iv.f.2 surface water quality - department of city planning

City of Los Angeles USC Development Plan SCH. No. 2009011101 May 2010

Page IV.F-23 WORKING DRAFT - Not for Public Review

IV. Environmental Impact Analysis F.2 Surface Water Quality

1. Introduction

This section provides an analysis of potential surface water quality impacts associated with the proposed Project. Information for this analysis was provided by the Surface Water Quality Control Study, prepared by KPFF Consulting Engineers. This study is provided in Appendix H, of this Draft EIR.

2. Environmental Setting

a. Existing Conditions

(1) Hydrological Conditions

The Project site lies within the Los Angeles Basin as designated by the Regional Water Quality Control Board. The Los Angeles Basin (Basin) consists of the coastal areas of Los Angeles County, south of the divide of the San Gabriel Mountains and Santa Susana Mountains, plus a small part of the coastal portion of Ventura County, south of the divide of the Santa Monica Mountains.11 This Basin is drained by four watersheds: the Los Angeles River; the Rio Hondo River; Ballona Creek; and the San Gabriel River. Numerous tributaries discharge into these major drainages, most of which have intermittent flow. Except for a few rivers in the mountainous areas, most have been converted to flood control channels lined with concrete and stone rip-rap.

Specifically, the Project site is located within the Santa Monica Bay Watershed Management Area (WMA) of the Basin. The WMA includes several watersheds, with Malibu Creek and Ballona Creek being the two largest watersheds. The Project site is located at the downstream end of the highly urbanized Ballona Creek watershed, which drains stormwater runoff in a southwesterly direction to its outlet at Ballona Creek (located just south of Marina Del Rey). Ballona Creek ultimately drains into the Santa Monica Bay.

11 Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties, Regional Water Quality Control

Board – Los Angeles; accessed online on October 14, 2009 at http://www.swrcb.ca.gov/rwqcb4/water_issues/ programs/basin_plan/electronics_documents/bp1_introduction.pdf.

IV.F.2 Surface Water Quality



(a) Santa Monica Bay Watershed Management Area

According to the Santa Monica Bay Watershed Management Area Summary prepared by the Los Angeles Regional Water Quality Control Board, many of the beneficial uses of the WMA have been impaired or are threatened to be impaired due to pollutant loadings originating from human activities.12 Dischargers permitted under the County’s National Pollutant Discharge Elimination System (NPDES) Municipal Permit or individual permits for discharging to the Santa Monica Bay Water Management Area include the following:

193 NPDES discharges including: seven major NPDES permit discharges, three Publicly Owned Treatment Works (two with direct ocean discharge), one refinery, and three generating stations;

175 dischargers covered under general permits;

87 dischargers covered by an industrial storm water permit; and

401 dischargers covered by the construction storm water permit.

A majority of the 193 NPDES permitted dischargers are located in the Ballona Creek watershed. Moreover, a large number of the general industrial storm water permitted facilities drain to Ballona Creek as well.

(b) Ballona Creek

A majority of Ballona Creek is channelized and surrounded by highly developed residential and commercial areas. The list of 2006 303(d) impaired water bodies indicates cadmium, coliform bacteria, dissolved copper, cyanide, silver (sediment), toxicity, trash, and viruses as the major pollutants in Ballona Creek. At the mouth of Ballona Creek, bacterial levels frequently exceed the standard, which result in permanently posted warning signs on each side of the Creek. A study conducted by the US Army Corps of Engineers (USACE) in conjunction with the Los Angeles Basin Contaminated Sediment Task Force shows that both dry weather runoffs and storm runoffs in the Creek are toxic to marine organisms. The USACE is currently conducting a feasibility study of restoring natural streams and riparian habitats in the lower Ballona Creek.

12 Santa Monica Bay Watershed Management Plan Summary, Regional Water Quality Control Board – Los

Angeles, accessed online on October 14, 2009 at http://www.swrcb.ca.gov/rwqcb4/water_issues/ programs/regional_program/wmi/ws_santamonica.shtml.




Designated beneficial uses for Ballona Creek include municipal and domestic supply, limited water contact recreation, non-contact recreation, wildlife habitat, and warm freshwater habitat.

(c) Project Site

USC has been implementing Best Management Practices (BMPs) to address water quality within the Campus. Specifically, in compliance with NPDES Standard Urban Stormwater Management Program requirements (discussed later), BMPs have been incorporated on a case-by-case basis and as part of the requirements, the University has filed master covenant and agreements to maintain these BMPs. The following are examples of BMPs that have been implemented as part of four recent projects within the Campus:

Parkside Housing – Phase II: This Project, which was completed in 2006, provided structural BMPS that included CDS Stormwater Treatment Unit and catch basin filter inserts.13 In addition, a large detention pipe was installed to reduce the peak runoff from this site.

Downey Way Improvement Project: This Project, which was completed in December 2008, included installation of a new 24-inch storm drain retention facility along Downey Way and installation of catch basins along Downey and Watt Way. Structural BMPs for the Project included Contech Vortsentry and a dry well.14,15 Both BMPs were designed to treat storm water runoff from all storms up to and including the 85th percentile 24-hour storm event (the first ¾ inch of rainfall).

Watt Way Improvement Project: This Project is currently under construction and includes the installation of new catch basins along Watt Way and a portion of 37th Place, installation of 36-inch HDPE perforated pipe, and construction of an

13 A CDS Technologies Inc. storm water treatment unit model PMSU20_15 is effective for the removal of

petroleum-based hydrocarbons, silt and debris in storm water runoff. The unit is designed to accommodate up to and including the 85th percentile storm event (the first ¾ inch of rainfall) and utilizes a non-blocking, non-mechanical screening technique to remove pollutants from storm water flow. Filter pouches are included to remove additional design pollutants. The filters have been also selected to accommodate up to and including the 85th percentile storm event.

14 The Contech VortSentry Unit is a hydrodynamic separator with a small footprint which makes it an effective treatment option for projects where space is at a premium and efficiency is critical. The internal bypass ensures treatment chamber velocities remain low, which improves performance and eliminates the risk of resuspension. In addition to stand-alone applications, the VortSentry is an ideal pretreatment device. The system is housed inside a lightweight concrete manhole structure for easy installation and unobstructed maintenance access.

15 A dry well was also proposed for this project to allow for the infiltration of the first ¾ inch of rainfall. Dry wells consist of a vertical hole in the ground filled with an open graded aggregate fill, utilizing gravity to infiltrate stormwater into the ground.




infiltration trench. The BMPs are designed to treat storm water runoff from all storms up to and including the 85th percentile 24-hour storm event (the first ¾ inch of rainfall).

School of Cinema Arts Project: This Project, which is anticipated to be complete in summer 2010, would include catch basin filter inserts, sand filtration, and a retention system. The BMPs are designed to treat storm water runoff from all storms up to and including the 85th percentile 24-hour storm event (the first ¾ inch of rainfall).

Further details of these BMPs are provided in the Surface Water Quality Control Study in Appendix H of this Draft EIR.

(d) Pollutants of Concern

Pollutants of concern that have the potential to affect stormwater quality generally fall in one of the following seven categories: sediments, nutrients, bacteria/viruses, oil/grease, metals, organics, and pesticides. These pollutants of concern are described below:

Sediment is a common component of stormwater, and can be a pollutant. Sediment can be detrimental to aquatic life (primary producers, benthic invertebrates, and fish) by interfering with photosynthesis, respiration, growth, reproduction, and oxygen exchange in water bodies. Sediment can transport other pollutants that are attached to it including nutrients, trace metals, and hydrocarbons. Sediment is the primary component of total suspended solids, a common water quality analytical parameter.

Nutrients including nitrogen and phosphorous are the major plant nutrients used for fertilizing landscapes, and are often found in stormwater. These nutrients can result in excessive or accelerated growth of vegetation, such as algae, resulting in impaired use of water in lakes and other sources of water supply. In addition, un-ionized ammonia (one of the nitrogen forms) can be toxic to fish.

Bacteria and viruses are common contaminants of stormwater. For separate storm drain systems, sources of these contaminants include animal excrement and sanitary sewer overflow. High levels of indicator bacteria in stormwater have led to the closure of beaches, lakes, and rivers to contact recreation such as swimming.

Oil and grease include a wide array of hydrocarbon compounds, some of which are toxic to aquatic organisms at low concentrations. Sources of oil and grease include leakage, spills, cleaning and sloughing associated with vehicle and equipment engines and suspensions, leaking and breaks in hydraulic systems, restaurants, and waste oil disposal.




Metals including lead, zinc, cadmium, copper, chromium, and nickel are commonly found in stormwater. Many of the artificial surfaces of the urban environment (e.g., galvanized metal, paint, automobiles, or preserved wood) contain metals, which enter stormwater as the surfaces corrode, flake, dissolve, decay, or leach. Over half the trace metal load carried in stormwater is associated with sediments. Metals are of concern because they are toxic to aquatic organisms, can bioaccumulate (accumulate to toxic levels in aquatic animals such as fish), and have the potential to contaminate drinking water supplies.

Organics may be found in stormwater in low concentrations. Often synthetic organic compounds (adhesives, cleaners, sealants, solvents, etc.) are widely applied and may be improperly stored and disposed. In addition, deliberate dumping of these chemicals into storm drains and inlets causes environmental harm to waterways.

Pesticides (including herbicides, fungicides, rodenticides, and insecticides) have been repeatedly detected in stormwater at toxic levels, even when pesticides have been applied in accordance with label instructions. As pesticide use has increased, so too have concerns about adverse effects of pesticides on the environment and human health. Accumulation of these compounds in simple aquatic organisms, such as plankton, provides an avenue for biomagnification through the food web, potentially resulting in elevated levels of toxins in organisms that feed on them, such as fish and birds.

b. Regulatory Framework

The proposed Project is subject to the surface water quality regulations established by the United States Environmental Protection Agency (USEPA), the California State Water Resources Control Board, the Los Angeles Regional Water Quality Control Board (LARWQCB), the County of Los Angeles, and City of Los Angeles. Regulations include requirements for permits that regulate surface water discharges, and other water quality program requirements and plans. Below is a discussion of existing and applicable Federal, State, and local water quality regulations.

(1) Federal

(a) Clean Water Act

The Clean Water Act was first introduced in 1948 as the Water Pollution Control Act. The Clean Water Act authorizes Federal, state, and local entities to cooperatively create comprehensive programs for eliminating or reducing the pollution of state waters and tributaries. The primary goals of the Clean Water Act are to restore and maintain the chemical, physical, and biological integrity of the nation’s waters and to make all surface




waters fishable and swimmable. As such, the Clean Water Act forms the basic national framework for the management of water quality and the control of pollutant discharges. The Clean Water Act also sets forth a number of objectives in order to achieve the above-mentioned goals. These objectives include regulating pollutant and toxic pollutant discharges; providing for water quality which protects and fosters the propagation of fish, shellfish and wildlife; developing waste treatment management plans; and developing and implementing programs for the control of non-point sources of pollution.16

Since its introduction, major amendments to the Clean Water Act have been enacted (e.g., 1961, 1966, 1970, 1972, 1977, and 1987). Amendments enacted in 1970 created the USEPA, while amendments enacted in 1972 deemed the discharge of pollutants into waters of the United States from any point source unlawful unless authorized by a USEPA National Pollutant Discharge Elimination System (NPDES) permit. Amendments enacted in 1977 mandated development of a “Best Management Practices” Program at the state level and provided the Water Pollution Control Act with the common name of “Clean Water Act,” which is universally used today. Amendments enacted in 1987 required the USEPA to create specific requirements for discharges.

In response to the 1987 amendments to the Clean Water Act and as part of Phase I of its NPDES permit program, the USEPA began requiring NPDES permits for: (1) municipal separate storm sewer systems (MS4) generally serving, or located in, incorporated cities with 100,000 or more people (referred to as municipal permits); (2) 11 specific categories of industrial activity (including landfills); and (3) construction activity that disturbs five acres or more of land. Phase II of the USEPA’s NPDES permit program, which went into effect in early 2003, extended the requirements for NPDES permits to: (1) numerous small municipal separate storm sewer systems,17 (2) construction sites of one to five acres, and (3) industrial facilities owned or operated by small municipal separate storm sewer systems. The NPDES permit program is typically administered by individual authorized states. As further discussed below, in the State of California, the program is issued through the State Water Resources Control Board and the nine Regional Water Quality Control Boards.

16 Non-point sources of pollution are carried through the environment via elements such as wind, rain, or

stormwater and are generated by diffuse land use activities (such as runoff from streets and sidewalks or agricultural activities) rather than from an identifiable or discrete facility.

17 A small municipal separate storm sewer system (MS4) is any MS4 not already covered by the Phase I program as a medium or large MS4. The Phase II Rule automatically covers on a nationwide basis all small MS4s located in “urbanized areas” as defined by the Bureau of the Census (unless waived by the NPDES permitting authority), and on a case-by-case basis those small MS4s located outside of urbanized areas that the NPDES permitting authority designates.




In addition to regulating non-stormwater discharges, the Clean Water Act sets forth water quality standards and criteria based on a water body’s designated beneficial uses. Section 305(b) of the Clean Water Act requires preparation of a 303(d) list (list of water quality limited or impaired water bodies). This list identifies what water bodies that are not achieving water quality standards or receiving beneficial uses and for what pollutants. Once a water body is identified as impaired, a Total Maximum Daily Load (TMDL) for the constituent of concern (pollutant) must be developed for that water body. A TMDL specifies the maximum amount of a pollutant that a water body can receive and still meet water quality standards. Those facilities and activities that are discharging into the water body, collectively, must not exceed the TMDL. The USEPA oversees the 303(d) program and either the USEPA or the State Water Board establishes the TMDL schedule for individual constituents.

(b) Federal Anti-Degradation Policy

The Federal Antidegradation Policy (40 Code of Federal Regulations 131.12) requires states to develop statewide antidegradation policies and identify methods for implementing them. Pursuant to the Code of Federal Regulations (CFR), state antidegradation policies and implementation methods shall, at a minimum, protect and maintain (1) existing in-stream water uses; (2) existing water quality, where the quality of the waters exceeds levels necessary to support existing beneficial uses, unless the state finds that allowing lower water quality is necessary to accommodate economic and social development in the area; and (3) water quality in waters considered an outstanding national resource.

(2) State and Regional

(a) Porter-Cologne Water Quality Control Act (California Water Code)

The Porter-Cologne Water Quality Control Act (Porter-Cologne Act) was enacted in 1969 by the State of California. The Porter-Cologne Act includes provisions to address requirements of the Clean Water Act. These provisions include NPDES permitting, dredge and fill programs, and civil and administrative penalties. Regulations promulgated as a result of the Porter-Cologne Act are codified in Sections 13000-14958 of the California Water Code. The Porter-Cologne Act addresses issues relating to the conservation, control, and utilization of the water resources of the state. The Porter-Cologne Act states that the quality of all the waters of the state (including groundwater and surface water) shall be protected for the use and enjoyment by the people of the state.

The State Water Resources Control Board and its nine Regional Water Quality Control Boards are agencies within the umbrella structure of the California EPA. The State Water Resources Control Board has the principle responsibility for the development and




implementation of California water quality policy and must develop programmatic water quality control procedures to be followed by the Regional Water Quality Control Boards. Based on the State Water Resources Control Board procedures, the regional boards develop local water quality control plans. The Project site is located in Region 4, also known as the Los Angeles Region governed by the LARWQCB.

(b) California Antidegradation Policy

The California Antidegradation Policy, otherwise known as the Statement of Policy with Respect to Maintaining High Quality Water in California was adopted by the State Water Board (State Board Resolution No. 68-16) in 1968. Unlike the Federal Antidegradation Policy, the California Antidegradation Policy applies to all waters of the State, not just surface waters. The policy states that whenever the existing quality of a water body is better than the quality established in individual Basin Plans, such high quality shall be maintained and discharges to that water body shall not unreasonably affect present or anticipated beneficial use of such water resource.

(c) California Toxic Rule

In 2000, the EPA promulgated the California Toxic Rule, which establishes water quality criteria for certain toxic substances to be applied to waters in the State. EPA promulgated this rule based on the EPA's determination that the numeric criteria are necessary in the State to protect human health and the environment. The California Toxic Rule establishes acute (i.e., short-term) and chronic (i.e., long-term) standards for bodies of water such as inland surface waters and enclosed bays and estuaries that are designated by the LARWQCB as having beneficial uses protective of aquatic life or human health such as the Ballona Creek.

(d) Board Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties

As required by the California Water Code, the LARWQCB has adopted a plan entitled “Water Quality Control Plan, Los Angeles Region: Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties” (Basin Plan). Specifically, the Basin Plan designates beneficial uses for surface and groundwaters,18 sets narrative and numerical objectives that must be attained or maintained to protect the designated beneficial uses and conform to the State's antidegradation policy, and describes

18 Designated beneficial uses of water include but are not limited to: domestic, municipal, agricultural and

industrial supply; power generation; recreation; aesthetic enjoyment; navigation; and preservation and enhancement of fish, wildlife, and other aquatic resources or preserves. Such uses may be past, present and probable future beneficial uses of water.




implementation programs to protect all waters in the Los Angeles Region.19 In addition, the Basin Plan incorporates (by reference) all applicable State and Regional Board plans and policies and other pertinent water quality policies and regulations. Those of other agencies are referenced in appropriate sections throughout the Basin Plan.

The Basin Plan is a resource for the Regional Board and others who use water and/or discharge wastewater in the Los Angeles Region. Other agencies and organizations involved in environmental permitting and resource management activities also use the Basin Plan. Finally, the Basin Plan provides valuable information to the public about local water quality issues.

(e) Ballona Creek Watershed Management Master Plan

The Ballona Creek Watershed Management Master Plan is an outgrowth of the efforts of the Ballona Creek Watershed Task Force, a stakeholder group formed in 2001 by the Los Angeles County Department of Public Works, the Santa Monica Bay Restoration Commission, the City of Los Angeles and Ballona Creek Renaissance to collectively set forth a strategy to develop pollution control and habitat restoration actions that could achieve an ecologically healthy watershed. The plan provides an assessment of existing environmental conditions, establishes goals and objectives to achieve an ecologically healthy watershed, identifies methods to achieve specific water quality improvements, recognizes opportunities for habitat restoration, develops a community-based watershed monitoring plan, and identifies existing and future funding sources for plan implementation With regard to individual development projects, the plan calls for implementation of BMPs to reduce contaminants in dry weather flows and stormwater flows and to reduce the volume of stormwater flows.

(f) National Pollutant Discharge Elimination System (NPDES)

In the State of California, the State Water Resources Control Board and the nine Regional Water Quality Control Boards are responsible for implementing the NPDES permit program.

(i) Construction

As previously stated, the Clean Water Act requires stormwater discharges to surface waters associated with construction activity, including demolition, clearing, grading, and excavation, and other land disturbance activities (except operations that result in disturbance of less than one acre of total land area and which are not part of a larger

19 On April 2, 2009, the LARWQCB held a workshop on the triennial review of the Basin Plan. Updates to the

Basin Plan have not yet been adopted.




common plan of development or sale), to obtain coverage under a NPDES construction permit. The NPDES construction permit requires implementation of Best Available Technology Economically Achievable and Best Conventional Pollutant Control Technology to reduce or eliminate pollutants in storm water runoff. The NPDES construction permit also includes additional requirements necessary to implement applicable water quality standards.

The General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit) was adopted in 2004 by the State Water Resources Control Board.20,21 This Construction General Permit regulates construction activity that includes clearing, grading, and excavation resulting in soil disturbance of at least one acre of total land area.22 Specifically, the Construction General Permit prohibits the discharge of materials other than stormwater and authorized non-stormwater discharges and all discharges that contain a hazardous substance in excess of reportable quantities established in 40 Code of Federal Regulations (CFR) 117.3 and 40 CFR 302.4 unless a separate NPDES permit has been issued to regulate those discharges.

In order to obtain coverage under the Construction General Permit, a Project Applicant must file a Notice of Intent (NOI) to the Regional Water Quality Control Boards and prepare a Storm Water Pollution Prevention Plan (SWPPP) prior to commencement of construction.23 The purposes of the SWPPP are to identify potential pollutant sources that may affect the quality of discharge associated with construction activity, identify non-storm water discharges, and design the use and placement of BMPs to effectively prohibit the entry of pollutants from the Project site into the public storm drain system during construction. The BMPs typically address minimization of erosion during construction, stabilization of construction areas, sediment control, control of pollutants from construction materials, and post-construction management (e.g., the minimization of impermeable surfaces, treatment of runoff, etc). The SWPPP must also include a discussion of the program to inspect and maintain all BMPs. As construction progresses and as conditions warrant, the SWPPP will require modification by the construction contractor.

20 State Water Resources Control Board NPDES General Permit for Discharges Associated with

Construction Activity (Water Quality Order No. 99-08-DWQ). 21. A updated draft of the Construction General Permit with significant changes has been circulated has not

yet been approved. 22 Soil disturbance activities include clearing, grading, and disturbances to the ground such as stockpiling, or

excavation, but does not include regular maintenance activities performed to restore the original line, grade, or capacity of a facility.

23 State Water Resources Control Board, Storm Water Program, online at: http://www.waterboards.ca.gov/ water_issues/programs/stormwater/construction.shtml, accessed March 19, 2009.




Once construction of a project is complete, a Notice of Termination would need to be filed with the Regional Water Quality Control Board certifying that all State and local requirements have been met in accordance with the requirements of the Construction General Permit.

(ii) Operation

Under Section 402(p) of the Clean Water Act, municipal NPDES permits shall prohibit the discharge of non-storm water except under certain conditions and require controls to reduce pollutants in discharges to the maximum extent practicable. Such controls include BMPs, as well as system, design, and engineering methods. A municipal NPDES permit was issued to the County of Los Angeles and 84 incorporated cities, including the City of Los Angeles, in December 2001.24 The Los Angeles County Municipal NPDES Permit required implementation of the Storm Water Quality Management Program prepared as part of the NPDES approval process. The Storm Water Quality Management Program requires the County of Los Angeles and the 84 incorporated cities to:

Implement a public information and participation program to conduct outreach on storm water pollution;

Control discharges at commercial/industrial facilities through tracking, inspecting, and ensuring compliance at facilities that are critical sources of pollutants;

Implement a development planning program for specified development projects;

Implement a program to control construction runoff from construction activity at all construction sites within the relevant jurisdictions;

Implement a public agency activities program to minimize storm water pollution impacts from public agency activities; and

Implement a program to document, track, and report illicit connections and discharges to the storm drain system.

Under the Los Angeles County Municipal NPDES Permit, permittees are required to implement a development planning program to address storm water pollution. These programs require project applicants for certain types of projects to implement Standard Urban Stormwater Mitigation Plans (SUSMP) throughout the operational life of their projects. The purpose of SUSMP is to reduce the discharge of pollutants in storm water by outlining BMPs which must be incorporated into the design plans of new development and

24. 2001 Los Angeles County Municipal NPDES Permit (Order No 01-182, NPDES No. CAS0041). Note:

The permit was amended on August 9th, 2007 by Order R4-2007-0042 to include more specific provisions related to discharges of bacteria that could impact Mother’s Beach and the back Basin’s of Marina del Rey Harbor during summer dry weather.




redevelopment. A project is subject to SUSMP if it falls under one of the categories listed below:

Single-family hillside residential developments of one acre or more of surface area;

Housing developments of 10 units or more;

A 100,000 square feet or more impervious surface area industrial/commercial development;

Automotive service facilities [5,000 square feet or more of surface area];

Retail gasoline outlets [5,000 square feet or more impervious surface area and with projected averaged daily traffic of 100 or more vehicles];

Restaurants of 5,000 square feet or more of surface area;

Parking lot of 5,000 square feet or more of surface area or with 25 or more parking spaces;

Projects located adjacent to or discharging directly to an Environmentally Sensitive Area that meets the following threshold conditions: discharge stormwater and urban runoff that is likely to impact a sensitive biological species or habitat; and create 2,500 square feet or more of impervious surface area; and

Redevelopment projects in subject categories that meet redevelopment thresholds.

(3) Local

(a) City of Los Angeles Water Quality Compliance Master Plan for Urban Runoff

On March 2, 2007, City Council Motion 07-0663 was introduced by the City of Los Angeles City Council to develop a water quality master plan with strategic directions for planning, budgeting and funding to reduce pollution from urban runoff in the City of Los Angeles. The Water Quality Compliance Master Plan for Urban Runoff was developed by the Bureau of Sanitation, Watershed Protection Division in collaboration with the stakeholders to address the requirements of this Council Motion. The primary goal of the Water Quality Compliance Master Plan for Urban Runoff is to help meet water quality regulations. Implementation of the Water Quality Compliance Master Plan for Urban Runoff over the next 20 to 30 years will result in cleaner neighborhoods, rivers, lakes and bays, augmented local water supply, reduced flood risk, more open space, and beaches that are safe for swimming. The Water Quality Compliance Master Plan for Urban Runoff




also supports the Mayor and Council’s efforts to make Los Angeles the greenest major city in the nation.

The Water Quality Compliance Master Plan for Urban Runoff identifies and describes the various watersheds in the City, summarizes the water quality conditions of the City’s waters, identifies known sources of pollutants, describes the governing regulations for water quality, describes the BMPs that are being implemented by the City, discusses existing TMDL Implementation Plans and Watershed Management Plans. Additionally, the Water Quality Compliance Master Plan for Urban Runoff provides an implementation strategy that includes the following three initiatives to achieve water quality goals:

Water Quality Management Initiative, which describes how Water Quality Management Plans for each of the City’s watershed and TMDL-specific Implementation Plans will be developed to ensure compliance with water quality regulations.

The Citywide Collaboration Initiative, which recognizes that urban runoff management and urban (re)development are closely linked, requiring collaborations of many City agencies. This initiative requires the development of City policies, guidelines, and ordinances for green and sustainable approaches for urban runoff management.

The Outreach Initiative, which promotes public education and community engagement with a focus on preventing urban runoff pollution.

Finally, the Water Quality Compliance Master Plan for Urban Runoff includes a financial plan that provides a review of current sources of revenue, estimates costs for water quality compliance, and identifies new potential sources of revenue.

(b) City of Los Angeles Proposition O

On November 2, 2004, Los Angeles voters passed Proposition O with an overwhelming majority of 76 percent. The $500 million bond authorizes the City to fund projects that protect public health, capture stormwater for reuse and meet the Federal Clean Water Act through removal and prevention of pollutants entering regional waterways. A number of projects targeted at improving water quality have been authorized using Proposition O funds, including but not limited to: the Temescal Canyon Park Stormwater BMP, Los Angeles Zoo Parking Lot, the Westchester Stormwater BMP, Echo Park Lake Rehabilitation Project, and the Hansen Dam Recreational Area Parking Lot and Wetlands Restoration.25

25 City of Los Angeles Stormwater Program, Proposition O, website - http://www.lapropo.org/index.htm;

accessed August 4, 2009.




In addition, Proposition O funds were utilized for Catch Basin Screen Cover and Insert Project which provided for the installation of catch basin inserts and screen cover throughout the City beginning in 2005 with completion on September 30, 2007 (Phase I and Phase II). Phase III began in the spring of 2008 and will retrofit approximately 34,000 remaining catch basins with opening screen covers.26

(c) City of Los Angeles Stormwater Program

The City of Los Angeles Development Best Management Practices Handbook, Part A Construction Activities, 3rd Edition, adopted by the City of Los Angeles Department of Public Works in September 2004, and associated ordinances reinforce the policies of the Construction General Permit. The handbook and ordinances also have specific minimum BMP requirements for all construction activities and require dischargers whose construction projects disturb one acre or more of soil to prepare a SWPPP and file a NOI with the Regional Water Quality Control Board.

Requirements of the Los Angeles County Municipal NPDES permit are mirrored within the City of Los Angeles’s Development Best Management Practices Handbook, Part B Planning Activities, 3rd Edition, adopted by the City of Los Angeles Department of Public Works in June 2004. The manual provides guidance for developers in complying with the requirements of the Development Planning Program regulations of the City’s Stormwater Program. Compliance with the requirements of this manual is required by City of Los Angeles Ordinance No. 173,494.

The requirement to incorporate stormwater BMPs into the SUSMP is implemented through the City’s plan review and approval process. During the review process, project plans are reviewed for compliance with the City’s General Plans, zoning ordinances, and other applicable local ordinances and codes, including storm water requirements. Plans and specifications are reviewed to ensure that the appropriate BMPs are incorporated to address storm water pollution prevention goals. The SUSMP provisions that are applicable to new residential and commercial developments include, but are not limited to, the following:27

Peak Storm Water Runoff Discharge Rate: Post-development peak storm water runoff discharge rates shall not exceed the estimated pre-development rate for developments where the increased peak storm water discharge rate will result in increased potential for downstream erosion;

26 City of Los Angeles Stormwater Program, What’s New, website - http://www.lastormwater.org/siteorg/

events/PropO/121307.htm; accessed August 4, 2009. 27 City of Los Angeles Stormwater Program website, http://www.lastormwater.org/siteorg/businesses/susmp/

industrial.htm; http://www.lastormwater.org/siteorg/businesses/susmp/housing.htm; accessed August 2, 2009.




Provide storm drain system Stenciling and Signage (only applicable if a catch basin is built on-site);

Properly design outdoor material storage areas to provide secondary containment to prevent spills;

Properly design trash storage areas to prevent off-site transport of trash;

Provide proof of ongoing BMP Maintenance of any structural BMPs installed;

Design Standards for Structural or Treatment control BMPs:

o Conserve natural and landscaped areas;

o Provide planter boxes and/or landscaped areas in yard/courtyard spaces;

o Properly design trash storage areas to provide screens or walls to prevent off-site transport of trash;

o Provide proof on ongoing BMP maintenance of any structural BMP's installed;

Design Standards for Structural or Treatment Control BMPs:

o Post-construction treatment control BMPs are required to incorporate, at minimum, either a volumetric or flow based treatment control design or both, to mitigate (infiltrate, filter or treat) storm water runoff.

In addition, project applicants subject to the SUSMP requirements must select source control and, in most cases, treatment control BMPs from the list approved by the RWQCB. The BMPs must control peak flow discharge to provide stream channel and over bank flood protection, based on flow design criteria selected by the local agency. Further, the source and treatment control BMPs must be sufficiently designed and constructed to collectively treat, infiltrate, or filter stormwater runoff from one of the following:

The 85th percentile 24-hour runoff event determined as the maximized capture stormwater volume for the area, from the formula recommended in Urban Runoff Quality Management, WEF Manual of Practice No. 23/ASCE Manual of Practice No. 87, (1998);

The volume of annual runoff based on unit basin storage water quality volume, to achieve 80 percent or more volume treatment by the method recommended in California Stormwater Best Management Practices Handbook—Industrial/ Commercial, (1993);

The volume of runoff produced from a 0.75-inch storm event, prior to its discharge to a stormwater conveyance system; or




The volume of runoff produced from a historical-record based reference 24-hour rainfall criterion for “treatment” (0.75-inch average for the Los Angeles County area) that achieves approximately the same reduction in pollutant loads achieved by the 85th percentile 24-hour runoff event.

Per the City’s SUSMP Infiltration Requirements and Guidelines, the order of preference specified below shall be followed in determining the appropriate type of SUSMP improvement for the project site.

1. Infiltration Systems (Design based on the volume of storm water)

2. Bio-Filtration/Retention Systems (Design based on flow of storm water)

3. Storm Water Capture and Re-Use (Optional. Subject to County Health Dept approval)

4. Mechanical/Hydrodynamic Units

5. Combination of Any of the Above

(d) Los Angeles Municipal Code

In addition, earthwork activities, including grading, are governed by the Los Angeles Building Code, which is contained in Los Angeles Municipal Code (LAMC), Chapter IX, Article 1. Specifically, Section 91.7013 includes regulations pertaining to erosion control and drainage devices and Section 91.7014 includes general construction requirements as well as requirements regarding flood and mudflow protection.

Section 64.70 of the LAMC sets forth the City’s Stormwater and Urban Runoff Pollution Control Ordinance. The ordinance prohibits the discharge of the following into any storm drain system:

Any liquids, solids, or gases which by reason of their nature or quantity are flammable, reactive, explosive, corrosive, or radioactive, or by interaction with other materials could result in fire, explosion or injury.

Any solid or viscous materials which could cause obstruction to the flow or operation of the storm drain system.

Any pollutant that injures or constitutes a hazard to human, animal, plant, or fish life, or creates a public nuisance.

Any noxious or malodorous liquid, gas, or solid in sufficient quantity, either singly or by interaction with other materials, which creates a public nuisance, hazard to life, or inhibits authorized entry of any person into the storm drain system.




Any medical, infectious, toxic or hazardous material or waste.

Additionally, unless otherwise permitted by a NPDES permit, the ordinance prohibits industrial and commercial developments from discharging untreated wastewater or untreated runoff into the storm drain system. Furthermore, the ordinance prohibits trash or any other abandoned objects/materials from being deposited such that they could be carried into the storm drains. Lastly, the ordinance not only makes it a crime to discharge pollutants into the storm drain system and imposes stiff fines on violators, but also gives City public officers the authority to issue citations or arrest business owners or residents who deliberately and knowingly dump or discharge hazardous chemicals or debris into the storm drain system.

3. Environmental Impacts

a. Methodology

The analysis of surface water quality impacts is based in part on the Surface Water Quality Control Study, prepared by KPFF Consulting Engineers. This study is provided in Appendix H of this Draft EIR.

The analysis of surface water quality impacts identifies the types of pollutants associated with construction and operation of the proposed Project and considers their effects on surface water quality. Consideration is given to Project Design Features that would minimize polluted stormwater runoff.

b. Significance Thresholds

Appendix G of the State CEQA Guidelines provides a set of sample questions that address impacts with regard to water quality. These questions are as follows:

Would the project:

Violate any water quality standards or waste discharge requirements?

Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site?

Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?




Otherwise substantially degrade water quality?

In the context of these questions from Appendix G, the City of Los Angeles CEQA Thresholds Guide states that a project would normally have a significant impact on surface water quality if it would:

Result in discharges that would create pollution, contamination or nuisance as defined in Section 13050 of the California Water Code (CWC) or that cause regulatory standards to be violated, as defined in the applicable NPDES stormwater permit or Water Quality Control Plan for the receiving water body.

As defined in the CWC:

“Pollution” means an alteration of the quality of the waters of the State to a degree which unreasonably affects either of the following: 1) the waters for beneficial uses or 2) facilities which serve these beneficial uses. Pollution may include contamination.

“Contamination” means an impairment of the quality of the waters of the State by waste to a degree which creates a hazard to the public health through poisoning or through the spread of diseases. Contamination includes any equivalent effect resulting from the disposal of waste whether or not waters of the State are affected.

“Nuisance’ means anything which meets all of the following requirements: 1) is injurious to health, or is indecent or offensive to the senses, or an obstruction to the free use of property so as to interfere with the comfortable enjoyment of life or property; 2) affects at the same time an entire community or neighborhood, or any considerable number of persons although the extent of the annoyance or damage inflicted upon individuals may be unequal; and 3) occurs during or as a result of the treatment or disposal of wastes.

c. Project Design Features

In compliance with NPDES and City requirements, BMPs would be implemented to address water quality during both construction and operation of the proposed Project:

Specifically, during Project construction, the Project Applicant would prepare and implement site-specific SWPPPs. The SWPPPs would specify BMPs to be used during construction. BMPs would include but not be limited to: erosion control, sediment control, and non-stormwater management and material management. Examples of construction BMPs that could be implemented are listed in Table IV.F-4 on page IV.F-41 and include




preservation of existing vegetation, hydraulic mulch, silt fence, sediment basin, sediment trap, and storm drain inlet protection. In addition, the Project Applicant would be required to comply with City grading permit regulations, which require necessary measures, plans, and inspections to reduce sedimentation and erosion.

Throughout the operational life of the proposed Project, the Project Applicant would prepare and implement a SUSMP for individual developments within the Project site. Consistent with the Los Angeles County Municipal NPDES Permit requirements as well as the City Bureau of Engineering’s water quality regulations, the SUSMP would specify measures to detain storm water runoff on-site so that peak stormwater discharge from the site would be maintained at or below existing conditions. In addition, stormwater BMPs to address water quality in stormwater runoff would be incorporated into the design of the proposed Project and outlined in the SUSMP. BMPs would include source control and treatment control BMPs.

Table IV.F-4 Examples of Construction BMPs

Construction BMPs Description Examples

Erosion Control Erosion control is any source control practice that protects the soil surface and prevents soil particles from being detached by rainfall, flowing water, or wind. Also referred to as soil stabilization.

Preservation of existing vegetation, hydraulic mulch, hydroseeding, soil binders, straw mulch, earth dikes, and drainage swales

Sediment Control Sediment control is any practice that traps soil particles after they have been detached and moved by rain, flowing water, or wind. Sediment control measures are usually passive systems that rely on filtering or settling the particles of the water or wind that is transporting them.

Silt fence, sediment basin, sediment trap, check dam, gravel bag berm, sandbag barrier, storm drain inlet protection

Non-Stormwater Management and Materials Management

Non-stormwater management and materials management BMPs are source control BMPs that prevent pollution by limiting or reducing potential pollutants at their source or eliminating off-site discharge. These practices involve day-to-day operations of the construction site and are usually under the control of the contractor. Procedures and practices designed to minimize or eliminate the discharge of pollutants from vehicle and equipment cleaning, fueling, and maintenance operations to stormwater drainage systems or to watercourses. Also referred to as “good housekeeping practices”.

Keeping a clean, orderly construction site

Source: KPFF Consulting Engineers, 2009.




(1) Source Control BMPs

Source control BMPs would be used to prevent pollutants from entering into stormwater discharges. The following are examples of source control BMPs that would be considered for implementation for the proposed Project:

Effective Site Design & Landscape Planning: Each development site possesses unique topographic, hydrologic, and vegetative features, some of which may be more suitable for development than others. Integrating and incorporating appropriate landscape planning methodologies into the project design is an effective action that can be done to minimize surface and groundwater contamination from stormwater. Project plan designs would conserve landscape areas where appropriate, maximizing natural water storage and infiltration opportunities. In addition, project design would also include application methods of irrigation water that minimize runoff of excess irrigation water into the stormwater conveyance system;

Storm Drain Signage: Storm drain messages have become a popular method of alerting the public about the effects of and the prohibitions against waste disposal. The stencil or affixed sign with a brief statement that prohibits dumping of improper materials into the urban runoff conveyance system is recommended at all storm drain inlets within the boundary of the Project site;

Proper Design of Maintenance Bays & Docks: Several measures can be taken to prevent operations at maintenance bays and loading docks from contributing a variety of toxic compounds, oil and grease, heavy metals, nutrients, suspended solids, and other pollutants to the stormwater conveyance system. Preventative measures include overflow containment structures, dead-end sumps, and engineered infiltration systems;

Proper Design of Trash Storage Area: Stormwater runoff from areas where trash is stored or disposed of can be polluted, and loose trash and debris can be easily transported by water or wind into nearby storm drain inlets, channels, and/or creeks. Waste handling operations such as dumpsters, litter control, and waste piles may be sources of stormwater pollution. As preventative measures, trash container areas will be screened or walled to prevent off-site transport of trash, and drainage from adjoining roofs and pavement will be diverted around the area;

Proper Design of Outdoor Material Storage Areas: Proper design of outdoor storage areas for materials reduces opportunity for toxic compounds, oil and grease, heavy metals, nutrients, suspended solids, and other pollutants to enter the stormwater conveyance system. Materials with the potential to contaminate stormwater will be: (1) placed in an enclosure such as, but not limited to, a cabinet, shed, or similar structure that prevents contact with runoff or spillage to the stormwater conveyance system; or (2) protected by secondary containment




structures such as berms, dikes, or curbs. In addition, the storage area will be paved and sufficiently impervious to contain leaks and spills and have a roof or awning to minimize collection of stormwater within the secondary containment area; and

Proper Maintenance of Structural/Treatment Control BMP: Improper maintenance is one of the most common reasons why water quality controls will not function as designed or which may cause the system to fail entirely. It is important to consider who will be responsible for maintenance of a permanent BMP, and what equipment is required to perform the maintenance properly. As part of project review, if a project applicant has included or is required to include, Structural or Treatment Control BMPs in project plans, the applicant will be required to provide verification of maintenance provisions through such means as may be appropriate, including, but not limited to legal agreements, covenants, and/or CEQA mitigation requirements.

(2) Treatment Control BMPs

Treatment control BMPs would remove pollutants that have already entered stormwater discharge. There are two types of treatment control BMPs that would be implemented: flow-based treatment control BMPs and volume-based treatment control BMPs.

(a) Flow-Based Treatment Control BMPs

The following is a menu of potential flow-based treatment control BMPs that would be considered for feasibility during design of new development proposed by the proposed Project. In accordance with SUSMP, flow-based treatment control BMPs would be designed to treat the flow of runoff produced from a 0.75 inch storm event or as described below:

1. The flow of runoff produced from a rain event equal to at least 0.2 inches per hour intensity, or

2. The flow of runoff produced from a rain event equal to at least two times the 85th percentile hourly rainfall intensity for Los Angeles County, or

3. The flow of runoff produced from a rain event that will result in treatment of the same portion of runoff as treated using volumetric standards above.

Vegetative Systems: Vegetative systems are designed to treat runoff through filtering by the vegetated surface, filtering through a subsoil matrix, and/or infiltration into the underlying soils. They trap particulate pollutants (suspended solids and trace metals),




promote infiltration, and reduce the flow velocity of stormwater runoff. Vegetative system BMPs include vegetative filter strips, vegetated swale, green roof, and bioretention (Bioretention can be also considered as a volume-based treatment control BMP).

Vortex / Hydrodynamic System: Vortex separators are gravity separators, which the water moves in a centrifugal fashion before exiting. Unlike wet vault, by having the water move in a circular fashion, it is possible to obtain significant removal of suspended sediments and attached pollutants with less space.

Catch Basins Systems: Drain inserts are manufactured filters or fabric placed in a drop inlet to remove sediment and debris. There are a multitude of inserts of various shapes and configurations, typically falling into one of three different groups: socks, boxes, and trays. The sock consists of a fabric, usually constructed of polypropylene. The fabric may be attached to a frame or the grate of the inlet holds the sock. Socks are meant for vertical (drop) inlets. Boxes are constructed of plastic or wire mesh. Typically a polypropylene “bag” is placed in the wire mesh box. The bag takes the form of the box. Most box products are one box; that is, the settling area and filtration through media occur in the same box. Some products consist of one or more trays or mesh grates. The trays may hold different types of media. Filtration media vary by manufacturer. Types include polypropylene, porous polymer, treated cellulose, and activated carbon.

(b) Volume-based Treatment Control BMPs

Volume-based treatment control BMPs will be designed to treat:

1. The 85th percentile 24-hour runoff event determined as the maximized captured storm water volume for the area, from the formula recommended in Urban Runoff Quality Management, WEF Manual of Practice No. 23 / ASCE Manual of Practice No. 87, (1998), or

2. The volume of annual runoff based on unit basin storage water quality volume, to achieve 80 percent or more volume treatment by the method recommended in California Stormwater Best Management Practices Handbook – Industrial / Commercial, (1993), or

3. The volume of runoff produced from a 0.75 inch storm event, prior to its discharge to a storm water conveyance system, or

4. The volume of runoff produced from a historical-record based reference 24-hour rainfall criterion for “treatment” (0.75 inch average for the Los Angeles County area) that achieves approximately the same reduction in pollutant loads achieved by the 85th percentile 24-hour runoff event.




Infiltration/Retention: The infiltration type of BMPs utilizes the natural filtering ability of the soil to remove pollutants in stormwater runoff. Infiltration facilities store runoff until it gradually exfiltrates through the soil and eventually into the water table. This practice has high pollutant removal efficiency and can also help recharge groundwater, thus helping to maintain low flows in stream systems. Infiltration basins can be challenging to apply on many sites because of soils requirements. Pretreatment using buffer strips, swales, or detention basins is important for limiting amounts of coarse sediment entering the trench which can clog and render the trench ineffective. Examples of infiltration and retention BMPs include infiltration basins, cisterns, drywells, and extended detention ponds.

Pervious Pavement: Pervious paving may be considered for light vehicle loading in parking areas and pedestrian areas. The term describes a system comprising a load-bearing, durable surface together with an underlying layered structure that temporarily stores water prior to infiltration or drainage to a controlled outlet. The surface can itself be porous such that water infiltrates across the entire surface of the material (e.g., turf and gravel surfaces, porous concrete, and porous asphalt), or can be built up of impermeable blocks separated by spaces and joints, through which the water can drain. This latter system is termed ‘permeable’ paving. Advantages of pervious pavements are that they reduce runoff volume while providing treatment, and are unobtrusive resulting in a high level of acceptability. Asphalt porous pavements, concrete block porous pavements, and structural soil are part of pavement BMPs.

Media Filtration: Stormwater media filters are usually two-chambered including a pretreatment settling basin and a filter bed filled with sand or other absorptive filtering media. As stormwater flows into the first chamber, large particles settle out, and then finer particles and other pollutants are removed as stormwater flows through the filtering media in the second chamber. There are a number of design variations including the Austin sand filter, Delaware sand filter, and multi-chambered treatment train.

The above examples of BMPs that could be incorporated during operation of the proposed Project and implemented in compliance with SUSMP requirements are listed in Table IV.F-5 on page IV.F-46. The final list of BMPs to be completed as part of SUSMP requirements would be subject to City review for compliance with the City’s Development Best Management Practices Handbook, Part B Planning Activities and the SUSMP Infiltration Requirements and Guidelines.




d. Analysis of Proposed Project Impacts

(1) Construction

Construction activities such as earth moving, maintenance/operation of construction equipment, and handling/storage/disposal materials could contribute to pollutant loading in stormwater runoff. However, as previously discussed, construction contractors disturbing greater than one acre of soil would be required to obtain coverage under the NPDES General Construction Activity Permit (Order No. 99-08-DWQ). In accordance with the requirements of the permit, the Project Applicant would prepare and implement a site-specific SWPPP. The SWPPP would specify BMPs to be used during construction. As shown in Table IV.F-4 on page IV.F-41, BMPs would include but not be limited to: erosion control, sediment control, and non-stormwater management and materials management BMPs.

With implementation of these BMPs included as part of the SWPPP, the proposed Project would reduce or eliminate the discharge of potential pollutants from the storm water runoff to the maximum extent practicable. In addition, the Project Applicant would be required to comply with City grading permit regulations, which require necessary measures, plans (including a wet weather erosion control plan if construction occurs during the rainy season), and inspections to reduce sedimentation and erosion. Therefore, with compliance with NPDES requirements and City grading regulations, construction of the proposed Project would not result in discharges that would cause: (1) pollution which would alter the quality of the waters of the State (i.e., Ballona Creek) to a degree which unreasonably affects beneficial uses of the waters; (2) contamination of the quality of the waters of the

Table IV.F-5 Examples of Operation BMPs

Construction BMPs Description Examples

Source Control Source control BMPs are used to prevent pollutants from entering into stormwater discharges.

Effective Site Design & Landscape Planning; Storm Drain Signage; Proper Design of Maintenance Bays & Docks; Proper Design of Trash Storage Area; Proper Design of Outdoor Material Storage Areas; Proper Maintenance of Structural/Treatment Control BMP.

Treatment Control Treatment control BMPs are used to remove pollutants that have already entered the stormwater.

Vegetative Systems; Vortex / Hydrodynamic System; Catch Basins Systems; Infiltration/ Retention; Pervious Pavement; Media Filtration.





State by waste to a degree which creates a hazard to the public health through poisoning or through the spread of diseases; or (3) nuisance that would be injurious to health; affect an entire community or neighborhood, or any considerable number of persons; and occurs during or as a result of the treatment or disposal of wastes. Furthermore, construction of the proposed Project would not result in discharges that would cause regulatory standards to be violated in Ballona Creek. Therefore, construction-related short term impacts on surface water quality would be less than significant.

(2) Operation

As is typical of most major urban developments, stormwater runoff from the proposed Project site has the potential to introduce pollutants into the stormwater system. Anticipated and potential pollutants for the proposed Project’s various land uses are presented in Table IV.F-6 on page IV.F-48. The proposed Project falls into the following categories that are subject to NPDES SUSMP requirements:

Housing developments of 10 units or more;

A 100,000 square feet or more impervious surface area industrial/commercial development;

Restaurants of 5,000 square feet or more of surface area; and

Parking lot of 5,000 square feet or more of surface area or with 25 or more parking spaces.

Therefore, in accordance with NPDES requirements, the Project Applicant would be required to prepare and implement SUSMP requirements throughout the operational life of the proposed Project. Stormwater BMPs to address water quality in stormwater runoff would be incorporated into the design of the proposed Project. As described above and listed in Table IV.F-4 on page IV.F-41, BMPs would include source control and treatment control BMPs. Source control BMPs would be used to prevent pollutants from entering into stormwater discharges and may include effective site design and landscape planning, storm drain signage, properly managed maintenance bays and docks, properly managed trash storage areas, proper design and maintenance of outdoor material storage areas, and proper maintenance of structural/treatment control BMPS. Treatment BMPs remove pollutants from stormwater discharges and may include vegetative systems, vortex/hydrodynamic systems, catch basin systems, infiltration/retention, cisterns for collection and reuse of rainwater, pervious pavement, and media filtration. Moreover, single treatment BMPs or a combination of treatment BMPs would be implemented and designed to treat the first 75-inch rainfall in compliance with SUSMP requirements. As shown in Table IV.F-7 on page IV.F-49, different types of treatment BMPs target different pollutants and have different removal efficiencies.

IV.F. Surface Water Quality



Table IV.F-6 Anticipated and Potential Pollutants Generated by On-site Land Uses

Pathogens Metals Nutrients Pesticides Organic

Compounds Sediments Trash & Debris

Oxygen Demanding Substances

Oil and Grease

Detached Residential Development X X X X X X X

Attached Residential Development P X X X X P P

Commercial/Industrial Development P P P P P X P X

Restaurants X X X X

Parking Lots X P P P X P X

Streets, Highways, Freeways X P X X X P X

Note: X = Anticipated and P = Potential





With implementation of source control and treatment BMPs such as those described in Table IV.F-5 on page IV.F-46, which would be included as part of the SUSMP requirements, the proposed Project would reduce or eliminate the discharge of potential pollutants from the storm water runoff to the maximum extent practicable. Therefore, operation of the proposed Project would not result in discharges that would discharges that would cause: (1) pollution which would alter the quality of the waters of the State (i.e., Ballona Creek) to a degree which unreasonably affects beneficial uses of the waters; (2) contamination of the quality of the waters of the State by waste to a degree which creates a hazard to the public health through poisoning or through the spread of diseases; or (3) nuisance that would be injurious to health; affect an entire community or neighborhood, or any considerable number of persons; and occurs during or as a result of the treatment or disposal of wastes. Furthermore, operation of the proposed Project would not result in discharges that would cause regulatory standards to be violated in Ballona Creek. Rather, the proposed Project is anticipated to result in improved water quality due to the BMPs to be implemented. Thus, operational impacts on surface water quality would be less than significant.

(3) Transfers of Floor Area

The proposed Project would include flexibility to allow for transfers of floor area for academic/University uses and student housing between Subarea 1 and Subarea 3A on a per square foot basis. While transfers of floor area across Subareas would be permitted, the maximum amount of floor area would not exceed 30 percent of the Subarea total for Subarea 1 and 15 percent of the Subarea total for Subarea 3A. In addition, the maximum Project total of 5,230,000 square feet may not be exceeded. Floor area transfers would not result in new impacts with regard to surface water quality. Any new Project development (regardless of where land uses would specifically occur within the Project site) would

Table IV.F-7 Treatment Control BMPs and Target Pollutants

Sediments Nutrients Trash Metals Bacteria Oil/Grease Organics

Vegetated Swale Medium Low Low Medium Low Medium Medium

Vegetated Buffer Strip High Low Medium High Low High Medium

Vortex/Hydrodynamic System a Medium Low Unknown Low Unknown Unknown Unknown

Catch Basins System a Unknown Unknown Unknown Unknown Unknown Unknown Unknown

Infiltration/Retention High High High High High High High

Media Filtration High Low High High Medium High High

a Performance of system varies per manufacturer and model. Source: KPFF Consulting Engineers, 2009.




incorporate the Project Design Features previously described (e.g. source control and treatment control BMPs). As such, floor area transfers would not alter the conclusions with regard to surface water quality impacts. Should academic/University or student residential floor area be transferred across the Subareas, the resulting impacts would be similar to those evaluated herein.

4. Cumulative Impacts

The geographic context for the cumulative impact analysis on surface water quality is the Ballona Creek watershed. Like the proposed Project, forecasted 2030 growth in the Ballona Creek watershed (inclusive of the 30 related projects identified in Section III, Environmental Setting, of this Draft EIR) would be subject to NPDES requirements regarding water quality for both construction and operation. In addition, since the 30 identified related projects are generally in an already highly urbanized area, future land use changes or development are not likely to cause substantial changes in regional surface water quality. Furthermore, it is anticipated that these related projects and other future development projects would also be subject to SUSMP requirements and implementation of measures to comply with total maximum daily loads. In addition, increases in regional controls associated with other elements of the MS4 Permit would improve regional water quality over time. Therefore, with compliance with all applicable laws, rules and regulations, cumulative impacts to surface water quality would be less than significant.

5. Mitigation Measures

With compliance with regulatory requirements and implementation of the Project Design Features described above, Project-level impacts on surface water quality would be less than significant. In addition, cumulative impacts on surface water quality would also be less than significant. Therefore, no mitigation measures would be required.

6. Level of Significance After Mitigation

As indicated above, Project-level and cumulative impacts on surface water quality would be less than significant and thus, no mitigation measures would be required.

iv.f.2 surface water quality - department of city planning

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