The Integrated Resources Plan (IRP) is a planning document prepared under the leadership of the

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1 IV.M.2 WASTEWATER 1. INTRODUCTION This section discusses the wastewater system for the proposed Project site and surrounding area and evaluates potential Project impacts on the existing wastewater system maintained by the Bureau of Sanitation (BoS) of the City of Los Angeles Department of Public Works (LADPW). The analysis below is based, in part, on the technical report prepared by KPFF Consulting Engineers for the proposed Project, entitled Barlow Replacement Hospital and Master Plan: Wastewater (2010). That report is included as Appendix IV.M.2 of this. 2. REGULATORY FRAMEWORK a. City of Los Angeles General Plan Framework The City of Los Angeles General Plan Framework Element is a plan for long term growth that establishes a City wide context for guiding the update of Community Plans and General Plan elements. The Framework Element characterizes the reuse of gray water as an opportunity to reduce wastewater generation, although it notes that systems should be designed to ensure that gray water does not enter the storm drain system. Goal 9A within Chapter 9, Infrastructure and Public Services, of the General Plan Framework, and the related objectives and policies address the need for adequate wastewater collection and treatment capacity for the City and in basins tributary to City owned wastewater treatment facilities. 1 b. City of Los Angeles Integrated Resources Plan (IRP) The Integrated Resources Plan (IRP) is a planning document prepared under the leadership of the BoS and the Department of Water and Power (DWP) to comprehensively address the City s wastewater, stormwater management, and recycled water needs. Phase I of the IRP project took place between 1999 and 2001 and addressed the interrelationships of the Los Angeles basin wide water, wastewater, and stormwater systems and the needs of these programs to serve the population of Los Angeles through the year 2020 (the Integrated Plan for the Wastewater Program, or IPWP). The IPWP addressed the complex interrelationships of the water, wastewater and stormwater systems and the anticipated needs of the City in the year Phase I studies focused on gaps in the ability of the City s current water resources systems to serve future populations and focused on ways to bridge 1 City of Los Angeles, General Plan Framework Element, Chapter 9: Infrastructure and Public Services, City of Los Angeles IV.M.2 1 Barlow Hospital Replacement and Master Plan Project

2 those gaps through planning of future facilities, resource management, and demand management. Phase I also resulted in the development of a set of performance based guiding principles for future planning of water resources management. The guiding principle pertaining to wastewater is as follows: Build new wastewater facilities upstream in the system. New or expanded wastewater facilities will be needed. Placing these facilities upstream in the system offers greater operating flexibility system wide, increases opportunities to beneficially reuse treated effluent, and reduces dependency on imported water for uses such as irrigation, industrial processing and cooling, etc. Phase II of the IRP, undertaken between 2002 and 2006, encompassed the preparation of technical studies and the identification and comparison of different alternative approaches to management of the City s water resources. Four final alternatives were developed, based on the studies undertaken in Phase I, to define the appropriate infrastructure, policies, and programs for implementation by The Los Angeles City Council certified the Final EIR in November 2006 and adopted a final alternative, the Approved Alternative (Alternative 4). Alternative 4 is intended to increase wastewater collection and treatment capacity, water reclamation storage and beneficial use, water conservation, and runoff management opportunities. The IRP is documented in a collection of reports that address facilities planning, financial planning, and environmental documentation. 2 c. Planned Capital Improvements Wastewater initially first flows through small diameter sewers called laterals, or lateral pipelines, that convey wastewater from residences or businesses into larger diameter sewer mains beneath streets, alleys, and other rights of way. Mains in turn connect to collectors and trunk lines that discharge into interceptor sewers. Interceptor sewers, which may be eight feet or more in diameter, convey wastewater to the City s treatment and water reclamation plants. i. Wastewater Capital Improvement Program Every 10 years, the Bureau of Sanitation of the City of Los Angeles Department of Public Works updates the 10 Year Capital Improvement Program to address planned replacement, rehabilitation, and expansion of the major wastewater collection system and treatment facilities within the City s service area. Many of these improvements are necessary for compliance with State and Federal 2 City of Los Angeles, Integrated Resources Plan (IRP), City of Los Angeles IV.M.2 2 Barlow Hospital Replacement and Master Plan Project

3 Clean Water Act regulations; improvements are then carried out by various divisions within the Bureaus of Sanitation and Engineering. The most recent update, the Wastewater Capital Improvement Program: Fiscal Year 2006/ /2016, defines improvements scheduled through 2016 to the collection system, pumping plants, and the four treatment plants that serve the area. 3 Improvements planned for the collection system include primary sewer projects (i.e., mains, or municipally owned pipes 18 or more inches in diameter), secondary sewer system projects (i.e., pipes less than 18 inches in diameter, serving residential and commercial properties), relief sewers, and emergency projects. ii. Collection System Settlement Agreement In 2004, the City of Los Angeles reached a settlement agreement with local governments and environmental organizations to replace aging and substandard secondary wastewater system infrastructure, or pipes less than 16 inches in diameter serving residential and commercial properties, over the course of 10 years. 4 The Agreement identified aging wastewater systems in need of rehabilitation or replacement throughout the City s service area. Approximately 2.46 miles of wastewater pipelines throughout the Silver Lake Echo Park, Central City North, and Central City areas bounded by Academy Road on the north, Temple Street on the south, the Los Angeles River on the east and Glendale Boulevard on the west were acknowledged to be more than 70 years old and to have reached the end of their useful life. This area includes the Project site, and improvements are planned for portions of the system in one of the City projects planned under the settlement agreement (e.g., Secondary Sewer Renewal Program (SSRP) N13). Wastewater infrastructure improvements under that City project commenced in February 2011, and are expected to be completed by June iii. Wastewater System Design Criteria The City of Los Angeles Bureau of Engineering Sewer Design Manual: Part F establishes design criteria for pipes within the City s wastewater system. The Sewer Design Manual recommends that pipes be designed for peak dry weather flow depths of less than 50 percent of pipe depth for pipes 18 inches or less in diameter, to accommodate fluctuations in flow while still maintaining design 3 City of Los Angeles, Department of Public Works, Bureau of Sanitation, Wastewater Capital Improvement Program, Fiscal Years 2006/ / pdf City of Los Angeles, Department of Public Works, Collection System Settlement Agreement, KPFF Consulting Engineers, pers. com., February 28, 2012 (based on latest City of Los Angeles Project Information Report for SSRP N13) City of Los Angeles IV.M.2 3 Barlow Hospital Replacement and Master Plan Project

4 velocities. 6 In addition, for purposes of analyzing remaining capacity, wastewater pipes are considered constrained (i.e., at capacity) when flows surpass 75 percent of pipe depth, since flows in excess of this can cause internal pressure and surcharges in upstream portions of the system. 7 Bureau of Engineering Special Order No , which also sets forth design criteria for gravity sewers, further states that trunk, interceptor, outfall, and relief sewers (i.e., wastewater pipes 18 inches in diameter and greater) should have at least a 60 to 100 year design life, and sewer laterals (i.e., pipes less than 18 inches in diameter) should have at least a 100 year design life. 8 d. City of Los Angeles Municipal Code Sections and of the Los Angeles Municipal Code (LAMC) require approval of a sewer permit, also called an S Permit, prior to connection to the wastewater system. New connections are assessed a Sewerage Facilities Charge based on wastewater flow volume and strength. 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 wastewater related purposes including but not limited to industrial waste control and water reclamation purposes. Section of the LAMC requires that a Sewer Capacity Availability Request (SCAR) be performed by the Department of Building and Safety when a sewer permit is sought for a new connection to the City's wastewater system, or in the event of a proposed increase in discharge to a public wastewater line or proposed future development anticipated to generate 10,000 gallons or more of wastewater per day. A SCAR evaluates the existing wastewater collection system to determine whether adequate capacity exists to convey project generated wastewater to the appropriate treatment plant. If capacity is available, the Department of Building and Safety accepts project plans and specifications for plan check; otherwise, projects are placed on a waiting list to receive an allocation of forthcoming capacity, or applicants are required to construct a connection to the nearest wastewater line with available capacity. The Department of Building and Safety accepts project plans and specifications for plan check if the project is on the waiting list, although the 6 KPFF Consulting Engineers, Barlow Master Plan and Replacement Hospital: Wastewater, (2010) 4. 7 City of Los Angeles, Department of Public Works, Bureau of Sanitation, Hyperion Sewer System Management Plan, (2009), City of Los Angeles, Department of Public Works, Bureau of Engineering, Special Order : Planning Period, Flow, and Design Criteria for Gravity Sanitary Sewers and Pumping Plants, City of Los Angeles IV.M.2 4 Barlow Hospital Replacement and Master Plan Project

5 project may not connect to the City s wastewater system until capacity is available and a sewer permit has been issued. 3. EXISTING CONDITIONS a. City of Los Angeles Wastewater Collection and Conveyance The City of Los Angeles Department of Public Works, Bureau of Sanitation, is responsible for wastewater collection and treatment in the City of Los Angeles, including the Project site. The Bureau of Sanitation s Wastewater Collection Systems Division operates and maintains the largest wastewater collection system in the nation, serving over 4 million people within approximately a 600 square mile service area and comprising more than 6,700 miles of wastewater pipes, 140,000 maintenance structures, 100 diversion structures, and 44 sewage pumping plants. The City system also provides wastewater conveyance and treatment services to 29 agencies under contractual agreements. City wastewater pipes range from six to 150 inches in diameter, with approximately fifty percent of the system more than 50 years old. 9 The Bureau of Sanitation is also responsible for system maintenance. The municipal wastewater main beneath Stadium Way adjacent to the Project site is the most upstream main for this tributary area and therefore initially only serves the Project site (i.e., the Project site is the first connection). There are 15 available points of connection/discharge (laterals) between the Project site and the wastewater main beneath Stadium Way, including 10 for the eastern Project site and five for the western Project site. Six active laterals exist on the eastern Project site and two active laterals exist on the western Project site; the remaining four laterals on the eastern Project site and three laterals on the western Project site do not currently appear to be in use. The wastewater main beneath Stadium Way was constructed at different times in segments of varying diameters. The oldest remaining portions of the main were constructed in 1917, with upgraded, larger segments in the Project vicinity dating to the 1930s, 1940s, and 1960s. The most upstream segments of the wastewater main, beneath Stadium Way at Scott Street near the north end of the Project site, are 8 inches in diameter, increasing to 15 inches in diameter near the midpoint of the Project site, and then decreasing in size downstream, with 8, 10, and 12 inch segments south of the Project site. Wastewater systems are normally designed to steadily increase 9 Los Angeles Department of Public Works, About the City s Sewer System, City of Los Angeles IV.M.2 5 Barlow Hospital Replacement and Master Plan Project

6 in size downstream, to accommodate a larger number of connections and increasing volume of discharge. The variable size of the system in the Project vicinity therefore constrains the system s capacity, which is necessarily limited by the smallest diameter segments. Figure IV.M.2 1, Project Vicinity Wastewater Collection System, shows the ages and diameters of municipal wastewater main segments adjacent to and downstream of the Project site. From the Project site, wastewater is conveyed south beneath Stadium Way to a 10 inch line in Bernard Street before splitting into a 18 inch line in Alameda Street and a 15 inch line beneath College Street, both of which then discharge into a 30 inch line in Los Angeles Street. b. Project Site Wastewater Collection and Conveyance As discussed in Section II, Project Description, of this, the 25 acre Project site is divided into eastern and western parcels by Stadium Way. The eastern Project site, approximately 10.6 acres, is currently occupied by 29 buildings, including the existing hospital. The hospital and majority of the existing buildings on the eastern Project site are located within the relatively flat or gently sloped portions of the site closest to Stadium Way. Most of the buildings were constructed before 1930 as patient cottages, administrative offices, or maintenance facilities for the hospital s predecessor, Barlow Sanatorium. The currently operational 49 bed Barlow Respiratory Hospital occupies a building with portions constructed between Fifteen of the other buildings on the eastern Project site are used for additional office or storage space. The remainder of the buildings on the eastern Project site are no longer in use and do not generate wastewater The western Project site, approximately 14.2 acres, slopes steeply up from Stadium Way to Elysian Park Drive on its eastern boundary. The western Project site contains 10 buildings, including two currently occupied single family residences built in 1936 and 1940, respectively, at the top of the slope on Elysian Park Drive. Eight former patient cottages constructed before 1930 are located at the bottom of the slope along Stadium Way. One former cottage is currently used for storage by the hospital; the remaining cottages are no longer in use and do not generate wastewater. The existing wastewater collection system on the Project site was constructed in the 1930s and consists of an underground network of vitrified clay pipes (VCP) and polyester resin concrete (PRC) pipes. Figure IV.M.2 2, Project Site Wastewater Collection System, shows the locations of existing buildings and the on site wastewater pipes. Wastewater pipes, including those on the Project site, are typically designed to operate via gravity loading, where upstream (upslope) pipes convey wastewater flows downstream (downslope) to a point of discharge, relying only on gravity (not pumps or other mechanical aids) for conveyance. The use of gravity systems imposes some City of Los Angeles IV.M.2 6 Barlow Hospital Replacement and Master Plan Project

7 N LEGEND Scale (Feet) Source: KPFF Consulting Engineers, 12/21/2010. Figure IV.M.2-1 Project Site Wastewater Collection System

8 City of Los Angeles IV.M.2 8 Barlow Hospital Replacement and Master Plan Project

9 N Source: KPFF Consulting Engineers, 12/21/2010. Not to Scale Figure IV.M.2-2 Project Vicinity Wastewater Collection System

10 City of Los Angeles IV.M.2 10 Barlow Hospital Replacement and Master Plan Project

11 constraints on system design; pipes must have enough relative difference in elevation between points of building connection and discharge to ensure adequate slope, flow, and capacity for the buildings served. As previously noted, the eastern Project s site, which contains the existing hospital, is currently served by six active sewer laterals of varying length, size, and slope. The longest lateral, serving the majority of the eastern Project site, begins at Building No. 10, east of the hospital, travels south approximately 700 feet through the center of the site, and turns west through the existing parking lot, terminating in the municipal wastewater main beneath Stadium Way. This 8 inch lateral receives discharges from an network of four, six and eight inch lines that serve the buildings in the center of the eastern Project site as well as Building Nos. 6, 11, 12, 21, and 25. The remaining four active laterals on the eastern Project site consist of 8 inch VCP lines that provide direct connections between buildings that front on Stadium Way and the wastewater main beneath Stadium Way. The western Project site has two active VCP laterals of eight inches and 15 inches in diameter that connect directly to the wastewater main beneath Stadium Way. These laterals serve the buildings fronting on Stadium Way and are also believed to serve the two single family residences at the top of the slope on Elysian Park Drive. c. Wastewater Treatment the City of Los Angeles Department of Public Works, Bureau of Sanitation, owns and operates four wastewater treatment and water reclamation facilities:. the Hyperion Treatment Plant, located in Playa del Rey; two partial treatment/reclamation plants located inland (the Tillman Water Reclamation Plant in Van Nuys and the Los Angeles Glendale Water Reclamation Plant near Griffith Park); and the Terminal Island Water Reclamation Plant. The Bureau of Sanitation also operates two ocean outfalls; 48 pumping plants in low lying communities; and an array of wastewater system connections and major interceptors. These facilities collect and treat sewage generated throughout the City of Los Angeles as well as cities that contract for these services. The Los Angeles area is divided into two major service areas, the Hyperion Treatment Area and the Terminal Island Service area; the Project site is located within the Hyperion Treatment Area. Wastewater generated on the Project site is conveyed approximately 21 miles to, and is treated at, Hyperion Treatment Plant, the largest of the three treatment plants in the Hyperion Treatment System. The Hyperion Treatment Plant serves the central Los Angeles area, treats excess flows from the Los Angeles Glendale Water Reclamation Plant, and processes solids generated by the City s other treatment/reclamation plants. Opened in 1950, Hyperion Treatment Plant can now City of Los Angeles IV.M.2 11 Barlow Hospital Replacement and Master Plan Project

12 accommodate a total average flow of 450 million gallons per day (mgd) under dry weather conditions and up to one billion gallons per day during peak wet weather flow conditions. As of 2010, Hyperion Treatment Plant treated an average of 300 mgd, for a remaining capacity of up to 150 mgd. 10 Based on the latest data available, the average dry weather flow for the entire City service area is approximately 380 mgd, or 180 mgd below the design capacity of 560 mgd for all three plants. 11 This excess capacity is due, in part, to water conservation measures now required per the City of Los Angeles Uniform Building Code, since wastewater flows are directly proportional to water usage. With the approval of the 2006 Integrated Resource Plan, the capacity at Hyperion in conjunction with other relief wastewater treatment facilities is expected to provide sufficient wastewater treatment capacity for the service area through the year d. Wastewater Generation and Conveyance Capacity i. Project Site The total sewage generation of existing uses on the Project site, based on the generation factors defined by the City of Los Angeles in the Los Angeles CEQA Thresholds Guide, is approximately 16,067 gallons per day (gpd) (.016 mgd). Refer to Table IV.M.2 1, Existing Barlow Master Plan Sewer Load Summary, for a detailed breakdown of wastewater generation under existing conditions. As shown in the table, a number of the existing on site buildings are not currently in use and do not generate wastewater. ii. Project Area As previously stated, the wastewater main beneath Stadium Way adjacent to and south of the Project site varies in diameter, with segments of 8 inches, 12 inches, and 15 inches. Based on the City s established design capacity requirements for wastewater pipes, limiting peak flows to less than fifty percent of pipe depth, the maximum allowable design capacity of the 15 inch pipe is approximately 2.19 mgd. However, since the smallest diameter segment of the wastewater main in 10 City of Los Angeles, Department of Public Works, Bureau of Sanitation, Five Year Strategic Plan, Fiscal Years 2010/ /15, _Final.pdf City of Los Angeles, Department of Public Works, Bureau of Sanitation, Wastewater Engineering Services Division, Sewage Treatment Plant Flow Data, , (2006). City of Los Angeles IV.M.2 12 Barlow Hospital Replacement and Master Plan Project

13 Table IV.M.2 1 Existing Barlow Master Plan Sewer Load Summary Daily Buildings Type Description Amounts Units Generation Factor (gal/day/per unit) Generation (gal/day) 1 Office 2,559 gsf 150 gpd/1000 gsf Hospital/Medical 47,014 gsf 250 gpd/1000 gsf. 11,754 Building 2A Medical Building 1,804 gsf 250 gpd/1000 gsf Office 2,072 gsf 150 gpd/1000 gsf Office 1,392 gsf 150 gpd/1000 gsf Office 4,537 gsf 150 gpd/1000 gsf Maintenance 1,696 gsf 80 gpd/1000 gsf a 8 Office 1,505 gsf 150 gpd/1000 gsf Office 5,841 gsf 150 gpd/1000 gsf Storage 575 gsf 20 gpd/1000 gsf a 12 Office 808 gsf 150 gpd/1000 gsf a Office 648 gsf 150 gpd/1000 gsf Office 783 gsf 150 gpd/1000 gsf a 18 a 19 a 20 a 21 a 22 a 23 a 24 a 25 a 26 Storage 685 gsf 20 gpd/1000 gsf Maintenance 773 gsf 80 gpd/1000 gsf Maintenance 2,164 gsf 80 gpd/1000 gsf a 30 a 31 a 32 a 33 a 34 a 35 a 36 Office 824 gsf 150 gpd/1000 gsf Residential 1 du 160 gpd/du Residential 1 du 160 gpd/du 160 Total 16,067 a Not in use. Notes: gal gallons; gsf = gross square feet; du = dwelling units. Source: City of Los Angeles, Los Angeles CEQA Thresholds Guide, 2006 Wastewater Generation Factors. City of Los Angeles IV.M.2 13 Barlow Hospital Replacement and Master Plan Project

14 the Project vicinity is only 8 inches in diameter, this segment necessarily constrains wastewater system capacity upstream. The maximum allowable (i.e., fifty percent) design capacity of the 8 inch pipe is approximately 363,000 gpd, and as of November 2009 approximately flow levels in the pipe were gauged at approximately 22 percent of pipe depth IMPACT ANALYSIS a. Methodology The analysis in this section is based, in part, on the technical report prepared for the Project by KPFF Consulting Engineers. Information regarding existing public wastewater pipe location, age, and capacity was provided by the Bureaus of Engineering and Sanitation of the City of Los Angeles Department of Public Works based on the SCAR, published reports, as built plans and other sources. This analysis compares wastewater generation projected for the proposed Project to existing wastewater generation on the Project site, based on established City of Los Angeles wastewater generation factors, and determines the capacity of the existing public wastewater conveyance system to accommodate Project increases in wastewater generation. b. Significance Thresholds Appendix G of the State CEQA Guidelines provides sample checklist questions for use in an Initial Study to determine a project s potential for environmental impacts. According to the applicable questions 13 contained in Appendix G under Section XVII, Utilities and Service Systems, a project would have a potentially significant impact if it would: XVII.a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board; XVII.b) Require or result in the construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; or Correspondence from Brent Lorscheider, Division Manager, City of Los Angeles, Wastewater Engineering Services Division of the Bureau of Sanitation, Department of Public Works, November 10, Appendix G Utilities and Service Systems sample questions (XVI.b (in part), and d through g) pertain to water supply and solid waste and are addressed in Sections IV.L.1, Water Supply, and IV.L.3, Solid Waste. Sample question XVI.c pertains to hydrology and is addressed in Section IV.G, Surface Water Hydrology and Water Quality. 14 Sample question XVI.b addresses the construction of new water and wastewater treatment facilities and the expansion of existing facilities. As such, this sample checklist question is also discussed in Section IV.L 1, Water Supply of this. City of Los Angeles IV.M.2 14 Barlow Hospital Replacement and Master Plan Project

15 XVII.e) Result in a determination by the wastewater treatment provider that serves or may serve the project that it has inadequate capacity to serve the project s projected demand in addition to the provider s existing commitments. The factors used in the City of Los Angeles CEQA Thresholds Guide to determine significant wastewater impacts incorporate the more general checklist questions contained in Appendix G of the State CEQA Guidelines. Therefore, based on the more specific City of Los Angeles CEQA Thresholds Guide, the proposed Project would have a significant wastewater impact if: WW 1 WW 2 WW 3 The Project would cause 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; The Project s additional wastewater flows would substantially or incrementally exceed the future scheduled capacity of any one treatment plant by generating flows greater than those anticipated in the Wastewater Facilities Plan or General Plan and its elements; or The Project would result in exceedance of wastewater treatment requirements of the applicable Regional Water Quality Control Board. c. Project Design Features Barlow Hospital has committed to the following water conservation measures for the proposed Project, by the date of Project buildout: Bathroom faucets: 1.5 gallons per minute (GPM) (residential/private); 0.5 GPM (hospital/public) Kitchen faucets: 1.5 GPM Low flow showerheads: 2.0 GPM, no more than 1 showerhead per stall High efficiency clothes washers (residential): water savings factor of 5.0 or less High efficiency toilets: 1.28 gallons per flush or less, or dual flush High efficiency/ultra low water urinals: to 0.5 gallons per flush City of Los Angeles IV.M.2 15 Barlow Hospital Replacement and Master Plan Project

16 Energy star dishwashers High efficiency clothes washers (commercial): water savings factor or 7.5 or less Pre rinse kitchen spray head Public restroom self closing faucets Domestic water heating system in close proximity to point(s) of use Tankless and on demand water heaters Rotating sprinkler nozzles for landscape irrigation: 0.5 GPM Weather based irrigation controller Micro spray Bubbler irrigation Proper hydro zoning (i.e., group plants with similar water requirements together) Zoned irrigation Landscape contouring to minimize precipitation runoff Drought tolerant plants: 75 percent of total new landscape plantings Cooling tower conductivity controllers or cooling tower ph conductivity controllers (cooling towers to operate at a minimum of 5.5 cycles of concentration) Water saving pool filter Reclaimed water system for irrigation Convert cooling towers to 100 percent reclaimed water use, as permitted by law The proposed Project also would comply with the required Standard Urban Storm Water Mitigation Plan (SUSMP) and would implement Best Management Practices that have stormwater recharge or reuse benefits. City of Los Angeles IV.M.2 16 Barlow Hospital Replacement and Master Plan Project

17 d. Project Impacts WW 1 WW 2 Would the proposed Project cause 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? Would the proposed Project s additional wastewater flows substantially or incrementally exceed the future scheduled capacity of any one treatment plant by generating flows greater than those anticipated in the Wastewater Facilities Plan or General Plan and its elements? i. Construction Impacts Project implementation would involve the construction of a new on site wastewater system to service the proposed replacement hospital, skilled nursing facility, 868 condominium units, 20 residential townhomes, commercial uses, and adaptive reuse of existing buildings. New buildings would be constructed on both the eastern and western Project sites. Project implementation would necessitate upgrading Project site existing connections (laterals) to the existing public wastewater main beneath Stadium Way, and/or an increase in the volume of wastewater currently discharged to the public water system by on site uses. Additionally, during construction of the proposed Project, it is anticipated that construction contractors would provide portable, on site sanitation facilities that would be regularly serviced at approved disposal facilities located off site. Construction activities would, therefore, have no impact on the Project site s wastewater collection system. New and/or upgraded lateral connections to the Stadium Way sewer main associated with the proposed project would require construction activities that could affect the main. However, any such effects would be temporary and would occur in accordance with all applicable regulations as enforced under required LADPW construction permits. Because these requirements have been formulated to avoid significant impacts, such as disruptions of sewer service to existing adjacent uses and/or sewage spills during the construction period, project construction impacts would be less than significant ii. Operational Impacts Wastewater generation associated with the proposed Project was calculated using the sewer generation factors contained in the City of Los Angeles CEQA Thresholds Guide. Project implementation would increase the number of wastewater generation sources on the Project site City of Los Angeles IV.M.2 17 Barlow Hospital Replacement and Master Plan Project

18 through an increase in hospital beds, the introduction of a 24 bed skilled nursing facility, and the construction of residential units, including kitchen, bathroom, and laundry facilities, and commercial uses. As a result, Project implementation would increase the volume of wastewater generated on the Project site and discharged to the public system. Table IM.M.2 2, Projected Wastewater Discharges, shows the projected wastewater discharge volumes. The Project is projected to generate approximately 157,236 gpd of wastewater, for a net increase of approximately 141,169 gpd over existing conditions. This represents approximately 5 percent of the maximum allowable design capacity of the 15 inch wastewater main beneath Stadium Way and approximately 43 percent of the maximum allowable design capacity of the 8 inch wastewater main, and both wastewater pipes would therefore continue to operate below the maximum allowable design capacity. The Bureau of Sanitation has also indicated that there is sufficient capacity in the wastewater system to accommodate the anticipated Project wastewater flows. 15,16 Therefore, although the Project would result in an increase in wastewater flows into the wastewater system, the system is not presently constrained and the Project would not cause the system to become constrained. Therefore, project impacts on wastewater pipe capacity would be less than significant. WW 3 Would the Project result in exceedance of wastewater treatment requirements of the applicable Regional Water Quality Control Board As stated previously, wastewater from the Project site is currently, and would continue to be, conveyed by the public wastewater system to the Hyperion Treatment Plant. The plant currently processed average daily flows of 300 mgd and has the capacity to treat up to 450 mgd. The proposed Project would represent a minor incremental increase in the volume of wastewater treated at Hyperion, and the Bureau of Engineering has concurred that sufficient capacity exists at Hyperion to treat Project generated wastewater flows. Since the Project would not exceed the capacity of Hyperion or generate flows greater than those anticipated in the Wastewater Facilities Plan or General Plan, impacts would be less than significant. e. Mitigation Measures The proposed Project would result in less than significant impacts with respect to wastewater collection or conveyance systems or treatment capacity and no mitigation is required. 15 Correspondence from Brent Lorscheider, Division Manager, City of Los Angeles, Wastewater Engineering Services Division of the Bureau of Sanitation, Department of Public Works, November 10, City of Los Angeles, Bureau of Engineering, Department of Public Works, Sewer Capacity Availability Request (SCAR) no (resubmitted 5/13/10 as ), approved June 4, City of Los Angeles IV.M.2 18 Barlow Hospital Replacement and Master Plan Project

19 Table IV.M.2 2 Projected Wastewater Discharges Type Amounts Units General Factor (gal/day/per unit) Daily Generation (gal/day) Existing Existing Buildings to be Demolished 14,771 Existing Buildings to Remain (Historic Core): 2A, 3, 15, 16, 17, 18, 20, 37, and 38 1,296 Hospital (56 Beds) / Skilled Nursing Facility (24 Beds) / Administration and Support Facility Proposed Total (Existing) 16, ,000 gsf 250 gpd/1000 sq.ft. 30,000 Condos (2 Bedroom) 435 du 160 gpd/du 69,600 Condos (1 Bedroom) 435 du 120 gpd/du 52,200 Townhomes 18 du 230/du 4,140 Existing Buildings to Remain Total (Proposed) 155,940 1,296 Total (Existing to Remain + Proposed) 157,236 Net Increase 141,169 Source: KPFF Consulting Engineers; Wastewater Assessment prepared for the Project by The Bureau of Sanitation of the Department of Public Works, City of Los Angeles, October Notes: gsf = gross square feet; du = dwelling units.. f. Level of Significance After Mitigation Project impacts with respect to wastewater system capacity would be less than significant and no mitigation is required. g. Cumulative Impacts As stated in Section 2.c., Planned Capital Improvements, every 10 years, the City of Los Angeles updates its 10 Year Capital Improvement Program to address planned replacement and expansion of the wastewater collection system and treatment facilities within its service area; improvements are then carried out by the Bureaus of Sanitation and Engineering. The most recent update defines improvements scheduled through Moreover, the Secondary Sewer Renewal Program, which identifies substandard secondary sewers, includes planned upgrades to the wastewater system in City of Los Angeles IV.M.2 19 Barlow Hospital Replacement and Master Plan Project

20 the Project area (e.g., City project SSRP N13). These improvements commenced in February 2011 and are expected to be complete by June 2012, and are intended to ensure the wastewater system in the Project area is able to accommodate present and future wastewater flows. 17 Finally, the Project site is the most upstream point of connection to the public sewer beneath Stadium Way that serves the site, and no other properties discharge wastewater to this sewer. All the related projects defined in Section II, Environmental Setting, of this are located downstream of the Project site. According to the technical studies prepared for this analysis by the Project civil engineer and correspondence from the City of Los Angeles, the existing sewer system and wastewater treatment plant serving the Project site have adequate capacity to accommodate Project generated increases in wastewater flows under existing conditions, and will continue to do so following planned sewer improvements in the Project area. The downstream trunk and interceptor mains that convey Project wastewater flows to Hyperion Treatment Plant likewise have adequate capacity, as does Hyperion. For these reasons, the proposed Project, considered together with related projects, would not result in a cumulatively considerable contribution to cumulatively significant impacts related to the sewer system capacity or wastewater treatment capacity. 17 KPFF Consulting Engineers, pers. com., February 28, 2012 (based on latest City of Los Angeles Project Information Report for SSRP N13) City of Los Angeles IV.M.2 20 Barlow Hospital Replacement and Master Plan Project