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Permit Review Detail
Review Status: Completed
Review Details: RESUBMITTAL
Permit Number - T07OT00493
Review Name: RESUBMITTAL
Review Status: Completed
| Review Date | Reviewer's Name | Type of Review | Description | Status | Comments |
|---|---|---|---|---|---|
| 07/06/2009 | ELIZABETH LEIBOLD | 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: 3rd Revision of the Levee improvements for St Mary's Medical Center REVIEWER: Elizabeth Leibold, 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, a comprehensive response letter, an incomplete copy of geotechnical report, Floodplain addendum, copy of CLOMR letter (issued by FEMA for the levee project Case#05-09-0988R, Jan 30 2006) and CLOMR Report volumes, and copies of the revised draft of the Silvercroft Wash Levee Maintenance and Operation Plan Report now entitled the Operation Maintenance and Repair Manual. The subject property is currently 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 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 easements 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. Please be aware that there is an upcoming D-FIRM being prepared for issuance by FEMA. This project may be able to be reflected in the new updated FIRM panel if the project can be completed such that the LOMR is issued by a deadline expected sometime around January 2010. The City of Tucson needs remaining comments addressed in order to issue the floodplain use permit for the construction to begin. FLOODPLAIN USE PERMIT COMMENTS: 1) NFIP Section 65.10(d): It is still unclear from response letter whether the City, Carondelet, or Pima County will be taking responsibility for the Levee maintenance which is partially on the Arizona Board of Regents parcel and partially on the St Mary's property, that is within the City jurisdictional limits. During a meeting held April 10, 2009, Pima County RFCD was considering taking on responsibility of the levee, although throughout the reviews, Carondelet had been stating that they were to maintain the levee. It is imperative that responsibility is determined. It appears that either one of the following scenarios occurs: a) Carondelet constructs and functionally maintains the levee, with the City of Tucson assuming ultimate responsibility for maintenance (City of Tucson checks to see that Carondelet follows maintenance agreement requirements); or: b) Carondelet constructs and functionally maintains the levee, with PCRFCD assuming ultimate responsibility for maintenance (PCRFCD checks to see that Carondelet follows maintenance agreement requirements while providing copies of all maintenance reports to the City of Tucson for their records); or: c) The City of Tucson functionally maintains the levee as well as assumes ultimate responsibility for maintenance, after Carondelet constructs levee, provides certification documentation to FEMA, and obtains FEMA LOMR approval; or: d) The PCRFCD functionally maintains the levee as well as assumes ultimate responsibility for maintenance, after Carondelet constructs levee, provides certification documentation to FEMA, and obtains FEMA LOMR approval; or: e) Other scenario that meets CFR 44 Sec 65.2, and 65.10 levee requirements, and is agreed upon by all parties. 2) DS Sec.10-02.1.5: As stated in previous comment letter, 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. 3) DS Sec.10-02.2.2.5.D: As stated in previous submittal comment letter, 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. 4) DS Sec.2-05.2.4.H.5: Once the legal descriptions for the construction, maintenance, and temporary construction easements are completed, as stated in the response letter, provide copies. As stated in previous comment letter, 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. 5) NFIP Section 65.10(d), DS Sec.10-02.2.3.1.6.C.2: Address the remaining Silvercroft Wash St Mary's Medical Center Levee Operation Maintenance and Repair Manual comments. It is unclear from response letter whether the City, Carondelet or Pima County will be taking responsibility for the Levee maintenance. This issue must be resolved in order to further review the project's compliance with levee maintenance requirements. This plan must document the formal procedure that ensures that the stability, height, and overall integrity of the levee and its associated structures and systems are maintained. Address the remaining comments: a) Assure table that lists field items includes complete list of inspection / maintenance criteria. 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), and enclosure structures (functional security fencing). b) Clarify in the Routine Maintenance plan sections, between pre-stormflow, stormflow, and post-stormflow phases, with regard to occurrence. c) In stormflow section 4b), the manual states that the Stormflow Report needs to provide ALERT rainfall data. Provide in response letter or explain in manual whether there is an ALERT rain gauge near or upstream of the proposed levee structure. Provide location or gauge. d) Add to the manual that the Professional Engineer shall not only supervise and/or perform the inspection but will also prepare an assessment and corrections report if needed. e) Add to the manual 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. f) 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. g) Clarify and add to the Silvercroft Wash St Mary's Medical Center Levee Operation Maintenance and Repair Manual 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. h) Add to the Silvercroft Wash St Mary's Medical Center Levee Operation Maintenance and Repair Manual that the levee operator will also keep on file the copies of the inspection records. i) A copy of the maintenance easement shall be provided in the Silvercroft Wash St Mary's Medical Center Levee Operation Maintenance and Repair Manual. j) Add the special provisions report to the Silvercroft Wash St Mary's Medical Center Levee Operation Maintenance and Repair Manual, either as a reference or in the appendix. k) It will be necessary per NFIP Section 65.10(d) to provide contact data - please add contact phone numbers in the section of the Silvercroft Wash St Mary's Medical Center Levee Operation Maintenance and Repair Manual page 1, and the responsible parties names/titles. 6) Tucson Code Sec.26-11.2(f), -2(b)(4): Address the remaining comments for the levee improvement plan sheets: a) Address the following general note comments: i) As stated in previous comment letter, add a general note to improvement plans referencing special provisions report or right of entry agreement between the UofA and Carondelet Health Network for special construction monitoring requirements. ii) Revise/clarify or remove general note 10 regarding slope treatments, as plan details show other call out information. iii) Remove or explain purpose of general note 7. b) Provide easement information on plans for access at the northwest corner of the mobilization yard. c) It was stated in the response letter a detail would be provided - show on plans to 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. d) It was stated in response letter that structural calculations were provided for scour wall toedown structure, please provide. e) DS Sec.10-02.2.3.1.5.G: As stated in previous comment letter, 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. f) Tucson Code Sec. 26-7.2, DS Sec.10-02.1.5: As stated in previous comment letter, provide and label 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. g) Clarify connection detail for joint between existing and new concrete structure in Flood/Retaining Wall Connection detail on sheet 6. h) Clarify disturbance limits on cross-section detail on sheet 3 by labeling grading limits line on details B/3 and A/3. 7) Tucson Code 26: Revise the SWPPP for this project according to the remaining comments: a) As stated in previous comment letter, 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. b) As stated in previous comment letter, please label receiving waters on the SWPPP exhibit, for operators use. Silvercroft Wash may be labeled as receiving waters as well. If labeling Santa Cruz river, label on location map for contractors use. c) On plans, provide the easement information referenced in this submittal response regarding the access at the northwest corner of the mobilization yard. Assure sufficient area is available to traverse from the staging area next to Anklam Road to the mobilization yard area. d) For inspection purposes, include in SWPP report the enclosed "AZPDES - Posting Requirements" green sheet. This document or a copy of the NOI 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. e) Explain on SWPP exhibit how/when wash off area (as shown in keynote 3) is to be used. f) Provide hatching for all hatched areas shown on SWPP exhibit planview. 8) DS Sec.10-02.2.2.5.D: As stated in previous comment letter, 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. 9) DS Sec.2-13: As stated in previous comment letter, 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. 10) Tucson Code Sec. 26-11.2(i): Resubmittal is required. Submit one copy of the revised improvement plan sheets, a copy of correspondence from USACE regarding any requirements within 404 area, a copy of the revised drainage report with a copy of the drainage addendum showing floodplain limits (Addendum #1), complete copy of LMT geotechnical report, the draft of the maintenance Agreement between all parties, copy of recorded construction, maintenance, and temporary construction easements, a copy of the revised Operation Maintenance and Repair Manual, any structural calculations, a copy of the revised SWPPP, first submittal of 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 Leibold, PE, CPM, CFM Civil Engineer Engineering Division Development Services Department |
Final Status
| Task End Date | Reviewer's Name | Type of Review | Description |
|---|---|---|---|
| 07/22/2009 | CPIERCE1 | OUT TO CUSTOMER | Completed |
| 07/22/2009 | SUE REEVES | REJECT SHELF | Completed |