City of Los Angeles Paramount Pictures Master Plan Project SCH. No. 2011101035 September 2015 Page IV.L.2-1 IV. Environmental Impact Analysis L.2 Utilities and Service Systems— Wastewater 1. Introduction This section of the Draft EIR provides an analysis of the proposed Project’s potential impacts with regard to the existing wastewater infrastructure and treatment facilities that serve the Project Site. The analysis describes the existing wastewater system (including local and regional conveyance and treatment facilities), calculates the wastewater to be generated by the proposed Project, and evaluates whether sufficient capacity is available and will be available to meet the proposed Project’s estimated wastewater generation. The proposed Project’s consistency with relevant regulations pertaining to wastewater collection and treatment is also discussed. The analysis is based on the Wastewater System Technical Report (hereinafter the “Wastewater Report”), prepared by Incledon Consulting Group (August 2015), and included as Appendix U of this Draft EIR, as well as data from the City of Los Angeles Department of Public Works, Bureau of Sanitation (Bureau of Sanitation) and Bureau of Engineering. 2. Environmental Setting a. Regulatory Framework (1) City of Los Angeles General Plan Framework The City of Los Angeles General Plan Framework guides the update of the community plan and citywide elements, thereby providing a citywide strategy for long-term growth. As such, it addresses State and federal mandates to plan for the future. Chapter 9, Infrastructure and Public Services, of the City’s General Plan Framework identifies goals, objectives, and policies for utilities in the City. Goal 9A of Chapter 9 sets as a goal adequate wastewater collection and treatment capacity for the City and in basins tributary to City-owned wastewater treatment facilities. (2) City of Los Angeles Integrated Resources Plan The City of Los Angeles Integrated Resources Plan was created through a contemporary approach that emphasized stakeholder involvement, public input, and
Transcript
City of Los Angeles Paramount Pictures Master Plan Project SCH. No. 2011101035 September 2015
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IV. Environmental Impact Analysis L.2 Utilities and Service Systems—
Wastewater
1. Introduction
This section of the Draft EIR provides an analysis of the proposed Project’s potential impacts with regard to the existing wastewater infrastructure and treatment facilities that serve the Project Site. The analysis describes the existing wastewater system (including local and regional conveyance and treatment facilities), calculates the wastewater to be generated by the proposed Project, and evaluates whether sufficient capacity is available and will be available to meet the proposed Project’s estimated wastewater generation. The proposed Project’s consistency with relevant regulations pertaining to wastewater collection and treatment is also discussed. The analysis is based on the Wastewater System Technical Report (hereinafter the “Wastewater Report”), prepared by Incledon Consulting Group (August 2015), and included as Appendix U of this Draft EIR, as well as data from the City of Los Angeles Department of Public Works, Bureau of Sanitation (Bureau of Sanitation) and Bureau of Engineering.
2. Environmental Setting
a. Regulatory Framework
(1) City of Los Angeles General Plan Framework
The City of Los Angeles General Plan Framework guides the update of the community plan and citywide elements, thereby providing a citywide strategy for long-term growth. As such, it addresses State and federal mandates to plan for the future. Chapter 9, Infrastructure and Public Services, of the City’s General Plan Framework identifies goals, objectives, and policies for utilities in the City. Goal 9A of Chapter 9 sets as a goal adequate wastewater collection and treatment capacity for the City and in basins tributary to City-owned wastewater treatment facilities.
(2) City of Los Angeles Integrated Resources Plan
The City of Los Angeles Integrated Resources Plan was created through a contemporary approach that emphasized stakeholder involvement, public input, and
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interdepartmental collaboration.1 Multiple departments worked together to develop a single, integrated plan to address the facility needs of the City’s wastewater program, recycled water, and urban runoff/stormwater management through the year 2020.
The Los Angeles City Council certified the Integrated Resources Plan Final EIR in 2006 and adopted the Approved Alternative (Alternative 4) from the four Preliminary Alternatives. The Final Integrated Resources Plan 5-Year Review was released in June 2012. According to the Final Integrated Resources Plan 5-Year Review, Alternative 4 included 12 projects that were separated into two categories: (1) “Go Projects” for immediate implementation; and (2) “Go-If Triggered Projects” for implementation in the future once a trigger is reached.2 Triggers for these projects include wastewater flow, population, regulations, or operational efficiency. Based on the Final Integrated Resources Plan 5-Year Review, the Go Projects consisted of six capital improvement projects for which triggers were considered to have been met at the time the Integrated Resources Plan EIR was certified. The Go-If Triggered Projects consisted of six capital improvement projects for which triggers were not considered to have been met at the time the Integrated Resources Plan EIR was certified.
Since the implementation of the Integrated Resources Plan, new programs and projects, which have resulted in a substantial decrease in wastewater flows, have affected the Go Projects and Go-If Triggered Projects. Based on the Final Integrated Resources Plan 5-Year Review, two of the six Go Projects have been moved to the Go-If Triggered category and two have been deferred beyond the 2020 planning window of the Integrated Resources Plan. For the remaining two projects, construction of wastewater storage facilities at the Donald C. Tillman Water Reclamation Plant (Go Project 1) has been completed, and construction of the North East Interceptor Sewer Phase II (Go Project 6) is anticipated to begin in 2015 and end in 2022.3
(3) Sewer System Management Plan
On May 2, 2006, the State Water Resources Control Board adopted the Statewide General Waste Discharge Requirements for publicly owned sanitary sewer systems greater than 1 mile in length that collect and/or convey untreated or partially treated wastewater to
1 The Integrated Resources Plan replaced the City’s 1991 Wastewater Facilities Plan. 2 City of Los Angeles Department of Public Works Bureau of Sanitation and Department of Water and Power,
Integrated Resources Plan 5-Year Review FINAL Documents, June 2012, www.lacitysan.org/irp/documents/FINAL_IRP_5_Year_Review_Document.pdf, accessed March 2, 2015.
3 City of Los Angeles Department of Public Works, LA Sewers Website, Donald C. Tillman Water Reclamation Plant, Construction Projects, http://eng.lacity.org/iuprs/by_project_title_results.cfm?cfid=233809&cftoken=59463495, accessed March 24, 2015.
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a publicly owned treatment facility in California. Under the Statewide General Waste Discharge Requirements, the owners of such systems must comply with the following requirements: (1) acquire an online account from the State Water Board and report all sanitary sewer overflows online; and (2) develop and implement a written plan referred to as a Sewer System Management Plan to control and mitigate sanitary sewer overflows and make it available to any member of the public upon request in writing.
In accordance with the Statewide General Waste Discharge Requirements, the City of Los Angeles acquired online accounts from the State Water Board and began reporting sanitary sewer overflows by the due date of January 2, 2007. A Sewer System Management Plan was prepared for each of the City’s sanitary sewer systems and approved by the City’s Board of Public Works on February 18, 2009.4 The City’s Sewer System Management Plans were last updated in February 2014, which confirmed that the City’s Sewer System Management Plans are in full compliance with the Statewide General Waste Discharge Requirements and are effective.5
The goal of the Sewer System Management Plan for the Hyperion Sanitary Sewer System, in which the Project Site is located (as discussed below), is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system.6 In addition, the Sewer System Management Plan will help to reduce and prevent sanitary sewer overflows, as well as to mitigate any sanitary sewer overflows that do occur.
(4) Los Angeles Municipal Code
Los Angeles Municipal Code (LAMC) Sections 64.11 and 64.12 require approval of a sewer permit prior to connection to the sewer system. New connections to the sewer system are assessed a Sewerage Facilities Charge. The rate structure for the Sewerage Facilities Charge is based upon wastewater flow strength as well as volume. The determination of wastewater strength for each applicable project is based on City guidelines for the average wastewater concentrations of two parameters, biological oxygen demand, and suspended solids, for each type of land use. Fees paid to the Sewerage Facilities Charge are deposited in the City’s Sewer Construction and Maintenance Fund for
4 City of Los Angeles Department of Public Works, Sewer System Management Plan, www.lasewers.org/ssmp/index.htm, accessed March 2, 2015.
5 City of Los Angeles Department of Public Works, LA Sewers Website, Sewer System Management Plan, www.lasewers.org/ssmp/index.htm, accessed March 24, 2015.
6 City of Los Angeles Department of Public Works Bureau of Sanitation, Hyperion Sanitary Sewer System: Sewer System Management Plan, May 2011, http://lasewers.org/ssmp/pdfs/SSMP_Hyperion.pdf, accessed March 2, 2015.
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sewer and sewage-related purposes, including, but not limited to, industrial waste control and water reclamation purposes.
Section 64.15 of the LAMC requires that the City perform a Sewer Capacity Availability Review when any person seeks a sewer permit to connect a property to the City’s sewer collection system, proposes additional discharge through their existing public sewer connection, or proposes a future sewer connection or future development that is anticipated to generate 10,000 gallons or more of sewage per day. A Sewer Capacity Availability Review is an analysis of the existing sewer collection system to determine if there is adequate capacity existing in the sewer collection system to safely convey the newly generated sewage to the appropriate sewage treatment plant. If there is allotted sewer capacity available for the project, then the City’s Department of Building and Safety will accept the plans and specifications for plan check upon the payment of plan check fees. If a project is eligible to receive an allocation as a non-priority project, and the monthly allotment has been used, then the project is placed on a waiting list for the next month’s allotment. At the request of the project applicant, the Department of Building and Safety will accept the project’s plans and specifications as acceptable for plan check even if the project has been placed on the waiting list and a sewer permit has not yet been obtained from the City of Los Angeles Department of Public Works, with the understanding that the project will not be able to connect to the City’s wastewater system until capacity is available and a sewer permit issued.
In addition, the City of Los Angeles Bureau of Engineering Special Order No. SO06-0691 sets forth design criteria for sewer systems. Specifically, the order states that trunk, interceptor, outfall, and relief sewers (i.e., sewers that are 18 inches or greater in diameter) be designed for a planning period of 60–100 years and lateral sewers (i.e., sewers that are less than 18 inches in diameter) be designed for a planning period of 100 years. The order also requires that sewers be designed so that the peak dry weather flow depth, during their planning period, shall not exceed 50 percent of the pipe diameter.
b. Existing Conditions
(1) Wastewater Infrastructure
(a) Local Area Conditions
Sanitary sewer service to and from the proposed Project area is owned and operated by the City of Los Angeles. The existing wastewater collection system includes more than 6,700 miles of public sewers, which serves a population of more than 4 million
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people and conveys approximately 400 million gallons of wastewater per day to the City’s four wastewater treatment and water reclamation plants.7
Locally, the Project Site is served by private on-site, gravity flow sanitary sewers. All on-site wastewater flows from the private sanitary sewers ultimately discharge into City-owned sanitary sewers in streets within and adjacent to the Project Site as shown on Figure IV.L.2-1 on page IV.L.2-6 and discussed in more detail below. All City sanitary sewer systems serving the Project Site ultimately connect to the City’s Wilshire-Hollywood Interceptor Sewer, which is located in Norton Avenue.
As shown in Figure IV.L.2-1, the Main Lot is served by a 20-inch-diameter City sanitary sewer in Melrose Avenue and an 8-inch-diameter City sanitary sewer in Van Ness Avenue. The 20-inch-diameter City sanitary sewer in Melrose Avenue connects to the 20-inch-diameter sanitary City sewer in Bronson Avenue, which ultimately connects to an 18-inch-diameter City sanitary sewer in Norton Avenue to the south of the Project Site. The 8-inch-diameter City sanitary sewer in Van Ness Avenue also connects to the 20-inch-diameter City sanitary sewer in Bronson Avenue.
The Gregory Lot, Waring Lot and Camerford Lot are served by 8-inch-diameter City sanitary sewers located in alleys adjacent to the properties. The Gregory Lot and Waring Lot are served by an 8-inch-diameter City sanitary sewer in Waring Alley, which then connects to an 8-inch-diameter City sanitary sewer in El Centro Avenue, which connects to the 20-inch-diameter City sanitary sewer in Melrose Avenue. The Camerford Lot is served by an 8-inch-diameter City sanitary sewer in Melrose Avenue Alley, which then connects to the 8-inch-diameter City sanitary sewer in El Centro Avenue, which connects to the 20-inch-diameter City sanitary sewer located in Melrose Avenue. The Windsor Lot is served by the 20-inch-diameter City sanitary sewer in Melrose Avenue. The South Bronson Lot is served by the 20-inch-diameter City sanitary sewer in Melrose Avenue and the 20-inch-diameter City sanitary sewer located in Bronson Avenue. The Lemon Grove Lot is served by multiple laterals from the 8-inch-diameter City sanitary sewer in Van Ness Avenue and an 8-inch-diameter City sanitary sewer in Ridgewood Place, both of which connect to the 20-inch-diameter City sanitary sewer in Melrose Avenue, which connects to the 20-inch-diameter City sanitary sewer in Bronson Avenue.
According to the Bureau of Sanitation, the existing 18-inch-diameter (Norton Avenue), 20-inch-diameter (Melrose Avenue), and 20-inch-diameter (Bronson Avenue) City sanitary sewers providing service to the Project Site are operating at current flow levels of
7 City of Los Angeles, Department of Public Works, City Sewers, www.lasewers.org/sewers/about/index.htm, accessed March 2, 2015.
Source: Incledon Consulting Group, 2015.
Figure IV.L.2-1Existing Sanitary Sewer Lines
EXISTING CITYSANITARY SEWER LINE
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26 percent, 32 percent, and 25 percent, respectively.8 The Bureau of Sanitation does not have gauging information for the other sanitary sewer lines that serve the Project Site at this time.9
(b) On-Site Conditions
Sanitary sewer flows from the western area of the Main Lot are collected by a 6-inch-diameter sanitary sewer in Avenue C that connects to the 20-inch-diameter City sanitary sewer in Melrose Avenue discussed above. The 6-inch-diameter sanitary sewer in Avenue C also connects with a 10-inch-diameter City sanitary sewer lateral located near the Paramount Plaza across from Windsor Boulevard. This 10-inch-diameter lateral then connects to the 20-inch-diameter City sanitary sewer in Melrose Avenue.
Sanitary sewer flows from the central area of the Main Lot are collected by two 6-inch-diameter sanitary sewers located in Avenue K and Avenue P. These 6-inch-diameter sanitary sewers connect to 8-inch-diameter City sanitary sewer laterals located in the Valentino Place Alley and Valentino Place right-of-way. These 8-inch-diameter sanitary sewers combine into a single 8-inch-diameter sanitary sewer, continue south on Valentino Place, and connect to the 20-inch-diameter City sanitary sewer in Melrose Avenue.
Sanitary sewer flows from the eastern areas of the Main Lot connect to the 8-inch-diameter City sanitary sewer in Van Ness Avenue via three 8-inch-diameter sanitary sewer laterals. These laterals are located within Marathon Street, Monroe Street, and 11th Street.
The sewer lines serving the Ancillary Lots are discussed above.
(2) Wastewater Treatment
The Bureau of Sanitation operates four treatment and water reclamation plants: the Hyperion Treatment Plant, the Donald C. Tillman Water Reclamation Plant, the Terminal Island Water Reclamation Plant, and the Los Angeles–Glendale Water Reclamation Plant.10 The main purpose of these treatment facilities is to remove potential pollutants from sewage in order to protect river and marine environments and public health.
8 Written correspondence from Ali Poosti, Acting Division Manager, Wastewater Engineering Services Division, City of Los Angeles Bureau of Sanitation; dated November 29, 2011. See Appendix A.3 of this Draft EIR.
9 Wastewater Report, Incledon Consulting Group, March 2012. 10 City of Los Angeles, Department of Public Works, Treatment Plants, www.lasewers.org/treatment_plants/
about/index.htm, accessed March 2, 2015.
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(a) Hyperion Service Area
The Integrated Resources Plan divides the wastewater treatment system of the City into two major service areas: the Hyperion Service Area and the Terminal Island Service Area.11 The Hyperion Service Area is served by the Hyperion Treatment Plant, the Donald C. Tillman Water Reclamation Plant, and the Los Angeles–Glendale Water Reclamation Plant. The Terminal Island Service Area is served by the Terminal Island Treatment Plant. The Project Site is located within the Hyperion Service Area. As shown in Table IV.L.2-1 on page IV.L.2-9, the existing design capacity of the Hyperion Service Area treatment plants is approximately 550 million gallons per day (consisting of 450 million gallons per day at the Hyperion Treatment Plant, 80 million gallons per day at the Donald C. Tillman Water Reclamation Plant, and 20 million gallons per day at the Los Angeles–Glendale Water Reclamation Plant).12 The current flows to the treatment plants that comprise the Hyperion Service Area total approximately 449 million gallons per day (consisting of 362 million gallons per day to the Hyperion Treatment Plant, 67 million gallons per day to the Donald C. Tillman Water Reclamation Plant, and 20 million gallons per day to the Los Angeles–Glendale Water Reclamation Plant).13 The current flows are below the design capacity of the Hyperion Service Area of approximately 550 million gallons per day.
(b) Hyperion Treatment Plant
Wastewater flows from the Project Site are treated at the Hyperion Treatment Plant. As shown in Table IV.L.2-1, the Hyperion Treatment Plant has the capacity to treat approximately 450 million gallons per day of wastewater for full secondary treatment. The plant currently treats approximately 362 million gallons per day.14 As such, the Hyperion Treatment Plant is currently operating at approximately 80 percent of its capacity, with an available capacity of approximately 88 million gallons per day. The treated water from the Hyperion Treatment Plant is discharged through an outfall pipe 5 miles into the Santa Monica Bay and Pacific Ocean.15
11 Ibid. 12 City of Los Angeles Department of Public Works, Bureau of Sanitation, About Wastewater—Facts and
Figures, www.lacitysan.org/wastewater/factsfigures.htm, accessed March 2, 2015. 13 Ibid. 14 Ibid. 15 City of Los Angeles Department of Public Works, Hyperion Treatment Plant, www.lasewers.org/
treatment_plants/hyperion/index.htm, accessed March 2, 2015.
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Table IV.L.2-1 Existing Capacity of Hyperion Service Area
Plant Design Capacity
(million gallons per day)
Hyperion Treatment Plant 450
Donald Tillman Water Reclamation Plant 80
Los Angeles/Glendale Water Reclamation Plant 20
Total 550
Source: City of Los Angeles Department of Public Works, Bureau of Sanitation, About Wastewater—Facts and Figures, www.lacitysan.org/wastewater/factsfigures.htm, accessed March 2, 2015.
Incoming wastewater to the treatment plant initially passes through screens and basins to remove coarse debris and grit. This is followed by primary treatment, which is a physical separation process where solids are allowed to either settle to the bottom of tanks or float on the surface. These solids, called sludge, are collected, treated, and recycled. The portion of water that remains, called primary effluent, is treated through secondary treatment using a natural, biological approach. Living micro-organisms are added to the primary effluent to consume organic pollutants. These micro-organisms are later harvested and removed as sludge. After treatment is completed, the water is dispersed 5 miles offshore at a depth of 200 feet. As this treated effluent enters the ocean environment, it is diluted at a ratio of over 80 parts seawater to one part treated effluent. The discharge of effluent from the Hyperion Treatment Plant into Santa Monica Bay is regulated by permits issued under the Clean Water Act’s National Pollution Discharge Elimination System and is required to meet the Regional Water Quality Control Board’s requirements for a recreational beneficial use. Accordingly, the Hyperion Treatment Plant’s effluent to Santa Monica Bay is continually monitored to ensure that it meets or exceeds prescribed standards. The Los Angeles County Department of Health Services also monitors flows into Santa Monica Bay.16,17
The sludge that is collected at the plant is anaerobically digested in order to reduce volume and to produce valuable methane gas for energy recovery. Excess water that
16 City of Los Angeles Department of Public Works, Bureau of Sanitation, Environmental Monitoring Division, “Santa Monica Bay Biennial Assessment Report: 2005–2006,” http://lacitysan.org/emd/products/index.htm, accessed March 24, 2015.
17 City of Los Angeles Department of Public Works, Bureau of Sanitation, Environmental Monitoring Division, FAQS, www.lacitysan.org/emd/faqs/index.htm#a4, accessed March 2, 2015.
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remains in digested sludge is spun out by centrifuge dewatering equipment. The resultant material is well suited for reuse in a variety of beneficial methods. At present, 100 percent of the sludge is beneficially reused, either as an agricultural soil additive, as compost, as a fuel source in an energy recovery system, or as a chemically treated soil substitute for landfill cover.18
(3) Wastewater Generation
The existing average wastewater flow rates from the Project Site were calculated using existing metered domestic water demand volumes.19 Based on information from the Bureau of Sanitation, the amount of wastewater flows is assumed to be 90 percent of domestic water use. According to the Wastewater Report, the total average daily wastewater discharge from the Project Site under existing conditions is estimated at 0.196 cubic foot per second, which is equivalent to 0.127 million gallons per day.20 Peak daily wastewater discharge from the Project Site under existing conditions is 0.604 cubic foot per second, which is equivalent to 0.390 million gallons per day.
3. Project Impacts
a. Methodology
To evaluate potential impacts relative to wastewater infrastructure, the Wastewater Report was prepared for the Project Site. The report analyzes the impact of the proposed Project on existing off-site sanitary sewer facility capacity. Based on City wastewater generation information for sanitary sewer service, an estimate was made as to the wastewater generation of the proposed Project. Given the existing capacity of the Project Site’s sanitary sewer system and the Project Site’s future demand, an assessment was made of the impacts to the sanitary sewers and the City’s downstream sewers and treatment plants. The sanitary sewer system was evaluated by determining existing physical features and capacities of the system. Information was obtained from the Bureau of Sanitation as needed to define the existing system’s conveyance and treatment capacities.
18 Wastewater Report, Incledon Consulting Group, March 2012. 19 Average metered domestic water demand volumes are based on account usage statements provided by
the Applicant. 20 The existing peak wastewater flow rates were calculated using the following formula provided by the
American Society of Civil Engineers Gravity Sanitary Sewer Design and Construction manual: Peak flow rate = 2.64 * (Average Flow Rate in cubic feet per second ^ 0.905).
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To evaluate potential impacts relative to wastewater treatment capacity, this analysis evaluates whether adequate treatment capacity within the Hyperion Service Area would be available to accommodate the proposed Project based on the estimate of the proposed Project’s wastewater generation and data from the Bureau of Sanitation.
For the assessment of cumulative impacts on wastewater conveyance, the projected cumulative wastewater generation of the proposed Project and related projects in areas that are tributary to City sewers serving the Project Site area are compared to the capacity of such sewers. For the assessment of cumulative impacts on wastewater treatment, the projected cumulative wastewater generation is compared to the estimated available capacity of the Hyperion Service Area.
b. Significance Thresholds
Appendix G of the CEQA Guidelines provides a set of sample questions that address impacts with regard to wastewater. These questions are as follows:
Would the project:
Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board?
Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which would cause significant environmental effects?
Result in a determination by the wastewater treatment provider, which serve or may serve the project, that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
In the context of these questions from Appendix G of the CEQA Guidelines, the City of Los Angeles CEQA Thresholds Guide states that a project would normally have a significant wastewater impact if:
The project would cause a measurable increase in wastewater flows at a point where, and a time when, a sewer’s capacity is already constrained or that would cause a sewer’s capacity to become constrained; or
The project’s additional wastewater flows would substantially or incrementally exceed the future scheduled capacity of any one treatment plant by generating
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flows greater than those anticipated in the Wastewater Facilities Plan or General Plan and its elements.21
c. Project Design Features
To accommodate the proposed Project, new sanitary sewer lines and connections would be constructed both on-site and off-site. Specifically, where new buildings would be constructed over existing sanitary sewers, the existing lines would be abandoned and replaced with new, relocated lines within adjacent on-site streets as new buildings are constructed. In addition, several existing on-site and off-site sanitary sewers would also be replaced with larger lines to handle the increase in wastewater as areas of the Project Site are redeveloped. Prior to the development of a new building, the capacity of the on-site sanitary sewers serving the building would be evaluated using Bureau of Sanitation and California Plumbing Code standards, and replacement or new sanitary sewers would be installed as necessary. New sanitary sewers would be designed and constructed to conform to the applicable Bureau of Sanitation and California Plumbing Code standards. A conceptual plan for the new on-site and off-site sewer lines and connections is provided in Figure IV.L.2-2 on page IV.L.2-13.
In addition, as specified in Project Design Feature L.1-2 in Section IV.L.1, Utilities and Service Systems—Water Supply, of this Draft EIR, the proposed Project would implement a variety of water conservation features including, but not limited to, the use of high-efficiency irrigation systems, water-efficient landscaping, landscape contouring, high-efficiency toilets and fixtures, high-efficiency dishwashers and clothes washers, cooling tower conductivity controller, and standardized bottle-less water filters for drinking water. By reducing the amount of water consumed, these conservation measures would also serve to reduce the amount of wastewater generated by the proposed Project. To provide a conservative analysis, reductions in wastewater flows from implementation of these features are not accounted for in the estimate of the proposed Project’s wastewater generation below.
d. Analysis of Project Impacts
(1) Construction
Construction activities for the proposed Project would result in a temporary increase in wastewater generation as a result of construction employees on-site. Wastewater
21 The Wastewater Facilities Plan referenced in the City of Los Angeles CEQA Thresholds Guide has since been superseded by the Integrated Resources Plan.
Source: Incledon Consulting Group, 2015.
Figure IV.L.2-2Proposed Sanitary Sewer Lines
PROPOSED TO BE ABANDONEDSANITY SEWER LINE
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generation would occur incrementally throughout construction of the proposed Project (i.e., up to 2038). However, such use would be temporary and nominal when compared with the wastewater generated by an occupied permanent building. Thus, wastewater generation from proposed Project construction activities is not anticipated to cause a measurable increase in wastewater flows at a point where, and at a time when, a sewer’s capacity is already constrained or that would cause a sewer’s capacity to become constrained. For these same reasons, construction of the proposed Project is not anticipated to generate wastewater flows that would substantially or incrementally exceed the future scheduled capacity of any one treatment plant by generating flows greater than those anticipated in the Integrated Resources Plan.
Furthermore, the majority of proposed sanitary sewers, as shown in Figure IV.L.2-2 on page IV.L.2-13 and described above in the discussion of the project design features, would be constructed within the Project Site, with the exception of new and relocated lateral connections to the City sanitary sewer systems in adjacent streets. Construction impacts (including, but not limited to, street, traffic detouring and control, and impacts to other utilities) would be confined along Melrose Avenue and streets adjacent to the Ancillary Lots. Construction activities would include trenching for the sanitary sewer lines and would be temporary in nature. Pursuant to Project Design Feature K-2 in Section IV.K, Traffic, Access, and Parking, of this Draft EIR, during construction of the proposed Project, construction traffic management plans would be implemented to ensure that adequate and safe access and parking remains available within and near the Project Site during construction activities. As part of these plans, provisions for temporary traffic control (e.g., flaggers) would be provided during all construction activities along public rights-of-way to improve traffic flows. With implementation of the construction traffic management plans, construction impacts to the wastewater system would be less than significant and no mitigation measures are required.
(2) Operation
(a) Wastewater Generation
Development of the proposed Project would result in an overall increase in sanitary sewer wastewater flows from the Project Site during operation. Wastewater generated by the proposed Project was estimated using wastewater generation factors provided by the Bureau of Sanitation for each of the various land uses.22 As shown in Table IV.L.2-2 on page IV.L.2-15, the proposed Project is estimated to generate an average net wastewater
22 Written correspondence from Ali Poosti, Acting Division Manager, Wastewater Engineering Services Division, City of Los Angeles Bureau of Sanitation, dated November 29, 2011. See Appendix A.3 of this Draft EIR.
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Table IV.L.2-2 Net New Wastewater Flow Rates Under Proposed Project
Proposed Land Use
Quantity (net new square
feet)
Wastewater Generation Ratea
(gallons per day/1,000 square feet)
Wastewater Generation
(million gallons per day)
Wastewater Generation
(cubic feet per second)
Stage 21,000 20 0.000 0.000
Production Officeb 635,500 150 0.095 0.147
Support 1,900 20 0.000 0.000
Officeb 638,100 150 0.096 0.149
Retailb 89,200 393 0.035 0.054
Total (Average) 0.226 0.350
Total (Peak)c 0.660 1.021
1 cubic foot per second = 0.646272 million gallons per day
Numbers may not total due to rounding. a Wastewater generation rates based on the Bureau of Sanitation Sewage Generation Rates. “Stage” and
”Support” demand rates are based on the Bureau of Sanitation Sewage Generation Rate for “Warehouse.”
b Wastewater generation rate for “Retail” reflects a weighted average of 75 percent retail and 25 percent fast food restaurant (indoor seat—1 seat/15 square feet).
c Per the City of Los Angeles Sewer Design Manual, Peak Flow Rate = 2.64 * (Average Flow Rate in cubic feet per second^0.905).
Source: Incledon Consulting Group, 2015.
flow of 0.226 million gallons per day (0.350 cubic foot per second) and a peak wastewater flow of 0.660 million gallons per day (1.021 cubic feet per second).23
(b) Wastewater Conveyance
When compared to existing gauging data for the City’s 20-inch-diameter sanitary sewer line in Melrose Avenue, the proposed Project’s net increase in average daily wastewater flow of 0.226 million gallons per day would equate to 33 percent of the current average flow rate. The 20-inch-diameter Melrose Avenue sewer is operating at a current flow level of 32 percent. With the proposed Project, the 20-inch-diameter Melrose Avenue sewer would operate at a flow level of 38 percent. Therefore, there is capacity to accommodate the increased flows from the proposed Project.
23 Average flow is used to determine capacity. Peak flow is used to determine pipe sizing, and is provided for informational purposes only.
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When compared to existing gauging data for the City’s 20-inch-diameter sanitary sewer line in Bronson Avenue, the proposed Project’s net increase in average daily wastewater flow of 0.226 million gallons per day would equate to 41.3 percent of the current average flow rate. The 20-inch-diameter Bronson Avenue sewer is operating at a current flow level of 25 percent. With the proposed Project, the 20-inch-diameter Bronson Avenue sewer would operate at a flow level of 29 percent. Therefore, there is capacity to accommodate the increased flows from the proposed Project
When compared to existing gauging data for the City’s 18-inch-diameter sanitary sewer line in Norton Avenue, the proposed Project’s net increase in average daily wastewater flow of 0.226 million gallons per day would equate to 14.6 percent of the current average flow rate. The 18-inch-diameter Norton Avenue sewer is operating at a current flow level of 26 percent. With the proposed Project, the 18-inch-diameter Norton Avenue sewer would operate at a flow level of 28 percent. Therefore, there is capacity to accommodate the increased flows from the proposed Project. As such, the proposed Project would have a less-than-significant impact on the City’s main sewer lines serving the Project Site.
In addition, as previously noted, the proposed Project estimates do not account for reductions in wastewater that would occur with implementation of the water conservation measures mentioned above and described more fully in Section IV.L.1, Utilities and Service Systems—Water Supply, of this Draft EIR. All sewer system improvements would be designed to meet applicable Bureau of Sanitation and California Plumbing Code standards. Therefore, based on the above, the proposed Project would not cause a measurable increase in wastewater flows at a point where, and a time when, a sewer’s capacity is already constrained or that would cause a sewer’s capacity to become constrained. Impacts with respect to wastewater generation and infrastructure would be less than significant and mitigation measures are not required.
(c) Wastewater Treatment
Wastewater generated by the proposed Project would be conveyed via the existing wastewater conveyance systems for treatment at the Hyperion Treatment Plant, which is a component of the Hyperion Service Area. The Hyperion Treatment Plant has the capacity to accommodate the additional wastewater flows from the proposed Project.24 The proposed Project’s net increase in average daily wastewater flow of 0.226 million gallons per day would equate to less than one percent of the current available capacity of the
24 Written correspondence from Ali Poosti, Acting Division Manager, Wastewater Engineering Services Division, City of Los Angeles Bureau of Sanitation, dated November 29, 2011. See Appendix A.3 of this Draft EIR.
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Hyperion Treatment Plant. Therefore, the proposed Project-generated wastewater would be accommodated by the existing capacity of the Hyperion Treatment Plant and a less-than-significant impact would occur.
As previously stated, for purposes of planning for Citywide wastewater treatment capacity, the Integrated Resources Plan divides the wastewater treatment system of the City into two major service areas: the Hyperion Service Area and the Terminal Island Service Area. The existing design capacity of the Hyperion Service Area is approximately 550 million gallons per day, and the existing design capacity of the Hyperion Treatment Plant is approximately 450 million gallons per day.25 The current flow to the treatment plants that comprise the Hyperion Service Area is approximately 449 million gallons per day, and the current flow to the Hyperion Treatment Plant is approximately 362 million gallons per day.26 Various factors, including future development of new treatment plants, upgrades/improvements to existing treatment capacity, development of new technologies, etc., will ultimately determine the available capacity of the Hyperion Service Area in 2038, the year by which construction of the proposed Project is expected to be completed. While it is anticipated that future iterations of the Integrated Resources Plan would provide for improvements beyond 2020 to increase the treatment capacity of the Hyperion Service Area (above the projected 2020 capacity of 550 million gallons per day) to serve future population needs, it is conservatively assumed that no new improvements to the wastewater treatment plants would occur between 2020 and 2038. Thus, based on this conservative assumption, the 2038 effective capacity of the Hyperion Service Area would remain unchanged from 2020 and as such, is assumed to be approximately 550 million gallons per day. Similarly, the capacity of the Hyperion Treatment Plant in 2038 is assumed to be 450 million gallons per day.
Even with this conservative assumption, the proposed Project’s net increase in average daily wastewater generation of 0.226 million gallons per day plus the current flows of approximately 449 million gallons per day to the Hyperion Service Area would represent approximately 81.7 percent of the Hyperion Service Area’s assumed future capacity of 550 million gallons per day. Similarly, the proposed Project’s net increase in average daily wastewater generation of 0.226 million gallons per day plus the current flows of approximately 362 million gallons per day to the Hyperion Treatment Plant would represent approximately 80.5 percent of the Hyperion Treatment Plant’s assumed future capacity of 450 million gallons per day. In addition, the proposed Project’s net increase in average daily wastewater generation of 0.226 million gallons per day would represent approximately
25 City of Los Angeles Department of Public Works Bureau of Sanitation, About Wastewater—Facts and Figures, www.lacitysan.org/wastewater/factsfigures.htm, accessed March 2, 2015.
26 Ibid.
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0.04 percent of the Hyperion Service Area’s assumed future capacity of 550 million gallons per day and approximately 0.05 percent of the Hyperion Treatment Plant’s assumed future capacity of 450 million gallons per day. Thus, the proposed Project’s additional wastewater flows would not substantially or incrementally exceed the future scheduled capacity of any treatment plant by generating flows greater than those anticipated in the Integrated Resources Plan. Impacts with respect to wastewater treatment capacity would be less than significant and mitigation measures are not required.
(3) Interim Projects
As part of ongoing operations at the Project Site, additions and changes to the Project Site occur on a continuous basis, including interior and exterior improvements. It is expected that such activities will continue during the time period the proposed Project is under consideration by the City. During the review process for the proposed Project, it is anticipated that approximately 50,000 square feet of new floor area would be constructed as part of ongoing business activities. These additional facilities are referred to as “interim projects.” The interim projects are anticipated to consist of new office, stage, production office, and/or support uses.
Using a wastewater generation rate of 150 gallons per day per 1,000 square feet, the interim projects would generate approximately 7,500 gallons per day in average daily flows at the Project Site.27 The 7,500 gallons per day in average daily flows of wastewater would represent approximately 6 percent of the total average daily wastewater generated by the existing mix of entertainment production uses and approximately three percent of the net increase in total average daily wastewater associated with the proposed Project. Therefore, due to the small net increase in total average daily wastewater associated with the interim projects and the current flow levels and the capacity to accommodate the increased flows from the proposed Project (as discussed above), there is capacity within the main sewer lines serving the Project Site to accommodate the increased flows from the interim projects. Furthermore, any sewer system improvements associated with the interim projects would be designed to meet the Bureau of Sanitation and California Plumbing Code standards.
With respect to wastewater treatment, the 7,500 gallons per day in average daily flows generated by the interim projects plus the current flows of approximately 449 million gallons per day would represent approximately 81.6 percent of the Hyperion Service Area’s
27 Wastewater generation factor is for Production Office and Office land use category, which is the highest wastewater generation factor for the potential uses associated with the interim projects, thereby representing a conservative analysis.
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assumed future capacity of 550 million gallons per day. In addition, the interim projects’ increase in wastewater generation of 7,500 gallons per day in average daily flows would represent approximately 0.001 percent of the Hyperion Service Area’s assumed future capacity of 550 million gallons per day. The interim projects’ flows plus the current flows of approximately 362 million gallons per day would represent approximately 80.4 percent of the Hyperion Treatment Plant’s assumed future capacity of 450 million gallons per day. In addition, the interim projects’ flows would represent approximately 0.002 percent of the Hyperion Treatment Plant’s assumed future capacity of 450 million gallons per day.
Development of the interim projects would not substantially alter existing conditions on the Project Site and would have no substantial effect on the proposed Project’s impacts related to wastewater.
4. Cumulative Impacts
The geographic context for the cumulative impact analysis on the wastewater conveyance system is the area that includes the Project Site and the related projects that would potentially utilize the same infrastructure as the proposed Project. The geographic context for the cumulative impact analysis on wastewater treatment facilities is the Hyperion Service Area. The proposed Project and the interim projects in conjunction with growth forecasted in the Hyperion Service Area through 2038 (i.e., the proposed Project buildout year), would cumulatively generate wastewater, thus potentially resulting in cumulative impacts on wastewater conveyance and treatment facilities. Cumulative growth in the greater Project area through 2038 includes specific known development projects as well as general ambient growth projected to occur, as described in Section III, Environmental Setting, of this Draft EIR. These related projects primarily include retail/commercial, residential, office, and hotel uses.
a. Wastewater Generation
Development of the proposed Project and interim projects in conjunction with the related projects would result in an increase in the demand for sanitary sewer service in the Bureau of Sanitation’s service area. Forecasted growth from known related projects in areas that are tributary to the City sewers serving the Project Site would generate approximately 0.191 million gallons per day of wastewater under average conditions and 0.565 million gallons per day under peak flows, as shown in Table IV.L.2-3 on page IV.L.2-20.28 Combined with the proposed Project’s 0.226-million-gallon-per-day
28 Average flow is used to determine capacity. Peak flow is used to determine pipe sizing, and is provided for informational purposes only.
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Table IV.L.2-3 Estimate of Net New Cumulative Wastewater Flow
1 cubic feet per second = 0.646272 million gallons per day
Numbers may not total due to rounding. a Wastewater generation rates based on the Bureau of Sanitation Sewage Generation Rates. b Wastewater generation rate for “Residential—Apartment” and “Residential—Condominium” are based on
the demand rates for 3-bedroom units. c Wastewater generation rate for “School—College” and “School—Dorm” based on Table IV.I-4, Estimated
Wastewater Generation by Proposed Project, Emerson College Los Angeles Center Project Draft Environmental Impact Report, October 2009.
d Per the City of Los Angeles Sewer Design Manual, Peak Flow Rate = 2.64 * (Average Flow Rate in cubic feet per second^0.905).
Source: Incledon Consulting Group, 2015.
average flow and 0.660-million-gallon-per-day peak flow, this equates to a cumulative increase in average daily wastewater flow of 0.417 million gallons per day and a cumulative increase in peak daily wastewater flow of 1.225 million gallons per day. Combined with the proposed Project’s 0.226-million-gallon-per-day average flow and the interim projects’
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7,500-gallon- per-day average flow, this equates to a cumulative increase in average daily wastewater flow of 0.425 million gallons per day.
b. Wastewater Conveyance
With respect to capacity in the City’s 20-inch-diameter sanitary sewer line in Melrose Avenue, the cumulative net increase in average daily wastewater flow from the proposed Project, interim projects, and related projects of 0.425 million gallons per day equates to 61.0 percent of the current average flow rate. The 20-inch-diameter Melrose Avenue sewer is operating at a current flow level of 32 percent; with the forecasted growth, the 20-inch-diameter Melrose Avenue sewer would operate at a flow level of 43 percent. Therefore, there is capacity to accommodate the increased flows.
With respect to capacity in the City’s 20-inch-diameter sanitary sewer line in Bronson Avenue, the cumulative net increase in average daily wastewater flow from the proposed Project, interim projects, and related projects of 0.425 million gallons per day equates to 76.2 percent of the current average flow rate. The 20-inch-diameter Bronson Avenue sewer is operating at a current flow level of 25 percent; with the forecasted growth, the 20-inch-diameter Bronson Avenue sewer would operate at a flow level of 34 percent. Therefore, there is capacity to accommodate the increased flows.
With respect to capacity in the City’s 18-inch-diameter sanitary sewer line in Norton Avenue, the cumulative net increase in average daily wastewater flow from the proposed Project, interim projects, and related projects of 0.425 million gallons per day equates to 27.0 percent of the current average flow rate. The 18-inch-diameter Norton Avenue sewer is operating at a current flow level of 26 percent; with the forecasted growth, the 18-inch-diameter Norton Avenue sewer would operate at a flow level of 29 percent. Therefore, there is capacity to accommodate the increased flows. As such, there is capacity within the main sewer lines serving the Project to accommodate the cumulative flows.
New development projects occurring in the proposed Project vicinity would be subject to LAMC Sections 64.11 and 64.12, which require approval of a sewer permit prior to connection to the sewer system. Additionally, in order to connect to the sewer system, related projects in the City of Los Angeles would be subject to payment of the City’s Sewerage Facilities Charge. Payment of such fees would help to offset the costs associated with infrastructure improvements that would be needed to accommodate wastewater generated by overall future growth. Furthermore, similar to the proposed Project, each related project would be required to comply with water conservation programs of the local jurisdictions and the state, which are described more fully in Section IV.L.1, Utilities and Service Systems—Water Supply, of this Draft EIR. Therefore, cumulative impacts on wastewater conveyance systems would be less than significant.
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c. Wastewater Treatment
It is anticipated that the completion of construction of the proposed Project would conclude by 2038. Therefore, cumulative impacts on wastewater facilities were analyzed relative to 2038 growth projected in the Hyperion Service Area.
As discussed above, without accounting for the proposed Project’s water conservation features, the proposed Project, interim projects, and related projects would generate a net increase in average daily wastewater flows of approximately 0.425 million gallons per day. The forecasted 2038 average dry weather flow for the Hyperion Service Area is approximately 450 million gallons per day.29 Based the Hyperion Service Area’s assumed future capacity of approximately 550 million gallons per day, the Hyperion Service Area is expected to have adequate capacity to accommodate the cumulative wastewater flow of approximately 450.4 million gallons per day from the proposed Project, interim projects, related projects, and forecasted growth by 2038. Therefore, cumulative impacts on the wastewater treatment systems would be less than significant.
5. Project Design Features and Mitigation Measures
a. Project Design Features
Provided below are those specific project design features that would be implemented to address wastewater and wastewater infrastructure. In addition to the project design features listed below, pursuant to Project Design Feature K-2 in Section IV.K, Traffic, Access, and Parking, of this Draft EIR, the Applicant would prepare and implement construction traffic management plans, which would outline measures to ensure emergency vehicle access during all aspects of Project construction, including, but not limited to, the use of a flaggers during construction activities along public rights-of-way to facilitate traffic flows until construction is complete. Please refer to Section IV.K, Traffic, Access and Parking, of this Draft EIR for additional information regarding the proposed Project’s construction traffic management plans. Additionally, as specified in Project Design Feature L.1-2 in Section IV.L.1, Utilities and Service Systems—Water Supply, of this Draft EIR, the proposed Project would implement a variety of water conservation features including, but not limited to, the use of: high-efficiency irrigation systems, water-efficient landscaping, landscape contouring, high-efficiency toilets and fixtures, high-efficiency dishwashers and clothes washers, cooling tower conductivity controller, and standardized bottle-less water filters for drinking water.
29 Electronic mail correspondence with C. Bryan Trussell, P.E., Los Angeles Department of Public Works, Wastewater Engineering Services Division, dated June 25, 2012. See Appendix P of this Draft EIR.
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Project Design Feature L.2-1: Prior to the development of a new building, the capacity of the on-site sanitary sewers that would serve the building shall be evaluated based on applicable Bureau of Sanitation and California Plumbing Code standards and replacement or new sanitary sewers shall be installed on-site as necessary to accommodate proposed flows.
Project Design Feature L.2-2: New Project sanitary sewers that may be necessary shall be designed and constructed to conform to the applicable Bureau of Sanitation and California Plumbing Code standards.
Project Design Feature L.2-3: If it is determined, as part of the evaluation performed pursuant to Project Design Feature L.2-1, that existing on-site laterals cannot be utilized for future service for new Project development, the Applicant shall be responsible for the construction of all new service connections to off-site City sanitary sewers. New Project service connections and laterals shall be designed and constructed in accordance with Bureau of Sanitation and California Plumbing Code standards.
b. Mitigation Measures
With implementation of the project design features discussed above, Project-level and combined cumulative impacts of the proposed Project, interim projects, and related projects on the City’s wastewater conveyance and treatment infrastructure would be less than significant during construction and operation. Therefore, no mitigation measures would be required.
6. Level of Significance after Mitigation
Project-level and combined cumulative impacts of the proposed Project, interim projects, and related projects on the City’s wastewater conveyance and treatment infrastructure would be less than significant during construction and operation.
