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Permit Number: T11OT01442
Parcel: 11615088L

Review Status: Completed

Review Details: FLOODPLAIN

Permit Number - T11OT01442
Review Name: FLOODPLAIN
Review Status: Completed
Review Date Reviewer's Name Type of Review Description Status Comments
08/04/2011 ELIZABETH LEIBOLD ENGINEERING REVIEW Denied TO: Mike Zeller, P.E., TetraTech, Guy Shoaf, Carondelet Health Network
LOCATION: 1601 West St Mary's Rd, T14S R13E Sec02, Ward 1
SUBJECT: 5th Revision of the Levee improvements for St Mary's Medical Center
REVIEWER: Elizabeth Leibold, P.E., CPM, CFM
APPLICANT: Carondelet
CLOMR: Pending
ACTIVITY: T11OT 01442, T11BU00970 (T07OT00493 - old Floodplain Use Permit)

SUMMARY: A resubmittal for this project was submitted for Floodplain Use Permit review, including: 2 copies of the revised Saint Mary's Floodwall at Silvercroft Wash and Anklam Road, CD with Design Concept Summary, Special Provisions, and ERR report. A meeting was held 21JUL11 to go over the items submitted and discuss remaining items to be submitted. 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-2260L, effective date June 16, 2011. CLOMR letter issued by FEMA for Case#05-09-0988R, Jan 30 2006 has been resubmitted to FEMA for additional CLOMR review and is pending issuance. The City of Tucson attorney's office and TDOT is reviewing the project, including the proposed access and maintenance easement and agreement which has not been submitted yet. Further comments are forthcoming due to comments from the City Attorney, TDOT, and FEMA/State floodplain representatives. It is understood by PDSD Engineering, that FEMA is expected to update the SFHA for the St Mary's campus from Zone A to X zone, once the Levee is constructed by Carondelet and certification is obtained. Engineering Division of Planning & 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 City of Tucson drainage standards. The City of Tucson needs following comments addressed in order to issue the floodplain use permit for the construction to begin.

FLOODPLAIN USE PERMIT AND GRADING COMMENTS:
1) NFIP Section 65.10(d): From correspondence from TDOT, Floodplain Administrator, the City Attorney's Office, and previous discussions with the applicant, Carondelet is expected to construct levee, provide certification documentation to FEMA, obtain FEMA LOMR approval, and that Carondelet would be responsible for Levee maintenance, where the City of Tucson will act as facilitator. It was also discussed that TDOT under contract with Carondelet might act as an initial maintenance contractor for Carondelet and be reimbursed for maintenance activities. In Design Concept Summary Report, explain how this project conforms to maintenance requirements under CFR 44 Sec 65.2, and 65.10.
2) DS Sec.10-02.2.3.1.5.G, 10-02.1.5: A draft of the levee access and maintenance agreement documents must be provided to, and accepted by, the City of Tucson. Provide status of these documents. As stated in meetings, 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 and any MOU from City Attorney's Office will need acceptance by all parties including St. Mary's Hospital, The University of Arizona Board of Regents, & City of Tucson.
3) DS Sec.2-05.2.4.H.5: The proposed project is partially on the Arizona Board of Regents parcel and partially on the St Mary's property, and within the City jurisdictional limits. 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. Provide copies of the easements with legal descriptions for the construction, maintenance, and temporary construction easements. A notarized statement, an agreement, and / or accepted recorded easement from the Board of Regents will be required.
4) NFIP Section 65.10(d), DS Sec.10-02.2.3.1.6.C.2: Address the following levee maintenance and operation plan comments. 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 following comments:
a) Provide in response letter or explain in manual whether there is an ALERT rain gauge or other gauge near or upstream of the proposed floodwall levee structure. Provide location of closest gauge in report.
b) Add to the maintenance and operation plan report that the Carondelet Professional Engineer or other designee shall provide design assessment for major repairs if needed and proposed corrections in a report that may need to be submitted to the City of Tucson PDSD for review.
c) Explain in response letter the location of the maintenance and operation plan report where subsequent maintenance reports may be required to be submitted detailing the completion of any repair, restoration, reconstruction, or other action taken to address any deficiencies found from inspections.
d) Add to the 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. Clarify and add to the manual that there will be required minor 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.
e) A copy of the descriptions of the maintenance easements shall be provided in the maintenance and operation plan report.
f) Although the City of Tucson is intending to act at facilitator, ultimately responsible for ensuring maintenance activities are accomplished, Carondelet shall have a point of contact to advise on major repair or replacement of the levee structure, and, as discussed in prior meetings, provide financial reimbursement for maintenance. Provide contact name and phone number on one of the first pages of the maintenance and operation plan report.
g) The City of Tucson PDSD Engineering has understood that Carondelet is financially responsible for any maintenance that Carondelet may contract TDOT to do, and the City is the facilitator, ultimately responsible for maintenance management only. Clarify in agreements and maintenance plan report that other contractors may be used to do levee maintenance as approved by facilitator and accepted by Carondelet.
5) Tucson Code Sec.26-11.2(f), -2(b)(4), DS Sec.10-02.2.3.1.4.C.3: Address the following grading plan comments:
a) Clarify vertical datum in reports and clearly show benchmark that is referenced on grading plan note 49 sheet 1, on a grading plan planview.
b) Label limits of easement.
c) Label FEMA and jurisdictional floodplain limits.
d) Provide and label construction staging, vehicle wash off, and staging areas to be located within the access easement.
e) Provide dkt/pg on plans for access easement and temporary construction / mobilization yard area easement at the northwest corner of the project.
f) Tucson Code Sec. 26-7.2, DS Sec.10-02.1.5: 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) Provide structural calculations for scour wall structure.
h) Add note to plans that as-built plans are required to be submitted to City of Tucson Planning & Development Services Department Engineering Division once the levee construction is completed.
i) On sheet 2 address the following comments:
i) Details A, B & C, and sections A-A & B-B shall be shown on planview with callouts.
ii) Clarify use of salvaged rock for detail section B-B. Size of rock from existing berm may not meet minimum requirements of PC/COT standard specifications, and may be too large for 13.3-ft improvement section.
iii) Note 2 is missing specification number.
iv) Note 4 shall be revised; City Of Tucson requires no vegetation within access areas. Sized gravel shall be provided in the access areas.
v) Show on planview the existing sidewalk and EOP.
vi) Label distance to fence or resize disturbance limits on planview.
vii) Clarify distance of 4-ft freeboard.
j) DS Sec.10-02.2.3.1.4.C: On all planview sheets show FEMA and jurisdictional floodplain limits, erosion hazard setback, and WSEL's, for pre and post developed conditions.
k) Clarify locations of cross-section details on planview sheet or on section labels, to assure stationing matches section locations.
6) DS Sec.10-02.2.3.1.4.D: Address the following comments related to the HEC-RAS analysis, floodplain delineation, and detail sections:
a) Provide cross section labels for the sections on pages 55 through 60, and pages 76 through 84.
7) DS Sec.10-02.2.2.6: Provide copy of CLOMR and conditions of CLOMR. In response letter or on plans/reports, explain how any CLOMR conditions are met.
8) Tucson Code 26 Article 2: Revise the SWPPP for this project according to the remaining comments:
a) 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) Provide a SWPP plan for review.
c) 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.
d) 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.
e) 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.
f) 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.
g) Provide a note/reference to the project's special provisions report on the SWPPP exhibit plan.
h) Explain on SWPP exhibit how/when wash off area is to be used.
9) DS Sec.10-02.2.3.1.5.G: Any outstanding documentation regarding the authorization to construct the levee including any levee access easement or maintenance related agreements, shall be completed and accepted by the City. Address the following comments regarding the easements, agreements, and maintenance plan responsibilities:
a) As stated in meeting, the levee access and maintenance easement limits shall be reviewed by TDOT and City Attorney's Office once submitted, 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.
b) The City Attorney's office has directed PDSD to obtain all of the agreement and easement documentation in the next submittal, which will then be forwarded to the City Attorney's Office for review, addressing cover letters with attention to Damian Fellows.
c) Maintenance / operation plan documentation shall clearly identify responsible parties and address successors.
d) Provide copy of signed MOU from the University referenced in reports.
10) DS Sec.9-06: Address the following ERR Report comments:
a) In the report, the existing berm is referred to as a levee, however this berm does not meet levee standards, and thus the need for the project. Revise the verbiage on page 1 to clarify that the purpose of this project is to replace the non-conforming existing berm, located near the intersection of St. Mary's and Anklam roads, with a floodwall that is intended to meet NFIP levee requirements. Revise the verbiage on other pages in the report to clarify that the existing berm is not a levee.
b) Also revise statement on same page regarding "The proposed floodwall cannot be relocated …" ; this sentence needs clarifying. EOR should review ERR Report prior to resubmittal to correct or clarify statements in the report.
c) On page 7, clarify that the W.A.S.H. Ordinance portion of the drainage system is not impacted by this proposed improvement.
d) Clarify in the report that the floodwall levee improvement project is a private improvement.
e) Provide delineation of the floodplain limits on the exhibits and plans.
11) DS Sec.11-01.4.1.C, 10-02.6.6: Provide referenced copy of 2005 LMT report and any other geotechnical addenda or reports. Also provide specifically the concurrence from geotechnical engineer that the Silvercroft Wash east bank is stable along the study reach (page 5 of the Erosion Hazard Assessment portion of the Design Concept Summary report.)
12) NFIP Section 65.10(b)(3): Revise section of the Design Concept Summary report page 3 to address seepage. Discuss reinforcement of floodwall in report and how toedown depth reduces any potential seepage paths. Provide details how the floodwall levee structure provides reduction of any potential seepage path and minimize erosion.
13) Tucson Code Sec. 26-11.2(i): Resubmittal is required. Submit 2 copies of the revised improvement plan sheets, any copies of correspondence from USACE regarding any requirements within 404 area, a copy of the revised Design Concept Summary Report, one copy of the complete LMT geotechnical report and addenda, the draft of the maintenance agreement between all parties, copy of recorded construction, maintenance, and temporary construction easements, a copy of the maintenance and operation manual, MOU, agreements, easements, any structural calculations, a copy of the SWPPP, a copy of the special provisions report, and comprehensive response letter. It will be necessary to go over remaining comments in a meeting to assure complete resubmittal.

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

Elizabeth Leibold, PE, CPM, CFM
Civil Engineer
Engineering Division
Planning & Development Services Department

Final Status

Task End Date Reviewer's Name Type of Review Description
02/15/2012 FERNE RODRIGUEZ OUT TO CUSTOMER Completed
02/15/2012 SUE REEVES REJECT SHELF Completed