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Permit Number: T03BU01816
Parcel: 12801003A

Address:
240 S WILMOT RD

Review Status: Completed

Review Details: GRADING

Permit Number - T03BU01816
Review Name: GRADING
Review Status: Completed
Review Date Reviewer's Name Type of Review Description Status Comments
08/04/2003 LOREN MAKUS ENGINEERING REVIEW Denied DATE: August 4, 2003
TO: Cardell Andrews II
SUBJECT: LA Fitness, Grading Plan Review
REVIEWER: Loren Makus
ACTIVITY NUMBER: T03BU01816

SUMMARY: The Grading Plan was reviewed by Development Services Department Engineering Division. The grading plan and Stormwater Pollution Prevention Plan (SWPPP) were not approved at this time.
Grading Plan comments:
1. Show sidewalk scuppers for roof drainage locations so that the stormwater from a 10-year event will be conveyed under the sidewalk per City of Tucson Development Standards 2-08.4.1.E.
2. Add a comment stating that all grading will conform to IBC 2000.
SWPPP Comments:
The Stormwater Pollution Prevention Plan submitted for the LA Fitness project does not appear to meet the requirements of the Arizona Department of Environmental Quality (ADEQ) Arizona Pollutant Discharge Elimination System (AzPDES) General Permit for Discharge from Construction Activities to Waters of the United States (General Permit or CGP). Earlier this year, compliance inspectors from the United States Environmental Protection Agency (EPA) commented to us that SWPPPs should not be general and broad but should be specific to the project. The comments below reflect the comments we received from EPA.

3. Revise the SWPPP so that it is clearly applicable to this project. Some examples of sections that appear to contain inapplicable information.
a. 1.0 Introduction: "This SWPPP will be implemented prior to the commencement ofsoil disturbing activities associated with new construction or immediately for ongoing construction."
b. 3.3 Sequence of Major Construction Activities: "Utility Installation - Sewer, storm drain, water and dry utilities" and "Install storm drain inlet protection." If storm drains are to be installed, make sure they are shown on the grading plan and on the site map.
c. 3.3 Sequence of Major Construction Activities: The retention basin uses a wall with a low flow opening to provide the required capacity. Discuss the scheduling for construction of the wall.
d. 3.4.G Nutrient Application and Control: This section does not appear to reflect local practices.
e. 4.1.1 Stabilization Practices: "As much as possible, existing vegetation should be preserved in placeā€¦" Include a copy of the NPPO plan and Landscape plans with the resubmittal.
f. 3.4 Pollutants Associated with Construction Activities: This section lists a number of factors to consider when designing Best Management Practices (BMPs). The factors do not seem to be addressed in the BMP design for this site.
g. Silt Fence: BMP-63-68 provides details for silt fence that are not appropriate for construction site use.
h. 3.4.E.2 Concrete: Mixing surplus concrete/truck washout with the next load may cause problems with the next concrete load. Make sure this is an appropriate procedure before recommending it.
i. 3.4.E Pesticides: Will the contractor be storing and applying pesticides on this site or will a commercial application company be used as is the usual practice.?
Other sections of the SWPPP are so broad and general that they do not meet the EPA guidance for specificity. Please review and revise all sections of the SWPPP to ensure that they are written specifically for this project.

4. The CGP requires the SWPPP to "describe all pollution control measures that will be implemented as part of the construction project to control pollutants in stormwater discharges. For each major activity identified in the project description, the SWPPP must clearly describe appropriate control measures; the general sequence during the construction process that the measures will be implemented; and which operator is responsible for the control measure's implementation." (Part IV.D.1) Revise the SWPPP to address this requirement. Some examples of sections requiring revision are below:
a. 2.0 General Best Management Practices: Evaluate each recommendation. If it is appropriate for this project, make it mandatory. Provide enough detail for correct implementation include an implementation schedule.
b. 3.4 Pollutants Associated with Construction Activities: Revise the applicable recommendations so that they are mandatory. Omit the recommendations that do not apply. Provide details for structural controls (e.g. paved and curbed storage areas with drain, filet, and drum storage containment system.)
c. 4.1 Erosion and Sediment Controls: Provide specific timelines for installation of controls relative to the general sequence of construction events. If phasing of soil disturbing activities appropriate for this site, provide a phased grading and construction scheme.
d. 4.1.2 Structural Practices: Specify which structural controls will be used in each specified location. Provide adequate details for each structural BMP. If manufacturers specifications are different from the instructions in Appendix F, define which specifications will be followed.
e. 4.2 Stormwater Management: Provide timelines for the installation of the riprap aprons for velocity dissipation.
f. 5.0 Non-Storm Water Discharges: Describe BMPs for eliminating or reducing non-stormwater discharges to the extent feasible. Describe the BMPs that will be implemented to minimize pollutants in non-stormwater discharges. If superchlorinated water is used at the site, it must be dechlorinated prior to discharge.
g. 4.2 Storm Water Management: Will the sediment basin provide storage for the local 2-year, 24-hour storm event before the containment wall is constructed. Address the control of sediment laden water from the low flow opening in the wall once it has been constructed.
5. The CGP requires the SWPPP to "contain a site map" with a list of requirements. (Part IV.C.3) Revise the site map to include each of the applicable required items. All BMPs specified in the SWPPP must be shown. If the locations of any specified storage areas will be determined by the general contractor, the permit will be issued with the condition that all required contractor contributions to the SWPPP will need to be approved before any work on the project is started.
6. Revise the SWPPP to provide for keeping the required records of stabilization. (Part IV.D.4.c)
7. Revise the Notice of Intent, which does not match the information in the SWPPP. The receiving water is the Alamo Wash. The Alamo Wash is a part of the municipal separate storm sewer system operated by the City of Tucson.
8. Revise the site map so that sediment control structures are identified. If any "stabilization structures" are used, provide details.
9. Explain the statement "Current runoff water quality is unlikely" which is on page 6 of the SWPPP.
10. Revise the Sequence of Major Construction Activities to reflect that structural sediment controls will be installed before clearing and grubbing.
11. Section 3.4 classifies potential sources of pollutants as hazardous, liquid and solid wastes. Most of the materials of concern discussed in the section are not waste. Revise the section to clearly include non-waste materials, if you decide the section is applicable.
12. Revise section 3.4.A to provide instructions for managing the solvent containers, if you decide the section is applicable.
13. Revise section 4.2 of the SWPPP to provide an achievable disposal solution for sediment that is to be removed from the basin at the end of the project.
14. Revise the inspection forms to provide all of the required information and the inspector certification. (Part IV.H.5)
15. Provide a list of control measures and the parties that will be responsible for implementing and maintaining each. If the responsible party is not yet known, leave space to be filled in later.(Part IV.B.1.d)

Revise the Grading Plan and the SWPPP to address all of these comments and resubmit two copies of the grading plan and three copies of the SWPPP for review. Enclose a copy of the approved site plan. If you would like to meet with me to discuss any of these comments please call me at (520) 791-5550 ext. 1161.

Loren Makus
Senior Engineering Associate
Engineering Division
Development Services
08/04/2003 LOREN MAKUS NPDES REVIEW Denied The AzPDES (NPDES) submittal was reviewed by the engineering reviewer. The comments are with the engineering comments.
08/08/2003 JOE LINVILLE NPPO REVIEW Denied The review will not commence until approved copies of the NPPO plans and the site/landscape plans are submitted for review.
08/11/2003 Daniel Castro ZONING REVIEW Denied The grading plan must be approved by the Engineering and Landscape Review Sections prior to Zoning Review approval.

Final Status

Task End Date Reviewer's Name Type of Review Description
08/11/2003 TAMI ACHONG OUT TO CUSTOMER Completed
08/11/2003 ANGIE SHOFFSTALL REJECT SHELF Completed