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SAN LEANDRO SHORELINE DEVELOPMENT EIR ADDENDUM PROJECT CITY OF SAN LEANDRO Page 40 PlaceWorks flows and water quality which would result in a greater potential to introduce pollutants to receiving waters. Water quality impacts would be reduced to a less than significant impact by adhering to regulation such as those outlined by the Alameda County Clean Water Program, specifically the C.3 provisions set by the San Francisco Bay RWQCB. Adherence to City ordinances would also require the preparation of a Stormwater Management Plan (SWMP) which includes BMPs appropriate to control runoff for the Project. Furthermore, the project applicant would need to prepare an Operations and Maintenance (O&M) Plan for post-construction water quality measures, as per Alameda County C.3 provisions, to identify responsibility for maintenance of the stormwater treatment facilities and provide adequate funding to maintain and operate the stormwater improvements, and to comply with SWPPP requirements and San Leandro General Plan policies. As proposed, the Modified Project, which does not change the uses of the Approved Project and does not require alteration to the proposed treatment of stormwater, would remain in compliance with operationally related specifications applicable to those for the Original Project. Therefore, operational impacts associated with the Modified Project would not result in a new impact or a substantial increase in the magnitude of the existing impacts. As discussed in the Certified EIR for the Original Project, water quality would be improved through the treatment of stormwater on-site and through stormwater pollution reduction through the implementation of source control, site design, and LID measures in compliance with the C.3 provisions for stormwater in Alameda County. In addition, compliance with San Leandro Municipal Code Section 3-15, Stormwater Management and Discharge Control, as described in Chapter 4.8, Hydrology and Water Quality, of the Certified EIR, would further protect water quality during project construction and operation. Because the Modified Project would be in conformity with those specifications relevant to the Original Project, new impacts or any substantial increase in the magnitude of the existing impacts to water quality would be avoided. HYDRO-c i, ii, iii iv. The Original Project had the potential to increase impervious surfaces and to divert groundwater to surface waters through requiring short-term construction dewatering due to the shallow groundwater table. Dewatering activities would require obtaining a Waste Discharge Requirements (WDR) permit from the San Francisco Bay RWQCB. The WDR permit requirements would require testing to prevent discharged water from posing a risk to water quality in San Francisco Bay. In the case that pollutant levels are too high, treatment of the collected groundwater would be required prior to discharge to San Francisco Bay or the City’s storm drain system. As with the Original Project, the Modified Project would also be subject to SWPPP requirements ensuring that the discharge of construction dewatering would not significantly impact groundwater quality. The proposed residential housing units for the Modified Project, as with those in the Original Project, would be supplied with EBMUD water, which relies on surface water and recycled water rather than groundwater wells, therefore causing no depletion from groundwater well sources. Furthermore, the Modified Project would be consistent with the Original Project through the implementation of Low Impact Development (LID) measures and on-site infiltration, as required under the C.3 provisions of the Alameda County Clean Water Program which will increase the potential for groundwater recharge. Consistency through the use of site design features as per the C.3 provisions and implementation of water use efficiency measures mandated by the Water Conservation Act of 2009 would ensure that groundwater supplies are not depleted, and impacts would be less than significant. As proposed, the Modified Project, which would not alter drainage patterns on the project site or result in