Document Anaheim_doc_9a7fc3568a

5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-73 5.5 HYDROLOGY AND WATER QUALITY This section evaluates the potential impacts to hydrology and water quality conditions associated with the Proposed Project. Hydrology deals with the distribution and circulation of water, both on land and underground. Water quality deals with the quality of surface and groundwater. Surface water is water on the surface of the land and includes lakes, rivers, streams, and creeks. Groundwater is water below the surface of the earth. Water supply and wastewater treatment issues are addressed in Section 5.11, Utilities and Service Systems. The analysis in this section is based, in part, upon the following technical studies: • City of Anaheim Platinum Triangle Drainage Study, Merit Civil Engineering, Inc., September 2004. • Water Quality Technical Report For: Platinum Triangle Project, PSOMAS, February 2005. The complete reports are available in Appendices F and G, respectively. Current website information and pertinent documents from the City of Anaheim as well other appropriate agencies was also used in preparation of this section. These agencies include: • Southern California Association of Governments (SCAG) • U.S. Environmental Protection Agency (EPA) • Santa Ana River Basin Regional Water Quality Control Board • Orange County Water District (OCWD) • Orange County Flood Control District (OCFCD). 5.5.1 Environmental Setting Hydrology The Platinum Triangle generally covers an area that includes portions of City of Anaheim Drainage Districts 25, 26, and 27. Drainage Master Plans have been completed for these Districts and updated following the County’s publication of new hydrologic parameters in 1986. The new parameters resulted in greater storm run-off projections than previously estimated resulting in most existing storm drain systems being classified as undersized. The City’s current drainage criteria was developed with this issue in mind and resulted in the declaration that most systems within the City would be designed for a minimum storm frequency of10 years with specific and practical limits regarding surface flow during storms. This lower limit was established due to the overall limited conveyance capacity Storm drain systems tributary to the Santa Ana River require sizing to convey the run-off from a 25-year storm event. The improvement of the Santa Ana River by the Corps of Engineers to provide adequate capacity over the last decade has eliminated this once notable conveyance constraint and created the opportunity to relieve the watershed during heavy rainfall. In general, the area west of State College Boulevard will, at a minimum, require drainage infrastructure adequate to convey the 10-year run-off. Larger facilities may be required to meet the surface flow limitations. The area generally located east of State College Boulevard drains to the Southeast Anaheim Channel (also referred to as E12) and then to the Santa Ana River and will require drainage infrastructure adequate to ---PAGE BREAK--- 5. Environmental Analysis Page 5-74 • The Planning Center May 2005 convey the 25-year run-off. There are also surface flow limitations identified in the City’s drainage criteria packet for this area that may require additional storm drain construction. On-site Conditions The central portion of the Project Area drains into the Southeast Anaheim Channel (E12), which generally parallels State College Boulevard. The County of Orange maintains this channel. The channel was constructed in 1967 and is 9-foot by 9-foot reinforced concrete box that discharges into the Santa Ana River north of Chapman Avenue. The drainage channel collects urban run-off from approximately 1,541 acres through various tributary drains in southeast Anaheim. The Southeast Anaheim Channel (E12) is currently operating at or near capacity, and would require a large parallel system to adequately protect additional development during a 100-year storm event. The western portion of the Project Area drains into OCFCD’s Spinnaker Storm Drain (CO5P21). This drain discharges into OCFCD’s regional facility, the East Garden Grove-Wintersburg/Oceanview Channel System. The Project Area is almost entirely covered with impermeable surfaces. Run-off in the Project Area occurs primarily through sheet flow across the parking areas in a southwest direction to the surrounding street system. The street system has been designed to convey a 10-year storm event while maintaining one dry lane in each direction. Catch basins located within the street system collect gutter run-off and transport it via the drainage system to the Southeast Anaheim Channel. Flood Hazards The areas of special flood hazard identified by the Federal Insurance Administration (FIA) of the Federal Emergency Management Agency (FEMA) in the Flood Insurance Study (FIS) for the City of Anaheim dated September 15, 1989, and the Flood Insurance Rate Maps (FIRM) dated September 15, 1989, and all subsequent amendments and/or revisions, are hereby adopted by reference and declared to be a part of this chapter. This Flood Insurance Study and attendant mapping is the minimum area of applicability of this ordi- nance and may be supplemented by studies for other areas which allow implementation of this ordinance and which are recommended to the City of Anaheim by the City Engineer. The Project Area is located within a Federal Emergency Management Agency (FEMA) flood insurance study area within Zone A99 and X designation. The majority of the Project Area is located in Zone X, which lies in a 100-Year to 500-Year Flood Zone (with flooding below one foot), as shown on Figure 5.5-1. Two small areas of The Platinum Triangle are designated Zone A, located in a 100-Year Flood Zone. The larger location is first located on the eastern border of the Project Area, while the smaller zone is located between East Howell Avenue, Katella Avenue, and State College Boulevard. The larger area is located within an area designated for potential limited flooding from the Santa Ana River. According to the Orange County Flood Control District (OCFCD), the Southeast Anaheim Channel and the Spinnaker Storm Drain have been determined to be deficient to convey discharges associated with 100-year storm event. ---PAGE BREAK--- NOT TO SCALE 5. Environmental Analysis The Planning Center • Figure 5.5-1 Flood Hazard Zones The Platinum Triangle Master Land Use Plan Source: FEMA, February 18, 2004 The Platinum Triangle Boundary Howell Av Katella Av ---PAGE BREAK--- 5. Environmental Analysis Page 5-76 • The Planning Center May 2005 This page intentionally left blank. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-77 Water Quality Current Regulatory Setting Storm run-off from the Project Area, and discharges of run-off into and/or encroachment upon natural drainages, wetlands, and/or flood plains (if any) are subject to the requirements of the Federal Clean Water Act (33 U.S.C. 1251 et seq.; CWA) and associated regulations, the State Porter-Cologne Water Quality Control Act (Cal. Water Code 13000 et seq.) and associated regulations, and to requirements established by the U.S. EPA, , State Water Resources Control Board the Regional Water Quality Control Board, Santa Ana Region County of Orange, and the City of Anaheim. Each of these requirements and agencies are discussed below. Clean Water Act The Proposed Project would be subject to Federal permit requirements under the Clean Water Act. In 1972, the Federal Water Pollution Control Act (later referred to as the CWA) was amended to require that the discharge of pollutants to waters of the United States from any point source be effectively prohibited, unless the discharge is in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. In 1987, the CWA was again amended to add Section 402(p), requiring that the U.S. EPA establish regulations for permitting of storm water discharges by municipal and industrial facilities and construction activities under the NPDES permit program. The U.S. EPA published final regulations directed at municipal separate storm sewer systems (MS4s) serving a population of 100,000 or more, and storm water discharges asso- ciated with industrial activities, including construction activities, on November 16, 1990. The regulations require that MS4 dischargers to surface waters be regulated by a NPDES permit (Phase I Final Rule, 55 Fed. Reg. 47990). The U.S. EPA published final regulations directed at storm water discharges not covered in the Phase I Final Rule, including, as applicable here, small construction projects of one to five acres, on December 8, 1999 (Phase II Final Rule, 64 Fed. Reg. 68722). Section 402(p) of the CWA provides that MS4 permits must “require controls to reduce the discharge of pollutants to the maximum extent practicable [MEP], including management practices, control techniques and system, design and engineering methods and such other provisions as the [U.S. EPA] Administrator or the State determines appropriate for the control of such pollutants.” The Office of Chief Counsel of the State Water Resources Control Board has issued a memorandum interpreting the meaning of MEP to include technical feasibility, cost, and benefit derived with the burden being on the municipality to demonstrate compliance with MEP by showing that a BMP is not technically feasible in the locality or that BMP costs would exceed any benefit to be derived (dated February 11, 1993). The CWA authorizes the U.S. EPA to permit a state to serve as the NPDES permitting authority in lieu of the U.S. EPA. The State of California has in-lieu authority for an NPDES program. The Porter-Cologne Water Quality Control Act (Cal. Water Code 13000 et seq.) authorizes the through (as applicable here) the to regulate and control the discharge of pollutants into waters of the State. The entered into a memorandum of agreement with the U.S. EPA, on September 22, 1989, to administer the NPDES Program governing discharges to waters of the U.S. In addition, the CWA requires the States to adopt water quality standards for water bodies and have those standards approved by the EPA. Water quality standards consist of designated beneficial uses for a particular water body wildlife habitat, agricultural supply, fishing, etc.), along with water quality objectives necessary to support those uses. Water quality objectives can be numerical concentrations or levels of constituents, such as lead, and suspended sediment, or narrative statements that represent the quality of water needed to support a particular use. Because California had not established a complete list of acceptable water quality objectives to the U.S. EPA, the U.S. EPA, EPA Region IX (in which California lies) ---PAGE BREAK--- 5. Environmental Analysis Page 5-78 • The Planning Center May 2005 has established numeric water quality criteria applicable to all receiving waters for certain toxic constituents in the form of the California Toxics Rule (“CTR”) (40 CFR 131.38). When designated beneficial uses of a particular water body are being compromised and fail to meet water quality objectives, Section 303(d) of the CWA requires identifying and listing that water body as “impaired.” Once a water body has been deemed impaired, a Total Maximum Daily Load (“TMDL”) must be developed for each water quality constituent that compromises a beneficial use. A TMDL is an estimate of the total load of pollutants, from point, non-point, and natural sources that a water body may receive without exceeding applicable water quality standards (often with a “factor of safety” included). Once established, the TMDL is allocated among current and future dischargers into the water body. Pursuant to Section 303(d) of the CWA, the reach of the river in which the proposed project lies (Reach 2 of the Santa Ana River) has not been listed as being impaired for any pollutants, nor has the reach, Reach 1. Likewise, no have been developed for any reach of the Santa Ana River. General Construction Activity Storm Water Permit Under the General Construction Activity Storm Water Permit (NPDES No. CAS000002, General Construction Activity Storm Water Permit, reissued on April 17, 1997, updated 2001), facilities discharging storm water associated with construction projects with a disturbed area of one or more acres (March 2003) are required either to obtain individual NPDES permits for storm water discharges, or to be covered by a Statewide general permit by completing and filing a Notice of Intent with the The General Construction Activity Storm Water Permit addresses both storm water and non-storm water discharges from construction sites. The applicant under the General Construction Activity Storm Water Permit must ensure that a Storm Water Pollution Prevention Plan is prepared, and a Notice of Intent (NOI) is filed with the to comply with the State Permit prior to issuance of a grading permit. The General Construction Activity Storm Water Permit relies upon BMPs to control pollutants. The is the enforcement authority in the Santa Ana Region for the General Construction Activity Storm Water Permit, and all NPDES storm water and non-storm water permits issued by the These construction sites and discharges are also regulated under local laws and regulations. Water Quality Control Basin Plan All of the activities under the NPDES program are aimed at meeting water quality objectives of receiving waters, which eventually discharge into receiving waters that often traverse multiple counties and cities. The adopted the Water Quality Control Plan (Basin Plan) for the Santa Ana Region on March 11, 1994, which was further revised in 1995. The Basin Plan designates the beneficial uses of receiving waters, including Reach 2 of the Santa Ana River to which the project site currently discharges and the project would discharge, and specifies both narrative and numerical water quality objectives for these receiving waters in Orange County. Because these standards are applicable to receiving waters, they are not a direct measure of storm water quality from the project site. However, water quality criteria from the Basin Plan are useful as benchmarks. Reach 2 of the Santa Ana River lies between Prado Dam and 17th Street in Santa Ana. Under the Basin Plan, beneficial uses for Reach 2 include Agriculture; Groundwater; Contact Water Recreation; Non-Contact Water Recreation; Warm Freshwater Habitat; Wildlife Habitat; and Rare, Threatened or Endangered Species. The reach of the Santa Ana River (Reach 1, a normally dry flood control facility that extends from 17th Street to the tidal prism at the Pacific Ocean) has no additional beneficial uses. Both reaches have been excepted from Municipal uses. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-79 Basin Plan Water Quality Objectives Water quality objectives, as defined by the California Water Code Section 13050(h), are the “limits or levels of water quality constituents or characteristics which are established for the reasonable protection of beneficial uses or the prevention of nuisance within a specific area.” Beneficial uses are designated under CWA Section 303 in accordance with regulations. The Basin Plan defines existing and potential beneficial uses for identified water bodies receiving discharges. The project is located along Reach 2 of the Santa Ana River. Beneficial uses identified for Reach 2 include those listed above. The California Toxics Rule (CTR) is a Federal regulation issued by the U.S. EPA providing water quality criteria for protection of surface waters of the State of California with designated uses protective of human health or aquatic life. However, CTR water quality criteria and water quality objectives and beneficial uses do not apply directly to discharges of storm water run-off. Nonetheless, these standards can provide a useful benchmark to assess the potential for project discharges to affect the water quality of receiving waters when pollutant load analyses are performed. General MS4 Permit As stated above, on November 16, 1990, pursuant to Section 402(p) of the CWA, the U.S.EPA promulgated Federal regulations (40 Code of Federal Regulations [CFR] Part 122.26) establishing requirements for storm water discharges under the NPDES program. In California, the NPDES permit program is administered by the State Water Resources Control Board through the as established by the State Porter- Cologne Water Quality Control Act. The Project Area, located within the City of Anaheim, falls within the jurisdiction of the (Region and the project is subject to the waste discharge requirements of the Municipal Permit (General MS4 Permit) Order No. R8-2002-0010, NPDES No. CAS618030 (adopted January 2002). The City of Anaheim is a Permittee under the General MS4 permit and therefore has legal authority for enforcing the terms of the permit in its jurisdiction. The General MS4 Permit is intended to ensure that combinations of site planning, source control and treatment control BMPs are implemented to protect the quality of receiving waters. To do so, the General MS4 Permit requires that new development employ BMPs to the MEP (maximum extent practicable), in- cluding management practices, control and treatment techniques and systems, and site design planning to control the level of pollutants entering receiving waters. Further, the Permittees under the MS4 Permit (the County of Orange [Principal Permittee], the Orange County Flood Control District and incorporated cities, including the City of Anaheim) must ensure that storm water discharges from the MS4 shall neither cause nor contribute to the exceedance of water quality standards and objectives nor create conditions of nuisance in the receiving waters, and that the discharge of non-storm water to the MS4 has been effectively addressed. The General MS4 Permit notes, by reference to the U.S. EPA’s “Interim Permitting Approach for Water Quality-Based Effluent Limitations in Storm Water Permits” (August 26, 1996), that because of the nature of storm water discharges and the lack of detailed, documented, and accepted information on which to base numeric water quality-based effluent limitations (expressed as concentration and mass) for many pollutants of concern, the permitting approach utilizing BMPs does, indeed, provide for the attainment of water quality standards and negates the need for numerical effluent criteria as a standard. Among other things, the General MS4 Permit requires the Permittees to prepare a WQMP (Water Quality Management Plan) specifying the BMPs that will be implemented to reduce the discharge of pollutants in storm water to the MEP. The various components of the WQMP, taken together, are expected to reduce pollutants in storm water and urban run-off to the MEP. The emphasis of the WQMP is pollution prevention through education, public outreach, planning, and implementation as source control BMPs first, and then structural and treatment control BMPs. ---PAGE BREAK--- 5. Environmental Analysis Page 5-80 • The Planning Center May 2005 The U.S. EPA recommends that, for NPDES-regulated municipal storm water discharges, effluent limitations should be expressed as BMPs or other similar requirements, rather than as numeric effluent limits. This approach involves implementing site design, source control and treatment control BMPs that reduce the discharge of pollutants in storm water to the maximum extent practicable (MEP). County of Orange The County of Orange also regulates storm run-off and water quality as the Principal Permittee under the General MS4 Permit and the Drainage Area Management Plan (DAMP). As previously mentioned, the City of Anaheim is a co-permittee under the General MS4 Permit and has legal authority for enforcing the terms of the permit in its jurisdiction. Applicants for development projects have the following responsibilities under the General MS4 permit: • Implementation of management programs, monitoring programs, implementation plans and all BMPs outlined in the DAMP within each respective jurisdiction, and take any other actions necessary to meet the MEP standard. • Coordination among internal departments and agencies to facilitate implementation of the General MS4 Permit and the DAMP. • Establishment and maintenance of adequate legal authority, as required by Federal Storm Water Regulations. • Storm drain system inspection and maintenance in accordance with criteria developed by the County of Orange. • Implementation of enforcement actions for illicit discharges to the MS4 system owned or operated by the co-permittee. In addition to these responsibilities, the permittees are required to submit a Water Quality Management Plan (WQMP) for new development or significant redevelopment projects, and a Storm Water Pollution Prevention Plan for all municipal construction projects with disturbed areas greater than one acre. The DAMP recognizes such approaches to reducing water pollution as prevention of pollutant introduction into the drainage system (source controls) and the removal of pollutants from the drainage system (structural best management practices). In order to comply with the DAMP, the City of Anaheim, as well as other cities in Orange County, has adopted water quality ordinances to effectively prohibit non-storm water discharges into the storm drain system and to reduce the discharge of pollutants into urban run-off. Examples of measures include: implementation of ordinances such as new development guidelines, residential recycling, street sweeping, household hazardous waste management, local ordinances, drainage system maintenance, public education, and litter control. In the following section a general overview of the state of water quality best management practices and current efforts and requirements for MS4 Permittees (City of Anaheim and County of Orange) are outlined. Water Quality Best Management Practices In water pollution control, best management practices (BMPs) refer to the best means available to control pollution of waterways from non-point sources. For storm water run-off, Section 402(p) of the CWA provides that MS4 permits must require controls to reduce the discharge of pollutants to the MEP. The MEP standard was clarified by the Federal courts, which held that MEP did not require that municipal storm water discharges strictly comply with numeric water quality standards (Defenders of Wildlife v. Browner, 191 F.3d ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-81 1159 (9th Cir. 1999)). The MEP standard is attained by the use of BMPs. For a particular permit, the U.S. EPA generally bases the MEP standard on technological feasibility, water quality objectives, and other site- specific considerations. BMPs are actions and procedures established to reduce the pollutant loadings in storm drain systems. The three main categories of BMPs are 1) site design (or planning and management), 2) source control and 3) treatment and structural control. Site Planning BMPs – Site design or planning management BMPs are used to conserve natural areas and minimize impervious cover, especially in those areas directly connected to receiving waters. Site planning BMP strategies include: • Minimizing Impervious Areas and Directly Connected Impervious Areas • Selection of Construction Materials and Design Practices • Conservation of Natural Areas • Protection of Slopes and Channels with Vegetative Cover Source Control BMPs – Source control BMPs are usually the most effective and economical in preventing pollutants from entering storm and non-storm run-off. Examples of source control BMPs that may be relevant to the project include: • Public Education/Participation activities that make information available to homeowner groups, associations, and municipalities for further distribution to homeowners and businesses. • Drain Inlet Stenciling – This includes community and resort education and litter control program Materials Management Activities – Materials management activities include: • Materials Use Controls, which include good housekeeping practices (storage, use and cleanup) when handling potentially harmful materials, such as cleaning materials, fertilizers, paint, pool chemicals and, where possible, using safer alternative products; • Material Exposure Controls, which prevent and reduce pollutant discharge to storm water by minimizing the storage of hazardous materials (such as pesticides) on site, storing materials in a designated area, installing secondary containment, conducting regular inspections, and training employees and subcontractors; • Material Disposal and Recycling, which includes storm drain system signs and stenciling with language to discourage illegal dumping of unwanted materials. Household hazardous waste and used oil recycling at collection centers and round-up activities are very productive BMPs. • Spill Prevention and Cleanup activities, which are directed toward reducing the risk of spills during the outdoor handling and transport of chemicals, and toward developing plans and programs to contain and rapidly clean up spills before they get into a storm drain system. This BMP also deals with the prevention and reduction of pollution from vehicle leaks and spills from vehicles during ---PAGE BREAK--- 5. Environmental Analysis Page 5-82 • The Planning Center May 2005 transport, as well as aboveground storage tanks. This BMP would be relevant to the construction of a gasoline station within the area designated for commercial uses, should one occur. • Illegal Dumping Controls, which consist of laws, ordinances and public education programs intended to prevent the dumping of waste products (solid waste/liquid waste and yard trash) into storm drain systems and watercourses. • Street and Storm Drain Maintenance activities that control the movement of pollutants and remove them from pavement through catch basin cleaning, storm drain flushing, street sweeping, and by regularly removing illegally dumped material from storm channels and creeks. Modification of channel/creek characteristics to improve hydraulics and increase pollutant removals also enhances aesthetic and habitat value. • Good Housekeeping practices including such activities as sweeping down driveways as opposed to washing them down. • Irrigation Controls and Management, Proper Storage and Application of Fertilizers and Pesticides. • Capture and re-use of storm water run-off and nuisance flows. Treatment and Structural BMPs – Treatment and structural control BMPs involve physical treatment of the run-off, usually through structural means. Treatment control BMPs are also referred to as structural BMPs throughout this report. A variety of treatment control measures have been utilized throughout the country for storm water quality; however, the effectiveness of these controls is highly dependent on local conditions, such as climate, hydrology, soils, groundwater conditions, and extent of urbanization. Some of the more common Treatment Controls are: • Oil/water separators, which are designed to remove one specific group of contaminants: petroleum compounds and grease. However, separators will also remove floating debris and settable solids. • Infiltration, which refers to a family of systems in which the majority of the run-off from small storms is infiltrated into the ground rather than discharged to a surface water body. Infiltration systems include: ponds, vaults, trenches, dry wells, porous pavement, and concrete grids. • Biofilters, which are of two types: swale and strip. A swale is a vegetated channel that treats concen- trated flow. A strip treats sheet flow and is placed parallel to the contributing surface. • Extended water quality detention basins that are dry between storms. During a storm, the basin fills and a bottom outlet releases the storm water slowly to provide time for sediments to settle. • Media filtration consists of a settling basin followed by a filter. Common filter are sands, peat/sand mixtures, and other filter media. • Hydrodynamic Separator Systems such as Gross Solids Removal Devices and Continuous Deflector Separation (CDS) Units • Multiple systems which are a combination of two or more of the preceding controls in a series; also referred to as a “treatment train.” ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-83 City of Anaheim The City of Anaheim is required by the Santa Ana Region Municipal Permit to minimize short and long-term impacts on receiving waters from new development and significant redevelopment to the maximum extent practicable. The City of Anaheim’s General Plan which was updated in May 25, 2004, provides a general overview of requirements for development/redevelopment within the City to ensure adequate watershed and water quality protection to receiving waters. Furthermore, the City’s Local Implementation Plan (November 2003) requires new development and significant redevelopment projects within the City to address storm water quality impacts through incorporation of permanent (post-construction) BMPs in project design. “New Development” includes land disturbing activities; structural development, including construction or installation of a building or structure; the creation of impervious surfaces; and land subdivision. “Significant Redevelopment” means development that would create or add at least 5,000 square feet of impervious surfaces on an already developed site as defined by the Municipal Permit. Water Quality Management Plans are required for private and public “New Development” and “Significant Redevelopment” projects. The City requires the project applicants to submit a Project WQMP at the project processing and permitting stages. In general, the shall follow guidelines set forth in the Model WQMP, provided in the Orange County DAMP Section 7. Per these guidelines, a combination of Source Control BMPs (routine nonstructural and routine structural BMPs) and Site Design BMPs are recommended to be incorporated in projects. The City also requires Treatment Control BMPs to be considered for all Priority projects. The City shall categorize various projects as priority or nonpriority using specific guidelines relating to the type of development, location and size. 5.5.2 Thresholds of Significance According to Appendix G of the CEQA Guidelines, a project would normally have a significant effect on the environment if the project would: HD-1 Violate any water quality standards or waste discharge requirements. HD-5 Create or contribute run-off water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted run-off. HD-6 Otherwise substantially degrade water quality. HD-7 Place housing within a 100-year flood hazard area as mapped on a Federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. HD-8 Place within a 100-year flood hazard area structures which would impede or redirect flood flows. HD-9 Expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. The Initial Study, included as Appendix A, substantiates that impacts associated with the following thresholds would be less than significant: HD-2 Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted). ---PAGE BREAK--- 5. Environmental Analysis Page 5-84 • The Planning Center May 2005 HD-3 Substantially alter the existing drainage pattern of the site or area, including through the altera- tion of the course of a stream or river, in a manner which would result in a substantial erosion or siltation on- or off-site. HD-4 Substantially alter the existing drainage pattern of the site or area, including through the altera- tion of the course of a stream or river, or substantially increase the rate or amount of surface run- off in a manner which would result in flooding on- or off-site. HD-10 Be subject to inundation by seiche, tsunami, or mudflow. These topics, therefore, will not be addressed in the following analysis. 5.5.3 Environmental Impacts The following impact analysis addresses thresholds of significance for which the Initial Study disclosed potentially significant impacts. The applicable thresholds are identified in parentheses after the impact statement. IMPACT 5.5-1: DEVELOPMENT PURSUANT TO THE PROPOSED PROJECT WOULD ALTER THE AMOUNT OF IMPERVIOUS SURFACES ON THE SITE AND MAY AFFECT SURFACE WATER FLOWS INTO DRAINAGE SYSTEMS WITHIN THE WATERSHED. (THRESHOLD HD-5) Impact Analysis: Since the Project Area is primarily developed, the Proposed Project will not result in substantial increases in the amount of impervious surfaces and is not expected to result in a significant increase in run-off volumes. However, some areas of The Platinum Triangle are not currently served by adequate drainage facilities. As a result, a drainage study (see Appendix F) has been prepared which identifies existing deficiencies and the improvements necessary to protect existing and future structures from a 100-year storm event. As shown on Figure 5.5-2, Proposed Drainage Improvements and Benefit Zones, The Platinum Triangle has been divided into zones to identify the general drainage requirements that should be anticipated with development within each zone. In addition to local facilities needed as part of a specific development, there is in many cases a facility requirement or deficiency need that must be addressed as part of the development. The following is a description of each Benefit Zone with a description of the local and associated support facility requirements. Proposed additional or replacement facility sizes are noted on Figure 5.5-2. ---PAGE BREAK--- ---PAGE BREAK--- 5. Environmental Analysis Page 5-86 • The Planning Center May 2005 This page intentionally left blank. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-87 The various developments that occur throughout The Platinum Triangle will be subject to mitigation of the storm drain deficiencies. The following discussion identifies mitigation elements within each Benefit Zone that are anticipated for regional facilities (within arterial highways or County owned facilities), City facilities (within arterial highways and major laterals), and local facilities (necessary for local drainage associated with a development). The stated requirements are base level mitigations and additional specific requirements may be added as conditions of approval or as conditions of The Platinum Triangle Standardized Development Agreement relative to a specific project. Please refer to Appendix F for a detailed description of the necessary improvements for each Benefit Zone. Benefit Zone SD – 1: This area is located on the westerly edge of The Platinum Triangle and is the only zone that is not tributary to Drainage District 26. It is part of District 25 where deficiencies are limited. Development within Zone SD-1 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require only those storm drain facilities within the zone necessary to meet the City’s drainage criteria. Drainage systems associated with the particular development are required. Benefit Zone SD – 2: This area is located within District 26 on either side of Lewis Street south of Cerritos Avenue. The Master Plan of Drainage for District 26 identified the need to construct a parallel pipe along Lewis Street from vicinity of Anaheim Boulevard past the northerly Platinum Triangle boundary. In addition to participation with the Lewis Street parallel drain project, development within Zone SD-2 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Lewis Street parallel pipe from the existing stub north of the I-5 Freeway to the connection necessary to serve the subject development within Zone SD-2. A new line in Howell east of Lewis Street is required. Additionally, lateral storm drains from the Lewis Street parallel pipe will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 3: This area is located within District 26 on the west side Lewis Street on either side of Anaheim Boulevard at the I-5 Freeway and Katella Avenue. The Master Plan of Drainage for District 26 identified the storm drain in Katella Avenue as being adequate. In addition to participation with the Lewis Street parallel drain project, development within Zone SD-3 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Lewis Street parallel pipe from the existing stub north of the I-5 Freeway to the junction of the Katella line. Additionally, lateral storm drains from the Katella line may be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 4: This area is located within District 26 between Lewis Street and State College Boule- vard and is bounded on the north by the railroad. The Katella Mixed-Use District forms a part of Benefit Zone SD-4. The Master Plan of Drainage for District 26 identified the storm drain in Katella Avenue as being adequate; however, it is likely that additional lateral lines from Katella Avenue into the zone will be needed to meet the surface flow limitations depending on grading and development configuration. In addition to participation with the Lewis Street parallel drain project, development within Zone SD-4 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Lewis Street parallel pipe from the existing stub north of the I-5 Freeway to the junction of the Katella line. ---PAGE BREAK--- 5. Environmental Analysis Page 5-88 • The Planning Center May 2005 Additionally, lateral storm drains from the Katella line will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 5: This area is located within District 26 between the realigned Lewis Street and State College Boulevard adjacent to Gene Autry Way. The Katella Mixed-Use District and the Gene Autry Mixed- Use District form parts of Benefit Zone SD-5. The storm drain construction completed with the widening of the I-5 Freeway and the lines installed in Gene Autry Way are adequate; however, it is likely that additional lateral lines from Gene Autry Way into the zone will be needed to meet the surface flow limitations depending on grading and development configuration. An extension of the Gene Autry line is planned over to State College Boulevard and north on State College Boulevard approximately 300 feet to eliminate the need for cross gutters. In addition to participation with the storm drain extension project, development within Zone SD-5 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone is part of the Gene Autry and Katella Mixed-Use Districts and will require participation in the construction of the Gene Autry line extension from the base of the freeway overcrossing to State College Boulevard. Property west of the connection point of the extension will not be responsible for the extension. Additionally, lateral storm drains from the Gene Autry line will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 6: This area is located within District 26 between the I-5 Freeway and State College Boulevard south of Gene Autry Way. The Gene Autry Mixed-Use District forms a part of Benefit Zone SD-6. The storm drain construction completed with the widening of the I-5 Freeway is adequate; however, it is likely that additional lateral lines from Santa Cruz Way into the zone will be needed to meet the surface flow limitations depending on grading and development configuration. Development within Zone SD-6 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone drains to the storm drain system installed with the I-5 Freeway widening and will be connected at Santa Cruz Way. This is part of the Gene Autry Mixed-Use District. Lateral storm drains from the Gene Autry line will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 7: This area is located within District 26 north of Orangewood Avenue and west of State College Boulevard. The Gateway Mixed-Use District and the Gene Autry Mixed-Use District form parts of Benefit Zone SD-7. The storm drain construction completed with the widening of the I-5 Freeway is ade- quate; however, an extension of the line in Orangewood Avenue will be necessary to eliminate cross gutters along State College Avenue. Development within Zone SD-7 will be evaluated generally based on a 10-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone north of Orangewood Avenue is part of the Gateway Mixed-Use District and will require participation in the construction of the Orangewood line extension from just east of the I-5 Freeway undercrossing to State College Boulevard then 300 feet north. Additionally, lateral storm drains from the Orangewood line will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 8: This area is located within District 27 on either side of State College Boulevard south of Cerritos Avenue. The area is directly tributary to the Southeast Anaheim Channel (E12). This facility has been established as being significantly undersized and a parallel RCB is planned to address the deficiency. It is likely that additional lateral lines into the zone will be needed to meet the surface flow limitations, depending on grading and development configuration. In addition to participation with the parallel RCB ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-89 project, development within Zone SD-8 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the connection point of the development facilities. Additionally, lateral storm drains from the RCB will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 9: This area is located within District 27 between the Southeast Anaheim Channel (E12) and the SR-57 Freeway. The area is tributary to the Southeast Anaheim Channel (E12) through a line in Howell Avenue. This facility has been established as being undersized and a replacement line is planned to address the deficiency. It is likely that additional lateral lines into the zone will be needed to meet the surface flow limitations, depending on grading and development configuration. In addition to participation with the parallel RCB project, development within Zone SD-9 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Howell Avenue line and the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the Howell Avenue line. Additionally, lateral storm drains will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 10: This area is located within District 27 adjacent to the the SR-57 Freeway and south of Cerritos Avenue. The area is tributary to the Southeast Anaheim Channel (E12) through a line in Cerritos Avenue. This facility has been established as being undersized and a replacement is planned as part of the RCB project to address the deficiency. Additional lateral lines into the zone are not anticipated. In addition to participation with the parallel RCB project, any development within Zone SD-10 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Cerritos Avenue line and the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the Cerritos Avenue line at Sunkist Avenue. Additionally, lateral storm drains will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 11: This area is located within District 27 at the intersection of State College Boulevard and Katella Avenue. Benefit Zone SD-11 is completely within the Katella Mixed-Use District. The area is directly tributary to the Southeast Anaheim Channel (E12). This facility has been established as being signi- ficantly undersized and a parallel RCB is planned to address the deficiency. Additional lateral lines into the zone are not anticipated. In addition to participation with the parallel RCB project, development within Zone SD-11 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the connection point of the development drainage facilities north of Katella Avenue. Additionally, lateral storm drains from the RCB will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 12: This area is located within District 27 south of the railroad and Katella Avenue within the northerly portion of Angel Stadium of Anaheim. The Stadium and the Katella Mixed-Use Districts form parts of Benefit Zone SD-12. The area is directly tributary to the Southeast Anaheim Channel (E12). This facility has been established as being significantly undersized and a parallel RCB is planned to address the deficiency. It is likely that additional lateral lines into the zone will be needed to meet the surface flow limita- tions depending on grading and development configuration. In addition to participation with the parallel RCB ---PAGE BREAK--- 5. Environmental Analysis Page 5-90 • The Planning Center May 2005 project, development within Zone SD-12 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the connection point of the development drainage facilities. There are several smaller lines planned, as well, and those associated with a particular development will be also constructed. Additionally, lateral storm drains from the RCB will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 13: This area is located within District 27 north of the railroad and south of the inter- section of Katella Avenue and the SR-57 Freeway. Benefit Zone SD-13 is completely within the Katella Mixed- Use District. The area is tributary to the Southeast Anaheim Channel (E12) through a lateral along Katella Avenue. This lateral and the channel facility have been established as being undersized, and a parallel line and RCB are planned to address the deficiencies. Additional lateral lines into the zone are not anticipated. In addition to participation with the parallel RCP and RCB projects, development within Zone SD-13 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Katella Avenue line and the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the Katella Avenue line. Additionally, lateral storm drains will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 14: This area is located within District 27 north of Orangewood Avenue between State College Boulevard and the SR-57 Freeway over the southerly portion of the Angel Stadium of Anaheim parking area. The Stadium and Gateway Mixed-Use Districts form parts of Benefit Zone SD-14. The area is directly tributary to the Southeast Anaheim Channel (E12) through a lateral along Orangewood Avenue and its extensions onto the planned ring road. This lateral and the channel facility have been established as being undersized and a parallel line and RCB are planned to address the deficiencies. It is likely that additional lateral lines into the zone will be needed to meet the surface flow limitations depending on grading and development configuration. In addition to participation with the parallel RCP and RCB projects, development within Zone SD-14 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Orangewood Avenue line and the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the Orangewood Avenue line. The extensions of the lines into a conceptual ring road will be part of development mitigation within SD-14. Additionally, lateral storm drains will be necessary to meet the surface flow requirements stated in the City’s drainage criteria. Benefit Zone SD – 15: This area is located within District 27 east of State College Boulevard and south of Orangewood Avenue. Benefit Zone SD-15 is partially within the Gateway Mixed-Use District. The area is directly tributary to the Southeast Anaheim Channel (E12). This facility has been established as being significantly undersized and a parallel RCB is planned to address the deficiency. Additional lateral lines into the zone are not anticipated but may be necessary to meet the surface flow limitations depending on grading and development configuration. In addition to participation with the parallel RCB project, development within Zone SD-15 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require participation in the construction of the Southeast Anaheim parallel RCB from the Santa Ana River north to the junction of the connection point of the development drainage facilities. Additionally, lateral storm drains from the RCB may be necessary to meet the surface flow requirements stated in the City’s drainage criteria. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-91 Benefit Zone SD – 16: This area is located within District 27 adjacent to the SR-57 Freeway and south of Orangewood Avenue. The area is directly tributary to the Santa Ana River. Additional lateral lines into the zone are not anticipated but may be necessary to meet the surface flow limitations depending on grading and development configuration. Development within Zone SD-16 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require only those local storm drain facilities within the zone necessary to meet the City’s drainage criteria. Benefit Zone SD – 17: This area is located within District 27 adjacent to the SR-57 Freeway and south of Cerritos Avenue. The area is directly tributary to the Santa Ana River. Additional lateral lines into the zone are not anticipated but may be necessary to meet the surface flow limitations depending on grading and development configuration. Development within Zone SD-17 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require only those local storm drain facilities within the zone necessary to meet the City’s drainage criteria. Benefit Zone SD – 18: This area is located within District 27 adjacent to the SR-57 Freeway and north of Katella Avenue. Benefit Zone SD-18 is partially within the Arena Mixed-Use District. The area is directly tributary to the Santa Ana River. Additional lateral lines into the zone are not anticipated but may be neces- sary to meet the surface flow limitations depending on grading and development configuration. Development within Zone SD-18 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require only those local storm drain facilities within the zone necessary to meet the City’s drainage criteria. Benefit Zone SD – 19: This area is located within District 27 adjacent to the Santa Ana River and south of Cerritos Avenue. Currently, this area is primarily being used as parking lot for Arrowhead Pond of Anaheim, and the future development configuration is unknown. The area is directly tributary to the Santa Ana River. Additional lateral lines into the zone are not anticipated but may be necessary to meet the surface flow limitations, depending on grading and development configuration. Development within Zone SD-19 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: Development within this zone will require only those local storm drain facilities within the zone necessary to meet the City’s drainage criteria. Benefit Zone SD – 20: This area is located within District 27 between the Santa Ana River and the SR-57 Freeway south of Katella Avenue. Currently, this area is primarily being used as County maintenance complex, and the future development configuration is unknown. The area is directly tributary to the Santa Ana River. Additional lateral lines into the zone are not anticipated but may be necessary to meet the surface flow limitations, depending on grading and development configuration. The Douglass Street railroad underpass includes an outdated pump station that will need to be completely replaced. Development within Zone SD-20 will be evaluated generally based on a 25-year storm frequency and the appropriate surface flow limitations. Required Improvements: The Douglass Street pump station will have to be replaced. Otherwise, develop- ment within this zone will require only those local storm drain facilities within the zone necessary to meet the City’s drainage criteria. ---PAGE BREAK--- 5. Environmental Analysis Page 5-92 • The Planning Center May 2005 Future development within The Platinum Triangle will have to address the existing storm drain deficiencies and incorporate into their plans additional local systems to meet the City’s current drainage criteria in terms of street flooding limits and other surface flow parameters. Mitigation measures have been identified below which will adequately mitigate the impacts associated with the Proposed Project. IMPACT 5.5-2: PORTIONS OF THE PROJECT AREA PROPOSED FOR DEVELOPMENT ARE LOCATED WITHIN A 100-YEAR FLOOD HAZARD AREA. (THRESHOLDS HD-7 AND HD-8) Impact Analysis: The Project Area is located within a Federal Emergency Management Agency (FEMA) flood insurance study area within Zone A99 and X designation. The majority of the Project Area is located in Zone X which lies in a 100-Year to 500-Year Flood Zone with flooding below one foot (see previous Figure 5.5-1). According to the Orange County Flood Control District (OCFCD), the Southeast Anaheim Channel and the Spinnaker Storm Drain have been determined to be deficient to convey discharges associated with 100-year storm event. In addition to the widening of the Santa Ana River within the project vicinity, improve- ments completed under the Santa Ana River Mainstem Project include construction of Seven Oaks Dam and improvements to Prado Dam and channel facilities. Flooding levels are expected to occur at one foot. In accordance with the City of Anaheim’s Flood Hazard Reduction Ordinance, detailed designs for future habitable structures associated with the project implementation would be constructed above the lands at which a 100-year flood would occur on-site. All future projects within The Platinum Triangle must comply with all Federal and local regulatory requirements associated with Flood Hazard areas. In addition, mitigation measure 5.5-1 has been identified to reduce impacts to the Proposed Project. IMPACT 5.5-3: DURING THE CONSTRUCTION PHASE OF THE PROPOSED PROJECT, THERE IS THE POTENTIAL FOR SHORT-TERM UNQUANTIFIABLE INCREASES IN POLLUTANT CONCENTRATIONS FROM THE SITE. AFTER PROJECT DEVELOPMENT, THE QUALITY OF STORM RUN-OFF (SEDIMENT, NUTRIENTS, METALS, PESTICIDES, PATHOGENS, AND HYDROCARBONS) MAY BE ALTERED. (THRESHOLDS HD-1 AND HD-6) Impact Analysis: In order to address potential storm water quality impacts of the project, an assessment of existing conditions is necessary. This assessment is mainly based on published pollutant concentrations for various land uses. Specifically, it is based on the County of Los Angeles’s Integrated Receiving Water Impacts Report (1994-2000). This section provides an overview of existing storm water quality conditions for the Proposed Project and includes a discussion of typical pollutants associated with the project land uses (designated as “pollutants of concern”), event mean concentrations (EMCs), and comparison with regulatory standards. Pollutants of Concern Pollutants of concern typically consist of any pollutants that exhibit one or more of the following characteristics: • Current loadings or historic deposits of the pollutant are impacting the beneficial uses of a receiving water, • Elevated levels of the pollutant are found in sediments of a receiving water and/or have the potential to bioaccumulate in organisms therein, or • The detectable inputs of the pollutant are at concentrations or loads considered potentially toxic to humans and/or flora and fauna. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-93 Pollutants of concern for the Proposed Project were chosen based upon typical pollutants found in urban run-off associated with the existing and proposed land uses for the Project Area as well as the regulatory guidelines discussed previously. Table 5.5-1 provides a summary of existing and proposed categories of land uses for the Project Area. Table 5.5-1 Comparison of General Land Use Changes1 Land Use Existing (acres) Proposed (acres) Light Industrial 364.5 130.8 Commercial 362.52 214.83 Vacant/Open Space 16.2 2.3 Mixed-Use — 375.5 Public-Institutional — 19.8 Total 743.2 743.2 Notes: 1 Summarized and categorized based on fax and email summaries from The Planning Center (January 2005). 2 Includes Convention Center/Stadium Area, Lodging, Office, Outdoor Use, Quasi Public/Governmental, Retail/Service and Service Station. 3 Office-Low and Office-High. The project land uses are likely to generate the following broad categories of constituents: Sediment: Soils or other surface materials eroded and then transported or deposited by the action of wind, water, ice, or gravity. Sediments can increase turbidity, clog fish gills, reduce spawning habitat, lower young aquatic organisms survival rates, smother bottom dwelling organisms, and suppress aquatic vegetation growth. Nutrients: Inorganic substances, such as nitrogen and phosphorus. They commonly exist in the form of mineral salts that are either dissolved or suspended in water. Primary sources of nutrients in urban run-off are fertilizers and eroded soils. Excessive discharge of nutrients to water bodies and streams can cause excessive aquatic algae and plant growth. Such excessive production, referred to as cultural eutrophication, may lead to excessive decay of organic matter in the water body, loss of oxygen in the water, release of toxins in sediment, and the eventual death of aquatic organisms. Metals: Raw material components in nonmetal products such as fuels, adhesives, paints, and other coatings. The primary sources of metal pollution in storm water are typically commercially available metals and metal products. Metals of concern include cadmium, chromium, copper, lead, mercury, and zinc. Lead and chromium have been used as corrosion inhibitors in primer coatings and cooling tower systems. At low concentrations naturally occurring in soil, metals are not toxic. However, at higher concentrations, certain metals can be toxic to aquatic life. Humans can be impacted from contaminated groundwater resources, and bioaccumulation of metals in fish and shellfish. Environmental concerns, regarding the potential for release of metals to the environment, have already led to restricted metal usage in certain applications. Organic Compounds: Carbon-based (commercially available or naturally occurring) substances found in pesticides, solvents, and hydrocarbons. Organic compounds can, at certain concentrations, indirectly or directly constitute a hazard to life or health. When rinsing off objects, toxic levels of solvents and cleaning ---PAGE BREAK--- 5. Environmental Analysis Page 5-94 • The Planning Center May 2005 compounds can be discharged to storm drains. Dirt, grease, and grime retained in the cleaning fluid or rinse water may also adsorb levels of organic compounds that are harmful or hazardous to aquatic life. Trash and Debris: General waste products (such as paper, plastic, packing foam, aluminum materials, leaves, grass cuttings, and food waste) on the landscape. The presence of trash and debris may have a significant impact on the recreational value of a water body and aquatic habitat. Excess organic matter can create a high biochemical oxygen demand in a stream and thereby lower its water quality. Also, in areas where stagnant water exists, the presence of excess organic matter can promote septic conditions resulting in the growth of undesirable organisms and the release of odorous and hazardous compounds such as hydrogen sulfide. Oxygen-Demanding Substances: Biodegradable organic material as well as chemicals that react with dissolved oxygen in water to form other compounds. Proteins, carbohydrates, and fats are examples of biodegradable organic compounds. Compounds such as ammonia and hydrogen sulfide are examples of oxygen-demanding compounds. The oxygen demand of a substance can lead to depletion of dissolved oxygen in a water body and possibly the development of septic conditions. Oil and Grease: High-molecular weight organic compounds. The primary sources of oil and grease are petroleum hydrocarbon products, motor products from leaking vehicles, esters, oils, fats, waxes, and high molecular-weight fatty acids. Introduction of these pollutants to the water bodies are very possible due to the wide uses and applications of some of these products in municipal, residential, commercial, industrial, and construction areas. Elevated oil and grease content can decrease the aesthetic value of the water body, as well as the water quality. Bacteria and Viruses: Ubiquitous microorganisms that thrive under certain environmental conditions. Their proliferation is typically caused by the transport of animal or human fecal wastes from the watershed. Water containing excessive bacteria and viruses can alter the aquatic habitat and create a harmful environment for humans and aquatic life. Also, the decomposition of excess organic waste causes increased growth of undesirable organisms in the water. Pesticides: Chemical compounds commonly used to control nuisance growth of organisms. Excessive application of a pesticide may result in run-off containing toxic levels of its active component. Different land uses may generate different constituents, as shown in Table 5.5-2: ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-95 Table 5.5-2 Constituents Generated by Existing and Proposed Land Uses Constituents Land Uses Sediments Nutrients Heavy Metals Organic Substances Trash and Debris Oxygen-Demanding Substances Oils and Grease Bacteria and Viruses Pesticides Mixed-Use 9 9 9 9 9 9 9 9 9 Office – High 9 9 9 9 9 9 9 9 Office – Low 9 9 9 9 9 9 Industrial 9 9 9 9 9 9 9 9 9 Furthermore, these constituents were chosen for evaluation because they are commonly found in urban run- off and tend to be more amenable to treatment with urban Best Management Practices (BMPs). Furthermore, reliable land use data is available for these constituents for assessing water quality impacts. Event Mean Concentrations Storm water run-off water quality will vary within a storm event depending on the rainfall pattern and storm duration (intra-event variability). Because of this variability, water quality concentrations are often expressed in the form of Event Mean Concentrations (EMCs), which are the concentrations that would be measured if the entire run-off from an event were captured and mixed before sampling. The extensive use of EMCs to characterize storm water quality was initiated in the U.S. EPA’s Nationwide Urban Run-off Program (NURP) (U.S. EPA, Nationwide Urban Run-off Program, Executive Summary, 1983). Storm water run-off quality will also vary from storm to storm (inter-event variability) depending on a variety of conditions, including the characteristics of the storm event, the time between storms, conditions in the watershed, and time of year. This latter effect is particularly important in semi-arid environments where there is a dry and wet season, and where soil saturation and run-off vary greatly depending on the season and changes in long-term climate cycles. Because of this intra- and inter-event variability, storm water quality is often expressed and evaluated statistically. The EMCs used to characterize the existing (and developed) storm water quality for the proposed Project Area are shown in Table 5.5-3. This data was used to provide EMCs for the existing and proposed land uses because the monitored land uses were representative of the Proposed Project’s land uses and the data evaluates storm water quality unique to these specific land uses. Comparison of existing versus proposed conditions is only possible when statistically determinate EMCs are available for all land uses listed, therefore, only the following pollutants are considered: • Oxygen-Demanding Substances (COD, chemical oxygen demand, is used) • Sediment (TSS, total suspended solids, is used) ---PAGE BREAK--- 5. Environmental Analysis Page 5-96 • The Planning Center May 2005 • Metals (copper, lead, and zinc are used) • Nutrients (TKN, total Kjeldahl nitrogen, is used) In order to determine expected existing pollutant concentrations for the Project Area without having actual monitoring data, the EMCs from Table 5.5-3 have been prorated based on acreage of existing land uses, as shown in Table 5.5-1. Results are summarized in Table 5.5-4. Table 5.5-3 EMCs Based on Land Use Pollutant EMCs Dissolved Metals Land Use1 Oxygen- Demanding Substances COD (mg/l) Sediment TSS (mg/l) Cu (μg/l) Pb4 (μg/l) Zn (μg/l) Nutrients TKN (mg/l) Light Industrial 80 240 20 4.5 407 3.0 Commercial 98 66 14 4.8 152 3.4 Vacant/Open Space 17 186 8.644 ND6 25.85 0.79 Mixed-Use2 81 64.5 13 3.8 117.5 2.95 Public-Institutional3 37 95 13 1.3 66 1.6 Notes: 1 EMCs for each land use are based on LA County Integrated Receiving Water Impacts Report (1994–2000), unless noted. 2 Mixed-Use is not a land use designation utilized in the LA County Report; EMCs are taken to be roughly equivalent to the average of EMCs for Commercial and Mixed Residential land uses (except where EMCs were reported as “statistically invalid data” for one land use; then the EMC for the other land use was used), based on similarity in pollutants generated. 3 Public-Institutional is not a land use designation utilized in the LA County Report; EMCs are taken to be roughly equivalent to EMCs for Educational land uses. 4 EMCs reported by LA County Report are shown as “statistically invalid data”. Therefore, EMCs as reported for Total Pb were used in computing the estimated dissolved fraction of Pb based on information provided by Sansalone, et al. (1997). 5 EMCs reported by LA County Report are shown as “statistically invalid data”. Therefore, EMCs as reported for Total Cu and Total Zn were used in computing the estimated dissolved fractions based on fractions computed for other land uses (such as residential) from the LA County data. 6 ND = Not enough data detected above limits for both Dissolved and Total Pb. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-97 Table 5.5-4 Expected Existing Pollutant Concentrations Pollutant EMCs Metals Land Use (acre) Oxygen- Demanding Substances COD (mg/l) Sediment TSS (mg/l) Cu (μg/l) Pb (μg/l) Zn (μg/l) Nutrients TKN (mg/l) Light Industrial 364.5 49 39.2 117.6 9.8 2.2 199.4 1.5 Commercial 362.5 49 48.0 32.3 6.9 2.4 74.5 1.7 Vacant/Open Space 16.2 2 0.34 3.7 0.17 — 0.52 0.02 Total 743.2 100 87.5 153.6 16.9 4.6 274.4 3.2 Comparison with Water Quality Criteria The water quality criteria comparison includes the CTR criteria for trace metals and the water quality object- tives specified in the Basin Plan. However, there are no direct Basin Plan numerical objectives for the constituents listed on Table 5.5-4 applicable to the Project Area. This section provides a comparison of the expected existing pollutant concentrations to the CTR Criteria. Table 5.5-5 provides a comparison of the existing metal concentrations with the CTR criteria. As shown, the estimated pollutant concentrations in existing site conditions are below the CTR criteria with the exception of the estimated dissolved zinc concentration which is estimated to be above the limits at 200 mg/l hardness. Table 5.5-5 Estimated Dissolved Metals Concentrations Existing Conditions Compared to CTR Criteria California Toxics Rule – Freshwater Criteria (Dissolved Metals) 400 mg/l Hardness 200 mg/l Hardness Parameter Units Existing Conditions Chronic Acute Chronic Acute Dissolved Copper ug/L 16.9 31 52 17 27 Dissolved Lead ug/L 4.6 19 480 7.7 200 Dissolved Zinc ug/L 274.4 390 390 220 220 Construction Storm Water Quality Impacts Pollutant export could increase significantly during the project construction. Initial clearing and grading operations during construction exposes much of the surface soils. Unless adequate erosion controls are installed and maintained at the site, significant quantities of sediment may be delivered to the receiving water, along with attached soil nutrients and organic matter. Erosion and sedimentation caused by construction activities are dependent upon climatic and site con- ditions, as well as the degree of disturbance and type of construction project. Sediment resulting from the excessive erosion of disturbed soils is the primary pollutant of concern. Other pollutants of concern ---PAGE BREAK--- 5. Environmental Analysis Page 5-98 • The Planning Center May 2005 are metals, nutrients, soil additives, pesticides, construction chemicals, and miscellaneous waste from construction sites. The following is brief overview of the potential construction type pollutants. Nutrients: Nitrogen, phosphorous, and potassium are the major nutrients used for fertilizing new landscape at construction sites. Heavy use of commercial fertilizers can result in discharge of nutrients to water bodies where they may cause excessive algae growth. Trace Metals: Over half of the metal load carried in storm water is associated with sediments (Schuler, 1987). Many of the uses during a construction project such as galvanized metals, paint, or preserved wood may contain metals. If uncontrolled, these metals may enter the storm water and impact the receiving waters. Pesticides: Unnecessary or improper application of pesticides may result in direct surface water contamina- tion and/or indirect pollution by transport off soil surfaces into surface water. Other Toxic Chemicals: If improperly stored and/or disposed of, organic compounds (such as adhesives, cleaners, sealants, and solvents) that may be used at construction sites will have a significant impact on receiving waters. Miscellaneous Wastes: These may include wash water from concrete mixers, paints and painting equipment cleaning activities, solid wastes from land clearing activities, wood and paper material from packaging of building material, and sanitary wastes. Discharge of these wastes can lead to polluted waterways. Comparison with Existing Condition Concentrations Table 5.5-6 summarizes the expected changes in pollutant concentrations for the proposed condition, with and without Best Management Practices (BMPs). The BMPs are discussed in Section 5.5.1, Environmental Setting. Water Quality BMPs and their pollutant removal efficiencies are summarized on Table 5.5-7. Even without any mitigation, concentrations of all considered constituents are predicted to decrease for the project under the proposed land use conditions as compared to existing conditions. The decreases in concentrations are the result of changes in land use, which in general will result in less light industrial/ commercial and more mixed uses. With implementation of the recommended mitigation measures, these pollutant concentrations are expected to further decrease and the project water quality impacts (if any) fully mitigated. Therefore, with proper implementation of the recommended BMPs (structural and nonstructural), project water quality conditions are expected to be better than existing conditions and impacts would be less than significant. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-99 Table 5.5-6 Expected Changes in Pollutant Concentrations Proposed Condition – Mitigated and Unmitigated Pollutant EMCs Oxygen- Demanding Substances Sediment Metals Nutrients COD TSS Cu Pb Zn TKN (mgl) % Incr. (mg/l) % Incr. (μg/l) % Incr. (μg/l) % Incr. (μg/l) % Incr. (mg/l) % Incr. Existing 87.5 — 153.6 — 16.9 — 4.6 — 274.4 — 3.2 — Proposed (Unmitigated) 84.4 97.5 –37% 14.6 –14% 4.1 –11% 178.2 –35% 3.1 Mitigated w/Biofiltration (Swale) 27.9 –68% 18.5 –88% 7.2 –57% 1.4 –70% 51.7 –81% 1.9 –41% Mitigated w/ HSS 84.4 77.0 –50% 14.6 –14% 3.1 –33% 147.9 –46% 3.0 Mitigated w/Drain Inserts 32.9 –62% 66.3 –57% 13.2 –22% 4.1 –11% 178.2 –35% 3.1 Table 5.5-7 Removal Efficiencies for Selected BMPs Removal Efficiencies Oxygen-Demanding Substances Sediment Metals Nutrients COD TSS Cu Pb Zn TKN Swales 67% 81% 51% 67% 71% 38% HSS 0% 21% — 24% 17% 5% Catch Basin Inserts 61% 32% 9.5% — — — IMPACT 5.5-4: THE PROJECT SITE IS LOCATED WITHIN THE INUNDATION AREA OF THE PRADO DAM. (THRESHOLD HD-9) Impact Analysis: The City of Anaheim is located within the Prado Dam inundation area. The Prado Dam and reservoir are located approximately 2.5 miles east of Anaheim in Riverside County. The Prado Dam was completed in 1941 and was intended to provide flood protection to the Lower Santa Ana River Basin. In addition, Prado Dam works in tandem with Seven Oaks Dam, which is also located on the Santa Ana River in the upper Santa Ana Canyon about eight miles northeast of the City of Redlands in San Bernardino County and 40.3 miles upstream from Prado Dam, to provide flood protection to Orange County. During the early part of each flood season, run-off will be stored behind the dam in order to build a debris pool to protect the outlet works. Small releases will be made on a continual basis in order to maintain the water supply. During a flood, Seven Oaks Dam will store water destined for Prado Dam for as long as the reservoir pool at Prado Dam is rising. When the flood threat at Prado Dam has passed, Seven Oaks will begin to ---PAGE BREAK--- 5. Environmental Analysis Page 5-100 • The Planning Center May 2005 release its stored flood water at a rate which does not exceed the channel capacity. At the end of each flood season, the reservoir at Seven Oaks will be gradually drained and the Santa Ana River will flow through the Project Area unhindered. Construction of Seven Oaks Dam and improvements to the Prado Dam and channel facilities are being implemented under the Santa Ana Mainstream Project, con- structed by the U.S. Army Corps of Engineers, Los Angeles District. The channel capacity has increased to over 30,000 cfs, in addition to an increase in the storage and release capabilities. These improvements have enabled Prado Dam to take full advantage of the improved channel capacity down- stream and increase the level of flood protection to communities within the Santa Ana River floodplain. As a result, only two small portions of the Project Area are located within the 100-hear floodplain (see Figure 5.5-1). 5.5.4 Cumulative Impacts On-going development within the Santa Ana River watershed would alter existing drainage conditions and increase surface water flows. However, the large majority of the watershed is already built-out. As a result, surface flows are not expected to increase significantly. In addition, future projects will be required to provide necessary drainage improvements to protect existing and future structures. As a result, no significant cumulative impacts to the Santa Ana River watershed are anticipated. The nature of the land uses involved, the manner in which run-off is controlled prior to discharge, and the manner in which urban wastes are managed and prevented from becoming part of the storm water run-off would all affect the significance of such cumulative water quality impacts. The Santa Ana Basin Plan is designed to preserve and enhance water quality and protect the beneficial uses of all regional waters within the Region. The Plan includes narrative and numerical water quality objectives for several constituents and parameters that must be attained or maintained to protect the designated beneficial uses of the river and its tributaries. The Regional Water Quality Control Board, therefore, has the authority to regulate water quality in Orange County, including the Santa Ana River Watershed, and it is the responsibility of the local jurisdic- tions Orange County and City of Anaheim) to ensure that future development within the watershed would be subject to the same or similar types of water quality requirements as the Proposed Project. Therefore, with these requirements in place, cumulative water quality impacts are considered less than significant. 5.5.5 Existing Regulations and Standard Conditions • Future projects shall comply with the Storm Drain Impact and Improvement Fee in the Anaheim Municipal Code. The Fee is designed to implement the goals in the Master Plan of Drainage for the South Central Area, the Anaheim Resort Specific Plan, the City of Anaheim General Plan, and the Sanitary Sewer and Storm Drain Financial Implementation Plan for the South Central City Area, mitigating flooding and storm drainage impacts. • The property owner/developer shall demonstrate project conformance with the City's Flood Hazard Reduction Ordinance No. 4136 (Chapter 17.28 of the Anaheim Municipal Code) to the City of Anaheim Public Works Department, which pertains to properties that lie within the "A99" Special Flood Hazard Zone (Anaheim Floodplain Overlay Zone). • Future property owners/developers within the Mixed-Use Area of The Platinum Triangle shall be required to pay impact fees relating to storm drain improvements in accordance with the Standardized Development Agreement for The Platinum Triangle. ---PAGE BREAK--- 5. Environmental Analysis The Platinum Triangle Subsequent EIR City of Anaheim • Page 5-101 5.5.6 Level of Significance Before Mitigation Upon implementation of regulatory requirements and standard conditions of approval, Impacts 5.5-2 and 5.5-4 would be less than significant. Impacts 5.5-1 and 5.5-3 are considered potentially significant and require mitigation measures. 5.5.7 Mitigation Measures Applicable Measures from MMP No. 106 The following mitigation measures were included in Mitigation Monitoring Program No. 106 for The Platinum Triangle and were previously adopted as part of the Stadium Area Master Land Use Plan EIR and the General Plan and Zoning Code Update EIR No. 330. Some of these measures are being revised as part of this Subsequent EIR. Additions are shown in bold and deletions are indicated in strikeout format. 5.5-1 The property owner/developer shall submit a detailed drainage plan to the City of Anaheim Public Works Department and the Orange County Flood Control District for review and approval. This drainage plan shall be in conformance with the City's Master Plan of Drainage, Drainage District Map 27. The drainage plan shall demonstrate that run-off will effectively be conveyed to the surrounding off-site drainage system and run-off rates would not affect receiving drainage facilities. More specifically, the drainage plan shall examine the existing and the proposed conditions within the project limits and detail drainage deficiencies based upon the water elevations of the Santa Ana River in accordance with Drainage District Map 27. All drainage components shall be designed to the minimum requirements of the City and County. [Note: This mitigation measure has been replaced by Mitigation Measure 5.5-4, listed below.] 5.5-1 Prior to issuance of a grading permit, the property owner/developer shall submit plans documenting that the design of all aboveground structures (with the exception of parking structures) shall be at least three feet higher that the 100-year flood zone, where applicable, unless otherwise required by the City Engineer. All structures below this level shall be flood- proofed to prevent damage to property or harm to people. 5.5-2 The property owner/developer shall demonstrate project conformance with the City's Flood Hazard Reduction Ordinance No. 4136 (Chapter 17.28 of the Anaheim Municipal Code) to the City of Anaheim Public Works Department, which pertains to properties that lie within the "A99" Special Flood Hazard Zone (Anaheim Floodplain Overlay Zone.) [Note: This mitigation measure is an existing regulatory requirement as identified above and has therefore been deleted.] 5.5-2 At least 90 days prior to the initiation of grading activities, for projects greater than one five acre s, an NOI shall be filed with the Regional Water Quality Control Board by the property owner/developer pursuant to State and Federal National Pollution Discharge Elimination System (NPDES) requirements. As part of the NOI, a Surface Water Pollution Prevention Plan shall be prepared. The property owner/developer shall also prepare and submit to a Water Quality Management Plan (WQMP) in accordance with the City's municipal NPDES requirements and the Orange County Drainage Area Management Plan. The in conjunction with the WQMP, will describe the structural and nonstructural BMPs that will be implemented during construction (short-term) within the Project Area as well as BMPs for long- term operation of the Project Area. Long-term measures could include, but may not be limited to, street sweeping, trash collection, proper materials storage, designated wash areas connected to sanitary sewers, filter and grease traps, and clarifiers for surface parking areas. The BMPs selected shall be consistent with the Water Quality Technical Report set forth in for the Proposed Project (Appendix G) of SEIR No. 332. ---PAGE BREAK--- 5. Environmental Analysis Page 5-102 • The Planning Center May 2005 Additional Mitigation 5.5-3 The City Engineer shall review the location of each project to determine if it is located within an area served by deficient drainage facilities, as identified in The Platinum Triangle Drainage Study. If the project will increase storm water flows beyond those programmed in the appropriate master plan drainage study for the area or if the project currently discharges to an existing deficient storm drain system or will create a deficiency in an existing storm drain, the property owner/developer shall be required to guarantee mitigation of the impact to adequately serve the area to the satisfaction of the City Engineer and City Attorney’s Office. The property owner/developer shall be required to install the drainage facilities, as required by the City Engineer to mitigate the impacts of the proposed development based upon the Development Mitigation within Benefit Zones (Appendix E of The Platinum Triangle Drainage Study), prior to acceptance for maintenance of public improvements by the City or final Building and Zoning inspection for the building/structure, whichever occurs first. Additionally, the property owner/developer shall participate in the Infrastructure Improvement (Fee) Program, if adopted for the Project Area, as determined by the City Engineer, which could include fees, credits, reimbursements, construction, or a combination thereof. 5.5.8 Level of Significance After Mitigation With incorporation of the mitigation measures listed above, all potential impacts related to hydrology and water quality would be reduced to a less than significant level.