City of Santa Monica Charnock Well Field Restoration Project · 2009-11-19 · Charnock Well Field Restoration Project Final Environmental Impact Report Volume I: Report Prepared

City of Santa Monica

Charnock Well Field Restoration Project

Final Environmental Impact Report Volume I: Report November 2008


Final Environmental Impact Report

Volume I: Report

Prepared by:

City of Santa Monica City of Santa Monica Department of Public Works

Civil Engineering and Architecture Services 1437 4th Street, Suite 300 Santa Monica, CA 90401

Contact: Spiros Lazaris, P.E. (310) 458-2283

Prepared with the assistance of:

Rincon Consultants, Inc. 790 East Santa Clara Street, Suite 103

Ventura, California 93001

November 2008

_______________________________________________________________

This report is printed on 50% recycled paper with 50% post-consumer content and chlorine-free virgin pulp.

Charnock Well Field Restoration Project EIR Table of Contents

City of Santa Monica i


Final EIR

Table of Contents Page VOLUME I Executive Summary ............................................................................................................................. ES-1 1.0 Introduction 1.1 Purpose and Legal Authority ........................................................................................... 1-1 1.2 Scope and Content ............................................................................................................. 1-2 1.3 Areas of Known Controversy .......................................................................................... 1-4 1.4 Lead, Responsible, and Trustee Agencies ...................................................................... 1-4 1.5 Environmental Review Process ....................................................................................... 1-5 2.0 Project Description 2.1 Project Applicant ................................................................................................................ 2-1 2.2 Project Location .................................................................................................................. 2-1 2.3 Existing Site Characteristics .............................................................................................. 2-2 2.4 Project Characteristics ..................................................................................................... 2-15 2.5 Projected Schedule ........................................................................................................... 2-34 2.6 Required Approvals ........................................................................................................ 2-34 3.0 Environmental Setting 3.1 Regional Setting .................................................................................................................. 3-1 3.2 Project Site Setting ............................................................................................................... 3-1 3.3 Cumulative Projects Setting .............................................................................................. 3-2 4.0 Environmental Impact Analysis ..................................................................................................... 4-1 4.1 Aesthetics Effects ............................................................................................................. 4.1-1 4.2 Construction Effects ......................................................................................................... 4.2-1 4.3 Geology Effects ................................................................................................................. 4.3-1 4.4 Hazards and Hazardous Materials Effects ................................................................... 4.4-1 4.5 Hydrology and Water Quality Effects .......................................................................... 4.5-1 4.6 Neighborhood Effects ...................................................................................................... 4.6-1 4.7 Noise .................................................................................................................................. 4.7-1 5.0 Long Term Impacts 5.1 Economic and Population Growth ................................................................................... 5-1 5.2 Removal of Obstacles to Growth ...................................................................................... 5-1 5.3 Irreversible Environmental Effects ................................................................................... 5-2


City of Santa Monica ii

6.0 Alternatives 6.1 CEQA Alternatives Overview ........................................................................................... 6-1 6.2 Project Treatment Options ................................................................................................ 6-3 6.3 Project Alternatives ............................................................................................................. 6-4 6.4 No Project Alternative ........................................................................................................ 6-5 6.5 Reduced Profile Alternative .............................................................................................. 6-6 6.6 GAC Housing Alternative ................................................................................................ 6-9 6.7 SMWTP Only Alternative ............................................................................................... 6-10 6.8 Environmentally Superior Alternative ......................................................................... 6-12 7.0 References and Report Preparers 7.1 References ............................................................................................................................ 7-1 7.2 Report Preparers ................................................................................................................. 7-2 8.0 Response to Comments ................................................................................................................... 8-1 List of Figures Figure 1-1 Environmental Review Process ......................................................................... 1-8 Figure 2-1 Regional Location ................................................................................................ 2-3 Figure 2-2 Project Location ................................................................................................... 2-4 Figure 2-3 Santa Monica Schematic Hydraulic Profile ..................................................... 2-5 Figure 2-4 Charnock Site Layout ......................................................................................... 2-7 Figure 2-5 Charnock Process Flow Diagram ...................................................................... 2-9 Figure 2-6 SMWTP Site Layout .......................................................................................... 2-11 Figure 2-7 Charnock Treatment System ........................................................................... 2-13 Figure 2-8 Site Photos .......................................................................................................... 2-19 Figure 2-9 Site Photos .......................................................................................................... 2-25 Figure 2-10 Site Photos .......................................................................................................... 2-26 Figure 2-11 Site Photos .......................................................................................................... 2-28 Figure 2-12 Site Photos .......................................................................................................... 2-31 Figure 4.1-1 Charnock Photo Simulations ........................................................................ 4.1-11 Figure 4.1-2 Charnock Mitigation Photo Simulations .................................................... 4.1-15 Figure 4.1-3 Charnock Summer Solstice Shadows .......................................................... 4.1-21 Figure 4.1-4 Charnock Winter Solstice Shadows ............................................................. 4.1-23 List of Tables Table ES-1 Summary of Significant Environmental Impacts, Mitigation Measures, and Residual Impacts ...................................................................................... ES-3 Table 1-1 NOP Comment Issues ........................................................................................ 1-2 Table 2-1 Charnock Carbon Change Out Frequency .................................................... 2-22 Table 2-2 Charnock Trip Generation Estimates ............................................................. 2-24 Table 2-3 SMWTP Trip Generation Estimates ................................................................ 2-30 Table 3-1 Cumulative Projects in West Los Angeles ....................................................... 3-2 Table 4.2-1 SCAQMD Air Quality Thresholds ................................................................. 4.2-3


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Table 4.2-2 Typical Noise Levels at Construction Sites .................................................. 4.2-8 Table 4.2-3 Charnock Maximum Daily Construction Emissions (lbs/day) ............... 4.2-12 Table 4.2-4 SMWTP Maximum Daily Construction Emissions (lbs/day) ................. 4.2-13 Table 4.2-5 Salt Water Well Maximum Daily Construction Emissions (lbs/day) .... 4.2-13 Table 4.2-6 Total Project Maximum Daily Construction Emissions (lbs/day) .......... 4.2-13 Table 4.3-1 Liquefaction Zone Criteria .............................................................................. 4.3-4 Table 4.4-1 Hazardous Materials used at Project Sites ................................................... 4.4-7 Table 4.6-1 Summary of Neighborhood Effects ............................................................... 4.6-2 Table 4.7-1 Los Angeles Exterior Noise Standards .......................................................... 4.7-2 Table 4.7-2 Santa Monica Exterior Noise Standards ....................................................... 4.7-4 Table 4.7-3 Measures Sound Levels ................................................................................... 4.7-5 Table 4.7-4 Significance of Changes in Noise Exposure ................................................. 4.7-6 Table 4.7-5 Parking Lot Noise Sources at 100 feet ......................................................... 4.7-12 Table 6-1 Project Development Characteristics ................................................................ 6-5 Table 6-2 Impact Comparison of Alternatives ............................................................... 6-13 VOLUME II Appendices

Appendix A: Notice of Preparation, Initial Study and NOP Comments

Appendix B: Air Modeling Results

Appendix C: IS/MND Comments Received

Appendix D: Archaeological Study

Appendix E: SMWTP Risk Management Program

Appendix F: Charnock Field Noise Data

Appendix G: Treatment Technology Performance Report, Charnock Sub-Basin Los Angeles, California

Demonstration Test Report, Production Aquifer Remediation System, Arcadia Well Field, Santa Monica Water Treatment Plant and Former Mobil Station 18-LDM

Preliminary Design Report, Charnock Well Field Drinking Water Treatment Facility, Santa Monica, California

Appendix H: Hazards and Operability (HAZOP) Study, Production Aquifer Remediation System, Arcadia Well Field, Los Angeles, California

Appendix I: Updated Project Description

Appendix J: Mitigation Monitoring and Reporting Program


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Charnock Well Field Restoration Project EIR Executive Summary

City of Santa Monica ES-1

EXECUTIVE SUMMARY This document is a Final Environmental Impact Report (EIR) that addresses the potential environmental effects of the Charnock Well Field Restoration Project involving infrastucture improvements at the Charnock Well Field site and the Santa Monica Water Treatment Plant, both of which are located within the City of Los Angeles. The project is described in greater detail in Section 2.0, Project Description. In addition, the project design was updated during the EIR preparation process to reflect input received on the DEIR, specifically as it pertained to lowering the profile of the project elements at the Charnock location. Appendix I provides a summary of the updated project design as well as an environmental review of the project modifications. The Draft EIR was circulated for public review from August 18, 2008 to October 1, 2008. During that time, written comments were forwarded to the City. The Draft EIR and supporting documents were also available for review on file at the City and on the City’s website. During the public review period, eight written comment letters were received on the Draft EIR (DEIR). All letters received and responses to the comment letters are contained in Section 8.0 Comments and Responses. Section 8.0 Comments and Responses also provides clarification and minor modifications to the DEIR in accordance with CEQA Guidelines Section 15088. The Draft EIR, together with Section 8.0 Comments and Responses and Appendix I comprise the Final EIR for the Charnock Well Field Restoration Project. Changes to the DEIR are noted in strikethough and underline format. This section summarizes the characteristics of the proposed project and the significant environmental impacts, mitigation measures, and residual impacts associated with the proposed project. PROJECT SYNOPSIS Project Applicant City of Santa Monica Department of Public Works Civil Engineering and Architecture Services 1437 4th Street, Suite 300 Santa Monica, CA 90401 Project Description The Charnock well field site encompasses a 10-acre parcel located at 11375 Westminster Ave in the Palms-Mar Vista-Del Rey Community Plan Area of the City of Los Angeles. The Charnock well field site is situated at an average elevation of 97 feet above mean sea level (MSL) approximately 3.5 miles east of Santa Monica Bay, 4 miles south of the Santa Monica Mountains, and approximately 450 feet west of Interstate 405. The facility is located adjacent to Windward School and a residential neighborhood located to the south. The well field covers an area of approximately 450,000 square feet (10 acres) and is bounded by Sawtelle Boulevard to the east, Westminster Avenue to the south, Butler Avenue to the west and the Westwood Flood Control Channel (Westwood Channel) to the north.



The Santa Monica Water Treatment Plant (SMWTP) site encompasses a 4.8-acre parcel located at 1228 S. Bundy Drive in the West Los Angeles Community Plan Area of the City of Los Angeles. This location is approximately 1,250 feet east of the eastern limit of the City of Santa Monica. The facility is bordered by Saltair Avenue on the east, and Texas Avenue on the south (see Section 2.0, Project Description, Figure 2-2). The facility is located within a predominantly residential neighborhood, with commercial businesses and office buildings located to the north. In addition, the SMWTP has an ion exchange water softening treatment system. This system utilizes salt water that is piped from two salt water wells located on Santa Monica Beach. The two existing salt water wells are located west of Pacific Street and Ocean Avenue on the Santa Monica Beach. The project involves implementation of a water treatment system and other improvements that would help to remove groundwater contamination from the Charnock groundwater sub-basin and restore this resource as a water supply for the City of Santa Monica (City). As part of the project upgrades, improvements will be required at two existing City-operated water service facilities; the Charnock well field site and the SMWTP. In addition, the two salt water wells located on Santa Monica Beach may need to be upgraded or replaced as part of this project. With the exception of these well sites that are in the City of Santa Monica, the Charnock and SMWTP sites are located in the western portion of Los Angeles County, in the City of Los Angeles. ALTERNATIVES This analysis is intended to focus on those alternatives that are capable of avoiding or substantially lessening the significant environmental effects of the proposed project, even if the alternatives would impede to some degree the attainment of project objectives or would be more costly [State CEQA Guidelines §15126.6(b)]. A range of reasonable alternatives to the proposed project includes those that can feasibly accomplish most of the basic purposes of the project and could avoid or substantially lessen one or more significant effects. In addition, the “No Project” alternative is required to be evaluated. The following alternatives are described and evaluated in Section 6.0, Alternatives.

• Alternative 1: No Project • Alternative 2: Reduced Project Profile • Alternative 3: Equipment Housing Alternative • Alternative 4: Alternative Site (Move Charnock treatment facility to SMWTP location)

Significant impacts of the project as discussed in Table ES-1 below include the visual effect of the remediation vessels at the Charnock facility, increased lighting at the Charnock facility, construction effects at all facilities, the potential for liquefaction at the SMWTP, the use of chemicals at the Charnock facility and SMWTP (in particular the use of sodium fluoride at the SMWTP), urban pollutants (oil, grease, etc.) that may emanate from the facilities, the potential for a tsunami to affect the salt water well facility, and the noise from on-truck pumps and compressors during the change-out of activated carbon and material deliveries and waste removal. The “No Project” alternative would eliminate these potential consequences of the project, however the importation of drinking water would continue and the local groundwater would remain contaminated and unusable. Importation of water to the City results in substantially greater energy consumption than local groundwater pumping, and this energy



usage produces substantial air pollutants, including the emission of greenhouse gases that contribute to global climate change. In addition, imported water is primarily derived from surface water flows, the loss of which affects biological habitat and reduces the amount of available flow that supports several listed fish species and also reduces wildlife habitat. Overall, the “no project” alternative achieves none of the project objectives. The reduced project profile would reduce the visual impact at the cost of increasing the construction effects because of the excavation and removal of soil. The equipment housing alternative would eliminate the view of the round vessels, but replace it with a rectangular building that may be considered a greater visual impact by viewers. This alternative would also increase construction effects of air pollution emissions, noise, and temporary traffic congestion. Locating the treatment process at the SMWTP would reduce local effects at the Charnock facility by relocating those same effects to the existing SMWTP. While the SMWTP facility is a fully operational water treatment plant with significant water treatment features, the site would be visually impacted due to the water treatment vessels and increased features to a similar level as the Charnock site. This alternative may increase risks associated with the liquefaction hazard present at the SMWTP, which could be reduced to less than significant level given proper design and foundation construction. This alternative would reduce the risk associated with chemical use at Charnock, but such use was not considered significant at this facility because of the limited chemicals to be used. Because this alternative would involve the pipeline transport of contaminated groundwater to the SMWTP, a water pipeline failure could lead to surface and groundwater contamination. This alternative would be subject to California Department of Public Health (DPH) approval and may not be feasible from a regulatory perspective. In summary, none of the alternatives, including the “no project” alternative, is clearly superior to the proposed project with its recommended mitigation measures. SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATION MEASURES Table ES-1 includes a brief description of the environmental issues relative to the proposed project, the identified significant environmental impacts, proposed mitigation measures, and residual impacts. Impacts are categorized by classes. Class I impacts are defined as significant, unavoidable adverse impacts which require a statement of overriding considerations to be issued pursuant to the State CEQA Guidelines §15093 if the project is approved. Class II impacts are significant adverse impacts that can be feasibly mitigated to less than significant levels and which require findings to be made under Section 15091 of the State CEQA Guidelines. Class III impacts are considered less than significant impacts, and Class IV impacts are beneficial impacts.



Table ES-1. Summary of Significant Environmental Impacts,

Mitigation Measures, and Residual Impacts

Impact Mitigation Measures Significance After Mitigation

AESTHETICS EFFECTS Impact AES-1 The proposed project would involve construction of new water treatment facilities including fifteen 24-foot water treatment vessels and other miscellaneous tankage at the Charnock site. These facilities would be largely screened by existing and proposed mitigation and would be consistent with the height limits and massing that would be allowed under the current zoning. In addition, these facilitates would not alter or obstruct the views of any identified sensitive visual resource. As such, the proposed project would not exceed any identified visual impact threshold. The introduction of an industrial looking facility in the largely residential neighborhood has the potential to be perceived as inconsistent with the visual character of the area. This would be a Class II, significant but mitigable impact.

Introduction of site improvements at the SMWTP and the potential two salt water wells that may be constructed on Santa Monica Beach would not exceed any of the visual impact thresholds identified above and would not be inconsistent with the visual character of those areas. Thus the project visual impacts at those locations are considered Class III, less than significant.

AES-1 (a) Additional Screening and Site Design Features. Additional screening and/or site design features shall be implemented to provide visual relief of the onsite features. The physical appearance of the Charnock structures and site screening shall be compatible with and relate harmoniously to surrounding sites and neighborhood. Screening shall be equivalent to or greater than that shown in Figure I-2 (see Appendix I). Note that Photo 1 in Figure I-2 illustrates the minimum extent of screening that would be implemented between year 0 and year 2. Photo 2 in Figure I-2 illustrates the level of screening after year 2. Additional screening would be implemented to help block the currently unobstructed views of the new facility. This additional screening would include such design features as slats in the existing fence (to block the lower portions of the facilities from views through the chain link fence), landscaping or potted trees at base of structures, neutral earth tone colors of tanks and buildings and physical screens or facades. The physical screens or facades could be covered in vines (see Figure I-2), painted in either neutral colors as to mask their presence or as murals to provide a more interesting appearance. The physical screen or façade shall extend along the western portion of the site so as to screen views of the facility that exist over the existing 7 foot hedge row along Westminster Avenue. The Mar Vista Community Council and Windward School will be solicited for aesthetic input to help ensure that their physical location and appearance are compatible with and relate harmoniously to surrounding environs.

Less than significant.



Table ES-1. Summary of Significant Environmental Impacts, Mitigation Measures, and Residual Impacts

Impact Mitigation Measures Significance After Mitigation Impact AES-2 Proposed Charnock project structures would cast shadows onto adjacent properties in excess of those cast by the existing building. The net increase in shadow coverage would only affect the Windward School parking area adjacent to the Charnock site for more than three hours a day during the winter season. Therefore, the effect of shadows on existing uses would Class III, less than significant impact.

None required. Less than significant.

Impact AES-3 The proposed development would introduce new sources of light and glare to the project site. Although project design elements would minimize impacts associated with lighting; the project may subject surrounding properties to increased light and glare. This would be a Class II, significant but mitigable.

AES-3(a) Low-glare Materials. All design and placement of windows shall be of low-glare specification. Paint used for exterior façades shall be of low-reflectivity. Metal surfaces shall be brush-polished, and shall not be highly reflective. AES-3(b) Lighting Plan. Any exterior night lighting installed on the project site shall be of low intensity, low glare design, and shall be hooded to direct light downward onto the subject parcel and prevent spill-over onto adjacent parcels. The applicant shall develop a Lighting Plan incorporating these requirements.


CONSTRUCTION EFFECTS Impact CON-1 Project construction may temporarily place equipment staging on adjacent streets and would temporarily increase truck traffic in the project area. This could disrupt the normal use of the sidewalk and adjacent streets, and affect parking availability. Onsite construction activities would also have the potential to adversely impact activites at Windward School. This would be a Class II, significant but mitigable impact.

CON-1 (a) Construction Impact Mitigation Plan. The City shall prepare and implement a Construction Impact Management Plan which shall be designed to: • Prevent material traffic impacts on

the surrounding roadway network. • Minimize parking impacts both to

public parking and access to private parking to the greatest extent possible.

• Ensure safety for both those constructing the project and the surrounding community.

• Prevent substantial truck traffic through residential neighborhoods.

The Construction Impact Management Plan shall be subject to review and approval by the following City Departments: Department of Public





Impact Mitigation Measures Significance After Mitigation Works, and Department of Planning and Community Development to ensure that the Plan has been designed in accordance with this mitigation measure. This review shall occur prior to commencement of any construction staging for the project. It shall, at a minimum, including the following: Ongoing requirements throughout the duration of construction: • A detailed traffic control plan for work

zones shall be maintained which includes at a minimum accurate existing and proposed: parking and travel lane configurations; warning, regulatory, guide and directional signage: and area sidewalks, bicycle lanes and parking lanes. The plan shall include specific information regarding the projects construction activities that may disrupt normal pedestrian and traffic flow and the measures to address these disruptions. Such plans must be reviewed and approved by the Transportation Management Division prior to commencement of construction and implementation in accordance with this approval.

• Work within the public right-of-way shall be preformed between 9:00 a.m. and 4:00 p.m., including: dirt and demolition material hauling and construction material delivery.

• Streets and equipment should be cleaned in accordance with established Department of Public Works requirements.

• Trucks shall only travel on a City-approved construction route. Truck queuing/staging shall not be allowed on adjacent streets. Limited queuing may occur on the construction site itself.

• Materials and equipment should be minimally visible to the public; the preferred location for materials is to be on-site, with a minimum amount of materials within a work area in the public right-of-way, subject to a current Use of Public Property permit.

• Provisions of off-street parking for construction workers, which may include the use of a remote location




Impact Mitigation Measures Significance After Mitigation with shuttle transport to the site, if determined necessary by the City of Santa Monica.

• The Charnock location will require vehicles and trucks to restrict activities to Westminster Avenue and to avoid any side streets when feasible.

Project Coordination Elements that shall be implemented prior to commencement of construction: • Advise the traveling public of

impending construction activities (e.g. information signs, portable message signs, media listing/notification, implementation of an approved traffic control plan.

• Approval from the City through issuance of a Use of Public Property Permit Sewer or Oversize Load Permit, as well as any Caltrans Permits required, for any construction work requiring encroachment into public rights-of-way, detours or any other work within the public right-of-way.

• Timely notification of construction schedules to all affected agencies (e.g. Police Department, Fire Department, Department of Public Works, and Department of Planning and Community Development) and to all owners and residential and commercial tenants of property withina radius of 500 feet.

• Coordination of construction work with affected agencies in advance of start of work. Approvals may take up to two weeks per each submittal.

• Approval by the Transportation Management Division for haul routes, for earth, concrete or construction materials and equipment hauling.

CON-1(b) Windward School Construction Management Plan. The City shall prepare and implement a Windward School Construction Management Plan to minimize or avoid potential construction impacts associated with onsite construction, including pipeline trenching. The Windward SchoolConstruction Management Plan should focus on informing school and affected




Impact Mitigation Measures Significance After Mitigation parties of pipeline trenching activities and dates. This plan shall include the following:

• Coordination and planning with

Windward School to determine the optimal routing and time period to conduct trenching activities on school grounds in order to avoid or minimize impacts to school activities;trenching shall be planned to occur during summer to the extent that it will not disrupt the construction timeline;

• Timely notification of construction (including trenching) schedule to Windward School and the, surrounding community;

• Develop noise management program in conjunction with the measures safety protocols identified below; and

• Develop safety protocols for any school ground trenching and construction activities. This would include implementation of signage, fencing, trenching zone delineation and securing open non-active trenches, as needed to avoid or minimize the potential impacts associated with onsite construction activities including trenching. These would be in addition to and/or in support of the construction safety measures for the project.

Impact CON-2 Project construction would intermittently generate elevated noise levels on and adjacent to the site. This may affect noise sensitive receptors in the vicinity. This would be a Class II, significant but mitigable, impact.

CON-2(a) Diesel Equipment Mufflers. All diesel equipment shall be operated with closed engine doors and shall be equipped with factory-recommended mufflers. Performance standards shall be set so that noise levels exceeding 75 dBA at a distance of 50 feet from construction and industrial machinery shall be prohibited. CON -2(b) Electrically Powered Tools.Electrical power shall be used to run air compressors and similar power tools. Performance standards shall be set so that noise levels exceeding 75 dBA at a distance of 50 feet from construction and industrial machinery shall be prohibited. CON-2(c) Restrictions on Excavation and Foundation/Conditioning. Excavation, foundation-laying, and conditioning activities (the noisiest





Impact Mitigation Measures Significance After Mitigation phases of construction) shall be restricted to between the hours of 10:00 AM and 3:00 PM, Monday through Friday, in accordance with Section 4.12.110(d) of the Santa Monica Municipal Code. CON-2(d) Additional Noise Attenuation Techniques. For all noise generating construction activity on the project site, additional noise attenuation techniques shall be employed to reduce noise levels to City of Los Angeles noise standards of levels not exceeding 75 dBA at a distance of 50 feet. Such techniques may include, but are not limited to, the use of sound blankets on noise generating equipment and the construction of temporary sound barriers between construction sites and nearby sensitive receptors. CON-2(e) Construction Sign Posting. In accordance with Municipal Code Section 4.12.120, the project applicant shall be required to post a sign informing all workers and subcontractors of the time restrictions for construction activities. The sign shall also include the City telephone numbers where violations can be reported and complaints associated with construction noise can be submitted.

Impact CON-3 The proposed project would require the demolition of buildings and structures that could contain asbestos material or lead-based paints. Therefore, there is potential for a safety hazard to the public or the environment through the release of hazardous materials. However, implementation of appropriate measures regarding the handling and disposal of these materials would reduce these impacts to a Class II, significant but mitigable level.

CON-3(a) Asbestos Survey and Removal. Prior to the initiation of demolition work, areas of the onsite structures proposed for removal shall be sampled as part of an asbestos survey in compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP). If asbestos is found in any building, asbestos-related work, including demolition, involving 100 square feet or more of asbestos containing materials (ACMs) shall be performed by a licensed asbestos abatement contractor under the supervision of a certified asbestos consultant and asbestos shall be removed and disposed of in compliance with applicable State laws. Regardless of whether asbestos is identified in the building, prior to demolition of the existing structure, the South Coast Air Quality Management District (SCAQMD) shall be notified and an





Impact Mitigation Measures Significance After Mitigation SCAQMD Asbestos Demolition and Renovation Compliance Checklist shall be submitted to both SCAQMD and the City of Santa Monica.

CON-3(b) Lead Survey and Removal. Prior to demolition of onsite structures a lead based paint survey shall be performed by a qualified professional. If present, all hazardous materials shall be handled and disposed in accordance with local, state and federal regulations. According to the Department of Toxic Substances Control (DTSC), if paint is not removed from the building material during demolition (and is not chipping or peeling), the material can be disposed of as construction debris (a non-hazardous waste). All lead-based paint removed from these structures shall be hauled and disposed of by a transportation company licensed to transport this type of material. The landfill operator shall be contacted prior to disposal of building material debris to determine any specific requirements the landfill may have regarding the disposal of lead-based paint materials. Following completion of the lead-based paint abatement, a lead-based paint consultant shall provide a report documenting the abatement procedures used, the volume of lead based paint removed, where the material was moved to, and include transportation and disposal manifests or dump tickets. The abatement report shall be prepared for the property owner or other responsible party, with a copy submitted to the City of Santa Monica.

Impact CON-4 Project construction would generate air pollutant emissions however temporary construction impacts would not exceed SCAQMD construction thresholds. Impacts, therefore, would be Class III, not significant.

CON-4(a) Fugitive Dust Control Measures. The following shall be implemented during construction to minimize fugitive dust and associated particulate emissions: • All material excavated or graded

should be sufficiently watered to prevent excessive amounts of dust. Watering should occur at least three times daily with complete coverage, preferably at the start of the day, in the late morning and after work is done for the day

• All grading, earth moving or




Impact Mitigation Measures Significance After Mitigation excavation activities shall cease during periods of high winds (i.e., greater than 20 mph measured as instantaneous wind gusts) so as to prevent excessive amounts of dust

• All material transported on and off-site should be securely covered to prevent excessive amounts of dust

• Soils stockpiles shall be covered • Onsite vehicle speeds shall be

limited to 15 mph • Install wheel washers where

vehicles enter and exit the construction site onto paved roads or wash off trucks and any equipment leaving the site each trip

• Appoint a construction relations officer to act as a community liaison concerning onsite construction activity including resolution of issues related to PM10 generation

• Sweep streets at the end of the day using SCAQMD Rule 1186 certified street sweepers or roadway washing trucks if visible soil is carried onto adjacent public paved roads (recommend water sweepers with reclaimed water)

• All active portions the construction site shall be sufficiently watered three times a day to prevent excessive amounts of dust.

CON-4(b) Ozone Precursor Control Measures. The following shall be implemented throughout construction to reduce emissions of ozone precursors ROC and NOx: • Equipment engines should be

maintained in good condition and in proper tune as per manufacturer’s specifications;

• Schedule construction periods to occur over a longer time period (i.e. lengthen from 60 days to 90 days) during the smog season so as to minimize the number of vehicles and equipment operating simultaneously; and

• Use new technologies to control ozone precursor emissions as they become readily available.

CON-4(c) PM10 and PM2.5 Control Measures. Throughout construction, off-road and on-road diesel equipment




Impact Mitigation Measures Significance After Mitigation shall use Diesel Particulate Features (DPF) to reduce emissions of PM10 and PM2.5.

GEOLOGY Impact GEO-1 Seismically induced ground shaking could destroy or damage structures and infrastructure developed for the proposed project, resulting in loss of property or risk to human health. Provided that the design complies with all applicable provisions of the most recent Uniform Building Code and the California Building Code, impacts would be a Class III, less than significant.


Impact GEO-2 The SMWTP site is located in an area of liquefaction risk. Liquefaction could cause structural failure resulting in loss of property or risk to human health. Impacts would be a Class II, significant but mitigable.

GEO-2 Geotechnical Study. A geotechnical investigation for the SMWTP site and salt water well site (if implemented) will be required as the project proceeds. The City shall comply with all recommendations contained in the Geotechnical Study prepared for the project. In addition, all onsite structures shall comply with applicable provisions of the Uniform Building Code and the California Building Code. The investigation would evaluate the potential for liquefaction to occur and make recommendations to minimize the potential for this hazard to affect the water treatment supply infrastructure. The study would prescribe methods, techniques, and specifications as applicable for: site preparation, treatment of undocumented fill and/or alluvial soils, fill characteristics, fill placement and compactions, temporary excavations and shoring, permanent slopes, treatment of expansive soils, and treatment of corrosive soils. If portions of the site area identified as liquefiable, measures (such as those described above) will be recommended by the project geotechnical consultant and performed by a qualified Geotechnical Engineer and Engineering Geologist.


HAZARDS AND HAZARDOUS MATERIALS Impact HHS-1 The proposed project will utilize activated carbon and chemicals for groundwater treatment. The storage and use of these materials has the potential to result in health risks to workers and to affect

HHS-1(a) Site Safety Engineering Design Features. The final design plans shall meet the American Water Works Association (AWWA) standards for similar water treatment systems. These standards govern the design and





Impact Mitigation Measures Significance After Mitigation the greater numbers of the public. Impacts would be a Class II, significant but mitigable.

installation of products and equipment for safe reliable water treatment systems. The State of California Department of Public Health (DPH) utilizes these standards when developing specific guidelines for drinking water compliance. DPH approval will be required for the projects permit to operate. These will include chemical storage and usage standards and specific water treatment features such as secondary containment, spill detection, alarm systems, pipe material and sizes, backflow prevention devices and double lining of chemical transmission lines. HHS-1(b) Hazards and Operability Study. A Hazards and Operability (HAZOP) study will be prepared by the City and approved by the California Department of Public Health (DPH) prior to the issuance of the projects permit to operate. The HAZOP study will identify potential safety hazards and evaluate potential operational problems in characterizing potential consequences to the surrounding communities in the event of a release of a hazardous material. This document will be prepared in accordance with the evaluation process described in State of California Department of Public Health (DPH) Policy Memorandum 97-005 for the Direct Domestic Use of Extremely Impaired Sources of Drinking Water, issued on 5 November 1997. The HAZOP involves a detailed review of the design of an engineered system to evaluate the safety and operability of the system’s components under varying operational parameters. This study will further evaluate the storage, use and transportation of hazardous materials at the project location. All recommendations and measures identified in this study shall be implemented. The DPH will keep the HAZOP report as part of the permit application file, and will make reference to it in the water supply permit. Anticipated measures include proper identification of storage hazardous materials, implementation of proper spill prevention and countermeasures, emergency response procedures, and other design measures that are




Impact Mitigation Measures Significance After Mitigation necessary to eliminate or minimize to the greatest extent feasible any potential hazards associated with the new facilities and their operations. In addition, the HAZOP study focuses on how a plant or facility will respond to deviations from normal operation. This report will be prepared by the design engineers and approved by a professional engineer. A copy of the study shall be made available at the City of Santa Monica Engineering & Architectural Services Division for review and comment as part of the 97-005 public review process. HHS-1(c) Risk Management Program. For the Charnock location, as required by the Los Angeles City Fire Department, prior to operations, a Risk Management Program shall be prepared, filed and approved by the Los Angeles City Fire Department. The SMWTP shall update its current RMP. The salt water well location will file a Business Plan with the Santa Monica Fire Department. The Risk Management Program is required to reduce the risk of accidental releases. The RMP will have written operational procedures and provide emergency guidance. This document will feature emergency response protocols, emergency response techniques and emergency contact numbers to ensure proper emergency management. A copy of the Risk Management Program shall be made available at the City of Santa Monica Engineering & Architectural Services Division for review and comment prior to finalization of the document. HHS-1(d) Operations Manual. An operations manual shall be prepared once final design is determined. This operations manual will have written operational procedures for site operations and maintenance. This document will feature operational protocols and standard operating procedures to ensure proper facility management. All vendor contracts shall define the site access route as Sawtelle Boulevard to Westminster Avenue and prohibit the use of other residential streets. This document would also




Impact Mitigation Measures Significance After Mitigation include a written training program for all staff. HHS-1(e) OSHA Trained and Certified Operators. Require that all staff be trained for 40 hour OSHA Safety requirements and that all operators have a Class II water certification.

HYDROLOGY AND WATER QUALITY Impact HWQ-1 The proposed project would involve the demolition and reuse of existing structures, construction of new buildings and structures, and installation of new landscaping. Implementation of the City of Los Angeles Urban Runoff Pollution Control Ordinance and National Pollutant Discharge Elimination System (NPDES) requirements would reduce any potential impacts related to erosion and sedimentation from demolition and construction to Class III, less than significant.


Impact HWQ-2 Overall, the Charnock location is expected to generate fewer pollutants in water runoff than the current land uses on the site through the conversion of impervious surfaces to exterior holding areas with permeable surfaces. This is considered an overall beneficial impact. However, the proposed project could still contribute urban pollutants to surface runoff from onsite parking lots and landscaping. Impacts would be a Class II, significant but mitigable.

HWQ-2(a) Best Management Practices. The City shall include best management practices (BMPs), such as sand filters and grease traps, within the reconfigured surface parking lots to intercept and prevent pollutants, sediment, and debris from discharging offsite.

HWQ-2(b) Landscaping Maintenance Plan. A landscaping maintenance plan shall be implemented that limits the use of herbicides and inorganic fertilizers applied to landscaping to quantities that are necessary to treat specific problems. The maintenance plan shall incorporate features from the City of Santa Monica’s Integrated Pest Management Program, which include, but are not limited to the following: pest-resistant landscape materials and pest-repellant plants, provisions for mechanical weed control to be used wherever and whenever possible as the first choice; determination of the probable cause of a disease problem and correction as necessary (e.g., soil nutrient problems, irrigation, water quality, and plant type) prior to chemical use; provisions that herbicides are to be used only when necessary to cure a





Impact Mitigation Measures Significance After Mitigation problem and not as a preventative measure or as a regular, periodic application; and, guidelines for use of chemical forms that have a low potential for leaching from the site.

Impact HWQ-3 The project may require the installation of two salt water wells on Santa Monica beach. The salt water well sites would place them within a potential tsunami inundation area. Impacts would be a Class II, significant but mitigable.

HWQ-3 Tsunami Zone Building Recommendations. Specific flood proofing measures should include permanent sealing of grade level openings; use of paints, membranes, or mortar to reduce water seepage through walls; installation of water tight doors, bulkheads, installation of flood water pumps in structures; and proper modification and protection of all electrical equipment, circuits and appliances so that the risk of electrocution or fire is eliminated.


NOISE Impact N-1 Operation of stationary equipment such as groundwater pumps associated with the proposed project would generate noise levels that may periodically be audible to existing uses near the project site. Impacts would be Class III, less than significant.

No mitigation measures are necessary as no significant impacts are anticipated.


Impact N-2 Operation of mobile equipment such as truck such as truck transfer pumps and compressors associated with the proposed project would generate noise levels that would periodically be audible to existing residences near the project site. Impacts would be Class II, significant but mitigable.

N-2(a) Portable Noise Barriers. Portable noise barriers made from acoustic blankets (minimum STC of 25) at least eight feet in height shall be placed between the noise source on the off-loading trucks and the nearest residences and school buildings. Panels shall overlap and the blanket shall reach to and lie on the ground. The total length of panels shall be no less than 30 feet placed between the source and the receptor, and the panels shall be located no further than 10 feet from the source. The barriers will be designed and implemented such that an hourly Leq of 65 dBA will not be exceeded at the nearest residence. N-2(b) Electric Air Compressor. An electric air compressor located in a sheltered enclosure shall be provided onsite to provide the air pressure needed for GAC change out operations.




AREAS OF PUBLIC CONTROVERSY As discussed in more detail in Section 1.3, visual impacts, noise, traffic and potential hazards associated with the treatment facilites were major issues for neighborhood residents. ISSUES TO BE RESOLVED Issues to be resolved by the City of Santa Monica for the proposed project include: (1) whether or not the project is appropriate and necessary and so should be approved; and (2) whether or not one of the project alternatives should be selected in lieu of the proposed project. The City also must make a determination regarding implementation of recommended mitigation measures. As part of their decision-making, the City will need to make findings regarding those impacts that are considered significant but mitigable. No statement of overriding considerations regarding unavoidable impacts pursuant to Section 15093 of the CEQA Guidelines is necessary for the project as impacts are considered mitigatable; however, if the City chooses not to implement certain mitigation measures or replacement measures that have equal effectiveness, such a finding may then become necessary if the project is approved.



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Charnock Well Field Restoration Project EIR Section 1.0 Introduction

City of Santa Monica 1-1

1.0 INTRODUCTION This document is a Final Environmental Impact Report (EIR) that addresses the potential environmental effects of the Charnock Well Field Restoration Project involving infrastucture improvements at the Charnock Well Field site and the Santa Monica Water Treatment Plant, both of which are located within the City of Los Angeles. The project is described in greater detail in Section 2.0, Project Description. In addition, the project design was updated during the EIR preparation process to reflect input received on the DEIR, specifically as it pertained to lowering the profile of the project elements at the Charnock location. Appendix I provides a summary of the updated project design as well as an environmental review of the project modificaitons. The Draft EIR was circulated for public review from August 18, 2008 to October 1, 2008. During that time, written comments were forwarded to the City. The Draft EIR and supporting documents were also available for review on file at the City and on the City’s website. During the public review period, eight written comment letters were received on the Draft EIR (DEIR). All letters received and responses to the comment letters are contained in Section 8.0 Comments and Responses. Section 8.0 Comments and Responses also provides clarification and minor modifications to the DEIR in accordance with CEQA Guidelines Section 15088. The Draft EIR, together with Section 8.0 Comments and Responses and Appendix I comprise the Final EIR for the Charnock Well Field Restoration Project. Changes to the DEIR are noted in strikethrough and underline format. This section of the EIR further discusses:

• The environmental impact report background; • The legal basis for preparing an EIR; • The scope and content of the EIR; • Lead, responsible, and trustee agencies; and • The environmental review process required under the California

Environmental Quality Act (CEQA). 1.1 PURPOSE AND LEGAL AUTHORITY The authorization to proceed with final design and construction of the proposed project requires the discretionary approval of the City of Santa Monica City Council. Therefore, the project is subject to the requirements of the California Environmental Quality Act (CEQA). In accordance with Section 15121 of the State of California Environmental Quality Act (CEQA) Guidelines, the purpose of this EIR is to serve as an informational document that:

...will inform public agency decision-makers and the public generally of the significant environmental effects of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project.

This EIR has been prepared as a Project EIR pursuant to Section 15161 of the CEQA Guidelines. A Project EIR is appropriate for a specific development project. As stated in the CEQA Guidelines:



This type of EIR should focus primarily on the changes in the environment that would result from the development project. The EIR shall examine all phases of the project, including planning, construction, and operation.

This EIR is to serve as an informational document for the public and City of Santa Monica decision-makers. The process will culminate with City Council hearings to certify a Final EIR and to consider approval to move forward with the final design and construction phases of the proposed project. 1.2 SCOPE AND CONTENT On March 24, 2008 the City of Santa Monica circulated a Notice of Intent to Adopt a Negative Declaration (NOI) and an Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed project. A detailed Environmental Checklist with discussion was included. At that time the project was assigned State Clearinghouse number 2008031109. The document was circulated for a 30-day public review process that included 2 public meetings to receive public input on the content and findings of the IS/MND. These meeting occurred on April 15, 2008 for the Charnock facility and April 17, 2008 for the SMWTP. With regards to the Charnock facility, the public review process revealed that visual impacts, noise and potential hazards were common concerns for respondents. No formal comments were received concerning the SMWTP or the salt water wells. Based on the input received, the City has subsequently re-examined the project and decided to prepare this Environmental Impact Report (EIR). In accordance with the CEQA Guidelines, an Initial Study was prepared for the project and a Notice of Preparation (NOP) was distributed to affected agencies and the public for the required 30-day period on May 20, 2008. A public scoping meeting was held at Winward School on June 12, 2008, to receive comments on the scope of the EIR for the proposed project. The intent of the scoping meeting was to provide interested individuals, groups, public agencies and others a forum to provide input to the Lead Agency verbally in an effort to assist in further refining the intended scope and focus of the EIR. Table 1-1 summarizes the issues relevant to the EIR that were identified in the NOP comments received (approximately 11 letters, in addition to oral comments at the scoping meeting) and the EIR sections where the issues are addressed. The NOP, Initial Study, and NOP comment letters received are included in the EIR in Appendix A. This EIR addresses the issues identified during the scoping process that the City of Santa Monica determined to be potentially significant. The issues addressed in this EIR include:

• Aesthetics • Construction • Geology • Hazards and Hazardous Materials • Hydrology and Water Quality • Neighborhood • Noise



Table 1-1 NOP Comment Issues

Issue EIR Section

Aesthetic impacts of tall structures Aesthetics

Cultural Resources Initial Study – Section VI

Air Quality Impacts Initial Study – Section III

Operational Noise Noise

Operational Truck Impacts Initial Study – Section XIX

Presence of chemicals/hazardous materials Hazards

Groundwater pumping effects Hydrology/Water Quality

City of Los Angeles Permit Oversight Introduction (discussed below)

Pumping Charnock water to SMWTP Alternatives

Construction Hours Construction

Relocating Project to a Santa Monica Location Alternatives

Additional Groundwater Contamination Hydrology/Water Quality

This EIR examines these issues and identifies the potentially significant environmental impacts, including site-specific and cumulative effects, of the project. In addition, the EIR recommends feasible mitigation measures, where possible, that would eliminate or reduce adverse environmental effects of the project. The EIR references pertinent City policies and guidelines, certified EIRs and adopted CEQA documents, and background documents prepared by the City in preparing the analysis. A full reference list is contained in Section 7.0, References and Report Preparers. The analysis performed on this EIR also identified issues that the City of Santa Monica determined to be less than significant. The technical analyses that were used to reach this determination are included in the Initial Study contained in Appendix A. The issues found to be less than significant include:

• Agricultural Resources • Air Quality • Biological Resources • Cultural Resources • Economic and Social Resources • Land Use and Planning • Mineral Resources • Population and Housing • Public Services • Recreation • Shadows • Transportation/Traffic • Utilities and Service Systems



The Alternatives Section of the EIR (Section 6.0) was prepared in accordance with Section 15126.6 of the CEQA Guidelines which requires an evaluation of a “reasonable range” of alternatives capable of avoiding or reducing significant environmental effects of a project. The alternatives discussion evaluates the CEQA-required “no project” alternative, two alternative development scenarios for the site and an alternative site scenario for the Charnock treatment system. It also evaluates the environmentally superior alternative among the alternatives assessed. The level of detail contained throughout this EIR is consistent with the requirements of CEQA and applicable court decisions. The CEQA Guidelines provide the standard of adequacy on which this document is based. The CEQA Guidelines state:

An EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of the proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection, but for adequacy, completeness, and a good faith effort at full disclosure. (Section 15151)

1.3 AREAS OF KNOWN CONTROVERSY As discussed above, in March 2008 the City of Santa Monica circulated an NOI and an IS/MND for the proposed project. A detailed Environmental Checklist with discussion of each checklist issue was included in this notification. The document was circulated for a 30-day public review process that included 2 public meetings to receive public input on the content and findings of the IS/MND. These meetings occurred on April 15, 2008 for the Charnock facility and April 17, 2008 for the SMWTP. The April 15, 2008 Charnock meeting was attended by approximately 25 local community members. The attendees expressed concern regarding a number of issues related to the proposed project. The visual impact of the project was a major concern for several of the neighboring residents. Residents were concerned about the impact of implementing the new the treatment facilities at the Windward School site which is adjacent to a school and a residential neighborhood. In addition, residents expressed concern for noise, traffic and potential hazards at the site. The written comments expanded upon the public concern for these same issues. No formal comments were received concerning the SMWTP or the salt water wells located at Santa Monica Beach. In response to the input received, the City re-examined the project and decided to prepare this Environmental Impact Report (EIR). In accordance with the CEQA Guidelines, an Initial Study was prepared for the project and a Notice of Preparation (NOP) was distributed to affected agencies and the public for the required 30-day period on May 20, 2008. A public scoping meeting was held at Windward School on June 12, 2008, to receive comments on the scope of the EIR for the proposed project. The intent of the scoping meeting was to provide interested individuals, groups, public agencies and others a forum to provide input to the Lead Agency verbally in an effort to assist in further refining the intended scope and focus of the EIR. Table 1-1, above, summarizes the environmental issues that were identified during the public scoping process including



responses to the NOP and received during the scoping meeting. The letters received and the oral testimony provided at the scoping meeting expressed similar concerns for the project. These comments were also similar to the comments that were previously submitted during the previous public review process that was performed for the IS/MND. These topics, all of which focused on the Charnock site, included the visual impacts of the water treatment vessels, chemical and hazardous material usage, noise and traffic. Several comments were also raised concerning the City of Los Angeles permit authority for the project and requesting that the project be moved to a location within the City of Santa Monica. As with the IS/MND process, no formal comments were received concerning specific aspects of the SMWTP or the salt water well locations. 1.4 LEAD, RESPONSIBLE, AND TRUSTEE AGENCIES The State CEQA Guidelines define lead, responsible and trustee agencies. A responsible agency refers to a public agency other than the lead agency that has discretionary approval over the project, and a trustee agency refers to a state agency having jurisdiction by law over natural resources affected by a project. The City of Santa Monica is the lead agency for the project because it holds principal responsibility for approving the project. The City will be responsible for decisions regarding certification of this EIR and review and approval of subsequent stages of design and implementation of the project. Cities are exempt from each others building and zoning ordinances pursuant to California Government Code § 53091, therefore the City of Los Angeles does not have land use permitting authority over this project. Discretionary approval of the project would may be required from the following agencies:

• State of California Department of Public Health • City of Santa Monica/City Council (Adoption of the EIR and approval of subsequent design and

implementation phases of the project) • State Water Resources Control Board (NPDES Permit) • California Coastal Commission (salt water well modifications at Santa Monica Beach) • Los Angeles Regional Water Quality Control Board (permit to discharge to the storm drain from

the Reverse Osmosis facility at the SMWTP site) • Sewer District (permit to discharge to the sewer from the Reverse Osmosis facility at the

SMWTP site to the City of Los Angeles, Department of Public Works, Bureau of Sanitation) 1.5 ENVIRONMENTAL REVIEW PROCESS The major steps in the environmental review process, as required under CEQA, are outlined below and illustrated on Figure 1-1. The steps are presented in sequential order. 1. Notice of Preparation (NOP). After deciding that an EIR is required, the lead agency must file

an NOP soliciting input on the EIR scope to the State Clearinghouse, other concerned agencies, and parties previously requesting notice in writing (CEQA Guidelines Section 15082; Public Resources Code Section 21092.2). The NOP must be posted in the County Clerk’s office for 30



days. The NOP may be accompanied by an Initial Study that identifies the issue areas for which the proposed project could create significant environmental impacts.

2. Draft Environmental Impact Report (DEIR). The DEIR must contain:

a) table of contents or index; b) summary; c) project description; d) environmental setting; e) discussion of significant impacts (direct, indirect, cumulative, growth-inducing and

unavoidable impacts); f) a discussion of alternatives; and g) mitigation measures.

3. Notice of Completion/Notice of Availability of Draft EIR. A lead agency must file a

Notice of Completion with the State Clearinghouse when it completes a Draft EIR and prepare a Public Notice of Availability for the Draft EIR. The lead agency must place the Notice in the County Clerk’s office for 30 days (Public Resources Code Section 21092) and send a copy of the Notice to anyone requesting it (CEQA Guidelines Section 15087). Additionally, public notice of DEIR availability must be given through at least one of the following procedures: a) publication in a newspaper of general circulation; b) posting on and off the project site; and c) direct mailing to owners and occupants of contiguous properties. The lead agency must solicit input from other agencies and the public, and respond in writing to all comments received (Public Resources Code Sections 21104 and 21253). The minimum public review period for a DEIR is 30 days. When a Draft EIR is sent to the State Clearinghouse for review, the public review period must be 45 days unless the Clearinghouse (Public Resources Code 21091) approves a shorter period.

4. Final EIR. A Final EIR must include: a) the Draft EIR; b) copies of comments received

during public review; c) list of persons and entities commenting; and d) responses to comments.

5. Certification of FEIR. Prior to making a decision on a proposed project, the lead agency

must certify that: a) the FEIR has been completed in compliance with CEQA; b) the Final EIR was presented to the decision-making body of the lead agency; and c) the decision-making body reviewed and considered the information in the Final ElR prior to approving a project (CEQA Guidelines Section 15090).

6. Lead Agency Project Decision. A lead agency may: a) disapprove a project because of its significant environmental effects; b) require changes to a project to reduce or avoid significant environmental effects; or c) approve a project despite its significant environmental effects, if the proper findings and statement of overriding considerations are adopted (CEQA Guidelines Sections 15042 and 15043).

7. Findings/Statement of Overriding Considerations. For each significant impact of the

project identified in the EIR, the lead or responsible agency must find, based on substantial evidence, that either: a) the project has been changed to avoid or substantially reduce the magnitude of the impact; b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or c) specific economic, social, or other



considerations make the mitigation measures or project alternatives infeasible (CEQA Guidelines Section 15091). If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency's decision.

8. Mitigation Monitoring Reporting Program. When an agency makes findings on significant

effects identified in the EIR, it must adopt a reporting or monitoring program for mitigation measures that were adopted or made conditions of project approval to mitigate significant effects.

9. Notice of Determination. An agency must file a Notice of Determination after deciding to

approve a project for which an EIR is prepared (CEQA Guidelines Section 15094). A local agency must file the Notice with the County Clerk. The Notice must be posted for 30 days and sent to anyone previously requesting notice. Posting of the Notice starts a 30-day statute of limitations on CEQA legal challenges (Public Resources Code Section 21167[c]).

Section 1.0 Introduction

Figure 1-1 City of Santa Monica

Environmental Review Process

Lead Agency (City of Santa Monica)prepares Initial Study

City sends Notice of Preparation(NOP) to responsible agencies

City prepares Draft EIR

Public Review Period (30 day minimum)

City files Notice of Completion and gives public notice of availability of Draft EIR

City prepares Final EIR, including responses to comments on the Draft EIR

City prepares findings on the feasibility of reducing significant environmental effects

City makes a decision on the project

City files Notice of Determination with County Clerk

City solicits comment from Agencies & Public on the adequacy of the Draft EIR

Responsible Agency decision-making bodies consider the Final EIR

City solicits input from Agencies & Publi c on the content of the Draft EIR

Charnock Well Field Restoration Project EIR

Charnock Well Field Restoration Project EIR 2.0 Project Description


2.0 PROJECT DESCRIPTION This section provides a detailed description of the proposed project, including the project applicant, project location, a description of the major project characteristics, project objectives, and a list of discretionary approvals needed for project approval. In addition, the project design was updated during the EIR preparation process to reflect input received on the DEIR, specifically as it pertained to lowering the profile of the project elements at the Charnock location. Appendix I provides a summary of the updated project design as well as an environmental review of the project modifications. 2.1 PROJECT APPLICANT City of Santa Monica Department of Public Works Civil Engineering & Architecture Services 1437 4th Street, Suite 300 Santa Monica, CA 90401 2.2 PROJECT LOCATION The project involves implementation of a water treatment system and other improvements that would help to remove groundwater contamination from the Charnock groundwater sub-basin and restore this resource as a water supply for the City of Santa Monica (City). As part of the project upgrades, improvements will be required at two existing City-operated water service facilities; the Charnock well field site and the Santa Monica Water Treatment Plant (SMWTP). These sites are located in the western portion of Los Angeles County, in the City of Los Angeles. In addition, two existing salt water wells located on Santa Monica Beach may need to be upgraded or replaced depending upon the final water treatment technology that is implemented at the SMWTP. Figure 2-1 illustrates the location of the project sites in a regional context. The Charnock well field site encompasses a 10-acre parcel located at 11375 Westminster Ave in the Palms-Mar Vista-Del Rey Community area of the City of Los Angeles. The site is identified by Los Angeles County Assessor Parcel Numbers (APNs) 424-902-6270 to APN 424-902-6290 and is zoned OS-1XL (Open Space in Height District 1, Extra Limited). The facility is located adjacent to Windward School and a residential neighborhood located to the south. The Charnock well field site is situated at an average elevation of 97 feet above mean sea level (MSL) approximately 3.5 miles east of Santa Monica Bay, 4 miles south of the Santa Monica Mountains, and approximately 450 feet west of Interstate 405. The well field covers an area of approximately 450,000 square feet (10 acres) and is bounded by Sawtelle Boulevard to the east, Westminster Avenue to the south, Butler Avenue to the west and the Westwood Flood Control Channel (Westwood Channel) to the north (see Figure 2-2). A portion of the site is occupied by a number of small buildings related to the operation and maintenance of the municipal supply wells. Since 1982, the remainder of the site has been used by Windward School, which leases the property from the City of Santa Monica. The proposed Charnock treatment system will be located at the well field, south of the existing contact basin and east of the existing power building, in the storage yard area.



The SMWTP site encompasses a 4.8-acre parcel located at 1228 S. Bundy Drive in the West Los Angeles Community Plan Area of the City of Los Angeles. The site is identified as Los Angeles County Assessor Parcel Number (APN) is 426-300-3270 and is zoned [Q]PF-1XL (Qualified Public Facilities in Height District 1, Extra Limited). This location is approximately 1,250 feet east of the eastern limit of the City of Santa Monica. The facility is bordered by Saltair Avenue on the east, and Texas Avenue on the south (see Figure 2-2). The facility is located within a predominantly residential neighborhood, with commercial businesses and office buildings located to the north. In addition, the SMWTP has an ion exchange water softening treatment system. When it was in operation, this system utilized salt water that is piped from two salt water wells located on Santa Monica Beach. These wells may need to be upgraded or replaced depending upon the ultimate treatment technology that is implemented at the SMWTP. The two existing salt water wells are located west of Pacific Street and Ocean Avenue on Santa Monica Beach. 2.3 EXISTING SITE CHARACTERISTICS The Charnock site has historically been operated by the City as a ground water well field but is not currently active. The existing facilities at the Charnock well field include: five City water supply wells (#13, #15, #16, #18, and #19), a 116,500-gallon contact basin, a booster station, a Metropolitan Water District (MWD) turnout, a chlorine building, a power substation, a control room, and city storage yards. Additionally, 14 abandoned water production wells (#1 to #12, #14 and #17) are also located at the well field. Figure 2-3 depicts the City’s hydraulic profile; Figure 2-4 presents the Charnock Site layout; and Figure 2-5 depicts the Charnock flow process diagram. The primary use of the Charnock property is for water production, treatment and transmission. However, in addition to the water facilities, a portion of the Charnock well field site is leased and is currently occupied by Windward School. A lease provision with the school states that the primary use of the property is for water production, treatment and transmission. The school facility includes classrooms, play fields, a gymnasium, a library and administration buildings. Current enrollment is approximately 500 students. The SMWTP facility services a large portion of the City’s water supply needs. The following water treatment systems are located at the SMWTP site: a contact basin, a chlorine building, an ion exchange system (out of service), a clearwell and pH adjustment, a reservoir/mechanical aeration basin, and the distribution system booster pumps. When it was in use, the ion exchange system utilized two salt water wells that are located on Santa Monica Beach and piped to this facility. The two existing salt water wells are located west of Pacific Street and Ocean Avenue on Santa Monica Beach. The salt water wells are depicted on Figure 2-3. Figure 2-6 shows the SMWTP Site layout. Figure 2-7 depicts the SMWTP flow process diagram.

_̂

_̂

_̂

Charnock WellTreatment Site

SMWTP

Salt Water Wells

4th St

5th St

7th St

3rd St

2nd St

6th St

I-10

Broadw

ay

9th St

Ocean Ave

Colora

doAve

Arizon

a Ave

Lincoln Blvd

Santa

Monica

Blvd

Wilshir

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Palisades Beach Rd

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Main St

10th St

Olympic Blvd

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ay

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Project Vicinity Figure 2-2

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Section 2.0 Project DescriptionCharnock Well Field Restoration Project EIR

Map images copyright © 2008 ESRI and its licensors. All rights reserved. Used by permission.

_̂ Project Locations

Charnock Well Field Restoration Project EIRSection 2 Project Description

Figure 2-3City of Santa Monica

Santa Monica Hydraulic ProfileSource: Worley Parsons Komex, May, 2007.

Boundary of City of Santa Monica-Owned

/ 0 100 200 Feet

Source: Worley Parsons Komex, May, 2007.

Charnock Site Layout Figure 2-4City of Santa Monica






Charnock ProcessFlow Diagram

Drawing Source: Worley Parsons Komex, May, 2007, Revised June 2008.


BACKWASHTREATMENT

SYSTEM

ON TO SEWER

Na HSO

GREENSANDFILTER

3

Cl2

Cl2

Cl2

Cl2 Cl2

Cl2

Cl2

Na HSO3

Na HSO3

Na HSO3

Na HSO3

GREENSANDFILTER

GREENSANDFILTER

GREENSANDFILTER

GREENSANDFILTER

/

Source: Kennedy/Jenks/Chilton, 7, 18, 1990.

Santa Monica Water Treatment PlantSite Layout Figure 2-6



0 46 92 Feet




Green sand filters

MWD water for vessel backflush

Backwash storage and treatment

or to sewer

vessels

vessels to existing contact basin


Charnock TreatmentSystem Layout

Image Source: Worley Parsons Komex, May, 2007, Revised June 2008.

/ Feet0 25 50




2.4 PROJECT CHARACTERISTICS 2.4.1 Project Background The City of Santa Monica owns and operates its own municipal water utility as a self-supporting enterprise. The utility supplies water to the 89,000 residents of Santa Monica through 16,000 service connections supplied by 240 miles of distribution mains. The utility also owns and operates the SMWTP, a water softening and filtration plant capable of treating 14 million gallons per day (MGD) (15,700 acre-feet per year [AFY]). The City’s local supply is produced from three groundwater sub-basins within the Santa Monica Basin of the Los Angeles Coastal Plain: (1) the Charnock sub-basin, located east of the City limits, (2) the Coastal sub-basin, located within the City and extending south and east beyond the City limits, and (3) the Arcadia sub-basin located within the northern portion of the City. The Charnock well field is owned by the City, and until 1996, had been used for drinking water production and treatment since 1924. The Charnock groundwater well field includes five water production wells, the oldest of which (well #13) was installed in 1966, and the newest of which (well #19) was installed in 1989. In 1996, the Charnock groundwater well field was found to be contaminated with methyl tertiary-butyl ether (MTBE) as a result of the release of gasoline from nearby gasoline service stations and other underground storage tanks. The well field was shut down in 1996, and since that time the regional aquifer and individual service stations have undergone considerable subsurface investigation and source remediation. Due to this loss of groundwater production, the City has had to substantially increase imported water supplies from Metropolitan Water District (MWD) to meet its drinking water needs. Currently, approximately 85% of the City’s water supply is purchased from MWD. Between 1998 and 2003, the City and various responsible parties conducted a series of groundwater wellhead treatment technology investigations at the well field (these reports are included in Appendix G). The technologies evaluated during this pilot testing program included air stripping, adsorption using granular activated carbon (GAC), and advanced oxidation using ultraviolet light and hydrogen peroxide. Additional pilot testing was performed in 2003 using an ozone/peroxide AOP system. Based on this testing program it was determined that the optimal treatment process for the Charnock well field was GAC. GAC has been approved by the Department of Public Health (DPH) for the treatment of MTBE-and tertiary-butyl alcohol (TBA) -contaminated drinking water. TBA was not detected in the production wells at the time of shutdown in 1996. However, TBA has since been detected in the regional groundwater monitoring wells surrounding the site and is proposed to be addressed as part of the water treatment process. MTBE and TBA have similar characteristics in that they both:

• Spread further and more rapidly than other constituents of gasoline. • Are persistent in the environment. • Can cause water to become offensive in taste and odor at extremely low levels. • May cause adverse health effects. • Are difficult and expensive to remove from drinking water.



The chemical and physical properties of MTBE allow it to migrate with groundwater, make it potentially hazardous to human health (as a carcinogen), and make it difficult to remove from water. In summary, small amounts of MTBE can contaminate large areas of groundwater, render drinking water offensive to taste and odor, and non-potable, and pose a risk to human health. In addition, to MTBE and TBA, the Charnock groundwater basin historically has been impacted by trichloroethene (TCE) and 1,1-dichloroethene (1,1-DCE). TCE is a persistent VOC contaminant that infiltrates soil and ground water from improper disposal of dry cleaning agents, degreasing solvents, and paint strippers. 1, 1-DCE is used as a solvent and as a gasoline additive. These previously known Charnock groundwater contaminates will also be addressed as part of the water treatment process and will be included as part of the DPH approval process. Along with the implementation of the proposed Charnock treatment project, upgrades and improvements are also required at the SMWTP to bring this water supply back online. The City’s current resin-based cation exchange water softening system located at the SMWTP, was placed in stand-by mode following revisions to the former National Pollution Discharge Elimination System (NPDES) discharge permit which lowered the criteria for discharge of the facility’s backwash water to the storm drain. The water treatment facility currently continues to provide disinfection and water storage activities. In addition, MWD began water fluoridation treatment beginning in November 2007. Previously, in October 2001, the City approved water fluoridation, similar to that provided by MWD, for the City’s municipal system. Fluoridation improvements are to be implemented at the SMWTP as part of this project. Finally, evaluations of the SMWTP disinfection system are being conducted and it is anticipated that improvements to this system will be implemented as part of the facility improvements for this project. The anticipated designs of these improvements are discussed and this EIR assesses the magnitude of the likely impacts that could result from the anticipated improvements. 2.4.2 Project Objectives As noted above, in 1996, the City of Santa Monica’s Charnock groundwater well field was shutdown due to the detection of gasoline compounds, specifically MTBE, in the groundwater. In addition to MTBE, TBA has been detected in the regional monitoring wells surrounding the site and TCE and 1,1-DCE have previously been detected in the groundwater. The sources of the contaminants in the groundwater were determined to be leaking underground storage tanks at gasoline service stations located near the well field. At the time the well field was shut down, the Charnock well field was supplying the City with approximately 50% of its demand. The City’s primary goal with this project is to restore the groundwater resource of the Charnock sub-basin to its full beneficial use in the most expeditious, technically effective and environmentally sound manner possible. This will allow the City to regain the level of water self-sufficiency it had prior to the discovery of MTBE impacts to the groundwater. State drinking water resources have been severely impacted by increased demand, drought and environmental impacts. This project will restore a significant and vital local water resource and will remediate this resource for continued future use.



In September 1994, the Santa Monica City Council adopted the first Santa Monica Sustainable City Program. In February 2003, an updated Sustainable City Plan was adopted. This plan includes goals and strategies for the City government and all sectors of the community to conserve and enhance local resources, safeguard human health and the environment, maintain a healthy and diverse economy, and improve the livability and quality of life for all community members in Santa Monica. One of the guiding principals is the protection, preservation, and restoration of the natural environment. Inherent in this guiding principal is making Santa Monica less reliant on imported water supplied from hundreds of miles away. As mentioned previously, currently, approximately 85% of the City’s water supply is purchased from MWD. The City’s goal is to increase the percentage of locally-obtained potable water to 80% by the year 2010. The removal of the MTBE contamination at the Charnock well field, and the recovery of the largest source of local water supply to the City, moves Santa Monica towards drinking water sustainability, addressing one of the highest priorities in the Sustainable City Plan. Moreover, restoration of local water supplies provides far-reaching benefits: protection of distant aquatic ecosystems, restoration of the environment, reduction of imported water costs, reduction of energy and protection from continued drought and potential emergency conditions. Specific objectives of the Charnock Well Field Restoration Project include:

• Quality. Provide clean, safe drinking water that meets drinking water standards. • Reliability. Provide reliable water treatment, transmission, and distribution

infrastructure that meets long-term operational needs under average and maximum-day demand conditions, and meets City standards for planned, unplanned, and emergency outages.

• Implementation. Optimize system design, permitting and construction by involving stakeholders early in the process.

• Operations. Ensure that the project will meet short-term peak water demands, minimizing the potential for service disruptions and meeting the demands during construction, and ensure that the Charnock treatment facility is designed for ease of use and operation.

• Environmental. Eliminate or mitigate environmental impacts during construction and operation.

• Economic. Minimize life-cycle costs (capital, operating, and maintenance) to the City and its customers.

• Sustainability. Decrease reliance on imported water and bring an important water resource back into beneficial use.

2.4.3 Project Facility and Operation Descriptions The project will involve improvements at two principal locations: 1) Charnock Well Field and 2) the Santa Monica Water Treatment Plant. The project may also include the replacement of two existing salt water wells at Santa Monica Beach. Descriptions of these locations, including current features and proposed improvements are provided below. Improvements at the Charnock Well Field Site. The proposed project would involve the installation of a GAC adsorption system to treat contaminated groundwater from three wells



within the Charnock well field. The proposed Charnock treatment facility will have a capacity of 3,000 gallons per minute and will consist of five treatment trains (or rows) that consist of three vessels each. Four trains would be in operation and one train maintained in standby mode. The major components of the treatment system will include:

• Down-hole chlorination in each well to control microbial growth, which can limit the productivity of the well

• Influent equalization tank • Greensand filtration for iron and manganese removal (one greensand vessel per train) • GAC contactors, two vessels in series, plumbed in a lead-lag configuration per train • Backwash storage with mixing • Backwash treatment system of the greensand vessel to concentrate iron and manganese

solids to reduce the volume of waste flow from the process • 10,000-gallon sump storage tank • Hypochlorite storage and feed building (14 ft by 20 ft) • Sodium bisulfite storage and feed for dechlorination after the greensand filters • Control systems building (8 ft by 15 ft) • Transfer pumps, piping and appurtenances.

GAC changeouts are anticipated to occur 6-12 times annually during the period of peak MTBE, TBA, TCE and 1,1-DCE concentrations at the well field, after which carbon usage will decrease as the concentrations decline. Greensand media for iron and manganese removal is backwashed periodically to restore headloss and is continuously activated by the free chlorine residual that contacts the media. The greensand filters typically are replaced every 10 to 20 years and thus will not likely occur during this project’s operation period. One to two full time staff are expected to operate the facility. The Charnock GAC treatment facility is projected to operate for about 7-10 years. The project will then continue to pump and treat groundwater without the GAC treatment methodology. This portion of the system will be placed into a stand-by mode pending final DPH closure approval. At that point all GAC treatment equipment would be dismantled and removed from the site. Charnock Groundwater Wells. The Charnock well field has been used for potable water production and treatment since 1924. The Charnock well field includes five production wells, the oldest of which (well #13) was installed in 1966, and the newest of which (well #19) was installed in 1989. The locations of the five Charnock wells are shown in Figure 2-4. In addition, Figure 2-8, Photo 1, depicts groundwater Well #15. The wells shown are similar in design and size, however, the production varies from well to well. When these wells were in operation, each well featured wellhead chlorination, whereby chlorine gas was injected into the well to treat potential biological fouling of the well screens. As part of the proposed project, the City is proposing to modify the wellhead treatment to use sodium hypochlorite instead of chlorine gas. Sodium hypochlorite is less hazardous to handle and store while maintaining the same disinfection qualities as chlorine gas. The existing chlorine room is attached to the north side of the control room. Historically, this room was used for chemical storage and metering of the chlorine gas for the downhole and contact basin chlorination systems.

Source: Worley Parsons Komex, 2007.

Charnock Well Field Restoration Project EIRSection 2.0 Project Description


Project Photographs

Photo 1 - View of Charnock Groundwater Well #15. Photo 2 - View of the Charnock Contact Basin.

Photo 3 - View of typical sodium hypochlorite delivery truck. Photo 4 - View of typical delivery truck utilized for a 20,000 pound carbon change out.



A chlorine feed pipeline system is currently in place from the treatment area to groundwater wells 15, 18 and 19. As part of the proposed project, this pipeline system will require modifications and re-routing. The piping for Well #16 is currently located beneath the existing school parking lot and will need to be separated from Well #13 and relocated. The water pipeline alignments for Wells #15, 18 and 19 are currently under the Windward School play fields and will also need to be rerouted from each wellhead to the new treatment area. At a minimum, three tie-ins will be made to separate the flow from Wells #13, 15 and 19 to direct the water to the treatment facility. Since the pipelines from Wells #13, 15, and 19 currently pass underneath the playing fields of Windward School, these lines may be re-routed to pass along the southern portion of the site adjacent to Westminster Avenue. This would minimize trenching and construction across the play fields. The final design and routes of these water lines will be determined during the final design phase of the project. Since the Charnock groundwater wells have been out of service since 1996, the pumps in the wells will need to be inspected, repaired, maintained, or replaced prior to re-commencing production from the Charnock well field. Contact Basin. After the groundwater has been treated, it will be pumped to the existing contact basin system. Figure 2-8, Photo 2, depicts the Charnock contact basin. A contact basin is a surface containment area that holds the water for a period of time to allow for settling of solids and/or to increase the holding time to allow for proper disinfection. The contact basin is located in an enclosed one story structure (approximately 50 foot by 75 foot). The first stage of the contact basin, in the 13,500 gallon upper sedimentation basin, is used for removal of settleable solids, including iron and manganese. The water then will flow into the 103,000 gallon lower contact basin from whence it is pumped from the Charnock Booster Station to the SMWTP. Chlorine Building. The existing chlorine room is attached to the north side of the control room. Historically, this room was used for chemical storage and metering of the chlorine gas for the downhole and contact basin chlorination systems. As discussed above, the City will be switching disinfection treatment from chlorine gas to sodium hypochlorite. The new 14’ x 20’, 280 sf hypochlorite storage and feed building will be located in the northeast portion of the site, approximately 150 feet from its former location. Hypochlorite deliveries are expected to occur once per month. Two trucks will be required during each monthly delivery of (a total of) 6,000 gallons of the 12.5% sodium hypochlorite solution. Figure 2-8, Photo 3, depicts the typical truck that will be used for the sodium hypochlorite deliveries. Storm Drain. A storm drain is located in the northwest corner of the contact basin building. Discharges from the site into this drain are regulated by a National Pollutant Discharge Elimination System (NPDES) permit issued by the State Water Resources Control Board (SWRCB). The City currently has an active NPDES permit which was obtained to regulate pilot test discharge operations. Pipeline System. The existing water pipelines from each of the five wells currently pass under portions of the site in use by the school. The piping for Well #16 is currently located beneath the existing school parking lot and will need to be separated from Well #13 and relocated. The



water pipeline alignments for Wells #15, 18 and 19 are currently under the Windward School playing fields and will also need to be rerouted from each wellhead to the new treatment area. At a minimum, three tie-ins will be made to separate the flow from Wells #13, 15 and 19 to direct the water to the treatment facility. Since the pipelines from Wells #13, 15, and 19 currently pass underneath the playing fields of Windward School, these lines may be re-routed to pass along the southern portion of the site adjacent to Westminster Avenue. This would minimize trenching and construction across the playing fields. The final design and routes of these water lines will be determined during the design phase of the project. Also, the existing chlorine lines which will deliver sodium hypochlorite to each of the wells for downhole disinfection treatment are currently buried and pass under school facilities. Since the Charnock wells have been shut down for an extended period, these lines may need to be replaced and/or rerouted. This also will be determined during the final design phase of the project. Charnock GAC Treatment. The GAC treatment system will be located south of the existing contact basin and east of the power building in the former storage yard area. The general configuration of the GAC treatment facility will be five trains (or rows) of three vessels operated in series (15 vessels). The first vessel will be greensand filtration, and the second two vessels will be GAC contactors. The design will incorporate four trains in operation (duty) and one train maintained in standby-mode. The GAC treated water will discharge into the contact basin where it will be combined with the water from untreated wells (16 and 18). The major components of the treatment system were outlined at the beginning of this Section. The greensand filter will be used to remove iron and manganese upstream of the two GAC contactors. Current plans show the greensand filter contained in a pressure vessel similar in design to the GAC contactors. Periodically, the greensand filter will be backwashed to remove iron and manganese particles that become trapped in the filter. This backwash is planned to be treated separately to concentrate the iron and manganese solids, which results in a lower volume to be discarded. Backwash treatment will likely include a packaged plate settler unit, and the treated water will be recycled back into the equalization tank at the head of the plant. Since the effectiveness of GAC for organics removal is affected by exposure to chlorine, sodium bisulfite, a dechlorination chemical, will be added downstream of each greensand filter. GAC adsorbers are typically operated in series, i.e. a multi-stage arrangement. In multi-stage use, the first vessel in series, i.e. the “lead” vessel, serves as the primary treatment vessel, and the second vessel in series, i.e. the “lag” vessel, acts as a “polishing” step to remove any residual organics from the water. In drinking water systems, the lag adsorber is also used to provide added flexibility and redundancy. The lead adsorber in a series operation such as planned can be used past initial breakthrough (when the contaminants that have exceeded the capacity of the carbon adsorber and “broken through”) because the second adsorber continues to remove the contaminants. After the spent GAC of the lead adsorber is replaced, the valve manifold is adjusted so the flow is reversed, and the vessel containing the new GAC becomes the polishing adsorber. Virgin GAC is commonly used for drinking water treatment. During the pilot tests, coal- and coconut-based carbon were evaluated for use at the Charnock well field and both were deemed acceptable media for the GAC system. Adsorption of organic compounds by GAC occurs when the attractive forces at the carbon



surface overcome the attractive forces of water. The volume of the GAC column where the adsorption of organic constituents occurs is called the mass transfer zone. In a downward-flowing GAC column, the mass transfer zone gradually moves from the top to the bottom of the column until breakthrough occurs. Initial breakthrough occurs when the contaminant first appears in the discharge of the lead GAC vessel, and the time it takes for initial breakthrough to occur is a critical operating parameter that affects the operating cost. It is noted that the GAC removes not only petroleum-based hydrocarbons such as MBTE, TCE, and DCE, but also removes natural organic matter (NOM). NOM comprises the major portion of the total organic carbon (TOC) removed by the GAC and is typically present in concentrations 2-3 orders of magnitude greater than the contaminants of concern. Therefore, the concentration of NOM present in the water to be filtered can substantially affect the timing regarding when breakthrough occurs and the GAC needs to be exchanged. Table 2-1 describes the anticipated carbon change out frequency. To keep the wells running and to maintain the flow through the GAC facility during a changeout, the standby treatment train will be brought online to take the place of the vessels being changed out.

Table 2-1 Charnock Carbon Change Out Frequency

Year MTBE concentration a

(µg/L) Lead Vessel GAC Replacement Frequency b

(times per year) 2010 <1 1 c

2011 10 4 to 7 2012 30 6 to 12 2013 33 6 to 12 2014 26 6 to 10 2015 20 5 to 8 2016 10 4 to 7 2017 5 3 to 5 2018 2 0 2019 1 0 2020 <1 0

a. Source: worst case estimate (highest MTBE concentration) from WorleyParsonsKomex Preliminary Design Report, Charnock Well Field, July 2007

b. Represents the exchange of 80,000 lbs of GAC, i.e. four 20,000 lb vessels, requiring four truckloads of GAC (one truck per vessel). The range shown reflects the uncertainty of the impact of background TOC on GAC bedlife, and estimated changeout frequency is based on desk-top models of MTBE breakthrough, which occurs prior to TCE and DCE breakthrough in the model simulations.

c. Even though MTBE is present in low concentration, GAC adsorption capacity for MTBE may be exhausted by TOC.

During a changeout, the spent GAC will be transferred to a bulk trailer by pressurizing the GAC vessel and using compressed air to force the GAC from the vessel into the trailer. Figure 2-8, Photo 4, depicts the typical truck that will be used for the carbon change outs. The carbon will then be returned to the manufacturer’s plant site for thermal reactivation. Once the carbon removal operation is complete, a charge of fresh GAC will be transferred into the empty vessel. This is accomplished by saturating the GAC in the bulk trailer with water and partially filling the vessel with water. The bulk trailer is then pressurized with compressed air to force the



GAC from the trailer and into the vessel. The GAC will be allowed to sit in the vessel for up to 24 hours to become fully wetted, before a backwash procedure is conducted. Backwashing is conducted after fresh GAC has been placed into a vessel and during regular operation. Backwashing is expected to occur approximately every 8 weeks. Figure 2-9, Photo 1, depicts the typical truck that will be used for backwash pick ups. The backwash procedure involves running clean water in upflow mode through the GAC vessel to remove any remaining air from within the bed, remove particulates that can lead to excessive pressure drop and flow restriction, and remove carbon fines (particles) that may be plugging the underdrain nozzles. Backwash water will be collected and stored in a backwash storage tank (approximately 30,000 gallons). Backwash of GAC will be with treated water, and can be recycled to the head of the plant. Backwash of a GAC vessel that has just been loaded with GAC will be performed to remove GAC fines. The backwash that contains fines will be routed through the backwash treatment system, and then recycled. Treated water will also be used to backwash the greensand filters. Once the backwash water has been drained from the backwash storage tanks, the settleable solids (i.e. sludge – mostly fine particles of carbon with bound contaminants), which accumulate in the bottom of the tanks will be sampled and disposed off-site. This will occur on an as needed basis but is not anticipated to be more than once per month. Sludge will be pumped into disposal trucks and hauled to an approved disposal facility Water which collects in the facility sumps will be transferred to a 10,000-gallon on-site sump storage tank. The source of this water will typically be from one of the following occurrences: 1) precipitation which lands directly on the concrete slab of the GAC facility and collects in the sumps, or 2) process water which is transferred into the sump. This water will be sampled and it is anticipated to be disposed through the sewer system. The treated water from the Charnock treatment facility is discharged into the contact basin where it is combined with the raw groundwater from Wells #16 and #18. The combined water would then flow into the lower basin where it would be rechlorinated and subsequently pumped through the existing Charnock 24 inch transmission pipeline to the SMWTP, as described above. The addition of raw groundwater from wells 16 and 18 provides the City with a total capacity of 5,000 gpm from the Charnock well field. The GAC treated water will be sampled according to the requirements of the DPH permit amendment for the Charnock treatment facility. With implementation of the proposed new facility, the Charnock facility would be visited by one or two staff per day resulting in about 4 new daily trips on the local street system. In addition, there would be periodic carbon change outs, delivery of supplies and materials and disposal of sludge and, possibly, backwash water. Table 2-2 provides the trip generation estimates for the Charnock facility when it is in full operation.



Table 2-2 Charnock Trip Generation Estimates

Trip Uses Trips Vehicles per

activity

AM Peak Hour Trips

PM Peak Hour Trips

Water Department Staff 2 per day 2 (4 ADT) 0-2 0-2 GAC Change Outs 12 per year 4 (8 ADT - 12

times per year) 0-4 0-4

Sodium Hypochlorite Deliveries 1 per month 2 (4 ADT - 12


Sodium Bisulfite Deliveries 1 per month 1 (2 ADT - 12 times per year) 0-1 0-1

GAC Backwash Pick-up* 6 per year 1 (2 ADT 6 times per year) 0-1 0-1

GAC Backwash Sludge Pick-Up 1 per month 3 (6 ADT – 12


* Backwash water may be disposed via storm drain pending water sample results and approved NPDES permit

As shown in Table 2-2 the project would involve up to 12 daily trips (regular staff plus GAC change out) during a peak activity and would involve generation of up to 12 peak hour trips onto the local street system. The GAC carbon change out peak activity would be expected to occur up to 12 times per year during the first years of operation; reducing in subsequent years as the change out frequency declines. This level of traffic generation is not expected to adversely impact traffic or circulation patterns in the project vicinity and would not be expected to result in a decline in any peak hour levels of service at nearby roads or intersections. Improvements at the Santa Monica Water Treatment Plant Site. As previously discussed, the City’s groundwater sources, with the exception of Santa Monica Well No. 1, are pumped to the SMWTP for softening and treatment prior to entering the distribution system. This includes groundwater wells from the Charnock well field, the Olympic well field and the Arcadia well field. The major components of the SMWTP include the existing 5 million gallon reservoir, contact basin, chlorine building, ion exchange system, clearwell and pH adjustment, and distribution system booster pumps. Figure 2-11, Photos 13-16, includes SMWTP site features. As detailed below, the City is currently evaluating several treatment system modifications at this facility including the addition of a fluoridation system, and a switch from chlorine to chloramines for disinfection treatment. Upgrades to the softening system and disinfection delivery system are also being evaluated. SMWTP Water Softening. The City first installed a water softening system to the SMWTP in 1966. This system is currently shut down due to NPDES requirements on the backwash effluent from the softening system. Conditions of the permit were changed in 1999 and, as a result, the current system could not be operated in compliance within the discharge requirements of its NPDES permit. New water softening system improvements will be implemented as part of the proposed project. The proposed water softening system is continuing to be studied; however, the following two options are being considered: 1) rehabilitation of the existing ion exchange system, or 2) construction of a new membrane softening system. Potential environmental effects of both of these options are addressed in this study.

Source: Eco-Tec, 2007.

Source: Rincon C

onsultants, Inc. Decem

ber 2007.

Source: Rincon C


ber 2007.

Source: Worley Parsons Kom

ex, 2007.

Photo 6 - View of typical membrane vessel skid mounted system. Photo 5 - View of typical waste disposal truck.

Photo 7 - View of SMWTP Fluoride Storage and Mixing Area. Photo 8 - View of SMWTP Chlorine Storage and Distribution Building.


Project Photographs


Source: Rincon Consultants, December 2007.



Project Photographs

Photo 9 - View, looking northwest, of the Charnock Treatment area. A portion of the Contact Basin Building is to the left.

Photo 10 - View of Westminster Avenue, looking southwest. The Charnocksite is located to the right in this photo.

Photo 11 - View of front and entrance of the Charnock Treatment area.Photo taken from corner of Westminster Avenue and Corinth Avenue,looking northwest.

Photo 12 - View of Corinth Avenue and surrounding neighborhood. Phototaken from Westminster Avenue, looking southeast.



Ion Exchange. One water softening option is the use of ion exchange technology to remove salts from the groundwater supply wells. There is an existing ion exchange system at the SMWTP which remains functional, though repairs and upgrades must be completed to bring the system back into operation. These improvements include replacing the ion exchange resin, replacing or upgrading the City’s existing salt water wells due to low salt content, testing the saltwater transmission lines and applying for a new NPDES permit. If this system is reactivated, relatively little new construction would be required at the SMWTP. In an ion exchange process, water passes through a bed of sulfonated polystyrene beads that are supersaturated with sodium. Each softening bed has a design flow of approximately 1,500 gallons per minute. The existing SMWTP system has five beds. The ion exchange process takes place as hard water passes through the resin beads. The hardness minerals attach themselves to the resin beads while sodium on the resin beads is released into the water. When the resin becomes saturated with calcium and magnesium, it must be regenerated. The regeneration is done by passing a salt (brine) solution through the resin. At the SMWTP, the regeneration solution is salt water produced from salt water wells located at the City’s beach. The sodium replaces the calcium and magnesium which are discharged in the waste water. The system is fed from the SMWTP 350,000 gallon contact basin. The treated water is then discharged into the 70,000 gallon clearwell and then transferred to the 5 million gallon SMWTP reservoir. The salt water discharge will require a new NPDES permit. Membrane Softening. Another water softening technique that may be used is membrane softening. Reverse osmosis (RO) and nanofiltration (NF) are the membrane technologies that are being considered for the SMWTP. These processes force water through semi-permeable membranes under high pressure, while salts and other dissolved solids are retained. RO systems are typically used for desalination of seawater or brackish water, but have also been used for dissolved solids removal in freshwater sources. The membrane elements are contained in pressure vessels and skid mounted. The units come pre-plumbed from the factory in standard size modules. Feed pumps are used to pressurize the flow and force it through the membranes. Other auxiliary equipment includes a clean-in-place (CIP) system which uses chemicals (typically separate acid and caustic cleaning solutions) to clean the membranes, piping, and acid/antiscalant feed systems and cartridge filters for pretreatment. Pretreatment will also include upstream dechlorination and greensand filtration. Post-treatment typically consists of stabilization with chemical addition. If a membrane softening system is selected for the City’s water supply, approximately 7,500 square feet of new building space would be required. There will be 5 skids, each with about 2.5 mgd capacity. The feed flow will be approximately 10 mgd, possibly with some flow being bypassed, and from 75 to 80 percent recovery. The skid system will be single pass, but with two or three stages (depending on the silica concentration) of RO treatment. Each skid will hold approximately 82 pressure vessels, and each vessel will hold 6 elements. Figure 2-9, Photo 2, depicts a typical membrane configuration. Since membrane filtration removes the majority of dissolved solids, a portion of the feed water would be bypassed around the RO or NF unit and blended with the permeate (to add the lost minerals) to produce the desired finished water quality.

Source: Rincon Consultants, December 2007.



Project Photographs

Photo 13 - View of the SMWTP Ion Exchange Treatment building, lookingnorth.

Photo 14 - View from the top of the SMWTP Ion Exchange Treatmentbuilding, looking northeast.

Photo 15 - View from top of the SMWTP Ion Exchange Treatment building,looking southeast. View includes a portion of the 5-million gallon waterreservoir.

Photo 16 - View of SMWTP and surrounding office structures, looking west.



Because RO and NF membranes can foul rapidly when iron and manganese is in the feed water, greensand filters will be installed upstream of the membrane softening skids. These will be either pressure vessels, as described for the Charnock site, or gravity filters which might be constructed as a retrofit to the existing ion exchange beds. System components and hydraulics have not been full evaluated to confirm this design possibility. As with the Charnock site, treatment of the greensand filter backwash might be needed to minimize water losses at the SMWTP. If a packaged plate settler system is installed, a high percentage of the backwash flow could be returned to upstream of the greensand filters. The main challenge with operating a membrane plant at the SMWTP will be related to the handling of the concentrate waste stream. At a treated flow rate of 6,000 gpm (i.e. 1,000 gpm can be bypassed around the system and blended back in with the permeate), the flow rate of the waste stream can be as much as 20% of the feed stream, i.e. 1,200 gpm or 1.8 MGD. Disposal options which are typically evaluated for this high salt waste stream include one or more of the following: discharge to the sanitary sewer or discharge to the storm drain. The likely option would be disposal via the sanitary sewer (with accompanying NPDES permit and waste requirements). SMWTP Fluoridation. In October 2001 the Santa Monica City Council passed a motion to proceed with fluoridation of the City’s water supply. The City sent out mailers to City customers in the fall of 2007 notifying them of the impending fluoridation of MWD water (which currently supplies approximately 80% of the City’s water supply). In November 2007, MWD proceeded with water fluoridation. The City of Santa Monica fluoridation facilities will consist primarily of a fluoridation building at the SMWTP and a fluoridation vault at Santa Monica Well No. 1. Fluoride injection will occur at three locations: the MWD interconnection SM-1, Santa Monica Well No. 1 (which is currently operating with fluoride injection), and the influent pipeline to the SMWTP reservoir. The fluoride building at the SMWTP will house the bulk sodium fluoride chemical containers, as well as the saturators, solution storage tanks, and metering pumps. The metering pumps in this building will inject sodium fluoride solution at the MWD interconnection and at the SMWTP reservoir. Santa Monica Well No. 1 is currently receiving fluoride that is mixed and transported from the SMWTP. The fluoridation building at the SMWTP will be designed to store 9.5 tons of sodium fluoride (approximately 100 days of storage). A transfer pump will be provided at the SMWTP fluoride building to allow the operators to pump sodium fluoride solution into a truck-mounted solution container. This skid-mounted container will be used to transport the sodium fluoride solution from the solution tanks at the Santa Monica WTP site to Santa Monica Well No.1. Figure 2-9, Photo 7, depicts the fluoride mixing area at the SMWTP. Once filled, an operator will transport the tank to the Santa Monica Well No. 1 site and allow the solution tank to fill by gravity from the truck. SMWTP Disinfection. Disinfection is anticipated to change from injection of chlorine gas to sodium hypochlorite, and conversion from free chlorine to chloramination. To do this, a sodium hypochlorite feed system will be installed. Aqueous ammonia will be injected into the water upstream of the 5 MG reservoir. The chlorine and ammonia will react in the water to form chloramines. The chlorine and ammonia injections would take place downstream of the



future softening system, but before the softened water enters the reservoir at the SMWTP. The primary reason to switch to chloramination is to be consistent with water produced by MWD. The City will have to acquire a permit and develop a risk management plan for the aqueous ammonia. Figure 2-9, Photo 8, depicts the Chlorine Building at the SMWTP. This site is currently in operation 24 hours a day, 7 days a week and has 10 full time and 4 part time employees that report to the site. No new additional employee related trips are anticipated for the SMWTP. Table 2-3 provides the trip generation estimates for the SMWTP location once the proposed site modifications are implemented.

Table 2-3 SMWTP Trip Generation Estimates

Trip Uses Trips Vehicles per activity AM Peak

Hour Trips

PM Peak Hour Trips

Sodium Hypochlorite Deliveries 1 per month 2 ADT (12 times per

year) 0-1 0-1

Fluoride Deliveries 6 per year 2 ADT (6 times per year) 0-1 0-1

Ammonia 1 per month 2 ADT (12 times per year) 0-1 0-1

Antiscalant 1 per month 2 ADT (12 times per year) 0-1 0-1

As shown in Table 2-3 the project improvements may involve up to 4 daily trips during a peak activity and would involve generation of up to 4 peak hour trips onto the local street system. The peak activity level would not likely occur given the relative infrequent delivery schedules. This level of traffic generation is not expected to adversely impact traffic or circulation patterns in the project vicinity and would not be expected to result in a decline in any peak hour levels of service at nearby roads or intersections. Salt Water Wells. Two existing salt water wells located near Pacific Street and Ocean Avenue in Santa Monica are used as part of the ion exchange process. The wells are both 18-inch in diameter and have flow rates of 500,000 gallons per day, or about 350 gallons per minute. The wells are shown in Figure 2-12, photos 19 and 20. In addition to the wells, a 12’x20’ building is located on the edge of the parking lot at the foot of Pacific Street and Ocean Avenue. This building supports the pumping and water treatment prior to piping to SMWTP. An 8-inch transmission pipeline from the salt water wells starts in the parking lot at the foot of Pacific Street and Ocean Avenue. The pipeline then runs north along Ocean Avenue, and turns right (east) on Broadway which eventually becomes Ohio Avenue. The pipeline then turns left (north) on Bundy Drive, and heads up Bundy until it reaches the SMWTP near the intersection of Bundy and Wilshire. If the salt water wells are constructed, they will utilize sodium hypochlorite for disinfection. Hypochlorite deliveries are expected to occur once per month. 2.4.4 Project Construction Description and Schedules Information pertaining to the proposed construction descriptions and project schedules of the Charnock and SMWTP locations are provided below.

Source: Rincon C


ber 2007.


ex, 2007.


ex, 2007.

Source: Rincon C


ber 2007.

Photo 18 - View of portion of SMWTP perimeter and Texas Avenue residential structures, looking northeast. Saltair Avenue residential structuresare in the background.

Photo 17 - View of portion of SMWTP perimeter and Texas Avenueresidential structures, looking southwest.

Photo 19 - View of one of the Santa Monica salt water well vaults, lookingwest.

Photo 20 - View of the northern salt water well vault, looking northwesttoward the Santa Monica Pier.


Project Photographs




Charnock Project Construction Description and Schedule. As discussed above, the Charnock site will require the construction of additional facilities and upgrades to existing site features. Specific facilities that are proposed for the Charnock site include:

• Down-hole chlorination in each well to control microbial growth, which can limit the productivity of the well

• Influent equalization tank • Greensand filtration for iron and manganese removal (potentially one greensand vessel

per train) • GAC contactors, two vessels in series, plumbed in a lead-lag configuration per train • Backwash storage with mixing • Possible backwash treatment system to concentrate iron and manganese solids to

reduce the volume of waste flow from the process • 10,000-gallon sump storage tank • Hypochlorite storage and feed building (14ft by 20ft) • Sodium bisulfite storage and feed, for dechlorination after the greensand filters • Control systems building (8ft by 15ft) • Transfer pumps, piping and appurtenances.

In addition to the above features, improvements to the pump house, contact basin and booster pumps may be needed. Improvements to the Charnock groundwater wells and associated pipelines will also be implemented, as necessary. The pipelines will be re-routed in order to minimize their impacts on the school grounds and to increase water flow efficiency. This includes the separation of the pipeline from Well #16 from Well #13. This connection currently exists under parking lot for the school and will thus require construction within the current parking lot area. The pipeline alignments for wells #15, #18 and #19 are currently under the Windward School play fields and will need to be rerouted from each wellhead to the treatment area. The final design and routes of these pipelines will be determined during the design phase of the project. Pipeline construction will require trenching and backfilling. The City is anticipated to change its wellhead treatment from chlorine gas to sodium hypochlorite. Sodium hypochlorite is generally considered less hazardous to handle and store while maintaining the same disinfection qualities as chlorine gas. A portion of the chlorine pipeline feed system is currently in place from the treatment area to each individual wellhead. This pipeline system will require some modifications and possible re-routing. This will be determined during the design phase of the project. Construction is estimated to occur over a 6-9 month period; however an exact design and construction schedule has not been established. Pipeline trenching on Windward School grounds may be necessary and this would be expected to take approximately 1 month. The current estimate is that up to 10-15 construction workers will be on-site at any given time. However, the total number of workers involved could range from 20-40. The estimated construction primary tasks will most likely include: 1) mobilization, 2) site clearing and preparation, 3) grading, excavation and trenching, 4) subsurface piping installation, 5) concrete and foundation, 6) equipment installation, 7) electrical and control system installation, 8) system testing and, 9) demobilization. Grading plans and volumes for the site will be developed by the



design build contractor. The project site is relatively flat and therefore grading is expected to be minimal. Santa Monica Water Treatment Plant Construction Description and Schedule. As discussed above, the SMWTP site is currently being evaluated for additional facilities and upgrades to existing site features. Specific facilities that are proposed for the SMWTP site may include:

• Improvements to the water softening system by either 1) rehabilitating the existing water softening ion exchange system or by 2) constructing a new membrane softening system.

• Fluoridation Treatment System. • Disinfection Treatment System.

The existing ion exchange system at the SMWTP remains functional, though repairs and upgrades must be completed to bring the system back into operation. Relatively little new construction would be required at the SMWTP; however, improvements would likely include replacing the ion exchange resin, replacing or upgrading the salt water wells due to low salt content ,testing the salt water transmission lines, some construction for the new sodium hypochlorite feed system and aqueous ammonia system. If a membrane softening system is selected the City’s water supply, an approximately 7,500 square foot building would be required. The system would most likely consist of 210 pressure vessels. Each vessel is approximately 40 inches in length and 8 inches in diameter. The membrane elements are contained in pressure vessels and skid mounted. The units come pre-plumbed from the factory in standard size modules. Feed pumps are used to pressurize the flow and force it through the membranes. Other auxiliary equipment includes a clean-in-place (CIP) system which uses chemicals to clean the membranes, piping, and acid/antiscalant feed systems and cartridge filters for pretreatment. Pretreatment may also include upstream dechlorination and greensand filtration. Post-treatment typically consists of stabilization and/or chemical addition. All of the above ancillary features of the membrane filtration process would be housed in the new 7,500 square foot structure. Disinfection is anticipated to change from injection of chlorine gas to sodium hypochlorite with ammonia addition. The primary reason to switch to chloramination is to be consistent with the water produced by MWD. If this technology is employed a new 2,000 gallon tank will be constructed onsite to store ammonia for use in this process. Since the facility has existing chlorine building, no new structures will be needed for this process; however modifications will be needed to convert the storage area for sodium hypochlorite. Project related construction activities at the SMWTP are estimated to occur over a 6-12 month period; however the design and construction schedule has not been completed. The current estimate is that up to 10-15 construction workers will be on-site at any given time. However the total number of workers involved could range from 20-40. The estimated construction primary tasks will most likely include: 1) mobilization, 2) site clearing and preparation, 3) grading, excavation and trenching, 4) subsurface piping installation, 5) concrete and foundation, 6) equipment installation, 7) electrical and control system installation, 8) system testing and, 9)



demobilization. Grading plans and volumes for the site will be developed by the design build contractor. The project site is flat and therefore grading should be minimal. Salt Water Wells. The wells would be drilled to approximately 200 feet below ground, housed in two 15 foot by 15 foot concrete structure and piped to the existing salt water main transmission line for delivery to the SMWTP. In addition, if new wells are drilled, the current wells will be abandoned. The construction of these wells would be incorporated within the SMWTP improvements. On-site activities are expected to be 3-4 months. It is estimated that from to 2-8 construction workers will be on-site at any given time. The total number of workers involved could range from 10-15.

2.5 PROJECT SCHEDULE A preliminary project schedule for the Charnock Well Field was developed assuming a design-build project delivery approach. Final design is scheduled to take place during 2009, and construction would take place from mid-2009 through early 2010. Shakedown and testing would take place during early 2010. The target start date would be March 2010, and the Charnock treatment facility would operate for about 7-10 years beyond that. Final Santa Monica Water Treatment Plant upgrades and additions are currently being evaluated. Final designs and a project schedule are expected to be completed in late 2008.

2.6 REQUIRED APPROVALS The Charnock and SMWTP sites are owned and operated by the City of Santa Monica but are located within the City of Los Angeles. The City of Santa Monica is the Lead Agency under CEQA and has the responsibility for preparing and processing the environmental document to be used in the decision making process. The City will be responsible for certifying this EIR and reviewing and approving subsequent stages of design and implementation of the project. Cities are exempt from each others building and zoning ordinances pursuant to California Government Code § 53091. Discretionary approval of the project would may be required from the following agencies:

• City of Santa Monica/City Council (Adoption of the EIR and approval of design and implementation phases of the project)

• State of California Department of Public Health • State Water Resources Control Board (NPDES Permit) • California Coastal Commission (salt water well modifications at Santa Monica Beach) • Los Angeles Regional Water Quality Control Board (permit to discharge to the storm drain from

the Reverse Osmosis facility at the SMWTP site) • Sewer District (permit to discharge to the sewer from the Reverse Osmosis facility at the

SMWTP site to the City of Los Angeles, Department of Public Works, Bureau of Sanitation)

Charnock Well Field Restoration Project EIR Section 3.0 Environmental Setting


3.0 ENVIRONMENTAL SETTING This section provides a general overview of the environmental setting for the proposed project. More detailed descriptions of the environmental setting germane to each environmental issue area can be found in Section 4.0, Environmental Impact Analysis. 3.1 REGIONAL SETTING The project sites is located in the City of Los Angeles and the City of Santa Monica, in western Los Angeles County, within the greater Los Angeles metropolitan area (refer to Figure 2-1, Regional Location, and Figure 2-2, Project Vicinity in Section 2.0, Project Description). Los Angeles is a large expansive metropolitan area covering approximately 469 square miles. Santa Monica is approximately 10 miles west of downtown Los Angeles. The City is bounded to the north, east, and south by urban districts within the City of Los Angeles and to the west by the Pacific Ocean. Santa Monica is almost entirely developed, with only 1% of its land area considered undeveloped. The Mediterranean climate of the region and the coastal influence produce moderate temperatures year round, with rainfall concentrated in the winter months. The region is subject to various natural hazards, including earthquakes, landslides, and wildfires. 3.2 PROJECT SITE SETTING The Charnock Well Field Restoration Project is intended to enhance the City’s water supply by treating and restoring water production from the Charnock sub-basin. The project involves improvements at two separate existing facilities that are owned and operated by the City of Santa Monica. These include improvements at the Charnock well field located at 11375 Westminster Avenue and at the Santa Monica Water Treatment Plant (SMWTP) located at 1228 South Bundy Drive. Both of these facilities are located in the City of Los Angeles. In addition, the SMWTP has an ion exchange water softening treatment system. This system utilizes salt water that is piped from two salt water wells located on Santa Monica beach. These wells may need to be replaced. The two existing salt water wells are located west of Pacific Street and Ocean Avenue on Santa Monica beach. The proposed project involves the implementation of various water treatment measures in order to restore the groundwater resource of the Charnock sub-basin to its full beneficial use in the most expeditious and technically effective manner possible. The Charnock site has historically been operated by the City as a ground water well field but is not currently active. The existing facilities at the Charnock well field include: Five City water supply wells (#13, #15, #16, #18, and #19), a 116,500-gallon contact basin, a booster station, a Metropolitan Water District (MWD) turnout, a chlorine building, a power substation, a control room, and city storage yards. Additionally, 14 abandoned water production wells (#1 to #12, #14 and #17) are also located at the well field. The Charnock site is surrounded by Windward School to the north, east and west and single family residences to the south. The SMWTP facility services a large portion of the City’s water supply needs. The following water treatment systems are located at the SMWTP site: a contact basin, a chlorine building, an ion exchange system (out of service), a clearwell and pH adjustment, a reservoir/mechanical aeration basin, and the distribution system booster pumps. When it was in use, the ion



exchange system utilized two salt water wells that are located on Santa Monica Beach and piped to this facility. The SMWTP site is surrounded by residential development to the north and east and commercial development to the south and west. The two existing salt water wells are located west of Pacific Street and Ocean Avenue on Santa Monica beach. The salt water wells are depicted within Section 2.0, Project Description, Figure 2-3. Figure 2-6 shows the SMWTP Site layout. 3.3 CUMULATIVE PROJECTS SETTING CEQA defines cumulative impacts as two or more individual actions that, when considered together, are considerable or will compound other environmental impacts. Cumulative impacts are the changes in the environment that result from the incremental impact of development of the proposed project and other nearby projects. For example, traffic impacts of two nearby projects may be insignificant when analyzed separately, but could have a significant impact when analyzed together. Cumulative impact analysis allows the EIR to provide a reasonable forecast of future environmental conditions and can more accurately gauge the effects of a series of projects. Table 3-1 lists current planned and pending related projects in the West Los Angeles area. These projects are considered in the cumulative analyses in Section 4.0, Environmental Impact Analysis.

Table 3-1 Cumulative Projects in West Los Angeles

Project Name/Location Description Status Westfield Century City 10350 Santa Monica Blvd. City of Los Angeles Armbruster & Goldsmith (LA County Club) Cheviot Hills HOA

Removal of 360,964 sf of office, addition of 358,881 sf of shopping center, 106,253 sf of office, and 262 residential units in a 49-story tower

Entitlements Pending

JBM Century City Towers 10131 Constellation Blvd.

Two new high-rise residential towers and one mid-rise residential building with 350 units

Fully Entitled, Construction to Begin by 2008

St. Regis Redevelopment 2055 Avenue of the Stars

147-unit condominium building with 7,000-sf restaurant and 43,000-sf private club

Under Construction

ABC Entertainment Center 2000 Avenue of the Stars

Mid-rise office building with 763,900 sf of office uses, plus 61,912 sf of commercial uses

Recently Completed

Palazzo Westwood 1020 Glendon Ave.

New 5-story mixed-use project: 115,000-sf retail, 350 condominium units, 1,550 subterranean parking spaces

Under Construction

Wilshire Club-View 10250 W. Wilshire Blvd.

New 22–story, 35-unit condominium building

Under Construction




Project Name/Location Description Status Wilshire Carlyle 10776 W. Wilshire Blvd. Wilshire Hannover 10700 W. Wilshire Blvd.

New 24–story, 87-unit condominium


Under Construction Fully Entitled, Construction to Begin by 2008

10777 Wilshire 10777 Wilshire Blvd.


City Council approved; Design Review Board not Approved

Westside Pavilion Remodel [2] Pico Boulevard/Westwood Boulevard

Retail 723,466 sq. ft. Theater Expansion 1,994 seat (net increase)

Under review

11021 W. Pico Boulevard

Fast Food Restaurant 2,300 sq. ft. Under review

11625 Pico Boulevard

New West Middle School 250 students

Under review

10604 - 10612 National Boulevard

Condominiums 29 units Retail 1,250 sq. ft. Office 2,000 sq. ft.

Under review

11470 Tennessee Avenue

EZ Storage Facility Expansion 55,003 sq. ft.

Under review

Purdue Avenue/Pico Boulevard

West LA Animal Services Center NWC

Under review

2222 Pico Boulevard

Condominiums 2 unit Retail 2,399 sq. ft.

Under review

3205 Pico Boulevard

Condominiums 1 unit Retail 710 sq. ft.

Under review

3115 S. Sepulveda Boulevard 28,000 sq. ft. Specialty Retail Center and 138 duplex condominiums Under review

10852 Lindbrook Avenue 19 units, 6,100 square feet specialty retail

Under review 10804 Wilshire Boulevard Condominiums, 85 units Under review 10776 Wilshire Boulevard Condominiums, 119 units Under review 10604-10612 National Boulevard

Condominiums, 29 units, Retail, 1,250 square feet, Office, 2,000 square feet

Under review

1135 Rexford Drive Condominiums, 23 units Under review 1767 Westwood Boulevard Apartments, 111 units, retail, 7,000

square feet Under review

10763 Wilshire Boulevard Condominiums, 60 units Under review 9601 Wilshire Boulevard Sports Club LA, 30,000 square feet Under review 9844 Wilshire Boulevard Office, 95,000 square feet Under review 9590 Wilshire Boulevard Condominiums, 60 units, Retail

12,000 square feet Under review

9900 Wilshire Boulevard Condominiums, 252 units, Retail, 15,656 square feet, restaurant 4,800 square feet

Under review

9754 Wilshire Boulevard Office, 24,566 square feet, Medical Office, 7,977 square feet

Under review 12114 W. Idaho Avenue Apartments, 11 units Under review 10309 W. National Boulevard Private High School, 340 students Under review 1417 S. Butler Avenue Condominiums, 16 units Under review 1625 Barry Avenue Condominiums, 18 units Under review 1525 S. Armacost Avenue Condominiums, 18 units Under review




Project Name/Location Description Status

1633 S. Armacost Avenue Condominiums, 16 units Under review 2142 S. Pontius Avenue Office Building, 17,619 square feet Construction to begin by

2008 6101 Manchester Avenue Gas station, Starbucks and

convenience store Under review

4160 Grand View Boulevard School conversion – 250 students Under review Source: City Planning Division: City of Los Angeles. West Los Angeles Commercial Development Projects. June 2008, retrieved July 24, 2008.

Charnock Well Field Restoration Project EIR Section 4.0 Environmental Impact Analysis


4.0 ENVIRONMENTAL IMPACT ANALYSIS This section discusses the possible environmental effects of the proposed project for the specific issue areas that were identified through the Initial Study and NOP process as having the potential to experience significant impacts. “Significant effect” is defined by the State CEQA Guidelines §15382 as “a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. An economic or social change by itself shall not be considered a significant effect on the environment, but may be considered in determining whether the physical change is significant.” The assessment of each issue area begins with a discussion of the setting relevant to that issue area. Following the setting is a discussion of the project’s impacts relative to the issue area. Within the impact analysis, the first subsection identifies the methodologies used and the “significance thresholds,” which are those criteria adopted by the City, other agencies, universally recognized, or developed specifically for this analysis to determine whether potential impacts are significant. The next subsection describes each impact of the proposed project, mitigation measures for significant impacts, and the level of significance after mitigation. Each impact under consideration for an issue area is separately listed in bold text, with the discussion of the impact and its significance following. Each bolded impact listing also contains a statement of the significance determination for the environmental impact as follows:

Class I, Significant and Unavoidable: An impact that cannot be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires a Statement of Overriding Considerations to be issued if the project is approved.

Class II, Significant but Mitigable: An impact that can be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires findings to be made.

Class III, Not Significant: An impact that may be adverse, but does not exceed the threshold levels and does not require mitigation measures. However, mitigation measures that could further lessen the environmental effect may be suggested if readily available and easily achievable.

Class IV, Beneficial: An impact that would reduce existing environmental problems or hazards.

Following each environmental impact discussion is a listing of recommended mitigation measures (if required) and the residual effects or level of significance remaining after the implementation of the measures. In those cases where the mitigation measure for an impact could have a significant environmental impact in another issue area, this impact is discussed as a residual effect. The impact analysis concludes with a discussion of cumulative effects, which evaluates the impacts associated with the proposed project in conjunction with other future development in the area.

Charnock Well Field Restoration Project EIR Section 4.0 Environmental Impact Analysis



Charnock Well Field Restoration Project EIR Section 4.1 Aesthetics


4.1-1

4.1 AESTHETICS This section analyzes the proposed project’s impacts on visual resources including the project’s visual compatibility with the surrounding neighborhood and shadowing effects. 4.1.1 Setting

a. Existing Conditions. The proposed project involves infrastructure improvements at two existing water treatment facilities and the possible installation of two new salt water extraction wells in the vicinity of two existing City-owned salt water wells at Santa Monica Beach. The visual setting for each of these sites is discussed separately below. Charnock Well Field The proposed site for the Charnock well field restoration project is currently developed as a water production facility and is occupied by a group of small single story buildings related to the operation and maintenance of the Santa Monica municipal water supply wells. The primary use of the Charnock property is for water production, treatment and transmission. However, in addition to the water facilities, a portion of the Charnock well field site is leased and is currently occupied by Windward School. A lease provision with the school states that the primary use of the property is for water production, treatment and transmission. The school facility includes classrooms, play fields, a gymnasium, a library and administration buildings. Current enrollment is approximately 500 students. The proposed water treatment area is adjacent to and immediately north of Westminster Avenue. The greater site is bounded by Sawtelle Boulevard to the east, Westminster Avenue to the south, Butler Avenue to the west and the Westwood Flood Control Channel (Westwood Channel) to the north, as shown in Section 2, Project Description, Figure 2-2. Residential uses are located across Westminster Avenue immediately south of the project site.

New facilities that are proposed to be implemented at the Charnock site include:

• Granular activated carbon (GAC) filter system featuring ten GAC vessels. Each steel

vessel will be 10 to 12 feet in diameter and approximately 24 feet in height. • Five greensand filter vessels for iron and manganese removal. These filters will be

approximately 12 feet in diameter and would be approximately 24 feet in height. • One 35,000-gallon equalization tank. This tank will be approximately 16 feet in

diameter and would be less than 15 feet in height. • Two 30,000-gallon backwash storage tanks. These tanks will be approximately 16

feet in diameter and would be less than 15 feet in height. • One 10,000-gallon sump storage tank. This tank will be approximately 10 feet in

diameter and would be less than 15 feet in height. • One 15’ x 30’ square foot hypochlorite storage and feed building, anticipated to be

less than 15 feet in height. This will house two 6,000-gallon storage tanks in a secondary containment area, as well as valves, metering pumps and an electrical system to support the chemical feed system.



4.1-2

• One 8’ x 15’ square foot control systems building, anticipated being less than 15 feet in height.

In addition to the above features, improvements to the pump house, contact basin and booster pumps may be needed. Improvements to the Charnock groundwater wells and associated pipelines (the pipelines are underground pipelines except within the treatment compound), will also be implemented, as necessary. This includes the separation of the pipeline from Well #16 from Well #13. This connection currently exists under parking lot for the school and will thus require construction within the current school parking lot area. The pipeline alignments for wells #15, #18 and #19 are currently under the Windward School playing fields and will need to be rerouted from each wellhead to the treatment area. The final design and routes of these pipelines will be determined during the design phase of the project. Pipeline construction will require trenching and backfilling. Charnock Viewsheds. The proposed new facilities would include 15 cylindrical vessels that will be approximately 24 feet tall as well as several other proposed tanks and storage buildings that would be approximately 14 feet in height. All of these proposed new facilities would be located in the southern portion of the site about 50 feet from the southern property line. The most prominent views of the this location would occur from portions of Westminster Avenue, Purdue Avenue, Corinth Avenue (including from residential uses on the south side of Westminster Avenue) and portions of Windward School. There are no scenic corridors adjacent to the project site; however, the adjoining residential and school uses are considered visually sensitive. Views from the site include residential structures to the south and views of Windward School to the north, east and west. Charnock Light and Glare. Many of the existing structures surrounding the Charnock site provide nightlighting for pedestrian access and security purposes. Sources of light in the vicinity of the project site include lighting from Windward School and street lighting. Primary glare sources include the sun’s reflection from metallic or glass surface on surrounding buildings and vehicles parked along Westminster Avenue. Security lighting is currently provided at the facility. Residential buildings, located across Westminster Avenue, and Windward School, located adjacent to the north, east and west, are the nearest light-sensitive uses in the immediate project vicinity. Charnock Shadow Sensitive Uses. The Charnock site is located in the Mar Vista community of Los Angeles and surrounding land uses consist of primarily of residential and school use. Residential buildings, located across Westminster Avenue, and Windward School, located adjacent to the north, east and west, are the nearest shadow-sensitive uses in the immediate project vicinity. Santa Monica Water Treatment Plant (SMWTP) The Santa Monica Water Treatment Plant (SMWTP) is bordered by Saltair Avenue to the east,



4.1-3

and Texas Avenue to the south. The facility is located within a predominantly residential neighborhood, with commercial businesses and office buildings to the north. Views of land uses surrounding the SMWTP site are shown in Section 2, Project Description, Figure 2-11, photo 16 and Figure 2-12, photos 17 and 18. Existing water treatment systems that are present at the SMWTP site include: a contact basin, chlorine building, former ion exchange system, clearwell and pH adjustment, reservoir/mechanical aeration basin, and distribution system booster pumps. Views of the existing plant and onsite facilities are shown on Section 2, Project Description, Figure 2-11, and photos 13-16. Potential improvements that are currently under consideration for the SMWTP site include:

• Improvements to the water softening system by either 1) rehabilitate the existing

water softening ion exchange system or 2) construct a new membrane filtration system. The ion exchange would not require additional site improvements; however the system would need upgrades (including, possibly, two new salt water wells) and maintenance. The membrane system would require the construction of a 7,500 square foot building to house the system.

• Fluoridation Treatment System. This system would be located in an existing structure onsite.

• Disinfection Treatment System. No new structures would be required for any proposed changes to the current disinfection treatment system.

SMWTP Viewsheds. The most prominent views of various portions of the SMWTP site are from Bundy Drive, Texas Avenue, and Saltair Avenue. There are no designated scenic corridors adjacent to the project site; however adjoining residential uses are considered visually sensitive. Views from the site include adjacent urban development. West across Bundy Drive views from the site includes commercial structures. Views from the site northward are generally of mixed retail and commercial uses. Views east and south of this site are generally residential. SMWTP Light and Glare. Many of the existing structures surrounding the SMWTP site provide nightlighting for pedestrian access and security purposes. Sources of light in the vicinity of the project site include lighting on the exterior of commercial/office buildings and street lighting. Primary glare sources include the sun’s reflection from metallic or glass surface on surrounding buildings and vehicles parked along the surrounding streets. Security lighting is currently provided at the facility. Residential uses located to the east and south across Saltair and Texas Avenues are the nearest light-sensitive uses in the immediate project vicinity. SMWTP Shadow Sensitive Uses. The SMWTP site is located in the West Los Angeles community of Los Angeles and surrounding land uses consist of primarily of commercial and residential use. Residential uses



4.1-4

located to the east and south across Saltair and Texas Avenues are the nearest shadow-sensitive uses in the immediate project vicinity. Salt Water Wells

The City is currently evaluating new treatment processes for the SMWTP. In conjunction with the SMWTP improvements, two new salt water wells may need to be installed in the vicinity of two existing City salt water wells. These wells are utilized for its ion exchange water treatment system. These two new wells may be necessary to achieve higher salinity values. Another building associated with the site, located approximately 800 feet east of the wells, is utilized for the pumping and treatment of salt water to the SMWTP. Salt Water Wells Viewsheds. The most prominent views of various portions of the salt water well site are from Santa Monica Beach and the adjacent beach parking lot. There are no designated scenic corridors adjacent to the project site; however the site is located on Santa Monica Beach with views of the Pacific Ocean. East across Ocean Drive views from the site includes residential structures. Salt Water Well Light and Glare. Existing structures and uses surrounding the project site provide nightlighting for pedestrian access and security purposes. Sources of light in the vicinity of the project site include lighting for the beach parking lot and street lighting. Primary glare sources include the sun’s reflection from metallic or glass surface on nearby buildings and vehicles parked at the beach parking lot. Salt Water Well Sensitive Uses. The salt water well site is located on Santa Monica beach and surrounding land uses consist of primarily recreational and residential use. Residential uses located across Ocean Avenue, located to the east, are the nearest visually sensitive uses in the immediate project vicinity.

b. Regulatory Setting. This project has two locations in the City of Los Angeles and, possibly, a third which would be located in the City of Santa Monica. The Charnock site is located in the Palms-Mar Vista-Del Rey Community Plan Area of the City of Los Angeles. As a municipal water facility owned and operated by the City of Santa Monica, the project is exempt from local, City of Los Angeles zoning and land use requirements. Nevertheless this section uses the existing zoning designations for the site and the surrounding area as a way of examining the general visual character of the area and uses scale of development that is normally allowed under such designations. The zoning designation for the Charnock site is OS-1XL (Open Space in Height District 1, Extra Limited). While the Open Space zoning does not contain specific height limitations, the 1XL overlay has height restrictions of 30 feet or two stories. Allowable uses included within this zoning designation are Public Water Supply Reservoirs and Water Conservation Areas. Zoning on the southern adjacent properties is Residential 1 (R1) with a maximum allowable height of 45



4.1-5

feet. The SMWTP site is located in the West Los Angeles Community Plan Area of the City of Los Angeles. The zoning designation for the project site is [Q]PF-1XL (Qualified Public Facilities in Height District 1, Extra Limited). The facility is located within a predominantly residential neighborhood, with commercial businesses and office buildings located to the north. As noted in the project description, while the proposed Charnock and SMWTP are within the City of Los Angeles the project is exempt from local building and zoning requirements. The discussion of City of Los Angeles zoning requirements provided above is intended to show the development intensity that would normally be allowed under the current zoning provisions. It is included here in the visual impact assessment to help illustrate whether or not the project would be consistent with the structural massing and height provisions that are allowed under the current zoning. For the salt water well location in Santa Monica, the topic of aesthetics and neighborhood character is generally addressed in the Santa Monica City Land Use Plans and City Zoning Ordinances through a range of development standards that are applied by district. For Santa Monica the Urban Design Objectives and Policies (Section 3.0) of the Land Use Element of the General Plan including:

• Policy 3.1.1- Minimize the impact of the perceived mass of structures, attenuate wind

acceleration, and protect the solar access of major public space.... • Policy 3.1.2- Encourage the maintenance of high aesthetic standards and

architectural innovation consistent with the surrounding community and encourage large buildings to be of predominantly light color and materials that fit in with the existing context. Prohibit large expanses of highly reflective materials such as black glass or mirrored metal.

In addition to these established policies, architectural design is reviewed by the City of Santa Monica’s Architectural Review Board, whose mission is in part to “[a]ssure that buildings, structures, signs or other developments are in good taste, good design, harmonious with surrounding developments, and in general contribute to the preservation of Santa Monica’s reputation as a place of beauty, spaciousness and quality.” 4.1.2 Impact Analysis

a. Methodology and Significance Thresholds. Because the Charnock and SMWTP sites and proposed new facilities are located on sites within the City of Los Angeles, both the City of Los Angeles and City of Santa Monica visual impact criteria were used to assess the project impacts on visual resources. Based on the City of Los Angeles 2006 CEQA Threshold Guide, the determination of significance for aesthetics is made on a case-by-case basis, considering the following:

• The amount or relative proportion of existing features or elements that substantially contribute to the valued visual character or image of a neighborhood, community or localized area, which would be removed, altered or demolished;



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• The amount of natural open space to be graded or developed; • The degree to which proposed structures in natural open space areas would be effectively

integrated into aesthetics of the site, through appropriate design, etc; • The degree of contrast between proposed features and existing features that represent the

areas valued aesthetic image; • The degree to which the proposed zone change would result in buildings that would detract

from the existing style or image of the area due to density, height, bulk, setbacks, signage, or other physical elements;

• The degree to which the project would contribute to the area’s aesthetic value; • Applicable guidelines and regulations; • The nature and quality of recognized or valued views (such as topography, settings,

manmade or natural features of visual interest, and resources such as mountains or the ocean;

• Whether the project affects views from a designated scenic highway, corridor, or minor diminishment);

• The extent of obstruction (e.g. total blockage, partial interruption, or minor diminishment; and

• The extent of which the project affects recognized views available from a length of a public roadway, bike path, or trail as opposed to a single fixed vantage point.

Based on the City of Los Angeles 2006 CEQA Threshold Guide, the determination of significance for shadow effects is made on a case-by-case basis, considering the following:

• A project would normally be considered significant if shadow sensitive uses (i.e. residential uses, recreational uses, churches, schools, outdoor restaurants and pedestrian areas) would be shaded by project related structures for more than three hours between the hours of 9:00 A.M. to 3:00 P.M. Pacific Standard Time (between late October and early April), or for more than four hours between the hours of 9:00 A.M. and 5:00 P.M. Pacific Daylight Time (between early April and late October).

Based on the City of Los Angeles 2006 CEQA Threshold Guide, the determination of significance for substantial light and glare is made on a case-by-case basis, considering the following:

• The change in ambient illumination as a result of project sources; and • The extent to which project lighting would spill off the project site and affect adjacent light-

sensitive areas. The City of Santa Monica General Plan was reviewed relative to visual resources and design policy. An impact is considered significant under CEQA if it can be reasonably argued that the project would conflict with City policies, particularly the Urban Design Objectives and Policies (Section 3.0) of the Land Use Element of the General Plan as discussed in Section 4.1.1(b), Regulatory Setting (above), or result in the following:

• Loss of a major open space resource; • Obstruction of existing ocean views from a public area such as a park; • Loss of a major public scenic view;



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• Generation of excessive nighttime lighting that is out of character with the land uses surrounding the project site;

• A substantial increase in ambient lighting in residential areas; or • Generation of excessive glare.

In determining shadow effects, several factors are considered: • Affected land use (i.e., is it a light-sensitive use whereby sunlight is essential to its

use); • Duration (i.e., how many hours per day might a use be shadowed); • Time of day (i.e., is it in shadow at a time of day when sunlight is most important); • Season (i.e., what time of year might a particular use be in shadow); • Extent (i.e., what percentage of a particular use may be in shadow); • Nature of the shadows (i.e., is the shadow more solid or more dappled in nature); and, • Pre-existing conditions (i.e., are there existing buildings, landscaping or other

features that currently shadow the use). For a project to generate a significant shadow impact, a project must result in increased shadows cast upon light-sensitive uses. Shadow impacts are considered significant if light-sensitive uses would be shaded by project related structures for more than three hours a day between 9:00 a.m. and 3:00 p.m. PST between late October and early April (including Winter Solstice), or for more than four hours a day between early April and late October (including Summer Solstice). As noted above, facilities and operations sensitive to the effects of shading include: solar collectors; nurseries; primarily outdoor-oriented retail uses (e.g., certain restaurants); or, routinely useable outdoor spaces associated with recreational, institutional (e.g., schools), or residential land uses. These uses are considered sensitive because sunlight is important to function, physical comfort, and/or commerce.

b. Project Impacts and Mitigation Measures.

Impact AES-1 The proposed project would involve construction of new water treatment facilities including fifteen 24-foot water treatment vessels and other miscellaneous tankage at the Charnock site. These facilities would be largely screened by existing landscape features and proposed mitigation and would be consistent with the height limits and massing that would be allowed under the current zoning. In addition, these facilitates would not alter or obstruct the views of any identified sensitive visual resource. As such, the proposed project would not exceed any identified visual impact threshold. The introduction of an industrial looking facility in the largely residential neighborhood has the potential to be perceived as inconsistent with the visual character of the area. For this reason, the impact is considered to be a Class II, significant but mitigable impact.



4.1-8

Introduction of site improvements at the SMWTP and the potential two salt water wells that may be constructed on Santa Monica Beach would not exceed any of the visual impact thresholds identified above and would not be inconsistent with the visual character of those areas. Thus the project visual impacts at those locations are considered Class III, less than significant.

Charnock Well Field The Charnock site is currently developed as a water treatment facility. Existing onsite features include the pump house, contact basin and booster pumps. The existing on-site structures do not exceed 14 feet in height. Additionally, five groundwater wells are located on the water treatment facility and on the adjacent Windward School, which is leased from the City of Santa Monica. New facilities that are proposed to be implemented at the Charnock site include:

• Granular activated carbon (GAC) filter system featuring 10 GAC vessels. Each steel vessel will be 10 to 12 feet in diameter and approximately 24 feet in height.

• Five greensand filter vessels for iron and manganese removal. These filters will be approximately 12 feet in diameter and would be approximately 24 feet in height.

• One 35,000-gallon equalization tank. This tank will be approximately 16 feet in diameter and would be less than 15 feet in height.

• Two 30,000-gallon backwash storage tanks. These tanks will be approximately 16 feet in diameter and would be less than 15 feet in height.

• One 10,000-gallon sump storage tank. This tank will be approximately 10 feet in diameter and would be less than 15 feet in height.

• One 15’ x 30’ square foot hypochlorite storage and feed building, anticipated to be less than 15 feet in height. This will house two 6,000-gallon storage tanks in a secondary containment area, as well as valves, metering pumps and an electrical system to support the chemical feed system.

• One 8’ x 15’ square foot control systems building, anticipated being less than 15 feet in height.

This section uses the existing zoning designations for the site and the surrounding area as a way of examining the general visual character of the area and to provide guidance regarding the scale of development that is normally allowed under such designations. Under the City of Los Angeles zoning for the site public water facilities are an allowable use with the issuance of a conditional use permit. From this perspective, the proposed project is found to be generally consistent with the land use character that is permitted for the site. Current zoning allows structures up to a maximum of 30 feet in height. The proposed water treatment vessels would be 24 feet tall or about 20% less than the maximum allowable structure height for the site. Therefore the project is considered consistent with the building height standards that are applicable to the site. It is noted that the maximum height limitation for the adjoining residential area is 45 feet. The proposed structures would be approximately 47% less than 45 foot maximum height limit for the adjacent residential (R1) areas. From a massing perspective,



4.1-9

the 15 water treatment vessels would occupy the equivalent of an approximate 3,750 square foot structure. This building size is larger than most of the single family homes in the neighborhood but generally consistent with other structures in the immediate vicinity such as the multifamily structures along Sawtelle Blvd. Given the approximately 30 foot height of existing trees and the 7 foot hedge lined fence located on the southern boundary on the site, the proposed new facilities would be largely screened from the existing residential area to the south. Some views, specifically those facing the facility entry driveway, would have an unobstructed of the new facility because that area lacks screening. Figure 4.1-1 shows the anticipated street level visual representation that would occur with the proposed new facilities. The existing appearance of the site would change with project implementation. As part of this analysis a photo simulations were created to visually illustrate the views of the project. Figure 4.1-1 presents four views from Westminster Avenue looking at the site. An analysis of the views presented in Figure 4.1-1 is provided below.

• View 1 shows partial screening of the proposed water treatment vessels. This view is from Corinth Avenue looking at the entrance gate of the site. The chain link entrance gate does not afford any significant screening. Several large trees and the fence hedge would provide some screening from this vantage. The degree of screening from this vantage is estimated at approximately 40%.

• View 2 is looking eastward down Westminster from the corner of Purdue

Avenue. The existing trees and hedges are tall enough and provide a relatively continuous screen from this vantage. It is estimated that the treatment facility would be screened by over 90% from this view.

• View 3, looking northeast along Westminster Avenue, shows the area along the

Westminster Avenue were gap is present within the existing vegetation. Because of the discontinuous vegetation, the proposed project would be visible between two trees from this vantage. Despite the gap, the 30 foot plus trees and hedges provide some visual relief from this vantage. Current screening from this location is estimated at approximately 60%.

• View 4, south on Westminster Avenue, shows that a portion of the water

treatment vessels would be seen above the existing continuous hedge row. Again the existing trees would provide some screening, however, since no tress are along the western boundary of the construction area, the vessels would be at least partially visible. Screening from this view is approximately 60%.

As shown on the photo simulations and discussed above, given the approximately 30 foot height of existing trees and the 7 foot hedge lined fence located on the southern boundary on the site, the proposed new facilities would be largely screened from the existing residential area to the south. Some views, however, specifically those facing the facility entry gate and one area with a noticeable gap in vegetation, would have less complete screening.



4.1-10


Westminster AvePurdue Ave

Corinth Ave

View 1

View 3View 2

View 4

Photo Key

Charnock Well Field Restoration Project EIRSection 4.1 Aesthetics

Figure 4.1-1City of Santa Monica

Photo SimulationsView 3 - Looking northeast along Westminster Avenue at site property where small section of trees do not exist.

View 4 - Looking farther northeast along Westminster Avenue at site property on the left.

View 2 - Looking eastward down Westminster Avenue at Purdue Avenue. The Charnock Treatment plant located on the left is blocked by existing trees.

View 1 - Simulated tanks viewed through entrance to Charnock Treatment area. Photo taken from Corinth and Westminster Avenue looking northwest.

Note: White was chosen for the vessel color for contrast purposes only



4.1-13

Although the proposed facilities are consistent with the height and massing limitations outlined in the City of Los Angeles zoning regulations and the facilities would be largely screened by existing vegetation, the proposed facilities would not be fully consistent with the residential visual character of the area. Santa Monica Water Treatment Plant Existing water treatment systems that are located at the SMWTP site include: a contact basin, chlorine building, former ion exchange system, clearwell and pH adjustment, reservoir/mechanical aeration basin, and distribution system booster pumps. Views of the existing plant and onsite facilities are shown in Section 2.0, Project Description, Figure 2-11, and photos 13-16. Potential improvements that are currently under consideration for the SMWTP site include:

• Improvements to the water softening system by either 1) rehabilitate the existing

water softening ion exchange system or 2) construct a new membrane filtration system. The ion exchange would not require additional site improvements; however the system would need upgrades (including, possibly, two new salt water wells) and maintenance. The membrane system would require the construction of a 7,500 square foot building to house the system.

• Fluoridation Treatment System. This system would be located in an existing structure onsite.

• Disinfection Treatment System. No new structures would be required for any proposed changes to the current disinfection treatment system.

The only new structure that may be constructed at the SMWTP site would be a single story, approximately 7,500 square foot building that would house the new membrane filtration system. This building would be built within the existing water treatment facility and would replace all or a portion of the existing water softening facility. This potential new structure would be of similar size and scale as buildings currently onsite and would not change the existing visual character of the water treatment facility. Given the currently developed state of the project site and relatively small scale and infill nature of the potential new facilities, this component of the project would not substantially degrade the existing visual character or quality of the site or its surroundings. Salt Water Wells The City is currently evaluating new treatment processes for the SMWTP. In conjunction with the SMWTP improvements, two new salt water wells may need to be installed in the vicinity of two existing City salt water wells. This location also features a building, located approximately 800 feet east of the wells, that is utilized for the pumping and treatment of salt water to the SMWTP. The pump and treatment building would remain and not change. It is anticipated that the new wells would be installed in the vicinity of the two wells currently located west of the intersection of Pacific Street and Ocean Avenue on the Santa Monica beach. The new wells would be drilled to approximately 300 feet below ground utilizing a hollow stem drill rig. If implemented, the each well would be enclosed in a concrete block house,



4.1-14

approximately 15 ft by 15 ft (225 sf) with the interior space being about 20 feet tall. Similar to the existing wells on the beach, these structures would be partially buried, and only the top 5 feet are visible above the sand to reduce the visual impact. These new facilities would be subject to City staff aesthetic review to ensure that their physical location, size, massing, and appearance are compatible with and relate harmoniously to surrounding environs. Given the relative small scale of these potential well housings, their impacts would not be expected to substantially degrade the existing visual character or quality of their prospective sites or their surroundings. In addition, the two current wells would be abandoned since they would be out of service. The abandonment process would eliminate all above and below ground physical features of the existing wells.

Mitigation Measures. The following mitigation measures would reduce potential visual

impacts associated with the Charnock site of the proposed project. AES-1(a) Additional Screening and Site Design Features. Additional screening

and/or site design features shall be implemented to provide visual relief of the onsite features. The physical appearance of the Charnock structures and site screening shall be compatible with and relate harmoniously to surrounding sites and neighborhood. Additional screening would be implemented to help block the currently unobstructed views of the new facility. This additional screening would include such design features as slats in the existing fence (to block the lower portions of the facilities from views through the chain link fence), landscaping or potted trees at base of structures, neutral earth tone colors of tanks and buildings and physical screens or facades. The physical screens or facades could be painted in either neutral colors as to mask their presence or as murals to provide a more interesting appearance. The physical screen or façade shall extend along the western portion of the site so as to screen views of the facility that exist over the existing 7 foot hedge row along Westminster Avenue. The Mar Vista Community Council and Windward School will be solicited for aesthetic input to help ensure that their physical location and appearance are compatible with and relate harmoniously to surrounding environs.

To facilitate a visual illustration of additional Charnock site screening, Figure 4.1-2 was developed to present a mitigation simulation for the Charnock location. The simulation includes earth tone colored lattice for the chain link front gate, earth tone colors for the vessels and additional vegetation on the perimeter of the vessels and site boundaries. Figure 4.1-2 presents four views from Westminster Avenue looking at the site. An analysis of the views presented in Figure 4.1-2 is provided below.

Westminster Ave

Purdue Ave

Corinth Ave

View 1

View 4

View 2(not shown)

View 3


Mitigated SimulationView 1b - Same view as 1a without gate, showing 22 ft high panels with 7 ft access below, and potted plants.

View 1a - Simulated view of Charnock treatment plant entrance showing lattice inserts in gate and 22 ft high panels blocking painted tanks.

Note: Mitigated simulation illustrated for representation only and not final design.

View 3 - Looking northeast along Westminster Avenue at site property where small open view of tanks could be blocked by two additional trees.

View 4 - View looking farther northeast along Westminster Avenue with two additional trees (left center) blocking view of tanks.

Photo Key (Suggested additional trees and structured panels

are representated by darker images)




4.1-17

• View 1a is from Corinth Avenue looking at the entrance gate of the site. Earth tone color lattice inserts have been added to the chain link entrance to provide screening. A 22 foot earth tone facade is depicted to screen the vessels from this view. In addition, several trees have been placed at the base of the facade to enhance the blending with the surrounding vegetation. A small upper portion of the vessels is visible form this view in addition to a partially screened vessel side view. This view, with the added screen features, screens over 90% of the proposed vessels.

• View 1b is also from Corinth Avenue looking at the entrance gate of the site.

This view shows the site with the front gate open. A clearer view of the facade and potted plants are shown. As with View 1a, a small upper portion of the vessels is visible form this view. This view, with the added screen features, screens over 90% of the proposed vessels.

• View 2, looking northeast along Westminster Avenue, shows the area along the

Westminster Avenue were a gap has been filled with vegetation. The trees that are simulated provide a much greater level of screening from this view. The upper and lower portions of the vessels are heavily screened, with the middle portions having partial screening. The simulated screening from this location is estimated at approximately 80%. Additional screening, including trees, could augment this simulation to increase the screening to over 90%.

• View 3, south on Westminster Avenue, shows that, with additional screening a

very small portion of the vessels would be seen. The existing trees augmented by the additional screening would provide a high level of screening from this view. Screening from this view is approximately 95%.

For each of these views, the additional or proposed screening, together with the current vegetation, provide over 90% obstruction from residential vantages along the southern property boundary. These mitigated simulation illustrations are for representation only and are not final design. They do however show the type and level of screening that will be provided at the Charnock location to reduce the visual effects of the proposed vessels. Significance After Mitigation. With incorporation of proposed mitigation, impacts associated with visual compatibility would be less than significant.

Impact AES-2 Proposed Charnock project structures would cast shadows onto adjacent properties in excess of those cast by the existing building. However, the net increase in shadow coverage would only affect the Windward School parking area adjacent to the Charnock site for more than three hours a day during the winter season. Therefore, the effect of shadows on existing uses would be Class III, less than significant.



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Charnock Well Field The southeastern portion of the project site is currently developed as a municipal water facility with a storage yard and water treatment features including a single story contact basin building. The northern and western portion of the site is developed as the Windward School, a private 7-12th grade college preparatory school with a current enrollment of about 500 students. The nearest potentially shadow sensitive uses that could be affected are the existing school buildings located approximately 75 feet to the north of the proposed new facilities and residential uses located about 100 feet to the south across Westminster Avenue. These are the nearest light-sensitive uses surrounding the immediate project area. The features of the proposed project would be up to approximately 24 feet tall; therefore, the project would cast longer shadows than currently exist. In general, shadows cast by buildings are longest at the winter solstice and shorten through the equinox seasons until their shortest length during the summer. Shadow modeling was performed to illustrate whether or not the proposed new facilities had the potential to adversely impact adjoining school or residential uses. Figures 4.1-3 and 4.1-4 show the anticipated shadowing that would occur with the proposed new Charnock buildings during the summer and winter solstice. Charnock Summer Shadows. The projected summer solstice (June 21) shadows are illustrated on Figure 4.1-3. During summer mornings, shadows would fall to the northwest. As the day progresses, morning shadows would shorten and move northward. At noon, shadows from the proposed project would be minimal and would not travel off-site. At 3 p.m. shadows from the proposed backwash tanks and hypochlorite storage building would extend slightly offsite, to a Windward School parking area. As this parking area is not light sensitive; summer shadows from the proposed projects would not exceed City’s thresholds for these uses. Charnock Winter Shadows. The estimated winter solstice (December 21) shadows generated by the proposed project are illustrated on Figure 4.1-4. During winter mornings, shadows from the proposed project would fall to the northwest, however they would not affect any offsite areas. Throughout the day, shadows would extend north and eastward, shortening until noon and then lengthening again until sunset. At noon, the shadows from the proposed backwash tanks and hypochlorite storage building would extend slightly off site, to a Windward School parking area. By 3 p.m. the shadows would extent significantly into the Windward School parking area. The total parking area would see approximately 60% shadow coverage. As this parking area is not light sensitive; winter shadows from the proposed projects would not exceed City’s thresholds for these uses. At the most extreme during the winter solstice, the sun is to the west and the shadows are cast to the east away from the sensitive receptors. As shown in Figures 4.1-3 and 4.1-4, the project would not cause adverse shadow impacts to any sensitive land uses in the project vicinity. Therefore, while the project would cast shadows on light-sensitive uses (residential balconies); these shadows would not exceed the City threshold and impacts would be less than significant.



4.1-19

Santa Monica Water Treatment Plant The only new structure that may be constructed at the SMWTP site would be a single story, approximately 7,500 square foot building that would house the new membrane filtration system. This building would be built within the existing water treatment facility and would replace all or a portion of the existing water softening facility. This potential new structure would be of similar size and scale as buildings currently onsite and would not change the existing visual character of the water treatment facility. Further, due to its location onsite and its size, this potential new development would not create shadows that would extend off-site or otherwise adversely affect sensitive uses. Salt Water Wells It is anticipated that the new wells would be installed in the vicinity of the two wells currently located west of the intersection of Pacific Street and Ocean Avenue on the Santa Monica Beach. The current wells are shown in Section 2, Project Description, Figure 2-12, photos 19 and 20. The new wells would be drilled to approximately 200 feet below ground utilizing a hollow stem drill rig. If implemented, the each well would be enclosed in a concrete block house, approximately 15 ft by 15 ft (225 sf) with the interior space being about 20 feet tall. These structures would be partially buried, and only the top 5 feet would be visible above the sand to reduce the visual impact. Due to the location and relatively small size of these potential structures, no shadow effects are anticipated.

Mitigation Measures. As impacts would be less than significant, mitigation is not required.

Significance After Mitigation. The proposed project’s impact related to shadow effects would be less than significant without mitigation.

Impact AES-3 The proposed development would introduce new sources of light and glare to the project site. Although project design elements would minimize impacts associated with lighting; the project may subject surrounding properties to increased light and glare. This would be a Class II, significant but mitigable.

Charnock Well Field For security purposes, this site would incorporate lighting at building entrances and automobile access locations. Security lighting is currently provided at the site however portions of it have not been active since the site stopped fulltime water treatment activities in 1996. While new sources of nighttime lighting would be introduced, the net lighting would not change greatly from the existing condition. Design features of the proposed project include light fixtures that have cut off shields and would only shed light pools on the project site. In addition, the project would have stainless steel fixtures. Based on the design features, lighting from the proposed project is not anticipated to introduce a substantial amount of new light compared to existing conditions. Furthermore, structural lighting would not be expected to be out of character with



4.1-20

surrounding land uses as the adjacent school currently has lighting in common and pedestrian access areas for security purposes. Additional existing lighting adjacent to this site is located on Westminster Avenue. Although the proposed project would not substantially alter the vicinity lighting conditions, mitigation measures are required to minimize the potential for project-generated nighttime lighting that may adversely affect neighboring properties, particularly south of the site across Westminster Avenue. Sources of glare that may affect the adjacent neighborhood include building exterior materials, and surface paving materials. The proposed project may introduce new sources of glare from the new structures; however design features, such as flat paint, will be incorporated to reduce any potential impacts. Santa Monica Water Treatment Plant The only new structure that may be constructed at the SMWTP site would be a single story, approximately 7,500 square foot building that would house the new membrane filtration system. This building would be built within the existing water treatment facility and would replace all or a portion of the existing water softening facility. This potential new structure would be of similar size and scale as buildings currently onsite and would not change the existing visual character of the water treatment facility. In addition, security lighting is already present at this facility and any new additional features at the site would not include additional lighting. Salt Water Wells It is anticipated that the potential new wells would be installed in the vicinity of the two wells currently located west of the intersection of Pacific Street and Ocean Avenue on the Santa Monica Beach. The new wells would be drilled to approximately 200 feet below ground utilizing a hollow stem drill rig. If constructed, each well would be enclosed in a concrete block house, approximately 15 ft by 15 ft (225 sf) with the interior space being about 20 feet tall. These structures would be partially buried, and only the top 5 feet are visible above the sand to reduce the visual impact. No security lighting is currently provided and none is anticipated if the wells are constructed. The concrete structures are not anticipated to have any associated glare if they are constructed.

Mitigation Measures. The following mitigation measures would reduce potential glare impacts associated with Charnock location lighting and structures.

AES-3(a) Low-glare Materials. All design and placement of windows shall be of low-glare specification. Paint used for exterior façades shall be of low-reflectivity. Metal surfaces shall be brush-polished, and shall not be highly reflective.

AES-3(b) Lighting Plan. Any exterior night lighting installed on the project site

shall be of low intensity, low glare design, and shall be hooded to direct light downward onto the subject parcel and prevent spill-over onto adjacent parcels. The applicant shall develop a Lighting Plan



Summer Solstice Shadow - June 21st

3:00 PM

12:00 PM9:00 AM

/

Aerial Source: Google 2007, Rincon Consultants, Inc., January 2008.

0 25 50 100 Feet



Winter Solstice Shadow - December 21st

3:00 PM

12:00 PM9:00 AM

/

Aerial Source: Google 2007, Rincon Consultants, Inc., January 2008.

0 25 50 100 Feet



4.1-25

incorporating these requirements. Significance After Mitigation. With incorporation of proposed mitigation measures,

impacts associated with light and glare would be less than significant.

c. Cumulative Impacts. The proposed project would be located on an existing water facility site that has been in water production for many years. Implementation of the water treatment system would introduce cylindrical vessel structures that are generally consistent with the size and massing that would be allowed under the current site zoning but would be generally inconsistent is shape and form with residential structures. The vessel appearance would be more similar to an industrial style of facility. Implementation of the project mitigation measures identified above would reduce project effects to a less than significant level. Given the generally developed nature of the site and surrounding area, the project would not be expected to result in either a project specific or cumulative impact on visual resources.

Cumulative development of buildings of greater height, including the proposed project, would generally increase shadowing throughout the area. Because shadowing is dependent upon building height, massing, and location, as well as the sensitivity of uses in the immediate vicinity of a project, the significance of shadow effects of individual buildings are typically addressed on a case-by-case basis. Shadow effects resulting from the proposed project were determined to be less than significant. Thus the project is not considered cumulatively considerable and would not have a significant cumulative impact with regard to shadows. Increased lighting and glare associated with the proposed project would be mitigated to less than significant with the measures recommended above. Therefore, while the project would incrementally add to lighting and glare present in the site area and most urban areas, the project would not have a cumulatively considerable impact on light or glare.



4.1-26


Charnock Well Field Restoration Project EIR Section 4.2 Construction Effects


4.2-1

4.2 CONSTRUCTION EFFECTS This section analyzes the proposed project’s temporary construction effects. Construction effects are related to the site preparation and development components of a project’s implementation. These include potential construction-related impacts associated with traffic, parking, and staging, hazards, noise, and air quality. Water quality construction impacts are discussed in Section 4.5, Hydrology and Water Quality. 4.2.1 Setting a. Traffic. The Charnock project site is located on Westminster Avenue, in the City of Los Angeles. Westminster Avenue is a two lane residential street. Regional access to this area is provided primarily by the San Diego Freeway (I-405) and by Sawtelle Boulevard. Access to the San Diego Freeway is provided at Venice Boulevard. This full freeway interchange is approximately two miles to the southeast of the project site. The SMWTP project site is located on Bundy Drive, in the City of Los Angeles. Regional access to this area is provided primarily by the San Diego Freeway (I-405) and by Wilshire Boulevard. Access to the San Diego Freeway is provided at Wilshire Boulevard. This full freeway interchange is approximately two miles to the northeast of the project site. The Salt Water Well project site is located on Santa Monica beach, in the City of Santa Monica. Regional access to this area is provided primarily by the Santa Monica Freeway (I-10) and by Pico Boulevard. Access to the Santa Monica Freeway is provided at Pico Boulevard. This full freeway interchange is approximately one mile to the north of the project site.

b. Air Quality. Some land uses are considered more sensitive to construction-related air pollution than others due to the types of population groups or activities involved. Sensitive population groups include children, the elderly, the acutely ill, and the chronically ill, especially those with cardio-respiratory diseases. Residential uses are also considered sensitive to air pollution because residents (including children and the elderly) tend to be at home for extended periods of time, resulting in sustained exposure to any pollutants present. Industrial and commercial areas are considered the least sensitive to air pollution, because exposure periods are relatively short and intermittent as the majority of the workers tend to stay indoors most of the time. In addition, the working population is generally the healthiest segment of the public.

c. Noise. Some land uses are considered more sensitive to construction-related noise levels than others, due to the amount of noise exposure (in terms of both exposure time and insulation from noise) and the types of activities typically involved. Residences, motels and hotels, schools, libraries, churches, hospitals, nursing homes, auditoriums, parks, and outdoor recreation areas are generally considered more sensitive to noise than are commercial and industrial land uses. For the Charnock facility, noise-sensitive receptors located in the vicinity of the project site include the single-family residential uses across Westminster Avenue south of the project site (approximately 100 feet away) and Windward School located north, east and west of the project site. The most common sources of noise in the project vicinity are transportation-related, such as automobiles, trucks, and motorcycles. Traffic along Westminster Avenue (to the south) is the primary source of noise near the project site.



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For the SMWTP facility, noise-sensitive receptors located in the vicinity of the project site include the residential uses across Texas Avenue and across Saltair Avenue, south and east respectively, of the project site (approximately 100 feet away). The most common sources of noise in the project vicinity are transportation-related, such as automobiles, trucks, and motorcycles. Traffic along Bundy Drive is the primary source of noise near the project site. For the Salt Water Well site, noise-sensitive receptors located in the vicinity of the project site include the residential uses on Ocean Avenue east of the project site (approximately 100 feet away). The most common sources of noise in the project vicinity are transportation-related, such as automobiles, trucks, and motorcycles. Traffic along Ocean Avenue is the primary source of noise near the project site.

d. Hazards. Existing structures on the project locations may be demolished or modified. The majority of existing structures were constructed and modified in the 1960s. Some limited demolition or renovation of existing structures would be needed to accommodate upgrades and new facilities. There is potential for risk of upset if lead based paint or asbestos containing materials are present in the structures to be modified. These contaminants could pose health hazards to sensitive receptors such as the students at Windward School (located adjacent the Charnock well site) or residents in the vicinity of the SMWTP (located approximately 100 feet from the site), unless properly mitigated. Structural modification and demolition would potentially occur both at the Charnock and the SMWTP sites. 4.2.2 Impact Analysis

a. Methodology and Significance Thresholds. The proposed project has the potential to generate significant impacts related to temporary changes in construction related traffic patterns, noise, and air quality.

Traffic. Traffic impacts associated with construction activities are considered potentially significant if the project construction would materially interfere with the exiting traffic flow, cause unsafe conditions or introduce substantial truck traffic through a residential area.

Air Quality. Temporary air quality emissions related to project implementation were

estimated using the California Air Resources Board’s (ARB’s) URBEMIS 2007 computer model. Temporary air quality impacts are considered significant if emissions associated with construction would exceed adopted South Coast Air Quality Management District (SCAQMD) thresholds. Temporary construction emission thresholds have been set by the SCAQMD on a daily basis as follows:

• 75 pounds per day of ROC • 100 pounds per day of NOx • 550 pounds per day of CO • 150 pounds per day of PM10 • 150 pounds per day of SOx

In addition to the above thresholds, if quarterly construction emissions would exceed 2.5 tons for ROC or NOx, 24.75 tons for CO, or 6.75 tons for PM10, or SOx, air quality impacts relating to



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construction are considered significant. Table 4.2-1 lists the significant construction thresholds recommended by the SCAQMD for projects within the SCAB.

Table 4.2-1 SCAQMD Air Quality Significance Construction Thresholds

Pollutant Threshold

(lbs/day)

NOx 100

VOC 75

PM10 150

PM2.5 55

SOx 150

CO 550

Lead 3

Source: SCAQMD, June24, 2005, http://www.aqmd.gov/ceqa/hdbk.html; lbs/day = pounds per day

Noise. Noise associated with construction activity was evaluated using construction

equipment noise level estimates contained in the USEPA report Noise from Construction Equipment and Operations, Building Equipment, and Home Appliances (1971). Section 41.40 of the Los Angeles Municipal Code restricts construction activity to the hours between 7:00 AM and 9:00 PM Monday through Friday, between 9:00 AM and 5:00 PM on Saturday, and does not allow construction activity to occur on Sunday or major national holidays. No person, other than an individual homeowner engaged in the repair or construction of his single family dwelling, shall perform any construction or repair work of any kind before 8:00 a.m. or after 6:00 p.m. on Saturday, nor at any time on Sunday. Section 112.05 of the Municipal Code specifies the maximum noise level of powered equipment or powered hand tools. Any powered equipment or powered hand tool that produces a maximum noise level exceeding 75 dBA at a distance of 50 feet from construction and industrial machinery shall be prohibited. However, the above noise limitation shall not apply where compliance is technically infeasible. “Technically infeasible” means that the above noise limitation cannot be complied with despite the use of mufflers, shields, sound barriers, and/or any other noise reduction device or techniques during the operation of equipment. The City of Santa Monica Noise Ordinance (Municipal Code § 4.12, as amended in February 2004) prohibits noise associated with demolition and other construction activities from exceeding the allowable exterior noise level for any noise zone by more than 10 decibels (dB – please see Section 4.3, Noise, for an explanation of decibels). The Ordinance applies to all noise sources located on private property. As part of this ordinance, properties within the City are assigned a Noise Zone based on their corresponding zone district. Residential properties are designated as Noise Zone I; commercial districts are designated Noise Zone II; and



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manufacturing or industrial districts are designated as Noise Zone III. The noise standards for the City are shown in Table 4.7-1, Section 4.7, Noise). If any portion of a parcel is located within 100 feet of a noise zone with higher noise standards, as compared to the noise standards for the noise zone in which the parcel is located, then the maximum allowable exterior equivalent noise level for the entire parcel is the average of the noise standards of the two noise zones. However, any noise level measurement must be taken at least 25 feet from the parcel line of the source of the noise (SMMC §4.12.060). The City’s Noise Ordinance (SMMC §4.12.110) restricts construction activity to the hours between 8:00 AM and 6:00 PM, Monday through Friday; between 9:00 AM and 5:00 PM on Saturday, and does not allow construction activity to occur on Sunday or major national holidays. In general, the equivalent noise level during construction is prohibited from exceeding the standard on the receiving property, plus 20 dB (i.e., 80 dBA for Zone I during the daytime fifteen minute continuous period). The maximum instantaneous noise level during construction is prohibited from exceeding the standard plus 40 dB (i.e., 100 dB for Zone I during the daytime fifteen minute continuous period). However, construction-related noise exceeding these thresholds is permitted, provided that it is restricted to the hours between 10:00 a.m. and 3:00 p.m. Hazards. Significant human health and safety impacts would occur if the project implementation would expose residents, employees, facility users and nearby land users to concentrations of hazardous materials exceeding regulatory levels.


Impact CON-1 Project construction may temporarily place equipment staging on adjacent streets and would temporarily increase truck traffic in the project area. This could disrupt the normal use of the sidewalk and adjacent streets, and affect parking availability. Onsite construction activities would also have the potential to adversely impact activities at Windward School. This would be a Class II, significant but mitigable impact.

Charnock Well Field

Construction at the Charnock site would temporarily increase truck traffic in the project area, which could disrupt the normal use of Sawtelle Boulevard and Westminster Avenue. Construction is estimated to occur over a 6-9 month period; however, the design and construction schedule has not been completed. The current estimate is up to 10-15 construction workers will be on-site at any given time. The total number of workers involved could range from 20-40. Some onsite parking is expected to be available during the construction period. A sidewalk is located on northern side of Westminster Avenue. The project may temporarily affect the ability of pedestrians to use the sidewalks on the north side of the street. Some construction parking is expected onsite and thus will limit the impacts to offsite parking supply. In addition to the reduction in on-street parking capacity during construction of the proposed



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project, construction site workers would temporarily compete with other users for parking spaces. This would temporarily reduce the available supply of public parking. Onsite construction activities, such as trenching, also have the potential to disrupt or adversely affect normal operations at Windward School. Santa Monica Water Treatment Plant

Construction at the SMWTP would temporarily increase truck traffic in the project area, which could disrupt the normal use of South Bundy Drive, Saltair and Texas Avenues. Construction is estimated to occur over a 6-12 month period. The current estimate is that up to 10-15 construction workers will be on-site at any given time. The total number of workers involved could range from 20-40. Some onsite parking is expected to be available during the construction period. A sidewalk is located on South Bundy Drive. Project construction has the potential to disrupt traffic flow and parking supply in the vicinity of the site. Salt Water Wells

If new salt water wells are determined to be required, implementation would temporarily increase truck traffic in the project area, which would increase the normal use of Pacific Street, Ocean Avenue and Bicknell Avenue. Several truck trips per day would be expected in the vicinity of the project area during the 3-4 month construction period. It is estimated that from to 2-8 construction workers will be on-site at any given time. The total number of workers involved could range from 10-15. Parking is expected to be available during the construction period from an adjacent parking lot located west of Pacific Street and Ocean Avenue. Construction site workers would temporarily compete with other users for parking facilities, thus temporarily reducing the available supply of public parking. Beach access however would not be impeded during the construction period as the drilling area will be utilizing an estimated 20 foot by 20 foot area.

Mitigation Measures. The following is required to mitigate temporary project traffic impacts during construction.

CON-1(a) Construction Impact Management Plan. The City shall prepare and implement a Construction Impact Management Plan which shall be designed to:

• Prevent material traffic impacts on the surrounding roadway network. • Minimize parking impacts both to public parking and access to private

parking to the greatest extent possible. • Ensure safety for both those constructing the project and the

surrounding community. • Prevent substantial truck traffic through residential neighborhoods.

The Construction Impact Management Plan shall be subject to review and approval by the following City Departments: Department of Public Works and Department of Planning and Community Development to ensure that the Plan has been designed in accordance with this mitigation measure. This review shall



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occur prior to commencement of any construction staging for the project. It shall, at a minimum, including the following: Ongoing requirements throughout the duration of construction:

• A detailed traffic control plan for work zones shall be maintained which

includes at a minimum accurate existing and proposed: parking and travel lane configurations; warning, regulatory, guide and directional signage: and area sidewalks, bicycle lanes and parking lanes. The plan shall include specific information regarding the projects construction activities that may disrupt normal pedestrian and traffic flow and the measures to address these disruptions. Such plans must be reviewed and approved by the Transportation Management Division prior to commencement of construction and implementation in accordance with this approval.

• Work within the public right-of-way shall be preformed between 9:00 a.m. and 4:00 p.m., including: dirt and demolition material hauling and construction material delivery.

• Streets and equipment should be cleaned in accordance with established Department of Public Works requirements.

• Trucks shall only travel on a City-approved construction route. Truck queuing/staging shall not be allowed on adjacent streets. Limited queuing may occur on the construction site itself.

• Materials and equipment should be minimally visible to the public; the preferred location for materials is to be on-site, with a minimum amount of materials within a work area in the public right-of-way, subject to a current Use of Public Property permit.

• Any requests for work before or after normal construction hours within public right-of-way shall be subject to review and approval through the After Hours Permit process administered by the Building and Safety Division.

• Provisions of off-street parking for construction workers, which may include the use of a remote location with shuttle transport to the site, if determined necessary by the City of Santa Monica.


Project Coordination Elements that shall be implemented prior to commencement of construction:

• Advise the traveling public of impending construction activities (e.g.

information signs, portable message signs, media listing/notification, implementation of an approved traffic control plan.

• Approval from the City through issuance of a Use of Public Property Permit Sewer or Oversize Load Permit, as well as any Caltrans Permits required, for any construction work requiring encroachment into public rights-of-way, detours or any other work within the public right-of-way.



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• Timely notification of construction schedules to all affected agencies (e.g. Police Department, Fire Department, Department of Public Works, and Department of Planning and Community Development) and to all owners and residential and commercial tenants of property within a radius of 500 feet.

• Coordination of construction work with affected agencies in advance of start of work. Approvals may take up to two weeks per each submittal.

• Approval by the Transportation Management Division for haul routes, for earth, concrete or construction materials and equipment hauling.

The following is required to mitigate temporary impacts to Windward School during construction, including trenching and pipeline relocation.

CON-1(b) Windward School Construction Management Plan. The City shall

prepare and implement a Windward School Construction Management Plan to minimize or avoid potential construction impacts associated with onsite construction, including pipeline trenching. The Windward School Construction Management Plan should focus on informing school and affected parties of pipeline trenching activities and dates. This plan shall include the following:

• Coordination and planning with Windward School to determine the

optimal routing and time period to conduct trenching activities on school grounds in order to avoid or minimize impacts to school activities; trenching shall be planned to occur during summer to the extent that it will not disrupt the construction timeline;

• Timely notification of construction (including trenching) schedule to Windward School and the surrounding community;



Significance After Mitigation. Implementation of the Construction Impact

Management Plan will ensure that the proposed project does not interfere with existing traffic flow or cause unsafe traffic conditions during the construction period. With these mitigation measures, short-term construction traffic impacts along access routes to the sites would be reduced to less than significant. Implementation of the Windward School Construction Management Plan will ensure that the proposed project limits unsafe conditions during construction within the Charnock property, including the pipeline trenching period. With these mitigation measures, the circulation and access related construction impacts at Windward School would be reduced to less than significant.



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Impact CON-2 Project construction would intermittently generate elevated noise levels on and adjacent to the site. This may affect noise sensitive receptors in the vicinity. This would be a Class II, significant but mitigable, impact.

As shown in Table 4.2-2, noise levels associated with heavy equipment typically ranges from about 78 to 88 dBA at 50 feet from the source (US EPA, 1971). The grading and excavation phase of project construction tends to create the highest noise levels because of the operation of heavy equipment. Continuous operation of this equipment during a nine-hour workday can cause noise levels onsite and at adjacent receptor locations that are above ambient levels and could exceed applicable noise standards.

Table 4.2-2 Typical Noise Levels at Construction Sites

Construction Phase

Average Noise Level at 50 Feet

Minimum Required Equipment Onsite

All Pertinent Equipment Onsite

Clearing 84 dBA 84 dBA

Excavation 78 dBA 88 dBA

Foundation/Conditioning 88 dBA 88 dBA

Laying Subbase, Paving 78 dBA 79 dBA

Finishing and Cleanup 84 dBA 84 dBA

Source: Noise from Construction Equipment and Operations, Building Equipment, and Home Appliances, prepared for the U.S. Environmental Protection Agency, 1971.

As described in Section 4.2.2 (a), Methodology and Significance Thresholds, Section 41.40 of the Los Angeles Municipal Code restricts construction activity to the hours between 7:00 AM and 9:00 PM Monday through Friday, between 9:00 AM and 5:00 PM on Saturday, and does not allow construction activity to occur on Sunday or major national holidays. No person, other than an individual homeowner engaged in the repair or construction of his single family dwelling, shall perform any construction or repair work of any kind before 8:00 a.m. or after 6:00 p.m. on Saturday, nor at any time on Sunday. Section 112.05 of the Municipal Code specifies the maximum noise level of powered equipment or powered hand tools. Any powered equipment or powered hand tool that produces a maximum noise level exceeding 75 dBA at a distance of 50 feet from construction and industrial machinery shall be prohibited. However, the above noise limitation shall not apply where compliance is technically infeasible. “Technically infeasible” means that the above noise limitation cannot be complied with despite the use of mufflers, shields, sound barriers, and/or any other noise reduction device or techniques during the operation of equipment.



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For the Salt Water Well site, the City of Santa Monica Noise Ordinance prohibits the equivalent noise level resulting from demolition and other construction activities from exceeding the exterior noise standard for any zone by more than 20 dB and the instantaneous noise level from exceeding the standard by more than 40 dB, unless the noise occurs between 10:00 AM and 3:00 PM. The project site is located near a residential area of Santa Monica, which is classified as Noise Zone I and has an exterior daytime noise standard of 60 dBA (for a 15 minute continuous measurement period). Therefore, construction-related noise generated on the project site would not be permitted to exceed 80 dB, or 100 dB for instantaneous noise, at adjacent properties, unless the noise occurs between the hours of 10:00 AM and 3:00 PM. For the Charnock facility, noise-sensitive receptors located in the vicinity of the project site include the single-family residential uses across Westminster Avenue south of the project site (approximately 100 feet away) and Windward School located north, east and west of the project site. For the SMWTP facility, noise-sensitive receptors located in the vicinity of the project site include the residential uses across Texas Avenue and across Saltair Avenue, south and east respectively, of the project site (approximately 100 feet away). For the Salt Water Well site, noise-sensitive receptors located in the vicinity of the project site include the residential uses on Ocean Avenue east of the project site (approximately 100 feet away).

Mitigation Measures. The following measures are required to reduce construction noise impacts related to the project activities.

CON-2(a) Diesel Equipment Mufflers. All diesel equipment shall be operated with closed engine doors and shall be equipped with factory-recommended mufflers. Performance standards shall be set so that noise levels exceeding 75 dBA at a distance of 50 feet from construction and industrial machinery shall be prohibited.

CON-2(b) Electrically-Powered Tools. Electrical power shall be used to run

air compressors and similar power tools. Performance standards shall be set so that noise levels exceeding 75 dBA at a distance of 50 feet from construction and industrial machinery shall be prohibited.

CON-2(c) Restrictions on Excavation and Foundation/Conditioning.

Excavation, foundation-laying, and conditioning activities (the noisiest phases of construction) shall be restricted to between the hours of 10:00 a.m. and 3:00 p.m., Monday through Friday.

CON-2(d) Additional Noise Attenuation Techniques. For all

noise-generating construction activity on the project site, additional noise attenuation techniques shall be employed to reduce noise levels to City of Los Angeles noise standards of levels not exceeding 75 dBA at a distance of 50 feet. Such techniques may include, but are not limited to, the use of sound blankets on noise generating equipment and the construction of temporary sound barriers between construction sites and nearby sensitive receptors.



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CON-2(e) Construction Sign Posting. The City shall be required to post a

sign informing all workers and subcontractors of the time restrictions for construction activities. The sign shall also include the City telephone numbers where violations can be reported and complaints associated with construction noise can be submitted.

Significance After Mitigation. With implementation of Mitigation Measures CON-2(a-

e), temporary construction-related noise impacts would be less than significant.

Impact CON-3 The proposed project would require the demolition of buildings and structures that could contain asbestos material or lead-based paint. Therefore, there is potential for a safety hazard to the public or the environment through the release of hazardous materials. However, implementation of appropriate measures regarding the handling and disposal of these materials would reduce impacts to a Class II, significant but mitigable, level.

Construction of the proposed project may involve the demolition of existing onsite buildings. Use of regulated asbestos containing material (RACM) in the manufacturing of products such as spray acoustic ceilings, acoustic tiles, various plasters, duct wrap, paper backing of linoleum, non-bituminous roofing felt, wallboard, joint compound (joint "mud"), and thermal insulation on pipes and boilers, was banned in 1978. However, some products remained on the shelf and were used in the construction of buildings and homes for several years thereafter, and some are still used today. Lead-based paint was banned by the U.S. Consumer Product Safety Commission in 1978. However, many houses and apartments built before 1978 have paint that contains lead. As all existing onsite structures were built before 1978, RACM and lead-based paint could be contained in the building materials. Therefore, demolition of the existing buildings has the potential to disturb asbestos and lead containing materials within the buildings. Removal of any asbestos would require compliance with all pertinent existing rules and regulations, including SCAQMD Rule 1403 (Asbestos Demolition and Renovation Activities). This rule requires the applicant to notify the SCAQMD of the intent to perform demolition or renovation of any buildings which may contain asbestos prior to demolition and requires that asbestos containing material is removed prior any demolition that would break up, dislodge, or disturb the material. For the removal of lead based paint, the proposed project would have to comply with California Occupational Safety and Health Administration (Cal OSHA) regulations. The California Code of Regulations, §1532.1, applies to all construction work where an employee may be occupationally exposed to lead. This regulation requires testing, monitoring, containment, and disposal of lead-based materials such that exposure levels do not exceed Cal OSHA standards. Thus, impacts would be significant but mitigable.

Mitigation Measures. The following measures are required to mitigate potential impacts relating to the release of asbestos or lead during building demolition.



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CON-3(a) Asbestos Survey and Removal. Prior to the initiation of demolition work, areas of the onsite structures proposed for removal shall be sampled as part of an asbestos survey in compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP). If asbestos is found in any building, asbestos-related work, including demolition, involving 100 square feet or more of asbestos containing materials (ACMs) shall be performed by a licensed asbestos abatement contractor under the supervision of a certified asbestos consultant and asbestos shall be removed and disposed of in compliance with applicable State laws. Regardless of whether asbestos is identified in the building, prior to demolition of the existing structure, the South Coast Air Quality Management District (SCAQMD) shall be notified and an SCAQMD Asbestos Demolition and Renovation Compliance Checklist shall be submitted to both SCAQMD and the City of Santa Monica.

CON-3(b) Lead Survey and Removal. Prior to demolition of onsite structures

a lead based paint survey shall be performed by a qualified professional. If present, all hazardous materials shall be handled and disposed in accordance with local, state and federal regulations. According to the Department of Toxic Substances Control (DTSC), if paint is not removed from the building material during demolition (and is not chipping or peeling), the material can be disposed of as construction debris (a non-hazardous waste). All lead-based paint removed from these structures shall be hauled and disposed of by a transportation company licensed to transport this type of material. The landfill operator shall be contacted prior to disposal of building material debris to determine any specific requirements the landfill may have regarding the disposal of lead-based paint materials.

Following completion of the lead-based paint abatement, a lead-

based paint consultant shall provide a report documenting the abatement procedures used, the volume of lead based paint removed, where the material was moved to, and include transportation and disposal manifests or dump tickets. The abatement report shall be prepared for the property owner or other responsible party, with a copy submitted to the City of Santa Monica.

Significance After Mitigation. With implementation of the above mitigation measures,

the impacts related to exposure to asbestos containing material and lead based paint would be reduced to a less than significant level.

Impact CON-4 Project construction would generate air pollutant emissions

however temporary construction impacts would not exceed SCAQMD construction thresholds. Impacts, therefore, would be Class III, not significant.



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Construction effects are those impacts that are related to the site preparation and construction of the individual project components. The Charnock location would involve the construction of the GAC vessel system, several storage tanks, control building and a chemical storage building. The SMWTP project components would involve the possible upgrades to the ion exchange system, the construction of a reverse osmosis or nano-filtration system and upgrades to the fluoridation system, and disinfection treatment system. Depending upon the water treatment system ultimately selected for the SMWTP, there is the potential that two new salt water extraction wells will be required. These wells would be drilled to a depth of approximately 200 feet below ground surface utilizing a hollow stem drill rig. Construction would involve the drilling of two new wells and associated infrastructure (pipelines, well vaults, french drains, etc.). In addition, the current wells would be abandoned since they would no longer be utilized. Tables 4.2-3 through 4.2-6 show the worst-case daily emissions for the individual project components and the total project during implementation. Fugitive dust would generally result in the greatest amount of PM10 emissions, while construction equipment would generate the greatest amount of NOx, ROC, and CO emissions. As shown in Tables 4.2-3 through 4.2-6, although project implementation including materials deliveries, operation of mechanical equipment, drilling, boring and earth moving activities would result in the emissions of some criteria pollutants, total emissions during project implementation would be well below established SCAQMD thresholds for all pollutants. Charnock Well Field Construction at the Charnock site would generate a temporary increase in air pollutant emissions. However, as shown in Table 4.2-3, worst-case daily emissions are well below established SCAQMD thresholds for ROC, NOx, CO and PM10.

Table 4.2-3 Charnock Maximum Daily Construction Emissions (lbs/day)

Pollutant Construction Emissions SCAQMD Thresholds

Threshold Exceedance

(Yes/No)

ROC 1.67 75 No

NOx 13.11 100 No

CO 9.05 550 No

PM10 0.78 150 No

SOx 0.01 150 No See Air Quality Modeling Data sheets on in Appendix B



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Santa Monica Water Treatment Plant

Construction at the SMWTP site would generate a temporary increase in air pollutant emissions. However, as shown in Table 4.2-4, worst-case daily emissions are well below established SCAQMD thresholds for ROC, NOx, CO and PM10.

Table 4.2-4 SMWTP Maximum Daily Construction Emissions (lbs/day)



(Yes/No)

ROC 3.02 75 No

NOx 21.86 100 No

CO 15.17 550 No

PM10 1.46 150 No


Salt Water Wells Construction of two new salt water wells would generate a temporary increase in air pollutant emissions. However, as shown in Table 4.2-5, worst-case daily emissions are well below established SCAQMD thresholds for ROC, NOx, CO and PM10.

Table 4.2-5 Salt Water Well Maximum Daily Construction Emissions(lbs per day)



(Yes/No)

ROC 2.95 75 No

NOx 24.56 100 No

CO 11.12 550 No

PM10 1.40 150 No


As discussed above and summarized below, total project construction would generate a temporary increase in air pollutant emissions. However, as shown in Table 4.2-6, worst-case daily emissions are well below established SCAQMD thresholds for ROC, NOx, CO and PM10.



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Table 4.2-6 Total Project Maximum Daily Construction Emissions(lbs per day)



(Yes/No)

ROC 7.64 75 No

NOx 59.53 100 No

CO 35.34 550 No

PM10 3.64 150 No


Mitigation Measures. The following mitigation measures are recommended by the

SCAQMD to reduce emissions associated with construction activities to the greatest extent feasible. These measures shall be made conditions of approval and indicated on final construction and grading plans submitted to the City prior to issuance of a building permit or grading permit.

CON-4(a) Fugitive Dust Control Measures. The following shall be implemented during construction to minimize fugitive dust and associated particulate emissions:

• All material excavated or graded should be sufficiently watered to

prevent excessive amounts of dust. Watering should occur at least three times daily with complete coverage, preferably at the start of the day, in the late morning and after work is done for the day

• All grading, earth moving or excavation activities shall cease during periods of high winds (i.e., greater than 20 mph measured as instantaneous wind gusts) so as to prevent excessive amounts of dust

• All material transported on and off-site should be securely covered to prevent excessive amounts of dust

• Soils stockpiles shall be covered • Onsite vehicle speeds shall be limited to 15 mph • Install wheel washers where vehicles enter and exit the

construction site onto paved roads or wash off trucks and any equipment leaving the site each trip

• Appoint a construction relations officer to act as a community liaison concerning onsite construction activity including resolution of issues related to PM10 generation

• Sweep streets at the end of the day using SCAQMD Rule 1186 certified street sweepers or roadway washing trucks if visible soil is carried onto adjacent public paved roads (recommend water sweepers with reclaimed water)



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• All active portions the construction site shall be sufficiently watered three times a day to prevent excessive amounts of dust.

The following measure is required to further reduce emissions of construction-related ozone precursors (ROC and NOx).

CON-4(b) Ozone Precursor Control Measures. The following shall be implemented throughout construction to reduce emissions of ozone precursors ROC and NOx:

• Equipment engines should be maintained in good condition and

in proper tune as per manufacturer’s specifications; • Schedule construction periods to occur over a longer time period

(i.e. lengthen from 60 days to 90 days) during the smog season so as to minimize the number of vehicles and equipment operating simultaneously; and

• Use new technologies to control ozone precursor emissions as they become readily available.

The following measure is required to reduce emission of construction-related Particulate Matter including PM10 and PM2.5.

CON-4(c) PM10 and PM2.5 Control Measures. Throughout construction, off-

road and on-road diesel equipment shall use Diesel Particulate Features (DPF) to reduce emissions of PM10 and PM2.5.

Significance After Mitigation. Implementation of the above mitigation measures would

reduce temporary construction emissions for all phase of construction to the greatest extent feasible. Thus, impacts would be less than significant.

c. Cumulative Impacts. Cumulative projects in the project area would have the potential to generate construction effects that could result in adverse health and safety conditions. This development would create the potential for temporary traffic, noise, and hazardous material impacts similar to those described for the project. However, the effects of construction activity would be localized and temporary in nature and would not contribute to any cumulative citywide impacts. Consequently, compliance with standard construction mitigation requirements similar to those described for the project on a case-by-case basis would mitigate any potential impacts from individual construction projects. Given the limited scale of the proposed project and the construction activities associated with the project, the project would not have a cumulatively considerable impact related to construction activities.



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Charnock Well Field Restoration Project EIR Section 4.3 Geology

City of Santa Monica 4.3-1

4.3 GEOLOGY This section analyzes potential impacts associated with geologic processes and includes hazards associated with seismic activity, liquefaction, and other soil-related risks. For a discussion of potential flooding impacts related to tsunami risk, refer to Section 4.5, Hydrology and Water Quality. 4.3.1 Setting The City of Santa Monica is within the northwestern Coastal Plain of the Los Angeles Basin. The landward portion of the Los Angeles Basin is bounded to the north by the Santa Monica Mountains, Elysian Hills and Repetto Hills, to the east by the Merced Hills, Puente Hills, and Santa Ana Mountains, and to the south and west by the Pacific Ocean. The site is within the Transverse Ranges Geomorphic Province, which is characterized by east-west trending faults, folds and mountain ranges. This province is considered seismically active. The project sites are located within the Santa Monica Plain. The Charnock and SWMTP sites are at an elevation of about 80 feet above mean sea level. The salt water wells are located along Santa Monica beach. Each project location features generally level topography.

a. Regional Geology. The faulting and seismicity of Southern California is dominated by the compressionary regime associated with the intersection of the San Andreas Fault Zone and the Garlock Fault. The San Andreas Fault Zone separates two tectonic plates. The western side of the fault is the Pacific Plate and the eastern side of the fault is the North American Plate. The Western Plate is moving in a northwesterly direction relative to the North American Plate. The San Andreas Fault generally trends northwest to southeast. However, north of the Transverse Ranges Province, the fault trends more in an east-west direction, causing the fault’s right-lateral strike-slip movement to produce north-south compression between the two plates. This compression has produced rapid uplift of many of the mountain ranges in Southern California. North-south compression in southern California has been estimated at between 5 to 20 millimeters per year (SCEC, 1995). Quaternary age (within the last 1.6 million years) unconsolidated and semi-consolidated sediments are over 1,000 feet thick in some localities of the Coastal Plain. These sediments are approximately 400 feet thick in the eastern Santa Monica area. The Quaternary sediments are underlain by Tertiary (1.6 to 65 million years old) age rocks. The Tertiary rocks are principally composed of marine sediments of the Fernado, Monterey and Topanga formations and the Santa Monica Siate that filled the basin when it was below sea level. The Coastal Plain of the Los Angeles Basin is sub-divided into several groundwater basins. The divisions of these groundwater basins are caused by geologic features such as non-water bearing bedrock, faults and other features that impede the flow of groundwater. The project site is within the Santa Monica sub-basin, which is bounded by the Santa Monica Mountains to the north, the Ballona Escarpment to the south, the Inglewood Fault to the east and the Pacific Ocean to the west. Groundwater extends from the recent alluvium down to the fractured Tertiary rocks. Groundwater movement in the basin is generally towards the south with some minor subsurface flow towards the west near the City of Santa Monica.



b. Site Geology. The project area is located in the southern portion of the gently sloping Santa Monica Plain. The plain was formed by several alluvial fans derived out from the Santa Monica Mountains to the north. The plain is dissected by several streams draining from the Santa Monica Mountains. According to the Geologic Map of the Beverly Hills-Van Nuys (South ½) Quadrangle (Dibblee, 1992), the Charnock and SMWTP project locations are located on Quaternary age older alluvial gravel, sand, silt and clay derived mainly from the Santa Monica Mountains and also includes gravels and sands from stream channels. These Quaternary age sediments overlie Tertiary-age marine bedrock units of the drilled on Fernando and Monterey formations. For the salt water wells the regional geologic mapping (Geologic Map of California, Los Angeles Sheet, 1991) and Dibblee (1992) depict the project area as consisting of Quaternary-age alluvium. The alluvium is described as “beach sand”. These Quaternary-age sediments overlie Tertiary-age marine bedrock units of the Monterey and Fernando formations.

c. Seismic Hazards. Seismic Potential. The 1997 Uniform Building Code (UBC) defines different regions of

the United States and ranks them according to their seismic hazard potential. Four regions have been established, designated as Seismic Zones 1 through 4 (Zone 1 has the least seismic potential and Zone 4 has the highest seismic potential). As depicted on Figure 16-2 in Chapter 16 of the UBC (1997), the project area is within Seismic Zone 4. The proximity of active faults is such that the project area has experienced and will continue to experience strong seismically induced ground motion. The U.S. Geological Survey defines active faults as those that have had surface displacement within Holocene time (about the last 11,000 years). Surface displacement can be recognized by the existence of bluffs in alluvium, terraces, offset stream courses, fault troughs and saddles, the alignment of depressions, sag ponds, and the existence of steep mountain fronts. Potentially active faults are those that have had surface displacement during the last 1.6 million years. Inactive faults have not had surface displacement within the last 1.6 million years. Several active and potentially active faults are located in the general site vicinity. These nearby faults include:

• Santa Monica Fault • Hollywood Fault • Raymond Fault • Malibu Coast Fault • Palos Verdes Fault • Newport-Inglewood Fault • Charnock Fault

In addition to these nearby faults, other faults in the Southern California area have the potential to seismically affect the site. These include the San Gabriel Fault, the San Andreas Fault, and the probable existence of large blind thrust faults currently undocumented.



Faults generally produce damage in two ways: surface rupture and seismically induced ground shaking. Surface rupture is limited to areas very near the fault and ground shaking covers a wide area.

Surface Rupture. Surface rupture along a fault is the surface expression of fault displacement. Fault displacement occurs when material on one side of a fault moves relative to the material on the other side of the fault. Surface displacement can range from a few inches to tens of feet during a rupture event. This can have catastrophic consequences, including injury and loss of life, when buildings are located within the rupture zone. It is not practically feasible (structurally or economically) to design and build structures that can accommodate the rapid displacement involved with surface rupture.

Alquist-Priolo Earthquake Fault Zones are areas within 500 feet from a known active fault trace. Pursuant to the Alquist-Priolo legislation, no structure for human occupancy is permitted on the trace of an active fault. The term “structure for human occupancy” is defined as any structure used or intended for supporting or sheltering any use or occupancy, which is expected to have a human occupancy rate of more than 2,000 person-hours per year. Any new development proposed within an Alquist-Priolo Zone must be preceded by a fault study. If the study indicates that an active fault is located within a proposed development site, then all structures associated with the development must be set back at least 50 feet on both sides of the fault trace. The Alquist-Priolo legislation presumes that any area within 50 feet of an active fault is underlain by active branches of the fault unless proven otherwise (CDMG, 1994). None of the project sites are located within an Alquist-Priolo Earthquake Fault Zone or the City of Santa Monica Fault Hazard Management Zone. The closest significant faults are the Newport-Inglewood Fault Zone, about 3 miles southeast of the SMWTP, approximately 2 ½ miles east of the Charnock site, and about 6 miles east of the salt water well location. The Santa Monica-Hollywood Fault Zone is located about 0.5 miles south of the SMWTP, approximately 1 mile north of the Charnock site and about 2 miles north of the salt water well location. Several other faults have been identified in the vicinity of the project locations. The Potrero Grande fault runs east-west beneath the southern corner of the SMWTP and two potentially active faults are located near the Charnock site. To the east is the Overland Fault and to the west is the Charnock Fault. The potential for surface rupture at the project sites are considered low, however the sites could potentially experience severe seismic ground shaking in the event of an earthquake on the Santa Monica fault or any of several faults in the area.

Seismically Induced Ground Shaking. Ground shaking covers a wide area and is greatly influenced by the distance of the site to the seismic source, soil conditions, and depth to groundwater. Ground shaking is a result of the seismic waves produced by a fault rupture event. Secondary hazards associated with seismically induced ground shaking include liquefaction, seismically induced settlement, earthquake-triggered landslides, tsunamis and seiches. Any of the faults listed above could generate substantial ground shaking at the project site. As shown in the Seismic Shaking Hazard Maps of California (California Division of Mines and Geology, 1999), each of the sites has about a 10 percent probability of experiencing 0.4-0.5 gravity (g) peak horizontal ground acceleration within the next 50 years. The CDMG has produced three maps depicting ground acceleration in the west Los Angeles area (CDMG,



2001). These maps are for firm rock conditions, soft rock conditions, and alluvium conditions. The 10% exceedance in 50 years peak ground accelerations expected at the site are 0.40-0.41 g for firm rock conditions; 0.43-0.45 g for soft rock conditions; and 0.45-0.46 g for alluvium conditions. The calculation of accelerations for firm rock, soft rock, and alluvial conditions assumes that the entire area is properly described as firm rock, soft rock, or alluvial material. Immediately beneath the project site (to at least a depth of 51 feet below grade), the earth materials consist of alluvial material. Thus, the appropriate horizontal ground acceleration expected would be modeled by the alluvial conditions (0.42 –0.46g) (CDMG, 2001). The strength of ground shaking in an area is primarily a function of the distance between the area and the seismic source epicenter, the type of material underlying the property, and the motion of fault displacement. In addition, the Northridge (1994) earthquake showed how peculiarities in basin effects could play a significant role in ground accelerations at specific areas. For instance, ground accelerations exceeding 1g were recorded at areas far from the epicenter of the Northridge earthquake, including the Santa Monica area. Because of the proximity to major active faults, such as the San Andreas and Newport-Inglewood fault systems, it is possible that accelerations near or over 1.0g could occur anywhere within the area, including the project sites. d. Secondary Seismic Hazards and Soil Hazards. Liquefaction. Liquefaction is a temporary, but substantial, loss of shear strength in granular solids, such as sand, silt, and gravel, usually occurring during or after a major earthquake. This occurs when the shock waves from an earthquake of sufficient magnitude and duration compact and decrease the volume of the soil; if drainage cannot occur, this reduction in soil volume will increase the pressure exerted on the water contained in the soil, forcing it upward to the ground surface. This process can transform stable granular material into a fluid-like state. The potential for liquefaction to occur is greatest in areas with loose, granular, low-density soil, where the water table is within the upper 40 to 50 feet of the ground surface. Liquefaction can result in slope and foundation failure. Other effects of liquefaction include lateral spread, flow failures, ground oscillations, and loss of bearing strength. Liquefaction is intrinsically linked with the depth of groundwater below the site and the types of sediments underlying an area. Table 4.3-1 lists the relationship between liquefaction hazard and groundwater depth.

Table 4.3-1 Liquefaction Zone Criteria

Geologic Unit Depth to Groundwater Greater than 40 feet Less than 40 feet Qa Low High all other Low Low Source: CDMG, 1995.

To more accurately determine the potential for liquefaction, site-specific geologic studies are required prior to new construction. Such studies would typically include site specific depth to groundwater and soil composition as they relate to seismically induced hazards. Areas having



liquefiable sediments should be identified, and structures should be properly designed to withstand the conditions. According to the Safety Element of the City of Los Angeles General Plan (1996), the SMWTP site is located within a liquefaction area (the Charnock location is not within this area). The Safety Element defines these areas as containing recent alluvial deposits and groundwater at less than 30 feet deep. In addition, the proposed salt water wells are identified as being in high liquefaction area (City of Santa Monica Safety Element, 1995).

Subsidence. Seismically induced settlement occurs in loose to medium dense unconsolidated soil above groundwater. Loose to medium dense unconsolidated soil can compress (settle) when subject to seismic shaking. The settlement is exacerbated by increased loading, such as from the construction of structures onsite. This settlement can be mitigated prior to development through the removal and re-compaction of loose soils. The City of Los Angeles Safety Element states that subsidence, especially near former clay pits, could occur. These pits are not near the project locations; therefore, subsidence hazard at the project location is low.

Landsliding and Slope Instability. Landslides occur when slopes become unstable and masses of earth material move downslope. Landslides are generally considered to be rapid events, often triggered during periods of rainfall or by earthquakes. Mudslides and slumps are a more shallow type of slope failure compared to landslides. These typically affect the upper soil horizons, and are not bedrock features. Historically, mudslides and slumps occur during or soon after periods of rainfall. Erosion can occur along manufactured slopes that are improperly designed or not adequately re-vegetated. The probability of seismically-induced landslides affecting the subject development is considered to be remote, due to the lack of significant slope on the sites and in the surrounding areas. 4.3.2 Impact Analysis

a. Methodology and Significance Thresholds. An impact is considered potentially significant if it will expose people or structures to major geologic hazards. Therefore, impacts are considered significant if the proposed development would be exposed to high potential for such seismic hazards as ground shaking, liquefaction, or subsidence.


Impact GEO-1 Seismically induced ground shaking could destroy or damage structures and infrastructure developed for the proposed project, resulting in loss of property or risk to human health. Provided that the design complies with all applicable provisions of the most recent Uniform Building Code and the California Building Code, impacts would be a Class III, less than significant.

The proximity of active faults is such that the project area has experienced and will continue to experience strong seismically induced ground motion. Surface displacement can be recognized by the existence of bluffs in alluvium, terraces, offset stream courses, fault troughs and saddles,



the alignment of depressions, sag ponds, and the existence of steep mountain fronts. Several active and potentially active faults are located in the general site vicinity. These nearby faults include the Santa Monica Fault, Hollywood Fault, Raymond Fault, Malibu Coast Fault, Palos Verdes Fault, Newport-Inglewood Fault and the Charnock Fault. In addition to these nearby faults, other faults in the Southern California area have the potential to seismically affect the site. These include the San Gabriel Fault, the San Andreas Fault, and the probable existence of large blind thrust faults currently undocumented. The faults listed are not the only faults in the area that can produce earthquakes, but they are the most probable to affect the project locations according to the latest data. Earthquakes along these faults could produce potentially significant impacts to site structures. Although nothing can ensure that structures do not fail under seismic stress, proper engineering, including the measures identified below, can minimize the risk to life and property. The most recent Uniform Building Code and California Building Code ensure that the design and construction of new structures are engineered to withstand the expected ground acceleration that may occur. The calculated design base ground motion for the sites should take into consideration the soil type, potential for liquefaction, and the most current and applicable seismic attenuation methods that are available. For the groundwater wells, ANSI/AWWA A100-06 standards for water wells will be required. This standard covers the minimum requirements for vertical water supply wells, including geologic/hydrologic conditions and water quality and well construction. This standard will be referenced in specifications for constructing the groundwater wells.

Mitigation Measures. Provided that the design and construction of the building, groundwater wells and parking structure complies with all applicable provisions of the most recent Uniform Building Code, California Building Code and ANSI/AWWA standards, no further mitigation is necessary.

Significance After Mitigation. The probability of a larger than expected earthquake with higher ground accelerations to occur can never be reduced to absolute zero. Any structure built in California is susceptible to failure due to seismic activity. However, the potential for structural failure due to seismic ground shaking would be considered less than significant through implementation of the most recent industry standards for structural designs.

Impact GEO-2 The SMWTP site is located in an area of liquefaction risk. Liquefaction could cause structural failure resulting in loss of property or risk to human health. This would be a Class II, significant but mitigable impact.

According to the Safety Element of the City of Los Angeles General Plan (1996), the SMWTP site is located within a liquefaction area (the Charnock location is not within this area). The Safety Element defines these areas as containing recent alluvial deposits and groundwater at less than 30 feet deep. In addition, the proposed salt water wells are identified as being in high liquefaction area (City of Santa Monica Safety Element, 1995).



Liquefaction is a temporary, but substantial, loss of shear strength in granular solids, such as sand, silt, and gravel, usually occurring during or after a major earthquake. This occurs when the shock waves from an earthquake of sufficient magnitude and duration compact and decrease the volume of the soil; if drainage cannot occur, this reduction in soil volume will increase the pressure exerted on the water contained in the soil, forcing it upward to the ground surface. This process can transform stable granular material into a fluid-like state.

Mitigation Measures. The following measures would reduce impacts associated with liquefaction hazards to a less than significant level: GEO-1 Geotechnical Study. A geotechnical investigation for the SMWTP site

and salt water well site (if implemented) will be required as the project proceeds. The City shall comply with all recommendations contained in the Geotechnical Study prepared for the project. In addition, all onsite structures shall comply with applicable provisions of the Uniform Building Code and the California Building Code. The investigation would evaluate the potential for liquefaction to occur and make recommendations to minimize the potential for this hazard to affect the water treatment supply infrastructure. The study would prescribe methods, techniques, and specifications as applicable for: site preparation, treatment of undocumented fill and/or alluvial soils, fill characteristics, fill placement and compactions, temporary excavations and shoring, permanent slopes, treatment of expansive soils, and treatment of corrosive soils. If portions of the site area identified as liquefiable, measures (such as those described above) will be recommended by the project geotechnical consultant and performed by a qualified Geotechnical Engineer and Engineering Geologist.

Significance After Mitigation. Current structural engineering methods for foundation design, in areas prone to liquefaction, may not be sufficient to prevent a building’s foundation from failing in a larger earthquake with stronger and longer groundshaking. However, implementation of the above mitigation measure will address impacts related to seismically induced liquefaction to the extent of industry standards, and will therefore reduce the impact to less than significant. c. Cumulative Impacts. Proposed development, in conjunction with other cumulative projects proposed in the City, would expose additional people and property to seismically related hazards. Cumulative impacts related to seismically related ground shaking, liquefaction, and soil compaction would be similar to what is described for project-specific impacts, and would be dealt with on a project by project basis. The project would not result in a cumulatively considerable or otherwise significant impact on geologic hazards.




Charnock Well Field Restoration Project EIR Section 4.4 Hazards and Hazardous Materials


4.4-1

4.4 HAZARDS and HAZARDOUS MATERIALS This section analyzes potential impacts associated with hazards and the use of hazardous materials. Impacts relating to potential project activities on the site and in the vicinity are addressed. 4.4.1 Setting

a. Regulatory Setting. Numerous federal, state, and local regulations regarding use, storage, transportation, handling, processing and disposal of hazardous materials and waste have been adopted since the passage of the federal Resource Conservation and Recovery Act (RCRA) of 1976. The goal of RCRA is to assure adequate tracking of hazardous materials from generation to proper disposal. California Fire Code (CFC) Articles 79, 80 et al., which augment RCRA, are the primary regulatory guidelines used by the City to govern the storage and use of hazardous materials. The CFC also serves as the principal enforcement document from which corresponding violations are written. The State of California defines a hazardous material as a substance that is toxic, flammable/ignitable, reactive, and/or corrosive. Extremely hazardous materials are substances that show high or chronic toxicity, carcinogenic, bioaccumulative properties, persistence in the environment, or that are water reactive. Hazardous substances include both hazardous wastes and hazardous materials. In general, a material or waste is classified as hazardous if it is one of more than 700 chemicals specifically listed in the California Code of Regulations; if it contains one of these chemicals; or if it is reactive, ignitable, corrosive, or toxic. Because of their potential threat to public health and the environment, hazardous substances are closely regulated by federal, state, and local laws that focus on controlling their production, handling, storage, transportation, and disposal. Hazards and hazardous materials include those actions and materials affecting health and safety of the public and the release of hazardous materials into the environment. Hazards discussed in this section include naturally occurring contamination (i.e., oil fields and soil gas), man-made contamination in soil (as well as groundwater), and public nuisances (vector management issues, such as activities that could involve conditions that attract rodents and insects that could transmit disease and create a health hazard). Hazardous materials include solids, liquids, or gaseous materials which because of their quantity, concentration or physical, chemical or infectious characteristics may: (1) cause or contribute to an increase in mortality or serious illness; or (2) pose a substantial present or potential harm to human health or the environment when improperly handled, used, transported, stored or disposed. This section addresses the environmental safety issues listed below:

• Hazardous Materials Use and Storage: Hazardous materials use and storage refers to

procedures for the acquisition, use, handling and storage of hazardous materials (i.e., limitations on use and storage quantities and types, employee training and storage design requirements) at the project sites.

• Hazardous Materials Management: Hazardous materials management refers to the

planning for the acquisition, use, storage, disposal, and potential accidental release of hazardous materials, and the tracking of hazardous materials throughout their life cycle.



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• Hazardous Waste: Hazardous waste refers to either: (1) refuse associated with the use of

hazardous materials in certain industrial and commercial processes (i.e., operational hazardous waste); or (2) residual contamination of soil and groundwater by hazardous materials at the project site which could pose a significant existing or future hazard to public health or the environment unless measures are taken during development of the project.

The lead agency regulating hazardous materials for the City of Los Angeles is the City Fire Department (LAFD). LAFD issues permits for hazardous materials handling, enforces the Hazardous Materials Release Response Plans and Inventory Act (AB 2185), and administers the applicable sections of the Los Angeles City Fire Code, including Division 8, “Hazardous Materials Disclosures.” LAFD issues a Business Identification number to businesses that handle hazardous materials. Those who store hazardous waste or hazardous materials must submit a Certificate of Disclosure to the LAFD. The California Health and Safety Code (HSC 25500 et seq.) requires that all California facilities that store hazardous materials in quantities that, cumulatively for a site, exceed 55 gallons of a liquid or 500 pounds of a solid or 200 cubic feet of a gas at standard temperature and pressure or, for radioactive materials, the quantity for which an emergency response plan is required under federal or state regulations, are subject to hazardous material inventory and reporting regulations. In addition, a Process Safety Management/Risk Management Program (PSM/RMP) is required by the Los Angeles Fire Department (Appendix E includes the PSM/RMP for the SMWTP). This document is prepared to satisfy several regulations and is governed by the following agencies:

• Cal-OSHA California Code of Regulations, Title 8, '5189, Process Safety Management (PSM) of Highly Hazardous Materials.

• Federal EPA Code of Federal Regulations, Title 40, Part 68, Accidental Release Prevention Requirements: Risk Management Programs (RMP) Clean Air Act Section 112(r), Program 3 requirements.

• California Office of Emergency Services, California Code of Regulations, Title 19, Division 2, Chapter 4.5, California Accidental Release Prevention (CalARP) Program.

• California Health and Safety Code, Section 25531 through 25534. The purpose of the PSM/RMP document is to:

• Increase the protection of public health, the environment, and facility employees by ensuring proper emergency response and mitigation procedures when handling regulated substances.

• Assist local government agencies in their communication and coordination efforts to improve facility safety while handling chemicals and hazardous materials.

The City of Santa Monica identifies the following materials as hazardous (City of Santa Monica, Safety Element, 1995):

• Substances on the list prepared by the Director of Industrial Relations pursuant of Labor Code Section 6382.

• Hazardous substances defined in the Health and Safety Codes, Sections 25316 and 25532.



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• Any substance which is classified by the National Fire Protection Association as a flammable liquid, a Class II combustible liquid, or a Class III-A combustible liquid.

• Any substance on the master list of hazardous substances prepared in accordance with Health and Safety Code 25281.

• Any substance required to be disclosed under Chapter 3 of Article V of the City Code relating to Toxic Chemical Disclosure.

Federal and state regulations require businesses storing, using, or manufacturing specific amount of hazardous materials to report the quantities and types of materials to its local administering agency. In Santa Monica, the City’s Fire Department acts as the administering agency. Municipal Code Section 5.24.010 requires all businesses to declare to the City if they use, store, or manufacture any quantity of a hazardous or extremely hazardous material. An annual business plan must be submitted the same as described under LAFD requirements discussed above. In addition to inventorying the materials in question, the business plan must describe emergency response plans and procedures to be used in the event of an accident. As a potable water provider, the City adheres to standards of the American Water Works Association (AWWA) for water treatment including the storage, delivery and handling of water treatment chemicals, including hypochlorites. The AWWA Standards describe minimum requirements for water supply materials/equipment and ensure that a product designed to such standards will be safe. AWWA Standards are vital guidelines for all facets of drinking water projects. They provide the minimum requirements for design, installation, performance, and manufacturing of products used in the water industry, including pipe, chemicals, storage facilities, valves, and other appurtenances. These standards provide industry-approved technical guidance for 24 categories of products and processes in municipal water supply. AWWA regularly issues new Standards and annually revises 20 to 25 Standards, with all standards revised approximately every 5 years. The purpose of the standards is to ensure safe reliable water treatment systems. AWWA standards key points are listed below:

• Best practices. AWWA Standards provide industry-recognized best practices for water utility management and operations. Each Standard undergoes a formal, scheduled review to update it with current utility best practices.

• Quality assurance. AWWA Standards have been developed for every major type of chemical, pipe, and appurtenance used in municipal water service.

• Industry consensus. AWWA Standards represent a consensus of the water supply industry. Each AWWA Standard is developed by water professionals and subjected to a rigorous, formal approval process.

• Most used. The largest, best-managed, North American water and wastewater utilities as well as manufacturers of fine pipe, equipment, and chemicals use AWWA Standards exclusively to ensure quality and performance. Thousands of utilities of all sizes in North America and in dozens of countries have adopted AWWA Standards.

• ANSI approved. AWWA is an American National Standards Institute (ANSI)-approved standards developing organization for the water industry. Accreditation by ANSI



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signifies that the procedures used by AWWA in connection with the development of American National Standards meet the Institute’s essential requirements for openness, balance, consensus, and due process. Before an AWWA Standard is issued, it must be approved by ANSI. ANSI accreditation provides additional assurance of excellence of each and every AWWA Standard.

The State of California Department of Public Health (DPH) refers to these standards when developing specific guidelines for drinking water compliance. DPH approval will be required for the projects permit to operate.

b. Project Hazards. The City’s goal is to restore the groundwater resource of the Charnock sub-basin to its full beneficial use in the most expeditious and technically effective manner possible. The groundwater has been contaminated with gasoline additives methyl tertiary-butyl ether (MTBE) and tertiary-butyl alcohol (TBA) from gasoline stations in the vicinity of the site. MTBE and TBA have similar characteristics in that they both:

• Spread further and more rapidly than other constituents of gasoline. • Are persistent in the environment. • Can cause water to become offensive in taste and odor at extremely low levels. • May cause adverse health effects. • Are difficult and expensive to remove from drinking water.

In addition, to MTBE and TBA, the Charnock groundwater basin historically has been impacted by trichloroethene (TCE) and 1,1-dichloroethene (1,1-DCE). TCE is a persistent VOC contaminant that infiltrates soil and ground water from improper disposal of dry cleaning agents, degreasing solvents, and paint strippers. 1,1-DCE is used as a solvent and as a gasoline additive. These previously known Charnock groundwater contaminates will also be addressed as part of the water treatment process and will be included as part of the DPH approval process. To remediate the existing groundwater contamination and restore well production, the routine use, disposal and transport of chemicals will be required. Hazards and risk of upset at the Charnock facility and the salt water well location could be associated with chemicals utilized in the treatment of potable water such as sodium hypochlorite. Hazards and risk of upset at the SMWTP facility could be associated with chemicals utilized in the treatment of potable water such as sodium hypochlorite, sodium fluoride, anti-scalants, aqueous ammonia and hydrochloric acid. In addition, remediation of the existing Charnock groundwater contamination will require disposal of sludge waters and carbon that will contain small amounts of MTBE, TBA, TCE and 1,1-DCE. The following is a discussion of the materials and the hazards associated with them. Sodium Hypochlorite. Sodium hypochlorite is an oxidizer that is commonly used for water treatment and has proven to be a safe, effective and reliable water disinfectant. It will be used at the facilities as a 12.5% solution in water (basically an industrial form of household bleach, which is normally at about a 5% solution). OSHA defines this concentration as an irritant by definition of Hazard Communication Standard (29 CFR 1910.1200). It is not flammable nor explosive, and on heating to water’s boiling point, decomposes. It has a relatively high pH (11.2 – 11.4) and is caustic, potentially causing chemical burns if splashed



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onto broken skin. Otherwise it is a mild skin irritant, but can cause eye damage if splashed into eyes. Vapor in an enclosed space may cause irritation to the upper respiratory tract. It does not pose a substantial inhalation hazard and is not listed in the NIOSH Pocket Guide to Chemical Hazards (NIOSH, September 2007), but it does have a bleach odor. According to the National Fire Protection Association (NFPA), solutions containing less than 40% are classified as a moderate oxidizing hazard (NFPA 430, 2000). Because it is an oxidizing agent, it reacts violently with amines, ammonia and its compounds, and acids and is required to be kept separate from such chemicals. Sodium Fluoride. Sodium fluoride is currently added to the majority of municipal water systems in the U.S. to prevent cavities in children. Sodium fluoride is a dry additive and is the ionic form of fluorine. Primary risk is caused by airborne dust that can be then inhaled or ingested. While particulate fluorides are not likely to cause acute health problems among workers unless large quantities are ingested, flouride poisoning can occur if large amounts are inhaled or swallowed, with a human acute lethal dose of 5 grams of sodium fluoride reported. An Immediately Dangerous to Life or Health (IDLH) particulate air concentration of 250 mg of Fluoride/m3 has been established by NIOSH (September 2007). Sodium Bisulfite. This material is used to remove free chlorine from the system at both the Charnock facility and SMWTP after iron and magnesium removal through the greensand vessel. It is typically used in all commercial wines to prevent oxidation and in fruit canning to prevent browning and kill microbes. No IDLH has been determined for this material per the NIOSH Pocket Guide to Chemical Hazards (NIOSH, September 2007) and it is not considered toxic. It would be used at the sites in an aqueous form, and splashed material on the skin can cause irritation. Vapor is irritating to the eyes and respiratory system. It is not flammable. Anti-scalants. This is a mixed group of chemicals used to minimize fouling and reduce the frequency of membrane cleaning within water treatment systems. While the exact specification of anti-scalant has not been chosen, the information for provided below is supplied by Itasca Systems, Inc. for its Antiscalant 98 product. The anti-scalant ingredients are not considered hazardous as defined by the OSHA Hazard Communication Standard (29 CFR 1910.1200). This product contains potassium salts of acrylate polymers and phosphonate. The product is a clear amber liquid and it is considered a mild base. Potential routes of entry are inhalation, skin contact, and eye contact. Since it is a mild base, it may cause irritation or burns to skin, eyes, mucous membranes and respiratory tract. This material is not flammable. Aqueous Ammonia. Aqueous ammonia is a disinfectant anticipated to be used at the SMWTP at a 24%solution. It is found in household ammonia products at a concentration range of from 5 to 10% by weight. Aqueous ammonia is a clear colorless liquid, is very alkaline and reacts corrosively with all body tissues, causing irritation or burns to skin, eyes, mucous membranes and respiratory tract. This product is defined hazardous by OSHA’s Hazard Communication Standard (29 CFR 1910.1200). The routes of entry are inhalation, skin contact, eye contact and ingestion. Its NIOSH IDLH as a gas is 300 parts per million (ppm) or 210 mg/m3. While not flammable, in the event of fire it should be treated as such.

Hydrochloric Acid. Hydrochloric acid is used to control the pH of process water and will be used if reverse osmosis or nanofiltration is employed at the SMWTP. As a 33-40% solution, it is a strong acid (pH~2) that is highly corrosive, with more dilute solutions less corrosive.



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Contact with the eyes or skin can cause serious permanent damage. Concentrated solutions can release dangerous quantities of hydrogen chloride vapor. Its NIOSH IDLH as a gas is 50 parts per million (ppm) or 74.5 mg/m3. It is not flammable.

Granulated Activated Carbon (GAC). This is carbon that has been processed to make it extremely porous and thus has a very large surface area available for chemical reactions. It is the same type of material used for aquarium filters. In its granulated form, GAC makes only minor amounts of dust which is not toxic and it is not considered a hazardous material; however, it can burn. The purpose of the GAC is to absorb pollutants, and once it has served this purpose, it is treated as a hazardous waste because of the absorbed pollutants. The GAC is transported to a regeneration facility where the pollutants (in this case MBTA and TBA) are removed and the GAC then reused.

Gasoline additives – MTBE and TBA. The proposed project concerns the removal of gasoline additives from drinking water and these compounds will be transported from the site bound to the GAC and also in small amounts in sludge water removed from the site. Methyl tertiary-butyl ether was used as a fuel additive to increase the amount of oxygen in gasoline to make it cleaner burning and reduce air pollution, particularly the formation of carbon monoxide and NOx. At room temperature, MTBE is a volatile, flammable and colorless liquid that dissolves relatively easily in water, where it leaves an unpleasant taste and odor that is readily detected by humans. The USEPA Integrated Risk Information System (IRIS) reports a non-carcinogenic chronic inhalation hazard of 3 mg/m3 (ie: if breathed continuously at this concentration over a long period of time, it can cause liver and kidney damage). The California Office of Environmental Health Hazard Assessment (OEHHA) Toxicity Criteria Database reports MTBE as an oral and inhalation carcinogen. Tertiary-butyl alcohol (TBA; also tert-butanol) is an octane booster in gasoline, used as an anti-knock additive, and is also used as a solvent in paint removers and an intermediate for the synthesis of other chemicals such as flavors and perfumes. It is a combustible solid or liquid (above 77ºF) and its vapor has an IDLH of 1,600 ppm or 4,848 mg/m3 per NIOSH. It is not contained in either the IRIS or OEHHA databases.

TCE and 1,1-DCE. The proposed project would also include the removal of Trichloroethene (TCE) and 1,1-Dichloroethene (1,1-DCE) from the groundwater. Because these are organic compounds, they will also be removed from the groundwater during the GAC treatment process and removed from the site in the used GAC and also in small amounts in sludge water removed from the site. TCE is a persistent VOC contaminant that infiltrates soil and ground water from improper disposal of dry cleaning agents, degreasing solvents, and paint strippers. It’s a pale blue nonflammable liquid with a sweet smell that evaporates easily. TCE is a chlorinated aliphatic hydrocarbon, suspected of being carcinogenic and mutagenic (EPA 1997). TCE is labeled as a dense non-aqueous phase liquid (DNAPL) meaning it sinks into the soil subsurface by displacing water from soil pores and eventually sinking into the groundwater while leaving behind residual pockets that can contribute to long term contamination. The OEHHA Toxicity Criteria Database reports TCE as an agent that is probably carcinogenic to humans. OEHHA reports a chronic Reference Exposure Level (REL) of 600 µg/m3 (ie: if exposed at this concentration over a long period of time, it can cause nervous system damage).



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1,1-DCE is used as a solvent and as a gasoline additive. It is a highly flammable, colorless liquid with a sharp, harsh odor. The USEPA IRIS database reports 1,1-DCE as a likely human carcinogenic that can cause liver and kidney damage. The OEHHA data base does not list 1,1-DCE as a carcinogen, however it does list the California Public Health Goal (PHG) at 0.01 (mg/L). Table 4.4-1 lists the US Department of Transportation classification per the Table of Hazardous Materials (Code of Federal Regulations, Title 49, Part 172, Subpart B).

Table 4.4-1 Hazardous Materials Used at Project Sites a

Material Hazard Type Reportable Quantity as Waste, lbs

Sodium hypochlorite corrosive 100 Sodium fluoride poison 1,000

Sodium bisulfite corrosive (aqueous forms) 5,000

Ammonia (10 – 35% solution) corrosive 100 Hydrochloric acid corrosive 5,000 Activated carbon flammable solid Not applicable MTBE flammable liquid 1,000 TBA flammable liquid 5,000 TCE poison 100 1, 1-DCE flammable liquid 1,000

a Per US DOT classification ( 49 CFR 172, Subpart B) c. Sensitive Receptors. The following land uses are generally considered to be sensitive receptors with respect to potential hazardous releases (particularly air-borne releases): long-term health care facilities; rehabilitation centers; convalescent centers; retirement homes; residences; schools; playgrounds; child care centers; and athletic facilities. For the purpose of this evaluation, sensitive receptors with respect to hazardous materials exposure would include existing residential uses located adjacent to the project sites and Windward School located adjacent to the Charnock facility. Material delivery and waste trucks would access the Charnock site from Westminster Avenue, with primary access to this site from the freeway system via Sawtelle and Sepulveda Boulevards. The nearest intersection to the I-405 freeway is located just south of Venice Boulevard, about 0.5 mile south of the site. Primarily residential uses are located along Sawtelle Boulevard, while Sepulveda Boulevard has a greater mix of residential and commercial uses. Material delivery trucks would access the SMWTP site via Wilshire Boulevard, which has a major intersection with the I-405 freeway approximately 1 mile east of this site. Wilshire Boulevard along this route is primarily in commercial and office use. Material deliveries to the salt water wells would be limited to occasional hypochlorite solution added to a 500 gallon tank. Access to this site is via the Santa Monica freeway (I-10) to Lincoln Boulevard or 4th Street, then west via Pico Boulevard to Ocean Avenue and the site. Santa Monica Government Center and Santa Monica High School are adjacent to 4th Street and Pico Boulevard, with commercial/office uses primarily along the remainder of this access route.



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4.4.2 Impact Analysis.

a. Methodology and Significance Thresholds. The methodology used in this assessment includes a review of the materials to be used within the water treatment process and the pollutants to be removed from the drinking water. Significant human health and safety impacts would occur if the project implementation would expose employees and nearby sensitive uses to concentrations of hazardous materials exceeding regulatory levels. This would include if the project created a significant hazard through the routine transport, use or disposal of hazardous materials. In addition, if a project would emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school it may cause a significant impact if such use would expose students to either acute or chronic hazards.

For hazardous materials, significance criteria is dependent on the physical hazard associated with the material (such as toxicity), the amount of material present, proximity of the material to the populace, regulatory requirements regarding storage, use and transport, potential for spill or release, and the proximity of the material to receiving waters or other significant environmental resource. The significance of impacts from a spill is characterized by the magnitude of the event, the frequency of the occurrence, and the hazard associated with the spilled material. Minor spills if they occur frequently would be considered significant if they cause a chronic inhalation hazard to sensitive land uses or are polluting important biological resources, whereas a severe or disastrous event would be considered significant even if it rarely occurs (for example, once during the operational lifetime) and has dire consequences (loss of life). The characterization of the event magnitude is also related to the physical hazard associated with the material. For a gas, a significant hazard would be present if in the event of a spill or other release, the IDLH would be exceeded at the nearest sensitive use. For a chemical that could cause either a carcinogenic or chronic hazard, the following thresholds are applicable:

• Probability of contracting cancer for the Maximally Exposed Individual (MEI) exceeds 10 in one million.

• Ground-level concentrations of non-carcinogenic contaminants would result in a Hazard Index greater than 1 for the MEI.

The cancer significance threshold is based on an analysis of the number of excess cancers relative to a chosen risk level. Excess cancer risks are defined as those occurring in excess of or above and beyond those risks that would normally be associated with a location or activity if toxic pollutants were not present. The USEPA considers for risk management those pollutants that could cause carcinogenic risks between one in 10,000 (1.0 x 10-4 or 1.0E-04) and one in one million (1.0 x 10-6 or 1.0E-06). Passage of Proposition 65 (encoded in California Health and Safety Code Section 25249.6) in 1986 prohibits a person in the course of doing business from knowingly and intentionally exposing any individual to a chemical that has been listed as known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning. For a chemical that is listed as a carcinogen, the “no significant risk” level under Proposition 65 is defined as the level which is calculated to result in not more than one excess case of cancer in 100,000 individuals (1 x 10-5) exposed over a 70-year lifetime, which is also the risk level as indicated above. To provide a perspective on this risk level, the American Cancer Society (2007) reports that in the U.S., men have a one in two chance (0.5 probability)



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and women about one in three chance (0.3) probability of developing cancer during a lifetime, with one in four deaths (0.23) in the U.S. attributed to cancer. Given this background carcinogenic risk level in the general population, application of a 10-5 excess risk limit means that the contribution from a contaminant should not cause the resultant risk for the exposed population to exceed 0.5001 for men and 0.33001 for women.


Impact HHS-1 The proposed project will utilize activated carbon and chemicals for groundwater treatment. The storage and use of these materials has the potential to result in health risks to workers and to affect the public. This is a Class II, significant but mitigable impact.

Groundwater at the Charnock facility has been contaminated with gasoline additives methyl tertiary-butyl ether (MTBE) and tertiary-butyl alcohol (TBA) from gasoline stations in the vicinity of the site. In addition, Trichloroethene (TCE) and 1,1-Dichloroethene (1,1-DCE) have been previously detected in the Charnock groundwater basin. The project’s main objective is to treat the MTBE, TBA, TCE and 1,1-DCE contaminated groundwater and make it available for domestic use. The California Department of Public Health (DPH) prohibits public water suppliers from delivering water to their customers if the water contains chemicals at concentrations greater than their respective Maximum Contaminant Levels (MCLs). In 1999, the DPH promulgated a secondary MCL for MTBE of 5 µg/L (parts per billion). This standard was based on taste and odor threshold concentrations. In April 2000, the DPH promulgated a primary MCL for MTBE of 13 µg/L. The TCE MCL is 5 µg/L and 1,1-DCE is 6 µg/L. Overall, the maximum MTBE, TBA, TCE and 1,1-DCE concentrations in any single well at Charnock are predicted to be:

MTBE: 61 µg/L (Well 15) TBA: 9 µg/L (Well 15) TCE: 35 µg/L (Well 16) 1,1-DCE: 12 µg/L (Well 16)

The DPH operating permit will likely specify that the well head treatment system will have to operate until the combined influent concentrations from the treated wells have been less than 2.5 µg/L for MTBE (1/2 of the secondary MCL for MTBE), 2.5 µg/L for TCE (1/2 of the secondary MCL for TCE), 3.0 µg/L for 1,1-DCE (1/2 of the secondary MCL for 1,1-DCE) and less than 6 µg/L for TBA (1/2 of the NL) for one year. After this period of operation, the Charnock treatment facility will likely be taken off-line, by-passed, and placed in stand-by mode. Therefore, the following threshold concentrations have been selected to predict the duration of operation of the treatment system:

MTBE: 5 µg/L (secondary MCL – applies to individual wells) 2.5 µg/L (1/2 of the secondary MCL – applies to combined influent) TBA: 6 µg/L (1/2 of the Notification Level [NL]) TCE: MCL (5 ppb) at individual wells and ½ MCL at combined Influent 1,1-DCE: MCL (6 ppb) at individual wells and ½ MCL at combined Influent



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These contamination levels are for drinking water standards. Note that these levels are not of a high enough concentration to be classified as hazardous. The weight of evidence suggests the carcinogenic potential of MTBE for humans is very low. Human health risks associated with MTBE additionally are deemed even lower based on its offensive odor at very low concentrations. USEPA has classified MTBE as an animal carcinogen, but not as a human carcinogen. CalEPA classifies MTBE as a carcinogen, but has not included it as part of Proposition 65 list of chemicals. TCE has been identified as an agent that is probably carcinogenic to humans. Proposition 65 developed safe harbor levels for carcinogens. The TCE No Significant Risk Level (NSRL) for oral exposure is 50 µg/day and 80 µg/day for inhalation. 1,1-DCE is not listed in the Proposition 65 list of chemicals. A summary of the project’s chemical and treatment material use by site follows. Charnock Well Field GAC Treatment. The GAC treatment system is expected to use coconut shell based, acid-washed granular activated carbon. The carbon will be required to conform to ANSI/AWWA B604-96. This standard covers gravel, high-density gravel, silica sand, high-density media, anthracite filter materials, and the placement of the materials in filters for water supply service application. This treatment process will create saturated carbon that will require periodic carbon change outs. Carbon change outs are expected to occur 6-12 times a year during the main contaminant removal stages of the project (an approximate three year period; see Table 2-1 in the Project Description), with reduced change outs in the later stages. The treatment process requires the use of (clean) water to backwash and flush the spent carbon from the vessels. Backwash water will be collected and stored in two 30,000-gallon backwash storage tanks. Backwash water will be disposed of through storm drain discharges (which will require an NPDES permit) or off-site. Once the backwash water has been drained from the backwash storage tanks, the settleable solids (i.e. sludge – fine particles of carbon and carbon bound contaminants), which accumulate in the bottom of the tanks, will be disposed of off-site. This will occur on an as needed basis but not more than twice per month. Carbon change outs will involve one truck per vessel. Each truck has two compartments, one that holds virgin (new) carbon and the other which is empty. The vessel is pressurized using an air compressor (typically located on the truck), and then the pressurized air forces the water/carbon slurry into the truck. Once all old material is removed from the vessel, the new carbon is similarly transferred as a water slurry into the vessel. Some air venting (or air displacement) is required for this process; however, no contaminants are expected to volatize into the air nor are any objectionable odors expected from this process because the contaminants stay bound to the carbon. The change out process will occur within the carbon vessel secondary containment area so that any spillage from lines can be contained and cleaned up. After the new carbon is added to the vessel, the old carbon is dewatered to the backwash storage tanks. Each carbon truck will be required to present a copy of a safety checklist that will document visual inspections and adherence to all required DOT, local and state safety requirements. Prior to transportation off-site, the spent carbon will be tested using the Toxicity Characteristic



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Leaching Procedure (TCLP). The TCLP is designed to determine the mobility of both organic and inorganic analytes present in liquid, solid, and multiphasic wastes. This is usually used to determine if a waste may meet the definition of a hazardous waste code under RCRA (40 CFR Part 261) of D004 through D052. The Code of Federal Regulations (CFR) 40 CFR §261.24, outlines the 40 contaminants the TCLP analysis tests for. The regulatory level for TCE (EPA HW# D039) is listed at 0.5 mg/L and 1,1-DCE (EPA HW# D029) is listed at 0.7 mg/L. MTBE and TBA are not listed under these guidelines. These tests will be performed when the carbon is spent and needs to be replaced. If the tests for TCE and 1,1-DCE are above the regulatory levels, they will need to be transported under a hazardous material manifest. If they are below the regulatory levels, the spent carbon is eligible to be reactivated at a facility that can accept non-hazardous carbons. Reactivation of the spent carbon results in the complete destruction of the contaminates and relieves the generator of liabilities for this carbon once a certificate of destruction has been issued. Because the MBTE, TBA, TCE and 1,1-DCE would be bound to the GAC, exposure to these compounds would only occur during minor spills within the secondary containment areas during the course of change outs. In the event of such spills, no volatilization of the chemicals would be expected to occur given the affinity of the organic materials to the carbon, and no exposure to offsite school employees or students or the residential neighborhood would occur. MBTE, TBE, TCE, 1,1-DCE and activated carbon are considered potentially hazardous because of their flammability, but because all material will be handled as a wet slurry, no potential for burning is present. In the event of a GAC spill, employees would be exposed to the material, but are unlikely to inhale or ingest materials, and none of these materials pose a dermal adsorption hazard. As employees would not be exposed to air concentrations that exceed either an IDLH or a chronic inhalation hazard amount, the handling of the new and spent GAC does not present a significant risk.

Backwash Water. This treatment process involves the use of clean water to backwash and flush the carbon. Backwash water will be collected and stored in the two 30,000-gallon backwash storage tanks. Backwash of GAC will be with treated water, and can be recycled to the head of the plant. As described above, the backwash water will need to be sampled and analyzed prior to discharge. State and local regulatory guidelines, including possible NPDES permitting, will be followed prior to discharge.

Sludge. Once the backwash water has been drained from the backwash storage tanks, the settleable solids (i.e. sludge – mostly fine particles of carbon with bound contaminants), which accumulate in the bottom of the tanks will be sampled and disposed off-site. This will occur on an as needed basis but is not anticipated to be more than once per month. Sludge will be pumped into disposal trucks and hauled to an approved disposal facility. Since the sludge will be transported off-site, it will follow the same TCLP procedures described above. If the tests for TCE and 1,1-DCE are above the regulatory levels, they will need to be transported under a hazardous material manifest. Once the sludge waste has been classified it will be transported to the appropriate type of State-licensed treatment and disposal facility.

Water that collects in the facility sumps will be transferred to a 10,000-gallon on-site sump storage tank. The sump storage tank will have a secondary containment area capable of containing 150% of the storage tank volume. The source of this water will typically be from one of the following occurrences: 1) precipitation that lands directly on the concrete slab of the GAC



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facility and collects in the sumps, or 2) process water which is transferred into the sump. This water will be sampled and disposed off-site. Disposal is estimated to occur once a month involving two truckloads. Off-site disposal would be transported to a State-licensed treatment and disposal facility. For the sludge, and if required, the backwash water, each process will require the use of a vacuum truck. Vacuum truck personnel shall be trained in the safe operation of the vacuum equipment, be familiar with the hazards of the different products being handled and be aware of the permit of the owner/operator to comply with federal, state and local regulations. Each truck operator will be required to present a copy of a safety checklist that will document visual inspections and adherence to all required DOT, local and state safety requirements.

Sodium Hypochlorite. The Charnock treatment system formally used chlorine gas for disinfection, however it will switch to sodium hypochlorite. Sodium hypochlorite will be used for both down well disinfection and for treatment of the groundwater once it has been pumped to the treatment area. This product is generally considered safer to use and store than chlorine gas while retaining the same disinfection qualities. The sodium hypochlorite system will consist of a 6,000-gallon storage tank, chemical metering pumps, and a leak detection system and alarm system enclosed within the new 5’ x 30’ hypochlorite storage and feed building, re-located on the eastern section of the system layout, approximately 150 feet southeast of its current location (Section 2.0, Project Description, Figure 2-7). The storage and handling will be equipped with a tank level monitor, temperature and pressure monitors and alarms, and excess flow and emergency block valves. Floor areas of the building will be epoxy-coated to protect the concrete from chemical spills and to prevent chemicals from seeping through the floor and into the underlying ground. A concrete containment area with a sump will be provided to contain chemical spills. A high level alarm will be installed on the tanks to notify the facility control system when the liquid has reached a predetermined level. If there is an inadvertent release from the storage tank, the liquid will be contained within the secondary containment structure. Specific safety measures will be employed for the use, handling and off-loading of the sodium hypochlorite. These measures will include operator training, securing/locking devices on tank loading lines, checklists that the operator must complete before each delivery is accepted, an emergency internal valve switch located on the liquid bulk trailer and the color coding and labeling of process lines and fittings. The City will use AWWA standards with respect to the use and handling of hypochlorite, specifically: ANSI1/AWWA B300-Standard for Hypochlorites, ANSI/AWWA B301-Standard for Liquid Chlorine and Simplified Procedures for Water Examination (AWWA Manual M12. AWWA, Denver (1978)). Sodium hypochlorite will be utilized at each well head for down well treatment. The existing chlorine lines which will deliver sodium hypochlorite to each of the wells for downhole chlorination are currently buried and pass under school playfields and parking areas. Since the Charnock facility has been shut down for an extended period, these lines may need to be replaced and/or rerouted. This determination will be made during the construction phase of the project. The chlorine transmission lines are currently buried at a depth of approximately 3 feet below ground surface. If any replacement or repairs are necessary for these lines, they will be maintained at or below these depths and be double lined. American Water Works



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Association (AWWA) standards will be applied to material and equipment specifics such as size, materials and dimensions. Deliveries of sodium hypochlorite are expected to occur once per month from two 3,000 gallon trucks. Specific safety measures will be employed during the handling and off-loading of the sodium hypochlorite. These measures include operator training, securing/locking devices on tank loading lines, checklists that the operator must complete before each delivery is accepted, an emergency internal valve switch located on the liquid bulk trailer and the color coding and labeling of process lines and fittings. This information will be summarized in the Risk Management Plan that is required to be completed and filed with the Los Angeles City Fire Department prior to the operation of the plant. Trucks will be unloaded in a tank truck unloading area paved with concrete and surrounded by a containment berm. All sodium hypochlorite delivery trucks will follow federal, state, and local permitting transportation requirements. Potential sources of sodium hypochlorite exposure would be through spills within the storage and feed building, spills during delivery (hose breakage, valve not closed properly), breakage of the chlorine transmission lines, or in the event of an accident involving the delivery vehicle. In the event of a spill within the building or during delivery, sodium hypochlorite would be fully contained within the containment areas and exposure would occur only to the workers present, with no offsite exposure to the general public or students at the school. Since the material used would not form a vapor, these spills would not cause an offsite inhalation hazard. Because this is a corrosive, employees would be exposed to a dermal (skin) irritant that could cause burns, and proper protective clothing would be required to be worn during the cleanup of the spill. In addition, in the event of dermal exposure, immediate relief can be acquired by diluting with substantial quantities of water. Breakage of the buried chlorine lines would not expose people on the surface to this corrosive material. Therefore, no significant effect is associated with the use of sodium hypochlorite at the site. The risk of hazards due to use of this common water treatment chemical is reduced to below a level of significance or effectively eliminated due to adherence to the AWWA Standards and because hypochlorite poses little risk in itself. Santa Monica Water Treatment Plant Following remediation at the Charnock site, clean water would be delivered via existing infrastructure (pipeline system) to the Santa Monica Water Treatment Plant for final treatment. The City also receives water from MWD (at the SMWTP), which has treatment method requirements the City must adhere to. With the Charnock field groundwater restoration project and changes to the Metropolitan Water Districts (MWD) water treatment methods, the existing SMWTP softening and disinfection facilities are proposed to be upgraded and brought back online as part of this project. Changes to the SMWTP are further described in Section 2.4.3 of this EIR. Operation of the SMWTP facility currently involves the regular handling, use, and disposal of both chemicals and wastes during the course of normal operations. Operational oversight is addressed through the established and defined federal, state, and local regulatory structure



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outlined previously. Specifically, the SMWTP has an active Risk Management Plan (RMP) on file with the Los Angeles City Fire Department (LAFD) (Appendix D). Any changes to operation at this facility will require a notification to the LAFD and an updating of its RMP. It is expected that this facility, which includes required permits, notices of intent to operate, discharge requirements, and LAFD notification, would adequately reduce the potential for hazard exposure to workers, nearby residents, the general public, and the environment to a less-than-significant level. Nonetheless, the following further discusses those new chemicals proposed for use at the SMWTP and assesses the risk associated with these chemicals. It is noted that the SMWTP already treats groundwater for the contaminants TCE and 1,1-DCE.

Sodium Hypochlorite. The City is currently permitted to use a one ton tank/bottle of chlorine gas at the SMWTP for the purpose of bacterial disinfection of the drinking water. In the event that the City chooses to convert to sodium hypochlorite, risks associated with this chemical would be similar to that described above for the Charnock facility. As previously stated, sodium hypochlorite is a safer chemical to use than chlorine gas, which in the event of an accidental release, could expose employees and the offsite public to a toxic gas. No significant risk is anticipated from use of sodium hypochlorite when AWWA standards are used.

Sodium Fluoride. The SMWTP currently has a building that houses fluoride that is used for Santa Monica groundwater Well #1. This building is also utilized for equipment storage. Currently the fluoride is contained in 20 pound bags and mixed into a solution storage tank. Once the fluoride has been properly mixed, the storage tank is removed and trucked to Well No. 1 for injection. The new sodium fluoride system would also be placed within this building and would include a 9.5 ton sodium fluoride storage area, saturators, solution storage tanks, chemical metering pumps, and a leak detection system and alarm system. The metering pumps in this building will inject sodium fluoride solution at the MWD interconnection and at the SMWTP reservoir. The storage and handling will be equipped with a tank level monitor, temperature and pressure monitors and alarms, and excess flow and emergency block valves. Secondary containment will be provided. If there is an inadvertent release from the storage tank, the liquid will be contained within the secondary containment structure. It is noted that sodium fluoride is not a new chemical to the SMWTP site, but it would be stored at the site in greater quantities. It will be stored in a self contained building that will adhere to standards of the AWWA, which provides guidance on the storage, delivery and handling of water treatment chemicals. Specific safety measures will be incorporated for the use, handling and off-loading of the sodium flouride. In addition, the facility’s current Risk Management Program would be updated to identify and describe actions to be taken by the facility and public emergency response personnel in case of an accidental spill or traffic accident involving the release of sodium fluoride to the environment. Sodium fluoride is classified as a poison, with the greatest risk associated with spillage of bulk material that causes a particulate cloud. If approximately 1 ounce of fluoride were to become suspended in the air in an enclosed space (400 square feet), it would be at the IDLH criteria of 250 mg/m3. This potential hazard to employees associated with bulk fluoride storage at the SMWTP is considered a potentially significant impact. Such a cloud would likely be contained within the storage building, and if exposed to outside air would rapidly be diluted.



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A system of local and/or general exhaust is recommended by the AWWA to keep employee exposures below the Airborne Exposure Limits. Local exhaust ventilation is generally preferred because it can control the emissions of the contaminant at its source, preventing dispersion of it into the general work area. The City will follow AWWA standards to develop specific design safety features. The AWWA standards for fluoride additives are ANSI/AWWA B701-99 (sodium fluoride), ANSI/AWWA B702-99 (sodium fluorosilicate) and ANSI/AWWA B703-00 (FSA). AWWA’s standards are prepared by its Fluoride Standards Committee and are reviewed and updated at least every 5 years. AWWA standards stipulate product quality testing requirements and verification.

Anti-scalants. Anti-scalants may be used at the SMWTP for reverse osmosis or nanofiltration treatment. It is highly effective for wide varieties of different waters and will minimize fouling and reduce the frequency of membrane cleaning. The anti-scalant system will consist of a 1,000-gallon storage tank and be equipped with a tank level monitor, temperature and pressure monitors and alarms, and excess flow and emergency block valves. Secondary containment will be provided. If there is an inadvertent release from the storage tank, the liquid will be contained within the secondary containment structure.

Specific safety measures will be incorporated for the use, handling and off-loading of the anti-scalants. These measures will include operator training, securing/locking devices on tank loading lines, checklists that the operator must complete before each delivery is accepted, an emergency internal valve switch located on the liquid bulk trailer and the color coding and labeling of process lines and fittings. The City will follow AWWA standards to develop specific design safety features. Because anti-scalants pose only a small hazard in terms of irritated skin upon dermal exposure, the use of such chemicals is not considered significant.

Hydrochloric acid. The hydrochloric system will consist of a 1,000-gallon storage tank and be equipped with a tank level monitor, temperature and pressure monitors and alarms, and excess flow and emergency block valves. Secondary containment will be provided. If there is an inadvertent release from the storage tank, the liquid will be contained within the secondary containment structure. One 1,000 gallon sodium hypochlorite delivery is expected to occur monthly. Hydrochloric acid is corrosive, and can cause chemical burns on dermal exposure during use or an accident. Specific safety measures will be incorporated for the use, handling and off-loading of the hydrochloric acid. These measures will include operator training, securing/locking devices on tank loading lines, checklists that the operator must complete before each delivery is accepted, an emergency internal valve switch located on the liquid bulk trailer and the color coding and labeling of process lines and fittings. The City will follow AWWA standards to develop specific design safety features.

Aqueous Ammonia. The aqueous ammonia system will consist of a 2,000-gallon storage tank, chemical metering pumps, and a leak detection system and alarm system. The storage and handling will be equipped with a tank level monitor, temperature and pressure monitors and alarms, and excess flow and emergency block valves. Secondary containment will be provided. If there is an inadvertent release from the storage tank, the liquid will be contained within the secondary containment structure. Aqueous ammonia needs to be stored below 25º C (77º F),



4.4-16

kept in a tightly closed container, stored in a cool, dry, ventilated area, protect against physical damage and isolate from incompatible substances. One 2,000 gallon delivery of aqueous ammonia is expected to occur monthly to the SMWTP. Specific safety measures will be incorporated for the use, handling and off-loading of the aqueous ammonia. These measures will include operator training, securing/locking devices on tank loading lines, checklists that the operator must complete before each delivery is accepted, an emergency internal valve switch located on the liquid bulk trailer and the color coding and labeling of process lines and fittings. The City will follow water industry standards for aqueous ammonia, specifically ANSI/Compressed Gas Association (AGA)-2.1. Salt Water Wells Two salt water wells are currently in place in addition to a building that supports the pumping and water treatment prior to piping to the SMWTP. Chlorine was previously used for bacterial treatment prior to the salt water being pumped to the SMWTP. If the system is brought back on-line, sodium hypochlorite will be utilized and stored in a 500 gallon tank. As discussed above with respect to the Charnock facility, exposure to sodium hypochlorite could occur in the event of a spill and site employees and delivery personnel would be subject to potential dermal irritation when the spill is cleaned up. The volume of any such spill would be small, on the order of less than 10 gallons, and could be readily diluted with the water present at the well site. In addition, the salt water well location will develop a Business Plan, as required by the Santa Monica Fire Department, that would identify and describe actions to be taken by the facility and public emergency response personnel in case of an accidental spill or traffic accident involving the release of sodium hypochlorite to the environment. No exposure of the public to this corrosive material would be expected, and no significant risk would occur. Material Transportation Transportation of hazardous materials by truck involves the potential for traffic accidents with resultant spillage of the transported material. A total of 1,592 incidents involving the transportation of hazardous materials occurred in California in 2007, which resulted in 2 hospitalizations for injuries and 16 non-hospitalized injuries, and no fatalities (USDOT, HAZMAT Summary by Incident State, data as of 6/12/2008). The federal Office of Hazardous Materials Safety has calculated for comparison the risk of accidental death associated with various activities, including the transportation of all hazardous wastes in the United States (http://hazmat.dot.gov/riskmgmt/riskcompare.htm). Per the OHMS based on a five year average from 1999-2003, the annual risk of death from motor vehicle accident was 1 per 7,700 (=1.03E-4 or 9.09E-3 over a 70 year lifetime), or about 1000 times greater than the Proposition 65 risk criteria of 1.0E-5. In comparison, the annual probability of death due to a hazardous material transportation accident is 4.28E-8 or 3.0E-6, which is less than the risk criteria. Therefore, the potential risk associated with the transportation of hazardous materials to the various sites is considered less than significant. In addition, the City will develop a Risk Management Plan (Appendix E includes the RMP for the SMWTP) that will identify and describe actions to be taken at the different facilities and by public emergency response personnel in case of an accidental spill or traffic accident involving the release of any chemicals to the environment.



4.4-17

Mitigation Measures. While the potential risk due to chemical use is primarily

associated with sodium fluoride, located at the SMWTP only, the following mitigation measures are applicable to all hazardous materials to be used to reduce potential human health impacts related to operational procedures and exposure to chemicals. HHS-1(a) Site Safety Engineering Design Features. The final design plans shall

meet the American Water Works Association (AWWA) standards for similar water treatment systems. These standards govern the design and installation of products and equipment for safe reliable water treatment systems. The State of California Department of Public Health (DPH) utilizes these standards when developing specific guidelines for drinking water compliance. DPH approval will be required for the projects permit to operate. These will include chemical storage and usage standards and specific water treatment features such as secondary containment, spill detection, alarm systems, pipe material and sizes, backflow prevention devices and double lining of chemical transmission lines.

HHS-1(b) Hazards and Operability Study. A Hazards and Operability (HAZOP)

study will be prepared by the City and approved by the California Department of Public Health (DPH) prior to the issuance of the projects permit to operate. The HAZOP study will identify potential safety hazards and evaluate potential operational problems in characterizing potential consequences to the surrounding communities in the event of a release of a hazardous material. This document will be prepared in accordance with the evaluation process described in State of California Department of Public Health (DPH) Policy Memorandum 97-005 for the Direct Domestic Use of Extremely Impaired Sources of Drinking Water, issued on 5 November 1997. The HAZOP involves a detailed review of the design of an engineered system to evaluate the safety and operability of the system’s components under varying operational parameters. This study will further evaluate the storage, use and transportation of hazardous materials at the project location. All recommendations and measures identified in this study shall be implemented. The DPH will keep the HAZOP report as part of the permit application file, and will make reference to it in the water supply permit. Anticipated measures include proper identification of storage hazardous materials, implementation of proper spill prevention and countermeasures, emergency response procedures, and other design measures that are necessary to eliminate or minimize to the greatest extent feasible any potential hazards associated with the new facilities and their operations. In addition, the HAZOP study focuses on how a plant or facility will respond to deviations from normal operation. This report will be prepared by the design engineers and approved by a professional engineer. A copy of the study shall be made available at the City of Santa Monica Engineering & Architectural Services Division for review and comment as part of the 97-005 public review process.



4.4-18

HHS-1(c) Risk Management Program. For the Charnock location, as required by the Los Angeles City Fire Department, prior to operations, a Risk Management Program shall be prepared, filed and approved by the Los Angeles City Fire Department. The SMWTP shall update its current RMP. The salt water well location will file a Business Plan with the Santa Monica Fire Department. The Risk Management Program is required to reduce the risk of accidental releases. The RMP will have written operational procedures and provide emergency guidance. This document will feature emergency response protocols, emergency response techniques and emergency contact numbers to ensure proper emergency management. A copy of the Risk Management Program shall be made available at the City of Santa Monica Engineering & Architectural Services Division for review and comment prior to finalization of the document.

HHS-1(d) Operations Manual. An operations manual shall be prepared once final

design is confirmed. This operations manual will have written operational procedures for site operations and maintenance. This document will feature operational protocols and standard operating procedures to ensure proper facility management. This document would also include a written training program for all staff. All vendor contracts shall define the site access route as Sawtelle Boulevard to Westminster Avenue and prohibit the use of other residential streets. This document would also include a written training program for all staff.

HHS-1(e) OSHA Trained and Certified Operators. Require that staff be trained

for 40 hour OSHA Safety requirements and that operators have a Class II water certification.

Significance After Mitigation. Implementation of recommendations and procedures in

these mitigation measures would ensure that impacts from storage and use of the groundwater treatment materials in addition to risk of upset would be reduced to a level that is less than significant. c. Cumulative Impacts. Cumulative projects in the project area would have the potential to encounter hazardous materials during construction and to generate hazards that could result in adverse health and safety conditions. However, regulations and review processes are in place to ensure that new development is required to remediate such hazards prior to site excavation or demolition, and construction and to ensure that new operations and use of hazardous materials implement appropriate handling, storage and operational procedures to mitigate potential impacts associated with the use of such materials. These existing programs would be expected to reduce potential cumulative impacts associated with hazards and hazardous materials to a level less than significant.

Charnock Well Field Restoration Project EIR Section 4.5 Hydrology and Water Quality


4.5-1

4.5 HYDROLOGY AND WATER QUALITY 4.5.1 Setting

a. Surface Water Drainage. The Charnock site is relatively flat and has historically been developed as a water supply facility. Similar to the Charnock site, the SMWTP site is relatively flat and has historically been developed as a water supply facility. The overall drainage flow patterns from these locations are from the north and east to the south and west. An underground storm drain system collects surface runoff through a series of catch basins and carries the majority of the storm water west into Santa Monica Bay. The City of Santa Monica Utilities Division manages stormwater collection for Santa Monica. The project locations are contained within Zone C (FEMA Map No. 060159). Therefore, the project locations are not subject to a 100-year flood zone risk. b. Water Quality. The quality of the storm water draining into Santa Monica Bay remains a concern for the region. Each year, an average of 30 billion gallons of storm water and urban runoff are discharged through more than 200 outlets. Even in dry weather, 10 to 25 million gallons of water flow through storm drains into Santa Monica Bay every day (The Santa Monica Bay Restoration Commission, 2005). Street litter, garden fertilizers, pesticides, animal feces, oil, grease, and other contaminants generated from motor vehicles are some of the many urban wastes that are carried to the ocean along with rainwater. Over 100 National Pollutant Discharge Elimination System (NPDES) permitted dischargers release treated wastewater into these channels. Accidental sewer-overflows, as well as other miscellaneous wastewater from commercial and industrial sources, such as fire fighting wastewater, illegally discharged household and industrial hazardous wastes, and operational spills (i.e., truck and work area washdowns) are potential dischargers into the channels. Surface runoff probably constitutes the largest source of contaminants to the Bay and may be an important source of trace metals, pesticides, and coliform bacteria to the Bay. Coliform bacteria are of particular concern since surface runoff discharges across or near beaches, where the likelihood of contact with swimmers is high. Coliform counts are several times higher during and just after rains than on dry days. The most effective way to reduce the level of contamination from surface runoff is through the control of pollutants prior to their discharge to the drainage system. On October 1, 1998 the Stormwater and Urban Runoff Pollution Control Ordinance (L.A.M.C. 64.70) became law in the City of Los Angeles. The new ordinance not only makes it a crime to discharge pollutants into the storm drain system and imposes stiff fines on violators, but now also gives City public officers the authority to issue citations or arrest business owners or residents who deliberately and knowingly dump or discharge hazardous chemicals or debris into the system. A primary concern regarding storm drains and their impact on the quality of water in Santa Monica Bay are the pollutants carried by the drains into the Bay during the dry weather months, referred to as low-flow or dry weather flow. The water in these flows comes not from rains but from over-irrigation, wash-down of private property, emptying of swimming pools, groundwater inflow and infiltration, and other non-regulated discharges. Dry weather flow



was formerly diverted to the Pico-Kenter drain where it subsequently traveled to the Hyperion Treatment Plant for treatment, and then was discharged into Santa Monica Bay. Santa Monica's Urban Runoff Recycling Facility (SMURRF) treats approximately 500,000 gallons per day (gpd) of urban runoff generated in parts of the cities of Santa Monica and Los Angeles. All of the dry weather flow is diverted from the Pico-Kenter and Pier Storm Drains into the SMURRF and treated to remove pollutants such as trash, sediment, oil, grease, and pathogens. Treatment processes include coarse and fine screening to remove trash and debris, dissolved air flotation to remove oil and grease, degritting systems to remove sand and grit, micro-filtration to remove turbidity, and ultra-violet (UV) radiation to kill pathogens. Once treated, the water is safe for all landscape irrigation and dual-plumbed systems (buildings plumbed to accept recycled water for the flushing of toilets) as prescribed by the California Department of Health Services. In this way, the amount of pollution flowing into Santa Monica Bay is reduced and the amount of water available for landscaping and irrigation is increased.

c. Groundwater. The Santa Monica Groundwater Basin is located on the northwestern section of the Coastal Plain of Los Angeles County. Groundwater flow within the Coastal Plain is restricted by geologic structures such as faults that denote the edges of basins within the Plain. The basin is bounded by the Santa Monica Mountains to the northwest, the Pacific Ocean to the west and southwest, the Newport-Inglewood fault to the northeast, and the Ballona escarpment and Baldwin Hills to the south and southeast. The Santa Monica Basin is separated from the West Coast Basin by the Ballona Gap. Faults subdivide the Santa Monica Basin into five sub-basins: Arcadia, Olympic, Coastal, Charnock and Crestal.

The Santa Monica Basin is vertically segmented into multiple aquifers separated by zones of low-permeability sediment (silts and clays). Groundwater is extracted from the upper aquifers, which consist of younger marine sediments and the overlying alluvial deposits. The City operates three groundwater well fields in the Olympic, Charnock and Arcadia Sub-Basins, extracting groundwater via ten wells. The primary sources of groundwater recharge into the Santa Monica Basin are direct infiltration from precipitation in the basin and subsurface inflows from the Santa Monica Mountains, the upper unconfined aquifer from the east, and the upper unconfined and lower San Pedro formation from the south. Water is discharged from the basin via surface runoff, evapotranspiration, and subsurface outflow to the south. The Charnock Basin is bounded by the Santa Monica Mountains on the north, the Overland Avenue Fault on the east, the Ballona Escarpment and Baldwin Hills on the south and by the Charnock Fault on the west. The City of Santa Monica has pumped groundwater from this vicinity since the 1920s. In 1996, the City of Santa Monica’s Charnock well field was shutdown due to the detection of gasoline compounds, specifically methyl tertiary-butyl ether (MTBE), in the water supply. The sources of the gasoline in the groundwater are leaking underground storage tanks at gasoline service stations located to the south of the well field. At the time the well field was shut down, the Charnock well field was supplying the City with approximately 50% of its demand. The contamination of the Charnock groundwater basin led the California Regional Water Quality Control Board, Los Angeles Region (RWQCB) and the United States Environment



Protection Agency, Region 9 (USEPA) to require extensive studies. These studies required the drilling of over 400 wells, the collection and analysis of over 4000 groundwater samples, and over 10,000 soil samples. This investigation focused on areas where contamination has spread beyond the boundaries of individual source sites. These studies include a Basin Information Summary Report, Current Conditions Report, Conceptual Flow and Transport Model Report and Regional Investigation Report (available at http://www.epa.gov/region09/mtbe/charnock/reginvestigation.html). One of the more significant objectives of the studies was to evaluate groundwater flow and the movement of gasoline-related constituents, including methyl tertiary-butyl ether (MTBE), within the Charnock Sub-Basin1 under current conditions and a variety of remedial action scenarios. The City has owned and maintained the water rights for the Charnock groundwater basin since the 1920’s. The Charnock wells have a total pumping capacity of 9,000 gallons per minute (gpm), however this production flow rate is not sustainable, as it exceeds the perennial safe yield from the Charnock subbasin, estimated to be 5,500 gpm. Historically, the well field was operated with three of the five wells pumping at a time, yielding a long-term average production rate of 5,200 gpm (7.5 MGD). Because the well field has not been operated since 1996, the aquifer has recharged, or refilled. As a result of this extra volume of available water, the Charnock well field can be safely pumped at flow rates greater than the safe yield for up to seven years before the production rate must be decreased to less than the perennial safe yield of the sub-basin (WorleyParsons Komex, Preliminary Design Report, July 2007). Provided that the treatment system is operated within the (long term) safe yield parameters, the proposed project would not significantly impact groundwater supplies and would enhance ground water quality. California does not have a statewide management program or statutory permitting system for groundwater. Groundwater use and associated rights has therefore evolved from a series of court decisions beginning in the early 20th century. Several groundwater basins in California, typically ones in which the groundwater has been “overdrafted,” have had specific pumping rights assigned to public and private entities, and so are termed “adjudicated” basins. Others are specifically managed under a variety of statutory authorities. The Santa Monica Basin, including the Charnock Basin, has not been adjudicated and is not formally managed. The primary producer in the basin is the city of Santa Monica. Water rights to the basin are determined by the “first in time, first in right” doctrine whereby the City’s operation since the 1920’s gives it such rights. In addition, the California Public Utilities Commission approved in 2002 the transfer of limited water rights held by the Southern California Water Company to the Charnock Basin to the City of Santa Monica. In addition to the MTBE in the groundwater, the Charnock Basin has high concentrations of minerals (high total dissolved solids) and has been previously impacted by other chemicals such as perchlorethylene and trichloroethylene. The City of Santa Monica will continue to meet or exceed all drinking water standards and will monitor the Charnock groundwater to determine both the quality and quantity of this valuable local resource.

d. Tsunamis and Seiches. Tsunamis are large ocean surges that are created as a result of a subsea earthquake or landslide. The waves created by the subsea earthquake or landslide travel across the ocean at high speeds (several hundreds of miles per hour). As the waves reach shore, their amplitudes increase. Once the waves reach land, they can cause widespread



flooding. The areas susceptible to tsunamis are those near to the ocean and along low-lying river channels. A seiche is a wave or series of waves that are produced within an enclosed or partially enclosed body of water (such as a lake or bay). Most seiches are created as landslides fall into the body of water and displace the water. The water then sloshes out of the bay or lake, creating the seiche. If a seiche overtops a dam, the water can erode the dam face to the point where the dam can fail.

e. Regulatory Setting. The federal Clean Water Act (CWA) and the California Ocean Plan are the primary mechanisms through which pollutant discharges are regulated in California. The CWA established minimum national water quality goals and created the National Pollutant Discharge Elimination System (NPDES) permit system to regulate the quality of discharged water. The U.S. Environmental Protection Agency (EPA) is the primary Federal agency responsible for implementing the CWA. The Los Angeles Regional Water Quality Control Board (RWQCB) is the primary state agency responsible for implementing the CWA and the state’s Porter-Cologne Water Quality Act within state waters. The RWQCB is also responsible for water quality regulation through its work in preparing and adopting the California Ocean Plan. Local agencies also have responsibility for managing wastewater discharges. All are required to meet criteria set forth in their NPDES permits, to monitor their discharges, and to submit monthly reports to the RWQCB and the EPA. As operators of two treatment plants that discharge to the Bay, the City of Los Angeles and the County Sanitation Districts of Los Angeles also have “control authority” over the pretreatment program. They are responsible for ensuring that indirect dischargers achieve and maintain compliance with pretreatment standards and requirements. As a co-permittee under the County National Pollutant Discharge Elimination System (NPDES), the City of Santa Monica is obligated to implement a Standard Urban Water Mitigation Plan and Best Management Practice procedures to regulate and reduce urban runoff. As a result, the City requires all new construction to treat or infiltrate runoff by the amount equal to or more than the volume produced by a storm event. Regulations under the federal Clean Water Act require that, for projects disturbing greater than one acre during construction, a NPDES State General Construction Permit must be obtained from the Los Angeles Regional Water Quality Control Board (LARWQCB). The Permit requires the preparation of a Storm Water Pollution Prevention Plan (SWPPP) that contains specific actions, termed Best Management Practices (BMPs), to control the discharge of pollutants, including sediment, into local surface water drainages. A Notice of Intent (NOI) to perform work under the Permit must be filed with the State. Completion of a SWPPP and submittal of a NOI to the LARWQCB satisfies the Erosion and Sediment Control Requirements for construction within the County SWMP. The California Department of Public Health (DPH) prohibits public water suppliers from delivering water to their customers if the water contains chemicals at concentrations greater than their respective Maximum Contaminant Levels (MCLs). In addition, the State Water Resources Control Board (SWRCB) regulates the cleanup of contaminated groundwater to levels consistent with background, i.e. naturally occurring, concentrations. For petroleum and chlorinated hydrocarbon compounds, this means that the water source (aquifer) should be restored to uncontaminated conditions.



As noted earlier, the City of Los Angeles has adopted a Stormwater and Urban Runoff Pollution Control Ordinance. The ordinance sets forth uniform requirements and prohibitions for dischargers and places of discharge to the storm drain system, and the receiving waters, necessary to adequately enforce and administer all laws and lawful standards and orders or special orders that provide for the protection, enhancement and restoration of water quality. 4.5.2 Impact Analysis a. Methodology and Significance Thresholds. This evaluation is based on a review of existing information that has been developed for the project and other available regional sources. An impact is considered to be significant if the project would:

• Substantially degrade water quality • Contaminate a public water supply • Cause substantial flooding or siltation • Substantially alter surface flow conditions, patterns, or rates • Substantially degrade or deplete groundwater resources • Interfere substantially with groundwater recharge

b. Project Impacts and Mitigation Measures. Impact HWQ-1 The proposed project would involve the demolition and

reuse of existing structures, construction of new buildings and structures, and installation of new landscaping. Implementation of the City of Los Angeles Urban Runoff Pollution Control Ordinance and National Pollutant Discharge Elimination System (NPDES) requirements would reduce any potential impacts related to erosion and sedimentation from demolition and construction to Class III, less than significant.

For the Charnock location, the proposed project would involve the installation of a granular activated carbon (GAC) filter system to treat groundwater from three contaminated wells within the Charnock well field. The major components of the treatment system will include five up-flow greensand filter vessels, 10 down-flow 20,000 pound GAC vessels (up-flow describes the process where water enters the bottom of the vessel and flows upward, down-flow is where water flows down from the top of the vessel) one 35,000-gallon equalization tank, two 30,000-gallon backwash storage tanks, one 10,000-gallon sump storage tank, a 280 square foot (sf) hypochlorite storage and feed building(14ft by 20ft), a 120 sf control systems building (8ft by 15ft) and transfer pumps, piping and appurtenances. For the SMWTP, the City is currently evaluating several treatment system modifications at this facility including the addition of a fluoridation system, and a switch from chlorine to chloramines for disinfection treatment. Upgrades to the water softening system and disinfection delivery system are also currently being evaluated. The water softening upgrades may include the installation of two new salt water wells on Santa Monica Beach. Two salt water wells are currently installed and they would be upgraded or replaced if the ion exchange water softening system is upgraded. Demolition and construction activities on-site could potentially introduce construction debris into the surrounding environment and surface waters. Grading associated with project



construction could result in erosion of soils on-site and sedimentation, with consequent temporary impacts to surface water quality. The project may require the removal of sand, demolition and construction materials, and the importation of soils for new landscaping, all of which would require temporary storage onsite. Movement and storage of these materials would increase the potential for soil/debris migration off-site via wind and/or water erosion. The City of Los Angeles Construction and Demolition Waste Management (CMDW) Specification includes procedures for ensuring optimal diversion of construction and demolition waste generated by projects, and documentation procedures for tracking waste generation and diversion. Pursuant to this chapter, applicants must complete and submit a waste management plan (WMP), as part of the application packet for the construction or demolition permit. The completed WMP shall indicate all of the following:

• The estimated volume or weight of the project C&D material, by material type, to be generated;

• The maximum volume or weight of such materials that can feasibly be diverted via reuse or recycling. No more than twenty percent of the sixty percent diversion rate can be achieved through the recycling or reuse of inert materials unless [the] applicant can demonstrate to the satisfaction of the WMP Compliance Official that sufficient structural materials do not exist for recycling or that forty percent diversion of total waste through non-inert materials is not feasible;

• The vendor or facility where the applicant proposes to use to collect or receive that material; and

• The estimated volume or weight of C&D materials that will be landfilled in Class III landfills (“Class III landfill”) and inert disposal facilities (“Inert disposal facility/inert waste landfill”).

The City of Los Angeles Stormwater and Urban Runoff Pollution Control Ordinance requires standard erosion control practices to be implemented for all new construction. Requirements of the Ordinance include: the use of drainage controls such as down drains, detention ponds, filter berms, or infiltration pits; removal of any sediment tracked offsite within the same day that it is tracked; containment of polluted runoff onsite; use of plastic covering to minimize erosion from exposed areas; and, restrictions on the washing of construction equipment. The total area of the project site is approximately five acres and—as the proposed project would disturb greater than one acre during construction—a Storm Water Pollution Prevention Plan (SWPPP) would be required for the site in accordance with the requirements of the National Pollutant Discharge Elimination System (NPDES) and subject to the oversight of the Los Angeles Regional Water Quality Control Board. The SWPPP must include best management practices (BMPs) to reduce or eliminate erosion and sedimentation of material on-site, and must be available on the project site at all times. Implementation of these standard requirements would ensure that water quality impacts from demolition and construction activities are less than significant.

Mitigation Measures. Implementation of the erosion control practices of the Stormwater

and Urban Runoff Pollution Control Ordinance; submittal of, and compliance with, a



Construction and Demolition Material Waste Management Plan; and preparation and implementation of a SWPPP for the project site would reduce impacts associated with demolition, erosion and sedimentation to a less than significant level. No additional mitigation measures would be required. Significance After Mitigation. Impacts would be less than significant.

Impact HWQ-2 Overall, the Charnock location is expected to generate fewer pollutants in water runoff than the current land uses on the site through the conversion of impervious surfaces to exterior holding areas with permeable surfaces. This is considered an overall beneficial impact. However, the proposed project could still contribute urban pollutants to surface runoff from onsite parking lots and landscaping. This is considered a Class II, significant but mitigable, impact.

The project sites currently contain several buildings, parking areas, and previously developed lands. The proposed project will involve the demolition of existing buildings, and the construction of new structures, all of which would utilize impermeable surfaces. However, new buildings and structures would be located primarily within areas that are currently developed with impermeable surfaces and, therefore, would not result in a significant change in the amount of pollutants that are contributed to water runoff. The Charnock location will also be constructing exterior containment features for portions of the project. Moreover, improvements to the Charnock location may include landscaping and tree plantings, thus further increasing pervious surfaces onsite. By introducing natural vegetated pervious ground cover, which can both absorb water and filter out pollutants, new landscaped areas would reduce pollutants such as parking lot deposits of oil, grease, and other vehicle fluids and hydrocarbons that can cumulate on-site and enter water runoff. The addition of fertilizers, pesticides and other chemicals to the proposed landscaped areas has the potential to include higher than natural concentrations of trace metals, biodegradable wastes (which affect dissolved oxygen levels), and excessive major nutrients such as nitrogen and phosphorus. While recent advances in landscape irrigation techniques generally minimize the amount of water that deep percolates, return water losses are nonetheless estimated at 15% of applied water. This percolating water has the potential to carry leachable materials from the ground surface to the underlying shallow groundwater. The proposed project would be required to comply with the City of Los Angeles Stormwater and Urban Runoff Pollution Control Ordinance, which outlines practices for all developments in the City and runoff control requirements for all new development. Good housekeeping practices include: (1) collection, storage, and minimization of urban runoff; (2) maintenance of equipment; (3) removal of debris; and, (4) prohibition of the use of any pesticides and fungicides that are banned by the US Environmental Protection Agency. As part of the runoff control requirements for new developments, all new developments in the City must prepare an Urban Runoff Mitigation Plan that must address one or more of the following goals: (1) maximization of permeable areas for infiltration of runoff; (2) maximization of the amount of runoff directed toward permeable areas or stored for reuse; and, (3) removal of pollutants



through installation of treatment control BMPs. Compliance with the City’s Stormwater and Urban Runoff Pollution Control Ordinance would ensure that the project does not adversely affect offsite water quality. However, because of the continued potential for adverse impacts to surface and groundwater quality due to the possible application of herbicides and fertilizers to new landscaping, and from oil and grease from existing parking lots, mitigation is recommended to reduce these impacts to a level that is less than significant.

Mitigation Measures. The following mitigation measures would reduce impacts related

to the water quality of surface runoff during project operation:

HWQ-2(a) Best Management Practices. The City shall include best management practices (BMPs), such as sand filters and grease traps within the reconfigured surface parking lots. These features will be designed to intercept and prevent pollutants, sediment, and debris from discharging offsite.

HWQ-2(b) Landscaping Maintenance Plan. A landscaping maintenance

plan shall be implemented that limits the use of herbicides and inorganic fertilizers applied to landscaping to quantities that are necessary to treat specific problems. The maintenance plan shall incorporate features from the City of Santa Monica’s Integrated Pest Management Program, which include, but are not limited to the following: pest-resistant landscape materials and pest-repellant plants, provisions for mechanical weed control to be used wherever and whenever possible as the first choice; determination of the probable cause of a disease problem and correction as necessary (e.g., soil nutrient problems, irrigation, water quality, and plant type) prior to chemical use; provisions that herbicides are to be used only when necessary to cure a problem and not as a preventative measure or as a regular, periodic application; and, guidelines for use of chemical forms that have a low potential for leaching from the site.

Significance After Mitigation. With implementation of the above mitigation measures, project impacts related to water quality runoff during project operation would be improved when compared to existing conditions. Impact HWQ-3 The project may require the installation of two salt water wells

on Santa Monica Beach. The salt water well sites would place them within a potential tsunami inundation area. This is considered a Class II, significant but mitigable, impact.

The SMWTP may require the upgrading of its water softening treatment system. This system utilizes two salt water wells located on Santa Monica Beach. The potential well sites would be located on Santa Monica Beach in the vicinity of two existing wells which is identified as a potential tsunami inundation area (City of Santa Monica Safety Element, 1995). Tsunamis are



spontaneous water waves that are usually caused when hundreds to thousands of square miles of submerged continental shelf or slope are rapidly displaced several feet in a vertical direction during a large earthquake. Damage may be confined to a near coast, but waves may travel across oceans and devastate distant shorelines. Destructive tsunami waves are also generated when earthquake-triggered rocks or landslides fall into water bodies. Historically, California has suffered little tsunami damage. The wide, physiographically complex offshore borderland may aid in decreasing tsunami effects in Southern California. Predictive models for distantly generated tsunamis indicate that wave heights of 10 to 17 feet are exceeded on the average of once every 500 years along the Santa Monica Bay (McCulloch, 1985). The site does not lie within mapped inundation boundaries from to a seiche or a breached upgradient reservoir. Therefore, the risk from seiches is also considered to be low. This potential location would not result in increased visitation in the tsunami inundation area, however, since the Salt Water wells would be located on Santa Monica Beach, the risk of loss, injury or death from inundation is potentially significant unless mitigation incorporated. Mitigation Measures. The following mitigation measure is required to reduce tsunami impacts: HWQ-3 Tsunami Zone Building Recommendations. Specific flood proofing

measures should include permanent sealing of grade level openings; use of paints, membranes, or mortar to reduce water seepage through walls; installation of water tight doors, bulkheads, installation of flood water pumps in structures; and proper modification and protection of all electrical equipment, circuits and appliances so that the risk of electrocution or fire is eliminated.

Significance After Mitigation. With the implementation of the above mitigation measure, the impacts related to tsunami effects would be reduced to less than significant levels.

c. Cumulative Impacts. The proposed project, in conjunction with other cumulative projects proposed in the City of Los Angeles, would result in a general decrease in surface water quality during construction. As discussed above, the project would result in slightly decreased storm water runoff and increased groundwater infiltration after the project is complete. The development of pending projects would potentially increase runoff and add to the drainage burden of existing facilities. However, pending development in the immediate vicinity would occur for the most part, in urbanized and developed areas on properties that are or were previously built upon.

Compliance with federal requirements, including development of a Storm Water Pollution Prevention Plan for project construction; adherence to the City of Los Angeles Urban Runoff Pollution Control Ordinance for construction and operation of new developments; and compliance with the City of Los Angeles Construction and Demolition Waste Management would be expected to mitigate these potential cumulative impacts by requiring onsite detention, treatment, or other best management practices for controlling urban runoff. Therefore, cumulative impacts related to hydrology and water quality are expected to be less than significant.




Charnock Well Field Restoration Project EIR Section 4.6 Neighborhood Effects


4.6-1

4.6 NEIGHBORHOOD EFFECTS This section summarizes the proposed project’s potential impacts to the surrounding neighborhood. 4.6.1 Setting

a. Regulatory Setting. The City of Santa Monica Land Use Element of the General Plan requires the completion of a neighborhood impact statement, with public input. This requirement details the assessment of neighborhood impacts associated with all proposed projects, by looking at possible impacts to the character and cohesiveness of each neighborhood in the City. The principal objective stated under “Neighborhood Participation”, in the Land Use Element, is to encourage citizen and neighborhood participation in the City planning process to ensure realization of the plan goals.

b. Existing Neighborhood Characteristics. The proposed project involves water quality and water supply improvements for the City of Santa Monica and overall benefits to the regional water supplies. The proposed improvements would occur at two existing City operated water facilities and the possible installation of two new salt water wells in the immediate vicinity of two existing wells at Santa Monica Beach. The Charnock well field site encompasses a 10-acre parcel located at 11375 Westminster Ave in the Palms-Mar Vista-Del Rey Community Plan Area of the City of Los Angeles (Figure 2-3 Section 2.0, Project Description). The site is identified by Los Angeles County Assessor Parcel Numbers (APNs) 424-902-6270 to APN 424-902-6290 and is zoned OS-1XL (Open Space in Height District 1, Extra Limited). A portion of the site is occupied by a number of small buildings related to the operation and maintenance of the municipal supply wells. Since 1982, the remainder of the site has been used by Windward School, which leases the property from the City of Santa Monica. Residential uses are located to the south of this location. The SMWTP site encompasses a 4.8-acre parcel located at 1228 S. Bundy Drive in the West Los Angeles Community Plan Area of the City of Los Angeles (Figure 2-3, Section 2.0, Project Description). The site is identified as Los Angeles County Assessor Parcel Number (APN) is 426-300-3270 and is zoned [Q]PF-1XL (Qualified Public Facilities in Height District 1, Extra Limited). This location is approximately 1,250 feet east of the eastern limit of the City of Santa Monica. The facility is bordered by Saltair Avenue on the east, and Texas Avenue on the south. The facility is located within a predominantly residential neighborhood, with commercial businesses and office buildings located to the north. The two existing salt water wells are located west of Pacific Street and Ocean Avenue on Santa Monica Beach. Surrounding land uses include residential uses to the east and recreational uses to the north, south and west. 4.6.2 Summary of Neighborhood Impacts and Mitigation Measures Project impacts that would affect the surrounding neighborhood are summarized in Table 4.6-1. A discussion of the project’s effects on the surrounding neighborhood follows. Included in the



4.6-2

criteria for neighborhood effects are impacts that would affect the surrounding community, such as traffic and construction. The significance criteria for each impact listed below are described in their respective sections (Section 4.1, Aesthetics, Section 4.2, Construction, Section 4.4, Hazards and Hazardous Materials and Section 4.7, Noise). Please refer to individual report sections for detailed analysis of project impacts and mitigation measures for each issue area.

Aesthetics. The project involves implementation of a water treatment system and other improvements that would help to remove groundwater contamination from the Charnock groundwater sub-basin and restore this resource as a water supply for the City of Santa Monica (City). As part of the project upgrades, improvements will be required at two existing City-operated water service facilities; the Charnock well field site and the Santa Monica Water Treatment Plant (SMWTP). In addition, two salt water wells may need to replace existing salt water wells located on Santa Monica beach. The proposed project would involve the construction of new facilities on the Charnock site. This will include 15 water treatment vessels and other water treatment features. The vessels would be approximately 24 feet high and, while largely screened by existing vegetation, would have a visual impact to the surrounding neighborhood. This impact is considered potentially significant unless mitigation incorporated. Design features such as a physical screen or façade, landscaping or potted trees at base of structures, neutral earth tone colors of tanks and buildings and placement of decorative redwood slats in the existing chain link fence would reduce impacts to a less than significant level.

Table 4.6-1 Summary of Neighborhood Effects

Impact Mitigation Measures

Section 4.1, Aesthetics

Impact AES-1: The proposed project would involve construction of new water treatment facilities including fifteen 24-foot water treatment vessels and other miscellaneous tankage at the Charnock site. These facilities would be largely screened by existing and proposed mitigation and would be consistent with the height limits and massing that would be allowed under the current zoning. In addition, these facilitates would not alter or obstruct the views of any identified sensitive visual resource. As such, the proposed project would not exceed any identified visual impact threshold. The introduction of an industrial looking facility in the largely residential neighborhood has the potential to be perceived as inconsistent with the visual character of the area. This impact is considered potentially significant unless mitigation incorporated. Introduction of site improvements at the SMWTP and the potential two salt water wells that may be constructed on Santa Monica Beach would not exceed any of the visual impact thresholds identified above and would not be inconsistent with the visual character of those areas. Thus the project visual impacts at those locations are considered Class III, less than significant. See Section 4.1, for a complete discussion of this impact.

AES-1 Additional Screening and Site Design Features.



4.6-3



Impact AES-2: Proposed Charnock project structures would cast shadows onto adjacent properties in excess of those cast by the existing building. The net increase in shadow coverage would only affect the Windward School parking area adjacent to the Charnock site for more than three hours a day during the winter season. Therefore, the effect of shadows on existing uses would Class III, less than significant impact. See Section 4.1, for a complete discussion of this impact.

None required.

Impact AES-3: The proposed development would introduce new sources of light and glare to the project site. Although project design elements would minimize impacts associated with lighting; the project may subject surrounding properties to increased light and glare. This would be a Class II, significant but mitigable.

AES-3(a) Low-glare Materials. AES-3(b) Lighting Plan.

Section 4.2, Construction Effects

Impact CON-1: Project construction may temporarily place equipment staging on adjacent streets and would temporarily increase truck traffic in the project area. This could disrupt the normal use of the sidewalk and adjacent streets, and affect parking availability. Onsite construction activities would also have the potential to adversely impact activities at Windward School. This would be a Class II, significant but mitigable impact See Section 4.2, for a complete discussion of this impact.

CON-1 (a) Construction Impact Management Plan. CON-1 (b) Windward School Construction Impact Management Plan.

Impact CON-2: Project construction would intermittently generate high noise levels on and adjacent to the site. This may affect noise sensitive receptors in the vicinity. This would be a potentially significant but mitigable, impact. See Section 4.2, for a complete discussion of this impact.

CON-2 (a) Diesel Equipment Mufflers. CON-2 (b) Use of Electric Powered Equipment. CON-2 (c) Restrictions on Excavation and Foundation/Conditioning CON-2 (d) Additional Noise Attenuation Techniques. CON-2 (e) Construction Sign Posting.

Impact CON-3: Project implementation may require the demolition of existing structures, which could result in the dispersal of asbestos or lead containing materials, if present. This impact is considered potentially significant unless mitigation incorporated. See section 4.2, for a complete discussion of this impact.

CON-3 (a) Building Asbestos Survey and Removal. CON-3 (b) Lead Survey and Removal.

Impact CON-4: Project construction would generate air pollutant emissions however temporary construction impacts would not exceed SCAQMD construction thresholds. Impacts, therefore, would be Class III, not significant. See section 4.2, for a complete discussion of this impact.

CON-4 (a) Fugitive Dust Control Measures. CON-4 (b) Ozone Precursor Control Measures.



4.6-4



CON-4 (c) PM10 and PM2.5 Control Measures.

Section 4.4, Hazards and Hazardous Materials

Impact HAZ-1: The proposed project will utilize activated carbon and chemicals for groundwater treatment. The storage and use of these materials has the potential to result in health risks to workers and to affect the greater numbers of the public. This impact is considered potentially significant unless mitigation incorporated. See section 4.4, for a complete discussion of this impact.

HAZ-1 (a) Site Safety Engineering Features. HAZ-1 (b) Preparation of a Hazardous and operability Study and Implementation of measures identified therein. HAZ-1 (c) Risk Management Program. HAZ-1 (d) Operations Manual. HAZ-1 (e) OSHA Trained and Certified Operators.

Section 4.7, Noise

Impact N-1: Operation of stationary equipment such as groundwater pumps associated with the proposed project would generate noise levels that may periodically be audible to existing uses near the project site. Impacts would be Class III, not significant. See sections 4.2 and 4.7, for complete discussions of this impact

None required.

Impact N-2: Operation of mobile equipment such as truck mounted pumps associated with the proposed project would generate noise levels that may periodically be audible to existing uses near the project site. Impacts would be Class II, significant but mitigable. See sections 4.2 and 4.7, for complete discussions of this impact

N-2 (a) Portable Noise Barriers.

Construction Effects. The project has the potential to have temporary construction-

related traffic, noise and air quality. Water quality construction impacts are discussed in Hydrology and Water Quality. Each issue is discussed in more detail below. Project construction activity would not generate air pollutant emissions that exceed SCAQMD construction thresholds. Therefore, the proposed project would not have significant construction related air quality impacts. However, the SCAQMD requires that all construction related activity use dust minimization mitigation. Therefore, these measures have been included to reduce impacts associated with fugitive dust and ozone to the maximum extent feasible. Project construction would temporarily increase truck traffic in the project area, which could disrupt the normal use of the sidewalk and Westminster Avenue, and also affect parking availability, thereby resulting in Class II, potentially significant impacts. However,



4.6-5

implementation of a Construction Impact Mitigation Plan, which would provide for traffic and parking capacity management during construction, would reduce impacts to a less than significant level. Project construction would intermittently generate high noise levels on and adjacent to the sites. Implementation of measure to reduce construction noise including: Diesel Equipment mufflers, electrically-powered tools to run air compressors, restrictions on the times of excavation and foundation activities, and additional noise attenuation techniques (e.g., the use of noise blankets and temporary sound barriers); and, the posting of signs to inform workers and neighbors of construction activity times and how to report violations. Impacts would be less than significant after mitigation. Hazards and Hazardous Materials. The project would require the use of chemicals and the transport of spent carbon off-site. This impact is considered potentially significant unless mitigation incorporated. Implementation of mitigation measures including Site Safety Engineering Features, preparation of a Hazardous and Operability Study, Risk Management Program, Operations Manual, and OSHA Trained and Certified Operators would reduce impacts to a less than significant level. In addition, project implementation may require the demolition of existing structures, which could result in the dispersal of lead and asbestos if present. This impact is considered potentially significant unless mitigation incorporated. Implementation of mitigation measures including building lead and asbestos survey and building lead and asbestos removal would reduce impacts to a less than significant level.

Noise. Project generated traffic would incrementally increase noise levels on some area roadways. This project related increase would generally not be audible, as one to two decibel changes are generally not perceivable to the human ear. In addition, this change is less than the thresholds established by FICON as shown in Table 4.7-3; therefore, impacts would be less than significant. Operation of the project has the potential to generate noise from stationary and mobile equipment such as pumps. The impacts from the stationary sources are considered less than significant since virtually all will be located within a structure. The impact from the mobile sources is considered potentially significant unless mitigation incorporated. Implementation of mitigation measures including portable noise barriers would reduce impacts to a less than significant level. The mitigation measures would reduce noise levels and would meet or exceed the City’s Noise Ordinance standards. Impacts would be less than significant.



4.6-6


Charnock Well Field Restoration Project EIR Section 4.7 Noise


4.7 NOISE This section evaluates the proposed project’s long-term impact upon local noise conditions. Noise impacts associated with temporary construction activities are addressed in Section 4.2, Construction Effects. 4.7.1 Setting

a. Overview of Sound Measurement. Noise level (or volume) is generally measured in

decibels (dB) using the A-weighted sound pressure level (dBA). The A-weighting scale is an adjustment to the actual sound power levels to be consistent with that of human hearing response, which is most sensitive to frequencies around 4,000 Hertz (about the highest note on a piano) and less sensitive to low frequencies (below 100 Hertz).

The sound pressure level is measured on a logarithmic scale with the 0 dB level based on the lowest detectable sound pressure level that people can perceive (an audible sound that is not zero sound pressure level). Based on the logarithmic scale, a doubling of sound energy is equivalent to an increase of 3 dB, and a sound that is 10 dB less than the ambient sound level has no effect on ambient noise. Because of the nature of the human ear, a sound must be about 10 dB greater than the reference sound to be judged as twice as loud. In general, a 3 dB change in community noise levels is noticeable, while 1-2 dB changes generally are not perceived. Quiet suburban areas typically have noise levels in the range of 40-50 dBA, while those along arterial streets are in the 50-60+ dBA range. Normal conversational levels are in the 60-65 dBA range, and ambient noise levels greater than 65 dBA can interrupt conversations. Noise levels typically attenuate (or drop off) at a rate of 6 dBA per doubling of distance from point sources such as industrial machinery. Noise from lightly traveled roads typically attenuates at a rate of about 4.5 dBA per doubling of distance. Noise from heavily traveled roads typically attenuates at about 3 dBA per doubling of distance. In addition to the actual instantaneous measurement of sound levels, the duration of sound is important since sounds that occur over a long period of time are more likely to be an annoyance or cause direct physical damage or environmental stress. One of the most frequently used noise metrics that considers both duration and sound power level is the equivalent noise level (Leq). The Leq is defined as the single steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual fluctuating levels over a period of time (essentially, the average noise level). Typically, Leq is summed over a one-hour period. The actual time period in which noise occurs is also important since noise that occurs at night tends to be more disturbing than that which occurs during the daytime. Two commonly used noise metrics – the Day-Night average level (Ldn) and the Community Noise Equivalent Level (CNEL) - recognize this fact by weighting hourly Leqs over a 24-hour period. The Ldn is a 24-hour average noise level that adds 10 dB to actual nighttime (10 p.m. to 7 a.m.) noise levels to account for the greater sensitivity to noise during that time period. The CNEL is identical to the Ldn, except it also adds a 5 dB penalty for noise occurring during the evening (7 a.m. to 10 p.m.).



b. Sensitive Receptors. Noise exposure goals for different land uses reflect the varying noise sensitivities associated with those uses. Generally noise-sensitive land uses include: public or private schools, places of worship, cemeteries, libraries, hospitals and similar health care institutions. These noise-sensitive land uses are most sensitive to noise intrusion and therefore have more stringent noise exposure targets than manufacturing or industrial uses that are not subject to effects such as sleep disturbance. Noise-sensitive receptors located in the vicinity of the project site include residential uses to the south of the project site (approximately 100 feet away) and the Windward School site immediately north and adjacent to the Charnock site.

c. Regulatory Setting. The City of Los Angeles has a noise ordinance and enforcement practices that apply to intrusive noise and that guide new construction. The City’s Comprehensive Noise Ordinance (Municipal Code Section 111 et seq.) establishes sound measurement criteria, minimum ambient noise levels for different land use zoning classifications, sound emission levels for specific uses (radios, television sets, vehicle repairs, and amplified equipment, etc.), hours of operation for certain uses (construction activity, rubbish collection, etc.), standards for determining a disturbance of the peace, and legal remedies for violations. Its ambient noise standards are consistent with current state and federal noise standards. The standards guide building construction, equipment installation, equipment maintenance, and nuisance noise enforcement.

The Charnock and SMWTP project sites are located within the City of Los Angeles and are subject to the General Plan Noise Element and Noise Ordinances incorporated therein. Section 41.40 of the Los Angeles Municipal Code indicates that no construction or repair work shall be performed between the hours of 9:00 p.m. and 7:00 a.m. on any weekday, since such activities generate loud noises and disturb persons occupying sleeping quarters in adjacent hotel dwellings, apartments, or other places of residence. No person, other than an individual homeowner engaged in the repair or construction of his single family dwelling, is to perform any construction or repair work of any kind before 8:00 a.m. or after 6:00 p.m. on Saturday, nor at any time on Sunday. The City of Los Angeles Noise Ordinance (Los Angeles, CA Chapter XI) prohibits sound levels “detrimental to the health and welfare of the citizenry” in the City. The City of Los Angeles Noise Ordinance regulates noise by referencing Section 41.40 of the Los Angeles Municipal Code. The City of Los Angeles follows the State’s Guidelines for Noise Compatible Land Use. Table 4.7-1 shows the allowable noise levels within each noise exposure levels.

Table 4.7-1 Exterior Noise Standards

Land Use Category

Day-Night Average Exterior Sound Level (CNEL dBA)

Acceptable¹ Conditionally² Acceptable Unacceptable³

Residential, School, Library, Church, Hospital

Up to 55 Up to 70 Above 70


Playgrounds, Neighborhood Parks Up to 65 Up to 75 Above 75




Land Use Category

Day-Night Average Exterior Sound Level (CNEL dBA)

Acceptable¹ Conditionally² Acceptable Unacceptable³

Office Buildings, Business,

Commercial, Professional


1 Specified land use is satisfactory. No noise mitigation measures are required. 2 Use should be permitted only after careful study and inclusion of protective measures as needed for intended use and to satisfy policies of the Noise Element. 3 Development is not feasible in accordance with the Noise Element. Use is prohibited

Source: Governors Office of Planning and Research, Guidelines for Noise Compatible Land Use. Section 112.05 of the City’s Noise Ordinance places specific limitations on the maximum noise level of powered equipment or powered hand tools. Heavy-duty construction equipment and similar powered equipment are limited to no more than 75 dBA at a distance of 50 feet between the hours of 7:00 a.m. and 10:00 p.m., in any residential zone of the City or within 500 feet thereof. The City of Santa Monica’s General Plan Noise Element was revised in 1992. The Noise Element provides a description of existing and projected future noise levels and incorporates comprehensive goals, policies, and implementing actions. The Noise Element also includes a Land Use/Noise Compatibility Matrix which identifies the compatibility of different land uses with a range of noise levels, from less than 55 dBA CNEL to over 80 dBA CNEL. For example, with mitigation, residential uses are considered compatible with noise environments of up to 70 dBA CNEL; however, schools and libraries are considered compatible with noise environments of up to only 65 dBA. The City Noise Ordinance (Municipal Code § 4.12) enforces the goals and policies of the Noise Element. The Noise Ordinance was adopted in March 2004. Consistent with the Noise Element, the Noise Ordinance requires that noise attenuation features be followed in the siting and design of new development if necessary. The Noise Ordinance prohibits any “unnecessary, excessive, or annoying noise and vibration” in the City. The Ordinance does not control traffic noise, but applies to all noise sources located on private property. As part of this ordinance, properties within the City are assigned a noise zone based on their corresponding zoning district. Residential districts are designated as Noise Zone I; commercial districts are designated Noise Zone II; and manufacturing or industrial districts are designated as Noise Zone III. The Ordinance also limits the amount of noise generated by uses during normal operation that may affect the surrounding areas. Table 4.7-2 shows the allowable noise levels and corresponding times of day for each of the three identified noise zones. The standards plus 20 dB (i.e., 80 dBA for 7 a.m. to 10 p.m. for Zone I) apply to maximum instantaneous noises occurring for any period of time. Subsection (d) of Section 4.12.060 (Exterior Noise Standards) of the Noise Ordinance also states, “[i]f the ambient noise level exceeds the allowable exterior noise level standard, the ambient noise level shall be the standard.” It also states that “[i]f any portion of a parcel is located within 100 feet of a noise zone with higher noise standards as compared to the noise standards for the



noise zone in which the parcel is located, then the maximum allowable exterior equivalent noise level for the entire parcel shall be the average of the noise standards of the two noise zones. However, any noise level measurement must be taken at least twenty-five feet from the parcel line of the source of the noise.”


Noise Zone Time Interval Allowable Leq

15-Minute Continuous Measurement Period

5-Minute Continuous Measurement Period

I

Monday – Friday 10 PM – 7 AM 7 AM – 10 PM

50 dBA 60 dBA

55 dBA 65 dBA

Saturday and Sunday 10 PM – 8 AM 8 AM – 10 PM

50 dBA 60 dBA

55 dBA 65 dBA

II All Days of Week

10 PM – 7 AM 7 AM – 10 PM

60 dBA 65 dBA

65 dBA 70 dBA

III Anytime 70 dBA 75 dBA

Source: City of Santa Monica Municipal Code §4.12.060(a).

d. Existing Noise Conditions and Sources. The most common sources of noise in the

vicinity of the project sites are transportation related noise sources, including automobiles, trucks, and motorcycles. The following discusses noise levels at the project sites

Charnock Well Field. The neighborhood in which the Charnock project site is located is primarily residential, with a park and an adjacent private school. Primary noise sources in the area include the I-405 freeway, though much of the noise from this freeway is attenuated by the mid-rise residential buildings adjacent to the west side of the freeway and by a freeway sound wall that has recently been under construction. Nonetheless, it is the primary source of background ambient noise in the area. Sawtelle and Palms Boulevards are the other major sound sources in the area, though noise effects of these streets are primarily confined to those uses that front on them.

The site is currently occupied by a group of small single story buildings related to the operation and maintenance of the Santa Monica municipal water supply wells. The site operated as a full time groundwater treatment facility from approximately the 1930’s to 1996. In addition, since 1982, portions of the property have also been used by Windward School, which leases the property from the City of Santa Monica. The school features several classroom and administrative buildings in addition to outdoor recreation areas. The school generates sound associated with outdoor recreational use, recreational events, and daily traffic. Traffic along Westminster Avenue is a minor local source of noise, but because of its low volumes, it does not contribute a substantial amount of noise to the adjacent neighborhood.



Existing noise conditions at the Charnock site were determined through monitoring using an Extech Instruments Datalogger Model 407780 integrating sound level meter. Noise measurements were taken at two locations: (1) the intersection of Westminster Avenue and Corinth Avenue, and (2) the intersection of Westminster Avenue and Purdue Avenue. These measurements were taken on June 10, 2008 at two locations. Location number 1 featured two sampling periods, the first in the morning from approximately 10:45-11:00 a.m. and the second, in the afternoon, from approximately 3:00- 3:15 p.m. These two locations were selected to represent the expected baseline noise level and the worst case noise impact area based on existing development and traffic flow. Instantaneous sound levels were measured, integrated, and recorded by the sound level meter in 0.1-second intervals. The measurements were 15-minute samples consistent with the measurement duration suggested in the Caltrans Technical Noise Supplement (October 1998). Measured noise levels are shown in Table 4.7-3.

Table 4.7-3 Measured Sound Levels, dBA

Location Leq Lmax Lmin

Westminster Ave/SW Corner of Corinth Avenue – 11 a.m.

55.8 n/a n/a

Westminster Ave/SE corner of Purdue Avenue 51.9 n/a n/a

Westminster Ave/SW Corner of Corinth Avenue – 3 p.m.

51.9 71.6 42.7

Leq is the average sound level over the measurement period; Lmax is the maximum measured level; Lmin is the minimum measured level. n/a – Data not available

Observed noise sources during the first measurement period located at Westminster Avenue and Corinth Avenue included high altitude airplane flyovers, distant traffic on Sawtelle Boulevard and the freeway, light traffic on Westminster Avenue, truck delivery at water treatment plant, birds chirping/squawking, and construction activities northeast of project site and sampling location. Observed noise sources during the measurement period located at Westminster Avenue and Purdue Avenue included high altitude airplane flyovers, distant traffic on Sawtelle Boulevard and the freeway, light traffic on Westminster Avenue, children playing, birds chirping/squawking, and construction activities northeast of project site and sampling location. Observed noise sources during the second measurement period located at Westminster Avenue and Corinth Avenue included high altitude airplane flyovers, distant traffic on Sawtelle Boulevard and the freeway, light traffic on Westminster Avenue, birds chirping/squawking, and construction activities northeast of project site and sampling location. Based on the project location noise measurements, the local CNEL is about 52-55 dBA, which is consistent with residential use and school related activities (traffic, recreational activities, etc). Sounds that were measured during these recorded periods, as noted, included construction activities at Windward School and a truck delivery at the Charnock facility, which would be similar to that which would occur with the proposed project. Noise measurements at the site indicate that existing sound levels are compatible with residential and school land uses.



Santa Monica Water Treatment Plant. The SMWTP site is currently occupied by an active water treatment facility. Noise sources in the project area include those associated with onsite operations as well as traffic noise generated along the road system in the project area, and activities associated with adjoining land uses. Noise levels in the project area are dominated by traffic noise along Wilshire Boulevard and Bundy Drive, with ambient noise levels depending upon the traffic volumes and proximity of the receptor to the traffic source. Noise levels in the immediate vicinity range from about 60dBA to over 65dBA along these two thoroughfares.

Salt Water Well. The potential salt water well site is located at Santa Monica Beach. Noise sources in this area include minor vehicular activities, human recreational activities, and sounds of the surf. 4.7.2 Impact Analysis

a. Methodology and Significance Thresholds. For traffic-related noise, impacts are considered significant if project-generated traffic results in exposure of noise-sensitive land uses to unacceptable noise levels as indicated in Table 4.7-1.

In addition, sound levels associated with site use and vehicular generation can cause a general cumulative increase in local sound levels. The level of significance changes with increasing noise exposure, such that smaller changes in ambient noise levels result in significant impacts at higher existing noise levels. For the purpose of this EIR, significance thresholds developed by the Federal Interagency Committee on Noise (FICON) originally for aircraft noise will be used to determine the level of significance for increases in noise levels caused either by the project alone or by cumulative development (Table 4.7-4).

Table 4.7-4 Significance of Changes in Noise Exposure

Ambient Noise Level Without Project

(Ldn or CNEL) Significant Impact

< 60 dB + 5.0 dB or more

60 – 65 dB + 3.0 dB or more

> 65 dB + 1.5 dB or more

Source: Federal Interagency Committee on Noise (FICON), August 1993

If residential development or other sensitive receptors would be exposed to noise increases exceeding the above criteria, impacts would be considered significant. Impacts relating to onsite activities are considered significant when project-related activities create noise exceeding the standards as identified by the applicable noise zone for the particular project site (see Tables 7.4-1 and 7.4-2). The City of Los Angeles Noise Ordinance (Los Angeles, CA Chapter XI) prohibits any “detrimental to the health and welfare of the citizenry” in the City. The City of Los Angeles Noise Ordinance regulates construction noise by referencing Section 41.40 of the Los Angeles Municipal Code. The Ordinance does not control traffic noise on public streets, but applies to



all noise sources located on private property including traffic noise. Section 41.40(a) prohibits use of any noise-producing device or powered equipment for construction or repair work on any building or structure between the hours of 9:00 p.m. and 7:00 a.m. on weekdays. Section 41.40(c) prohibits non-emergency grading or construction, other than by an individual homeowner on his/her own single-family residence, on or within 500 feet of residential land before 8:00 a.m. and after 6:00 p.m. on Saturdays and national holidays, and at any time on Sundays. These sections also prohibit operation, repair, or servicing of construction equipment and job-site delivering of construction materials during those hours. Section 112.05 of the City’s Noise Ordinance is interpreted to mean that temporary noise events should not exceed 75 dBA at the residential property line. The City of Santa Monica’s Noise Ordinance (SMMC §4.12.110) restricts construction activity to the hours between 8:00 AM and 6:00 AM Monday through Friday; between 9:00 a.m. and 5:00 p.m. on Saturday; and does not allow construction activity to occur on Sunday or major national holidays. In general, the equivalent noise level during construction cannot exceed the standard on the receiving property, plus 20 dB (i.e., 85 dBA for Zone I during the daytime 5 minute continuous period). The maximum instantaneous noise level during construction cannot exceed the standard plus 40 dB (i.e., 100 dB for Zone I). However, construction-related noise exceeding these thresholds is permitted, provided that it is restricted to between the hours of 10:00 AM and 3:00 PM. For a discussion of temporary noise impacts associated with project construction see Section 4.1, Construction Effects.


Impact N-1 Operation of stationary equipment such as groundwater pumps and booster pumps associated with the proposed project would generate noise levels that may periodically be audible to existing uses near the project site. Impacts would be Class III, less than significant.

Charnock Well Field Operation of the project would result in an increase in ambient noise levels as a result of increased onsite activity, including pumps and other equipment, as well as routine maintenance that will include periodic delivery and pick up of various materials. Only about 11 vehicles are anticipated to access the site on a peak daily basis. Given this low level of operational traffic associated with the project, traffic noise is not expected to significantly change ambient noise conditions. The stationary sources of noise for this facility will be groundwater pumps and pumps used to transport treated water within the site and, eventually, off-site. Pumping of groundwater will occur from five groundwater production wells. The groundwater pumps will be located at each wellhead in self contained structures. In addition, transfer pumps and booster pumps will be used within the contact basin to pump treated water to an off-site treatment facility for additional treatment. Sump pumps will be used for secondary containment areas.

The Charnock well field includes five production wells, the oldest of which (well #13) was installed in 1966, and the newest of which (well #19) was installed in 1989. The locations of the five Charnock wells are shown in Section 2.0, Project Description, Figure 2-4. In addition, Section



2.0, Project Description, Figure 2-8, Photo 1, depicts groundwater Well #15. The wells are similar in design and size, however, the production varies from well to well. The Charnock groundwater wells have been out of service since 1996 so the pumps in the wells will need to be inspected, repaired, maintained, or replaced prior to commencing production from the Charnock well field. Each wellhead has one groundwater pump. While specific new pumps have not been designed for the site, the pumps located at the Charnock are expected to be similar to the Alfa Laval LKH-110. This pump was especially developed for applications with high pressure and low capacity requirements. This pump has a noise level rating (at 3 feet) of 60-80 dBA depending on mode of operation. Each well has an individual enclosed housing structure, roughly 5 feet by 5 feet. These structures are necessary for both safety and noise purposes. Each structure is constructed with wood, insulation and fiberglass. Generally these structures attenuate the pump sound levels by at least 20 to 25 dBA, depending on the design. As a result of the enclosure, a low hum or slight vibration is the only noticeable sound in the vicinity of the wellhead housing structures. Even at maximum sound level, the sound level immediately outside the enclosure would not be expected to exceed 60 dBA. Transfer and sump pumps will be required for the movement of water through the treatment processes. The Charnock facility will use up to 4 transfer pumps and 6 sump pumps. Additional pumps will be installed; however these will be stand-by pumps that will be operated only if the primary pump fails. The majority of these pumps will be small (10 horsepower [hp] or less) and be 10% or less operational. Two pumps will be 90% operational: a 150 hp transfer pump and a low powered (0.5 hp) sodium hypochlorite pump. The 150 hp water transfer pump will be located near the contact basin. A typical 150 hp turbine pump has a noise level rating (at 3 feet) of up to 85 dBA. This pump will be located within an enclosed concrete block masonry structure that will reduce the pump station noise by approximately 35-50 dBA. The EIR preparer, Rincon Consultants, has previously measured a 250 hp water well pump in a typical concrete structure for a 24-hour period (Crestview Mutual Water Company Alviso Drive well house) and determined a base sound level from the pump of about 49 dBA at 33 feet from the enclosure. The 0.5 hp sodium hypochlorite pump would typically have a maximum noise level of about 60 dBA at three feet from the pump, and would not be audible outside of the hypochlorite storage and feed building where it would be housed. Consequently, the pump noise levels at the Charnock site are anticipated to be below the City of Los Angeles criteria at the closest residential property line, approximately 100 feet from the nearest proposed facilities. Cumulative pump activity is also not anticipated to be significant. Depending on resident location, several of the pumps are behind other structures, which substantially decreases the noise from a particular pump at a residence. From a cumulative perspective, those residences that front Westminster Avenue would be exposed to noise from wellhead pumps No. 15, 18, and 19 and the transfer pump, with wellhead pumps 13 and 16 located behind buildings. Based on measured sound levels, the presence of the enclosures, and assuming 90% operational for a 24 hour basis, the sound level at the nearest residence caused by all pumps would be an Leq of 42 dBA, which would cause only about a 1 dBA sound level increase in the CNEL at the nearest residence (see Appendix F). Consequently, the cumulative pump noise levels are expected to be below the City of Los Angeles criteria at the closest residential property and pump noise levels



are compatible with the adjoining school and residential land uses (reference Table 4.7-1). Therefore, noise standards would not be exceeded and the noise impact associated with the proposed pumping activities would be less than significant. Site safety features may include alarm systems designed to alert operators of a change in operational conditions. These alarms, however, would be located within buildings, would be expected to occur rarely, and not expected to impact the adjacent land uses. Therefore, the noise from stationary onsite activities are not anticipated to be significant and would not be expected to exceed the City’s Noise Ordinance standards. In addition, alarms are exempted from the Noise Ordinance. Santa Monica Water Treatment Plant This site is currently occupied by an active water treatment facility. The proposed project would involve improvements to this facility including the construction of a new 7,500 square foot building and the addition of other new equipment to the current treatment processes. These improvements are not expected to generate any new employment positions and would not generate any new commuter traffic or related noise. Further the new stationary treatment equipment that would be employed at the site would be within enclosed structures or otherwise obstructed from potential sensitive receptors and would not be expected to generate any significant increase in noise levels on the site or in neighboring areas. Therefore, noise impacts related to new stationary noise sources are considered less than significant. Salt Water Wells The City is currently evaluating new treatment processes for the SMWTP and depending upon the ultimate treatment process selected up to two new salt water wells may need to be installed. The construction of these wells would be in the vicinity of the City’s two existing wells located west of the intersection of Pacific Street and Ocean Avenue. Well construction would take approximately 3-4 months. This schedule would also include the abandonment of the two existing wells.

Once installed, these facilities would require periodic maintenance, but would not result in any new employment positions or increases in commuter traffic or traffic noise. Each wellhead would be equipped with a pump and would be housed in a concrete 225 sf (15 ft by 15 ft) structure. A pump and treatment building is located on the eastern edge of the parking lot adjacent to the intersection of Pacific Street and Ocean Avenue. This building will continue to house a pump system and is expected to provide sodium hypochlorite treatment to the salt water. All equipment will be enclosed and not expected to radiate noise from beyond its structure. As a result, these facilities would not be expected to significantly increase noise levels or adversely affect sensitive noise receptors in the immediate project area. Therefore, noise impacts associated with new mobile and stationary noise sources are considered less than significant. Mitigation Measures. No mitigation measures are necessary as no significant impacts are anticipated.



Significance After Mitigation. Impacts related to project operational noise levels would

be less than significant. Impact N-2 Operation of mobile equipment such as truck transfer pumps

and compressors associated with the proposed project would generate noise levels that would periodically be audible to existing residences near the project site. Impacts would be Class II, significant but mitigable.

Onsite operations are expected to involve noise associated with deliveries and maintenance. A summary of the project noise sources are described below. Charnock Well Field The Charnock location would have up to 11 daily trips during a peak activity and would involve generation of up to 7 peak hour trips onto the local street system. From a quarterly perspective, site delivery activities (other than routine maintenance) would occur up to 21 times. Typical daily maintenance vehicles using the site would include automobiles and pick-up trucks. However, large heavy-duty trucks would access the site during the loading and unloading of carbon, the delivery of sodium hypochlorite, the delivery of sodium bisulfite, the removal of GAC backwash sludge and, possibly, GAC backwash water. Each of these activities would include movement on and off the site by the heavy-duty trucks and the use of either compressors or pumps during loading operations. Note that typical views of carbon and other delivery vehicles are shown on Section 2.0, Project Description, Figures 2-8 and 2-9. Noise measurements conducted of diesel truck loading operations at various locations (Knott’s Berry Farm, Home Depot, Stater Brothers distribution center) have been reported by Mestre Greve Associates (2004) and Bollard Acoustical Consultants (May 2007). These measurements confirmed that the noise levels associated with trucks accelerating (engine noise) and decelerating (engine and air break noise) during maneuvers around the loading dock generated the loudest noise levels by activity in the loading dock. The measurement data indicated that the majority of truck pass-bys have a maximum sound level in the range of 68 to 78 dBA (at 50 feet). The loudest truck measured was approximately 85 dBA at 50 feet. The average of the data was 71.6 dBA at 50 feet with a standard deviation of 4.5. The loudest truck measured was near to the maximum sound limit of 86 dBA at 50 feet set by the California Motor Vehicle Code for trucks operating at speeds less than 35 miles per hour (Section 23130). For comparison purposes, a garbage truck during loading operations is typically considered to cause sound levels up to 100 dBA within about 25 feet (94 dBA at 50 feet), though more typical levels are in the mid-80’s dBA at 50 feet. Garbage truck activities occur on a weekly basis in this area. In addition to the operation of the delivery truck in itself, the truck engines could be used to power pumps for the delivery of sodium hypochlorite and removal of backwash and sludge, while the GAC system requires the use of an air compressor that is typically located on the truck. Each delivery operation is described below.

Sodium Hypochlorite and Sodium Bisulfite – Sodium hypochlorite deliveries would be up to 1 per month using two trucks. Each delivery would be expected to last for approximately one



hour. An on-truck pump is used to offload the liquid into the onsite 6,000 gallon storage tank. Sodium bisulfite deliveries would be up to 1 per month using one truck. Each delivery would be expected to last for approximately one hour. An on-truck pump is used to offload the liquid into the onsite 5,000 gallon storage tank.

While the exact models for each use is not known, a typical truck engine, such as a Duetz 3L912D would be used by vendors for pumping and off-loading materials. For a 2300 rpm engine, the Duetz 3L912D is rated at 100 dBA at 1 meter (approximately 3 feet), which would result in about 80 dBA at 50 feet on a worst case basis. Considering distance attenuation, the maximum noise level at the nearest residential property line would be approximately 73 dBA during the 1 hour pumping period. While this sound level would not exceed the City of Los Angeles 75 dBA criteria for temporary construction activity, it would nonetheless be a source of nuisance noise once per month. In addition, it would exceed the City of Santa Monica’s criteria. On a time-weighted daily basis, one hour of pumping at this level would cause the daily CNEL to increase from about 55 dBA to 61 dBA, which exceeds the significance criteria of +5 dB provided in Table 4.7-4.

GAC Carbon – The Granulated Activated Carbon (GAC) carbon change out peak activity would be expected to occur 6-12 times per year during the peak concentration of MBTE at the well field (an approximate three year time period) or once per month, reducing in subsequent years as the change out frequency declines (see Table 2-1). The process involves one truck at a time, with 1 truck required per vessel, and a total of approximately six hours to complete the exchange process. The exchange process involves the replacement of carbon in only one vessel of a train, therefore four of the five trains would be changed at a time over a 3-4 day period. Each of the delivery or transport trucks will require mechanical features for their specific operations. While the exact models for each use is not known, the carbon transfer process typically uses a 185 cubic feet per minutes (cfm) compressor. Commonly used compressor manufacturers include Ingersoll-Rand and Sullair. These manufacturers’ models are produced to meet or be less than USEPA noise level regulations of 76 dBA at 7 meters (23 feet). Considering distance attenuation, the noise level at the nearest residential property line would be approximately 63 dBA. This would not exceed the City of Los Angeles 75 dBA criteria, nor the City of Santa Monica’s 65 dBA for Zone II (commercial use). However, if in operation for an 8-hour day basis, it would increase the local CNEL at the residences to about 60 dBA, which exceeds the significance criteria of +5 dB provided in Table 4.7-4.

GAC Backwash and Sludge – The GAC process will require periodic flushing with potable

water. The backwash water will be collected and stored in the two 30,000-gallon backwash storage tanks. Upon receipt of the results, the backwash water will either be: a) returned to the equalization tank and reused, b) discharged directly to the storm drain if the water quality complies with the NPDES permit for the site, c) treated prior to discharge, or d) disposed off-site. Off-site disposal would be transported to a State-licensed treatment and disposal facility. Off-site backwash water disposal, if necessary, is expected to occur once every two months. Once the backwash water has been drained from the backwash storage tanks, the settleable solids (i.e. sludge), which accumulate in the bottom of the tanks, will also be disposed off-site. This is expected to occur once per month. Sludge will be pumped out and loaded onto disposal trucks.



The backwash and sludge pump trucks utilize the truck engines for power, similar to the sodium hypochlorite trucks. Backwash water disposal, if necessary, is expected to occur once every two months. This operation is expected to last up to 3 hours. Sludge disposal is expected to occur once per month. The sludge operations are expected to last for approximately 2 hours. The activities described above would average 1-3 hours per activity and occur 2-3 days per month. The activities will be limited to during business hours (8 a.m. to 5 p.m.). As noted above, the pumps would cause neighborhood sound levels to increase substantially both during the pumping period and when considered over a 24-hour time-weighted period. This is considered a significant effect of the project. General parking lot noise, including the movement of vehicles through the parking area and the slamming of car doors, could also be audible to nearby sensitive receptors. Typical noise levels associated with various parking lot activities are summarizes in Table 4.7-5. It is anticipated that these noises would be infrequent due to the relatively low site activity. In addition, these noises would not exceed the City Noise Ordinance standard of 90 dBA for instantaneous noise. The movement of heavy duty trucks transporting materials to and from the site will also cause high noise levels (average of about 72 dBA) over a few second time period as the trucks move past the residences. Given the short duration of such movements and the relative infrequency of truck traffic to the site, impacts would be less than significant.

Table 4.7-5 Parking Lot Noise Sources at 100 Feet

Source Level (dBA) Car Horns 63

Door Slams 58

Talking 30

Radios 58

Tire Squeals 60

Source: Gordon Bricken & Associates, 1996. Estimates based on actual noise measurements taken at various parking lots.

Santa Monica Water Treatment Plant The SMWTP is a operational at all times (24/7/365 days a year). Depending upon the type of treatment systems ultimately employed at the facility, the improvements could result in a small increase in the number of vehicles for delivery of materials and waste disposal. This is expected to involve up to one to two trips per week depending upon the final design and treatment methods. This level of increased site activity would not result in any substantial changes to the current ambient noise environment at the site or the surrounding area and would not exceed established significance thresholds, or otherwise adversely affect sensitive receptors. Therefore, noise impacts associated with new mobile noise sources are considered less than significant.



Salt Water Wells The City is currently evaluating new treatment processes for the SMWTP and depending upon the ultimate treatment process selected up to two new salt water wells may need to be installed. The construction of these wells would be in the vicinity of the City’s two existing wells located west of the intersection of Pacific Street and Ocean Avenue. Well construction would take approximately 3-4 months. This schedule would also include the abandonment of the two existing wells. Once installed, these facilities would require periodic maintenance, but would not result in any new employment positions or increases in commuter traffic or traffic noise.

Mitigation Measures. Material loading and offloading within the site would cause a significant noise impact to the school facilities and the adjacent residential neighborhood. The following mitigation is recommended.

N-2(a) Portable Noise Barriers. Portable noise barriers made from acoustic

blankets (minimum STC of 25) at least eight feet in height shall be placed between the noise source on the off-loading trucks and the nearest residences and school buildings. Panels shall overlap and the blanket shall reach to and lie on the ground. The total length of panels shall be no less than 30 feet placed between the source and the receptor, and the panels shall be located no further than 10 feet from the source. The barriers will be designed and implemented such that an hourly Leq of 65 dBA will not be exceeded at the nearest residence.

N-2(b) Electric Air Compressor. An electric air compressor located in a sheltered

enclosure shall be provided onsite to provide the air pressure needed for GAC change out operations.

Significance After Mitigation. Impacts related to project operational noise levels would

be less than significant after implementation of the above mitigation measures.

c. Cumulative Impacts. The immediate project area is currently developed with residential and school uses. Other than the proposed project, no other pending projects are known that would cumulatively add substantial traffic or stationary noise to the project site or immediate area along Westminster Avenue.

Increases in traffic and other development in the City and greater Los Angeles community would add to the overall noise generated within the region; however the project would not have a cumulatively considerable contribution to any noise impacts that are known to exist in the immediate area. Thus, noise level increases due to cumulative traffic increase would be less than significant.




Charnock Well Field Restoration Project EIR Section 5.0 Long Term Impacts


5-1

5.0 LONG TERM IMPACTS The State CEQA Guidelines requires a discussion of a proposed project’s potential to foster economic or population growth, including ways in which a project could remove an obstacle to growth. Growth does not necessarily create significant physical changes to the environment. However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. The proposed project’s growth-inducing potential is therefore considered significant if it could result in significant physical effects in one or more environmental issue areas. The most commonly cited example of how an economic effect might create a physical change is where economic growth in one area could create blight conditions elsewhere by causing existing competitors to go out of business and the buildings to be left vacant. 5.1 ECONOMIC AND POPULATION GROWTH The project involves implementation of a water treatment system and other improvements that would help to remove groundwater contamination from the Charnock groundwater sub-basin and restore this resource as a water supply for the City of Santa Monica (City). As part of the project upgrades, improvements will be required at two existing City-operated water service facilities; the Charnock well field site and the Santa Monica Water Treatment Plant (SMWTP). In addition, two salt water wells may need to replace existing salt water wells located on Santa Monica beach. These sites are located in the western portion of Los Angeles County, in the City of Los Angeles. The proposed project would not involve the increase of population. The construction of the water treatment system will be a benefit to the region since it will be treating contaminated groundwater and improving the groundwater quality thereby increasing the local potable supply and reducing the reliance on imported groundwater. Construction activity associated with the project would generate temporary jobs. The project would not have economic or social effects that would result in adverse physical changes or deterioration of the surrounding area, as the area is currently developed with commercial and residential uses.

Mitigation Measures. None required. Residual Impacts. No significant environmental impacts relating to economic or

population growth are anticipated. 5.2 REMOVAL OF OBSTACLES TO GROWTH The proposed project would be located in the urbanized area of the City of Los Angeles, which is well-served by existing infrastructure. Because the project involves restoration of a former local water supply for the City of Santa Monica, it is not expected to remove an obstacle to growth in the City. The restoration of the Charnock well field would reduce the City’s reliance on imported water sources that it has used since the well field was taken out of production. In effect this could free up the current commitments to State water for other users to purchase to accommodate future growth. Alternatively, this additional water could be used to augment

Charnock Well Field Restoration Project EIR Section 5.0 Long Term Impacts


5-2

water supplies needed to address environmental needs within the overall water system. It is highly speculative to forecast how the Charnock well field restoration would facilitate new development or result in impacts related to growth. Minor improvements to electrical, water, sewer and drainage connection infrastructure may be needed to implement the proposed project. However, the project is in an urbanized area and would not require the extension of new infrastructure through an otherwise undeveloped area. In this regard project implementation would not remove an obstacle to growth.

Mitigation Measures. None required.

Residual Impacts. The implementation of the Charnock Well Field project will increase the availability of water to the State of California by restoring the use of a local groundwater source and reducing demands for State water. Given that the project would restore the ground water supply to its historical usage and because the service area is already highly urbanized, the project is not expected to generate significant environmental impacts relating to the removal of an obstacle to local population growth. The restoration of this historic groundwater source would in effect free up State water for productive use in other areas. However, it would be speculative to project whether this would result in growth inducement or negative environmental effects.

5.3 IRREVERSIBLE ENVIRONMENTAL EFFECTS The CEQA Guidelines require that EIRs evaluating projects involving amendments to public plans, ordinances, or policies contain a discussion of significant irreversible environmental change. While the project does not involve an amendment to a public plan or ordinance, CEQA also requires decision makers to balance the benefits of a proposed project against its unavoidable environmental risks in determining whether to approve a project. This section addresses non-renewable resources, the commitment of future generations to the proposed uses, and irreversible impacts associated with the proposed development. The Charnock and SMWTP sites are currently developed with water facility land uses. These locations will likely continue as water treatment facilities and would likely result in a long-term commitment of the sites to these operations. Development of the proposed project would not result in alteration of the urban built environment that would be irreversible. Construction of the new buildings would involve the use of building materials and energy, some of which are non-renewable resources. Consumption of these resources would occur with any development in the region and are not unique to the Charnock Well Field Restoration Project. Overall, the project is expected to reduce the need for electricity by restoration of a local water source and reduction of the City of Santa Monica’s reliance on the import of State water. The development of the proposed project would not increase the number of residential dwellings on the subject property and thus, would not increase population in the City of Los Angeles. Additionally, the project would not necessitate the need for more housing; and as a result, would not adversely affect available housing within the City of Los Angeles. The proposed project would not induce population growth that could irreversibly or adversely affect the environment.

Charnock Well Field Restoration Project EIR Section 6.0 Alternatives


6.0 ALTERNATIVES As required by Section 15126.6 of the State CEQA Guidelines, this EIR examines a range of reasonable alternatives to the proposed project. Four alternatives are analyzed: the CEQA-required “no project” alternative, a redesign of the project to lower the profile of the onsite equipment alternative, a redesign of the project to house the treatment vessels and onsite equipment within a building alternative, and the development of the treatment system project at the SMWTP alternative. In addition to these alternatives, this section includes a summary of the project treatment alternatives considered by the City of Santa Monica as part of the preliminary feasibility analysis. 6.1 CEQA ALTERNATIVES OVERVIEW CEQA Guidelines Section 15126.6 provides direction for the discussion of alternatives to the proposed project. This section requires:

• A description of “...a range of reasonable alternatives to the project, or to the location of a 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, and evaluate the comparative merits of the alternatives.” [15126.6(a)]

• A setting forth of alternatives that “...shall be limited to ones that would avoid or

substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project.” [15126.6(f)]

• A discussion of the "No Project" alternative, and “...If the environmentally

superior alternative is the "no project" alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” [15126.6(e)(2)]

• A discussion and analysis of alternative locations “…that would substantially

lessen any of the significant effects of the project need to be considered for inclusion in the EIR.” [15126.6(f)(2)(BA)]

The alternatives evaluation uses the "rule of reason" approach as discussed in CEQA (CEQA Guidelines Section 15126.6(f)). The rule of reason approach has been defined to require that EIRs address a range of feasible alternatives that have the potential to diminish or avoid adverse environmental impacts:

“The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project.” (CEQA Guidelines Section 15126.6(f))



In defining feasibility of alternatives, the CEQA Guidelines state:

“Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” (CEQA Guidelines Section 15126.6(f)(1))

Further, in addition to the evaluation of on-site alternatives, the evaluation of alternative sites is subject to consideration under CEQA. The California Supreme Court, in Citizens of Goleta Valley v. Board of Supervisors (1990), indicated that a discussion of alternative sites is needed if the project “may be feasibly accomplished in a successful manner considering the economic, environmental, social, and technological factors involved” at another site. As suggested in the Goleta case, several criteria form the basis of whether alternative sites need to be considered in detail. These criteria take the form of the following questions:

1. Could the size and other characteristics of another site physically accommodate the project?

2. Is another site reasonably available for acquisition? 3. Is the timing of carrying out development on an alternative site reasonable for the

applicant? 4. Is the project economically feasible on another site? 5. What are the land use designation(s) of alternative sites? 6. Does the lead agency have jurisdiction over alternative sites? 7. Are there any social, technological, or other factors that may make the consideration

of alternative sites infeasible? Based on input received during the public scoping process, project development at an alternative location was examined as part of this EIR. Alternative 6.7, SMWTP Alternative assumes that the treatment facilities proposed for the Charnock location would instead be constructed at the SMWTP site. The environmental effects of this alternative are examined in greater detail below. In addition, other alternative site locations were identified during the public scoping and were considered to determine whether they would offer reduced environmental effects and also met the criteria above. Sites that were referenced during the public review included the old Papermate facility on 26th and Olympic in Santa Monica and other possible suitable locations within the City of Santa Monica. Because of the nature of the project, as a groundwater clean up project, certain project features, such as the well field cannot be relocated to another site. Further, since the Charnock site has historically operated as a water treatment facility and is integrated into the City’s current water supply distribution infrastructure, all required piping systems are in place to convey treated groundwater to the SMWTP for final treatment and distribution into the City’s water system. Relocating the treatment components of the project to an alternative site not already part of the water distribution system is considered to be infeasible because it would require that this infrastructure be substantially modified. Similar to the SMWTP alternative, this would require the construction of new and separate water mains that



are dedicated to transferring only contaminated groundwater to the alternative treatment site as such water cannot be intermixed into the current drinking water system until decontaminated. In addition, in the event of an accidental release because of breakage of a water main, the contaminated water could then potentially contaminate another of the subbasins, requiring additional clean-up operations. The feasibility of right of way and other site acquisition is not known with certainty, but would be expected to substantially delay the project due to the increased technical and political complexity of this process. This would not be consistent with the project objective of restoring the Charnock ground water supply in an expeditious manner. In addition to these feasibility concerns and inconsistency with the project objectives, it would be highly likely that development at an alternative site would have many of the same environmental impacts of the project, with anticipated substantially greater construction effects (air quality, noise, and traffic impacts) expected due to the increased level of infrastructure required. For these reasons, further examination of these alternative locations is not required under CEQA. 6.2 PROJECT GROUNDWATER TREATMENT OPTIONS Several pilot tests for this project have been conducted since 1998 (included in Appendix G). As part of the technology selection and process evaluation for the Charnock well head treatment system, the pilot study results and the preliminary designs were reviewed with respect to their technical feasibility and their ability to comply with the objectives of the City’s Sustainable City Program. The main goals that were factored into the evaluation process were: resource conservation, environmental and public health, transportation and land use. Resource Conservation. This goal focuses on increasing the use of local, renewable, non-polluting renewable resources, and decreasing the consumption of non-local, non-renewable energy and non-recyclable materials. Two specific areas were evaluated: (1) use of a local, renewable water resource, and (2) use of a sustainable treatment technology. The City’s stated goal is to produce over 80% of its potable water supply from local, renewable resources, rather than relying on imported water to meet the City’s water needs. Returning the Charnock well field to full production is the center piece to achieve this goal. The use of local groundwater provides water to the City with a minimum expenditure of energy, prevents depletion of resources from other locations, and provides the City with self-reliance for its water. GAC treatment rated high for energy efficiency when compared against advanced oxidation processes (AOPs) or air stripping. Advanced oxidation using hydrogen peroxide in combination with ultraviolet light had been considered for use at the Charnock well field. However, this technology was eliminated from consideration for the following reasons:

• Energy usage. Ultraviolet light is energy intensive to produce, and is cost prohibitive relative to treatment using GAC.

• By-product formation. Treatment of MTBE and TBA using UV-peroxide may result in the formation of undesirable by-products, including formaldehyde and tertiary-butyl formate. Additional treatment using GAC would be required to ensure that all by-products are removed from the water prior to distribution.



GAC treatment generates low volumes of solid waste when influent concentrations are low. This is because few carbon changeouts are required when influent concentrations are low. As the influent concentrations increase, the volume of spent GAC produced also increases, however GAC can be recyclable at acceptable regulatory levels. One other source of solid waste generation occurs during backwash events which are performed as needed on the GAC vessels in order to remove excess biomass, flush out inorganic precipitates, or fluff up the downflow beds. This waste sludge will be transported off-site for disposal at an approved disposal facility. Environmental and Public Health. This criterion involves minimizing the use of hazardous or toxic chemicals, minimizing or eliminating the levels of pollutants entering the air, and minimizing or eliminating the risks that environmental problems pose to humans. GAC treatment rated high in this respect when compared against AOP systems which used high doses of hydrogen peroxide in conjunction with ultraviolet light. GAC treatment does not require the use of hazardous chemicals. Although GAC systems are quiet to operate, noise levels from pumps and air compressors are a potential concern to nearby residents. See the discussion in Section 4.7 regarding this issue. Open Space and Land Use/Housing. Compared to the alternative treatment options examined, GAC treatment rated high in this category due to the small footprint required. Section 6.6 below examines the possibility of placing the GAC vessels within a building. Section 6.5 below examines the possibility of lowering the elevation of the GAC vessels by constructing these vessels below ground surface. Additional geotechnical feasibility analysis would be necessary to confirm the feasibility of this alternative. Transportation. This criterion involves minimizing or eliminating motor vehicle-generated pollution and traffic congestion. For both the AOP and GAC treatment processes, truck deliveries were directly related to influent concentrations (i.e. higher MTBE, TBA, TCE and 1,1-DCE influent concentrations required more frequent chemical deliveries and more frequent carbon changeout). Based on the predicted influent concentrations, carbon changeouts are expected to occur no more frequently than once per month when the MBTE is at its highest concentration in the well field (a period of about three years; see Table 2-1). Summary. GAC and AOP processes are recognized treatment measures by the California Department of Public Health (DPH). Overall, the GAC treatment process rated higher than the AOP process which had relatively high power requirements and greater hazards associated with bulk chemical delivery and usage. 6.3 PROJECT ALTERNATIVES Table 6-1 provides a summary comparison of the development characteristics of the proposed project and the alternatives. A more detailed description of the alternatives is included in the impact analysis for each alternative. This section also includes a discussion of the environmentally superior alternative among those studied.



Table 6-1 Project Development Characteristics

Feature Proposed Project

No Project (Existing

Conditions)

Reduced Profile Alternative

Equipment Housing

Alternative SMWTP Project

Construction Period 6-12 Months 0 12-24 months 12 -18 months 12-18 months

GAC Vessel Height (above

ground) 24 feet 0 2 feet 27 feet 24 feet

Average Daily Trips (ADT) – Peak Activity

Charnock (up to 12 trips)

SMWTP (up to 4 trips)

0







6.4 NO PROJECT ALTERNATIVE 6.4.1 Description The no project alternative assumes that the proposed project would not be constructed. The existing water treatment structures as well as associated groundwater wells would remain in their current condition. The site locations would remain in their current condition and the existing structures and existing uses would remain in place. 6.4.2 Impact Analysis No change in environmental conditions would occur under this alternative because no new development would occur. In addition, the project’s potentially significant but mitigable impacts for aesthetics, construction, geological, hazards and hazardous material, hydrology and water quality and noise would be avoided. However, the no project alternative would have several significant adverse impacts. The primary impact related to this alternative would be the continued energy consumption from pumping imported water to the City. Water use in California consumes significant amounts of electrical energy. Preliminary estimates indicate that total energy used to pump and treat water in the state exceeds 15,000 GWh per year, or at least 6.5 percent of the total electricity used in the State per year (California Energy Commission, Water Energy Use in California, 2004). This energy use is expected to increase due to growing population, increasing reuse of wastewater, the remoteness or lower quality of alternative water sources, and increasingly stringent treatment requirements due to variety of water quality and environmental protection concerns. Currently the City of Santa Monica receives over 80% of its drinking water from the State Water Project and the Colorado River via the Metropolitan Water District. The movement of these water sources is energy intensive. A stated goal of the Charnock project is to increase groundwater production so that approximately 80% of the City’s drinking water is obtained from local resources. While the project will require energy for the pumping and treating of



groundwater, the energy consumption will be significantly less than the energy required to import water from distance locations. In addition, the City plans as part of the proposed project to implement energy saving methodologies for the groundwater extraction including:

• Variable frequency drives • Energy efficient motors • Lighting improvements • Heating, cooling and ventilation improvements • Electrical load management strategies

Given these project measures and the switch from importing water to local groundwater, the “no project” alternative would be considered to have greater impacts with respect to continued energy consumption and its associated emissions of air pollutants, including greenhouse gases (GHGs). Imported water also is primarily derived from surface water flows from the Colorado River and the State Water Project (SWP), which diverts surface water primarily from the Feather, Sacramento, and San Joaquin Rivers. SWP diversions, particularly in drought years, have had substantial biological impacts on fish and wildlife resources of the Sacramento-San Joaquin Delta area, as well as on upstream riparian and in-stream habitat. Continued reliance on imported water results in continued cumulative impacts on biological resources. In addition, this alternative would not result in clean up of the Charnock groundwater sub basin. The State of California drinking water supply has been severely impacted due to increased demands, drought and curtailments from recent court decisions. A portion of the supply provided to Santa Monica through the MWD is derived from Colorado River flows, which have been over-allocated. In 2003, the federal government determined that MWD had 15 years to reduce their diversion and find other sources of water. The proposed project is vital as it is resurrecting a significant local water resource and it will remediate the contaminated groundwater. The project also ensures a water source if MWD water becomes unavailable due to natural or manmade disaster. As a result, the no project alternative would have greater impacts than the project with reference to groundwater quality, water supply, and energy resources usage. It would also not aid in accomplishing the City’s long range sustainability objectives. 6.5 REDUCED PROFILE ALTERNATIVE 6.5.1 Description The Reduced Project Profile alternative would involve lowering the 15 water treatment vessels about 22 feet below ground surface. Under this alternative, the top of the proposed 24-foot water treatment vessels would be approximately 2 feet above ground surface. The treatment vessels would remain in their current proposed location. It is noted that this alternative has been developed primarily to reduce the visual impacts associated with the project in response to public input received during the project scoping to lower the profile of the GAC vessels by placing them at least partially underground. This alternative does not involve complete subsurface development of all elements of the project because of the increased environmental impacts that would be associated with full site excavation. All other project aspects would remain the same. This alternative would not affect the anticipated construction activities at two



other proposed project locations, the SMWTP and the salt water wells. Operations at those sites would also remain the same. Note that in response to input received during the DEIR public review process the City has updated the design of the project, including the Charnock facility to lower the profile of the onsite equipment by placing some of the tankage underground and reducing the height of the carbon vessels from 24 feet to 15 feet. The updated project design and a comparison of its impacts to the DEIR project analysis is detailed in Appendix I. 6.5.2 Impact Analysis a. Aesthetics Effects. This alternative would have reduced aesthetics effects compared to the proposed project. The reduced profile alternative would visually reduce the impacts of the water treatment vessels. The 24 foot vessels would be installed about 22 feet below grade. Other structures such as the existing contact basin, the existing pump house and the proposed storage tanks would remain in their project proposed locations. Under this alternative the tops of the GAC vessels and other onsite equipment, including the current 14’ pump house and 14’ contact basin, proposed 14’ tall backwash storage tanks and 14’ tall equalization tank, would retain some level of visibility. Visual impacts resulting from this alternative would be substantially reduced compared to the project but, as with the project, some additional screening and other measures to help reduce the visual effects and enhance the visual compatibility with the existing neighborhood would be required. This alternative is considered visually superior to the proposed project. b. Construction Effects. This alternative would increase construction effects compared to those associated with the proposed project as the reduced project profile alternative would require soil excavation in addition to the subterranean construction of the treatment vessel containment area. The excavation would encompass an area of 60’x 100’. An approximate total of 9,000 cubic yards of soil excavation would be required for the vessel containment area. This would require approximately 580 truck loads of soil to be removed from the site. Since the Charnock location would not be able to accommodate soil stockpiling, approximately 4,000 cubic yards will need to be returned to the site for backfilling. This process will require approximately 260 truck loads of soil. In total, this alternative would involve about 1,680 one way truck trips during the course of the construction period. Additional construction could include pile driving for shoring, which could have significant noise and vibration impacts. A significant increase of construction related activities including noise, traffic and air quality would occur. In addition, the overall construction period would be longer than the proposed project. The additional construction would require 6-12 additional months to complete this individual task. The total estimated construction period would 12-24 months. As with the proposed project, impacts related to temporary changes in traffic patterns, noise, and air quality would be significant but mitigable. As such, the measures identified in the EIR to mitigate construction effects would apply. c. Geology. This alternative would increase the geological impacts at the Charncok location compared to the proposed project as it would involve substantial site modification. A geotechnical feasiblity analysis would need to be performed due to confirm the feasibility and



determine the subterranean construction methods required for this alternative. This feasibility analysis would assess the on-site geology and soils as well as the constructability of this alternative. As with the proposed project, geology impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. d. Hazards and Hazardous Materials. This alternative would not be materially different from the proposed project from an hazards and hazardous materials perspective. Operational procedures may be changed to accommodate the revised site configuration but it would not be expected to materially affect the use or storage of chemicals onsite. As with the proposed project, hazards and hazardous materials impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. e. Hydrology and Water Quality. This alternative would have similar water qualtiy and hydrologic effects as compared to the proposed project. Some operational procedures, such as additional storm water pumping, would change under this alternative but these changes would not be expected to substantially affect project hydrology or water quality. As with the proposed project, hydrology and water quality impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. This alternative would have similar hydrology and water quality impacts to those described for the proposed project.

f. Neighborhood Effects. This alternative would reduce neighborhood effects in the long term compared to the proposed project. This would be due to the reduced visual impact. The water treatment vessels would be 22 feet lower than the proposed project. However, in the short term, as discussed above, the reduced project profile alternative would result in a longer construction period and would involve greater construction impacts than the proposed project. Temporary construction-related traffic and noise resulting from this alternative would result in significant but mitigable impacts that would require the implementation of the same mitigation measures described for the project. Some increases in noise may occur due to additional sump pump (for storm water) requirements, however the overall effects are expected to be similar to the proposed project and any noise increase resulting from this alternative would require the implementation of the same mitigation measures described for the project. g. Noise. This alternative would essentially have the same long term operational noise impacts as those of the proposed project. Operational noises at the wellhead and during the delivery of materials would be the same as the proposed project. Construction noise would be substantially greater with this alternative due to the site grading equipment and the import and and export of soils that would be required. This alternative would also lengthen the construction schedule and the time during which the construction impacts would occur. As described above, increases in operational noise may occur due to additional sump pump requirements (related to storm water events), however the overall effects are expected to be similar to the proposed project and any noise increase resulting from this alternative would require the implementation of the same mitigation measures described for the project. This alterrnative is considered similar to the proposed project from an operational noise perspective and inferior to the proposed project from a construction noise perspective. Additional construction noise mitigation would be necessary for this alternative depending on the the type of foundation determined to be necessary.



6.6 EQUIPMENT HOUSING ALTERNATIVE 6.6.1 Description The Equipment Housing Alternative would involve the construction of a structure to enclose the onsite equipment at the Charnock site. This structure would be designed to contain the 15 water treatment vessels, backwash storage tanks, the equalization tank, the control room, the electrical room and the hypochlorite storage room. The proposed structure would be approximately 7,050 square feet and have an overall height of approximately 27 feet. All other project aspects would remain the same. This alternative would not affect the two other proposed project locations, the SMWTP and the salt water wells. Operations at the sites would essentially remain the same. 6.6.2 Impact Analysis a. Aesthetics Effects. This alternative would change the visual appearance of the project from one of an industrial appearance with visible vessels and tankage to a single rectangular structure. This structure would be approximatly 7,050 square feet and 27 feet tall. This structure would encompass an area roughly twice the size of the proposed vessel area and would be about 3 feet taller (to allow proper clearance and building ventilation). This proposed structure would have a greater massing than the project, however, to some this structure would be more visually compatible with the current neighborhood character (as a rectangular building) than the appearance of the proposed project. In addition, design and color features of the stucture could be incorporated to reduce the visual impacts. Because of the greater size of this structure, this alternative is considered to have similar but slightly greater visual impacts compared to the proposed project. As with the proposed project, visual impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. b. Construction Effects. This alternative would increase construction effects compared to those associated with the proposed project as the Equipment Housing Alternative would require additional construction for the structure. An increase of construction related activities including noise, traffic and air quality would occur. In addition, the overall construction period would be longer than the proposed project. The additional construction would require up to 6 additional months when compared to the proposed project. The total estimated construction period would 12-18 months. As with the proposed project, impacts related to temporary changes in traffic, noise, and air quality would be significant but mitigable. As such, the measures identified in the EIR to mitigate construction effects would apply. This alternative is considered similar but slightly inferior to the proposed project with respect to construction effects. c. Geology. This alternative would have similar geologic impacts as those described for the proposed project. As with the proposed project, geology impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. d. Hazards and Hazardous Materials. This alternative would not greatly effect the operation of the Charnock facility compared to the proposed project. Some amount of operational procedures would be changed but it would not affect the the use and storage of



chemicals onsite. As with the proposed project, hazards and hazardous materials impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. e. Hydrology and Water Quality. This alternative would not substantially change onsite operations and would have similar hydrology and water quality impacts as described for the proposed project. As with the proposed project, hydrology and water quality impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. f. Neighborhood Effects. This alternative would have greater neighborhood effects when compared to the proposed project. This would be due to the increased visual impact associated with the larger structure that would be developed on the site and the increased construction period than would be required. The temporary construction-related traffic and noise resulting from this alternative would result in significant but mitigable impacts and require the implementation of the same mitigation measures described for the proposed project. In addition, as with the proposed project, visual impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. g. Noise. This alternative would essentially have the same noise impacts as those of the proposed project, with the exception of construction noise which would be slightly greater than the proposed project because of the longer construction schedule. Some stationary source noise may be reduced due to the enclosed structure, however these noise levels would be expected to be similar noise levels associated with the project, although migitation may be slighly greater for the project. Noise impacts for this alternative would be less than significant after mitigation. 6.7 SMWTP ALTERNATIVE 6.7.1 Description The SMWTP alternative involves development of the proposed Charnock treatment facility at the SMWTP. It would involve use of the Charnock well field to extract the contaminated groundwater and transport of the MTBE contaminated groundwater to the SMWTP for treatment. This alternative would also involve the need to construct additional pipeline facilities in order to separate the uncontaminated water generated from onsite Charnock wells and the water generated from the contaminated wells. It is assumed that this additional infrastructure could be developed within the same right of way as the current pipeline connections between these two facilities. The California Department of Public Health (DPH) would need to review and approve this treatment methodology and the new proposed project. If approved, the groundwater would be pumped from the existing groundwater wells located at the Charnock facility. The groundwater would then be pumped to the existing contact basin, treated with sodium hypochlorite and then pumped via an existing water distribution pipeline to the SMWTP. The GAC treatment for the contaminated groundwater would occur at the SMWTP. All equipment related to this treatment technology would occur at the SMWTP. The existing facilities at the Charnock location would need to be upgraded and possibly reconfigured as part of this



alternative. These onsite features include the groundwater pumps, booster pumps and pipelines. The existing chlorine building would be moved to the proposed location, on the eastern portion of the property. 6.7.2 Impact Analysis a. Aesthetics Effects. This alternative would essentially transfer the visual impacts associated with the project at the Charnock site to the SMWTP site. This would increase the visual impacts for residences adjoing the SMWTP (on the east and south) and reduce them for uses adjoining the Charnock facility. The 24-foot water treatment vessels and other tankage would result in similar visual impacts at the SMWTP as those described for the proposed project. While the SMWTP facility is a fully operational water treatment plant with significant water treatment features including a 5 million gallon reservior, contact basin and control building, the project would be require new facilties, including the 15 24-foot vessels. Visual impacts resulting from this alternative would be similar to the project, although transferred to a different location, and would require mitigation to reduce impacts to a less than significant level. b. Construction Effects. This alternative would transfer construction related impacts of the project from the Charnock location to the SMWTP site. This would result in a decrease the construction effects at the Charnock facility and an increase in the construciton impacts at the SMWTP compared to the proposed project. An increase of construction related activities including noise, traffic and air quality would occur at the SMWTP. In addition, the overall construction period would be longer than the proposed project. This alternative would also require pipeline infrastructure improvements along the current right of way in order to keep the uncontaminated water generated from the Charnock wells separate from that of the contaminated wells. As with the proposed project, impacts related to temporary changes in traffic, noise, and air quality would be significant but mitigable. The construciton effects of this alternative are considered to be similar to the proposed project and the measures identified to mitigate construction effects of the proposed project would also apply to this alternative. c. Geology. This alternative would involve similar geologic impacts to the proposed project. Since the SMWTP is located within a potential liquefaction area, a geolotechnical design analysis will need to be performed to develop the need for project specific design parameters. As with the proposed project, geology impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. d. Hazards and Hazardous Materials. In general, this alternative would involve similar effects to the project with respect to hazards and hazardous materials. This alternative would reduce these effects at the Charnock facility and relocate them to the SMWTP area. However, this alternative is considered inferior to the project in that it would involve transport of contaminant impacted groundwater from the Charnock area to the SMWTP treatment site. This involves a greater risk of upset from a pipeline leak than the project as it would increase the extent to which the contaminated material would be transported compared to the proposed project. As with the proposed project, hazards and hazardous materials impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level.



e. Hydrology and Water Quality. The SMWTP alternative would require DPH approval to pump the MTBE contaminted groundwater from the Charnock facility to the SMWTP facility. This would increase the hydrology and water quality impacts for this alternative compared to the project. The operational procedures for both locations would be changed but not materially different than those expected for the proposed project. Similar to the project, hydrology and water quality impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level. As noted, this alternative would be subject to DPH approval and may not be feasible from a regulatory perspective. f. Neighborhood Effects. This alternative would transfer the project’s neighborhood effects from the Charnock site to the SMWTP area and would also involve additional effects along the infrastructure corridor. This would result in decreased neighborhood effects for the Charnock location when compared to the proposed project. This would be due to the decreased visual impact and the decreased construction period than would be required for the proposed project. The impacts for the SMWTP and along the infrastructure improvement corridor would increase due the longer construction period required and the increased visual effects that would occur. Similar to the project, temporary construction-related traffic and noise resulting from this alternative would result in significant but mitigable impacts that would require the implementation of the same mitigation measures described in the EIR. In addition, as with the proposed project, visual impacts resulting from this alternative would require mitigation to reduce impacts to a less than significant level.

g. Noise. This alternative would essentially have the same noise impacts as those of the proposed project. Construction noise at the SMWTP would increase whereas the noise impacts at the Charnock facility would decrease. Operation of the facilities under this alternative would be expected to generate similar noise levels compared to the proposed project although the setback distances to sensitive uses at the SMWTP would be expected to be somewhat greater than those available at Charnock. The noise effects would decrease at Charnock due to less operation maintanence and overall activity. The noise effect would increase at the SMWTP and during construction along the infrastructure improvement corridor, as these actvities would be shifted to this location. The same mitigation measures would be required to reduce impacts to a less than significant level. 6.8 ENVIRONMENTALLY SUPERIOR ALTERNATIVE This section discusses the environmentally superior alternative. Table 6-2 summarizes impacts for each of the alternatives considered in this analysis and compares them to the proposed project. The No Project alternative would involve no new construction. However, this alternative would contine the practice of importing drinking water. This alternative also would not accomplish the City’s objectives to restore the groundwater conditions within the Charnock subbasin, provide the beneficial use of local groundwater, reduce City reliance on State water and conserve energy resources. None of the project alternatives is clearly environmentally superior to the proposed project, including the no project alternative. The no project alternative fails to meet the stated objectives



of the project and results in continued cumulative significant energy, air pollution, and biological resources impacts associated with the use of imported water. The other alternatives involve tradeoffs between impact areas. The reduced project profile alternative is considered the environmentally preferred alternative of those considered.

Table 6-2 Impact Comparison of Alternatives *

Issue Addressed in EIR Proposed Project

No Project **

Reduced Profile

Alternative

Equipment Housing

Alternative

SMWTP Only

Aesthetics = + + - +/-

Construction Effects = + - - +/-

Geology = + - = =

Hazards and Hazardous Materials = + = = =

Hydrology and Water Quality = +/- = = -

Neighborhood Effects = + +/- - +/-

Noise = + = = =

+ Superior to the proposed project (reduced level of impact) - Inferior to the proposed project (increased level of impact) +/- Characteristics both better and worse than the proposed project = Similar level of impact to the proposed project * Please note that if the proposed project’s impact is below the threshold of significance, the fact the alternative is even further below the impact threshold doesn’t make it environmentally superior. ** Please note that the “No Project” Alternative has impacts asociated with the continued reliance on imported water not specifically addressed as an issue area in this EIR.

This alternative would reduce visual impacts but would substantially increase impacts related to geologic and construction impacts. Specifically, construction impacts related to noise, air pollution, and traffic would increase due to the extended construction schedule. The vessel housing alternative would result in increased visual impacts and increased construction impacts. The SMWTP alternative would decrease aesthetic, construction and noise effects at the Charnock location; however it would increase these same impacts at the SMWTP and along the interconnecting pipeline infrastructure corridor. In addition, this alternative would increase potential risk of upset and hydrology and water quality impacts due to the transport of contaminant impacted groundwater over greater distances from Charnock to the SMWTP. This alternative would be subject to DPH approval and may not be feasible from a regulatory perspective. Note that the proposed project has been revised in response to public input received during the public review period on the Draft EIR. The updated project design reduces the profile of the Charnock equipment by placing some of the proposed tankage underground and reconfiguring the onsite equipment. The updated project design is fully described and analyzed in Appendix I. The updated project design involves partial burial of the proposed carbon vessels, which reduces the visual effects of the revised project when compared to the DEIR project description. This alternative also reduces excavation and subsequent construction impacts when compared to the Reduced Profile Alternative described above. The updated project design would be



buried nine feet rather than 22 feet as examined in the DEIR Reduced Profile Alternative (see above analysis).

Charnock Well Field Restoration Project EIR Section 7.0 References and Report Preparers


7.0 REFERENCES AND REPORT PREPARERS 7.1 REFERENCES American Water Works Association Standards. December 2007. Volume 10, No. 2. Bass, Ronald E., Herson, Albert I., Bogdan, Kenneth M, (ed.), CEQA Deskbook, 1999, 2001

Supplement, November 2000. Bollard Acoustical Consultants, May 2007. Environmental Noise Assessment, Home Depot Project. Bolt, Beranek, and Newman, Noise from Construction Equipment and Operations, Building

Equipment, and Home Appliances, prepared for the US EPA, 1971. California Air Resources Board, Air Quality and Meteorological Information System, http://www.arb.ca.gov/aqd/aqinfo.htm, accessed December 2007. California Air Resources Board, Quality Assurance Air Monitoring Site Information, http://www.arb.ca.gov/qaweb/sitelist_create.php, accessed December 2007. California Air Resources Board, URBEMIS 2007, Version 9.2.2. California Department of Conservation, Division of Mines and Geology, 1999, Seismic Hazard

Zone Map, Beverly Hills 7.5-minute Quadrangle, Los Angeles County, California, Released March 25, 1999. Map is available online at http://gmw.consrv.ca.gov/shmp/download/pdf/ozn_bevh.pdf

California Department of Water Resources. October 29, 2008. Notice to State Water Project

Constractors. No. 08-07. 2009 State Water Project Initial Allocation. California Energy Commission, Water Energy Use in California, 2004. Dibblee, T. W. Jr., 1992, Geologic Map of the Beverly Hills and Van Nuys (South ½) Quadrangles, Los

Angeles County, California, Dibblee Geological Foundation. Environmental Protection Agency website, accessed June 2008 at

http://www.epa.gov/region09/mtbe/charnock/reginvestigation.html Federal Emergency Management Agency, The National Flood Insurance Program Community

Status Book, available online at http://www.fema.gov/fema/csb.shtm, accessed December 2007.

Google Earth, December 2007. Kennedy Jenks Consultants Inc. 2000. Treatment Technology Performance Report Charnock Sub-

Basin Los Angeles, California.



Komex H2O Science Inc. 2001. Demonstration Test Report, Production Aquifer Remediation System, Arcadia Well Field, Santa Monica Water Treatment Plant and Former Mobil Station 18-LDM.

Los Angeles, City of, Buereu of Engineering Naviagte LA website, accessed June 2008 at

http://navigatela.lacity.org/index01.htm Los Angeles, City of, Department of Building and Safety website, accessed December 2007. Los Angeles, City of, Noise Ordinance, Chapter XI, updated 2004. Los Angeles, City of, Safety Element of General Plan, 1996. McCulloch, D.S. Evaluating Tsunami Potential. In Ziony (Ed.), Evaluating Earthquake Hazards in

the Los Angeles Region, An Earth-Science Perspective (pp. 374-413). U.S. Geological Survey, Professional Paper 1360, 1985.

Mestre Greve Associates, Inc., September 2004. Noise Assessment for: Wal-Mart Retail Store, City of

Lemoore. National Institute for Occupational Safety and Health, September 2007. NIOSH Pocket Guide to

Chemical Hazards. http://www.cdc.gov/niosh/npg/default.html DHHS (NIOSH) Pub. No. 2005-149.

National Science Foundation Standard 50. Santa Monica, City of, Environmental Programs Division 2002 Water Efficiency Strategic Plan,

2002. Santa Monica, City of, Municipal Code, available on-line at http://www.codemanage.com/

santamonica/, accessed December 2007. Santa Monica, City of, Master Environmental Assessment Update, 2002.

Santa Monica, City of, Noise Element, 1992. Santa Monica, City of, Noise Ordinance, updated 2004.

Santa Monica, City of, Official Homepage http://santa-monica.org, accessed December 2007. Santa Monica, City of, Safety Element, 1995. Santa Monica, City of, Safety Element EIR, 1995. State of California Department of Public Health. November 5, 1997. Policy Memorandum 97-005

for the Direct Domestic Use of Extremely Impaired Sources of Drinking Water. U.S. Fish and Wildlife Service, Region 1, Western Snowy Plover (Charadrius alesandrinus nivosus)

Pacific Coast Population Draft Recovery Plan, May 2001.



WorleyParsons Komex. July 2007. Preliminary Design Report, Charnock Well Field Drinking Water

Treatment Facility Santa Monica, California. 7.2 REPORT PREPARERS This EIR was prepared by Rincon Consultants, Inc., under contract to the City of Santa Monica Department of Public Works. Consultant staff involved in the preparation of the EIR is listed below. Rincon Consultants, Inc. Michael P. Gialketsis, REA, Vice-President Duane Vander Pluym, DESE, Vice-President John Onkka, Associate Environmental Planner Kathy Babcock, Graphics Technician Katie Stanulis, Production Coordinator




Charnock Well Field Restoration Project EIR 8.0 Comments and Responses


8.0 COMMENTS and RESPONSES This section of the EIR for the Charnock Well Field Restoration Project contains all of the written comments received in response to the EIR during the 45-day public review period of August 18, 2008, through October 1, 2008. Each comment received by the City of Santa Monica has been included within this report. Responses to all comments have been prepared to address the concerns raised by the commenters and to indicate where and how the EIR addresses environmental issues. Specific comments contained within any particular written response have been numbered in order to provide a reference to it in the response. Each comment letter is presented first, with the responses following. COMMENTERS on the DRAFT EIR The City of Santa Monica received 8 written comments on the Draft EIR. These letters are listed as follows and will be used for referencing in this section.

Commenter Page 1. Sarah Crompton 8-9 2. Dave Singleton, Program Analyst, Native American Heritage

Commission 8-11

3. Rob Kadota, Chair, Mar Vista Community Council 8-15 4. John and Donna Jones 8-25 5. Stephen W. Kierman, Director Facilities and Operations,

Windward School 8-34

6. Bill Rosendahl, City of Los Angeles, 11th District Councilmember 8-42 7. Thomas M. Erb, Director of Water Resources, Los Angeles

Department of Water and Power 8-45

8. Terry Roberts, Senior Planner, State Clearinghouse 8-50

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The following General Responses have been prepared to address similar themes in the responses submitted by commenters. The responses are all pertaining to the Charnock location unless otherwise noted. General Response 1 – Alternative Sites Several commenters stated that the Draft EIR did not sufficiently address or examine the potential use of an alternative site that would be located in Santa Monica, rather than at the site of the existing facilities, which is within the City of Los Angeles. As discussed within the EIR and the alternatives section, this project is critical to meet the water supply needs of the City and to reduce the region’s dependency on imported drinking water. In June 2008, the Governor of California issued an executive order declaring a statewide drought, which directed his state agencies and departments to take immediate action to address the serious drought conditions and water delivery reductions that exist in California. Moreover, on October 30, 2008 the Department of Water Resources (DWR) announced an initial allocation of 15 percent for water delivery to the State Water Project (SWP) contractors in 2009 (DWR, October 29, 2008). The allocation is the second lowest in the history of the SWP and reflects the low carryover storage levels in the state's major reservoirs, ongoing drought conditions and court ordered restrictions on water deliveries from the Delta (DWR, October 29, 2008). The lowest initial allocation figure was 10 percent of SWP Contractors' requests in 1993, but that number was increased to 100 percent during the water year as conditions developed (DWR, October 29, 2008). Last year, the initial figure was 25 percent and it was increased to 35 percent (DWR, October 29, 2008). The Charnock Well Field Restoration Project will restore over 80% of the drinking water supplies for the City of Santa Monica, allowing the City to decrease dependence on imported water supplies such as SWP supplies that are sold through Metropolitan Water District. The EIR alternatives evaluation uses the "rule of reason" approach as discussed in CEQA (CEQA Guidelines Section 15126.6(f)). The rule of reason approach has been defined to require that EIRs address a range of feasible alternatives that have the potential to diminish or avoid adverse environmental impacts:

“The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project.” (CEQA Guidelines Section 15126.6(f))

In defining feasibility of alternatives, the CEQA Guidelines state:

“Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” (CEQA Guidelines Section 15126.6(f)(1))

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Further, in addition to the evaluation of on-site alternatives, the evaluation of alternative sites is subject to consideration under CEQA. The California Supreme Court, in Citizens of Goleta Valley v. Board of Supervisors (1990), indicated that a discussion of alternative sites is needed if the project “may be feasibly accomplished in a successful manner considering the economic, environmental, social, and technological factors involved” at another site. As suggested in the Goleta case, several criteria form the basis of whether alternative sites need to be considered in detail. These criteria take the form of the following questions:

1. Could the size and other characteristics of another site physically accommodate the project?

2. Is another site reasonably available for acquisition? 3. Is the timing of carrying out development on an alternative site reasonable for the

applicant? 4. Is the project economically feasible on another site? 5. What are the land use designation(s) of alternative sites? 6. Does the lead agency have jurisdiction over alternative sites? 7. Are there any social, technological, or other factors that may make the consideration

of alternative sites infeasible? Based on input received during the public scoping process, Section 6.0, Alternatives, of the EIR the City of Santa Monica analyzed several project alternatives including alternative site locations. The analysis examined one specific location, the Santa Monica Water Treatment Plant (SMWTP), and also examined the concept of locating the project at a general as-yet undetermined site somewhere within the City of Santa Monica. Because the project involves groundwater clean up (remediation) and reactivation of an existing groundwater production facility, certain project features, such as the well field and groundwater contamination plume are site specific and cannot be relocated to another site. Further, since the Charnock site has historically operated as a water treatment facility and is integrated into the City’s current water supply distribution infrastructure, all required piping systems are in place to convey treated groundwater to the SMWTP for final treatment and distribution into the City’s water system. Under the proposed project, all remediation treatment activities would be conducted at the existing Charnock pumping facility, and only clean decontaminated water would be routed from the site within existing piping for final treatment and distribution at the SMWTP. Relocating the remediation treatment components of the project to an alternative site not already part of the water distribution system is considered to be infeasible because it would require construction of new piping to convey untreated contaminated water to another treatment location. This would involve miles of additional piping installation. The SMWTP is located about four miles northwest (Sawtelle Boulevard to West Olympic Boulevard to Bundy Drive). A site other than the SMWTP would require piping to deliver the contaminated water from the Charnock site to the remediation site and piping to transmit the clean water to the SMWTP. Moreover, it should be emphasized that the remediation treatment process is not permanent, but is rather anticipated to require between seven and ten years to complete. Following treatment, the piping would no longer be necessary and would need to either be abandoned or removed. Lastly, even if the remediation treatment components were relocated

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to another facility, the groundwater extraction operations would still occur at the Charnock facility, as this is the location of the well field, currently consisting of five groundwater production wells, a contact basin, a booster station, a Metropolitan Water District turnout, a chlorine building, a power substation, a control room and City of Santa Monica storage yards. Alternative site development for groundwater remediation would require the construction of new and separate piping, dedicated to transferring only contaminated groundwater to the alternative treatment site, as such water cannot be intermixed into the current drinking water system until decontaminated. The new piping would need to be installed within the right-of-way and it is not certain whether adequate space within the right-of-way exists to accommodate the new piping. The existing right-of-way contains infrastructure for conveyance of other utilities including water, wastewater, electricity, natural gas and others. In addition, in the event of an accidental release during conveyance, the contaminated water could then potentially contaminate other areas, requiring additional clean-up operations. The feasibility of right of way and other site acquisition is not known with certainty, but would be expected to delay the project due to the increased technical and political complexity of this process. This delay would have an overall negative effect on the region’s water supply. Substantial delays would not be consistent with the project objective of restoring the Charnock ground water supply in an expeditious manner. In addition to these feasibility concerns and inconsistency with the project objectives, it would be highly likely that development at an alternative site would have many of the same environmental impacts of the project, with anticipated substantially greater construction effects (air quality, noise, and traffic impacts) expected due to the increased level of infrastructure required. Adverse environmental effects would merely be transferred to a different area, but would not be reduced or eliminated. Moreover, it should be emphasized that all physical environmental effects of the project as proposed can be mitigated to levels that are less than significant. General Response 2 - Aesthetics Several comments suggested that the visual impact of the Charnock location was not fully addressed. Section 4.1, Aesthetics, discusses the project impacts related to general appearance of the project and its potential to result in significant visual impacts. The analysis performed in this section looked at both the impacts related to the proposed structures and uses criteria available from local zoning to help establish impact thresholds for the project. The Charnock site is within the Mar Vista Community of the City of Los Angeles. While the project is exempt from local zoning under State law, information from the local zoning ordinance (City of Los Angeles) was provided in the Draft EIR to allow for a comparison of the project to the scale of development that is currently allowed on the project site and in the immediate project area. The zoning designation for the project site is designated OS-1XL and the General Plan Use is “Open Space”. Included within this zoning designation are Public Water Supply Reservoirs and Water Conservation Areas. For OS no specific zoning requirements are set forth concerning building heights. However the 1XL overlay has height restrictions of 30 feet or two stories. Zoning on the southern adjacent properties is R1 with a height maximum of 45 feet.

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The Draft EIR indicated the treatment components at the Charnock site would not exceed 24 feet in height. As described in Appendix I, the updated project would include treatment components that are reduced to 15 feet in height. This is well within the 30 foot maximum allowable for zoning at this location, 50% below the maximum height allowable. The proposed structures would be approximately 67% below the 45 foot limit for the adjacent R1 maximum height restrictions. From a massing perspective, the 10 carbon vessels would take up about 3,750 square feet. The massing is consistent with surrounding development. Photo simulations provided in the Draft EIR help to illustrate the impacts of the proposed project and the resultant views of the project before and after mitigation. Mitigation Measure, AES-1(a), was developed to reduce visual impacts for the site and would require screening equivalent to or greater than that depicted in the photo simulation. In response to public input during the CEQA process, an updated project design was developed in order to reduce the profile of the project and to further minimize or avoid the project impacts identified in the Draft EIR. The updated project description and Charnock facility layout is provided in Appendix I along with an updated photosimulaton shown on Figure I-2. Mitigation measure AES-1(a) would still apply to the updated project design and would continue to require screening equivalent or greater than that depicted in the updated photo simulation shown on Figure I-2. With the updated design, the number and profile of the onsite carbon vessels have been reduced and the site facilities reoriented to provide a greater setback from Westminster Avenue. As shown in the updated photosimulations, the onsite tankage is no longer visible or only nominally visible from Westminster Avenue and the adjoining residential area to the south. The vessel height has been reduced from 24 feet, discussed in the DEIR, to 15 feet in the updated lower profile design. With the placement of the proposed single story equipment buildings south of the vessels, the new buildings together with the existing and proposed additional landscaping substantially reduce the visibility of the onsite tankage and facilities. It should be noted that the updated project is a hybrid of the proposed project and the Reduced Profile Alternative described in the DEIR. The updated project design reduces the project profile by undergrounding onsite tankage and replacing the proposed 24 foot carbon vessels with shorter 15 foot vessels. Construction effects would be somewhat greater than the proposed project but less than those described for the Reduced Profile Alternative described in the DEIR. This is because onsite excavation would be limited to 9 feet below the ground surface verses 24 feet as examined for the Reduced Profile Alternative in the DEIR. A detailed description of the updated project design and a comparison of the impacts of the updated design to the analysis contained in the DEIR are provided in Appendix I. As substantiated in Appendix I, the updated project design would not result in any new impacts or a significant increase in the severity of the impacts examined in the DEIR. Figure I-2, located near the end of Appendix I, shows the updated project and an “Eco Screen” mitigation strategy, which consists of a screen covered by a fast growing vine. Figure I-2 is located near the end of Appendix I. The final design, as discussed in Mitigation Measure AES-1(a), would be developed with input from the Mar Vista Community Council and Windward School. While the updated design fully mitigates all potentially significant visual impacts of the project, final project design could include additional screening. Such design features could include slats in the existing fence (to block the lower portions of the facilities from views through the chain link fence), landscaping or potted trees at the base of treatment components, neutral earth tone colors of tanks and buildings and physical screens or facades. The physical

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screens or facades could be painted in either neutral colors as to mask their presence or as murals to provide a more interesting appearance. Based on all of the criteria used in the EIR, including significance thresholds for the City of Los Angeles, it was determined that the project’s visual impacts would be reduced to less than significant with mitigation. General Response 3 - Noise Several comments concerning noise were received during the Notice of Preparation and Draft EIR public comment period. Discussion and analysis of these issues are presented in Section 4.7, Noise. The proposed facility will have both stationary and mobile noise sources. The stationary sources of noise for the proposed project will be groundwater pumps and pumps used to transport treated water within the site and, eventually, off-site. Pumping of groundwater will occur from five groundwater production wells. The groundwater pumps will be located at each wellhead in self contained structures. In addition, pumps will be used within the contact basin to pump treated water to an off-site treatment facility for additional treatment. The Charnock facility will use up to 4 transfer pumps and 6 sump pumps. Additional pumps will be installed; however these will be stand-by pumps that will be operated only if a primary pump fails. The majority of these stand-by pumps will be small (10 horsepower [hp] or less) and be operational less than 10% of the time, meaning that they will only be used when one of the primary pumps is down or for testing. Two pumps will be operational 90% of the time: a 150 hp transfer pump and a low powered (0.5 hp) sodium hypochlorite pump. The 150 hp water transfer pump will be located near the contact basin. A typical 150 hp turbine pump has a noise level rating (at 3 feet) of up to 85 dBA. This pump will be located within an enclosed concrete block masonry structure that will reduce the pump station noise by approximately 35-50 dBA. The EIR preparer, Rincon Consultants, has previously measured a 250 hp water well pump in a typical concrete structure for a 24-hour period (Crestview Mutual Water Company Alviso Drive well house) and determined a base sound level from the pump of about 49 dBA at 33 feet from the enclosure. The 0.5 hp sodium hypochlorite pump would typically have a maximum noise level of about 60 dBA at three feet from the pump, and would not be audible outside of the hypochlorite storage and feed building where it would be housed. Consequently, the pump noise levels at the Charnock site will be below the City of Los Angeles criteria at the closest residential property line, approximately 100 feet from the nearest proposed facilities. From a cumulative perspective, assuming simultaneous operation of pumps that are 90% operational for a 24 hour basis, the presence of enclosures, and existing measured sound levels, the noise level at the nearest residence with operation of all pumps would be an average of 42 decibels (dBA). The increase is about a one dBA sound level increase in the Community Noise Exposure Level (CNEL) at the nearest residence (see Appendix F). Consequently, noise levels will be within the acceptable range pursuant to the City of Los Angeles Exterior Noise Standards (see Table 4.7-1 in Section 4.7 Noise). Therefore, noise standards would not be exceeded and the noise impact associated with the proposed pumping activities would be less than significant.

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The mobile noise sources from the proposed project will be from vehicles loading and unloading various water treatment materials and routine operations. The Charnock location would have up to 10 daily trips during a peak activity and would involve generation of up to 6 peak hour trips onto the local street system. From a quarterly perspective, site delivery activities (other than routine maintenance) would occur up to 21 times. Typical daily maintenance vehicles using the site would include automobiles and pick-up trucks. However, large heavy-duty trucks would access the site during the loading and unloading of carbon, the delivery of sodium hypochlorite, the delivery of sodium bisulfite, the removal of granular activated carbon (GAC) backwash sludge and, possibly, GAC backwash water. Noise generated during deliveries and pick-pick up would be mitigated to a level that is less than significant with use of portable noise barriers to shield receptors from noise associated with material exchange pumping activities. With the implementation of Mitigation Measure N-2 noise impacts would be less than significant at the closest receptors. General Response 4 – Hazardous Materials Several of the comments expressed concern for the water treatment materials and site activities described in Section 4.4, Hazards and Hazardous Materials. The Charnock groundwater has been contaminated with gasoline additives methyl tertiary-butyl ether (MTBE) and tertiary-butyl alcohol (TBA) from gasoline stations in the vicinity of the site. In addition, to MTBE and TBA, the Charnock groundwater basin historically has been impacted by trichloroethene (TCE) and 1,1-dichloroethene (1,1-DCE). The project’s main objective is to treat the MTBE, TBA, TCE and 1,1-DCE contaminated groundwater and make it available for domestic use. The project will utilize Granulated Activated Carbon (GAC) to treat the groundwater. GAC has proven to be a highly effective treatment method for MTBE, TBA, TCE and 1,1-DCE contaminated groundwater and was determined to be effective pursuant to the conclusions of studies conducted for the City’s groundwater remediation projects (Kennedy/Jenks Consultants, 2000; Komex H2O Science Inc, 2000; Worley Parsons Komex, 2007; see Appendix G). Section 4.4 Hazards and Hazardous Materials of the Draft EIR outlines the specific details of water treatment activities and the chemicals that are anticipated to be used. Each water treatment chemical is analyzed with regards to their hazards potential relative to the nearest sensitive receptors. Pages 4.4-4 through 4.4-6 in Section 4.4 Hazards and Hazardous Materials, characterizes each of the chemicals that would be used as part of the proposed project. As discussed in Section 4.4, because the MBTE, TBA, TCE and 1,1-DCE would be bound to the GAC, exposure to these compounds would only occur if minor spills were to occur within the secondary containment areas during the course of change outs. Though not anticipated, in the event of such spills, no volatilization of the chemicals would occur given the affinity of the organic materials to the carbon, and no exposure to offsite school employees or students or the residential neighborhood would occur. MBTE, TBE, TCE, 1,1-DCE and activated carbon are considered potentially hazardous because of their flammability, but because all material will be handled as a wet slurry, no potential for burning is present. In the event of a GAC spill, employees would be exposed to the material, but are unlikely to inhale or ingest materials, and none of these materials pose a dermal adsorption hazard. As employees would not be exposed to air concentrations that exceed either an IDLH or a chronic inhalation hazard amount, the handling of the new and spent GAC does not present a significant risk.

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Section 4.4 also describes the regulatory and water treatment standards that the project will be required to follow. As a potable water provider, the City of Santa Monica adheres to standards of the American Water Works Association (AWWA), which establishes standards for water treatment including the storage, delivery and handling of water treatment chemicals, including hypochlorites. The AWWA Standards describe minimum requirements for water supply materials/equipment and represent a consensus of the water supply industry that a product designed to such standards will provide safety and service. The standards are revised approximately every 5 years. AWWA publishes over 140 consensus standards for equipment and materials used in the treatment and distribution of drinking water. AWWA standards have been developed for pipes, valves, meters, chemicals storage tanks, pumps, filters and wells. The standards govern the design and installation of products and equipment for safe reliable water treatment systems. The State of California Department of Public Health (DPH) refers to these standards when developing specific guidelines for drinking water compliance. In addition, the water treatment facilities would adhere to National Science Foundation Standard 60 (NSF 60), which also provides standards for the safe and effective treatment of potable water. The risk of hazards due to use of common water treatment chemicals will be reduced to below a level of significance or effectively eliminated due to adherence to these standards. Five specific Mitigation Measures for Hazards and Hazardous Materials have been developed. Each of these measures was developed to further ensure that the treatment materials and facilities would reduce potential human health impacts related to operational procedures and exposure to chemicals to a less than significant level. These mitigation measures ensure that there is local oversight for compliance with state and national standards [HHS-1(a)], site specific analysis of daily Charnock site operations and potential hazards response scenarios [HHS-1(b)], Emergency Response plans [HHS-1(c)], daily operations manual and certified training for operators [HHS-1(d-e)]. Regulatory oversight for the project’s implementation will be provided by the DPH, the City of Los Angeles Fire Department, and City of Santa Monica. Mitigation Measure HHS-1(b), the HAZOP study, is required by the DPH before a permit to operate can be obtained. The City of Santa Monica will be required to implement all of the recommendations contained in the HAZOP study and no operational permit will be issued without completion of the HAZOP Study. In addition, Mitigation Measure HHS-1(c), the Risk Management Program, is required by the City of Los Angeles Fire Department. As summarized in the Draft EIR, adherence to adopted standards will reduce to a level of less than significant or eliminate hazards and hazardous materials impacts on adjacent and nearby residents and site occupants. In addition the implementation of Mitigation Measures HHS-1 (a – e) would further ensure that any potential hazards and hazardous materials are fully mitigated to below recognized thresholds. Moreover, it should be noted that the remediation portion of the project would be phased out once the ground water contamination is cleaned up. It is anticipated that the remediation would require between seven and ten years to complete. Once this period ends the remediation equipment would be put on standby, with subsequent removal upon approval by DPH.

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Response 1 COMMENTER: Sarah Crompton DATE: September 8, 2008 RESPONSE: The commenter expresses concern for the truck routes that would be used for the project and the potential varied effects it would have on the neighborhood. The commenter specifically requests that all traffic be only from Sawtelle Boulevard onto Westminster Avenue. The Draft EIR addressed this issue in Section 4.2, Construction Effects and Section 4.4, Hazards and Hazardous Materials. In Section 4.2 and within Mitigation Measure CON-1 it is stated that “The Charnock location will require vehicles and trucks to restrict activities to Westminster Avenue and to avoid any side streets when feasible”. In response to this comment, the “when feasible” caveat will be stricken from the mitigation measure CON-1(a) as shown below.


The Hazards section discusses accessing the site from Westminster Avenue via Sawtelle Boulevard. In addition, Mitigation Measure HHS-1 (d) has been expanded to require that the City include language in all vendor contracts that define the site access route as Sawtelle Avenue to Westminster Avenue, prohibiting the use of other residential streets. Note that there is only one principal site access route to the Charnock facility (from Sawtelle Boulevard to Westminister Avenue) and that this mitigation measure will help clarify the access and ensure that project related delivery vehicles do not mistakenly utilize other routes or the local residential street system. New text within the mitigation measure is shown in underline format.

HHS-1(d) Operations Manual. An operations manual shall be prepared once final design is confirmed. This operations manual will have written operational procedures for site operations and maintenance. This document will feature operational protocols and standard operating procedures to ensure proper facility management. All vendor contracts shall define the site access route as Sawtelle Boulevard to Westminster Avenue and prohibit the use of other residential streets. This document would also include a written training program for all staff.

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Response 2 COMMENTER: Dave Singleton, Program Analyst, Native American Heritage

Commission DATE: September 17, 2008 RESPONSE: The commenter recommends a series of actions to determine whether or not the proposed project would significantly affect historic or archaeological resources. Impacts to historic and archaeological resources are addressed in Section VI of the Initial Study (IS). As part of the analysis contained in the IS, a Phase I Archaeological Study was prepared for the proposed project by the Historical Environmental Archaeological Research Team (June 2008). The study was prepared in order to determine the presence of cultural resources on the project sites. The results of the Phase 1 Archaeological Study for the three project areas yielded no indications of prehistoric or historic archaeological resources within each parcel. This report is provided in its entirety in Appendix D to the Draft EIR. In addition, the project sites are highly disturbed due to onsite buildings and urbanization that has occurred in the vicinity of the sites. Therefore the likelihood of finding intact significant archaeological resources is very low. Nevertheless, as indicated in the NAHC letter, Health and Safety Code § 7050.5, Public Resources Code § 5097.98 and § 15064.5 of the California Code of Regulations (CEQA Guidelines) mandate procedures to be followed, including that construction or excavation be stopped in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery until the County coroner or medical examiner can determine whether the remains are those of a Native American. Note that § 7052 of the Health & Safety Code states that disturbance of Native American cemeteries is a felony.

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Response 3 COMMENTER: Rob Kadota, Chair, Mar Vista Community Council DATE: September 25, 2008 RESPONSE: Response 3(A) The commenter asserts that the EIR rejects the input of the Mar Vista Community Council provided during the scoping process, including consideration of Alternative Sites. The EIR was prepared in part to expand analysis of the proposed project including assessing Alternative Sites specifically in response to input received during the Mitigated Negative Declaration (MND) process (initiated for the project and then expanded to an EIR process) and public scoping process for the EIR. Section 1.0 Introduction discusses public input received during the MND process and EIR process, documenting three public meetings on the project and two public comment collection periods prior to circulation of this EIR for public review. Public meetings were held on April 15, 2008; April 17, 2008; and June 12, 2008. Table 1-1 in Section 1.0 Introduction shows where each of the issue areas were addressed in the EIR. The Alternatives section of the EIR presents analysis of the environmental effects of the alternatives, indicating there are environmental trade-offs associated with each of the alternatives. The proposed project does not have any significant environmental effects that cannot be mitigated. The EIR describes the reasons why an alternative site in Santa Monica is not feasible and further examination is not required. Please refer to General Response 1 – Alternative Sites at the beginning of this section for more information regarding exploration of other locations for processing the contaminated water. Response 3(B) The commenter states that the City should have further discussions with the Charnock location residents regarding the trade-offs between aesthetics and increased construction effects. Specifically a Reduced Profile Alternative in Section 6.0 Alternatives was developed in order to examine the Charnock site structures being placed below grade. This alternative would reduce visual impacts but would increase impacts to construction, noise, air quality and traffic. It should be noted that the updated project is a hybrid of the proposed project and the Reduced Profile Alternative, which proposes partial burial (9 feet) rather than the 22 feet examined in Section 6.0. As outlined in the Reduced Profile Alternative discussion, the construction impacts of this alternative, while short term in nature, would be greater than those identified for the proposed project. The Reduced Profile alternative would involve lowering the 15 water treatment vessels about 22 feet below ground surface. Under this alternative, the top of the proposed 24-foot water treatment vessels would be approximately 2 feet above ground surface. This alternative would require soil excavation in addition to the subterranean construction of the treatment vessel containment area. It is estimated that the additional construction would require 6-12

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additional months to complete. The total estimated construction period for the project with this alternative would 12-24 months. Construction impacts would include an estimated 580 truck loads of soil to be removed from the site. Impacts related to temporary changes in traffic patterns, noise, and air quality would be significant but mitigable. The environmental effects of the updated project are examined in detail in Appendix I. It proposes a little less than half of the excavation proposed under the Reduced Project Alternative (see Section 6.0 Alternatives), and the construction effects would be less than significant with the required DEIR mitigation. The City of Santa Monica decision makers (City Council) will hold a public hearing to consider the EIR and the project. The City Council will consider the EIR along with any written comments and public testimony. The comment that the Charnock location residents would like to choose whether the project or an alternative is implemented is noted for the public record. However, the City Council is the decision maker with the authority to certify the EIR and approve a project. The public is encouraged to express support for any alternative and the decision makers will consider the public input when deciding whether or not to certify the EIR and approve the project as proposed. It is also noted that in response to input received during the CEQA public review process, the project has been updated to reflect a lower profile that would avoid some of the visual impact concerns that were raised by the local neighborhood. Specifically, the number and height of the proposed vessels have been reduced and site orientation has been modified in a way that the vessels are screened behind existing and proposed vegetation and single story onsite buildings. This together with the mitigation measures provided in the DEIR will further ensure that the project’s visual impacts are not significant and that it is visually compatible with the surrounding neighborhood. Response 3(C) The Community Council requests that an architect be hired to create a design consistent with existing neighborhood residential and Windward School architectural designs, indicating this was previously requested during the scoping process. Pursuant to Section 15126.6(a) of the CEQA Guidelines, an EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. The EIR generally described an alternative involving containment of Charnock facility components within a structure. The shell of the structure could be modified to add architectural details consistent with Windward School facilities or adjacent residential neighborhood and is not omitted from consideration or inconsistent with existing analyses. Moreover, if the equipment housing alternative were selected, an architect would be contracted. While specific architectural details are not known at this time, the City’s internal design review and community input measures identified in the DEIR will help to ensure that a compatible design is implemented, should this alternative be selected. The EIR evaluated the physical environmental effects associated with construction of such a structure in addition to the other project components. Full discussion of this alternative (6.6 Equipment Housing Alternative) pursuant to the requirements of CEQA is contained in Section 6-8 of the EIR. Additional discussion of aesthetic mitigation variations is included under General Response 2- Aesthetics.

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Response 3(D) The commenter asserts an opinion that the noise mitigation will not be implemented correctly during operations at the Charnock site and that neighborhood noise levels will be higher than currently exist. Please refer to General Response 3 – Noise at the beginning of this section. The EIR identifies an incremental but less than significant increase in noise levels associated with the project. Noise levels during truck loading and offloading activities will range from 73 to 65 dBA as indicated under the Impact N-2 discussion for the Charnock Site. These are worst-case conservative noise levels for the period of activity. Noise levels will be reduced by eight dBA with implementation of mitigation measure N-2(a). Mitigated CNEL noise levels associated with each activity are shown in the following table. The CNEL noise level is a time weighted average over a 24-hour period. It is not comparable to an hourly Leq which is the average noise energy level over a one hour period. It should be emphasized that these activities are periodic and would not be occurring simultaneously or on a daily basis. As indicated in the DEIR, truck related activities would occur up to 21 times in a quarterly period, which is about once every three days. Moreover, some activities only require an hour, though some will require up to eight hours.

Summary of Operational Truck Activity Noise at Charnock

Leq during operation

Mitigated Leq

Mitigated CNEL Activity Hours of

operation Times per year dBA

Offloading sodium bisulfate/ hypochlorite

1 12 73 65 55

GAC Carbon changeout 8 12 decreasing

to 6 65 57 56

GAC backwash and sludge flushing

3 33 73 65 58

Data Sheet included in Appendix F.

The mitigated CNEL would range from 55 to 58 dBA, on days when onsite activities occur. These levels are between the acceptable and conditionally acceptable range for residential uses within the City of Los Angeles as shown in Table 4.7-1 in Section 4.7, Noise of the EIR. Pursuant to the requirements of CEQA, a Mitigation Monitoring and Reporting Program (MMRP) has been prepared for the project and would be implemented to ensure that all mitigation measures are implemented properly and are effective in reducing project impacts to below adopted impact thresholds. Response 3(E) The commenter requests assurance that trucks will not utilize residential neighborhood streets.

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As discussed, the Initial Study and Section 4.4, Hazards and Hazardous Materials, the project will adhere to all Department of Transportation (DOT), state and local laws pertaining to the transportation of materials, including any weight restrictions. In addition, Mitigation Measure HHS-1 (d) has been expanded to require that all vendor contracts that define the site access route as Sawtelle Boulevard to Westminster Avenue, prohibiting the use of other residential streets. Please refer to Response 1 in this section for additional discussion regarding this issue. Response 3(F) The commenter asserts an opinion that the potential for adverse effects related to the remediation and water treatment process from water contaminants and treatment chemicals has not been adequately addressed in the EIR. Pages 4.4-4 through 4.4-6 in Section 4.4 Hazards and Hazardous Materials, characterizes each of the chemicals that would be used as part of the proposed project. As discussed in Section 4.4, because the MBTE, TBA, TCE and 1,1-DCE would be bound to the GAC, exposure to these compounds would only occur during minor spills within the secondary containment areas during the course of change outs. Although not anticipated, in the event of such spills, no volatilization of the chemicals would occur given the affinity of the organic materials to the carbon, and no exposure to offsite school employees or students or the residential neighborhood would occur. MBTE, TBE, TCE, 1,1-DCE and activated carbon are considered potentially hazardous because of their flammability, but because all material will be handled as a wet slurry, no potential for burning is present. In the event of a GAC spill, employees would be exposed to the material, but are unlikely to inhale or ingest materials, and none of these materials pose a dermal adsorption hazard. As employees would not be exposed to air concentrations that exceed either an IDLH or a chronic inhalation hazard amount, the handling of the new and spent GAC does not present a significant risk. A Hazards and Operability Study for the Arcadia well field (SMWTP area) is included in Appendix H, which further discusses the potential for hazards from remediation with a GAC system. Normal day to day operations would not pose any significant health risks with the treatment process as proposed; however, mitigation measures HHS -1(a-e) would maximize safety design features and involve preparation of emergency response plans in accordance with applicable requirements. Please refer to General Response 4 – Hazards and Hazardous Materials for additional discussion on this topic. Response 3(G) The commenter requests evaluation of the piping that would carry treated water to the Santa Monica Water Treatment Plant (SMWTP), further expressing concern about potential construction impacts to City of Los Angeles streets. As noted in the EIR, the Charnock well field is owned by the City of Santa Monica, and until 1996, had been used for drinking water production and treatment since 1924. An existing infrastructure system (pipeline) is in place that connects the Charnock facility to the Santa Monica Water Treatment Plant (about 4.5 miles). This system was previously used for many years when the Charnock facility was in operation, and is currently used to transport potable imported water from Metropolitan Water District (MWD). There are no known leaks, and

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other than routine maintenance the City is not proposing any significant upgrades or improvements to this system as part of the proposed project. Therefore, the proposed project would not be expected to have any significant effects along this existing infrastructure corridor. It is noted that relocation of the treatment system to the Santa Monica Water Treatment Plant (SMWTP) as examined as an alternative to the proposed project and other alternative site options that were eliminated from consideration as infeasible, would require that new infrastructure be developed. Construction of new infrastructure was discussed as one reason that alternative sites would not be environmentally superior to the proposed project. For the SMWTP alternative infrastructure needs would likely include parallel pipeline system to the one that currently exists. This parallel pipeline system (for this alternative) is required because only some of the existing groundwater wells in the Charnock wellfield are contaminated and require treatment. Under this alternative, one pipeline would be needed to transport water from the clean water wells to SMWTP facility and one pipeline would be needed to transport water from the contaminated wells to the treatment unit at SMWTP. Response 3(H) The commenter expresses doubt about the City’s right to extract groundwater from the Charnock Basin and suggests coordination with other entities including the City of Los Angeles, the Los Angeles Department of Water and Power. The commenter further requests a basin description and characterization as well as exploration of the potential effects of harmful gas migration (methane, hydrogen sulfide and BTEX gases) due to lowering of the groundwater level beneath the Mar Vista Community. There are no other entities that have asserted a water right superior to the City. As noted above, the City of Santa Monica utilized the Charnock Subbasin for its water supply for many years dating back to 1924 with no adverse effects related to the basins safe yield, harmful gas migration, subsidence or any other geological or hydrological issues. The proposed project would not extract more than can be safely yielded from the basin. As such, there is no evidence to suggest that the proposed project would result in any significant effects in these areas. In fact, based on previous operation, the evidence demonstrates that the project will have no significant impacts in these areas. The preliminary Design Report (Worley Parsons Komex July 2007, contained in Appendix G) contains details regarding water supply and extraction. That report does not identify any significant impacts associated with the project’s long term pumping on the ground water basin.

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Response 4 COMMENTER: John and Donna Jones DATE: September 30, 2008 RESPONSE: Response 4(A) The commenter asserts an opinion that the EIR has not adequately addressed the potential for adverse aesthetic effects on the neighborhood. The commenter specifically refers to gaps in trees and the gap that would occur at the driveway/gate to the site. As discussed in Section 4.1 Aesthetics under Impact AES-1 and as shown on Figures 4.1-1 through 4.1-2, given the approximately 30 foot height of existing trees and the 7 foot hedge lined fence located on the southern boundary on the site, the proposed new facilities would be largely screened from the existing residential area to the south. Some views, however, specifically those facing the facility entry gate and one area with a noticeable gap in vegetation, would have less complete screening. However, the project has been modified such that the above ground components would now be reduced to 15 feet tall as opposed to 24 feet, which was previously proposed. Figure 4.1-2 shows that with supplemental planting as required under mitigation measure AES-1(a), gaps in the existing tree rows would be eliminated along Westminster Avenue (see Views 3 and 4 on Figure 4.1-2). Planter located internally could serve to break up the massing of the tanks as viewed from the driveway (see View 1b on Figure 4.1-2). Alternatively, the latest simulation, included in Appendix I of this EIR (see Figure I-2 near the end of Appendix I), shows the reduced profile project with an “Eco Screen” mitigation strategy consisting of a mesh support with fast growing vines, which would completely screen the treatment components such that the components do not look industrial in character (see Figures 1-3 in Appendix I). Moreover, Mar Vista Community Council would be a part of the final designs. It is also important to note that the visibility of a project from a particular vantage point does not mean that a project would have a significant visual impact under CEQA. For the proposed project, significance was determined based on the factors identified in the EIR and it was concluded that the project would not exceed any impact thresholds and would not result in any significant visual impacts after mitigation. It is further noted that the assessment of visual impacts can be subjective and the commenter’s opinion is hereby noted as part of the public record. With respect to noise reductions from vegetative screening, it should be noted that the EIR does not assert that vegetative screening will reduce noise effects, as it is not an effective barrier. Operational noise would be reduced through implementation of mitigation measures N-2(a-b), which require the use of portable sound blankets and the use of a sheltered electrical air compressor. The increased setbacks and reorientation of onsite buildings in the updated lower profile design would further help to mitigate onsite noise levels. Design considerations including housing for well pumps will ensure that these operations do not result in exceedance

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of noise thresholds for residential receptors (see Impact N-1 in Section 4.7 Noise). Please see General Response 4 - Noise for additional discussion about the project’s effects with respect to noise. Response 4(B) The commenter expresses support for development on an alternative site within the City of Santa Monica. The commenter further asserts an opinion that the zoning of the property is not compatible with the proposed use, and that Westminster Avenue is not permitted to allow trucks in excess of 6,000 lbs. The commenter’s preference for development on an alternative site within the City of Santa Monica is noted, though it is emphasized that the proposed project involves upgrades and reactivation of an existing facility developed by the City of Santa Monica to extract groundwater for potable consumption. The facility was in operation from 1924 to 1996 before contamination was discovered. Because the groundwater and groundwater contamination exists below the project site the City does not have the option to relocate the wellfield to another location. See General Response 1 – Alternative Sites earlier in this section. It is also important to note that this project would help to ensure a sustainable local water supply, which has benefits for both the City of Santa Monica as well as other water users within the region. As discussed in Section 2.0 Project Description and Section 4.1 Aesthetics, the zoning designation for the Charnock site is OS-1XL (Open Space in Height District 1, Extra Limited). Allowable uses included within this zoning designation are Public Water Supply Reservoirs and Water Conservation Areas. Moreover, as discussed in Section 2.0 Project Description, the existing site contains five water supply wells, a 116,500-gallon contact basin, a booster station, an Metropolitan Water District (MWD) turnout, a chlorine building, a power substation, a control room, and City storage yards. The proposed project involves development of remediation facilities to treat the existing groundwater contamination, which would result in reactivation of an existing developed groundwater extraction facility. The remediation activities would be of a limited duration and are anticipated to require between seven and ten years after which the remediation equipment would be placed on standby until removal is approved by the Department of Health Services (DHS). See Response 1 to Sarah Crompton earlier in this section for a discussion of truck routing. The proposed project involves a total of about 164 truck trips per year during the initial peak years of operation. This amounts to an average of about three truck trips per week. Peak truck traffic would occur during carbon change outs which would involve 8 daily truck trips (4 inbound and 4 outbound). This would occur 4 times per year during the initial stages of the project reducing to less frequent carbon change outs as the clean up progressed over the life of the project. This level of truck traffic is not expected to significantly impact the roadway from either a capacity or roadway design perspective. With regard to weight limitations on Westminster Avenue, based on discussions with the City of Los Angeles Department of Transportation, neither Sawtelle Boulevard nor Westminster Avenue are currently weight restricted. This is discussed in the Initial Study included as Appendix A of both the Draft and Final EIR. In the event that either of these streets becomes weight restricted and the City of Los Angeles implements a permitting program for such usage, the City of Santa Monica would work closely with the City of Los Angeles to ensure that any issues related to the project access are quickly and effectively

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resolved. Moreover, it is also noted that the City of Los Angeles Department of Transportation commonly allows trucks to access businesses and other facilities, if their business destination is located on a weight restricted street. Moreover, it is noted that regular truck traffic such as garbage and recycling trucks, street sweepers, UPS and bottled water delivery trucks regularly utilize residential streets such as Westminster Avenue. The proposed project would involve deliveries of large trucks filled with liquids such as sodium hypochlorite. These trucks could have capacities of up to 2,800 gallons and weigh an average of about 45,000 pounds. As a measure of comparison, other types of vehicles that would be anticipated to routinely travel on Westminster Avenue include the following.

• Compact pickups and minivans - weight about 3,750 pounds • Full size vans - weigh between 3,751 and 8,500 pounds • A large pickup or van - weight about 8,501 to 10,000 pounds • Garbage trucks - weight about 50,000 pounds when full • School buses – weight about 33,000 to 42,000 pounds • A Sparklett’s water delivery truck - weight up to 80,000 pounds

Most of these vehicles exceed 6,000 pounds and even typical van and truck vehicles associated with residential development can exceed this level. Given the relatively low truck traffic volumes associated with the project, project related traffic would not be expected to impact Westminster Avenue. It is further noted that the project site has historically been used as a water treatment facility and is currently utilized for storage. Both of these uses have involved a low level of truck usage of the local street system. Project mitigation would prohibit project traffic from utilizing local residential streets, with the exception of that portion of Westminster Avenue between the project site and Sawtelle Boulevard. Response 4(C) The commenter asserts an opinion that there may be significant effects due to groundwater extraction, such as sinkholes and dangerous or toxic gas migration to the surface beneath the Mar Vista Community. Please refer to response 3 H for a response to this concern. Response 4(D) The commenter expresses concern about the noise that would be associated with operation of the facilities at the Charnock site. The commenter asserts that the project will expose residents and school children to the potential for toxic chemical spills. The commenter closes by asserting an opinion that the project should be constructed in a manner that does not have any adverse effects on the local neighborhood. The comments concerning noise and hazards have been previously addressed under General Response 3 – Noise and General Response 4 – Hazards and Hazardous Materials earlier in this section. As discussed in the Draft EIR, there is potential for an increase in ambient noise levels as a result of implementation of the proposed project. However, incorporation of design features such as concrete housing for pumps in addition to mitigating operational noise through the use of portable noise barriers during periodic noise generating activities (such as carbon change outs) would ensure that the project does not exceed recognized noise impact thresholds. Please see response 3D for additional discussion of operational noise.

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Similarly, adherence to mitigation measures HHS-1(a) through HHS-1(e) would ensure that the project is designed, constructed and operated in accordance with existing standards of the American Water Works Association (AWWA),the Division of Occupational Safety and Health (OSHA), the Los Angeles City Fire Department, and the State of California Department of Public Health (DPH). Compliance with the standards and requirements of these agencies as incorporated under HHS-1(a) through HHS-1(e) will ensure that any potential risk of upset is reduced to a less than significant level and would not pose a significant hazard to adjoining or nearby land uses. Please refer to General Response 4 – Hazards for a more detailed discussion regarding the less than significant potential for adverse health effects. Response 4(E) The commenter suggests that the project should consider use of an existing school access driveway off of Sawtelle Boulevard to avoid routing traffic on Westminster Avenue. As discussed in the EIR, the proposed project would generate about 10 daily trips and about six peak hour trips during a peak activity such as a carbon change out. Trucks and autos would access the Charnock site from an existing driveway off of Westminster Avenue that currently provides access to the site. The site is currently utilized by City of Santa Monica Water Department for storage. Closing this existing Westminster access to reroute traffic access via the school site would bring additional vehicles through the school site which is not considered environmentally superior to use of the current and historic Westminster Avenue access to the project site. Use of Sawtelle Boulevard Driveways through the school site for access to the site would introduce new truck traffic into an environment where students are accustomed to conducting school related activities without consideration of truck or other onsite vehicular traffic. This could increase the project’s effects on the Windward school. Please refer to Response 1 for additional discussion about truck traffic restrictions on Westminster Avenue. Mitigation measures have been expanded to further reduce the potential for truck traffic on Westminster Avenue. Response 4(F) The commenter asserts an opinion that the DEIR needs to address water rights, building and construction codes of the City of Los Angeles, and suggests that the City be named as co-lead agency. The commenter further asserts an opinion that the DEIR does not include adequate details about the construction and operation of the project to determine the potential for adverse effects to the Mar Vista Community. As discussed under Section 2.6 in Section 2.0 Project Description, California Government Code § 53091 states that cities are exempt from each others building and zoning ordinances. Therefore, although the Charnock and SMWTP sites are located within the City of Los Angeles, they are not subject to discretionary approval by the City of Los Angeles. Nevertheless, where it is instructive to the reader and promotes the understanding of the project effects the EIR discusses the City of Los Angeles General Plan and zoning designations and ordinance standards that relate to the proposed project sites (i.e. reference to City of Los Angeles Noise Ordinance requirements, zoning height parameters, etc.).

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With respect to water rights, the City of Santa Monica has historically (1924 to 1996) utilized this groundwater basin as a water source for the City and maintains the right to continued use into the future. There are no other entities that have asserted a water right superior to the City. The proposed project would bring the well field into production at a level that is similar to historic use. The proposed project will not reduce water levels in the basin beyond the pre-determined safe-yield level. This is further described in the EIR Project Description and the preliminary design report (Worley Parsons Komex, July 2007) included in Appendix G. It is also important to note that the water rights issue goes beyond the discussion required by CEQA which is intended to focus on the physical effects of a project on the environment. The project would not exceed pervious extraction levels and impacts to the groundwater basin would be less than significant. Section 15051(a) of the CEQA Guidelines states that ”if the project will be carried out by a public agency, that agency shall be the Lead Agency even if the project would be located within the jurisdiction of another public agency.” As such, it is consistent with current water resources law and CEQA requirements for the City of Santa Monica to act as the Lead Agency for this project. With respect to the level of detail regarding construction and operation of the proposed project, it should be noted that the project facility and operation descriptions encompass eight full pages of text within the project description, while the project construction schedule consists of two and one half pages of text. There are 20 photographs of the existing facility components and seven graphics that detail locations, site layouts, water treatment processes and the City of Santa Monica’s hydraulic profile. In addition, an entire section discusses the potential for construction effects including construction traffic, construction air quality, construction noise, and the potential for dispersal of lead and asbestos if found within existing structures proposed for demolition. Operational effects analysis included detailed discussions of the remediation activities and maintenance of the equipment to facilitate operations. The remediation processes have been widely studied and represent proven technology to treat these contaminants. Detailed descriptions of contaminants and treatment processes were included. All physical environmental effects were determined to be less than significant pursuant to CEQA with implementation of mitigation measures for Aesthetics, Noise, Geotechnical, Hazards and Hazardous materials, and Hydrology and Water Quality (see Table ES-1). Technical reports were prepared as background studies for the EIR, including the following.

• Preliminary Design Report (Worley Parsons Komex July 2007) - see Appendix G • Process Safety Management/Risk Management Program Volume I (Tracer

Environmental Sciences & Technologies, Inc. June 15, 1999) – see Appendix E • Demonstration Test Report (Komex H2O Science Inc, July 2001) - see Appendix G • Hazards and Operability Study Production Aquifer Remediation System Arcadia Well

Field Los Angeles California (Komex, September 2001) – see Appendix H These reports provided technical details about proposed operations at the facilities analyzed in the EIR. Section 15146 of the CEQA Guidelines states that the “degree of specificity required in an EIR will correspond to the degree of specificity involved in the underlying activity which is described in the EIR”. Section 15151 of the CEQA Guidelines states that an “EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the

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environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible.” The DEIR contains detailed discussions of construction and operational effects in accordance with the requirements of CEQA.

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Response 5 COMMENTER: Windward School DATE: October 1, 2008 RESPONSES: Response 5(A) The commenter conveys positive opinions about the re-routing of pipelines at the Charnock location. The commenter requests relocation of Well #15, so that it would no longer be located in the center of Windward’s athletic field. The City will review its current and proposed pipelines and well field configuration to determine the feasibility of this request, but relocation of the pipelines is not currently proposed as part of this project. Response 5(B) The commenter requests to be provided a copy of the mitigation plan for aesthetic impacts and expresses a preference for the Reduced Profile Alternative that would involve lowering the water treatment vessels to about 22 feet below the ground surface. The commenter further expresses interest in having the aesthetic impact reduced on all four sides of the site indicating that it will be viewed by Windward students, parents, and faculty from all perspectives. The commenter requests to be included in the preliminary review process along with the Mar Vista Community Council pursuant to the stipulations of mitigation measures AES-1(a). The proposed project has been modified such that the new above ground vessels at the Charnock site will be about nine feet lower than originally anticipated (15 feet tall instead of 24 feet tall). A revised visual simulation is included near the end of Appendix I as Figure I-2. The updated project as shown in Figure I-2 shows an “Eco Screen” mitigation technique that would include a mesh screen on three sides, which would be covered in vines. A fast growing ivy such as Algerian ivy could be utilized. If densely planted, such as 5-gallon vines a minimum of eight feet tall and planted at 20 feet on center, these vines could provide full coverage within two years if irrigated by drip irrigation. Prior to growth, green landscape fabric could be used to obscure views of the tanks (see top photo on Figure I-2). The comments stating a preference for the reduced profile alternative and request for visual screening on all four sides is noted for consideration by City decision makers. A review of the City of Los Angeles criteria for evaluation of significant aesthetic impacts indicates the proposed project would not exceed any threshold criteria (see Impact AES-1 and threshold discussion on pages 4.1-5 and 4.1-6 in Section 4.1 Aesthetics). However, because the introduction of an industrial looking facility in the largely residential neighborhood has the potential to be perceived as inconsistent with the visual character of the area, mitigation was included to reduce the potential for this perception. For this reason, the impact is considered to be a Class II, significant but mitigable impact. Mitigation measure AES-1(a) will be revised to

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reflect inclusion of the Windward School in the design review process. The following changes will be made to the mitigation measure. New text is shown in underline format.

AES-1(a) Additional Screening and Site Design Features. Additional screening and/or site design features shall be implemented to provide visual relief of the onsite features. The physical appearance of the Charnock structures and site screening shall be compatible with and relate harmoniously to surrounding sites and neighborhood. Screening shall be equivalent to or greater than that shown in Figure I-2 (see Appendix I). Note that Photo 1 in Figure I-2 illustrates the minimum extent of screening that would be implemented between year 0 and year 2. Photo 2 in Figure I-2 illustrates the level of screening after year 2. Additional screening would be implemented to help block the currently unobstructed views of the new facility. This additional screening would include such design features as slats in the existing fence (to block the lower portions of the facilities from views through the chain link fence), landscaping or potted trees at base of structures, neutral earth tone colors of tanks and buildings and physical screens or facades. The physical screens or facades could be covered in vines (see Figure I-2), painted in either neutral colors as to mask their presence or as murals to provide a more interesting appearance. The physical screen or façade shall extend along the western portion of the site so as to screen views of the facility that exist over the existing 7 foot hedge row along Westminster Avenue. The Mar Vista Community Council and Windward School will be solicited for aesthetic input to help ensure that their physical location and appearance are compatible with and relate harmoniously to surrounding environs.

Response 5(C) The commenter asserts that the consideration regarding trenching under the athletic fields for coordination with Windward School is appreciated and the best time to conduct the trenching would be during the summer, with further specificity pending mutual consideration. The mitigation measure will be revised to reflect this consideration. New text is shown in underline format.

CON-1(b) Windward School Construction Management Plan. The City shall prepare and implement a Windward School Construction Management Plan to minimize or avoid potential construction impacts associated with onsite construction, including pipeline trenching. The Windward School Construction Management Plan should focus on informing school and affected parties of pipeline trenching activities and dates. This plan shall include the following:

• Coordination and planning with Windward School to determine the

optimal routing and time period to conduct trenching activities on school

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grounds in order to avoid or minimize impacts to school activities; trenching shall be planned to occur during summer to the extent that it will not disrupt the construction timeline;

• Timely notification of construction (including trenching) schedule to Windward School and the surrounding community;



Response 5(D) The commenter reiterates significance findings from the Initial Study that was prepared for the project and requests to be informed of plans that would mitigate any potential hazard to students. As indicated previously under Response 4 D, Compliance with the standards and requirements of the American Water Works Association (AWWA), the Division of Occupational Safety and Health (referred to as OSHA), the Los Angeles City Fire Department, and the State of California Department of Public Health (DPH) will ensure that any potential risk of upset is reduced to a level that is less than significant and that the project will not pose a significant hazard. In addition mitigation measures HHS-1(a) through HHS-1(e) in Section 4.4 Hazards and Hazardous Materials would further ensure that any potential risk of upset is reduced to a level that is less than significant and that the project will not pose a significant hazard. Nevertheless, the following mitigation measures have been revised to clarify that a copy of the HAZOP study shall be made available to the public at the City of Santa Monica Engineering & Architectural Services Division for review and comment as part of the 97-005 public review process. New text is shown in underline format.

HHS-1(b) Hazards and Operability Study. A Hazards and Operability (HAZOP) study will be prepared by the City and approved by the California Department of Public Health (DPH) prior to the issuance of the projects permit to operate. The HAZOP study will identify potential safety hazards and evaluate potential operational problems in characterizing potential consequences to the surrounding communities in the event of a release of a hazardous material. This document will be prepared in accordance with the evaluation process described in State of California Department of Public Health (DPH) Policy Memorandum 97-005 for the Direct Domestic Use of Extremely Impaired Sources of Drinking Water, issued on 5 November 1997. The HAZOP involves a detailed review of the design of an engineered system to evaluate the safety and operability of the system’s components under varying operational parameters. This study will further evaluate the storage, use and transportation of

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hazardous materials at the project location. All recommendations and measures identified in this study shall be implemented. The DPH will keep the HAZOP report as part of the permit application file, and will make reference to it in the water supply permit. Anticipated measures include proper identification of storage hazardous materials, implementation of proper spill prevention and countermeasures, emergency response procedures, and other design measures that are necessary to eliminate or minimize to the greatest extent feasible any potential hazards associated with the new facilities and their operations. In addition, the HAZOP study focuses on how a plant or facility will respond to deviations from normal operation. This report will be prepared by the design engineers and approved by a professional engineer. A copy of the study shall be made available at the City of Santa Monica Engineering & Architectural Services Division for review and comment as part of the 97-005 public review process.

HHS-1(c) Risk Management Program. For the Charnock location, as

required by the Los Angeles City Fire Department, prior to operations, a Risk Management Program shall be prepared, filed and approved by the Los Angeles City Fire Department. The SMWTP shall update its current RMP. The salt water well location will file a Business Plan with the Santa Monica Fire Department. The Risk Management Program is required to reduce the risk of accidental releases. The RMP will have written operational procedures and provide emergency guidance. This document will feature emergency response protocols, emergency response techniques and emergency contact numbers to ensure proper emergency management. A copy of the Risk Management Program shall be made available at the City of Santa Monica Engineering & Architectural Services Division for review and comment prior to finalization of the document.

Additional discussion regarding hazards is contained in General Response 3 – Hazards and Hazardous Materials. Response 5(E) The commenter requests notification of mitigation that would reduce the potential for hazards from inundation. The inundation effects that the commenter is referring pertain only to the Salt Water Well location. No inundation effects are expected at either the Charnock or Santa Monica Water Treatment Plant. Response 5(F) The commenter refers to the project component involving replacement or rerouting of chlorine lines that run beneath the Windward School athletic fields and states a preference for having

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the lines re-routed. This comment is noted and will be considered by City decision makers and project designers. Response 5(G) The commenter reiterates significance findings from the Initial Study indicating the proposed project requires mitigation for Aesthetics, Construction Effects, Hazards and Hazardous Materials, and Noise. These issue areas were explored and discussed in the Draft EIR that was circulated for public review. Table ES-1 contains a summary of the impacts and mitigation measures for the project. These impacts have been mitigated to a level that is less than significant. Response 5(H) The commenter asserts there is a discrepancy between the Los Angeles Municipal Code construction hours and the hours of construction activity. As discussed in Section 4.2 Construction Effects, it is noted that the Section 41.40 of the Los Angeles Municipal Code restricts construction activity to the hours between 7:00 AM and 9:00 PM Monday through Friday, between 9:00 AM and 5:00 PM on Saturday, and does not allow construction activity to occur on Sunday or major national holidays. No person, other than an individual homeowner engaged in the repair or construction of his single family dwelling, shall perform any construction or repair work of any kind before 8:00 a.m. or after 6:00 p.m. on Saturday, nor at any time on Sunday. Moreover, it is noted that mitigation measure CON-1(a) restricts work within the right of way to between 9:00 A.M. and 4:00 P.M. The greater restriction within the mitigation measures is specifically intended to reduce the potential for conflicts with peak hour traffic; therefore no change was made. Additionally, it is noted that mitigation measure CON-2(c) requires that foundation conditioning and the noisiest phases of construction be limited to between the hours of 10:00 A.M. and 3:00 PM, which also intentionally targets the middle of the day to provide the least amount of disruption to surrounding residential receptors. Therefore no changes were made to the EIR.

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Response 6 COMMENTER: Bill Rosendahl, City of Los Angeles, 11th District Councilmember DATE: October 1, 2008 RESPONSES: Response 6(A) The commenter conveys opposition to the project. No response necessary. Response 6(B) The commenter acknowledges that the EIR considered both an alternative location as well as undergrounding the remediation towers at the Charnock facility. The commenter expresses disappointment that the alternative site was determined to be infeasible and that the undergrounding was rejected for the Charnock site. Please refer to General Response 1 – Alternative Sites for a discussion regarding this alternative. Additionally, it should be noted that the undergrounding alternative (Reduced Profile Alternative) has not been rejected; however, there are trade-offs with respect to the physical environmental effects associated with the Reduced Profile Alternative. As discussed in Section 6.0 Alternatives, the Reduced Profile Alternative is considered the environmentally preferred alternative of those considered. This alternative would reduce visual impacts but would increase impacts related to geologic and construction impacts. Specifically, construction impacts related to noise, air pollution, and traffic would increase due to the extended construction schedule. It is noted that the project has been updated to include a partial burial of the towers, that results in both the reduced aesthetic impacts and reduced construction impacts (see Appendix I). The City Council is the only body with the discretionary authority to decide whether an alternative should be supported or rejected for this project. However, since all of the environmental impacts of the proposed project can be mitigated there is no requirement to select an alternative in place of the proposed project. Please refer to response 3B for additional discussion of the process the project will undergo for consideration of EIR certification and project approval. It should also be noted that in response to input received during the CEQA public review process, the updated project design includes a lowered profile and other features intended to address public concerns regarding the visual compatibility of the project with the surrounding area. The updated project description and full impact evaluation of the modifications are included in Appendix I. The updated project design reduces the projects visual effects compared to the conceptual design examined in the DEIR. Response 6(C) The commenter asserts preference for locating the project at another site with industrial zoning. See General Response 1 – Alternative Sites. This comment is noted, but no further response is necessary.

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Response 6(D) The commenter requests submittal of the project to the City of Los Angeles’ permitting process, but acknowledges the project is exempt pursuant to State Law. The commenter further asserts that the Councilman’s office and Mar Vista Community Council be furnished with regulatory filings, notices of hearings or other public input opportunities, and permits issued. These requests are noted and copies will be furnished upon request. Response 6(E) The commenter states that there are significant unresolved issues pertaining to environmental safety, water rights, traffic, noise, and aesthetics. The commenter further asserts an opinion that the project would intensify uses at the site and would have a detrimental effect on the quality of life in the neighborhood. The proposed project would have no effects that cannot be mitigated to levels that are less than significant. No statements of overriding considerations would be necessary. Mitigation requirements of the project would be ensured through the adoption and implementation of a Mitigation Monitoring and Reporting Program (MMRP) as required under CEQA. The proposed project would involve re-activation and remediation of this already developed groundwater pumping facility to restore groundwater pumping. The activity would have an overall beneficial impact on regional water supplies due to reduced reliance on Metropolitan Water District (MWD) deliveries. Please refer to General Response- 2 Aesthetics, General Response 3- Noise, and General Response 4 – Hazardous Materials for additional discussion in these issue areas. Also please see response 3H for a discussion about groundwater rights. Please see Response 1, Response 4(B) and Response 4(E) for additional discussions regarding project generated traffic. Response 6F The commenter issues a request for the City of Santa Monica to work closely with the neighbors and Mar Vista Community Council to develop the project and implement mitigation in consultation with and agreeable to the Mar Vista Community Council. The history of the CEQA public outreach, scoping and public review process is outlined in the Introduction section of the EIR. The City of Santa Monica has employed a comprehensive public outreach program for this project since its inception which goes beyond the EIR process. Through the CEQA process the City of Santa Monica has considered all input received by the public including the development and analysis of alternatives. It is also noted that the Mar Vista Community Council and Windward School are included within mitigation measure AES-1(a) as a participant in evaluating aesthetic mitigation designs.

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Response 7 COMMENTER: Thomas M. Erb, Director of Water Resources, Los Angeles Department of

Water and Power DATE: October 1, 2008 RESPONSES: Response 7(A) The commenter requests evaluation of an alternative site within the City of Santa Monica. Please refer to General Response 1 – Alternative Sites. Response 7(B) The commenter requests evaluation of the SMWTP as an alternative location for treatment of the contaminated groundwater. Please refer to General Response 1 – Alternative Sites. Response 7(C) The commenter requests that any necessary permits from the City of Los Angeles, including a Conditional Use Permit be listed in the project description of the EIR. These comments are noted; however, as discussed in Section 2.0 Project Description and as mentioned under General Response 2 and Response 6(D) of this section, cities are exempt from each others building and zoning ordinances pursuant to California Government Code § 53091. Therefore, no changes have been made to the project description. Response 7(D) The commenter asserts that the safe yield of the basin should be established and that all pumping by the City of Santa Monica should be within the safe yield of the sub-basin to prevent subsidence and other geologic impacts. Please refer to Response 3(H). Response 7(E) The commenter requests evaluation of additional options to mitigate aesthetic impacts associated with the 24-foot tall GAC towers. Please refer to General Response 1 – Alternative Sites and General Response 2 – Aesthetics. Furthermore, it is emphasized the CEQA Guidelines does not require evaluation of every possible alternative, and the Guidelines provide the following guidance with respect to selection of alternatives.

“An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decisionmaking and public participation.” (CEQA Guidelines Section 15126.6(a))

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It is the City’s opinion that the EIR examines a reasonable range of alternatives and that it was also responsive to the public comment in developing the alternatives to be examined. The alternatives examined in the EIR were a direct result of public input received and were intended to address potentially significant impacts of the project consistent with the requirements of CEQA. Response 7(F) The commenter asserts an opinion that a contingency plan needs to be identified to provide for remediation in the event that additional groundwater contaminants are detected in the future or the concentrations of groundwater contaminants are higher than anticipated. This comment is noted. The City conducted several pilot projects to determine the most efficient and reliable method of treating the water and restoring production. As discussed under Response 4(F), a number of studies were prepared to evaluate the groundwater contaminants and determine the best method of treatment. These reports are referenced in bullet format near the end of Response 4(F) and are included in the appendices. The EIR has considered these contaminants and the remediation system would serve to treat the groundwater to drinking water standards as previously mentioned. The remediation system is designed to remove MBTE, TBE, TCE, 1,1-DCE as discussed in Section 4.4 Hazards of the DEIR, General Response 4 – Hazardous Materials and Response 3(F). The proposed project involves an extensive monitoring program that would be implemented throughout the final design, implementation and operational phases of the project. Ongoing planning has and will continue to consider contingencies such as those that are suggested by the commenter. If significant modifications to the proposed project are required, the approval of such modifications would be subject to subsequent CEQA review. The extent of such review would depend upon the nature of the project modification and the potential for any modification to result in significant environmental impacts that are not addressed in this EIR. Please see General Response 4 – Hazards and Hazardous Materials

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Response 8 COMMENTER: Terry Roberts, Senior Planner, State Clearinghouse DATE: October 7, 2008 RESPONSES: Response 8 The commenter indicates the project has been submitted to the State Clearinghouse and complied with State Clearinghouse review requirements. A second letter is included, forwarding comments from the Native American Heritage Commission. This letter was received earlier and is addressed as response 2. Please see response 2 to address comments from the Native American Heritage Commission. No additional response is necessary.

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Documents

City of Santa Monica Charnock Well Field Restoration Project · 2009-11-19 · Charnock Well Field Restoration Project Final Environmental Impact Report Volume I: Report Prepared