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HomeMy WebLinkAboutOCSD 99-19RESOLUTION NO.OCSD 99-19 MAKING CERTAIN FINDINGS RELATING TO SIGNIFICANT ENVIRONMENTAL EFFECTS IDENTIFIED IN THE FINAL PROGRAM ENVIRONMENTAL IMPACT REPORT FOR IMPLEMENTATION OF THE 1999 STRATEGIC PLAN; ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM;ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS;AND AUTHORIZING THE FILING OF A NOTICE OF DETERMINATION RE SAID PROJECT A RESOLUTION OF THE BOARD OF DIRECTORS OF THE ORANGE COUNTY SANITATION DISTRICT MAKING CERTAIN FINDINGS RELATING TO SIGNIFICANT ENVIRONMENTAL EFFECTS IDENTIFIED IN THE DRAFT PROGRAM ENVIRONMENTAL IMPACT FOR THE DRAFT PROGRAM ENVIRONMENTAL IMPACT REPORT FOR IMPLEMENTATION OF THE 1999 STRATEGIC PLAN (“THE PROJECT”);ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM; ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS;AND AUTHORIZING THE FILING OF A NOTICE OF DETERMINATION RE SAID PROJECT WHEREAS,the Board of Directors of the Orange County Sanitation District (OCSD),hereinafter referred to as uDistricr is presently considering the approval of the 1999 Strategic Plan,a master plan for new facilities through the year 2020,herein referred as the Strategic Plan;and, WHEREAS,the District is the lead agency for the preparation and consideration of environmental documents for the Strategic Plan,pursuant to the California Environmental Quality Act of 1970,as amended,(“CEQA”),the State of California CEQA Guidelines and District CEQA procedures;and, WHEREAS,to assess the Strategic Plan’s environmental impacts objectively,the District has caused to be prepared a Draft Program Environmental Impact Report (EIR) to assess the significant environmental impacts,mitigation measures,and alternatives associated with the Strategic Plan;and, WHEREAS,the District has consulted with other public agencies and the general public,giving them an opportunity to comment on the Draft Program EIR as required by CEQA;and, WHEREAS,on July 21,1999,the District held a duly-noticed public hearing to provide a further opportunity for the general public to comment on and respond to the Draft Program EIR;and, WHEREAS,the District has objectively evaluated the comments from public agencies and persons who reviewed the Draft Program EIR;and, 1 WHEREAS,the comments and recommendations received on the Draft Program EIR,either in full or in summary,together with the District’s responses to significant environmental concerns raised in the review and consultation process,have been included in the Final Program EIR;and, WHEREAS,said Final Program EIR consisting of the Draft Program EIR,Technical Appendix,and the Response to Comments have been presented to the members of the District Board of Directors for review and consideration prior to the final approval of,and commitment to,the Strategic Plan. NOW,THEREFORE,the Board of Directors of Orange County Sanitation District, DOES HEREBY RESOLVE,DETERMINE AND ORDER: 1.That the proposed Strategic Plan Final Program EIR has identified a number of significant or potentially significant environmental effects.These impacts are identified in the Final Program EIR. 2.That the Board of Directors do further find that changes or alterations have been required in,or incorporated into,the proposed project,which avoid or substantially lessen significant environmental effects,all identified in the Final Program EIR. 3.That the Draft Program EIR includes findings concerning the Scenario 2,the “Preferred Alternative”;significant unavoidable adverse impacts;significant impacts reduced to less than significant levels by mitigation measures incorporated into the Strategic Plan,attached as Attachment A. 4.That the District will implement mitigation measures to reduce significant impacts to less-than significant levels as identified as Attachment B. 5.That the Board of Directors hereby makes Findings of Fact concerning the Project Alternatives,identified as Attachment C. 6.That the Board Secretary is authorized and directed to file the Notice of Determination and any other documents in accordance with the requirements of CEQA and the District’s CEQA procedures. PASSED AND ADOPTED at a regular meeting held October 27,1999. ATTEST:1 Board ~cretary ~ ~\radon\data1\wp.dta~.admin~BS\ResoIutions\1999\OcsD99-19.doc ) 2 ATTACHMENT A FINDINGS CONCERNING THE PREFERRED ALTERNATIVE The Preferred Alternative in the 1999 Strategic Plan is Treatment Scenario 2 —providing sufficient secondary treatment to meet the needs of the Groundwater Replenishment (GWR) System Project being undertaken jointly by the District and the Orange County Water District (OCWD)and maintaining compliance with the National Pollutant Discharge Elimination System (NPDES)permit requirements for ocean discharge.In order to meet the treatment goals of this Scenario,the Strategic Plan identifies capital improvements for both the collection system and the treatment plants.In conjunction with the Preferred Alternative,the District may be required to use the existing 78-inch diameter outfall to accommodate emergency peak flows in excess of current discharge capacity.Attachment A provides detailed discussion of the rationale for choosing the Preferred Alternative over other alternatives analyzed. Level of Treatment:Treatment Scenario 2 would provide the level of treatment necessary to meet the NPDES permit conditions and the California Ocean Plan,which embodies State of California regulatory requirements for ocean discharges.All wastewater would receive advanced primary treatment with a percentage also receiving secondary treatment prior to ocean discharge. In coordination with OCWD,50-80 mgd average daily flow and up to 100 mgd peak wet weather flow of secondary effluent would be diverted from OCSD to the GWR System.The amount of secondary treatment in the ocean discharge would be governed by needs of the GWR System and by the NPDES permit limits. Treatment Plant Expansion:Under Treatment Scenario 2,all proposed additional treatment facilities would be located within the existing property boundaries of the District’s Reclamation Plant No.I and Treatment Plant No.2.Figures 3-7 through 3-1 1 in the DEIR illustrate the treatment plant expansion.Treatment Scenario 2 would require the least number of new facilities of any of the alternatives analyzed. Ocean Discharge:The existing 120-inch diameter outfall has adequate capacity to accommodate average dry weather flows to the year 2020 as shown in Figure 3-2 of the DEIR.The outfall would also accommodate most wet weather flows using the combination of peak wet weather management measures outlined on page S-16 of the DEIR.The existing 120-inch diameter outfall’s rated capacity of 480 mgd has been exceeded on five separate occasions since its installation in 1971,reaching 550 mgd during a storm event in 1995.During each event,the outfall was able to accommodate all the effluent without requiring emergency discharge at either of the alternative two discharge points.Due to increased development and projected population growth within the service area,peak wet weather flows are estimated to reach 775 mgd by the year 2020 (see Section 3.4).To reconcile the discharge capacity deficiencies during peak flow OCSD Resolution 99-19,Attachment A A—i ESA I 960436 periods,the District will implement several measures to alleviate peak wet weather flow (DEIR S-l6).As a last resort,the District would use the existing 78-inch diameter outfall for infrequent peak flow discharges.Modeling of wet weather flows in the system indicate that the need or probability of use for the 78-inch to handle peak wet weather flow is greater today (three times in five years)than it will be under the preferred project in the future (one time in three years).This is due in part to the hydraulic relief provided by the GWR System,significantly reducing the need for peak wet weather discharges to the near-shore. Collection System:Based on the modeled pipeline deficiencies by the year 2020 within the system,OCSD proposes to replace and rehabilitate pipelines to meet future needs and prevent overflows.In addition,five pump stations were determined to be in need of equipment upgrades. Nearly 47 miles of pipeline replacements (separated into 32 individual projects)are planned almost exclusively within developed city streets.Open trench and jack-and-bore construction would be employed.Specific collection system projects are summarized in Table 3-19 of the Draft PEIR. Biosolids Program:The Strategic Plan recommends no immediate changes in the method of biosolids processing and beneficial reuse (or disposal as needed),however,a number of studies of the system are proposed.The Strategic Plan outlines several process changes which could potentially increase biosolids quality and operational efficiency.None of these technologies are recommended for immediate implementation,but the District will continue to play an active role in researching new technologies and monitoring studies performed nation-wide.The District will need to find additional land applications sites for the projected increase in biosolids.The District will continue to research the possibility of acquiring land dedicated to biosolids recycling. FINDINGS CONCERNING SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS The FPEIR indicates that the project would result in six significant unavoidable impacts attributable to the project.As described below in the findings for each of these impacts,there are either no feasible mitigation measures or the feasible mitigation measures would only partially mitigate the impact and the residual effect would remain significant.It is hereby determined that these impacts are acceptable for the reasons specified in Statement of Overriding Considerations. OCEAN DISCHARGE /MARINE ENVIRONMENT (PEIR CHAPTER 5.0) Pathogen Levels from Peak Wet Weather Discharge (Impact 5-9):Effluent discharge to the 78-inch outfall at a rate of once every three years would result in significant impacts to levels of pathogens in the nearshore waters used for water-contact activities or where shellfish are harvested.Use of the 78-inch diameter outfall would require short-term closure of the beach to human use. Cumulative Pathogen Levels from Peak Wet Weather Discharge (Impact 5-13):Use of the 78-inch outfall for peak wet weather discharges would contribute to significant OCSD Resolution 99-19,Attachment A A—2 ESA/960436 cumulative pollutant loads (particularly pathogens)to the nearshore environment during wet weather events in combination with non-point source pollution. TREATMENT FACILITY EXPANSION (PEIR CHAPTER 6.0) Noise Impacts from Construction (Impact 6.4-1):Construction activities related to the proposed treatment plant improvements at Reclamation Plant No.1 and Treatment Plant No.2 would intermittently and temporarily generate noise levels above existing ambient levels in the project vicinity. Air Quality Impacts from Construction (Impact 6.5-1):Project development under any of the six project scenarios would generate short-term emissions of air pollutants,including dust and criteria pollutants from demolition,construction and/or restoration activities. Air Quality Impacts from Mobile Sources (Impact 6.5-3):Emissions at both treatment plants under any of the project scenarios would continue to result from mobile sources. Mobile sources are projected to exceed the SCAQMD nitrous oxides significance threshold of 55 lbs/day. Cumulative Air Quality Impacts from Construction Projects (Impact 6.11-1): Cumulative impacts to air quality and noise could occur as a result of treatment facility construction activities coupled with the construction of the GWR System treatment facilities. SECONDARY EFFECTS OF GROWTH Secondary Effects of Growth (Impact 11-2):The OCSD Strategic Plan would accommodate planned growth in the Service Area.Implementation of planned growth would result in secondary environmental effects.The effects of planned growth have been identified and addressed in the EIRs for Regional Plans,General Plans for Service Area cities,and associated Specific Plans.Some of the secondary effects of growth which have been identified as significant and unavoidable include air quality and traffic congestion. FINDINGS Based on the FPEIR and the entire record before the OCSD Board,the Board finds that there is no feasible mitigation measure that will reduce the impacts presented above to less than significant levels.Nonetheless,the District is adopting the mitigation measures presented in the Mitigation and Monitoring/Reporting Program included as Attachment B.Specific economic, legal,social,technological,or other considerations justify approval of the project notwithstanding these impacts as more fully described in the Statement of Overriding Considerations. OCSD Resolution 99-19,Attachment A A—3 ESA /960436 FINDINGS CONCERNING SIGNIFICANT IMPACTS REDUCED TO LESS THAN SIGNIFICANT LEVELS BY MITIGATION MEASURES INCORPORATED INTO THE PROJECT The FPEIR identifies significant impacts,that are reduced to a “less than significant”level by the inclusion in the project approval of the mitigation measures identified in the FPEIR.It is hereby determined that these significant environmental impacts of the project will be avoided or substantially lessened by the inclusion of the identified mitigation measures,which are presented in the MMRP in Attachment B. OCEAN DISCHARGE /MARINE ENVIRONMENT Oil and Grease Levels (Impact 5-3):Oil and Grease effluent levels would comply with numeric permit limits under Scenarios 1,2,and 5 but would potentially create observable floating particles which would be a permit violation. Brine Added to Discharge (Impact 5-5):Increased discharge of brine under any scenario but particularly under Scenarios 2,4,and 6 with the GWR System would reduce initial dilution and increase metals concentrations.This could result in potentially significant toxicity impacts. Outfall Cleaning (Impact 5-11):Clean out of the existing 120-inch outfall,if needed,to remove accumulated sediments and debris would move sediments into the marine environment,which could result in short-term water quality and sediment impacts affecting marine organisms. New 120-Inch Diameter Outfall (Impact 5-12):Laying pipeline for the new outfall would result in the permanent loss of hundreds of thousands of square feet of soft-bottom, benthic habitat.Adjacent communities would be temporarily disrupted by increased sedimentation.Disturbance of bottom sediment may result in the short-term release of contaminants into the water column. TREATMENT FACILITY EXPANSION Construction Impacts to Neighboring Land Uses (Impact 6.1-1):Expansion of the OCSD treatment facilities,as proposed under Scenarios 2 and 4,would require the construction of additional facilities at Reclamation Plant No.I and at Treatment Plant No. 2.Project construction would result in short-term disturbance of adjacent land uses. Visual Impacts Impact (6.1-3):Expansion and operation of the proposed facilities for both Scenarios 2 and 4 could adversely alter existing visual character of the site with installation of tall structures and the removal of trees.In additional project implementation could introduce new sources of light and glare. Traffic Impacts from Construction (Impact 6.2-1):Periods of peak construction will increase traffic along local access streets. OCSD Resolution 99-19,Attachment A A—4 ESA /960436 Local Traffic Impacts from Operations (Impact 6.2-2):Additional traffic would be generated from the ongoing operations of the facilities at Reclamation Plant No.1 and Treatment Plant No.2.Sources of new traffic include chemical truck deliveries,trips by new District’s employees,and increased biosolids hauling truck trips. Regional Traffic Impacts from Operation (Impact 6.2-3):Increased biosolids and chemical truck trips would impact regional transportation systems including freeways, especially 1-405 and 1-5. Birds Nests (Impact 6.3-1):Removal of trees on the treatment plant sites during construction could impact nesting birds.This impact is considered less than significant with mitigation. Noise Impacts from Operations (Impact 6.4-2):Operation of proposed new equipment at Reclamation Plant No.I and Treatment Plant No.2 would generate noise levels above existing ambient levels in the project vicinity. Noise Impacts to Workers (Impact 6.4-3):Workers at Reclamation Plant No.I and Treatment Plant No.2 may be exposed to excess noise levels from the operation of new facilities. Air Quality Impacts from Operations (Impact 6.5-2):Emissions at both treatment plants under any of the project scenarios would continue to result from stationary sources. Increasingly restrictive air quality regulations are anticipated in the near future to comply with federal air quality standards,making air emissions permits for new and modified equipment more difficult to obtain. Air Quality Impacts from Central Generation System -CGS (Impact 6.5-4):Modifying the current CGS or adding new power-generating equipment would require South Coast Air Quality Management District (SCAQMD)permit modifications.Energy requirements greater than the permitted CGS capacity of 18 megawatt would require permit modifications. Odor Impacts (Impact 6.5-5):The project under each of the treatment scenarios could generate objectionable odors in the project vicinity and in other areas located downwind from the treatment facilities. Seismic Hazards (Impact 6.6-1):Project facilities,under any of the treatment scenarios, would be located in areas susceptible to primary and secondary seismic hazards (groundshaking,liquefaction,settlement).Damage to facilities could result in the event of a major earthquake. Sewage Spills from Seismic Hazards (Impact 6.6-2):Groundshaking could cause spills of raw sewage,causing a significant impact to public health. OCSD Resolution 99-19,Attachment A A—S ESA /960436 Erosion during Construction (Impact 6.7-1):Construction of any of the treatment system scenarios could result in an increase in erosion and siltation into surface waters. Construction could also result in chemical spills (e.g.,fuels,oils,or grease)to stormwater, and increase turbidity and decrease water quality in waters of the U.S. Dewatering (Impact 6.7-2):Pile driving and excavation activities at Reclamation Plant No.1 and Treatment Plant No.2 may encounter groundwater,and local dewatering may be required. Flood Hazards (Impact 6.7-3):Reclamation Plant No 1.and Treatment Plant No.2 are located in the 100-year floodplain of the Santa Ana River.New facilities proposed under any of the scenarios considered would expose structures and people to a 100-year flood event and/or effects of a tsunami. Hazardous Materials (Impact 6.9-1):Increasing quantities of hazardous materials stored on site could impact public health in the event of a catastrophic spill or explosion. Increasing liquid oxygen storage could increase the hazard. Growth-Inducement (Impact 11-1):By removing wastewater treatment capacity as one barrier to growth,the District would have indirect,growth-inducement potential to support planned development within the Service Area that is consistent with and within the levels of development approved in the adopted General Plans. COLLECTION SYSTEM IMPROVEMENTS Construction Impacts to Neighboring Land Uses (Impact 7.1-1):Construction activities associated with the trunk sewer systems would involve the rehabilitation and replacement of existing pipelines.Construction activities would result in short-term disturbance of adjacent land uses. Traffic Impacts from Construction (Impact 7.2-1):Construction activities during trenching in city streets will impact traffic circulation during construction period. Biology (Impact 7.3-1):Based on conceptual alignment information for OCSD’s proposed collection system projects,construction of the collection pipeline system improvements would occur in previously disturbed,developed areas,primarily public streets.No impact to biological resources would occur if projects occur within paved areas.However,if final project alignments are revised to include an undeveloped area or open space,potential impacts to biological resource could occur;in these cases OCSD would conduct additional CEQA evaluations as needed to clarify and address impacts to biological resources. Noise Impacts from Construction (Impact 7.4-1):Construction activities related to the proposed collection system improvements would intermittently and temporarily generate noise levels above existing ambient levels in the project vicinity. OCSD Resolution 99-19,Attachment A A—6 ESA /960436 Air Quality Impacts from Construction (Impact 7.5-1):The proposed improvements to OCSD’s collection systems would generate short-term emissions of air pollutants, including dust and criteria pollutants,from excavation,installation and/or replacement activities.This is considered a short-term significant impact that would cease at the completion of construction activities.Construction emission impacts are estimated to occur for an average of three to four weeks within one block of any given property. Seismic Hazards (Impact 7.6-1):Project facilities would be located in areas susceptible to primary and secondary seismic hazards (groundshaking,liquefaction,settlement).Damage to facilities could result in the event of a major earthquake. Erosion from Construction (Impact 7.7-1):Construction activities could result in erosion and siltation into nearby surface waters,leading to degradation of water quality or flooding hazards.Construction could also result in chemical spills (e.g.,fuels,oils,or grease)to stormwater,and increase turbidity and decrease water quality in waters of the U.S. Impacts to Emergency Services During Construction (Impact 7.8-1):Construction of the collection pipeline system could result in short-term disruption of emergency services in the vicinity of the project area. Public Safety During Construction (Impact 7.8-2):Construction of the collection system projects would create a public safety hazard in the vicinity of the construction area. Utilities Relocation (Impact 7.8-3):Construction of the collection pipeline system could result in short-term disruption of utility service and may require utilities relocation. Aesthetics (Impact 7.9-1):Project implementation could result in short-term visual impacts resulting from construction activities.Less than Significant after Mitigation Measures. Cultural Resources from Construction (Impact 7.10-1):Implementation of the proposed collection system improvements may affect known,significant archaeological resources. Cultural Resources from Construction (Impact 7.10-2):Implementation of the proposed collection system improvements may affect unknown,potentially significant archeological resources.Less than Significant with Mitigation Measures. Cumulative Construction Impacts (Impact 7.11-1):Construction activities of the collection system projects in conjunction with other projects would result in short-term cumulative impacts.Less than Significant with Mitigation Measures. BIOSOLIDS MANGEMENT Traffic Impacts from Biosolids Trucks (Impact 8-2):The projected increase in residual solids volumes would increase truck traffic on local roadways. OCSD Resolution 99-19,Attachment A A—7 ESA /960436 Noise Impacts from Increased Truck Traffic (Impact 8-3):The projected increase in residual solids volumes and related truck traffic would increase ambient noise levels at nearby sensitive receptor locations. Cumulative Impacts to Regional Biosolids Applications (Impact 8-5):The projected increase in biosolids production from POTWs in the Southern California region could present a cumulative impact on the availability of land application sites. FINDiNGS Based on the Final PEIR and the entire administrative record,the Board finds that changes or alterations have been incorporated into the project which will substantially lessen the significant effects as identified above,thereby reducing potential effects to less than significant levels.The District adopts the mitigation measures included in the Mitigation Monitoring/Reporting Program included in Attachment B. Based on the Final PEIR and the entire administrative record before the OCSD Board,the Board finds that the Mitigation Measure 6.5-if would not be feasible based on economic and technical considerations and could create additional impacts.The mitigation measure will therefore not be adopted. The mitigation measure was included in the Draft PEIR as follows: Mitigation Measure 6.5-if:Trucks should be washed off prior to leaving the construction site. It is infeasible to wash construction trucks off prior to the trucks leaving construction sites. Facilities and space are generally not available,nor is it feasible to capture and potentially treat the wash-water runoff which would be generated from washing numerous large construction vehicles.Mud and water generated by washing operations would be tracked onto City streets and create potential safety and aesthetic impacts.The additional time and costs associated with such activities on the construction sites are also infeasible. The other measures designed to reduce dust emissions 6.5-la through 6.5-le are adequate to reduce the potential impact to less-than-significant levels.Therefore,Mitigation Measure 6.5-if will not be included in the Mitigation Monitoring/Reporting Program and will not be adopted as part of these findings. Finally,based on the Final PEIR and the entire administrative record before the OCSD Board,the Board finds that the Impact 6.7-4 is not a significant impact.The Draft PEIR identified the impact as follows: Impact 6.7-4:Construction and long-term operation of the proposed improvements to both treatment plants would increase the area of impervious surface and result in an incremental increase in surface runoff in these areas.Less than Significant with Mitigation Measures. OCSD Resolution 99-19,Attachment A A—8 ESA /960436 Since the District collects and treats surface runoff within the two treatment plant sites,the increase in impervious area created by additional facilities would not significantly increase storm water runoff.As a result,impacts associated with increased storm water runoff would not be anticipated.The District finds that this impact is less than significant.No mitigation measures would be necessary to address this impact. STATEMENT OF OVERRIDING CONSIDERATIONS SUMMARY OF OVERRIEDING CONSIDERATIONS The California Environmental Quality Act (CEQA)requires a decision-maker,in this case the OCSD Board of Directors,to balance the benefits of a proposed project against its unavoidable environmental risks in determining whether to approve the project.If the Board of Directors allows the occurrence of significant effects through approval of a project,it must state its specific reasons for so doing in writing.Such reasons are included in the “statement of overriding considerations.” Section 15093 of the CEQA Guidelines establishes the following requirements for a statement of overriding considerations: (a)CEQA requires the decision-making agency to balance,as applicable,the economic,legal, social,technological or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project.If the specific economic,legal,social,technological or other benefits of a proposed project outweigh the unavoidable adverse environmental effects,the adverse environmental effects may be considered “acceptable.” (b)When the lead agency approves a project which will result in the occurrence of significant effects,which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and/or other information in the record.The statement of overriding considerations shall be supported by substantial evidence in the record. (c)If an agency makes a statement of overriding considerations,the statement should be included in the record of the project approval and should be mentioned in the notice of determination.This statement does not substitute for,and shall be in addition to,findings required pursuant to Section 15091. The Orange County Sanitation District (hereafter referred to as “District”or “OCSD”)adopts and makes the following statement of overriding considerations regarding the remaining unavoidable impacts identified within the 1999 Strategic Plan Program Environmental Impact Report (PEIR). In adopting this Resolution,the District’s Board of Directors acknowledges that it has weighed the benefits of the identified Preferred Alternative,treatment Scenario 2 against the adverse significant impacts that have not been avoided or substantially lessened to less-than-significant levels through mitigation. The OCSD Board of Directors hereby determines that the benefits of the Preferred Alternative of the 1999 Strategic Plan outweigh the unmitigated adverse impacts and the project should be OCSD Resolution 99-19,Attachment A A—9 ESA /960436 approved.The OCSD Board of Directors finds that to the extent that the identified significant adverse impacts have not been avoided or substantially lessened,there are specific economic, legal,social,technological or other considerations which support approval of the project. SIGNIFICANT UNA VOIDABLE IMPACTS Unavoidable or potentially unavoidable significant environmental effects of the project identified in the Final EIRIEIS and Findings of Significant Impacts include the following: Effluent discharge to the 78-inch diameter outfall at a rate of once every three years would result in elevated levels of pathogens in the near-shore waters during brief wet weather events significantly impacting beneficial uses and prompting beach closures.(Impact 5-9) These infrequent near-shore discharges in conjunction with non-point source discharges in the region would create a cumulative significant impact to beneficial uses.(Impact 5-13) Construction activities related to the proposed treatment plant improvements at Reclamation Plant No.I and Treatment Plant No.2 would intermittently and temporarily generate noise levels above existing ambient levels in the project vicinity (Impact 6.4-1) Construction and demolition activities related to the proposed treatment plant improvements would generate short-term emissions of air pollutants.(Impact 6.5-1) Mobile-source air emissions would continue to result from operations at both treatment plants.Mobile sources are projected to exceed the SCAQMD nitrous oxides significance threshold of 55 lbs/day.(Impact 6.5-3) Cumulative impacts to air quality and noise could occur as a result of treatment facility construction activities coupled with the construction of the GWR System treatment facilities.(Impact 6.11-1) The OCSD Strategic Plan would continue to accommodate planned growth in the Service Area.Implementation of planned growth would result in secondary environmental effects, some of which have been identified as significant including air quality and traffic. (Impact 11-2) ADOPTION OF OVERRIDING CONSIDERATIONS The District specifically adopts this Statement of Overriding Considerations and finds that:a)as part of the approval provisions,the Preferred Alternative has eliminated or substantially lessened all significant effects on the environment where feasible;b)other mitigation measures to mitigate the secondary effects of growth associated with the project are within the jurisdiction of other public agencies,and,c)the remaining unavoidable impacts of the project are acceptable in light of the environmental,economic,legal,social,technological,and other considerations set forth herein,because the benefits of the project outweigh the significant and adverse impacts. The District finds that each of the overriding considerations set forth below constitutes a separate and independent ground for finding that the benefits of the Preferred Alternative of the Strategic Plan outweigh its significant adverse environmental impacts and is an overriding consideration OCSD Reso’ution 99-19,Attachment A A—10 ESA /960436 warranting approval of the Preferred Alternative.These matters are supported by substantial evidence in the record. BENEFITS The adoption of the Preferred Alternative of the Strategic Plan will enable the District to provide sanitary sewer collection services and wastewater treatment for the projected population of the Service Area through the year 2020,protecting public health and safety.The District finds that the benefits of safe and reliable wastewater collection and treatment overrides the significant construction and operational impacts associated with the Preferred Alternative. Participation in the GWR System would contribute substantially to the responsible management of water resources in the Southern California region by recycling 60 to 100 million gallons per day of highly treated effluent for groundwater recharge.The District finds that implementation of the GWR System would significantly reduce the frequency of need for near-shore discharges to the 78-inch outfall during peak wet weather events. The District finds that the economic,technological,and environmental benefits of using the existing 78-inch diameter near-shore outfall for infrequent peak wet weather discharge would override the temporary significant impacts to near-shore beneficial uses.Use of the 78-inch diameter outfall for infrequent peak wet weather discharges would occur in lieu of constructing a new $150-200 million deepwater outfall.A new deep-water outfall would constitute a significant capital expense for a facility needed for infrequent peak wet weather discharges.The additional dry weather capacity would far exceed anticipated need.By delaying the installation of a new 120-inch diameter outfall parallel to the existing outfall,the District will avoid adverse construction impacts to the coastal and marine environments in addition to avoiding significant expense. The cities serviced by the District (DEIR page 2-1 Table 2-1)and the County of Orange acknowledge the economic benefits including jobs,increased sales revenue,and increased property tax revenue derived from the implementation of their General Plans and associated specific plans.The cities and County also acknowledge social benefits derived from implementation of their General Plans and associated specific plans,including increases in housing opportunities within the city and the region,increases in affordable housing,increases in each city’s contribution to its fair share of the regional housing opportunities,and provision of a mix of housing types.The District finds that the benefits of continued sanitary sewer service commensurate with forecast regional demand override the significant secondary effects of growth. H:\wp.dta\eng\JOBS &CONTRACTS\STRAT PLAN\J-40-4\99\FEIR Certification\Findings of Fact -Attachment A.doc OCSD Resolution 99-19,Attachment A A—il ESA /960436 ATTACHMENT B MITIGATION MONITORING/REPORTING PROGRAM OCSD Resolution 99-19,Attachment B ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MITIGATION MONITORING /REPORTING PROGRAM MARINE ENVIRONMENT /OCEAN DISCHARGE Impact 5-3.Oil and Grease effluent levels would comply with numerical permit limits under Scenarios 1,2,and 5 but would potentially create observable floating particles which would be a permit violation.This impact would be mitigated through monitoring and treatment to achieve and maintain compliance. Measure 5-3a:Oil and Grease.The District shall monitor receiving water in accordance with its current NPDES permit monitoring requirement and,if floating particulates from the discharge are observed in surface receiving water,the District shall modify its treatment process to reduce oil and grease in the effluent.Treatment modifications that may be implemented to address this issue include:increasing the level of secondary effluent in the discharge blend,and employing new and/or additional chemical processes (new polymer)to increase oil and grease removal. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Incorporate surface water observations Publish results with annual monitoring Monthly,beginning when in monthly marine monitoring program program report submitted to the RWQCB.OCSD treatment level is changed. focused above ZID as well as down- current. 2.Establish methods of increasing treatment in order to be prepared to eliminate floatables if necessary. Measure 5-3b:Local Grease Ordinance.The District shall work with its member agencies to encourage adoption of local ordinances for improved source control of oil and grease. MONITORING AN])REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Board of Directors to pursue source Board to adopt source control policies.On-going control policy actions.OCSD OCSD Strategic Plan —Resolution 99-19,Attachment B B —1 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM Impact 5-5.Increased discharge of brine under any scenario but particularly under Scenarios 2,4,and 6 with the GWR System would reduce initial dilution and increase metals concentrations.This could result in potentially significant toxicity impacts.Potentially significant. Measure 5-5:Brine Effect Studies.Study and monitor the effect of brine and adjust treatment and/or brine addition as needed to maintain NPDES permit effluent quality compliance. a)Conduct a pilot study of the effect of increased brine discharge to OCSD effluent on effluent quality to demonstrate NPDES permit compliance.Prior to start-up of full operation of the GWR System Project,OCSD will test effluent quality with the addition of the GWR System project brine concentrate in accordance with the acute and chronic toxicity testing procedures required in the District’s NPDES permit.This will allow the District to confirm the potential compliance with the NPDES permit. b)During GWR System operation,OCSD will continue its effluent quality testing and ocean monitoring in compliance with its NPDES permit.If this testing or monitoring indicates the occurrence of or potential for non-compliance with effluent toxicity standards,the District will implement measures to achieve and maintain NPDES compliance,including: •brine dilution •brine treatment •toxicity identification evaluation and appropriate source control measures MONITORING AND REPORTiNG MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Initiate contract to study brine toxicity.Include status of contract and study At adoption of findings. 2.Based on study results,identify further results in Annual Operations And OCSD and OCWD actions.Maintenance Report. Impact 5-9:Effluent discharge to the 78-inch outfall at a rate of once every three years would result in significant impacts to levels of pathogens in the nearshore waters used for water-contact activities or where shellfish are harvested. Measure 5-9a:Pathogen Reduction.Pathogen reduction in the wet weather discharge would partially mitigate the impact of wet weather discharge to the nearshore area by reducing the pathogen levels and thereby reducing the health risk.Disinfection could reduce pathogen levels but it is not recommended by the RWQCB based on cost and the potential for residual chlorine in the discharge to have an adverse impact to marine organisms. Alternative methods of pathogen removal appropriate for wet weather flow treatment are under development and include filtration processes.The District will continue to evaluate new technologies for pathogen reduction and will implement those that prove to be feasible,effective,and cost- effective.Even with some level of pathogen reduction,beach closure would still probably be required,thus the impact to beach use would remain significant and unavoidable during these infrequent events. OCSD Strategic Plan-Resolution 99-19,Attachment B B -2 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONtTORII4G SChEDULE I.Continue research of pathogen Include status and results of research in On-going. reduction technologies,in particular,Annual Operations And Maintenance OCSD micro-filtration.Report. Impact 5-11:Removal of accumulated sediments in the existing 120-inch outfall,if needed,would move sediments into the marine environment,which could result in short-term water quality and sediment impacts affecting marine organisms. Measure 5-11:Outfall Cleaning.If necessary,the District will develop plans to clean out the outfall using appropriate methods approved by the RWQCB to protect water quality in accordance with regulations.The plan will include methods to contain floatables and disperse the sediments so that impacts to benthic communities and water quality are minimized. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Submit clean-out methods to RWQCB Include status and results of methods in prior to implementation.Annual Operations And Maintenance OCSD Prior to clean-out Report. Impact 5-12.Laying pipeline for any new outfall would result in the permanent loss of hundreds of thousands of square feet of soft-bottom,benthic habitat. Adjacent communities would be temporarily disrupted by increased sedimentation.Disturbance of bottom sediment may result in the short-term release of contaminants into the water column.Potentially significant but can be mitigated. Measure 5-12:Outfall Siting.The District would conduct additional detailed,site-specific studies for the siting of a new second 120-inch ocean outfall.These studies would clarify the extent of marine resources that would be affected by construction and identified appropriate mitigation measures to minimize the area of disturbance. OCSD Strategic Plan-Resolution 99-19,Attachment B B —3 ESA /960436 Mitigation Monitoring and Reporting PrOgram October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM MONITORING AND REPORTING MONITORiNG IMPLEMIENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Initiate feasibility and design studies Include status and methods in Annual prior to construction.Operations And Maintenance Report.OCSD Prior to construction 2.Prepare appropriate CEQA documentation of proposed project. 3.Implement mitigation measures identified in subsequent CEQA documentation. Impact 5-13:Use of the 78-inch outfall for peak wet weather discharges would contribute to significant cumulative pollutant loads (particularly pathogens) to the nearshore environment during wet weather events in combination with non-point source pollution.Significant. Measure 5-13:Pathogen Reduction.To mitigate the cumulative contribution from use of the 78-inch outfall,the District will implement Mitigation Measure 5-9,above to provide additional pathogen reduction as allowed and/or required by the RWQCB. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Continue research of pathogen Include status and results of methods in reduction technologies,in particular,Annual Operations And Maintenance OCSD On going micro-filtration.Report. Treatment Plant Land Use Impact 6.1-1.Expansion of the OCSD treatment facilities,as proposed under Scenarios 2 and 4,would require the construction of additional facilities at Reclamation Plant No.1 and at Treatment Plant No.2.Project construction would result in short-term disturbance of adjacent land uses.Less than Significant with Mitigation Measures. OCSD Strategic Plan-Resolution 99-19,Attachment B B —4 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM Measure 6.1-la:Construction Hours.The District’s standard specifications provide construction hours of work between 7:00 AIvI and 5:30 PM,except for emergency or special circumstances requiring that work be done during low-flow periods. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include compliance with local noise Maintain record of construction oversight Prior to and during construction and construction ordinances in for administrative record.OCSD construction specifications. 2.Provide construction oversight to ensure scope of work is carried out. Measure 6.1-ib:Construction Notification.The District shall post informational signs outside plant when major projects are being constructed. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Post notices near job site outside plant Maintain record of distribution for Prior to construction property,administrative record.OCSD Impact 6.1-3.Expansion and operation of the proposed facilities for both Scenarios 2 and 4 could adversely alter existing visual character of the site with installation of tall structures and the removal of trees.In additional project implementation could introduce new sources of light and glare.Less than Significant with Mitigation Measures. Measure 6.1-3a:Implement Landscaping Master Plan.The District will implement the Urban Design Element of the Strategic Plan in order to improve the visual appearance of the site.Recommendations from the Landscape Master Plans (of the Urban Design Element)include the development of buffer zones,planting of trees at the perimeter of the plants along sensitive visual corridors (e.g.Santa Ana bikeway),and maintaining and enhancing the appearance of existing buffer zones. OCSD Strategic Plan-Resolution 99-19,Attachment B B -5 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Comply with Urban Design Plan.Maintain Urban Design plan for On going administrative record.OCSD Measure 6.1-3b:Exterior Lighting.The District will install permanent exterior lighting on new facilities to point away from neighboring residential areas as possible to minimize visible light sources. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Comply with Urban Design Plan.Maintain Urban Design Plan and record Prior to and after construction 2.Conduct nighttime survey after new of nighttime inspection for administrative OCSD construction to confirm less than record. significant impact. Traffic Impact 6.2-1:Periods of peak construction will increase traffic along local access streets.Less than Significant with Mitigation Measures. Measure 6.2-1:Contractor Coordination.For each major project or construction period,the District would complete a detailed construction schedule and notify the Cities of Fountain Valley and Huntington Beach of construction.Construction vehicles shall be run on a schedule to minimize truck traffic on arterial highways. OCSD Strategic Plan-Resolution 99-19,Attachment B B -6 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Require traffic control plan for Ensure that construction vehicle traffic Prior to and during construction construction projects.complies with traffic control plan.OCSD 2.Notify affected cities of construction schedule.Provide record of construction oversight. 3.Provide construction oversight. Impact 6.2-2:Additional traffic would be generated from the ongoing operations of the facilities at Reclamation Plant No.I and Treatment Plant No.2. Sources of new traffic include chemical truck deliveries,trips by new District’s employees,and increased biosolids hauling truck trips.Less than Significant with Mitigation Measures. Measure 6.2-2a:Ride-Sharing Program.The Districts will continue the existing ride-sharing program to encourage employees to join a carpool and use transit. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE Include status of rideshare program in Annually Operation and Maintenance Annual OCSD Report. Measure 6.2-2b:Traffic Management Chemical delivery trucks and screenings and grit and biosolids disposal trucks will avoid operating during peak traffic hours when possible. OCSD Strategic Plan-Resolution 99-19,Attachment B B -7 ESA /960436 Mitigation Monitoring and Reporting PrOgram October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.The District will develop a preferred Prepare a record of hauling schedule.At hauler’s contract renewal truck-hauling schedule avoiding peak OCSD traffic hours. 2.Thereafter the District will attempt to comply with the schedule whenever possible. 3.The District will incorporate this preferred schedule when renewing contracts with haulers and chemical deliverers. Impact 6.2-3:Increased biosolids and chemical truck trips would impact regional transportation systems including freeways,especially 1-405 and 1-5.Less than Significant with Mitigation Measures. Measure 6.2-3:Biosolids Transport.The District shall arrange for the transport of biosolids by trucks during off-peak travel hours when possible to reduce truck travel times and minimize impacts to the regional transportation system. OCSD Strategic Nan-Resolution 99-19,Attachment B B -8 ESA /960436 Mitigation Monitoiing and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORiNG SCHEDULE 1.The District will develop a preferred Prepare a record of hauling schedule.At hauler’s contract renewal truck-hauling schedule avoiding peak OCSD traffic hours. 2.Thereafter the District will attempt to comply with the schedule whenever possible. 3.The District will incorporate this preferred schedule when renewing contracts with haulers. Impact 6.3-1:Removal of trees on the treatment plant sites during construction could impact nesting birds.This impact is considered less than significant with mitigation. Measure 6.3-1:Nesting Birds.Prior to the removal of healthy trees on site,a biologist knowledgeable of birds will survey the trees to determine if active nests are present.If nests of sensitive species are present,tree removal will be scheduled to avoid the nesting season. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include tree surveys in construction Maintain record of biologist survey OCSD Prior to and during construction specifications for on-site construction recommendations and record of District projects.adherence with recommendations. OCSD Strategic Plan-Resolution 99-19,Attachment B B -9 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Noise Impact 6.4-1:Construction activities related to the proposed treatment plant improvements at Reclamation Plant No.I and Treatment Plant No.2 would intermittently and temporarily generate noise levels above existing ambient levels in the project vicinity.Significant and Unavoidable. Measure 6.4-la:Construction Hours.The District’s standard specifications provide construction hours of work between 7:00 AM and 5:30 PM, except for emergency or special circumstances requiring that work be done during low-flow periods. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 2.Include compliance with local noise Maintain record of construction oversight Prior to and during construction and construction ordinances in for administrative record.OCSD construction specifications. 3.Provide construction oversight to ensure scope of work is carried out. Measure 6.4-ib:Muffled Equipment.All equipment used during construction shall be muffled and maintained in good operating condition.All internal combustion engine driven equipment shall be fitted with intake and exhaust mufflers that are in good condition. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Include compliance with local noise Maintain record of construction oversight Prior to and during construction and construction ordinances in for administrative record.OCSD construction specifications. 2.Include noise reduction procedures in construction specifications 3.Provide construction oversight to ensure scope of work is carried out. Measure 6.4-lc:Pile-Driving Noise Reduction.OCSD shall consult with an acoustical engineer to evaluate other alternatives for mitigating impacts from extensive pile driving activities when necessary. OCSD Strategic Plan-Resolution 99-19,Attachment B B —10 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Initiate contract with qualified engineer Maintain record of construction oversight OCSD Prior to and during construction to reduce noise impacts.for administrative record. 2.Incorporate noise reduction solutions. 3.Provide construction oversight to ensure scope of work is carried out. Measure 6.4-id:Alternatives for Foundations.OCSD will evaluate the use of alternative foundation designs to avoid a need for pilings where cost-effective and technically feasible. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include preference to avoid pilings Maintain record of design specifications.OCSD Prior to project design where possible in project design specifications. Measure 6.4-le:Construction Notification.Nearby sensitive receptors affected by construction shall be notified concerning the project timing and construction schedule,and shall be provided with a phone number to call with questions or complaints. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Prepare and distribute notifications.Maintain record of notification OCSD Prior to construction distribution list. Measure 6.4-if:Pile Driving Noise Reduction.Noise-reduction measures will be implemented such as acoustic insulation or by other means during the construction period at Reclamation Plant No.I to reduce a nuisance condition to the closest residences when pile driving is taking place. OCSD Strategic Plan-Resolution 99-19,Attachment B B -11 ESA /960436 Mitigation Monitoiing and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include noise reduction procedures in Maintain record of construction oversight OCSD Prior to and during construction construction specifications for administrative record. 2.Provide construction oversight to ensure scope of work is carried out. Measure 6.4-ig:Noise Reduction.The District will require construction contractors to include methods to reduce noise and elevated activity impacts to nearby wildlife when working on the southern and southeastern border of Treatment Plant No.2. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include noise reduction procedures in Maintain record of construction oversight OCSD Prior to and during construction construction specifications for administrative record. 2.Conduct wildlife sensitivity training during morning tail-gate meetings. 3.Provide construction oversight to ensure scope of work is carried out. Measure 6.4-lh:Exterior Lighting.The District will install permanent exterior lighting on new facilities to point away from the wetland areas adjacent to Plant No.2 as possible to minimize light sources permanently shining on the adjacent habitats. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include lighting design in construction Conduct periodic evening surveys to OCSD Prior to and during construction specifications.observe lights. OCSD Strategic Plan-Resolution 99-19,Attachment B B -12 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Impact 6.4-2:Operation of proposed new equipment at Reclamation Plant No.1 and Treatment Plant No.2 would generate noise levels above existing ambient levels in the project vicinity.Less than Significant with Mitigation Measures. Measure 6.4-2a:Noise Performance Standard.OCSD shall establish a performance noise standard for operational noise at Reclamation Plant No.1 and Treatment Plant No.2.The performance standard shall apply to the property line of each plant and shall prohibit hourly average noise levels in excess of 55 dBA between the hours of 7:00 a.m.to 10:00 p.m.and 50 dBA between the hours of 10:00 p.m.and 7:00 a.m.,as required by the Fountain Valley and Huntington Beach Noise Ordinances.Available mitigation to achieve the performance standard consists of locating noise sources away from sensitive receptors,installation of acoustical enclosures around noise sources,installation of critical application silencers and sequential mufflers for exhaust noise,installation of louvered vents,directing vent systems away from nearby residences,and constructing soundwalls at the property lines. MONITORING AND REPORTING MONITORiNG IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Include compliance with local noise Maintain record of noise complaints for OCSD On-going and construction ordinances in administrative record. standard operational procedures. 2.Implement noise reduction procedures when possible. 3.Consider operational noise when locating new equipment. Measure 6.4-2b:Community Liaison.The District will assign a community liaison for odor and noise complaints. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Meet with community groups.Maintain record of meetings with OCSD On-going 2.Develop tasks and assignments for community groups. liaison. 3.Periodically review effectiveness of community liaison program. OCSD Strategic Plan-Resolution 99-19,Attachment B B —13 ESA /960436 Mitigation Monitonng and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Impact 6.4-3:Workers at Reclamation Plant No.I and Treatment Plant No.2 may be exposed to excess noise levels from the operation of new facilities. Less than Significant with Mitigation Measures. Measure 6.4-3:Noise Control.Noise control measures shall be incorporated into the design of the facility.Once the facility is operational,a certified industrial hygienist or other qualified individual shall measure the noise levels to which workers are exposed.If the OSHA 8-hour time weighted average exposure for any worker exceed the 85 dBA threshold,a hearing conservation program must be initiated and appropriate administrative and engineering controls must be put in place to protect workers. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include noise control measures in Include noise assessment results in annual OCSD Annually design of new equipment.Operations and Maintenance Report. 2.Conduct noise assessments on site and on the perimeter to quantify impacts to workers and neighborhood to respond to complaints. Air Quality Impact 6.5-1:Project development under any of the six project scenarios would generate short-term emissions of air pollutants,including dust and criteria pollutants,from demolition,construction and/or restoration activities.Significant and Unavoidable. Measure 6.5-la:Equipment Emissions.General contractors shall maintain equipment engines in proper tune and operate construction equipment so as to minimize exhaust emissions.Such equipment shall not be operated during second stage smog alerts. Measure 6.5-lb:Truck Emissions.During construction,trucks and vehicles in loading or unloading queues shall be kept with their engines off,when not in use,to reduce vehicle emissions.Construction activities shall be phased and scheduled to avoid emissions peaks,and discontinued during second- stage smog alerts. Measure 6.5-ic:Dust Control.General contractors should use reasonable and typical watering techniques to reduce fugitive dust emissions.All unpaved demolition and construction areas shall be wetted as necessary during excavation and construction,and temporary dust covers shall be used to reduce dust emissions and meet SCAQMD District Rule 403. Measure 6.5-id:Soil Binders.Soil binders shall be spread on site,unpaved roads,and parking areas when needed. OCSD Strategic Plan-Resolution 99-19,Attachment B B -14 ESA I 960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Measure 6.5-le:Ground Cover.Ground cover shall be re-established following completion of construction activities through seeding and watering if needed. MONITORING AN])REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include air emissions restrictions and Maintain record of construction oversight OCSD Prior to and during construction. standard operating procedures for for administrative record. construction work in contract specifications. 2.Include dust reduction measures listed in mitigation measures in contract specifications. 3.Conduct oversight of construction activities to ensure scope of work is carried out. Impact 6.5-2:Emissions at both treatment plants under any of the project scenarios would continue to result from stationary sources.Increasingly restrictive air quality regulations are anticipated in the near future to comply with federal air quality standards,making air emissions permits for new and modified equipment more difficult to obtain.This impact would be less than significant with mitigation measures. Measure 6.5-2a:Non-Combustion Air Emissions.The District will research ways of reducing NO~and air toxics emissions from stationary sources, including non-combustion sources to meet future emission reductions that will be imposed by the SCAQMD. Measure 6.5-2b:Future Air Emission Reductions.The District will comply with existing and future air quality regulations including SCAQMD Rules and permit requirements.As air quality regulations become more restrictive in the South Coast Air Basin coinciding with increased operational demand,the District will be required to reduce emissions through process modifications or by implementing new control technologies. OCSD Strategic Plan-Resolution 99-19,Attachment B B —15 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM IMPLEMENTATION PROCEDURE 1.Initiate research on innovative control technology. 2.Provide SCAQMD with mandated emissions reports to verify compliance. MONITORING AND REPORTING ACTIONS Maintain record of air emission data. Include status and results of air emissions research in annual Operations and Maintenance Report. MONITORING RESPONSIBILITY OCSD MONITORING SCHEDULE Annually. Impact 6.5-3:Emissions at both treatment plants under any of the project scenarios would continue to result from mobile sources.Mobile sources are projected to exceed the SCAQMD nitrous oxides significance threshold of 55 lbs/day.This would result in a significant impact to air quality. Measure 6.5-3a:Ride-Sharing Program.The District will maintain its ride-share programs to reduce commuter traffic and air quality impacts. Measure 6.5-3b:Use of CNG.The District will complete the implementation of compressed natural gas (CNG)stations and encourage contractors to employ CNG-powered engines on residual solids haul trucks through contract incentives where possible. Measure 6.5-3c:Alternative Fuels for Trucks.Alternative fuels shall be considered for biosolids haul trucks including low NO~emitters. Measure 6.5-3d:Transportation Alternatives.The District shall initiate research on alternative methods of transporting biosolids to land application sites including electric vehicles and rail. OCSD Strategic Plan-Resolution 99-19,Attachnient B Mitigation Monitoring and Reporting Program B -16 ESA /960436 October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM IMPLEMENTATION PROCEDURE 1.Initiate research on innovative control technology,alternative fuels,and biosolids hauling methods. 2.Provide SCAQMD with mandated emissions reports to verify compliance. 3.Include in contracts and requests for qualifications from haulers that CNG is available and encouraged. MONITORING AND REPORTING ACTIONS Include status of rideshare program in Operation and Maintenance Annual Report. Include status of research in alternative fuels and biosolids haul methods in Operation and Maintenance Annual Report. MONITORING RESPONSIBILITY OCSD MONITORING SChEDULE On going Impact 6.5-4:Modifying the current CGS or adding new power-generating equipment would require SCAQMD permit modifications.Energy requirements greater than the permitted CGS capacity of 18 MW would require permit modifications.Less Than Significant impact with Mitigation. Measure 6.5-4a:Energy Purchases.The District will purchase energy from off-site sources if air emissions permit modifications are denied. Measure 6.5-4b:Clean-Burning Engines.The District will continue to research clean-burning engines for the CGS,in an effort to increase power output while reducing criteria and toxic pollutants. Measure 6.5-4c:Install BACT.The District will install Best Available Control Technology if necessary to comply with SCAQMD Rules. IMPLEMENTATION PROCEDURE MONITORING AND REPORTING ACTIONS MONITORING RESPONSIBILITY MONITORING SCHEDULE 1.Initiate research on innovative control Maintain record of air emission data. technology. 2.Provide SCAQMD with mandated emissions reports to verify compliance. Include status and results of air emissions research in annual Operations and Maintenance Report. OCSD Annually. OCSD strategic Plan-Resolution 99-19,Attachment B Mitigation Monitoring and Reporting Program B-17 ESA I 960436 October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM Impact 6.5-5:The project under each of the treatment scenarios could generate objectionable odors in the project vicinity and in other areas located downwind from the treatment facilities.Less Than Significant after Mitigation Measures. Measure 6.5-5a:Odor Control.The District will evaluate the need for odor control equipment for future facilities to reduce fugitive foul odors and include odor control when necessary.The District will also periodically review air emissions from existing solids handling to determine if odor control is necessary. Measure 6.5-Sb:Dewatering Odor Control.When dewatering is required during excavation,the District shall provide odor control systems to reduce construction odor impacts when necessary. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Maintain odor control technology.Include odor complaints in annual OCSD Annually. 2.Provide odor control on new facilities Operations and Maintenance Report. as needed. Measure 6.5-Sc:Community Liaison.The District will assign a community liaison for odor and noise complaints. Measure 6.5-Sd:Odor Complaint Follow-Up The District will follow-up with copies of odor complaint analysis to complainant and/or neighborhood groups including the Southeast Huntington Beach Neighborhood Association representative. Measure 6.5-Se:Pre-Design Coordination.The District will maintain pre-design coordination on future projects at its treatment plants with interested parties including cities and neighborhood associations. Measure 6.5-Sf:Community Outreach.The District will establish regular community outreach meetings with neighbors. OCSD Strategic Plan-Resolution 99-19,Attachment B B -18 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBiLITY MONITORING SCHEDULE 1.Meet with community groups to Maintain record of meetings with OCSD On-going choose community liaison and periodic community groups. meeting schedule. 2.Develop tasks and assignments for liaison. 3.Periodically review effectiveness of community liaison program. 4.Provide odor and noise complaint information to community groups. Geology Impact 6.6-1:Project facilities,under any of the treatment scenarios,would be located in areas susceptible to primary and secondary seismic hazards (groundshaking,liquefaction,settlement).Damage to facilities could result in the event of a major earthquake.Less than Significant with Mitigation Measures. Measure 6.6-la:Geotechnical Evaluations.During the project design phase for all facilities,the District will perform design-level geotechnical evaluations.The geotechnical evaluations will include subsurface exploration and review of seismic design criteria to ensure that design of the facilities meet seismic safety requirements of the Uniform Building Code. Site-specific testing for soils susceptible to liquefaction would be conducted.If testing results indicates that conditions are present that could result in significant liquefaction and damage to project facilities,appropriate feasible measures will be developed and incorporated into the project design.The performance standard to be used in the geotechnical evaluations for mitigation liquefaction hazards will be minimization of the hazards.Measures to minimize significant liquefaction hazards could include the following: •Densification or dewatering of surface or subsurface soils. •Construction of pile or pier foundations to support pipelines and/or buildings. •Removal of material that could undergo liquefaction in the event of an earthquake and replacement with stable material. Recommendations of the geotechnical report will be incorporated into the design and construction of proposed facilities. OCSD Strategic Plan-Resolution 99-19,Attachment B B —19 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM Measure 6.6-ib:Seismic Safety.The District will design and construct new facilities in accordance with District seismic standards and/or meet or exceed seismic,design standards in the most recent edition of the California Building Code. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include design-level geotechnical Maintain record of specifications for OCSD Prior to construction evaluations in specifications prior to administrative record. construction. 2.Include in specifications compliance with California Building Code Impact 6.6-2:Groundshaking could cause spills of raw sewage,causing a significant impact to public health.Less than Significant impact with Mitigation Measures. Measure 6.6-2a:Spill Prevention.The District will implement the Spill Prevention Containment and Countermeasures Plan (SPCC). Measure 6.6-2b:Spill Containment.OCSD chemical facilities will be designed with secondary containment,such as berms,to contain and divert toxic chemicals from wastewater flows and isolate damaged facilities to reduce contamination risks. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Implement and update SPCC plan.Maintain record of SPCC for OCSD As needed. administrative record. Hydrology Impact 6.7-1:Construction of any of the treatment system scenarios could result in an increase in erosion and siltation into surface waters.Construction could also result in chemical spills (e.g.,fuels,oils,or grease)to stormwater,and increase turbidity and decrease water quality in waters of the U.S.Less than Significant with Mitigation Measures. OCSD Strategic Plan-Resolution 99-19,Attachment B B —20 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM Measure 6.7-la:Best Management Practices.The District will implement Best Management Practices (BMPs)as outlined in the SWMP. Measure 6.7-ib:Storm Water Management.The District will train construction and operation employees in storm water pollution prevention practices.Individual contractors performing construction at each treatment facility shall be required to comply with provisions of the SWMIP. Measure 6.7-ic:Storm Drain Inspection.The District will inspect and maintain all on-site storm water drains and catch basins on plant property regularly. Measure 6.7-id:Regional Board.The District will apply the SARWQCB’s recommended BMPs during construction and operation as specified in the SWMP. Measure 6.7-ic:Construction Site Storm Water.For construction involving disturbance greater than five acres of land,the District will incorporate into contract specifications the following requirements: The District will comply with the RWQCB requirements of the NPDES General Permit for Discharges of Storm Water Associated with Construction Activity.The District will require that the contractor implement control measures that are consistent with the General Permit and with the recommendations and policies of the RWQCB.This would include submitting a Notice of Intent and site map to the RWQCB,developing a Storm Water Pollution Prevention Plan,and implementing site-specific best management practices to prevent sedimentation to surface waters. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Implement BMPs.Maintain compliance with SWMP for OCSD As needed. 2.Implement SWMP.administrative record. 3.Periodically update SWMP. 4.Implement mitigation measures listed Maintain record of site inspections. above. 5.Periodically inspect construction sites. Impact 6.7-2:Pile driving and excavation activities at Reclamation Plant No.1 and Treatment Plant No.2 may encounter groundwater,and local dewatering may be required.Less than Significant with Mitigation Measures. Measure 6.7-2a:Groundwater Dewatering.Construction contractors will comply with the District’s Dewatering Specifications. Measure 6.7-2b:Dewatering Discharge.Water from dewatering operations will be disposed of in a suitable manner in conformance with the NPDES permit,as approved by the RWQCB. OCSD Strategic Plan-Resolution 99-19,Attachment B Mitigation Monitoring and Reporting Program B-21 ESA /960436 October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Update dewatering procedures Maintain record of dewatering procedures OCSD During construction. periodically,for administrative record 2.Periodically inspect construction sites. Maintain record of site inspections. Impact 6.7-3:Reclamation Plant No 1.and Treatment Plant No.2 are located in the 100-year floodplain of the Santa Ana River.New facilities proposed under any of the scenarios considered would expose structures and people to a 100-year flood event and/or effects of a tsunami.Less than Significant With Mitigation Measures. Measure 6.7-3a:Chemical Spills During Floods.The District shall construct and maintain secondary containment berms to protect against release of toxic chemicals in an event of a spill from flooding. Measure 6.7-3b:Coordination with COE.The District shall coordinate with the Army Corp of Engineers to ensure levees located adjacent to Reclamation Plant No.1 and Treatment Plant No.2 continue to provide adequate protection for a 100-year flood event. Measure 6.7-3c:Hazard Awareness Notification.The District shall adhere to the Emergency Contingency Plan and the Flood Protection Plan to minimize the affects of flooding and tsunamis to Reclamation Plant No.1 and Treatment Plant No.2.These measures shall include hazard awareness notifications to neighborhoods downstream from Reclamation Plant No.1. Measure 6.7-3d:Flood Protection.The District shall adhere to Orange County’s flood protection program as implemented by the Orange County Flood Control District. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Comply with programs listed in Maintain record of communication with OCSD On going. mitigation measures.U.S.Army Corps of Engineers and County Flood Control District for administrative record. OCSD Strategic Plan-Resolution 99-19,Attachment a B -22 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Hazardous Materials Impact 6.9-1:Increasing quantities of hazardous materials stored on site could impact public health in the event of a catastrophic spill or explosion. Increasing liquid oxygen storage could increase the hazard.Less than Significant with Mitigation Measures. Measure 6.9-la:Worker Safety Training.Worker safety training shall emphasize hazards of liquid oxygen and stored methane.Routine safety measures including hazard communication shall be adopted and strictly enforced in hazardous areas.Hazard training and communication shall include laboratory operations and routine process chemical use. Measure 6.9-ib:Oxygen Facility Safely.If additional liquid oxygen storage facilities are installed,the District shall research explosion and fire potential to determine explosion arc perimeters.If neighboring land uses are not adequately distant,the District shall reconfigure the oxygen storage facility to remove explosion hazards on neighboring land uses. Measure 6.9-ic:Risk Management Program.Liquid oxygen operations shall be included in the District’s Risk Management Program. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Maintain and periodically update Risk Maintain training records,medical OCSD On going. Management Program.records,notification records,and safety 2.Maintain and periodically update record for administrative record. worker safety program. 3.Implement mitigation measures listed above. 4.Conduct monthly and annual safety inspections. Cumulative Impact 6.11-1:Cumulative impacts to air quality and noise could occur as a result of treatment facility construction activities coupled with the construction of the GWR System treatment facilities.Significant unavoidable. Measure 6.11-la:Construction Coordination with OCWD.Coordinate construction activities with OCWD to minimize PM10 emissions,construction vehicle exhaust,and cumulative noise impacts during excavation and pile driving activities. OCSD Strategic Plan-Resolution 99-19,Attachment B B —23 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Include air emissions restrictions and Maintain record of construction oversight OCSD Prior to and during construction. standardoperating procedures for for administrative record. construction work in contract specifications. 2.Conduct oversight of construction activities to ensure scope of work is carried out. Growth-Inducement Impact 11-1:By removing wastewater treatment capacity as one barrier to growth,the District would have indirect,growth-inducement potential to support planned development within the Service Area that is consistent with and within the levels of development approved in the adopted General Plans. Less the Significant with Mitigation Measures. Measure 11-la:Phased Construction.The project’s phased design helps minimize growth inducement potential.The Strategic Plan allows for the incremental expansion of treatment capacity,allowing Service Area cities to re-evaluate and revise long-term needs before completing full “build out.” Measure 11-lb:Lower Flow Projections.The District revises its Strategic Plan periodically allowing the treatment facilities to best meet the actual needs of the Service Area.The implementation of this Strategic Plan was based on a projected decrease influent flow and serves to decrease anticipated capacity requirements.Future revisions every five years will assist the District in maintaining service for reasonably foreseeable planned growth levels. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Phase construction of new facilities as Begin update Strategic Plan in 2004.OCSD Begin in 2004. outlined in the Strategic Plan. 2.Review and incorporate growth predictions every five years. 3.Update Strategic Plan periodically. Impact 11-2:The OCSD Strategic Plan would accommodate planed growth in the Service Area.Implementation of planned growth would result in secondary environmental effects.The effects of planned growth have been identified and addressed in the EIRs on Regional Plans,General Plans for OCSD Strategic Plan-Resolution 99-19,Attachment B B —24 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Service Area cities,and associated Specific Plans.Some of the secondary effects of growth which have been identified as significant and unavoidable include air quality and traffic congestion. Measure 11-2:Growth Mitigation Measures.OCSD does not have the authority to make land use and development decisions,nor does it have the authority or jurisdiction to address many of the identified significant,secondary effects of planned growth.Authority to implement such measures lies with the County and cities which enforce local,state,and federal regulations through the permit process.Other agencies with authority to require mitigation or with responsibility to implement measures to mitigate the effects of planned growth include regional and state agencies such as the South Coast Air Quality management District (SCAQMD),Regional Water Quality Control Board (RWQCB),California Department of Fish and Game (CDFG),California Department of Health Services (DHS),California Department of Transportation (Caltrans),and federal agencies including U.S.Fish and Wildlife Service (USFWS),U.S.Environmental Protection Agency (EPA),and the U.S.Corps of Engineers (USACE). MONITORING AN])REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Phase construction of new facilities as Begin update Strategic Plan in 2004.OCSD Begin in 2004. outlined in the Strategic Plan. 2.Review and incorporate growth predictions every five years. 3.Update Strategic Plan periodically. Collection System Land Use Impact 7.1-1:Construction activities associated with the trunk sewer systems would involve the rehabilitation and replacement of existing pipelines. Construction activities would result in short-term disturbance of adjacent land uses.Less than Significant with Mitigation Measures. Measure 7.1-la:Construction Hours.The District will comply with local ordinances and restrict construction activities to daylight hours or as specified in encroachment permits. Measure 7.i-lb:Construction Notification.The District shall post notices or provide notification of construction activities to adjacent property owners (including homeowners and adjacent businesses)at least 72 hours in advance of construction and provide a contact and phone number of a District staff person to be contacted regarding questions or concerns about construction activity. Measure 7.1-ic:Emergency Services Access.The District shall coordinate with officials of adjacent fire station,the Fountain Valley Regional Hospital as well as other hospital to ensure that 24-hour emergency access is available. OCSD Strategic Plan-Resolution 99-19,Attachment B B —25 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM Measure 7.1-id:Covered Trenches.To minimize disruption of access to driveways to adjacent land uses,the District or its contractor(s)shall maintain steel-trench plates at the construction sites to restore access across open trenches.Construction trenches in streets will not be left open after work hours. Measure 7.l-ie:Signage.The District shall provide temporary signage indicating that businesses are open. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include compliance with local Maintain record of signage,business and OCSD Prior to and during construction construction ordinances in construction fire department notifications,inspections, specifications including site safety and construction schedule. during non construction hours. 2.Include the preparation and distribution of notifications prior to construction activities in contract specifications. 3.Include 24-hour emergency access in contract specifications. 4.Maintain record of communication with local authorities. 5.Include signage for impacted businesses in contract specifications. 6.Conduct periodic construction site inspections. Traffic Impact 7.2-1:Construction activities during trenching in city streets will impact traffic circulation during construction period.Less than Significant with Mitigation Measures. Measure 7.2-ia:Traffic Control Plans.Traffic control plans will be prepared by a qualified professional engineer,prior to the construction phase of each sewer line project as implementation proceeds. Measure 7.2-ib:Alternative Routes.Traffic control plans will consider the ability of alternative routes to carry additional traffic and identify the least disruptive hours of construction site truck access routes,and the type and location of warning signs,lights and other traffic control devices.Consideration will be given to maintaining access to commercial parking lots,private driveways and sidewalks,bikeways and equestrian trails,to the greatest extent feasible. OCSD Strategic Plan-Resolution 99-19,Attachment B B -26 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Measure 7.2-ic:Encroachment Permits.Encroachment permits for all work within public rights-of-way will be obtained from each involved agency prior to commencement of any construction.Agencies involved include Caltrans,the Orange County Planning and Development Services (PDS) (Development Services Section)and the various cities where work will occur.The District will comply with traffic control requirements,as identified by Caltrans and the affected local jurisdictions. Measure 7.2-id:Traffic Control Plans.Traffic control plans will comply with the Work Area Traffic Control Handbook and/or the Manual of Traffic Controls as determined by each affected local agency,to minimize any traffic and pedestrian hazards that exist during project construction. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE I.Contract with qualified traffic control Maintain traffic control plan,permits,and OCSD Prior to and during construction engineer to prepare Control Plan for construction schedule and methods for each construction project.administrative record. 2.Ensure that issues highlighted in mitigation measures are included in Maintain record of site inspections Control Plan.including post-construction inspections. 3.Include within contract specifications the acquisition of all necessary encroachment permits. 4.Review list of required permits and verify adequacy prior to construction. 5.Conduct periodic site inspections including post-completion inspection. Measure 7.2-ic:Traffic Disruption Avoidance.The construction technique for the implementation of the proposed sewer lines,such as tunneling,cut and cover with partial street closure,or cut and cover with full street closure,shall include consideration of the ability of the roadway system,both the street in question and alternate routes,to carry existing traffic volumes during project construction.If necessary,adjacent parallel streets will be selected as alternate alignments for the proposed sewer improvements.As required by local jurisdictions,trunk sewers will be jacked under select major intersections,to avoid traffic disruption and congestion. Measure 7.2-if:Street Closure.Public streets will generally be kept operational during construction,particularly in the morning and evening peak hours of traffic.Lane closures will be minimized during peak traffic hours. Measure 7.2-ig:Roadway Restoration.Public roadways will be restored to a condition mutually agreed to between the District and local jurisdictions prior to construction. OCSD Sfrategic Plan-Resolution 99-19,Attachment B B -27 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM Measure 7.2-lh:Sewer Construction Coordination.The Districts will attempt to schedule construction of relief facilities to occur jointly with other public works projects already planned in the affected locations,through careful coordination with all local agencies involved. Measure 7.2-li:Emergency Services.Emergency service purveyors will be contacted and consulted to preclude the creation of unnecessary traffic bottlenecks that will seriously impede response times.Additionally,measures to provide an adequate level of access to private properties shall be maintained to allow delivery of emergency services. Measure 7.2-lj:OCTA Coordination.OCTA will be contacted when construction affects roadways that are part of the OCTA bus network. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include adherence to the Traffic Maintain traffic control plan,permits,and OCSD Prior to and during construction Control Plan in contract specifications construction schedule and methods for 2.Contact local authorities listed in administrative record. mitigation measures and maintain record of communication.Maintain record of site inspections 3.Conduct periodic site inspections including post-construction inspections. including post-completion inspection. Measure 7.2-1k:Railroad Encroachment Procedures.This measure is applicable to the following collection systems improvements:Lower Santa Ana River Interceptor Improvements,Newhope-Placentia Trunk Replacement,and Gisler-Redhill System Improvements —B.To reduce impacts to railroad rights-of-way,the District is required to follow the Right-of-Way Encroachment Approval Procedures —SCRRA Form No.36.The procedures for temporary encroachment calls for 1)the submittal of a written statement on the reason and location of the encroachment;2)a completed and executed SCRRA Form No.6,Right-of-Entry Agreement;3)plan check,inspection,and flagging fees;and 4)insurance certificates as described in the Right-of- Entry Agreement.Per SCRRA Form No.6,the District must comply with the rules and regulations of this agreement at all times when working on SCRRA property,including those outlined in the “Rules and Requirements for Construction at Railway Property,SCRRA Form No.37”and General Safety Regulations for Construction /Maintenance Activity on Railway Property”. OCSD Strategic Plan-Resolution 99-19,Attachment B B -28 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include application for SCRRA Maintain encroachment permit OCSD and SCRRA Prior to and during construction encroachment permit in contract application and permit for administrative specifications record. 2.Contact SCRRA prior to project design. Measure 7.2-il:Trails and Bikeways.Short term construction impacts and closures to locally designated trails and bikeways,as found in the County’s Master Plan of Regional Riding and Hiking Trails (RRHT)and Commuter Bikeways Strategic Plan (CBSP),shall be mitigated with detours,signage, flagmen and reconstruction as appropriate.Long term impacts such as permanent trail link closures should be mitigated with provisions for new rights-of- way for trails and/or bikeways and reconstruction. Measure 7.2-im:County of Orange Coordination.Any construction plans that could potentially impact regional riding and hiking trails or Class I bikeways shall be submitted to the County’s Division of Harbors,Beaches and Parks/Trails Planning and Implementation for review and approval prior to project construction activities. Measure 7.2-in:Trails Restoration.Regional Riding and Hiking Trails and Class I Bikeways impacted by construction activities shall be restored to their original condition after project construction. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include adherence with County of Maintain construction design for OCSD and SCRRA Prior to and during construction Orange RRHT and CBSP in contract administrative record. specifications. 2.Contact County of Orange prior to designing detours. OCSD Strategic Plan-Resolution 99-19,Attachment B B -29 ESA I 960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Biology Impact 7.3-1:Based on conceptual alignment information for OCSD’s proposed collection system projects,construction of the collection pipeline system improvements would occur in previously disturbed,developed areas,primarily public streets.No impact to biological resources would occur if projects occur within paved areas.However,if final project alignments are revised to include an undeveloped area or open space,potential impacts to biological resource could occur;in these cases OCSD would conduct additional CEQA as needed to clarify and address impacts to biological resources. Measure 7.3-1:Additional CEQA Review.If in the future,as OCSD develops the design of each specific collection system project for implementation, a project alignment includes unpaved,undeveloped park or open space area,OCSD will conduct additional CEQA review as needed to clarify and address potential impacts to biological resources. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Biological surveys will be conducted Maintain record of previous condition for OCSD Prior to and during construction for construction activities in previously each construction site for administrative undisturbed locations,record. Noise Impact 7.4-1:Construction activities related to the proposed collection system improvements would intermittently and temporarily generate noise levels above existing ambient levels in the project vicinity.Less than Significant with Mitigation Measures. Measure 7.4-la:Hours of Construction.Construction activities shall be limited to between the hours of 7:30 a.m.and 5:30 p.m.and as necessary to comply with local ordinances.Any nighttime or weekend construction activities would be subject to local permitting. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include compliance with local noise Maintain record of construction oversight Prior to and during construction and construction ordinances in for administrative record.OCSD construction specifications. 2.Provide construction oversight to ensure scope of work is carried out. OCSD Strategic Plan-Resolution 99-19,Attachment B B —30 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING P RAM Measure 7.4-ib:Noise Control.All equipment used during construction shall be muffled and maintained in good operating condition.All internal combustion engine driven equipment shall be fitted with intake and exhaust mufflers that are in good condition. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include compliance with local noise Maintain record of construction oversight OCSD Prior to and during construction and construction ordinances in for administrative record. construction specifications. 2.Include noise reduction procedures in construction specifications 3.Provide construction oversight to ensure scope of work is carried out. Measure 7.4-ic:Pile-Driving Noise Reduction.Contractors shall use vibratory pile drivers instead of conventional pile drivers where feasible and effective in reducing impact noise from shoring ofjack-pit locations in close proximity to residential areas,where applicable. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include preference to avoid pilings Maintain record of design specifications.OCSD Prior to project design where possible in project design specifications. Measure 7.4-id:Construction Notification.Sensitive receptors affected by pipeline replacement projects,and manhole rehabilitation activities shall be notified concerning the project timing and construction schedule,and shall be provided with a phone number to call with questions or complaints. OCSD Strategic Plan-Resolution 99-19,Attachment B B -31 ESA /960436 Mitigation Monitonng and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Prepare and distribute notifications.Maintain record of notification OCSD Prior to construction distribution list. Air Quality Impact 7.5-1:The proposed improvements to OCSD’s collection systems would generate short-term emissions of air pollutants,including dust and criteria pollutants,from excavation,installation and/or replacement activities.This is considered a short-term significant impact that would cease at the completion of construction activities.Construction emission impacts are estimated to occur for an average of three to four weeks within one block of any given property.Less than Significant with Mitigation Measures. Measure 7.5-la:Dust Control.The District shall require the contractors to implement a dust abatement program that would reduce fugitive dust generation to lessen impacts to nearby sensitive receptors.The dust abatement program could iiiclude the following measures: •Water all active construction sites at least twice daily. •Cover all trucks having soil,sand,or other loose material or require all trucks to maintain at least two feet of freeboard. •Apply water as necessary,or apply non-toxic soil stabilizers on all unpaved access roads,parking areas and staging areas at construction sites. •Sweep daily (with water sweepers)all paved access roads,parking areas and staging areas at construction sites. •Sweep daily (with water sweepers)if visible soil material is carried into adjacent streets. •Water twice daily or apply non-toxic soil binders to exposed soil stockpiles. •Limit traffic speeds on unpaved roads to 15 mph. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Conduct mitigation measures to reduce Maintain record of construction methods OCSD Prior to and during construction construction air emissions.for administrative record. 2.Conduct periodic construction site inspections.Maintain record of site inspections for administrative record. Measure 7.5-ib:Exhaust Emissions.Contractors shall maintain equipment engines in proper working order and operate construction equipment so as to minimize exhaust emissions.Such equipment shall not be operated during first or second stage smog alerts. OCSD Strategic Plan-Resolution 99-19,Attachment B B —32 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM Measure 7.5-ic:Truck Emissions Reductions.During construction,trucks and vehicles in loading or unloading queues shall be kept with their engines off,when not in use,to reduce vehicle emissions.Construction activities shall be discontinued during second-stage smog alerts. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include air emission reduction Maintain record of construction OCSD Prior to construction mitigation measures in construction specifications and site inspections for specifications.administrative record. 2.Conduct periodic site inspections to verif~’adherence to mitigation measures. Geology Impact 7.6-i:Project facilities would be located in areas susceptible to primary and secondary seismic hazards (groundshaking,liquefaction,settlement). Damage to facilities could result in the event of a major earthquake.Less than Significant with Mitigation Measures. Measure 7.6-ia:Seismic Safety.The District will design and construct new facilities in accordance with District seismic standards and/or meet or exceed seismic,design standards in the most recent edition of the California Building Code. Measure 7.6-ib:Soils Survey.Soils surveys shall be conducted to determine the liquefaction potential along the collection system improvements route. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Use design criteria to reduce seismic Maintain record of construction OCSD Prior to construction hazards.specifications and geotechnical 2.Contract with qualified geologist to information. conduct geotechnical evaluations prior to construction. OCSD Strategic Plan-Resolution 99-19,Attachment B B —33 ESA /960436 Mitigation Monitonng and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM Hydrology Impact 7.7-1:Construction activities could result in erosion and siltation into nearby surface waters,leading to degradation of water quality or flooding hazards.Construction could also result in chemical spills (e.g.,fuels,oils,or grease)to stormwater,and increase turbidity and decrease water quality in waters of the U.S.Less than Significant with Mitigation Measures. Measure 7.7-la:Contractor BMPs.Construction contractors will implement Best Management Practices to prevent erosion and sedimentation to avoid significant adverse impacts to surface water quality. Measure 7.7-lb:Storm Season Restrictions.In addition,open-trench installation of pipelines across open drainage channels and the interplant connector shall be limited to the dry season. Measure 7.7-ic:County of Orange Coordination.The District shall coordinate with the Orange County Public Facilities and Resources Department (Orange County Flood Control District)Planning Section to ensure compatibility and joint use feasibility with existing and future projects. Measure 7.7-id:Waterway Protection.The District shall incorporate into contract specifications the requirement that the contractor(s)enforce strict on-site handling rules to keep construction and maintenance materials out of receiving waters.The rules will include measures to: •Store all reserve fuel supplies only within the confines of a designated construction staging area. •Refuel equipment only within designated construction staging area. •Regularly inspect all construction vehicles for leaks. Measure 7.7-le:Spill Prevention.The District shall incorporate into contract specifications the requirement that the contractor(s)prepare a Spill Prevention,Control,and Countermeasure Plan.The plan would include measures to be taken in the event of an accidental spill. Measure 7.7-if:Spill Containment.The District shall incorporate into contract specifications the requirement that the construction staging areas be designed to contain contaminants such as oil,grease,and fuel products so that they do not drain towards receiving waters or storm drain inlets.If heavy duty construction equipment is stored overnight adjacent to a potential receiving water,drip pans will be placed beneath the machinery engine block and hydraulic systems. OCSD Strategic Plan-Resolution 99-19,Attachment B B -34 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Implement BMPs of State-wide Maintain compliance with SWMP and OCSD On going SWPPP.SPCC for administrative record. 2.Prepare construction SWPPP for sites Including annual reports to the SWRCB. greater than 5 acres. 3.Implement existing SWMP and SPCC.Maintain record of site inspections and 4.Periodically update SWMP and SPCC.sample analysis results. 5.Provide adequate spill prevention and surface water management SOPs in contract specifications. 6.Periodically inspect construction sites. Measure 7.7-ig:Flood Control Facilities.The District will contact the Orange County Flood Control District prior to excavation activities involved with the construction of the interplant connector to ensure the integrity of the flood control system along the Santa Ana River. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Contract with qualified engineer to Maintain reports for administrative OCSD Prior to construction of interplant assess structural impacts to SAR levee record.connector. prior to construction of interplant connector.Maintain record of site inspections. 2.Periodically inspect construction site. Public Services Impact 7.8-1:Construction of the collection pipeline system could result in short-term disruption of emergency services in the vicinity of the project area. Less than significant with Mitigation Measures. Measure 7.8-la:Traffic Control Plan Notifications.The contractor shall provide a copy of the Traffic Control Plan to the Sheriff’s Department local police departments and fire departments prior to construction.The District shall provide 72-hour notice of construction to the local service providers of individual pipeline segments. OCSD Strategic Plan-Resolution 99-19,Attachment B B -35 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM Measure 7.8-ib:Emergency Facility Access.Access to fire stations and emergency medical facilities must be maintained on a 24-hour basis and at least one access to medical facilities shall be available at any one time during construction.The District shall notify appropriate officials at the impacted medical facility regarding construction schedule. Measure 7.8-ic:Trench Openings.Trenches shall be promptly backfihled after pipeline installation.If installation is incomplete,steel trench plates shall be used to cover open trenches. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include site safety measures in contract Maintain record of notifications for OCSD During construction specifications.administrative record. 2.Notify local authorities of construction schedule.Maintain record of site inspections. 3.Maintain access to emergency facilities during construction activities including during non-work hours. 4.Periodically inspect construction sites. Impact 7.8-2:Construction of the collection system projects would create a public safety hazard in the vicinity of the construction area.Less than Significant with Mitigation Measures. Measure 7.8-2a:Pedestrian Safety.Construction contractors shall ensure that adequate barriers would be established to prevent pedestrians from entering open trenches of an active construction area.Warnings shall also be posted sufficient distances from the work area to allow pedestrians to cross the street at controlled intersections rather than having to jaywalk. Measure 7.8-2b:Equipment Security.Construction contractors shall be responsible for providing appropriate security measures,including the provision of security guards,for all equipment staging and/or storage areas needed for the project. Measure 7.8-2c:Construction Refuse.Construction contractors shall dispose of construction refuse at approved disposal locations.Contractors shall not be permitted to dispose of construction debris in residential or business containers. OCSD strategic Plan-Resolution 99-19,Attachment B B -36 ESA I 960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MOMTORII~G ANI)REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include site safety measures in contract Maintain specifications for administrative OCSD Prior to and during construction. specifications.record. 2.Include waste disposal methods in construction specifications.Maintain record of site inspections. 3.Periodically inspect construction sites. Impact 7.8-3:Construction of the collection pipeline system could result in short-term disruption of utility service and may require utilities relocation. Less than Significant with Mitigation Measures. Measure 7.8-3a:Utility Search.A detailed study identifying utilities along the pipeline routes shall be conducted during the design stages of the project. For segments with adverse impacts the following mitigations shall be implemented. •Utility excavation or encroachment permits shall be required from the appropriate agencies.These permits include measures to minimize utility disruption.The District and its contractors shall comply with permit conditions and such conditions shall be included in construction contract specifications. •Utility locations shall be verified through field survey. •Detailed specifications shall be prepared as part of the design plans to include procedures for the excavation,support,and fill of areas around utility cables and pipes.All affected utility services would be notified of the District’s construction plans and schedule.Arrangements shall be made with these entities regarding protection,relocation,or temporary disconnection of services. Measure 7.8-3b:Utility Conflicts.In order to reduce potential impacts associated with utility conflicts,the following measures should be implemented in conjunction with 7.8-3a. •Disconnected cables and lines would be promptly reconnected. •The District shall observe Department of Health Services (DHS)standards which require a 10-foot horizontal separation between parallel sewer and water mains;(2)one foot vertical separation between perpendicular water and sewer line crossings.In the event that the separation requirements cannot be maintained,the District shall obtain DHS variance through provisions of water encasement,or other means deemed suitable by DHS;and (3) encasing water mains in protective sleeves where a new sewer force main crosses under or over an existing sewer main. Measure 7.8-3c:Protect Utilities.The construction contractor shall comply with District requirements and specification to protect existing utility lines. OCSD Strategic Plan-Resolution 99-19,Attachment B B -37 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM Measure 7.8-3d:Agency Coordination.The District should coordinate with the Orange County Public Facilities Resources Department,Orange County Flood Control District,Planning Section,Metropolitan Water District of Southern California,Municipal Water District of Orange County,Coastal Municipal Water District,and Orange County Water District,and affected jurisdictions to ensure compatibility and joint use feasibility with existing future projects. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Implement mitigation measures listed Maintain specifications for administrative OCSD Prior to and during construction. above,record. 2.Include underground utility surveys in construction specifications.Maintain record of site inspections. 3.Coordinate with local authorities to minimize utility disruption. 4.Periodically inspect construction sites. Measure 7.8-3e:Identify Abandoned Oil Wells.Prior to construction,the District shall identify existing and abandoned oil production wells within the project area using the California Department of Conservation,Division of Oil,Gas,and Geothermal Resources (DOGGR),District 1 well location maps. Access to identified non-abandoned oil wells will be maintained.Previously abandoned wells identified beneath proposed structures or utility corridors may need to be plugged to current DOGGR specifications including adequate gas venting systems. Measure 7.8-3f:Abandon Wells.Should construction activities uncover previously unidentified oil production wells,the DOGGR will be notified,and the well will be abandoned following DOGGR specifications for well abandonment. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include existing and abandoned oil Maintain specifications for administrative OCSD Prior to and during construction. well surveys in construction record. specifications. 2.Coordinate with Department of Maintain record of oil well discoveries Conservation to expedite search.and searches for the administrative record. OCSD Strategic Plan-Resolution 99-19,Attachment B B —38 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING P RAM Aesthetics Impact 7.9-1:Project implementation could result in short-term visual impacts resulting from construction activities.Less than Significant after Mitigation Measures. Measure 7.9-la:Construction Site Restoration.The District shall ensure that its contractors restore disturbed areas along the pipe line alignment to a condition mutually agreed to between the District and local jurisdictions prior to construction such that short-term construction disturbance does not result in long-term visual impacts. Measure 7.9-ib:Construction Housekeeping.Construction contractors shall be required to keep construction and staging areas orderly,free of trash and debris. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include construction site house-Maintain specifications for administrative OCSD Prior to and during construction. keeping measures in contract record. specifications. 2.Conduct post-construction site Maintain record of site inspections. inspections. Cultural Resources Impact 7.10-1:Implementation of the proposed collection system improvements may affect known,significant archaeological resources.Less than Significant with Mitigation Measures. Measure 7.10-1:Archaeological Surveys.During project design,within the area of the 6 recorded archaeological sites within proposed project alignments,a qualified archaeologist shall conduct a subsurface testing program to determine whether intact significant deposits exist in the excavation area.Shall testing indicate that areas of significant deposits do exist,the deposits would be preserved in place,if feasible.If preservation in place is not feasible,a Data Recovery Plan would be prepared to address the removal of those deposits and would be implemented before the beginning of construction.The Plan would define how and when mechanical and manual excavation would be conducted,the anticipated volume of recovered soils, artifact analysis,cataloging and curation,and monitoring and reporting requirements.For the three sites where human remains have been recorded (CA ORA-85,CA-ORA-87,and CA-ORO-300),the District would enter into a written agreement between an archaeological consultant,to be retained by the District,and a Native American representative prior to construction in the vicinity of these sites.This agreement would specif~’terms as to the treatment and disposition of the human remains,and shall define “associated burial goods”with reference to Public Resources Code Sections 5097.94,5097.98,and 5097.99 and Health and Safety Code Section 7050.5. OCSD Strategic Plan-Resolution 99-19,Attachment B B -39 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Contract with a qualified archaeologist Maintain construction specifications for OCSD Prior to and during construction. to conduct pre-construction site administrative record. surveys in areas with a high probability of cultural resources.Maintain record of site inspections. 2.Include necessary actions in specifications shall archaeological artifacts be discovered during construction activities. 3.Conduct post-construction site inspections. Impact 7.10-2:Implementation of the proposed collection system improvements may affect unknown,potentially significant archeological resources.Less than Significant with Mitigation Measures. Measure 7.10-2a:Archaeological Resources.Subsurface construction has a low to very high potential for exposing significant subsurface cultural resources.Due to the likelihood of encountering cultural resources,the District shall implement the following prior to project construction: •Language shall be included in the General Specifications section of any subsurface construction contracts alerting the contractor to the potential for subsurface cultural resources and trespassing on known or potential resources adjacent to the project. •Prior to construction,contractors and District staff will receive an archaeological orientation from a professional archaeologist regarding the types of resources which may be uncovered and how to identif~’these resources during construction activities.The orientation shall also cover procedures to follow in the case of any archaeological discovery. Measure 7.10-2b:Cultural Resources.If cultural resources are encountered at any time during project excavation,construction personnel would avoid altering these materials and their context until a qualified archaeologist has evaluated the situation.Project personnel would not collect or retain cultural resources.Prehistoric resources include,but are not limited to,chert or obsidian flakes,projectile points,mortars,and pestles;and dark,friable soil containing shell and bone,dietary debris,heat-affected rock,or human burials.Historic resources include stone or adobe foundations or walls;structures and remains with square nails;and refuse deposits (glass,metal,wood,ceramics),often found in old wells and privies. Measure 7.10-2c:Human Remains Alert.In the event of accidental discovery or recognition of any human remains,the County Coroner would be notified immediately and construction activities shall be halted.If the remains are found to be Native American,the Native American Heritage Commission would be notified within 24 hours.Guidelines of the Native American Heritage Commission shall be adhered to in the treatment and disposition of the remains. OCSD Strategic Plan-Resolution 99-19,Attachment B B —40 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING /REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Implement the mitigation measures Maintain construction specifications for OCSD Prior to and during construction. listed above.administrative record. 2.Contract with a qualified archaeologist to conduct pre-construction site Maintain record of site inspections. surveys for areas with a high probability of cultural resources. 3.Include necessary actions in specifications shall archaeological artifacts be discovered during construction activities. Cumulative Impact 7.11-1:Construction activities of the collection system projects in conjunction with other projects would result in short-term cumulative impacts. Less than Significant with Mitigation Measures. Measure 7.11-la:Coordinate Construction.The District will continue to coordinate construction activities with the county and city public works and planning departments and other local agencies to identif~’overlapping pipeline routes,project areas,and construction schedules.To the extent feasible, construction activities shall be coordinated to consolidate the occurrence of short-term construction-related impacts. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Coordinate with local authorities prior Maintain record of communication and OCSD Prior to construction. to final design.outreach with local authorities for 2.Conduct coordination incentives with administrative record. local jurisdictions. Measure 7.11-ib:Recycling.To reduce cumulative impacts related to solid waste,the District shall make all practicable efforts to recycle where feasible. OCSD Strategic Plan-Resolution 99-19,Attachment B B —41 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MONITORING AND REPORTiNG MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Where feasible,include recycling Maintain record of soils hauling.OCSD Prior to construction. measures in construction contracts. 2.Conduct site surveys to ensure scope of Maintain record site surveys for work is followed,administrative record. Biosolids Impact 8-2:The projected increase in residual solids volumes would increase truck traffic on local roadways.Less than Significant with Mitigation. Measure 8-2:Trucking Impact Reduction.The District shall limit truck trips associated with the transport of residual solids to off-peak hours when possible as a means of reducing truck travel times and minimizing congestion impacts to the regional transportation system. MONITORING AND REPORTiNG MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include preferred schedule in contracts Maintain record of contract for OCSD On going with haulers.administrative record. Impact 8-3:The projected increase in residual solids volumes and related truck traffic would increase ambient noise levels at nearby sensitive receptor locations.Less than Significant with Mitigation Measures. Measure 8-3a:Truck Noise Reduction.The District shall limit truck trips associated with the transport of residual solids at Treatment Plant No.2 to non-noise sensitive (daytime)and non-peak hour periods as a means of reducing exposure of residences to truck-related noise whenever possible. Measure 8-3b:Biosolids Transport.The District shall investigate options for reducing the number of biosolids truck trips at Treatment Plant No.2. The study could focus on evaluating such practices as using underground pipelines to pump biosolids from Plant 2 up to Plant 1. OCSD Strategic Plan-Resolution 99-19,Attachment B B —42 ESA /960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT B,MITIGATION MONITORING I REPORTING RAM MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Include preferred schedule in contract Maintain record of contract for OCSD On going with haulers.administrative record. Impact 8-5:The projected increase in biosolids production from POTWs in the Southern California region could present a cumulative impact on the availability of land application sites.Less than Significant with Mitigation. Measure 8-5a:Biosolids Application Sites.The District will continue to research land application sites in the region and consider the management options including the acquisition of dedicated application sites. Measure 8-5b:Biosolids Land Application.The District will continue to coordinate with other POTWs in the region to cooperatively research innovative ways to solve land availability issues. MONITORING AND REPORTING MONITORING IMPLEMENTATION PROCEDURE ACTIONS RESPONSIBILITY MONITORING SCHEDULE 1.Continue research and efforts to Maintain record of research and efforts OCSD On going increase land application,for administrative record. 2.Coordinate with POTWs in the region. H:\wp.dta\eng\JOBS &CONTRACTS\STRAT PLAN\J-40-4\99\FEIR Certification\MMRP for Resolution 99-19,Attachment B.doc OCSD Strategic Plan-Resolution 99-19,Attachment B B -43 ESA I 960436 Mitigation Monitoring and Reporting Program October 1999 ATTACHMENT C FINDiNGS OF FACT CONCERNiNG PROJECT ALTERNATIVES OCSD Resolution 99-19,Attachment C ATTACHMENT C FINDINGS OF FACT CONCERNING PROJECT ALTERNATIVES INTRODUCTION Pursuant to the California Environmental Quality Act (CEQA)Guidelines Section 15091 as amended January 1,1999,the Orange County Sanitation District (OCSD)upon review of the Final Environmental Impact Report (FEIR),including the comments and responses therein,and based on all the information and evidence in the records,hereby makes the Findings set herein: CEQA and the CEQA Guidelines require that an EIR “describe a range of reasonable alternatives to the project or to the location of the project,which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project...”(CEQA Guidelines 15 126.6(a)If a project alternative will substantially lessen the significant environmental effects of a proposed project,the decision maker should not approve the proposed project unless it determines that specific economic,legal,social,technological,or other considerations make the project infeasible.The findings with respect to alternatives to the project identified in the EIR are described in this section. REASONABLE RANGE OF ALTERNATIVES The EIR analyzed a reasonable range of alternatives.Since the EIR constitutes a program-level analysis of the District’s long-term (2000)planning for it’s entire system,alternatives are considered for several different elements of OCSD’s Strategic Plan.These elements include level of treatment,plant expansion,peak wet weather management,collection system improvements, water reclamationlreuse through the co-sponsorship program between OCSD and the Orange County Water District (OCWD)for Phase I of the Groundwater Water Replenishment (GWR) System Project,ocean disposal facilities,and residual solids/biosolids management. Table I provides a matrix of the alternatives considered for each program element.The key alternatives considered in this EIR,the six alternative treatment scenario and two alternative discharge options,are evaluated at equal level of detail and are discussed in the main body of the EIR.As described in the PEIR,the level of treatment alternatives analyzed include the following: Action Scenarios •Scenario 1:NPDES Permit Compliance without GWR System Project.Provide a level of treatment necessary to meet the NPDES permit conditions and the California Ocean Plan.All wastewater would receive advanced primary treatment with a percentage also receiving secondary treatment prior to ocean discharge.Under this Scenario,the GWR OCSD Resolution 99-19,Attachment C C-i ESA /960436 System would not be implemented,thereby increasing the percentage of secondary effluent available for ocean discharge.The amount of secondary treatment would be governed by the NPDES permit limits. •Scenario 2:NPDES Permit Compliance with GWR System Project.Provide the level of treatment necessary to meet the NPDES permit conditions and the California Ocean Plan.All wastewater would receive advanced primary treatment with a percentage also receiving secondary treatment prior to ocean discharge.In coordination with OCWD,50- 80 mgd average daily flow and up to 100 mgd peak wet weather flow of secondary effluent would be diverted from OCSD to the GWR System.The amount of secondary treatment in the ocean discharge would be governed by needs of the GWR System and by the NPDES permit limits. •Scenario 3:Full Secondary Treatment without GWR System Project.Provide full secondary treatment to all wastewater prior to ocean disposal.Under this Scenario,the GWR System project would not be implemented.The capacity for secondary treatment within both Plants 1 and 2 would be increased to accommodate projected peak flows.The existing facilities would be optimized through flow diversions to minimize the construction of new facilities. •Scenario 4:Full Secondary Treatment with GWR System Project.Provide full secondary treatment to all wastewater prior to ocean disposal.In coordination with OCWD,50-80 mgd average daily flow and up to 100 mgd peak wet weather flow of secondary effluent would be diverted from OCSD to the GWR System.The capacity for secondary treatment within both Plants 1 and 2 would be increased to accommodate projected peak flows.The existing facilities would be optimized through flow diversions to minimize the construction of new facilities. No Project/Existing Conditions •Scenario 5:50:50 Blend without GWR System Project.Maintain the level of treatment currently provided.All wastewater would receive advanced primary treatment with about 50 percent also receiving secondary treatment prior to ocean discharge.Under this Scenario,the GWR System would not be implemented. •Scenario 6:50:50 Blend with GWR System Project.Maintain the level of treatment currently provided.All wastewater would receive advanced primary treatment.In coordination with OCWD,50-80 mgd average daily flow and up to 100 mgd peak wet weather flow of secondary effluent would be diverted from OCSD to the GWR System. Half of the remaining ocean discharge would require secondary treatment. SUMMARY OF COMPARISON OF ALTERNATIVES DEIR Chapter 9.0,Alternatives describes other alternatives to the Preferred Project considered during development of the Strategic Plan,shown on Table ES-lO.DEIR Chapter 9.0 compares the potential environmental impacts of the various project alternatives to those of the Preferred Strategic Plan Alternative.In most cases,the alternatives for each of these system components have similar construction and operation impacts and the same mitigation requirements.All alternatives share the same three significant unavoidable impacts: OCSD Resoluuon 99-19,Attachment C C-2 ESA /960436 •Significant noise,vibration and air quality impacts during construction at the treatment plants. •Significant air quality emissions from increased mobile sources (i.e.,vehicles for deliveries and hauling). •Some of the secondary effects of growth planned by the cities and County land use agencies within the District have been determined to be significant and unavoidable by those agencies.These impacts include,but are not limited to,traffic congestion,air quality impacts,and loss of open space. Except for these significant unavoidable impacts that are common to each alternative,the impacts associated with each alternative can be reduced to less than significant with mitigation.Thus,the alternatives are not clearly distinguished by the number or type of significant impacts they generate.The distinction among the alternatives is the degree of impact.Compared to the Preferred Alternative (Scenario 2),the alternatives do result in more or less of some of the impacts. Table ES-l 1 presents a brief summary of the key characteristics and impacts of each alternative. Scenarios I and 2 require construction and operation of the fewest additional facilities,and provide the least amount of secondary treatment facilities.Scenarios 3 and 4,Full Secondary, require most additional facilities and provide the most secondary treatment (100 percent for all flows).Scenario 2 and Scenario 4 bracket the low end and high end of the range of possible project changes and therefore are the focus of the EIR analysis to assess the range of potential impacts and benefits.Scenarios 5 and 6 represent the District’s current policy to provide sufficient secondary treatment facilities to maintain a 50:50 blend of primary and secondary effluent for ocean discharge.The proposed actions and impacts of Scenarios 5 and 6 fall in between those described for Scenarios 2 and 4.As illustrated in Table ES-il,the six treatment scenario alternatives pose environmental impact trade-offs regarding cross-media impacts to land, air and water resources. OCSD Resolution 99-19.Attachment C C-3 ESA I 960436 TABLE ES-tO:ALTE TWES CONSIDERED Alternative Collection System Treatment Level / Effluent Quality Water Reuse Peak Wet Weather ] How Management I Ocean Disposal Residuals Management PREFERI(ED ALTERNATIVE •“Base Case”- Upsizing existing trunk sewers. Manhole rehab- ilitation. •Scenario 2 -Produce a blend of primaly and secondary effluent that meets NPDES permit requirements for ocean discharge. Increase secondary treatment capacity to support GWR System. •Continue existing reuse programs: GAP and Talbert saltwater intrusion barrier. •Implement GWR System -Phase 1. •Implement 13 mgd conservation by 2020. •Implement 20%I/I reduction, •Utilize and maximize existing in-plant storage. Participate in GWRS - Phase 1. •Use 78-inch outfall for infrequent wet weather discharge. •Use existing 120- inch Outfall, •Use 78-inch outfall for infrequent wet weather discharge at an estimated frequency of once every 3 years by the year 2020. •Continue existing beneficial reuse program for land application of biosolids to the extent possible. •Continue current program of landfill disposal for grit and screenings. NO PROJECT ALTERNATIVE (1989 Strategic Plan) •Similar collection projects to those of Preferred Alternative. •Produce a blend of 50 percent primary and 50 percent secondary effluent for ocean discharge (Scenarios 5 and 6). •Continue existing reuse programs: GAP and Talbert saltwater intrusion barrier, Construct and use a new 120-inch outfall. •Use existing 120- inch outfall. •Construct a new, second 120-inch outfall. •Continue beneficial reuse (land application)of biosolids to the extent possible. •Continue landfill disposal for grit and screenings. Other Options Studied •Construct Super Sewers: Super Bushard Super SARI Super Newhope Super Euclid •Produce 100 percent, full secondary effluent for ocean discharge (Scenarios 3 and 4). •Do not implement GWR System. Increase wastewater influent reductions through increased conservation and I/I flow reduction beyond that included in the Preferred_Alternative. •Construct a new, 120-inch outfall. U Disposal of all biosolids in a landfill. • Construct upstream storage facilities. •Increase storage at the Wastewater Treatment Plants (WWTP5). (See also Collection System alternatives and Disposal alternatives,which contribute to peak wet weather flow management). •Construct a parallel,15,000- foot barrel to the existing 120-inch outfall that connects to the diffuser_section. •Discharge to the Santa Ana River for peak wet weather emergency discharge. OCSD Resolution 99-19,Attachment C C-4 ESA /960436 PROJECT OBJECTIVES The objectives of the Strategic Plan are: (1)To plan for wastewater collection,treatment,and disposal facilities to serve the needs of the OCSD service area through 2020; (2)To ensure compliance with existing and anticipated ocean discharge permit conditions, including the requirements of the 301(h)modified (secondary treatment waiver)National Pollutant Discharge Elimination System (NPDES)permit for discharge; (3)To recommend projects that meet the community’s needs,protect public health,are technically feasible,and are cost effective and environmentally responsible;and (4)To maximize the use of treated effluent for water recycling. PREFERRED ALTERNATIVE The Preferred Alternative in the 1999 Strategic Plan is Treatment Scenario 2 —providing sufficient secondary treatment to meet the needs of the GWR System Project (Phase I for 5 0-80 mgd and 100 mgd of peak flow)and maintaining compliance with NPDES permit requirements for ocean discharge.In order to meet the treatment goals of this scenario,the Strategic Plan identifies capital improvements for both the collection system and the treatment plants.In conjunction with the preferred alternative,the District may be required to use the existing 78-inch diameter outfall to accommodate emergency peak flows in excess of current discharge capacity. Level of Treatment:Treatment Scenario 2 would provide the level of treatment necessary to meet the NPDES permit conditions and the California Ocean Plan.All wastewater would receive advanced primary treatment with a percentage also receiving secondary treatment prior to ocean discharge.In coordination with OCWD,50-80 mgd average daily flow and up to 100 mgd peak wet weather flow of secondary effluent would be diverted from OCSD to the GWR System.The amount of secondary treatment in the ocean discharge would be governed by needs of the GWR System and by the NPDES permit limits. Treatment Plant Expansion:Under treatment Scenario 2,all proposed additional treatment facilities would be located within the existing property boundaries of the District’s Reclamation Plant No.I and Treatment Plant No.2.Figures 3-7 through 3-11 in the DEIR illustrate the treatment plant expansion.Treatment Scenario 2 would require the least number of new facilities of any of the alternatives analyzed. Ocean Discharge:The existing 120-inch diameter outfall has adequate capacity to accommodate dry weather flows to the year 2020 as shown in Figure 3-2 of the DEIR.The outfall would also accommodate most wet weather flows using the combination of peak wet weather management measures outlined on page S-16 of the DEIR.The existing 120-inch diameter outfall’s rated capacity of 480 mgd has been exceeded on five separate occasions since its installation in 1971, reaching 550 mgd during a storm event in 1995.During each event,the outfall was able to OCSD Resolution 99-19,Attachment C C-5 ESA /960436 accommodate all the effluent without requiring emergency discharge at either of the alternative two discharge points.Due to increased development and projected population growth within the service area,peak wet weather flows are estimated to reach 775 mgd by the year 2020 (see Section 3.4).To reconcile the discharge capacity deficiencies during peak flow periods,the District will implement several measures to alleviate peak wet weather flow (DEIR S-16).As a last resort,the District would use the existing 78-inch diameter outfall for infrequent peak flow discharges.Modeling of wet weather flows in the system indicate that the need or probability of use for the 78-inch to handle peak wet weather flow is greater today (three times in five years) than it will be under the preferred project in the future (one time in three years).This is due in part to the hydraulic relief provided by the GWR System,significantly reducing the need for peak wet weather discharges to the near-shore. Collection System:Based on the modeled pipeline deficiencies by the year 2020 within the system,OCSD proposes to replace and rehabilitate pipelines to meet future needs and prevent overflows.In addition,five pump stations were determined to be in need of equipment upgrades. Nearly 47 miles of pipeline replacements (separated into 32 individual projects)are planned almost exclusively within developed city streets.Open trench and jack-and-bore construction would be employed. Biosolids Program:The Strategic Plan recommends no immediate changes in the method of biosolids processing or disposal,however,a number of studies of the system are proposed.The Strategic Plan outlines several process changes which could potentially increase biosolids quality and operational efficiency.None of these technologies are recommended for immediate implementation,but the District will continue to play an active role in researching new technologies and monitoring studies performed nation-wide.The District will need to develop additional land applications for the projected increase in biosolids.The District will continue to research land acquisitions dedicated to biosolids recycling. NO PROJECT ALTERNATIVE The No Project Alternative for the OCSD strategic planning efforts would be continued implementation of the District’s existing adopted program from the 1989 Master Plan,including continued treatment in accordance with the 50:50 blend policy and continued collection system improvement and plant expansion to accommodate planned growth service needs.The CEQA Guidelines,Section 15126.6(e)(3)(A)and (B)indicate that the No Project Alternative in certain cases can be considered as the continuation of previously approved planning policies.In light of this CEQA guidance,this analysis has not considered the termination of capital improvements planned in the 1989 Master Plan as an alternative. Treatment Level:Treatment Scenarios 5 and 6,50:50 blend of advanced primary and secondary effluent,represent the No Project Alternative in terms of treatment level.Scenario 6 incorporates the GWR System Project Phase 1,Scenario 5 does not.Under the No Project Alternative the District would continue this treatment level,which would comply with its current NPDES permit for ocean discharge. OCSD Resolution 99-19,Attachment C C-6 ESA /960436 Collection System:Under the No Project Alternative,OCSD would continue to improve the collection system to eliminate conveyance deficiencies and handle wet-weather flows.About half of the collection system projects included in the 1999 Strategic Plan are the same as those previously analyzed and adopted as part of the 1989 Master Plan.Under the No Project Alternative,collection system projects would have similar temporary community disruption impacts as those proposed in the Preferred Alternative,although fewer trunk sewers would be worked on.The District now has more current and accurate information about the collection system deficiencies and therefore has identified additional projects to improve the system.Under the No Project Alternative,without these additional system improvements,the risk of a sewage spill within the collection system would increase,posing both a human health and environmental health concern. Water Reclamation:With respect to water reuse,the adopted 1989 Master Plan also recommended the District’s active participation in and expansion of water reuse projects.That plan considered options for upstream,satellite water reclamation plants with local distribution systems to support non-potable reuse throughout the service area.These options are no longer under consideration.The GWR System Project concept had not been developed at the time of the 1989 Master Plan.However,given the District’s adopted policy to support additional reuse,it is reasonable to assume that under the No Project Alternative,the District would still participate with OCWD in the development and implementation of the GWR System Project. Ocean DischargefPeak Wet Weather Management:With respect to ocean discharge and peak wet-weather management,the 1989 Master Plan recommended construction of a second 120-inch outfall as part of the long-term program.Therefore,under the No Project Alternative,the District would continue to evaluate the timing and need for implementing this program component and would initiate design studies when appropriate.Hydraulic modeling conducted by the District for the Strategic Plan indicates that the 78-inch diameter outfall may be needed for hydraulic relief during peak wet weather events under current conditions.In fact,the frequency of need is statistically greater under current conditions than under projected conditions in the year 2020. Implementation of the GWR System would provide hydraulic relief,significantly delaying the need for peak wet weather discharges to the near-shore. Biosolids Management:Under the No Project Alternative,the biosolids management program would be essentially the same.The Strategic Plan does not propose significant changes to the current biosolids management policies. Findings The No Project Alternative is hereby rejected for the following reasons: 1.The No Project Alternative as described on page 9-6 of the DEIR would not avoid the significant impacts to land-side resources associated with the Preferred Alternative including air quality,energy resources,and land acreage for biosolids applications.In fact,this alternative would involve construction and operation of more treatment facilities at the District’s two plants,resulting in greater land-side impacts than the preferred OCSD Resolution 99-19,Attachment C C-7 ESA I 960436 project.As discussed on page 10-8 of the DEIR,the No Project Alternative would consume greater amounts of energy and emit more air pollutants than the Preferred Alternative.Larger quantities of biosolids would be produced under the No Project Alternative requiring more land acreage for biosolids recycling.In addition,the No Project Alternative would result in the same three land-side significant unavoidable impacts (summarized in Section V,above)as the preferred project.Under the No Project Alternative,treatment Scenario 5 or 6 would be implemented.Table ES-il in the Executive Summary provides a comparison between treatment scenarios.The No Project Alternative generally results in greater land-side impacts than Scenarios 1 and 2 and less than Scenarios 3 and 4.The No Project Alternative would provide higher quality effluent to the ocean discharge.However,the Preferred Alternative would not create a significant impact to the marine environment that would be reduced or eliminated by the No Project Alternative.The Preferred Alternative would provide adequate treatment to comply with the existing NPDES permit. 2.The No Project Alternative would not reduce the current potential need for emergency discharge to the 78-inch diameter outfall.This near-shore discharge is identified as a significant unavoidable impact due to the potential for beach closures (DEIR Table S-2, Impact 5-9).Under the No Project Alternative,the significant unavoidable impact would remain until a new 120-inch diameter outfall were constructed. 3.The No Project Alternative would require the installation of the new 120-inch diameter outfall to avoid frequent emergency discharges to the 78-inch diameter outfall under peak wet weather conditions.Installation of this parallel outfall could adversely impact the marine environment during construction.Although the Preferred Alternative allows for the possibility that the 120-inch diameter outfall may be needed in the distant future and acknowledges that these impacts could occur (DEIR page 3-38 and 9-10),additional methods of reducing peak wet weather discharges are provided.As described on page S 16 of the DEIR,methods to reduce the need for excess discharge to the 78-inch diameter outfall would include flow reduction via water conservation,inflow and infiltration reduction,in-plant equalization storage,the GWR System,and stormwater detention storage on site.These measures are not explicitly outlined or planned under the No Project Alternative. 4.Impacts from the upgrade and rehabilitation of the collection system under the No Project Alternative would be similar to the Preferred Alternative.However,the additional projects identified under the Preferred Alternative would reduce the risk of overflows or leaks within the collection system.The Preferred Alternative would therefore have fewer potential impacts to public health and safety than the No Project Alternative (DEIR page 9-6). 5.Implementation of the GWR-System would be as likely to occur under the No Project Alternative as under the Preferred Alternative.Therefore,the water reuse project would not be a factor in distinguishing the Preferred Alternative from the No Project Alternative.Either treatment Scenario 5 (no GWR)or 6 (with GWR)is considered to be the No Project Alternative as described in the DEIR on page 3-9. OCSD Resolution 99-19,Attachment C C-8 ESA /960436 6.Under the No Project Alternative,a new 120-inch diameter outfall would be constructed to accommodate project peak wet weather flows.The construction of the new outfall would be the most costly alternative (DEIR page 3-41).The Preferred Alternative would reduce the need for the new outfall through the implementation of wet weather management methods described on page S-16 of the DEIR. OTHER ALTERNATIVES STUDIED FULL SECONDARY TREATMENT The 1999 Strategic Plan analyzes the alternative of providing full secondary treatment for all wastewater flow (Scenarios 3 and 4).The alternative would require additional treatment facilities within the foot-print of the existing treatment plants and use more energy,increase air emissions, and create greater quantities of residual solids for reuse or disposal.The alternative would provide greater treatment than currently required under the 1998 NPDES permit.However,the District’s 30 1(h)waiver NPDES permit requires that full secondary treatment be analyzed. Findings This alternative was rejected since it would not avoid significant impacts of the project: 1.Full secondary treatment would not avoid the significant unavoidable impacts associated with the Preferred Alternative including beach closure during discharges to the near-shore 78-inch diameter outfall.Table S-i of the DEIR provides a comparison of the treatment alternatives.Although full secondary treatment provides for higher quality effluent to the ocean discharge,marine monitoring results suggest that impacts to the marine environment would not be significant under treatment Scenario 2.In addition,treatment Scenario 2 would maintain full compliance with the District’s NPDES permit. 2.Full secondary treatment would require the construction of the greatest number of new treatment facilities of all alternatives analyzed.The additional treatment facilities would create greater operational impacts to energy resources,air quality,and biosolids reuse and disposal facilities as discussed in Chapter 10 of the DEIR. 3.Construction impacts from treatment facility construction would be greater under this alternative.As indicated in Tables 3-2 and 3-3,the Preferred Alternative (Scenario 2) would require the least amount of new treatment facilities.Impacts associated with Full Secondary Scenarios 3 and 4 would include greater air emissions from energy consumption and mobile sources,greater energy requirements,potentially new air emissions permits from the South Coast Air Quality Management District (SCAQMD), need for greater amount of land for biosolids recycling applications,and greater construction impacts including air emissions,noise,and traffic impacts to surrounding neighborhoods (DEIR Chapter 10). 4.The costs associated with the construction and operation of full secondary treatment facilities are significantly greater than with other treatment alternatives.Treatment Scenario 2,the Preferred Alternative,would be the least costly alternative. OCSD Resotution 99-19,Attachment C C-9 ESA I 960436 PEAK WET WEATHER MANAGEMENT As discussed on page S-16 of the DEIR,several strategies were considered to reduce projected peak wet weather flows to the ocean outfall: •Flow reduction via water conservation of up to 13 mgd by 2020. •Inflow and Infiltration (I/I)flow reduction of extraneous water entering the collection system by up to 20%(about 80 mgd)by 2020. •Utilize and maximize existing in-plant storage (7 mg). •Participate in GWR System —Phase 1 (100 mgd peak wet weather flow diversion for reuse). •Add stormwater detention storage at the treatment plants. •Use the 78-inch outfall for infrequent wet weather discharges,only when the capacity provided by all of the above measures is exceeded. In addition to these projects,the District considered several storage and discharge options to increase discharge capacity to accommodate peak wet weather including: •Construction of a new 120-inch deepwater outfall •Construction of a parallel barrel for the existing 120-inch outfall that ties into the diffuser •Discharge to the Santa Ma River •Increased storage at the treatment plants (beyond 7 MG) As discussed in EIR Chapter 9,Alternatives,only construction of the a new 120-inch deepwater outfall is a feasible alternative for peak wet weather flow management.This option would eliminate the need for use of the 78-inch outfall and avoid the need for beach closure.As with the existing 120-inch outfall,effluent discharge from the deepwater location would not affect the near-shore environment and necessitate beach closure.Implementation of the GWR System will significantly delay the need for a new deepwater outfall.The remaining options were eliminated due to questions of feasibility. CONSTRUCT A NEW 120-INCH OUTFALL The 1999 Strategic Plan analyzes the installation of an additional 120-inch diameter outfall extending four to five miles from shore,parallel to the existing outfall.The outfall would provide adequate discharge capacity to meet projected peak wet weather flow volumes well past the year 2020.In addition,the outfall would eliminate the significant unavoidable impacts created by peak wet weather discharges to the near-shore through the 78-inch diameter outfall.Due to the elimination of these significant impacts including the need for beach closure,the installation of the new 120-inch diameter outfall was considered to be the environmentally superior peak wet weather discharge alternative (DEIR page S-16).The construction of a new 120-inch outfall is the only option studied by the District that would eliminate the significant and unavoidable impact (as denoted in the DEIR Summary Table S-2)of beach closure during a peak wet weather event.Even full secondary treatment would not eliminate this impact due to the need to OCSD Resolution 99-19,Attachment C C-b ESA /960436 discharge periodically to the near-shore just as with the other treatment scenarios.However,the new outfall option was not included within the Preferred Alternative for reasons discussed below. Findings This alternative was rejected since it would not meet the third project objective of proposing “projects that meet the community’s needs...and are cost effective and environmentally responsible.”The following issues highlight this deficiency: 1.Installation of a new parallel 120-inch diameter outfall could adversely impact the marine environment during construction.Additional impact analysis would be required prior to implementation.Although the Preferred Alternative allows for the possibility that the 120-inch diameter outfall may be needed in the distant futUre and acknowledges that impacts could occur (DEIR page 3-38 and 9-10),additional methods of reducing wet weather discharges are provided.As described on page S-16 of the DEIR,methods to reduce the need for excess discharge to the 78-inch diameter outfall would include flow reduction via water conservation,inflow and infiltration reduction,in-plant equalization storage,the GWR System,and stormwater detention storage on site. 2.The additional discharge capacity provided by a new outfall at this time would far exceed average daily needs.With a new outfall,the District would have discharge capacity well beyond projected needs in year 2020.The excess of discharge capacity would be a growth inducing element of the system,that would not be sized in accordance with planned land use and projected demand.For peak wet weather management purposes,a new outfall would only be needed an estimated once every three years.The DEIR acknowledges that the 120-inch outfall may be necessary,particularly if the GWR System is not implemented.However,the Preferred Alternative implements actions including the GWR System to avoid creating significant new discharge capacity solely for peak wet weather needs. 3.The construction of the new outfall would be the most costly alternative (estimated at $1 50-200 million)and one of the most expensive hydraulic wet-weather relief options considered.A new deep water outfall would constitute a significant capital expense for a facility needed for infrequent peak wet weather discharges.The additional dry weather capacity would far exceed anticipated need.The Preferred Alternative reduces the need for the new outfall through the implementation of wet weather management methods described on page S-i 6 of the DEIR.At this time,economics render this alternative economically infeasible. CONSTRUCT ON-SITE STORAGE As a means to accommodate peak wet weather flows without increasing discharge capacity,the 1999 Strategic Plan analyzed the installation of peak wet weather storage tanks within the plant sites.These storage tanks would be able to provide temporary storage of untreated wastewater until the treatment plants and discharge facilities were able to accommodate the additional flow. OCSD Resolution 99-19,Attachment C c-il ESA /960436 Findings This option was rejected because it created additional significant environmental impacts or is infeasible for the following reasons: 1.The necessary size of the tanks would create significant visual impacts to the surrounding areas.As discussed on page 9-12 of the DEIR,on-site equalization storage could also create odor,aesthetics,and public safety impacts on local neighborhoods.The Preferred Alternative would avoid these impacts. 2.Underground tanks would be infeasible due to the shallow groundwater levels.As discussed on page 9-12 of the DEIR,due to engineering restraints,the tanks would not have enough storage capacity to be effective.This option was eliminated from consideration as a result. CONSTRUCT A 15,000-FOOT BARREL PARALLEL TO EXISTING OUTFALL As a means of providing additional peak wet weather disposal capacity,the 1999 Strategic Plan considered the installation of a 15,000-foot barrel running on the ocean floor,parallel to the existing 120-inch outfall.The barrel would act as a post-treatment storage chamber during periods of increased flow,providing approximately 150 million gallons per day (mgd)additional discharge capacity.Total discharge capacity would be 633 mgd with this option. Findings This alternative was rejected since it would not meet project objectives: 1.As discussed on page 9-12 of the DEIR,the increased discharge capacity of 150 mgd combined with the existing 480 mgd would not meet the projected 775 mgd peak wet weather flow by the year 2020.As a result,this option was eliminated from consideration. 2.In addition,costs and construction impacts would be significant considering that subsequent peak wet weather relief facilities would be necessary in addition to the 15,000-foot barrel.The Preferred Alternative would avoid these impacts. USE THE SANTA ANA RIVER FOR PEAK WET WEATHER DISCHARGE As a means of providing peak wet weather disposal capacity,the 1999 Strategic Plan considered using the Santa Ana River weirs to dispose treated wastewater during peak flow events into the River at Treatment Plant No.2. Findings This alternative was rejected since it would not meet project objectives: OCSD Resolution 99-19,Attachment C C-12 ESA I 960436 1.The perceived impacts to water quality and beneficial uses of the Santa Ana River and the near shore ocean environment removed this option from consideration (DEIR page 9-11). 2.The NPDES permit identifies this disposal location as an extreme emergency discharge location only.This option may have required requesting revisions to the permit from the RWQCB.The Preferred Alternative would avoid these impacts. COLLECTION SYSTEM Construct Super Sewers in the Collection System The 1999 Strategic Plan analyzes the possibility of installing extra large sewer segments along key trunk alignments to reduce the need for up-sizing sewers throughout the trunk system.These “super-sewers”would provide hydraulic relief to certain areas of a trunk system and,in theory, reduce the need for multiple sewer up-sizing construction areas. Findings This alternative was rejected since it would not meet project objectives: 1.After further analysis,the installation of the super-sewers did not appear to provide enough hydraulic relief to eliminate the need for additional up-sizing up-stream.The super sewer alternative would not reduce impacts associated with the base-case sewer upgrades identified as the preferred alternative (DEIR page S-17). 2.The construction impacts associated with the installation of super sewers would be concentrated in one place for longer periods,unduly impacting certain areas.The construction impacts would be greater than with the Preferred Alternative (DEIR page S 17). Construct Up-Stream Equalization Storage in the Collection System As a means to accommodate peak wet weather flows without increasing discharge capacity,the 1999 Strategic Plan analyzed the installation of peak wet weather storage facilities upstream of the treatment plants.These storage tanks would be able to provide temporary storage of untreated wastewater until the treatment plants and discharge facilities were able to accommodate the additional flow. Findings This option was rejected because it would create additional significant impacts for the following reasons: 1.The installation of up-stream storage tanks would create additional impacts to neighborhoods,involving visual impacts,odor,and public safety issues.The Preferred Alternative would eliminate these impacts (DEIR page 9-12). OCSD Resolution 99-19,Attachment C C-13 ESA /960436 2.The costs associated with acquiring the amount of land needed and constructing adequately safe storage facilities was not justified by the perceived need for additional up stream storage.The Preferred Alternative would eliminate these impacts (DEIR page 9- 12). H:\wp.dta\eng\JOBS &CONTRACTS\STRAT PLAN\J-40-4\99\FEIR Certification\Findings Alternatives -Attachment C.doc OCSD Resolution 99-19,Attachment C C-14 ESA /960436