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Permit Review Detail
Review Status: Completed
Review Details: RESUBMITTAL
Permit Number - T11OT01442
Review Name: RESUBMITTAL
Review Status: Completed
| Review Date | Reviewer's Name | Type of Review | Description | Status | Comments |
|---|---|---|---|---|---|
| 02/22/2012 | ELIZABETH LEIBOLD | ENGINEERING | REVIEW | Denied | DATE: March 15, 2012 TO: Mike Zeller, P.E., TetraTech, Guy Shoaf, Carondelet Health Network LOCATION: 1601 West St Mary's Rd, T14S R13E Sec02, Ward 1 SUBJECT: 6th Revision of the Levee improvements for St Mary's Medical Center REVIEWER: Elizabeth Leibold, P.E., CPM, CFM APPLICANT: Carondelet CLOMR: 11-09-2928R ACTIVITY: T11OT01442, T11BU00970 (T07OT00493 - old Floodplain Use Permit) SUMMARY: A resubmittal for this project was submitted for Floodplain Use Permit review, due to the extent of comments, a meeting is requested to go over responses prior to next submittal. This resubmittal was submitted for Floodplain Use Permit review. including: a copy of the revised Saint Mary's Floodwall at Silvercroft Wash and Anklam Road Construction sheets (TetraTech's 2nd Submittal).pdf, a copy of the SWPPP, 2 CD's with Maintenance and Operation Plan.pdf, Special Provisions_REV01_08232011, TetraTech Responses to COT Floodwall Comments (02-10-12).pdf, CLOMR HEC-RAS, copy of archaeological permit, CHN_HPTP_Addendum_Final.pdf (Addendum to the Historic Properties Treatment Plan), Revised Design Concept Summary -- St. Mary's Floodwall.pdf, Updated ERR Report, REVISED -- Desert Earth.pdf with appendices, and other documentation. 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. 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. Previous CLOMR letter issued by FEMA for Case#05-09-0988R, Jan 30 2006 has been updated with CLOMR 11-09-2928R (August 30, 2011). The City of Tucson attorney's office and TDOT is reviewing the project, including the proposed access and maintenance easement and agreements. Further comments are forthcoming due to comments from the City Attorney, TDOT, and Landscaping for ERR review. 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 remaining 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 remaining 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): Provide location in the Design Concept Summary Report where explanation is provided regarding 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. Include flowage easement for the City. 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, assuring that sufficient turn around or maneuverability is provided. 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) 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. b) 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. c) 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. d) A copy of the descriptions of the maintenance easements shall be provided in the maintenance and operation plan report. e) 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 any financial reimbursement for maintenance. Provide contact name / title and phone number on one of the first pages of the maintenance and operation plan report. f) The City of Tucson PDSD Engineering has understood that Carondelet is financially responsible for any maintenance that Carondelet must coordinate any agreements with TDOT, 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. g) Address maintenance and operations plan comments provided in redlined attachment. h) Add to the maintenance and operation plan, that copies of maintenance and inspection reports and verification that any deficiencies that were noted during maintenance inspections have been corrected should be submitted. Documentation of any levee maintenance-related training conducted (e.g., agenda, attendee sign in sheets, etc) should also be submitted. Written commentary on the performance of the levee floodwall in any actual flood events should be submitted. This assessment should include as much of the following information as is available: i) Dates and magnitude of flood events ii) Photographs of levee protected areas during historical flood events iii) Whether or not the levee was overtopped, breached, or otherwise failed iv) How gravity outlets performed v) Extent and depth of interior ponding behind the levee vi) Extent and magnitude of any underseepage vii) Extent and magnitude of erosion, sedimentation, or structural damage to the system viii) Extent, if any, of damage to any buildings or infrastructure due to flooding behind the levee system ix) Geotechnical settlement analysis every 10 years at minimum x) Any other pertinent information relevant to the levee's performance 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) Provide location in response letter for the clarification of the 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 dimensions for widths and limits of easements including existing utilities. c) Label effective FEMA and jurisdictional floodplain limits. d) Provide owner documentation regarding offsite construction staging, vehicle wash off, and staging areas. 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 docket/page for flowage easement / levee maintenance easement on plan view once the maintenance easement is obtained for the levee structure and access to the levee structure. g) Provide wall review application in next submittal with structural calculations for scour wall. h) On sheet 2 address the remaining comments: i) Clarify distance of 4-ft freeboard. Label the additional 1 foot freeboard within 100 feet of either side of culvert structure, and label the additional one-half foot of freeboard on upstream end. i) DS Sec.10-02.2.3.1.4.C: On all planview sheets show effective FEMA and jurisdictional floodplain limits, erosion hazard setback, and WSEL's, for pre and post developed conditions. j) Label constructed side slopes for details on sheet 5 for Stations 0+0.1.22 and 2+25. k) Explain slope protection techniques for the areas of constructed slope near and around Stations 0+0.1.22 and 2+25. l) See redlines for additional clarification requests. 6) DS Sec.10-02.2.2.6: In response letter or on plans/reports, explain how any CLOMR conditions are met. For notification requirement, please provide address list of impacted properties for City review. 7) Tucson Code 26 Article 2: No responses were previously provided for the following comments. 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. 8) 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 remaining comments regarding the easements, agreements, and maintenance plan responsibilities: a) As stated in meeting, the levee access and maintenance (flowage) 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) Update maintenance / operation plan documentation to clearly identify responsible parties by name/title and address successors. d) Provide copy of revised documentation for any MOU's from the University or Carondelet. e) Provide documentation from Gas, Tucson Water, and PCRWRD for nearby utility lines and acceptance of proposed construction clearances. 9) DS Sec.9-06: Provide response letter to 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) Label and provide effective FEMA FIRM floodplain limit delineation on the ERR exhibits and construction plans. f) Label and state that the Silvercroft Wash is an ERZ Wash under review. 10) DS Sec.11-01.4.1.C, 10-02.6.6: To assure minimized settlement and to maintain freeboard, the geotechnical recommendations for compaction should be provided and emphasized on plans. 11) NFIP Section 65.10(b)(3): Add statement in the Design Concept Summary report or add to specifications report regarding material used for grout for floodwall prevent seepage. Many types of colored grout are known to erode; explain how grouted CMU block floodwall prevents seepage. Also state in report whether the hydrodynamic and hydrostatic lateral loads provided on sheet 5 are sufficient for debris impact. 12) Tucson Code Sec. 26-11.2(i): Resubmittal is required. Submit 2 copies of the revised improvement plan sheets, and previous documents and reports, including: any copies of correspondence from USACE regarding any requirements within 404 area, the draft of the maintenance agreement between all parties, copy of recorded construction, maintenance, temporary construction, and flowage easements, MOU, agreements, utility easement correspondence, revised SWPPP and 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 to set up a meeting, or if you have questions. Elizabeth Leibold, PE, CPM, CFM Civil Engineer Engineering Division Planning & Development Services Department |