accordance with ASTM D7263 T Grain size distribution in accordance with ASTM D6913 Particle size distribution of fine-grained soil (between 75 and 0.2 micrometer) in accordance with ASTM D7928 Moisture content in accordance with ASTM D2216 Mr. Dan Niles February 9, 2024 arcadis.com Page: 15/18 5 REPORTING After the investigation is complete and laboratory data are received and validated, Arcadis will prepare an investigation report summarizing the sampling and analytical results. Geotracker reporting will be completed. 6 SCHEDULE The PFAS investigation event is tentatively scheduled to be performed upon the Regional Board’s approval of this Work Plan. Arcadis will initiate the sampling work described above within 90 days of the Regional Board’s approval. An investigation report with results will be provided to the Regional Board within 90 days of receipt of final validated laboratory results. The final validated laboratory data will be uploaded to GeoTracker. Please direct any questions, comments, or correspondence regarding this project to Steve Rice, Arcadis Project Manager and copy Owen Ranta and James Beacom of CEMC on all written correspondences. Sincerely, Arcadis U.S., Inc. Steve Rice Program Manager Copies: Johnsie Lang, Arcadis Owen Ranta, CEMC James Beacom, CEMC Enclosures: Tables 1 Sampling Locations and Methods 2 Field Parameter List Applicable to Groundwater Samples (in text) 3 Vertical Permeability and Geophysical Parameters Applicable to Groundwater Investigation Locations (in text) 4 PFAS Analyte List Figures 1 Site Location Map 2 Water Well Analytical Results 3A Sediment PFAS Concentrations – Acacia Creek 3B Surface Water PFAS Concentrations – Acacia Creek Mr. Dan Niles February 9, 2024 arcadis.com Page: 16/18 4 Northwest Operations Area – Features and Proposed Soil Sampling Points 5 Proposed Sampling Locations 6 Potential PFAS Source Locations Attachments A Response to Regional Board’s Comments Provided in 2023 Letter B San Luis Auto Salvage Industrial Stormwater Discharge Permit Documentation References Arcadis. 2018a. PFAS Sampling Procedures and Low-Flow Groundwater Purging for Monitoring Wells. June 19. Arcadis 2018b. Tie Fire Response Summary Report, San Luis Obispo, CA – May 16, 2018 Tie Fire Incident. October 5. Arcadis. 2020. Per- and Polyfluoroalkyl Substances Sampling Work Plan, San Luis Obispo Tank Farm, San Luis Obispo, California. September 30. Arcadis. 2021. Poly- and Perfluoroalkyl Substance (PFAS) Sampling and Analysis Guidance for Chevron Corporation. June 25. Arcadis. 2022. Per- and Polyfluoroalkyl Substances Sampling Results Investigation Report, San Luis Obispo Tank Farm, San Luis Obispo, California. January 21. Arcadis. 2022b. TGI – Vertical Aquifer Profile (VAP) Sampling. Rev: 2.0. June 15. Arcadis. 2023. Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan, San Luis Obispo Tank Farm, San Luis Obispo, California. March 17. Avocet Environmental, Inc. 2011. Technical Memorandum: Environmental Issues Concerning Future Water Supply Wells, Former San Luis Obispo Tank Farm, San Luis Obispo, California. Prepared for Bill Almas, Chevron Business and Real Estate Services. December 2. Avocet. 2015. Final Remedial Action Plan, San Luis Obispo Tank Farm, 276 Tank Farm Road, San Luis Obispo, California. March 31. California Stormwater Quality Association. 2014. Stormwater Pollution Prevention Template, BMP Handbook Portal: Industrial and Commercial. September. California State Water Quality Control Board. 2020. Per- and Polyfluoroalkyl Substances (PFAS) Sampling Guidelines for Non-Drinking Water. September. California Bid Network. 2023. Tank Farm Lift Station Discharge Pipe Replacement. https://www.californiabids.com/bid_opportunities/2023/10/11/12959065-tank-farm-lift-station- discharge-pipe-replacement.html. Accessed January 11, 2024. City of San Luis Obispo Public Utilities. 2021. City of San Luis Obispo Water Resource Recovery Facility PFAS Summary Report. March 13. Dibblee, T.W. Jr. 2004. Geologic Map of the San Luis Obispo Quadrangle, California. Mr. Dan Niles February 9, 2024 arcadis.com Page: 17/18 England Geosystem, Inc. 2002. Supplemental Site Characterization Report, Unocal San Luis Obispo Tank Farm, San Luis Obispo, California. Prepared for Central Coast Group, Unocal Corporation. January 10. Environmental.com Compliance Group. 2015. Storm Water Pollution Prevention Plan, San Luis Auto Salvage. Waste Discharge Identification Number 3 40I024911. August 10. Five Cities Times-Press-Recorder (Arroyo Grande, California), 1976. Industrial Fire Drills Scheduled. Friday, November 5, 1976. Retrieved from: Microsoft Outlook - Memo Style (ca.gov) Foamite equipment patents (various). 1918-1960. Foamite Firefoam. 1925. Extinguishing Oil and Other Fires; the Foamite Firefoam Method. Retrieved from: https://archive.org/details/ExtinguishingOilAndOtherFiresTheFoamiteFirefoamMethod Gluge, J. et al. 2020. “An Overview of The Uses of Per- and Polyfluoroalkyl Substances (PFAS).” The Royal Society of Chemistry. Environmental Science Processes & Impacts, 22, 2346. Houseman, P.A. and Lacey, H.T. 1929. “The Licorice Root in Industry” Industrial and Engineering Chemistry. October. 915–917. The Licorice Root in Industry (acs.org) ITRC. 2020. PFAS – Section 3: Firefighting Foams. April 14. Retrieved from: https://pfas-1.itrcweb.org/3- firefighting-foams/#3_1 Marine Research Specialists. 2013. Chevron Tank Farm Remediation and Development Project, Final Environmental Impact Report. December. Michigan PFAS Action Response Team. 2024. Firefighting Foam and PFAS. https://www.michigan.gov/pfasresponse/investigations/firefighting-foam. Accessed February 8. Oilfield Environmental & Compliance, Inc. 2021. Analytical Report for Project WWTP PFAS. March 23. Padre. 2019. 2018 Annual Summary Report, Remediation and Restoration Activities. Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April. Regional Board. 2020. Site Cleanup Program: Chevron (Former Unocal) – Tank Farm Road Bulk Storage, 276 Tank Farm Road, San Luis Obispo, San Luis Obispo County – Requirement for PFAS Investigation Workplan Pursuant to California Water Code 13267. August 7. Regional Board. 2022. Site Cleanup Program: Chevron (Former Unocal) – Tank Farm Road Bulk Storage, 276 Tank Farm Road, San Luis Obispo, San Luis Obispo County – Denial of No Further Action and Requirements to Comply with California Water Code 13267 Order Dated August 7, 2020. December 9. Regional Board. 2023. Site Cleanup Program: Chevron (Former Unocal) – Tank Farm Road Bulk Storage, 276 Tank Farm Road, San Luis Obispo, San Luis Obispo County – Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan. October 23. Roux Associates, Inc. 2022. Supplemental PFAS Investigation Report. San Luis Obispo County Regional Airport, 975 Airport Drive, San Luis Obispo, California. July 29 Roux Associates, Inc. 2023. Per- and Polyfluoroalkyl Substances (PFAS) Site Conceptual Model. San Luis Obispo County Regional Airport, 975 Airport Drive, San Luis Obispo, California. October 19. San Luis Obispo County Telegram – Tribune, 1985. County Digest – Training Fire Tuesday. Wednesday October 30, 1985. Retrieved from: Microsoft Outlook - Memo Style (ca.gov) Mr. Dan Niles February 9, 2024 arcadis.com Page: 18/18 Santa Maria Times. 1972. Union Oil Fire School announcement. Tuesday March 14, 1972. Retrieved from: Microsoft Outlook - Memo Style (ca.gov) Seventy Six. Fall 1988. Retrieved from: https://static1.1.sqspcdn.com/static/f/765516/27948662/1531847651683/Fall+1988.pdf?token=XxTJo Dg7gR5C7VgMlcQKpjoZxmk%3D Trihydro. 2020. 2019 Annual Summary Report, Remediation and Restoration Activities, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 15. Trihydro. 2021. 2020 Annual Summary Report, Remediation and Restoration Activities, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 15. Unocal. 1956. Revised 1981. Fire Protection Map, San Luis Obispo Tank Farm, San Luis Obispo Dist., San Luis Obispo County, Calif. Sheet D2A713. Union Oil Company of California. July 27. Unocal. 1991. General Arrangement San Luis Obispo Tank Farm Northern California Division Pipeline. Unocal Corporation. Los Angeles, CA. January. United States Environmental Protection Agency. 2009. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities. Unified Guidance. March. United States Environmental Protection Agency. 2021a. Industrial Stormwater Fact Sheet Series, Sector M: Automobile Salvage Yards. EPA-883-F-06-028. February. United States Environmental Protection Agency. 2021b.Preliminary Effluent Guidelines Program Plan 15. EPA-HQ-OW-2021-0547; FRL-5601.5-01-OW. Federal Register. Volume 86, Number 175. September 14. United States Environmental Protection Agency. 2024. PFAS Analytic Tools. https://awsedap.epa.gov/public/extensions/PFAS_Tools/PFAS_Tools.html. Accessed January 11. Young et al. 2021. Per- and Polyfluoroalkyl Substances (PFAS) and Total Fluorine in Fire Station Dust. J Expo Sci Environ Epidemiol. September 31 (5): 930-942. Tables Table 1 Sampling Locations and Methods San Luis Obispo Tank Farm San Luis Obispo, California Page: 1/4 Sample Type Medium Location ID Rationale Sample Collection Location Sample Method Sample Type Number of Samples Analytes San Luis Obispo Tank Farm Soil FFTA-1 Former fire school AST location First native and capillary fringe Grab N 2 PFAS / Aluminum FFTA-2 Former fire school AST location N 2 FFTA-3 Former fire school location N 2 FFTA-4 West perimeter of FFTA Trench N 2 FFTA-5 North perimeter of FFTA Trench N 2 FFTA-6 East perimeter of FFTA Trench N 2 FFTA-7 South perimeter of FFTA Trench N 2 FFTA-8 Center of FFTA Trench N 2 FFTA-9 Beneath historic boiler N 2 BG-1 Northwest property boundary Surface, horizon matching first native from FFTA, and capillary fringe N, MS/MSD, FD 5 BG-2 North/central property boundary N, MS/MSD, FD 5 BG-3 North/central property boundary N, MS/MSD, FD 5 BG-4 Northeast property boundary N 3 BG-5 Northeast property boundary N 3 BG-6 East property boundary N 3 BG-7 East property boundary, south of tank farm road N 3 BG-8 Southeast property boundary N 3 BG-9 Southeast property boundary N 3 BG-10 Southeast property boundary N 3 BG-11 Off property – west of FFTA N 3 San Luis Obispo Tank Farm Groundwater / soil lithology VAP-1 Downgradient of FFTA; to bedrock interface High “K” zone, every 5’ to 10’ Low flow N 3 to 8 PFAS / HPT / Permeability / Geophysical Parameters VAP-2 Downgradient of FFTA; to bedrock interface Low flow N 3 to 8 Table 1 Sampling Locations and Methods San Luis Obispo Tank Farm San Luis Obispo, California arcadis.com Page: 2/4 Sample Type Medium Location ID Rationale Sample Collection Location Sample Method Sample Type Number of Samples Analytes VAP-3 Downgradient of FFTA; to bedrock interface+20 feet Low flow N 7 to 14 VAP-4 Downgradient of FFTA; to bedrock interface Low flow N 3 to 8 VAP-5 Upgradient of FFTA; to bedrock interface+20 feet Low flow N, MS/MSD, FD* 13 to 20 VAP-6 Upgradient of FFTA; to bedrock interface+20 feet Low flow N, MS/MSD, FD* 13 to 20 VAP-7 East property boundary; to bedrock interface+20 feet Low flow N, MS/MSD, FD* 13 to 20 VAP-8 Southeast property boundary; to bedrock interface+20 feet Low flow N 7 to 14 VAP-9 South property boundary; to bedrock interface+20 feet Low flow N 7 to 14 VAP-10 Downgradient of FFTA and south of Tank Farm Rd; to bedrock interface+20 feet Low flow N 7 to 14 VAP-11 Cross gradient of FFTA at unnamed creek; to bedrock interface+20 feet Low flow N 7 to 14 VAP-12 Cross gradient of FFTA and adjacent to sewer pumphouse; to bedrock interface+20 feet Low flow N 7 to 14 VAP-13 Offsite and Cross gradient of FFTA; to bedrock interface+20 feet Low flow N 7 to 14 San Luis Obispo Tank Farm Stormwater SW-1 Downgradient of San Luis Auto Salvage Yard Stormwater Discharge, on Chevron property Stormwater, during precipitation event Grab N 1 PFAS San Luis Obispo Tank Farm Sediment and Surface Water (collocated) SED -2 SW-2 West Fork of Tank Farm Creek entry onto property Upper 6-inches of native creek bed and surface water Grab N 2 PFAS / Moisture Content (sediment only) SED-3 SW-3 East Fork of Tank Farm Creek entry onto property Grab N, MS/MSD, FD 6 SED-4 SW-4 Acacia Creek entry onto property Grab N 2 SED-5 SW-5 Acacia Creek, downstream of Airport Outfall Grab N 2 Table 1 Sampling Locations and Methods San Luis Obispo Tank Farm San Luis Obispo, California arcadis.com Page: 3/4 Sample Type Medium Location ID Rationale Sample Collection Location Sample Method Sample Type Number of Samples Analytes SED-6 SW-6 Drainage leading from NW Operations Area, at Tank Farm Road culvert Grab N 2 SED-7 SW-7 Tank Farm Creek, at Tank Farm Road culvert Grab N 2 SED-8 SW-8 Tank Farm Creek, downstream of Tank Farm Road Grab N 2 SED-9 SW-9 Downgradient of the San Luis Auto Salvage Yard stormwater discharge, within drainage feature on Chevron property Grab N 2 Equipment Blanks PFAS-Free Water SLO-EB-X Stainless steel hand auger, stainless-steel trowel, or acetate liner (soil sampling) See Section 4.1 EB Variable, up to 55 PFAS SLO-EB-X Drilling cutting shoe (VAP) 13 SLO-EB-X Clean HDPE tubing 1 SLO-EB-X Submersible Pump Variable, one per groundwater sample location (up to 180) SLO-EB-X Depth to water meter Variable, one per groundwater sample location (up to 180) SLO-EB-X Lexan tube or stainless-steel trowel (sediment) Variable, up to 8 Field Blanks PFAS-Free Water SLO-FB- X- MMDDYY YY One per day. N/A FB One per day PFAS Table 1 Sampling Locations and Methods San Luis Obispo Tank Farm San Luis Obispo, California arcadis.com Page: 4/4 Notes: EB = equipment blank MS/MSD = matrix spike/matrix spike duplicate FB = field blank N = normal FD = field duplicate N/A = not applicable HDPE = high-density polyethylene TBD = To be determined *If a fourth, or fifth, MS/MSD is needed during groundwater sampling (due to QAPP frequency requirements – 1/20 samples), the final MS/MSD will be collected from the deepest sampled interval at VAP-4, VAP-5, and VAP-6, in addition to the shallow interval. Table 4 PFAS Analyte List San Luis Obispo Tank Farm San Luis Obispo, California Chemical Abstracts Service (CAS) No. Perfluoroundecanoic acid PFUA/PFUdA 2058-94-8 2.00 0.500 0.200 0.0500 Perfluorotridecanoic acid PFTriA/PFTrDA 72629-94-8 2.00 0.500 0.200 0.0500 Perfluorotetradecanoic acid PFTA/PFTeDA)376-06-7 2.00 0.500 0.200 0.0500 Perfluoropentanoic acid PFPeA 2706-90-3 4.00 1.00 0.400 0.100 Perfluorododecanesulfonic acid PFDoS 79780-39-5 2.00 0.900 0.200 0.0500 Perfluoropentanesulfonic acid PFPeS 2706-91-4 2.00 0.500 0.200 0.0500 Perfluorooctanoic acid PFOA 335-67-1 2.00 0.640 0.200 0.0510 Perfluorooctanesulfonic acid PFOS 1763-23-1 2.00 0.500 0.200 0.0510 Perfluorooctanesulfonamide PFOSA 754-91-6 2.00 0.500 0.200 0.0500 Perfluorooctadecanoic acid*PFODA 16517-11-6 3.00 1.00 0.600 0.200 Perfluorononanoic acid PFNA 375-95-1 2.00 0.500 0.200 0.0500 Perfluorononanesulfonic acid PFNS 68259-12-1 2.00 0.400 0.200 0.0500 Perfluorohexanoic acid PFHxA 307-24-4 2.00 0.500 0.200 0.0590 Perfluorohexanesulfonic acid PFHxS 355-46-4 2.00 0.570 0.200 0.0500 Perfluorohexadecanoic acid*PFHxDA 67905-19-5 3.00 1.00 0.600 0.200 Perfluoroheptanoic acid PFHpA 375-85-9 2.00 0.520 0.200 0.0500 Perfluoroheptanesulfonic acid PFHpS 375-92-8 2.00 0.400 0.200 0.0500 Perfluorododecanoic acid PFDoDA 307-55-1 2.00 0.500 0.200 0.0500 Perfluorodecanoic acid PFDA 335-76-2 2.00 0.500 0.200 0.0500 Perfluorodecanesulfonic acid PFDS 335-77-3 2.00 0.500 0.200 0.0500 Perfluorobutanoic acid PFBA 375-22-4 8.00 2.00 0.800 0.100 Perfluorobutanesulfonic acid PFBS 375-73-5 2.00 0.300 0.200 0.0500 N-methyl perfluorooctanesulfonamido ethanol N-MeFOSE 24448-09-7 20.0 5.00 2.00 0.500 N-methyl perluorooctanesulfonamide NMeFOSA 31506-32-8 2.00 0.500 0.200 0.0500 N-methylperfluorooctanesulfonamidoacetic acid N-MeFOSAA 2355-31-9 4.00 1.20 0.200 0.0500 N-ethyl perfluorooctanesulfonamido ethanol N-EtFOSE 1691-99-2 20.0 5.00 2.00 0.500 N-ethyl perfluorooctanesulfonamide N-EtFOSA 4151-50-2 2.00 0.500 0.200 0.0500 N-ethylperfluorooctanesulfonamidoacetic acid N-EtFOSAA 2991-50-6 2.00 0.700 0.200 0.0500 Hexafluoropropylene Oxide Dimer Acid HFPO-DA 13252-13-6 8.00 2.00 0.800 0.0510 4,8-Dioxa-3H-perfluorononanoic acid ADONA 919005-14-4 8.00 1.50 0.800 0.200 9-Chlorohexadecafluoro-3-oxanonane-1-sulfonic acid 9-Cl-PF3ONS 756426-58-1 8.00 1.00 0.800 0.200 11-Chloroeicosafluoro-3-oxaundecane-1-sulfonic acid 11-Cl-PF3OdS 763051-92-9 8.00 2.00 0.800 0.200 10:2 Fluorotelomer sulfonic acid*10:2 FTS 120226-60-0 5.00 1.00 2.00 0.600 8:2 Fluorotelomer sulfonic acid 8:2 FTS 39108-34-4 8.00 2.60 1.00 0.350 6:2 Fluorotelomer sulfonic acid 6:2 FTS 27619-97-2 8.00 2.50 1.00 0.350 4:2 Fluorotelomer sulfonic acid 4:2 FTS 757124-72-4 8.00 1.70 0.800 0.200 Perfluoro-3-methoxypropanoic acid PFMPA 377-73-1 4.00 0.500 0.400 0.104 Perfluoro(4-methoxybutanoic acid)PFMBA 863090-89-5 4.00 0.100 0.400 0.100 Perfluoro-3,6-dioxaheptanoic acid NFDHA 151772-58-6 4.00 0.100 0.400 0.100 Perfluoro (2-ethoxyethane) sulfonic acid PFEESA 113507-82-7 4.00 0.500 0.400 0.100 2H, 2H, 3H, 3H-perfluorohexanoic acid 3:3 FTCA 356-02-5 10.0 1.50 1.00 0.250 2H, 2H, 3H, 3H-perfluorooctanoic acid 5:3 FTCA 914637-49-3 50.0 10.0 5.00 1.00 2H, 2H, 3H, 3H-perfluorodecanoic acid 7:3 FTCA 812-70-4 50.0 10.0 5.00 1.00 Notes: ng/L = nanogram per liter ng/g = nanogram per garm * = To be analyzed using EPA Method 537.1 Modified All other chemicals to be analyzed by EPA Draft Method 1633 Chemical Name Abbreviation Groundwater Minimum Detection Limit (ng/L) Soil Minimum Detection Limit (ng/g) Soil/Sediment Reporting Limit (ng/g) Groundwater Reporting Limit (ng/L) Page 1 of 1 Figures Union Pacific Rail Road Tie Fire San Luis Auto Salvage City of San Luis Obispo Wastewater Tank Farm Lift Station City of San Luis Obispo Wastewater Treatment Plant City of San Luis Obispo Fire Training Site San Luis Obispo Regional County Airport 35°15'50"N35°15'40"N35°15'30"N35°15'20"N35°15'10"N35°15'0"N35°14'50"N35°14'40"N35°14'30"N35°14'20"N35°14'10"N35°14'0"N35°13'50"N35°15'40"N35°15'30"N35°15'20"N35°15'10"N35°15'0"N35°14'50"N35°14'40"N35°14'30"N35°14'20"N35°14'10"N35°14'0"N35°13'50"N35°13'40"N120°38'0"W120°38'10"W120°38'20"W120°38'30"W120°38'40"W120°38'50"W120°39'0"W120°39'10"W120°39'20"W120°39'30"W120°39'40"W120°39'50"W120°40'0"W120°40'10"W120°40'20"W120°40'30"W120°40'40"W120°40'50"W120°41'0"W120°41'10"W120°41'20"W120°41'30"W 120°37'50"W120°38'0"W120°38'10"W120°38'20"W120°38'30"W120°38'40"W120°38'50"W120°39'0"W120°39'10"W120°39'20"W120°39'30"W120°39'40"W120°39'50"W120°40'0"W120°40'10"W120°40'20"W120°40'30"W120°40'40"W120°40'50"W120°41'0"W120°41'10"W120°41'20"W 0 1,500 3,000 SCALE IN FEET I SITE LOCATION MAP User Name: ski01076 DATE: 2/8/2024 1:05 PMPATH: T:\_ENV\Chevron_PFAS_SLO_Tank_Farm\MXD\2023\Chevron_PFAS_SLO_Tank_Farm_2023.aprxTOPOGRAPHIC SOURCE: U.S. Geological Survey https://ngmdb.usgs.gov/topoview/ REFERENCES: USGS Topographic Quadrangles: San Luis Obispo, Lopez Mountain, Pismo Beach, and Arroyo Grande NE, California 7.5-Minute Series PROJECTIONS: NAD 1983 State Plane California V Feet FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA FIGURE 1 P a c i f i c O c e a n Site Location California Nevada Utah Oregon Idaho Arizona <<<!(@A !(@A !(@A!(@A !(@A!(@A!(@A !(@A !(@A !(@A !< !< @A @A @A @A @A@A @A @A @A @A @A @A @A @A@A !< !< !< !< !( !( !(!( !( !(!( !( !( Water Supply Well (SW) MW-3 Copeland S. Properties, Well 01 AcaciaCreekWhitson Industrial Park, Well 01 Holdgrafer & Associates, Well 01 11-LA MW-18 MW-35 MW-29MW-43 MW-45 MW-38MW-39 MW-47 MW-26 MW-27 MW-40 SLOW-17 MW-49 SLOW-18 SLOW-12MW-56R MW-50 MW-48S MW-53D MW-48D MW-53S MW-41 MW-19 MW-17 36" Diameter Gate Valve Water Supply Well (NW)OrcuttCre e k Orcutt Creek East ForSan Luis Obispo Creek W estForkTank Far m CreekTankFarm C re e kT r ib u t a ry to EastForSanLuisObispoCreekE a s t F o rk T a nk Farm C r e e k Acadia Cree k PW-65 PW-63 PW-66 PW-56 PW-57 Well 01 (CA4000726) Well 01 (CA4000216) MW-5 MW-6 35°15'0"N35°14'30"N35°15'0"N35°14'30"N120°39'0"W120°39'30"W120°40'0"W 120°39'0"W120°39'30"W120°40'0"W 0 600 1,200 SCALE IN FEET I WATER WELL ANALYTICAL RESULTS User Name: ski01076 DATE: 1/24/2024 11:58 AMPATH: T:\_ENV\Chevron_PFAS_SLO_Tank_Farm\MXD\2023\Chevron_PFAS_SLO_Tank_Farm_2023.aprxFIGURE 2 Notes: 1. Method: 537.1 (modified) - Per- and Polyfluoroalkyl Substances (PFAS; ng/L) 2. Bold results indicate a concentration measured at or above the method detection limit. 3. ft btoc = feet below top of casing 4.* = GSI Water Solutions, Inc. 2022. San Luis Obispo Valley Groundwater Basin Annual Report (Water Years 2020-2021). San Luis Obispo Basin Groundwater Sustainability Committee and the Groundwater Sustainability Agencies. March 24. 5. ** = Roux Associates, Inc. 2023. Per- and Polyfluoroalkyl Substances (PFAS) Site Conceptual Model, San Luis Obispo County Regional Airport, 975 Airport Drive, San Luis Obispo, California. October 19. 6. Orange = Chevron Monitoring Well Results 7. Pink = Offsite Groundwater Supply Well Results 8. Purple = Airport Groundwater Results 9. ng/L = nanogram per liter 10. J = The concentration is an approximate value because it is less than the reporting limit but greater than or equal to the method detection limit. Legend !(Private Well Sampled For PFAS** Groundwater Sampling Location @A Groundwater Monitoring Well (Active) !<Groundwater Supply Well (Active) Current Stream Channel <Direction of Groundwater Flow* Former Fire Training Area Site Boundary !(Airport Well** Well Name MW-5P MW-5 Sample Date 5/6/2020 5/6/2020 Well Screen Interval (ft btoc)18.5' - 28.5'34' - 44' Perfluorooctanoic acid (PFOA)53 54 Perfluorobutanesulfonic acid (PFBS)44 47 Perfluorohexanesulfonic acid (PFHxS)150 B 180 B Perfluorooctanesulfonic acid (PFOS)430 480 Well Name MW-6P MW-6 Sample Date 5/5/2020 5/5/2020 Well Screen Interval (ft btoc)9.5' - 19.5'36.5' - 51.5.' Perfluorooctanoic acid (PFOA)35 3.7 Perfluorobutanesulfonic acid (PFBS)34 4.5 Perfluorohexanesulfonic acid (PFHxS)130 B 15 B Perfluorooctanesulfonic acid (PFOS)180 B 4.6 B Well Name PW-56 Sample Date 11//9/2022 Screen unknown Perfluorooctanoic acid (PFOA)58 Perfluorobutanesulfonic acid (PFBS)59 Perfluorohexanesulfonic acid (PFHxS)310 Perfluorooctanesulfonic acid (PFOS)73 Well Name PW-57 Sample Date 4/13/2023 Screen unknown Perfluorooctanoic acid (PFOA)14 Perfluorobutanesulfonic acid (PFBS)38 Perfluorohexanesulfonic acid (PFHxS)160 Perfluorooctanesulfonic acid (PFOS)48 Well Name PW-65 Sample Date 5/31/2023 Screen unknown Perfluorooctanoic acid (PFOA)5.8 Perfluorobutanesulfonic acid (PFBS)22 Perfluorohexanesulfonic acid (PFHxS)78 Perfluorooctanesulfonic acid (PFOS)23 Well Name PW-66 Sample Date 5/31/2023 Screen unknown Perfluorooctanoic acid (PFOA)5.3 Perfluorobutanesulfonic acid (PFBS)21 Perfluorohexanesulfonic acid (PFHxS)71 Perfluorooctanesulfonic acid (PFOS)20 Well Name Well 01 (CA4000726) Sample Date 2/6/2020 Screen 60 - 160 Perfluorooctanoic acid (PFOA)15 Perfluorobutanesulfonic acid (PFBS)13 Perfluorohexanesulfonic acid (PFHxS)15 Perfluorooctanesulfonic acid (PFOS)28 Well Name Holdgrafer & Associates Well 01 Sample Date 4/19/2021 Screen unknown Perfluorooctanoic acid (PFOA)4.5 Perfluorobutanesulfonic acid (PFBS)9.3 Perfluorohexanesulfonic acid (PFHxS)43 Perfluorooctanesulfonic acid (PFOS)46 Well Name Copeland S. Properties Well 01 Sample Date 3/17/2020 Screen 100' - 170' Perfluorooctanoic acid (PFOA)<3 Perfluorobutanesulfonic acid (PFBS)21 Perfluorohexanesulfonic acid (PFHxS)37 Perfluorooctanesulfonic acid (PFOS)53 Well Name Well 01 (CA4000216) Sample Date 9/29/2022 Screen 50 - 65 Perfluorooctanoic acid (PFOA)4.2 Perfluorobutanesulfonic acid (PFBS)18 Perfluorohexanesulfonic acid (PFHxS)45 Perfluorooctanesulfonic acid (PFOS)54 Well Name Whitson Industrial Park Well 01 Sample Date 3/17/2020 Screen 60' - 115' Perfluorooctanoic acid (PFOA)17 Perfluorobutanesulfonic acid (PFBS)17 Perfluorohexanesulfonic acid (PFHxS)140 Perfluorooctanesulfonic acid (PFOS)88 Well Name PW-63 Sample Date 10/20/2022 Screen unknown Perfluorooctanoic acid (PFOA)11 Perfluorobutanesulfonic acid (PFBS)23 Perfluorohexanesulfonic acid (PFHxS)88 Perfluorooctanesulfonic acid (PFOS)54 Well Name MW-NW Sample Date 4/21/2022 Well Screen Interval (ft btoc)80' - 140' Perfluorooctanoic acid (PFOA)<1.6 Perfluorooctanesulfonic acid (PFBS)1.4 J Perfluorohexanesulfonic acid (PFHxS)1.0 J Perfluorooctanesulfonic acid (PFOS)<1.6 Well Name MW-SW Sample Date 10/22/2021 Well Screen Interval (ft btoc)100' - 180' Perfluorooctanoic acid (PFOA)<1.9 Perfluorooctanesulfonic acid (PFBS)2.1 J Perfluorohexanesulfonic acid (PFHxS)5 Perfluorooctanesulfonic acid (PFOS)4.6 J Well Name MW-17 Sample Date 10/21/2021 Well Screen Interval (ft btoc)5' - 20' Perfluorooctanoic acid (PFOA)4.3 Perfluorooctanesulfonic acid (PFBS)42 Perfluorohexanesulfonic acid (PFHxS)59 Perfluorooctanesulfonic acid (PFOS)59 Well Name MW-19 Sample Date 10/21/2021 Well Screen Interval (ft btoc)6' - 21' Perfluorooctanoic acid (PFOA)2.3 Perfluorooctanesulfonic acid (PFBS)22 Perfluorohexanesulfonic acid (PFHxS)59 Perfluorooctanesulfonic acid (PFOS)47 J Well Name MW-43 Sample Date 10/21/2021 Well Screen Interval (ft btoc)10' - 25' Perfluorooctanoic acid (PFOA)0.98 J Perfluorooctanesulfonic acid (PFBS)25 J Perfluorohexanesulfonic acid (PFHxS)53 Perfluorooctanesulfonic acid (PFOS)29 J FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA FIGURE 3A PATH: T:\_ENV\CHEVRON_PFAS_SLO_TANK_FARM\MXD\2023\CHEVRON_PFAS_SLO_TANK_FARM_2023.APRX SAVED: 1/11/2024 BY: SKI01076NOTES: 1. ROUX ASSOCIATES, INC. 2023. PER- AND POLYFLUOROALKYL SUBSTANCES (PFAS) SITE CONCEPTUAL MODEL. SAN LUIS OBISPO COUNTY REGIONAL AIRPORT, 975 AIRPORT DRIVE, SAN LUIS OBISPO, CALIFORNIA. OCTOBER 19. 2. SAMPLE LOCATIONS ARE APPROXIMATE. 3. UNITS IN MICROGRAMS PER KILOGRAM UG/KG. 4. ITALICIZED VALUES DENOTES DUPLICATE SAMPLES. 5. J = RESULT IS LESS THAN THE REPORTING LIMIT BUT GREATER THAN OR EQUAL TO THE METHOD DETECTION LIMIT AND THE CONCENTRATION IS AN APPROXIMATE VALUE. 6. G = THE REPORTED QUANTITATION LIMIT HAS BEEN RAISED DUE TO AN EXHIBITED ELEVATED NOISE OR MATRIX INTERFERENCE. SEDIMENT PFAS CONCENTRATIONS ACACIA CREEK ACR-01-1 ACR-01-2 ACR-01-3 ACR-01-4 ACR-01-1 ACR-01-2 ACR-01-3 ACR-01-4 County of San Luis Obispo, Maxar Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 1.6 0.12 J <0.29 0.16 J 2/8/2023 2.3 0.16 J <0.30 0.26 J ACR-01-1 Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 3.8 0.26 J 0.053 J 0.34 ACR-01-2 Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 2.7 0.16 J <0.29 0.38 ACR-01-3 Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 3.4 0.17 J <1.2 G 0.39 ACR-01-4 Legend ROUX SEDIMENT SAMPLE LOCATION SAN LUIS OBISPO CREEKS SITE BOUNDARY FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA FIGURE 3B PATH: T:\_ENV\CHEVRON_PFAS_SLO_TANK_FARM\MXD\2023\CHEVRON_PFAS_SLO_TANK_FARM_2023.APRX SAVED: 1/11/2024 BY: SKI01076NOTES: 1. ROUX ASSOCIATES, INC. 2023. PER- AND POLYFLUOROALKYL SUBSTANCES (PFAS) SITE CONCEPTUAL MODEL. SAN LUIS OBISPO COUNTY REGIONAL AIRPORT, 975 AIRPORT DRIVE, SAN LUIS OBISPO, CALIFORNIA. OCTOBER 19. 2. SAMPLE LOCATIONS ARE APPROXIMATE. 3. UNITS IN NANOGRAMS PER LITER (NG/L). 4. NL=SWRCB DIVISION OF DRINKING WATER NOTIFICATION LEVEL FOR PFOS, PFOA, PFBS & PFHXS RESPECTIVELY IS 6.5, 5.1, 500 & 3 NG/L. 5. RL=SWRCB DIVISION OF RESPONSE LEVEL FOR PFOS, PFOA, PFBS & PFHXS RESPECTIVELY IS 40, 10, 5,000 & 20 NG/L. 6. GREEN TEXT INDICATES CONCENTRATION ABOVE NL ADVISED BY THE STATE OF CALIFORNIA DIVISION OF DRINKING WATER. 7. RED TEXT INDICATES CONCENTRATION ABOVE DRINKING WATER RL ADVISED BY THE STATE OF CALIFORNIA DIVISION OF DRINKING WATER. 8. ITALICIZED VALUES DENOTES DUPLICATE SAMPLES. SURFACE WATER PFAS CONCENTRATIONS ACACIA CREEK ACR-01-1 ACR-01-2 ACR-01-3 ACR-01-4 ACR-01-1-W ACR-01-2-W ACR-01-3-W ACR-01-4-W County of San Luis Obispo, Maxar Legend ROUX SURFACE WATER SAMPLE LOCATION SAN LUIS OBISPO CREEKS SITE BOUNDARY Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 80 10 26 72 2/8/2023 88 11 29 79 ACR-01-1-W Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 79 11 32 80 ACR-01-2-W Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 74 12 33 82 ACR-01-3-W Sample Date PFOS PFOA PFBS PFHxS 2/8/2023 140 13 33 87 ACR-01-4-W FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA ORIGINAL BUILDING ORIGINAL BUILDING EXISTING FIRE WATER TANK TANK FARM ROAD FORMER FIRE SCHOOL LOCATION TRENCH USED BY THE FORMER FIRE SCHOOL FORMER PUMP STATION LOCATION (REMOVED) MAIN ACCESS GATE B-33 B-35 B-36 SLOW-18 MW-50 MW-56 SLOW-12 MW-49 ACCESS ROADAPPROXIMATE LOCATION OF EXISTING SEPTIC TANK & LEACH LINES 6" WATER 8" RELIEF LINE8"8" BYP A S S 10"3"8"8"16"6" 16"16"16"8"16" 3" 10" 8" RELIEF 10" 16" LOCATION OF ABANDONED AND DEMOLISHED FORMER HEATER FORMER GASOLINE AST LOCATION EXISTING OIL LINE "A" 4" GAS LINE 2" GAS LINE 2" GAS LINE REPORTED TO BE ABANDONED STORAGE CONTAINER APPROXIMATE LOCATION OF EXISTING SEPTIC TANK PADS FOR FORMER FIRE PUMPS APPROXIMATE LOCATION OF ABANDONED WATER SUPPLY WELL No. 2 16" PIPE LINE FOUNDATION OF FORMER ELECTRICAL HOUSE VAULTS VAULTS FORMER LINE No. 2 TO SANTA MARGARITA APPROXIMATE LOCATION OF ABANDONED 12" DIA. WELL No. 1 APPROXIMATE LOCATION OF FORMER 55,000 BBL ABOVE GROUND TANK - AST 522 (DEMOLISHED BETWEEN 1959 AND 1965) FORMER FIRE SCHOOL AST LOCATIONS APPROXIMATE LOCATION OF FORMER 55,000 BBL ABOVE GROUND TANK (NOT REBUILT AFTER 1926 FIRE) APPROXIMATE LOCATION OF FORMER 55,000 BBL ABOVE GROUND TANK - USED FOR FIRE WATER STORAGE FROM APPROXIMATELY 1994-2004 (REMOVED AUGUST 2000) APPROXIMATE LOCATION OF FORMER 55,000 BBL ABOVE GROUND TANK (REMOVED 1994) LEACH FEILD NEW MODULAR OFFICE BUILDING PETROLEUM TESTING LABORATORY OPERATIONAL WATER SUPPLY WELL (SUPPLIES NON-POTABLE WATER TO SITE) FOUNDATION OF FORMER BOILER AND TANK LOCATIONS SCALE 0 80 160 FEETV:\1212_Padre-Chevron_SLOTF\1212.001_Remedial_Design\013_1212.001_Historical_Operations_Area.dwg\04/17/14N SITE PROPERTY BOUNDARY TOPOGRAPHIC CONTOUR FENCEX LEGEND 125 EXISTING LIGHT POLE FIRE HYDRANT EXISTING MONITORING / PRODUCTION WELL WATER LINE DRAIN LINE CRUDE OIL GAS - CRUDE OIL GAS - OIL NOTES: 1. FIGURE ONLY SHOWS THE PRINCIPAL HISTORIC ELEMENTS OF THE OPERATIONS AREA. THE AERIAL PHOTOGRAPH ILLUSTRATES THE CURRENT CONDITIONS. THE HIGHLIGHTED ELEMENTS WERE IN-PLACE PRIOR TO 1994 (WHEN PETROLEUM OPERATIONS CEASED). SHADED ELEMENTS HAVE BEEN DEMOLISHED OR DISMANTLED. 2. FIRE SCHOOL OPERATIONS WERE RELOCATED TO THE RICHMOND REFINERY IN THE 1970'S. 3. THE PUMP HOUSE BUILDINGS WERE DEMOLISHED AND REMOVED IN THE LATE 1990'S. REFERENCE: 1. AERIAL PHOTOGRAPH BY CENTRAL COAST AERIAL MAPPING, DATED MARCH 2, 2007. 2. TOPOGRAPHIC CONTOURS AND FEATURES PROVIDED BY EDA, DATED JULY 2007. FFTA-8 FFTA-6 FFTA-4 FFTA-5 FFTA-7 FFTA-3 FFTA-1 FFTA-2 GAS GASOLINE PROPOSED SOIL SAMPLE LOCATION FIGURE 3 CHEVRON SAN LUIS OBISPO TANK FARMSAN LUIS OBISPO, CALIFORNIA REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM NORTHWEST OPERATIONS AREA - FEATURES AND PROPOSED SOIL SAMPLING POINTS FFTA-9 FIGURE NORTHWEST OPERATIONS AREA - FEATURES AND PROPOSED SOIL SAMPLING POINTS FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA 4 ==! ==! ==! ==! ==! ==! ! ! !! ! ! ! ! ! ! ! !!!! !!! ! ! ==! ==! ==! ==!!!!Airport Stormwater Outlet #6 Airport Outfall #6 Runway 11-29 VAP-7 SED-8/SW-8 120'VAP-9 80542 55538 55536 55534 80544 805465552655524 80548526 AST destroyed in 1926 fire, not rebuilt 522 AcaciaCreekBG-10 SED-5/SW-5 VAP-5 BG-9 BG-8 BG-7 SED-4/SW-4 BG-6 BG-5BG-4SED-3/SW-3BG-3BG-2 VAP-6 SED-2/SW-2 BG-1 SED-6/SW-6 SED-7/SW-7 VAP-11 VAP-10 150'140'130'VAP-1 VAP-2 VAP-3 VAP-4 VAP-13 BG-11 VAP-8 VAP-12 SED-9/SW-9 SW-1 WestForkTankFarm C r e ekT a n k F arm C reekEastFor k T a n k FarmCreek E a s t F o r k S a n L u i s O b i s p o C re e k Former Recycling Center Reservoir 5 Reservoir 6 Reservoir 7 Reservoir 3 Reservoir 2 Reservoir 4 35°15'0"N35°14'55"N35°14'50"N35°14'45"N35°14'40"N35°14'35"N35°14'30"N35°14'25"N35°15'0"N35°14'55"N35°14'50"N35°14'45"N35°14'40"N35°14'35"N35°14'30"N35°14'25"N35°14'20"N120°38'50"W120°38'55"W120°39'0"W120°39'5"W120°39'10"W120°39'15"W120°39'20"W120°39'25"W120°39'30"W120°39'35"W120°39'40"W120°39'45"W120°39'50"W120°39'55"W120°40'0"W 120°38'50"W120°38'55"W120°39'0"W120°39'5"W120°39'10"W120°39'15"W120°39'20"W120°39'25"W120°39'30"W120°39'35"W120°39'40"W120°39'45"W120°39'50"W120°39'55"W 0 500 1,000 SCALE IN FEETI PROPOSED SAMPLING LOCATIONS User Name: ski01076 DATE: 2/8/2024 12:58 PMPATH: T:\_ENV\Chevron_PFAS_SLO_Tank_Farm\MXD\2023\Chevron_PFAS_SLO_Tank_Farm_2023.aprxFIGURE 5 Legend==!Proposed VAP/HPT to Bedrock Interface + 20 feet !Proposed Sediment and Surface Water Sampling Locations !Proposed Background Soil Sample Location !Proposed VAP/HPT to Bedrock Interface Groundwater Contours Direction of Groundwater Flow* Buildings Site Boundary Current Stream Channel Former Stream Channel Former Aboveground Storage Tank Former Tank (Water Tank) Former Fire Training Area NOTES: * = GSI Water Solutions, Inc. 2022. San Luis Obispo Valley Groundwater Basin Annual Report (Water Years 2020-2021). San Luis Obispo Basin Groundwater Sustainability Committee and the Groundwater Sustainability Agencies. March 24. FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA 35°16'0"N35°15'30"N35°15'0"N35°14'30"N35°14'0"N35°13'30"N35°15'30"N35°15'0"N35°14'30"N35°14'0"N35°13'30"N120°36'30"W120°37'0"W120°37'30"W120°38'0"W120°38'30"W120°39'0"W120°39'30"W120°40'0"W120°40'30"W120°41'0"W120°41'30"W120°42'0"W120°42'30"W 120°36'30"W120°37'0"W120°37'30"W120°38'0"W120°38'30"W120°39'0"W120°39'30"W120°40'0"W120°40'30"W120°41'0"W120°41'30"W120°42'0"W120°42'30"W 0 2,200 4,400 SCALE IN FEET I POTENTIAL PFAS SOURCE LOCATIONS User Name: ski01076 DATE: 1/24/2024 11:58 AMPATH: T:\_ENV\Chevron_PFAS_SLO_Tank_Farm\MXD\2023\Chevron_PFAS_SLO_Tank_Farm_2023.aprxFIGURE 6 Legend POTENTIAL PFAS SOURCE LOCATIONS NATIONAL HYDROGRAPHY DATASET FLOWLINE AND DIRECTION PROJECT BOUNDARY 1 MILE BUFFER 0.25 MILE BUFFER APPROXIMATE LOCATIONS OF FEATURES OF NOTE SAN LUIS OBISPO REGIONAL AIRPORT FORMER CHEVRON SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO, CALIFORNIA Response to Regional Board's Comments Provided in 2023 Letter Attachment A Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 1 # Regional Board Comment Response General Comments 1. The Central Coast Water Board provided further description of those requirements in its December 2022 Letter, which included:  The need to determine potential for transport and fate of PFAS from the Former Fire Training Area (FFTA) in the Northwest Operations area, per the “Requirement for a Workplan Addendum”, bullet three, which states, “Thus, investigation of native soil, sediment, and groundwater is needed. PFAS transport from the Northwest Operations area potentially occurred by (1) direct infiltration to groundwater in the source areas and/or (2) overland flow to the East Tank Farm Creek drainage area bisected by Tank Farm Road with recharge to groundwater along its flow path.”  A proposed schedule for site-wide PFAS investigation per the “Workplan Addendum Implementation Schedule”, which states, “The workplan addendum must also include an implementation schedule for an offsite investigation commensurate with the investigation findings for the fire training area, and a proposed schedule for a site-wide PFAS investigation.” The scope of work partially responds to the first requirement of the implementation schedule, while the requirement for a schedule for the site-wide investigation remains outstanding. The Revised Supplemental Work Plan has been modified to include all requested media (soil, groundwater, and sediment) be sampled as part of the proposed scope of work in one phase. Additional groundwater, soil, sediment, and surface water sampling points have been added to assess potential transport of PFAS from the Northwest Operations Area as requested by the Regional Board. The phasing of different sample media collection (i.e., soils, then groundwater, followed by sediment) has been removed from the Revised Supplemental Work Plan’s scope of work. A proposed schedule has been included as Section 6 of the Revised Supplemental Work Plan. A meeting was held between members of the Regional Board, CEMC, and Arcadis in November 2023. At this meeting it was agreed that the immediate next phase of work should be focused on the FFTA, and that conversations around scheduling of the site-wide investigation will continue following evaluation of the impending FFTA investigation. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 2 # Regional Board Comment Response 2. The Central Coast Water Board acknowledges the proposed stepwise approach in the Supplemental Work Plan; however, the scope of work presented requires clarification and rescoping to focus the first phase of investigation on the Northwest Operations Area FFTA activities. For example, some of the proposed soil and sediment sampling shown on Figure 7 do not address the FFTA in the Northwest Operations Area regarding source identification. Specifically, the proposed soil and sediment sampling locations BG-1 to BG-10 and SED-1 to SED-5, respectively, do not respond to the two- phased approach as described in the Central Coast Water Board’s December 2022 Letter for the FFTA in the Northwest Operations Areas. These sample locations would be more appropriately directed toward filling data gaps in the conceptual site model (CSM) in the event a source area is identified in the Northwest Operations Area for the FFTA and related activities, as detailed further herein. See Response to Comment (RTC) #1. As discussed in the Original, and Revised Supplemental Work Plan text, various sampling locations have been selected to help establish what contamination, if any, may be attributable to offsite sources. The original Order requested work be performed to determine the “extent of PFAS suspected to be at and emanating from the SLO Tank Farm.” These background/ambient locations will aid in determining what measured PFAS may be emanating from the FFTA, and what may instead be attributable to offsite source(s). 3. The Central Coast Water Board’s December 2022 Letter emphasizes the need to investigate the potential for PFAS to migrate to groundwater from the Northwest Operations Area FFTA due to the presence of the off-site supply wells identified to the west of the property in the westerly groundwater flow direction from the Site. Central Coast Water Board staff, in numerous meetings and teleconferences with CEMC and their representatives, identified the channel and basin area south of Tank Farm Road along Tank Farm Creek, and the area west of Tank Farm Creek, as essential to the first phase of investigation efforts with the objective of addressing potential sources of PFAS to the off-site supply wells. This investigation is missing from the Supplemental Work Plan and must be included as part of a revised scope of work. The Revised Supplemental Work Plan has been modified to include an additional groundwater sampling point (VAP-10) downgradient of the FFTA, south of Tank Farm Road, west of Tank Farm Creek, and adjacent to the off-site supply wells. Three sediment/surface water sampling locations (SED-6 through SED-8) have been added to Tank Farm Creek, downstream of the FFTA (Figure 5). Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 3 # Regional Board Comment Response 4. The scope of work requires reframing around investigation efforts tailored to source identification that is more general in scope, as opposed to the proposed discrete level of data collection currently proposed for targeted aquifer profiling across thin complex interbed layers for lithology analyses, and the multi- sampling approach across thinly-interbedded groundwater zones. Currently available characterization information including boring logs, groundwater elevations and flow directions, monitoring for constituents of concern, etc. from Union Oil Company of California’ years of Site investigation should be integrated, and presented to illustrate the understanding of Site conditions and support proposed sampling locations. The Revised Supplemental Work Plan has been modified to include additional sampling points around the FFTA for the purpose of source determination. The dataset previously developed for groundwater characterization at the Site would benefit from the addition of aquifer profiling as described in the workplan. This approach was discussed and agreed upon between members of the Regional Board, CEMC, and Arcadis in a November 2023 meeting. Specifically, the Regional Board stated “your vertical investigation is suitable, though needs to be expanded horizontally.” Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 4 # Regional Board Comment Response 5. The hydrogeologic investigation methods proposed in the Supplemental Work Plan are applicable once primary source zones have been identified. Afterward, the primary data quality objectives (DQOs) should shift to a delineation of the primary source areas for transport and fate analyses toward developing a more detailed CSM, determining risk to receptors, and understanding and developing feasibility analyses for control and cleanup options. The Central Coast Water Board does not concur with CEMC’s proposed requesting of a “no further action” (NFA) determination between each phase of the investigation and will evaluate an NFA determination when the approved scope of work is completed. See RTC #4. All proposed pathways to request NFA have been removed from the Revised Supplemental Work Plan. The intent of the Revised Supplemental Work Plan is to definitively determine the presence or absence of targeted PFAS in soil, groundwater, sediment, and surface water that may be emanating from the FFTA. Due to the presence of multiple known and suspected offsite sources, data collected at and downgradient/downstream of the FFTA will be compared to investigation data collected along upgradient and upstream locations. In addition, analyte-specific abundance profiles or source “signature” comparisons will provide valuable insight as to what, if any, PFAS contamination may be attributable to the FFTA. The hydrogeologic methods are proposed to fulfill the additional objectives including, a) the identification of groundwater pathways downgradient of the FFTA , b) evaluating vertical conductivity to deeper groundwater bearing zones (i.e., the groundwater zones the offsite water supply wells are screened in), and c) identification of potential groundwater pathways across and onto the Site. 6. Section 3, 3.1, Attachment A, Quality Assurance Project Plan (QAPP), et. Al.: Remove the requests for NFA as intervening steps for the investigation of soil, sediment, and groundwater. Central Coast Water Board staff requires revising the scope of work throughout the various sections of the work plan to present a baseline sequencing approach that starts with the Northwest Operations Area, then a site wide evaluation. All proposed pathways to request NFA have been removed from the Revised Supplemental Work Plan. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 5 # Regional Board Comment Response 7. Section 3, 3.1 and 3.2: Proposed expanded soil and groundwater investigations within the Northwest Operations area related to the FFTA, as only five (5) soil borings locations are currently proposed. Additional sampling locations are needed to account for historic operational variabilities and uncertainties, as cited in the Supplemental Work Plan, in the areas surrounding burn trench. Examples include activities such as nozzle testing for fire suppression mixture optimization for aqueous film forming foam (AFFF) not directly deployed to extinguishing fires in the fire trench noted in the Supplemental Work Plan; nozzle cleaning post AFFF deployments, chemical storage and mixing areas and appurtenances and related out-buildings; among other related structures and activities. Toward this effort, consider utilizing and presenting larger scale overlays of historical aerial photographs, former operations schematics (such as those in the 2015 RAP) for the Northwest Operations area help to inform a proposed expanded investigation for the above partial list of considerations for further developing a revised scope of work. Four (4) soil boring locations have been added to scope of work. Nine (9) soil boring locations are proposed at/near the FFTA. These locations have been selected using historic infrastructure maps of the FFTA as identified in Figure 4 and new information including an 1976 historic fire location. As explained in the text, no AFFF use (and hence, no AFFF nozzle testing or cleaning areas) were identified on site. Instead, appropriate investigation of the known FFTA and infrastructure is proposed. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 6 # Regional Board Comment Response 8. Section 3, 3.2: Similar to the previous comment, a groundwater investigation is needed south of Tank Farm Road along the western site boundary. The objectives are to assess the potential for overland flow and infiltration from surface water to groundwater from Northwest Operations area and FFTA, to determine the relative horizontal and vertical hydrogeologic conditions for developing transport and fate conditions to inform the CSM relative to the off- site supply wells to the west, and to determine potential impacts from industrial activities west of the property, as indicated, in part, in section 1.5 of the Supplemental Work Plan. Because more than one groundwater sampling event will be necessary to confirm ongoing chemical and hydrogeologic conditions at the Site, consider installing permanent (vs. temporary) groundwater monitoring wells. One (1) groundwater sampling location has been added south of the FFTA and along the western Site boundary. Monitoring Well MW-41 is south of Tank Farm Road, west of Tank Farm Creek, and near the western property boundary. MW-41 was sampled as part of the 2021 investigation activities. Results were below California Department of Drinking Water response levels for regulated compounds. Overland flow from the FFTA will also be addressed by the addition of three (3) sediment sampling locations within Tank Farm Creek and its westernmost tributary. Furthermore, a stormwater sample has been proposed to collect discharge from the adjacent San Luis Auto Salvage Yard, which maintains an industrial activity general permit to discharge storm water. The permitted stormwater sampling point is at the property boundary, adjacent to the storm channel flood control feature on the SLO Tank Farm property. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 7 # Regional Board Comment Response 9. Section 3, 3.3: Propose a scope of work for sediment investigation for the Northwest Operations Area FFTA and south of Tank Farm Road along current and historic drainages related to runoff from the FFTA as potential routes of overland transport and fate for PFAS from the Northwest Operations Aera FFTA. The need for the sediment sampling is consistent with the requirements of the Central Coast Water Board’s 2020 Order and December 2022 Letter, and previous discussions involving Central Coast Water Board staff, CEMC representatives, and ARCADIS, technical representatives for CEMC. Also, during numerous discussions with CEMC and ARCADIS staff, Central Coast Water Board staff conveyed the requirement for a proposed scope of work for investigating sediment in the drainages flowing from the FFTA to current and previous drainage ways, both proximal and distal to the Northwest Operations Area. The intent of the required scope of work for a sediment investigation serves the dual objective of assessing the relative presence/absence of PFAS and their potential for infiltration to groundwater in the channel and basin areas south of Tank Farm Road and along the western site boundary related to FFTA in the Northwest Operations Area. Three (3) sediment sampling locations, within Tank Farm Creek and its westernmost tributary, have been added to the Revised Supplemental Workplan (Figure 5). 10. Attachment F, Portable Document Format (PDF) page 141, section 3: Please note that approval is required for injection of fluorescein dye to groundwater pursuant to Central Coast Water Board Order R3-2019-0089, General Waiver for Specific Types of Discharges, dated September 20, 2019 (General Waiver).8 If fluorescein dye or other tracer dyes are proposed for use, the revised Supplemental Work Plan scope or work must expressly indicate that such injections with will meet the conditions of Order R3-2019-0089, Attachment A, Section B. The potential use of fluorescein dye would be considered as a component of the overall site investigation and cleanup effort and could be performed under the existing General Waiver with modifications for compliance with the conditions for injections to groundwater. Any proposed injection will be used in accordance with Central Coast Water Board Order R3-2019-0089. The Revised Supplemental Workplan has been updated to include the assurance that any use of fluorescein dye will be in accordance with Central Coast Water Board Order R3-2019-0089. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 8 # Regional Board Comment Response Specific Comments 11. Section 1.2 and 2, groundwater hydrology: Conclusions regarding vertical communication between groundwater-bearing zones being “unlikely” must be further assessed on a macro scale (vs. micro scale as currently proposed). The March 31, 2015 Final Remedial Action (2015 RAP) Plan, PDF page 51, section 6.6, and PDF page 92, Figure 3, respectively, describe and illustrate 12-inch large diameter supply wells in the Northwest Operations Area with notations indicating “abandon.” Description of the histories for these wells in the 2015 RAP indicates documentation is not available for their historical uses, pumping rates, construction information for the presence or absence of annular seals and depths, number and depth of screened intervals, total well depths; and whether proper abandonment was performed prior the implementation of the remedy. As part of the revised Supplemental Work Plan, include a discussion of the final determination regarding location efforts for proper abandonment of these wells as described in section 6.6 of the 2015 RAP, and provide a related description as part of the CSM, consideration of potential vertical preferential transport of PFAS between groundwater-bearing units under theoretical pumping conditions and passive scenarios for non- pumping conditions. The March 31, 2015 Final Remedial Action Plan (2015 RAP) identified two (2) historical water wells in the Northwest Operations Area. The approximate locations of the wells were unable to be verified and “It is likely that the wells were abandoned many years ago and any other record of them has long since been lost” (Trihydro 2015). Historical records and well completion reports were reviewed to identify the status of the 12-inch- diameter supply wells in the Northwest Operations Area. Additionally, geophysical subsurface investigations for these wells were completed as part of the Northwest Operations Area excavation and capping effort. Neither the historical records review nor subsurface investigations identified the presence or abandonment of additional supply wells. 12. Section 3.1, Soil Investigation: Further evaluation and explanation is required for potential biases of laboratory analytical results during sample preparation involving non-aqueous phase liquid (NAPL) occurrences for soil and groundwater. The response must include a discussion of data reliability and confidence relative to the DQOs for achieving data representative of Site conditions for evaluation and decision-making purposes. Part of the response must also include how laboratory sample preparation and analytical methods may account for biases depending on utilization of various internal procedures. NAPL extraction will not be performed on soil and groundwater samples unless the presence of significant amounts of NAPL prohibit analysis of the sample. Whole samples will be analyzed so that an accurate representation of soil or groundwater PFAS concentrations will be identified. This whole-sample analysis methodology aligns with the primary data quality objective, “…determine the presence or absence of PFAS in soil, groundwater, and sediment.” Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 9 # Regional Board Comment Response 13. Section 3.2, Groundwater Investigation: Specify the rationale for the selected sampling intervals and depths. Attachment F indicates 3- to 5-foot intervals for more thinly bedded geologic conditions, conditions that are likely to be encountered at the site, whereas the Supplemental Work Plan scope of work indicates 5- to 10-foot internals. Given the relatively shallow depth to groundwater and complex hydrogeologic conditions that occur across the Site, implementation of the more frequent sampling internals appears appropriate for determining Site characteristics for transport and fate flow paths related to the targeted groundwater sampling and development of the CSM. Also refer to the above General Comment regarding the proposed approach and methodologies for groundwater sampling scope and scale related to DQOs for source investigation. Attachment F of the 2023 Supplemental Work Plan is a Technical Guidance Instruction (TGI) for Vertical Aquifer Profile (VAP) Sampling. These TGI documents are written to provide general instruction for activity implementation across a variety of site conditions. While the Site geologic conditions are thinly bedded, a 5- to 10-foot interval is adequate to assess groundwater contaminant concentrations. Ultimately, sample intervals will be selected real time during the investigation based on the HPT data to identify zones of higher permeability based on observed conditions at each boring. 14. Section 3.2: PDF page 15, continued paragraph at top of page: Central Coast Water Board staff recommends collecting soil samples for PFAS analyses along with the proposed collection of soil cores for geophysical properties for the objective of determining the presence or absence of targeted PFAS. Soil samples for geophysical properties analysis must be collected as intact cores to develop a comprehensive understanding of groundwater hydrogeology and vertical connectivity. As a result, collecting soil samples for PFAS analytes along with the proposed collection of soil cores would require an additional borehole for each location. If AFFF was used at the FFTA indications of its use will be present in the soil samples scoped for investigation. Collecting soil samples at the VAP/HPT locations near the FFTA would therefore be redundant. For background VAP/HPT locations Arcadis is proposing standalone soil samples around the perimeter of the property (Figure 5). Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 10 # Regional Board Comment Response 15. Section 4, PDF page 21, second paragraph: Clarify use and application of tracer dye, if any. The hydraulic profiling method described earlier in the Supplemental Work Plan scope of work does not indicate that use of a tracer dye for vertical aquifer profiling (VAP) is needed to determine groundwater sampling zones that will already be identified via use of the hydraulic profiling tool (HPT). Given that the HPT locations are posed as part of a paired geophysical investigation approach for optimizing the proposed groundwater sampling, define the conditions that may indicate use of a tracer. Tracer dye would only be used if drilling fluids (e.g., water) are needed during the drilling of VAP/HPT boreholes based on encountered drilling conditions. Typically, when groundwater sampling is performed during drilling, the purge volume to be removed is at least as much as was lost during drilling. However, accurately determining the volume of water lost to the formation or specific intervals within the borehole is not always feasible or possible. Using tracer dye in any drilling fluids applied to the subsurface will be used to visually confirm when unimpacted native groundwater enters the borehole. The tracer dye would be used to identify the dilution of groundwater by drilling fluids and if correction factors/groundwater purging is required to collect a representative sample. Note that the use of water (and resulting tracer dye) during drilling operations is not expected. Any proposed injection will be used in accordance with Central Coast Water Board Order R3-2019-0089. If possible, drilling for the VAP borings will be conducted without the use of drilling water. 16. Section 4, PDF page 21, third paragraph: Provide a description for including PFAS sampling as part of the sampling for the soil cores (see previous related comment), as the soil core recovery methodology may allow, or if feasible. See RTC #14. Soil core recovery as scoped for geophysical analysis will not provide suitable volume for PFAS analysis without the addition of additional test boreholes. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 11 # Regional Board Comment Response 17. Section 4, PDF page 22, first paragraph: Describe the criteria used to determine whether soil core retrieval will be utilized utilizing the proposed direct-push advancement tool, and how the decision whether to collect the cores aligns with the overall data collection objectives toward Site characterization. This text has been removed from the Revised Supplemental Work Plan. HPT data will be used to identify target groundwater sampling intervals. The collection of soil cores for PFAS analysis at groundwater investigation locations is not planned as part of the revised work scope. Soil investigation locations are scoped separately (Figure 4 and Figure 5). The collection of soil cores directly for geophysical properties correlates with the data objectives toward Site characterization and to fill the data gap of vertical conductivity to deeper groundwater bearing units. The collection of soil cores will be used in conjunction with the HPT data to establish detailed modeling inputs for groundwater flow at the FFTA. 18. Section 4, PDF page 22, second paragraph: See prior comment regarding use of tracer dye and requirements for compliance with the conditions of the General Waiver. See RTC #15. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 12 # Regional Board Comment Response 19. Section 5, Table 4. PFAS Analyte List: Constituent list needs to match updated constituent list in the State Water Resources Control Board’s (State Water Board) December 6, 2022, “Target Reporting Limits” table, at a minimum, and reporting of all resultant laboratory reportable PFAS is required. The Table 4 list also differs from the list in Appendix E, Table 3a. Explain the reasons for the difference. Please also note the reporting limits and provide consistency throughout the work plan and confirm laboratory capabilities for analyses of the PFAS listed in the State Water Board’s PFAS Target Reporting Limits table. The constituent list identified in Table 4 has been updated to align with the State Water Board’s December 6, 2022 “Target Reporting Limits” table, which lists criteria for 43 PFAS compounds. Eurofins Lancaster Laboratories method detection and reporting limit capabilities have been added to Table 4 for the requested analyses. With the exception of three compounds, draft analytical method 1633 will be used. The remaining three compounds (10:2 Fluorotelomer sulfonic acid, Perfluorooctadecanoic acid, and Perfluorohexadecanoic acid) will be analyzed by method 537.1 Modified. The discrepancy between Table 4 and Appendix E, Table 3a, of the original work plan was inadvertent. This comment is acknowledged and appreciated. 20. Figure 7, Proposed Sampling Locations: As indicted in the General Comments herein and consistent with the Central Coast Water Board’s requirements detailed herein for the revised Supplemental Work Plan scope of work, revise Figure 7 to illustrate sediment, soil, and groundwater sampling locations correspondingly. Include selected locations for hydrologic profiling with groundwater sampling to determine the potential for PFAS from on-site sources and possible PFAS from sources off-site. Sampling locations that focus on the northwest corner of the Site property south of Tank Farm Road and within the East Tank Farm Creek drainage area corridor, must be included. Figure 5 has been updated to include sampling locations south of Tank Farm Road and within the East Tank Farm Creek drainage area. An additional figure, Figure 4, has been included to show the focus of soil sampling at the FFTA. The text of the Revised Supplemental Work Plan provides rationale for sample location selection. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 13 # Regional Board Comment Response 21. Figure 7, Proposed Sampling Locations: Soil sampling locations BG-6 through BG-10 appear to be selected to evaluate if off-site PFAS sources are coming onto the Site. However, not all potential sources on the Site are being evaluated with limited (only five) soil samples proposed for the FFTA, no soil sample locations proposed south of the FFTA, and no soil sample locations are proposed on or near the Site’s Former Recycling Center. Soil sampling locations BG-1 through BG-10 (and now BG-11) depicted on Figure 7 of the Supplemental Work Plan (now Figure 5 of the Revised Supplemental Work Plan) have been selected to evaluate background/ambient PFAS concentrations at the perimeter of the Site and outside of historic fire training activities. Additional soil samples have been proposed within the FFTA at locations of former infrastructure, as shown in Figure 4. During the November 2023 meeting the Regional Board agreed that the next phase of the investigation should be focused on the FFTA, and not site wide (including the Former Recycling Center). 22. Figure 8, Proposed Northwest Operations Area Sampling Locations: As indicated in the general comments herein, an expanded areal sampling is required due to operational variabilities and uncertainties, fate and transport considerations, and for gathering a broader data set for Site source evaluation purposes. Sediment sampling along the unnamed tributary west of the branch of West Fork Tank Farm Creek, and as close to the FFTA as possible and within native sediments in the wetland areas (i.e., re-established, and rehabilitated), to the extent feasible. Additional soil samples have been proposed within the FFTA, as shown in Figure 4. Sediment sampling locations have been added along the unnamed tributary west of the branch of West Fork Tank Farm Creek (Figure 5). Sediment sampling locations and an additional VAP/HPT location have been added south of the FFTA to address fate and transport considerations (Figure 5). Furthermore, surface water samples have also been proposed in the Revised Supplemental Work Plan, which will be collected at areas of sediment collection (or immediately upstream to avoid sediment disturbance impacts) 23. Attachment A, PDF page 42, CSM, note 2: Explain rationale for determination that stormwater runoff from the FFTA would not have potentially caused PFAS impacts in uncapped and un-remediated areas. Due to the potential routes of exposure, features comprising the drainages that would have served as conveyances for runoff from FFTA activities require investigation as part of the revised Supplemental Work Plan. Sediment sampling locations have been added to the drainages downstream of the FFTA (Figure 5). VAP/HPT locations have been added south and west of the FFTA. These additional sampling points address fate and transport considerations from the FFTA. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 14 # Regional Board Comment Response 24. Attachment A, PDF page 43, table column Phase I, second column Objective, second row down: Please update this table to be part of the revised scope of work in reference to the above comments for expanded investigation. The scope of work provided in the Revised Supplemental Work Plan no longer includes no-further-action decision points or contingent-based next steps. The Technical Objective and Conceptual Work Plan Approach Table, provided in Attachment A in the 2023 Supplemental Work Plan, has been omitted from the Revised Supplemental Work Plan to fulfill the request of the Regional Board for reduced work plan file size/length. 25. Attachment A, PDF page 45, table column Phase 3, third column Method / Rationale, second bullet: Provide explanation for the preemptive determination as to why and how “[...]data collected will be inconclusive in establishing a point source.” The possibilities for multiple sources, including point sources and diffuse “hot spot” aeras must be investigated and not immediately discounted as inconclusive in the context of the potential routes of transport and fate due to runoff patterns from the Northwest Operations Area and FFTA. This comment is acknowledged. The intent of the Revised Supplemental Work Plan is to evaluate whether the FFTA was a source of PFAS. The areas of interest will be investigated to determine presence / absence. PFAS analyte “signatures” observed, if detected, will be compared against upgradient PFAS signatures to aid in CSM development regarding determination of contamination origin sources.. 26. Attachment A, PDF page 45, note 1: See prior comments regarding a discussion of analytical biases for potential NAPL encounters and corresponding sampling. See RTC #12. 27. Attachment A, PDF page 46, note 1: Phased approach schedule: General comment consistent with requirements for revising the Supplemental Work Plan scope of work for all media as part of a stepwise investigation removing the references to “no further action” to comply with 2020 Order per the December 2022 Letter. A request for no further action related to a step wise investigation has been removed from the Revised Supplemental Work Plan. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 15 # Regional Board Comment Response 28. Attachment B, Aerial Imagery, 1926 photo: Explain the history, ownership history (including if Union Oil Company of California or related entities owns or once owned this property), and operations for what appear to be 12 tank/storage structures and related features shown to the north of the present- day Union Oil Company of California property boundary comprising the Site. Explain how these structures may influence the findings of the investigation, understanding of background conditions and potential influences on DQOs and analytical results. For example, “background” soil sampling locations BG-1 through BG-5 may not be representative of background conditions as this property was used for oil storage. Please provide any soil and/or groundwater sampling data related to this property north of the Site. To the extent known, please provide information about fire fighting training activities that may have occurred in this area. Available historical records support that Union Oil Company owned the properties north of the San Luis Obispo Tank Farm (SLOTF) during the time period that the tank farm facility was being constructed. Aerial photography depicts circular “scars” on those northern properties similar in size and orientation to that of the secondary containment berms encircling the above ground storage tanks operated by Union Oil at the SLOTF. CEMCs investigation of historical records concludes that the property was initially intended for a potential expansion of the SLOTF facility but was never constructed or used in that capacity. Shortly after the 1926 aerial image was taken, the surface use of the property was changed to that of an airstrip (Clark Field). Clark Field was replaced circa 1939 by the present-day San Luis Obispo County Regional Airport. Over the years, the circular “scars” gradually faded until they were no longer visible. Between the 1930’s and the 1990’s, Union Oil Company sold the properties. The exact divestiture date has not been identified. The visual presence of these circular “scars” will not influence the findings of the SLOTF investigation and will not have an impact on the establishment of background data or DQOs associated with the SLOTF PFAS investigation. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 16 # Regional Board Comment Response 29. Attachment E, PDF page 78, section 4.1, fourth paragraph: Interstate Technology and Regulatory Council’s reference for use of standards: Explain whether the intent for citing this reference is to portend that the two contracted laboratories follow these sample preparation procedures, especially in relation to the use of isotopically labelled analogs for target analytes. The ITRC reference documents were included in the 2023 Supplemental Work Plan to provide PFAS reference information and industry-standard procedures for the sampling and analysis of PFAS. Note that the 2023 work plan proposed analysis by 537.1 modified whereas the revised supplemental work plan will primarily utilize EPA Method 1633. The ITRC site characterization, sampling precaution, and laboratory analytical method guidance documents have not been updated to include 1633 specifics. 30. Attachment E, PDF page 120, section 11.6, fourth bullet: Confirm use of isotopic dilutions (ID) for targeted analytes. Please change "should" to "must" per list on State Water Board's webpage and requirements of the Department of Defense's Quality Systems Manual 5.3, or later, for analyses utilizing IDs for quantifying data of known quality and representativeness of Site investigation media. This comment is acknowledged and will be used to update the PFAS Sampling and Analysis Guidance prepared for Chevron Corporation. Arcadis intends to update this guidance, in the future, to reflect the latest regulatory requirements and guidance criteria including those provided by the State Water Board and the Department of Defense. The guidance has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. 31. Attachment E, PDF page 131, section 6, Procedure 6.: Please provide a backup plan for collecting groundwater samples for potential instances where the targeted shallow groundwater is relatively non-recoverable. Protocols indicate allowing sufficient time for well recoveries; however, specific alternative plans are recommended in the event of non-recoveries per the proposed sampling procedures. Historic field observations may provide guidance for how reliability shallow samples can be collected when accounting for groundwater recovery time upon purging prior to sampling. This comment is acknowledged and will be used to update the PFAS Sampling Procedures and Low-Flow Groundwater Purging for Monitoring Wells. Arcadis intends to update this guidance, prior to investigation, to reflect the latest regulatory requirements including those provided by the State Water Board. The guidance has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 17 # Regional Board Comment Response 32. Attachment F, PDF page 140, section 2, third paragraph: Clarify use of a tracer per the following comments regarding characterization methodologies. See RTC #15. 33. Attachment F, PDF page 141, section 3, fourth paragraph: Cross-reference to section 4, page 2 to provide rationale and clarification for VAP profiling with tracer fluid when using prior direct push characterization with HPT technology. With characterization using the HPT methodology preceding VAP and VAP samples are co-located as separate but adjacent field points, explain whether tracer dye is needed. Use of the HPT can target transmissive zones for optimized groundwater sampling while not using drilling fluids and tracers as part of collecting representative groundwater samples for source area identification and assessment. Also consider that the proposed VAP methods may be better suited to transport and fate objectives as part of subsequent delineation strategies once potential sources have been established. See RTC #15. 34. Attachment F, PDF page 141, section 3, fifth paragraph: See comment to section 3.2 of the main text regarding proposed sampling intervals. See RTC #13. 35. Attachment F, PDF page 141, section 3, fifth paragraph: Update to refer to section 8 on PDF page 146. This comment is acknowledged and will be used to update the TGI – Vertical Aquifer Profile (VAP) Sampling following discussion with Arcadis technical experts. Arcadis intends to update this guidance, in the future, to reflect the latest regulatory requirements including those provided by the State Water Board. The guidance has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. 36. Attachment F, PDF page 143, section 5, fifth solid bullet, and related section 8.2.3.2, PDF page 150: Same as comment for use of a tracer and the proposed field sampling method for separate but co-located HPT and VAP sampling points. See RTC #15. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 18 # Regional Board Comment Response 37. Attachment F, PDF page 148, section 8.2, second paragraph: Same as the previous comment. See RTC #15. 38. Attachment F, PDF page 149, section 8.2.2, second paragraph: Discrete sampling of deeper groundwater zones is preferrable without the use of packers, as the noted disadvantages of groundwater introduction from above the target zone may cause false positive results for PFAS given the low detection and reporting limits for laboratory PFAS analytical methodologies. Clarification is needed regarding procedures to prevent potential transfers of PFAS between variable groundwater zones. The TGI documents are written to provide general instruction for implementing VAP sampling across a variety of sites and site conditions. For PFAS sites, a top-down sampling approach (via DPT or sonic drilling) is preferred to limit potential for cross-contamination, and a packer sampling assembly is not planned for use at the site. With a DPT rig, an outer casing is advanced with the screen-point sampling device to limit the potential for cross-contamination between sampling intervals. With a sonic rig, a push-ahead groundwater profiler will be driven ahead of the sonic casing into the un-disturbed formation to the prescribed depth interval, and the sonic casing limits the potential for groundwater introduction from above the target interval. 39. Attachment F, PDF page 155, section 11.5, last bullet: Please update to also include the latest applicable version of the Department of Defense Quality Systems Manual, i.e., version 5.4. See RTC #30. 40. Attachment H, PDF page 240, QAPP Worksheet # 11, third and fourth paragraphs: Same as prior comments requiring a description of the potential for sample biases and how resultant data will be evaluated for determining its representativeness to Site conditions. See RTC #12. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 19 # Regional Board Comment Response 41. Attachment H, PDF page 241, QAPP Worksheet # 11, second full paragraph: Describe the rationale for determining the need for performing data validation. Main text of the Supplemental Work Plan (e.g., PDF page 25, section 5) and other portions throughout definitively indicate procedures and process for performing data validation and reporting, whereas the text of Worksheet # 11 suggests a discretionary approach to performing and reporting data validation. Please also confirm whether analytical data from use of alternative analytical protocols and methods will likewise undergo validation, such USEPA methodologies pending approval to be consistent with the above referenced State Water Board’s Target Reporting Limits analyte list for PFAS. All analytical data collected for CEMC undergoes 3rd party data validation. Arcadis and CEMC utilize Eurofins Lancaster Labs (Eurofins) for all PFAS analysis. As analytical protocols progress Eurofins consistently audits and validates processes consistent with USEPA expectations. 42. Attachment H, PDF page 251, QAPP Worksheet # 15: Clarify example Reporting Limits noted in the listings versus actual Reporting limits to be used in comparison to those cited in the State Water Board’s Target Reporting Limits. Please ensure consistency throughout the revised Supplemental Work Plan. Updated analyte reporting limits have been provided in Table 4. The QAPP within the project files has been updated to include the revised analyte list as provided in the Revised Supplemental Work Plan. The QAPP has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. 43. Attachment H, PDF page 253, QAPP Worksheet # 17, first paragraph: Clarify whether the reference to Figure 2 needs to be updated to correctly reference Figures 7 and 8. This comment is acknowledged. The QAPP within the project files has been updated to reference the updated figures provided in the Revised Supplemental Work Plan. The QAPP has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 20 # Regional Board Comment Response 44. Attachment H, PDF page 254, QAPP Worksheet # 17, first paragraph under the heading “Soil Sampling”: Please reference the General Comments regarding the required revised scope of work to an expanded areal investigation for soil sampling due to operational variabilities and uncertainties. This comment is acknowledged. The areal extent of soil sampling has been expanded as previously described. The QAPP within the project files has been updated to include the revised scope of work provided in the Revised Supplemental Work Plan. The QAPP has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. 45. Attachment H, PDF page 254, QAPP Worksheet # 17, second main paragraph under the heading “Soil sampling”: See prior comments regarding the need to explain the noted analytical variables in more detail to frame how resultant sampling data could be affected by NAPL occurrences. Compare identified biases with DQOs for collecting data representative of Site conditions. See RTC #12. 46. Attachment H, PDF page 255, QAPP Worksheet #17, second paragraph under the heading “Groundwater Investigation”: Include in the revised Supplemental Work Plan a scope of work for step-out locations consistent with an expanded scope of work, as detailed in the General Comments. This comment is acknowledged. The QAPP within the project files has been updated to include the revised scope of work provided in the Revised Supplemental Work Plan. Step-out locations for groundwater investigation purposes may be identified following review and interpretation of results from the subject Revised Supplemental Work Plan scope of work. 47. Attachment H, PDF page 256, QAPP Worksheet #17, first paragraph under the heading “Sediment Sampling”: Include in the revised Supplemental Work Plan a scope of work for investigation of soil and sediment to the south of Tank Farm Road and the area west of West Tank Farm Creek consistent with the General Comments and Specific Comments. Also, provide the rationale for preemptively deeming data as inconclusive for wetlands and flood areas (see Specific Comments related to the wetlands and drainages). See RTCs #1 through #10 and RTC #25. Central Coast Regional Water Quality Control Board Response to Comments Rejection of Supplemental Per- and Polyfluoroalkyl Substances Sampling Work Plan San Luis Obispo Tank Farm Geotracker Case ID: T10000020189 San Luis Obispo, California www.arcadis.com 21 # Regional Board Comment Response 48. Attachment A, PDF page 337, section 4 Equipment List: Please specify the use of approved and certified/verified PFAS-free detergents for the investigation equipment decontamination procedures. This comment is acknowledged. Pg 90 of the Supplemental Work Plan (Attachment E) specifies use of caution and decontamination materials not recommended for use in PFAS site investigations. 49. Attachment C, PDF page 381, listing of analytes: Clarify if this listing includes the use of USEPA Method 537.1 modified, as proposed in the work plan, and provide assurances of laboratory capabilities for analyzing and reporting for PFAS identified in the State Water Board’s Target Reporting Limits list. This comment is acknowledged. The QAPP within the project files has been updated to include the latest PFAS analyte list provided in Table 4 of the Revised Supplemental Work Plan. The QAPP has been omitted from the revised work plan submittal at the request of the Regional Board for reduced work plan file size/length. San Luis Auto Salvage Industrial Stormwater Discharge Permit Documentation Attachment B 1 From:Christian, Kevin Sent:Tuesday, May 30, 2023 4:57 PM To:info@mitchtsailaw.com; mitch@mitchtsailaw.com; hind@mitchtsailaw.com Cc:CityClerk; City_Attorney Subject:Records Request Response: PRR22294 Tsai - 276 Tank Farm Rd Attachments:PRR22294 Tsai - 276 Tank Farm Rd.pdf To: Tsai Law, The City of San Luis Obispo (“City”) received your request pursuant to the California Public Records Act delivered via email on November 18, 2022. In accordance with the requirements of the Act, I am providing the following linked records, which are responsive to your request, and described as follows: 11-18-2022 PRR22294 Tsai - 276 Tank Farm Rd (slocity.org) Folder Path within “Responsive Records” Folder File Name No. Pgs batch 3 SLO Tank Farm Phase I ESA_10-04-22 2471 batch 3 The Link (276 Tank Farm) - Project Description 1 batch 3 The Link Rendering 1 batch 3 The Link Site Plan 1 batch 3 The Link (276 Tank Farm) - Preliminary Civil Exhibits 4 batch 3 The Link Completeness Letter 9-8-2022 6 batch 3 Applicant Responses to Completeness Letter 11-10- 22 10 batch 3 The Link (276 Tank Farm) - Project Plans 111 batch 2/PRR22294 - batch 2 attachments 202104_AnnualPre-ActivitySurvey_RPT 69 batch 2/PRR22294 - batch 2 attachments 202204_AnnualPre-ActivitySurvey_RPT 76 batch 2/PRR22294 - batch 2 attachments Attachment A - Revised Project Description For 231 batch 2/PRR22294 - batch 2 attachments Chevron 82 batch 2/PRR22294 - batch 2 attachments Chevron NOP 58 batch 2/PRR22294 - batch 2 attachments Conservation Easement Processing 3-25-15 1 batch 2/PRR22294 - batch 2 attachments Figure 1-Location Map-reduced 1 batch 2/PRR22294 - batch 2 attachments PD Comments Table (2) 29 batch 2/PRR22294 - batch 2 attachments Preliminary Traffic Study Narrative and Attach 3 batch 2/PRR22294 - batch 2 attachments Processing Flowchart 3-25-15 1 2 batch 2/PRR22294 - batch 2 attachments The Link - Project Description - with Attachments 44 batch 2/PRR22294 - batch 2 attachments The Link Prelim TIS_Transportation Development 17 Note that several documents were withheld pursuant to Government Code 7927.500 (formerly Government Code §6254 (a)), this division does not require disclosure of any preliminary drafts, notes, or interagency or intra-agency memoranda that are not retained by a public agency in the ordinary course of business, if the public interest in withholding those records clearly outweighs the public interest in disclosure. This request was reviewed by Assistant City Attorney Markie Kersten and Paralegal Olga Martinez. This correspondence finalizes our production for your current request. Please be advised that every effort has been made to search for all records which may fall within the scope of your records request, and, as such, we believe our search is quite thorough. However, if you have knowledge of a specific document which has not been provided in response to your request, please notify us, and we will be happy to provide the document(s) to you unless, of course, it is exempt from disclosure pursuant to California Government Code §7921.000 et seq. Kevin Christian, CMC Deputy City Clerk City Administration City Clerk's Office 990 Palm Street, San Luis Obispo, CA 93401-3218 E kchristian@slocity.org T 805.781.7104 slocity.org Ph: (626) 381-9248 Fx: (626) 389-5414 Em: info@mitchtsailaw.com Mitchell M. Tsai Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 VIA E-MAIL November 18, 2022 Teresa Purrington, City Clerk City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 Em: tpurrington@slocity.org RE: Public Records Act and Advance Notice List Request Regarding the 276 Tank Farm Road Project Dear City Clerk, On behalf of Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”) and its members, this Office requests that the City of San Luis Obispo City”) provide any and all information referring or related to the 276 Tank Farm Road Project (“Project”) pursuant to the California Public Records Act (“PRA”), Cal. Government (“Gov’t”) Code §§ 6250–6270 (collectively “PRA Request”). Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. The Southwest Regional Council of Carpenters is a labor union representing more than 50,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning and addressing the environmental impacts of development projects, such as the Project. I. PUBLIC RECORDS ACT REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 2 of 7 Southwest Carpenters is requesting any and all information referring or related to the Project. The Public Records Act defines the term “public record” broadly as “any writing containing information relating to the conduct of the public’s business . . . regardless of physical form and characteristics.” Gov’t Code § 6252(d). “Records” includes all communications relating to public business regardless of physical form or characteristics, including but not limited to any writing, picture, sound, or symbol, whether paper, magnetic, electronic, text, other media, or written verification of any oral communication. Included in this request are any references in any appointment calendars and applications, phone records, or text records. These “records” are to include, but are not limited to correspondences, e-mails, reports, letters, memorandums, and communications by any employee or elected official of the City concerning the Project. Please include in your response to this request the following examples of “records,” as well as any similar physical or electronic forms of communication: any form of writing such as correspondence, electronic mail records (“email”), legal and factual memoranda, facsimiles, photographs, maps, videotapes, film, data, reports, notes, audiotapes, or drawings. Cal. Government Code § 6252(g) (defining a writing to including “any record thereby created, regardless of the manner in which the record has been stored”). Responsive correspondence should include, inter alia, emails, text messages, or any other form of communication regardless of whether they were sent or received on public or privately-owned electronic devices “relating to the conduct of the public’s business.” Cal. Government Code § 6252(e); Citizens for Ceres v. Super. Ct. Ceres”) (2013) 217 Cal. App. 4th 889, 909; Citizens for Open Gov’t v. City of Lodi Lodi”) (2012) 205 Cal.App.4th 296, 307, 311; City of San Jose v. Superior Court (2017) 2 Cal. 5th 608, 625 (finding that a public employee or officer’s “writings about public business are not excluded” from the California Public Records Act “simply because they have been sent, received, or stored in a personal account.”) . This Office requests any and all information referring or related to the Project, including but not limited to: 1) All Project application materials; 2) All staff reports and related documents prepared by the City with City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 3 of 7 respect to its compliance with the substantive and procedural requirements of the California Environmental Quality Act, Public Resources Code § 21000 et seq., and the CEQA Guidelines, title 14, California Code of Regulations, § 15000 et seq. (collectively CEQA”) and with respect to the action on the Project; 3) All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the agency pursuant to CEQA; 4) Any transcript or minutes of the proceedings at which the decisionmaking body of the City heard testimony on, or considered any environmental document on, the Project, and any transcript or minutes of proceedings before any advisory body to the public agency that were presented to the decisionmaking body prior to action on the environmental documents or on the Project; 5) All notices issued by the City to comply with CEQA or with any other law governing the processing and approval of the Project; 6) All written comments received in response to, or in connection with, environmental documents prepared for the Project, including responses to the notice of preparation; 7) All written evidence or correspondence submitted to, or transferred from, the City with respect to compliance with CEQA or with respect to the Project; 8) Any proposed decisions or findings submitted to the decisionmaking body of the City by its staff, or the Project proponent, Project opponents, or other persons; 9) The documentation of the final City decision and approvals, including the final environmental impact report, mitigated negative declaration, negative declaration, or notice of exemption, and all documents, in addition to those referenced in paragraph (3), cited or relied on in the findings or in a statement of overriding City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 4 of 7 considerations adopted pursuant to CEQA; 10) Any other written materials relevant to the public agency's compliance with CEQA or to its decision on the merits of the Project, including the initial study, any drafts of any environmental document, or portions thereof, that have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the Project and either made available to the public during the public review period or included in the City 's files on the Project, and all internal agency communications, including staff notes and memoranda related to the Project or to compliance with CEQA; and 11) The full written record before any inferior administrative decisionmaking body whose decision was appealed to a superior administrative decisionmaking body prior to the filing of any litigation. Please respond within 10 days from the date you receive this request as to whether this request specifies identifiable records not exempt from disclosure under the PRA or otherwise privileged or confidential, and are therefore subject to disclosure. This Office understands that this time may be extended up to 14 days for unusual circumstances as provided by Cal. Government Code § 6253(c), and that we will be notified of any extension and the reasons justifying it. We request that you provide all documents in electronic format and waive any and all fees associated with this Request. SWRCC is a community-based organization. Please notify and obtain express approval from this Office before incurring any duplication costs. If any of the above requested documents are available online, please provide us with the URL web address at which the documents may be downloaded. If any of the requested documents are retained by the City in electronic computer-readable format such as PDF (portable document format), please provide us with pdf copies of the documents via email, or inform us of the location at which we can copy these documents electronically. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 5 of 7 In preparing your response, please bear in mind that you have an obligation under Government Code section 6253.1 to (1) identify all records and information responsive to our request or the purpose of our request; (2) describe the information technology and physical location in which the records exist; and (3) provide suggestions for overcoming any practical basis for denying access to the records or information sought. In responding to this request, please bear in mind that any exemptions from disclosure you may believe to be applicable are to be narrowly construed. Marken v. Santa Monica- Malibu Unif. Sch. Dist. (2012) 202 Cal. App. 4th 1250,1262; and may be further narrowed or eliminated by the adoption of Proposition 59, which amended article I, section 3(b)(2) of the California Constitution to direct that any “statute ... or other authority ... [that] limits the right of access” to “information concerning the conduct of the people’s business” must be “narrowly construed.” As for any records that you nonetheless decline to produce on the grounds of an exemption, please bear in mind that the case law under the Public Records Act imposes a duty on you to distinguish between the exempt and the non-exempt portion of any such records, and to attempt in good faith to redact the exempt portion and to disclose the balance of such documents. Please bear in mind further that should you choose to withhold any document from disclosure, you have a duty under Government Code section 6255, subd. (a) to “justify withholding any record by demonstrating that the record in question is exempt under express provisions” of the Public Records Act or that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” Finally, please note that you must retain and not destroy any and all records, notwithstanding any local record retention or document destruction policies. As the Court noted in Golden Door Properties, LLC v. Superior Court of San Diego County (2020) 53 Cal.App.5th 733 that a public agency “must retain ‘[a]ll written evidence or correspondence submitted to, or transferred from’ . . . with respect to” CEQA compliance or “with respect to the project.” II. ADVANCE NOTICE LIST REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 6 of 7 We also ask that you put this Office on its notice list for any and all notices issued under the CEQA and the Planning and Zoning Law. In particular, we request that the City send by mail or electronic mail notice of any and all actions or hearings related to activities undertaken, authorized, approved, permitted, licensed, or certified by the City and any of its subdivision for the Project, or supported, in whole or in part, through permits, contracts, grants, subsidies, loans, or other forms of approvals, actions or assistance, including but not limited to the following: Notices of any public hearing held in connection with the Project; as well as Any and all notices prepared pursuant to CEQA, including but not limited to: Notices of determination that an Environmental Impact Report EIR”) or supplemental EIR is required for a project, prepared pursuant to Public Resources Code Section 21080.4; Notices of availability of an EIR or a negative declaration for a project prepared pursuant to Public Resources Code Section 21152 and Section 15087 of Title 14 of the California Code of Regulations; Notices of approval or determination to carry out a project, prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of approval or certification of any EIR or negative declaration prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of exemption from CEQA prepared pursuant to Public Resources Code section 21152 or any other provision of law; and Notice of any Final EIR prepared pursuant to CEQA. This Office is requesting notices of any approvals or public hearings under CEQA and the California Planning and Zoning Law. This request is filed pursuant to California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 7 of 7 65092 requiring agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Please send notice by regular and electronic mail to: Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 Em: maria@mitchtsailaw.com Em: mitch@mitchtsailaw.com Em: reza@mitchsailaw.com Em: info@mitchtsailaw.com We look forward to working with you. If you have any questions or concerns, please do not hesitate to contact our Office. Sincerely, Mitchell M. Tsai Attorneys for Southwest Regional Council of Carpenters 1 From:Ranta, Owen <OwenRanta@chevron.com> Sent:Friday, December 16, 2022 2:42 PM To:Whorley, Serenity Subject:RE: PFAS appt with Regional Board Thanks for the info, Serenity! Happy holidays- Owen Ranta Manager – Pre-Execution Strategy Environmental Management & Real Estate Company 276 Tank Farm Road San Luis Obispo, CA Tel: (805) 546-6912 Mobile: (815) 530-6939 E-mail: owenranta@chevron.com From: Whorley, Serenity <swhorley@slocity.org> Sent: Thursday, December 15, 2022 4:34 PM To: Ranta, Owen <OwenRanta@chevron.com>; 'Damien Mavis' <dmavis@covelop.net>; 'Pat Arnold' <parnold@covelop.net>; ddixon@rouxinc.com; Tulledge, Kim [Arcadis] <Kim.Tulledge@chevron.com>; bhulburd@covelop.net Subject: [**EXTERNAL**] RE: PFAS appt with Regional Board Be aware this external email contains an attachment and/or link. Ensure the email and contents are expected. If there are concerns, please submit suspicious messages to the Cyber Intelligence Center using the Report Phishing button. Hi Owen, The City Attorney will not be in attendance for the meeting. You should be seeing an invite in your inbox shortly. Best, Serenity Whorley pronouns she/her/hers Supervising Administrative Assistant Public Utilities 879 Morro Street, San Luis Obispo, CA 93401-3249 E swhorley@slocity.org T 805.781.7013 slocity.org 2 Stay connected with the City by signing up for e-notifications From: Ranta, Owen <OwenRanta@chevron.com> Sent: Thursday, December 15, 2022 4:25 PM To: Whorley, Serenity <swhorley@slocity.org>; 'Damien Mavis' <dmavis@covelop.net>; 'Pat Arnold' <parnold@covelop.net>; ddixon@rouxinc.com; Tulledge, Kim [Arcadis] <Kim.Tulledge@chevron.com>; bhulburd@covelop.net Subject: RE: PFAS appt with Regional Board Serenity- I’m being asked to check on the attendee list for the meeting among the City, Water Board staff, Covelop and Chevron. To be transparent in our rationale…we are checking to see if the City is planning to have attorneys present, as that will likely mean tha t Chevron will want to add an attorney to our requested attendees. Are you able to let me know if the City Attorney is planning to attend, please? Thank you! Owen Ranta Manager – Pre-Execution Strategy Environmental Management & Real Estate Company 276 Tank Farm Road San Luis Obispo, CA Tel: (805) 546-6912 Mobile: (815) 530-6939 E-mail: owenranta@chevron.com From: Whorley, Serenity <swhorley@slocity.org> Sent: Wednesday, December 14, 2022 3:22 PM To: 'Damien Mavis' <dmavis@covelop.net>; 'Pat Arnold' <parnold@covelop.net>; ddixon@rouxinc.com; Ranta, Owen <OwenRanta@chevron.com>; Tulledge, Kim [Arcadis] <Kim.Tulledge@chevron.com>; bhulburd@covelop.net Subject: [**EXTERNAL**] RE: PFAS appt with Regional Board Be aware this external email contains an attachment and/or link. Ensure the email and contents are expected. If there are concerns, please submit suspicious messages to the Cyber Intelligence Center using the Report Phishing button. Good afternoon, I am assisting Aaron with scheduling this meeting. It is proving to be a little tricky and I was hoping you might have flexibility in your schedules. Do you have availability on December 22 nd, between 1pm-3pm? If we are unable to make that timeframe work, we will need to push this meeting to January 17th. Thank you, Serenity Whorley pronouns she/her/hers Supervising Administrative Assistant 3 Public Utilities 879 Morro Street, San Luis Obispo, CA 93401-3249 E swhorley@slocity.org T 805.781.7013 slocity.org Stay connected with the City by signing up for e-notifications From: Floyd, Aaron <afloyd@slocity.org> Sent: Tuesday, December 13, 2022 1:34 PM To: Whorley, Serenity <swhorley@slocity.org> Subject: FW: PFAS appt with Regional Board From: Bryan Hulburd <bhulburd@covelop.net> Sent: Tuesday, December 13, 2022 11:35 AM To: Floyd, Aaron <afloyd@slocity.org> Cc: 'Damien Mavis' <dmavis@covelop.net>; 'Pat Arnold' <parnold@covelop.net>; ddixon@rouxinc.com; 'Ranta, Owen' <OwenRanta@chevron.com>; 'Tulledge, Kim [Arcadis]' <Kim.Tulledge@chevron.com> Subject: RE: PFAS appt with Regional Board This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hi Aaron – thank you for helping us coordinate. Below are the final attendees we would like included in this meeting. Their email addresses are included in this thread and it’s best to send the meeting invites directly to them. Damien Mavis – Covelop David Dixon – Roux (Covelop’s Environmental Consultant) Kim Tulledge – Chevron Owen Ranta – Chevron This group is all available at the below times for an in-person meeting with the Water Board: 12/28 or 12/29 – after 1:30pm 1/3 – 1/5 – after 1:30pm 1/10 – 1/12 – after 1:30pm If you have any questions, please let me know. Thank you, Bryan Bryan Hulburd Project Manager 4 bhulburd@covelop.net Begin forwarded message: From: "Ranta, Owen" <OwenRanta@chevron.com> Subject: RE: PFAS appt with Regional Board Date: December 12, 2022 at 2:45:33 PM PST To: "Floyd, Aaron" <afloyd@slocity.org> Cc: "parnold@covelop.net" <parnold@covelop.net>, "dmavis@covelop.net" <dmavis@covelop.net>, "Tulledge, Kim [Arcadis]" <Kim.Tulledge@chevron.com> Aaron- From the Chevron side, I would like to attend, but I also believe it is important for Kim Tulledge to be invited. She has much more connectivity to the particulars of Chevron’s general redevelopment plan/commitments than do I. As for availability, Kim and I could both be available for the following:  Thursday 12/15, any time 2:30 through end of day.  The week between Christmas and New Year (12/26 – 12/30) except 12/27.  Jan 2 through noon Jan 6  Jan 10 - 13 You could work directly with me. As for Covelop’s information, I trust you will get that from one of them. Thanks, Owen Ranta Manager – Pre-Execution Strategy Environmental Management & Real Estate Company 276 Tank Farm Road San Luis Obispo, CA Tel: (805) 546-6912 Mobile: (815) 530-6939 E-mail: owenranta@chevron.com From: Floyd, Aaron <afloyd@slocity.org> Sent: Monday, December 12, 2022 10:28 AM To: parnold@covelop.net; dmavis@covelop.net; Ranta, Owen <OwenRanta@chevron.com> Subject: [**EXTERNAL**] PFAS appt with Regional Board Be aware this external email contains an attachment and/or link. Ensure the email and contents are expected. If there are concerns, please submit suspicious messages to the Cyber Intelligenc e Center using the Report Phishing button. Good morning. 5 I’ve been in contact with the Regional Water Board in regards to setting up a meeting to discuss PFAS. As discussed previously, we believe that a limited number of people in attendance would be better received. From the City, it would be Derek Johnson and me. Could you please answer the following highlighted questions to assist with scheduling. From Covelop, would you like Damien and Pat to attend? Then for the challenge of scheduling. Do you have any preferrable times? This could be in a broad sense or specific days – just trying to narrow the possibilities. Should I have our City staff work directly with you to set up the appointment or is there someone who manages your calendar? I, or one of our City staff, will follow up when I hear back from you. Thanks Aaron Aaron Floyd Utilities Director Public Utilities 879 Morro Street, San Luis Obispo, CA 93401-2710 E afloyd@slocity.org T 805.781.7205 slocity.org Stay connected with the City by signing up for e-notifications 1 From:Beech, Ryan Sent:Friday, January 26, 2024 9:08 AM To:Beech, Ryan Subject:Fwd: A lot of Emission Regulations. FW: Permit copies. Attachments:PTO 646-4.pdf; PTO 960-2.pdf; PTO 961-2.pdf; PTO 1610-7.pdf; PTO 1630-2.pdf; PTO 1809-3.pdf; PTO 1850-2.pdf; Conditional Exemption 2368-1.pdf; DOORS Registered Equipment.JPG; DOORS CARB idle policy faq.pdf Get Outlook for iOS From: Felt, Chris <cfelt@slocity.org> Sent: Wednesday, January 24, 2024 5:26:33 PM To: Floyd, Aaron <afloyd@slocity.org>; Boerman, Mychal <mboerman@slocity.org>; Lehman, Chris <clehman@slocity.org>; Meeks, Jason <jmeeks@slocity.org>; Henderson, Marcus <mhenders@slocity.org>; Beech, Ryan <RBeech@slocity.org>; Evans, Noah <nevans@slocity.org>; McGrath, Patrick <pmcgrath@slocity.org> Cc: Cruce, Greg <gcruce@slocity.org> Subject: A lot of Emission Regulations. FW: Permit copies. Hello folks, To help wrap up City emissions reporting ownership, I sent a request to the APCD for a copy of every permit issued to SLO City. They are attached above, minus the Fire station and PW stationary generators. If there is equipment that is not covered by the above, or by PERP / DOORS reporting (see below) let’s communicate to find the best solution and which system to report it in. If you have APCD permits that are not attached above, the APCD should be contacted for explanation and possibly to update the registered agency name information. When renewals are sent in, a copy of the operating conditions are not returned with the renewed permit, hence the importance of having the original permit that contains that information located with the equipment. The State equipment reporting system for portable equipment is called PERP - (Portable Equipment Registration Program). Chris Leman created an excellent spreadsheet showing the PERP equipment and our stationary units, linked here: City of SLO APCD Permits and CARB PERP Registrationed Equipment.xlsx I added some additional data fields and filled in information where I could. Another State emission reporting system for diesel off-road equipment that is driven by an operator is called DOORS - (Diesel Off-road Online Reporting System). I have attached all ‘Registrationed’ (sounds painful, but that’s what the APCD called it!) equipment above. Note the EIN numbers assigned; these decals must remain on the equipment, so please have operators be careful not to blast them away with a pressure washer – if missing or damaged, let me know and I will source replacement EIN decals. Fun Stuff! A new law affecting all PERP and DOORS equipment: starting January 1st, 2024, all units must be fueled with R99 or R100 renewable diesel only. Maintaining proof of this with detailed fueling records is now a requirement of the operating permit. Since most of these items are fueled at the CY, and we use R99 in our diesel tank, Fleet will have 2 proof of proper fuel usage. If users routinely fuel off-site, please make them aware of this new requirement. All remote diesel tanks (Whale Rock, WTP, LLGC) will be R99, so it won’t be an issue if equipment is fueled from these sources. More R99 info: due to a superior refining process, renewable diesel has lower emissions, a long storage life, and with its high purity, less fuel filter and DPF clogging than biodiesel or even conventional diesel. Therefore, I recommend using this fuel in stationary generators as well. Red-Dyed renewable diesel is now available from JB Dewar for these applications, and they are happy to answer any questions regarding this fuel. I may as well mention an old but still enforced law; the maximum 5-minute idle time regulation. I’ve highlighted the good parts and attached it above. We are considered a small fleet in this application, so we are not required to have a written idling policy. Page 6 shows the penalty of up to $10,000 per day – yikes! There are some exemptions, and waivers may be applied for – naturally before a violation notice. I will include idling guidelines in the City drivers / operators Vehicle Use Policy currently being drafted by HR / Risk Management. Please reach out with any questions or comments, I’m happy to help where I can. Chris Felt Fleet Maintenance Supervisor Public Works Fleet Services 25 Prado Road, San Luis Obispo, CA 93401-7314 E cfelt@slocity.org T 805.781.7046 C 805.431.0843 slocity.org Stay connected with the City by signing up for e-notifications From: Kristin A. Weeks <kweeks@co.slo.ca.us> Sent: Monday, January 22, 2024 3:46 PM To: Felt, Chris <cfelt@slocity.org> Subject: RE: Permit copies Hi Chris, Hope you are doing well! I have attached all the permits for the City. If you have any questions or concerns please feel free to reach out. Sincerely, Kristin Weeks | Administrative Assistant III SLO County Air Pollution Control District 3433 Roberto Court, SLO 93401 805-781-4101 • SLOCleanAir.org • SLOCarFree.org 3 From: Felt, Chris <cfelt@slocity.org> Sent: Friday, January 19, 2024 12:54 PM To: Kristin A. Weeks <kweeks@co.slo.ca.us> Subject: [EXT]RE: Permit copies ATTENTION: This email originated from outside the County's network. Use caution when opening attachments or links. That is totally fine! Thanks and Happy Friday to you as well! Have a great (hopefully not to rainy) weekend, Chris From: Kristin A. Weeks <kweeks@co.slo.ca.us> Sent: Friday, January 19, 2024 9:01 AM To: Felt, Chris <cfelt@slocity.org> Subject: Permit copies This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Good Morning, I just wanted to let you know that I have not forgotten about you. Its been crazy here, I will try to start working on these today but I do have meetings as well. I’m hoping to get them all to you by early next week. Sorry for the delay and Happy Friday!! Sincerely, Kristin Weeks | Administrative Assistant III SLO County Air Pollution Control District 3433 Roberto Court, SLO 93401 805-781-4101 • SLOCleanAir.org • SLOCarFree.org T 805.781.5912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401 P E R M I T TO O P E R A T E Number 1630-2 EQUIPMENT OWNER-OPERATOR: City of San Luis Obispo - Department of Utilities 879 Morro Street San Luis Obispo, CA 93401 EQUIPMENT LOCATION: Site ID: 4156 City of San Luis Obispo WWTP Lift Station, 276 Tank Farm Road, San Luis Obispo EQUIPMENT DESCRIPTION: Tank Farm lift station consisting of: One (1) 250 kW Cummins Power Equipment Model DQDAA-7549912, emergency standby generator driven by a Cummins Model QSL9-G3, S/N 4690075, EPA Family # 8CEXL0540AAB, 399 bhp, Tier 3 diesel engine with 17.0 hours on August 12, 2009. CONDITIONS: 1. Non-Emergency Operation a. Non-emergency operation shall be limited to maintenance and performance testing only and shall not exceed thirty (30) hours per engine per calendar year. Operation for emissions testing required by the District shall not be limited by this condition. b. The Air Pollution Control Officer (APCO) shall be notified in writing within seven (7) days of exceeding the yearly non-emergency operation limit. c. An emergency is defined as failure of normal electrical power service that is beyond the control of the permit holder and does not include voluntarily disconnecting from utility grid power. 2. Only diesel fuel that meets the California Air Resources Board's specifications for on-road use shall be used to fuel the engine(s) unless otherwise approved by the APCO. Records of the fuel purchases shall be maintained to demonstrate compliance with this condition. San Luis Obispo City - Tank Farm Lift Station Permit to Operate Number 1630-2 August 17, 2021 Page 2 of 4 CONDITIONS (continued): 3. Visible emissions from the engine shall not exceed Ringelmann No. ½ or ten percent (10%) opacity for periods aggregating more than three (3) minutes in any hour. 4. A non-resettable hour meter for each engine shall be installed and maintained unless an APCO-approved alternative tracking procedure is approved. 5. The engine exhaust shall discharge vertically free of obstructions. 6. An operating log for the current calendar year shall be maintained for each engine on a monthly basis. Entries shall also be made for any day that the engine is operated and for any day that the engine receives fuel. The logs shall be retained for at least three (3) years and shall include the following data: a. Operating mode: emergency, maintenance, or District required testing b. Engine hour meter reading at start-up, c. Engine hour reading at shutdown, d. Operating hours for the calendar day, e. Running total calendar year to date operating hours, f. Running total calendar year to date operating hours in maintenance mode, g. Running total calendar year to date operating hours in emergency mode, h. Estimated fuel use for the day in gallons, i. Running total calendar year to date fuel use in gallons, j. Fuel purchased in gallons, and k. Total costs of any engine repair or reconstruction, excluding consumable items associated with standard maintenance activities. 7. Within fourteen (14) days of a request, the following information shall be submitted to the APCO for the previous calendar year for each engine: a. Maintenance operating hours, b. Emergency operating hours, c. District required testing operating hours, d. Total engine operating hours, e. Total fuel usage, f. Copies of all fuel purchase records, and g. Total cost of engine repairs to date for each engine. 8. The APCO shall be notified prior to the repair or reconstruction of any diesel engine under permit. Consumable items used for regular main tenance, such as filters, hoses, belts, fluids, and glow plugs, are not considered repairs. In addition, replacement parts costing less than $1,000.00 can be omitted from this requirement. This condition is a result of a state regulation on rebuilds or repairs. Extensive repairs could trigger lower allowable emission rates. If lower emission rates apply, they may not be achievable with a simple rebuild. 9. Temporary Engine Replacement: Any engine subject to this permit may be temporarily replaced with another engine if all the requirements listed in sections a. through e. below are satisfied: San Luis Obispo City - Tank Farm Lift Station Permit to Operate Number 1630-2 August 17, 2021 Page 3 of 4 CONDITIONS (continued): a. The APCO shall be notified in writing or by fax at (805) 781-1002 within seventy-two (72) hours of a permitted engine being replaced. The notification shall include the replacement engines make, model, rated horsepower, engine family number if available, the current engine hour meter reading, manufacturer’s particulate matter and oxides of nitrogen (NOx) emission rates in grams per horsepower-hour (g/hp-hr) and the reason for the replacement. b. The permitted engine is in need of routine repair or maintenance and is returned to its original service within 180 days of installation of the temporary engine. c. The temporary replacement engine has the same or lower emission rate in g/hp-hr for particulate matter and NOx as the permitted engine that is being temporarily replaced or if written approval from the APCO is obtained for an engine that meets current permitting requirements. For breakdown conditions reported under the procedures of Rule 107, Breakdowns or Upset Conditions and Emergency Variances, the APCO may approve the use of any replacement engine that meets the requirements of the State Airborne Toxic Control Measure and would not create a public nuisance. d. The temporary replacement engine shall comply with all conditions of this permit, including but not limited to, engine operating hour limits, recordkeeping and reporting requirements. e. The APCO shall be notified in writing or by fax at (805) 781-1002 within fourteen (14) days of removal of the temporary engine. 10. This equipment shall be operated and maintained in accordance with the manufacturer's recommendations and the information presented in the application under which this permit was granted. 11. If the APCO determines that the operation of this equipment is causing a public nuisance, the owner/operator shall take immediate action and eliminate the nuisance. 12. The APCO shall be notified and authorization obtained prior to making any changes in operating procedures, equipment, or materials used which have the potential to increase the emission of any air contaminant or which would change the equipment description or the applicability of a permit condition. 13. All information needed to estimate air pollution emissions shall be provided to the District upon request. This information may consist of, but is not limited to throughput data, process variables, device characteristics, and pollutant release characteristics. 14. This permit is not transferable to a new owner or location without the APCO's approval. A change of ownership application shall be submitted to the APCO at least ten (10) working days prior to any change in the person, partnership, company, corporation, or agency that is responsible for the operation of the equipment San Luis Obispo City - Tank Farm Lift Station Permit to Operate Number 1630-2 August 17, 2021 Page 4 of 4 CONDITIONS (continued): described above. An authority to construct application must be submitted and approved by the APCO prior to moving the permitted equipment to a new location. August 17, 2021 August (Annually) ISSUANCE DATE ANNIVERSARY GARY E. WILLEY Air Pollution Control Officer DORA K. DREXLER Manager, Engineering & Compliance Division Application Number: 7187 H:\PERMITS\PO\7187PO.DOCX 1 From:Cohen, Rachel Sent:Monday, January 9, 2023 10:56 AM To:Bultema, Graham Subject:RE: PR Request: The Link Mixed Use Master Plan Weird. Trevor works for the County. I will see about responding. Thanks! Rachel Cohen pronouns she/her/hers Senior Planner Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E rcohen@slocity.org T 805.781.7574 slocity.org Stay connected with the City by signing up for e-notifications From: Bultema, Graham <gbultema@slocity.org> Sent: Monday, January 9, 2023 10:54 AM To: Cohen, Rachel <rcohen@slocity.org> Subject: FW: PR Request: The Link Mixed Use Master Plan From: Community <community@careca.org> Sent: Friday, January 6, 2023 5:04 PM To: Planning <planning@slocity.org> Subject: PR Request: The Link Mixed Use Master Plan This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. January 6th, 2023 Via Email and U.S. Mail City of San Luis Obispo Attn: Trevor Keith 1055 Monterey St San Luis Obispo, CA 93408 2 planning@slocity.org RE: Public Records Act Request and Request for Mailed Notice of Public Hearings and Actions – The Link Mixed Use Master Plan, 276 Tank Farm Road, San Luis Obispo, CA 93401 Dear Mr. Keith, CARE CA is writing to request a copy of any and all records related to the project, The Link Mixed Use Master Plan, located at 276 Tank Farm Road in San Luis Obispo. The project will be the construction of 725 multifamily attached units, 69,150 square feet of retail mixed use space, 279,700 square feet of professional and medical office uses, 209,000 square feet of industrial and warehouse space, and 237,200 square feet of mixed service commercial uses. We are also writing to request copies of all mailed notice of any and all hearings and/or actions related to the Project. Our request for mailed notice of all hearings includes hearings, study sessions and community meetings related to the Project, certification of the MND (or recirculated DEIR), and approval of any Project entitlements. This request is made pursuant to Public Resources Code Sections 21092.2, 21080.4, 21083.9, 21092, 21108 and 21152 and Government Code Section 65092, which require local agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Our request includes notice to any City actions, hearings or other proceedings regarding the Project, Project approvals and any actions taken, or additional documents released pursuant to the California Environmental Quality Act. Our request for all records related to the Project is made pursuant to the California Public Records Act. (Government Code § 6250 et seq.) This request is also made pursuant to Article I, section 3(b) of the California Constitution, which provides a constitutional right of access to information concerning the conduct of government. Article I, section 3(b) provides that any statutory right to information shall be broadly construed to provide the greatest access to government information and further requires that any statute that limits the right of access to information shall be narrowly construed. We will pay for any direct costs of duplication associated with filling this request up to $200. However, please contact me at (951) 540-1290 with a cost estimate before copying/scanning the materials. Pursuant to Government Code Section 6253.9, if the requested documents are in electronic format and are 10 MB or less (or can be easily broken into sections of 10 MB or less), please email them to me as attachments. My contact information is: U.S. Mail Jeff Modrzejewski CARE CA 501 Shatto Place, Suite 200 Los Angeles, CA. 90020 Email community@careca.org Please call me if you have any questions. Thank you for your assistance with this matter. 3 Sincerely, Jeff Modrzejewski Executive Director 1 From:Cohen, Rachel Sent:Monday, January 9, 2023 11:14 AM To:community@careca.org Subject:276 Tank Farm Hello- The City of SLO has received the email below that appears to be meant for the County of SLO (Trevor Keith works for the County of SLO). You can reach the Planning Division at mlarue@co.slo.ca.us or find their webpage at https://www.slocounty.ca.gov/Departments/Planning-Building.aspx. If this email was intended for the City of San Luis Obispo, please let us know. Note that 276 Tank Farm is located in the Cou nty of SLO, however the Link is a project that has been submitted to the City and includes an annexation. The application is NOT complete and no notices or hearings are scheduled or have happened regarding this project. Sincerely, Rachel Cohen pronouns she/her/hers Senior Planner Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E rcohen@slocity.org T 805.781.7574 slocity.org Stay connected with the City by signing up for e-notifications From: Community <community@careca.org> Sent: Friday, January 6, 2023 5:04 PM To: Planning <planning@slocity.org> Subject: PR Request: The Link Mixed Use Master Plan This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. January 6th, 2023 Via Email and U.S. Mail City of San Luis Obispo Attn: Trevor Keith 2 1055 Monterey St San Luis Obispo, CA 93408 planning@slocity.org RE: Public Records Act Request and Request for Mailed Notice of Public Hearings and Actions – The Link Mixed Use Master Plan, 276 Tank Farm Road, San Luis Obispo, CA 93401 Dear Mr. Keith, CARE CA is writing to request a copy of any and all records related to the project, The Link Mixed Use Master Plan, located at 276 Tank Farm Road in San Luis Obispo. The project will be the construction of 725 multifamily attached units, 69,150 square feet of retail mixed use space, 279,700 square feet of professional and medical office uses, 209,000 square feet of industrial and warehouse space, and 237,200 square feet of mixed service commercial uses. We are also writing to request copies of all mailed notice of any and all hearings and/or actions related to the Project. Our request for mailed notice of all hearings includes hearings, study sessions and community meetings related to the Project, certification of the MND (or recirculated DEIR), and approval of any Project entitlements. This request is made pursuant to Public Resources Code Sections 21092.2, 21080.4, 21083.9, 21092, 21108 and 21152 and Government Code Section 65092, which require local agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Our request includes notice to any City actions, hearings or other proceedings regarding the Project, Project approvals and any actions taken, or additional documents released pursuant to the California Environmental Quality Act. Our request for all records related to the Project is made pursuant to the California Public Records Act. (Government Code § 6250 et seq.) This request is also made pursuant to Article I, section 3(b) of the California Constitution, which provides a constitutional right of access to information concerning the conduct of government. Article I, section 3(b) provides that any statutory right to information shall be broadly construed to provide the greatest access to government information and further requires that any statute that limits the right of access to information shall be narrowly construed. We will pay for any direct costs of duplication associated with filling this request up to $200. However, please contact me at (951) 540-1290 with a cost estimate before copying/scanning the materials. Pursuant to Government Code Section 6253.9, if the requested documents are in electronic format and are 10 MB or less (or can be easily broken into sections of 10 MB or less), please email them to me as attachments. My contact information is: U.S. Mail Jeff Modrzejewski CARE CA 501 Shatto Place, Suite 200 Los Angeles, CA. 90020 Email community@careca.org Please call me if you have any questions. Thank you for your assistance with this matter. 3 Sincerely, Jeff Modrzejewski Executive Director 1 From:Christian, Kevin Sent:Thursday, December 1, 2022 2:55 PM To:Maria Sarmiento Cc:CityClerk; City_Attorney Subject:Records Request DETERMINATION: PRR22294 Tsai - 276 Tank Farm Rd Attachments:PRR22294 Tsai - 276 Tank Farm Rd.pdf Maria The City of San Luis Obispo (“City”) received your request pursuant to the California Public Records Act delivered via email on November 18, 2022. We have determined that we do have records responsive to your request. A review of those records will be scheduled and records will be released following review, except where any exemptions apply. Kevin Christian, CMC Deputy City Clerk City Administration City Clerk's Office 990 Palm Street, San Luis Obispo, CA 93401-3218 E kchristian@slocity.org T 805.781.7104 slocity.org Bcc: Cohen Ph: (626) 381-9248 Fx: (626) 389-5414 Em: info@mitchtsailaw.com Mitchell M. Tsai Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 VIA E-MAIL November 18, 2022 Teresa Purrington, City Clerk City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 Em: tpurrington@slocity.org RE: Public Records Act and Advance Notice List Request Regarding the 276 Tank Farm Road Project Dear City Clerk, On behalf of Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”) and its members, this Office requests that the City of San Luis Obispo City”) provide any and all information referring or related to the 276 Tank Farm Road Project (“Project”) pursuant to the California Public Records Act (“PRA”), Cal. Government (“Gov’t”) Code §§ 6250–6270 (collectively “PRA Request”). Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. The Southwest Regional Council of Carpenters is a labor union representing more than 50,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning and addressing the environmental impacts of development projects, such as the Project. I. PUBLIC RECORDS ACT REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 2 of 7 Southwest Carpenters is requesting any and all information referring or related to the Project. The Public Records Act defines the term “public record” broadly as “any writing containing information relating to the conduct of the public’s business . . . regardless of physical form and characteristics.” Gov’t Code § 6252(d). “Records” includes all communications relating to public business regardless of physical form or characteristics, including but not limited to any writing, picture, sound, or symbol, whether paper, magnetic, electronic, text, other media, or written verification of any oral communication. Included in this request are any references in any appointment calendars and applications, phone records, or text records. These “records” are to include, but are not limited to correspondences, e-mails, reports, letters, memorandums, and communications by any employee or elected official of the City concerning the Project. Please include in your response to this request the following examples of “records,” as well as any similar physical or electronic forms of communication: any form of writing such as correspondence, electronic mail records (“email”), legal and factual memoranda, facsimiles, photographs, maps, videotapes, film, data, reports, notes, audiotapes, or drawings. Cal. Government Code § 6252(g) (defining a writing to including “any record thereby created, regardless of the manner in which the record has been stored”). Responsive correspondence should include, inter alia, emails, text messages, or any other form of communication regardless of whether they were sent or received on public or privately-owned electronic devices “relating to the conduct of the public’s business.” Cal. Government Code § 6252(e); Citizens for Ceres v. Super. Ct. Ceres”) (2013) 217 Cal. App. 4th 889, 909; Citizens for Open Gov’t v. City of Lodi Lodi”) (2012) 205 Cal.App.4th 296, 307, 311; City of San Jose v. Superior Court (2017) 2 Cal. 5th 608, 625 (finding that a public employee or officer’s “writings about public business are not excluded” from the California Public Records Act “simply because they have been sent, received, or stored in a personal account.”) . This Office requests any and all information referring or related to the Project, including but not limited to: 1) All Project application materials; 2) All staff reports and related documents prepared by the City with City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 3 of 7 respect to its compliance with the substantive and procedural requirements of the California Environmental Quality Act, Public Resources Code § 21000 et seq., and the CEQA Guidelines, title 14, California Code of Regulations, § 15000 et seq. (collectively CEQA”) and with respect to the action on the Project; 3) All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the agency pursuant to CEQA; 4) Any transcript or minutes of the proceedings at which the decisionmaking body of the City heard testimony on, or considered any environmental document on, the Project, and any transcript or minutes of proceedings before any advisory body to the public agency that were presented to the decisionmaking body prior to action on the environmental documents or on the Project; 5) All notices issued by the City to comply with CEQA or with any other law governing the processing and approval of the Project; 6) All written comments received in response to, or in connection with, environmental documents prepared for the Project, including responses to the notice of preparation; 7) All written evidence or correspondence submitted to, or transferred from, the City with respect to compliance with CEQA or with respect to the Project; 8) Any proposed decisions or findings submitted to the decisionmaking body of the City by its staff, or the Project proponent, Project opponents, or other persons; 9) The documentation of the final City decision and approvals, including the final environmental impact report, mitigated negative declaration, negative declaration, or notice of exemption, and all documents, in addition to those referenced in paragraph (3), cited or relied on in the findings or in a statement of overriding City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 4 of 7 considerations adopted pursuant to CEQA; 10) Any other written materials relevant to the public agency's compliance with CEQA or to its decision on the merits of the Project, including the initial study, any drafts of any environmental document, or portions thereof, that have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the Project and either made available to the public during the public review period or included in the City 's files on the Project, and all internal agency communications, including staff notes and memoranda related to the Project or to compliance with CEQA; and 11) The full written record before any inferior administrative decisionmaking body whose decision was appealed to a superior administrative decisionmaking body prior to the filing of any litigation. Please respond within 10 days from the date you receive this request as to whether this request specifies identifiable records not exempt from disclosure under the PRA or otherwise privileged or confidential, and are therefore subject to disclosure. This Office understands that this time may be extended up to 14 days for unusual circumstances as provided by Cal. Government Code § 6253(c), and that we will be notified of any extension and the reasons justifying it. We request that you provide all documents in electronic format and waive any and all fees associated with this Request. SWRCC is a community-based organization. Please notify and obtain express approval from this Office before incurring any duplication costs. If any of the above requested documents are available online, please provide us with the URL web address at which the documents may be downloaded. If any of the requested documents are retained by the City in electronic computer-readable format such as PDF (portable document format), please provide us with pdf copies of the documents via email, or inform us of the location at which we can copy these documents electronically. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 5 of 7 In preparing your response, please bear in mind that you have an obligation under Government Code section 6253.1 to (1) identify all records and information responsive to our request or the purpose of our request; (2) describe the information technology and physical location in which the records exist; and (3) provide suggestions for overcoming any practical basis for denying access to the records or information sought. In responding to this request, please bear in mind that any exemptions from disclosure you may believe to be applicable are to be narrowly construed. Marken v. Santa Monica- Malibu Unif. Sch. Dist. (2012) 202 Cal. App. 4th 1250,1262; and may be further narrowed or eliminated by the adoption of Proposition 59, which amended article I, section 3(b)(2) of the California Constitution to direct that any “statute ... or other authority ... [that] limits the right of access” to “information concerning the conduct of the people’s business” must be “narrowly construed.” As for any records that you nonetheless decline to produce on the grounds of an exemption, please bear in mind that the case law under the Public Records Act imposes a duty on you to distinguish between the exempt and the non-exempt portion of any such records, and to attempt in good faith to redact the exempt portion and to disclose the balance of such documents. Please bear in mind further that should you choose to withhold any document from disclosure, you have a duty under Government Code section 6255, subd. (a) to “justify withholding any record by demonstrating that the record in question is exempt under express provisions” of the Public Records Act or that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” Finally, please note that you must retain and not destroy any and all records, notwithstanding any local record retention or document destruction policies. As the Court noted in Golden Door Properties, LLC v. Superior Court of San Diego County (2020) 53 Cal.App.5th 733 that a public agency “must retain ‘[a]ll written evidence or correspondence submitted to, or transferred from’ . . . with respect to” CEQA compliance or “with respect to the project.” II. ADVANCE NOTICE LIST REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 6 of 7 We also ask that you put this Office on its notice list for any and all notices issued under the CEQA and the Planning and Zoning Law. In particular, we request that the City send by mail or electronic mail notice of any and all actions or hearings related to activities undertaken, authorized, approved, permitted, licensed, or certified by the City and any of its subdivision for the Project, or supported, in whole or in part, through permits, contracts, grants, subsidies, loans, or other forms of approvals, actions or assistance, including but not limited to the following: Notices of any public hearing held in connection with the Project; as well as Any and all notices prepared pursuant to CEQA, including but not limited to: Notices of determination that an Environmental Impact Report EIR”) or supplemental EIR is required for a project, prepared pursuant to Public Resources Code Section 21080.4; Notices of availability of an EIR or a negative declaration for a project prepared pursuant to Public Resources Code Section 21152 and Section 15087 of Title 14 of the California Code of Regulations; Notices of approval or determination to carry out a project, prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of approval or certification of any EIR or negative declaration prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of exemption from CEQA prepared pursuant to Public Resources Code section 21152 or any other provision of law; and Notice of any Final EIR prepared pursuant to CEQA. This Office is requesting notices of any approvals or public hearings under CEQA and the California Planning and Zoning Law. This request is filed pursuant to California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 7 of 7 65092 requiring agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Please send notice by regular and electronic mail to: Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 Em: maria@mitchtsailaw.com Em: mitch@mitchtsailaw.com Em: reza@mitchsailaw.com Em: info@mitchtsailaw.com We look forward to working with you. If you have any questions or concerns, please do not hesitate to contact our Office. Sincerely, Mitchell M. Tsai Attorneys for Southwest Regional Council of Carpenters 1 From:Scott McAlpin <smcalpin@trihydro.com> Sent:Monday, April 1, 2024 2:27 PM To:Schani Siong Cc:r4lsa@wildlife.ca.gov; Ross, Emma B CIV USARMY CESPL (USA); Michaela Craighead; Grosso, Diana@Wildlife; Stong, Nate; Diel, Christopher; Cisneros, Luis D; Mailloux, Michael; Beacom, James; Matt Clark; Iliana Arroyos Subject:2024 SLO Tank Farm Annual Pre-Activity Biological Survey Report Attachments:202404_AnnualPre-ActivitySurvey_RPT.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Dear Ms. Siong: Pursuant to the County of San Luis Obispo Conditional Use Permit DRC2013-00056 and Amended CUP DRC2015-00067, Condition of Approval Numbers 43, 78, and 83, and the California Department of Fish and Wildlife Streambed Alteration Agreement Measures No. 2.3 and 2.4, provided is the 2024 Pre-Activity Biological Survey Report for the San Luis Obispo Tank Farm Remediation Project. Should you have any questions or comments regarding the referenced report, please contact me by email or phone at (307) 745- 7474. Thank you, ScoƩ McAlpin, PG Project Geologist 142 Cross Street, Suite 200 San Luis Obispo, CA 93401 (989) 506-1105 (mobile) (307) 745-7474 (office) smcalpin@trihydro.com www.trihydro.com Sign up to receive industry updates in your inbox. CONFIDENTIAL INFORMATION: This electronic message is intended only for the use of the person or enƟty to which it is addressed and may contain informaƟon that is privileged and confidenƟal, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby noƟfied that any disseminaƟon, distribuƟon or copying of this informaƟon is STRICTLY PROHIBITED. If you have received this message in error, please immediately noƟfy the sender by either email or telephone. Please destroy the related message. Thank you for your cooperaƟon. 202404_AnnualPre-ActivitySurvey_RPT.docx 2024 PRE-ACTIVITY BIOLOGICAL SURVEY REPORT RESERVOIR 5 AND 7 AREAS DEMOLITION, GRADING AND RESTORATION SAN LUIS OBISPO TANK FARM REMEDIATION AND RESTORATION PROJECT SAN LUIS OBISPO COUNTY, CALIFORNIA April 1, 2024 Project #: CHEVR-024-0023 PREPARED BY: Trihydro Corporation 1252 Commerce Drive, Laramie, WY 82070 PREPARED FOR: Chevron Environmental Management Company 276 Tank Farm Road, San Luis Obispo, CA 93401 202404_AnnualPre-ActivitySurvey_RPT.docx AUTHENTICITY AND SIGNATURE PAGE Trihydro Corporation hereby certifies that all statements furnished in the following Pre-Activity Biological Resources Report and all supporting information required for this biological evaluation are true and correct to the best of our knowledge and belief. Further, we certify that all field surveys associated with this report were performed by Trihydro Corporation using standards accepted by San Luis Obispo County and accurately represent all information retained from field visits to the San Luis Obispo Tank Farm Property operated by Chevron Environmental Management Company, San Luis Obispo County, California. ____________________________________ ____________________________________ Scott McAlpin Iliana Arroyos Project Manager Biologist ____________________________________ Matt Rhodes Ecologist 202404_AnnualPre-ActivitySurvey_RPT.docx Table of Contents EXECUTIVE SUMMARY ........................................................................................................................I 1.0 INTRODUCTION ................................................................................................................... 1-1 1.1 Project Description .................................................................................................... 1-1 1.2 Regulatory Setting ..................................................................................................... 1-2 1.2.1 San Luis Obispo County ............................................................................... 1-2 1.2.2 California Department of Fish and Wildlife ................................................... 1-5 2.0 METHODS ............................................................................................................................. 2-1 2.1 Desktop Review ........................................................................................................ 2-1 2.2 Field Activities ........................................................................................................... 2-1 2.2.1 Special-status Plant Species Population Mapping ....................................... 2-2 2.2.2 Plant Community Field Verification............................................................... 2-2 2.2.3 Bloom and Seed Status Surveys .................................................................. 2-3 2.2.4 Seed Collection ............................................................................................. 2-3 2.2.5 Plant Salvage ................................................................................................ 2-5 2.2.6 Weed Management ...................................................................................... 2-5 2.2.7 California Red-legged Frog Surveys ............................................................ 2-5 2.2.8 Burrowing Owl ............................................................................................... 2-6 2.2.9 Nesting Bird Surveys .................................................................................... 2-6 2.2.10 Vernal Pool Fairy Shrimp Habitat ................................................................. 2-6 2.2.11 Wetlands and Waters ................................................................................... 2-7 3.0 RESULTS .............................................................................................................................. 3-1 3.1 Special-status Plant Species Population Mapping ................................................... 3-1 3.2 Plant Community Field Verification ........................................................................... 3-1 3.3 Bloom and Seed Status Surveys .............................................................................. 3-2 3.4 Seed Collection ......................................................................................................... 3-2 3.5 Plant Salvage ............................................................................................................ 3-2 3.6 Weed Management ................................................................................................... 3-2 3.7 California Red-legged Frog Surveys ......................................................................... 3-2 3.8 Burrowing Owl Surveys ............................................................................................. 3-3 3.9 Nesting Bird Surveys ................................................................................................. 3-3 202404_AnnualPre-ActivitySurvey_RPT.docx Table of Contents (cont.) 3.10 Vernal Pool Fairy Shrimp Habitat .............................................................................. 3-3 3.11 Wetlands and Waters ................................................................................................ 3-4 4.0 DISCUSSION ......................................................................................................................... 4-1 5.0 REFERENCES ...................................................................................................................... 5-1 202404_AnnualPre-ActivitySurvey_RPT.docx List of Tables 2-1. Summary of Field Activities 3-1. Special-Status Plant Acreages within Proposed Work Areas 3-2. Plant Community Acreages within Proposed Work Areas 202404_AnnualPre-ActivitySurvey_RPT.docx List of Figures 3-1. Pre-Activity Botanical Survey Results Map; Special-Status Plants 3-2. Pre-Activity Botanical Survey Results Map; Plant Communities 3-3. Pre-Activity Biological Survey Results Map; Special-Status Wildlife 202404_AnnualPre-ActivitySurvey_RPT.docx List of Appendices A. BOTANICAL SURVEY GUIDELINES B. SITE PHOTOGRAPHS C. VERNAL POOL FAIRY SHRIMP PRE-ACTIVITY USFWS CONSULTATION LETTER D. CALIFORNIA RED-LEGGED FROG PRE-ACTIVITY SURVEY DATA SHEETS 202404_AnnualPre-ActivitySurvey_RPT.docx i EXECUTIVE SUMMARY The following Pre-Activity Biological Survey Report (Report) has been prepared by Trihydro Corporation (Trihydro) in support of the proposed San Luis Obispo Tank Farm (SLO Tank Farm) Remediation and Restoration Project (Project), on behalf of Chevron Environmental Management Company (Chevron). The purpose of this Report is to provide the results of pre-activity biological surveys conducted by Trihydro in compliance with Project permits, prior to the initiation of the 2024 Project activities within the Reservoir 5 and 7 areas, the aggregate stockpile area, the south contractor staging area, and the Flower Mound borrow area. The 2024 Project activities consist of remediation and restoration of the Reservoir 5 and 7 areas and include completion of the installation of a permanent soil cap, with the potential sourcing of borrow material from the Flower Mound borrow area. Per the County of San Luis Obispo Conditional Use Permit (DRC2013-00056), Amended Conditional Use Permit (CUP; DRC2015-00067) Condition of Approval (COA) Numbers (No.) 43, 78, and 83, and the California Department of Fish and Wildlife (CDFW) Streambed Alteration Agreement (SAA) (Notification No. 1600-2015-0094-R4) Measures No. 2.3 (a-g), and 2.4, Trihydro completed pre-activity biological surveys for botanical resources and special- status wildlife in 2023 and the beginning of 2024. Pre-activity nesting bird surveys (COA Nos. 82 and 93) will be conducted immediately prior to all vegetation removal for the duration of Project activities, which will occur during nesting bird season (February 15 through August 31). All vernal pool fairy shrimp (Branchinecta lynchi; VPFS) features within the proposed 2024 work areas were removed or restored during 2022 and 2023 remediation activities. Prior to their removal, inoculum was collected from seven vernal pools (FS-20, FS-22, FS-42, FS-53, FS-55, FS-67, and FS-81) that were determined to contain adequate VPFS cyst densities for the inoculation of constructed restoration pools. Collected VPFS inoculum was utilized to create planned VPFS features as described in the Vernal Pool Habitat Restoration and Monitoring Plan (Appendix H of the Landscape Restoration Plan [Padre, 2015a]). All VPFS features adjacent to the 2023/2024 work areas were delineated and protected prior to 2023 ground disturbance to avoid incidental impacts and include FS-22, FS-23, FS-24, FS-25, FS-27, FS-45, FS-46, FS-55, FS-57, and FS-80. Based on the desktop survey and pre-activity field surveys conducted in proposed 2024 work areas, plant communities observed within the 2024 planned work areas include non-native annual grassland, serpentine bunch grassland, and palustrine nonpersistent emergent vernal swale/pool. All special-status plants and plant communities within Reservoir 5, Reservoir 7, the aggregate stockpile work area, and contractor staging area were impacted or removed during 2022 and 2023 work activities. The work activities in 2024 include the potential for new disturbance in the Flower Mound borrow area, where serpentine dudleya and purple needlegrass grassland were documented during 2024 ii 202404_AnnualPre-ActivitySurvey_RPT.docx pre-activity surveys. As of the date of this Report, it is uncertain whether 2024 work activities will cause new disturbance in the Flower Mound borrow area. While this Report includes acreages of special-status plants and plant communities in previously undisturbed portions of the Flower Mound borrow area, note that Project-related impacts to special-status plants and plant communities in the Flower Mound borrow area have already been accounted for and mitigated. No special-status wildlife species, including state protected species, were observed during 2024 pre-activity surveys. This Report includes a summary of field activities, survey methods, and results of the botanical resources and special- status wildlife pre-activity surveys conducted prior to commencement of 2024 Project activities. Figures, photographs, and associated documents are included as appendices to this Report. 202404_AnnualPre-ActivitySurvey_RPT.docx 1-1 1.0 INTRODUCTION The following Pre-activity Biological Survey Report (Report) has been prepared by Trihydro Corporation (Trihydro) in support of the San Luis Obispo Tank Farm (SLO Tank Farm) Remediation and Restoration Project (Project), on behalf of Chevron Environmental Management Company (Chevron). The objective of the biological resources pre-activity surveys was to identify the special-status botanical and wildlife resources that may be disturbed by 2024 Project activities, per the County of San Luis Obispo (County) Conditional Use Permit (DRC2013-00056), Amended Conditional Use Permit (CUP; DRC2015-00067) Condition of Approval (COA) Number (No.) 78 and 83, and the California Department of Fish and Wildlife (CDFW) Streambed Alteration Agreement (SAA) (Notification No. 1600-2015-0094-R4) Measures No. 2.3 (a-g), and 2.4 (a-b). The 2024 Project activities consist of completing remediation and restoration of the Reservoir 5 and 7 areas that began in 2022, with associated activity in the aggregate stockpile area, contractor staging area, and Flower Mound borrow area. Most 2024 work activities will occur in areas previously disturbed during remediation work that occurred in 2022 and 2023. Limited new disturbance may occur in the Flower Mound borrow area. This Report includes the mapped results of pre-activity botanical resource surveys conducted in 2021 and 2022, within and adjacent to the proposed 2023/2024 work areas that were disturbed in 2023. Note that the 2021-2022 pre-activity botanical resource survey results provide the most current status of special-status plant populations within the proposed 2024 work areas, in accordance with Project permit conditions. However, recognizing the potential for new disturbance in the Flower Mound borrow area, Trihydro completed an updated pre-activity botanical survey in 2024 of the Flower Mound area to verify plant communities and special-status plant populations in this area. Also included in this Report are the results of the pre- activity California red-legged frog (Rana draytonii), burrowing owl (Athene cunicularia), and nesting bird surveys conducted in February and March 2024. Although pre-activity surveys are not required for vernal pool fairy shrimp (Branchinecta lynchi; VPFS), management of vernal pool fairy shrimp occupied habitat occurring adjacent to the proposed 2024 work areas is also discussed within this Report. Figures, photographs, and associated documents are included as appendices to this Report. 1.1 PROJECT DESCRIPTION The Project activities proposed for 2024 will occur within the Reservoir 5 and 7 areas, aggregate stockpile area, contractor staging area, and Flower Mound borrow area. The 2024 Project will consist of the following activities:  Clean soil stockpiling  Backfill and topsoil replacement 1-2 202404_AnnualPre-ActivitySurvey_RPT.docx  Restoration of Reservoir 5 and 7 Areas  Potential excavation of borrow material from the Flower Mound borrow area 1.2 REGULATORY SETTING This section summarizes the regulations and policies administered by resource agencies pertaining to pre-activity surveys required for the proposed 2024 work areas. These areas fall under the scope of the pre-activity requirements of the County CUP and the CDFW SAA. 1.2.1 SAN LUIS OBISPO COUNTY Prior to Project initiation, a California Environmental Quality Act (CEQA) review and approval was required. The City of San Luis Obispo (SLO) and the County of SLO entered into a Memorandum of Understanding in February 2013, which designated the City of SLO as acting lead agency for CEQA review. The City of SLO certified the Final Environmental Impact Report (FEIR) in September 2014 and the County of SLO issued CUP. An Amended CUP was issued in June 2021 to allow for an increased volume of Non-Hazardous Impacted Soils (NHIS) removal and approval of haul routes to allow for disposal of NHIS at the Cold Canyon Landfill. Mitigation measures identified in the FEIR were adopted by the County and issued as Exhibit B-Conditions of Approval CUP. Permit requirements that are discussed in this section include Amended CUP COA Nos. 43, 78, 79, 80, 82, 83, and 93. COA No. 43 (BIO-1c) states, The final restoration plan shall provide for plant salvaging and replanting where appropriate (e.g., San Luis Obispo dudleya), restoration, and/or creation of habitat suitable for special-status plant species including Cambria morning glory, Congdon’s tarplant, San Luis Obispo owl’s clover, Hoover’s button-celery, San Luis Obispo serpentine dudleya, and purple needlegrass. COA No. 78 (BIO-1b) states, Prior to commencement of grading, the applicant shall conduct updated surveys of sensitive species habitats (including sensitive plant species, CRLF, wetland habitat, and VPFS habitat) within the project site within the appropriate season immediately prior to the onset of any ground disturbances associated with the project in order to evaluate the current occupancy of suitable habitat for sensitive species and to refine the final habitat mitigation replacement acreages. Updated surveys for federally listed species shall be completed per the timing and methodology specified by resource agency protocol. 202404_AnnualPre-ActivitySurvey_RPT.docx 1-3 COA No. 79 (BIO-1i) states, The VPFS-qualified biologist shall conduct sensitive vernal pool branchiopod surveys within the appropriate season immediately prior to the start of construction activities per the timing and methodology specified by USFWS protocol. The VPFS qualified biologist shall monitor during construction activities in the vicinity of habitats to be avoided. The final acreage of habitat loss shall be revised as necessary to adequately mitigate actual disturbance to habitats for listed and special- status species due to remediation. COA No. 80 (BIO-1j) states, The VPFS-qualified biologist shall conduct cyst collection efforts (cyst-bearing soil) and storage efforts from work areas prior to construction activities from the entire work area of each impacted pool when the ephemerally wetted areas are dry. The VPFS-qualified biologist shall follow USFWS standard procedures and guidance established in that agency’s permitting process. The cysts shall be stored in labeled containers that are adequately ventilated. The cysts shall be kept out of direct sunlight to prevent excessive heating of the soil. The cysts shall be kept out of direct contact with water. When restored VPFS habitat is constructed, the inoculum shall be placed within the surface layer of the soil in a manner following USFWS protocols and guidance. COA No. 82 (BIO-2e) states, Hawks and owls nest earlier than most other native birds. If initial construction activities, ground disturbance, or vegetation clearing involving vegetation removal/trimming occur from December 1 through August 31, the nest monitor would conduct a pre-construction survey within three days prior to vegetation removal or other construction-related disturbances focused on actively nesting hawks or owls. If any actively nesting hawks or owls are found, a 500-foot buffer would be established around the nest tree to help ensure that nesting is not disrupted. The buffer would be delineated by orange construction fencing and signage and would remain in place until the nest is either abandoned or the young have fledged. The nest monitor would be present when any buffer fencing is established. COA No. 83 (BIO-7a) states, A qualified biologist shall conduct surveys throughout areas proposed to be disturbed to determine the presence of wildlife species prior to ground disturbance. The biologist shall be on site during initial site disturbances (i.e., brush removal, topsoil disturbances). Wildlife species encountered during the initial disturbances shall be relocated to suitable habitat out of potential danger. All handling and relocation of sensitive and non-sensitive wildlife species shall be conducted by biologists with appropriate authorizations and permits (CDFW and USFWS). Remediation activities, including restoration efforts shall be regularly monitored throughout the remediation and restoration phases to 1-4 202404_AnnualPre-ActivitySurvey_RPT.docx ensure that wildlife species have not entered work areas. The biological monitor shall conduct regular site inspections of the remediation and restoration activities to ensure that all applicable mitigation measures are being enacted. The biological monitor shall have the authority to temporarily halt activities if permit requirements and conditions are not being met. The biological monitor shall prepare an annual summary report describing site visit observations and shall provide this report to the City, County, and regulatory agencies (including CDFW, USACE, and USFWS) for review. COA No. 93 (BIO-2d) states, To minimize potential impacts to nesting native bird species, and in compliance with the federal Migratory Bird Treaty Act and Sections 3503, 3503.5, or 3513 of the California Fish and Game Code, all activities resulting in ground disturbances during all phases of remediation, restoration, pipe removal, and construction activities involving vegetation removal/trimming shall be done, as feasible, outside the breeding season (February 15 through August 31). If vegetation must be removed during this period, then the Applicant shall retain a biologist acceptable to the County in consultation with the City to conduct surveys for nesting birds. Surveys shall be conducted within three days prior to vegetation removal or other construction-related disturbances. If nesting birds are observed within the vicinity, then a minimum 100-foot buffer from the nest would be established. The buffer would be delineated by orange construction fencing or other delineator approved by County in consultation with the City and signage and would remain in place until the nest is abandoned or the young have fledged. The qualified biologist shall be present when any buffer fencing is established. The qualified biologist shall monitor the nest to ensure that Project activities do not violate the Migratory Bird Treaty Act or the California Fish and Game Code. At minimum, the biologist would check for new active nests, and determine the status of ongoing active nests, weekly during the specified nesting season. The biologist would ensure that all fencing and signage was properly maintained, and would provide weekly, or less frequent if requested by the agencies, e-mail updates on the status of all monitored nests to the County, City, CDFW, and USFWS. If the biologist determines that nesting is being disrupted, the construction activities shall cease and wait until a new buffer area is determined, the young have fledged, or the nest is determined to have failed. 202404_AnnualPre-ActivitySurvey_RPT.docx 1-5 1.2.2 CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE The CDFW SAA also contains conditions that pertain to pre-activity biological surveys. Permit requirements that are discussed in the section include CDFW SAA Measures No. 2.3 (a-g), 2.4 (b), and 4.2. 2.3 Listed and Other Special-Status Species (a) Pre-activity surveys for potential rare, listed, or other sensitive status species shall be conducted by a qualified biologist within 30 days prior to commencement of Project activities. Surveys shall be conducted within the work area and all access routes to avoid and minimize incidental take, confirm previous observations, identify any areas occupied by listed or sensitive species, and clearly mark all resources to be avoided by Project activities. If any State- or Federally- listed threatened or endangered species are found or could be impacted by the work proposed, Permittee shall notify CDFW of the discovery immediately. An amended Agreement and/or an Incidental Take Permit may be warranted. (b) Western Pond Turtle and Western Spadefoot: All western pond turtles and western spadefoot discovered at the Project site immediately prior to or during Project activities shall be allowed to move out of the area of their own volition; if this is not feasible, they shall be captured by a qualified biologist and relocated out of harm’s way to the nearest suitable habitat immediately upstream or downstream from the Project site. (c) California Red-Legged Frog (CRLF): If water is present within 250 feet of the Project work area, a qualified biologist shall survey the Project site for CRLF within 48 hours prior to commencing work. Survey results shall be submitted to CDFW. Between October 15 and April 30, vegetation within the Project work area that will be disturbed or removed shall be removed by hand prior to the use of heavy equipment or machinery. If CRLF are found prior to the Project or at any time during Project activities, work shall cease or shall not commence (whichever applies) until CDFW has been contacted and has given written approval for work to continue. All CRLF individuals shall be allowed to leave the Project work area unharmed. Permittee shall contact CDFW within 24 hours of each detection. (d) Southern Steelhead (South Central California Coast DPS): Project activity shall not occur within the wetted channel. (e) American Badger: American badger detected within the Project work area during Project activities shall be allowed to move out of the work area of its own volition. If American badger is denning on or immediately adjacent to a Project work area, Permittee shall consult with CDFW 1-6 202404_AnnualPre-ActivitySurvey_RPT.docx to determine whether the animal(s) may be evicted from the den. Eviction of badgers will not be approved by CDFW unless it is confirmed that no dependent young are present. (f) Burrowing Owl: A qualified wildlife biologist shall survey for burrowing owl within a 500-foot radius of the Project site, within 30 days prior to starting Project activities each year. Surveys shall be conducted at appropriate times to maximize detection. If any active burrowing owl burrows are observed, these burrows shall be designated an ESA, protected, and monitored by a qualified biologist during Project-related activities. A minimum 500-foot avoidance buffer shall be established and maintained around each owl burrow during the nesting season (February 1 through August 31). If active burrowing owl burrows are observed outside of the nesting season, a minimum 150-foot no disturbance buffer shall be established around each burrow. Eviction of owls from burrows is not authorized by CDFW in this Agreement. (g) Special-Status Plant Species: If suitable habitat for any special-status plant species is present within a work area, a qualified botanist shall conduct focused Plant Surveys for these plants within one year prior to the start of Project activities. Repeated floristic surveys shall be conducted by a qualified botanist multiple times during the appropriate floristic period(s) in order to adequately assess the potential impacts to special-status plant species. If any listed or other special-status plant species is found, Permittee shall identify them with flagging and avoid plants with a 25-foot no disturbance buffer. If a buffer around non-listed plant species is not feasible, CDFW may approve a buffer reduction in writing and in advance of the buffer reduction, provided that Permittee proposes written alternate methods to minimize impacts; for example salvaging topsoil after plants have set seed, and replacing it in areas of temporary disturbance to the affected species. 2.4 Fish and Wildlife (b) Pursuant to FGC Sections 3503 and 3503.5, it is unlawful to take, possess, or destroy the nest or eggs of any bird or bird-of-prey. To protect nesting birds, no Project activity shall be completed from February 15 through August 31 unless the following Avian Nest Surveys are completed by a qualified biologist within 30 days prior to Project initiation. Birds of Prey: Survey for nesting activity of birds of prey within a 500-foot radius of each Project work area. If any active nests are observed, these nests shall be designated an ESA and protected by a minimum 500-foot avoidance buffer until the breeding season has ended or until a qualified biologist has determined that the young have fledged and are no longer reliant upon the nest or parental care for survival. 202404_AnnualPre-ActivitySurvey_RPT.docx 1-7 Other Avian Species: Survey for nesting activity within a 250-foot radius of the defined work area. If any nesting activity is found, these nests shall be designated an ESA and protected with a minimum 250-foot buffer until young have fledged and are no longer reliant on the nest site or parental care. CDFW may consider variances from these buffers when there is a compelling biological or ecological reason to do so, such as when the Project area would be concealed from a nest site by topography. 4.2 Reports. Permittee shall submit the following Reports to CDFW: Construction/work schedule submitted to CDFW prior to Project commencement (Administrative Measure 1.8) A Training Sign-in Sheet submitted to CDFW within one (1) week of completing training (Administrative Measure 1.9) Pre-activity survey results provided to CDFW at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.3[a]) Results of California red-legged frog surveys submitted to CDFW no more than one (1) week from the completion of the survey (Avoidance and Minimization Measure 2.[c]) Results of surveys for burrowing owls, submitted to CDFW at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.[f]) Results of Plant Surveys submitted at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.3[g]) Results of surveys for nesting birds if any Project activity is scheduled during the avian nesting season, submitted to CDFW at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.4[b]) In compliance with COA No. 78, Trihydro conducted a botanical resources survey in the spring to capture the blooming period of the special-status plant species and plant community components, when the plants were readily identifiable. In addition, Trihydro conducted California red-legged frog pre-activity surveys of all aquatic habitat within and adjacent to the proposed 2024 work areas. Padre consulted with the USFWS in regard to updating the vernal pool fairy shrimp surveys and received approval in a correspondence dated January 25, 2016, to forego updating the surveys (COA No. 79) based on the Project’s history of comprehensive survey data. In compliance with COA No. 82, and No. 93, Trihydro conducted burrowing owl and nesting bird surveys prior to ground disturbance. In 1-8 202404_AnnualPre-ActivitySurvey_RPT.docx compliance with COA No. 83, Trihydro will continue to conduct wildlife clearance surveys for the duration of the Project, as necessary. 202404_AnnualPre-ActivitySurvey_RPT.docx 2-1 2.0 METHODS Methods to collect sensitive wildlife data and botanical resources information for the proposed 2024 work areas include a desktop review and field activities. Both methods are discussed in this section. 2.1 DESKTOP REVIEW The desktop review incorporated an aerial imagery review of the Project site and proposed 2024 work areas, which included an approximately 10-foot (ft) buffer. The desktop review also included an examination of multiple sources of technical survey information pertaining to biological resources within the Project site, including the following:  Description and Analysis of the Botanical Resources, Including Vascular Plant Species of Conservation Concern, at the Chevron Tank Farm Facility, San Luis Obispo, California (Padre and WSP 2008)  Landscape Restoration Plan, Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project, San Luis Obispo County, California (Padre 2015a)  Botanical Pre-Activity Survey Guidelines for Special-Status Plants and Plant Communities. In-house document prepared by Padre. (Padre 2015b)  California Red-legged Frog Survey Report for the Chevron San Luis Obispo Tank Farm, San Luis Obispo County, California (Padre 2014)  CDFW California Natural Diversity Database query of updated occurrences of California red-legged frog, burrowing owl, and western pond turtle within San Luis Obispo County (CDFW 2024)  Previous annual pre-activity biological survey reports for the Project (Padre 2018; Trihydro 2019, 2020a, 2021a, 2022a, and 2023a)  Biological Resources Monitoring Program Annual Summary Report (Padre 2019; Trihydro 2020b, 2021b, 2022b, 2023b, and 2024) 2.2 FIELD ACTIVITIES Pre-construction biological field activities completed within the proposed 2024 work areas included a special-status plant mapping reconnaissance survey, plant community field verification survey, CRLF day and night surveys, burrowing owl surveys, and nesting bird surveys. Trihydro staff involved in the field activities included: Victoria Trautman, Roxanne Nolan, Steven Belus, and Iliana Arroyos. The survey dates and personnel for all field activities are summarized in Table 2-1. 2-2 202404_AnnualPre-ActivitySurvey_RPT.docx 2.2.1 SPECIAL-STATUS PLANT SPECIES POPULATION MAPPING The special-status plant species previously documented as occurring within SLO Tank Farm property include Cambria morning glory (Calystegia subacaulis ssp. episcopalis), San Luis Obispo owl’s clover (Castilleja densiflora ssp. obispoensis), Congdon’s tarplant (Centromadia parryi ssp. congdonii), Hoover’s button celery (Eryngium aristutalum var. hooveri), San Luis Obispo serpentine dudleya (Dudleya abramsii ssp. bettinae), and California walnut (Juglans californica) (Padre and WSP, 2008). In addition, areas comprised of greater than 10 percent (%) purple needlegrass, are considered special-status plant communities and mapped as special-status plant species populations. In compliance with the permit conditions, the status of existing special-status plant populations will be assessed immediately prior to disturbance, during the appropriate season when plants are readily identifiable. Trihydro biologists conducted a pre-activity special-status plant species survey in June 2021 within the proposed Reservoir 5 and 7, and the aggregate stockpile areas for 2022-2024 work activities. Most surfaces within the 2024 work areas were graded, excavated, or otherwise disturbed during 2022 and 2023 remediation work, and therefore no special-status plant populations persist in these areas. Planned 2024 work activities include potential new disturbance in the Flower Mound borrow area. Most of this area was disturbed during prior remediation work, but a portion of the proposed 2024 work area includes areas that were not previously disturbed and contain special-status species and communities for which impacts have already been mitigated. During special-status plant species population mapping in 2021-2024, Trihydro biologists drove on established access roads and walked the terrain within and adjacent to all proposed work areas. A field map illustrating previously mapped special-status plant populations (Padre and WSP, 2008) was utilized as a field reference. The mapping schedule was dependent on the blooming period when species were most identifiable. Per the Padre Botanical Survey Guidelines (Appendix A), Trihydro biologists identified special-status populations through direct observation of blooms and/or morphological characteristics, then installed temporary pin flags around the extent of the population. Populations were documented using a hand-held global positioning system (Trimble and ArcGIS Collector GPS unit). 2.2.2 PLANT COMMUNITY FIELD VERIFICATION Per the Padre Botanical Survey Guidelines (Appendix A), a field survey was conducted to verify the existing plant communities within the proposed 2024 work areas. The plant community field verification survey was conducted in conjunction with the 2021-2022 special-status plant species mapping surveys. As noted above, since 2024 Project activities include potential new disturbance in the Flower Mound borrow area, a field survey was conducted on March 25, 2024, to verify plant communities and special-status plant populations in this area are similar in extent to when originally mapped. Note that plant communities are readily identifiable throughout the year. Observations and 202404_AnnualPre-ActivitySurvey_RPT.docx 2-3 general composition of the plant communities were compared to previously mapped plant communities (Padre and WSP, 2008). 2.2.3 BLOOM AND SEED STATUS SURVEYS During 2023 remediation activities in Reservoir 5 and 7 and in the aggregate stockpile area, all plant communities within the 2024 work areas were impacted and removed. Due to the early spring Project start date, it was not feasible to conduct bloom and seed status surveys of the undisturbed areas in 2022, and as such, these were instead conducted during spring and summer of 2021. The purpose of these surveys is to assist in scheduling seed collection when seed is mature within the future work areas. Section 2.2.5 describes seed collection methods. Per the Botanical Survey Guidelines, qualitative reconnaissance surveys within the proposed 2024 work areas were conducted periodically throughout the spring and summer months of 2021 to determine the bloom and seed status of special-status species. During bloom and seed status field surveys, biologists drove on established access roads and walked the terrain within the proposed 2024 work areas and an approximately 50-ft buffer. Direct visual observations of the subject species were recorded. The bloom status observations were used to predict and schedule seed collection events, and as a general indicator of the size and density of the special-status plant populations within the SLO Tank Farm property. Seed collection was conducted following observation of mature seed within a population. Specific plant characteristics that were utilized to determine seed maturity on all special-status plant species documented to occur within the SLO Tank Farm property were as follows:  Cambria morning glory. Flower has dropped or is intact but dry, leaves green to brown, capsule is visible, seed is brown to black and is easily removed from capsule.  San Luis Obispo owl’s clover. Dried blooms intact, stems and leaves green to brown, seed is brown and can be seen when pod is crushed with fingers.  Congdon’s tarplant. Dried/remnant blooms intact, stems and leaves pale green to brown, seed is dark brown to black and can be seen when pod is crushed with fingers.  Hoover’s button celery. Dried/remnant blooms intact, stems and leaves pale green to brown, seed can be seen when pod is crushed with fingers.  Purple needlegrass. Inflorescence is intact, awns are bent, and seed is easily removed from the stalk by hand. 2.2.4 SEED COLLECTION Seed was last collected during spring of 2022. The purpose of seed collection is to obtain seed for plant propagation and increase seed for future restoration activities. Seed Collection Data Sheets were used to document the target 2-4 202404_AnnualPre-ActivitySurvey_RPT.docx species, date of collection, approximate population size of collection area (as number of plants and acreage of population), the plant height, and assessment of seed vigor (healthy, insect-damaged, undeveloped, moldy, or other damage). Methods and techniques utilized for collection were dependent on the target species. Following observation of mature seed during bloom/seed status surveys, seed was collected. General seed collection techniques consisted of hand-pulling and or vegetation clipping, dependent on which species was being collected. Seed was bagged in envelopes or bags, and sent to CaliFlora Resources, a local native seed and processing company, for processing, and then returned for storage. Summary of seed collection and methods are as follows:  Cambria morning glory. No seed from this species was collected in 2023. Previous seed collected had poor germination rates and it was determined that vegetatively collecting plants/divisions would be more efficient than seed collection. As described below, the top 6 to 12 inches of soil containing Cambria morning glory is also salvaged.  San Luis Obispo owl’s clover. 0.25 pounds of seed was collected from approximately 100 plants in April 2022. Plants were collected from the development area adjacent to Borrow Area No. 2. Plants were pulled and placed into buckets for transport to the processing facility. No seed was collected in 2023.  Congdon’s tarplant. No seed from this species was collected in 2023. The large surplus of Congdon’s tarplant seed collected during 2021 activities is sufficient to restore the vernal pool acreage impacted during 2022 and 2023 activities.  Hoover’s button celery. No seed from this species was collected in 2023 as there are no Hoover’s button celery in the proposed 2024 work area. Previous seed collection methods consisted of cutting stems and plants with inflorescences with hand clippers and placing into buckets.  Purple needlegrass. No seed was collected in 2023 and no future seed collection is planned. Seed collected from 2009 – 2015 was tested for viability, and results indicated that majority of the seed, collected on-site, had very low viability. It was determined that seed purchased from a vendor would be a cost-effective method to obtain the quantities of viable seed necessary for future restoration.  California walnut. No seed from this species was collected in 2023. California walnut is located within the oxbow areas in the future proposed work areas, and one California walnut tree may be impacted by work activities in the future. California walnut seed was collected in 2021 and was used to begin growth of saplings in an offsite growing facility.  San Luis Obispo serpentine dudleya. No seed from this species was collected in 2023. All (337) serpentine dudleya that occurred on site were salvaged in 2015 and donated to the San Luis Obispo Botanical Garden since no suitable habitat would be present on the project sites after remediation activities. 202404_AnnualPre-ActivitySurvey_RPT.docx 2-5 2.2.5 PLANT SALVAGE Salvage methods consist of collecting the top 12- to 24-inches of topsoil containing Cambria morning glory and/or purple needlegrass rhizomes, seed, and/or vegetative plants, with an excavator, dozer, or skid steer. Plant salvaging activities will only take place in occurrences growing on clean soils. If plants are near contaminated soil areas, the salvaged topsoil will either be lab tested and only used if clean or discarded along with the excavated contaminated soil if found to be impacted. The salvaged material will be immediately transported to a designated patch population plot chosen based on similar habitat and environmental conditions, and the occurrence of an existing population adjacent to the transplant plot. The soil will then be raked to achieve a suitable thickness to promote seedling, rhizome, and root establishment. No plant salvage is anticipated for 2024 Project activities. 2.2.6 WEED MANAGEMENT Weed management activities will be implemented in accordance with the Landscape Restoration Plan (Padre, 2015a) to minimize the presence of noxious and non-native plant species within the proposed 2024 work areas. Weed management activities within the 2024 work areas will begin in spring of 2024. A qualified herbicide contractor will spot spray target species within the 2024 work areas. 2.2.7 CALIFORNIA RED-LEGGED FROG SURVEYS Per Amended CUP COA No.78 (BIO-1b), updated CRLF surveys were conducted immediately prior to ground disturbance in vicinity of the 2024 planned work areas. The 2024 CRLF surveys were conducted during the breeding season, using protocols detailed in the Revised Guidance on Site Assessments and Field Surveys for the California Red- legged (Guidance) published by the USFWS in 2005. The surveys focused on suitable aquatic habitat inside and within 250 feet of the planned work areas. Surveys were conducted by Trihydro biologists Iliana Arroyos, Victoria Trautman, Roxanne Nolan, and Steven Belus, on February 27 and March 5, 12, and 19, 2024. Prior to entering aquatic habitat, Trihydro biologists decontaminated all equipment in accordance with the Recommended Equipment Decontamination Procedures found in Appendix B of the Guidance to limit the spread of pathogens and parasites (USFWS, 2005). Weather and water temperature data were recorded before each survey. Daytime surveys focused on identifying egg masses, larvae, metamorphs, and metamorphosing sub-adults. Prior to entering the aquatic habitats, and approximately every 33 meters (m) (100 feet) within the habitat, Trihydro biologists stopped to listen for frog calls. Care was taken when entering and exiting the aquatic habitat to avoid crushing root- balls, overhanging banks, and creekside vegetation that may have provided shelter for frogs. 2-6 202404_AnnualPre-ActivitySurvey_RPT.docx Nighttime surveys followed the same approach as the daytime surveys while focusing on identifying sub-adult and adult CRLF. Trihydro biologists utilized LED Maglite® flashlights (less than 100,000 candle watt) and binoculars (Bushnell® 10X42 and Nikon® 10X42) to detect and identify eye-shine. Trihydro biologists listened for frog calls and estimated the abundance of each species that was detected. In addition, any observations of potential CRLF predators were documented on data sheets. 2.2.8 BURROWING OWL Pre-activity burrowing owl surveys were conducted in tandem with the CRLF surveys. Trihydro biologists systematically surveyed the proposed 2024 work areas and at least 500 feet of surrounding habitat, searching for owl activity, potential burrows, whitewash, pellets/prey remains, and signs of nesting behavior. In addition, biologists listened for alarm calls and vocalizations from fledglings. 2.2.9 NESTING BIRD SURVEYS Preliminary nesting bird surveys were conducted in conjunction with the burrowing owl surveys completed on March 26, 2024. The survey consisted of walking transects through the proposed 2024 work areas and inspecting trees, shrubs, and grasslands for nests. During the survey, the biologists listened for bird vocalizations and alarm calls, and watched for nesting or territorial behaviors. Another nesting bird survey will be completed in April 2024, and surveys will continue throughout the construction season whenever vegetation or new ground will be disturbed. 2.2.10 VERNAL POOL FAIRY SHRIMP HABITAT Project USFWS Biological Opinion (BO; SPL-2014-00444) does not contain any pre-activity survey conditions for VPFS; however, Amended CUP COA Nos. 78, 79, and 80 require pre-activity surveys and topsoil collection within VPFS habitat features that will be impacted. After consultation with USFWS, it was concluded that additional VPFS pre-activity surveys will not be required (Appendix C - vernal pool fairy shrimp Pre-Activity USFWS Consultation Letter). As such, a desktop survey was completed to identify any VPFS habitat within the proposed 2024 work areas. No VPFS inoculum collection is planned for 2024 work activities. All VPFS adjacent to the proposed 2024 work areas was properly delineated and protected prior to ground disturbance in 2022 to avoid incidental impacts. Any impacted VPFS-occupied habitat will be included within the final impact acreages, reported in the Annual Project Status and Habitat Restoration Monitoring Report, and mitigated as detailed in the Landscape Restoration Plan (Padre, 2015a). 202404_AnnualPre-ActivitySurvey_RPT.docx 2-7 2.2.11 WETLANDS AND WATERS The Project RWQCB Section 401 Water Quality Certification (No. 34015WQ06) does not contain any conditions for conducting pre-activity surveys prior to wetland and waters disturbance, however, Amended CUP COA No. 45 requires that all wetlands and waters be replaced per the Landscape Restoration Plan (Padre, 2015). As such, a desktop survey was completed to identify any existing waters and wetlands within the proposed 2024 work areas. 202404_AnnualPre-ActivitySurvey_RPT.docx 3-1 3.0 RESULTS The following discussion includes findings of the 2024 pre-activity biological surveys within SLO Tank Farm (Figures 3-1, 3-2, and 3-3). 3.1 SPECIAL-STATUS PLANT SPECIES POPULATION MAPPING Based on the spring and summer 2021-2022 pre-activity botanical surveys of the proposed 2024 work areas, four special-status plant species were mapped within the proposed 2024 work areas and consisted of the following: Cambria morning glory, San Luis Obispo owl’s clover, San Luis Obispo serpentine dudleya, and purple needlegrass grassland. Most of the plant communities and populations within the 2024 work areas were impacted or otherwise removed during 2022 and 2023 remediation activities. As a result, the only special-status plant populations detected within the 2024 pre-activity survey area were San Luis Obispo serpentine dudleya and purple needlegrass grassland, both of which were documented in the Flower Mound borrow area. As noted above, Project-related impacts to these species were previously mitigated. While San Luis Obispo serpentine dudleya has re-colonized the Flower Mound area, all San Luis Obispo serpentine dudleya plants that were present before the initiation of remediation activities were salvaged and relocated. During the 2024 pre-activity verification survey, this species was documented in areas of rocky serpentine microhabitat; it is unclear if 2024 work activities would disturb these areas. Similarly, as noted above in Section 2.2.4, restoration of purple needlegrass, if necessary, is best accomplished by purchasing seed from a reputable vendor. While Table 3-1 provides the resulting acreages of special-status plant populations and communities in previously undisturbed portions of the Flower Mound borrow area, note that Project-related impacts to special-status plants and plant communities in this area have already been accounted for and mitigated. Locations of special-status plants and plant communities are shown on Figure 3-1. 3.2 PLANT COMMUNITY FIELD VERIFICATION Plant community boundaries were originally mapped in the field in 2008. Based on the spring and summer 2022 plant community field verification survey, disturbed/ruderal habitat and three plant communities were documented to occur within the proposed 2024 work areas. These include palustrine nonpersistent emergent vernal swale/pool, serpentine bunch grassland, and non-native annual grassland. Most of the plant communities within the 2024 work areas were impacted or otherwise removed during 2022 and 2023 remediation activities. However, 2024 work activities include the potential for new disturbance in the Flower Mound borrow area. Table 3-2 provides the resulting acreages for previously undisturbed portions of the 2024 work areas and Figure 3-2 shows the locations of the community types. 3-2 202404_AnnualPre-ActivitySurvey_RPT.docx 3.3 BLOOM AND SEED STATUS SURVEYS Bloom and seed status surveys were conducted in spring and summer 2022, as discussed in Methods Section 2.2.3. The purpose of these surveys was to assist in scheduling seed collection when seed is likely to be mature. The bloom and seed status surveys conducted in 2022 resulted in successful collection of San Luis Obispo owl’s clover mature seed from Borrow Area No. 2. 3.4 SEED COLLECTION Special-status plant seed was collected in April 2022, as discussed in Methods Section 2.2.4. Collected seed was shipped to CaliFlora Resources for processing. No seed collection has been completed since 2022. 3.5 PLANT SALVAGE Approximately 0.10 acres of Cambria morning glory, and 1.62 acres of San Luis Obispo owl’s clover were salvaged from the work areas prior to 2022 work activities. Most 2024 work activities will occur in these same areas, and therefore no further plant salvage is anticipated for 2024 work areas. 3.6 WEED MANAGEMENT As observed in the winter/spring of 2022, there were scattered dense patches of invasive, non-native plant species including yellow star thistle (Centauria solsticialis), Black mustard (Brassica nigra), and bristly ox-tongue (Helminthotheca echioides). These species remain present at the Project site. Weed management will be implemented during 2024 Project activities. 3.7 CALIFORNIA RED-LEGGED FROG SURVEYS During daytime and nighttime surveys, surface water was detected in areas adjacent to the proposed 2024 work areas (Figure 3-3). The site received above average rainfall during the 2023-2024 wet season, which increased the number, size, and depth of wetlands that were inundated during the winter on the Project site. During the protocol six-week survey period, CRLF habitat was increased on the Project site due to the winter rain events with above average rainfall. The majority of the aquatic habitat has been historically seasonally ponded, with the exception of the East Fork San Luis Obispo Creek (Creek) which runs along the southern boundary of the Project site and can be described as an intermittent to perennial tributary to the main channel of San Luis Obispo Creek as described in the Landscape Restoration Plan (Padre, 2015a). 202404_AnnualPre-ActivitySurvey_RPT.docx 3-3 Trihydro biologists observed or heard approximately 253 Sierran treefrogs (Pseudacris sierra) and approximately 15 American bullfrogs (Lithobates catesbeianus) during the CRLF surveys. No CRLF were observed. Trihydro biologists identified sign of CRLF predators including raccoon (Procyon lotor), crayfish (Pacifastacus leniusculus), kingsake (Lampropeltis sp.), great egret (Ardea alba), American coot (Fulica americana), and red-tailed hawk (Buteo jamaicensis). Appendix D contains detailed data sheets for each of the survey events. 3.8 BURROWING OWL SURVEYS Burrowing owl surveys were conducted in tandem with the CRLF surveys. No burrowing owls were observed within the 2024 work areas during the surveys. Historically, burrowing owl have occupied the site during the non-breeding season; however, additional biological clearance surveys will be conducted to identify any owl nesting activity prior to Project activities within the nesting season. These results will be included in weekly Project status updates. 3.9 NESTING BIRD SURVEYS No nesting behavior was observed during the March 26 nesting bird survey. Bird species observed during the March 26 survey include great egret (Ardea alba), mallard (Anas platyrhnchos), northern shoveler (Spatula clypeata), cinnamon teal (Spatula cyanoptera), American coot (Fulica americana), killdeer (Charadrius vociferus), red-tailed hawk (Buteo jamaicensis), mourning dove (Zenaida macroura), black phoebe (Sayornis nigricans), horned lark (Eremophila alpestris), American crow (Corvus brachyrhnchos), rock wren (Salpinctes obsoletus), western bluebird (Sialia mexicana), American pipit (Anthus rubescens), orange-crowned warbler (Leiothlypis celata), common yellowthroat (Geothlypis trichas), California towhee (Melozone crissalis), chipping sparrow (Spizella passerina), lark sparrow (Chondestes grammacus), song sparrow (Melospiza melodia), white-crowned sparrow (Zonotrichia leucophrys), western meadowlark (Sturnella neglecta) , red-winged blackbird (Agelaius phoeniceus), house finch (Haemorhous mexicanus). Additional nesting bird surveys will be conducted throughout the nesting bird season (through August 31), or until Project activities are complete for the year, whichever comes first. 3.10 VERNAL POOL FAIRY SHRIMP HABITAT All vernal pools within the 2024 work areas were excavated, graded, or otherwise disturbed during work activities in 2022. VPFS inoculum was collected from all vernal pools within the 2022/2023 work areas that were identified as viable sources for VPFS cysts prior to 2022 work activities. Salvaged inoculum will be used for VPFS habitat restoration as described in Vernal Pool Habitat Restoration and Monitoring Plan (Appendix H of the Landscape Restoration Plan [Padre, 2015a]). All VPFS habitat and their buffers adjacent to the 2024 work areas were properly 3-4 202404_AnnualPre-ActivitySurvey_RPT.docx delineated and protected prior to ground disturbance in 2022 to avoid incidental impacts. Any impacted vernal pool fairy shrimp-occupied habitat will be included within the final impact acreages, reported in the Annual Monitoring Report, and mitigated as detailed in the Landscape Restoration Plan (Padre, 2015a). 3.11 WETLANDS AND WATERS U.S. Army Corps of Engineers jurisdictional and non-jurisdictional wetlands and waters occurred within the proposed 2023 work areas prior to disturbance activities in 2022, but no such wetlands or waters occur within the planned 2024 work areas. During 2022 remediation activities, all jurisdictional and non-jurisdictional wetlands within 2023 work areas were excavated, graded, or otherwise removed. Ground disturbance within wetlands was conducted outside of rain events, when wetlands were dry, and completed in compliance with all permit conditions. Limits of protected and preserved wetland habitats adjacent to the work areas were delineated to avoid incidental impacts to wetlands that were not permitted for disturbance. The wetlands and waters within the SLO Tank Farm property were delineated and recorded in 2008. Figure 3-2 shows the locations of wetlands and waters within the SLO Tank Farm Property. 202404_AnnualPre-ActivitySurvey_RPT.docx 4-1 4.0 DISCUSSION Biological pre-activity surveys were conducted within and adjacent to the proposed Reservoir 5 and 7 areas, the aggregate stockpile area, the contractor staging area, and the Flower Mound borrow area from February through March 2024 for the purpose of documenting the extent of special-status plant populations and plant communities, nesting bird activity, burrowing owl presence, and California red-legged frog presence prior to the initiation of Project activities. Most habitat and plant communities were removed from the 2024 work areas during 2022 and 2023 remediation activities. The botanical results for the 2021 and 2024 pre-activity survey are included in this Report and were representative of the distribution and abundance of special-status plants and plant communities present within the proposed 2024 work areas prior to the ground disturbance that occurred in 2022 and will occur in 2024. Mapped special-status plant species within the proposed 2024 work areas include Cambria morning glory, San Luis Obispo owl’s clover, purple needlegrass grassland, San Luis Obispo serpentine dudleya and Congdon’s tarplant. Among these special-status plants and communities, only San Luis Obispo serpentine dudleya and purple needlegrass grassland were observed within the proposed 2024 work areas during the 2024 pre-activity botanical field verification survey. Plant communities occurring within the proposed 2024 work areas were verified and were consistent with the pre-existing communities mapped in 2008. Following documentation of the special-status species within the proposed 2024 work areas, no salvage or seed collection was conducted pursuant to CUP COA No. 43. Project-related impacts to special- status plant species and communities that fall within the planned 2024 work areas have already been accounted for and mitigated. No special-status wildlife species or nesting birds were observed during the 2024 pre-activity surveys. Similarly, no active nests or burrowing owls were observed during the 2024 pre-activity surveys. Nesting bird and burrowing owl surveys will be conducted during morning biological clearance surveys throughout the duration of the Project. There are no jurisdictional or non-jurisdictional waters or wetlands within the proposed 2024 work areas. As such, it is unlikely that CRLF will be encountered during 2024 Project activities. Similarly, all VPFS features adjacent to the proposed 2024 work areas were properly delineated in previous years to avoid impacts. All wildlife conflicts, impacts, observations, and botanical impact acreages, and wetland and waters impacts will be documented in the Annual Biological Monitoring Report, to be submitted following the completion of 2024 Project activities. 202404_AnnualPre-ActivitySurvey_RPT.docx 5-1 5.0 REFERENCES California Department of Fish and Wildlife (CDFW). 2024. California Natural Diversity Database (CNDDB) Query of San Luis Obispo County. California Native Plant Society, Rare Plant Program. 2019. Inventory of Rare and Endangered Plants of California (online edition, v8-03 0.39). Website http://www.rareplants.cnps.org [accessed 14 March 2019]. Padre Associates, Inc. (Padre) and WSP Environment & Energy (WSP). 2008. Description and Analysis of the Botanical Resources, Including Vascular Plant Species of Conservation Concern, at the Chevron Tank Farm Facility, San Luis Obispo, California. Consultant’s report developed for CEMC, San Luis Obispo, California. Padre Associates, Inc. (Padre). 2014. California Red-legged Frog Survey Report for the Chevron San Luis Obispo Tank Farm, San Luis Obispo County, California. Prepared for CEMC, San Luis Obispo, California. Padre Associates, Inc. (Padre). 2015a. Landscape Restoration Plan, Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project, San Luis Obispo County, California. April 2015. Padre Associates, Inc. (Padre). 2015b. Pre-Activity Botanical Resources Survey Guidelines for Special-Status Plants and Plant Communities. In-house document prepared by Padre, 2015. Padre Associates, Inc. (Padre). 2018. Biological Resources Monitoring 2017 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2018. Padre Associates, Inc. (Padre). 2019. Biological Resources Monitoring 2018 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. March 2019. San Luis Obispo County, Department of Building and Planning. 2014. Notice of Final County Action; Conditional Use Permit (County File Number DRC2013-00056). Letter dated October 28, 2014. San Luis Obispo County, Department of Building and Planning. 2020. Notice of Final County Action; Conditional Use Permit (County File Number DRC2015-00067). Letter dated June 28, 2021. 5-2 202404_AnnualPre-ActivitySurvey_RPT.docx Trihydro Corporation (Trihydro). 2019. 2019 Pre-Activity Biological Survey Report, North Marsh Area Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2019. Trihydro Corporation (Trihydro). 2020a. 2020 Pre-Activity Biological Survey Report, Reservoir 3 Area Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. March 2020. Trihydro Corporation (Trihydro). 2020b. Biological Resources Monitoring 2019 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2020. Trihydro Corporation (Trihydro). 2021a. 2021 Pre-Activity Biological Survey Report, Reservoir 3 Area Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2021. Trihydro Corporation (Trihydro). 2021b. Biological Resources Monitoring 2020 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2021. Trihydro Corporation (Trihydro). 2022a. 2022 Pre-Activity Biological Survey Report, Reservoir 5 and 7 Areas Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2022. Trihydro Corporation (Trihydro). 2022b. Biological Resources Monitoring 2021 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2022. Trihydro Corporation (Trihydro). 2023a. 2023 Pre-Activity Biological Survey Report, Reservoir 5 and 7 Areas Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. March 2023. 202404_AnnualPre-ActivitySurvey_RPT.docx 5-3 Trihydro Corporation (Trihydro). 2023b. Biological Resources Monitoring 2022 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2023. Trihydro Corporation (Trihydro). 2024. Biological Resources Monitoring 2023 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2024. TABLES TABLE 2-1. SUMMARY OF FIELD ACTIVITIES 2-1_202403_Summary-FieldActivities_TBL-2-1.docx 1 of 1 Survey Dates Field Activity Biological Staff April – August, 2022 Plant Bloom and Seed Status Surveys G.Pelzmann, and I.Arroyos April – June, 2022 Plant Community Verification Survey I.Arroyos, and G.Pelzmann June 9, 2020 Sensitive Plant Mapping Survey M.Thule February 27, 2024 California red-legged frog Survey; Burrowing Owl Survey (night) V.Trautman, I. Arroyos March 5, 2024 California red-legged frog Survey; Burrowing Owl Survey (night) I.Arroyos, R. Nolan March 12, 2024 California red-legged frog Survey; Burrowing Owl Survey (night) I.Arroyos, S. Belus March 19, 2024 California red-legged frog Survey; Burrowing Owl Survey (night) V.Trautman, R. Nolan March 9, 2021 Special-status plant mapping reconnaissance survey – Cambria morning glory, Owl’s clover I.Arroyos March 9, 2021 Plant community mapping verification survey I.Arroyos March 25, 2024 Plant community mapping verification survey I.Arroyos March 26, 2024 Nesting Bird Survey V.Trautman TABLE 3-1. SPECIAL-STATUS PLANT ACREAGES WITHIN PROPOSED WORK AREAS 3-1_202403_PlantAcreages_TBL-3-1.docx 1 of 1 Species Acres & Work Area(s) Cambria Morning Glory Approximately 1.1 acres in previously undisturbed portions of flower mound borrow area. San Luis Obispo owl’s clover Observed in previously undisturbed portions of flower mound borrow area during 2024 pre-activity verification survey, but not previously mapped in that area. All populations within Reservoir 5 and Reservoir 7 were impacted/removed during 2022 activities. Congdon’s tarplant No occurrences within proposed work areas. All populations within Reservoir 5 and Reservoir 7 were impacted/removed during 2022 activities. Purple needlegrass Approximately 5 acres in previously undisturbed portions of flower mound borrow area. Hoover’s button celery No occurrences within proposed work areas. San Luis Obispo serpentine dudleya Approximately 0.83 acres in previously undisturbed portions of flower mound borrow area. California walnut No occurrences within proposed work areas. Note: Project-related impacts to special-status plants in the flower mound area have already been accounted for and mitigated. TABLE 3-2. PLANT COMMUNITY ACREAGES WITHIN PROPOSED WORK AREAS 3-2_202403_CommunityAcreages_TBL-3-2.docx 1 of 1 Plant Community Acres & Work Area(s) Non-native annual grassland Approximately 4.08 acres in previously undisturbed portions of flower mound borrow area. Palustrine nonpersistent emergent vernal swale/pool Approximately 0.09 acres in previously undisturbed portions of flower mound borrow area. Serpentine bunch grassland Approximately 4.96 acres in previously undisturbed portions of flower mound borrow area. Palustrine forested broad-leaf deciduous valley stream-bank wetland Does not occur in proposed 2024 work areas. Palustrine scrub-shrub broad-leaf deciduous valley stream-bank wetland Does not occur in proposed 2024 work areas. Serpentine rock outcrop Does not occur in proposed 2024 work areas. Palustrine persistent emergent vernal freshwater marsh Does not occur in proposed 2024 work areas. FIGURES Last exported to pdf from ArcGIS Pro by nmelady on 3/28/2024, 9:38 AM. 1252 Commerce Drive Laramie, WY 82070 www.trihydro.com (P) 307/745.7474 (F) 307/745.7729 File: 3-1_SpecialStatusPlants_Fig3-1 C:\USERS\NMELADY\TRIHYDRO\CHEVRON - SLO TANK FARM - GIS\MAPPING\11_REPORTS\ANNUAL_PRE-ACTIVITY_REPORT\2024\SLOTF_ANNUALPREACTIVITYREPORT_2024.APRXDate: 3/28/24Scale: 1" = 600'Checked By: MRDrawn By: NM SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO COUNTY, CA PRE-ACTIVITY BOTANICAL SURVEY RESULTS MAP SPECIAL-STATUS PLANTS FIGURE 3-1 0 600 ' EXPLANATION SLO OWL'S CLOVER SLO CAMBRIA MORNING GLORY SLO SERPENTINE DUDLEYA RESERVOIR 5 RESERVOIR 7 CONTRACTOR STAGING AREA AND CONTAMINATED STOCKPILE FLOWER MOUND AGGREGATE STOCKPILE Esri, HERE, iPC, County of San Luis Obispo, Maxar, Microsoft 2024 WORK AREA PROJECT SITE BOUNDARY CONGDON'S TARPLANT HOOVER'S BUTTON CELERY PURPLE NEEDLEGRASS GRASSLAND Last exported to pdf from ArcGIS Pro by nmelady on 3/27/2024, 10:29 AM. 1252 Commerce Drive Laramie, WY 82070 www.trihydro.com (P) 307/745.7474 (F) 307/745.7729 File: 3-2_PlantCommunities_Fig3-2 L:\CHEVRON - SLO TANK FARM - GIS\MAPPING\11_REPORTS\ANNUAL_PRE-ACTIVITY_REPORT\2024\SLOTF_ANNUALPREACTIVITYREPORT_2024.APRXDate: 3/27/24Scale: 1" = 600'Checked By: MRDrawn By: NM SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO COUNTY, CA PRE-ACTIVITY BOTANICAL SURVEY RESULTS MAP PLANT COMMUNITIES FIGURE 3-2 0 600 ' EXPLANATION 2024 WORK AREA PROJECT SITE BOUNDARY PALUSTRINE FORESTED BROAD-LEAF DECIDUOUS VALLEY STREAM-BANK WETLAND PALUSTRINE NONPERSISTANT EMERGENT VERNAL SWALE/POOL PALUSTRINE PERSISTENT EMERGENT VERNAL FRESHWATER MARSH PALUSTRINE SCRUB-SHRUB BROAD-LEAF DECIDUOUS VALLEY STREAM-BANK WETLAND SERPENTINE BUNCH GRASSLAND NON-NATIVE ANNUAL GRASSLAND RESERVOIR 5 RESERVOIR 7 CONTRACTOR STAGING AREA AND CONTAMINATED STOCKPILE FLOWER MOUND AGGREGATE STOCKPILE Esri, HERE, iPC, County of San Luis Obispo, Maxar, Microsoft Last exported to pdf from ArcGIS Pro by nmelady on 3/27/2024, 10:30 AM. 1252 Commerce Drive Laramie, WY 82070 www.trihydro.com (P) 307/745.7474 (F) 307/745.7729 File: 3-3_SpecialStatusWildlife_Fig3-3 L:\CHEVRON - SLO TANK FARM - GIS\MAPPING\11_REPORTS\ANNUAL_PRE-ACTIVITY_REPORT\2024\SLOTF_ANNUALPREACTIVITYREPORT_2024.APRXDate: 3/27/24Scale: 1" = 600'Checked By: MRDrawn By: NM SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO COUNTY, CA PRE-ACTIVITY BIOLOGICAL SURVEY RESULTS MAP SPECIAL-STATUS WILDLIFE FIGURE 3-3 0 600 ' EXPLANATION 2024 WORK AREA PROJECT SITE BOUNDARY CALIFORNIA RED-LEGGED FROG HABITAT VERNAL POOL FAIRY SHRIMP OCCUPIED POOL (OUTSIDE DISTURBANCE AREA) RESERVOIR 5 RESERVOIR 7 CONTRACTOR STAGING AREA AND CONTAMINATED STOCKPILE FLOWER MOUND AGGREGATE STOCKPILE Esri, HERE, iPC, County of San Luis Obispo, Maxar, Microsoft APPENDIX A BOTANICAL SURVEY GUIDELINES Chevron San Luis Obispo Tank Farm Remediation, Restoration Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0307 - 1 - PRE-ACTIVITY BOTANICAL SURVEY GUIDELINES FOR SPECIAL-STATUS SPECIES AND PLANT COMMUNITIES The following outlines the background information, monitoring methodology, and reporting tasks associated with pre-activity botanical surveys at the Project site. The purpose of a botanical pre-activity survey is to document the location and acreage of special-status plant populations and plant communities to be impacted within the Project site. GUIDANCE AND REGULATIONS Pre-activity surveys will be completed within the appropriate season prior to the onset of initial ground disturbance activity conducted at the Project site. Botanical pre-activity surveys will be conducted within the disturbance areas per the Project Final Environmental Impact Report (EIR) Conditions of Approval BIO-1b, which states: “The Applicant shall conduct updated surveys of sensitive species habitats (including sensitive plant species, CRLF, wetland habitat, and VPFS habitat) within the Project Site within the appropriate season immediately prior to the onset of any ground disturbances associated with the Project in order to evaluate the current occupancy of suitable habitat for sensitive species and to refine the final habitat mitigation replacement acreages. Updated surveys for federally listed species shall be completed per the timing and methodology specified by resource agency protocol”. As stated above, and as including in the Project Landscape Restoration Plan botanical pre-activity surveys will be conducted prior to disturbance, to determine the acreages of special- status species and plant communities that are proposed to be impacted. The resulting acreage values may be used to refine target acreages. Special-status species population target densities will not be re-evaluated, as they are expressed as set “target densities” in the Success Criteria outlined in the Landscape Restoration Plan. SURVEY METHODS Prior to conducting field surveys, a Job Safety Analysis (JSA) will be completed for all activities. All personal protective equipment (PPE) will be dawn per the Project health and safety plan (HASP). The JSA and HASP will be on the field personnel during all field activities. Field survey standard operational plans (SOPs) will be reviewed as necessary prior to conducting activities. During pre-activity botanical surveys, the limits of the special-status species populations will be surveyed using a hand-held GPS unit and qualitative assessments of special-status species populations will be completed within the immediate disturbance area per Project phase. Qualitative assessments of the special-status species populations will include documentation of species composition, general location notes, and overall health and vigor of the population. Plant communities mapped in 2009 will be field verified and any major shifts in the extent of the Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 2 - communities may be mapped, as necessary. Representative photographs will be taken of special-status species populations and plant communities within the proposed disturbance area. Special-Status Species The procedures for special-status species population surveys include both survey of the population size and location, and qualitative assessment, and are described in this section. 1. Reconnaissance survey. Qualitative assessment within the proposed disturbance area to determine blooming status of special-status species. Assessments will be completed during appropriate blooming periods as illustrated in Table 1. Table 1. Blooming Period for Special-Status Plant Species Blooming Period (month) Plant Species (Common Name) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Cambria morning glory San Luis Obispo owl’s clover Congdon’s tarplant Hoover’s button-celery Purple needlegrass 2. Survey extent of the population. During the peak of the blooming season for each special-status species population, biologists will survey the extent of the population within the proposed disturbance area using a hand-held GPS unit. Pin flags will be used to mark boundaries and will be removed following mapping. 3. Data Collection/GPS Documentation. Data collection in the GPS unit will be saved in a corresponding folder specific to the year in which the survey was collected. The code system as described in Table 2 will be used to identify each population and saved in the year’s folder. Table 2. Special-Status Species Population GPF Filename Codes Representative GPS Filename for Special-Status Species Populations: “ SLOTF SSS 2015” Species GPS ID Code Cambria Morning Glory (Calystegia subacaulis ssp. episcopalis ) CASUE SLO Owl’s Clover (Castilleja densiflora ssp. obispoensis) CADEO Congdon’s tarplant (Centromadia parryi ssp. congdonii ) CEPAC Hoover’s button celery (Eryngium aristutalum var. hooveri) ERAR Purple needlegrass (Stipa pulchra) STPU SLO Serpentine dudleya (Dudleya abramsii ssp. bettinae) DUAB California walnut (Juglans californica) JUCA Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 3 - 4. Qualitative Botanical Assessment. Record the dominant plant species that occur within the populations, environmental conditions, estimate percent bloom, and soil moisture. This data is for informational purposes only and will be used to document seasonal and yearly changes in site conditions throughout the Project duration and may be useful for restoration planning. 5. Photographs. Representational photographs will be taken of populations within the proposed disturbance area. Plant Communities The procedures for plant community surveys include a representative qualitative assessment and field verification of previously mapped boundaries, as described below. Plant communities follow the nomenclature used in the 2008 SLO Tank Farm Botanical Report. 1. Field verification of plant community boundaries. Using a field copy of the previously mapped plant communities, representative portions of the plant communities will be verified. If significant discrepancies between the reference map and the field conditions are observed, the extent of the community may be re-surveyed. 2. Survey extent of the community. Biologists will survey the extent of the community within the proposed disturbance area using a hand-held GPS unit. Pin flags will be used to mark boundaries and will be removed following mapping. Communities will only be surveyed if there are significant changes in community size or location. 3. Data Collection/GPS Documentation. For communities that have significant changes in population size/location, data collection in the GPS unit will be saved in a corresponding folder specific to the year in which the survey was collected. The code system as described in Table 3 will be used to identify each community and saved in the year’s folder. Table 3. Plant Community GPS Filename Codes Representative GPS Filename for Plant Community Polygons: “SLOTF PC 2015” Plant Community (PC) GPS ID Code Non-native annual grassland GRASS Serpentine bunchgrass grassland SERP Palustrine persistent emergent vernal freshwater marsh VERMAR Palustrine nonpersistent emergent vernal swale/pool VERNPOOL Palustrine scrub-shrub broad-leaf deciduous valley stream-bank wetland SCRUBWET Palustrine Forested broad-leaf deciduous valley stream-bank wetland WOODWET Serpentine rock outcrop ROCK Urban/Ruderal RUD Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 4 - 4. Qualitative Botanical Assessment. Record the dominant plant species that occur within the community and environmental conditions. This data is for informational purposes only and will be used to document seasonal and yearly changes in site conditions throughout the Project duration and may be useful for restoration planning. 5. Photographs. Representational photographs will be taken of all communities within the disturbance area. Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 5 - FIELD MATERIALS CHECKLIST  Trimbel GeoXT GPS Unit  Camera  Field Data Sheet  Pin flags  JSA/HASP  PPE  Plastic bags for plant collection; if needed for positive identification using dissecting scope  Field maps (PDF and/or hard copy): 1. SLOTF aerial with property boundary and existing plant communities (2008); 2. SLOTF aerial with property boundary and existing special-status plant populations (2008); and 3. SLOTF aerial with illustrated Project disturbance limits for the given year. REPORTING The resulting data will be used to generate an annual botanical resources report that may be used to support Project permit reporting requirements. The annual botanical resources report will provide a summary of botanical surveys completed within the year and associated figures, data sheets, and photographs. The report will include a summary of survey methods, including survey boundaries. The survey results, previously mapped plant communities, and proposed Project disturbance limits will be included in figures. APPENDIX B SITE PHOTOGRAPHS APPENDIX B. SITE PHOTOGRAPHS 2-202404_SitePhotos_APP-B.docx 1 of 3 Photo 1. Reservoir 5 – botanical communities surveyed prior to 2022 disturbance. Aspect: north. Date: 04/08/2022. Photo 2. Reservoir 7 – botanical communities surveyed prior to 2022 disturbance. Aspect: west. Date: 04/15/2022. APPENDIX B. SITE PHOTOGRAPHS 2 of 3 2-202404_SitePhotos_APP-B.docx Photo 3. Flower mound area – conditions during 2024 pre-activity botanical survey. Date: 03/25/2024. Photo 4. Flower mound area – conditions during 2024 pre-activity botanical survey. Date: 03/25/2024. APPENDIX B. SITE PHOTOGRAPHS 2-202404_SitePhotos_APP-B.docx 3 of 3 Photo 5. Reservoir 5 – habitat surveyed during 2023 pre-activity surveys. Aspect: northeast. Date: 03/24/2023. Photo 6. Reservoir 7 – habitat surveyed during 2023 pre-activity surveys. Aspect: south. Date: 03/24/2023. APPENDIX C VERNAL POOL FAIRY SHRIMP PRE-ACTIVITY CONSULTATION LETTER United States Department of the Interior tFtk’1 FISH AND WILDLIFE SERVICE Ventura Fish and Wildlife Office 3.2493 Portola Road,Suite B Ventura,California 93003 IN REPLY REFER TO: O$EVENOO-2016-CPA-0061 January 25,2016 Sarah Powell Padre Associates,Inc. 369 Pacific Street San Luis Obispo,California 93401 Subject:Pre-activity surveys for vernal pooi fairy shrimp at Chevron’s San Luis Obispo Tank Farm site Ms.Powell: This correspondence responds to your letter dated November 13,2015,that requests ourguidanceregardingtheneedforadditionalsurveysforvernalpooifairyshrimp(&anchinectalynchi;VPFS)at Chevron’s San Luis Obispo Tank Farm site located at 276 Tank Farm Road,County of San Luis Obispo,California.The site is within a decommissioned oil facility originally owned by Union Oil,which reorganized as Unocal in the 19$Os,and was purchased byChevronin2005.This approximately 340-acre site was previously used to store petroleum,andotherrelatedproductsalthoughthestoragetanksandotherinfrastructurehavebeenremoved. Much of the surrounding area is largely undeveloped land that has historically been used forlivestockgrazingwiththeSanLuisObispoAirportlocatedtothesoutheast.Lands to the eastandwesthavebeendevelopedforresidential,commercial and light industrial uses. As you are aware,Chevron staff and their consultants have been working with Julie Vanderwier and Jenny Marek of the U.S.Fish and Wildlife Service’s (Service)office in Ventura to ensure endangered species compliance as part of the proposed site remediation and development project.The remediation project would address soil and groundwater contamination identified as potential human health or ecological risks agreed upon by resources agencies who participated in a highly collaborative process.Development would involve the creation of both business park and service commercial uses.Of particular concern relative to project implementation is the presence of the federally threatened VPFS,an invertebrate species first identified in some of the seasonally inundated features on Chevron’s property in 2003.Surveys indicate that 32.6 acres of habitat variously occupied by VPFS is present onsite. In 2011,in consultation with the U.S.Army Corps of Engineers (Corps),the Service issued biological opinion 8-8-1 0-F-63 that analyzed the effects to VPFS from investigations necessary to characterize cultural resources and onsite soils as part of the preparation of an environmental impact report (EIR)for the proposed remediation and development project.It was our conclusion that the proposed action was not likely to jeopardize the continued existence of vernal pooi fairy Sarah Powell 2 shrimp.The final EIR (FEIR;Marine Research Specialists 2013)for the remediation and development project was completed in 2013.Currently,we are in consultation with the Corps regarding the effects to VPFS that would result from their issuance of a permit for this same project. Relevant to VPFS,it has come to our attention that two mitigation measures included in the FEIR for the remediation and development project have been made conditions of Conditional Use Permit DRC2O13-00056 issued by the County of San Luis Obispo.These conditions (#77 [FEW BIO-lb]and #78 [fEIR BlO ii])require that,prior to the commencement of grading or other construction activities,the applicant conduct updated surveys for VPf S and its habitat (Marine Research Specialists 2013).The following table provides information regarding wet and dry season surveys that have been conducted for VPFS onsite to-date. VPFS Survey History at the SLO Tank Farm Site VPFS Survey Survey Results and Report Reference Initial wet and dry season surveys conducted at 60 of $6 potential habitat features sampled were the SLO Tank Farm Site between 2003 and 2005.determined to support the VPf S (Rincon 2005). Supplemental surveys of previously unoccupied 5 of 24 previously unoccupied habitat features habitat requested by the U$FWS and conducted included in the surveys were determined to during the 2011/2012 wet season.support the VPFS (Padre 2012). Wet and dry season surveys of offsite potential No VPF$individuals or eggs were found in offsite habitat (Garcia Property)conducted between potential habitat (Padre 2013a;Padre 20l4a; 2012 and 2015.Padre 2015a). Dry season surveys conducted as part of the Cyst Determined cyst density of occupied features Density Study.onsite for the purposes of designing a prioritized topsoil collection plan (LSA 2014). Cultural Resource Surveys,Soil Assessment,and Eight of ten monitored features met performance Waste Characterization Project Post-Construction criteria for successful restoration of habitat VPFS Monitoring.hydroperiod and one of three monitored features consistently met the VPFS performance criteria (Padre 2013b;Padre 2014b;Padre 2015b). It is our opinion that these surveys are adequate to characterize site use by this species,to inform effects analyses necessary for our consultation with the Corps,and to inform the preparation and implementation of a restoration plan intended to improve site conditions for VPFS.When considering project effects to this species,we use occupied habitat as a surrogate as it is not possible to estimate take of individuals and will therefore be focused on the restoration of habitat Sarah Powell 3 that can support vernal pooi fairy shrimp in the long-term.We cannot speak to the appropriateness of the conditions contained in the CUP;however,we do not believe that additional surveys will add significantly to our knowledge regarding use of this site by VPF$or be necessary to develop and implement the required restoration plan.As part of our discussions with Chevron and the County and City of San Luis Obispo over the years,we have consistently maintained that it was not our desire to see the effects and/or take of this species be compensated for using an established ratio.Rather,in order to further species recovery,it was our desire to see an increase in the value and function of onsite habitat that would be managed for persistence of VPFS in perpetuity.As such,minor adjustments to occupied habitat are not considered important to the continued existence of vernal pooi fairy shrimp within the project area post-project completion.Rather,one of the specific goals of the draft habitat restoration plan is to increase thevalueandfunctionofhabitatforVPFS. Because we do not believe that pre-activity surveys for VPFS and their habitat would provide substantially different information regarding species presence onsite and because our guidance allows for flexibility as to when we would ask for surveys to be conducted,we do not think thatitisnecessarytoconductadditionalsurveysandconsiderthattheexistingdataissufficientforustocompleteourconsultationwiththeCorpsregardingprojectimplementation. If you have any questions regarding this determination or the ongoing consultation,pleasecontactMs.Vanderwier at ($05)644-1766,extension 222.She may also be contacted using emailatthisaddress:julie_vanderwierfws.gov. Sincerely, Glen W.Knowles Assistant Field Supervisor ecc: Crystahi Taylor,Padre Associates Jenny Marek,Ventura Fish and Wildlife Office LITERATURE CITED LSA Associates,Inc [LSAJ.2014.Chevron San Luis Obispo Tank Farm Vernal Pool Branchiopod Cyst Density Study,October,2014. Marine Research Specialists.2013.Chevron Tank Farm Remediation and Development Project Final Environmental Impact Report (FEIR).Prepared For:City of San Luis Obispo County of San Luis Obispo (SCH #200903 1001). Padre Associates,Inc [Padre].2012.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the San Luis Obispo Tank Farm Site,San Luis Obispo,CA (USFWS Reference Nos.81440-2009-B-0180 [Chevron Tank Farm];$1440-2010-B-0026 [Powell];81440-2009-B-0049 [Thomas]).Consultant’s Report for U.S.Fish and Wildlife Service.June,2012. Padre Associates,Inc [Padre].2013a.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the Offsite Impact Area at the Chevron San Luis Obispo Tank Farm Site,San Luis Obispo,California (USFWS Reference Nos.$1 440-2009-B-0 120 [Chevron Tank Farm];81440-2010-B-0026 [Powell];81440-2009-B-0049 [Thomas]).Consultant’s Report for U.S.Fish and Wildlife Service.July,2013. Padre Associates,Inc [Padre].2013b.2012/2013 Wet Season (Year-i)VPFS Monitoring Report for the San Luis Obispo Tank Farm Cultural Resources Survey and Waste Characterization Survey Projects.Consultant’s Monitoring Report prepared for U.S.Fish and Wildlife Service.September,2012. Padre Associates,Inc [Padre].20l4a.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the Offsite Impact Area at the Chevron San Luis Obispo Tank Farm Site,San Luis Obispo,California (USFWS Reference Nos.81440-2009-3-0180 [Chevron Tank Farm];81440-2010-B-0026 [Powell];81440-2009-B-0049 [Thomas])—Statement of No Survey Activity.Consultant’s Report for U.S.Fish and Wildlife Service.July,2014. Padre Associates,Inc [Padre].2014b.2013/2014 Wet Season VPFS Monitoring Report (Year-2) for the San Luis Obispo Tank Farm Cultural Resources Survey and Waste Characterization Survey Projects.Consultant’s Monitoring Report prepared for U.S.Fish and Wildlife Service.August,2014. Padre Associates,Inc [Padre].201 5a.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the Offsite Impact Area at the Chevron San Luis Obispo Tank Farm Project Site,San Luis Obispo,California (USFWS Reference Nos.81440-2009-B-0180 [Chevron Tank Farm];81440-2010-B-0026 [Powell]).Consultant’s Report for U.S.Fish and Wildlife Service.June,2015. Padre Associates,Inc [Padre].20155.2014/2015 Wet Season VPF$Monitoring Report (Year-3) for the Cultural Resources Survey and Waste Characterization Survey Projects at the San Luis Obispo Tank Farm.Consultant’s Monitoring Report prepared for U.S.Fish and Wildlife Service.June,2015. Rincon Consultants,Inc [Rincon].2005.Unocal Corporation San Luis Obispo Tank Farm Comprehensive Fairy Shrimp Wet and Dry Season Survey Report.Consultant’s report prepared for Union Oil Company.San Luis Obispo,CA. APPENDIX D CALIFORNIA RED-LEGGED FROG PRE-ACTIVITY SURVEY DATA SHEETS 1 From:Stephanie Seay <sseay@trihydro.com> Sent:Wednesday, June 28, 2023 1:43 PM To:Fortner, Kellie Subject:RE: Renew your Construction Water Permit for 2023-2024! Attachments:202306_ConstructionWaterPermit_2023_2024_signed.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hi Kellie, Please find aƩached the completed applicaƟon for the San Luis Obispo Tank Farm RemediaƟon Project construcƟon water permit applicaƟon. Warm regards, Stephanie Seay Compliance & Permitting Biologist 142 Cross Street, Suite 200 San Luis Obispo, CA 93401 (805) 674-7588 (cell) (805) 329-3488 (phone) sseay@trihydro.com Connect with us on: CONFIDENTIAL INFORMATION: This electronic message is intended only for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. If you have received this message in error, please immediately notify the sender by either email or telephone. Please destroy the related message. Thank you for your cooperation. From: Fortner, Kellie <kfortner@slocity.org> Sent: Wednesday, June 28, 2023 9:49 AM Subject: Renew your Construction Water Permit for 2023-2024! Construction Water Permit Holders, Caution: This email is from an external sender. Please report suspicious emails using the Report Message button in Outlook. 2 Your current Construction Water Permit for the use of Recycled Water within the City of San Luis Obispo expires on June 30, 2023. If your project within city limits will continue to need water past this date, please submit a new application for 2023- 2024 to UT_Services@slocity.org. Please note, any new water haulers added to the permit will be required to have an inspection conducted at our office at 879 Morro St before the permit is finalized. Water Haulers are required to have: 1. Airgap separation or a backflow device 2. Non-potable signage 3. Hydrant wrench for opening/closing 4. Company name visible After your application is reviewed, you will be instructed to submit payment of $1260 to our Finance Department either in person or by calling 805-781-7124. Thank you, Kellie Fortner Water Resource Technician Public Utilities 879 Morro, San Luis Obispo, CA 93401-2710 E kfortner@slocity.org T 805.783.7860 slocity.org Stay connected with the City by signing up for e-notifications 2023-24 RECYCLED WATER CONSTRUCTION WATER PERMIT This Construction Water Permit must be available for inspection. A copy must be retained in the transport vehicle. 2023-24 Fees: $ 1,260 Permit Valid July 1, 2023 through June 30, 2024 Annual Permit # Fees Paid: Approval: CUSTOMER INFORMATION Business Name Address Phone Number E-mail VEHICLE DESCRIPTION Make Model License # Type: Tank Truck, Trailer, or Other CONSTRUCTION SUPERVISOR Name Address Phone Number Email SITE/USE LOCATION Site/Location of project(s) CERTIFICATION I HEREBY CERTIFY UNDER PENALTY OF PERJURY THAT THE INFORMATION PROVIDED ON THIS APPLICATION AND IN ANY ATTACHMENT IS TRUE AND ACCURATE. I ALSO CERTIFY THAT I HAVE READ AND AGREE TO ABIDE BY ALL APPLICABLE PROCEDURES FOR USE OF RECYCLED WATER IN THE CITY. Signature of Water Customer Title Date Union Oil Company of California (Chevron Environmental Management Company P.O. Box 1332, San Luis Obispo, CA 93406 (925) 842-2982 James.Beacom@chevron.com Caterpillar 660 34502Z2 Tank Truck Freightliner MI BCI5632 Tank Truck Jorge Calvo c/o Entact, LLC. 865 Aerovista, Suite 230, San Luis Obispo, CA 93401 (713) 562-6810 jcalvo@entact.com 276 Tank Farm Road, San Luis Obispo, CA 93401 Pre-Execution Specialist 6/28/2023 1 From:Martinez, Olga Sent:Tuesday, May 30, 2023 1:31 PM To:Christian, Kevin Cc:City_Attorney; CityClerk Subject:Final Production - PRR22294 Tsai - 276 Tank Farm Rd. Attachments:PRR22294 Tsai - 276 Tank Farm Rd.pdf Hi Kevin, Happy to announce this one is completely done সহ঺঻ In the Responsive Records folder, I have added the following documents: To folder labelled – Batch 2, I added “PRR22294 - batch 2 attachments,” with 12 documents. I created folder labelled – Batch 3, and I have added “PRR22294 - batch 3,” with 8 documents. Note that several documents were withheld pursuant to Government Code 7927.500 (formerly Government Code §6254 (a)), this division does not require disclosure of any preliminary drafts, notes, or interagency or intraagency memoranda that are not retained by a public agency in the ordinary course of business, if the public interest in withholding those records clearly outweighs the public interest in disclosure. This request was reviewed by Assistant City Attorney Markie Kersten and Paralegal Olga Martinez. This correspondence finalizes our production for your current request. Please be advised that every effort has been made to search for all records which may fall within the scope of your records request, and, as such, we believe our search is quite thorough. However, if you have knowledge of a specific document which has not been provided in response to your request, please notify us, and we will be happy to provide the document(s) to you unless, of course, it is exempt from disclosure pursuant to California Government Code §7921.000 et seq. Thank you, Olga Martinez Paralegal II City Attorney's Office 990 Palm Street, San Luis Obispo, CA 93401-3249 E omartine@slocity.org T 805.781.7139 slocity.org Stay connected with the City by signing up for e-notifications 2 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. Ph: (626) 381-9248 Fx: (626) 389-5414 Em: info@mitchtsailaw.com Mitchell M. Tsai Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 VIA E-MAIL November 18, 2022 Teresa Purrington, City Clerk City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 Em: tpurrington@slocity.org RE: Public Records Act and Advance Notice List Request Regarding the 276 Tank Farm Road Project Dear City Clerk, On behalf of Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”) and its members, this Office requests that the City of San Luis Obispo City”) provide any and all information referring or related to the 276 Tank Farm Road Project (“Project”) pursuant to the California Public Records Act (“PRA”), Cal. Government (“Gov’t”) Code §§ 6250–6270 (collectively “PRA Request”). Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. The Southwest Regional Council of Carpenters is a labor union representing more than 50,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning and addressing the environmental impacts of development projects, such as the Project. I. PUBLIC RECORDS ACT REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 2 of 7 Southwest Carpenters is requesting any and all information referring or related to the Project. The Public Records Act defines the term “public record” broadly as “any writing containing information relating to the conduct of the public’s business . . . regardless of physical form and characteristics.” Gov’t Code § 6252(d). “Records” includes all communications relating to public business regardless of physical form or characteristics, including but not limited to any writing, picture, sound, or symbol, whether paper, magnetic, electronic, text, other media, or written verification of any oral communication. Included in this request are any references in any appointment calendars and applications, phone records, or text records. These “records” are to include, but are not limited to correspondences, e-mails, reports, letters, memorandums, and communications by any employee or elected official of the City concerning the Project. Please include in your response to this request the following examples of “records,” as well as any similar physical or electronic forms of communication: any form of writing such as correspondence, electronic mail records (“email”), legal and factual memoranda, facsimiles, photographs, maps, videotapes, film, data, reports, notes, audiotapes, or drawings. Cal. Government Code § 6252(g) (defining a writing to including “any record thereby created, regardless of the manner in which the record has been stored”). Responsive correspondence should include, inter alia, emails, text messages, or any other form of communication regardless of whether they were sent or received on public or privately-owned electronic devices “relating to the conduct of the public’s business.” Cal. Government Code § 6252(e); Citizens for Ceres v. Super. Ct. Ceres”) (2013) 217 Cal. App. 4th 889, 909; Citizens for Open Gov’t v. City of Lodi Lodi”) (2012) 205 Cal.App.4th 296, 307, 311; City of San Jose v. Superior Court (2017) 2 Cal. 5th 608, 625 (finding that a public employee or officer’s “writings about public business are not excluded” from the California Public Records Act “simply because they have been sent, received, or stored in a personal account.”) . This Office requests any and all information referring or related to the Project, including but not limited to: 1) All Project application materials; 2) All staff reports and related documents prepared by the City with City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 3 of 7 respect to its compliance with the substantive and procedural requirements of the California Environmental Quality Act, Public Resources Code § 21000 et seq., and the CEQA Guidelines, title 14, California Code of Regulations, § 15000 et seq. (collectively CEQA”) and with respect to the action on the Project; 3) All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the agency pursuant to CEQA; 4) Any transcript or minutes of the proceedings at which the decisionmaking body of the City heard testimony on, or considered any environmental document on, the Project, and any transcript or minutes of proceedings before any advisory body to the public agency that were presented to the decisionmaking body prior to action on the environmental documents or on the Project; 5) All notices issued by the City to comply with CEQA or with any other law governing the processing and approval of the Project; 6) All written comments received in response to, or in connection with, environmental documents prepared for the Project, including responses to the notice of preparation; 7) All written evidence or correspondence submitted to, or transferred from, the City with respect to compliance with CEQA or with respect to the Project; 8) Any proposed decisions or findings submitted to the decisionmaking body of the City by its staff, or the Project proponent, Project opponents, or other persons; 9) The documentation of the final City decision and approvals, including the final environmental impact report, mitigated negative declaration, negative declaration, or notice of exemption, and all documents, in addition to those referenced in paragraph (3), cited or relied on in the findings or in a statement of overriding City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 4 of 7 considerations adopted pursuant to CEQA; 10) Any other written materials relevant to the public agency's compliance with CEQA or to its decision on the merits of the Project, including the initial study, any drafts of any environmental document, or portions thereof, that have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the Project and either made available to the public during the public review period or included in the City 's files on the Project, and all internal agency communications, including staff notes and memoranda related to the Project or to compliance with CEQA; and 11) The full written record before any inferior administrative decisionmaking body whose decision was appealed to a superior administrative decisionmaking body prior to the filing of any litigation. Please respond within 10 days from the date you receive this request as to whether this request specifies identifiable records not exempt from disclosure under the PRA or otherwise privileged or confidential, and are therefore subject to disclosure. This Office understands that this time may be extended up to 14 days for unusual circumstances as provided by Cal. Government Code § 6253(c), and that we will be notified of any extension and the reasons justifying it. We request that you provide all documents in electronic format and waive any and all fees associated with this Request. SWRCC is a community-based organization. Please notify and obtain express approval from this Office before incurring any duplication costs. If any of the above requested documents are available online, please provide us with the URL web address at which the documents may be downloaded. If any of the requested documents are retained by the City in electronic computer-readable format such as PDF (portable document format), please provide us with pdf copies of the documents via email, or inform us of the location at which we can copy these documents electronically. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 5 of 7 In preparing your response, please bear in mind that you have an obligation under Government Code section 6253.1 to (1) identify all records and information responsive to our request or the purpose of our request; (2) describe the information technology and physical location in which the records exist; and (3) provide suggestions for overcoming any practical basis for denying access to the records or information sought. In responding to this request, please bear in mind that any exemptions from disclosure you may believe to be applicable are to be narrowly construed. Marken v. Santa Monica- Malibu Unif. Sch. Dist. (2012) 202 Cal. App. 4th 1250,1262; and may be further narrowed or eliminated by the adoption of Proposition 59, which amended article I, section 3(b)(2) of the California Constitution to direct that any “statute ... or other authority ... [that] limits the right of access” to “information concerning the conduct of the people’s business” must be “narrowly construed.” As for any records that you nonetheless decline to produce on the grounds of an exemption, please bear in mind that the case law under the Public Records Act imposes a duty on you to distinguish between the exempt and the non-exempt portion of any such records, and to attempt in good faith to redact the exempt portion and to disclose the balance of such documents. Please bear in mind further that should you choose to withhold any document from disclosure, you have a duty under Government Code section 6255, subd. (a) to “justify withholding any record by demonstrating that the record in question is exempt under express provisions” of the Public Records Act or that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” Finally, please note that you must retain and not destroy any and all records, notwithstanding any local record retention or document destruction policies. As the Court noted in Golden Door Properties, LLC v. Superior Court of San Diego County (2020) 53 Cal.App.5th 733 that a public agency “must retain ‘[a]ll written evidence or correspondence submitted to, or transferred from’ . . . with respect to” CEQA compliance or “with respect to the project.” II. ADVANCE NOTICE LIST REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 6 of 7 We also ask that you put this Office on its notice list for any and all notices issued under the CEQA and the Planning and Zoning Law. In particular, we request that the City send by mail or electronic mail notice of any and all actions or hearings related to activities undertaken, authorized, approved, permitted, licensed, or certified by the City and any of its subdivision for the Project, or supported, in whole or in part, through permits, contracts, grants, subsidies, loans, or other forms of approvals, actions or assistance, including but not limited to the following: Notices of any public hearing held in connection with the Project; as well as Any and all notices prepared pursuant to CEQA, including but not limited to: Notices of determination that an Environmental Impact Report EIR”) or supplemental EIR is required for a project, prepared pursuant to Public Resources Code Section 21080.4; Notices of availability of an EIR or a negative declaration for a project prepared pursuant to Public Resources Code Section 21152 and Section 15087 of Title 14 of the California Code of Regulations; Notices of approval or determination to carry out a project, prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of approval or certification of any EIR or negative declaration prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of exemption from CEQA prepared pursuant to Public Resources Code section 21152 or any other provision of law; and Notice of any Final EIR prepared pursuant to CEQA. This Office is requesting notices of any approvals or public hearings under CEQA and the California Planning and Zoning Law. This request is filed pursuant to California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 7 of 7 65092 requiring agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Please send notice by regular and electronic mail to: Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 Em: maria@mitchtsailaw.com Em: mitch@mitchtsailaw.com Em: reza@mitchsailaw.com Em: info@mitchtsailaw.com We look forward to working with you. If you have any questions or concerns, please do not hesitate to contact our Office. Sincerely, Mitchell M. Tsai Attorneys for Southwest Regional Council of Carpenters 1 From:Curry, Krista Sent:Friday, August 25, 2023 1:54 PM To:LaFreniere, Matt; Nelson, Brian; Holt, Timothy; Pinizzotto, Julie Subject:RE: Developer Deposits for 2023 Adding @Pinizzotto, Julie to the email chain সহ঺঻ From: LaFreniere, Matt <mlafreni@slocity.org> Sent: Friday, August 25, 2023 1:20 PM To: Curry, Krista <kcurry@slocity.org>; Nelson, Brian <BNelson@slocity.org>; Holt, Timothy <tholt@slocity.org> Subject: RE: Developer Deposits for 2023 Hi all, Please see the attachments related to the 4/17/2023 transaction. The project address is 276 Tank Farm Road. They are required to pay for their impact to the road, based on their average daily truck trips. This is the account number: 600-2416. This account was specifically created for this project. It’s a manually-entered transaction, not done through EnerGov. Thank you, Matt LaFreniere pronouns he/him/his Permit Technician III Community Development Engineering Development Review 919 Palm Street, San Luis Obispo, CA 93401-3218 E mlafreni@slocity.org T 805.781.7015 slocity.org Stay connected with the City by signing up for e-notifications From: Curry, Krista <kcurry@slocity.org> Sent: Friday, August 25, 2023 12:09 PM To: Nelson, Brian <BNelson@slocity.org>; LaFreniere, Matt <mlafreni@slocity.org>; Holt, Timothy <tholt@slocity.org> Subject: FW: Developer Deposits for 2023 Here are the attachments to go with my email. Krista 2 From: Curry, Krista Sent: Wednesday, August 23, 2023 10:53 AM To: Pinizzotto, Julie <jpinizzo@slocity.org> Cc: Garcia, Tavy <tgarcia@slocity.org> Subject: RE: Developer Deposits for 2023 Hi Julie, Attached is documentation for the below transactions. I added PO numbers for those that have one. These are all processed on our old Samsung register to generate a receipt. Thank you, Krista From: Pinizzotto, Julie <jpinizzo@slocity.org> Sent: Monday, August 21, 2023 11:17 AM To: Curry, Krista <kcurry@slocity.org> Subject: Developer Deposits for 2023 Hi Krista, I hope all is well. Finance is currently working to reconcile and update the Developer accounts. I hope you will be able to assist me with some questions about a few Developer Deposits for 2023 or direct me to the correct person to ask. The following deposits were made in Teller by CDD for Developer Deposits in 2023. I need to identify the projects associated with each. Purchase order numbers would be great! 02/15/2023 $9,360.00 included in total deposit of $276,711.16 Receipt # finance-02152023-6.10 PO #615444 Planning Services Authorization San Luis Ranch Annual Reporting 03/06/2023 $90,837.00 included in total deposit of $96240.86 Receipt # finance-03062023-8.4 I Project Specific Impact Fee 862 Aerovista 04/28/2023 $6,447.00 included in total deposit of $$74,986.98 Receipt # finance-04282023-33.18 PO #616449 Planning Services Authorization 466 Dana St. 04/17/2023 $6,639.00 included in total deposit of $10,025.29 Receipt # finance-04172023-9.5 Coded to PWREV Chevron Road Rehabilitation Project 04/05/2023 $26,651.70 included in total deposit of $ 110,968.46 Receipt # finance-04052023-18.19 PO #614711 1911 Johnson Ave. Thank you for your assistance. Julie Pinizzotto Accounting Assistant Finance E jpinizzo@slocity.org slocity.org Stay connected with the City by signing up for e-notifications 1 From:Floyd, Aaron Sent:Wednesday, September 27, 2023 1:58 PM To:Scott, Shawna; Boerman, Mychal Subject:FW: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO - RISK MITIGATION PLAN COMMENTS Attachments:09-26-2023_SCP_covelop_RMP_letter_att1.pdf Importance:High From: Bryan Hulburd <bhulburd@covelop.net> Sent: Wednesday, September 27, 2023 1:53 PM To: vheger@meyersnave.com; Lindgren, Adam <adam@meyersnave.com> Cc: 'David Dixon' <ddixon@rouxinc.com>; 'Damien Mavis' <dmavis@covelop.net>; 'Pat Arnold' <parnold@covelop.net>; Schwartz, Luke <LSchwart@slocity.org>; Stong, Nate <nstong@slocity.org>; McDonald, Whitney <WMcDonal@slocity.org>; Dietrick, Christine <cdietric@slocity.org>; Kersten, Markie <mkersten@slocity.org>; Floyd, Aaron <afloyd@slocity.org> Subject: FW: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO - RISK MITIGATION PLAN COMMENTS Importance: High This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hi Vivi – I just got off the phone with David Dixon from Roux. He has reviewed the WB comments to the RMP/SMP and expressed concern over what the WB is asking of this infrastructure project. We think it’s criƟcal that at a minimum you and David connect on this maƩer prior to the Monday meeƟng. Below are some of his open Ɵmes this week: This aŌernoon Thursday aŌer 11:30am Friday aŌer 10:30am with the excepƟon of 2-3pm If anyone else would like to join this meeƟng (I’ll send a zoom link), please let me know. Thank you, Bryan Bryan Hulburd Project Manager 805-459-0753 bhulburd@covelop.net From: Hernandez, Christine@Waterboards <Christine.Hernandez@Waterboards.ca.gov> Sent: Tuesday, September 26, 2023 9:37 AM To: Bryan Hulburd <bhulburd@covelop.net> Cc: LSchwart@slocity.org; djohnson@slocity.org; wmcdonal@slocity.org; afloyd@slocity.org; nstrong@slocity.org; mkersten@slocity.org; cdietric@slocity.org; vheger@meyersnave.com; adam@meyersnave.com; dmavis@covelop.net; parnold@covelop.net; dixon@rouxinc.com; owenranta@chevron.com; kim.tulledge@chevron.com; 2 jenniferforinger@chevron.com; rgoodman@rjo.com; Froelich, Sophie@Waterboards <Sophie.Froelich@Waterboards.ca.gov>; Lodge, Ryan@Waterboards <Ryan.Lodge@waterboards.ca.gov>; Tryon, Thea@Waterboards <Thea.Tryon@waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Soderberg, Sheila@Waterboards <Sheila.Soderberg@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov> Subject: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO – RISK MITIGATION PLAN COMMENTS SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONTRUCTION, SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – RISK MITIGATION PLAN COMMENTS The Central Coast Regional Water Quality Control Board is increasing its efforts to transmit correspondence and other information electronically, reducing the amount of paper used, and increasing the speed of which information is distributed. Therefore, you are receiving the attached correspondence for the subject site from the Central Coast Water Board in a Portable Data Format (PDF) format. If you need help opening this document, please refer to the link below; http://www.adobe.com/products/acrobat/readstep2.html Central Coast Regional Water Quality Control Board September 26, 2023 Bryan Hulburd Sent via Electronic Mail Covelop, Inc. 1304 Garden Street San Luis Obispo, CA 93401 Email: bhulburd@covelop.net Dear Bryan Hulburd: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – RISK MITIGATION PLAN COMMENTS The Central Coast Regional Water Quality Control Board (Central Coast Water Board) reviewed Roux Associates, Inc.’s (Roux) Risk Mitigation Plan (RMP) for the Tank Farm and Santa Fe Roads Roundabout Construction Project (Site) dated August 23, 2023 1 (Work Plan Addendum), submitted on behalf of Covelop, Inc. The RMP provides a general description of how Site soils and groundwater will be managed during the roundabout construction. Covelop, Roux, and Central Coast Water Board staff had two working group meetings on March 29, 2023, and May 22, 2023, to assist in the RMP development process and discuss preliminary comments. The RMP did not address many of the comments discussed. Attachment 1 includes a list of general and specific comments that must be addressed in the RMP. Please submit a revised RMP that addresses these comments to the Central Coast Water Board by December 1, 2023. Additionally, Central Coast Water Board staff recommend rescheduling the meeting planned for October 2, 2023, to allow Covelop, Inc sufficient time to review the comments in detail and submit a revised RMP by December 1, 2023. Pending receipt and review of a revised RMP, Central Coast Water Board staff will coordinate with the group to schedule a meeting to discuss next steps. We look forward to working with Covelop, Roux, the City of San Luis Obispo, and County of San Luis Obispo on the Tank Farm and Santa Fe Roads Roundabout Construction Project. If you have any questions regarding this letter, please contact Dan Niles at (805) 549- 3355 (dan.niles@waterbaords.ca.gov) or Sheila Soderberg at (805) 549-3592 (sheila.soderberg@waterboards.ca.gov). 1Link to RMP: https://geotracker.waterboards.ca.gov/?surl=bnyin Bryan Hulburd - 2 - September 26, 2023 Sincerely, for Matthew T. Keeling Executive Officer Attachment 1 – Central Coast Water Board Comments on Risk Mitigation Plan cc: Luke Schwartz, City of San Luis Obispo, LSchwart@slocity.org Derek Johnson, City of San Luis Obispo, djohnson@slocity.org Whitney McDonald, City of San Luis Obispo, wmcdonal@slocity.org Aaron Floyd, City of San Luis Obispo, afloyd@slocity.org Nate Strong, City of San Luis Obispo, nstong@slocity.org Markie Kersten, City of San Luis Obispo, mkersten@slocity.org Christine Dietric, City of San Luis Obispo, cdietric@slocity.org Viviana Heger, Meyers Nave, vheger@meyersnave.com Adam Lindgren, Meyers Nave, adam@meyersnave.com Mavis Damien, Covelop, dmavis@covelop.net Pat Arnold, Covelop, parnold@covelop.net David Dixon, Roux, dixon@rouxinc.com Owen Ranta, Chevron, owenr anta@chevron.com Kim Tulledge, Chevron, Kim.Tulledge@chevron.com Jennifer Forringer, Chevron, jenniferforinger@chevron.com Bob Goodman, Chevron, rgoodman@rjo.com Sophie Froelich, Office of Chief Counsel, Sophie.Froelich@Waterboards.ca.gov Ryan Lodge, Central Coast Water Board, ryan.lodge@waterboards.ca.gov Thea Tryon, Central Coast Water Board, thea.tryon@waterboards.ca.gov Angela Schroeter, Central Coast Water Board, angela.schroeter@waterboards.ca.gov Greg Bishop, Central Coast Water Board, greg.bishop@waterboards.ca.gov Sheila Soderberg, Central Coast Water Board, sheila.soderberg@waterboards.ca.gov Dan Niles, Central Coast Water Board, dan.niles@waterboards.ca.gov BizFlow [M30000]; SCP-Reg 3 Site Specific and DARTS: [Covelop, Inc. Roundabout]; Site Cost Recovery ID: [2030187]; and GeoTracker ID [T100000020989]. File path: \\ca.epa.local\rb\rb3\shared\scp\sites\slo co\san luis obispo\276 tank farm road - covelop slo tank farm\roundabout project\09-25-2023_scp_covelop_rmp.docx Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 1 The Central Coast Regional Water Quality Control Board (Central Coast Water Board) reviewed the document titled “Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction, San Luis Obispo, California” (RMP) dated August 23, 2023, and submitted by Roux Associates, Inc. on behalf of Covelop, Inc. (Covelop). The RMP is for a proposed roundabout road improvement project located within and adjacent to several former and active Site Cleanup Program sites, including the San Luis Obispo Tank Farm, Union Pacific Railroad Tie Fire, and San Luis Obispo Regional Airport. Due to the project’s proximity to these investigation and cleanup sites1, and the potential for other unknown pollution sources, the Central Coast Water Board requested Covelop develop a plan for managing potential soil and groundwater pollution that may be encountered during grading and excavation activities for the project. The Central Coast Water Board is providing the following general and specific comments and requires the RMP to be revised to address the comments provided below and submitted by December 1, 2023. General Comments The RMP must be signed by a California licensed professional engineer or geologist, experienced in oversight of projects with the potential for encountering soil, sediment, and groundwater pollution. The RMP should include a clear, detailed description of project management for environmental oversight, including the following standard elements: • Identify the environmental oversight contractor(s). • List the primary environmental oversight contacts and contact information. • Describe the level of environmental oversight planned for the entire project starting with initial surveying prior to earth movement , earth movement, groundwater encroachment, staging area, etc. • Provide the lines communication, timing of reporting, and notification procedures. • Identify who is responsible for stop-work orders in the event of encountering unexpected and/or significant risks. • Describe procedures for securing the construction area in the event contingency measures are triggered. • Identify who is/are responsible for project area security. • Provide the project schedule for the proposed scope of work. 1Contaminants of concern include total petroleum hydrocarbons, polycyclic aromatic hydrocarbons, arsenic, lead, benzene, toluene, ethylbenzene, total xylenes, and per - and polyfluoroalkyl substances for proximal Site Cleanup Program sites. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 2 Specific Comments Introduction, first paragraph: • Include that the intent of the RMP, in addition to soil, is for the management of potential occurrences of groundwater. • State that in addition to managing human health and safety risks, the RMP includes ecological screening levels to protect ecological receptors. The basis for this comment is explained further below in comments to Section 2.3. Introduction, second paragraph: • Provide a plan for characterizing the native and imported soil for the proposed stormwater basin. • Include a section describing processes and procedures for documenting the characteristics and acceptance criteria for the proposed use of imported soil to create the noted berms. This is particularly important for direct contact of stormwater within proposed stormwater basin, and protection of ecological receptors. • Describe the origin of the imported fill and the expected volume. • Describing the physical criteria of the imported fill (i.e., no metal, glass, expansive soils, concrete, etc.). See Padre's 2018 Soil Segregation & Stockpiling Plan as an example of the type of information that should be included in the RMP. • Procedures for profiling verification and documentation that imported soil meets ecological risk screening levels are needed. This includes profiling for direct soil contact and soil contacting stormwater. Introduction: Project location, numbers 1 to 4: • Provide a figure clearly illustrating the location of the project area in relation to the five parcels the project encompasses. The current map lacks clarity for understanding the spatial aspects of the project , the involved parcels, and who owns the involved parcels. Introduction, third paragraph: • Provide clearly illustrated cut and fill figures in plan view and in cross-sections. • Provide a soil characterization and use plan inclusive of applicable comparative ecological risk screening levels for the proposed reuse of project excavated soil as backfill. This is applicable to soil proposed for use in areas that may have direct contact exposure to ecological receptors, such as burrowing animals. This is needed for ecological protection purposes. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 3 Introduction, fourth paragraph, first sentence: • Provide clarification differentiating the risk drivers and corresponding approved remedial plan applicable to the post-remedy land uses for the Tank Farm property versus the roundabout project. Central Coast Water Board staff recommends using the standardized San Francisco Bay Regional Water Quality Control Board’s (SF Bay Water Board) Environmental Screening Levels (ESLs)2, rather than utilizing site-specific risk-based screening levels (RBSLs) derived for the unique conditions on the Tank Farm property. • Provide a basis for exclusively using Tank Farm Site health and safety risk criteria while not considering potential unidentified risks that may be associated with prior property uses not on Tank Farm property. Note, some of the risk-based screening levels were based on recreational users, age-dependent adjustment factors applied only to mutagens, which may not be applicable for the proposed project. • Provide Phase I and Phase II investigation data, if available, that supports the assertion of no known contamination for APN 053-421-006 and existing roadway property. If no Phase I and Phase II type data are available, provide a description of the decision basis for why such data were not collected as part of the project screening analysis for determining potential risk factors. Explain why the assumptions for soil are different than the stated assumptions for groundwater. Describe prior land uses, utilities, water supply, water supply wells, and wastewater disposal systems, such as septic systems, etc. • Recommend pre-characterization of anticipated wastes in the project area to assist with waste management or re-use (i.e., determine if most excavated soil can be used as fill material or if excavated soils will need to be disposed of at the landfill). Section 2.1, first paragraph: • See above request for a figure clearly illustrating the project footprint and involved parcels. Section 2.2, last paragraph: • See above request for plan view and cross-section cut and fill plans. Please provide these plans as part of a revised RMP and at least 2 months in advance of commencing proposed grubbing and grading activities. 2 More information about SF Bay Water Board’s ESLs: https://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/esl.html Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 4 Section 2.3, paragraph five: • Copies of figures are presented in Appendix B. Please superimpose the location of the roundabout project on the f igures to show what contaminants of concern (COCs) may be encountered during construction. Section 2.3, paragraph preceding the bulleted list: • Clarify how the use of RBSLs apply to the project in contrast with those identified for the Tank Farm Site that are applicable to post-remedy land uses for that site. As stated above, consider using SF Bay Water Board’s ESLs for comparison purposes. • Explain the decision basis for excluding screening for other potential project- specific COC, such as per- and polyfluoroalkyl substances, organochlorine pesticides, polychlorinated biphenyls, and comprehensive heavy metals screening in addition to the noted arsenic and lead and relate those to potential project-specific ecological receptors based on direct routes of exposure. Section 2.4, Table 1: • Explain why ecological screening levels are deemed “Not applicable” to the project. Development of project-specific COC and corresponding screening levels is recommended. Section 3, first paragraph: • See General Comments above and provide a detailed flowchart for project oversight, level of oversight throughout the project , communications between the different contracting representatives, personnel responsibilities, contact information, etc. • Correct the cited “ELAP” acronym to indicate it references the California Environmental ‘Laboratory’ Accreditation Program. • Provide further screening criteria such as incidental observations of odors (as referenced in Section 6, but include here in Section 3) and clarify, more specifically visual cues specific to identifying discoloration/staining as differentiated from what is expected for characteristics of native soil. Provide consistency throughout the RMP for use and actionable responses to qualitative indicators of potential impacts to soil and groundwater. • Describe the potential for identification of non-native fill material unrelated to engineered road-base. For the latter, provide a rationale regarding potential screening specific to possible end-uses and corresponding routes of exposure and risk. Section 3.1, third paragraph: • Citation is only identified for Occupational Safety and Health Administration (OSHA) lead in construction. Note, other OSHA standards apply for arsenic (i.e., Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 5 10 micrograms per cubic meter of air averaged over any 8-hour period) and asbestos (0.1 fiber/milliliter of air over an 8-hour period) which are wastes potentially found in the project area. Section 3.2, first paragraph: • See General Comments above and provide a detailed flowchart for project oversight, communications, personnel responsibilities, contact information, etc. Clarification is required for proposed environmental oversight activities and principal responsibilities assigned thereto in relation to communications with agencies, contractors, and subcontractors. Section 3.2, second paragraph, reference to Table 1: • See above comments to Section 2.3. Provide project-specific application of ecological risk-based screening levels for potential routes of direct exposure. Justification for project-specific COC is needed. Section 3.2, reference to flowchart Figure 3: • Modify flowchart for project-specific end land use and configuration related to potential ecological receptors. Section 3.2, open sub-bullet two: • Clarify reference to the noted “section 5.3” regarding composite sampling details, which were not included in the RMP. Section 3.4, second paragraph: • Describe containment of removed and potentially impacted soil cleaned from construction and hauling vehicles and equipment. Clarify if water use is part of the cleaning process and if “yes,” describe the potential volumes that may require containment, and provide a description of the procedures for profiling the impacted materials for proper handling and disposal. Section 3.6: • See above comments to Section 3.4. • Provide more information about vehicle and equipment decontamination . • Identify the decontamination area on the site map. Will there be rumble strips for vehicles leaving the construction site? If so, please specify how construction materials will be contained onsite. Section 4, first paragraph: • See comments requiring clarification of project environmental oversight. Section 4.2: • Clarify reference to the cited section 5.3.; there’s currently no section 5.3. in the RMP. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 6 • Include analyses for per- and polyfluoroalkyl substances, organochlorine pesticides, and polychlorinated biphenyls. Section 4.2: • Include sampling and analyses for per- and polyfluoroalkyl substances consistent with prior oral communications and direction from Central Coast Water Board staff. Section 4.3: • See prior comments regarding use of RBSLs as a criterion governing soil reuses related to ecological risk receptors. RBSLs cited in the RMP are applicable to the Tank Farm Site but differ for the roundabout project. This is due to the differences in proposed soil reuses. RBSLs for the Tank Farm Site are intended for waste left in-place and not available for direct routes of exposure, i.e., capped and contained, and intended for corresponding land uses identified in the approved remedial action plan. Differentiate in the RMP the difference in end use and configuration between the Tank Farm Site and proposed roundabout project relative to the potential for direct routes of exposure for ecological receptors based on comparative ecological screening levels. • An analysis for acceptance criteria is missing from the list: Add Corrosivity by USEPA 9040 and Fish Bioassay (96-hour acute aquatic toxicity). Section 5: • Specify characterization and profiling for collected groundwater, including sampling and analyses for per- and polyfluoroalkyl substances consistent with prior communications and direction from Central Coast Water Board staff. • Provide references to qualitative indicators for identifying potential impacted groundwater, i.e., types of indicators such as sheening, odor, photoionization detector (PID) screening of ambient air in and around trenches, etc . • Develop reporting procedures for groundwater characterization and specify Central Coast Water Board approval is required prior to any onsite discharges for non-impacted groundwater. • Describe the procedures for documenting approval to discharge to the sanitary sewer system. • Note that direct discharge to a storm drainage system of impacted groundwater, or treated impacted groundwater, requires enrollment in and compliance with the Central Coast Water Bo ard’s “Order No. R3-2022-0035 NPDES No. CAG99304 Waste Discharge Requirements National Pollutant Discharge Elimination System General Permit for Discharges with Limited Treat to Water Quality.”3 3 https://www.waterboards.ca.gov/centralcoast/board_decisions/adopted_orders/#go_npdes_statewide Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 7 Section 6: • See comments requiring clarification of project environmental oversight. • Include both soil and/or groundwater impacts for contingency planning as both may be co-located and not solely mutually exclusive upon encountering. Section 6.1, first paragraph: • Change the text to indicate that contingency measures will be implemented as a project requirement, as opposed to indicating that contingency measures “’should’ be implemented,” which implies that the contingency measures are subject to discretionary determinations for whether they’ll be followed. Section 6.1, second bullet: • As noted above, provide clarification of lines of communication, and timing thereof based on clear metrics (i.e., what conditions and qualitative and quantitative metrics constitute a determination that encountered conditions present a “material threat to human health and the environment”) with contact information for all environmental oversight work. A flowchart is recommended. Section 6.1, sentence after third bullet: • Provide a decision matrix, or detailed description, with specific indicators for triggering determinations to provide notifications and obtain permits with corresponding contacts and anticipated permits needed. Section 6.1, last paragraph: • Provide a contact matrix inclusive of local agencies to be notified in the event of underground storage tanks (USTs) or pipelines are found (e.g., local tank removal oversight agencies are the City Fire Department and/or San Luis Obispo County Environmental Health depending on the location of the infrastructure). • Include a plan for testing and cleanup of stockpile areas for impacted soil and/or groundwater to ensure all potential residual contamination is removed and areas cleaned up. • Provide a soil testing plan that complies with local agency(ies) requirements for removal and dispensation of USTs and associated infrastructure. Also, provide a citation for, or include, as appropriate, in deference to local agency requirements, the noted “RWQCB guidelines” for UST removals for ease of reference for the environmental oversight representative and contractors. • Provide a description of the process and procedures for delineating the extent of impacted material and confirmation criteria for determining removal has occurred, e.g., analyses to be performed, expected laboratory reporting periods for informing necessary iterative field removal activities, etc. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 8 Figure 1: • Revise Figure 1 to specify the correct roundabout project location. Potential incorrect reference to roundabout project north of the Tank Farm property on Prado Road. Appendices: • Exhibit A-1 - suggest adding the proposed location of the roundabout on the county parcel map. • Appendix B – suggest adding the proposed roundabo ut location on historical maps. • Add Appendix C – overall project schedule. If you have any questions regarding these comments, please contact Dan Niles at (805) 549-3355 (dan.niles@waterbaords.ca.gov) or Sheila Soderberg at (805) 549- 3592 (sheila.soderberg@waterboards.ca.gov). 1 From:Martinez, Olga Sent:Tuesday, May 30, 2023 1:31 PM To:Christian, Kevin Cc:City_Attorney; CityClerk Subject:Final Production - PRR22294 Tsai - 276 Tank Farm Rd. Attachments:PRR22294 Tsai - 276 Tank Farm Rd.pdf Hi Kevin, Happy to announce this one is completely done সহ঺঻ In the Responsive Records folder, I have added the following documents: To folder labelled – Batch 2, I added “PRR22294 - batch 2 attachments,” with 12 documents. I created folder labelled – Batch 3, and I have added “PRR22294 - batch 3,” with 8 documents. Note that several documents were withheld pursuant to Government Code 7927.500 (formerly Government Code §6254 (a)), this division does not require disclosure of any preliminary drafts, notes, or interagency or intraagency memoranda that are not retained by a public agency in the ordinary course of business, if the public interest in withholding those records clearly outweighs the public interest in disclosure. This request was reviewed by Assistant City Attorney Markie Kersten and Paralegal Olga Martinez. This correspondence finalizes our production for your current request. Please be advised that every effort has been made to search for all records which may fall within the scope of your records request, and, as such, we believe our search is quite thorough. However, if you have knowledge of a specific document which has not been provided in response to your request, please notify us, and we will be happy to provide the document(s) to you unless, of course, it is exempt from disclosure pursuant to California Government Code §7921.000 et seq. Thank you, Olga Martinez Paralegal II City Attorney's Office 990 Palm Street, San Luis Obispo, CA 93401-3249 E omartine@slocity.org T 805.781.7139 slocity.org Stay connected with the City by signing up for e-notifications 2 The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. Ph: (626) 381-9248 Fx: (626) 389-5414 Em: info@mitchtsailaw.com Mitchell M. Tsai Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 VIA E-MAIL November 18, 2022 Teresa Purrington, City Clerk City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 Em: tpurrington@slocity.org RE: Public Records Act and Advance Notice List Request Regarding the 276 Tank Farm Road Project Dear City Clerk, On behalf of Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”) and its members, this Office requests that the City of San Luis Obispo City”) provide any and all information referring or related to the 276 Tank Farm Road Project (“Project”) pursuant to the California Public Records Act (“PRA”), Cal. Government (“Gov’t”) Code §§ 6250–6270 (collectively “PRA Request”). Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. The Southwest Regional Council of Carpenters is a labor union representing more than 50,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning and addressing the environmental impacts of development projects, such as the Project. I. PUBLIC RECORDS ACT REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 2 of 7 Southwest Carpenters is requesting any and all information referring or related to the Project. The Public Records Act defines the term “public record” broadly as “any writing containing information relating to the conduct of the public’s business . . . regardless of physical form and characteristics.” Gov’t Code § 6252(d). “Records” includes all communications relating to public business regardless of physical form or characteristics, including but not limited to any writing, picture, sound, or symbol, whether paper, magnetic, electronic, text, other media, or written verification of any oral communication. Included in this request are any references in any appointment calendars and applications, phone records, or text records. These “records” are to include, but are not limited to correspondences, e-mails, reports, letters, memorandums, and communications by any employee or elected official of the City concerning the Project. Please include in your response to this request the following examples of “records,” as well as any similar physical or electronic forms of communication: any form of writing such as correspondence, electronic mail records (“email”), legal and factual memoranda, facsimiles, photographs, maps, videotapes, film, data, reports, notes, audiotapes, or drawings. Cal. Government Code § 6252(g) (defining a writing to including “any record thereby created, regardless of the manner in which the record has been stored”). Responsive correspondence should include, inter alia, emails, text messages, or any other form of communication regardless of whether they were sent or received on public or privately-owned electronic devices “relating to the conduct of the public’s business.” Cal. Government Code § 6252(e); Citizens for Ceres v. Super. Ct. Ceres”) (2013) 217 Cal. App. 4th 889, 909; Citizens for Open Gov’t v. City of Lodi Lodi”) (2012) 205 Cal.App.4th 296, 307, 311; City of San Jose v. Superior Court (2017) 2 Cal. 5th 608, 625 (finding that a public employee or officer’s “writings about public business are not excluded” from the California Public Records Act “simply because they have been sent, received, or stored in a personal account.”) . This Office requests any and all information referring or related to the Project, including but not limited to: 1) All Project application materials; 2) All staff reports and related documents prepared by the City with City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 3 of 7 respect to its compliance with the substantive and procedural requirements of the California Environmental Quality Act, Public Resources Code § 21000 et seq., and the CEQA Guidelines, title 14, California Code of Regulations, § 15000 et seq. (collectively CEQA”) and with respect to the action on the Project; 3) All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the agency pursuant to CEQA; 4) Any transcript or minutes of the proceedings at which the decisionmaking body of the City heard testimony on, or considered any environmental document on, the Project, and any transcript or minutes of proceedings before any advisory body to the public agency that were presented to the decisionmaking body prior to action on the environmental documents or on the Project; 5) All notices issued by the City to comply with CEQA or with any other law governing the processing and approval of the Project; 6) All written comments received in response to, or in connection with, environmental documents prepared for the Project, including responses to the notice of preparation; 7) All written evidence or correspondence submitted to, or transferred from, the City with respect to compliance with CEQA or with respect to the Project; 8) Any proposed decisions or findings submitted to the decisionmaking body of the City by its staff, or the Project proponent, Project opponents, or other persons; 9) The documentation of the final City decision and approvals, including the final environmental impact report, mitigated negative declaration, negative declaration, or notice of exemption, and all documents, in addition to those referenced in paragraph (3), cited or relied on in the findings or in a statement of overriding City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 4 of 7 considerations adopted pursuant to CEQA; 10) Any other written materials relevant to the public agency's compliance with CEQA or to its decision on the merits of the Project, including the initial study, any drafts of any environmental document, or portions thereof, that have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the Project and either made available to the public during the public review period or included in the City 's files on the Project, and all internal agency communications, including staff notes and memoranda related to the Project or to compliance with CEQA; and 11) The full written record before any inferior administrative decisionmaking body whose decision was appealed to a superior administrative decisionmaking body prior to the filing of any litigation. Please respond within 10 days from the date you receive this request as to whether this request specifies identifiable records not exempt from disclosure under the PRA or otherwise privileged or confidential, and are therefore subject to disclosure. This Office understands that this time may be extended up to 14 days for unusual circumstances as provided by Cal. Government Code § 6253(c), and that we will be notified of any extension and the reasons justifying it. We request that you provide all documents in electronic format and waive any and all fees associated with this Request. SWRCC is a community-based organization. Please notify and obtain express approval from this Office before incurring any duplication costs. If any of the above requested documents are available online, please provide us with the URL web address at which the documents may be downloaded. If any of the requested documents are retained by the City in electronic computer-readable format such as PDF (portable document format), please provide us with pdf copies of the documents via email, or inform us of the location at which we can copy these documents electronically. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 5 of 7 In preparing your response, please bear in mind that you have an obligation under Government Code section 6253.1 to (1) identify all records and information responsive to our request or the purpose of our request; (2) describe the information technology and physical location in which the records exist; and (3) provide suggestions for overcoming any practical basis for denying access to the records or information sought. In responding to this request, please bear in mind that any exemptions from disclosure you may believe to be applicable are to be narrowly construed. Marken v. Santa Monica- Malibu Unif. Sch. Dist. (2012) 202 Cal. App. 4th 1250,1262; and may be further narrowed or eliminated by the adoption of Proposition 59, which amended article I, section 3(b)(2) of the California Constitution to direct that any “statute ... or other authority ... [that] limits the right of access” to “information concerning the conduct of the people’s business” must be “narrowly construed.” As for any records that you nonetheless decline to produce on the grounds of an exemption, please bear in mind that the case law under the Public Records Act imposes a duty on you to distinguish between the exempt and the non-exempt portion of any such records, and to attempt in good faith to redact the exempt portion and to disclose the balance of such documents. Please bear in mind further that should you choose to withhold any document from disclosure, you have a duty under Government Code section 6255, subd. (a) to “justify withholding any record by demonstrating that the record in question is exempt under express provisions” of the Public Records Act or that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” Finally, please note that you must retain and not destroy any and all records, notwithstanding any local record retention or document destruction policies. As the Court noted in Golden Door Properties, LLC v. Superior Court of San Diego County (2020) 53 Cal.App.5th 733 that a public agency “must retain ‘[a]ll written evidence or correspondence submitted to, or transferred from’ . . . with respect to” CEQA compliance or “with respect to the project.” II. ADVANCE NOTICE LIST REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 6 of 7 We also ask that you put this Office on its notice list for any and all notices issued under the CEQA and the Planning and Zoning Law. In particular, we request that the City send by mail or electronic mail notice of any and all actions or hearings related to activities undertaken, authorized, approved, permitted, licensed, or certified by the City and any of its subdivision for the Project, or supported, in whole or in part, through permits, contracts, grants, subsidies, loans, or other forms of approvals, actions or assistance, including but not limited to the following: Notices of any public hearing held in connection with the Project; as well as Any and all notices prepared pursuant to CEQA, including but not limited to: Notices of determination that an Environmental Impact Report EIR”) or supplemental EIR is required for a project, prepared pursuant to Public Resources Code Section 21080.4; Notices of availability of an EIR or a negative declaration for a project prepared pursuant to Public Resources Code Section 21152 and Section 15087 of Title 14 of the California Code of Regulations; Notices of approval or determination to carry out a project, prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of approval or certification of any EIR or negative declaration prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of exemption from CEQA prepared pursuant to Public Resources Code section 21152 or any other provision of law; and Notice of any Final EIR prepared pursuant to CEQA. This Office is requesting notices of any approvals or public hearings under CEQA and the California Planning and Zoning Law. This request is filed pursuant to California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 7 of 7 65092 requiring agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Please send notice by regular and electronic mail to: Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 Em: maria@mitchtsailaw.com Em: mitch@mitchtsailaw.com Em: reza@mitchsailaw.com Em: info@mitchtsailaw.com We look forward to working with you. If you have any questions or concerns, please do not hesitate to contact our Office. Sincerely, Mitchell M. Tsai Attorneys for Southwest Regional Council of Carpenters 1 Sent:Friday, May 5, 2023 5:15 PM To:hind@mitchtsailaw.com Cc:City_Attorney; CityClerk Subject:Records Request Update 05-05-2023: PRR22294 Tsai - 276 Tank Farm Rd. Attachments:PRR22294 Tsai - 276 Tank Farm Rd.pdf Good afternoon Ms. Baki, The City of San Luis Obispo (“City”) received your request pursuant to the California Public Records Act delivered via email on November 18, 2023. In accordance with the requirements of the Act, I am providing the following linked records, which are responsive to your request, and described below. “PRR22294 batch 2,” with 19 pages. Please note that any confidential or privileged records were withheld due to attorney-client privilege, exempt from disclosure pursuant to California Government Code §7927.705, CA Evidence Code § 1040 and Government Code §7922.000, as the public interest in nondisclosure clearly outweighs the public interest in disclosure. This request was reviewed by Attorney Chelsea O’ Sullivan and Paralegal Olga Martinez. The next batch of records will be provided to you week of May 8th, 2023. Thank you, Olga Martinez Paralegal II City Attorney's Office 990 Palm Street, San Luis Obispo, CA 93401-3249 E omartine@slocity.org T 805.781.7139 slocity.org Stay connected with the City by signing up for e-notifications The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT (805) 781-7140. Thank you. Ph: (626) 381-9248 Fx: (626) 389-5414 Em: info@mitchtsailaw.com Mitchell M. Tsai Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 VIA E-MAIL November 18, 2022 Teresa Purrington, City Clerk City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 Em: tpurrington@slocity.org RE: Public Records Act and Advance Notice List Request Regarding the 276 Tank Farm Road Project Dear City Clerk, On behalf of Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”) and its members, this Office requests that the City of San Luis Obispo City”) provide any and all information referring or related to the 276 Tank Farm Road Project (“Project”) pursuant to the California Public Records Act (“PRA”), Cal. Government (“Gov’t”) Code §§ 6250–6270 (collectively “PRA Request”). Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. The Southwest Regional Council of Carpenters is a labor union representing more than 50,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning and addressing the environmental impacts of development projects, such as the Project. I. PUBLIC RECORDS ACT REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 2 of 7 Southwest Carpenters is requesting any and all information referring or related to the Project. The Public Records Act defines the term “public record” broadly as “any writing containing information relating to the conduct of the public’s business . . . regardless of physical form and characteristics.” Gov’t Code § 6252(d). “Records” includes all communications relating to public business regardless of physical form or characteristics, including but not limited to any writing, picture, sound, or symbol, whether paper, magnetic, electronic, text, other media, or written verification of any oral communication. Included in this request are any references in any appointment calendars and applications, phone records, or text records. These “records” are to include, but are not limited to correspondences, e-mails, reports, letters, memorandums, and communications by any employee or elected official of the City concerning the Project. Please include in your response to this request the following examples of “records,” as well as any similar physical or electronic forms of communication: any form of writing such as correspondence, electronic mail records (“email”), legal and factual memoranda, facsimiles, photographs, maps, videotapes, film, data, reports, notes, audiotapes, or drawings. Cal. Government Code § 6252(g) (defining a writing to including “any record thereby created, regardless of the manner in which the record has been stored”). Responsive correspondence should include, inter alia, emails, text messages, or any other form of communication regardless of whether they were sent or received on public or privately-owned electronic devices “relating to the conduct of the public’s business.” Cal. Government Code § 6252(e); Citizens for Ceres v. Super. Ct. Ceres”) (2013) 217 Cal. App. 4th 889, 909; Citizens for Open Gov’t v. City of Lodi Lodi”) (2012) 205 Cal.App.4th 296, 307, 311; City of San Jose v. Superior Court (2017) 2 Cal. 5th 608, 625 (finding that a public employee or officer’s “writings about public business are not excluded” from the California Public Records Act “simply because they have been sent, received, or stored in a personal account.”) . This Office requests any and all information referring or related to the Project, including but not limited to: 1) All Project application materials; 2) All staff reports and related documents prepared by the City with City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 3 of 7 respect to its compliance with the substantive and procedural requirements of the California Environmental Quality Act, Public Resources Code § 21000 et seq., and the CEQA Guidelines, title 14, California Code of Regulations, § 15000 et seq. (collectively CEQA”) and with respect to the action on the Project; 3) All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the agency pursuant to CEQA; 4) Any transcript or minutes of the proceedings at which the decisionmaking body of the City heard testimony on, or considered any environmental document on, the Project, and any transcript or minutes of proceedings before any advisory body to the public agency that were presented to the decisionmaking body prior to action on the environmental documents or on the Project; 5) All notices issued by the City to comply with CEQA or with any other law governing the processing and approval of the Project; 6) All written comments received in response to, or in connection with, environmental documents prepared for the Project, including responses to the notice of preparation; 7) All written evidence or correspondence submitted to, or transferred from, the City with respect to compliance with CEQA or with respect to the Project; 8) Any proposed decisions or findings submitted to the decisionmaking body of the City by its staff, or the Project proponent, Project opponents, or other persons; 9) The documentation of the final City decision and approvals, including the final environmental impact report, mitigated negative declaration, negative declaration, or notice of exemption, and all documents, in addition to those referenced in paragraph (3), cited or relied on in the findings or in a statement of overriding City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 4 of 7 considerations adopted pursuant to CEQA; 10) Any other written materials relevant to the public agency's compliance with CEQA or to its decision on the merits of the Project, including the initial study, any drafts of any environmental document, or portions thereof, that have been released for public review, and copies of studies or other documents relied upon in any environmental document prepared for the Project and either made available to the public during the public review period or included in the City 's files on the Project, and all internal agency communications, including staff notes and memoranda related to the Project or to compliance with CEQA; and 11) The full written record before any inferior administrative decisionmaking body whose decision was appealed to a superior administrative decisionmaking body prior to the filing of any litigation. Please respond within 10 days from the date you receive this request as to whether this request specifies identifiable records not exempt from disclosure under the PRA or otherwise privileged or confidential, and are therefore subject to disclosure. This Office understands that this time may be extended up to 14 days for unusual circumstances as provided by Cal. Government Code § 6253(c), and that we will be notified of any extension and the reasons justifying it. We request that you provide all documents in electronic format and waive any and all fees associated with this Request. SWRCC is a community-based organization. Please notify and obtain express approval from this Office before incurring any duplication costs. If any of the above requested documents are available online, please provide us with the URL web address at which the documents may be downloaded. If any of the requested documents are retained by the City in electronic computer-readable format such as PDF (portable document format), please provide us with pdf copies of the documents via email, or inform us of the location at which we can copy these documents electronically. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 5 of 7 In preparing your response, please bear in mind that you have an obligation under Government Code section 6253.1 to (1) identify all records and information responsive to our request or the purpose of our request; (2) describe the information technology and physical location in which the records exist; and (3) provide suggestions for overcoming any practical basis for denying access to the records or information sought. In responding to this request, please bear in mind that any exemptions from disclosure you may believe to be applicable are to be narrowly construed. Marken v. Santa Monica- Malibu Unif. Sch. Dist. (2012) 202 Cal. App. 4th 1250,1262; and may be further narrowed or eliminated by the adoption of Proposition 59, which amended article I, section 3(b)(2) of the California Constitution to direct that any “statute ... or other authority ... [that] limits the right of access” to “information concerning the conduct of the people’s business” must be “narrowly construed.” As for any records that you nonetheless decline to produce on the grounds of an exemption, please bear in mind that the case law under the Public Records Act imposes a duty on you to distinguish between the exempt and the non-exempt portion of any such records, and to attempt in good faith to redact the exempt portion and to disclose the balance of such documents. Please bear in mind further that should you choose to withhold any document from disclosure, you have a duty under Government Code section 6255, subd. (a) to “justify withholding any record by demonstrating that the record in question is exempt under express provisions” of the Public Records Act or that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” Finally, please note that you must retain and not destroy any and all records, notwithstanding any local record retention or document destruction policies. As the Court noted in Golden Door Properties, LLC v. Superior Court of San Diego County (2020) 53 Cal.App.5th 733 that a public agency “must retain ‘[a]ll written evidence or correspondence submitted to, or transferred from’ . . . with respect to” CEQA compliance or “with respect to the project.” II. ADVANCE NOTICE LIST REQUEST. City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 6 of 7 We also ask that you put this Office on its notice list for any and all notices issued under the CEQA and the Planning and Zoning Law. In particular, we request that the City send by mail or electronic mail notice of any and all actions or hearings related to activities undertaken, authorized, approved, permitted, licensed, or certified by the City and any of its subdivision for the Project, or supported, in whole or in part, through permits, contracts, grants, subsidies, loans, or other forms of approvals, actions or assistance, including but not limited to the following: Notices of any public hearing held in connection with the Project; as well as Any and all notices prepared pursuant to CEQA, including but not limited to: Notices of determination that an Environmental Impact Report EIR”) or supplemental EIR is required for a project, prepared pursuant to Public Resources Code Section 21080.4; Notices of availability of an EIR or a negative declaration for a project prepared pursuant to Public Resources Code Section 21152 and Section 15087 of Title 14 of the California Code of Regulations; Notices of approval or determination to carry out a project, prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of approval or certification of any EIR or negative declaration prepared pursuant to Public Resources Code Section 21152 or any other provision of law; Notice of exemption from CEQA prepared pursuant to Public Resources Code section 21152 or any other provision of law; and Notice of any Final EIR prepared pursuant to CEQA. This Office is requesting notices of any approvals or public hearings under CEQA and the California Planning and Zoning Law. This request is filed pursuant to California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section City of San Luis Obispo – 276 Tank Farm Road Project November 18, 2022 Page 7 of 7 65092 requiring agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body. Please send notice by regular and electronic mail to: Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue Suite 200 Pasadena, California 91101 Em: maria@mitchtsailaw.com Em: mitch@mitchtsailaw.com Em: reza@mitchsailaw.com Em: info@mitchtsailaw.com We look forward to working with you. If you have any questions or concerns, please do not hesitate to contact our Office. Sincerely, Mitchell M. Tsai Attorneys for Southwest Regional Council of Carpenters 1 From:Bryan Hulburd <bhulburd@covelop.net> Sent:Tuesday, September 26, 2023 4:38 PM To:Floyd, Aaron Cc:Scott, Shawna; Boerman, Mychal; Dietrick, Christine Subject:RE: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO - RISK MITIGATION PLAN COMMENTS Attachments:Roundabout Risk Mitigation Plan_8-23-23.pdf No problem – please see aƩached. Bryan Hulburd Project Manager 805-459-0753 bhulburd@covelop.net From: Floyd, Aaron <afloyd@slocity.org> Sent: Tuesday, September 26, 2023 4:03 PM To: Bryan Hulburd <bhulburd@covelop.net> Cc: Scott, Shawna <sscott@slocity.org>; Boerman, Mychal <mboerman@slocity.org>; Dietrick, Christine <cdietric@slocity.org> Subject: RE: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO - RISK MITIGATION PLAN COMMENTS Hi Bryan, Can you send us the Risk Mitigation Plan mentioned below: Thanks Aaron Aaron Floyd pronouns he/him/his Utilities Director 2 Public Utilities 879 Morro Street, San Luis Obispo, CA 93401-2710 E afloyd@slocity.org T 805.781.7205 slocity.org Stay connected with the City by signing up for e-notifications From: Bryan Hulburd <bhulburd@covelop.net> Sent: Tuesday, September 26, 2023 9:59 AM To: 'Hernandez, Christine@Waterboards' <Christine.Hernandez@Waterboards.ca.gov> Cc: Schwartz, Luke <LSchwart@slocity.org>; Johnson, Derek <djohnson@slocity.org>; McDonald, Whitney <WMcDonal@slocity.org>; Floyd, Aaron <afloyd@slocity.org>; nstrong@slocity.org; Kersten, Markie <mkersten@slocity.org>; Dietrick, Christine <cdietric@slocity.org>; vheger@meyersnave.com; Lindgren, Adam <adam@meyersnave.com>; dmavis@covelop.net; parnold@covelop.net; dixon@rouxinc.com; owenranta@chevron.com; kim.tulledge@chevron.com; jenniferforinger@chevron.com; rgoodman@rjo.com; 'Froelich, Sophie@Waterboards' <Sophie.Froelich@Waterboards.ca.gov>; 'Lodge, Ryan@Waterboards' <Ryan.Lodge@waterboards.ca.gov>; 'Tryon, Thea@Waterboards' <Thea.Tryon@waterboards.ca.gov>; 'Schroeter, Angela@Waterboards' <Angela.Schroeter@waterboards.ca.gov>; 'Bishop, Greg@Waterboards' <Greg.Bishop@waterboards.ca.gov>; 'Soderberg, Sheila@Waterboards' <Sheila.Soderberg@waterboards.ca.gov>; 'Niles, Dan@Waterboards' <Dan.Niles@waterboards.ca.gov> Subject: RE: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO - RISK MITIGATION PLAN COMMENTS This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Thank you, ChrisƟne. The team will review these comments right away. Our team would like to keep the meeƟng as scheduled for October 2nd (next Monday) as we believe it will be very valuable for the City team to meet with the Water Board directly to discuss its important infrastructure project. Thank you, Bryan Bryan Hulburd Project Manager 805-459-0753 bhulburd@covelop.net From: Hernandez, Christine@Waterboards <Christine.Hernandez@Waterboards.ca.gov> Sent: Tuesday, September 26, 2023 9:37 AM To: Bryan Hulburd <bhulburd@covelop.net> Cc: LSchwart@slocity.org; djohnson@slocity.org; wmcdonal@slocity.org; afloyd@slocity.org; nstrong@slocity.org; mkersten@slocity.org; cdietric@slocity.org; vheger@meyersnave.com; adam@meyersnave.com; dmavis@covelop.net; parnold@covelop.net; dixon@rouxinc.com; owenranta@chevron.com; kim.tulledge@chevron.com; jenniferforinger@chevron.com; rgoodman@rjo.com; Froelich, Sophie@Waterboards <Sophie.Froelich@Waterboards.ca.gov>; 3 Lodge, Ryan@Waterboards <Ryan.Lodge@waterboards.ca.gov>; Tryon, Thea@Waterboards <Thea.Tryon@waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Soderberg, Sheila@Waterboards <Sheila.Soderberg@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov> Subject: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO – RISK MITIGATION PLAN COMMENTS SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONTRUCTION, SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – RISK MITIGATION PLAN COMMENTS The Central Coast Regional Water Quality Control Board is increasing its efforts to transmit correspondence and other information electronically, reducing the amount of paper used, and increasing the speed of which information is distributed. Therefore, you are receiving the attached correspondence for the subject site from the Central Coast Water Board in a Portable Data Format (PDF) format. If you need help opening this document, please refer to the link below; http://www.adobe.com/products/acrobat/readstep2.html Environmental Consulting & Management +1.800.322.ROUX rouxinc.com Risk Mitigation Plan ________________________________ TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION San Luis Obispo, California August 23, 2023 Prepared for: Covelop, Inc. Prepared by: Roux Associates, Inc. 555 12th Street, Suite 250 Oakland, California 94607 3957.0001S100/SMP 3374.0001S000 Site Mitigation Plan | ROUX | i Table of Contents 1. Introduction .................................................................................................................................... 2 2. Project Background & Current Conditions ..................................................................................... 4 2.1 Property Location and Description ...................................................................................... 4 2.2 Project Description ............................................................................................................... 4 2.3 Adjacent Site History & Environmental Assessment ........................................................... 4 2.4 Risk Based Screening Levels for Soil .................................................................................. 6 3.0 Soil Excavation, Handling, and Off-Hauling Mitigative Measures .................................................. 7 3.1 Site-Specific Health and Safety Plan ................................................................................... 7 3.2 Soil Excavation and Management ....................................................................................... 8 3.3 Soil Stockpiling and Storage ................................................................................................ 9 3.4 Soil and Groundwater Transport and Disposal .................................................................... 9 3.5 Dust Control ......................................................................................................................... 9 3.6 Decontamination of Equipment ......................................................................................... 10 4. Soil Characterization and Disposal .............................................................................................. 11 4.1 Four-Point Composite Sampling ........................................................................................ 11 4.2 Sample Analysis ................................................................................................................ 11 4.3 Offsite Disposal .................................................................................................................. 11 5. Groundwater Management .......................................................................................................... 13 6. Environmental Contingency Plan ................................................................................................. 14 6.1 Contingency Measures for Unanticipated Conditions ....................................................... 14 7. Site Security ................................................................................................................................. 15 Figures 1. Site Location Map 2. Interim Design Plan 3. Decision Flow Chart for Petroleum Hydrocarbon Impacted Soil Tables Table 1. Human Health and Ecological Risk Based Screening Levels Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Appendices A. San Luis Obispo Assessor Parcel Maps B. Figures from Historical San Luis Obispo Tank Farm Documents 3374.0001S000 Site Mitigation Plan | ROUX | 2 1. Introduction Roux Associates, Inc. (Roux), on behalf of Covelop, has prepared this Risk Management Plan (RMP) to be implemented during soil disturbing activities for a portion of Tank Farm Road at approximately 520 feet west of the existing intersection with Sante Fe Road, California (Site) (Figure 1). The project involves widening a portion of Tank Farm Road and construction of a roundabout. This RMP has been prepared to mitigate potential health and safety risks associated with soil disturbing activities proposed to be completed during the road construction at the Site. As part of a road construction proposed for the Site, the following soil disturbing activities are planned: clearing and grubbing (to five inches below ground surface [bgs]) associated with shallow general grading for road construction, utility trench excavations ranging from three to eight feet bgs, potential localized groundwater dewatering in utility trenches to facilitate subsurface construction, and potential soil off-hauling and groundwater management activities. A stormwater basin is proposed at the southeast corner of the roundabout. There will be no soil excavation required for the construction of this basin as the bottom will be at existing grade with imported soil used to create berms. It is Roux’s understanding that the project is located on land owned by four different entities: 1. Chevron owns the property northwest and south of the existing Tank Farm Road Assessor Parcel Numbers (APN) 076-381-021 Parcels 4 and 5, and 076-382-005 Parcels 6 and 7, respectively; 2. Covelop owns the property northeast of the existing Tank Farm Road (APN 053-421-006); 3. The City of San Luis Obispo owns Tank Farm Road east of the approximate center of the roundabout; and 4. The County of San Luis Obispo owns Tank Farm Road west of the approximate center of the roundabout. Copies of the parcel maps are provided in Appendix A. Preliminary construction plans indicate that the project will disturb approximately 8,300 cubic yards (13,400 tons) of soil during: clearing, grubbing, and general grading (90,900 square feet [sqft]); the utility trench excavations (up to 12,200 sqft); Excavated soil from the Project development may be reused as backfill for the roundabout project, disposed of at the Santa Maria Regional Landfill (SMRL), or soil from the Covelop and Chevron Sites may be reused at each of their respective sites. Site investigations conducted at the adjacent Chevron former San Luis Obispo petroleum tank farm identified extensive petroleum hydrocarbon impacts in soil and groundwater which may also be present in the planned work area of the Site. To determine potential health and safety risks, Roux reviewed the adjacent property history and accepted soil movement procedures as presented in Chevron documentation for the adjacent site, including: Final Remediation Action Plan (RAP) (Avocet, 2015), the Soil Remediation Endpoint Plan (Padre, 2018a) the Soil Segregation and Stockpiling Plan (Padre 2018b). Characterization and cleanup at the adjacent Chevron site is being overseen by the Central Coast Water Quality Control board (RWQCB). There is no known contamination at the APN 053-421-006 parcel which is east of the Chevron site and was never part of the Chevron operations. There is no known soil contamination in the existing roadway property, however it is assumed that groundwater impacts at the Chevron site underlay the roadway, as it bisects the Chevron site where there are documented groundwater impacts. Based on the proposed soil disturbing activities and the potential of presence of hazardous materials at the Site, this RMP includes the following sections: • Section 2.0 provides the Site background and history, environmental conditions at the Site, and a description of the project; 3374.0001S000 Site Mitigation Plan | ROUX | 3 • Section 3.0 presents mitigative measures to be implemented during excavation, handling and off- hauling of soil/fill material; • Section 4.0 presents characterization activities for the disposal of excavated soil/fill material; • Section 5.0 includes measures for handling and disposing of groundwater, if necessary; • Section 6.0 presents an environmental contingency plan; and • Section 7.0 presents responsibilities for Site security. 3374.0001S000 Site Mitigation Plan | ROUX | 4 2. Project Background & Current Conditions This section provides a description of the planned project, location, Site history based on the adjacent former San Luis Obispo Tank Farm, and a summary of the risk-based screening levels for soil developed for the adjacent SLO Tank Farm property. 2.1 Property Location and Description The Site is a portion of Tank Farm Road at approximately 520 feet west of the existing intersection with Sante Fe Road, California and includes portions of San Luis Obispo County Assessor’s Parcel Number Blocks 076-381-021 Parcels 4 and 5, and 076-382-005 Parcel 6 and 7, 053-421-006. The City of San Luis Obispo owns Tank Farm Road east of the approximate center of the roundabout and the County of San Luis Obispo owns Tank Farm Road west of the approximate center of the roundabout. The Site contains portions of the San Luis Obispo Tank Farm to the north and south of Tank Farm Road owned by Chevron, a portion of a parking lot to the Northeast owned by Covelop, and City and County of San Luis Obispo owned Road to the East and West, respectfully of the center of the roundabout. There are no buildings within the construction footprint of the proposed roundabout. 2.2 Project Description The project involves construction of a roundabout on a portion of Tank Farm Road. Soil disturbing activities related to the roundabout construction include clearing, grubbing, general grading and utility trench excavation. Soil excavations related to the roundabout construction, based on the 60 percent complete Tank Farm & Santa Fe Public Improvement Plans provided by Client, include approximately 8,300 cubic yards (13,400 tons) of soil to be removed during: clearing, grubbing, and general grading to lower the existing soil profile to make vertical space for the public improvement subgrade (90,900 sqft to five inches bgs); the utility trench excavations (up to 12,200 sqft and depths ranging from three to eight feet bgs). Excavated soil from the Project development may be reused as backfill for the roundabout project, disposed of at the Santa Maria Regional Landfill (SMRL), or soil from the Covelop and Chevron Sites may be reused at each of their respective sites. A preliminary plan showing the proposed roundabout construction is presented as Figure 2. Final structural drawings for the planned construction will be provided to the Contractor prior to the start of construction. 2.3 Adjacent Site History & Environmental Assessment From 1910 until the 1980s, the San Luis Obispo Tank Farm property was used for the storage of crude oil transported by pipeline. Storage facilities consisted of six earthen reservoirs ranging in capacity from 775,000 to 1,350,000 barrels1, and 21 steel ASTs, each with a capacity of 55,000 barrels. The reservoirs consisted of excavated circular depressions, which were lined with reinforced concrete. Between the reservoirs and ASTs, the Property had a total capacity of over 6 million barrels of petroleum. On April 7, 1926, lightning strikes ignited the vapors in four of the reservoirs and led to a fire at the Property. Despite fire suppression efforts, the fire from the initial lightning strikes spread to the other reservoirs and to 14 of the ASTs present at the time. Crude oil flowed out of the reservoirs and tanks and on to the surrounding ground. Over the four days after the lighting strike, all but a few thousand of the six million barrels of inventory had been released and spread across the San Luis Obispo Tank Farm property. Much of this oil burnt to petroleum coke, which is a black solid residue usually obtained from cracking (burning) in the refining 1 One barrel is equivalent to 42 gallons. 3374.0001S000 Site Mitigation Plan | ROUX | 5 process. To date, highly weathered and burned petroleum covers the ground in areas of the San Luis Obispo Tank Farm, particularly in topographically low points. After the fire, Union Oil resumed operations and reconstructed 10 ASTs and four of the reservoirs including Reservoir 4 in the south portion of APN 076-381-021 Parcel 4 and 5 northwest of the Roundabout. Reconstruction included adding additional fire breaks and containment areas around the reservoirs. During operations, arsenic-based herbicides were used for weed control, primarily in the northwest area of the San Luis Obispo Tank Farm. The four reconstructed reservoirs continued to be used for several decades, before being decommissioned between 1959 and 1976. The petroleum, petroleum impacted soil, and walls were removed from the reservoirs, but the reinforced concrete bottom in Reservoir #4 was left in place and then covered with between 5 and 10 feet of non-engineered backfill. The origin of this backfill was from soil removed from the Reservoir 4 that was stockpiled and sampled to confirm it met the site-specific screening levels. Figures from the Closure Summary Report North Property Soils – OU#3 and OU#4 (Trihydro, 2020) show test pit locations near the Site and surface expressions of pliable highly weathered crude oil adjacent to the Site to the northwest. Copies of these figures are presented in Appendix B. Since 2002, the human health and ecological risks associated with the San Luis Obispo Tank Farm have been analysed by Union Oil Company of California (Union Oil, now a subsidiary of Chevron) and regulatory agency representatives as part of the Surface Evaluation, Remediation, and Restoration Team (SERRT). The SERRT is a multi-agency collaborative stakeholder group that was convened to evaluate the potential impacts to human and ecological health from petroleum hydrocarbons and other chemical at the San Luis Obispo Tank Farm. The SERRT includes representatives of the Central Coast Regional Water Quality Control Board (RWQCB), the California Department of Fish and Wildlife (CDFW), San Luis Obispo County Environmental Services (SLOEHS), U.S. Army Corps of Engineers (USACE), U.S. Fish and Wildlife Services (USFWS), California Environmental Protection Agency – Office of Environmental Health Hazard Assessment (OEHHA), San Luis Obispo County District (APCD), County of San Luis Obispo, City of San Luis Obispo, and Union Oil (now a subsidiary of Chevron) and its environmental consultants. The following documents have been prepared that address human and ecological risk associated with the petroleum hydrocarbons and other contaminants of concern at the San Luis Obispo Tank Farm. • Baseline Human Health Risk Assessment (McDaniel Lambert, 2004); • Predictive Ecological Risk Assessment, Version 2.0 (BBL, 2004); • Risk Management Summary (BBL, 2005); • Feasibility Study (Avocet Environmental, 2007); • Remedial Action Plan (Avocet Environmental, Inc., 2007); • Project Execution Plan (Padre, 2007); • Environmental Impact Report (MRS Environmental, 2013); • Updated Human Health Risk Assessment (McDaniel Lambert, 2013); • Revised Remedial Action Plan (Avocet, 2015); • Human Health Risk Action Summary (McDaniel Lambert, 2015); • Soil Segregation and Stockpiling Plan (Padre, 2015); • Recommended Ecological Risk-Based Screening Levels for Soil and Sediment (ERM, 2017); and • Arsenic Background Re-evaluation Report (Intrinsik, 2017). Summaries of these documents can be found in the Soil Remediation Endpoint Plan (Padre, 2018). 3374.0001S000 Site Mitigation Plan | ROUX | 6 2.4 Risk Based Screening Levels for Soil Based on multiple documents to address human and ecological risk associated with petroleum hydrocarbons and other contaminants of concern at the San Luis Obispo Tank Farm, a set of Risk Based Screening Levels (RBSLs) for Soil were proposed (Padre, 2018). Table 1 below presents the proposed RBSLs for the Site and the basis for each constituent of potential concern (COPC). These RBSLs are based on the agency approved RBSLs for the San Luis Obispo Tank Farm site. The soil concentration values are presented below in milligrams per kilogram as dry weight. The values are subdivided between open space and development areas. Open space RBSLs are further subdivided between ecological and human-health based values. Since it is anticipated that petroleum hydrocarbon impacts that may be encountered at the site would be legacy contamination form past regional Tank Farm uses, the human-health based RBSLs shown below will be used for soil at the Site. These RBSLs are currently approved by the RWQCB for cleanup and restoration on the properties surrounding the Site and therefore using these values will provide consistency with currently occurring activities at the adjacent properties. The Development Area RBSLs will be used for soil below the planned project hardscape, and the Open Space RBSLs will be used for exposed soil at the Site. . Table 1. Human Health and Ecological Risk Based Screening Levels Constituent Open Space (within upper two ft outside of PPSH areas) (mg/kg, dry weight) Development Area (within upper four ft) (mg/kg, dry weight) Ecological1 Human Health2 Human Health3 Arsenic NA 12.54 12.54 Lead NA 1805 3205 TPH (C4-C40) 782 7,6196 41,2806 Benzene NA 4.06 1.86 Toluene NA 7,9006 5,9076 Ethylbenzene NA 606 316 Total Xylenes NA 21,7506 18,4206 PAHs NA 0.97 1.87 Notes: NA – Not applicable. mg/kg – milligrams per kilogram. 1 Based on BBL 2004, ERM 2017, most conservative Low Ecological Benchmark Value. 2 Based on McDaniel Lambert 2013, Intrinsik, 2015, recreator exposure scenario. 3 Based on McDaniel Lambert 2013, Intrinsik, 2015, intrusive construction worker exposure scenario. 4 Based on Intrinsik, 2017, revised background inflection point. 5 Based on McDaniel Lambert 2013, uHHRA/California Human Health Screening Levels (CHHSLs) or equivalent. 6 Human health risk-based screening levels based on uHHRA exposure parameters and Site-specific TPH fractions; recreator user Age-Dependent Adjustment Factors applied only to mutagens. 7 PAHs RBSL for recreator based on Northern California background Benzo(a)pyrene Equivalent Value (TEQ). 3374.0001S000 Site Mitigation Plan | ROUX | 7 3. Soil Excavation, Handling, and Off-Hauling Mitigative Measures Based on the elevated levels of petroleum hydrocarbons in the soil or fill material (referred to collectively as “soil” in this document) adjacent to the Site, excavation, soil handling and loading activities associated with the soil may require a contractor with the appropriate licenses and personnel training to handle hazardous waste (Contractor), if contamination is present. Soil samples must be submitted to a laboratory certified through the California Environmental Accreditation Program (ELAP). The Contractor will be responsible for profiling the waste for landfill acceptance and disposal of impacted soil excavated from the Site. Excavation, handling and loading activities for impacted soil will be conducted under the oversight of Roux. Following the completion of off-hauling activities associated with the soil at the Site, Roux will prepare an excavation completion report to document that the RMP was implemented during any soil moving activities at the Site. Excavation, handling and off-hauling of soil will be implemented using mitigative measures to protect human health for the following controls and site activities: : • Site-Specific Health and Safety Plan; • Soil Excavation and Management; • Soil Stockpiling and Storage; • Soil and Groundwater Transport and Disposal; • Dust Control; • Groundwater Management; and • Equipment Decontamination. A detailed description of each control or activity is provided in the sections below. 3.1 Site-Specific Health and Safety Plan A Site-specific Health and Safety Plan (HASP) will be prepared for field activities related to the excavation, handling and off-hauling of soil at the Site in accordance with 29 CFR 1910.120 Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER), and California Code of Regulations, Title 8, Section 5192. The HASP will be provided under a separate cover. The HASP will include guidelines and general requirements for all workers performing field activities involving contact with soil. The HASP shall serve as a general template for contractors performing work related to subsurface construction activities at the Site. The HASP attempts to identify all known potential hazards at the Site; however, Site conditions are dynamic and new hazards could appear. Therefore, the HASP shall serve as a general template for contractors performed work related to the construction of the proposed improvements at the Site. Each contractor will be required to prepare and implement an independent HASP that shall comply with 29 CFR 1910.120 OSHA HAZWOPER, 29 CFR 1926.62 OSHA Lead in Construction (as applicable) and the contractor’s own health and safety standard operating procedures (SOPs) to prevent exposure to potential hazardous constituents in soil. 3374.0001S000 Site Mitigation Plan | ROUX | 8 3.2 Soil Excavation and Management Soil encountered during construction excavation activities will be evaluated for the presence of discoloration/ staining. If discoloration/staining is observed, the potentially impacted soils will be segregated from the rest of the soil. In addition to visual observations, a photoionization detector (PID) will be used to further screen soils for organic vapors during excavation work. Note that these requirements do not apply to asphalt from the roadway or base rock below the road, which are considered recyclable materials. The PID will provide real-time data on the presence of potentially hazardous compounds. Soil screening procedures with a PID are as follows: • A soil sample will be placed into an unused re-sealable Ziplock plastic bag (or similar air-tight container) until the bag is approximately one-half full. • The bag will be sealed and soil crumbled by hand, if possible, while inside the bag and left to sit for least 2 minutes out of direct sunlight. • The container will be opened enough to allow the PID probe into the headspace of the plastic bag. • The sample will be considered as possibly impacted if the PID reading is 50 parts per million by volume (ppmv) or higher for 10 seconds or more. The site-specific RBSLs presented in Table 1 will be utilized during field activities when determining whether in-situ petroleum hydrocarbon-containing soil encountered in the field will be excavated and transported off- site for disposal, reused as backfill, or may remain in place. Table 1 will be followed for determining the appropriate course of action for soil indicated with suspect petroleum hydrocarbon impacts identified during the course of the project. The field geologist will utilize visual observations, odor, and soil screening using a photoionization detector (PID) in the identification of suspect soils. The decision flowchart included as Figure 3 presents the decision criteria that will be utilized during on-site remedial excavations to determine the appropriate action. The initial observations made in the field will proceed as follows: • Visible free oil – material requires off-site disposal; • Plastic/pliable material – material requires off-site disposal; • Asphaltic material – utilize Field Procedure to confirm, may be utilized on-site for fill material. Inert asphaltic material to be re-used only if it meets project geotechnical and/or other fill specifications. Submit representative samples of impacted soil for chemical analyses and compare to site specific RBSLs.. If in-situ soil meets the RBSL requirements, it may remain in-place. If soil requires excavation for another purpose (e.g., re-grading of area for restoration purposes) the soil will be stockpiled and transported off-site for disposal; o Discolored/odorous soil in-situ – discrete soil samples will be collected at a sufficient density across a potentially impacted area to identify the extent of impacted soil.; and o Discolored/odorous soil stockpile – one systematic composite soil sample will be collected for up to a maximum of 3,000 CY of stockpiled soil (see section 5.3 for details). The planned sampling frequency is in accordance with Santa Maria Landfill requirements for characterization of NHIS. Stockpiled soil will be divided into approximately equally-sized and spaced grid cells. One grab soil sample will be collected from each cell and homogenized into one composite soil sample. 3374.0001S000 Site Mitigation Plan | ROUX | 9 3.3 Soil Stockpiling and Storage Excavated soil shall be placed a a designed soil stockpile area and managed in accordance with the dust control requirements (section 3.5 and any permit requirements) and the Site Construction Storm Water Pollution Prevention Plan (SWPPP) which is not part of this RMP. Excavated soil that is known or suspected to be impacted shall be collected in a covered roll-off container or placed on hard scape or in a designated stockpiling area. If impacted soil is not placed on hardscape or on plastic sheeting, then a sufficient amount of underlying soil will need to be removing to ensure that no residual impacted soil is left behind. At minimum, plastic sheeting shall be 10-mil polyethylene sheeting or equivalent, such as Visqueen. Stockpiled soils shall be stored in accordance with the following: • Any saturated impacted soils (assumed to be excavated from approximately below 3 feet bgs) shall be stored on plastic sheeting or on hard scape and any runoff water contained. • When impacted stockpiled soils are not being handled, they shall be adequately covered and secured to control dust. 3.4 Soil and Groundwater Transport and Disposal The excavation contractor will be responsible for tracking soil removed from the site. Transportation will be coordinated in such a manner that at any given time, onsite trucks will be in communication with the Project operator. In addition, all vehicles will be required to maintain slow speeds (i.e., less than 5 mph) for safety and for dust control purposes on the Site. Prior to exiting the Project area, the vehicles will be cleaned to remove any loose soil from areas not covered or protected. The cleaning area will be set up as close to the loading area as possible so as to minimize the spreading of any loose soils. Prior to offsite transport, each truck will be inspected to ensure that the payloads are adequately tarped, the trucks are cleaned of excess loose soil, properly placarded (if applicable), and that the truck’s manifest (if applicable) or bill-of-lading has been completed and signed by the generator (or its agent) and the transporter. Soil will be transported to appropriate receiving facilities as determined by the waste classification. For any non-hazardous or hazardous soil or groundwater that needs to be removed from the Site appropriate licensed waste transporters will be required for off-site disposal. 3.5 Dust Control Dust control measures shall be implemented during dust-generating activities at the Site to protect the Contractor’s field personnel and to prevent and minimize dust emissions from the Site. Specifically, the implementation of dust control will prevent exposure to any hazardous constituents through inhalation of contamination particulates, dermal absorption and accidental ingestion from either direct or indirect cross- contamination activities. Dust control must also be maintained in accordance with any project specific permits. Dust control will be implemented at the Site by the Contractor and its subcontractors (as applicable when all dust-generating activities [i.e., excavation, drilling, soil loading and hauling] are being conducted at the Site). Visible dust generated during soil management activities shall trigger dust control techniques to be employed at the Site. Dust control techniques such as applying water to exposed areas shall be implemented where visible dust is generated. Stockpiled soil shall be kept covered during downtime periods or stored in soil bins with covers in order to prevent dust emissions. The inhalation potential for Site workers is anticipated to be low if dust control is implemented at the Site. 3374.0001S000 Site Mitigation Plan | ROUX | 10 3.6 Decontamination of Equipment Equipment used as part of excavation, handling and loading of impacted material at the Site shall be decontaminated before leaving the work zone and moving to a “clean” area (i.e., an area that does not contain impacted soil) and/or before it is removed from the Site. Equipment decontamination activities shall be implemented to remove, collect, and contain visible soil potentially containing hazardous constituents. Equipment shall be decontaminated using brooms, brushes, shovels and plastic scrapers or equivalent equipment. In addition, loose dirt will be scraped or swept off tires, treads, mud flaps, fenders and other accessible areas before leaving the Site. In the event that soil cannot be easily removed from equipment, a pressure washer may be used in a manner to prevent overspray from the decontamination area. All wastewater generated during decontamination shall be collected and held in drums or tanks for characterization and disposal. 3374.0001S000 Site Mitigation Plan | ROUX | 11 4. Soil Characterization and Disposal The project environmental consultant will conduct oversight activities during excavation, handling, and off- hauling of soil at the Site. The soil samples collected will characterize soil for disposal at an appropriate landfill. Analytical data from the soil samples will be used by the Contractor for waste profiling for disposal at an appropriate disposal facility. Soil disposal activities will be documented in the RMP Implementation Report. Table 1 (Section 2.4) presents the soil screening criteria for soil at the Site. Table 2 presents the Santa Maria Landfill acceptance criteria for soil being disposed of off-site. Soil can be replaced in the excavation if it meets reuse criteria or will be disposed of offsite if it is deemed as impacted. Soil characterization samples will be collected and analyzed as described in the following sections. 4.1 Four-Point Composite Sampling To determine if soils are suitable for reuse, a four-point composite sample shall be collected at the frequency of up to one four-point composite sample per 1,000 -3,000 cubic yards of soil (see section 5.3 for details). The four samples should be submitted to a laboratory for compositing. 4.2 Sample Analysis Samples shall be labelled, placed into a cooler with ice, and transported by courier to the appropriate California state certified laboratory under chain-of-custody documentation. Composite samples from soil generated at the Site shall be, at minimum, analysed for the following: • Volatile Organic Compounds (VOCs) and Total Petroleum Hydrocarbons (TPH) as gasoline (TPH- g) by EPA Method 8260B Note that samples for VOC analysis cannot be composited and a single sample out of the four must be designated for VOC analysis. • TPH as diesel (TPH-d) and TPH as motor oil (TPH-mo) by EPA Method 8015B/M • California Assessment Manual 17 (CAM 17) metals using Environmental Protection Agency (EPA) Method 6020B/7470A; • Polycyclic Aromatic Hydrocarbons (PAHs) by EPA Method 8270 4.3 Offsite Disposal If soils exceed the appropriate RBLS for soil, the following procedures shall be followed to appropriately dispose of soils offsite. The City of Santa Maria Utilities Department operates a Non-hazardous Hydrocarbon Impacted Soils (NHIS) Program at the Santa Maria Regional Landfill. The program accepts soil that is impacted, but not hazardous, and must be tested for a suite of analytical constituents to determine if it meets all of the regulated requirements. The analytical requirements for Clean Soil are: • California Assessment Manual 17 (CAM 17) metals using Environmental Protection Agency (EPA) Method 6020B/7470A; • Total Petroleum Hydrocarbons (TPH) using EPA Method 8015M; and • Flashpoint/ Ignitability using EPA Method 1010. The analytical requirements for the NHIS soil are the following analyses at a rate of 1 sample for the first 1,000 cubic yards and then one sample for each additional 3,000 cubic yards: • CAM 17 metals using EPA Method 6020B/7470A; o Soluble Threshold Limit Concentration (STLC) for metals if the Total Threshold Limit Concentration (TTLC) is not exceeded but total concentration exceeds the STLC value by 10 times; 3374.0001S000 Site Mitigation Plan | ROUX | 12 • TPH as gasoline range organics using EPA 8015M or 8260; • TPH as diesel range organics and motor/crude oil using EPA 8015M or 8270; • De-ionized Waste Extraction Test (DI WET) for Total Petroleum Hydrocarbons; • Volatile organic compounds (VOCs) using EPA Method 8260B; • Semi-volatile organic compounds (SVOCs) using EPA Method 8270C; • Organochlorine pesticides using EPA Method 8081A; • Polychlorinated biphenyls (PCBs) using EPA Method 8082; o STLC for PCBs is required if the TTLC concentration is between 1 milligram per kilogram (mg/kg) and 5 mg/kg; • Reactive Sulfides and Cyanide using SW 846, Section 7.3; • pH using EPA Method 9040/9045; and • Flashpoint/ Ignitability using EPA Method 1010. The NHIS acceptance criteria is provided in Table 2. Leachability • Soil samples with analytes on the STLC list with total metals concentrations equal to or greater than 10 times their STLC criterion shall be extracted with the WET leachability tests and the extracts analysed for those metals. • Soil samples with analytes on the TCLP list with total metals concentrations equal to or greater than 20 times their TCLP criterion shall be extracted with the TCLP test and the extract analysed for those metals. If concentrations exceed their specific STLC or TCLP criteria, the soil represented by those results will be considered hazardous waste. All generated wastes must be adequately characterized to ensure proper waste management and disposal to the appropriate disposal facility. If designated hazardous, such soils must be removed from the site within 90 days of the date excavation of the material was completed. 3374.0001S000 Site Mitigation Plan | ROUX | 13 5. Groundwater Management Based on shallow occurrence of groundwater at the Site, between 3 and 8 feet bgs, it is likely that groundwater will be encountered during excavation activities at the Site. If groundwater is encountered, localized dewatering may be necessary to complete construction activities. Groundwater generated during dewatering activities will be transferred to a drum or holding tank and sampled for potential contaminants. Non-impacted water may be re-used for dust control onsite based on project criteria such as the water volume collected during construction. Re-using non-impacted water on-site should also be approved by the RWQCB or SLOEHS. Impacted water will be transported and disposed of offsite or discharged to the sanitary or storm sewer. For onsite discharge, the Contractor may work with the City of San Luis Obispo to meet analytically requirements for discharge to appropriate City sanitary lines. If applicable, the Contractor, may obtain a NPDES permit from the RWQCB for ongoing discharge of groundwater associated with construction dewatering. 3374.0001S000 Site Mitigation Plan | ROUX | 14 6. Environmental Contingency Plan The Project Environmental Engineer, Scientist or Geologist shall inspect excavated and exposed soil at the Site as construction activities progress. If an inspection of the excavated and exposed soil indicates potential for unanticipated soil or groundwater impacts (i.e., soil staining or odors) in the excavations, the Contractor will suspend work immediately and follow contingency measures identified in Section 6.1. 6.1 Contingency Measures for Unanticipated Conditions The following tasks should be implemented during soil excavation if unknown historical subsurface features and/or unanticipated hazardous materials are encountered. Such materials may include unaccounted for underground storage tanks (USTs) and associated product lines, pipelines, sumps, and/or vaults, former monitoring wells, and soil with significant petroleum hydrocarbon odors and/or other stains or odors: • Stop work in the area where the suspect material is encountered, cover with plastic sheets and create an exclusion zone around the area; • Notify the General Contractor’s site safety officer and site superintendent. The General Contractor will request that Roux conduct a site inspection and will consult with Roux regarding appropriate follow-up actions in the suspect area. Roux will notify the property owner(s) of site conditions that indicate a material threat to human health or the environment; and, • Review the existing health and safety plan for revisions, if necessary, and have appropriately trained personnel on-site to identify and work with the affected materials, once directed by the General Contractor. If necessary, notifications will be performed and permits will be obtained prior to subsurface feature removals. If a UST, product line, sump or vault is found, the RWQCB will be notified, and a licensed tank removal contractor will be retained to properly remove and dispose of the UST. Proper permits and notifications should be in place prior to removal of the UST. If soil staining is observed, the affected soil will be placed in a separate stockpile on plastic sheets and covered with plastic sheets. Roux will complete soil sampling and analysis tasks for UST closure, in accordance with RWQCB guidelines. Roux will collect and analyze soil samples to determine the appropriate disposal procedures for the material, the extent of the impacted soil, and confirm that impacted material has been appropriately removed. Soil samples collected from beneath fuel pipelines, if any, will be collected beneath joints and elbows and at a frequency of one sample per 20 linear feet. Any unanticipated conditions observed will be documented in Roux’s RMP Implementation Report. 3374.0001S000 Site Mitigation Plan | ROUX | 15 7. Site Security During excavation activities, the contractor will be responsible for establishing an exclusion zone surrounding the excavation area. The purpose of this exclusion zone is to isolate the work zone and prevent unauthorized personnel from entering the work zone and potentially being exposed to hazardous constituents which may be present in excavated soil. In addition, this exclusion zone will prevent unauthorized personnel from entering the work zone while heavy equipment is in operation to ensure that field personnel are not unnecessarily exposed to the hazards of the equipment. In addition, the Contractor will be responsible for securing the work zone (i.e., open excavation areas, soil stockpiles, equipment staging areas, etc.) at the end of each work day throughout construction activities. RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX FIGURES 1. Site Location Map 2. 65% Interim Design Plan 3. Decision Flow Chart for Petroleum Hydrocarbon Contaminated Prepared for: Title: Compiled by: Prepared by: Project Mgr: File: Date: Project: Scale: FIGURE 1 SITE LOCATION MAP 276 TANK FARM ROADSAN LUIS OBISPO, CALIFORNIA COVELOP, INC. MM MM DD 22MAR2023 AS SHOWN 3957.0001S000 SLO TANK FARM FIGURES.DWG \\SRVOLCAFP1\OAKLAND SHARED\DIXON PROJECTS\SLO TANK FARM\05-ROUX DOCS\06-RMP\FIGURES\CAD\SLO TANK FARM FIGURES.DWGSITE SANTA FE ROAD TANK FARM ROADINTERIM DESIGN PLANSCALE: 1" = 150'ENCROACHMENT EXHIBITS FIGURE 2TANK FARM RD & SANTA FE RDROUNDABOUTCOVELOP0200'100'PROPOSED R/WEXISTING R/WEXISTING R/WPROPERTY LINE (TYP)NOTE:1. PROPOSED R/W DOES NOT INCLUDE AREA THAT MAY BE NEEDED FORWATERBOARD TREATMENT AND RETENTION REQUIREMENTSProjectClientPlot Date:15 June 2023 - 10:07 AMN:\US\San Luis Obispo\Projects\561\12579768\Digital_Design\ACAD 2020\Figures\12579768-GHD-0000-EXH-CI-0100-InterimEncroachment-County-City-Area.dwgPlotted By: Olivia Ramirez0Bar is one inch onoriginal size sheetApprovedDateAuthorDesignerProject DirectorProject No.DateFilename:Sheet No.This document and the ideas and designs incorporated herein, as an instrument of professional service, is the property ofGHD. This document may only be used by GHD’s client (and any other person who GHD has agreed can use thisdocument) for the purpose for which it was prepared and must not be used by any other person or for any other purpose.www.ghd.comTitle1"IssueNo.CheckedDesign CheckDrafting CheckProject ManagerConditions of UseScaleANSI BSizePRELIMINARYGHD Inc.1101 Monterey Street Suite 120San Luis Obispo California 93401 USAT 1 805 242 0461NORTHBIORETENTIONFACILITYPARCEL 5(PARCEL I)CONSTRUCTIONEASEMENTAPN 076-381-021AREA (12672 SF)PARCEL 4 (PARCEL J)CONSTRUCTIONEASEMENT AREAAPN 076-381-021(7108 SF)PARCEL 4 (PARCEL J)RIGHT OF WAYDEDICATION AREAAPN 076-381-021(5648 SF)PARCEL 5 (PARCEL I) RIGHT OF WAYDEDICATION AREAAPN 076-381-021(42431 SF)600 TANK FARMCONSTRUCTIONEASEMENT AREAAPN 053-421-006(17026 SF)600 TANK FARM RIGHT OFWAY DEDICATION AREAAPN 053-421-006(36602 SF)150'300'NPARCEL 6 (PARCEL H)CONSTRUCTION EASEMENT AREAAPN 076-382-005 (7137 SF)PARCEL 6 (PARCEL H) RIGHTOF WAY DEDICATION AREAAPN 076-382-005(11237 SF)PARCEL 7 (PARCEL G) RIGHTOF WAY DEDICATION AREAAPN 076-382-005(23342 SF)PARCEL 7 (PARCEL G)CONSTRUCTION EASEMENT AREAAPN 076-382-005 (13090 SF)FUTURE TEMPORARY STORMWATERRETENTION EASEMENT (20165 SF)LEGENDEXISTING R/WPROPOSED R/WCONSTRUCTION EASEMENTPROPERTY LINESCITY AREACOUNTY AREACOUNTY AREA - FUTURE STORMWATER RETENTION EASEMENTDRAINAGESWALE RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX TABLES 1. Site Location Map (imbedded in document) 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values BTEX - EPA Method 8260B or EPA Method 8021 Benzene 71-43-2 0.1 mg/Kg 100 µg/L Toluene 108-88-3 15 mg/Kg 15 µg/L Ethylbenzene 100-41-4 70 mg/Kg 70 µg/L Xylenes 1330-20-7 170 mg/Kg 170 µg/L TOTAL TPH - EPA Method 8015 or EPA Method 8260 (GRO only), TPH D.I. WET (mg/L) - EPA Method 8015/ DI WET GRO (C4-C12)68334-30-5 1000 mg/Kg 1 mg/L DRO (C13-C23)8006-61-9 15000 mg/Kg 5 mg/L ORO (C24-C36)68476-77-7 200000 mg/Kg 10 mg/L PCB's - EPA Method 8082 PCB 1016 12674-11-2 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1221 11104-28-2 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1232 11141-16-5 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1242 53469-21-9 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1248 12672-29-6 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1254 11097-69-1 5mg/Kg, >1 mg/kg *0.1 mg/L PCB 1260 11096-82-5 5mg/Kg, >1 mg/kg *0.1 mg/L Metals - EPA Method 6020,7471(Hg)/WET STLC Antimony 7440-36-0 500 mg/Kg or >150 mg/kg *15 mg/L Arsenic 7440-38-2 500 mg/Kg or >50 mg/kg *5 mg/L Barium 7440-39-3 10000 mg/Kg or >1000 mg/kg *100 mg/L Beryllium 7440-41-7 75 mg/Kg or >7.5 mg/kg *0.75 mg/L Cadmium 7440-43-9 100 mg/Kg or >10 mg/kg *1 mg/L Chromium III 7440-47-3 2500 mg/Kg or >50 mg/kg *5 mg/L Chromium VI 18540-29-9 500 mg/Kg or >50 mg/kg *5 mg/L Cobalt 7440-48-4 8000 mg/Kg or >800 mg/kg *80 mg/L Copper 7440-50-8 2500 mg/Kg or >250 mg/kg *25 mg/L Lead 7439-92-1 1000 mg/Kg or >50 mg/kg *5 mg/L Mercury 7439-97-6 20 mg/Kg or >2 mg/kg *0.2 mg/L Molybdenum 7439-98-7 3500 mg/Kg or >3500 mg/kg *350 mg/L Nickel 7440-02-0 2000 mg/Kg or >200 mg/kg *20 mg/L Selenium 7782-49-2 100 mg/Kg or >10 mg/kg *1 mg/L Silver 7440-22-4 500 mg/Kg or >50 mg/kg *5 mg/L Thallium 7440-28-0 700 mg/Kg or >70 mg/kg *7 mg/L Vanadium 7440-62-2 2400 mg/Kg or> 240 mg/kg *24 mg/L Zinc 7440-66-6 5000 mg/Kg or >2500 mg/kg *250 mg/L Volatile Organic Compounds - EPA Method 8260B or EPA Method 8021 1-Chlorohexane 544-10-5 N/A Title 22 or 100 x MCL*** 1,1-Dichloroethane 75-34-3 N/A 500 µg/L 1,1-Dichloroethene 75-35-4 N/A 70 µg/L 1,1-Dichloropropene 563-58-6 N/A Title 22 or 100 x MCL** 1 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values 1,1,1-Trichloroethane (TCA)71-55-6 N/A 20,000 µg/L 1,1,1,2-Tetrachloroethane 630-20-6 N/A Title 22 or 100 x MCL** 1,1,2-Trichloro-1,2,2-trifluoroethane (freon 113)76-13-1 N/A 120,000 µg/L 1,1,2-Trichloroethane 79-00-5 N/A 500 µg/L 1,1,2,2-Tetrachloroethane 79-34-5 N/A 100 µg/L 1,2-Dibromo-3-chloropropane 96-12-8 N/A 20 µg/L 1,2-Dichlorobenzene 95-50-1 N/A 60,000 µg/L 1,2-Dichloroethane (EDC)107-06-2 N/A 50 µg/L 1,2-Dichloropropane 78-87-5 N/A 500 µg/L 1,2,3-Trichlorobenzene 87-61-6 N/A Title 22 or 100 x MCL*** 1,2,3-Trichloropropane 96-18-4 N/A Title 22 or 100 x MCL** 1,2,4-Trichlorobenzene 120-82-1 N/A 500 µg/L 1,2,4-Trimethylbenzene 95-63-6 N/A Title 22 or 100 x MCL** 1,3-Dichlorobenzene 541-73-1 N/A Title 22 or 100 x MCL** 1,3-Dichloropropane 142-28-9 N/A Title 22 or 100 x MCL** 1,3,5-Trimethylbenzene 108-67-8 N/A Title 22 or 100 x MCL** 1,4-Dichlorobenzene 106-46-7 N/A 750 µg/L 2-Butanone (MEK)78-93-3 N/A Title 22 or 100 x MCL** 2-Chloroethylvinyl ether 110-75-8 N/A Title 22 or 100 x MCL*** 2-Chlorotoluene 95-49-8 N/A Title 22 or 100 x MCL** 2-Hexanone 591-78-6 N/A Title 22 or 100 x MCL** 2,2-Dichloropropane 594-20-7 N/A Title 22 or 100 x MCL** 4-Chlorotoluene 106-43-4 N/A Title 22 or 100 x MCL** 4-Isopropyltoluene 99-87-6 N/A Title 22 or 100 x MCL*** Acetone 67-64-1 N/A Title 22 or 100 x MCL** Benzene 71-43-2 100 µg/L Bromobenzene 108-86-1 N/A Title 22 or 100 x MCL** Bromochloromethane 74-97-5 N/A Title 22 or 100 x MCL** Bromodichloromethane 75-27-4 N/A 8,000 µg/L Bromoform 75-25-2 N/A 8,000 µg/L Bromomethane 74-83-9 N/A Title 22 or 100 x MCL** Carbon Disulfide 75-15-0 N/A Title 22 or 100 x MCL** Carbon tetrachloride 56-23-5 N/A 50 µg/L Chlorobenzene 108-90-7 N/A 10,000 µg/L Chloroethane 75-00-3 N/A Title 22 or 100 x MCL** Chloroform 67-66-3 N/A 600 µg/L Chloromethane 74-87-3 N/A Title 22 or 100 x MCL** cis-1,2-Dichloroethene 156-59-2 N/A 600 µg/L cis-1,3-Dichloropropene 10061-01-5 N/A 50 µg/L Dibromochloromethane 124-48-1 N/A 8,000 µg/L Dibromomethane 74-95-3 N/A Title 22 or 100 x MCL*** 2 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values Dichlorodifluoromethane (Freon- 12)75-71-8 N/A Title 22 or 100 x MCL** Dichlorofluoromethane 75-43-4 N/A Title 22 or 100 x MCL*** Dichlorotrifluoroethane 34077-87-7 N/A Title 22 or 100 x MCL*** Diisopropyl ether (DIPE)108-20-3 N/A Title 22 or 100 x MCL** Ethanol 64-17-5 N/A Title 22 or 100 x MCL** Ethyl t-Butly Ether (ETBE)637-92-3 N/A Title 22 or 100 x MCL*** Ethylbenzene 100-41-4 70 mg/L Ethylene dibromide (EDB)106-93-4 N/A 5 µg/L Hexachlorobutadiene 87-68-3 N/A Title 22 or 100 x MCL** Isopropylbenzene 98-82-8 N/A Title 22 or 100 x MCL** m,p-Xylene 179601-23-1 N/A total xylenes < 170 mg/L Methyl isobutyl ketone 108-10-1 N/A Title 22 or 100 x MCL** Methyl-tert-butyl ether (MTBE)2 1634-04-4 N/A 13 µg/L Methylene chloride 75-09-2 N/A 500 µg/L n-Butylbenzene 104-51-8 N/A Title 22 or 100 x MCL** n-Propylbenzene 103-65-1 N/A Title 22 or 100 x MCL** Naphthalene 91-20-3 N/A Title 22 or 100 x MCL** o-Xylene 95-47-6 N/A total xylenes < 170 mg/L Oxygenates - EPA Method 8260 VOC's N/A sec-Butylbenzene 135-98-8 N/A Title 22 or 100 x MCL** Styrene 100-42-5 N/A 10,000 µg/L t-Amyl Methyl Ether (TAME)994-05-8 N/A Title 22 or 100 x MCL*** t-Butyl Alcohol (TBA)75-65-0 N/A Title 22 or 100 x MCL** tert-Butylbenzene 98-06-6 N/A Title 22 or 100 x MCL** Tetrachloroethene (PCE)127-18-4 N/A 500 µg/L Toluene 108-88-3 15 mg/L total Xylenes 1330-20-7 170 mg/L trans-1,2-Dichloroethene 156-60-5 N/A 1,000 µg/L trans-1,3-Dichloropropene 10061-02-6 N/A 50 µg/L Trichloroethene (TCE)79-01-6 N/A 500 µg/L Trichlorofluoromethane (Freon-11)75-69-4 N/A 15,000 µg/L Vinyl acetate 108-05-4 N/A Title 22 or 100 x MCL** Vinyl chloride 75-01-4 N/A 20 µg/L Semi-Volatile Organic Compounds - EPA Method 8270 1-Methylnaphthalene 90-12-0 N/A Title 22 or 100 x MCL*** 1,2-Dichlorobenzene 95-50-1 N/A 60,000 µg/L 1,2,4-Trichlorobenzene 120-82-1 N/A 500 ug/L 1,3-Dichlorobenzene 541-73-1 N/A Title 22 or 100 x MCL** 1,4-Dichlorobenzene 106-46-7 N/A 750 µg/L 2-Chloronaphthalene 91-58-7 N/A Title 22 or 100 x MCL** 3 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values 2-Chlorophenol 95-57-8 N/A Title 22 or 100 x MCL** 2-Methylnaphthalene 91-57-6 N/A Title 22 or 100 x MCL** 2-Methylphenol 95-48-7 N/A Title 22 or 100 x MCL** 2-Nitroaniline 88-74-4 N/A Title 22 or 100 x MCL*** 2-Nitrophenol 88-75-5 N/A Title 22 or 100 x MCL** 2,4-Dichlorophenol 120-83-2 N/A Title 22 or 100 x MCL** 2,4-Dimethylphenol 105-67-9 N/A Title 22 or 100 x MCL** 2,4-Dinitrophenol 51-28-5 N/A Title 22 or 100 x MCL** 2,4-Dinitrotoluene 121-14-2 N/A 13 µg/L 2,4,5-Trichlorophenol 95-95-4 N/A 40,000 µg/L 2,4,6-Trichlorophenol 88-06-2 N/A 200 µg/L 2,6-Dinitrotoluene 606-20-2 N/A Title 22 or 100 x MCL** 3-Nitroaniline 99-09-2 N/A Title 22 or 100 x MCL*** 3,3'-Dichlorobenzidine 91-94-1 N/A Title 22 or 100 x MCL** 4-Bromophenyl-phenylether 101-55-3 N/A Title 22 or 100 x MCL** 4-Chloro-3-methylphenol 59-50-7 N/A Title 22 or 100 x MCL** 4-Chloroaniline 106-47-8 N/A Title 22 or 100 x MCL** 4-Chlorophenyl-phenylether 7005-72-3 N/A Title 22 or 100 x MCL*** 4-Methylphenol 106-44-5 N/A Title 22 or 100 x MCL** 4-Nitroaniline 100-01-6 N/A Title 22 or 100 x MCL*** 4-Nitrophenol 100-02-7 N/A Title 22 or 100 x MCL** 4,6-Dinitro-2-methylphenol 534-52-1 N/A Title 22 or 100 x MCL** Acenaphthene 83-32-9 N/A Title 22 or 100 x MCL** Acenaphthylene 208-96-8 N/A Title 22 or 100 x MCL** Aniline 62-53-3 N/A Title 22 or 100 x MCL** Anthracene 120-12-7 N/A Title 22 or 100 x MCL** Benzo(a)anthracene 56-55-3 N/A 10 µg/L Benzidine 92-87-5 N/A Title 22 or 100 x MCL** Benzo(a)pyrene 50-32-8 N/A 20 µg/L Benzo(b)fluoranthene 205-99-2 N/A Title 22 or 100 x MCL** Benzo(g,h,i)perylene 191-24-2 N/A Title 22 or 100 x MCL** Benzo(k)fluoranthene 207-08-9 N/A Title 22 or 100 x MCL** Benzoic acid 65-85-0 N/A Title 22 or 100 x MCL** Benzyl alcohol 100-51-6 N/A Title 22 or 100 x MCL*** Bis(2-chloroethoxy)methane 111-91-1 N/A Title 22 or 100 x MCL** Bis(2-chloroethyl)ether 111-44-4 N/A Title 22 or 100 x MCL** Bis(2-chloroisopropyl) ether 108-60-1 N/A Title 22 or 100 x MCL** Bis(2-ethylhexyl)phthalate 117-81-7 N/A 400 µg/L Butylbenzylphthalate 85-68-7 N/A Title 22 or 100 x MCL** Chrysene 218-01-9 N/A Title 22 or 100 x MCL** Di-n-butylphthalate 84-74-2 N/A Title 22 or 100 x MCL** 4 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values Di-n-octylphthalate 117-84-0 N/A Title 22 or 100 x MCL** Dibenzo(a,h)anthracene 53-70-3 N/A Title 22 or 100 x MCL** Dibenzofuran 132-64-9 N/A Title 22 or 100 x MCL*** Diethylphthalate 84-66-2 N/A Title 22 or 100 x MCL** Dimethylphthalate 131-11-3 N/A Title 22 or 100 x MCL** Fluoranthene 206-44-0 N/A Title 22 or 100 x MCL** Fluorene 86-73-7 N/A Title 22 or 100 x MCL** Hexachlorobenzene 118-74-1 N/A 13 µg/L Hexachlorobutadiene 87-68-3 N/A 50 µg/L Hexachlorocyclopentadiene 77-47-4 N/A 300 µg/L Hexachloroethane 67-72-1 N/A Title 22 or 100 x MCL** Indeno(1,2,3-cd)pyrene 193-39-5 N/A Title 22 or 100 x MCL** Isophorone 78-59-1 N/A Title 22 or 100 x MCL** n-Nitroso-di-n-propylamine 621-64-7 N/A Title 22 or 100 x MCL** n-Nitrosodimethylamine 62-75-9 N/A Title 22 or 100 x MCL** n-Nitrosodiphenylamine 86-30-6 N/A Title 22 or 100 x MCL** Naphthalene 91-20-3 N/A Title 22 or 100 x MCL** Nitrobenzene 98-95-3 N/A 200 µg/L Pentachlorophenol 87-86-5 N/A 17 µg/L Phenanthrene 85-01-8 N/A Title 22 or 100 x MCL** Phenol 108-95-2 N/A Title 22 or 100 x MCL** Pyrene 129-00-0 N/A Title 22 or 100 x MCL** Organochlorine Pesticides - EPA Method 8081A Aldrin 309-00-2 1.4 mg/Kg N/A Technical Chlordane 57-74-9 2.5 mg/Kg N/A 4,4'-DDD 72-54-8 1 mg/Kg N/A 4,4'-DDE 72-55-9 1 mg/Kg N/A 4,4'-DDT 50-29-3 1 mg/Kg N/A Dieldrin 60-57-1 8 mg/Kg N/A Endrin 72-20-8 0.2 mg/Kg N/A Heptachlor 76-44-8 4.7 mg/Kg N/A (g-BHC) Lindane 58-89-9 4 mg/Kg N/A Methoxychlor 72-43-5 100 mg/Kg N/A Toxaphene 8001-35-2 5 mg/Kg N/A Other Parameters 2 pH (EPA Method 9045B)2 < pH < 12.5 N/A Flashpoint (EPA Method 1010 (deg°F)) >140°F N/A Reactive Cyanide (SW 846 Ch.7 (mg/Kg))<250 mg/Kg N/A 5 of 6 Table 2. Santa Maria Sanitary Landfill NHIS Acceptance Criteria Laboratory Criteria Tested CAS Number SMSL Acceptance Criteria, TTLC values SMSL Acceptance Criteria, STLC (DI WET for TPH), or MCL values Reactive Sulfide (SW 846 Ch.7 (mg/Kg))<500 mg/Kg N/A Fish Bioassay (96-hour Aquatic Toxicity)PASS N/A Specific Notes: 1. The SMRL NHIS Program does not allow any detectable MtBE, even though MtBE has a 100x the MCL limit of 1,300 µg/L 2. Data Results cannot be averaged * = Soluble Threshold Limit Concentrtion by WET method is required **No established MCL General Notes: If PQL and MDL >Acceptance Criteria, then PQL=Acceptance Criteria Should the constituent be non-detect (ND), the PQL or the MDL value will be used for averaging purposes. If total concentration > 100x the MCL, then run the DI WET and see if value < 100x the MCL. Must be accompanied by fish bioassay test. DI = deionized water N/A = Not Applicable MCL = maximum cotaminant limit STLC = soluble threshold limit concentration mg/Kg = milligrams per kilogram TTLC = total threshold limit concentration µg/L = micrograms per liter WET = waste extraction Test mg/L = milligrams per liter WET = waste extraction Test NHIS - Non-hazardous impacted soil 6 of 6 RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX APPENDICES A. San Luis Obispo Assessor Parcel Map B. Figures from Historical San Luis Obispo Tank Farm Documents RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX APPENDIX A San Luis Obispo Assessor Parcel Map CHVR-53046\2431951.2 Exhibit A-1 EXHIBIT A-1 EXISTING COUNTY PARCEL MAP DocuSign Envelope ID: 94CDDD5B-A58D-400A-961B-721F26A7C58A RISK MITIGATION Plan Tank Farm & Santa Fe Roads Roundabout Construction San Luis Obispo, California 3957.0001S000/CVRS ROUX APPENDIX B Figures from Historical San Luis Obispo Tank Farm Documents RESERVOIR 4 NORTHWEST AREA RESERVOIR 5 RESERVOIR 6 RESERVOIR 7 RESERVOIR 3 RESERVOIR 2 FORMER RECYCLING AREA T A N K F A R M R O A D NORTH MARSH OCCUPIED OFFICE STUCTURES FORMER FIRE SCHOOL LOCATION S:\GIS\1306_SLOTF-EMC_Work_Activities\1306.003_2013_Work_Activities\ArcMapDocuments\024_1306.003_Chevron_Pipelines.mxd\4/11/2014FIGURE 5 CHEVRON PIPELINES REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA EXPLANATION PROJECT AREA BOUNDARY CRUDE OIL PIPELINES OTHER UNDERGROUND PIPELINES APPROXIMATE SCALE FEET 0 500 1,000250 SEE FIGURE 6 FOR DETAIL NOTES: 1) LEACH LINES AND DRAIN LINES ARE SHOWN AS CRUDE OIL LINES ON THIS FIGURE FOR CLARITY. SIMILIARLY FOAMITE LINES ARE SHOWN AS WATER LINES DUE TO THEIR SIMILIAR FUNCTIONS DURING OPERATIONS. 2) UTILITY LOCATIONS ARE APPROXIMATE. ACTUAL LOCATION TO BE VERIFIED IN THE FIELD. 3) PORTIONS OF CRUDE OIL AND WATER LINES EXTENDING ALONG THE NORTH SIDE OF TANK FARM ROAD WERE REMOVED AS PART OF THE CITY'S SEWER PROJECT IN 2008. SUMMARY OF PIPELINE LENGTHS LENGTH (FEET) 25,125 258 914 38,263 9,177 TYPES CRUDE OIL LEACH LINE (SANITATION) DRAIN LINES WATER LINE FOAMITE REFERENCES: 1. AERIAL PHOTOGRAPH DATED FEBRUARY 4, 2008 2. GENERAL ARRANGEMENT SAN LUIS OBISPO TANK FARM, PRODUCERS PIPELINE, UNION OIL COMPANY OF CALIFORNIA, DRAWING No. UNKNOWN, DATED APRIL 3, 1950. GENERAL ARRANGEMENT SAN LUIS OBISPO TANK FARM NORTHERN DIVISION PIPELINE UNION OIL COMPANY OF CALIFORNIA, DRAWING No. D2A180, DATED JULY 30, 1981. ıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóRESERVOIR 4NORTHWESTAREARESERVOIR5RESERVOIR6RESERVOIR7RESERVOIR3RESERVOIR2FORMERRECYCLINGAREAS:\GIS\1306_SLOTF-EMC_Work_Activities\1306.004_SLOTF_2014_Support-EMC\ArcMapDocuments\002_1306.004_Wetlands_Fairy_Shrimp_Rare_Plant.mxd\12/9/2014FIGURE 12WETLANDS, FAIRY SHRIMP, ANDRARE PLANT HABITATSREMEDIAL ACTION PLANSAN LUIS OBISPO TANK FARMPREPARED FORCHEVRON EMCSAN LUIS OBISPO, CALIFORNIA05001,000250FeetApproximateScaleSOURCE: BIOLOGICAL RESOURCES MAPPING CONDUCTED BYPADRE AND WSP. FIELD STUDIES PERFORMED 2008.REFERENCE: AERIAL PHOTOGRAPH BY CENTRAL COAST AERIAL MAPPING.DATED MARCH 2, 2007EXPLANATIONSITE PROPERTY BOUNDARYıôóSOUTHERN CALIFORNIA WALNUTHOOVER'S BUTTON CELERYPURPLE NEEDLEGRASS GRASSLANDSLO (CAMBRIA) MORNING GLORYSLO MORNING GLORY (2003 SURVEY)SLO OWL'S CLOVERSLO SERPENTINE DUDLEYACONGDON'S TARPLANTDELINEATED WETLAND (SEE NOTE 1)PROTECTED FAIRY SHRIMPPRESENT (32.56 ACRES)PROTECTED FAIRY SHRIMPNOT PRESENT (71.80 ACRES)NOTE:THE WATERS OF THE U.S., INCLUDING WETLANDSUNDER US FEDERAL JURISDICTION SHOWN IN THISFIGURE WERE IDENTIFIED AND DELINEATEDCONSISTENT WITH DEFINITIONS OF WATERS OF THEUS PROVIDED AT 33 CFR 328.3 (A) (1-8) AND 33 CFR328.4 (B). FIELD DELINEATION PROTOCOLS FOLLOWTHE 1987 UPDATED AND ONLINE VERSION OF THEU.S, ARMY CORPS OF ENGINEERS WETLANDSDELINEATION MANUAL !( !( !( RESERVOIR 4 NORTHWEST AREA RESERVOIR 5 RESERVOIR 6 RESERVOIR 7 RESERVOIR 3 RESERVOIR 2 FORMER RECYCLING AREA BETITA PROPERTY 801 mg/kg 1,151 mg/kg 488 mg/kg WETLANDS IMPACTED BY ASPHALTIC CRUST T-8-0.5 T-2-0.5 T-17-0.5 S:\GIS\1306_SLOTF-EMC_Work_Activities\1306.003_2013_Work_Activities\ArcMapDocuments\031_1306.003_Summary_Environmental_Impacts.mxd\4/28/2013FIGURE 13 SUMMARY OF ENVIRONMENTAL IMPACTS REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA05001,000250 Feet Approximate Scale EXPLANATION TPH IN SOIL > 100 mg/kg EXTENT OF BTEX LIQUID CRUDE OIL. CAPABLE OF GENERATING "FREE" DROPLETS OF OIL. (EVALUATED FOR REMEDIATION IN FEASIBILITY STUDY) PLIABLE, HIGHLY WEATHERED CRUDE OIL. EVIDENCE OF RECENT PLASTIC FLOW. (EVALUATED FOR REMEDIATION IN FEASIBILITY STUDY) SOLID, FORMER CRUDE OIL PLIABLE, HIGHLY WEATHERED CRUDE OIL. NO EVIDENCE OF PLASTIC FLOW LNAPL OCCURANCE PROJECT AREA BOUNDARY TPH IN SOIL > 1,000 mg/kg !(SOIL SAMPLE SHOWING LEAD CONCENTRATION IN mg/kg REFERENCE: AERIAL PHOTOGRAPH DATED FEBRUARY 4, 2008. AREA OF ASENIC IMPACT (EVALUATED FOR REMEDIATION IN THE FEASIBILITY STUDY) AREA OF ARSENIC IMPACT TANK FARM ROAD EXISTING FENCE PROTECT-IN-PLACE NEW FENCE EXISTING FENCE REMOVE AND DISPOSE EXISTING FENCE PROTECT-IN-PLACE ASPHALTIC MATERIAL EXISTING WETLAND 0.068 Ac REMOVE ASPHALTIC MATERIAL ASPHALTIC MATERIAL ASPHALTIC LOCATION OF ROOF FOUNDATION ASPHALTIC MATERIAL EXISTING WETLAND 0.044 Ac REMOVE EXISTING UTILITY POLES PROTECT-IN-PLACE FORMER PUMP-HOUSE CONCRETE FOUNDATIONS REMOVE AND DISPOSE FORMER 10-INCH CRUDE-OIL LINE REMOVE AND DISPOSE NEW FENCE ABANDON FENCE CUT AND CAP WATERLINE EXISTING WETLAND 0.023 Ac REMOVE APPROXIMATE LOCATION OF FORMER CONCRETE FOUNDATION OF FORMER RESERVOIR WALL FORMER CRUDE-OIL PIPELINE CONCRETE FOUNDATION LIGHTNING TOWER No. 2 REMOVE AND DISPOSE 4" DIA. FIRE WATER DISTRIBUTION LINE CLEAR AND GRUB LINE EXISTING BARBED-WIRE FENCE REMOVE AND DISPOSE REMOVE AND DISPOSE BARBED-WIRE FENCE REMOVE AND DISPOSE EXISTING WETLAND 0.022 Ac REMOVEREMOVE AND DISPOSE EXISTING WETLAND 0.053 Ac REMOVE BARBED-WIRE FENCE REMOVE AND DISPOSE EXISTING WETLAND 0.316 Ac REMOVE TO CLEAR AND GRUB LINE WOOD FRAME TEST PLOT REMOVE AND DISPOSE WOOD FRAME TEST PLOT REMOVE AND DISPOSE REMOVE AND DISPOSE WOOD FRAME TEST PLOTS REMOVE AND DISPOSE CONCRETE FOUNDATION LIGHTENING TOWER No. 1 REMOVE AND DISPOSE EXISTING WETLAND .0125 Ac REMOVE EXISTING WETLAND PROTECT-IN-PLACE BARBED-WIRE FENCE REMOVE AND DISPOSE MONITORING WELL TMW-9 ABANDON EXISTING PROPANE CANON TO BE REMOVED BY CHEVRON REMOVE AND DISPOSE APPROXIMATE LOCATION OF EXPOSED WATER LINE REMOVE AND DISPOSE APPROXIMATE LOCATION OF FORMER TANK GAUGING CABLE CUT AND CAP CRUDE-OIL LINE EXISTING WETLAND .007 Ac REMOVE REFERENCE: TOPOGRAPHIC CONTOURS PROVIDED BY EDA, INC., DATED JULY 11, 2007. SCALE 0 120 240 FEET LEGEND V:\1212_Padre-Chevron_SLOTF\1212.001_Remedial_Design\031_1212.001_Reservoir_4_Demolition_Plan.dwg\05/13/14N FIGURE 35 RESERVOIR 4 (OU #3) DEMOLITION PLAN REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA TOPOGRAPHIC CONTOUR FENCEX 125 TREE / BRUSH LINE EXISTING MONITORING / SUPPLY WELL CUT/FILL LINE RIDGE LIMIT OF CLEAR AND GRUB WETLAND-PROTECT-IN-PLACE HYDROCARBON SURFACE EXPRESSION REMEDIATION REQUIRED HYDROCARBON SURFACE EXPRESSION - REMEDIATION NOT REQUIRED WETLAND-IMPACTED BY CONSTRUCTION TANK FARM ROAD EXTENT OF SURFACE EXPRESSION EXCAVATION ASPHALTIC MATERIAL EXISTING PG&E OVERHEAD ELECTRICAL PROTECT-IN-PLACE APPROXIMATE LOCATION OF FORMER CONCRETE FOUNDATION OF FORMER RESERVOIR WALL APPROXIMATE EXTENT OF GEOTEXTILE ASPHALTIC MATERIAL TMW-9 (TO BE ABANDONED) REFERENCE: TOPOGRAPHIC CONTOURS PROVIDED BY EDA, INC., DATED JULY 11, 2007. SCALE 0 120 240 FEET V:\1212_Padre-Chevron_SLOTF\1212.001_Remedial_Design\032_1212.001_Reservoir_4_Excavation_and_Geotextile_Placement_Plan.dwg\05/12/14N FIGURE 37 RESERVOIR 4 (OU #3) EXCAVATION AND GEOTEXTILE PLACEMENT PLAN REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA LEGEND TOPOGRAPHIC CONTOUR FENCEX 125 TREE / BRUSH LINE EXISTING MONITORING / SUPPLY WELL APPROXIMATE EXTENT OF GEOTEXTILE LIMIT OF CLEAR AND GRUB HYDROCARBON SURFACE EXPRESSION REMEDIATION REQUIRED HYDROCARBON SURFACE EXPRESSION - REMEDIATION NOT REQUIRED WETLAND - PROTECT-IN-PLACE WETLAND - IMPACTED BY CONSTRUCTION ıôóıôóıôóıôóıôóıôóıôóıôó ıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôóıôó ıôóıôóıôó ıôóıôó ıôó ıôó ıôóıôó ıôó ıôó ıôóıôóıôóıôóıôó ıôó ıôó RESERVOIR 4 NORTHWEST AREA RESERVOIR 5 RESERVOIR 6 RESERVOIR 7 RESERVOIR 3 RESERVOIR 2 FORMER RECYCLING AREA S:\GIS\1306_SLOTF-EMC_Work_Activities\1306.003_2013_Work_Activities\ArcMapDocuments022_1306.003_Areas_of_Habitat_Impact.mxd\11/21/13FIGURE 46 AREAS OF HABITAT IMPACT REMEDIAL ACTION PLAN SAN LUIS OBISPO TANK FARM PREPARED FOR CHEVRON EMC SAN LUIS OBISPO, CALIFORNIA 0 500 1,000250 Feet Approximate Scale NOTE: CRLF = CALIFORNIA RED LEGGED FROG SOURCE: BIOLOGICAL RESOURCES MAPPING CONDUCTED BY RINCON CONSULTANTS INC., 2003. FIELD STUDIES PERFORMED MAY THROUGH SEPTEMBER 2003. REFERENCE: AERIAL PHOTOGRAPH BY CENTRAL COAST AERIAL MAPPING. DATED: FEBRUARY 4, 2008 EXPLANATION SITE PROPERTY BOUNDARY ıôó SOUTHERN CALIFORNIA WALNUT HOOVER'S BUTTON CELERY PURPLE NEEDLEGRASS GRASSLAND SLO (CAMBRIA) MORNING GLORY SLO MORNING GLORY (2003 SURVEY) SLO OWL'S CLOVER SLO SERPENTINE DUDLEYA CONGDON'S TARPLANT DELINEATED WETLAND PROTECTED FAIRY SHRIMP PRESENT (32.56 ACRES) PROTECTED FAIRY SHRIMP NOT PRESENT (71.80 ACRES) HABITAT IMPACT !! !! ! Total Project Disturbance Area STAGING AREA BORROW AREAS ACCESS ROUTE!! !! ! LEGEND PROPERTY BOUNDARY LINE PROJECT NAME: PROJECT NUMBER: DATE: SCALE IN FEET 0 100 200 ENVIRONMENTAL SCIENTISTSENGINEERS, GEOLOGISTS &associates, inc.3 FIGURE NN 1301-0307 April 2018 CEMC San Luis Obispo, CaliforniaSAN LUIS OBISPO TANK FARM FIELD ASSESSMENT MAP TEST PIT LOCATIONWITH APPROXIMATE DEPTH TO TPH-CONTAINING OR STAINED SOIL TEST TRENCH LOCATION WITH APPROXIMATEDEPTH TO TPH-CONTAINING SOIL RESERVOIR 4PLIABLE, HIGHLY WEATHERED CRUDE OILNO EVIDENCE OF PLASTIC FLOW (AVOCET,2015) PLIABLE, HIGHLY WEATHERED CRUDE OILEVIDENCE OF RECENT PLASTIC FLOW (AVOCET,2015) AVOCET CONSTRUCTION CONTROL LINE AS-BUILT EXCAVATIONS LIMITS EDGE OF CONCRETE NOTES 1. TOPOGRAPHIC CONTOURS PROVIDED BY RRM DESIGN GROUP DATED MARCH 2013. www.trihydro.com 1252 Commerce Drive Laramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 2. FIGURE CREATED BY PADRE ASSOCIATES, INC. AND MODIFIED BY TRIHYDRO CORPORATION. www.trihydro.com 1252 Commerce DriveLaramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 5 CLOSURE SUMMARY REPORT FIGURE CREATED BY AVOCET ENVIRONMENTAL, INC. AND MODIFIED BY TRIHYDRO CORPORATION. 1 42 5 5 5 5 5 5 5 5 5 5 5 4 4 4 3 3 3 3 5 5 5 5 5 5 5 5 4 4 4 3 5 5 5 5 5 5 5 5 4 4 4 4 4 4 4 4 5 5 4 4 4 3 4 4 6 5 5 4 4 4 3 3 3 5 5 5 5 4 4 3 5 5 5 4 4 5 5 5 4 4 4 5 5 4 4 5 4 4 6 4 4 34 4 3 34 3 33 8 33 3 33 4 42 4 43 54 54 53 4 43 6 5 5 3 3 3 3 3 3 3 3 66 3 751 642 532 43 43 3 3 3 4 4 4 4 4 4 4 4 4 4 4 3 2 3 4 4 4 4 3 3 3 4 2 4 4 4 4 4 5 4 4 5 5 4 2 4 4 4 5 5 4 4 5 5 5 4 3 2 5 5 5 5 4 5 4 5 5 5 4 3 3 5 5 6 7 4 6 5 3 3 5 5 5 3 3 3 4 5 6 6 4 6 5 4 4 4 5 5 3 3 3 2 5 6 6 4 6 5 5 4 4 4 4 3 3 3 3 5 6 6 4 6 5 5 4 4 3 4 4 3 3 3 4 6 6 5 6 5 4 4 3 3 4 4 4 3 4 6 6 5 6 5 4 4 3 4 4 4 4 4 4 6 6 5 6 5 5 4 4 4 4 4 5 4 5 6 6 5 6 5 5 4 4 4 5 5 5 4 5 6 6 6 6 5 5 5 4 4 5 5 5 4 5 6 6 6 6 5 5 5 4 4 5 5 5 4 4 6 6 6 6 6 5 5 4 4 5 5 5 5 5 6 6 5 7 6 5 5 4 4 5 5 5 5 5 6 6 5 7 6 5 5 4 4 5 5 5 5 4 6 6 6 6 6 5 5 4 4 5 5 5 4 4 6 6 5 6 6 5 5 4 4 5 5 5 4 5 6 6 6 6 6 5 5 5 4 5 5 6 4 5 6 6 6 6 5 5 5 5 5 6 6 6 4 5 6 6 5 6 5 5 5 5 5 6 6 6 4 5 6 6 6 6 5 5 5 5 5 6 6 6 4 5 6 6 6 6 5 5 5 5 5 6 6 6 5 5 6 6 6 6 6 5 6 6 5 6 6 6 6 5 6 6 7 5 5 5 6 5 5 6 6 6 6 5 6 6 7 5 5 5 6 5 4 6 6 6 6 5 6 6 8 5 5 5 6 5 4 6 6 6 6 5 6 6 7 5 5 5 6 6 5 6 6 7 4 5 6 6 7 6 5 5 6 6 5 6 7 7 4 6 7 6 7 6 5 5 7 7 4 7 7 8 4 5 6 7 7 6 6 5 4 4 7 7 5 7 7 7 4 5 6 5 8 6 6 5 4 4 7 7 5 7 7 7 5 5 6 5 9 6 5 5 4 5 6 7 6 6 7 6 6 6 6 5 5 6 6 5 5 6 6 7 6 6 5 8 6 6 5 5 5 5 5 5 5 6 5 4 6 7 6 5 5 5 6 6 4 5 6 4 5 8 6 6 5 6 5 6 6 6 6 6 8 7 6 7 7 1 CEMC SAN LUIS OBISPO, CA PROJECT NAME: PROJECT NUMBER:1301-0307 DATE:April 2018 SCALE IN FEET 0 80 160 ENVIRONMENTAL SCIENTISTSENGINEERS, GEOLOGISTS &associates, inc.5 FIGURE TANK FARM PROJECT SITE NN RESERVOIR 4FILL MAP AS-BUILT EXCAVATIONS LIMITS PROPERTY BOUNDARY LEGEND TANK FARM ROAD PAVED ROAD DIRT ROADS DEPTH OF FILL IN FEET5 FINAL GRADE CONTOURS EXCAVATION CONTOURS EDGE OF CONCRETE NOTES 1. EXCAVATION TOPOGRAPHIC CONTOURS PROVIDED BY CANNON DATED JUNE 2017. 2. FINAL GRADE TOPOGRAPHIC CONTOURS PROVIDED BY CANNON DATED OCTOBER 2017. www.trihydro.com 1252 Commerce Drive Laramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 3. FIGURE CREATED BY PADRE ASSOCIATES, INC. AND MODIFIED BY TRIHYDRO CORPORATION. C B AG H I J K L M N O P D EF CEMC SAN LUIS OBISPO, CA PROJECT NAME: PROJECT NUMBER:1301-0307 DATE:April 2018SCALE IN FEET 0 100 200 ENVIRONMENTAL SCIENTISTSENGINEERS, GEOLOGISTS &associates, inc.6A FIGURE TANK FARM PROJECT SITE NN REMEDIAL EXCAVATIONCONTOUR MAP AS-BUILT EXCAVATIONS LIMITS LEGEND DIRT ROADS EXISTING CONTOURS EXCAVATION CONTOURS PROPERTY BOUNDARY LINE RESERVOIR 4 A NOTES 1. EXISTING TOPOGRAPHIC CONTOURS PROVIDED BY RRM DESIGN GROUP DATED MARCH 2013. PIPELINES REMOVED PIPELINES LEFT IN PLACE ASPHALTIC FIELD TEST LOCATIONS LIQUID CRUDE OIL AND GROUNDWATER SEEPS 2. EXCAVATION TOPOGRAPHIC CONTOURS PROVIDED BY CANNON DATED JUNE 2017. www.trihydro.com 1252 Commerce Drive Laramie, Wyoming 82070 (P) 307/745.7474 (F) 307/745.7729 3. FIGURE CREATED BY PADRE ASSOCIATES, INC. AND MODIFIED BY TRIHYDRO CORPORATION. 1 From:Hind Baki <hind@mitchtsailaw.com> Sent:Tuesday, September 12, 2023 1:06 PM To:Cohen, Rachel Cc:Reza Bonachea Mohamadzadeh; Mitchell M. Tsai Attorney at Law, P.C. Subject:Re: SWMSRCC - City of San Luis Obispo - 276 Tank Farm Road Mixed Use Project - project status inquiry Attachments:image004.png Thank you very much for this email. Best wishes, --Hind On Tue, Aug 29, 2023 at 8:50 AM Cohen, Rachel <rcohen@slocity.org> wrote: Hello, The project has not progressed and continues to be on hold. Thank you, Rachel Cohen pronouns she/her/hers Senior Planner The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location. Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E rcohen@slocity.org T 805.781.7574 slocity.org The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and l The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and l The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and l Stay connected with the City by signing up for e-notifications From: Hind Baki <hind@mitchtsailaw.com> Sent: Monday, August 28, 2023 2:40 PM To: Cohen, Rachel <rcohen@slocity.org> 2 Cc: Reza Bonachea Mohamadzadeh <reza@mitchtsailaw.com>; Mitchell M. Tsai Attorney at Law, P.C. <info@mitchtsailaw.com> Subject: SWMSRCC - City of San Luis Obispo - 276 Tank Farm Road Mixed Use Project - project status inquiry Good afternoon...we are checking to see if you might have an update for us on this project. Thank you, in advance, for your help. Hind Baki Paralegal Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue, Suite 200 Pasadena, CA 91101 Office: (626) 314-3821 Fax: (626) 389-5414 Email: hind@mitchtsailaw.com Website: http://www.mitchtsailaw.com **Please note that Hind Baki is out of office on Fridays; for any urgent matters, please contact info@mitchtsailaw.com** CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at hind@mitchtsailaw.com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you. On Tue, May 16, 2023 at 4:31 PM Hind Baki <hind@mitchtsailaw.com> wrote: Thank you very much for this update. We appreciate your time. 3 Best wishes, --Hind On Tue, May 16, 2023 at 4:03 PM Cohen, Rachel <rcohen@slocity.org> wrote: Hello, This project has been deemed incomplete and is on hold. Sincerely, Rachel Cohen pronouns she/her/hers Senior Planner The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location. Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E rcohen@slocity.org T 805.781.7574 slocity.org The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and l The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and l The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and l Stay connected with the City by signing up for e-notifications From: Hind Baki <hind@mitchtsailaw.com> Sent: Tuesday, May 16, 2023 3:22 PM To: Cohen, Rachel <rcohen@slocity.org>; Reza Bonachea Mohamadzadeh <reza@mitchtsailaw.com>; Mitchell M. Tsai Attorney at Law, P.C. <info@mitchtsailaw.com> Subject: SWMSRCC - City of San Luis Obispo - 276 Tank Farm Road Mixed Use Project - project status inquiry This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Good afternoon, 4 Our Firm is interested in the above-mentioned project, and would like to check with you on whether the application has been deemed complete, and whether tentative public hearings have been scheduled. Thank you, in advance, for your help. Best wishes, --Hind Hind Baki Paralegal Mitchell M. Tsai, Attorney At Law 139 South Hudson Avenue, Suite 200 Pasadena, CA 91101 Office: (626) 314-3821 Fax: (626) 389-5414 Email: hind@mitchtsailaw.com Website: http://www.mitchtsailaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at hind@mitchtsailaw.com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you. 1 From:Taylor, Callie Sent:Wednesday, August 16, 2023 4:56 PM To:McGhee, Ethan Cc:Yun, David Subject:RE: Alternate Station 5 location Attachments:The Link (276 Tank Farm) - Project Plans.pdf Hi Ethan, The draft Specific Plan for The Link is attached. This shows a 5th fire station site in areas 12 and 13, Public Facilities Zoning. See description on page 11, site plan on page 24 – 26 & 32 We had hoped this would be the site of the 5th fire station, but due to environmental hold ups on the Chevron site, it looks like development could be too far in the future to work for what the City needs. We would like to find a site for fire station development in the next 2-3 years, but the timeframe on The Link is unknown at this time and not moving forward at the moment. Callie From: McGhee, Ethan <emcghee@slocity.org> Sent: Wednesday, August 9, 2023 3:25 PM To: Taylor, Callie <CLTaylor@slocity.org> Cc: Yun, David <dyun@slocity.org> Subject: RE: Alternate Station 5 location Hi Callie, Absolutely. Thanks for sharing the document for us to reference as we begin our analysis. Best, Ethan From: Taylor, Callie <CLTaylor@slocity.org> Sent: Wednesday, August 9, 2023 3:20 PM To: McGhee, Ethan <emcghee@slocity.org> Subject: FW: Alternate Station 5 location Hi Ethan, I am hoping you could help me with some preliminary GIS mapping that the Fire Department has requested. The Fire Department is looking for a potential future 5th Fire Station in the southern part of the City. Todd Tuggle has prepared a scope of work and identified parameters for site requirements (attached). He has a few maps of the areas to consider in the attached document. Before we hire an outside consultant to look for sites, I am hoping that you could do some preliminary searches in GIS to identify vacant and potential sites in the area. We could set up a meeting with Fire staff to get you more info if needed. 2 Callie Taylor Associate Planner Community Development 919 Palm St., San Luis Obispo, CA 93401-3218 E CLTaylor@slocity.org T 805.781.7016 slocity.org Stay connected with the City by signing up for e-notifications From: Tuggle, Todd <ttuggle@slocity.org> Sent: Wednesday, July 19, 2023 3:03 PM To: Corey, Tyler <tcorey@slocity.org> Cc: Fox, Sammy R. <sfox@slocity.org>; Blattler, James <jblattle@slocity.org>; Vert, Nicole <nvert@slocity.org>; Tway, Timothea (Timmi) <TTway@slocity.org> Subject: RE: Alternate Station 5 location Good afternoon Tyler, We were able to put together a document that we hope will help guide RRM in the selection of potential sites for a permanent fire station 5. It is a no-frills document so if it needs to be on letter head or something similar, let me know and we’ll get it formatted. Also, if the descriptions need to be adjusted or information needed, I’ll get it clarified asap. AvilaRanchFireStaƟon5.docx Todd Tuggle pronouns he/him/his Fire Chief Fire Department 2160 Santa Barbara, San Luis Obispo, CA 93401-5240 E ttuggle@slocity.org C 805.858.0435 slocity.org Stay connected with the City by signing up for e-notifications From: Corey, Tyler <tcorey@slocity.org> Sent: Wednesday, July 12, 2023 10:41 AM To: Tuggle, Todd <ttuggle@slocity.org> Cc: Tway, Timothea (Timmi) <TTway@slocity.org>; Fox, Sammy R. <sfox@slocity.org>; Blattler, James <jblattle@slocity.org>; 3 Vert, Nicole <nvert@slocity.org> Subject: RE: Alternate Station 5 location Hi Todd, I think the best place to start is for your team to develop the scope for services. From there I am happy to solicit proposals from our on-call consultants. Let me know if this approach sounds right and if you have any questions, Tyler Corey Deputy Director of Community Development Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E tcorey@slocity.org T 805.781.7169 slocity.org Stay connected with the City by signing up for e-notifications From: Tuggle, Todd <ttuggle@slocity.org> Sent: Wednesday, July 12, 2023 7:57 AM To: Corey, Tyler <tcorey@slocity.org> Cc: Tway, Timothea (Timmi) <TTway@slocity.org>; Fox, Sammy R. <sfox@slocity.org>; Blattler, James <jblattle@slocity.org>; Vert, Nicole <nvert@slocity.org> Subject: Alternate Station 5 location Good morning Tyler, Thanks for the great conversation yesterday and valuable input to the decision-making process. One of my tasks is to reach out to any consultants we may have available to identify an alternate site location from the intended site in the Link development. This alternate site would be potentially available immediately, with a station opening date within a reasonable time frame of January of 2026. I thought I had worked with RRM in the past, I was wrong, it was RNT that I worked with, specifically Chris Bradbury. Would you happen to have a contact at RRM to start the process? Also, what would be the process for engaging them in this work? I can’t imagine it would be incredibly expensive to do the analysis, hopefully less than $10k. Is a scope of work and a signed contract enough. Thanks in advance for the help and I appreciate the background and assistance in getting to the best solution for the Community and the City. Todd Tuggle pronouns he/him/his Fire Chief 4 Fire Department 2160 Santa Barbara, San Luis Obispo, CA 93401-5240 E ttuggle@slocity.org C 805.858.0435 slocity.org Stay connected with the City by signing up for e-notifications THE LINK: PROJECT DESCRIPTION AUGUST 2022 APPLICATION INFORMATION Applicant: Property Owner: Representative: Address: APNs: Covelop, Inc. Union Oil Company of California Peck Planning and Development & RRM Design Group 276 Tank Farm Road 076-383-001, 076-381-021, 076-382-005, 076-383-002, 076-352-062, & 076-352-061 TABLE OF CONTENTS Introduction ...................................................................................................... 1 Background Information .................................................................................... 3 Site and Setting ...................................................................................... 3 Program and Development ................................................................................ 5 Land Use/Zoning Plan ............................................................................ 5 Development Potential ........................................................................... 5 Development Phasing ............................................................................. 8 Recreation and Amenities .................................................................................. 9 Public/Common Open Space ................................................................... 9 Transportation and Circulation .......................................................................... 10 Tank Farm Road ..................................................................................... 10 Santa Fe Road Improvements ................................................................. 10 Transit ................................................................................................... 11 Pedestrian and Bicycle Circulation .......................................................... 11 Airport Facilities ..................................................................................... 11 Special Project Design Features ......................................................................... 11 City Processing Requirements ............................................................................ 11 Needed Entitlements .............................................................................. 11 Covenant With Deed Restrictions ....................................................................... 14 LIST OF FIGURES AND ATTACHMENTS Figures and Attachments Figure 1: Location Map Figure 2: AASP Land Use Map (existing) Figure 3: ALUP Safety Zones and Project Location Attachment A Project Birdseye View Illustrative Land Use Plan (East) Illustrative Land Use Plan (Overall) Figure A-1: Development Areas and Building Key Map Figure A-2: Development Areas and Development Potential Figure A-3: Circulation: (Overall) Figure A-4: Circulation Features: East Figure A-5 Circulation Features: West Figure A-6: Proposed Land Use Designations (Zoning): Overall Figure A-7: Proposed Land Use Designations (Zoning): East Figure A-8: Proposed Land Use Designations (Zoning): West Figure A-9: Phasing Figure A-10: Land Plan and ALUP Safety Zones Attachment B Plan Data by Area and Building Attachment C Phasing and Buildout Attachment D Project Imagery and Background Attachment E General Plan, AASP and Community Design Guidelines Consistency Analysis Attachment F Airport Land Use Plan Consistency Analysis INTRODUCTION Covelop, Inc. (“Covelop”) is proposing an exciting project on the site of the former San Luis Obispo Tank Farm (“SLO Tank Farm”) owned by Union Oil Company of California (“Union Oil”). The pro- posed project will provide a compact arrangement of multiple uses with flexible land use designations and special development standards that will provide a high-quality development. This proposed project will significantly advance several of the City of San Luis Obispo’s development goals, including: • Providing a better jobs-housing balance in the community, especially in comparison to the land uses currently designated for the site; • Completing essential infrastructure to serve the proposed project and the major growth areas of the community beyond; and, • Addressing essential transportation connections. As currently planned, the proposed project will include 725 multifamily attached units, 69,150 square feet of retail mixed use space to serve the needs of the growing Tank Farm Road neighborhood, 279,700 square feet of professional and medical office uses, 209,000 square feet of industrial and ware- house space, and 237,200 square feet of mixed service commercial uses. The planned uses are not in- tended to compete with the Downtown or other areas committed to development. The proposed office use area and commercial uses are intended to serve the growing local residential neighborhood, and uses that cannot be accommodated elsewhere in the community such as larger scale offices for business headquarters, medical office clinics, and others. The proposed project also includes approximately 250 acres (three fourths of the proposed project) as open space and conservation. This will contribute to biological diversity, airport and aircraft safety, and the quality of the scenic environment. The proposed project would also provide a home for the planned fifth (permanent) City fire sta- tion, which would serve southern San Luis Obispo, as well as provide two neighborhood parks. Like other residential projects in the vicinity, the unit sizes would be compact, and the emphasis would be on rental units. Units will range in size from 450 square feet to 1,300 square feet. Overall, the average unit size across the 725 units is expected to be lower than other recent Specific Plan and master planned projects in the community. The resulting proposed project mix will create housing opportunities for many families that are currently priced out of the market. The residential and commercial elements of the proposed mixed-use project will be clustered around common open space areas and include facili- ties such as a recreation center or community building. The figures in Attachment A show the site plan, development concepts and circulation features for the proposed project. The name “The Link” was intentionally selected for the proposed project given its internal link- ages within development areas, as well as circulation connections to other sites beyond the periphery of the proposed project. While the 332-acre proposed project site was once a hub for employment and oil storage facilities, it has been underutilized since Union Oil ceased its activities and demolished its facili- ties. Located between Broad and South Higuera Streets along one of the San Luis Obispo’s most im- portant thoroughfares, the site has development potential and is currently undergoing remediation The Link Project Description Page 2 of 16 work. A project description with proposed plans to remediate the site and develop business park uses was prepared on behalf of Union Oil, which was acquired by Chevron Corporation, and was submitted to the City and other governmental agencies for California Environmental Quality Act (CEQA) evaluation. The City, in consultation with the other government agencies, certified the Chevron Tank Farm Remedia- tion and Development Project Final Environmental Impact Report (2013 FEIR) (SCH # 2009031001) dated December 2013 and prepared by Marine Research Specialists (MRS). The previously proposed business park uses in that plan evaluated in the 2013 FEIR were found to be infeasible because of the limited market for office and business park uses, infrastructure requirements, and because it was unable to im- prove the City’s jobs-housing imbalance. With the uses proposed, the project will have an internal jobs- housing ratio of 2.21, more closely meeting the General Plan’s requirement that new projects not exac- erbate the jobs-housing imbalance. By comparison, the existing site land uses for the site would have a jobs-housing ratio of 7.25, which would significantly worsen the imbalance. In many respects, the proposed project will link the city’s existing and proposed growth areas and unlock the development potential in south San Luis Obispo. Covelop’s neighboring project at 600 Tank Farm Road is already delivering road improvements along Tank Farm Road and Santa Fe, and will construct the planned roundabout at that intersection. The Link project will build on those improve- ments by extending Santa Fe south of the roundabout, correcting the existing substandard diagonal in- tersection east of the proposed project. The proposed project will also extend the Santa Fe roadway and utilities to its north property line in its early phases. This improvement will assist in the eventual ability of the Garcia Ranch project, located north of The Link, to develop since it currently has limited sewer and storm drainage capacity without connecting to the sewer main in Tank Farm Road. In addition, the improvements to Tank Farm Road for vehicles, bikes and pedestrians will provide important safety and capacity improvements to this important arterial roadway. The proposed project also ties together disparate portions of the City’s circulation system, in- cluding the connection of Avila Ranch’s pedestrian and bike trails north to the Damon Garcia Sports Fields, and ultimately further connections to the north all the way to Cal Poly. To the south, Avila Ranch’s completion of the Buckley Road extension, and the completion of the remainder of the Bob Jones Trail by San Luis Obispo County will provide a connection of south San Luis Obispo to Avila Beach. Therefore, the proposed project’s improvements would complete the bike trail connection from Cal Poly to Avila Beach. The proposed project will also facilitate the connection of development in the Margarita Specific Plan Area to Tank Farm Road, and the actual construction of a protected Class I bike path and buffered Class II bike lanes between Innovation Way and Santa Fe Road. The mix of uses in the proposed project would also facilitate the implementation of the City’s capital facilities plans. The proposed mix of land uses would generate approximately $16.3 million in traffic impact fees, $6.5 million greater than that estimated for the land uses evaluated in the 2013 FEIR. Furthermore, the proposed project would generate approximately $3.5 million in park fees and create new park areas in a portion of the community without any neighborhood or community park facilities. The Link Project Description Page 3 of 16 BACKGROUND INFORMATION Site and Setting o Site Location The proposed project site is located on the north and south sides of Tank Farm Road between South Higuera Street and Broad Street (see Figure 1: Project Location Map). It is centrally lo- cated along the roadway between urban development on the east and west sides. The total site area is 332 acres. Figure 1. Project Location Map The Link Project Description Page 4 of 16 o Project Overview The proposed project will provide for a mix of land uses including residential, commercial, indus- trial, office, park, and public facility on 82.4 acres of the total proposed project site. The entire site is undergoing remediation and restoration by the current property owner under permits is- sued by the San Luis Obispo County and other governmental agencies. Remediation progress is well underway as the current property owner has submitted a Request for Closure Report for the largest portion of the developable areas north of Tank Farm Road and east of the site. As shown in Figure A-1 (Attachment A) there are 14 separate development areas on the proposed project site. Attachment B shows the development statistics associated with each area, and for each building in each area. The intervening area between the development areas will remain as open space in a conservation easement. Details of the planned development areas are described in the following section of this proposed project description, and in Attachment B. The pro- posed project site is currently in the County and annexation to the City of San Luis Obispo is pro- posed as part of the proposed project’s entitlements. Figures A-1 through Figure A-8(Attachment A) show the proposed development plans for the project, including the location of the various development sites, proposed land uses, and major circulation features. The proposed project is anticipated to be constructed in three development phases over a period of 5 to 15 years. Figure A-9 shows planned phasing, and Attachment C shows the anticipated buildout and market absorption for the different proposed project ele- ments and land uses based on state and county economic projections for San Luis Obispo County and the City of San Luis Obispo. Actual development and buildout will depend on mar- ket conditions, and actual buildout may occur faster or slower than shown in Attachment C. The City of San Luis Obispo has a compact urban form and limited areas to accommodate new development. Given recent development patterns and changes in City and County land use plans and development regulations, this area is now viewed as an infill development area. The site is located within the Airport Area Specific Plan (AASP) which was originally adopted on Au- gust 23, 2005, and amended several times since. The AASP provides a framework and guidance for further urban development. The uses in the proposed project will complement the commer- cial, employment, and residential uses now planned in the vicinity of the site. The proposed project is intended to address housing, employment, and service needs in the community through a combination of design excellence, value-added features, and location. o Site History/Constraints The proposed project site, which is composed of fourteen parcels and forms the largest property in the airport area, is currently undergoing remediation and restoration work. Remediation work supporting business park and commercial uses has been done in most of the areas cur- rently proposed for development; the current schedule anticipates that remaining work in the proposed development areas will be done by the end of 2024. Site restoration will continue in the open space (future conservation easement) beyond 2024. The proposed land uses will need to be included in the Supplemental EIR (or other project CEQA document) to identify any im- pacts or additional mitigations resulting from the proposed changes in land uses. The proposed land uses have been located in accordance with the density and use restrictions of airport safety zones. The Link Project Description Page 5 of 16 o Flower Mound A large hill exists in the northeastern portion of the eastern development area. It is known lo- cally as the “flower mound”. In the past there were some quarry activities associated with this rock formation. The 2013 FEIR evaluated the associated impacts with the removal of this rock outcropping and established mitigation measures for removal activities. The applicant intends to separately seek a grading permit with the County of San Luis Obispo to move forward with the grading work to remove the outcropping as a separate action from this proposed project under the evaluation and mitigation measures in the 2013 FEIR. PROGRAM AND DEVELOPMENT Land Use/Zoning Plan o Current Land Use Map The two portions of the proposed project site where development is proposed are outlined on a copy of the existing AASP land use map (see Figure 2: AASP Land Use Map with Project Loca- tion). This figure shows that proposed development is located in areas that are already planned to accommodate development. The existing planned land uses in the AASP were so designated primarily to comply with the 2005 County Airport Land Use Plan (ALUP) which restricted the site to non-residential development. Consequently, the AASP and City Land Use Element describes the site as having a mixture of public, manufacturing, and business park uses. The ALUP was amended in 2021 and now permits additional forms of development in the vicinity of the air- port, including residential uses that were previously prohibited. The applicant is proposing modi- fications to the proposed project site’s land use categories to accommodate planned uses needed in the community and that are consistent with the recently adopted Airport Land Use Plan (ALUP). Figure 3: ALUP Safety Zones and Project Location and Figure A-10 show the loca- tion of the proposed project site and the ALUP land use compatibility zones. o Proposed Uses/Zoning Designations The proposed land uses and zoning categories for the overall proposed project site are shown on Figures A-6, A-7, and A-8: Proposed Land Use Designations (Zoning). The specific land use and zoning categories are discussed with the descriptions of the different proposed project com- ponents in the following section. Development Potential (units/sf/parking) As noted, the proposed project includes a wide variety of land uses with different development configu- rations tailored for the particular use and portion of the site on which they are located. The following section describes these various proposed project components in more detail. Figure A-1 shows the loca- tion of each of the development areas and buildings referenced herein, And Figure A-2 and Attachment B show the planned amount and type of development in each area. o Purpose The proposed plan utilizes existing city land use and zoning designations as a base to guide de- velopment but also is proposing to adjust the list of allowable uses and development standards in certain areas to provide for a compatible mix of land uses. A special, combined base zone will be created that includes the uses in the City’s “O”, “BP” and “CS” zones. Special sub-areas will be The Link Project Description Page 6 of 16 designated that emphasize subsets of this base zone, but not exclude other uses that are con- tained in the base zone. Combined with special development standards and regulations for compatibility, the goal is to establish a broader range of uses for the site than currently con- tained in any one City zone, and to establish more “Allowed” uses without the need for Minor Use Permits, special findings, Conditional Use Permits, or other discretionary reviews. This flexi- bility, combined with the special design standards that will be established for the site will ensure that the city’s high development standards and expectations are met while creating more cer- tainty in the execution and completion of the proposed project. In a sense, some of the pro- posed zoning categories are hybrid blends of different land uses. The ultimate goal is to provide for zoning flexibility and a compatible mix of land uses in a walkable environment. By defining the desired character and unique features of different areas, the desired outcome is to accom- modate a variety of land uses that are allowed by right through the plan and minimize the need for future conditional use permits. o Residential & Mixed-Use Areas There are four proposed areas of the site that will contain multi-family residential uses. These proposed areas are either zoned R-4 , High Density Residential, or C-C-MU, Community Com- mercial Mixed-Use which allows for a mixed-use project, with commercial uses fronting public streets (commercial-residential). • Area 8: Multi-family Area 1 (R-4 Zoning) This area is adjacent on its east side to the planned residential units in the 600 Tank Farm project and would include 350 dwelling units. As provided in the San Luis Obispo Zoning Ordinance, R-4 zoning allows for dwellings at a density of 24 density units per net acre. Such zoning is to be used to provide for attached dwellings with common outdoor areas and compact private outdoor spaces, and to accommodate various types of higher density housing to allow for dense housing close to concentrations of employment, along transit corridors and nodes, and in areas largely committed to high-density resi- dential development. Density is shown as 23.9 density units per acre. • Area 10: Multi-family Area 2 (R-4 Zoning) This area would be zoned R-4 and is planned to contain approximately 50 dwelling units in four residential floors. It is proposed in the southeast corner of Santa Fe and Tank Farm Road adjacent to Acacia Creek. Density is estimated to be 21.6 density units per net acre. • Area 1: Mixed-Use Area East (C-C-MU Zoning) Area 1 is a mixed use site at the northwest corner of Santa Fe and Tank Farm Road. It is planned to contain 100 dwelling units within three upper residential floors with com- mercial uses on the ground floor. This area of the site will contain 32,750 square feet of commercial on the ground floor of the two mixed use buildings, plus approximately 10,000 square feet of free-standing retail commercial buildings. As provided in the C-C zone, allowed density would be 36 density units per net acre; planned density is 19.4 density units per net acre. • Area 11: Mixed-Use Area West (C-C-MU Zoning) Area 11 is a mixed use site at the northeast corner of Tank Farm Road and Innovation Way. It is planned to contain 225 dwelling units in three buildings. The buildings facing The Link Project Description Page 7 of 16 Tank Farm Road will have ground floor commercial uses and two upper residential floors. The third building would contain four floors of residential uses. As provided in the C-C zone, allowed density would be 36 density units per net acre; planned density is 28 density units per net acre. This portion of the site will add housing to areas typically sought out by residents, surrounded by employment bases along South Higuera and its ancillary roads, retail including grocery outlets and food and beverage, and commercial services including health and fitness centers. This area would be connected to the rest of the proposed project through future Class I bike paths along Tank Farm Road as well as a recreational path through the northern portion of the site. This area is proposed for residential development to help balance jobs and housing and to reduce vehicle miles travelled, while complying with local GHG and Climate Action Plan regulations. o Business and Commercial Service Areas These areas contain a variety of hybrid uses combining retail and some fabrication. • Area 2: “The Hangars” – Retail/Manufacturing (C-S Zoning) Spaces within these two buildings will be flexible, but envision front of house retail (in- cluding food and beverage) combined with some micro-manufacturing that are service oriented. Attachment D shows architectural concepts and imagery. Uses could range from a food hall to light manufacturing service commercial uses with retail outlets. • Area 4: “The District” - R&D/Retail (C-S Zoning) This area will contain four buildings that are intended to house service commercial re- tail and office uses. They are arranged in a pedestrian oriented format with onstreet diagonal parking to facilitate pedestrian connections and orientation. • Area 7: Commercial Building - Retail/Restaurant/Drinking (C-S Zoning) This small commercial building is located in Area 7 adjacent to a park and ponding ba- sin. It is intended to be coupled with a dog park and serve residents and visitors in the area and provide a pleasant environment and backdrop to enjoy a meal or drink. o Areas 3 and 9: Office Areas There are two distinct office areas in the proposed project both zoned Business Park-Service- Commercial (BP-C-S). General offices are proposed on the north side of Tank Farm Road and medical offices are proposed on the south side of the street. The idea with the hybrid zone would be to mainly accommodate office uses, but also provide flexibility to allow certain typical C-S uses that are of a character and integrity to be compatible with office development. In con- trast to the office use provisions of the C-S and B-P zones, the location of office uses in these ar- eas would be the preferred predominant use. These areas may also be used for C-S uses if the market is soft for office uses. • Area 3: General Core Offices (north-BP-C-S Zoning) Five separate buildings are proposed here for general office uses with good visibility and identification from Tank Farm Road. Office buildings would be clustered around a com- mon open space to provide a campus environment, with supportive parking located on the periphery. The Link Project Description Page 8 of 16 • Area 9: Medical Offices (south-BP-C-S Zoning) Four separate buildings are proposed here to provide medical uses in a campus layout. o Areas 5 and 6: Industrial Areas Two different industrial areas are proposed within the project. Area 5 is a research and develop- ment/light manufacturing area that is proposed on the north and west sides of The District com- mercial area. Area 6 is a more traditional industrial area that is proposed further to the north- west. Total floor area of industrial uses in the proposed project is 209,000 square feet. • Area 5: Light Manufacturing/R&D (C-S Zoning) A total of five buildings are proposed in this area. They are intended to accommodate a variety of light industrial uses and research and development enterprises. • Area 6: Industrial (C-S Zoning) Two buildings are proposed in this area. They are larger volume spaces generally with one floor level and the option for some mezzanine space to accommodate more tradi- tional manufacturing and warehouse type uses. o Areas 12 and 13: Public Facilities (PF Zoning) The public parks and the fire station are identified for Public Facilities (PF) zoning. Actual zoning for the fire station site (Area 13) will depend on actual city development plans; if the fire station is deemed to not be necessary by the city, or is to be located on another property, this property would be zoned C-S like the adjacent parcels. Development Phasing The proposed project will be developed in three phases as illustrated on the Phasing plan on Figure A-9 in Attachment A. Phase 1 circulation improvements will include: the completion of the northeastern two-thirds of Santa Fe Road, from its current planned terminus at the entrance to 600 Tank Farm to the northern property line and the completion of the Tank Farm Road frontage improvements west of the Santa Fe roundabout along the Phase 1 frontage. Phase 1 will also include: the neighborhood park and the development portions of the proposed project site east and north of Santa Fe on the north side of Tank Farm Road; a portion of the office uses at the southwest corner of Tank Farm and Santa Fe; the R-4 development at the southeast corner of Tank Farm and Santa Fe; the mixed-use portion of the proposed project in the west development area; and the fire station. Phase 2 includes the balance of the medical office uses and the balance of the professional office uses, the "District" uses, and a R&D building. Phase 2 circulation improvements would include the necessary widening and safety median for Tank Farm Road between the proposed project and Innovation Way, and the remainder of the Tank Farm Road frontage. Phase 3 will include completion of the public streets, the balance of the R&D uses, and the Manufacturing uses. Table 1 below shows a preliminary summary of the proposed project's phasing. Ultimate development of the proposed project will depend on future market conditions and absorption. Phasing will be subject to changes based on actual demand at the time of development. The Link Project Description Page 9 of 16 Table 1: Summary of Land Use by Phase (Residential: Units, Commercial: Square Feet) Projected commercial buildout under the existing land use plan (803,000 commercial square feet) was compared to the currently proposed plan (794,960 commercial square feet). The proposed plan would result in 4,540 less square feet of commercial area, while accommodating 725 multifamily dwelling units. As was noted in the introduction of this project description, the proposed project, with its land use mix that includes residential units, will have a jobs-housing ratio of 2.04, better meeting the General Plan’s requirements that new projects not exacerbate the jobs-housing imbalance. This is a marked im- provement to the existing site land use plan which would have a jobs-housing ratio of 7.25 that would significantly worsen the imbalance. RECREATION AND AMENITIES Public/Common Open Space o Area 12: Neighborhood Park As this area of the city continues to build out, the need for park facilities to serve residents be- comes more important. With the approval and eventual development of the two mixed-use, but primarily residential, projects at 600 and 650 Tank Farm Road to the immediate east, there will be more demand for community parks beyond the recreation amenities in each of these projects. The Damon-Garcia sports fields are located near this site, but this facility serves sports teams and does not provide the needed neighborhood and community park facilities called for by the City's Parks and Recreation Element to serve residents. While there will be a series of parks de- veloped to the southwest in the Avila Ranch development, these are outside of the neighbor- hood park service radius established in the Parks and Recreation Element. ln addition, much of the western portion of the Margarita Area Specific Plan (MASP) area has been developed, but without the public parks planned to support it which are located in the eastern portion of the MASP. Consequently, there is a need to develop neighborhood park facilities to serve the pro- ject's residents. Land Use 1 2 3 Total Multifamily Residential 725 - - 725 Retail/Office Mixed-Residential Medical Offices 79,531 57,638 - 137,169 Professional Offices 41,000 101,500 - 142,500 Retail/Office Mixed-Commercial 64,250 4,900 - 69,150 R&D/Retail (District)- 96,375 - 96,375 R&D/Light Manufacturing - 23,438 75,375 98,813 Light Manufacturing/Retail (Hangar)41,953 - - 41,953 Manufacturing - - 209,000 209,000 Total Residential 725 - - 725 Total Non-Residential 226,734 283,851 284,375 794,960 Phase The Link Project Description Page 10 of 16 To help address area needs, the proposed project includes a 2.1-acre park that would be dedi- cated to the City of San Luis Obispo and ultimately include different amenities. This park area is located to the southwest of the larger proposed R-4 residential area in the northeastern portion of the site. A second park site is identified adjacent to the stormwater basin just north of Tank Farm Road. As noted in describing the features of different areas of the proposed project, this park site is adjacent to a commercial area designated for restaurant retail uses and would in- clude a small dog park area. o Area 7: Stormwater Pond/Park The proposed project includes a stormwater basin in the in the western corner of the eastern portion of the development area just north of Tank Farm Road. The total area of the basin and adjacent park is 5.45 acres. o Area 10: Riparian Area Multi-family Area 2 is located in the southeast corner of the Santa Fe roundabout and borders Acacia Creek on its southeast side. The proposed development is adjacent to the Acacia Creek corridor will need to comply with the required riparian setback. There is 0.46 acres of riparian area that will be designated for Open Space/Conservation. TRANSPORTATION AND CIRCULATION Tank Farm Road o The AASP and Circulation Element describe Tank Farm Road as a 120-foot-wide Parkway Arterial with bike paths, bike lanes, landscaped center median, and two through lanes in each direction. The development plan includes special sections for different segments of Tank Farm Road, in- cluding a full 120-foot right of way along the frontages of the eastern development sites. Given environmental constraints associated with the conservation easement areas further to the west, different right of way configurations will likely be developed for the area between the east de- velopment sites and Innovation Way. In accordance with recent traffic studies and the update of the City’s traffic model and buildout projections, there will be one through lane in each direction along these areas with reduced rights of way. Based on preliminary studies, it is anticipated that this reduced area will have a 90-foot right of way, with a through lane in each direction, a Class I bike path on the north and on the south, Class II bike lanes, a five-foot swale/shoulder for drain- age, and an 8’-12’ safety median. Figures A-3 through A-5 (Attachment A) show the various features of Tank Farm Road. The precise location of Tank Farm Road, and the width of the vari- ous sections in the proposed project will be determined based on traffic and civil engineering studies to be conducted during the entitlement, design and environmental review phases. Santa Fe Road Improvements o The Santa Fe/Tank Farm roundabout will be constructed as part of the conditions of approval for the 600 Tank Farm project, including the eastern approach to the roundabout and the transi- tion/tapers to the west. Santa Fe will be designed in accordance with the new standard that was recently established in the AASP. Figures A-3 through A-4 (Attachment A) show the various features of Santa Fe Road. The Link Project Description Page 11 of 16 Transit o There are two proposed transit stops with shelters along the east-west portion of Santa Fe in the interior of the eastern development area. These stops will connect the proposed project to San Luis Obispo’s transit network via the proposed Prado Road connection to the north and Tank Farm Road directly to the south. See Figure A-4, the “Circulation Features: East” exhibit. Pedestrian and Bicycle Circulation o The eastern proposed project development area will implement sidewalks and Class IV bike paths along Santa Fe Road through the proposed project’s interior consistent with the AASP standard for Commercial Collectors. Additional pedestrian walkways and bike facilities will be provided in the interior of the proposed project as seen in Figure A-4 the “Circulation Features: East” exhibit. Tank Farm Road will include Class II bike lanes between Innovation Way and 500 feet west of Santa Fe Road (where these facilities merge with off-street Class IV or Class I paths). Tank Farm Road will also include a Class I multiuse trail (two-way bikes and ped path) on the north side. These facilities will also provide connectivity to other Class I bike paths shown in the Active Transportation Plan. Figures A-3 through A-5 (Attachment A) show the various fea- tures of Tank Farm Road. Airport Facilities o The proposed project site is north of San Luis Obispo County Airport. Because of its proximity to the airport, there are additional documents that regulate and provide guidance to development in this area. As was noted in the Project Introduction, the site is part of the Airport Area Specific Plan (AASP). The AASP is a City land use document that was originally adopted in 2005 and has been updated several times since then. It provides guidance on land use, circulation, develop- ment standards, design guidelines, and infrastructure. Another regulatory document that affects site development is the County Airport Land Use Plan (ALUP). The ALUP focuses on topics that relate to airport operations such as safety, noise, build- ing heights, and compliance with FAA regulations. An updated version of this document was adopted in 2021. The changes to the document were significant and have an impact on the types of uses that can be established at the proposed project site. The current ALUP includes safety zones consistent with the California Airport Land Use Planning Handbook that are used in most areas in the state near airports. All of the residential uses will be located in Zone 6. Figures 3 and A-10 show the ALUP safety zones’ relationship to the proposed project site and the land plan for the proposed project. The project consistency analysis will provide more insights and details about the proposed pro- ject’s compliance and consistency with the ALUP. The Link Project Description Page 12 of 16 SPECIAL PROJECT DESIGN FEATURES 1. Building energy efficiency standards that will enable the proposed project to comply with the “net zero” energy requirements and compliance with the City’s Reach Code. Electricity shall be the only energy source for the entirety of project operations including but not lim- ited to space conditioning, water heating, illumination, cooking appliances, and plug loads (exemptions to this requirement shall be limited to appliances in commercial kitchens, emergency backup generators, and medical end-uses that have no viable electric alterna- tive). 2. Enhanced pedestrian and bicycle connectivity, including ped and bike connectivity to exist- ing and proposed development at both east and west ends of Tank Farm Road. The pro- posed project will implement the City’s new raised “Class IV” bike lanes. A parking require- ment reduction/exception totaling 8 percent of the total statistical parking demand per Sec- tion 17.72.050 will be part of the requested entitlements, and is justified based on shared parking between the residential and commercial development (with peak residential parking in the evening and peak commercial parking in mid-day), car sharing, pedestrian and bike connections to and through properties to the east and west, proximity to convenience goods centers, onsite mixed use, and the renter preference program described below. 3. Special at-grade “speed table” pedestrian street crossings have also been included. These provide for traffic calming and a continuous walking experience. 4. Residential portions of the proposed project will include an onsite manager or contact who will be the first point of contact for any noise complaints. Residents will also be required to certify that they have completed an online training on airport operations, airport hazards and impacts, and acknowledgement that they will contact onsite management for noise concerns. 5. An avigation easement will be placed on the property per County and ALUP regulations. 6. The proposed project’s buildings will be arranged to diffuse sound, and to locate the most sensitive portions of the proposed project toward the rear in the northeast corner of the site. This will include orienting any outdoor activity and patio areas so that they are the least impacted by airport and traffic noise. 7. Per AASP Policy 4.5.3, all residential units shall be designed to limit the aircraft-related 24- hour, 10-second interval interior peak noise (Lmax) impacts to no more than 45 decibels, five decibels less than in Table 4 or the current ALUP. 8. The proposed project will implement a preference program for local workers. This strategy will capture, and house, those working east of Higuera, south of South/Santa Barbara, west of the railroad, and north of Crestmont Road. This will provide preference to those working at MindBody, the San Luis Obispo Regional Airport, Morabito Business Park, AeroVista Busi- ness Park, Sacramento Drive, and other south city Business Park areas. Like the Avila Ranch and San Luis Ranch projects, this will ensure that existing commuting employees are given first preference for housing, and that their commute trip length will be reduced, and that many home-work trip modes will be shifted from personal vehicles to biking or pedestrian The Link Project Description Page 13 of 16 modes. This preference program, however, will be focused on the south and southeast por- tions of the community to ensure the greatest reduction in vehicle miles traveled and to maximize the potential for ped and bike trips from the proposed project to work destina- tions. 9. As discussed in the preceding narrative about proposed parks, the two park areas and the dog park will address a noted lack of facilities in this part of town and serve new residents in the area. These facilities will serve as an important community benefit. 10. The proposed project includes a highly integrated system of Class I, Class II, Class III and Class IV bike facilities that provide obvious priority for this mode of transportation. Connec- tions from these facilities can be made to the offsite connections to the Serra Meadows bike path, the Avila Ranch bike path, and the connection to Damon-Garcia Sports Park through 600 Tank Farm Road. The applicant is also exploring additional recreational paths through the open space areas to augment the commuter facilities. The Link Project Description Page 14 of 16 CITY PROCESSING REQUIREMENTS Needed Entitlements o General Plan Amendment/Prezoning - To accommodate the planned changes to the City’s land use and zoning maps, applications will be submitted to amend the proposed zoning and land use maps to be consistent with the project development plan. o Circulation Element and AASP Circulation Amendments - These amendments will be needed to modify the Parkway Arterial Standard for Tank Farm Road to include several different cross sec- tions, layouts and right of way standards, which are dependent on the development context and environmental constraints at different locations. o AASP Amendments - Certain amendments will need to be processed to comply with the pro- posed Development Plan. o Active Transportation Plan Amendments - Certain amendments will need to be processed to comply with the Development Plan. o Affordable Housing Plan - An affordable housing plan will be prepared to demonstrate how the proposed project will comply with the requirements of the City’s inclusionary housing require- ments and outline any desired density bonuses. o Development Agreement - The applicant plans to have a development agreement approved by the City Council along with other entitlements. The development agreement will cover a wide variety of project components and topics including, but not limited to, infrastructure financing, affordable housing, and development plan regulations. o Annexation – The proposed project site is currently under county jurisdiction and will require annexation into the City of San Luis Obispo. This process will require authorization by the City Council and also include coordination and hearings with LAFCO. o CEQA Compliance - It is anticipated that compliance with CEQA will be met by the preparation of a Supplemental EIR to the Chevron Tank Farm Remediation and Development Project Final Environmental Impact Report (SCH #2009031001). This list of needed entitlements from the City does not include any permits or approvals from applicable federal, state, and local agencies that may be required for the proposed project and its land uses. COVENANT WITH DEED RESTRICTIONS The proposed project includes changes in proposed uses and other requirements from those evaluated in the 2013 FEIR and included in the Final Remedial Action Plan, San Luis Obispo Tank Farm (RAP), dated March 31, 2015, prepared by Avocet Environmental Inc. The Regional Water Quality Control Board (RWQCB) approved the RAP by letter dated April 15, 2015. A Supplemental Remedial Action Plan AOC #1-North Marsh Area (SRAP), dated May 2018, was prepared by Padre Associates, Inc. The SRAP was approved by the RWQCB in a letter dated June 28, 2018. A Covenant with Deed Restrictions predicated on those uses within the 2013 FEIR will be executed in the coming months. The Link Project Description Page 15 of 16 The proposed project will need to be evaluated by the RWQCB and in the Supplemental EIR review to ensure that it doesn't pose any unacceptable human health or ecological risks or, if needed, to establish mitigation measures with appropriate additional safeguards. It is anticipated that this would require one or more addenda to the risk assessment evaluations that were evaluated for the 2013 FEIR and the RAP. These additional risk assessment evaluations are currently underway at the direction of the appli- cant. Upon completion of these evaluations, the applicant will work with the RWQCB and current site owner to amend the covenant to ensure it does not restrict any of the land uses proposed in this appli- cation. The Link Project Description Page 16 of 16 Figures and Attachments Figure 1: Location Map Figure 2: AASP Land Use Map (existing) Figure 3: ALUP Safety Zones and Project Location Attachment A Figure A-1: Development Areas and Building Key Map Figure A-2: Development Areas and Development Potential Figure A-3: Circulation: Overall) Figure A-4: Circulation Features: East Figure A-5 Circulation Features: West Figure A-6: Proposed Land Use Designations (Zoning): Overall Figure A-7: Proposed Land Use Designations (Zoning): East Figure A-8: Proposed Land Use Designations (Zoning): West Figure A-9: Phasing Figure A-10: Land Plan and ALUP Safety Zones Attachment B Plan Data by Area and Building Attachment C Phasing and Buildout Attachment D Project Imagery and Background Attachment E General Plan, AASP and Community Design Guidelines Consistency Analysis Attachment F Airport Land Use Plan Consistency Analysis LAND USE | 4-5 Attachment A Development Plan and Circulation THE LINK 2740-01-CU22 02 AUGUST 2022 OVERALL BIRDSEYE NTS THE LINK 2740-01-CU22 04 AUGUST 2022 ILLUSTRATIVE SITE PLAN - OVERALL 0’260’130’390’ TANK FARM ROAD S ANTA FE ROAD RECREATIONAL PATH AVILA RANCH CONNECTOR C L A S S 1 P A TH PARKS / PONDS (CS) FIRE STATION NEIGHBORHOOD PARK INDUSTRIAL (CS) MULTIFAMILY 1 & 2 (R-4) DISTRICT FLEX SPACE (CS) LAND USE LEGEND HANGAR COMMERCIAL (CS) RETAIL (C-C/MU) MIXED USE (C-C/MU) MEDICAL OFFICES (BP-C-S) PROFESSIONAL OFFICES (BP-C-S) RESEARCH AND DEVELOPMENT (CS) THE LINK 2740-01-CU22 04 AUGUST 2022 ILLUSTRATIVE SITE PLAN - ENLARGEMENT AREA (EAST) NTS TANK FARM ROAD S ANTA FE ROAD PARKS / PONDS (CS) FIRE STATION NEIGHBORHOOD PARK INDUSTRIAL (CS) MULTIFAMILY 1 & 2 (R-4) DISTRICT FLEX SPACE (CS) LAND USE LEGEND HANGAR COMMERCIAL (CS) RETAIL (C-C/MU) MIXED USE (C-C/MU) MEDICAL OFFICES (BP-C-S) PROFESSIONAL OFFICES (BP-C-S) RESEARCH AND DEVELOPMENT (CS) CLASS 1 MULTI-USE PATH RECREATIONAL PATH AVILA RA N C H C O N N E C TOR CLASS 1 PATH Covelop: The LinkJuly 11, 2022 Covelop: The Link A-1Peck Planning and Development Development Areas and Buildings Key Map Figure 1 9 4 3 2 8 7 6 5 1211 10 14 13 1615 17 18 19 20 22 21 26252423 27 28 29 Area 11: Mixed Use (C-C/MU) Area 1: Mixed Use (C-C/MU) Area 2: Hangar Commercial (CS) Area 3: Professional Offices (BP-C-S) Area 4: District Flex Space (CS) Area 5: Research and Development (CS) Area 6: Industrial (CS) Area 7: Park/Pond (CS) Area 8: Multifamily 1 (R-4) Area 9: Medical Offices (BP-C-S) Area 10: Multifamily 2 (R-4) Area 12: Neighborhood Park Area 13: Fire Station Area 14: Overflow Parking (CS) See Figure A-2 and Attachment B for a statistical summary of building areas, parking and other site data for each subarea and each building. See Figure A- 10 for ALUP Safety Zones. RRM Design Group Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road"B" Street "A" Street"C" Street 30 31 32 33 34 35 36 37 Covelop: The LinkJuly 11, 2022 Covelop: The Link A-2 Commercial Mixed Use 21,375 SF Office/Services 21,375 SF Retail 100 Residential Units (75 DU) Parking Provided: 240 Parking Required: 242 Hangar Commercial 41,950 SF Retail (10%)/Man (90%) Parking Provided: 135 Parking Required: 129 Multifamily 1 350 Units (245 du) DU/Net Acre: 23.9 Parking Provided: 557 Parking Required: 555 Multifamily 2 50 Units (37.5 DU) DU/Net Acre: 21.6 Parking Provided: 50 Parking Required: 60 Offices (Medical) 137,200 SF Parking Provided: 597 Parking Required: 610 Office Core 142,500 SF Parking Provided: 424 Parking Required: 438 Retail/Eating/Drinking 4,900 SF Parking Provided: 10 Parking Required: 16 Research and Development/Light Manufacturing 98,800 SF Parking Provided: 257 Parking Required: 198 The District 48,200 SF Retail 48,200 SF R&D Parking Provided: 272 Parking Required: 148 Industrial w/Office 209,000 SF Parking Provided: 270 Parking Required: 279 Office/Retail Mixed 10,750 SF Office (Street Front) 10,750 SF Retail (Street Front) 225 Units (163 DU) DU/Net Acre: 28.03 Parking Provided: 367 Parking Required: 381 City Park FS Development Areas Overflow/Surplus Parking Spaces: 88 Peck Planning and Development Multifamly Residential R&D/Light Manufacturing R&D/Retail (District) Retail/Office Mixed Professional Offices Medical Offices Light Manufacturing/Retail (Hangar) Manufacturing FigureRRM Design Group Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road"B" Street "A" Street"C" Street Covelop: The LinkJuly 11, 2022 Covelop: The Link A-3 City Park FS Parkway Arterial: A Parkway Arterial: B EB Left Turn (In Only) Right In/Right Out Truck Access (Private) Local Street (Public) w/Class II Bike Lanes Local Street (Public) w/Class III Bike Lanes Santa Fe per (Revised) AASP Standard Class I to Class II Ramps Connection to Avila Ranch Class I Class I Bike Paths Class II Bike Lanes Class I Bike Paths Ped Crossing w/Enhanced Crosswalk Transit Stops w/Shelter and Rider Amenities Connection to Hoover Class I Santa Fe per (Revised) AASP Standard Continuation of Center Turn Lane Right In/Right Out Dedicated Right Turn Two Lanes Circulation: Overall 422'423' Ped, Bike and Emergency Access Only Class IV Bike Path 507'619' 1127' 2911' Peck Planning and Development 0 250 500 ft Multifamly Residential R&D/Light Manufacturing R&D/Retail (District) Retail/Office Mixed Professional Offices Medical Offices Light Manufacturing/Retail (Hangar) Manufacturing Road Cross Sections and Locations Preliminary Only Subject to Change per Further Studies FigureRRM Design Group Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road"B" Street "A" Street"C" Street Covelop: The LinkJuly 11, 2022 Covelop: The Link A-4 Class IV Bike PathsClass II Bike Lanes On Interior Public Street Center Turn Lane Class III Bike Lane (Shared) Class IV Connection To Hoover Rd Class I Circulation Features: East Transit Stops with Shelters and Rider AmenitiesClass III Bike Lane Connection to 2-Way CLass I to 650 Tank Farm and Damon Garcia Sports Park Dedicated RT Lane EB Left Turn In Peck Planning and Development 0 250 500 ft FigureRRM Design Group Covelop: The LinkJuly 11, 2022 Covelop: The Link A-5 Class I Bike Paths Class II Bike Lanes Circulation Features: West Continuous Center Left Turn Lanes Connection to Avila Ranch Bike Path Dedicated RT Lane Peck Planning and Development 0 250 500 ft FigureRRM Design Group Covelop: The LinkJuly 11, 2022 Covelop: The Link A-6Proposed Land Use Desigations (Zoning): Overall Open Space/Conservation (C/OS) Open Space/Conservation (C/OS) Commercial-MU (C-C/MU) Commercial Mixed Use (C-C/MU) Multifamily (R-4)Office-Medical (BP-C-S) Retail/ Manu (C-S) Professional Office (BP-C-S) Park (PF) Multiufamily (R-4) Public (PF) Industrial (C-S) R&D/Light Manu. (C-S) R&D/Retail (CS) Parking (C-S) Ponding (C-S) Peck Planning and Development 0 250 500 ft Multifamly Residential R&D/Light Manufacturing R&D/Retail (District) Retail/Office Mixed Professional Offices Medical Offices Light Manufacturing/Retail (Hangar) Manufacturing (C-S) FigureRRM Design Group Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road"B" Street "A" Street"C" Street Covelop: The LinkJuly 11, 2022 Covelop: The Link A-7Proposed Land Use Desigations (Zoning): East Office (Medical) (BP-C-S) R&D/Light Manufacturing (C-S) Professional Offices (BP-C-S) Hangar Retail/Manu. (C-S) The District R&D/Retail (CS) Commercial Mixed Use (C-C/MU) Manufacturing (C-S) Fire Station (PF) Multifamily (R-4) Park (PF) Commercial (C-S) Park (C-S) Parking (C-S) Peck Planning and Development 0 250 500 ft Multifamily (R-4) FigureRRM Design Group Covelop: The LinkJuly 11, 2022 Covelop: The Link A-8Proposed Land Use Desigations/Zoning: West Commercial Mixed Use (C-C/MU) Peck Planning and Development 0 250 500 ft FigureRRM Design Group Covelop: The LinkAugust 5, 2022 Covelop: The Link A-9August 5, 2022 Open Space/Conservation Open Space/Conservation Com-MU Com-MU R-4Office-Medical Retail/ ManuOffice Park R-4 PublicIndustrial R&D/Light Manu. R&D/Retail Parking Phasing 1 1 1 2 2 2 Peck Planning and Development 1 0 250 500 ft Figure 1 RRM Design Group See Attachment C for buildout and absorption by Phase. 1 Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road1 1 3 July 8, 2022 Peck Planning and Development Safety Zone 3 Safety Zone 2 RPZ Safety Zone 6 Safety Zone 6 Covelop: The LinkLand Plan and ALUP Safety Zones FigureRRM Design Group A-10 Attachment B Plan Data by Area and Building Reference Number (See Figure A‐1)Use Area/UsesGround FloorFloorsTotal Floor AreaDwelling UnitsCommercial Square FootageParking ProvidedCity Parking Requirement w/DiscountParking Required (Residential)Parking Required (Commercial)Total Parking Required Area Units/Acre Density Units/Unit Density UnitsDensity Units/AcreFARArea 1Mixed UseBldg 1 Residential Mixed Use23,500 4.00 94,000 72 23,500 195 97 59 156 Bldg 2 Residential Mixed Use9,250 4.00 37,000 28 9,250 45 38 23 61 Bldg 3 Retail10,000 1.00 10,000 10,000 25 25 Mixed Use Subtotal 42,750 141,000 100 42,750 240 ‐ 135 107 242 3.86 25.9 0.750 75.0 19.4 0.84 Area 2HangarBldg 4 Retail/Light Manufacturing Mixed14,350 1.25 17,938 22,422 65 325 69 69 0.87 0.47 Bldg 5 Retail/Light Manufacturing Mixed12,500 1.25 15,625 19,531 70 325 60 60 0.80 0.45 Hangar Use Subtotal 26,850 33,563 ‐ 41,953 135 ‐ 129 129 1.67 0.46 Office Core GroupArea 3Office 1Bldg 6 Office Mixed10,250 2.00 20,500 20,500 60 325 63 63 1.03 0.46 Bldg 7 Office Mixed10,250 2.00 20,500 20,500 60 325 63 63 1.03 0.46 Bldg 8 Office Mixed11,000 2.50 27,500 27,500 75 325 85 85 1.20 0.53 Bldg 9 Office Mixed11,000 2.50 27,500 27,500 75 325 85 85 1.20 0.53 Bldg 10 Office Mixed15,500 3.00 46,500 46,500 154 325 143 143 1.82 0.59 Office Core Subtotal58,000 142,500 142,500 424 438 438 6.28 0.52 DistrictArea 4District Flex SpaceBldg 11 RD/Retail (50/50)13,750 1.50 20,625 20,625 68 650 32 32 1.02 0.47 Bldg 12 RD/Retail (50/50)15,500 1.50 23,250 23,250 68 650 36 36 1.02 0.52 Bldg 15 RD/Retail (50/50)19,000 1.50 28,500 28,500 68 650 44 44 1.02 0.64 Bldg 16 RD/Retail (50/50)16,000 1.50 24,000 24,000 68 650 37 37 1.02 0.54 District Subtotal63,750 1.50 96,375 ‐ 96,375 272 650 148 148 4.07 0.54 Research and DevelopmentArea 5Research and DevelopmentBldg 17 RD/Light Man (50/50)18,750 1.25 23,438 23,438 62 500 47 47 0.80 0.67 Bldg 18 RD/Light Man (50/50)16,750 1.25 20,938 20,938 60 500 42 42 0.76 0.63 Bldg 14 RD/Light Man (50/50)14,500 1.25 18,125 18,125 31 500 36 36 0.70 0.59 Bldg 19 RD/Light Man (50/50)15,250 1.25 19,063 19,063 31 500 38 38 0.77 0.57 Bldg 13 RD/Light Man (50/50)13,800 1.25 17,250 17,250 73 500 35 35 1.50 0.26 RD/Light Man Subtotal79,050 98,813 98,813 257 198 198 4.06 0.56 IndustrialArea 6Industrial w/Office (80/20)Bldg 20 Industrial/Service CommercialBldg 21 Industrial/Service CommercialBldg 22 Industrial/Service CommercialIndustrial Subtotal209,000 1.00 209,000 209,000 270 750 279 279 11.71 0.41 Park/PondArea 7Park Pond Park K Dog Park4,900 1.00 4,900 4,900 10 300 16 16 0.64 0.18 Pond 3.37 Park‐ 30 1 ‐ ‐ 0.89 Park/Pond Subtotal4,900 1.00 4,900.00 ‐ 4,900.00 40 ‐ 16 16 4.90 ‐ ‐ ‐ ‐ 0.18 Area 8Multifamily 1Multifamily350 557 1.50 525 525 10.26 34.1 0.700 245.0 23.9 0.76 Area 9Medical OfficesBldg 23 Medical Offices10,975 1.50 16,463 16,463 80 225 73 73 1.38 0.27 Bldg 24 Medical Offices23,529 1.75 41,176 41,176 122 225 183 183 2.11 0.45 Bldg 25 Medical Offices19,732 1.75 34,531 34,531 208 225 153 153 2.41 0.33 Bldg 26 Medical Offices22,500 2.00 45,000 45,000 187 225 200 200 2.38 0.43 Med Office Subtotal76,736 137,169 137,169 597 225 610 610 8.28 0.38 Area 10Multifamily 2Multifamily50 50 1.20 60 60 1.74 28.7 0.750 37.5 21.55 0.64 Area 11Mixed UseBldg 27 Residential Mixed Use15,500 3 46,500 34 10,750 325 4633 79Bldg 28 Residential Mixed Use15,500 3 46,500 34 10,750 325 4633 79Bldg 29 Multifamily37,500 4 150,000 157 ‐ 212212Mixed Use Subtotal68,500 243,000 225 21,500 367 30466 370 5.82 38.7 0.725 163.1 28.030.96 Other Uses/AreasArea 12Public Park1.96 Public Roads15.40 Area 13Fire Station8,850 1 8,850 11 1.32 Area 14Overflow Parking80 0.74 Open Space/Conservation250.30 Other Uses/Areas Subtotal 8,850 1 8,850 ‐ ‐ 91 ‐ ‐ ‐ ‐ 269.72 ‐ ‐ ‐ ‐ ‐ Total1,115,169 725 794,960 3,300 1,024 1,991 3,015 332.37 521 0.54 Attachment C Phasing Data Buildout Retail, Commercial, Office and Industrial Residential Estimated Annual Absorption Rate 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036Planning and EngineeringDesignDevelopment/Offsites/OnsitesPhase 1Multifamily Residential 725 150 12.5 per Month per AR Market Study150 150 150 150 125 Medical Offices79,531 15,000 (25% of Annual Local SLO Demand)15,000 15,000 15,000 15,000 15,000 4,531 Professional Offices41,000 10,000 (25% of Annual Local SLO Demand)10,000 10,000 10,000 11,000 Retail/Office Mixed64,250 10,000 (50% of Neighborhood Demand)20,000 7,500 7,500 7,500 7,500 14,250 R&D/Retail (District)10,000 R&D/Light Manufacturing10,000 Light Manufacturing/Retail (Hangar)41,953 7,500 7,500 7,500 7,500 7,500 7,500 4,453 Manufacturing50,000 (35% of Annual Local SLO Demand)Subtotal‐Phase 1226,734 725 ‐ 52,500 40,000 40,000 41,000 30,000 23,234 ‐ ‐ ‐ ‐ Phase 2Multifamily Residential 150 12.5 per Month per AR Market StudyMedical Offices57,638 15,000 (25% of Annual Local SLO Demand)15,000 15,000 15,000 12,638 Professional Offices101,500 10,000 (25% of Annual Local SLO Demand)10,000 10,000 10,000 10,000 Retail/Office Mixed4,900 10,000 (50% of Neighborhood Demand)4,900 R&D/Retail (District)96,375 10,000 10,000 10,000 10,000 10,000 R&D/Light Manufacturing23,438 10,000 10,000 13,438 Light Manufacturing/Retail (Hangar)7,500 Manufacturing(35% of Annual Local SLO Demand)Subtotal‐Phase 2283,851 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 39,900 45,000 48,438 32,638 Phase 3Multifamily Residential 150 12.5 per Month per AR Market StudyMedical Offices15,000 (25% of Annual Local SLO Demand)Professional Offices10,000 (25% of Annual Local SLO Demand)Retail/Office Mixed10,000 (50% of Neighborhood Demand)R&D/Retail (District)10,000 R&D/Light Manufacturing75,375 10,000 Light Manufacturing/Retail (Hangar)7,500 Manufacturing209,000 50,000 (35% of Annual Local SLO Demand)Subtotal‐Phase 3284,375 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ TotalMultifamily Residential ‐ 725 150 12.5 per Month per AR Market Study‐ 150 150 150 150 125 ‐ ‐ ‐ ‐ ‐ Medical Offices137,169 ‐ 15,000 (25% of Annual Local SLO Demand)‐ 15,000 15,000 15,000 15,000 15,000 4,531 15,000 15,000 15,000 12,638 Professional Offices142,500 ‐ 10,000 (25% of Annual Local SLO Demand)‐ 10,000 10,000 10,000 11,000 ‐ ‐ 10,000 10,000 10,000 10,000 Retail/Office Mixed69,150 ‐ 10,000 (50% of Neighborhood Demand)‐ 20,000 7,500 7,500 7,500 7,500 14,250 4,900 ‐ ‐ ‐ R&D/Retail (District)96,375 ‐ 10,000 ‐ ‐ ‐ ‐ ‐ ‐ ‐ 10,000 10,000 10,000 10,000 R&D/Light Manufacturing98,813 ‐ 10,000 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 10,000 13,438 ‐ Light Manufacturing/Retail (Hangar)41,953 ‐ 7,500 ‐ 7,500 7,500 7,500 7,500 7,500 4,453 ‐ ‐ ‐ ‐ Manufacturing209,000 ‐ 50,000 (35% of Annual Local SLO Demand)‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ Total794,960 725 ‐ 52,500 40,000 40,000 41,000 30,000 23,234 39,900 45,000 48,438 32,638 Building Construction and OccupancyPlanning and DesignBasis of AbsorptionTotal UnitsPlanning and EntitlementsPhase 1 (See Figure A‐9)Phase 2 (See Figure A‐9) Buildout Retail, Commercial, Office and Industrial Residential Estimated Annual Absorption Rate Planning and EngineeringDesignDevelopment/Offsites/OnsitesPhase 1Multifamily Residential 725 150 Medical Offices79,531 15,000 Professional Offices41,000 10,000 Retail/Office Mixed64,250 10,000 R&D/Retail (District)10,000 R&D/Light Manufacturing10,000 Light Manufacturing/Retail (Hangar)41,953 7,500 Manufacturing50,000 Subtotal‐Phase 1226,734 725 Phase 2Multifamily Residential 150 Medical Offices57,638 15,000 Professional Offices101,500 10,000 Retail/Office Mixed4,900 10,000 R&D/Retail (District)96,375 10,000 R&D/Light Manufacturing23,438 10,000 Light Manufacturing/Retail (Hangar)7,500 ManufacturingSubtotal‐Phase 2283,851 ‐ Phase 3Multifamily Residential 150 Medical Offices15,000 Professional Offices10,000 Retail/Office Mixed10,000 R&D/Retail (District)10,000 R&D/Light Manufacturing75,375 10,000 Light Manufacturing/Retail (Hangar)7,500 Manufacturing209,000 50,000 Subtotal‐Phase 3284,375 ‐ TotalMultifamily Residential ‐ 725 150 Medical Offices137,169 ‐ 15,000 Professional Offices142,500 ‐ 10,000 Retail/Office Mixed69,150 ‐ 10,000 R&D/Retail (District)96,375 ‐ 10,000 R&D/Light Manufacturing98,813 ‐ 10,000 Light Manufacturing/Retail (Hangar)41,953 ‐ 7,500 Manufacturing209,000 ‐ 50,000 Total794,960 725 Building Construction and OccupancyPlanning and DesignTotal Units2037 2038 2039 2040 2041 2042 2043 2044 Total Check Total‐ ‐ 725 725 79,531 79,531 41,000 41,000 64,250 64,250 ‐ ‐ ‐ ‐ 41,953 41,953 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 226,734 226,734 ‐ ‐ ‐ ‐ 57,638 57,638 10,000 10,000 10,000 10,000 10,000 11,500 101,500 101,500 4,900 4,900 10,000 10,000 10,000 10,000 16,375 96,375 96,375 23,438 23,438 ‐ ‐ ‐ ‐ 20,000 20,000 20,000 20,000 26,375 11,500 ‐ ‐ 283,851 283,851 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 10,000 10,000 10,000 10,000 10,000 10,000 10,000 5,375 75,375 75,375 ‐ ‐ 50,000 50,000 50,000 59,000 209,000 209,000 10,000 10,000 10,000 60,000 60,000 60,000 69,000 5,375 284,375 284,375 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 725 725 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 137,169 137,169 10,000 10,000 10,000 10,000 10,000 11,500 ‐ ‐ 142,500 142,500 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 69,150 69,150 10,000 10,000 10,000 10,000 16,375 ‐ ‐ ‐ 96,375 96,375 10,000 10,000 10,000 10,000 10,000 10,000 10,000 5,375 98,813 98,813 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ 41,953 41,953 ‐ ‐ ‐ 50,000 50,000 50,000 59,000 ‐ 209,000 209,000 30,000 30,000 30,000 80,000 86,375 71,500 69,000 5,375 794,960 794,960 Phase 3 (See Figure A‐9)Total Attachment D Project Background and Imagery Attachment E General Plan, AASP and Community Design Guidelines Consistency Analysis The Link General Plan, AASP and Community Design Guidelines Consistency Analysis Consistency with General Plan Land Use Element (LUE) LUE Section Goal/Policy How Project Complies Environment Goal 10 Support statewide and regional efforts to create more sustainable communities, reduce green- house gas emissions, and develop transportation systems that support all modes of circulation. The mix of proposed land uses in a walkable environment will minimize trips and improves the City’s job-hous- ing imbalance. The project does not ex- ceed the current jobs-housing balance in the community, and includes bike and pedestrian modes of transportation in conformance with the Active Trans- portation Plan. The project will also be all-electric, in conformance with the City’s Climate Action Plan and GHG “REACH” goals. Society & Econ- omy Goal 15 Emphasize more productive use of existing com- mercial buildings and land areas already commit- ted to urban development. The proposed development areas are already committed to development in the City and County General Plans. con- sistent with the existing areas identified for urban development. New zoning categories provide for the range of uses currently desired and in a more efficient development pattern. Society & Econ- omy Goal 21 Actively seek ways to provide housing which is affordable to residents with very low, low, and moderate incomes, within existing neighbor- hoods and within expansion areas. The project will provide a mix of hous- ing units, some of which may be deed- restricted affordable units, and other market rate units, such as the studios and one-bedroom units, which are af- fordable by design. The project will comply with the City’s Inclusionary Housing Ordinance. Society & Econ- omy Goal 28 Provide a wide range of parks and sports and recreational facilities for the enjoyment of our citizens. The project will provide recreational amenities within housing developments as well as public park space which ad- dresses an existing void in the neighbor- hood. City Form Goal 32 Maintain the town's character as a small, safe, comfortable place to live, and maintain its rural setting, with extensive open land separating it from other urban development. The project will include a synergistic mix of land uses that is consistent with other parts of the City and will maintain a large central open space area con- sistent with the City’s natural resources goals. City Form Goal 34 Where appropriate, create compact, mixed-use neighborhoods that locate housing, jobs, recrea- tion, and other daily needs in close proximity to The project includes a mix of office, in- dustrial, retail and residential land uses that will provide for housing and busi- nesses with services in close proximity The Link 2 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies one another, while protecting the quality of life in established neighborhoods. to one another as well as are housing in close proximity to other employers in south San Luis Obispo The addition of residential units in the western develop- ment area (Area 11) will place new resi- dential units close to neighborhood ser- vices at Higuera Plaza and the Public Market, and employment areas in the Hind and Granada Business Parks. Growth Manage- ment Policy 1.5 Jobs/Housing Relationship: The gap between housing demand (due to more jobs and college enrollment) and supply should not increase. The existing General Plan designations and County zoning for the property re- sults in a jobs-housing ratio in excess of 7.25:1. By adding residential units as now permitted by the updated and amended Airport Land Use Plan, some of which are affordable units, this pro- ject helps reduce the gap between housing demand and supply, and will re- sult in a project jobs-housing ratio of 2.21 meeting the General Plan’s re- quirements that new projects not exac- erbate the jobs-housing imbalance. Growth Manage- ment Policy 1.10.2 Means of Protection: The City shall require that open space be preserved either by dedication of permanent easements or transfer of fee ownership to the City, the County, or a re- sponsible, nonprofit conservation organization. The intervening area between the de- velopment areas is identified as Conser- vation/Open Space on the land use map and will remain as open space in a con- servation easement. The project would result in total parks and open space ar- eas totaling 257 acres, over 77 percent of the total project site area. Growth Manage- ment Policy 1.11.3 Phasing Residential Expansions: Before a residen- tial expansion area is developed, the City must have adopted a specific plan or a development plan for it. Such plans for residen- tial expansion projects will provide for phased development, consistent with the population growth outlined in Table 3, and taking into ac- count expected infill residential development. The project site is not specifically called out as an additional expansion area in the LUE, but is part of the original ex- pansion area for the Airport Area Spe- cific Plan (AASP). The AASP, its subse- quent amendment to address the pro- ject, and the inclusion of special devel- opment regulations and growth man- agement requirements in a Develop- ment Agreement will satisfy LUE Policy 1.11.3. The project’s adjacency to exist- ing employment centers and commer- cial services qualifies the project as an “infill” project. The project will move forward with a development plan and annexation to the City along with other entitlements. Residential development will be part of the project’s Phase 1 and The Link 3 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies permit approvals for development will consider City population growth projec- tions. The project will result in the de- velopment of 725 dwelling units which are expected to be built out and occu- pied at a rate of 150 dwelling units per year between 2027 and 2032. Average annual residential growth rate between 2015 and 2021 was estimated to be 0.81% per year in the 2021 General Plan Status Report, approximately 398 units below the 1% growth cap. Projected to 2035, this growth rate would result in 24,454 units by 2035, 1,304 units below the 25,762 dwelling units shown in Ta- ble 3. The project would represent a lit- tle more than half (55.6%) of the gap between the current rate of growth and the maximum 1% permitted by the Land Use and Circulation Element. The Growth Management Policy 1.11.4 Nonresidential Growth Rates: Each year, the City Council shall evaluate the actual increase in non- residential floor area over the preceding five years. The Council shall consider establishing lim- its for the rate of nonresidential development if the increase in nonresidential floor area for any five-year period exceeds five percent. Any limits so established shall not apply to: A. Changed operations or employment levels, or relocation or ownership change, of any business existing within the City at the time the limit is set; B. Additional nonresidential floor area within the Downtown core (Figure 4); C. Public agencies; and D. Manufacturing, light industrial, research busi- nesses, or companies providing a significant number of head of household jobs. Projected commercial buildout for the project site has already been accounted for in City plans. A total of 803,000 com- mercial square feet was anticipated under the existing land use plan. Pro- posed commercial development under the currently proposed plan is 794,960 square feet which is slightly below origi- nal build-out projections. Further, of- fice, medical office and industrial land uses qualify as uses that provide a sig- nificant number of head of household jobs and are exempt under LUCE Policy 1.11.4 D. Growth Manage- ment Policy 1.13.3 Annexation Purpose and Timing: The City may use annexation as a growth management tool, both to enable appropriate urban development and to protect open space. Areas within the ur- ban reserve line which are to be developed with urban uses should be annexed before urban de- velopment occurs. The City may annex an area long before such development is to occur, and the City may annex areas which are to remain permanently as open space. An area may be The project includes annexation to the City and development will build out in phases over a multi-year timeframe. The details of the phasing plan take into account absorption rates and the devel- opment of infrastructure and street im- provements. The Link 4 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies annexed in phases, consistent with the city-ap- proved specific plan or development plan for the area. Phasing of annexation and development will reflect topography, needed capital facilities and funding, open space objectives, and existing and proposed land uses and roads. Growth Manage- ment Policy 1.13.5 Annexation in Airport Area: Properties in the Air- port Area Specific Plan may only be annexed if they meet the following criteria: A. The property is contiguous to the existing city limits; and B. The property is within the existing urban re- serve line; and C. The property is located near to existing infra- structure; and D. Existing infrastructure capacity is available to serve the proposed development; and E. A development plan for the property belong- ing to the applicant(s) accompanies the applica- tion for annexation; and F. The applicant(s) agree to contribute to the cost of preparing the specific plan and construct- ing area-wide infrastructure improvements ac- cording to a cost -sharing plan maintained by the City. The project complies with all of the noted criteria. It is contiguous to 600 Tank Farm Road and the Garcia Ranch properties, both of which are in the City; it is in the Urban Reserve line as shown on Figure 2 in the LUE; the prop- erty has sewer and water lines adjacent to the development properties and will complete infrastructure needed for the development of other properties in the vicinity; a development plan and devel- opment agreement are being developed to guide development; and, much- needed area infrastructure will be de- veloped with the project and the appli- cant will participate in cost-sharing with the City to finance improvements.. The applicant is processing a develop- ment plan (including amendment of the AASP and other entitlements consistent with City requirements. Growth Manage- ment Policy 1.13.8 Open Space: The City shall require that each an- nexation help secure permanent protection for areas designated Open Space, and for the habi- tat types and wildlife corridors within the annex- ation area that are identified in the Conservation and Open Space Element. Proper- ties, which are both along the urban reserve line and on hillsides, shall dedicate land or ease- ments for about four times the area to be devel- oped (developed area includes building lots, roads, parking and other paved areas, and set- backs required by zoning). (See also Policy 6.4 and Policies 6.4.1 – 6.4.7). The following stand- ards shall apply to the indicated areas: A. Airport Area Specific Plan properties shall se- cure protection for any on-site resources as iden- tified in the Conservation and Open Space Ele- ment. These properties, to help maintain the greenbelt, shall also secure open space protec- tion for any contiguous, commonly owned land outside the urban reserve. If it is not feasible to On-site resources include the interven- ing area between the development ar- eas which are identified as Conserva- tion/Open Space on the land use map. Consistent with AASP policies and guid- ance, 257 acres of the site 332 acres will remain as open space and will be pro- tected through a conservation ease- ment. The Link 5 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies directly obtain protection for such land, fees in lieu of dedication shall be paid when the prop- erty is developed, to help secure the greenbelt in the area south of the City's southerly urban re- serve line. Growth Manage- ment Policy 1.13.9 Costs of Growth: The City shall require the costs of public facilities and services needed for new development be borne by the new development, unless the community chooses to help pay the costs for a certain development to obtain community-wide benefits. The City shall consider a range of options for financing measures so that new development pays its fair share of costs of new services and facilities which are required to serve the project and which are reasonably re- lated to the new growth attributable to the de- velopment. Details of project financing will be pro- vided to show how costs for public facil- ities and services will be addressed. Cost-sharing between the applicant and City will be a component of this infra- structure financing plan and pro-forma. The proposed mix of land uses would generate approximately $16.3 million in traffic impact fees, $6.5 million greater than that estimated for the existing planned land uses. Furthermore, the project would generate approximately $3.5 million in park fees and create new park areas in a portion of the commu- nity without any neighborhood or com- munity park facilities. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.2.3 Neighborhood Traffic: Neighborhoods should be protected from intrusive traffic. All neighbor- hood street and circulation improvements should favor pedestrians, bicyclists, and local traffic. Vehicle traffic on residential streets should be slow. To foster suitable traffic speed, street design should include measures such as narrow lanes, landscaped parkways, traffic circles, textured crosswalks, and, if necessary, stop signs, speed humps, bollards, and on-street parking and side- walks. Residential components of the project will be served by local streets or private driveways that limit traffic and are de- signed for low speeds. Tank Farm Road and Santa Fe Road will be designed per the LUCE’s mode priority matrix. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.2.4 Neighborhood Connections: The City shall pro- vide all areas with a pattern of streets, pedes- trian network, and bicycle facilities that promote neighborhood and community cohe- siveness. There should be continuous sidewalks or paths of adequate width, connecting neigh- borhoods with each other and with public and commercial services and public open space to provide continuous pedestrian paths throughout the city. Connectivity to nearby community facilities (such as parks and schools), open space, and supporting commercial areas shall also be enhanced, but shall not be done in a method that would increase cut-through traffic. (See also the Circulation Element.) The project area will have a hierarchy of street improvements including the Park- way Arterial - Tank Farm Road and the commercial collector - Santa Fe, as well as local public streets identified as Streets “A”, “B” and “C” on the develop- ment plan. All proposed roadways will include bike paths or lanes, sidewalks, and vehicle traffic buffers. The street improvements included in the project will enhance and improve areawide cir- culation. The Link 6 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.2.6 Neighborhood Characteristics: The City shall pro- mote livability, quiet enjoyment, and safety for all residents. Characteristics of quality neighborhoods vary from neighborhood to neighborhood, but often include one or more of the following characteristics: ▪ A mix of housing type styles, density, and af- fordability. ▪ Design and circulation features that create and maintain a pedestrian scale. ▪ Nearby services and facilities including schools, parks, retail (e.g., grocery store, drug store), restaurants and cafes, and com- munity centers or other public facilities. ▪ A tree canopy and well-maintained land- scaping. ▪ A sense of personal safety (e.g., low crime rate, short police and emergency response times). ▪ Convenient access to public transportation. ▪ Well-maintained housing and public facili- ties. The proposed project will add 725 multi-family housing units. There will be a variety of unit types, including studios, one-bedroom units and two-bedroom units, generally of smaller sizes, with an emphasis on rental units. Units will within walking distance (660 linear feet) of a public park, and will have private and common outdoor use areas. The mixed-use nature of the development area will benefit residents by providing housing within walking or biking dis- tance (no more than 2.5 miles) of exist- ing employment centers. There is also 150,000 SF of neighborhood commer- cial uses within one-half mile of the east development areas and 125,000 SF of neighborhood commercial uses within one-half mile of the west development area. A transit stop with amenities (bus shelter, time boards, etc.) is planned for the Santa Fe Road. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.2.7 Neighborhood Enhancement: The City shall pro- mote infill development, redevelopment, reha- bilitation, and adaptive reuse efforts that contribute positively to existing neighborhoods and surrounding areas. The City of San Luis Obispo has a com- pact urban form and limited areas to ac- commodate new development. Given recent development patterns and changes in City and County land use plans and development regulations, this area is now viewed as an infill develop- ment area. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.1 Residential Location, Uses, and Design: Mixed Uses and Convenience. The City shall promote a mix of compatible uses in neighborhoods to serve the daily needs of nearby residents, includ- ing schools, parks, churches, and convenience re- tail stores. Neighborhood shopping and services should be available within about one mile of all dwellings. When nonresidential, neighborhood- serving uses are developed, existing housing shall be preserved, and new housing added where possible. If existing dwellings are removed for such uses, the development shall include replacement dwell- ings (no net loss of residential units). The mix of proposed uses in the project will complement the commercial, em- ployment, and residential uses now planned in the vicinity of the site. The project addresses housing, employ- ment, and service needs in the commu- nity through a combination of design excellence, value-added features, and location. The mixed-use nature of the development area will benefit residents by providing housing within walking or biking distance (no more than 2.5 miles) of existing employment centers. There is also 150,000 SF of neighborhood commercial uses within one-half mile of the east development areas and 125,000 SF of neighborhood The Link 7 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies commercial uses within one-half mile of the west development area. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.3 Residential Next to Non-residential: In designing development at the boundary between residen- tial and non-residential uses, the City shall make protection of a residential atmosphere the first priority. The two largest residential components are more discretely located on the edge of other development and provide open spaces and recreational amenities. Multi-family Area 8 in the northeast cor- ner of the project will be immediately adjacent to another approved residen- tial project at 600 Tank Farm. The in- dustrial uses, which have the highest potential for land use conflicts with resi- dential uses, are located on the western edge of the east development area, far- thest away from the residential uses. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.4 Street Access: The City shall ensure new residen- tial development and redevelopment involving large sites are designed to orient low-density housing to local access streets, and medium- or high-density housing to driveways accessible from collector streets. Major arterials through residential areas shall provide only lim- ited private access or controlled street intersec- tions. Residential components of the project will be served by local streets or private driveways beyond arterial or collector roads. Direct access to Area 8 will be from “C” Street, a local public street that connects to Santa Fe. The Area 1 mixed use area will be access from a common internal driveway and no di- rect access to Santa Fe. Area 10 has limited options for access and has lim- ited private access from Santa Fe and from Tank Farm Road, and mixed-use Area 11 has limited access to Tank Farm Road and primary access from Innova- tion Way. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.5 Neighborhood Pattern: The City shall require that all new residential development be inte- grated with existing neighborhoods. Where physical features make this impossible, the new development should create new neighborhoods. Area 8 in the northeast corner of the project will be immediately adjacent to another approved residential project at 600 Tank Farm. Connections are pro- vided between Area 8 and 600 Tank Farm Road. Connections are also planned between the project site and the Damon Garcia project to the north. Other residential areas will be part of the new neighborhood, either on dis- crete sites or part of mixed-use build- ings in development areas. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.6 Housing and Business: The City shall encourage mixed use projects, where appropriate and com- patible with existing and planned development on the site and with adjacent and nearby properties. The City shall support the lo- cation of mixed use projects and community and The project combines a variety of land uses in close proximity to one another. This type of development pattern ac- commodates residential uses near jobs and services. The mix of proposed uses in the project will complement the The Link 8 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies neighborhood commercial centers near major activity nodes and transportation corridors / transit opportunities where appropriate. commercial, employment, and residen- tial uses now planned in the vicinity of the site. The project addresses housing, employment, and service needs in the community through a combination of design excellence, value-added fea- tures, and location. The mixed-use na- ture of the development area will bene- fit residents by providing housing within walking or biking distance (no more than 2.5 miles) of existing employment centers. There is also 150,000 SF of neighborhood commercial uses within one-half mile of the east development areas and 125,000 SF of neighborhood commercial uses within one-half mile of the west development area. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.7 Natural Features: The City shall require residen- tial developments to preserve and incorporate as amenities natural site features, such as land forms, views, creeks, wet- lands, wildlife habitats, wildlife corridors, and plants. Multi-family Area 10 is adjacent to Aca- cia Creek which will preserved in an open channel. Other sensitive site re- sources will be included as open space and preserved through a conservation easement. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.8 Parking: The City shall discourage the develop- ment of large parking lots and require parking lots be screened from street views. In general, parking should not be lo- cated between buildings and public streets. Preliminary massing models for areas show parking screened from street views. Parking for Areas 1-5 are distrib- uted throughout the site and large-scale parking lots have been avoided. Parking lots are no deeper than two double- loaded parking bays and will be buff- ered and screened by parking bay plant- ers at the end of each bay. Where pos- sible, buildings front onto public streets with the predominant share of the park- ing being provided at the side and the rear of the buildings per AASP Standard 5.4.1. Areas 1 through 3 have a central landscape and open space features with the buildings oriented to that feature. This results in the “rear” parking of the north-facing buildings being located be- tween the buildings and Tank Farm Road. To compensate, additional land- scaping, trees and vegetative screening and setbacks will be provided between those parking lots and Tank Farm Road. In total, the parking lots will be set back 35 feet from the curb face (5’-10’ The Link 9 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies minimum required by Table 4-7 of the AASP, depending on zone district), and there will be a total of 22 feet of land- scaping (7-foot parkway strip and a 15- foot landscape setback from the Class I bike path) between the street and park- ing lots compared to the 10 feet of land- scaping required by the AASP. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.10 Site Constraints: The City shall require new resi- dential developments to respect site constraints such as property size and shape, ground slope, access, creeks and wet- lands, wildlife habitats, wildlife corridors, native vegetation, and significant trees. Proposed development areas avoid sen- sitive resources and work in unison with site constraints. Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.3.11 Residential Project Objectives: Residential pro- jects should provide: A. Privacy, for occupants and neighbors of the project; B. Adequate usable outdoor area, sheltered from noise and prevailing winds, and ori- ented to receive light and sunshine C. Use of natural ventilation, sunlight, and shade to make indoor and outdoor spaces comfortable with minimum mechanical sup- port. D. Pleasant views from and toward the project; E. Security and safety. F. Bicycle facilities consistent with the City’s Bi- cycle Plan; G. Adequate parking and storage space; H. Noise and visual separation from adjacent roads and commercial uses. (Barrier walls, isolating a project, are not desirable. Noise mitigation walls may be used only when there is no practicable alternative. Where walls are used, they should help create an attractive pedestrian, residential setting through features such as setbacks, changes in alignment, detail and texture, places for people to walk through them at regular in- tervals, and planting.) I. Design elements that facilitate neighbor- hood interaction, such as front porches, front yards along streets, and entryways fac- ing public walkways. J. Buffers from hazardous materials transport routes, as recommended by the City Fire De- partment. The proposed project will add 725 multi-family housing units. There will be a variety of unit types, generally of smaller sizes, with an emphasis on rental units. The two largest residential components are more discretely located on the edge of other development and provide open spaces and recreational amenities. Siting of these areas was done to buffer residents from noise sources and to take advantage of views. A public park is located adjacent to the largest residential multi-family Area 8. The project provides for automobile parking, bicycle facilities, and storage areas. The Link 10 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies Conservation and Develop- ment of Residen- tial Neighbor- hoods Policy 2.4.2 Density Bonuses: The City shall approve a density bonus for projects that: A. Provide a receiving site, within expansion ar- eas or the downtown commercial core only, for development credit transferred to protect open space; B. Include affordable housing for seniors or lower income households consistent with the require- ments of State Law. Residential components will utilize den- sity bonus requests and meet project In- clusionary Ordinance requirements on- site. Commercial & Industrial Devel- opment Policy 3.1.1 Slope: Commercial and industrial uses should be developed in appropriate areas where the natu- ral slope of the land is less than ten percent. Project development sites are of slopes less than 10%. Commercial & Industrial Devel- opment Policy 3.1.2 Access: The City shall require that commercial and industrial uses have access from arterial and collector streets, and be designed and located to avoid increasing traffic on residential streets. Access to the industrial uses will be from local streets “A” and “B” which connect to Tank Farm Road and Santa Fe. These two local roads exclusively serve industrial, service commercial and research and development uses and will not mix with traffic from residential uses. Local street “C” exclusively serves development areas 8 (multifamily) and 12 (public park) and connects to Santa Fe, a collector road. Residential devel- opments have discrete separated access points. Commercial & Industrial Devel- opment Policy 3.3.1 New or Expanded Areas of Neighborhood Com- mercial Use: The City shall provide for new or ex- panded areas of neighborhood commercial uses that: A. Are created within, or extended into, non- residential areas adjacent to residential neighborhoods; B. Provide uses to serve nearby residents, not the whole city; C. Have access from arterial streets, and not in- crease traffic on residential streets; D. Have safe and pleasant pedestrian access from the surrounding service area, as well as good internal circulation; E. Are designed to be pedestrian-oriented, and architecturally compatible with the adjacent neighborhoods being served. Pedestrian-ori- ented features of project design should in- clude: Commercial areas have been created that are consistent with all of the listed criteria. They provide services to serve nearby residents, are adjacent to resi- dential areas, and have good internal circulation. The Link 11 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies i. Off-street parking areas located to the side or rear of buildings rather than be- tween buildings and the street; ii. Landscaped areas with public seating; and iii. Indoor or outdoor space for public use, designed to provide a focus for some neighborhood activities. Commercial & Industrial Devel- opment Policy 3.5.1 Office Locations: A. All types of offices are appropriate in the Downtown General Retail district, but are discouraged at street level in storefronts of the commercial core. B. All types of office activities are appropriate in the Office district which surrounds the Downtown commercial area, though offices needing very large buildings or generating substantial traffic may not be appropriate in the area which provides a transition to resi- dential neighborhoods. C. Medical services should be near the hospi- tals, and may also be located in other com- mercial areas of the City. D. Government social services and the regional offices of state and federal agencies should be near the intersections of South Higuera Street, Prado Road, and Highway 101 (Figure 5); E. Offices having no substantial public visita- tion or need for access to Downtown gov- ernment services may be in Services and Manufacturing districts. Certain business and professional services having no substan- tial public visitation or limited need for ac- cess to Downtown government services may be in Services and Manufacturing districts. Examples of such uses are computer ser- vices, utilities engineering and administra- tion, architects and engineers, industrial de- sign, advertising, building contractors, labor and fraternal organizations, and insurance and financial services that do not directly serve retail customers. F. Certain business and professional services with limited need for access to Downtown government services may be located in ar- eas that are away from the Downtown, and designated Community Commercial. Criterion A & B do not apply to this pro- ject. The medical offices proposed in Area 9 would be consistent with Crite- rion C since the policy does not man- date that they be located near hospi- tals, and there are few, if any develop- ment sites remaining near French and Sierra Vista Hospitals. The medical of- fice sites have been designed to allow enough space for an anchor use such as a specialty clinic or multi-practice medi- cal group, imaging center or outpatient surgery center, and smaller physician’s offices. The project does not anticipate government social services and agencies called out in Criterion D but potentially could accommodate if they do not re- quire substantial public visitation. Of- fices consistent with Criterion E & F are planned for Area 3. The Link 12 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies Appropriate types of offices include those that provide direct "over-the-counter" ser- vices to customers and clients. Professional offices may also be appropriate, particularly above the ground floor. Commercial & Industrial Devel- opment Policy 3.7.2 Access: The City shall require access to Service and Manufacturing areas be provided by com- mercial collector streets, to avoid customer traf- fic on residential streets or delivery routes which pass through residential areas. Driveway access onto arterial streets should be minimized. Access to the industrial uses will be from local streets “A” and “B” which connect to Tank Farm Road and Santa Fe. These two local roads exclusively serve industrial, service commercial and research and development uses and will not mix with traffic from residential uses. Local street “C” exclusively serves development areas 8 (multifamily) and 12 (public park) and connects to Santa Fe, a collector road. Residential devel- opments have discrete separated access points. Commercial & Industrial Devel- opment Policy 3.7.3 Air & Water Quality: Industries locating or ex- panding in San Luis Obispo shall comply with all applicable air-quality and water-quality regulations. Industrial uses will comply with all appli- cable air-quality and water-quality regulations. Commercial & Industrial Devel- opment Policy 3.6.4 Utility Service: The City shall require Services and Manufacturing uses to connect to the City water and sewer systems, unless other means of providing service are identified in a City-adopted plan. All components of the project will be connected to City sewer and water sys- tems. Commercial & Industrial Devel- opment Policy 3.8.2 Convenience Facilities: The City shall allow con- venience facilities serving daily needs, such as small food stores, branch banks, and child and el- der care, and amenities such as picnic areas, in centers of employment. Space for such amenities may be required within large commercial and in- dustrial developments. The project will incorporate various amenities into the project to serve both residents and employees of commercial and industrial uses. Commercial & Industrial Devel- opment Policy 3.8.3 Neighborhood Centers: The City shall identify suitable sites for new or expanded neighborhood centers as it prepares specific plans and develop- ment plans. The commercial uses proposed for the project are intended to serve the con- venience needs of the labor force and residents in the project. Neighborhood centers already existing in the area, in- cluding Higuera Plaza on Higuera at Sub- urban, and the Marigold Center at Broad and Tank Farm. The Marigold Center provides 150,000 SF of neighbor- hood commercial uses within one-half mile of the east development areas and Higuera Plaza provides 125,000 SF of neighborhood commercial uses within The Link 13 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies one-half mile of the west development area. Commercial & Industrial Devel- opment Policy 3.8.5 Mixed Uses: The City encourages compatible mixed uses in commercial districts. The project as designed incorporates a mix of uses. Compatible mixed-use components are proposed in Areas 1 & 11. Resource Protec- tion Policy 6.2.2 Resource Protection: The City shall seek to pro- tect resource areas deemed worthy of perma- nent protection by fee acquisition, easement, or other means. On-site resources include the interven- ing area between the development ar- eas which are identified as Conserva- tion/Open Space on the land use map. Consistent with AASP policies and guid- ance, this area will remain as open space and will be protected through a conservation easement. Resource Protec- tion Policy 6.3.2 Open Space Uses: Lands designated Open Space should be used for purposes which do not need urban services, major structures, or extensive landform changes. Such uses include: watershed protection; wildlife and native plant habitat; grazing; cultivated crops; and passive recreation. The City shall require that buildings, lighting, paving, use of vehicles, and alterations to the landforms and native or cultural landscapes on open space lands are minimized, so rural charac- ter and resources are maintained. Buildings and paved surfaces, such as parking or roads, shall not exceed the following: where a parcel smaller than ten acres already exists, five percent of the site area; on a parcel of ten acres or more, three percent. (As explained in the Con- servation and Open Space Element, the charac- teristics of an open space area may result in it being suitable for some open space uses, but not the full range.) Parcels within Open Space areas should not be further subdivided. The project is consistent with this policy as urban type improvements are not proposed for the open space areas. Resource Protec- tion Policy 6.6.3 Amenities and Access: The City shall require new public or private developments adjacent to the lake, creeks, and wetlands to respect the natural environment and incorporate the natural fea- tures as project amenities, provided doing so does not diminish natural values. Developments along creeks should include public access across the development site to the creek and along the creek, provided that wildlife habitat, public safety, and reasonable privacy and security of the development can be maintained, consistent with the Conservation and Open Space Element. Multi-family Area 10 is adjacent to Aca- cia Creek which will preserved in an open channel consistent with this pol- icy. The Active Transportation Plan does not identify a path along this portion of Acacia Creek as part of the bike or pe- destrian circulation plan. The Link 14 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies Resource Protec- tion Policy 6.6.4 Open Channels: The City shall require all open channels be kept open and clear of structures in or over their banks. When necessary, the City may approve structures within creek channels under the limited situations described in the Conservation and Open Space Element. Multi-family Area 10 is adjacent to Aca- cia Creek which will preserved in an open channel consistent with this pol- icy. Resource Protec- tion Policy 6.6.5 Runoff Reduction and Groundwater Recharge: The City shall require the use of methods to facil- itate rainwater percolation for roof areas and outdoor hardscaped areas where practical to re- duce surface water runoff and aid in groundwa- ter recharge. The project will comply with onsite wa- ter quality treatment requirements of the Regional Water Quality Control Board (MS4 standards). A regional drainage basin is proposed near Tank Farm Road. Resource Protec- tion Policy 6.6.6 Development Requirements: The City shall re- quire project designs that minimize drainage concentrations and impervious coverage. Floodplain areas should be avoided and, where feasible, any channelization shall be designed to provide the appearance of a natural water course. Bioswales, pervious paving, and other storm water control measures as appli- cable will be utilized to efficiently ac- commodate stormwater runoff. Resource Protec- tion Policy 6.6.7 Discharge of Urban Pollutants: The City shall re- quire appropriate runoff control measures as part of future development proposals to mini- mize discharge of urban pollutants (such as oil and grease) into area drainages. For those limited instances where drain- age may be directed to a creek corridor, oil and sand separators or other filtering media shall be installed at each drain in- let intercepting runoff as a means of fil- tering toxic substances from run off be- fore it enters the creek directly or through the storm water system. Resource Protec- tion Policy 6.6.8 Erosion Control Measures: The City shall require adequate provision of erosion control measures as part of new development to minimize sedi- mentation of streams and drainage channels. During construction, the project will abide by mitigation measures to limit erosion and avoid sedimentation to any natural drainage courses. Sustainability Policy 9.5 Urban Heat Effects: The City shall reduce heat ef- fects of urban development by requiring new de- velopment to incorporate, as appropriate, fea- tures such as reduced hardscape, light or heat reflective roofing, and shade trees. The project will incorporate more per- meable hardscapes where feasible, pro- vide shade trees, and incorporate sus- tainable building materials to reduce heat effects and comply with energy code requirements. Sustainability Policy 9.7 Sustainable Design: The City shall promote and, where appropriate, require sustainable building practices that consume less energy, water and other resources, facilitate natural ventilation, use daylight effectively, and are healthy, safe, com- fortable, and durable. Projects shall include, un- less deemed infeasible by the City, the following sustainable design features. A. Energy-Efficient Structure: Utilize building standards and materials that achieve or sur- pass best practices for energy efficiency. Since adoption of the LUCE in 2014, the City has adopted updates to the Uni- form Building Code, established “Reach” standards for GHG reductions, and up- dated its Climate Action Plan to address the issues in Sustainability Policy 9.7. The project will incorporate the listed features as required by the Uniform Building Code and local ordinances to create a more sustainable project and The Link 15 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies B. Energy-Efficient Appliances: Utilize appli- ances, including air conditioning and heating systems that achieve high energy efficiency. Incorporation of alternative energy systems (e.g., passive and/or active solar, heat pumps) is encouraged. C. Natural Ventilation: Optimize potential for cooling through natural ventilation. D. Plumbing: Utilize plumbing fixtures that con- serve or reuse water such as low flow fau- cets or grey water systems and implement a builder incentive program that will encour- age new homes to be built with onsite wa- ter/heat recycling systems to help achieve the goal of net zero water and energy use. E. Efficient Landscaping: Include landscaping that reduces water use through use of drought-tolerant / native plant species, high- efficiency irrigation (drip irrigation), and re- duction or elimination of the use of turf. Collection and use of site runoff and rainwa- ter harvesting in landscape irrigation is en- couraged. F. Solar Orientation: Optimize solar orientation of structures to the extent possible. G. Privacy and Solar Access: New buildings out- side of the downtown will respect the pri- vacy and solar access of neighboring build- ings and outdoor areas, particularly where multistory buildings or additions may over- look backyards of adjacent dwellings. H. Solar Ready: The City shall encourage new development to be built “solar ready” so that owners may easily install solar infra- structure, as appropriate. I. Solar Canopies: The City shall encourage the inclusion of solar canopies that include solar panels (such as structures over parking lots) on new construction, as appropriate. reduce energy costs for businesses and residents. Healthy Commu- nity Policy 10.4 Encouraging Walkability: The City shall encour- age projects which provide for and enhance ac- tive and environmentally sustainable modes of transportation, such as pedestrian movement, bicycle access, and transit services. The project will include bicycle paths and lanes, sidewalks, and other pedes- trian pathways in accordance with the Active Transportation Plan. A transit stop will be provided at the intersection of Santa Fe Road and “C” Street to en- sure that transit is located no farther than ¼ mile from the development ar- eas that it serves. Implementation of The Link 16 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 LUE Section Goal/Policy How Project Complies the transit services to the transit stop is dependent on amendment of the City’s Short Term Transit Plan and project buildout. The Link 17 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Circulation Element Circulation Ele- ment Section Goal/Policy How Project Complies Transit Service Policy 3.1.7 Transit Service Access. New development should be designed to facilitate access to transit service. There are two proposed transit stops with shelters along the east-west por- tion of Santa Fe in the interior of the eastern development area. These stops will connect the project to San Luis Obispo’s transit network via the pro- posed Prado Road connection to the north and Tank Farm Road directly to the south. Bicycle Transpor- tation Policy 4.1.4 New Development. The City shall require that new development provide end-of-trip facilities to encourage bicycle use and to make bicycling safe, convenient, and enjoyable. There will be a resting area and bicycle care center incorporated into a central location within the project. The center will have tire pumps, tire patch kits, and volunteer repair surfaces. Walking Policy 5.1.3 New Development. New development shall pro- vide sidewalks and pedestrian paths consistent with City policies, plans, programs, and stand- ards. When evaluating transportation impact, the City shall use a Multimodal Level of Service analysis. The project will include bicycle paths and lanes, sidewalks and other pedes- trian pathways in accordance with the Active Transportation Plan. A transit stop will be provided at the intersection of Santa Fe Road and “C” Street to en- sure that transit is located no farther than ¼ mile from the development ar- eas that it serves. Implementation of the transit services to the transit stop is dependent on amendment of the City’s Short Term Transit Plan and project buildout. Multi-Modal Cir- culation Policy 6.1.4 Defining Significant Circulation Impact: Any deg- radation of the level of service shall be mini- mized to the extent feasible in accordance with the modal priorities established in Policy 6.1.2 and Table 2. If the level of service degrades be- low thresholds established in Policy 6.1.2 and Ta- ble 2, it shall be determined a significant impact for purposes of environmental review under the California Environmental Quality Act (CEQA). For roadways already operating below the estab- lished MMLOS standards, any further degrada- tion to the MMLOS score will be considered a significant impact under CEQA. Where a potential impact is identified, the City in accordance with the modal priorities established in Policy 6.1.2 and Table 2, can determine if the modal impact in question is adequately served through other means e.g., another parallel Degradation of the operational level of service is no longer considered to be (nor permitted to be) a significant envi- ronmental impact. For the purposes of General Plan and Circulation Element conformity, however, the project will consider the MMLOS impacts of the project and any improvements needed to comply with City standards. The Link 18 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Circulation Ele- ment Section Goal/Policy How Project Complies facility or like service. Based on this determina- tion, a finding of no significant impact may be determined by the City. Multi-Modal Cir- culation Policy 6.1.5 Mitigation. For significant impacts, develop- ments shall be responsible for their fair share of any improvements required. Potential improve- ments for alternative mode may include, but are not limited to: A. Pedestrian: Provision of sidewalk, providing or increasing a buffer from vehicular travel lanes, increased sidewalk clear width, providing a continuous barrier between pe- destrians and vehicle traffic, improved cross- ings, reduced signal delay, traffic calming, no right turn on red, reducing intersection crossing distance. B. Bicycle: Addition of a bicycle lane, traffic calming, provision of a buffer between bicy- cle and vehicle traffic, pavement resurfacing, reduced number of access points, or provi- sion of an exclusive bicycle path, reducing intersection crossing distance. C. Transit: For transit related impacts, devel- opments shall be responsible for their fair share of any infrastructural improvements required. This may involve provision of street furniture at transit stops, transit shel- ters, and/or transit shelter amenities, pullouts for transit vehicles, transit signal prioritization, provision of additional transit vehicles, or exclusive transit lanes. The project will be adding significant cir- culation and multi-modal improvements to the area that will have a widespread positive impact on the City. The pedes- trian, bicycle, and transit improvements will be developed based on guidance from City staff and consistent with City standards. Multi-Modal Cir- culation Policy 6.1.6 City Review: When new projects impact the ex- isting circulation system, the City shall review the effectiveness and desirability of “direct fix” miti- gation improvements to address MMLOS im- pacts. Where a significant Impact is found, alter- native system wide project mitigations may be submitted for consideration to the City in accord- ance with the modal priorities established in Pol- icy 6.1.2 and Table 2. Exceptions shall be based on the physical conditions of the right-of-way to support additional improvements. If the right-of way in question cannot address onsite mitiga- tion, appropriate offsite improvements that have direct nexus to and effectively address the spe- cific impacts created by the project may be con- sidered. Portions of the Tank Farm Road right-of- way are adjacent to wetland areas with protected and sensitive plant and ani- mal species. Given these conditions, full build-out of the street corridor in some locations may not be possible for envi- ronmental reasons. The precise loca- tion and width of Tank Farm Road right- of-way may need to be tailored and will be determined based on traffic and civil engineering studies to be conducted during the entitlement, de- sign, and environmental review phases. The Link 19 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Circulation Ele- ment Section Goal/Policy How Project Complies Neighborhood Traffic Manage- ment Policy 8.1.2 Residential Streets: The City should not approve commercial development that encourages cus- tomers, employees or deliveries to use Residen- tial Local or Residential Collector (Minor and Ma- jor) streets. Access to commercial and industrial uses will be from local streets off of ar- terial and collector roads. Residential developments have discrete separated access points that would not be used for commercial access or deliveries. Neighborhood Traffic Manage- ment Policy 8.1.6 Non-Infill Development: In new, non-infill devel- opments, dwellings shall be set back from Re- gional Routes and Highways, Parkway Arterials, Arterials, Residential Arterials, and Col- lector streets so that interior and exterior noise standards can be met without the use of noise walls. Residential components of the project will be served by local streets or private driveways beyond arterial or collector roads. The two largest residential com- ponents are more discretely located on the edge of other development. Siting of these areas was done to buffer resi- dents from noise sources. Street Network Changes Policy 9.1.1 New Development: The City shall require that new development assumes its fair share of re- sponsibility for constructing new streets, bike lanes, sidewalks, pedestrian paths and bus turn- outs or reconstructing existing facilities. Details of project financing will be pro- vided to show how costs for public facil- ities and services will be addressed. Cost-sharing between the applicant and City will be a component of this infra- structure financing plan and pro-forma. Scenic Roadways Policy 15.1.2 Development Along Scenic Routes: The City will preserve and improve views of important scenic resources form streets and roads. Development along scenic roadways should not block views or detract from the quality of views. A. Projects, including signs, in the viewshed of a scenic roadway should be considered as "sensitive" and require architectural review. B. Development projects should not wall off scenic roadways and block views. C. As part of the city's environmental review process, blocking of views along scenic road- ways should be considered a significant envi- ronmental impact. D. Signs along scenic roadways should not clut- ter vistas or views. E. Streetlights should be low scale and focus light at intersections where it is most needed. Tall light standards should be avoided. Street lighting should be inte- grated with other street furniture at loca- tions where views are least disturbed. How- ever, safety priorities should remain supe- rior to scenic concerns. F. Lighting along scenic roadways should not degrade the nighttime visual environment and night sky per the City’s Night Sky Preser- vation Ordinance. Figure 3 of the Circulation Element shows that portions of Tank Farm Road are designated as having medium or high scenic value. Given that much of the Tank Farm frontage between devel- opment areas will remain as open space, important view corridors will re- main intact. Specific potential visual im- pacts associated with new development along the street corridor will be evalu- ated through development plan and en- vironmental review processes. The Link 20 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Circulation Ele- ment Section Goal/Policy How Project Complies Circulation Ele- ment Implemen- tation, Program Funding and Management Policy 16.2.4 Evaluate Transportation Effects. Major develop- ment proposals to the City will include displays of the proposal’s interfaces with nearby neigh- borhoods, and indicate expected significant qual- itative transportation effects on the entire com- munity. The street improvements included in the project, especially those to the re- gional arterial route - Tank Farm Road, and the commercial collector - Santa Fe, will enhance and improve areawide cir- culation. This constitutes a positive qualitative transportation effect that will affect many beyond those living or working in the project. Suitable graphic images will be produced to show how the development connects with other surrounding areas. The Link 21 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Housing Element Housing Ele- ment Section Goal/Policy How Project Complies Mixed Income Housing Policy 4.1 Within newly developed neighborhoods, housing that is affordable to various economic strata should be intermixed rather than segre- gated into separate enclaves. The mix should be comparable to the relative percentages of ex- tremely low, very-low, low, moderate and above- moderate income households in the City’s quan- tified objectives. Affordable housing units will be devel- oped in the project to meet the City’s Inclusionary Ordinance. Consistent with this policy, the deed-restricted afforda- ble units will be a mix of unit types that are available to different income levels, and intermixed throughout the residen- tial and mixed-use development areas. Beyond the required inclusionary units in the project, the range of sizes and the density of the project qualify as afforda- ble to lower and moderate-income households according to HCD’s criteria. The product mix will be virtually all multi-family residential units including studios, one-bedroom units, two-bed- room units, and a limited number of three-bedroom units. The product mix has intentionally been skewed to the lower and moderate-income housing types. Mixed Income Housing Policy 4.2 Include both market-rate and affordable units in apartment and residential condominium projects and intermix the types of units. Afforda- ble units should be comparable in size, appearance, and basic quality to market-rate units. The types of affordable units offered will reflect a proportional share of the total units to provide a variety of rental options and to be in parity with market- rate units. Housing Variety Policy 5.1 Encourage mixed-use residential/commercial projects in all commercial zones, especially those close to activity centers where compatible with existing and planned surrounding development. The mix of proposed uses in the project will complement the commercial, em- ployment, and residential uses now planned in the vicinity of the site. The project addresses housing, employ- ment, and service needs in the commu- nity through a combination of design excellence, value-added features, and location. The project includes two areas (Areas 1 and 11) which include commer- cial that is horizontally and vertically in- termixed with the residential units. Housing Produc- tion Policy 6.8 To help meet the 6th cycle RHNA production tar- gets, the City will support residential infill development and promote higher residential density where appropriate. The project’s residential and mixed-use components will provide a variety of unit types generally of smaller sizes that will benefit the city in meeting its RHNA requirements. Density bonuses will be utilized to create added density oppor- tunities. The project’s residential The Link 22 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Housing Ele- ment Section Goal/Policy How Project Complies density is approximately 23.9 density units per net acre or 32.7 dwelling units per net acre. The site functions as an infill location due to existing and pro- posed development of business, em- ployment, and shopping areas within walking distance. In particular, the de- velopment of Area 11 on Tank Farm Road just east of Innovation Way pro- vides a development opportunity within walking and biking distance of the South Higuera Plaza shopping center, the Pub- lic Market, and the employment areas east of South Higuera between Prado Road and Suburban Road. Neighborhood Quality Policy 7.2 Higher density housing should maintain high quality standards for unit design, privacy, security, amenities, and public and private open space. Such standards should be flexible enough to allow innovative design solutions. Residential development will include private and common open spaces areas, shared amenities like clubhouses and pools, and be of quality design and con- struction. Neighborhood Quality Policy 7.3 New residential developments should incorpo- rate pedestrian and bicycle linkages that provide direct, convenient and safe access to ad- jacent neighborhoods, schools, parks, and shopping areas. The residential units in the project will have bike linkages and pedestrian paths to provide access within the project boundaries and beyond. All bike and pedestrian facilities as recommended in the Active Transportation Plan will be implemented including a Class I bike path on Tank Farm Road, Class II bike lanes on both sides of Tank Farm Road and “A” and “B” Streets, and Class IV bike paths on both sides of Santa Fe, north of Tank Farm Road. Other bicycle linkages include connections to the Serra Meadows/Margarita Class I bike path, the “Hoover” Class I bike path on south Santa Fe, and the “Avila Ranch” Class I bike path located in the Tank Farm Creek corridor on the west side of the project. A public park is located ad- jacent to the largest residential multi- family Area 8. Neighborhood Quality Policy 7.5 Housing should be sited to enhance safety along neighborhood streets and in other public and semi-public areas. The larger residential areas are ac- cessed from driveways off of local streets and are in close proximity to other compatible uses. Multi-family Area 8 also has the benefit of having a neighborhood park across the street. Parking areas and common open space The Link 23 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Housing Ele- ment Section Goal/Policy How Project Complies areas are situated in close proximity to units ensuring that there are open views to these features increasing safety for residents. Internal sidewalks and pe- destrian corridors are connected to ex- ternal perimeter sidewalks and trails no less frequently than every 400 feet of public street frontage. Neighborhood Quality Policy 7.6 The physical design of neighborhoods and dwell- ings should promote walking and bicycling and preserve open spaces and views. The project will include bicycle paths and lanes, sidewalks, and other pedes- trian pathways in accordance with the Active Transportation Plan. In addition, the project will include a connection to the Avila Ranch bike and pedestrian trail to the south, and to the Damon Garcia Sports Fields to the north, to provide ac- cess to other areas of the City. All of the proposed residential areas in the pro- ject will have views to the South Street hills and intervening open spaces. Neighborhood Quality Policy 7.9 Encourage neighborhood design elements that improve overall health of residents such as providing safe and convenient opportunities to access healthy food and attractive places for recreational exercise. Specific neighborhood design elements within the project have direct health benefits including the network of pe- destrian and bike paths, to and through properties to the east and west, and the proximity to convenience goods centers within the project, and nearby like the Marigold Shopping Center to the east, to provide access to healthy foods. Two parks are proposed in the project that will include different amenities and pro- vide attractive areas for exercise. Resi- dential development will include private and common open spaces areas, and shared amenities like clubhouses and pools Sustainable Housing Policy 9.1 Residential developments should promote sus- tainability consistent with the Climate Action Plan (CAP) and California Building Energy Effi- ciency Standards (Title 24) in their design, placement, and functionality. Residential development will be re- quired to meet Title 24 requirements and many of the project’s sustainability features like bike and pedestrian con- nections, parks, and access to services are consistent with the CAP. Building energy efficiency standards that will en- able the project to comply with the “net zero” energy requirements and compli- ance with the City’s Reach Code. Elec- tricity shall be the only energy source for the entirety of project operations The Link 24 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Housing Ele- ment Section Goal/Policy How Project Complies including but not limited to space condi- tioning, water heating, illumination, cooking appliances, and plug loads Sustainable Housing Policy 9.2 Residential units, subdivision layouts, and neigh- borhood amenities should be coordinated to support sustainable design. Residential developments in the project have been designed to promote walking and biking and to be connected to area services and jobs which are the tenets of sustainable design. Regional Vision for Housing Goal 1 Strengthen Community Quality of Life – We be- lieve that our Region’s quality of life depends on four cornerstones to foster a stable and healthy economy for all: resilient infrastructure and resources, adequate housing supply, busi- ness opportunities, and educational pathways. The project includes new commercial development to provide business op- portunities and new jobs, 725 new resi- dential units, and new infrastructure im- provements. Regional Vision for Housing Goal 2 Share Regional Prosperity – We believe that our Region should share the impacts and benefits of achieving enduring quality of life among all people, sectors and interests. The project will meet its Inclusionary Housing Ordinance requirements onsite providing opportunities for all income levels to have access to safe and sus- tainable housing. Regional Vision for Housing Goal 3 Create Balanced Communities – We believe that our Region should encourage new development that helps to improve the balance of jobs and housing throughout the Region, providing more opportunities to residents to live and work in the same community. The project includes new commercial development and housing together which addresses City goals to improve its jobs-housing balance. The modified project will result in an internal jobs- housing ratio of 2.21:1. By comparison, the existing land use designations pro- vide for a jobs-housing ratio of 7.25:1, which would exacerbate and degrade the City imbalance. Regional Vision for Housing Goal 4 Value Agriculture & Natural Resources – We be- lieve that our Region’s unique agricultural resources, open space, and natural environ- ments play a vital role in sustaining healthy local communities and a healthy economy, and there- fore should be purposefully protected. The project includes proposes to create a conservation easement over the 250- acre property at the center of the site that includes wetlands and other sensi- tive plant and animal resources. Regional Vision for Housing Goal 6 Foster Accelerated Housing Production – We be- lieve that our Region must achieve efficient planning and production of housing and focus on strategies that produce the greatest impact. The State has identified that there is a housing crisis in California. The pro- posed 725 new residential units will help the City meet its RHNA require- ments and place housing where people work. Regional Vision for Housing Pol- icy R-2 Encourage an adequate housing supply and resil- ient infrastructure, services, and resources to im- prove the balance of jobs and housing through- out the Region. The project will have an internal jobs- housing ratio of 2.21, more closely meeting the General Plan’s requirement that new projects not exacerbate the jobs-housing imbalance. By comparison, the existing site land uses for the site would have a jobs-housing ratio 7.25, The Link 25 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Housing Ele- ment Section Goal/Policy How Project Complies which would significantly worsen the imbalance. Regional Vision for Housing Pol- icy R-7 Support housing development that is located within existing communities and strategically planned areas. The City has a compact urban form, and development as proposed within the ur- ban reserve and surrounded by City de- velopment, is providing infill develop- ment, rather than sprawl. The Link 26 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Noise Element Noise Element Section Goal/Policy How Project Complies Noise Element Goal 5 Prevent incompatible land uses from encroach- ing on existing or planned uses which are desired parts of the community, but produce noise. The industrial uses, which have the highest potential for land use conflicts with residential uses, such as potentially creating noise, are located on the west- ern edge of the east development area, farthest away from the residential uses. Noise Element Policy 1.3 New Development Design and Transportation Noise Sources. New noise-sensitive development shall be located and designed to meet the maxi- mum outdoor and indoor exposure levels of Ta- ble 1. The main noise source to the project is automobile traffic along Tank Farm Road, and in the future, automobile traffic along the northern extension of Santa Fe Road. Buildings within the pro- ject will be strategically located to block and attenuate sound to the most noise sensitive residential uses beyond. Standard construction techniques will provide for compliance with interior noise standards. Common outdoor uses will be oriented so that they comply with outdoor noise standards. Noise Element Policy 1.6 New Development and Stationary Noise Sources. New development of noise-sensitive land uses may be permitted only where location or design allow the development to meet the standards of Table 2, for existing stationary noise sources. Noise-sensitive residential uses have been strategically located to areas far- ther away from the main transportation noise sources. The industrial uses, which have the highest potential for land use conflicts with residential uses, such as potentially creating noise, are located on the western edge of the east development area, farthest away from the residential uses. Noise Element Policy 1.8 Preferred Noise Mitigation Approaches. When approving new development of noise-sensitive uses or noise sources, the City will require noise mitigation in the descending order of desirability shown below. For example, when mitigating outdoor noise exposure, providing distance be- tween source and recipient is preferred to providing berms and walls. Before using a less desirable approach, the applicant must show that more desirable approaches are not effective or that it is not practical to use the preferred ap- proaches consistent with other design criteria based on the General Plan. 1.8.1. Mitigating Noise Sources Project development will follow mitiga- tion strategies recommended by a re- quired noise study. Land uses in the project have been specifically located to address potential noise exposure con- cerns with buildings located along street frontages helping to attenuate and diffuse sound and locating noise sensitive uses farther from noise sources. This strategy is consistent with the hierarchy of mitigation strategies listed in this policy. The project does not intend to rely on walling off develop- ment to address noise concerns. The Link 27 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Noise Element Section Goal/Policy How Project Complies A. Arrange activity areas on the site of the noise-producing project so project features, such as buildings containing uses that are not noise-sensitive, shield neighboring noise-sensitive uses; B. Limit the operating times of noise-producing activities; C. Provide features, such as walls, with a pri- mary purpose of blocking noise. 1.8.2. Mitigating Outdoor Noise Exposure A. Provide distance between noise source and recipient; B. Provide distance plus planted earthen berms; C. Provide distance and planted earthen berms, combined with sound walls; D. Provide earthen berms combined with sound walls; E. Provide sound walls only; F. Integrate buildings and sound walls to create a continuous noise barrier. 1.8.3. Mitigating Indoor Noise Exposure A. Achieve indoor noise level standards assum- ing windows are open B. Achieve indoor noise level standards assum- ing windows must be closed (this option re- quires air conditioning or mechanical venti- lation in buildings.) Noise Element Program 1.13 Noise Studies. Where a project may expose peo- ple to existing noise levels or projected built-out noise levels exceeding acceptable limits, the City shall require the applicant to provide a noise study early in the review process so that noise mitigation may be included in the project design. The City will maintain standards and procedures for the preparation of noise studies. (See the Noise Guidebook for specifics.) The project environmental review pro- cess will include a noise study which will evaluate the design and propose mitiga- tion measures to comply with noise lev- els for indoor and outdoor uses identi- fied in the Noise Element. The Link 28 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Safety Element Safety Element Section Goal/Policy How Project Complies Safety Element Policy 3.0 Adequate Fire Service. Development shall be ap- proved only when adequate fire suppression ser- vices and facilities are available or will be made available concurrent with development, consid- ering the setting, type, intensity, and form of the proposed development. Project construction will include fire hy- drants, backflow prevention devices, and sprinklers to assist with any future fire suppression needs. The project pro- poses a location on Santa Fe north of Road “B” for the planned fifth (perma- nent) City fire station, which would serve southern San Luis Obispo. Safety Element Policy 4.7 Avoiding Liquefaction Hazards. Development may be located in areas of high liquefaction po- tential only if a site-specific investigation by a qualified professional determines that the pro- posed development will not be at risk of damage from liquefaction. The Chief Building Official may waive this requirement upon determining that previous studies in the immediate area provide sufficient information. Figure 5 of the Safety Element shows that the site has a high liquefaction po- tential. Consistent with this policy, a site-specific technical study will be done to make recommendations related to site preparation and foundation design. Safety Element Policy 5.2 Minimizing Hazardous Materials Exposure. Peo- ple’s exposure to hazardous substances should be minimized. For decades there has been ongoing remediation work in the former Chev- ron tank farm to clean up the soils and groundwater in the area. Most of the areas currently proposed for develop- ment have been remediated, or will be remediated by 2024. Safety Element Policy 7.0 Uses in the Airport Land Use Plan Area: Devel- opment should be permitted only if it is con- sistent with the requirements of the California State Aeronautics Act (Public Utilities Code §21670, et. seq.), guidance from the California Airport Land Use Planning Handbook, other re- lated federal and state requirements relating to airport land use compatibility planning, and the San Luis Obispo County Regional Airport Land Use Plan unless the City overrules a determina- tion of inconsistency in accordance with Section 21676.5 et. seq. of the Public Utilities Code. Pro- spective buyers of property that is subject to air- port influence should be so informed. A separate analysis was performed for the project’s consistency with the ALUP, and the project was found to be con- sistent with the noise, safety, and over- flight metrics. A 7460-1 FAA review has been initiated. Per AASP Policy 4.5.3, all residential units shall be designed to limit the aircraft-related 24-hour, 10- second interval interior peak noise (Lmax) impacts to no more than 45 dec- ibels, five decibels less than in Table 4 or the current ALUP. Safety Element Policy 9.1 Emergency Preparedness and Response. There should be adequate planning, organization, and resources for emergency preparedness and emergency response. The proposed improvements to both Tank Farm Road and Santa Fe afford the residents and businesses within the de- velopment multiple routes for emer- gency access and potential evacuation needs. The project proposes a location on Santa Fe north of Road “B” for the The Link 29 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Safety Element Section Goal/Policy How Project Complies planned fifth (permanent) City fire sta- tion, which would serve southern San Luis Obispo. Safety Element Policy 9.13 Emergency Access and Evacuation. Substantial development will be allowed only where multi- ple routes of road access can be provided, con- sistent with other General Plan policies on devel- opment location and open space protection. “Substantial development” means industrial, commercial, and institutional uses, multifamily housing, and more than ten single-family dwell- ings. ”Multiple routes” include vehicle connec- tions that provide emergency access only, as well as public and private streets. The proposed improvements to both Tank Farm Road and Santa Fe afford the residents and businesses within the de- velopment multiple routes for emer- gency access and potential evacuation needs. Safety Element Policy 9.18 Safety of Structures and Facilities. Existing and new structures and facilities should reflect adopted safety standards. New structures will be constructed to comply with applicable City and State safety standards. The Link 30 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Conservation and Open Space Element Conservation and Open Space Element Section Goal/Policy How Project Complies Air Policy 2.2.2 Health standards. Air quality should meet State and Federal standards, whichever are more pro- tective, for human health. The project will abide by all required air quality mitigation measures for both construction and operational conditions as determined by the environmental re- view process. Air Program 2.3.3 Alternative transportation/land use strategies. Implement public transit-, bicycle- and pedes- trian-oriented land use and design strategies in new development, as described in the Land Use and Circulation Elements of the General Plan to reduce the number of single-occupant trips in fossil-fueled vehicles. The project has been specifically de- signed to provide for a range of compat- ible land uses that will reduce single-oc- cupancy trips and comply with City jobs- housing balance goals. The project will include bicycle paths and lanes, side- walks, and other pedestrian pathways in accordance with the Active Transporta- tion Plan. Energy Policy 4.4.1 Pedestrian- and bicycle-friendly design. Resi- dences, work places and facilities for all other ac- tivities will be located and designed to promote travel by pedestrians and bicyclists. All land uses within the project will meet bicycle parking requirements. Energy Program 4.6.17 Require solar power for new dwellings. Within new single-family residential projects of 20 or more dwelling units, 5% of the total number of dwellings shall be built with photovoltaic solar collectors beginning in 2008; this percentage shall increase 4% each year until 2020. Multi- family residential developments shall be exempt from this requirement, except for common-use facilities such as recreation rooms, spas or swim- ming pools. In these cases, the common facilities shall be built with photovoltaic solar col- lectors. This is an antiquated requirement that has been superseded by new building code requirements and the City’s “Reach” code. Currently, solar installa- tion is required for multi-family devel- opments of three stories or less. Com- mercial and mixed-use projects are not yet mandated for solar but may be by the time proposed development is ready for construction. Materials Pro- gram 5.5.7 Energy efficiency and Green Building in new de- velopment. The City shall encourage material and energy-efficient “green buildings” as certi- fied by the U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) Program or equivalent certification, as described below. (See also Chapter 4.6.14) “Green Building Checklist” defined: In the items below, “green building checklist” means the checklist of a green building certification system approved by the Community Development De- partment. For projects greater than 5,000 There are not specific plans for buildings to meet LEED certification. However, the project intends to include energy ef- ficiency standards that will enable the project to comply with the “net zero” energy requirements and with the City’s Reach Code. Electricity shall be the only energy source for the entirety of project operations including but not limited to space conditioning, water heating, illumination, cooking appli- ances, and plug loads A green building The Link 31 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Conservation and Open Space Element Section Goal/Policy How Project Complies square feet of gross floor area, LEED is approved. For residential projects, LEED or the California Green Building Guidelines (with San Luis Obispo amendments) are approved. rating using another approved green building certification system approved by the Community Development Department. checklist will be submitted if requested or required at the time of construction. Materials Pro- gram 5.5.8 Recycling Facilities in New Development. Dur- ing development review, the City shall require fa- cilities in new developments to accommodate and encourage recycling. All project components will incorporate storage areas or other facilities to ac- commodate recycling. Natural Commu- nities Policy 7.5.2 Use of Native California plants in urban land- scaping. Landscaping should incorporate native plant species, with selection appropriate for lo- cation. For drought tolerant landscapes and to reduce water use, native plants will be predominantly featured in landscaping palettes. Natural Commu- nities Policy 7.5.5 Soil conservation and landform modification. Public and private development projects shall be designed to prevent soil erosion, minimize land- form modifications to avoid habitat disturbance and conserve and reuse on-site soils. The proposed project will meet City grading requirements. Natural Commu- nities Program 7.7.7 Preserve ecotones. Condition or modify devel- opment approvals to ensure that “ecotones,” or natural transitions along the edges of different habitat types, are preserved and enhanced be- cause of their importance to wildlife. Natural ecotones of particular concern include those along the margins of riparian corridors, marsh- lands, vernal pools, and oak woodlands where they transition to grasslands and other habitat types. Edge treatments for those development areas adjacent to the open space con- servation easement will provide for any necessary transitions to preserve and protect resources. Natural Commu- nities Program 7.7.8 Protect wildlife corridors. Condition develop- ment permits in accordance with applicable miti- gation measures to ensure that important corri- dors for wildlife movement and dispersal are protected. Features of particular importance to wildlife include riparian corridors, wetlands, lake shorelines, and protected natural areas with cover and water. Linkages and corridors shall be provided to maintain connections between habi- tat areas. Dedication of the 250-acre conservation easement and keeping the Acacia Creek corridor open will address accommodat- ing wildlife corridors. Natural Commu- nities Program 7.7.9 Creek Setbacks. As further described in the Zon- ing Regulations, the City will maintain creek set- backs to include: an appropriate separation from the physical top of bank, the appropriate floodway as identified in the Flood Management The proposed project will meet City-re- quired 35-foot setbacks from Acacia creek, FEMA floodway designations, and native riparian plants/wildlife habitat identified in relevant City-adopted The Link 32 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Conservation and Open Space Element Section Goal/Policy How Project Complies Policy, native riparian plants or wildlife habitat and space for paths called for by any City- adopted plan (Figure 4). In addition, creek set- backs should be consistent with the following: A. The following items should be no closer to the wetland or creek than the setback line: buildings, streets, driveways, parking lots, above-ground utilities, and outdoor com- mercial storage or work areas. B. Development approvals should respect the separation from creek banks and protection of floodways and natural features identified in part A above, whether or not the setback line has been established. C. Features which normally would be outside the creek setback may be permitted to en- croach where there is no practical alterna- tive, to allow reasonable development of a parcel, consistent with the Conservation and Open Space Element. D. Existing bridges may be replaced or wid- ened, consistent with policies in this Ele- ment. Removal of any existing bridge or res- toration of a channel to more natural condi- tions will provide for wildlife corridors, traf- fic circulation, access, utilities, and reasona- ble use of adjacent properties. plans. A graphic map/exhibit will be pro- vided to show how proposed develop- ment will be set back from Acacia Creek and relevant floodways in the area of proposed development that includes Acacia Creek in the eastern-most por- tion of the site. Open Space Pol- icy 8.3.3 Open space for safety. Secure open space where development would be unsafe. Generally, the following locations are considered to be unsafe: A. Areas within the most restrictive aviation safety zone as defined in the Airport Land Use Plan. B. Land straddling active or potentially active earthquake faults. C. Land where risks of ground shaking, slope in- stability, settlement, or liquefaction cannot be adequately mitigated. D. Areas subject to flooding, where the fre- quency, depth, or velocity of floodwaters poses an unacceptable risk to life, health, or property. E. Areas of high or extreme wildland fire haz- ard. The proposed project will meet devel- opment restrictions for San Luis Obispo Airport Safety Zones; the project’s de- velopment areas will mitigate other safety concerns regarding earth move- ment, flooding, and fire danger. A signif- icant portion of the project within the Airport Safety Zones will be included as open space in the Conservation Ease- ment. The Link 33 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Conservation and Open Space Element Section Goal/Policy How Project Complies Open Space Pol- icy 8.4.2 Open spaces access and restoration. The City in- tends to allow public access to open space that fosters knowledge and appreciation of open space resources without harming them and with- out exposing the public to unacceptable risk. The main goal is to protect open space and wild- life habitat, with a secondary goal of providing passive recreation where it will not harm the en- vironment. Approximately 76% of the proposed project site will be included as open space in a Conservation Easement. Lim- ited public access to this area may be al- lowed through public trails to the extent it does not pose an unacceptable risk to the pubic or damage the surrounding sensitive habitat or environment. Pub- licly accessible areas within the devel- opment areas will be designated as such; accessible areas within the Con- servation Easement area will be deter- mined by the Conservation Easement Agreement. Open Space Pol- icy 8.5.1 8.5.1. Public access. Public access to open space resources, with interpretive information, should be provided when doing so is consistent with protection of the resources, and with the secu- rity and privacy of affected landowners and occupants. Access will generally be limited to non-vehicular movement, and may be visually or physically restricted in sensitive areas. Public ac- cess to or through production agricultural land, or through developed residential lots, will be considered only if the owner agrees (Land for ac- tive recreation is typically designated “Park” in the General Plan Land Use Map). The City shall also designate open space areas that are not intended for human presence or activity. Because of the environmental re- strictions and covenants that are re- quired to be placed on the property by the State and Chevron, there will be lim- ited public access to designated open space areas through public trails to the extent this access not pose an unac- ceptable risk to the pubic or damage the surrounding sensitive habitat or en- vironment. Publicly accessible areas within the development areas will be designated as such; accessible areas within the Conservation Easement area will be determined by the Conservation Easement Agreement. Open Space Pol- icy 8.5.6 Determination of appropriate uses for City- owned open space. Determination of the appro- priate land management practices and the recre- ational uses of City-owned open space lands shall be made on an area-specific basis, based upon the policies in the Conservation and Open Space Element, the Open Space Ordinance (SLOMC 12.22), and the adopted “Conservation Guide- lines for City-Owned Open Space Lands.” These policies will be applied through the public plan- ning and review process specified in the Conser- vation Guidelines, and will guide the preparation and adoption of conservation plans for City- owned open space properties. Uses and restrictions regarding open space within the Conservation Ease- ment area will be determined by the Conservation Easement Agreement. There is currently no City-owned open space. Views Policy 9.1.2 Urban Development. The City will implement the following principle and will encourage other New development in the project will take guidance from the Airport Area The Link 34 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Conservation and Open Space Element Section Goal/Policy How Project Complies agencies with jurisdiction to do so: urban devel- opment should reflect its architectural context. This does not necessarily prescribe a specific style, but requires deliberate design choices that acknowledge human scale, natural site features, and neighboring urban development, and that are compatible with historical and architectural resources. Plans for sub-areas of the city may re- quire certain architectural styles. Specific Plan design guidelines and Com- munity Design Guidelines on building massing, articulation, and architectural styles. Views Policy 9.1.3 Utilities and signs. In and near public streets, plazas, and parks, features that clutter, degrade, intrude on, or obstruct views should be avoided. Necessary features, such as utility and communi- cation equipment, and traffic equipment and signs should be designed and placed so as to not impinge upon or degrade scenic views of the Morros or surrounding hillsides, or farmland, consistent with the primary objective of safety. New billboard signs shall not be allowed, and ex- isting billboard signs shall be removed as soon as practicable, as provided in the Sign Regulations. Signs and utility equipment will be placed strategically so that they are functional, but do not block or impinge on important view corridors. Views Policy 9.1.4 Streetscapes and major roadways. In the acqui- sition, design, construction or significant modifi- cation of major roadways (highways/regional routes and arterial streets), the City will promote the creation of “streetscapes” and linear scenic parkways or corridors that promote the City’s visual quality and character, enhance adjacent uses, and inte- grate roadways with surrounding districts. To ac- complish this, the City will: A. Establish streetscape design standards for major roadways. B. Encourage the creation and maintenance median planters and widened parkway plantings. C. Retain mature trees in the public right-of- way. D. Emphasize the planting and maintenance of California Native tree species of sufficient height, spread, form and horticultural char- acteristics to create the desired streetscape canopy, shade, buffering from adjacent uses, and other desired streetscape characteristics, consistent with the Tree Or- dinance or as recommended by the Tree Streetscape design will incorporate street trees and parkway landscaping consistent with City standards. New util- ities will be installed underground. The Link 35 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Conservation and Open Space Element Section Goal/Policy How Project Complies Committee or as approved by the Architec- tural Review Commission. E. Encourage the use of water-conserving land- scaping, street furniture, decorative lighting and paving, arcaded walkways, public art, and other pedestrian-oriented features to enhance the streetscape appearance, com- fort and safety. F. Encourage and where possible, require un- dergrounding of overhead utility lines and structures. Views Policy 9.2.1 Views to and from public places, including sce- nic roadways. The City will preserve and improve views of important scenic resources from public places, and encourage other agencies with juris- diction to do so. Public places include parks, pla- zas, the grounds of civic buildings, streets and roads, and publicly accessible open space. In par- ticular, the route segments shown in Figure 11 are designated as scenic roadways. A. Development projects shall not wall off sce- nic roadways and block views. B. Utilities, traffic signals, and public and pri- vate signs and lights shall not intrude on or clutter views, consistent with safety needs. C. Where important vistas of distant landscape features occur along streets, street trees shall be clustered to facilitate viewing of the distant features. D. Development projects, including signs, in the viewshed of a scenic roadway shall be con- sidered “sensitive” and require architectural review. Figure 3 of the Circulation Element shows that portions of Tank Farm Road are designated as having medium or high scenic value. Given that much of the Tank Farm frontage between devel- opment areas will remain as open space, important view corridors will re- main intact. Building placement along Tank Farm Road will ensure that view corridors are provided, and that new development does not “wall off” views. Development throughout the project, including public spaces like parks, will have views to the South Street hills and intervening open spaces. Views Policy 9.2.2 Views to and from private development. Projects should incorporate as amenities views from and within private development sites. Pri- vate development designs should cause the least view blockage for neighboring property that al- lows project objectives to be met. Private development throughout the project will have views to the South Street hills and intervening open spaces. Views Policy 9.2.3 Outdoor lighting. Outdoor lighting shall avoid: operating at unnecessary locations, levels, and times; spillage to areas not needing or wanting il- lumination; glare (intense line-of-site contrast); and frequencies (colors) that interfere with as- tronomical viewing. Project lighting will comply with the City’s Night Sky Preservation require- ments included in the Zoning Regula- tions. The Link 36 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Conservation and Open Space Element Section Goal/Policy How Project Complies Water Policy 10.3.1 Efficient water use. The City will do the following in support of efficient water use, and will encour- age individuals, organizations, and other agen- cies to do likewise: A. Landscaping: 1. Choose plants that are suitable for the cli- mate and their intended function, with em- phasis on use of native and drought-tolerant plants. 2. Prepare soils for water penetration and re- tention. 3. Design and operate suitable and efficient ir- rigation systems. 4. The City will encourage drought-tolerant landscaping, vegetable gardens and fruit trees in lieu of large expanses of lawn or other more water-demanding plantings. 5. Landscape maintenance: Landscaped areas will be properly designed for efficient water use, and shall be properly installed and maintained, including the upkeep and re- placement of low-flow irrigation fixtures and equipment. 6. Facilitate use of tertiary-treated water and seek to legalize use of grey water for non- potable household purposes. 7. Promote water conservation through leak control in residential, commercial, industrial and public plumbing systems. Landscaped areas will utilize drought tolerant and native plants to limit water use. Soil preparation treatments and on-going maintenance will be per- formed to assure that systems continue to function efficiently in the future. The Link 37 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Parks and Recreation Element Parks and Rec- reation Ele- ment Section Goal/Policy How Project Complies Parks and Recre- ation Element Policy 1.3 Park Access Standards. The City shall seek to provide a neighborhood or community park within a half-mile, or ten-minute, walk of all resi- dents along streets and paths. In park-deficient areas where providing a new neighborhood park is not feasible, access improvements to existing parks and the creation of mini parks will be prior- itized. Two parks are proposed in the project that will include different amenities and provide attractive areas for exercise. The larger 2.1-acre park area is located to the southwest of the larger proposed R-4 residential area in the northeastern portion of the site. A second park site is identified adjacent to the stormwater basin just north of Tank Farm Road. As noted in describing the features of dif- ferent areas of the project, this park site is adjacent to a commercial area desig- nated for restaurant retail uses, and would include a small dog park area is proposed north of the City park near the northern property line. The project will also have connections to 600 Tank Farm Road which is constructing a bike path to the Damon Garcia Sports Com- plex. The project area vicinity has over 500 approved residential units planned beyond those included in the project. Therefore, the onsite public park will fill an important gap and shortfall in parks in the area. Parks and Recre- ation Element Policy 1.7 New Parks and Park Access in Existing Neighborhoods. The City shall seek to create new parks and/or improve access to existing parks in neighborhoods where there are gaps. The City should pursue the following specific opportuni- ties, also shown generally on Figure 4-2: • Create a new neighborhood or community park in the South Higuera corridor (Sub-area 5); As noted above with the discussion of Policy 1.3, two new park sites are pro- posed within the development to serve residents, workers, and visitors. These park spaces will help offset notable gaps in park facilities within the area. In addi- tion, in-lieu park fees will be paid to help fund other parks in the vicinity of the project. Parks and Recre- ation Element Policy 1.9 New Parks with Future Development. The City shall continue to require that future Planned de- velopments and annexations dedicate ten acres of parkland per 1,000 residents. Of this amount, five acres shall be dedicated as a neighborhood park. The remaining five acres required under the ten acres per 1,000 residents in the residen- tial annexation policy may be located anywhere within the City’s park system in a way that helps to fulfill the goals and policies of this Plan, as Based on the 725 residential units with an average multi-family household size of 1.81 persons per dwelling unit (per the EPS impact fee nexus study), the project would create a demand for 13.1 acres of parkland. This will be met by 2.9 acres of public park space, 1.16 acres of private recreational facilities, and in-lieu fees for 9.04 acres. Of the 9.04 acres in lieu fees, the equivalent of The Link 38 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Parks and Rec- reation Ele- ment Section Goal/Policy How Project Complies directed by the Parks and Recreation Commis- sion. The City’s in-lieu fee program may be offered as an alternative for smaller development projects at the City’s dis- cretion. 2.5 acres will be used to support neigh- borhood parks in the adjacent Marga- rita Area. The balance will be used to support community wide facilities and parks facilities in other neighborhoods. Parks and Recre- ation Element Policy 2.2 Community-Desired Park Elements. Parks and facilities should be planned and designed to support community needs. For neighborhood and mini parks, this should involve consideration of the specific goals of neighborhood residents; for community parks, recreation facilities and special features, citywide needs take prece- dence. The proposed park will include typical amenities for a neighborhood park. Spe- cific features proposed will accompany the development plan submittal and will be reviewed by the Parks and Rec- reation Commission. Parks and Recre- ation Element Policy 3.1 Access by Foot, Bike, and Roll. New parks and fa- cilities should be located centrally to their service population, integrated with their community context, and easily accessed on foot, by bike, and roll. Where feasible, new parks should: • Be accessible from multiple points; • Face directly onto public streets; • Be accessible from transit and active transpor- tation network; • Be located adjacent to other community uses like schools, libraries, and commercial districts; • Be located adjacent to multifamily housing. The planned 2.1-acre neighborhood park is planned at the project’s circula- tion focal point at “C” Street and Santa Fe. This location will have a transit stop, a pedestrian crossing, ample park- ing, and adjacent sidewalks and bike lanes. The Link 39 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with General Plan Water and Wastewater Element Water and Wastewater Element Sec- tion Goal/Policy How Project Complies Water and Wastewater Pol- icy A 5.2.5 Paying for Water for New Development. New development shall pay its proportionate or “fair share” for water supplies, expanded treatment and distribution system capacity and upgrades. The project will pay its proportionate share for extending water services to the site for proposed development. Water and Wastewater Pol- icy A 2.2.3 Wastewater Service for New Development. New development shall pay its proportionate or “fair share” of expanded treatment and collection sys- tem capacity and upgrades. New development will only be permitted if adequate capacity is available within the wastewater collection sys- tem and/or Water Resource Recovery Facility. The project will pay its proportionate share for accommodating wastewater (sewer) services to the site for proposed development. The northern extension of Santa Fe will assist in the eventual ability of the Garcia Ranch project, lo- cated north of The Link, to develop since it currently has limited sewer and storm drainage capacity without con- necting to the sewer main in Tank Farm Road. The Link 40 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with Airport Area Specific Plan Airport Area Specific Plan Section Goal/Policy How Project Complies Conservation and Resource Management Policy 3.2.14 Chevron Property Open Space Lands. Designate open space lands on the Chevron property as a permanent ecological preserve dedicated to the preservation and enhancement of the area’s nat- ural resources, and public environmental educa- tion. The 257-acre intervening area between the development areas of the 332-acre site will be designated open space lands. A conservation easement will preserve and enhance the area’s natural resources. Conservation and Resource Management Policy 3.2.15 Continuous Open Space Corridors. Provide con- tinuous open space corridors that link open space resources within the Airport Area to re- sources outside of the Airport Area. The 257-acre open space area of the project would contribute to continuity of open space corridors within the Air- port Area. Conservation and Resource Management Policy 3.2.24 City Consideration of “Changed Conditions” on the Chevron Property following remediation and restoration. It is acknowledged that Chevron has prepared a remediation plan for its property ad- dressing the contaminated areas on the site. The remediation plan has been reviewed by mul- tiple agencies (including: Army Corps of Engi- neers, California Department of Fish and Wildlife, Regional Water Quality Control Board) as part of the EIR prepared for the Chevron Tank Farm Re- mediation and Development project. The Chev- ron EIR found that the remediation project will impact wetlands and other terrestrial habitat on the site. The EIR requires mitigation measures that provide for the replacement and restoration of wetland and terrestrial habitat on-site follow- ing the remediation project. After completion of the restoration component of the project ongo- ing monitoring and maintenance of restoration activities will be required (per EIR mitigation) to ensure compliance. The restored wetlands and terrestrial habitat areas shall be included within a permanent open space easement. Consistent with mitigation measures of the Chevron EIR, the intervening area between the development areas will re- main as open space in a conservation easement. Land Use Goal 4.1.1 Urbanization and Resource Protection. Urbaniza- tion of the Airport Area in a manner consistent with City goals for resource protection. The project proposes development in areas identified for urban development in the City and County General Plans, and the preservation of open space area, consistent with City goals for re- source projection. Land Use Goal 4.1.2 Job Creation. Further the City’s goals for growth management, economic development, and com- munity character by designating land uses The project includes a mix of office, commercial and industrial uses that will support over 2,000 new jobs. Retail and residential land uses will provide for The Link 41 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Airport Area Specific Plan Section Goal/Policy How Project Complies which facilitate and encourage the creation of high quality base-level and support-level jobs in the Airport Area. housing and businesses with services in close proximity to one another, as well as housing in close proximity to other employers in south San Luis Obispo. The addition of residential units in the west- ern development area (Area 11) will place new residential units close to neighborhood services at Higuera Plaza and the Public Market, and employment areas in the Hind and Granada Business Parks. Land Use Goal 4.1.3 Compact Urban Form. A compact urban form that minimizes sprawl onto surrounding agricultural and rural lands. The project proposes a compact urban form including a mix of industrial, retail and residential land uses with over 77% of the site designated as open space. Overall, density of the project is esti- mated to be 24 density units to the acre, and 32 dwelling units per acre on the development portions of the project site. Development on the project site as proposed will reduce the need to ex- pand the Urban Reserve line in the fu- ture. Land Use Goal 4.1.5 Employment Opportunities. Employment oppor- tunities appropriate for area residents’ desires and skills. The mixed-use nature of the develop- ment area will benefit residents by providing housing within walking or bik- ing distance (no more than 2.5 miles) of existing employment centers. There is also 150,000 SF of neighborhood com- mercial uses within one-half mile of the east development areas and 125,000 SF of neighborhood commercial uses within one-half mile of the west devel- opment area. The project will accom- modate over 2,000 jobs, with 75% per- cent of those jobs considered to be head of household jobs. Land Use Goal 4.1.6 Land Use Compatibility. Compatibility with exist- ing and proposed uses both inside and outside the Airport Area. The project proposes development in areas identified for urban development in the City and County General Plans. Several of the residential development areas are located near uses that may have activities that are incompatible with residential uses; however, site con- ditions and development standards will eliminate these potential impacts. Area 11, the mixed use project east of The Link 42 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Airport Area Specific Plan Section Goal/Policy How Project Complies Innovation Way is separate from the service commercial and wrecking yard uses by more than 100 feet at its near- est point. Commercial uses on the ground floor provide buffering. The Area 10 multifamily site is located adja- cent to service commercial uses on the south side of Santa Fe. However, Acacia Creek provides an effective physical buffer with the service commercial uses at least 150 feet from the nearest resi- dential structure. Within the develop- ment itself, the industrial uses are sepa- rated from the more sensitive uses by offices, R&D uses, and retail/commer- cial uses. Land Use Goal 4.1.7 Sense of Place. New development that contrib- utes to a sense of place. This includes arranging the improvements around central nodes or linear features such as riparian open space corridors, and by creating mini-parks or facilities as focal points for neighborhoods. The project will include a synergistic mix of land uses consistent with other parts of the City and will maintain a large cen- tral open space area, in addition to a public park and common outdoor use areas integrated as neighborhood focal points. Land Use Goal 4.1.8 Protect and Enhance Natural Features. Protec- tion and enhancement of natural features such as creeks, wetlands, and grasslands, within a sys- tem of permanent open space. The project proposes to protect and en- hance natural features by preserving Acacia Creek in an open channel and protecting open space areas through a conservation easement. Land Use Goal 4.1.9 Airport Operations. Airport Area land uses and development, including Airport Compatible Open Space, compatible with the long-term operation of the airport, and enhancing the viability of the airport as a regional transportation facility. The project is compatible with Airport Area land uses and development and will not impede long-term operation of the airport. See separate airport land use plan compatibility analysis. Land Use Goal 4.1.10 Balance of Conservation and Development. A balanced conservation and development pro- gram that enhances public safety, community character and natural resource values while rem- edying long-standing environmental and aesthetic problems. With 77% of the project site designated open space, the project balances con- servation with development. The mix of proposed land uses in a walkable envi- ronment would enhance public safety and community character through acti- vation of the site, while remedying long- standing environmental and aesthetic problems. Land Use Policy 4.3.6 Tank Farm Site. The Chevron Remediation and Development project and its accompanying EIR provides for a comprehensive development and conservation plan for the entire property. This The proposed project is consistent with the Chevron Remediation and Develop- ment project and its accompanying EIR. The Development Agreement would The Link 43 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Airport Area Specific Plan Section Goal/Policy How Project Complies development plan includes mitigation measures adopted with the Chevron Tank Farm Remedia- tion and Development Project EIR and must meet with the approval of federal, state and lo- cal agencies with jurisdiction over the hazards and natural resources present, and includes: A. A detailed resource management plan to pro- tect and enhance natural resources found on the Tank Farm Site, including sensitive species and their habitats (e.g., wetlands, riparian corridors, and native grasslands). B. Conservation easements for the permanent protection of natural resources dedicated to an appropriate trustee agency such as the City, County, RWQCB or SLO Land Trust. C. A detailed, site-specific plan for remediation of contaminated areas associated with developing areas designated for development and habitat restoration consistent with the Remedial Action Plan evaluated with the Chevron Tank Farm EIR (2013-2014). D. An implementation plan that links develop- ment entitlements to completion of specific re- mediation and habitat-improvement actions. E. A mechanism, such as an endowment, for im- plementing the long-term monitoring, enhance- ment and maintenance included in the plan. describe the open space easement for the permanent protection of natural re- sources on the site dedicated to the City. A detailed plan for remediation of contaminated areas associated with de- veloping areas will be provided con- sistent with the Chevron Tank Farm EIR. A plan for long-term monitoring, en- hancement, and maintenance and an implementation plan describing devel- opment entitlements and associated re- mediation and habitat-improvement ac- tions will be included in the Develop- ment Agreement. Land Use Policy 4.3.7 Tank Farm Road Improvements. Prior to develop- ment of the Tank Farm site, Chevron, or its suc- cessor in interest, must provide a tentative map with preliminary design plans for improvements to Tank Farm Road adjacent to its property. The design plans will address roadway design stand- ards provided in Chapter 6, including the road- way design, median and parkway landscaping, re-grading of the berms, re-location and replace- ment of chain link fencing with a more visually compatible solution, and alignment and design of on-street and off-street pedestrian and bicycle connections as shown in the circulation section, chapter 6. A tentative map with preliminary design plans for improvements to Tank Farm Road, including roadway design, median and parkway landscaping, re-grading of the berms, re-location and replacement of chain link fencing, and alignment and design of on-street and off-street pe- destrian and bicycle connections, would be provided prior to development of the Tank Farm site. Land Use Policy 4.3.11 Uses Not Listed. The Community Development Director is authorized to determine whether uses not listed in Table 4-3 are allowed or conditionally allowed, subject to the appeal The Community Development Director has the authority to determine if uses not listed in Table 4-3 are allowed, sub- ject to the established appeal proce- dures. This procedure does not allow The Link 44 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Airport Area Specific Plan Section Goal/Policy How Project Complies procedures established in the Municipal Code. The interpretation procedure is not used as a substitute for the amendment procedure to add new types of uses to a zone. for new types of uses to be added to an existing zone. Circulation Goal 6.1.4 Comprehensive Bikeway and Pedestrian System. Complete a series of Class I - facilities throughout the area as soon as possible to encourage com- muter use and an alternative to single occupant driving. Develop a comprehensive and connected bikeway and pedestrian system that connects the area’s employment centers to the broader community, promotes alternatives to the single occupant automobile, enhances the public’s enjoyment of the community’s open space resources, and connects the local bikeway system to the regional bikeway and pedestrian system such as the Bob Jones Trail. The project includes a highly integrated system of Class I, Class II, Class III and Class IV bike facilities that provide obvi- ous priority for this mode of transporta- tion. Connections from these facilities can be made to the offsite connections to the Serra Meadows bike path, the Avila Ranch bike path, and the connec- tion to Damon-Garcia Sports Park through 600 Tank Farm Road. The ap- plicant is also exploring additional recre- ational paths through the open space areas to augment the commuter facili- ties. All proposed roadways will include bike paths or lanes, sidewalks, and vehi- cle traffic buffers. The street improve- ments included in the project will en- hance the public’s enjoyment of the community’s open space resources and improve areawide circulation. Circulation Standard 6.4.1.2 Tank Farm Road is designated a parkway arterial and will have a continuous, four-lane, urban cross-section. The development plan includes special sections for different segments of Tank Farm Road, including a full 120-foot right of way along the frontages of the eastern and western development sites, and special sections in between to mini- mize environmental impacts while still providing for adequate and safe traffic flow, pedestrian flow, and bicycle traf- fic. Given environmental constraints as- sociated with the conservation ease- ment areas further to the west, differ- ent right of way configurations will likely be developed for the area between the east development sites and Innovation Way. In accordance with recent traffic studies and the update of the City’s traf- fic model and buildout projections, there will be one through lane in each direction along these areas with re- duced rights of way. Based on prelimi- nary studies, it is anticipated that The Link 45 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Airport Area Specific Plan Section Goal/Policy How Project Complies this reduced area will have a 90-foot right of way, with a through lane in each direction, a Class I bike path on the north and on the south, Class II bike lanes, a five-foot swale/shoulder for drainage, and an 8’-14’ safety median. The precise location of Tank Farm Road, and the width of the various sections in the project will be determined based on traffic and civil engineering studies to be conducted during the entitlement, design and environmental review phases. Circulation Goal 6.4.4 Establish a system of collector streets that con- nect arterials and local streets. As part of that system, extend Santa Fe Road north to the Prado Road extension and introduce a new collector through the property west of the Chevron property from Tank Farm Road linking with Sueldo Street. The project area will have a hierarchy of street improvements including the Park- way Arterial - Tank Farm Road and the commercial collector - Santa Fe, as well as local public streets identified as Streets “A”, “B” and “C” on the develop- ment plan. The project will also extend the Santa Fe roadway north. The Link 46 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Consistency with Community Design Guidelines Community Design Guide- lines Section Goal/Policy How Project Complies Goals for Design Quality and Character 1.4.A.3 The quality of development at city gateways and along key corridors is critical to the city's overall image for residents and visitors. The project will activate and enhance one of San Luis Obispo’s most important thoroughfares through circulation im- provements and quality mixed-use buildings and site design. Goals for Design Quality and Character 1.4.B Design to create and maintain pedestrian scale wherever appropriate. Pedestrian orientation and scale will be integrated in site planning, architectural design, articulation, and massing. Site Design Prin- ciple 2.1.C Site Function. The various activities and ele- ments proposed on a site should be logically lo- cated so the project will operate efficiently, and effectively address the needs of all users. The mix of uses in the proposed project would be located so the project will op- erate efficiently for all users. The two largest residential components are more discretely located on the edge of other development and provide open spaces and recreational amenities. Multi-family Area 8 in the northeast cor- ner of the project will be immediately adjacent to another approved residen- tial project at 600 Tank Farm. The in- dustrial uses are located on the western edge of the east development area, far- thest away from the residential uses. Enhanced pedestrian and bicycle con- nectivity would address the needs of all users. Commercial Pro- jects Design Guideline 3.1.A.2 Avoid “boxy” structures with large, flat wall planes by articulating building forms and eleva- tions to create interesting rooflines, building shapes, and patterns of shade and shadow. Special design standards would be es- tablished for the site to ensure that the city’s high development standards and expectations are met, including the de- sire for articulated building forms and interesting massing, roof forms, and materials. Commercial Pro- jects Design Guideline 3.1.B.3 Design consistency. Designs should demonstrate a consistent use of colors, materials, and detail- ing throughout all elevations of the building. Ele- vations which do not directly face a street should not be ignored or receive only minimal architec- tural treatment. Each building should look like the same building from all sides. Special design standards would include provisions for design consistency, in- cluding colors, materials, and detailing on all sides of the building. Industrial Project Design Guide- lines Goal 3.3.B.1 Architectural style. The architectural style of buildings in the business park/industrial category should incorporate clean simple lines. Buildings should project an image of high quality through Special design standards will encourage high-quality architectural styles for busi- ness park/industrial buildings by includ- ing guidelines for site design, massing, articulation, and materials. The Link 47 of 47 General Plan, AASP and Community Design Guidelines Consistency Analysis August, 2022 Community Design Guide- lines Section Goal/Policy How Project Complies the use of appropriate durable materials and well-landscaped settings. Multi-Family & Clustered Hous- ing Design 5.4.A.2 Multi-family units should be clustered. A project of more than 10 units outside the Downtown should separate the units into structures of six or fewer units. To accommodate smaller unit sizes and residential densities of more than 15 units per acre, it is not feasible to com- ply with this requirement. In order to comply with this guideline, the units would have to be 75% larger which con- flicts with the City and project objec- tives for the development of the site. Multi-Family & Clustered Hous- ing Design 5.4.B. Parking and driveways. Individual closeable gar- ages are the preferred method for providing parking for residents in multi-family projects. If garages within the residential structures are not provided, dispersed parking courts are accepta- ble. For the density proposed, it is not feasi- ble to provide garage spaces for all resi- dential units. Surface parking spaces in close proximity to units is the preferred solution and will be screened by build- ings and landscaping. Subdivision De- sign and General Residential Pro- ject Principle A Develop “neighborhoods.” Each new residential project should be designed to integrate with the surrounding neighborhood to ensure that it maintains the established character. Subdivisions in City expansion areas should be designed so that individual, separately developed projects work together to create distinct neighborhoods, instead of disjointed or isolated enclaves. The proposed project will add 725 multi-family housing units to the grow- ing Tank Farm Road neighborhood. Resi- dential neighborhoods within the pro- ject will be clustered around common open space areas and include facilities such as a recreation center or commu- nity building. Miscellaneous Design Details Guideline C Lighting. Exterior lighting should be designed to be compatible with the architectural and land- scape design of the project while preserving the night sky, and not create a nuisance for adjacent and nearby properties. See also the Night Sky Preservation standards in Chapter 17.23 of the Zoning Regulations. Exterior lighting within the project site would be compliant with Night Sky Preservation standards of the Zoning Regulations. Attachment F Airport Land Use Plan Consistency Analysis The Link 1 of 7 ALUP Conformity Analysis August, 2022 The Link Project Airport Land Use Plan Compatibility Analysis Project Location Relative to Airport Facilities The closest portions of the Project are located within 1,800 feet of airport Runway 11-29. One of the key factors in determining compatibility with the airport is the project’s location relative to flight paths, regular and frequent approaches and departures, and the ALUP’s various safety zone boundaries and noise contours. The location of the various safety zones is driven by mathematical criteria associ- ated with the location of the runway facilities, distance from the runway ends, approved and frequently used approach and departure corridors, and the probable elevation of aircraft at different points in their flight operations. As described in the recently amended Airport Land Use Plan (ALUP), the airport area is broken down into six zones which are based on Caltrans’ Airport Land Use Planning Handbook, with a slight modification of Handbook zones 3 and 6 to accommodate the mix of commercial and General Avi- ation traffic using Runway 11-29. The configuration of the zones is based on Handbook Figures 4B through 4G, and the zone dimensions described in Handbook Figure 3A for a Long General Aviation Runway (runway length of 6,000 feet or more). In addition to safety zone considerations, there are also airspace, avigation and instrumentation issues to consider. FAA Part 77 establishes imaginary surfaces to set the maximum height of structures in the vicinity of the airport. None of the proposed structures will conflict with these maximums. ALUP Policy 2.5.2.1 prohibits development of any structure that is higher than 200 AGL to protect the Part 77 air space surfaces. FAA Part 77.9 also has special regulations to control obstructions that may be a haz- ard to avigation or to airport instrumentation. Projects that have an elevation greater than 1/100th of their distance to the nearest runway end (that is, buildings and structures that penetrate an imaginary surface that projects from the edges of the runway at a slope of 1 foot vertical for 100 feet horizontal) are to be reviewed and cleared by the FAA through a Form 7460-1 FAA Application before construction is proposed that penetrates this imaginary surface. Based on the preliminary grading plan, several struc- tures may exceed the elevation for 7460-1 review, and an application has been submitted to the FAA for its review. Compatibility with the ALUP is also dependent on the existence of airport compatible open space near the project and the City regulations. The City has an adopted Airport Compatible Open Space Plan (ACOS) and the Airport Area Specific Plan qualifies and serves as a Detailed Area Plan (DAP) under the ALUP. The Link 2 of 7 ALUP Conformity Analysis August, 2022 Safety Zones A development-area specific analysis was prepared for the Project that assessed population density, coverage, dwelling unit density, and other relevant factors contained in the ALUP. The results of that analysis are shown on Table 1. The relevant Safety Areas that affect the project are Zone 1 (Run- way Protection Zone), Zone 2 (Inner Approach/Departure Zone), Zone 3 (Inner Turning Zone), and Zone 6 (Traffic Pattern Zone) and these zones are shown on Figure 1 (Application Figures A-1 and A-10) as they relate to the Project’s Development Areas. Safety Zone 1—Runway Projection Zone (RPZ). This area is comprised or off-airport areas that are the most likely to be impacted by safety, overflight and noise issues. The RPZ has subareas desig- nated by the FAA that include object-free zones and obstruction free zones. Per FAA and ALUP regula- tions there are only limited uses and activities that are permitted in the RPZ. According to FAA Circular AC 150, while it is desirable to clear all objects from the RPZ, some uses are permitted, provided they do not attract wildlife, are outside of the Runway Object Free Area (OFA), and do not interfere with naviga- tional aids. Automobile parking facilities, although discouraged, may be permitted, provided the parking facilities and any associated appurtenances, are located outside of the central portion of the RPZ. Fuel storage facilities may not be located in the RPZ. Land uses prohibited from the RPZ are residences and places of public assembly such as churches, schools, hospitals, office buildings, shopping centers, and other uses with similar concentrations of persons typify places of public assembly. A small 9,500 SF portion of the parking lot in Development Area 11 is located in the RPZ, but otherwise has no surface improvements or objects. Most of Development Area 7 is in the RPZ, and it is designated for a park/pond. Per FAA and City of San Luis Obispo requirements, the ponding basin has been designed so that there is a maximum 48–hour period when standing water will exist, and the pond will be remain completely dry between storms. The project site and site plan comply with the FAA and ALUP design requirements for Safety Zone 1 (RPZ) because it has no dwellings, no places of public as- sembly, has limited parking and ponding facilities on approximately 4 acres of the 79-acre RPZ, and all such facilities are outside of the central portion of the RPZ and outside of the Object Free Area and the Obstruction Free Areas. Safety Zone 2 (Inner Approach-Departure Zone)—This zone includes areas that have frequent traffic associated with straight in, straight-out approaches and departures, especially by commercial air- craft. Approximately 1.4 acres of the parking lot in Development Area 11 at the northeast corner of In- novation Way and Tank Farm Road is located in Safety Zone 2. According to ALUP Table 4-5, parking lots are not listed, but “vehicle, freight, and transit terminals, truck stops” are listed as “compatible” uses and are this listed use is the closest land use group to parking lots in the table. The project site and site plan comply with the land use and design requirements for Safety Zone 2 because there are no dwell- ings, no places of public assembly, and is the same or similar to a land use listed as “compatible” in Table 4-5. Safety Zone 3 (Inner Turning Zone)— This zone includes areas that have frequent traffic associ- ated with turning or maneuvering of General Aviation aircraft. Safety Zone 3 for the San Luis Obispo Re- gional Airport is an amalgamation of Caltrans Safety Zone 3 for medium length and long general aviation runways and is intended to recognize that virtually all General Aviation and Commercial aircraft use runway 11-29. Only commercial elements of the project are contained in Safety Zone 3, and there are no residential uses. Table 1 shows the density of development in Zone 3 for each Development Area. Since the project site is covered by an ACOS and a Detailed Area Plan (the City Airport Area Specific The Link 3 of 7 ALUP Conformity Analysis August, 2022 Plan), the maximum permitted average density over the portion of the Zone 3 area proposed for devel- opment is 84 persons (customers and employees) per gross acre, and the maximum permitted density is 280 persons per any single acre according to ALUP Table 4-2. All of the proposed uses are considered Compatible or Conditionally Compatible (subject to density limitations) according to ALUP Table 4-5. The average density in the Zone 3 portion of the Project proposed for development is 72.4, and the max- imum density of a single acre in Zone 3 is 233 compared to the permitted maximum of 280. The ALUP specifies maximum building lot coverage of 60% in Zone 3; the project has a building lot coverage of 25.8%. All buildings in Zone 3 are also no more than three habitable above-ground stories. The pro- ject site and site plan comply with the land use and design requirements for Safety Zone 3 in the ALUP because there are no dwellings, no development that exceeds the density limitations, all of the proposed uses are listed as “compatible” or “conditionally compatible” in ALUP Table 4-5, and the lot coverage is substantially less than the 60% maximum specified in the ALUP. Safety Zone 6 (Inner Turning Zone)— This safety zone is the “traffic pattern” zone that is out- side of the main approach and departure corridors. Safety Zone 6 contains all of the residential units proposed for the project, including Development Areas 1, 8, 10 and 11. All of the proposed uses are considered Compatible or Conditionally Compatible (subject to density limitations) according to ALUP Table 4-5. The permitted residential density in Zone 6 is “unlimited”. For purposes of disclosure, the average density in the two Development Areas that are exclusively residential (Development Areas 8 and 10) of Zone 6 are 34.8 and 28.7, respectively. Development Areas 1 and 11 are mixed use portions of the project and the maximum permitted average population density in Zone 6 per ALUP Table 4-2 is 300 persons per gross acre, and the maximum for any single acre is 1,200 persons per gross acre. Within Development Area 1, the average density is 215.8 persons per gross acre, and the maximum for any sin- gle acre in Development Area 1 is 639 person per gross acre. Within Development Area 11, the average density is 170.9 persons per gross acre, and the maximum for any single acre in Development Area 11 is 274.8 person per gross acre. For Zone 6 as a whole (excluding the open space and conservation areas) the average density is 72.4, and the maximum density of a single acre in Zone 3 is 233 compared to the permitted maximum of 280. The project site and site plan comply with the land use and design re- quirements for Safety Zone 6 in the ALUP because the both the residential and mixed use portions of the project do not exceed the density limits in ALUP Table 4-2. Noise Zones As with the safety area criteria, the noise impact contours also follow mathematical rules re- lated to noise dispersion, and aircraft type and flight frequency along established and flight corridors. Peak and average noise levels that are mapped in the ALUP were projected through the usage of the FAA’s Integrated Noise Model, and contours are normally mapped relative to runway centerlines. In the case of the San Luis Obispo Regional Airport, it is estimated that approximately 97%+ of the flights use Runway 11-29, and that those flights that use Runway 7-25 normally use Runway 25 as an alternate ap- proach. According to the Airport Master Plan, Runway 11-29 provides 98.9% favorable wind coverage, and so the usage of Runway 7-25 is rare. Therefore, the ALUP’s and the Master Plan’s airport noise con- tours are both mapped relative to the extended centerline of Runway 11-29, and there are no special contours for Runway 7-25. A noise study was also prepared for the ALUC by RS&H that utilizes the most current and validated version of the Integrated Noise Model confirmed these conclusions. The Link 4 of 7 ALUP Conformity Analysis August, 2022 As illustrated on ALUP Figure 3 (ALUP Figure 4-1), none of the designated Development Areas are within the CNEL 60 noise contours to the RSH Noise Study. The ALUP has established a maximum permitted exterior noise level of 65 CNEL for Extremely Sensitive Land Use (such as residences and dwellings). It also establishes an interior noise standard for residential uses of 45 dB(A) and 50 dB(A) for non-residential uses. The 65 dB(A) contours do not impact any of the Development Areas; and, assum- ing a sound level reduction of 20 dB(A) between exterior and interior noise levels as specified in the ALUP, no building interiors will be exposed to aircraft noise exceeding 40 dB(A). California Airport Reg- ulations in PUC Section 21669, and Section 5000 of the California Code of Regulations also states that 65 CNEL or less is acceptable for residential uses. Further, 65 CNEL and greater is considered compatible if there is an avigation easement, indoor noise exposure is limited to 45 dB(A) CNEL or less. The City noise standard is for an interior CNEL/Ldn of 45 dB(A) or less, and an outdoor level of 60 dB(A) or less. The ALUP noise contours show that none of the site’s Development Areas will be exposed to outdoor aircraft noise in excess of 60 dB(A), or interior aircraft noise of 40 dB(A) or greater. The Project com- plies with federal, state, City and ALUP standards. The project is consistent with ALUP noise policies N-1, N-2, N-3, N-4 and N-5. The Link 5 of 7 ALUP Conformity Analysis August, 2022 Figure 1 Safety Zones Covelop: The LinkJuly 11, 2022 Covelop: The Link A-1Peck Planning and Development Development Areas and Buildings Key Map Figure 1 9 4 3 2 8 7 6 5 1211 10 14 13 1615 17 18 19 20 22 21 26252423 27 28 29 Area 11: Mixed Use (C-C/MU) Area 1: Mixed Use (C-C/MU) Area 2: Hangar Commercial (CS) Area 3: Professional Offices (BP-C-S) Area 4: District Flex Space (CS) Area 5: Research and Development (CS) Area 6: Industrial (CS) Area 7: Park/Pond (CS) Area 8: Multifamily 1 (R-4) Area 9: Medical Offices (BP-C-S) Area 10: Multifamily 2 (R-4) Area 12: Neighborhood Park Area 13: Fire Station Area 14: Overflow Parking (CS) See Figure A-2 and Attachment B for a statistical summary of building areas, parking and other site data for each subarea and each building. See Figure A- 10 for ALUP Safety Zones. RRM Design Group Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road"B" Street "A" Street"C" Street 30 31 32 33 34 35 36 37 Covelop: The LinkJuly 26, 2022 Covelop: The Link A-10July 26, 2022 Peck Planning and Development Safety Zone 3 Safety Zone 2 RPZ Safety Zone 6 Safety Zone 6 Covelop: The LinkLand Plan and ALUP Safety Zones FigureRRM Design Group Tank Farm Road Tank Farm Road Santa Fe RoadSanta Fe Road"B" Street "A" Street"C" Street05001000 ft 2'6' 1"=400' The Link 6 of 7 ALUP Conformity Analysis August, 2022 Figure 3 Noise Zones Chapter 4 – San Luis Obispo Regional Airport Land Use Policies San Luis Obispo County Regional Airport – Airport Land Use Plan 4-7 Figure 4-1: San Luis Obispo County Regional Airport Noise Contours Source: RS&H, 2015 The Link 7 of 7 ALUP Conformity Analysis August, 2022 Table 1 ALUP Conformity Table Table 1 Airport Land Use Plan Conpatibility Analysis Reference Number (See Figure A-1)Use Area/Uses Ground Floor Floors Total Floor Area Dwelling Units Commercial Square Footage RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (1) Safety Zone 6 (2) Total RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total Area 1 Mixed Use - - - - - - Bldg 1 Residential Mixed Use 23,500 4.00 94,000 72 23,500 72 72 - - - - 126 126 Bldg 2 Residential Mixed Use 9,250 4.00 37,000 28 9,250 28 28 - - - - 49 49 Bldg 3 Retail 10,000 1.00 10,000 10,000 - - - - - - - Mixed Use Subtotal 42,750 141,000 100 42,750 0.52 3.34 3.86 100 100 - - - - 175 175 Average Area Density 29.94 Maximum Single Acre Density 72.00 Area 2 Hangar - - - - - - - Bldg 4 Retail/Light Manufacturing Mixed Use 14,350 1.25 17,938 22,422 0.87 - - - - - - - Bldg 5 Retail/Light Manufacturing Mixed Use 12,500 1.25 15,625 19,531 0.80 - - - - - - - Hangar Use Subtotal 26,850 33,563 - 41,953 1.67 1.67 - - - - - - - Average Area Density Maximum Single Acre Density Office Core Group - Area 3 Office 1 - - - - - - - Bldg 6 Office Mixed 10,250 2.00 20,500 20,500 1.03 - - - - - - - Bldg 7 Office Mixed 10,250 2.00 20,500 20,500 1.03 - - - - - - - Bldg 8 Office Mixed 11,000 2.50 27,500 27,500 1.20 - - - - - - - Bldg 9 Office Mixed 11,000 2.50 27,500 27,500 1.20 - - - - - - - Bldg 10 Office Mixed 15,500 3.00 46,500 46,500 1.82 - - - - - - - Office Core Subtotal 58,000 142,500 142,500 6.28 6.28 - - - - - - - Average Area Density Maximum Single Acre Density District - - - - - - - Area 4 District Flex Space - - - - - - - Bldg 11 RD/Retail (50/50)13,750 1.50 20,625 20,625 1.02 - - - - - - - Bldg 12 RD/Retail (50/50)15,500 1.50 23,250 23,250 1.02 - - - - - - - Bldg 15 RD/Retail (50/50)19,000 1.50 28,500 28,500 1.02 - - - - - - - Bldg 16 RD/Retail (50/50)16,000 1.50 24,000 24,000 1.02 - - - - - - - District Subtotal 63,750 96,375 - 96,375 4.07 4.07 - - - - - - - Average Area Density Maximum Single Acre Density Research and Development Area 5 Research and Development - - - - - - - Bldg 17 RD/Light Man (50/50)18,750 1.25 23,438 23,438 0.80 - - - - - - - Bldg 18 RD/Light Man (50/50)16,750 1.25 20,938 20,938 0.76 - - - - - - - Bldg 14 RD/Light Man (50/50)14,500 1.25 18,125 18,125 0.70 - - - - - - - Bldg 19 RD/Light Man (50/50)15,250 1.25 19,063 19,063 0.77 - - - - - - - Bldg 13 RD/Light Man (50/50)13,800 1.25 17,250 17,250 1.50 - - - - - - - RD/Light Man Subtotal 79,050 98,813 98,813 4.06 4.06 - - - - - - - Average Area Density Maximum Single Acre Density Industrial Area 6 Industrial w/Office (80/20)- - - - - - - Bldg 20 Industrial/Service Commercial - - - - - - - Bldg 21 Industrial/Service Commercial - - - - - - - Bldg 22 Industrial/Service Commercial - - - - - - - Industrial Subtotal 209,000 1.00 209,000 209,000 11.71 11.71 - - - - - - - Average Area Density Maximum Single Acre Density Park/Pond Area 7 Park Pond - - - - - - - Park K Dog Park 4,900 1.00 4,900 4,900 0.64 - - - - - - - Pond 3.37 - - - - - - - Park - 0.89 - - - - - - - Park/Pond Subtotal 4,900 4,900.00 - 4,900.00 4.53 0.28 0.09 4.90 - - - - - - - Average Area Density Maximum Single Acre Density Area Dwelling Units Population Table 1 Airport Land Use Plan Conpatibility Analysis Reference Number (See Figure A-1)Use Area/Uses Ground Floor Floors Total Floor Area Dwelling Units Commercial Square Footage RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (1) Safety Zone 6 (2) Total RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total Area Dwelling Units Population Area 8 Multifamily 1 Multifamily 350 0.21 10.05 10.26 350 350 - - - - 613 613 Average Area Density 34.83 34.11 Maximum Single Acre Density 46.00 Area 9 Medical Offices Bldg 23 Medical Offices 10,975 1.50 16,463 16,463 1.38 - - - - - - - Bldg 24 Medical Offices 23,529 1.75 41,176 41,176 2.11 - - - - - - - Bldg 25 Medical Offices 19,732 1.75 34,531 34,531 2.41 - - - - - - - Bldg 26 Medical Offices 22,500 2.00 45,000 45,000 2.38 - - - - - - - Med Office Subtotal 76,736 137,169 137,169 7.75 0.53 8.28 - - - - - - - Average Area Density - - Maximum Single Acre Density 46.00 Area 10 Multifamily 2 Multifamily 50 1.74 1.74 50 50 - - - - 88 88 Average Area Density 28.74 28.74 Maximum Single Acre Density 35.00 Area 11 Mixed Use Bldg 27 Residential Mixed Use 15,500 3.00 46,500 34 10,750 34 34 - - - 60 - 60 Bldg 28 Residential Mixed Use 15,500 3.00 46,500 34 10,750 34 34 - - - 60 - 60 Bldg 29 Multifamily 37,500 4.00 150,000 157 - 157 157 - - - 275 - 275 Mixed Use Subtotal 68,500 243,000 225 21,500 1.42 4.40 5.82 225 225 - - - 394 - 394 Average Area Density 51.14 Maximum Single Acre Density 157.00 Other Uses/Areas Area 12 Public Park 1.96 1.96 - - - - - - - Public Roads 1.99 2.85 6.02 1.64 2.90 15.40 - - - - - - - Area 13 Fire Station 8,850 1.00 8,850 1.32 1.32 - - - - - - - Area 14 Overflow Parking 0.10 0.64 0.74 - - - - - - - Open Space/Conservation 48.43 75.23 19.29 107.35 - 250.30 - - - - - - - Other Uses/Areas Subtotal 8,850 8,850 - - 50.52 78.08 29.23 108.99 2.90 269.72 - - - - - - - Total 1,115,169 725 794,960 55.05 79.78 65.59 113.39 18.56 332.37 - - - 225 500 725 - - - 394 875 1,269 Check Total 55.05 79.78 65.59 113.39 18.56 332.37 Allowed Density with Approved ACOS (Area)- 0 0 None None Allowed Density (Max Single Acre)- - - None None Maximum Allowed Lot Coverage Allowed Mixed Use Density with Approved ACOS (Area) Allowed Mixed Use Density (Max Single Acre) Project Density (Area Average)37.25 26.94 Project Density (Max Single Acre)157.00 72.00 Table 1 Airport Land Use Plan Conpatibility Analysis Reference Number (See Figure A-1)Use Area/Uses Ground Floor Floors Total Floor Area Dwelling Units Commercial Square Footage Area 1 Mixed Use Bldg 1 Residential Mixed Use 23,500 4.00 94,000 72 23,500 Bldg 2 Residential Mixed Use 9,250 4.00 37,000 28 9,250 Bldg 3 Retail 10,000 1.00 10,000 10,000 Mixed Use Subtotal 42,750 141,000 100 42,750 Average Area Density Maximum Single Acre Density Area 2 Hangar Bldg 4 Retail/Light Manufacturing Mixed Use 14,350 1.25 17,938 22,422 Bldg 5 Retail/Light Manufacturing Mixed Use 12,500 1.25 15,625 19,531 Hangar Use Subtotal 26,850 33,563 - 41,953 Average Area Density Maximum Single Acre Density Office Core Group Area 3 Office 1 Bldg 6 Office Mixed 10,250 2.00 20,500 20,500 Bldg 7 Office Mixed 10,250 2.00 20,500 20,500 Bldg 8 Office Mixed 11,000 2.50 27,500 27,500 Bldg 9 Office Mixed 11,000 2.50 27,500 27,500 Bldg 10 Office Mixed 15,500 3.00 46,500 46,500 Office Core Subtotal 58,000 142,500 142,500 Average Area Density Maximum Single Acre Density District Area 4 District Flex Space Bldg 11 RD/Retail (50/50)13,750 1.50 20,625 20,625 Bldg 12 RD/Retail (50/50)15,500 1.50 23,250 23,250 Bldg 15 RD/Retail (50/50)19,000 1.50 28,500 28,500 Bldg 16 RD/Retail (50/50)16,000 1.50 24,000 24,000 District Subtotal 63,750 96,375 - 96,375 Average Area Density Maximum Single Acre Density Research and Development Area 5 Research and Development Bldg 17 RD/Light Man (50/50)18,750 1.25 23,438 23,438 Bldg 18 RD/Light Man (50/50)16,750 1.25 20,938 20,938 Bldg 14 RD/Light Man (50/50)14,500 1.25 18,125 18,125 Bldg 19 RD/Light Man (50/50)15,250 1.25 19,063 19,063 Bldg 13 RD/Light Man (50/50)13,800 1.25 17,250 17,250 RD/Light Man Subtotal 79,050 98,813 98,813 Average Area Density Maximum Single Acre Density Industrial Area 6 Industrial w/Office (80/20) Bldg 20 Industrial/Service Commercial Bldg 21 Industrial/Service Commercial Bldg 22 Industrial/Service Commercial Industrial Subtotal 209,000 1.00 209,000 209,000 Average Area Density Maximum Single Acre Density Park/Pond Area 7 Park Pond Park K Dog Park 4,900 1.00 4,900 4,900 Pond Park - Park/Pond Subtotal 4,900 4,900.00 - 4,900.00 Average Area Density Maximum Single Acre Density RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total 23,500 23,500 - - - - 392 392 9,250 9,250 - - - - 154 154 10,000 10,000 - - 167 - - 167 - - 10,000 - 32,750 42,750 - - 167 - 546 713 29.4%22.5% 22,422 22,422 - - 100 - - 100 19,531 19,531 - - 87 - - 87 - - 41,953 - - 41,953 - - 186 - - 186 36.9%111.65 111.65 186.00 20,500 20,500 - - 103 - - 103 20,500 20,500 - - 103 - - 103 27,500 27,500 - - 138 - - 138 27,500 27,500 - - 138 - - 138 46,500 46,500 - - 233 - - 233 - - 142,500 - - 142,500 - - 713 - - 713 21.2%113.46 113.46 233.00 20,625 20,625 - - 92 - - 92 23,250 23,250 - - 103 - - 103 28,500 28,500 - - 127 - - 127 24,000 24,000 - - 107 - - 107 - - 96,375 - - 96,375 - - 428 - - 428 36.0%105.24 105.24 127.00 23,438 23,438 - - 104 - - 104 20,938 20,938 - - 93 - - 93 18,125 18,125 - - 81 - - 81 19,063 19,063 - - 85 - - 85 17,250 17,250 - - 77 - - 77 - - 98,813 - - 98,813 - - 439 - - 439 44.7%108.17 108.17 104.00 - - - - 209,000 209,000 - - 643 - - 643 41.0%54.92 54.92 193.00 - 4,900 4,900 - - 82 - - 82 - - - - - - - - - - - - - - - - 4,900 - - 4,900 - - 82 - - 82 2.3%907.41 16.67 Commercial SF Max Occupancy per ALUP Table 4-2 Table 1 Airport Land Use Plan Conpatibility Analysis Reference Number (See Figure A-1)Use Area/Uses Ground Floor Floors Total Floor Area Dwelling Units Commercial Square Footage Area 1 Mixed UseArea 8 Multifamily 1 Multifamily 350 Average Area Density Maximum Single Acre Density Area 9 Medical Offices Bldg 23 Medical Offices 10,975 1.50 16,463 16,463 Bldg 24 Medical Offices 23,529 1.75 41,176 41,176 Bldg 25 Medical Offices 19,732 1.75 34,531 34,531 Bldg 26 Medical Offices 22,500 2.00 45,000 45,000 Med Office Subtotal 76,736 137,169 137,169 Average Area Density Maximum Single Acre Density Area 10 Multifamily 2 Multifamily 50 Average Area Density Maximum Single Acre Density Area 11 Mixed Use Bldg 27 Residential Mixed Use 15,500 3.00 46,500 34 10,750 Bldg 28 Residential Mixed Use 15,500 3.00 46,500 34 10,750 Bldg 29 Multifamily 37,500 4.00 150,000 157 - Mixed Use Subtotal 68,500 243,000 225 21,500 Average Area Density Maximum Single Acre Density Other Uses/Areas Area 12 Public Park Public Roads Area 13 Fire Station 8,850 1.00 8,850 Area 14 Overflow Parking Open Space/Conservation Other Uses/Areas Subtotal 8,850 8,850 - - Total 1,115,169 725 794,960 Check Total Allowed Density with Approved ACOS (Area) Allowed Density (Max Single Acre) Maximum Allowed Lot Coverage Allowed Mixed Use Density with Approved ACOS (Area) Allowed Mixed Use Density (Max Single Acre) Project Density (Area Average) Project Density (Max Single Acre) RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total Commercial SF Max Occupancy per ALUP Table 4-2 23.5%- - 16,463 16,463 - - 82 - - 82 41,176 41,176 - - 206 - - 206 34,531 34,531 - - 173 - - 173 45,000 45,000 - - 225 - - 225 - - 137,169 - - 137,169 - - 686 - - 686 22.7%88.50 82.83 225.00 - - 16.0%- 10,750 10,750 - - - 179 - 179 10,750 10,750 - - - 179 - 179 - - - - - - - - - - 21,500 - 21,500 - - - 358 - 358 35.7% - - - 10 10 - - - - - - - - - - - - 10 - - 10 - - 740,710 21,500 32,750 794,960 - - 3,354 358 546 4,258 35 84 300 300 128 280 1,200 1,200 0%50%60%100%100% 72.43 59.33 29.41 233.00 179.17 391.67 Table 1 Airport Land Use Plan Conpatibility Analysis Reference Number (See Figure A-1)Use Area/Uses Ground Floor Floors Total Floor Area Dwelling Units Commercial Square Footage Area 1 Mixed Use Bldg 1 Residential Mixed Use 23,500 4.00 94,000 72 23,500 Bldg 2 Residential Mixed Use 9,250 4.00 37,000 28 9,250 Bldg 3 Retail 10,000 1.00 10,000 10,000 Mixed Use Subtotal 42,750 141,000 100 42,750 Average Area Density Maximum Single Acre Density Area 2 Hangar Bldg 4 Retail/Light Manufacturing Mixed Use 14,350 1.25 17,938 22,422 Bldg 5 Retail/Light Manufacturing Mixed Use 12,500 1.25 15,625 19,531 Hangar Use Subtotal 26,850 33,563 - 41,953 Average Area Density Maximum Single Acre Density Office Core Group Area 3 Office 1 Bldg 6 Office Mixed 10,250 2.00 20,500 20,500 Bldg 7 Office Mixed 10,250 2.00 20,500 20,500 Bldg 8 Office Mixed 11,000 2.50 27,500 27,500 Bldg 9 Office Mixed 11,000 2.50 27,500 27,500 Bldg 10 Office Mixed 15,500 3.00 46,500 46,500 Office Core Subtotal 58,000 142,500 142,500 Average Area Density Maximum Single Acre Density District Area 4 District Flex Space Bldg 11 RD/Retail (50/50)13,750 1.50 20,625 20,625 Bldg 12 RD/Retail (50/50)15,500 1.50 23,250 23,250 Bldg 15 RD/Retail (50/50)19,000 1.50 28,500 28,500 Bldg 16 RD/Retail (50/50)16,000 1.50 24,000 24,000 District Subtotal 63,750 96,375 - 96,375 Average Area Density Maximum Single Acre Density Research and Development Area 5 Research and Development Bldg 17 RD/Light Man (50/50)18,750 1.25 23,438 23,438 Bldg 18 RD/Light Man (50/50)16,750 1.25 20,938 20,938 Bldg 14 RD/Light Man (50/50)14,500 1.25 18,125 18,125 Bldg 19 RD/Light Man (50/50)15,250 1.25 19,063 19,063 Bldg 13 RD/Light Man (50/50)13,800 1.25 17,250 17,250 RD/Light Man Subtotal 79,050 98,813 98,813 Average Area Density Maximum Single Acre Density Industrial Area 6 Industrial w/Office (80/20) Bldg 20 Industrial/Service Commercial Bldg 21 Industrial/Service Commercial Bldg 22 Industrial/Service Commercial Industrial Subtotal 209,000 1.00 209,000 209,000 Average Area Density Maximum Single Acre Density Park/Pond Area 7 Park Pond Park K Dog Park 4,900 1.00 4,900 4,900 Pond Park - Park/Pond Subtotal 4,900 4,900.00 - 4,900.00 Average Area Density Maximum Single Acre Density RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total - - - - 518 518 - - - - 203 203 - - 167 - - 167 - - 167 - 721 888 320.51 215.82 229.92 639.00 - - 100 - - 100 - - 87 - - 87 - - 186 - - 186 - - 103 - - 103 - - 103 - - 103 - - 138 - - 138 - - 138 - - 138 - - 233 - - 233 - - 713 - - 713 - - 92 - - 92 - - 103 - - 103 - - 127 - - 127 - - 107 - - 107 - - 428 - - 428 - - 104 - - 104 - - 93 - - 93 - - 81 - - 81 - - 85 - - 85 - - 77 - - 77 - - 439 - - 439 - - 643 - - 643 - - 82 - - 82 - - - - - - - - - - - - - - - - 82 Max Occupancy Residential and Non-Residential Population Table 1 Airport Land Use Plan Conpatibility Analysis Reference Number (See Figure A-1)Use Area/Uses Ground Floor Floors Total Floor Area Dwelling Units Commercial Square Footage Area 1 Mixed UseArea 8 Multifamily 1 Multifamily 350 Average Area Density Maximum Single Acre Density Area 9 Medical Offices Bldg 23 Medical Offices 10,975 1.50 16,463 16,463 Bldg 24 Medical Offices 23,529 1.75 41,176 41,176 Bldg 25 Medical Offices 19,732 1.75 34,531 34,531 Bldg 26 Medical Offices 22,500 2.00 45,000 45,000 Med Office Subtotal 76,736 137,169 137,169 Average Area Density Maximum Single Acre Density Area 10 Multifamily 2 Multifamily 50 Average Area Density Maximum Single Acre Density Area 11 Mixed Use Bldg 27 Residential Mixed Use 15,500 3.00 46,500 34 10,750 Bldg 28 Residential Mixed Use 15,500 3.00 46,500 34 10,750 Bldg 29 Multifamily 37,500 4.00 150,000 157 - Mixed Use Subtotal 68,500 243,000 225 21,500 Average Area Density Maximum Single Acre Density Other Uses/Areas Area 12 Public Park Public Roads Area 13 Fire Station 8,850 1.00 8,850 Area 14 Overflow Parking Open Space/Conservation Other Uses/Areas Subtotal 8,850 8,850 - - Total 1,115,169 725 794,960 Check Total Allowed Density with Approved ACOS (Area) Allowed Density (Max Single Acre) Maximum Allowed Lot Coverage Allowed Mixed Use Density with Approved ACOS (Area) Allowed Mixed Use Density (Max Single Acre) Project Density (Area Average) Project Density (Max Single Acre) RPZ Safety Zone 2 Safety Zone 3 Safety Zone 6 (West) Safety Zone 6 (East) Total Max Occupancy Residential and Non-Residential Population - - - - 613 613 - - 82 - - 82 - - 206 - - 206 - - 173 - - 173 - - 225 - - 225 - - 686 - - 686 - - - - 88 88 - - - 239 - 239 - - - 239 - 239 - - - 275 - 275 - - - 752 - 752 - 170.93 129.22 274.75 - - - - - - - - 10 - - 10 - - - - - - - - 10 - - 10 - - 20 - - 20 - - 3,282 752 1,421 5,537 - 53 98 300 300 159 294 1,200 1,200 70.89 124.52 76.55 232.50 274.75 639.00 1 From:Bryan Hulburd <bhulburd@covelop.net> Sent:Wednesday, August 23, 2023 1:20 PM To:'Hernandez, Christine@Waterboards' Cc:dmavis@covelop.net; scargill@covelop.net; 'Lotz, Tracy@Waterboards'; 'Schroeter, Angela@Waterboards'; 'Bishop, Greg@Waterboards'; 'Niles, Dan@Waterboards'; Schwartz, Luke Subject:RE: ROUNDABOUT PROJECT, EAST BOUNDARY 276 TANK FARM ROAD, CITY OF SAN LUIS OBISPO - COST RECOVERY PROGRAM Attachments:08-21-2023_scp_cost_recovery_covelop_executed.pdf Flag Status:Flagged This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Thank you, ChrisƟne. Please see aƩached executed cost recovery agreement. Bryan Hulburd Project Manager bhulburd@covelop.net From: Hernandez, Christine@Waterboards <Christine.Hernandez@Waterboards.ca.gov> Sent: Monday, August 21, 2023 8:43 AM To: Bryan Hulburd <bhulburd@covelop.net> Cc: dmavis@covelop.net; scargill@covelop.net; Lotz, Tracy@Waterboards <Tracy.Lotz@Waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov> Subject: SCP: ROUNDABOUT PROJECT, EAST BOUNDARY 276 TANK FARM ROAD, CITY OF SAN LUIS OBISPO – COST RECOVERY PROGRAM SITE CLEANUP PROGRAM: ROUNDABOUT PROJECT AT EAST BOUNDARY OF THE FORMER UNION OIL COMPANY OF CALIFORNIA, SAN LUIS OBISPO SAN LUIS OBISPO TANK FARM, 276 TANK FARM ROAD, CITY OF SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – COST RECOVERY PROGRAM FOR REGIONAL WATER QUALITY CONTROL BOARD REGULATORY OVERSIGHT The Central Coast Regional Water Quality Control Board is increasing its efforts to transmit correspondence and other information electronically, reducing the amount of paper used, and increasing the speed of which information is distributed. Therefore, you are receiving the attached correspondence for the subject site from the Central Coast Water Board in a Portable Data Format (PDF) format. If you need help opening this document, please refer to the link below; http://www.adobe.com/products/acrobat/readstep2.html @sV Yrrl Glccn FNVIAONM€NIAL PNOlECTION Glvrn Nswsou Water Boards Central Coast Regional Water Quality Control Board August 21,2023 Bryan Hulburd Covelop, lnc. 1304 Garden Street San Luis Obispo, CA 93401 Email: bhulburd@covelop. net Sent via Electronic Mail Dear Bryan Hulburd: SITE CLEANUP PROGRAM: ROUNDABOUT PROJECT AT EAST BOUNDARY OF THE FORMER UNION OIL COMPANY OF CALIFORNIA, SAN LUIS OBISPO SAN LUIS OBISPO TANK FARM, 276 TANK FARM ROAD, CITY OF SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY - COST RECOVERY PROGRAM FOR REGIONAL WATER QUALITY CONTROL BOARD REGULATORY OVERSIGHT The California Regional Water Quality Control Board (Central Coast Water Board) is a state regulatory agency with the responsibility for protecting the quality of the waters of the state within its area of jurisdiction. The Central Coast Water Board has authority to require submission of information, direct action, establish regulations, levy penalties, and bring legal action when necessary to protect water quality. California Water Code (Water Code) section 13304 provides that the Central Coast Water Board may require any person who causes or permits the discharge of waste into waters of the State to clean up all waste discharged and restore the affected water to background conditions (i.e. the water quality that existed before the discharge). One of the most effective ways for a responsible party and Central Coast Water Board staff to be involved in cleanup oversight is through the Cost Reimbursement Program. This Program assures a responsible party that Central Coast Water Board participation will be efficient and timely. Cost Reimbursement for Regulatory Oversight Our statutory authority to recover reasonable costs for regulatory oversight of cleanups is based on Water Code provisions, including sections 13304 and 13365. These sections allow the Central Coast Water Board to recover reasonable expenses from a responsible party for oversight of cleanup of illegal discharges, contaminated properties, and other unregulated releases potentially or actually adversely affecting waters of the State. lt is our intention to recover regulatory oversight costs for time expended providing regulatory review and oversight of the remediation project, if needed, at the subject site. Our oversight work includes: field and office work; site inspections; sampling; coordination with other agencies; meetings; case discussions; technical report and document review; regulatory review; correspondence preparation; closure Jarue GRav, cHnrn I Marruew T. KreLtltc, EXEcurlvE oFFlcEB 895 Aerovista Placo, Suite 1 01, San Luis Obispo, CA 93401 | www.waterboards.ca.gov/centralcoast Bryan Hulburd -2-August 21,2023 reviews; and enforcement, as necessary. You will be invoiced periodically (generally every three to six months) and your account will be due and payable at the time of invoicing. Please acknowledge your intent to reimburse costs for cleanup oversight work as stated herein by completing and signing Attachment 3, "Acknowledgement of Receipt of Oversight Cost Reimbursement Account Letter," and returning it to this office nolaterthan@'Adetaileddescriptionofthebillingprocedureis enclosed (Attachment 2). Also, pursuant to state law, this letter provides you with the following information regarding costs for regulatory oversight: 1. An estimate of the work to be performed or services to be provided. 2. A statement of the expected outcome of that work. 3. The billing rates for all individuals and classes of employees expected to engage in the work. 4. An estimate of all expected charges to be billed to you by this agency. 1. Estimate of Work to be Performed Central Coast Water Board staff estimates that the following work will be performed during state fiscal year 202312024 (July 1 to June 30): . Develop specific requirements addressing water quality issues. . Conduct site inspection(s) to help determine status of various potential water quality issues.o Attend meetings with discharger(s), their representatives, consultants and other interested parties. . Conduct telephone communications with discharger(s) their representatives, consultants and other interested parties. o Review and comment on technical reports such as workplans, monitoring reports, ground and surface water monitoring program proposals, site health and safety plan, site characterization and remedial action plan, remedial action reports, etc.. Conduct agency internal communications such as memos, meetings, etc. . Conduct site inspections and verification sampling. 2. Statement of Expected Outcome The following are expected outcomes of work performed during state fiscal year 202312024:. Accurate physical and chemical characterization of water and sediment pollution sources and impacts, if appropriate. . Adequate water quality monitoring, if needed. . Commence remediation of water and sediment pollution sources and water and sediment pollution, as needed. . Agency verification of the discharger's data and conclusions. . Compliance with agency requirements. Bryan Hulburd -3-August 21,2023 3. Billinq Rates Enclosed are the billing rates for Central Coast Water Board employees expected to perform work. The name and classification of employees who charge time to this site will be listed on the invoices. We will make every attempt to minimize staff oversight costs. A description of the billing procedures and the cost recovery process are included in Attachments 1 and 2. 4. Estimate of Expected Charqes ln accordance with state law, this letter and attachments provide you with an estimate of the projected number of hours that we will charge for oversight of your cleanup project during lhe 2023t2024 fiscal year, July 1 ,2023, to June 30,2024. Central Coast Water Board staff expects to charge approximately 80 hours of work related to this site and estimate the total cost to be $17,500. The rate will vary depending on the salary of the Central Coast Water Board staff individual(s) responsible for the oversight. This is a rough estimate and the actual time expended will depend on the nature and extent of tnelite investigation and cleanup (if needed), as well as yourwillingness to accomplish the cleanup in a timely manner. 5.Case Prioritization a nd Resoonse Times The Central Coast Water Board ranks and prioritizes cleanup cases using three criteria . Risk to human health and the environment, . Site waste and complexity, and . Public participation interest and need. Site that are ranked with a higher priority using these criteria, particularly the risk to human health and the environment, will be given priority for staff time. Other projects, such as redevelopment projects that may not rank as a priority using these criteria, may experience delayed response times. lf you have any questions, please feel free to contact Greg Bishop at (805) 549-3132 or by email at qreq. bishop@waterboards. ca.qov. Sincerely, s h e i I a s o d e r b 66W, lJji'triiJ,:i.",'11Tf'i"' '.,.. i, for Matthew T. Keeling Executive Officer Attachments: 1. Billing Cost Explanation 2. Process for Regulatory Oversight Bryan Hulburd -4-August 21,2023 3. Acknowledgement of Receipt of Oversight Cost Reimbursement Account Letter cc: Damien Mavis, Covelop, dmavis@covelop.net Shell Carg ill, Covelop, scarg ill@covelop. net Tracy Lotz, State Water Resources Control Board, tracy.lotz@waterboards.ca.gov Angela Sch roeter, Central Coast Water Board, angela. sch roeter@waterboards. ca. gov Greg Bishop, Central Coast Water Board, greg. bishop@waterboards. ca. gov Dan Niles, Central Coast Water Board, dan.niles@waterboards.ca.gov GT rD# T10000020787 R:\RB3\Shared\ScP\SITES\SLO Co\San Luis Obispo\276 Tank Farm Road - Covelop SLO Tank Farm\Cost Recovery - Roundabout\O8-1 8-2023-scp-cost-recovery-covelop-roundabou!-slo{f .docx Attachment 1 STATE WATER RESOURCES CONTROL BOARD srTE CLEANUP PROGRAM (SCP) BTLLING COST EXPLANATION Fiscal Year 2023'2024 Em and Benefit Classification Ran AEO - Assistant Executive Officer CEA ADMOFFII - Admin Officer ll AGPA - Associate Governmental Program Analyst AFCNSL - Staff Counsel (Attorney) SFCNSLIII - Staff Counsel lll (Attorney) SFCNSLIV - Staff Counsel lV (Attorney) BSA - Business Serv Asst EG - Engineering Geologist EPMI- Environmental Program Manager I EPMII- Environmental Program Manager ll ES - Environmental Scientist EOI- Exec Officer I EOll- Exec Officer ll OA - Office Assistant OT - Office Technician PWRCE - PrincipalWater Resources Control Engineer PPS - Public Participation Specialist SEA - Sanitary Engineering Associate SET - Sanitary Engineering Technician SEG - Senior Engineering Geologist SRES - Senior Environmental Scientist SRES - Senior EnvironmentalScientist (Spec) SWRCE - Senior Water Resources Control Engineer SSA - Staff Services Analyst SUEG - Supervising Engineering Geologist SUWRCE - Supervising Water Resources Control Engineer WRCE - Water Resources Control Engineer $ 13,563 $ 8,550 $ 7,902 $ 10,244 $ 14,643 $ 16,177 $ 4,482 $ 8,585 $ 16,609 $ 19,276 $ 5,936 $ 22,167 $ 22,709g 4,124 $ 4,825 $ 20,198 $ 7,902 $ 8,e08 $ 6,137 $ 15,136 $ 14,364 $ 10,506 $ 15,136 $ 5,061 $ 16,625 $ 16,625 $ 8,585 28,008 10,623 1 0,1 91 15,518 18,786 20,770 7,063 16,164 20,648 21,898 11,351 25,182 25,794 5,767 6,220 22,942 9,892 11,152 8,815 18,944 17,857 13,069 18,944 8,472 20,810 20,810 16,082 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ lntermittent Emplovees : SA - Scientific Aid $16.07/hour $1 9.07/hour Note: The State is currently in negotiations with the unions so the upper limits of these ranges may be subject to change. lndirect Costs (Overhead + Admin = cost of doing business) Billing Example for One Month Salary WRCE - Water Resources Control Engineer Total Direct Labor Charges [3] (per month): Contract Charges (if applicable): Direct Labor Overhead: State Board Program Admin and Overhead: Regional Board Program Admin and Overhead: Total Cost (per month): Operating Expenses and Equipment [2] (both State and Regional Board offices) 140% 12,062 2,414 8,041 Divided by 176 hours per month equals per hour: (Due to the various classifications that expend SCP resources an average of $215.00 per hour can be used for projection purposes.) $ 38,600 $ 219 [1] The name and classification of employees performing oversight work will be listed on invoices you receive [2] The examples are estimates based on recent billings. Actual charges may be higher or lower. [3] Total Direct Labor Charges = Salary and Benefits $ $ $ $ $ 0826, @sv Yara Gancta ENVIFONMENTAT Pfl OTECIION Grvrn NEwsou Water Boards Central Coast Regional Water Quality Control Board ATTACHMENT 2 srTE GLEANUP PROGRAM (SCP) PROCESS FOR REGULATORY OVERSIGHT We have identified your facility or property as requiring regulatory cleanup oversight. Pursuant to the Porter-Cologne Water Quality ControlAct (a. k. a. California Water Code), the Central Coast Regional Water Quality Control Board (Water Board) can recover reasonable costs for such oversight from the responsible party or parties. The purpose of the enclosure is to explain the oversight billing process structure. INTRODUCTION The Porter-Cologne Water Quality ControlAct authorizes the State Water Resources Control Board (State Water Board) to set up Cost Recovery Programs. The Budget Act of 19g3 authorized the State Water Board to establish a Site Cleanup (SCP) Cost Recovery Program. The program is set up so that reasonable expenses incurred by the State WEter Board and Water Board in overseeing cleanup of illegal discharges, contaminated properties, and other unregulated releases adversely impacting the State's waters can be reimbursed by the responsible party. Reasonable expenses will be billed to responsible parties and collected by the Fee Coordinator at the State Water Board. This statement of oversight costs is being sent to each of the parties named in the Cleanup and Abatement Order (Order) or to the party who signed the agreement to pay oversight costs. Each party is jointly and severally responsible that the full amount is paid. the parties may agree to apportion the amount as they see appropriate. lf payment in full is not received by the due date, the State Water Board will enforce its coit recovery against any or all the parties named in the Order or, who signed the agreement to pay oversight costs. THE BILLING SYSTEM Each cost recovery account has a unique charge number assigned to it. Whenever any oversight work is done, the hours are billed to the account number on the employee's time sheet. The cost of the staff hours is calculated by the State Accounting System based on the employee's salary and benefit rate and the State Water Board overhead rate. State Water Board and Water Board Administrative charges for work such as accounting, billing preparation, general program meetings, and program specific training cannot be-charged directly to an account. This work will be charged to Administrative accounting codes. The Accounting Office totals these administrative charges for the billing period and distributes them back to all of the accounts based on the number of Janr Gnav, cHarn I Mersew T' Kreltlte, EXEcurlvE oFFlcEB 8g5 Aerovista Place, Suite 1 01, San Luis Obispo, CA 93401 | www.waterboards.ca.gov/centralcoa3t Cost Recovery Oversight Process hours charged to each account during that billing period. These charges show as State Water Board Program Administrative Charges and Water Board Program Administrative Charges on the lnvoice. The Overhead Charges are based on the number of labor hours charged to the account. The overhead charges consist of rent, utilities, travel, supplies, training, and personnel services. lf there is no labor charged to the account during the billing period, there will be no overhead charges for that billing period with the exception of the last month of each fiscal year. This is due to the labor charges reconciling at the end of June for the current fiscal year. However, several kinds of overhead charges such as supply orders and travel expenses are paid after the fiscal year ends. The State Water Board Accounting Office keeps track of these charges and distributes them back to all of the accounts based on the number of hours charged to each account for the fiscal year that has just ended. Therefore, the quarterly statements for the last month of the iiscal year could show no labor hours charged for the billing period, but some overhead charges could be charged to the account. lnvoices are issued quarterly, one quarter in arrears. lf a balance is owed, a check is to be remitted to the State Water Board with the invoice remittance stub within 30-days after receipt of the invoice. The Accounting Office sends a report of payments to the Fee Coordinator on a quarterly basis. Copies of the invoices are sent to the Water Board so that they are aware of the oversight work invoiced. Questions regarding the work performed should be directed toward the Water Board. lf the responsible party becomes delinquent in their quarterly payments, oversight work will cease immediately. Work will not begin again unless the payments are brought up to date. DISPUTE LUTION lf a dispute regarding oversight cannot be resolved with the staff responsible over the oversight, the party subject to oversight costs should invoke the dispute resolution provision contained in Water Code Section 13365(c)( ). The Water Board will designate a person who is responsible for resolving disputes regarding the charges subject to thls section and who is not responsible for, or performing, the work or service for which the charges are assessed. DAILY LOGS Each employee at the Water Board who works on the cleanup oversight at a property keeps a detailed description (daily log) of the actual work being done at specific sites. This information is provided on the quarterly invoice using standardized work activity codes to describe the work performed. Upon request, a more detailed description of the work performed is available from the Water Board staff. -2-Attachment 2 Cost Recovery Oversight Process -3-Attachment 2 REMOVAL FROM T E BILLING SYSTEM After the cleanup is complete the Water Board will submit a closure form to the State Water Board to close the account. lf a balance is due, the Fee Coordinator will send a final billing for the balance owed. The responsible party should then submit a check to the State Water Board to close the account. AGREEMENT No cleanup oversight will be performed unless the responsible party of the property has agreed in writing to reimburse the State for appropriate cleanup oversight costs. You may wish to consult an attorney in this matter. As soon as the letter is received, the account will be added to the active SCP Cost Recovery billing list and oversight work will begin. Revised November 16, 2022 @sv Yrrl Glncrl \1.{:ts+ t,\ilv ti)s Glvrn Nrwsou Water Boards Central Coast Regional Water Quality Control Board ATTACHMENT 3 slTE GLEANUP PROGRAM (SCP) ACKNOWLEDGMENT OF RECEIPT OF OVERSIGHT COST REIMBURSEMENT ACCOUNT LETTER l, Brvan Hulburd , acting within the authority vested in me as an authorized representative of Corporation acknowledge that I ave received and read a copy of the attached REIMBURSEMENT PROCESS FOR REGULATORY OYERS'GH f and the cover letter dated Aug u st 21 , 2023 concerning cost reimbursement for Water Board staff costs involved with oversight of cleanup and abatement efforts at the Tank Farm Roundabout . The address forthis site is portions of 276 Tank Farm Rd - Exhibit A . The GeoTracker Global lD is TBD I understand the reimbursement process and billing procedures as explained in the letter. Our company is willing to participate in the cost recovery program and pay all subsequent billings in accordance with the terms in your letter and its attachments. I also understand that signing this form does not constitute any admission of liability, but rather only intent to pay for costs associated with oversight, as sef forth above, and to the extent required by law. Billings for payment of oversight costs should be mailed to the following individual and address: BILLING CONTACT PERSON Bryan Hulburd BILLING ADDRESS:1304 Garden St San Luis Obispo, CA. 93401 EMAIL: TELEPHONE NUMBER: RESPONSIBLE PARTY'S NAME: RESPONSIBLE PARTY'S TITLE: RESPONSIBLE PARTY'S EMAIL: bhulburd@covelop. net; admin@covelop. net 805-459-0753 Covelop, lnc. - Bryan Hulburd (Title) bhulburd et (Email) RESPONSIBLE PARTY'S SIGNATURE: (Signature) 8123123 (Date) Jaue Gnnv, cnetn I MerrHEw T. Kerrtruc, EXEcurlvE oFFlcER a (Name) Development Project Manager 895 Aerovista Place, Suite 1 01, San Luis Obispo, CA 93401 | www,waterboards.ca.gov/centralcoast Exhibit A - Tank Farm Roundabout Project Area SANTA FE ROAD TANK FARM ROADINTERIM DESIGN PLANSCALE: 1" = 150'ENCROACHMENT EXHIBITSFIGURE 1TANK FARM RD & SANTA FE RDROUNDABOUTCOVELOP0EXISTING R/WEXISTING R/WPROPERTY LINE (TYP)NOTE:ProjectClientPlot Date:19 July 2023 - 1:56 PMN:\US\San Luis Obispo\Projects\561\12579768\Digital_Design\ACAD 2020\Figures\12579768-GHD-0000-EXH-CI-0100-InterimEncroachment-County-City-Area-No-600Tank.dwgPlotted By: Olivia Ramirez0Bar is one inch onoriginal size sheetApprovedDateAuthorDesignerProject DirectorProject No.DateFilename:Sheet No.This document and the ideas and designs incorporated herein, as an instrument of professional service, is the property ofGHD. This document may only be used by GHD’s client (and any other person who GHD has agreed can use thisdocument) for the purpose for which it was prepared and must not be used by any other person or for any other purpose.www.ghd.comTitle1"No. IssueCheckedDesign CheckDrafting CheckProject ManagerConditions of UseScaleANSI BSizePRELIMINARYGHD Inc.1101 Monterey Street Suite 120San Luis Obispo California 93401 USAT 1 805 242 0461NORTHBIORETENTIONFACILITYPARCEL 5(PARCEL I)CONSTRUCTIONEASEMENTAPN 076-381-021AREA (12672 SF)PARCEL 4 (PARCEL J)CONSTRUCTIONEASEMENT AREAAPN 076-381-021(7108 SF)PARCEL 4 (PARCEL J)RIGHT OF WAYDEDICATION AREAAPN 076-381-021(5648 SF)PROPOSED R/WPARCEL 5 (PARCEL I) RIGHT OF WAYDEDICATION AREAAPN 076-381-021(42431 SF)'100'150200'300'NPARCEL 6 (PARCEL H)CONSTRUCTION EASEMENT AREAAPN 076-382-005 (7137 SF)PARCEL 6 (PARCEL H) RIGHTOF WAY DEDICATION AREAAPN 076-382-005(11237 SF)PARCEL 7 (PARCEL G) RIGHTOF WAY DEDICATION AREAAPN 076-382-005(23342 SF)PARCEL 7 (PARCEL G)CONSTRUCTION EASEMENT AREAAPN 076-382-005 (13090 SF)FUTURE TEMPORARY STORMWATERRETENTION EASEMENT (20165 SF)LEGENDEXISTING R/WPROPOSED R/WCONSTRUCTION EASEMENTPROPERTY LINESCOUNTY AREACOUNTY AREA - FUTURE STORMWATER RETENTION EASEMENTDRAINAGESWALE 1 From:Galen Pelzmann <gpelzmann@trihydro.com> Sent:Friday, March 31, 2023 11:38 AM To:Schani Siong Cc:Stephanie Seay; 'R4LSA@wildlife.ca.gov'; 'Emma.B.Ross@usace.army.mil'; Scott McAlpin; 'Michaela Craighead'; Diana.Grosso@wildlife.ca.gov; Mailloux, Michael; Stong, Nate; Beacom, James; Diel, Christopher; Cisneros, Luis D Subject:2023 SLO Tank Farm Annual Pre-Activity Biological Survey Report Attachments:202303_AnnualPre-ActivitySurvey_RPT.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Dear Ms. Siong: Pursuant to the County of San Luis Obispo Conditional Use Permit DRC2013-00056 and Amended CUP DRC2015-00067, Condition of Approval Numbers 43, 78, and 83, and the California Department of Fish and Wildlife Streambed Alteration Agreement Measures No. 2.3 and 2.4, provided is the 2023 Pre-Activity Biological Survey Report for the San Luis Obispo Tank Farm Remediation Project. Should you have any questions or comments regarding the referenced report, please contact me at (805) 801-0270. Galen Pelzmann Associate Scientist Direct (307) 745-7474 | Cell (805) 801-0270 142 Cross Street, Suite 200, San Luis Obispo, CA 93401 www.trihydro.com Follow us: Sign up to receive industry updates in your inbox. CONFIDENTIAL INFORMATION: This electronic message is intended only for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. If you have received this message in error, please immediately notify the sender by either email or telephone. Please destroy the related message. Thank you for your cooperation. 202303_AnnualPre-ActivitySurvey_RPT.docx 2023 PRE-ACTIVITY BIOLOGICAL SURVEY REPORT RESERVOIR 5 AND 7 AREAS DEMOLITION, GRADING AND RESTORATION SAN LUIS OBISPO TANK FARM REMEDIATION AND RESTORATION PROJECT SAN LUIS OBISPO COUNTY, CALIFORNIA March 31, 2023 Project #: 81S-001-005 PREPARED BY: Trihydro Corporation 1252 Commerce Drive, Laramie, WY 82070 PREPARED FOR: Chevron Environmental Management Company 276 Tank Farm Road, San Luis Obispo, CA 93401 202303_AnnualPre-ActivitySurvey_RPT.docx AUTHENTICITY AND SIGNATURE PAGE Trihydro Corporation hereby certifies that all statements furnished in the following Pre-Activity Biological Resources Report and all supporting information required for this biological evaluation are true and correct to the best of our knowledge and belief. Further, we certify that all field surveys associated with this report were performed by Trihydro Corporation using standards accepted by San Luis Obispo County and accurately represent all information retained from field visits to the San Luis Obispo Tank Farm Property operated by Chevron Environmental Management Company, San Luis Obispo County, California. ____________________________________ ____________________________________ Scott McAlpin Galen Pelzmann Project Geologist Biologist ____________________________________ Stephanie Seay Compliance & Permitting/Biologist 202303_AnnualPre-ActivitySurvey_RPT.docx Table of Contents EXECUTIVE SUMMARY ........................................................................................................................i 1.0 INTRODUCTION ................................................................................................................... 1-1 1.1 Project Description .................................................................................................... 1-1 1.2 Regulatory Setting ..................................................................................................... 1-2 1.2.1 San Luis Obispo County ............................................................................... 1-2 1.2.2 California Department of Fish and Wildlife ................................................... 1-5 2.0 METHODS ............................................................................................................................. 2-1 2.1 Desktop Review ........................................................................................................ 2-1 2.2 Field Activities ........................................................................................................... 2-1 2.2.1 Special-status Plant Species Population Mapping ....................................... 2-2 2.2.2 Plant Community Field Verification............................................................... 2-2 2.2.3 Bloom and Seed Status Surveys .................................................................. 2-3 2.2.4 Seed Collection ............................................................................................. 2-3 2.2.5 Plant Salvage ................................................................................................ 2-4 2.2.6 Weed Management ...................................................................................... 2-5 2.2.7 California Red-legged Frog Surveys ............................................................ 2-5 2.2.8 Burrowing Owl ............................................................................................... 2-6 2.2.9 Nesting Bird Surveys .................................................................................... 2-6 2.2.10 Vernal Pool Fairy Shrimp Habitat ................................................................. 2-6 2.2.11 Wetlands and Waters ................................................................................... 2-7 3.0 RESULTS .............................................................................................................................. 3-1 3.1 Special-status Plant Species Population Mapping ................................................... 3-1 3.2 Plant Community Field Verification ........................................................................... 3-1 3.3 Bloom and Seed Status Surveys .............................................................................. 3-1 3.4 Seed Collection ......................................................................................................... 3-1 3.5 Plant Salvage ............................................................................................................ 3-2 3.6 Weed Management ................................................................................................... 3-2 3.7 California Red-legged Frog Surveys ......................................................................... 3-2 3.8 Burrowing Owl Surveys ............................................................................................. 3-3 3.9 Nesting Bird Surveys ................................................................................................. 3-3 202303_AnnualPre-ActivitySurvey_RPT.docx Table of Contents (cont.) 3.10 Vernal Pool Fairy Shrimp Habitat .............................................................................. 3-3 3.11 Wetlands and Waters ................................................................................................ 3-3 4.0 DISCUSSION ......................................................................................................................... 4-1 5.0 REFERENCES ...................................................................................................................... 5-1 202303_AnnualPre-ActivitySurvey_RPT.docx List of Tables 2-1. Summary of 2022-2023 Field Activities 3-1. Special-Status Plant Acreages within Proposed Work Areas 3-2. Plant Community Acreages within Proposed Work Areas 3-3. Summary of Seed Collected in 2022 202303_AnnualPre-ActivitySurvey_RPT.docx List of Figures 3-1. Pre-Activity Botanical Survey Results Map; Special-Status Plants 3-2. Pre-Activity Botanical Survey Results Map; Plant Communities 3-3. Pre-Activity Biological Survey Results Map; Special-Status Wildlife 202303_AnnualPre-ActivitySurvey_RPT.docx List of Appendices A. BOTANICAL SURVEY GUIDELINES B. SITE PHOTOGRAPHS C. VERNAL POOL FAIRY SHRIMP PRE-ACTIVITY USFWS CONSULTATION LETTER D. CALIFORNIA RED-LEGGED FROG PRE-ACTIVITY SURVEY DATA SHEETS 202303_AnnualPre-ActivitySurvey_RPT.docx i EXECUTIVE SUMMARY The following Pre-Activity Biological Survey Report (Report) has been prepared by Trihydro Corporation (Trihydro) in support of the proposed San Luis Obispo Tank Farm (SLO Tank Farm) Remediation and Restoration Project (Project), on behalf of Chevron Environmental Management Company (Chevron). The purpose of this Report is to provide the results of pre-activity biological surveys conducted by Trihydro in compliance with Project permits, prior to the initiation of the 2023 Project activities within the Reservoir 5, and 7 areas, and the aggregate stockpile area. Oxbow Areas 1, 2, 3, and 4 have been included in this Report; however, activities associated with these areas are dependent upon permit issuance and construction scheduling constraints. Due to permit issuance and scheduling constraints, activities within these areas is expected to begin in 2024. The 2023 Project activities consist of remediation and restoration of the Reservoir 5 and 7 areas, and include excavation of hydrocarbon impacted soil, and installation of a permanent soil cap. Per the County of San Luis Obispo Conditional Use Permit (DRC2013-00056), Amended Conditional Use Permit (CUP; DRC2015-00067) Condition of Approval (COA) Numbers (No.) 43, 78, and 83, and the California Department of Fish and Wildlife (CDFW) Streambed Alteration Agreement (SAA) (Notification No. 1600-2015-0094-R4) Measures No. 2.3 (a-g), and 2.4, Trihydro completed pre-activity biological surveys for botanical resources and special- status wildlife in 2022 and the beginning of 2023. Pre-activity nesting bird surveys (COA Nos. 82 and 93) will be conducted immediately prior to all vegetation removal for the duration of Project activities, which will occur during nesting bird season (February 15 through August 31). All vernal pool fairy shrimp (Branchinecta lynchi; VPFS) features within the proposed 2023 work areas were removed or restored during 2022 remediation activities. Prior to their removal, inoculum was collected from five vernal pools (FS-20, FS-22, FS-42, FS-53, and FS-55) that were determined to contain adequate VPFS cyst densities for the inoculation of constructed restoration pools. Inoculum was also collected from one VPFS feature of unknown cyst- density (FS-81). Partial inoculum collection was performed in one VPFS feature of variable cyst-density (FS-66) in Borrow Area No. 2. Collected VPFS inoculum will be utilized to create planned VPFS features as described in the Vernal Pool Habitat Restoration and Monitoring Plan (Appendix H of the Landscape Restoration Plan [Padre, 2015a]). All VPFS features adjacent to the 2022/2023 work areas were delineated and protected prior to 2022 ground disturbance to avoid incidental impacts and include FS-20, FS-24, FS-25, FS-27, FS-45, FS-75, FS-76, and FS-80. Based on the desktop survey and pre-activity field surveys conducted in proposed 2023 work areas, plant communities observed within the Project limits include non-native annual grassland, palustrine nonpersistent emergent vernal swale/pool, palustrine forested broad-leaf deciduous valley stream-bank wetland, and palustrine scrub-shrub broad-leaf ii 202303_AnnualPre-ActivitySurvey_RPT.docx deciduous valley stream-bank wetland. Cambria morning glory (Calystegia subacaulis ssp. Episcopalis) was the only special-status plant observed in the 2023 work areas, and was only present in the Oxbow 1 and Oxbow 3 areas. All special-status plants and plant communities within Reservoir 5, Reservoir 7, and the aggregate stockpile work areas were impacted or removed during 2022 work activities. Special-status wildlife, including state protected species observed during 2023 pre-activity surveys included loggerhead shrike (Lanius ludovicianus), white-tailed kite (Elanus leucurus), and golden eagle (Aquila chrysaetos). No special-status amphibians were observed. This Report includes a summary of field activities, survey methods, and results of the botanical resources and special- status wildlife pre-activity surveys conducted prior to commencement of 2023 Project activities. Figures, photographs, and associated documents are included as appendices to this Report. 202303_AnnualPre-ActivitySurvey_RPT.docx 1-1 1.0 INTRODUCTION The following Pre-activity Biological Survey Report (Report) has been prepared by Trihydro Corporation (Trihydro) in support of the San Luis Obispo Tank Farm (SLO Tank Farm) Remediation and Restoration Project (Project), on behalf of Chevron Environmental Management Company (Chevron). The objective of the biological resources pre-activity surveys was to identify the special-status botanical and wildlife resources that may be disturbed by 2023 Project activities, per the County of San Luis Obispo (County) Conditional Use Permit (DRC2013-00056), Amended Conditional Use Permit (CUP; DRC2015-00067) Condition of Approval (COA) Number (No.) 78 and 83, and the California Department of Fish and Wildlife (CDFW) Streambed Alteration Agreement (SAA) (Notification No. 1600-2015-0094-R4) Measures No. 2.3 (a-g), and 2.4 (a-b). The 2023 Project activities consist of remediation and restoration of the Reservoir 5 and 7 areas. Oxbow Areas 1, 2, 3, and 4, have been included in this Report; however, activities associated with these areas are dependent upon permit issuance and construction scheduling constraints. Due to permit issuance and scheduling constraints, activities within these areas is expected to be conducted in 2024. All 2023 work activities will occur in areas previously disturbed during remediation work that occurred in 2022. Due to the Project start date of early spring of 2023, and the major ground disturbance that occurred in the work areas during 2022, it was not feasible to map special-status species populations bloom prior to the preparation of this Report. As such, this Report includes the mapped results of pre-activity botanical resource surveys conducted in April through August of 2021, within and adjacent to the proposed 2022/2023 work areas. Note that the 2021 pre-activity botanical resource survey results provide the most current status of special-status plant populations within the proposed 2023 work areas, in accordance with Project permit conditions. Also included in this Report are the results of the pre- activity California red-legged frog (Rana draytonii), burrowing owl (Athene cunicularia), northern harrier (Circus hudsonius), and nesting bird surveys conducted in February and March 2023. Although pre-activity surveys are not required for vernal pool fairy shrimp (Branchinecta lynchi; VPFS), management of vernal pool fairy shrimp occupied habitat occurring adjacent to the proposed 2023 work areas is also discussed within this Report. Figures, photographs, and associated documents are included as appendices to this Report. 1.1 PROJECT DESCRIPTION The Project activities proposed for 2023 will occur within the Reservoir 5 and 7 areas, and the aggregate stockpile area. Work in Oxbow Areas 1, 2, 3, and 4 is expected to begin in 2024. The 2023 Project will consist of the following activities:  Topsoil salvage  Clean soil stockpiling 1-2 202303_AnnualPre-ActivitySurvey_RPT.docx  Hydrocarbon containing soil remediation and hauling  Backfill and topsoil replacement  Restoration of Reservoir 5 and 7 Areas and the creation of 6 planned VPFS features 1.2 REGULATORY SETTING This section summarizes the regulations and policies administered by resource agencies pertaining to pre-activity surveys required for the proposed 2023 work areas. These areas fall under the scope of the pre-activity requirements of the County CUP and the CDFW SAA. 1.2.1 SAN LUIS OBISPO COUNTY Prior to Project initiation, a California Environmental Quality Act (CEQA) review and approval was required. The City of San Luis Obispo (SLO) and the County of SLO entered into a Memorandum of Understanding in February 2013, which designated the City of SLO as acting lead agency for CEQA review. The City of SLO certified the Final Environmental Impact Report (FEIR) in September 2014 and the County of SLO issued CUP. An Amended CUP was issued in June 2021 to allow for an increased volume of Non-Hazardous Impacted Soils (NHIS) removal and approval of haul routes to allow for disposal of NHIS at the Cold Canyon Landfill. Mitigation measures identified in the FEIR were adopted by the County and issued as Exhibit B-Conditions of Approval CUP. Permit requirements that are discussed in this section include Amended CUP COA Nos. 43, 78, 79, 80, 82, 83, and 93. COA No. 43 (BIO-1c) states, The final restoration plan shall provide for plant salvaging and replanting where appropriate (e.g., San Luis Obispo dudleya), restoration, and/or creation of habitat suitable for special-status plant species including Cambria morning glory, Congdon’s tarplant, San Luis Obispo owl’s clover, Hoover’s button-celery, San Luis Obispo serpentine dudleya, and purple needlegrass. COA No. 78 (BIO-1b) states, Prior to commencement of grading, the applicant shall conduct updated surveys of sensitive species habitats (including sensitive plant species, CRLF, wetland habitat, and VPFS habitat) within the project site within the appropriate season immediately prior to the onset of any ground disturbances associated with the project in order to evaluate the current occupancy of suitable habitat for sensitive species and to refine the final habitat mitigation replacement acreages. Updated surveys for federally 202303_AnnualPre-ActivitySurvey_RPT.docx 1-3 listed species shall be completed per the timing and methodology specified by resource agency protocol. COA No. 79 (BIO-1i) states, The VPFS-qualified biologist shall conduct sensitive vernal pool branchiopod surveys within the appropriate season immediately prior to the start of construction activities per the timing and methodology specified by USFWS protocol. The VPFS qualified biologist shall monitor during construction activities in the vicinity of habitats to be avoided. The final acreage of habitat loss shall be revised as necessary to adequately mitigate actual disturbance to habitats for listed and special- status species due to remediation. COA No. 80 (BIO-1j) states, The VPFS-qualified biologist shall conduct cyst collection efforts (cyst-bearing soil) and storage efforts from work areas prior to construction activities from the entire work area of each impacted pool when the ephemerally wetted areas are dry. The VPFS-qualified biologist shall follow USFWS standard procedures and guidance established in that agency’s permitting process. The cysts shall be stored in labeled containers that are adequately ventilated. The cysts shall be kept out of direct sunlight to prevent excessive heating of the soil. The cysts shall be kept out of direct contact with water. When restored VPFS habitat is constructed, the inoculum shall be placed within the surface layer of the soil in a manner following USFWS protocols and guidance. COA No. 82 (BIO-2e) states, Hawks and owls nest earlier than most other native birds. If initial construction activities, ground disturbance, or vegetation clearing involving vegetation removal/trimming occur from December 1 through August 31, the nest monitor would conduct a pre-construction survey within three days prior to vegetation removal or other construction-related disturbances focused on actively nesting hawks or owls. If any actively nesting hawks or owls are found, a 500-foot buffer would be established around the nest tree to help ensure that nesting is not disrupted. The buffer would be delineated by orange construction fencing and signage and would remain in place until the nest is either abandoned or the young have fledged. The nest monitor would be present when any buffer fencing is established. COA No. 83 (BIO-7a) states, A qualified biologist shall conduct surveys throughout areas proposed to be disturbed to determine the presence of wildlife species prior to ground disturbance. The biologist shall be on site during initial site disturbances (i.e., brush removal, topsoil disturbances). Wildlife species encountered during the initial disturbances shall be relocated to suitable habitat out of potential danger. All 1-4 202303_AnnualPre-ActivitySurvey_RPT.docx handling and relocation of sensitive and non-sensitive wildlife species shall be conducted by biologists with appropriate authorizations and permits (CDFW and USFWS). Remediation activities, including restoration efforts shall be regularly monitored throughout the remediation and restoration phases to ensure that wildlife species have not entered work areas. The biological monitor shall conduct regular site inspections of the remediation and restoration activities to ensure that all applicable mitigation measures are being enacted. The biological monitor shall have the authority to temporarily halt activities if permit requirements and conditions are not being met. The biological monitor shall prepare an annual summary report describing site visit observations and shall provide this report to the City, County, and regulatory agencies (including CDFW, USACE, and USFWS) for review. COA No. 93 (BIO-2d) states, To minimize potential impacts to nesting native bird species, and in compliance with the federal Migratory Bird Treaty Act and Sections 3503, 3503.5, or 3513 of the California Fish and Game Code, all activities resulting in ground disturbances during all phases of remediation, restoration, pipe removal, and construction activities involving vegetation removal/trimming shall be done, as feasible, outside the breeding season (February 15 through August 31). If vegetation must be removed during this period, then the Applicant shall retain a biologist acceptable to the County in consultation with the City to conduct surveys for nesting birds. Surveys shall be conducted within three days prior to vegetation removal or other construction-related disturbances. If nesting birds are observed within the vicinity, then a minimum 100-foot buffer from the nest would be established. The buffer would be delineated by orange construction fencing or other delineator approved by County in consultation with the City and signage and would remain in place until the nest is abandoned or the young have fledged. The qualified biologist shall be present when any buffer fencing is established. The qualified biologist shall monitor the nest to ensure that Project activities do not violate the Migratory Bird Treaty Act or the California Fish and Game Code. At minimum, the biologist would check for new active nests, and determine the status of ongoing active nests, weekly during the specified nesting season. The biologist would ensure that all fencing and signage was properly maintained, and would provide weekly, or less frequent if requested by the agencies, e-mail updates on the status of all monitored nests to the County, City, CDFW, and USFWS. If the biologist determines that nesting is being disrupted, the construction activities shall cease and wait until a new buffer area is determined, the young have fledged, or the nest is determined to have failed. 202303_AnnualPre-ActivitySurvey_RPT.docx 1-5 1.2.2 CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE The CDFW SAA also contains conditions that pertain to pre-activity biological surveys. Permit requirements that are discussed in the section include CDFW SAA Measures No. 2.3 (a-g), 2.4 (b), and 4.2. 2.3 Listed and Other Special-Status Species (a) Pre-activity surveys for potential rare, listed, or other sensitive status species shall be conducted by a qualified biologist within 30 days prior to commencement of Project activities. Surveys shall be conducted within the work area and all access routes to avoid and minimize incidental take, confirm previous observations, identify any areas occupied by listed or sensitive species, and clearly mark all resources to be avoided by Project activities. If any State- or Federally- listed threatened or endangered species are found or could be impacted by the work proposed, Permittee shall notify CDFW of the discovery immediately. An amended Agreement and/or an Incidental Take Permit may be warranted. (b) Western Pond Turtle and Western Spadefoot: All western pond turtles and western spadefoot discovered at the Project site immediately prior to or during Project activities shall be allowed to move out of the area of their own volition; if this is not feasible, they shall be captured by a qualified biologist and relocated out of harm’s way to the nearest suitable habitat immediately upstream or downstream from the Project site. (c) California Red-Legged Frog (CRLF): If water is present within 250 feet of the Project work area, a qualified biologist shall survey the Project site for CRLF within 48 hours prior to commencing work. Survey results shall be submitted to CDFW. Between October 15 and April 30, vegetation within the Project work area that will be disturbed or removed shall be removed by hand prior to the use of heavy equipment or machinery. If CRLF are found prior to the Project or at any time during Project activities, work shall cease or shall not commence (whichever applies) until CDFW has been contacted and has given written approval for work to continue. All CRLF individuals shall be allowed to leave the Project work area unharmed. Permittee shall contact CDFW within 24 hours of each detection. (d) Southern Steelhead (South Central California Coast DPS): Project activity shall not occur within the wetted channel. (e) American Badger: American badger detected within the Project work area during Project activities shall be allowed to move out of the work area of its own volition. If American badger is denning on or immediately adjacent to a Project work area, Permittee shall consult with CDFW 1-6 202303_AnnualPre-ActivitySurvey_RPT.docx to determine whether the animal(s) may be evicted from the den. Eviction of badgers will not be approved by CDFW unless it is confirmed that no dependent young are present. (f) Burrowing Owl: A qualified wildlife biologist shall survey for burrowing owl within a 500-foot radius of the Project site, within 30 days prior to starting Project activities each year. Surveys shall be conducted at appropriate times to maximize detection. If any active burrowing owl burrows are observed, these burrows shall be designated an ESA, protected, and monitored by a qualified biologist during Project-related activities. A minimum 500-foot avoidance buffer shall be established and maintained around each owl burrow during the nesting season (February 1 through August 31). If active burrowing owl burrows are observed outside of the nesting season, a minimum 150-foot no disturbance buffer shall be established around each burrow. Eviction of owls from burrows is not authorized by CDFW in this Agreement. (g) Special-Status Plant Species: If suitable habitat for any special-status plant species is present within a work area, a qualified botanist shall conduct focused Plant Surveys for these plants within one year prior to the start of Project activities. Repeated floristic surveys shall be conducted by a qualified botanist multiple times during the appropriate floristic period(s) in order to adequately assess the potential impacts to special-status plant species. If any listed or other special-status plant species is found, Permittee shall identify them with flagging and avoid plants with a 25-foot no disturbance buffer. If a buffer around non-listed plant species is not feasible, CDFW may approve a buffer reduction in writing and in advance of the buffer reduction, provided that Permittee proposes written alternate methods to minimize impacts; for example salvaging topsoil after plants have set seed, and replacing it in areas of temporary disturbance to the affected species. 2.4 Fish and Wildlife (b) Pursuant to FGC Sections 3503 and 3503.5, it is unlawful to take, possess, or destroy the nest or eggs of any bird or bird-of-prey. To protect nesting birds, no Project activity shall be completed from February 15 through August 31 unless the following Avian Nest Surveys are completed by a qualified biologist within 30 days prior to Project initiation. Birds of Prey: Survey for nesting activity of birds of prey within a 500-foot radius of each Project work area. If any active nests are observed, these nests shall be designated an ESA and protected by a minimum 500-foot avoidance buffer until the breeding season has ended or until a qualified biologist has determined that the young have fledged and are no longer reliant upon the nest or parental care for survival. 202303_AnnualPre-ActivitySurvey_RPT.docx 1-7 Other Avian Species: Survey for nesting activity within a 250-foot radius of the defined work area. If any nesting activity is found, these nests shall be designated an ESA and protected with a minimum 250-foot buffer until young have fledged and are no longer reliant on the nest site or parental care. CDFW may consider variances from these buffers when there is a compelling biological or ecological reason to do so, such as when the Project area would be concealed from a nest site by topography. 4.2 Reports. Permittee shall submit the following Reports to CDFW:  Construction/work schedule submitted to CDFW prior to Project commencement (Administrative Measure 1.8)  A Training Sign-in Sheet submitted to CDFW within one (1) week of completing training (Administrative Measure 1.9)  Pre-activity survey results provided to CDFW at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.3[a])  Results of California red-legged frog surveys submitted to CDFW no more than one (1) week from the completion of the survey (Avoidance and Minimization Measure 2.[c])  Results of surveys for burrowing owls, submitted to CDFW at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.[f])  Results of Plant Surveys submitted at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.3[g])  Results of surveys for nesting birds if any Project activity is scheduled during the avian nesting season, submitted to CDFW at least one (1) week prior to the start of Project activities (Avoidance and Minimization Measure 2.4[b]) In compliance with COA No. 78, Trihydro conducted a botanical resources survey in the spring to capture the blooming period of the special-status plant species and plant community components, when the plants were readily identifiable. In addition, Trihydro conducted California red-legged frog pre-activity surveys of all aquatic habitat within and adjacent to the proposed 2023 work areas. Padre consulted with the USFWS in regard to updating the vernal pool fairy shrimp surveys and received approval in a correspondence dated January 25, 2016, to forego updating the surveys (COA No. 79) based on the Project’s history of comprehensive survey data. In compliance with COA No. 82, and No. 93, Trihydro conducted burrowing owl, hawk, and nesting bird surveys prior to ground disturbance. In 1-8 202303_AnnualPre-ActivitySurvey_RPT.docx compliance with COA No. 83, Trihydro will continue to conduct wildlife clearance surveys for the duration of the Project, as necessary. 202303_AnnualPre-ActivitySurvey_RPT.docx 2-1 2.0 METHODS Methods to collect sensitive wildlife data and botanical resources information for the proposed 2023 work areas include a desktop review and field activities. Both methods are discussed in this section. 2.1 DESKTOP REVIEW The desktop review incorporated an aerial imagery review of the Project site and proposed 2023 work areas, which included an approximately 10-foot (ft) buffer. The desktop review also included an examination of multiple sources of technical survey information pertaining to biological resources within the Project site, including the following:  Description and Analysis of the Botanical Resources, Including Vascular Plant Species of Conservation Concern, at the Chevron Tank Farm Facility, San Luis Obispo, California (Padre and WSP 2008)  Landscape Restoration Plan, Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project, San Luis Obispo County, California (Padre 2015a)  Botanical Pre-Activity Survey Guidelines for Special-Status Plants and Plant Communities. In-house document prepared by Padre. (Padre 2015b)  California Red-legged Frog Survey Report for the Chevron San Luis Obispo Tank Farm, San Luis Obispo County, California (Padre 2014)  CDFW California Natural Diversity Database query of updated occurrences of California red-legged frog, burrowing owl, and western pond turtle within San Luis Obispo County (CDFW 2023)  Previous annual pre-activity biological survey reports for the Project (Padre 2018; Trihydro 2019, 2020a, 2021a, and 2022a)  Biological Resources Monitoring Program Annual Summary Report (Padre 2019; Trihydro 2020b, 2021b, 2022b, and 2023) 2.2 FIELD ACTIVITIES Pre-construction biological field activities completed within the proposed 2023 work areas included a special-status plant mapping reconnaissance survey, plant community field verification survey, CRLF day and night surveys, burrowing owl surveys, and nesting bird surveys. Trihydro staff involved in the field activities included: Galen Pelzmann, Stephanie Seay, Victoria Trautman, Jeanette Moore, and Iliana Arroyos. The survey dates and personnel for all field activities are summarized in Table 2-1. 2-2 202303_AnnualPre-ActivitySurvey_RPT.docx 2.2.1 SPECIAL-STATUS PLANT SPECIES POPULATION MAPPING The special-status plant species previously documented as occurring within SLO Tank Farm property include Cambria morning glory (Calystegia subacaulis ssp. episcopalis), San Luis Obispo owl’s clover (Castilleja densiflora ssp. obispoensis), Congdon’s tarplant (Centromadia parryi ssp. congdonii), Hoover’s button celery (Eryngium aristutalum var. hooveri), San Luis Obispo serpentine dudleya (Dudleya abramsii ssp. bettinae), and California walnut (Juglans californica) (Padre and WSP, 2008). In addition, areas comprised of greater than 10 percent (%) purple needlegrass, are considered special-status plant communities and mapped as special-status plant species populations. In compliance with the permit conditions, the status of existing special-status plant populations will be assessed immediately prior to disturbance, during the appropriate season when plants are readily identifiable. Trihydro biologists conducted a pre-activity special-status plant species survey in June 2021 within the proposed Reservoir 5 and 7, and the aggregate stockpile areas for 2022 work activities. All surfaces within the 2023 work areas were graded, excavated, or otherwise disturbed during 2022 remediation work, and therefore no special-status plant populations persist in these areas. In April 2023, Trihydro will be conducting a pre-activity special-status plant species mapping reconnaissance survey to identify and document any early emergent or blooming occurrences of special-status plant species populations within the Oxbow Areas 1, 2, 3, and 4 work areas. During special-status plant species population mapping in 2021 and 2022, Trihydro biologists drove on established access roads and walked the terrain within and adjacent to all proposed work areas. A field map illustrating previously mapped special-status plant populations (Padre and WSP, 2008) was utilized as a field reference. The mapping schedule was dependent on the blooming period when species were most identifiable. Per the Padre Botanical Survey Guidelines (Appendix A), in 2021 and 2022, Trihydro biologists identified special-status populations through direct observation of blooms and/or morphological characteristics, then installed temporary pin flags around the extent of the population. The population was documented using a hand-held global positioning system (Trimble and ArcGIS Collector GPS unit). 2.2.2 PLANT COMMUNITY FIELD VERIFICATION Per the Padre Botanical Survey Guidelines (Appendix A), a field survey was conducted to verify the existing plant communities within the proposed 2023 work areas. The plant community field verification survey was conducted in conjunction with the June 2, 2021 special-status plant species mapping reconnaissance survey. Note that plant communities are readily identifiable throughout the year. Observations and general composition of the plant communities were compared to previously mapped plant communities (Padre and WSP, 2008), to verify that the plant communities are similar in extent to when originally mapped. 202303_AnnualPre-ActivitySurvey_RPT.docx 2-3 2.2.3 BLOOM AND SEED STATUS SURVEYS During 2022 remediation activities in Reservoir 5 and 7 and in the aggregate stockpile area, all plant communities within the 2023 work areas were impacted and removed. Due to the early spring Project start date, it was not feasible to conduct bloom and seed status surveys in 2022, and as such, these were instead conducted during spring and summer of 2021. The purpose of these surveys is to assist in scheduling seed collection when seed is mature. Section 2.2.5 describes seed collection methods. Per the Botanical Survey Guidelines, qualitative reconnaissance surveys within the proposed 2023 work areas were conducted periodically throughout the spring and summer months of 2021 to determine the bloom and seed status of special-status species. During bloom and seed status field surveys, biologists drove on established access roads and walked the terrain within the proposed 2023 work areas and an approximately 50-ft buffer. Direct visual observations of the subject species were recorded. The bloom status observations were used to predict and schedule seed collection events, and as a general indicator of the size and density of the special-status plant populations within the SLO Tank Farm property. Seed collection was conducted following observation of mature seed within a population. Specific plant characteristics that were utilized to determine seed maturity on all special-status plant species documented to occur within the SLO Tank Farm property were as follows:  Cambria morning glory. Flower has dropped or is intact but dry, leaves green to brown, capsule is visible, seed is brown to black and is easily removed from capsule.  San Luis Obispo owl’s clover. Dried blooms intact, stems and leaves green to brown, seed is brown and can be seen when pod is crushed with fingers.  Congdon’s tarplant. Dried/remnant blooms intact, stems and leaves pale green to brown, seed is dark brown to black and can be seen when pod is crushed with fingers.  Hoover’s button celery. Dried/remnant blooms intact, stems and leaves pale green to brown, seed can be seen when pod is crushed with fingers.  Purple needlegrass. Inflorescence is intact, awns are bent, and seed is easily removed from the stalk by hand. 2.2.4 SEED COLLECTION Due to the early spring Project start date, it was not feasible to conduct seed collection activities in 2023, and as such, seed was collected during spring of 2022. The purpose of seed collection is to obtain seed for plant propagation and increase seed for future restoration activities. Seed Collection Data Sheets were used to document the target species, date of collection, approximate population size of collection area (as number of plants and acreage of population), the plant height, and assessment of seed vigor (healthy, insect-damaged, undeveloped, moldy, or other damage). Methods and techniques utilized for collection were dependent on the target species. Following observation of mature seed during bloom/seed status surveys, seed was collected. General seed collection techniques consisted of hand-pulling 2-4 202303_AnnualPre-ActivitySurvey_RPT.docx and or vegetation clipping, dependent on which species was being collected. Seed was bagged in envelopes or bags, and sent to CaliFlora Resources, a local native seed and processing company, for processing, and then returned for storage. Summary of seed collection and methods are as follows:  Cambria morning glory. No seed from this species was collected in 2022. Previous seed collected had poor germination rates and it was determined that vegetatively collecting plants/divisions would be more efficient than seed collection. As described below, the top 6 to 12 inches of soil containing Cambria morning glory is also salvaged.  San Luis Obispo owl’s clover. 0.25 pounds of seed was collected from approximately 100 plants in April 2022. Plants were collected from the development area adjacent to Borrow Area No. 2. Plants were pulled and placed into buckets for transport to the processing facility.  Congdon’s tarplant. No seed from this species was collected in 2022. The large surplus of Congdon’s tarplant seed collected during 2021 activities is sufficient to restore the vernal pool acreage impacted during 2022 and 2023 activities.  Hoover’s button celery. No seed from this species was collected in 2022 as there are no Hoover’s button celery in the proposed 2023 work area. Previous seed collection methods consisted of cutting stems and plants with inflorescences with hand clippers and placing into buckets.  Purple needlegrass. No seed was collected in 2022 and no future seed collection is planned. Seed collected from 2009 – 2015 was tested for viability, and results indicated that majority of the seed, collected on-site, had very low viability. It was determined that seed purchased from a vendor would be a cost-effective method to obtain the quantities of viable seed necessary for future restoration.  California walnut. No seed from this species was collected in 2022. California walnut is located within the oxbow areas in the proposed 2024 work areas, and one California walnut tree may be impacted by work activities in 2024. California walnut seed was collected in 2021 and was used to begin growth of saplings in an offsite growing facility.  Serpentine Dudleya. No seed from this species was collected in 2022. All (337) serpentine dudleya that occurred on site were salvaged in 2015 and donated to the San Luis Obispo Botanical Garden since no suitable habitat would be present on the project sites after remediation activities. 2.2.5 PLANT SALVAGE Salvage methods consist of collecting the top 12- to 24-inches of topsoil containing Cambria morning glory and/or purple needlegrass rhizomes, seed, and/or vegetative plants, with an excavator, dozer, or skid steer. Plant salvaging 202303_AnnualPre-ActivitySurvey_RPT.docx 2-5 activities will only take place in occurrences growing on clean soils. If plants are near contaminated soil areas, the salvaged topsoil will either be lab tested and only used if clean or discarded along with the excavated contaminated soil if found to be impacted. The salvaged material will be immediately transported to a designated patch population plot chosen based on similar habitat and environmental conditions, and the occurrence of an existing population adjacent to the transplant plot. The soil will then be raked to achieve a suitable thickness to promote seedling, rhizome, and root establishment. 2.2.6 WEED MANAGEMENT Weed management activities will be implemented in accordance with the Landscape Restoration Plan (Padre, 2015a) to minimize the presence of noxious and non-native plant species within the proposed 2023 work areas. Weed management activities within the 2023 work areas will begin in spring of 2023. A qualified herbicide contractor will spot spray target species within the 2023 work areas primarily on the steep berms and tank rings. 2.2.7 CALIFORNIA RED-LEGGED FROG SURVEYS Per Amended CUP COA No.78 (BIO-1b), updated CRLF surveys were conducted immediately prior to ground disturbance in the 2023 disturbance areas. The 2023 CRLF surveys were conducted during the breeding season. A two day and four-night survey protocol was followed, and as per the Revised Guidance on Site Assessments and Field Surveys for the California Red-legged (Guidance) published by the USFWS in 2005, surveys were scheduled seven days apart from one another and took place over a six-week period. The surveys focused on suitable aquatic habitat inside and within 250 feet of the planned work areas. Surveys were conducted by Trihydro biologists Stephanie Seay, Victoria Trautman, Jeanette Moore, Galen Pelzmann, and Iliana Arroyos, on February 1, 8, 15, 21, and March 3 and 24, 2023. Prior to entering aquatic habitat, Trihydro biologists decontaminated all equipment in accordance with the Recommended Equipment Decontamination Procedures found in Appendix B of the Guidance to limit the spread of pathogens and parasites (USFWS, 2005). A Kestrel® 2000 (thermometer and anemometer) was utilized to record weather data and a Traceable® waterproof thermometer was used to record water temperature data before each survey. Daytime surveys focused on identifying egg masses, larvae, metamorphs, and metamorphosing sub-adults. Prior to entering the aquatic habitats, and approximately every 33 meters (m) (100 feet) within the habitat, Trihydro biologists stopped to listen for frog calls. Care was taken when entering and exiting the aquatic habitat to avoid crushing root- balls, overhanging banks, and creekside vegetation that may have provided shelter for frogs. 2-6 202303_AnnualPre-ActivitySurvey_RPT.docx Nighttime surveys followed the same approach as the daytime surveys while focusing on identifying sub-adult and adult CRLF. Trihydro biologists utilized LED Maglite® flashlights (less than 100,000 candle watt) and binoculars (Bushnell® 10X42 and Nikon® 10X42) to detect and identify eye-shine. Trihydro biologists listened for frog calls and estimated the abundance of each species that was detected. In addition, any observations of potential CRLF predators were documented on data sheets. 2.2.8 BURROWING OWL Pre-activity burrowing owl surveys were conducted on February 1, 8, 15, 21, and March 3 and 24, 2023. Trihydro biologists systematically surveyed the proposed 2023 work areas and at least 500 feet of surrounding habitat, searching for owl activity, potential burrows, whitewash, pellets/prey remains, and signs of nesting behavior. In addition, biologists listened for alarm calls and vocalizations from fledglings. 2.2.9 NESTING BIRD SURVEYS Preliminary nesting bird surveys were conducted in conjunction with the burrowing owl surveys completed on March 3 and 24, 2023. The survey consisted of walking transects through the proposed 2023 work areas and inspecting trees, shrubs, and grasslands for nests. During the survey, the biologists listened for bird vocalizations and alarm calls, and watched for nesting or territorial behaviors. Nesting bird surveys will continue throughout the construction season whenever vegetation or new ground will be disturbed. 2.2.10 VERNAL POOL FAIRY SHRIMP HABITAT Project USFWS Biological Opinion (BO; SPL-2014-00444) does not contain any pre-activity survey conditions for VPFS; however, Amended CUP COA Nos. 78, 79, and 80 require pre-activity surveys and topsoil collection within VPFS habitat features that will be impacted. After consultation with USFWS, it was concluded that additional VPFS pre-activity surveys will not be required (Appendix C - vernal pool fairy shrimp Pre-Activity USFWS Consultation Letter). As such, a desktop survey was completed to identify any VPFS habitat within the proposed 2023 work areas. The desktop survey also included documenting VPFS inoculum collection pools that may be harvested for 2023 restoration activities. All VPFS adjacent to the proposed 2023 work areas was properly delineated and protected prior to ground disturbance in 2022 to avoid incidental impacts. Any impacted VPFS-occupied habitat will be included within the final impact acreages, reported in the Annual Project Status and Habitat Restoration Monitoring Report, and mitigated as detailed in the Landscape Restoration Plan (Padre, 2015a). 202303_AnnualPre-ActivitySurvey_RPT.docx 2-7 2.2.11 WETLANDS AND WATERS The Project RWQCB Section 401 Water Quality Certification (No. 34015WQ06) does not contain any conditions for conducting pre-activity surveys prior to wetland and waters disturbance, however, Amended CUP COA No. 45 requires that all wetlands and waters be replaced per the Landscape Restoration Plan (Padre, 2015). As such, a desktop survey was completed to document the existing waters and wetlands that occur within the proposed 2023 work areas. 202303_AnnualPre-ActivitySurvey_RPT.docx 3-1 3.0 RESULTS The following discussion includes findings of the 2023 pre-activity biological surveys within SLO Tank Farm (Figures 3-1, 3-2, and 3-3). 3.1 SPECIAL-STATUS PLANT SPECIES POPULATION MAPPING Based on the spring and summer 2021 pre-activity botanical survey of the proposed 2023 work areas, three special- status plant species were documented to occur within the proposed 2023 work areas and consisted of the following: Cambria morning glory, San Luis Obispo owl’s clover, and Congdon’s tarplant. All plant communities within the 2023 work areas were impacted or otherwise removed during 2022 remediation activities. As a result, the only special-status plant populations detected within the 2023 pre-activity survey area were Cambria morning glory populations in Oxbows 1 and 3. Table 3-1 provides the resulting acreages, and locations are shown on Figure 3-1. 3.2 PLANT COMMUNITY FIELD VERIFICATION Based on the spring and summer 2022 plant community field verification survey, disturbed/ruderal habitat and four plant communities were documented to occur within the proposed 2023 work areas. These include palustrine forested broad-leaf deciduous valley stream-bank wetland, palustrine nonpersistent emergent vernal swale/pool, palustrine scrub-shrub broad-leaf deciduous valley stream-bank wetland, and non-native annual grassland. All plant communities within the 2023 work areas were impacted or otherwise removed during 2022 remediation activities. As a result, the plant communities recorded within the 2023 pre-activity survey area were located within Oxbow Areas 1, 2, 3, and 4. Plant community boundaries were originally mapped in the field in 2008. Table 3-2 provides the resulting acreages and Figure 3-2 shows the locations of the community types. 3.3 BLOOM AND SEED STATUS SURVEYS Bloom and seed status surveys were conducted in spring and summer 2022, as discussed in Methods Section 2.2.3. The purpose of these surveys was to assist in scheduling seed collection when seed is likely to be mature. The bloom and seed status surveys conducted in 2022 resulted in successful collection of San Luis Obispo owl’s clover mature seed from Borrow Area No. 2. 3.4 SEED COLLECTION Special-status plant seed was collected in April 2022, as discussed in Methods Section 2.2.4. Collected seed was shipped to CaliFlora Resources for processing. Table 3-3 summarizes the seed collection results. 3-2 202303_AnnualPre-ActivitySurvey_RPT.docx 3.5 PLANT SALVAGE Approximately 0.10 acres of Cambria morning glory, and 1.62 acres of San Luis Obispo owl’s clover were salvaged from the work areas prior to 2022 work activities. All 2023 work activities will occur in these same areas, and therefore no further plant salvage occurred in 2023 work areas. 3.6 WEED MANAGEMENT As observed in the winter/spring of 2022, there were scattered dense patches of invasive, non-native plant species including yellow star thistle (Centauria solsticialis), Italian thistle (Carduus pycnocephalus), and bristly ox-tongue (Helminthotheca echioides). Dense patches were sprayed with herbicide prior to blooming. 3.7 CALIFORNIA RED-LEGGED FROG SURVEYS During daytime and nighttime surveys, surface water was detected in areas adjacent to and within the proposed 2023 work areas (Figure 3-3). The site received above average rainfall during the 2022-2023 wet season, which increased the number, size, and depth of wetlands that were inundated during the winter on the Project site. During the protocol six-week survey period, CRLF habitat was increased on the Project site due to the winter rain events with above average rainfall. The majority of the aquatic habitat has been historically seasonally ponded, with the exception of the East Fork San Luis Obispo Creek (Creek) which runs along the southern boundary of the Project site and can be described as an intermittent to perennial tributary to the main channel of San Luis Obispo Creek as described in the Landscape Restoration Plan (Padre, 2015a). Trihydro biologists did not observe or hear adult Sierran treefrogs (Pseudacris sierra) during day surveys and no amphibian egg masses were observed. However, 4 larvae were observed within the 2023 project area. During night eye-shine surveys, Trihydro biologists observed and heard approximately 230 adult Sierran treefrogs (Pseudacris sierra). California red-legged frog were not observed in any of the survey wetlands or surrounding habitat during day- or night-time surveys. Trihydro biologists identified sign of CRLF predators including raccoon (Procyon lotor), crayfish (Pacifastacus leniusculus), Virginia opossum (Didelphis viginiana), and migratory shorebirds (i.e., Lesser yellowlegs (Tringa flavipes). Trihydro biologists did not observe CRLF. Appendix D contains detailed data sheets for each of the survey events. 202303_AnnualPre-ActivitySurvey_RPT.docx 3-3 3.8 BURROWING OWL SURVEYS Burrowing owl surveys were conducted by Stephanie Seay, Victoria Trautman, Jeanette Moore, Galen Pelzmann, and Iliana Arroyos on February 1, 8, 15, 21, and March 3 and 24, 2023. No burrowing owls were observed within the 2023 work areas during the surveys. Historically, burrowing owl have occupied the site during the non-breeding season; however, additional biological clearance surveys will be conducted to identify any owl nesting activity prior to Project activities within the nesting season. These results will be included in weekly Project status updates. 3.9 NESTING BIRD SURVEYS Nesting behavior was observed in a western meadowlark (Sturnella neglecta) on the northeast perimeter of the Reservoir 5 work area during the survey on March 3. Nesting behavior was also observed in a pair of black phoebes (Sayornis nigricans) on the south perimeter of Reservoir 5 work area during the March 24 survey. Various bird species were also observed foraging or hunting within the survey areas. Species observed included, but were not limited to, Northern harrier (Circus cyaneus), violet-green swallow (Tachycineta thalassina), black phoebe (Sayornis nigricans), American robin (Turdus migratorius), and killdeer (Charadrius vociferus). Additional nesting bird surveys will be conducted throughout the nesting bird season (February 15 through August 31), or until Project activities are complete for the year, whichever comes first. 3.10 VERNAL POOL FAIRY SHRIMP HABITAT All vernal pools within the 2023 work areas were excavated, graded, or otherwise disturbed during work activities in 2022. VPFS inoculum was collected from all vernal pools within the 2022/2023 work areas that were identified as viable sources for VPFS cysts prior to 2022 work activities. Salvaged inoculum will be used for VPFS habitat restoration as described in Vernal Pool Habitat Restoration and Monitoring Plan (Appendix H of the Landscape Restoration Plan [Padre, 2015a]). All VPFS habitat and their buffers adjacent to the 2023 work areas were properly delineated and protected prior to ground disturbance in 2022 to avoid incidental impacts. Any impacted vernal pool fairy shrimp-occupied habitat will be included within the final impact acreages, reported in the Annual Monitoring Report, and mitigated as detailed in the Landscape Restoration Plan (Padre, 2015a). 3.11 WETLANDS AND WATERS U.S. Army Corps of Engineers jurisdictional and non-jurisdictional wetlands and waters occurred within the proposed 2023 work areas prior to disturbance activities in 2022. During 2022 remediation activities, all jurisdictional and non- jurisdictional wetlands within 2023 work areas were excavated, graded, or otherwise removed. Ground disturbance 3-4 202303_AnnualPre-ActivitySurvey_RPT.docx within wetlands was conducted outside of rain events, when wetlands were dry, and completed in compliance with all permit conditions. Limits of protected and preserved wetland habitats adjacent to the work areas were delineated to avoid incidental impacts to wetlands that were not permitted for disturbance. The wetlands and waters within the SLO Tank Farm property were delineated and recorded in 2008. Figure 3-3 shows the locations of wetlands and waters adjacent to the 2023 work areas. 202303_AnnualPre-ActivitySurvey_RPT.docx 4-1 4.0 DISCUSSION Biological pre-activity surveys were conducted within and adjacent to the proposed Reservoir 5 and 7 areas, Oxbow Areas 1, 2, 3, and 4, and vegetation and clean soil stockpile area from February through March 2023 for the purpose of documenting the extent of special-status plant populations and plant communities, nesting bird activity, burrowing owl presence, and California red-legged frog presence prior to the initiation of Project activities. All habitat and plant communities were removed from the 2023 work areas during 2022 remediation activities. The botanical results for the 2021 pre-activity survey are included in this Report and were representative of the distribution and abundance of special-status plants and plant communities present within the proposed 2023 work areas prior to the ground disturbance that occurred in 2022. Mapped special-status plant species included Cambria morning glory, San Luis Obispo owl’s clover, and Congdon’s tarplant. Plant communities occurring within the proposed 2022/2023 work areas were verified and were consistent with the pre-existing communities mapped in 2008. Following documentation of the special-status species within the proposed 2023 work areas, salvage or seed collection was conducted as part of restoration and to satisfy CUP COA No. 43. The mapped acreages and quantity of seed collected are as follows:  Cambria morning glory: 0.10 acres collected in 2022, no seed collected in 2022  San Luis Obispo owl’s clover: 1.62 acres collected in 2022, 0.25-lbs of seed collected in 2022  Congdon’s tarplant: no topsoil salvage or seed collected in 2022 Special-status wildlife observed during pre-activity surveys included white-tailed kite, northern harrier, and loggerhead shrike. Nesting behavior was observed in one western meadowlark and a pair of black phoebes outside of the Reservoir 5 work area perimeter. No active nests or burrowing owls were observed during the 2023 pre-activity surveys. Nesting bird and burrowing owl surveys will be conducted during morning biological clearance surveys throughout the duration of the Project. Prior to remediation activities in 2022, there was 5.94 acres of waters/wetlands under federal Clean Water Act (CWA) jurisdiction and 3.25 acres of non-jurisdictional wetlands and waters within the proposed 2023 work areas. All wetlands within the 2023 work areas were excavated, graded, or otherwise disturbed during 2022 activities, and 3.58 acres of new wetlands and vernal pools were constructed. The new wetland habitat was surveyed and no CRLF were identified during day or night surveys. Based on these results and previous survey results, it is unlikely that CRLF will be encountered during Project activities. Four new VPFS features were constructed within the proposed 2023 work areas. No pre-activity VPFS surveys are required (Padre, 2015a; Appendix C). All VPFS occupied vernal pools adjacent to the proposed 2023 work areas were properly delineated prior to ground disturbance in the area to avoid impacts. 4-2 202303_AnnualPre-ActivitySurvey_RPT.docx All wildlife conflicts, impacts, observations, and botanical impact acreages, and wetland and waters impacts will be documented in the Annual Biological Monitoring Report, to be submitted following the completion of 2023 Project activities. 202303_AnnualPre-ActivitySurvey_RPT.docx 5-1 5.0 REFERENCES California Department of Fish and Wildlife (CDFW). 2022. California Natural Diversity Database (CNDDB) Query of San Luis Obispo County. California Native Plant Society, Rare Plant Program. 2019. Inventory of Rare and Endangered Plants of California (online edition, v8-03 0.39). Website http://www.rareplants.cnps.org [accessed 14 March 2019]. Padre Associates, Inc. (Padre) and WSP Environment & Energy (WSP). 2008. Description and Analysis of the Botanical Resources, Including Vascular Plant Species of Conservation Concern, at the Chevron Tank Farm Facility, San Luis Obispo, California. Consultant’s report developed for CEMC, San Luis Obispo, California. Padre Associates, Inc. (Padre). 2014. California Red-legged Frog Survey Report for the Chevron San Luis Obispo Tank Farm, San Luis Obispo County, California. Prepared for CEMC, San Luis Obispo, California. Padre Associates, Inc. (Padre). 2015a. Landscape Restoration Plan, Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project, San Luis Obispo County, California. April 2015. Padre Associates, Inc. (Padre). 2015b. Pre-Activity Botanical Resources Survey Guidelines for Special-Status Plants and Plant Communities. In-house document prepared by Padre, 2015. Padre Associates, Inc. (Padre). 2018. Biological Resources Monitoring 2017 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2018. Padre Associates, Inc. (Padre). 2019. Biological Resources Monitoring 2018 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. March 2019. San Luis Obispo County, Department of Building and Planning. 2014. Notice of Final County Action; Conditional Use Permit (County File Number DRC2013-00056). Letter dated October 28, 2014. San Luis Obispo County, Department of Building and Planning. 2020. Notice of Final County Action; Conditional Use Permit (County File Number DRC2015-00067). Letter dated June 28, 2021. 5-2 202303_AnnualPre-ActivitySurvey_RPT.docx Trihydro Corporation (Trihydro). 2019. 2019 Pre-Activity Biological Survey Report, North Marsh Area Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2019. Trihydro Corporation (Trihydro). 2020a. 2020 Pre-Activity Biological Survey Report, Reservoir 3 Area Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. March 2020. Trihydro Corporation (Trihydro). 2020b. Biological Resources Monitoring 2019 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2020. Trihydro Corporation (Trihydro). 2021a. 2021 Pre-Activity Biological Survey Report, Reservoir 3 Area Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2021. Trihydro Corporation (Trihydro). 2021b. Biological Resources Monitoring 2020 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2021. Trihydro Corporation (Trihydro). 2022a. 2022 Pre-Activity Biological Survey Report, Reservoir 5 and 7 Areas Demolition, Grading and Restoration, San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. April 2022. Trihydro Corporation (Trihydro). 2022b. Biological Resources Monitoring 2021 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2022. Trihydro Corporation (Trihydro). 2023. Biological Resources Monitoring 2022 Annual Summary Report, Chevron San Luis Obispo Tank Farm Remediation and Restoration Project, San Luis Obispo County, California. January 2023. TABLES TABLE 2-1. SUMMARY OF 2022-2023 FIELD ACTIVITIES 2-1_202303_Summary-FieldActivities_TBL-2-1.docx 1 of 1 Survey Dates Field Activity Biological Staff April – August, 2022 Plant Bloom and Seed Status Surveys G. Pelzmann, and I. Arroyos April – June, 2022 Plant Community Verification Survey I. Arroyos, and G. Pelzmann June 9, 2020 Sensitive Plant Mapping Survey M. Thule February 1, 2023 California red-legged frog Survey; Burrowing Owl Survey (night) S. Seay, G. Pelzmann, V. Trautman, I. Arroyos February 8, 2023 California red-legged frog Survey; Burrowing Owl Survey (night) S. Seay, G. Pelzmann, J. Moore, I. Arroyos February 15, 2023 California red-legged frog Survey; Burrowing Owl Survey (night) S. Seay, G. Pelzmann, I. Arroyos February 21, 2023 California red-legged frog Survey; Burrowing Owl Survey (night) S. Seay, G. Pelzmann, I. Arroyos March 3, 2023 California red-legged frog Survey; Burrowing Owl Survey (day) S. Seay, G. Pelzmann March 24, 2023 California red-legged frog Survey; Burrowing Owl Survey (day) S. Seay, G. Pelzmann March 9, 2021 Special-status plant mapping reconnaissance survey – Cambria morning glory, Owl’s clover I. Arroyos March 9, 2021 Plant community mapping verification survey I. Arroyos March 3, 24, 2023 Nesting Bird Survey S. Seay, G. Pelzmann TABLE 3-1. SPECIAL-STATUS PLANT ACREAGES WITHIN PROPOSED WORK AREAS 3-1_202303_PlantAcreages_TBL-3-1.docx 1 of 1 Species Acres Work Area(s) Cambria Morning Glory 0.08 Oxbow 11, Oxbow 31 San Luis Obispo owl’s clover No occurrences within proposed work areas. All populations within Reservoir 5 and Reservoir 7 were impacted/removed during 2022 activities Congdon’s tarplant No occurrences within proposed work areas. All populations within Reservoir 5 and Reservoir 7 were impacted/removed during 2022 activities Purple needlegrass No occurrences within proposed work areas Hoover’s button celery No occurrences within proposed work areas San Luis Obispo serpentine dudleya All SLO serpentine dudleya salvaged in 2015 California walnut No occurrences within proposed work areas Note: 1 Work areas proposed for 2023 activities. TABLE 3-2. PLANT COMMUNITY ACREAGES WITHIN PROPOSED WORK AREAS 3-2_202303_CommunityAcreages_TBL-3-2.docx 1 of 1 Plant Community Acres Work Area(s) Non-native annual grassland 0.41 Oxbows1 1 - 4 Palustrine nonpersistent emergent vernal swale/pool 0.06 Oxbow 11, Oxbow 21 Palustrine forested broad-leaf deciduous valley stream-bank wetland 0.06 Oxbow 21, Oxbow 31, Oxbow 41 Palustrine scrub-shrub broad-leaf deciduous valley stream-bank wetland 0.02 Oxbow 11 Serpentine rock outcrop Does not occur in proposed work areas Palustrine persistent emergent vernal freshwater marsh Does not occur in proposed work areas Notes: All plant communities within Reservoir 5, Reservoir 7, and the Aggregate Stockpile Area were impacted/removed during 2022 activities. 1 Work areas proposed for 2023 activities. TABLE 3-3. SUMMARY OF SEED COLLECTED IN 2021 3-3_202303_SeedCollected_TBL-3-3.docx 1 of 1 Species Date(s) collected Processed Quantity Tested San Luis Obispo owl’s clover April 20 and 24, 2022 0.25 lbs No Congdon’s tarplant No seed collected. Hoover’s button celery No seed collected; plants located outside of proposed work areas. Cambria morning glory No seed collected. Purple needlegrass No seed collected; will purchase seed/plugs for restoration. San Luis Obispo serpentine dudleya1 All SLO serpentine dudleya salvaged in 2015. California walnut No seed collected; trees located outside of proposed work areas. Note: 1 See summary in Annual Pre-Activity Biological Survey Report (Padre, 2016) FIGURES Last exported to pdf from ArcGIS Pro by hettick on 3/17/2023, 11:43 AM. 1252 Commerce Drive Laramie, WY 82070 www.trihydro.com (P) 307/745.7474 (F) 307/745.7729 File: 3-1_SpecialStatusPlants_Fig3-1 M:\CHEVRON\SANLUISOBISPO\GIS\MAPPING\REPORTS\ANNUAL_PRE-ACTIVITY_REPORT\2023\SLOTF_ECO_PRE-ACTIVITYREPORT_2023PH.APRXDate: 3/17/23Scale: 1" = 600'Checked By: GPDrawn By: NM SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO COUNTY, CA PRE-ACTIVITY BOTANICAL SURVEY RESULTS MAP SPECIAL-STATUS PLANTS FIGURE 3-1 0 600 ' EXPLANATION 2023 WORK AREA FUTURE WORK AREA PROJECT SITE BOUNDARY CONGDON'S TARPLANT HOOVER'S BUTTON CELERY PURPLE NEEDLEGRASS GRASSLAND SLO OWL'S CLOVER SLO CAMBRIA MORNING GLORY OXBOW AREA NO. 4 OXBOW AREA NO. 3 OXBOW AREA NO. 2 OXBOW AREA NO. 1 RESERVOIR 5 RESERVOIR 7 AGGREGATE STOCKPILE OXBOW AREA NO. 3 OXBOW AREA NO. 5 Esri, HERE, iPC, Maxar Last exported to pdf from ArcGIS Pro by hettick on 3/17/2023, 11:43 AM. 1252 Commerce Drive Laramie, WY 82070 www.trihydro.com (P) 307/745.7474 (F) 307/745.7729 File: 3-2_PlantCommunities_Fig3-2 M:\CHEVRON\SANLUISOBISPO\GIS\MAPPING\REPORTS\ANNUAL_PRE-ACTIVITY_REPORT\2023\SLOTF_ECO_PRE-ACTIVITYREPORT_2023PH.APRXDate: 3/17/23Scale: 1" = 600'Checked By: GPDrawn By: NM SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO COUNTY, CA PRE-ACTIVITY BOTANICAL SURVEY RESULTS MAP PLANT COMMUNITIES FIGURE 3-2 0 600 ' EXPLANATION 2023 WORK AREA FUTURE WORK AREA PROJECT SITE BOUNDARY PALUSTRINE FORESTED BROAD-LEAF DECIDUOUS VALLEY STREAM-BANK WETLAND PALUSTRINE NONPERSISTANT EMERGENT VERNAL SWALE/POOL PALUSTRINE PERSISTENT EMERGENT VERNAL FRESHWATER MARSH PALUSTRINE SCRUB-SHRUB BROAD-LEAF DECIDUOUS VALLEY STREAM-BANK WETLAND SERPENTINE BUNCH GRASSLAND NON-NATIVE ANNUAL GRASSLAND OXBOW AREA NO. 4 OXBOW AREA NO. 3 OXBOW AREA NO. 2 OXBOW AREA NO. 1 RESERVOIR 5 RESERVOIR 7 AGGREGATE STOCKPILE OXBOW AREA NO. 3 OXBOW AREA NO. 5 Esri, HERE, iPC, Maxar Last exported to pdf from ArcGIS Pro by hettick on 3/17/2023, 11:44 AM. 1252 Commerce Drive Laramie, WY 82070 www.trihydro.com (P) 307/745.7474 (F) 307/745.7729 File: 3-3_SpecialStatusWildlife_Fig3-3 M:\CHEVRON\SANLUISOBISPO\GIS\MAPPING\REPORTS\ANNUAL_PRE-ACTIVITY_REPORT\2023\SLOTF_ECO_PRE-ACTIVITYREPORT_2023PH.APRXDate: 3/17/23Scale: 1" = 600'Checked By: GPDrawn By: NM SAN LUIS OBISPO TANK FARM SAN LUIS OBISPO COUNTY, CA PRE-ACTIVITY BIOLOGICAL SURVEY RESULTS MAP SPECIAL-STATUS WILDLIFE FIGURE 3-3 0 600 ' EXPLANATION PROJECT SITE BOUNDARY 2023 WORK AREA FUTURE WORK AREA CALIFORNIA RED-LEGGED FROG HABITAT VERNAL POOL FAIRY SHRIMP OCCUPIED POOL (OUTSIDE DISTURBANCE AREA) OXBOW AREA NO. 4 OXBOW AREA NO. 3 OXBOW AREA NO. 2 OXBOW AREA NO. 1 RESERVOIR 5 RESERVOIR 7 AGGREGATE STOCKPILE OXBOW AREA NO. 3 OXBOW AREA NO. 5 Esri, HERE, iPC, Maxar APPENDIX A BOTANICAL SURVEY GUIDELINES Chevron San Luis Obispo Tank Farm Remediation, Restoration Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0307 - 1 - PRE-ACTIVITY BOTANICAL SURVEY GUIDELINES FOR SPECIAL-STATUS SPECIES AND PLANT COMMUNITIES The following outlines the background information, monitoring methodology, and reporting tasks associated with pre-activity botanical surveys at the Project site. The purpose of a botanical pre-activity survey is to document the location and acreage of special-status plant populations and plant communities to be impacted within the Project site. GUIDANCE AND REGULATIONS Pre-activity surveys will be completed within the appropriate season prior to the onset of initial ground disturbance activity conducted at the Project site. Botanical pre-activity surveys will be conducted within the disturbance areas per the Project Final Environmental Impact Report (EIR) Conditions of Approval BIO-1b, which states: “The Applicant shall conduct updated surveys of sensitive species habitats (including sensitive plant species, CRLF, wetland habitat, and VPFS habitat) within the Project Site within the appropriate season immediately prior to the onset of any ground disturbances associated with the Project in order to evaluate the current occupancy of suitable habitat for sensitive species and to refine the final habitat mitigation replacement acreages. Updated surveys for federally listed species shall be completed per the timing and methodology specified by resource agency protocol”. As stated above, and as including in the Project Landscape Restoration Plan botanical pre-activity surveys will be conducted prior to disturbance, to determine the acreages of special- status species and plant communities that are proposed to be impacted. The resulting acreage values may be used to refine target acreages. Special-status species population target densities will not be re-evaluated, as they are expressed as set “target densities” in the Success Criteria outlined in the Landscape Restoration Plan. SURVEY METHODS Prior to conducting field surveys, a Job Safety Analysis (JSA) will be completed for all activities. All personal protective equipment (PPE) will be dawn per the Project health and safety plan (HASP). The JSA and HASP will be on the field personnel during all field activities. Field survey standard operational plans (SOPs) will be reviewed as necessary prior to conducting activities. During pre-activity botanical surveys, the limits of the special-status species populations will be surveyed using a hand-held GPS unit and qualitative assessments of special-status species populations will be completed within the immediate disturbance area per Project phase. Qualitative assessments of the special-status species populations will include documentation of species composition, general location notes, and overall health and vigor of the population. Plant communities mapped in 2009 will be field verified and any major shifts in the extent of the Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 2 - communities may be mapped, as necessary. Representative photographs will be taken of special-status species populations and plant communities within the proposed disturbance area. Special-Status Species The procedures for special-status species population surveys include both survey of the population size and location, and qualitative assessment, and are described in this section. 1. Reconnaissance survey. Qualitative assessment within the proposed disturbance area to determine blooming status of special-status species. Assessments will be completed during appropriate blooming periods as illustrated in Table 1. Table 1. Blooming Period for Special-Status Plant Species Blooming Period (month) Plant Species (Common Name) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Cambria morning glory San Luis Obispo owl’s clover Congdon’s tarplant Hoover’s button-celery Purple needlegrass 2. Survey extent of the population. During the peak of the blooming season for each special-status species population, biologists will survey the extent of the population within the proposed disturbance area using a hand-held GPS unit. Pin flags will be used to mark boundaries and will be removed following mapping. 3. Data Collection/GPS Documentation. Data collection in the GPS unit will be saved in a corresponding folder specific to the year in which the survey was collected. The code system as described in Table 2 will be used to identify each population and saved in the year’s folder. Table 2. Special-Status Species Population GPF Filename Codes Representative GPS Filename for Special-Status Species Populations: “ SLOTF SSS 2015” Species GPS ID Code Cambria Morning Glory (Calystegia subacaulis ssp. episcopalis ) CASUE SLO Owl’s Clover (Castilleja densiflora ssp. obispoensis) CADEO Congdon’s tarplant (Centromadia parryi ssp. congdonii ) CEPAC Hoover’s button celery (Eryngium aristutalum var. hooveri) ERAR Purple needlegrass (Stipa pulchra) STPU SLO Serpentine dudleya (Dudleya abramsii ssp. bettinae) DUAB California walnut (Juglans californica) JUCA Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 3 - 4. Qualitative Botanical Assessment. Record the dominant plant species that occur within the populations, environmental conditions, estimate percent bloom, and soil moisture. This data is for informational purposes only and will be used to document seasonal and yearly changes in site conditions throughout the Project duration and may be useful for restoration planning. 5. Photographs. Representational photographs will be taken of populations within the proposed disturbance area. Plant Communities The procedures for plant community surveys include a representative qualitative assessment and field verification of previously mapped boundaries, as described below. Plant communities follow the nomenclature used in the 2008 SLO Tank Farm Botanical Report. 1. Field verification of plant community boundaries. Using a field copy of the previously mapped plant communities, representative portions of the plant communities will be verified. If significant discrepancies between the reference map and the field conditions are observed, the extent of the community may be re-surveyed. 2. Survey extent of the community. Biologists will survey the extent of the community within the proposed disturbance area using a hand-held GPS unit. Pin flags will be used to mark boundaries and will be removed following mapping. Communities will only be surveyed if there are significant changes in community size or location. 3. Data Collection/GPS Documentation. For communities that have significant changes in population size/location, data collection in the GPS unit will be saved in a corresponding folder specific to the year in which the survey was collected. The code system as described in Table 3 will be used to identify each community and saved in the year’s folder. Table 3. Plant Community GPS Filename Codes Representative GPS Filename for Plant Community Polygons: “SLOTF PC 2015” Plant Community (PC) GPS ID Code Non-native annual grassland GRASS Serpentine bunchgrass grassland SERP Palustrine persistent emergent vernal freshwater marsh VERMAR Palustrine nonpersistent emergent vernal swale/pool VERNPOOL Palustrine scrub-shrub broad-leaf deciduous valley stream-bank wetland SCRUBWET Palustrine Forested broad-leaf deciduous valley stream-bank wetland WOODWET Serpentine rock outcrop ROCK Urban/Ruderal RUD Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 4 - 4. Qualitative Botanical Assessment. Record the dominant plant species that occur within the community and environmental conditions. This data is for informational purposes only and will be used to document seasonal and yearly changes in site conditions throughout the Project duration and may be useful for restoration planning. 5. Photographs. Representational photographs will be taken of all communities within the disturbance area. Chevron San Luis Obispo Tank Farm Remediation, Restoration, and Development Project Pre-Activity Botanical Survey Guidelines Project No. 1301-0306 - 5 - FIELD MATERIALS CHECKLIST  Trimbel GeoXT GPS Unit  Camera  Field Data Sheet  Pin flags  JSA/HASP  PPE  Plastic bags for plant collection; if needed for positive identification using dissecting scope  Field maps (PDF and/or hard copy): 1. SLOTF aerial with property boundary and existing plant communities (2008); 2. SLOTF aerial with property boundary and existing special-status plant populations (2008); and 3. SLOTF aerial with illustrated Project disturbance limits for the given year. REPORTING The resulting data will be used to generate an annual botanical resources report that may be used to support Project permit reporting requirements. The annual botanical resources report will provide a summary of botanical surveys completed within the year and associated figures, data sheets, and photographs. The report will include a summary of survey methods, including survey boundaries. The survey results, previously mapped plant communities, and proposed Project disturbance limits will be included in figures. APPENDIX B SITE PHOTOGRAPHS APPENDIX B. SITE PHOTOGRAPHS 2-202303_SitePhotos_APP-B.docx 1 of 3 Photo 1. Reservoir 5 – botanical communities surveyed prior to 2022 disturbance. Aspect: north. Date: 04/08/2022. Photo 2. Reservoir 7 – botanical communities surveyed prior to 2022 disturbance. Aspect: west. Date: 04/15/2022. APPENDIX B. SITE PHOTOGRAPHS 2 of 3 2-202303_SitePhotos_APP-B.docx Photo 3. Oxbow No. 2 – habitat surveyed for amphibians and nesting birds. Aspect: south. Date: 03/24/2023. Photo 4. Oxbow No. 4 – habitat surveyed for amphibians and nesting birds. Aspect: southwest. Date: 03/24/2023. APPENDIX B. SITE PHOTOGRAPHS 2-202303_SitePhotos_APP-B.docx 3 of 3 Photo 5. Reservoir 5 – habitat surveyed for amphibians and nesting birds. Aspect: northeast. Date: 03/24/2023. Photo 6. Reservoir 7 – habitat surveyed for amphibians and nesting birds. Aspect: south. Date: 03/24/2023. APPENDIX C VERNAL POOL FAIRY SHRIMP PRE-ACTIVITY CONSULTATION LETTER United States Department of the Interior tFtk’1 FISH AND WILDLIFE SERVICE Ventura Fish and Wildlife Office 3.2493 Portola Road,Suite B Ventura,California 93003 IN REPLY REFER TO: O$EVENOO-2016-CPA-0061 January 25,2016 Sarah Powell Padre Associates,Inc. 369 Pacific Street San Luis Obispo,California 93401 Subject:Pre-activity surveys for vernal pooi fairy shrimp at Chevron’s San Luis Obispo Tank Farm site Ms.Powell: This correspondence responds to your letter dated November 13,2015,that requests ourguidanceregardingtheneedforadditionalsurveysforvernalpooifairyshrimp(&anchinectalynchi;VPFS)at Chevron’s San Luis Obispo Tank Farm site located at 276 Tank Farm Road,County of San Luis Obispo,California.The site is within a decommissioned oil facility originally owned by Union Oil,which reorganized as Unocal in the 19$Os,and was purchased byChevronin2005.This approximately 340-acre site was previously used to store petroleum,andotherrelatedproductsalthoughthestoragetanksandotherinfrastructurehavebeenremoved. Much of the surrounding area is largely undeveloped land that has historically been used forlivestockgrazingwiththeSanLuisObispoAirportlocatedtothesoutheast.Lands to the eastandwesthavebeendevelopedforresidential,commercial and light industrial uses. As you are aware,Chevron staff and their consultants have been working with Julie Vanderwier and Jenny Marek of the U.S.Fish and Wildlife Service’s (Service)office in Ventura to ensure endangered species compliance as part of the proposed site remediation and development project.The remediation project would address soil and groundwater contamination identified as potential human health or ecological risks agreed upon by resources agencies who participated in a highly collaborative process.Development would involve the creation of both business park and service commercial uses.Of particular concern relative to project implementation is the presence of the federally threatened VPFS,an invertebrate species first identified in some of the seasonally inundated features on Chevron’s property in 2003.Surveys indicate that 32.6 acres of habitat variously occupied by VPFS is present onsite. In 2011,in consultation with the U.S.Army Corps of Engineers (Corps),the Service issued biological opinion 8-8-1 0-F-63 that analyzed the effects to VPFS from investigations necessary to characterize cultural resources and onsite soils as part of the preparation of an environmental impact report (EIR)for the proposed remediation and development project.It was our conclusion that the proposed action was not likely to jeopardize the continued existence of vernal pooi fairy Sarah Powell 2 shrimp.The final EIR (FEIR;Marine Research Specialists 2013)for the remediation and development project was completed in 2013.Currently,we are in consultation with the Corps regarding the effects to VPFS that would result from their issuance of a permit for this same project. Relevant to VPFS,it has come to our attention that two mitigation measures included in the FEIR for the remediation and development project have been made conditions of Conditional Use Permit DRC2O13-00056 issued by the County of San Luis Obispo.These conditions (#77 [FEW BIO-lb]and #78 [fEIR BlO ii])require that,prior to the commencement of grading or other construction activities,the applicant conduct updated surveys for VPf S and its habitat (Marine Research Specialists 2013).The following table provides information regarding wet and dry season surveys that have been conducted for VPFS onsite to-date. VPFS Survey History at the SLO Tank Farm Site VPFS Survey Survey Results and Report Reference Initial wet and dry season surveys conducted at 60 of $6 potential habitat features sampled were the SLO Tank Farm Site between 2003 and 2005.determined to support the VPf S (Rincon 2005). Supplemental surveys of previously unoccupied 5 of 24 previously unoccupied habitat features habitat requested by the U$FWS and conducted included in the surveys were determined to during the 2011/2012 wet season.support the VPFS (Padre 2012). Wet and dry season surveys of offsite potential No VPF$individuals or eggs were found in offsite habitat (Garcia Property)conducted between potential habitat (Padre 2013a;Padre 20l4a; 2012 and 2015.Padre 2015a). Dry season surveys conducted as part of the Cyst Determined cyst density of occupied features Density Study.onsite for the purposes of designing a prioritized topsoil collection plan (LSA 2014). Cultural Resource Surveys,Soil Assessment,and Eight of ten monitored features met performance Waste Characterization Project Post-Construction criteria for successful restoration of habitat VPFS Monitoring.hydroperiod and one of three monitored features consistently met the VPFS performance criteria (Padre 2013b;Padre 2014b;Padre 2015b). It is our opinion that these surveys are adequate to characterize site use by this species,to inform effects analyses necessary for our consultation with the Corps,and to inform the preparation and implementation of a restoration plan intended to improve site conditions for VPFS.When considering project effects to this species,we use occupied habitat as a surrogate as it is not possible to estimate take of individuals and will therefore be focused on the restoration of habitat Sarah Powell 3 that can support vernal pooi fairy shrimp in the long-term.We cannot speak to the appropriateness of the conditions contained in the CUP;however,we do not believe that additional surveys will add significantly to our knowledge regarding use of this site by VPF$or be necessary to develop and implement the required restoration plan.As part of our discussions with Chevron and the County and City of San Luis Obispo over the years,we have consistently maintained that it was not our desire to see the effects and/or take of this species be compensated for using an established ratio.Rather,in order to further species recovery,it was our desire to see an increase in the value and function of onsite habitat that would be managed for persistence of VPFS in perpetuity.As such,minor adjustments to occupied habitat are not considered important to the continued existence of vernal pooi fairy shrimp within the project area post-project completion.Rather,one of the specific goals of the draft habitat restoration plan is to increase thevalueandfunctionofhabitatforVPFS. Because we do not believe that pre-activity surveys for VPFS and their habitat would provide substantially different information regarding species presence onsite and because our guidance allows for flexibility as to when we would ask for surveys to be conducted,we do not think thatitisnecessarytoconductadditionalsurveysandconsiderthattheexistingdataissufficientforustocompleteourconsultationwiththeCorpsregardingprojectimplementation. If you have any questions regarding this determination or the ongoing consultation,pleasecontactMs.Vanderwier at ($05)644-1766,extension 222.She may also be contacted using emailatthisaddress:julie_vanderwierfws.gov. Sincerely, Glen W.Knowles Assistant Field Supervisor ecc: Crystahi Taylor,Padre Associates Jenny Marek,Ventura Fish and Wildlife Office LITERATURE CITED LSA Associates,Inc [LSAJ.2014.Chevron San Luis Obispo Tank Farm Vernal Pool Branchiopod Cyst Density Study,October,2014. Marine Research Specialists.2013.Chevron Tank Farm Remediation and Development Project Final Environmental Impact Report (FEIR).Prepared For:City of San Luis Obispo County of San Luis Obispo (SCH #200903 1001). Padre Associates,Inc [Padre].2012.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the San Luis Obispo Tank Farm Site,San Luis Obispo,CA (USFWS Reference Nos.81440-2009-B-0180 [Chevron Tank Farm];$1440-2010-B-0026 [Powell];81440-2009-B-0049 [Thomas]).Consultant’s Report for U.S.Fish and Wildlife Service.June,2012. Padre Associates,Inc [Padre].2013a.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the Offsite Impact Area at the Chevron San Luis Obispo Tank Farm Site,San Luis Obispo,California (USFWS Reference Nos.$1 440-2009-B-0 120 [Chevron Tank Farm];81440-2010-B-0026 [Powell];81440-2009-B-0049 [Thomas]).Consultant’s Report for U.S.Fish and Wildlife Service.July,2013. Padre Associates,Inc [Padre].2013b.2012/2013 Wet Season (Year-i)VPFS Monitoring Report for the San Luis Obispo Tank Farm Cultural Resources Survey and Waste Characterization Survey Projects.Consultant’s Monitoring Report prepared for U.S.Fish and Wildlife Service.September,2012. Padre Associates,Inc [Padre].20l4a.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the Offsite Impact Area at the Chevron San Luis Obispo Tank Farm Site,San Luis Obispo,California (USFWS Reference Nos.81440-2009-3-0180 [Chevron Tank Farm];81440-2010-B-0026 [Powell];81440-2009-B-0049 [Thomas])—Statement of No Survey Activity.Consultant’s Report for U.S.Fish and Wildlife Service.July,2014. Padre Associates,Inc [Padre].2014b.2013/2014 Wet Season VPFS Monitoring Report (Year-2) for the San Luis Obispo Tank Farm Cultural Resources Survey and Waste Characterization Survey Projects.Consultant’s Monitoring Report prepared for U.S.Fish and Wildlife Service.August,2014. Padre Associates,Inc [Padre].201 5a.90-Day Report on Wet Season Vernal Pool Branchiopod Surveys for the Offsite Impact Area at the Chevron San Luis Obispo Tank Farm Project Site,San Luis Obispo,California (USFWS Reference Nos.81440-2009-B-0180 [Chevron Tank Farm];81440-2010-B-0026 [Powell]).Consultant’s Report for U.S.Fish and Wildlife Service.June,2015. Padre Associates,Inc [Padre].20155.2014/2015 Wet Season VPF$Monitoring Report (Year-3) for the Cultural Resources Survey and Waste Characterization Survey Projects at the San Luis Obispo Tank Farm.Consultant’s Monitoring Report prepared for U.S.Fish and Wildlife Service.June,2015. Rincon Consultants,Inc [Rincon].2005.Unocal Corporation San Luis Obispo Tank Farm Comprehensive Fairy Shrimp Wet and Dry Season Survey Report.Consultant’s report prepared for Union Oil Company.San Luis Obispo,CA. APPENDIX D CALIFORNIA RED-LEGGED FROG PRE-ACTIVITY SURVEY DATA SHEETS Tank Farm Sewer Lift Station 264 Tank Farm Road 1630-1 28.2 2.4 Cummings 250 KW 0.0 DQDAA-7549912 2022 Operating Mode Engine HR Engine HR Calendar Year Calendar Year Calendar Year Fuel Use Fuel Use Fuel Total Cost M- (Maintenance) Meter at Meter at Total Operational Total Maintenance Total Emergency Estimate Fuel Total Calendar Purchased Engine Repair or E-(Emergency) Start-Up Shut-down Hours to Date Operating Hours Operating Hours Use In Gallons Fuel Use For in Gallons Reconstruction D- (District Testing) for the Day This Year 1/12/22 MB M- (Maintenance) 378.1 379.5 379.5 1.4 0.0 2.8 2.8 0 0 774 1/24/22 MB M- (Maintenance) 379.5 380.0 380.0 0.5 0.0 1.0 3.8 0 0 775 2/7/22 JR M- (Maintenance) 380.0 380.9 380.9 0.9 0.0 1.8 5.6 0 0 777 2/9/22 SLPH M- (Maintenance) 380.9 381.2 381.2 0.3 0 0.6 6.2 0 0 780 2/24/22 GE M- (Maintenance) 381.2 382.6 382.6 1.4 0.0 2.8 9.0 0 0 782 3/7/22 JR M- (Maintenance) 382.6 383.1 383.1 0.5 0.0 1.0 10.0 0 0 783 3/21/22 JR M- (Maintenance) 383.1 384.0 384.0 0.9 0.0 1.8 11.8 0 0 785 4/4/22 JR M- (Maintenance) 384.0 385.2 385.2 1.2 0.0 2.4 14.2 0 0 788 4/18/22 JR M- (Maintenance) 385.2 386.1 386.1 0.9 0.0 1.8 16.0 0 0 790 5/2/22 CL M- (Maintenance) 386.1 387.0 387.0 0.9 0.0 1.8 17.8 0 0 792 5/16/22 JR M- (Maintenance) 387.0 388.0 388.0 1.0 0.0 2.0 19.8 0 0 794 5/31/22 JR M- (Maintenance) 388.0 389.2 389.2 1.2 0.0 2.4 22.2 0 0 797 6/13/22 JR M- (Maintenance) 389.2 390.1 390.1 0.9 0 1.8 24 0 0 799 6/27/22 CL M- (Maintenance) 390.1 391.0 391.0 0.9 0.0 1.8 25.8 0 0 801 7/11/22 CL M- (Maintenance) 391.0 392.0 392.0 1.0 0.0 2.0 27.8 0 0 803 7/25/22 JR M- (Maintenance) 392 393.3 393.3 1.3 0 2.6 30.4 0 0 806 8/8/22 JR M- (Maintenance) 393.3 394.2 394.2 0.9 0.0 1.8 32.2 0 0 808 8/22/22 JS M- (Maintenance) 394.2 395.4 395.4 1.2 0.0 2.4 34.6 0 0 811 9/12/22 JS M- (Maintenance) 395.4 396.8 396.8 1.4 0.0 2.8 37.4 0 0 814 9/19/22 JR M- (Maintenance) 396.8 397.3 397.3 0.5 0.0 1.0 38.4 0 0 815 10/3/22 JS M- (Maintenance) 397.3 398.2 398.2 0.9 0 1.8 40.2 0 0 817 10/17/22 JS M- (Maintenance) 398.2 399.1 399.1 0.9 0.0 1.8 42.0 0 0 819 10/31/22 JS M- (Maintenance) 399.1 400.1 400.1 1.0 0.0 2.0 44.0 0 0 821 11/15/22 JS M- (Maintenance) 400.1 401.1 401.1 1.0 0.0 2.0 46.0 0 0 822 11/16/22 SLPH M- (Maintenance) 401.1 403.2 403.2 2.1 0.0 4.2 50.2 0 0 825 11/18/22 JH M- (Maintenance) 403.2 404.4 404.4 1.2 0.0 2.4 52.6 0 0 826 12/12/22 JS M- (Maintenance) 404.4 405.3 405.3 0.9 0.0 1.8 54.4 0 0 827 12/21/22 JH M- (Maintenance) 405.3 406.3 406.3 1.0 0 2.0 56.4 0 0 829 28.2 56.4 28.2 56.4 NOTES: 1. Maximum Annual Maintenance Hours = 30 Hours 2. Entries shall be made for any day the engine is operated and for any day the engine receives fuel 3. To estimate fuel consumption use 2.0 Gallons/Hour 4. * Denotes Extra Start for Mainenance City of San Luis Obispo, Utilities Department San Luis Obispo County Air Pollution Control District Calendar Year Engine Operating Log # Starts 2022 Total Annual Operational Hours: 2022 Total Annual Maintenance Hours: 2022 Total Annual Emergency Hours: InitialsDate Facility: # 2665 Permit #: Engine: Model #: Year: Address: 1 From:Beech, Ryan Sent:Friday, February 17, 2023 6:30 AM To:SLO APCD EI 2022-2665 Cc:Lehman, Chris Subject:RE: Tank Farm APCD Emissions Inventory Request for 2022 (2665) Attachments:2022 Tank Farm Generator APCD Log.xls; 2665 _San_Luis_Obisp_ENG032StandByBackupGenerators.pdf; 2665 _San_Luis_Obisp_Contacts_ENG001.pdf; 2665_San_Luis_Obisp_ENG001.pdf Hello, Here are the 2022 APCD emissions inventory documents you requested for Tank Farm Lift Station (facility ID #: 2665). Please let me know if need any other information. Thank You, Ryan Beech WWC System Supervisor Public Utilities 25 Prado Road, San Luis Obispo, CA 93401-7314 E RBeech@slocity.org T 805.781.7033 C 805.540.8937 slocity.org Stay connected with the City by signing up for e-notifications From: SLO APCD <APCD_slocleanair@co.slo.ca.us> Sent: Thursday, February 2, 2023 3:29 PM To: Beech, Ryan <RBeech@slocity.org> Subject: APCD Emissions Inventory Request for 2022 (2665) This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Facility Name: San Luis Obispo City - Tank Farm Lift Station Facility ID #: 2665 Forms Required: 1, 32 The Air Pollution Control District is required to achieve and maintain state ambient air quality standards. As part of our effort to comply, the District has developed a plan to monitor and reduce air pollutant emissions. To track 2 our progress toward achieving the goals of our plan, the District must survey our permitted facilities to verify the emission sources, location, types, and amounts of air emissions. Please download the attached file: 2665_San_Luis_Obisp_ENG001.pdf. This file is a fillable PDF file that contains the required ENG001 Data Certification form. Please review the ENG001 form and return it to us - re- typing your name in the signature field is valid as a signature. Also attached, is 2665_San_Luis_Obisp_Contacts_ENG001.pdf that contains a copy of the contact information we have on file for your facility. Please return this form to us if there are corrections to be made to your contact information. Some forms have been revised for 2022 reporting. Please download and complete the forms indicated above for 2022 data, specific to the equipment you operate, from our website located at slocleanair.org/library/download-forms.php. Forms are organized online by form number. Please be sure to provide all requested information for calendar year 2022 activities. Please note - the Facility ID # referenced above will need to be entered on all forms and supplemental information you submit. Use the attached Form 32 (2665_San_Luis_Obisp_ENG032StandByBackupGenerators.pdf ) to report data for all Standby and Backup Generators at all facilities for which you report usage data. For your convenience, the form has been pre-filled with data held on file at the District. Please verify the information is correct and complete. Include corrected or omitted information on the form, along with the required operating information for 2022. Retain a copy for your records. If you have suggestions to improve these forms, please indicate in your submittal where improvements can be made. The District welcomes your input. After completing the required forms, please fax, mail, or email them to the District office by March 1, 2023. Forms may be faxed to (805) 781-1002 or emailed to ei@slocleanair.org. If you have any questions or need assistance obtaining or submitting the required forms, please contact our office at (805) 781-5912. Sincerely, Dora Drexler Manager, Engineering & Compliance Division Facility ID # 2665 Facility Name: San Luis Obispo City - Tank Farm Lift Station Forms Required: 1, 32 (Form 1 should be attached) Download Forms (see Emissions Inventory section) Facility Contact Information – Please review If contact corrections are required, record them below and submit this page with your ENG001 Data Certification form. Facility, Inspection, Emissions Inventory, and Accounting contacts will be assumed to be the Owner unless otherwise noted. Please provide mail address, phone number (w-work, c-cell, f-fax), and email address for each contact type. Facility # and Name: On File Corrections to be made Owner Facility Contact Inspection Contact Emissions Inventory Contact (EI) Accounting Contact I, (Clearly Print Name), certify that the contact information provided above is complete and accurate to the best of my knowledge. Signature: Date: 3433 Roberto Court San Luis Obispo CA 93401 (805) 781-5912 FAX: (805) 781-1002 www.slocleanair.org DATA CERTIFICATION FORM For Inventory Year – 2022 Page 2 – Contact Corrections T 805.781.5912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401 Please review and correct, if necessary, all fields on both enclosed forms and retain a copy for your records. Print your name and sign the forms in the spaces provided at the bottom. Submit completed forms by the due date stated in the cover letter to avoid possible penalties. Completed forms may be mailed, faxed to (805) 781-1002, or scanned and emailed to ei@slocleanair.org. Call (805) 781-5912 if you have any questions. A. Emission Inventory Data (Please provide contact corrections on page 2.) Facility ID (see cover letter) Site ID Facility Name Equipment Address* Emissions Inventory Contact (Name, Mailing Address, Phone, and e-mail) Required Forms Download forms from: slocleanair.org, Downloadable Forms *Note: Ensure the Equipment Address is the location where the equipment or process is located. B. Facility contact information on page 2 has been reviewed and corrected, as needed. Yes No C. Is trade secret data included? (If yes, attach explanation.) Yes No D. Are there any NEW air emission sources? (If yes, describe in Remarks box below.) Yes No E. Are there any emission sources no longer in service? (If yes, write permit number in Remarks box below.) Yes No F. Are the required forms submitted or enclosed? Yes No Remarks: Under California Health and Safety Code sections 40701 and 42303 the District has the right to request data needed to estimate pollutant emissions. Consequently, you are obligated to provide all requested data by the due date. This data is also requested under the authority of the Air Toxics Hot Spots program. The data may be used to determine perm it renewal fees. Failure to provide complete data by the due date may result in fines or penalties. I, (Clearly Print Name), certify that the data provided above and in all attachments is complete and accurate to the best of my knowledge. Signature: Date: DATA CERTIFICATION FORM For Inventory Year - 2022 Equipment Identification Annual Fuel Consumption (Required) Annual Hours Used (Required) APCD Permit No. APCD Facility ID Device Description (1) (as described on your Permit to Operate) Equipment Rating (hp) (2) Fuel Type (3,4) Amount Units (5) Method (6) Total Hours (7) Non- emergency Hours (8) Meter Reading (9) Date of Meter Reading (10) 1234 1234 Example: 99KW Cummins Model ABC789 170 hp Diesel 20 Gal E 5 4 18.7 EMISSIONS INVENTORY INFORMATION For Inventory Year – 2022 FORM 32: STAND-BY/BACKUP GENERATORS NOTES (1) Refer to the equipment description on your permit. (2) For internal combustion engines, specify horsepower (hp). Include units of measure. (3) Examples: natural gas, propane gas, diesel fuel, fuel oil. If fuel oil is burned, specify grade (example: fuel oil No. 2). (4) If a device burns more than one fuel, use a separate line for each fuel. (5) Examples of acceptable units of measure (therms, mcf, mmcf, gal, mgal, bbl, or mbbl). Be sure that your units of measure are correct. (6) How annual fuel use was determined. Use the following codes: M = measured or metered, E = Estimated based on fuel purchases/deliveries, H = Estimated based on hours run, O = Other. If the method is Other (O), please briefly describe in the remarks column of Form 1. (7) The total number of hours the device was run in 2022. (8) The total number of non-emergency hours the device was run in 2022, including all hours used for testing, maintenance, and repairs. (9) The end of year hour meter reading from the device. (10) Date on which the reported meter reading was taken. Eng032.doc Revised Dec 2020 Permit Holder Name Contact Use this form to report data for all Standby and Backup Generators at all facilities for which you report usage data. Retain a copy for your records. (The first line in the table is an example.) Please refer to NOTES section at bottom of page for explanation of requested data for each column. ----- Include a copy of the operating log for calendar year 2022 as required by your Permit to Operate. ------ Jan 10, 2022 1 From:Heger, Viviana <vheger@meyersnave.com> Sent:Wednesday, September 27, 2023 2:31 PM To:Dietrick, Christine; Kersten, Markie; McDonald, Whitney; Schwartz, Luke; Stong, Nate Cc:Lindgren, Adam Subject:FW: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO – RISK MITIGATION PLAN COMMENTS Attachments:09-26-2023_SCP_covelop_RMP_letter_att1.pdf Flag Status:Flagged This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Dear All: According to the attached, the Water Board would like to delay the October 2, 2023 meeting and has numerous comments on the Risk Mitigation Plan (“RMP”) that Covelop submitted in late August. Twice the Water Board commented that Roux must explain why polyfluoroalkyl substances (“PFAS”) was not included in the RMP. Specifially, the Board has asked Covelop’s consultant, Roux, to explain why Section 2.3 of the RMP excludes PFAS as a chemicals of concern (“COC”) and why Section 5.0 does not address testing for PFAS in groundwater and determining how any impacted groundwater should be handled. In an e- mail today, Bryan Hulburd has asked that I speak with David Dixon of Roux, Inc., which I can do later this week. 2 From: Hernandez, Christine@Waterboards <Christine.Hernandez@Waterboards.ca.gov> Sent: Tuesday, September 26, 2023 9:37 AM To: Bryan Hulburd <bhulburd@covelop.net> Cc: LSchwart@slocity.org; djohnson@slocity.org; wmcdonal@slocity.org; afloyd@slocity.org; nstrong@slocity.org; mkersten@slocity.org; cdietric@slocity.org; Heger, Viviana <vheger@meyersnave.com>; Lindgren, Adam <adam@meyersnave.com>; dmavis@covelop.net; parnold@covelop.net; dixon@rouxinc.com; owenranta@chevron.com; kim.tulledge@chevron.com; jenniferforinger@chevron.com; Robert Goodman <rgoodman@rjo.com>; Froelich, Sophie@Waterboards <Sophie.Froelich@Waterboards.ca.gov>; Lodge, Ryan@Waterboards <Ryan.Lodge@water boards.ca.gov>; Tryon, Thea@Waterboards <Thea.Tryon@waterboards.ca.gov>; Schroeter, Angela@Waterboards <Angela.Schroeter@waterboards.ca.gov>; Bishop, Greg@Waterboards <Greg.Bishop@waterboards.ca.gov>; Soderberg, Sheila@Waterboards <Sheila.Soderberg@waterboards.ca.gov>; Niles, Dan@Waterboards <Dan.Niles@waterboards.ca.gov> Subject: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO – RISK MITIGATION PLAN COMMENTS [EXTERNAL E-MAIL] SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONTRUCTION, SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – RISK MITIGATION PLAN COMMENTS The Central Coast Regional Water Quality Control Board is increasing its efforts to transmit correspondence and other information electronically, reducing the amount of paper used, and increasing the speed of which information is distributed. Therefore, you are receiving the attached correspondence for the subject site from the Central Coast Water Board in a Portable Data Format (PDF) format. If you need help opening this document, please refer to the link below; http://www.adobe.com/products/acrobat/readstep2.html Central Coast Regional Water Quality Control Board September 26, 2023 Bryan Hulburd Sent via Electronic Mail Covelop, Inc. 1304 Garden Street San Luis Obispo, CA 93401 Email: bhulburd@covelop.net Dear Bryan Hulburd: SITE CLEANUP PROGRAM: TANK FARM & SANTA FE ROADS ROUNDABOUT CONSTRUCTION, SAN LUIS OBISPO, SAN LUIS OBISPO COUNTY – RISK MITIGATION PLAN COMMENTS The Central Coast Regional Water Quality Control Board (Central Coast Water Board) reviewed Roux Associates, Inc.’s (Roux) Risk Mitigation Plan (RMP) for the Tank Farm and Santa Fe Roads Roundabout Construction Project (Site) dated August 23, 2023 1 (Work Plan Addendum), submitted on behalf of Covelop, Inc. The RMP provides a general description of how Site soils and groundwater will be managed during the roundabout construction. Covelop, Roux, and Central Coast Water Board staff had two working group meetings on March 29, 2023, and May 22, 2023, to assist in the RMP development process and discuss preliminary comments. The RMP did not address many of the comments discussed. Attachment 1 includes a list of general and specific comments that must be addressed in the RMP. Please submit a revised RMP that addresses these comments to the Central Coast Water Board by December 1, 2023. Additionally, Central Coast Water Board staff recommend rescheduling the meeting planned for October 2, 2023, to allow Covelop, Inc sufficient time to review the comments in detail and submit a revised RMP by December 1, 2023. Pending receipt and review of a revised RMP, Central Coast Water Board staff will coordinate with the group to schedule a meeting to discuss next steps. We look forward to working with Covelop, Roux, the City of San Luis Obispo, and County of San Luis Obispo on the Tank Farm and Santa Fe Roads Roundabout Construction Project. If you have any questions regarding this letter, please contact Dan Niles at (805) 549- 3355 (dan.niles@waterbaords.ca.gov) or Sheila Soderberg at (805) 549-3592 (sheila.soderberg@waterboards.ca.gov). 1Link to RMP: https://geotracker.waterboards.ca.gov/?surl=bnyin Bryan Hulburd - 2 - September 26, 2023 Sincerely, for Matthew T. Keeling Executive Officer Attachment 1 – Central Coast Water Board Comments on Risk Mitigation Plan cc: Luke Schwartz, City of San Luis Obispo, LSchwart@slocity.org Derek Johnson, City of San Luis Obispo, djohnson@slocity.org Whitney McDonald, City of San Luis Obispo, wmcdonal@slocity.org Aaron Floyd, City of San Luis Obispo, afloyd@slocity.org Nate Strong, City of San Luis Obispo, nstong@slocity.org Markie Kersten, City of San Luis Obispo, mkersten@slocity.org Christine Dietric, City of San Luis Obispo, cdietric@slocity.org Viviana Heger, Meyers Nave, vheger@meyersnave.com Adam Lindgren, Meyers Nave, adam@meyersnave.com Mavis Damien, Covelop, dmavis@covelop.net Pat Arnold, Covelop, parnold@covelop.net David Dixon, Roux, dixon@rouxinc.com Owen Ranta, Chevron, owenr anta@chevron.com Kim Tulledge, Chevron, Kim.Tulledge@chevron.com Jennifer Forringer, Chevron, jenniferforinger@chevron.com Bob Goodman, Chevron, rgoodman@rjo.com Sophie Froelich, Office of Chief Counsel, Sophie.Froelich@Waterboards.ca.gov Ryan Lodge, Central Coast Water Board, ryan.lodge@waterboards.ca.gov Thea Tryon, Central Coast Water Board, thea.tryon@waterboards.ca.gov Angela Schroeter, Central Coast Water Board, angela.schroeter@waterboards.ca.gov Greg Bishop, Central Coast Water Board, greg.bishop@waterboards.ca.gov Sheila Soderberg, Central Coast Water Board, sheila.soderberg@waterboards.ca.gov Dan Niles, Central Coast Water Board, dan.niles@waterboards.ca.gov BizFlow [M30000]; SCP-Reg 3 Site Specific and DARTS: [Covelop, Inc. Roundabout]; Site Cost Recovery ID: [2030187]; and GeoTracker ID [T100000020989]. File path: \\ca.epa.local\rb\rb3\shared\scp\sites\slo co\san luis obispo\276 tank farm road - covelop slo tank farm\roundabout project\09-25-2023_scp_covelop_rmp.docx Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 1 The Central Coast Regional Water Quality Control Board (Central Coast Water Board) reviewed the document titled “Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction, San Luis Obispo, California” (RMP) dated August 23, 2023, and submitted by Roux Associates, Inc. on behalf of Covelop, Inc. (Covelop). The RMP is for a proposed roundabout road improvement project located within and adjacent to several former and active Site Cleanup Program sites, including the San Luis Obispo Tank Farm, Union Pacific Railroad Tie Fire, and San Luis Obispo Regional Airport. Due to the project’s proximity to these investigation and cleanup sites1, and the potential for other unknown pollution sources, the Central Coast Water Board requested Covelop develop a plan for managing potential soil and groundwater pollution that may be encountered during grading and excavation activities for the project. The Central Coast Water Board is providing the following general and specific comments and requires the RMP to be revised to address the comments provided below and submitted by December 1, 2023. General Comments The RMP must be signed by a California licensed professional engineer or geologist, experienced in oversight of projects with the potential for encountering soil, sediment, and groundwater pollution. The RMP should include a clear, detailed description of project management for environmental oversight, including the following standard elements: • Identify the environmental oversight contractor(s). • List the primary environmental oversight contacts and contact information. • Describe the level of environmental oversight planned for the entire project starting with initial surveying prior to earth movement , earth movement, groundwater encroachment, staging area, etc. • Provide the lines communication, timing of reporting, and notification procedures. • Identify who is responsible for stop-work orders in the event of encountering unexpected and/or significant risks. • Describe procedures for securing the construction area in the event contingency measures are triggered. • Identify who is/are responsible for project area security. • Provide the project schedule for the proposed scope of work. 1Contaminants of concern include total petroleum hydrocarbons, polycyclic aromatic hydrocarbons, arsenic, lead, benzene, toluene, ethylbenzene, total xylenes, and per - and polyfluoroalkyl substances for proximal Site Cleanup Program sites. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 2 Specific Comments Introduction, first paragraph: • Include that the intent of the RMP, in addition to soil, is for the management of potential occurrences of groundwater. • State that in addition to managing human health and safety risks, the RMP includes ecological screening levels to protect ecological receptors. The basis for this comment is explained further below in comments to Section 2.3. Introduction, second paragraph: • Provide a plan for characterizing the native and imported soil for the proposed stormwater basin. • Include a section describing processes and procedures for documenting the characteristics and acceptance criteria for the proposed use of imported soil to create the noted berms. This is particularly important for direct contact of stormwater within proposed stormwater basin, and protection of ecological receptors. • Describe the origin of the imported fill and the expected volume. • Describing the physical criteria of the imported fill (i.e., no metal, glass, expansive soils, concrete, etc.). See Padre's 2018 Soil Segregation & Stockpiling Plan as an example of the type of information that should be included in the RMP. • Procedures for profiling verification and documentation that imported soil meets ecological risk screening levels are needed. This includes profiling for direct soil contact and soil contacting stormwater. Introduction: Project location, numbers 1 to 4: • Provide a figure clearly illustrating the location of the project area in relation to the five parcels the project encompasses. The current map lacks clarity for understanding the spatial aspects of the project , the involved parcels, and who owns the involved parcels. Introduction, third paragraph: • Provide clearly illustrated cut and fill figures in plan view and in cross-sections. • Provide a soil characterization and use plan inclusive of applicable comparative ecological risk screening levels for the proposed reuse of project excavated soil as backfill. This is applicable to soil proposed for use in areas that may have direct contact exposure to ecological receptors, such as burrowing animals. This is needed for ecological protection purposes. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 3 Introduction, fourth paragraph, first sentence: • Provide clarification differentiating the risk drivers and corresponding approved remedial plan applicable to the post-remedy land uses for the Tank Farm property versus the roundabout project. Central Coast Water Board staff recommends using the standardized San Francisco Bay Regional Water Quality Control Board’s (SF Bay Water Board) Environmental Screening Levels (ESLs)2, rather than utilizing site-specific risk-based screening levels (RBSLs) derived for the unique conditions on the Tank Farm property. • Provide a basis for exclusively using Tank Farm Site health and safety risk criteria while not considering potential unidentified risks that may be associated with prior property uses not on Tank Farm property. Note, some of the risk-based screening levels were based on recreational users, age-dependent adjustment factors applied only to mutagens, which may not be applicable for the proposed project. • Provide Phase I and Phase II investigation data, if available, that supports the assertion of no known contamination for APN 053-421-006 and existing roadway property. If no Phase I and Phase II type data are available, provide a description of the decision basis for why such data were not collected as part of the project screening analysis for determining potential risk factors. Explain why the assumptions for soil are different than the stated assumptions for groundwater. Describe prior land uses, utilities, water supply, water supply wells, and wastewater disposal systems, such as septic systems, etc. • Recommend pre-characterization of anticipated wastes in the project area to assist with waste management or re-use (i.e., determine if most excavated soil can be used as fill material or if excavated soils will need to be disposed of at the landfill). Section 2.1, first paragraph: • See above request for a figure clearly illustrating the project footprint and involved parcels. Section 2.2, last paragraph: • See above request for plan view and cross-section cut and fill plans. Please provide these plans as part of a revised RMP and at least 2 months in advance of commencing proposed grubbing and grading activities. 2 More information about SF Bay Water Board’s ESLs: https://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/esl.html Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 4 Section 2.3, paragraph five: • Copies of figures are presented in Appendix B. Please superimpose the location of the roundabout project on the f igures to show what contaminants of concern (COCs) may be encountered during construction. Section 2.3, paragraph preceding the bulleted list: • Clarify how the use of RBSLs apply to the project in contrast with those identified for the Tank Farm Site that are applicable to post-remedy land uses for that site. As stated above, consider using SF Bay Water Board’s ESLs for comparison purposes. • Explain the decision basis for excluding screening for other potential project- specific COC, such as per- and polyfluoroalkyl substances, organochlorine pesticides, polychlorinated biphenyls, and comprehensive heavy metals screening in addition to the noted arsenic and lead and relate those to potential project-specific ecological receptors based on direct routes of exposure. Section 2.4, Table 1: • Explain why ecological screening levels are deemed “Not applicable” to the project. Development of project-specific COC and corresponding screening levels is recommended. Section 3, first paragraph: • See General Comments above and provide a detailed flowchart for project oversight, level of oversight throughout the project , communications between the different contracting representatives, personnel responsibilities, contact information, etc. • Correct the cited “ELAP” acronym to indicate it references the California Environmental ‘Laboratory’ Accreditation Program. • Provide further screening criteria such as incidental observations of odors (as referenced in Section 6, but include here in Section 3) and clarify, more specifically visual cues specific to identifying discoloration/staining as differentiated from what is expected for characteristics of native soil. Provide consistency throughout the RMP for use and actionable responses to qualitative indicators of potential impacts to soil and groundwater. • Describe the potential for identification of non-native fill material unrelated to engineered road-base. For the latter, provide a rationale regarding potential screening specific to possible end-uses and corresponding routes of exposure and risk. Section 3.1, third paragraph: • Citation is only identified for Occupational Safety and Health Administration (OSHA) lead in construction. Note, other OSHA standards apply for arsenic (i.e., Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 5 10 micrograms per cubic meter of air averaged over any 8-hour period) and asbestos (0.1 fiber/milliliter of air over an 8-hour period) which are wastes potentially found in the project area. Section 3.2, first paragraph: • See General Comments above and provide a detailed flowchart for project oversight, communications, personnel responsibilities, contact information, etc. Clarification is required for proposed environmental oversight activities and principal responsibilities assigned thereto in relation to communications with agencies, contractors, and subcontractors. Section 3.2, second paragraph, reference to Table 1: • See above comments to Section 2.3. Provide project-specific application of ecological risk-based screening levels for potential routes of direct exposure. Justification for project-specific COC is needed. Section 3.2, reference to flowchart Figure 3: • Modify flowchart for project-specific end land use and configuration related to potential ecological receptors. Section 3.2, open sub-bullet two: • Clarify reference to the noted “section 5.3” regarding composite sampling details, which were not included in the RMP. Section 3.4, second paragraph: • Describe containment of removed and potentially impacted soil cleaned from construction and hauling vehicles and equipment. Clarify if water use is part of the cleaning process and if “yes,” describe the potential volumes that may require containment, and provide a description of the procedures for profiling the impacted materials for proper handling and disposal. Section 3.6: • See above comments to Section 3.4. • Provide more information about vehicle and equipment decontamination . • Identify the decontamination area on the site map. Will there be rumble strips for vehicles leaving the construction site? If so, please specify how construction materials will be contained onsite. Section 4, first paragraph: • See comments requiring clarification of project environmental oversight. Section 4.2: • Clarify reference to the cited section 5.3.; there’s currently no section 5.3. in the RMP. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 6 • Include analyses for per- and polyfluoroalkyl substances, organochlorine pesticides, and polychlorinated biphenyls. Section 4.2: • Include sampling and analyses for per- and polyfluoroalkyl substances consistent with prior oral communications and direction from Central Coast Water Board staff. Section 4.3: • See prior comments regarding use of RBSLs as a criterion governing soil reuses related to ecological risk receptors. RBSLs cited in the RMP are applicable to the Tank Farm Site but differ for the roundabout project. This is due to the differences in proposed soil reuses. RBSLs for the Tank Farm Site are intended for waste left in-place and not available for direct routes of exposure, i.e., capped and contained, and intended for corresponding land uses identified in the approved remedial action plan. Differentiate in the RMP the difference in end use and configuration between the Tank Farm Site and proposed roundabout project relative to the potential for direct routes of exposure for ecological receptors based on comparative ecological screening levels. • An analysis for acceptance criteria is missing from the list: Add Corrosivity by USEPA 9040 and Fish Bioassay (96-hour acute aquatic toxicity). Section 5: • Specify characterization and profiling for collected groundwater, including sampling and analyses for per- and polyfluoroalkyl substances consistent with prior communications and direction from Central Coast Water Board staff. • Provide references to qualitative indicators for identifying potential impacted groundwater, i.e., types of indicators such as sheening, odor, photoionization detector (PID) screening of ambient air in and around trenches, etc . • Develop reporting procedures for groundwater characterization and specify Central Coast Water Board approval is required prior to any onsite discharges for non-impacted groundwater. • Describe the procedures for documenting approval to discharge to the sanitary sewer system. • Note that direct discharge to a storm drainage system of impacted groundwater, or treated impacted groundwater, requires enrollment in and compliance with the Central Coast Water Bo ard’s “Order No. R3-2022-0035 NPDES No. CAG99304 Waste Discharge Requirements National Pollutant Discharge Elimination System General Permit for Discharges with Limited Treat to Water Quality.”3 3 https://www.waterboards.ca.gov/centralcoast/board_decisions/adopted_orders/#go_npdes_statewide Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 7 Section 6: • See comments requiring clarification of project environmental oversight. • Include both soil and/or groundwater impacts for contingency planning as both may be co-located and not solely mutually exclusive upon encountering. Section 6.1, first paragraph: • Change the text to indicate that contingency measures will be implemented as a project requirement, as opposed to indicating that contingency measures “’should’ be implemented,” which implies that the contingency measures are subject to discretionary determinations for whether they’ll be followed. Section 6.1, second bullet: • As noted above, provide clarification of lines of communication, and timing thereof based on clear metrics (i.e., what conditions and qualitative and quantitative metrics constitute a determination that encountered conditions present a “material threat to human health and the environment”) with contact information for all environmental oversight work. A flowchart is recommended. Section 6.1, sentence after third bullet: • Provide a decision matrix, or detailed description, with specific indicators for triggering determinations to provide notifications and obtain permits with corresponding contacts and anticipated permits needed. Section 6.1, last paragraph: • Provide a contact matrix inclusive of local agencies to be notified in the event of underground storage tanks (USTs) or pipelines are found (e.g., local tank removal oversight agencies are the City Fire Department and/or San Luis Obispo County Environmental Health depending on the location of the infrastructure). • Include a plan for testing and cleanup of stockpile areas for impacted soil and/or groundwater to ensure all potential residual contamination is removed and areas cleaned up. • Provide a soil testing plan that complies with local agency(ies) requirements for removal and dispensation of USTs and associated infrastructure. Also, provide a citation for, or include, as appropriate, in deference to local agency requirements, the noted “RWQCB guidelines” for UST removals for ease of reference for the environmental oversight representative and contractors. • Provide a description of the process and procedures for delineating the extent of impacted material and confirmation criteria for determining removal has occurred, e.g., analyses to be performed, expected laboratory reporting periods for informing necessary iterative field removal activities, etc. Attachment 1 – Central Coast Water Board Comments on the Risk Mitigation Plan - Tank Farm & Santa Fe Roads Roundabout Construction Project, San Luis Obispo September 26, 2023 8 Figure 1: • Revise Figure 1 to specify the correct roundabout project location. Potential incorrect reference to roundabout project north of the Tank Farm property on Prado Road. Appendices: • Exhibit A-1 - suggest adding the proposed location of the roundabout on the county parcel map. • Appendix B – suggest adding the proposed roundabo ut location on historical maps. • Add Appendix C – overall project schedule. If you have any questions regarding these comments, please contact Dan Niles at (805) 549-3355 (dan.niles@waterbaords.ca.gov) or Sheila Soderberg at (805) 549- 3592 (sheila.soderberg@waterboards.ca.gov). 1 From:Accounts Payable <ap@slocity.org> Sent:Thursday, September 7, 2023 1:50 PM To:eids.fin.invoices@workflow.mail.us6.oraclecloud.com Subject:FW: San Luis Obispo County APCD Invoice# 23165 PO# 617444 Attachments:PO 617444 Receipt 66521 $491.97 JR.pdf Timothy Holt Accounting Assistant Finance 990 Palm Street, San Luis Obispo, CA 93401-3668 E tholt@slocity.org T 805.781.7448 slocity.org Stay connected with the City by signing up for e-notifications From: Rucker, Jarrett <jrucker@slocity.org> Sent: Wednesday, September 6, 2023 2:00 PM To: Accounts Payable <ap@slocity.org> Subject: San Luis Obispo County APCD Invoice# 23165 PO# 617444 Jarrett Rucker WWC System Operator Public Utilities 25 Prado, San Luis Obispo, CA 93401-7314 E jrucker@slocity.org slocity.org Stay connected with the City by signing up for e-notifications T 805.781.5912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401 INVOICE 23165 TO: City of San Luis Obispo DATE: 8/31/23 25 Prado Road San Luis Obispo, CA 93401 Payment due in 30 days ATTN: Ryan Beech Account: 4326 NOTE: Fees not paid by the due date are subject to a 50% penalty fee along with any applicable late payment processing fees. Action Date App # A/R # Description Amount 08/24/23 7187 50444 Renewal of Equipment Under Permit # 1630-2 Operating Fee to August 2024: Any emergency standby engine $491.97 Equipment Location: City of San Luis Obispo WWTP Lift Station, 276 Tank Farm Road, San Luis Obispo TOTAL DUE $491.97 Please note – Fees included in this invoice reflect new rates for the 2023-2024 fiscal year, effective July 1, 2023. If you have questions, please refer to our Rule 302 Fee Rate Table located on our website at: https://www.slocleanair.org/rules-regulations/apcd-rules--regulations.php under Regulation III – Fees, or call us at 805-781-5912. The APCD accepts online payments for all issued invoices. To process an online payment, please visit https://paydirect.link2gov.com/SLOAPCDWEB. Please note, all online payments must pay the full invoiced amount. In addition, a service fee of 2.35% will be added for using the online payment service. If paying by check, please make check payable to San Luis Obispo County Air Pollution Control District. To ensure proper credit please reference invoice number on check. PO 617444 Receipt 66521 $491.97 JR 1 From:Christina Clifton <christina@mitchtsailaw.com> Sent:Tuesday, May 14, 2024 9:59 AM To:Cohen, Rachel Cc:Mitchell M. Tsai Attorney at Law, P.C. Subject:Re: WSRCC - [City of San Luis Obispo, 276 Tank Farm Road] - Project Status Inquiry Hi Rachel, Understood, thank you very much for this update! Have a lovely day. Best, Christina On Tue, May 14, 2024 at 9:36 AM Cohen, Rachel <rcohen@slocity.org> wrote: Hello Christina- There are no updates on this project and is in the same status as February. Sincerely, Rachel Cohen pronouns she/her/hers Senior Planner Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E rcohen@slocity.org T 805.781.7574 slocity.org Stay connected with the City by signing up for e-notifications From: Christina Clifton <christina@mitchtsailaw.com> Sent: Tuesday, May 14, 2024 9:30 AM To: Cohen, Rachel <rcohen@slocity.org> Cc: Mitchell M. Tsai Attorney at Law, P.C. <info@mitchtsailaw.com> Subject: Re: WSRCC - [City of San Luis Obispo, 276 Tank Farm Road] - Project Status Inquiry 2 Good afternoon, I'm checking back in to see if there have been any updates for this project? Can you confirm if a completed application has been received? If so, can you confirm if any public hearings have been scheduled? We would greatly appreciate any updates you can provide. Best, Christina On Mon, Feb 5, 2024 at 2:43 PM Christina Clifton <christina@mitchtsailaw.com> wrote: Hi Rachel, Thank you very much for this update. We appreciate your time and attention. Best, Christina On Mon, Feb 5, 2024 at 2:19 PM Cohen, Rachel <rcohen@slocity.org> wrote: Hello Christina- The project is still on hold and is still incomplete. We do not have any updates on when the applicant is planning to resubmit. 3 Sincerely, Rachel Cohen pronouns she/her/hers Senior Planner Community Development 919 Palm Street, San Luis Obispo, CA 93401-3218 E rcohen@slocity.org T 805.781.7574 slocity.org Stay connected with the City by signing up for e-notifications From: Christina Clifton <christina@mitchtsailaw.com> Sent: Monday, February 5, 2024 2:13 PM To: Cohen, Rachel <rcohen@slocity.org> Cc: Mitchell M. Tsai Attorney at Law, P.C. <info@mitchtsailaw.com>; Reza Bonachea Mohamadzadeh <reza@mitchtsailaw.com> Subject: WSRCC - [City of San Luis Obispo, 276 Tank Farm Road] - Project Status Inquiry This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Good Afternoon, Our office would like to inquire about The Link (276 Tank Farm) Project. You last advised that the project was on hold pending a completed application. Can you confirm if a completed application has been received? If so, can you confirm if any public hearings have been scheduled? We would greatly appreciate any updates you can provide. 4 Best, Christina -- Christina Clifton, Paralegal Mitchell M. Tsai Law Firm - Environmental & Land Use Litigation 139 South Hudson Avenue Suite 200 Pasadena, CA 91101 Phone: (626) 314-3821 Fax: (626) 389-5414 Email: christina@mitchtsailaw.com Website: https://www.mitchtsailaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at christina@mitchtsailaw.com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you. -- Christina Clifton, Paralegal Mitchell M. Tsai Law Firm - Environmental & Land Use Litigation 139 South Hudson Avenue Suite 200 Pasadena, CA 91101 Phone: (626) 314-3821 5 Fax: (626) 389-5414 Email: christina@mitchtsailaw.com Website: https://www.mitchtsailaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at christina@mitchtsailaw.com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you. -- Christina Clifton, Paralegal Mitchell M. Tsai Law Firm - Environmental & Land Use Litigation 139 South Hudson Avenue Suite 200 Pasadena, CA 91101 Phone: (626) 314-3821 Fax: (626) 389-5414 Email: christina@mitchtsailaw.com Website: https://www.mitchtsailaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at 6 christina@mitchtsailaw.com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you. -- Christina Clifton, Paralegal Mitchell M. Tsai Law Firm - Environmental & Land Use Litigation 139 South Hudson Avenue Suite 200 Pasadena, CA 91101 Phone: (626) 314-3821 Fax: (626) 389-5414 Email: christina@mitchtsailaw.com Website: https://www.mitchtsailaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at christina@mitchtsailaw.com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you. 1 Subject:Submit APCD Log Start: Recurrence:(none) Organizer:Beech, Ryan Hello John, I need the Tank Farm generator logs ready to submit by 2/14/2023. Thank you, -Ryan ________________________________________________________________________________ Microsoft Teams meeting Join on your computer, mobile app or room device Click here to join the meeting Learn More | Meeting options ________________________________________________________________________________ Facility Contact Information – Please review If contact corrections are required, record them below and submit this page with your ENG001 Data Certification form. Facility, Inspection, Emissions Inventory, and Accounting contacts will be assumed to be the Owner unless otherwise noted. Please provide mail address, phone number (w-work, c-cell, f-fax), and email address for each contact type. Facility # and Name: On File Corrections to be made Owner Facility Contact Inspection Contact Emissions Inventory Contact (EI) Accounting Contact I, (Clearly Print Name), certify that the contact information provided above is complete and accurate to the best of my knowledge. Signature: Date: 3433 Roberto Court San Luis Obispo CA 93401 (805) 781-5912 FAX: (805) 781-1002 www.slocleanair.org DATA CERTIFICATION FORM For Inventory Year – 2022 Page 2 – Contact Corrections T 805.781.5912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401 Please review and correct, if necessary, all fields on both enclosed forms and retain a copy for your records. Print your name and sign the forms in the spaces provided at the bottom. Submit completed forms by the due date stated in the cover letter to avoid possible penalties. Completed forms may be mailed, faxed to (805) 781-1002, or scanned and emailed to ei@slocleanair.org. Call (805) 781-5912 if you have any questions. A. Emission Inventory Data (Please provide contact corrections on page 2.) Facility ID (see cover letter) Site ID Facility Name Equipment Address* Emissions Inventory Contact (Name, Mailing Address, Phone, and e-mail) Required Forms Download forms from: slocleanair.org, Downloadable Forms *Note: Ensure the Equipment Address is the location where the equipment or process is located. B. Facility contact information on page 2 has been reviewed and corrected, as needed. Yes No C. Is trade secret data included? (If yes, attach explanation.) Yes No D. Are there any NEW air emission sources? (If yes, describe in Remarks box below.) Yes No E. Are there any emission sources no longer in service? (If yes, write permit number in Remarks box below.) Yes No F. Are the required forms submitted or enclosed? Yes No Remarks: Under California Health and Safety Code sections 40701 and 42303 the District has the right to request data needed to estimate pollutant emissions. Consequently, you are obligated to provide all requested data by the due date. This data is also requested under the authority of the Air Toxics Hot Spots program. The data may be used to determine perm it renewal fees. Failure to provide complete data by the due date may result in fines or penalties. I, (Clearly Print Name), certify that the data provided above and in all attachments is complete and accurate to the best of my knowledge. Signature: Date: DATA CERTIFICATION FORM For Inventory Year - 2022 Equipment Identification Annual Fuel Consumption (Required) Annual Hours Used (Required) APCD Permit No. APCD Facility ID Device Description (1) (as described on your Permit to Operate) Equipment Rating (hp) (2) Fuel Type (3,4) Amount Units (5) Method (6) Total Hours (7) Non- emergency Hours (8) Meter Reading (9) Date of Meter Reading (10) 1234 1234 Example: 99KW Cummins Model ABC789 170 hp Diesel 20 Gal E 5 4 18.7 EMISSIONS INVENTORY INFORMATION For Inventory Year – 2022 FORM 32: STAND-BY/BACKUP GENERATORS NOTES (1) Refer to the equipment description on your permit. (2) For internal combustion engines, specify horsepower (hp). Include units of measure. (3) Examples: natural gas, propane gas, diesel fuel, fuel oil. If fuel oil is burned, specify grade (example: fuel oil No. 2). (4) If a device burns more than one fuel, use a separate line for each fuel. (5) Examples of acceptable units of measure (therms, mcf, mmcf, gal, mgal, bbl, or mbbl). Be sure that your units of measure are correct. (6) How annual fuel use was determined. Use the following codes: M = measured or metered, E = Estimated based on fuel purchases/deliveries, H = Estimated based on hours run, O = Other. If the method is Other (O), please briefly describe in the remarks column of Form 1. (7) The total number of hours the device was run in 2022. (8) The total number of non-emergency hours the device was run in 2022, including all hours used for testing, maintenance, and repairs. (9) The end of year hour meter reading from the device. (10) Date on which the reported meter reading was taken. Eng032.doc Revised Dec 2020 Permit Holder Name Contact Use this form to report data for all Standby and Backup Generators at all facilities for which you report usage data. Retain a copy for your records. (The first line in the table is an example.) Please refer to NOTES section at bottom of page for explanation of requested data for each column. ----- Include a copy of the operating log for calendar year 2022 as required by your Permit to Operate. ------ Jan 10, 2022 1 From:SLO APCD <APCD_slocleanair@co.slo.ca.us> Sent:Thursday, February 2, 2023 3:29 PM To:Beech, Ryan Subject:APCD Emissions Inventory Request for 2022 (2665) Attachments:2665_San_Luis_Obisp_ENG001.pdf; 2665_San_Luis_Obisp_Contacts_ENG001.pdf; 2665 _San_Luis_Obisp_ENG032StandByBackupGenerators.pdf Flag Status:Flagged This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Facility Name: San Luis Obispo City - Tank Farm Lift Station Facility ID #: 2665 Forms Required: 1, 32 The Air Pollution Control District is required to achieve and maintain state ambient air quality standards. As part of our effort to comply, the District has developed a plan to monitor and reduce air pollutant emissions. To track our progress toward achieving the goals of our plan, the District must survey our permitted facilities to verify the emission sources, location, types, and amounts of air emissions. Please download the attached file: 2665_San_Luis_Obisp_ENG001.pdf. This file is a fillable PDF file that contains the required ENG001 Data Certification form. Please review the ENG001 form and return it to us - re- typing your name in the signature field is valid as a signature. Also attached, is 2665_San_Luis_Obisp_Contacts_ENG001.pdf that contains a copy of the contact information we have on file for your facility. Please return this form to us if there are corrections to be made to your contact information. Some forms have been revised for 2022 reporting. Please download and complete the forms indicated above for 2022 data, specific to the equipment you operate, from our website located at slocleanair.org/library/download-forms.php. Forms are organized online by form number. Please be sure to provide all requested information for calendar year 2022 activities. Please note - the Facility ID # referenced above will need to be entered on all forms and supplemental information you submit. Use the attached Form 32 (2665_San_Luis_Obisp_ENG032StandByBackupGenerators.pdf ) to report data for all Standby and Backup Generators at all facilities for which you report usage data. For your convenience, the form has been pre-filled with data held on file at the District. Please verify the information is correct and complete. Include corrected or omitted information on the form, along with the required operating information for 2022. Retain a copy for your records. If you have suggestions to improve these forms, please indicate in your submittal where improvements can be made. The District welcomes your input. 2 After completing the required forms, please fax, mail, or email them to the District office by March 1, 2023. Forms may be faxed to (805) 781-1002 or emailed to ei@slocleanair.org. If you have any questions or need assistance obtaining or submitting the required forms, please contact our office at (805) 781-5912. Sincerely, Dora Drexler Manager, Engineering & Compliance Division Facility ID # 2665 Facility Name: San Luis Obispo City - Tank Farm Lift Station Forms Required: 1, 32 (Form 1 should be attached) Download Forms (see Emissions Inventory section) 1 From:SLO APCD <APCD_slocleanair@co.slo.ca.us> Sent:Tuesday, September 19, 2023 11:39 AM To:Beech, Ryan Subject:APCD Renewal Notice Attachments:20585bc.pdf This message is from an External Source. Use cau Ɵon when deciding to open aƩachments, click links, or respond. ________________________________ GreeƟngs! Please aƩach this renewal noƟce to your Permit to Operate/CondiƟonal Permit ExempƟon/AG Engine RegistraƟon. How did we do? Your feedback is important to us! Please take a few minutes to complete a short customer sa ƟsfacƟon survey. To complete the survey, please click on the following link: hƩps://www.surveymonkey.com/r/APCDcompliancesurvey Thank you, San Luis Obispo County Air PolluƟon Control District ------------- 9/19/2023 11:38:29 AM TO: The Air Pollution Control District has received payment of your permit renewal fees. Attached below is your permit renewal. Please detach the bottom portion of this page and affix to your Permit to Operate. ----------------------------------------------------------------------------------------------------------------------------- PERMIT RENEWAL DATE: Permit Number: A permit renewal inspection was recently conducted at your facility and it has been determined from the inspection that the subject equipment is operated in compliance with the rules and regulations of the Air Pollution Control District. This is a renewal of the permit operating license until Please also consider this a receipt for your fees in the amount of Equipment Location: San Luis Obispo County Air Pollution Control District Please affix this note to your Permit to Operate. September 19, 2023 1630-2 August 2024. $491.97. City of San Luis Obispo WWTP Lift Station, 276 Tank Farm Road, San Luis Obispo CHRIS LEHMAN CITY OF SAN LUIS OBISPO 879 MORRO STREET SAN LUIS OBISPO CA 93401 1 From:Lehman, Chris Sent:Tuesday, September 19, 2023 1:44 PM To:Beech, Ryan Subject:Fwd: APCD Renewal Notice Attachments:20585bc.pdf Get Outlook for iOS From: SLO APCD <APCD_slocleanair@co.slo.ca.us> Sent: Tuesday, September 19, 2023 11:38:30 AM To: Lehman, Chris <clehman@slocity.org> Subject: APCD Renewal Notice This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. ________________________________ Greetings! Please attach this renewal notice to your Permit to Operate/Conditional Permit Exemption/AG Engine Registration. How did we do? Your feedback is important to us! Please take a few minutes to complete a short customer satisfaction survey. To complete the survey, please click on the following link: https://www.surveymonkey.com/r/APCDcompliancesurvey Thank you, San Luis Obispo County Air Pollution Control District ------------- 9/19/2023 11:38:29 AM TO: The Air Pollution Control District has received payment of your permit renewal fees. Attached below is your permit renewal. Please detach the bottom portion of this page and affix to your Permit to Operate. ----------------------------------------------------------------------------------------------------------------------------- PERMIT RENEWAL DATE: Permit Number: A permit renewal inspection was recently conducted at your facility and it has been determined from the inspection that the subject equipment is operated in compliance with the rules and regulations of the Air Pollution Control District. This is a renewal of the permit operating license until Please also consider this a receipt for your fees in the amount of Equipment Location: San Luis Obispo County Air Pollution Control District Please affix this note to your Permit to Operate. September 19, 2023 1630-2 August 2024. $491.97. City of San Luis Obispo WWTP Lift Station, 276 Tank Farm Road, San Luis Obispo CHRIS LEHMAN CITY OF SAN LUIS OBISPO 879 MORRO STREET SAN LUIS OBISPO CA 93401 1 From:APCD_slocleanair@co.slo.ca.us Sent:Wednesday, August 30, 2023 10:21 AM To:Beech, Ryan Subject:APCD Renewal Invoice #23165 Due 10/1/2023 Attachments:23165.pdf This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hello, Attached is your Renewal Fee invoice. The original will be sent in the mail on 8/31/2023. Please note, the invoice will be available for payment online the next business day. The APCD accepts online payments for all issued invoices. To process an online payment, please visit https://paydirect.link2gov.com/SLOAPCDWEB. Please note, all online payments must pay the full invoiced amount. In addition, a service fee of 2.35% will be added for using the online payment service. If paying by check, please make check payable to San Luis Obispo County Air Pollution Control District. To ensure proper credit please reference invoice number on check. Please let me know if you have any questions or concerns. Thank You, San Luis Obispo County Air Pollution Control District 3433 Roberto Court, San Luis Obispo, CA 93401 Main: 805-781-5912 Fax: 805-781-1002 To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. https://www.slocleanair.org/ T 805.781.5912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401 INVOICE 23165 TO: City of San Luis Obispo DATE: 8/31/23 25 Prado Road San Luis Obispo, CA 93401 Payment due in 30 days ATTN: Ryan Beech Account: 4326 NOTE: Fees not paid by the due date are subject to a 50% penalty fee along with any applicable late payment processing fees. Action Date App # A/R # Description Amount 08/24/23 7187 50444 Renewal of Equipment Under Permit # 1630-2 Operating Fee to August 2024: Any emergency standby engine $491.97 Equipment Location: City of San Luis Obispo WWTP Lift Station, 276 Tank Farm Road, San Luis Obispo TOTAL DUE $491.97 Please note – Fees included in this invoice reflect new rates for the 2023-2024 fiscal year, effective July 1, 2023. If you have questions, please refer to our Rule 302 Fee Rate Table located on our website at: https://www.slocleanair.org/rules-regulations/apcd-rules--regulations.php under Regulation III – Fees, or call us at 805-781-5912. The APCD accepts online payments for all issued invoices. To process an online payment, please visit https://paydirect.link2gov.com/SLOAPCDWEB. Please note, all online payments must pay the full invoiced amount. In addition, a service fee of 2.35% will be added for using the online payment service. If paying by check, please make check payable to San Luis Obispo County Air Pollution Control District. To ensure proper credit please reference invoice number on check.