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The Wamer Redhill Mixed -Use Project CEQA Findings of Fact <br />existing conditions. In addition, during construction, vehicles and equipment are prone to tracking <br />soil and/or spoil from work areas to paved roadways, which is another form of erosion that could <br />affect water quality. <br />However, the use of BMPs during construction implemented as part of a SWPPP as required by <br />the NPDES General Construction Permit and included as PPP WQ-1 would serve to ensure that <br />Project impacts related to construction activities resulting in a degradation of water quality would <br />be less than significant. <br />Operation <br />The proposed Project includes operation of retail and restaurant commercial and multi -family <br />residential uses. Potential pollutants associated with the proposed uses include various chemicals <br />from cleaners, pathogens from pet wastes, nutrients from fertilizer, pesticides and sediment from <br />landscaping, trash and debris, and oil and grease from vehicles. If these pollutants discharge into <br />surface waters, it could result in degradation of water quality. As described previously, San <br />Diego Creek Reach] and the Upper Newport Bay, to which the Project site ultimately drains, are <br />currently listed as impaired on the EPA's 303(d) list for various pollutants. <br />However, operation of the proposed Project would be required to comply with the requirements <br />of the Santa Ana Regional MS4 Permit to develop of a project -specific WQMP (included as PPP <br />WQ-2) that would describe implementation of LID infrastructure and non-structural, structural, and <br />source control and treatment control BMPs to protect surface water quality. <br />The Project site is located within the Selenium Concentration Area and the South Basin <br />Groundwater Protection Project area, and is adjacent to the Tustin Marine area, as shown in Draft <br />EIR Figure 5.8-1. Infiltration into the groundwater is prohibited by OCWD within these areas. As <br />such, infiltration of water quality pollutants from the Project would not occur, which would reduce <br />potential impacts to groundwater quality. <br />In addition, the proposed Project would install Modular Wetland System units for water quality <br />treatment, which have been sized to treat runoff from the Design Capture Storm (85th percentile, <br />24-hour) from the proposed Project. The Modular Wetland System units proposed for the Project <br />consist of biotreatment systems that utilize multi -stage treatment processes including screening <br />media filtration, settling, and biofiltration. The pre-treatment chamber contains a catch basin inlet <br />filter to capture trash, debris, gross solids and sediments, a settling chamber for separating out <br />larger solids, and a media filter cartridge for capturing fine silts, metals, nutrients, and bacteria. <br />Runoff then flows through the wetland chamber where treatment of the water is done through a <br />variety of physical, chemical, and biological processes. As storm water passes down through the <br />planting soil, pollutants are filtered, adsorbed, biodegraded and sequestered by the soil and <br />plants, functioning similar to bioretention systems. The discharge chamber at the end of the unit <br />collects treated flows and discharges it into the existing storm drain in Red Hill Avenue. <br />The WQMP is required to be approved prior to the issuance of a building or grading permit. The <br />Project's WQMP would be reviewed and approved by the City to ensure it complies with the <br />Santa Ana RWQCB MS4 Permit regulations. Overall, implementation of the WQMP pursuant to <br />the existing regulations would ensure that operation of the proposed Project would not violate <br />any water quality standards, waste discharge requirements, or otherwise degrade water quality; <br />and impacts would be less than significant. <br />City of Santa Ana <br />May 2020 <br />