IV.G.2. Water Resources - Groundwater quality delivered for public supply is also regulated under...

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

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WORKING DRAFT - Not for Public Review

Table of Contents G.2 Water Resources - Groundwater

1. INTRODUCTION ....................................................................................................... 1404

2. ENVIRONMENTAL SETTING ................................................................................... 1404 a. Regulatory Setting ............................................................................................... 1404

(1) Federal Regulations ....................................................................................... 1404 (a) Clean Water Act ........................................................................................ 1404 (b) Safe Drinking Water Act ............................................................................ 1405

(2) State Regulations .......................................................................................... 1405 (a) Porter-Cologne Water Quality Control Act (California Water Code) .......... 1405 (b) California Code of Regulations, Title 22 .................................................... 1406

(3) Local Regulations .......................................................................................... 1406 b. Existing Physical Conditions ................................................................................ 1408

(1) Regional Conditions ....................................................................................... 1408 (a) Regional Groundwater Hydrology.............................................................. 1408 (b) Regional Groundwater Quality .................................................................. 1410

(2) Project Site Conditions .................................................................................. 1410 (a) Groundwater Hydrology ............................................................................. 1410 (b) On-Site Groundwater Quality .................................................................... 1412

3. ENVIRONMENTAL IMPACTS .................................................................................. 1421 a. Methodology ........................................................................................................ 1421

(1) Groundwater Hydrology ................................................................................. 1421 (2) Groundwater Quality ...................................................................................... 1422

b. Thresholds of Significance .................................................................................. 1422 (1) Groundwater Levels ....................................................................................... 1422 (2) Groundwater Quality ...................................................................................... 1423

c. Project Design Features ...................................................................................... 1423 d. Project Impacts .................................................................................................... 1424

(1) Project Construction ...................................................................................... 1424 (a) Groundwater Hydrology ............................................................................. 1424 (b) Groundwater Quality .................................................................................. 1425

(2) Project Operation ........................................................................................... 1426 (a) Groundwater Hydrology ............................................................................. 1426 (b) Groundwater Quality .................................................................................. 1429

(3) Impacts Under the No Annexation Scenario .................................................. 1430

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4. CUMULATIVE IMPACTS .......................................................................................... 1430

5. PROJECT DESIGN FEATURES AND MITIGATION MEASURES ........................... 1432 a. Project Design Features ...................................................................................... 1432

(1) Groundwater Hydrology ................................................................................. 1432 (2) Groundwater Quality ...................................................................................... 1432

b. Mitigation Measures ............................................................................................ 1432 (1) Groundwater Hydrology ................................................................................. 1432 (2) Groundwater Quality ...................................................................................... 1432

6. LEVEL OF SIGNIFICANCE AFTER MITIGATION .................................................... 1433

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List of Figures

189 Nine California Regions Governed by Regional Water Quality Control Boards ..................................................................................................... 1407

190 Upper Los Angeles River Area Groundwater Basins ........................................... 1409 191 Approximate Location of Monitoring Wells Associated with the Solid Waste

Water Quality Assessment Test ........................................................................... 1414 192 Groundwater Monitoring Well Location Map ........................................................ 1416 193 Underground Storage Tank Locations Referenced in Analysis ............................ 1419


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IV. Environmental Impact Analysis G.2 Water Resources - Groundwater

1. Introduction

The following analysis is based on the Groundwater Technical Report prepared by Camp Dresser & McKee for the NBC Universal Evolution Plan Draft EIR March 2010. The full text of the Groundwater Technical Report is included in Appendix I-3 to this Draft EIR.

This section consists of an evaluation of the relationship between the Project Site and the regional and local groundwater hydrology, quality, and applicable regulations. In terms of groundwater hydrology, the section discusses groundwater recharge capacity and the use of groundwater for potable water. Issues specific to groundwater quality are also analyzed, including changes in the rate, movement, or area affected by existing contaminants in groundwater, or conditions that would cause regulatory water quality standards at an existing production well to be violated.

2. Environmental Setting

The following discussion describes the regulatory setting and the existing physical conditions of the Project Site and surrounding areas as they relate to groundwater hydrology and quality.

a. Regulatory Setting

(1) Federal Regulations

(a) Clean Water Act

As discussed in Section IV.G.1.b, Surface Water Quality, of this Draft EIR, the United States Environmental Protection Agency regulates water quality under the Clean Water Act. Although the goals set forth by the Clean Water Act were primarily developed to target surface water conditions, many of the resulting objectives are applicable to the protection of groundwater resources as well.

IV.G.2 Water Resources - Groundwater


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(b) Safe Drinking Water Act

The Safe Drinking Water Act sets drinking water standards throughout the country and is administered by the Environmental Protection Agency. These drinking water standards, which are set forth in the Code of Federal Regulations, are referred to as the National Primary Drinking Water Regulations, 40 Code of Federal Regulations Part 141, and the National Secondary Drinking Water Regulations, 40 Code of Federal Regulations Part 143.128 These regulations set Maximum Contaminant Levels for substances in drinking water.

(2) State Regulations

California law related to groundwater hydrology is associated with the pumping of groundwater. Landowners overlying a groundwater basin are permitted to pump their share of groundwater utilizing their overlying rights, so long as these rights have not been legally severed from the land and the groundwater pumping is limited to the landowners’ correlative share (which represents the portion of the water they can pump without adversely impacting other overlying water rights-holders). Usage of groundwater may also be controlled through a judicial adjudication, wherein water rights are partitioned out to the full potential of the basin. The San Fernando groundwater basin (California Department of Water Resources Basin No. 4-12), which was adjudicated in 1979, underlies a portion of the Project Site. Most of the Project Site lies within what is considered non-water bearing strata adjacent to the southern edge of the San Fernando groundwater basin (Basin).129 The only portion of the Project Site considered to be within the Basin is the northwestern area and a portion of the Project Site along the Los Angeles River Flood Control Channel.

The San Fernando Groundwater Quality Management Plan was issued in July 1983. The objective of this effort is to protect and upgrade the quality of stored water in the Basin. Special emphasis is placed on monitoring and removing the organic contaminants trichloroethylene and perchloroethylene found in the groundwater in the Basin.

(a) Porter-Cologne Water Quality Control Act (California Water Code)

The Porter-Cologne Water Quality Control Act, embodied in the California Water Code, establishes the principal California legal and regulatory framework for water quality

128 According to the United States Environmental Protection Agency, National Primary Drinking Water Regulations (primary standards) are legally enforceable standards that apply to public water systems. National Secondary Drinking Water Regulations (secondary standards) are non-enforceable guidelines regulating contaminants that may cause cosmetic or aesthetic effects in drinking water. The Environmental Protection Agency recommends secondary standards to water systems but does not require systems to comply.

129 DWR, Water Facts: Adjudicated Groundwater Basins in California, April 2004.



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control. As discussed in Section IV.G.1.b, Surface Water Quality, of this Draft EIR, the Porter-Cologne Act protects groundwater (as well as surface water) for use by the people of the State. The California Water Code authorizes the State Water Resource Control Board and the Regional Water Quality Control Boards to implement the provisions of the federal Clean Water Act. Under the California Water Code, the State of California is divided into nine regions (refer to Figure 189 on page 1407) governed by Regional Water Quality Control Boards that, under the guidance and review of the State Water Resource Control Board, implement and enforce provisions of the California Water Code and the Clean Water Act. Based on the State Water Resource Control Board procedures, the regional boards develop local water quality control plans. Once approved by the State Water Resource Control Board, these local plans are incorporated into the California Water Plan. The Project Site is located in Region 4, also known as the Los Angeles Region (Los Angeles Regional Water Quality Control Board).

(b) California Code of Regulations, Title 22

Groundwater quality delivered for public supply is also regulated under the California Domestic Water Quality and Monitoring Regulations found in Title 22, Division 4, Chapter 15 of the California Code of Regulations. Along with the federal regulations detailed above, these regulations identify primary and secondary drinking water standards for public drinking water supplies in the state.

(3) Local Regulations

The Los Angeles Regional Water Quality Control Board developed the Water Quality Control Plan for the Los Angeles River Basin (Basin Plan) in 1995 (as amended). The Basin Plan has been approved by the State Water Resource Control Board and is required to be reviewed and revised, if necessary, every three years. The Basin Plan regulates activities that affect or may affect surface water and groundwater quality. The beneficial uses of the water within the Basin, as designated by the Los Angeles Regional Water Quality Control Board, are for municipal and domestic water supply, industrial process and service supply, and agricultural supply.

Local regulations that regulate surface water point-source discharges, such as the National Pollutant Discharge Elimination System permit system, would also serve to minimize any short-term impacts on groundwater quality from construction activities. See Section IV.G.1.b, Surface Water Quality, of this Draft EIR for a listing and description of these surface water regulations.

ProjectLocation

1

7

6V3

5F

5S

5R

2

9

4

8

6SLT

Legend

Regional Board Boundary

Regional Board Offices1. North Coast2. San Francisco Bay3. Central Coast4. Los Angeles5. Central Valley 5R - Redding Office 5S - Sacramento Office 5F - Fresno Office6. Lahontan Region 6SLT - South Lake Tahoe Office 6V - Victorville Office7. Colorado River Basin8. Santa Ana9. San Diego

Source: http://www.swrcb.ca.gov/regions.html, 2010.

Figure 189Nine California Regions Governed by

Regional Water Quality Control Boards

Not to Scale

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b. Existing Physical Conditions

(1) Regional Conditions

(a) Regional Groundwater Hydrology

The Project Site, as shown in Figure 190 on page 1409, is in the Upper Los Angeles River Area, which in turn contains four groundwater basins: San Fernando; Sylmar; Verdugo; and Eagle Rock. The Project Site is located in the northeast corner of the eastern Santa Monica Mountains along the southern edge of the Basin. The Basin is a natural groundwater basin that encompasses a surface area of approximately 112,000 acres (175 square miles) in Los Angeles County and comprises 91.2 percent of total valley fill. The Basin represents an important source of drinking water for the Los Angeles metropolitan area. In addition to supplying approximately 15 percent of Los Angeles’ domestic water need, the Basin also acts as an underground reservoir where rainfall, runoff from surrounding mountains, and recharge from imported water accumulates and is stored for future use. Current and anticipated use of the regional groundwater in the vicinity of the Project Site is expected to be for domestic, irrigation, and industrial/ commercial uses.

Since the Basin is an adjudicated groundwater basin, the Upper Los Angeles River Area Watermaster has the responsibility to monitor and account for any groundwater extraction within the Basin. As shown in Figure 190 on page 1409, a majority of the Project Site is in the eastern Santa Monica Mountains, which is not part of the Basin or considered to be non-water bearing. As noted, the only portion of the Project Site considered to be within the Basin is the northwestern area and a portion of the Project site along the Los Angeles River Flood Control Channel.

There are no groundwater production wells or public water supply wells within one mile of the Project Site. The nearest water supply well, which is a public well owned by the Los Angeles Department of Water and Power, but is currently inactive, is approximately 1.2 miles northeast of the Project Site with the nearest active water well field approximately 3 miles away. Although the Basin includes several recharge basins (i.e., Pacoima, Tujunga, and Hansen spreading grounds), there are no spreading grounds within 1.5 miles of the Project Site. The estimated groundwater flow direction in the Basin is generally from west to east, toward the cities of Burbank and Glendale. Water levels in the overall Basin are fairly stable, with variations in water levels of 5 feet to 40 feet in the western parts of the Basin, a variation of approximately 40 feet in the southern and northern parts of the Basin, and a variation of about 80 feet in the eastern part of the Basin.

Source: http://www.groundwater.water.ca.gov/bulletin118/basin_maps/index.cfm, 2010.

Figure 190Upper Los Angeles River Area Groundwater Basins

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(b) Regional Groundwater Quality

In general, due to historical activities and practices, the groundwater quality in the County and City of Los Angeles has been substantially degraded from background levels. The degradation of regional groundwater is the result of seepage into the subsurface of fertilizers and pesticides (from agricultural uses), nitrogen and pathogenic bacteria (from septic tanks), and various hazardous substances (from leaking aboveground and underground storage tanks and industrial-type operations). As discussed above, a small portion of the Project Site is located along the southeast edge of the Basin.

The specific groundwater quality contaminants associated with the Basin include volatile organic compounds from industrial activity, and nitrates from subsurface sewage disposal and past agricultural activities. In particular, volatile organic compounds such as trichloroethylene, perchloroethylene, petroleum compounds, chloroform, nitrate, sulfate, and heavy metals are found within the Basin. Trichloroethylene, perchloroethylene, and nitrate contamination occurs in the eastern part of the Basin and elevated sulfate concentration occurs in the western part of the Basin. Due to the widespread pollution in the Basin, the Environmental Protection Agency has designated portions of the Basin as Superfund sites.130 Within 1/8 mile of the Project Site, the San Fernando Valley (Area 2) Crystal Springs Wellfield has been identified by the Environmental Data Resources as an area of contaminated groundwater in the Basin. As with much of the Basin, the contaminated groundwater at Crystal Springs Wellfield is impacted mostly by trichloroethylene and perchloroethylene.

(2) Project Site Conditions

(a) Groundwater Hydrology

The majority of the Project Site is in the eastern Santa Monica Mountains, which is not part of the Basin. Portions of the Project Site considered to be within the Basin include the northwestern area and a narrow portion of the Project Site along the Los Angeles River Flood Control Channel. The Project Site is located in an area with large variations in elevation. Shallow groundwater is encountered along the Los Angeles River Flood Control Channel adjoining the northern portion of the Project Site. Under the remainder of the Project Site, groundwater is limited to joints and fractures in the bedrock materials. Additionally, the Topanga geologic formation beneath a majority of the Project Site is considered non-water bearing, as it does not yield notable quantities of water available for extraction wells. Recent Alluvium (Qal) located north, west, and in a small area along the

130 A Superfund site is a facility that has been contaminated by hazardous substances and identified as a candidate for cleanup by the Environmental Protection Agency because it poses a risk to human health and/or the environment.



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southwest edge of Universal City and the Project Site (in the area along the 101 freeway) is considered to be water bearing.

Available data indicates that groundwater flow beneath the Project Site is consistent with the region, flowing in a northeasterly direction toward the Los Angeles River Flood Control Channel, and then moving east along the general path of the flood control channel. This northeasterly flow is perpendicular to the strike of the bedrock. In the vicinity of the Project Site, simulated groundwater contours associated with the Basin, produced by using the San Fernando Basin Groundwater Flow Model, ranged from approximately 480 to 490 feet above mean sea level. Groundwater elevations measured at the Project Site (in 2005 and 2006) ranged from approximately 512 to 697 feet above mean sea level; therefore, groundwater found beneath a majority of the Project Site is not considered to be hydrologically connected with the Basin.

Groundwater flow direction is toward the north-northeast at an average hydraulic gradient of approximately 0.18 (north sloping hill) to 0.19 (steeper southern portion) feet/foot underlying the southern portion of the Project Site and flattening to a gradient of approximately 0.02 to 0.06 feet/foot, underlying the relatively flat northern portion of the Project Site, by an area known as Park Lake. Geotechnical investigations at the Project Site indicate that groundwater has been encountered at various depths. Groundwater in the Mixed-Use Residential Area has been encountered from 21 feet below ground surface to 34 feet below ground surface. Although subsurface exploration in June 2007 encountered groundwater in the borings in the Business Area area at depths of 28 feet, the geotechnical investigation estimated that the historical high groundwater in the area was 15 feet below ground surface. Groundwater near the Los Angeles River Flood Control Channel has been encountered between 22.84 feet below ground surface and 38.22 feet below ground surface near the Earthquake attraction. The hydraulic conductivity data obtained from slug tests in 2007 indicate that the relative permeability of the soil in the area of the wells is semi-pervious.

Currently, limited dewatering occurs at the Project Site at locations with shallow groundwater that, as necessary, are dewatered and groundwater is discharged in the sanitary sewer under an existing Industrial Wastewater Permit. These locations include: (1) Jurassic Park Ride – “zero level/splash down” area; (2) Jaws Lake area – between Jaws and Falls Lake; and (3) Collapsing Bridge area. Dewatering at the Jurassic Park ride is necessary to depress shallow groundwater at the zero level/splash down area in order to protect the areas’ concrete liner. The active dewatering system at this location is designed to remove groundwater by automatic pumps to a nearby sanitary sewer. Limited dewatering occurs at the Jaws Lake area above the hillside between Jaws Lake and Falls Lake. The dewatering system associated with this location includes a passive under drain that collects groundwater by gravity flow to a nearby sanitary sewer. Dewatering near the Collapsing Bridge (north of the Tram Maintenance Garage) is located in an area of shallow



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groundwater at the base of the closed landfill. Dewatering pumps intercept groundwater at this location and pump it directly to the sanitary sewer. No groundwater production wells or public water supply wells are associated with the Project Site.

(b) On-Site Groundwater Quality

Groundwater quality issues underlying the Project Site are generally associated with the closed on-site landfill and the potential for contamination of groundwater from the handling and storage of hazardous materials in underground storage tanks.

(i) Closed On-Site Landfill

As discussed in Section IV.M, Environmental Safety, of this Draft EIR, a closed on-site landfill is located in the central portion of the Project Site, beneath portions of the existing tram garage parking lot, roadway, and tram garage. The landfill was originally a canyon, with filling operations that began in the late 1920s and ended around 1980. In 1980, the landfill area was covered with a final soil cap consisting of about two to six feet of clean earth fill. While operating, the landfill was used for studio and restaurant waste generated by activities on the Project Site and was not open for public use. No hazardous or potentially hazardous materials are known to have been disposed of at the former landfill site. Since the closure of the landfill, roads, asphalt pavement, and buildings have been developed over approximately 50 percent of the landfill surface area. Natural vegetation covers the remaining undeveloped slope surface of the landfill site (i.e., the northern portion). Several water quality studies and tests have been performed in the landfill area and are discussed below under separate headings.

Solid Waste Water Quality Assessment Test

As required by California Water Code Section 13273, the operators/owners of solid waste disposal sites are required to submit a Solid Waste Water Quality Assessment Test report to the appropriate Regional Water Quality Control Board. The Los Angeles Regional Water Quality Control Board is the jurisdictional agency for the Project Site. A Solid Waste Water Quality Assessment Test Report was prepared for the on-site landfill in 1988, with a follow-up report in 1989. Testing was conducted on the Project Site to determine whether there was hazardous waste leakage from the disposal site.

As part of the Solid Waste Water Quality Assessment Test, a total of three groundwater monitoring wells, one upgradient and two downgradient, were installed in January 1988 to determine groundwater quality in the vicinity of the closed landfill site. These wells were installed to depths ranging from 51 to 56 feet below ground surface, with screened sections ranging from approximately 29.5 to 56 feet below ground surface, and were reportedly located in the path of the gradient dictated by the northeast orientation of



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the bedrock strike in order to monitor for potential migration of contaminants along the strike of the Topanga formation. A leachate131 monitoring well was installed in June 1988 in the approximate center of the landfill at a location where groundwater was encountered during prior geotechnical investigations. The well was installed to depth of 120 feet below ground surface, with a screened section from 110 to 120 feet below ground surface. A sample was collected from the well for organics, metals, and general chemistry parameters. Volatile organic compounds and semi-volatile organic compounds were not detected above detectable levels and metals did not exceed the Soluble Threshold Limit Concentration values under California Title 22 regulations.

Figure 191 on page 1414 shows the approximate location of the three groundwater monitoring wells and the leachate monitoring well installed for the Solid Waste Water Quality Assessment Test. These monitoring wells are no longer in use but have not been abandoned.

Four quarters of groundwater monitoring and sampling of these wells and leachate sampling were performed in 1988. Analytical results, as summarized from the reports, indicated the following:

Sulfate and Total Dissolved Solids concentrations were above the Secondary Maximum Contaminant Levels (250 and 500 parts per million [ppm] respectively) in both upgradient and downgradient levels. The highest levels were noted in the leachate well while the lowest concentrations were associated with the downgradient well. Water that exceeds the Maximum Contaminant Levels is considered unsuitable for drinking water.

With the exception of cadmium and chromium during the first quarter event, metal concentrations in the groundwater samples were not above the Primary Maximum Contaminant Levels. None of the metal concentrations in the groundwater or leachate monitoring wells were above the Soluble Threshold Limit Concentration values provided in California Title 23 regulations for determination of California hazardous waste. Metal concentrations in the downgradient wells did not appear to vary significantly from the upgradient wells.

Iron and manganese were above the Secondary Maximum Contaminant Levels in all wells; however, no significant increase was noted in these parameters from upgradient to downgradient wells.

131 Leachate as discussed here refers to the liquid that collects at the bottom of a landfill as water percolates through the waste materials.

Not to Scale

Figure 191Approximate Location of Monitoring Wells

Associated with the Solid Waste Water Quality Assessment Test

Source: Camp Dresser & McKee, 2010.

14



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Analytical results for leachate sampling did not detect volatile organic compounds or semi-volatile organic compounds, and concentrations of metals were less than the Soluble Threshold Limit Concentration values for California hazardous waste. Levels of Total Dissolved Solids, hydrogen (pH), chloride, sulfate, iron, manganese, and zinc were above their Secondary Maximum Contaminant Levels. Levels of chromium, aluminum, and lead also were above their Primary Maximum Contaminant Levels and tap water action level (for lead).

During one quarter an increase for hydrogen, chloride, cadmium, boron, manganese, and potassium with cadmium above the Primary MCL was noted from upgradient to downgradient in the groundwater near the landfill.

Volatile organic compounds in groundwater were detected only during the first two quarters of groundwater monitoring in 1988; the compounds were not detected during the last two quarters of 1988. Of the compounds detected in the first two quarters, two were also detected in the landfill gas (1,1,1-tricholoroethane and methylene chloride). Therefore, levels of these two compounds in groundwater could potentially be the result of the vapor phase constituents dissolving in the groundwater.

It should be noted that neither the groundwater nor the leachate on-site is used for drinking water, since no water extraction occurs at the Project Site. Conclusions of the groundwater Solid Waste Water Quality Assessment Test Report indicate that no hazardous materials are known to exist in the closed landfill site. The report states that monitoring results showed no indication of leakage of hazardous materials from the closed on-site landfill and that unsaturated zone and leachate monitoring indicated no leakage of hazardous materials from the closed landfill. Based on the four quarters of groundwater monitoring data and subsequent statistical analyses submitted to the Los Angeles Regional Water Quality Control Board, no further monitoring has been required at the Project Site. In addition, if the wells need to be closed in the future, such action would occur in accordance with all applicable requirements.

(ii) Other Groundwater Studies

Figure 192 on page 1416 shows the groundwater monitoring wells associated with the groundwater studies on the Project Site.

Preliminary Phase II Environmental Site Assessment

As discussed in Section IV.M, Environmental Safety, a Preliminary Phase II Environmental Site Assessment was conducted in 2005 to evaluate the potential presence or absence of subsurface impacts in selected areas of potential environmental concern identified in the Preliminary Phase I Environmental Site Assessment (for additional discussion of the Phase I and Phase II environmental assessments performed on the

Figure 192Groundwater Monitoring Well

Location Map

Feet

0 400 800

Legend

Source: Camp Dresser & McKee, 2010.

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Project Site, see Section IV.M, Environmental Safety, of this Draft EIR). The study area of the Preliminary Phase II Environmental Site Assessment was more focused than the Phase I Environmental Site Assessment (approximately 143 acres were studied in the Preliminary Phase II Environmental Site Assessment compared to 186 acres studied in the Phase I Environmental Site Assessment).132 The Preliminary Phase II Environmental Site Assessment also included baseline assessment of shallow groundwater chemistry and hydraulic conditions underlying approximately half of the northern portion of the Project Site (mostly northeastern portion).

The Preliminary Phase II Environmental Site Assessment included the construction and sampling of 13 groundwater monitoring wells. The groundwater monitoring wells were installed in 2005 to depths ranging between 30 and 50 feet below ground surface. As in the 1988-1989 Solid Waste Water Quality Assessment Test tests, groundwater samples were chemically analyzed for a variety of substances including volatile organic compounds, semi-volatile organic compounds, Title 22 California Assessment Manual metals, total petroleum hydrocarbons-carbon chain range C7 through C44 (select samples only), and polychlorinated biphenyls. Groundwater monitoring and sampling of these wells were performed in 2005. Constituents reported above laboratory reporting limits included: the metals arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, thallium, vanadium, and zinc; the volatile organic compounds methyl-t-butyl ether, chloroform, and acetone; and total petroleum hydrocarbons-carbon chain (carbon chain range C9 to C44). Semi-volatile organic compounds and polychlorinated biphenyls were not detected above reporting limits. Substances detected above reporting limits were compared to Maximum Contaminant Levels or action levels for drinking water. The Maximum Contaminant Levels for drinking water was exceeded for barium, cadmium, lead, and nickel. The groundwater monitoring wells installed as part of the Preliminary Phase II Environmental Site Assessment are not being monitored at this time but have not been abandoned.

In addition, if the wells need to be closed in the future, such action would occur in accordance with all applicable requirements.

Supplemental Phase II Environmental Site Assessment

As discussed in Section IV.M, Environmental Safety, in late 2005, a Supplemental Phase II Environmental Site Assessment was performed to further investigate areas of

132 The study area of the Preliminary Phase II Environmental Site Assessment did not include the northwestern portion of the Phase I Environmental Site Assessment study area (area west of Park and Jaws Lakes). Of the potential environmental issues identified in the Phase I Environmental Site Assessment, the closed landfill and electrical transformers were not further addressed in the Preliminary Phase II Environmental Site Assessment.



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interest previously identified in the Preliminary Phase II Environmental Site Assessment and to complete an additional round of groundwater monitoring. One new monitoring well was successfully installed in 2005 and two additional wells were installed downgradient from an area of buried debris in 2006. A total of 15 wells were sampled and analyzed for volatile organic compounds, total petroleum hydrocarbons-, semi-volatile organic compounds, metals, polychlorinated biphenyls, and perchlorate for this additional study. Constituents reported above reporting limits included: acetone, chloform, methyl-t-butyl ether, total petroleum hydrocarbons-carbon chain and metals. Semi-volatile organic compounds, polychlorinated biphenyls, and percholate were not detected above reporting limits. Barium, cadmium, chromium, lead, and selenium were detected above Maximum Contaminant Levels in unfiltered samples. In filtered samples, only cadmium was detected above its Maximum Contaminant Levels in one sample. Polychlorinated biphenyls, semi-volatile organic compounds and perchlorate were not detected above their respective laboratory reporting limits in any of the samples. The groundwater monitoring wells installed as part of the Supplemental Phase II Environmental Site Assessment are not being monitored at this time but have not been abandoned. In addition, if the wells need to be closed in the future, such action would occur in accordance with all applicable requirements.

Additional Sampling Activities

In 2007, 17 existing groundwater monitoring wells were tested and measured for the following parameters such as pH, conductivity, temperature, turbidity, dissolved oxygen and Total Dissolved Solids. In general, high Total Dissolved Solids levels were observed. A majority of the Total Dissolved Solids levels in the groundwater monitoring wells were observed at concentrations exceeding Secondary Maximum Contaminant Levels for Total Dissolved Solids, which indicates that the groundwater underlying the study area is not suitable for drinking water.

(iii) Underground Storage Tanks

As discussed in Section IV.M (Environmental Safety) of this Draft EIR, several leaks or other releases have occurred from underground storage tanks on the Project Site. Below is a summary of groundwater quality issues associated with known on-site underground storage tank releases.

Stage 27 Groundwater Remediation/Treatment Plant

In 1984 and 1985, the Project Applicant removed seven underground storage tanks near Stage 27, shown in Figure 193 on page 1419 located along the northern edge of the Project Site. The tanks—which were used to store unleaded gasoline, lacquer thinner, and paint thinner—ranged in size from 250 to 6,000 gallons. In 1987, a 4,000 gallon diesel underground storage tank was removed from the same area. Leaks from the underground

Figure 193 Underground Storage Tank Locations Referenced in Analysis

Legend

Source: Camp Dresser & McKee and Rios Clementi Hale Studio, 2010.

Property Boundary

TECHNICOLOR

STAGE27

FORMER BLDG 436(NOW BLDG 3316)

BUILDING4250

TR-1, TR-2,TR-3, TR-4

BLDG 5437

TM-3BUILDING

1280

TM-1,TM-2

BUILDING8166

BUILDING5187

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storage tanks affected groundwater in this area. The Los Angeles Regional Water Quality Control Board developed waste discharge requirements for a treatment system to be constructed and operated by the Applicant. These requirements were incorporated into National Pollutant Discharge Elimination System Permit No. CA 0060950 and adopted in August of 1989. The Stage 27 treatment system removed petroleum hydrocarbons and volatile organic compounds, and discharged treated groundwater to a storm drain that outlets to the nearby Los Angeles River Flood Control Channel. Discharges from the facility were discontinued in 1995. Results of long-term monitoring indicate that concentrations of materials of concern had been substantially remediated. The Los Angeles Regional Water Quality Control Board issued a closure letter for the underground storage tank operation at Stage 27 in July 1996.

Solvents in Groundwater Underlying the Business Area

An on-site tenant (Technicolor), located in the northwestern corner of the Project Site in the Business Area, stored solvents in underground storage tanks. Solvent leakage from one or more underground storage tanks appears to have occurred, possibly contaminating shallow or perched groundwater.133 In 1996, the Los Angeles Regional Water Quality Control Board required Technicolor to monitor seven out of 17 groundwater monitoring wells located adjacent to the tenant’s portion of the Project Site. A soil remediation program was implemented using vapor extraction. Concurrently, a groundwater monitoring program was implemented to investigate and characterize groundwater conditions semi-annually in the area potentially affected by contamination and remediation. Though active soil remediation ceased in July 2004 (per Los Angeles Regional Water Quality Control Board request), groundwater monitoring continues. The most recent monitoring event (July 2006) analyzed for volatile organic compounds, diesel fuels and ammonia in nine groundwater wells. The December 2005 groundwater sampling event concluded that perchloroethylene and trichloroethylene concentrations generally decreased over the previous sampling event. Perchloroethylene was detected above the established Maximum Contaminant Level in three wells and trichloroethylene was detected above the established Maximum Contaminant Level in two wells. The concentration of 1,1-dichloroethane exceeded the established Maximum Contaminant Level in two samples. The concentration of 1,1,1-trichloroethane was detected above the established Maximum Contaminant Level in two wells and the concentration of 1,1-dichloroethene was detected above the established Maximum Contaminant Level in one well, and five wells had concentrations of cis-1,2-dichloroethene above the established Maximum Contaminant

133 Perched groundwater is a zone of saturation located within a formation that is discontinuous from the water table and the unsaturated zones surrounding the formation. The formation exists as a discrete saturated zone that may be ephemeral (created by precipitation in the immediate vicinity) or recharged by percolation from nearby surface water or other perched water zones. When perched groundwater exists it is generally because there is not any hydraulic connection with other aquifer(s).



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Level. Vinyl chloride was detected at a concentration that exceeded the Maximum Contaminant Level. Diesel fuel and ammonia were also detected during the sampling event. Technicolor’s groundwater monitoring program continues to be subject to agency action by the Los Angeles Regional Water Quality Control Board and will continue to be addressed pursuant to Los Angeles Regional Water Quality Control Board directives.

Additional On-Site Groundwater Releases

In 1988, six underground storage tanks, ranging in size from 500 to 15,000 gallons, were removed from the Building 5187 area. Prior to removal, the tanks were used to store unleaded and leaded gasoline, diesel, used oils, and motor oil. The final closure report indicates that contaminated soil was removed from several areas; a small area of soil with slightly elevated diesel fuel concentration was not removed, since removing it would interfere with existing structures. Testing has defined the extent of the elevated diesel fuel to a limited area. The final closure document reported no significant soil impacts at the location. In 1994, testing performed on groundwater monitoring wells indicated no substantial groundwater impacts related to these tanks.

In 1996, two 2,000 gallon underground storage tanks used to store acetone and paint thinner were removed from Building 4250 and one 5,000 gallon kerosene underground storage tank was closed in-place at Building 1280. Confirmation soil sampling indicated no substantial soil impacts in these areas. Results from groundwater monitoring wells also indicated that there were no groundwater impacts from the tanks.

In 2005, a rinse water underground storage tank for the spray booth at the Tram Maintenance Garage was removed. Soil and groundwater samples were not required by Los Angeles County Department of Public Works. The closure report is still being reviewed by Los Angeles County Department of Public Works.

3. Environmental Impacts

a. Methodology

(1) Groundwater Hydrology

The analysis of the Project’s potential impacts to groundwater hydrology is based on a review of existing groundwater uses (i.e., potable water and recharge) and an evaluation of the potential impacts of the proposed Project on those uses.

Short-term (construction) impacts could result from subsurface dewatering activities. Because the amount of dewatering required would be based on conditions encountered



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during construction and would not be determined until actual construction, these potential impacts are qualitatively assessed.

Long-term (operational) groundwater hydrology impacts due to changes in groundwater recharge are determined by evaluating changes in recharge based on the proposed land use changes and infiltration capacity of the underlying soil; and comparing the change in recharge to existing groundwater conditions.

Other potential long-term impacts to groundwater hydrology include potential permanent dewatering associated with development of subterranean buildings in areas of high groundwater or remediation dewatering systems. Such impacts are evaluated based on the locations of proposed development and anticipated dewatering activities.

(2) Groundwater Quality

The analysis of the potential impacts regarding groundwater quality is based on analysis of the existing on-site evaluations and information provided and referenced in the Groundwater Technical Report, NBC Universal Evolution Plan, prepared by Camp, Dresser, & McKee, March 2010 (Appendix I-3 of this Draft EIR).

Short-term (construction) groundwater quality impacts could potentially occur during construction of the Project as a result of soil or shallow groundwater being exposed to construction materials, wastes, or spilled materials or as a result of construction dewatering. These potential impacts are qualitatively assessed.

Long-term (operational) groundwater quality impacts associated with the Project could potentially occur due to permanent dewatering of subterranean buildings (i.e., underground parking structures), handling and storage of hazardous materials, and/or groundwater remediation activities. These potential impacts are qualitatively assessed.

b. Thresholds of Significance

Based on the criteria set forth in the City of Los Angeles CEQA Thresholds Guide (2006), the proposed Project would have a significant impact under the following criteria:

(1) Groundwater Levels

Result in demonstrable and sustained reductions of groundwater recharge capacity; or

Change potable water level sufficiently to:



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o Reduce the ability of the water utility to use the groundwater basin for public water supplies, conjunctive use purposes, storage of imported water, summer/winter peaking, or respond to emergencies and drought;

o Reduce yields of adjacent wells or well fields (public or private); or

o Adversely change the rate or direction of flow of groundwater.


Affect the rate or change the direction of the movement of existing contaminants;

Expand the area affected by contaminants;

Result in an increased level of groundwater contamination (including that from direct percolation, injection, or salt water intrusion); or

Cause regulatory water quality standards at an existing production well to be violated, as defined in the California Code of Regulations, Title 22, Division 4, Chapter 15 and the Safe Drinking Water Act.

c. Project Design Features

The following discussion describes the proposed project design features that serve to provide groundwater quality benefits relative to preventing pollutants from entering local groundwater and preventing contaminated groundwater from entering surface water flows or municipal stormwater systems during both construction and Project operations.

Any dewatering of groundwater associated with the construction and/or operation of the proposed Project shall occur pursuant to, and comply with, all applicable National Pollutant Discharge Elimination System or industrial user sewer discharge permit requirements.

As is currently the practice on-site, which shall be extended to include future construction contractors operating on the Project Site, all applicable federal, state and local requirements would be complied with concerning the handling, storage and disposal of hazardous materials (as detailed in Section IV.M, Environmental Safety, of this Draft EIR).

Any discharge of groundwater during construction or operation of the proposed Project shall be pursuant to, and comply with the applicable National Pollutant Discharge Elimination System permit or industrial user sewer discharge permit requirements. If contaminated groundwater is found during the management of construction or long-term dewatering, treatment and discharge, as appropriate, shall be conducted in compliance with the applicable regulatory requirements



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(i.e., Los Angeles Regional Water Quality Control Board General Permit conditions, or City or County of Los Angeles requirements). General Permit conditions and water quality requirements that will effectively reduce the potential for the construction of the Project to release pollutants into groundwater or impact groundwater quality are detailed in the Surface Water Quality Technical Report for the Project.

Should a groundwater monitoring well be discovered during construction, the abandonment of the well would occur in accordance with the guidelines set forth in the “Department of Water Resources, California Water Well Standards, Part III, Destruction of Monitoring Wells”, and the California Department of Health Services guidelines.

Additionally, a number of surface water drainage and surface water quality Project Design Features have been designed to reduce peak surface water flow rates and the potential for pollutants associated with both construction and operation. See Sections IV.G.1.a, Surface Water Drainage, and IV.G.1.b, Surface Water Quality, of this Draft EIR for additional information on these Project Design Features.

d. Project Impacts

(1) Project Construction


The primary concerns relating to groundwater hydrology associated with proposed Project construction and operation are: (1) effects upon groundwater level, rate, direction or flow related to possible temporary, short-term and/or long-term dewatering activities; and (2) reduction in pervious surfaces that has the potential to result in the reduction of groundwater recharge.

Groundwater under the proposed Project Site is not currently pumped for beneficial uses (i.e., drinking water, industrial activity, or agricultural supply). In addition, no water supply wells are located at the Project Site that could be impacted by construction and the Project would not include the construction of water supply wells. Therefore, due to the distance to existing water supply wells (over one mile) and the fact that drinking water, industrial or agricultural supply wells would not be constructed as part of the Project, construction is not anticipated to change potable water levels sufficiently to reduce the ability of water utilities to use the groundwater basin for public water supplies or in a manner that would reduce the yields of adjacent public or private wells or well fields.

Groundwater could be encountered as close to the surface as 15 feet below ground surface in areas of the Project Site. Therefore, portions of the Project could encounter



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groundwater during construction and could require dewatering activities associated with construction. If construction dewatering is required, local groundwater flow direction and depth may be temporarily affected. The hydraulic conductivity observed in the shallow zone at the site is low, with a maximum value of 6.8 feet/day observed at one location, and a geometric mean hydraulic conductivity of 1.5 feet/day. The estimated maximum depth of excavation would extend for only a short distance into the saturated zone, and final basement slab levels would require an anticipated maximum construction drawdown of 11 feet. Anticipated dewatering requirements during construction range from about 65 gallons per minute (gpm) initially, declining over several months to about 9 gpm. Therefore, dewatering is not anticipated to draw water across any substantial distance and impacts are considered negligible from a local and regional basin perspective. Since no water supply wells would be affected and construction dewatering is not anticipated to adversely impact the rate or direction of flow of groundwater, no significant impact from construction of the proposed Project is anticipated to groundwater hydrology.

(b) Groundwater Quality

The primary concerns relating to groundwater quality associated with Project construction are: (1) spillage of hazardous materials from temporary construction equipment and operations, and (2) effects upon groundwater quality relating to short-term dewatering activities (i.e., movement of existing contamination). Section IV.M, Environmental Safety, of this Draft EIR, analyzes potential impacts associated with these issues and identifies mitigation measures, as appropriate.

During on-site grading and building construction, hazardous materials such as fuels, paints, solvents, and concrete additives could be used. These hazardous materials require proper management and, in some cases, disposal. The management of any resultant hazardous wastes could increase the opportunity for hazardous materials releases into groundwater. However, compliance with all applicable federal, state and local requirements concerning the handling, storage and disposal of hazardous waste would effectively reduce the potential for the construction of the Project to release contaminants into groundwater that could affect existing contaminants, expand the area of an existing contamination, increase the level of groundwater contamination or cause the violation of regulatory water quality standards at an existing production well as defined in the California Code of Regulations, Title 22, Division 4, Chapter 15 and the Safe Drinking Water Act (see also Section IV.M, Environmental Safety, of this Draft EIR for additional discussion of hazardous materials regulations and practices). In addition, as there are no groundwater production wells or public water supply wells within one mile of the Project Site, no construction impacts are anticipated to existing wells. Therefore, Project construction would not result in any substantial increase in groundwater contamination through hazardous materials releases, and a less than significant impact would occur.



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As described previously, groundwater could be encountered as close to the surface as 15 feet below ground surface. Therefore, portions of the Project Site could encounter groundwater during construction and require dewatering. If construction dewatering is required, it has the potential to affect the rate, change the direction, or expand the area affected by groundwater contamination. Previous investigations indicated no leakage of hazardous materials from the closed landfill, and that potential groundwater contamination associated with on-site releases (i.e., associated with Technicolor) have been, or continue to be, addressed under applicable regulatory oversight. Therefore, no significant areas of groundwater contamination have been identified beneath the Project Site.

Further, adverse impacts are not anticipated relative to the rate or direction of flow of shallow groundwater, or the area affected by, or the level of, groundwater contaminants, because the estimated maximum depth of excavation would extend for only a short distance and the anticipated dewatering requirements during construction is estimated to range from about 65 gpm initially, declining over several months to about 9 gpm. Therefore, dewatering is not anticipated to draw water across any substantial distance and impacts are considered negligible from a local and regional basin perspective. In addition, a majority of the Project Site does not overlay or have a connection with the Basin, and there are no groundwater production wells or public water supply wells within one-mile of the Project Site. If dewatering is required, with existing project design features (see above), no operational impacts are anticipated to existing wells and no regulatory water quality standards at an existing production well would be violated as a result of the Project. Additionally, with compliance with the well abandonment guidelines as noted in project design features (see above), a less than significant impact would occur with respect to groundwater quality from construction of the proposed Project. Therefore, a less than significant impact would occur with respect to groundwater quality from construction of the proposed Project.

(2) Project Operation


No water supply wells are located at the Project Site and no drinking water, industrial, or agricultural supply wells would be impacted, installed, or operated as part of the Project. The nearest water supply well (a public well owned and operated by Los Angeles Department of Water and Power, which is currently inactive) is approximately 1.2 miles northeast of the Project Site, with the nearest active water well field three (3) miles away. Therefore, no impact on public water supplies and no reduction in yields of adjacent public or private wells or well fields are anticipated as a result of the proposed Project.

Development associated with the Project is not expected to include activities that would require groundwater remediation that could affect groundwater hydrology. In



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addition, no long-term dewatering is anticipated with the operation of the Project. However, if below grade structures associated with the Project extend into the groundwater table (e.g., subterranean parking), those structures may require permanent dewatering systems. Any necessary groundwater dewatering would be discharged either to the sanitary sewer system or to the Los Angeles River Flood Control Channel via the storm drain system and would be conducted in accordance with applicable regulatory requirements. As stated above, the majority of the Project Site does not overlay or have a connection with the Basin. In addition, adverse impacts are not anticipated relative to the rate or direction of flow of shallow groundwater from long-term dewatering because the maximum anticipated permanent dewatering rates are anticipated to be 0.9 to 4.0 gallon per minute and its radius of influence on groundwater is limited. This value is insignificant relative to the overall Basin. Assuming the Project included the development of structures that extended below the historic high water level (15 below ground surface) within portions of the Project Site that could be overlying the Basin, and at the anticipated maximum dewatering rates of 0.9 to 4.0 gpm, it is estimated that the amount of groundwater extracted from long-term dewatering could range from 3.0 to 13.0 acre-feet/year.134 Compared to the overall Basin, potential long-term dewatering from the Project is minimal. Therefore, dewatering is not anticipated to draw water across any substantial distance and impacts are considered negligible from a local and regional basin perspective. Since no water supply wells would be affected and dewatering is not anticipated to adversely impact the rate or direction of flow of groundwater, the operation of the Project is not expected to have a significant impact on potable water levels.

Percolation of precipitation that falls on pervious surfaces is variable depending upon the soil type, condition of the soil, vegetative cover and other factors. Though no change of the Project Site boundary would occur, implementation of the proposed Project would include both the addition and removal of impervious surfaces throughout the Project Site. While the amount of impervious surfaces would increase in the Mixed-Use Residential Area, the amount of impervious surface is anticipated to decrease in the existing Entertainment, Studio, and Business Areas as a result of a reduction in total impervious roads and parking.

As detailed in Section IV.G.1.a, Drainage, under the CEQA Development Classifications (in the City of Los Angeles CEQA Thresholds Guide) the existing and proposed developed portion of the Project Site could be considered 100 percent impervious and portions of the undeveloped hillside could be considered 35 percent impervious. However, for a Project Site of this size, the percentages based on the CEQA

134 The estimated range of groundwater extracted from long-term dewatering assumes that a total of approximately 150,000 square feet at a maximum depth of 23 feet could be developed within a portion of the Project Site that could overly the Basin.



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Development Classifications would be an oversimplification, and potentially an overstatement, of Project Site conditions. Therefore, the Project Site was divided into site-specific land use categories and percent impervious percentage factors assigned based on the land use to determine the amount and flow rates for both the existing and proposed conditions.135 The impervious percentage factors used for the site-specific land use categories are detailed in Attachment A of the Surface Water Quality Technical Report for the Project.136 Based on the site-specific land uses and impervious percentage factors, the Project Site is approximately 66 percent impervious.

Construction of the Project would include some net conversion of existing pervious surfaces to impervious surfaces, which would have the potential to reduce groundwater recharge. Development associated with the proposed Project would result in a net increase in impervious surface to approximately 70 percent of the Project Site. Although there could be a very slight reduction in groundwater recharge due to the overall change in impervious area (4 percent) associated with the proposed Project, from a regional hydrologic perspective, the potential minimal loss in groundwater recharge resulting from the increase in impervious surfaces as a result of development is not considered substantial for the following reasons. First, any groundwater that exists under most of the Project Site is largely locally perched groundwater because a majority of the Project Site does not overlay, or have a hydraulic connection with the Basin. While the maximum possible reduction in infiltration across the entire Project Site as a result of the change in percent imperviousness is estimated at 15 acre-feet/year,137 essentially the majority of this potential reduction would occur in the Mixed-Use Residential Area where there is no direct connection with the Basin. Therefore, operation of the Project would not result in demonstrable and sustained reductions of groundwater recharge capacity.

As Project operation would not change potable water levels or affect groundwater recharge capacity, it is anticipated that a less than significant impact would occur.

135 NBC Universal Evolution Plan, Hydrology Technical Report prepared by Incledon Consulting Group, dated March 2010.

136 NBC Universal Evolution Plan, Surface Water Quality Technical Report, prepared by CDM. March 2010. 137 An increase in runoff from the baseline to the proposed condition is equivalent to a corresponding

decrease in infiltration. As shown in Table A-5 in Attachment A of the Surface Water Quality Technical Report for the Project (provided in AppendixI-2), the net increase in runoff from the baseline condition was estimated to be approximately 15 acre-feet/year. However, as described above, the 15 acre-feet/year is the change across the entire Project Site, of which a majority of the change in impervious is expected in the Mixed-Use Residential Area, where there is no direct connection to the Basin. The change in percent imperviousness of approximately 15 acre-feet/year does not include potential reductions in groundwater infiltration and recharge from dewatering. Should dewatering be required during construction and/or operation, as addressed in the text above, the impacts are considered negligible from a local and regional basin as a majority of the Project Site does not overlay or have a connection with the Basin and the radius of influence on groundwater is limited. For the same reasons, dewatering is not anticipated to depress the water table or eliminate recharge potential of the Basin.



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(b) Groundwater Quality

The primary operational concern relating to groundwater quality involves the storage of hazardous materials in underground storage tanks. Surface spills from the handling of hazardous materials most often involve small quantities and are cleaned up in a timely manner, thereby resulting in little threat to groundwater below the Project Site. The following analysis assumes that hazardous materials such as fuels, waste oils, and materials used by the Applicant, tenants, and third-party vendors would continue to be used on-site during Project operation and that Project development could cause an increase in site attendance and employee operations. These increases in on-site activities may result in an increase in the usage of fuels, lubricants and other potential pollutants. An increase in the quantities of hazardous materials used on-site may require an increase in storage of the hazardous materials in existing underground storage tanks, or require additional underground storage tanks to be installed. Any increases in the numbers of underground storage tanks over existing conditions during Project operation would most likely be a result of fuel storage for boilers, generators, and/or fueling of vehicles in the Studio and Entertainment Areas. This increase in the number of underground storage tanks and the aggregate quantities of associated hazardous materials could result in a potential increase in the possibility of spillage and underground storage tank leakage, with subsequent contamination of groundwater. Above-ground storage tanks may also be considered for use, which may decrease the potential for releases to groundwater by confining potential spills and leaks to aboveground detention areas.

Although there is potential for an adverse effect due to a potential increase in the numbers of on-site underground storage tanks, as detailed in Section IV.M, Environmental Safety, of this Draft EIR, the existing hazardous materials and underground storage tank management programs would continue with implementation of the Project. Compliance with all applicable existing regulations and plans at the Project Site would prevent the Project from expanding the area affected by contaminants, prevent an increased level of groundwater contamination or cause regulatory water quality standards at an existing production well to be violated, as defined in the California Code of Regulations, Title 22. In addition, as there are no groundwater production wells or public water supply wells within one mile of the Project Site, no operational impacts are anticipated to existing wells. Therefore, Project operation would not cause substantial adverse effects with respect to groundwater contamination with hazardous substances, and no significant impacts are anticipated.

No permanent dewatering systems are anticipated with development of the proposed Project. However, if below ground structures associated with the Project extend into the groundwater table (e.g., subterranean parking), those structures may require permanent dewatering systems. Potential permanent dewatering systems could include dewatering for methane safety systems and dewatering of structures below areas of



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perched groundwater, depending on the location. If a dewatering system is necessary, it would be designed and operated in accordance with all applicable regulatory and permit requirements. As described above, groundwater from long-term dewatering could be discharged to either the Los Angeles River Flood Control Channel or sanitary sewer in compliance with all applicable regulations. A majority of the Project Site does not have a hydrologic connection with the Basin. In addition, no significant areas of groundwater contamination have been encountered beneath the Project Site. The estimated maximum flow of dewatering is low (0.9 to 4.0 gallon per minute) and the radius of influence on groundwater is limited. Therefore, dewatering is not anticipated to draw water across any substantial distance. As such, no substantial impacts are anticipated to the rate or direction of movement of any existing contaminants beneath the Project Site or the area affected by or the level of groundwater contaminants. In addition, as there are no groundwater production wells or public water supply wells within one mile of the Project Site, if permanent dewatering is required, with existing project design features (see above), no operational impacts are anticipated to existing wells and no regulatory water quality standards at an existing production well would be violated. Since Project operation would not cause substantial alterations in groundwater contaminants beneath the site due to dewatering, a less than significant impact is anticipated.

(3) Impacts Under the No Annexation Scenario

A portion of the Project Site is proposed to be annexed to the City of Los Angeles, which would place the Mixed-Use Residential Area under the jurisdiction of the City. Portions of the Entertainment, Studio and Business Areas would be detached from the City, and as such, would be under the jurisdiction of the County. If annexation occurs, the appropriate lead agency’s policies and procedures would be applicable to the areas within the new City/County boundaries. While there are some differences between the policies and procedures of the respective jurisdictions, adherence to the policies and procedures of the applicable jurisdiction would mitigate any potential impacts. Additionally, because groundwater quality is regulated on a federal, state and regional level, the potential impacts associated with the construction and operation of the Project would not change if annexation/detachment occurs. As such, impacts associated with the No Annexation scenario would be equivalent to those of the Project, and thus, would be less than significant.

4. Cumulative Impacts

Cumulative groundwater hydrology impacts could result from the overall utilization of respective groundwater basins located in proximity to the proposed Project and related-project sites. To the extent that it is possible that public supply wells are located within or near the related-project sites, and the related-projects could extract water or require water to be extracted by water supply agencies from local basins, such cumulative utilization of



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groundwater in the region could adversely affect local and regional groundwater hydrology. However, the extent to which the related-projects would extract or otherwise directly utilize groundwater is not possible to assess. All or most of the related-projects would depend on public water supply systems (Los Angeles Department of Water and Power, etc.). All the large local groundwater basins, mainly the San Fernando Basin, are adjudicated and essentially not able to be over produced due to water rights limitations. To the extent there is a cumulative increase in water demand, it would have to come from other sources (i.e., water conservation and recycled and imported water). In addition, regardless of the location of related-projects, a majority of the Project Site is in the eastern Santa Monica Mountains, which is not part of the Basin or considered to be non-water bearing. Consequently, no significant cumulative impacts to groundwater hydrology (including not reducing the ability of the water utility to use the groundwater basin for public water supplies) are anticipated. As such, cumulative impacts on groundwater hydrology would be less than significant.

Construction and operation of the Project includes some net conversion of existing pervious surfaces to impervious surfaces, which has the potential to reduce groundwater recharge. Development associated with related-projects could also result in a net increase in impervious surface. The extent to which the related-projects would increase impervious surface that might affect groundwater hydrology is not possible to assess. However, any reduction in groundwater recharge due to the overall net change in impervious area due to the Project is very minimal from a regional groundwater basin perspective. Operation of the Project is not expected to result in any measurable decrease in local groundwater levels and would not result in demonstrable and sustained reductions of groundwater recharge capacity. In addition, any groundwater that exists under most of the Project Site is largely locally perched groundwater as the majority of the site does not overlay, or have a hydraulic connection with, the Basin. Therefore, the proposed Project’s contribution to reduction in groundwater recharge is not cumulatively considerable and, therefore, less than significant.

Although development of related-projects could include groundwater remediation, development associated with the Project is not expected to include activities that would require groundwater remediation that could affect groundwater hydrology; therefore, no cumulative groundwater impacts are anticipated. Additionally, related-projects are unlikely to cause or increase groundwater contamination because existing statutes prohibit contamination of groundwater by existing and future land uses and also require remediation of existing contamination. The only portion of the Project Site considered to be within the Basin is the northwestern area and a narrow portion of the Project Site along the Los Angeles River Flood Control Channel. A majority of the Project Site is not hydrologically connected to the Basin. As such, and in light of existing statutes that apply to the Project and other projects, and the proposed Project’s control measures, the proposed Project’s contribution to groundwater quality impacts is not cumulatively



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considerable and, therefore, less than significant. In addition, cumulative impacts to groundwater quality would be less than significant, as the proposed Project is not anticipated to affect the rate or direction of movement of existing contaminants; expand the areas affected by contaminants; increase the level of groundwater contamination (including that from direct percolation, injection or saltwater intrusion); or cause regulatory water quality standards of existing production wells to be violated as defined in the California Code of Regulations, Title 22, Division 4, Chapter 15 and the Safe Drinking Water Act.

5. Project Design Features and Mitigation Measures

a. Project Design Features


No project design features are proposed with respect to groundwater hydrology.


Project Design Feature G.2-1: Should a groundwater monitoring well be discovered during construction, the abandonment or removal of the well shall be in accordance with the applicable guidelines of the California Department of Water Resources, and the California Department of Health Services. As part of the abandonment process, a Well Abandonment Permit shall be obtained from the Los Angeles County Department of Health Services.

Also, refer to the Environmental Safety and Surface Water Quality Technical Reports for the Project for additional Project Design Features that address the potential impacts to soil and surface water quality, which potentially impacts groundwater.

b. Mitigation Measures


No significant impacts are anticipated to potable water levels or the recharge of groundwater from the construction and operation of the proposed Project; therefore, no mitigation measures are required or recommended.


With implementation of the above project design features and applicable regulatory policies, construction and operation of the Project would result in less than significant impacts with regard to adversely affecting the rate, direction of flow, or extent of



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groundwater contamination that would result in increased levels of groundwater contamination, or cause regulatory water quality standards at existing production wells to be violated from the construction and operation of the proposed Project; therefore as Project impacts are less than significant, no mitigation measures are required.

6. Level of Significance After Mitigation

Project impacts with respect to groundwater hydrology and water quality would be less than significant.

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