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*:/ : 11-1 h WA <br />6th Street Site <br />The 6th Street Site is within the jurisdiction of the Santa Ana Regional Water Quality Control Board <br />(SARWQCB). Drainage and surface water discharges from the proposed park would not violate any water <br />quality standards or waste discharge requirement, since park uses would not contain unusual materials that <br />would violate water quality standards. <br />Soildisturbingactivities during construction of the project could temporarily increase the amount of soil <br />erosion and siltation entering the local stormwater drainage system. The 6th Street Site is approximately 0.42 <br />acres, and because the proposed development would not result in disturbance of more than one acre of soil, <br />compliance with the National Pollutant Discharge Elimination System (NPDES) Construction General Permit <br />(CGP) (Order No. 2009-0009-DW(2) would not be necessary. However, it is anticipated that standard best <br />management practices (BMPs) would be implemented during construction, and considering the small scale of <br />soil disturbances, less than significant water quality impacts would occur. <br />Raiff Street Site <br />The Raitt Street Site is also in the SARWQCB. Pursuant to Section 402 of the Clean Water Act, the <br />Environmental Protection Agency has established regulations under the NPDES program to control direct <br />stormwater discharges. In California, the State Water Resources Control Board (SWRCB) administers the <br />NPDES permitting program and is responsible for developing NPDES permitting requirements. The NPDES <br />program regulates industrial pollutant discharges, including construction activities for sites larger than one acre. <br />Raiff Street Site is 1.09 acres, and implementation of the proposed project would disturb more than one acre. <br />Therefore, the proposed project would be subject to the NPDES CGP (Order No. 2009-0009-DWG <br />requirements with the SWRCB prior to the start of construction. The City would be required to implement <br />appropriate best management practices (BMPs) to control erosion and prevent any discharge of sediments <br />from the site. The registration documents include a Notice of Intent, risk assessment, site map, Storm Water <br />Pollution Prevention Plan (SWPPP), annual fce, and signed certification statement. The SWPPP must list BMWs <br />that would be implemented to prevent soil erosion and discharge of other construction related pollutants that <br />could contaminate nearby water resources. Additionally, the SWPPP must include a visual monitoring program, <br />a chemical monitoring program for nonvisible pollutants if there is a failure of the BMPs, and a sediment <br />monitoring plan if the site discharges directly to a water body listed on the 303(d) list for sediment. The SWPPP <br />would estimate sediment risk for the construction areas and for receiving waters and specify erosion control <br />and sediment control BMPs adequate to address those risks. <br />Provided that the Raitt Street Site development would disturb more than one acre of soils, the required <br />incorporation of BMPs for erosion control and stormwater management during construction per the NPDES <br />permit would prevent violation of any applicable water quality standards or waste discharge requirement. <br />No surface discharges during operation of the proposed project would occur other than routine cleaning and <br />maintenance of the grounds, which would be conducted to avoid discharge into storm drains. Impacts would <br />not be significant, and no mitigation measures are required. <br />75C-98 <br />