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Septic to Gravity Sewer Conversion Project <br />Final Initial Study/Mitigated Negative Declaration <br />Letter 5 Response to Comments <br />5-1. <br />The project proposes sewer and water connections at the intersection of 17'h Street and Deodar Street, as <br />depicted in Figure 2. Project Location and Figure 3. Site Plan in the Draft IS/MND. This connection is <br />estimated to be approximately 140 feet west of the SR 55 SB offramp to 17'h Street at its nearest point. The <br />project does not anticipate a need to encroach on SR 55 right-of-way (ROW). <br />5-2. <br />Regarding NPDES, development of the proposed project would abide by requirements of the statewide <br />National Pollutant Discharge Elimination System (NPDES) stormwater permit for construction activity (Order <br />98-08 DWQ), Construction of the proposed project would be required to comply with the Construction <br />General Permit, either through a waiver or through preparation and implementation of a Storm Water <br />Pollution Prevention Plan (SWPPP). Best Management Practices (BMPs) are included as part of the Storm <br />Water Pollution Prevention Plan (SWPPP) prepared for the proposed project and would be implemented to <br />manage erosion and the loss of topsoil during construction -related activities. The project will implement <br />standard construction operating procedures and will conform with NPDES requirements. The proposed <br />project's grading/trenching plan would also ensure that the proposed earthwork is designed to avoid soil <br />erosion. As a co-permittee under the County of Orange MS4 NPDES permit, the City will comply with the MS4 <br />permit requirements. <br />According to the project specific geotechnical report (AESCO 2019), regional groundwater data indicates <br />groundwater in the project vicinity is generally less than 40 feet bgs, and groundwater was not encountered <br />during the project subsurface investigations at a maximum boring depth of 15 feet. Because pipeline <br />trenching activities are not expected to exceed 8 feet bgs, groundwater is not anticipated to be encountered <br />during the excavation of the proposed improvements. <br />5-3. <br />Regarding Permits, see response 5-1 regarding project proximityto the State ROW. In the event proposed <br />work would need to encroach within the State ROW, the City will coordinate with Caltrans to assure that any <br />additional documentation would be provided to support a permit. In addition, the City will provide Caltrans <br />with an opportunity to review the project Traffic Control Plan (HAZ-1). <br />Comments and Responses 2-17 November 2020 <br />