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Permit Number: T07OT00493
Parcel: 11615088L

Review Status: Completed

Review Details: FLOODPLAIN

Permit Number - T07OT00493
Review Name: FLOODPLAIN
Review Status: Completed
Review Date Reviewer's Name Type of Review Description Status Comments
03/17/2008 ELIZABETH EBERBACH ENGINEERING REVIEW Denied TO: Bruce Wilson, PE, Guy Shoaf, Carondelet Health Network
LOCATION: 1601 West St Mary's Rd, T14S R13E Sec02, Ward 1
SUBJECT: 2nd Revision of the Levee improvements for St Mary's Medical Center
REVIEWER: Elizabeth Eberbach, PE, CPM, CFM
ACTIVITY: T07OT00493 (Floodplain Use Permit)

SUMMARY:
A resubmittal for this project was submitted for review including revised Floodplain Use Permit Improvement Plans, structural calculations, a comprehensive response letter, and copies of the revised draft of the Maintenance Operation Plan. The subject property is entirely located within a Special Flood Hazard Area (SFHA), Zone A as shown on the Flood Insurance Rate Map (FIRM), Community- Panel No. 04019C-2210K, effective date February 8, 1999. A CLOMR was issued by FEMA for the levee project (Case#05-09-0988R, Jan 30 2006). A community notification letter shall be prepared. Also a community letter will be prepared for the acknowledgement of the map revision request once further items of the Floodplain Use Permit review are addressed, including the submission of the maintenance Agreement. The City of Tucson attorney's office must review the project for the proposed access and maintenance easement and Agreement. It is understood that Carondelet is communicating with The University of Arizona to resolve any outstanding issues and to obtain the easement and Agreement for the project. Further comments are forthcoming due to comments from the City Attorney and FEMA/State floodplain representatives. Engineering Division of Development Services Department has received and reviewed the resubmittal package and provides the following floodplain use permit comments per Floodplain, Stormwater, and Erosion Hazard Management Ordinance Sec.26-11.2.b and other sections of the Tucson Code and drainage standards.

FLOODPLAIN USE PERMIT COMMENTS:
1) DS Sec.10-02.1.5: A draft of the levee access and maintenance Agreement document must be provided to the City of Tucson. Submit to DSD and this will need to be reviewed by the City Attorney's Office, Viola Romero.
2) DS Sec.10-02.2.2.5.D: Provide a special provisions report. Include any construction restrictions, such as, having the construction vehicles wash off before entering the site to minimize weed seed contamination.
3) DS Sec.2-05.2.4.H.5: Since the levee access and construction easement will occur on two parcels, the levee access and maintenance Agreement shall reference both portions of the easement. There are the area owned by the Arizona Board of Regents (Parcel 116-15-1930), and the smaller area on Parcel 116-15-190C which is close to the existing box culvert at West Anklam Road, which is listed as being owned by St Mary's Hospital & Health Center. A notarized statement, an Agreement, and / or accepted recorded easement from the Board of Regents will be required.
4) DS Sec.10-02.2.3.1.6.C.2: Address the remaining Silvercroft Wash Levee Maintenance and Operation Plan Report comments.
a) The list of inspection condition items appears comprehensive, however, appears incomplete. For the list of inspection condition items, add or clarify: watershed (overall watershed flow direction and other watershed conditions), joint material (intact), utility disturbance (existing utility lines), compaction (geotechnical assessment may be needed), vandalism, and enclosure structures (functional security gates/fencing). Clarify under animal burrows that any animals shall be removed prior to plugging of burrows.
b) Add to item 3 of the Silvercroft Wash Levee Maintenance and Operation Plan Report on page 1, that the Professional Engineer shall not only supervise and/or perform the inspection but will also prepare a corrections report if needed.
c) Add to item 7 in the General Requirements section of the Silvercroft Wash Levee Maintenance and Operation Plan Report that the inspection report from the engineer shall specify a time frame / guideline for the expected time period to complete any required correction for each of the inspection condition items that must be addressed.
d) Add clarification that a subsequent report shall be submitted detailing the completion of any repair, restoration, reconstruction, or other action taken to address any deficiencies found from inspections.
e) Clarify and add to the Silvercroft Wash Levee Maintenance and Operation Plan Report that there will be required repair, restoration, reconstruction, or other action taken to address any deficiencies found from the inspection sheets, and that the report shall state a time frame to complete actions. There may be further clarification needed to specify the agreement and responsibilities of the levee maintenance. Further comments forthcoming after submitting the maintenance Agreement and further discussion with the City of Tucson Attorney.
f) Add to the Silvercroft Wash Levee Maintenance and Operation Plan Report that the levee operator will also keep on file the copies of the inspection records.
g) A copy of the maintenance easement shall be provided in the Silvercroft Wash Levee Maintenance and Operation Plan Report.
h) Add the special provisions report to the Silvercroft Wash Levee Maintenance and Operation Plan Report, either as a reference or in the appendix.
i) Add phone numbers in the section in the report page 1, for the contact phone numbers for the responsible Parties.
5) Tucson Code Sec.26-11.2(f), -2(b)(4): Address the remaining comments for the levee improvement plan sheets:
a) On sheet 2 clarify the connection between the proposed levee sheet piling and the existing bank protection structure along the existing embankment near the north wingwall.
b) For proposed sheet piling, provide geotechnical report for determining whether the sheet pilings will function and be able to be placed at these proposed locations. Clarify alternative toedown scour protection structure.
c) NFIP Section 65.10(b)(3): Provide details how the toedown will be connected to the concrete grouted rip rap, to provide reduction of any potential seepage path and minimize erosion.
d) Add general note to improvement plans referencing special provisions report and stating that special inspections and special pre-construction meetings are required to address special requirements including archeological relocation and staking prior to construction.
e) Clarify grading limits on planviews. A construction (existing) fence is called out on the plan as grading limits yet extends beyond the proposed easement limits. Clarify limits such that any disturbance is located within the limits of the construction easement. Update/clarify allowable disturbance area as stated in note 31.
f) There appears to be an access issue at the northwest corner of the mobilization yard. A proposed retaining wall is indicated along the north side of the proposed levee north of station 1+50. Only 10-ft is indicated between construction centerline / top of levee and the proposed retaining wall. Assure sufficient area is available to traverse from the staging area next to Anklam Road to the mobilization yard area.
g) Clarify connections for the joints between the toedown and the levee structure. Where concrete meets, show how the portions of the levee structure are to be tied or attached structurally to minimize seepage and settlement.
h) It was stated in a recent levee meeting that the toedown structure will be specified to address the construction encroachment issues brought up by the Army Corps of Engineers. Revise the Levee Improvement plan sheets to clarify which design will be used for the toedown structure and assure associated joint connection to the above ground portion of the levee matches.
i) It may be determined after finalization of toedown structure option, that a structural review will be needed for the floodwall, if used for final design.
j) DS Sec.10-02.2.3.1.5.G: Once authorization has been obtained, provide a copy of the letter of acceptance from property owner(s) for this drainage improvement. The access/maintenance Agreement for the levee easement area will need acceptance by all parties including St. Mary's Hospital / Director of Facilities for Carondelet, The University of Arizona Board of Regents, City of Tucson, and any other parties with vested interest.
k) Tucson Code Sec. 26-7.2, DS Sec.10-02.1.5: On riprap sections on sheet 6 and on planview detail on sheet 7, dimension the access and maintenance easement from top of levee structure to clarify construction area, maintenance, and any setback for future structures. Add docket/page for the levee maintenance easement on plan view once the maintenance easement is obtained for the levee structure and access to the levee structure.
l) The construction of the structures shall be clarified on the plans to adequately dimension construction area. Specifically, explain and show how the construction of the scour wall will be constructed as to not exceed disturbance limits on cross-section detail on sheet 3.
6) Tucson Code 26: Revise the SWPPP for this project according to the following comments:
a) Add reference to the project's special provisions report to SWPPP exhibit or report.
b) Assure that the new NOI form is used as well as signed and completed, for your project per recent ADEQ update to the CGP. The updated NOI, NOT, and Waiver Certification forms can be found at the ADEQ website at: http://www.azdeq.gov/environ/water/permits/download/constnoi.pdf
c) Assure that the new NOI form is used, as well as signed and completed, for your project per recent ADEQ update to the CGP http://www.azdeq.gov/function/forms/appswater.html#cgp . The updated NOI http://www.azdeq.gov/environ/water/permits/download/constnoi.pdf , NOT, and Waiver Certification forms can be found at the ADEQ websites.
d) Straw wattles or other plant-derived temporary stormwater control devices may be restricted or cause reseed concerns by the University. Consider providing notation on SWPPP that type of sediment and erosion control devices shall be functional to the SWPPP use and provide consideration to the University's plant farm.
e) Signatures for the operators on Certification Statements must be on the site copy of the Stormwater Pollution Prevention Plan (SWPPP) at, or before, commencement of construction. At minimum, one operator, either the engineer of record or the project manager shall sign the certification and submit with the SWPPP for the plan review package.
f) State receiving waters in SWPP report. Also, show and label receiving waters on a SWPPP exhibit.
g) There appears to be an access issue at the northwest corner of the mobilization yard. A proposed retaining wall is indicated along the north side of the proposed levee north of station 1+50. Only 10-ft is indicated between construction centerline / top of levee and the proposed retaining wall. Assure sufficient area is available to traverse from the staging area next to Anklam Road to the mobilization yard area.
h) For inspection purposes, include in SWPP report the enclosed "AZPDES - Posting Requirements" green sheet. This will need to be completed and posted at construction entrance of the site at beginning of construction activities and maintain this posted document throughout project construction.
7) DS Sec.10-02.2.2.5.D: The levee access and maintenance easement limits shall be revised to assure sufficient construction access, while minimizing disturbance of the floodplain area. Once the limits of the easement have been accepted by Arizona Board of Regents and by the City of Tucson, submit a copy of the recorded easement.
8) DS Sec.2-13: Per City Attorney's office, an ERR Report is required for the project. Submit an ERR Report according to Development Standard Section 2-13. Prepare an ERR Report that explains hydrology and hydraulics, as well as the ERR aspects for the proposed project. You may entitle the report St Mary's Levee ERR Report and include in the appendix the associated drainage report. The ERR reflects requirements in Tucson Code Chapter 26 Article I Section 5.2.(4) which states: Development in the floodway fringe shall not unnecessarily alter riparian habitats of watercourse and adjacent bank areas. If there is any proposed disturbance of the regulated 100-yr floodplain riparian watercourse on your site, an ERR report will be required to be submitted for review. The report shall explain the hydrology and hydraulics as well as the ERR aspects for the proposed project. Here is the link to the ERR requirements: http://www.ci.tucson.az.us/agdocs/20061107/nov7-06-610-2b.pdf Try page 8 for report contents. The report is somewhat similar to WASH Ordinance report and asks for similar information to be discussed in the report. (Specifically, see section 15 of the Tucson Code Chapter 29 Article VIII http://www.municode.com/resources/gateway.asp?pid=11294&sid=3 go down to Chapter 29, ARTICLE VIII. WATERCOURSE AMENITIES, SAFETY AND HABITAT.) Some line items may need more emphasis than others in the ERR Report. Explain intent of Carondelet to reduce their flood insurance by taking a large portion of the hospital structures out of the Special Flood Hazard Area (SFHA). State that the City of Tucson anticipates that the improvement will help reduce potential flood hazard conditions for downstream areas including the Nuns and St Mary's hospital campus. Explain in ERR Report whether a landscape plan or reseeding requirement is needed due to any University plant contamination concerns. Also provide discussion regarding University, USACE, and Archeological concerns and / or requirements. Discuss with the engineering reviewer whether there are some items outlined in section DS Sec.2-13 that need not be discussed in the ERR Report.
9) DS Sec.10-02.2.2.6: Per the CLOMR, clarify / explain how the following conditions of the CLOMR have been addressed:
a) There is a condition that states that the existing material of the existing levee shall be shown on the plans to be replaced by new material. Explain/revise improvement plans.
b) As-built plans are required to be submitted as well to the City of Tucson Development Services Department Engineering Division once the levee construction is completed.
c) Include the title of the local community official (per Floodplain Ordinance) responsible for ensuring maintenance activities are accomplished.
d) Explain and show on a drainage exhibit the location of the associated backwater ponding due to the proposed levee improvement. Any changes to the floodplain limits for any parcel shall be acceptable to the parcel owner. Provide notarized statement of acceptance from the affected parcel owners.
10) Tucson Code Sec. 26-11.2(i): Resubmittal is required. Additional floodplain review and meeting fees may apply; $300, and $75 respectively. Submit one copy of the revised improvement plan sheets, a hard copy of the CLOMR, a copy of correspondence from USACE regarding any requirements within 404 area, a copy of the revised drainage report or provide a drainage addendum addressing ponding limits and other items, copy of LMT geotechnical report, the draft of the maintenance Agreement, any acceptance documentation from parcel owners where proposed ponding may occur, any structural calculations, revised SWPPP, ERR Report, a copy of the special provisions report and response letter. It may be necessary to go over remaining comments to assure complete resubmittal.

I can be reached at 837-4934 if you have questions.

Elizabeth Eberbach, PE, CPM, CFM
Civil Engineer
Engineering Division
Development Services Department

Final Status

Task End Date Reviewer's Name Type of Review Description
07/10/2009 SUE REEVES OUT TO CUSTOMER Completed
07/10/2009 SHANAE POWELL REJECT SHELF Completed