22-102749-UP-Comment Response Letter-04-10-2023-V1Page 1 of 8
April 10, 2023
City of Federal Way
Attn: Becky Chapin
33325 8th Avenue S
Federal Way, WA 98003
Via email – becky.chapin@cityoffederalway.com
RE: File 22-102749-UP & 22-102752-SE
Process IV and SEPA - Combined Technical Review Comments 10-20-2022
Corliss Concrete Plant 2 Relocation, 35060 Pacific Highway S, Federal Way, WA
Dear Ms. Chapin:
Below are responses to City departments review comment letter dated October 20, 2022.
Community Development – Planning Division
Becky Chapin, (253) 835-2641, becky.chapin@cityoffederalway.com
1. General – Technical comments made about an item on one plan sheet, or in a document, may
necessitate changes to other related plan sheets and documents. It is the applicant’s
responsibility to determine any such necessary adjustments. Please ensure consistent
information is communicated throughout the plan set and associated application materials.
• Noted.
2. The site plan needs to show any proposed retaining walls and any proposed perimeter and/or
interior fencing.
• No retaining walls are proposed, perimeter fencing has been added to the site plan.
3. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 3(a).
3. If approved by the director of community development services, the height of a structure
may exceed 40 ft. above average building elevation (AABE), to a maximum of 55 ft. AABE, if
all of the following criteria are met:
a. The increased height is necessary to accommodate the structural, equipment, or operational
needs of the use conducted in the building, and/or all ground floor spaces have a minimum
floor-to-ceiling height of 13 ft. and a minimum depth of 15 ft.;
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• The additional height increase request is necessary to accommodate only one component of
the plant equipment to allow the plant to function. The cement silo shall be located centrally
on the site approximately 150 – 200 feet from all property lines, is not within 2,000 l.f. of a
residential zone and will not block views designated by the comprehensive plan. All other
plant components and the proposed building shall comply with the height criteria.
4. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 5.
5. No use or activity may be conducted that involves the release of toxins, noxious gases,
smoke, fumes, dust, odors, or other discharge on neighboring uses or natural systems.
• The existing plant has an active Sand and Gravel Permit issued by the Department of
Ecology and a current Order of Approval from Puget Sound Clean Air Agency. These
permits will be updated when the plant is relocated to its new location. All operation and
maintenance procedures and monitoring required by DOE and PSCAA will be followed to
ensure activities do not discharge on neighboring uses or natural systems.
5. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 6.
6. These uses shall cause no inherent and recurring generated noise or vibration perceptible
without instruments at any point along a property line, except transportation and delivery
operations typically and customarily associated with the use; and provided, that such operations
are not audible from a residential zone on a regular or recurring basis.
• The plant operations are to be located in the center area of the site and not along a property
line. The nearest residential zone is approximately 2,000 l.f. south of the site, it is not
anticipated that any regular noise will be heard from that distance.
6. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 7.
7. Any operation producing intense glare or heat shall be conducted within an enclosed building
or with other effective screening in such a manner as to make such glare or heat completely
imperceptible from any point along a property line.
• It is not expected that the plant operations will produce intense glare or heat.
7. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 8.
8. Hazardous waste treatment and storage facilities must comply with state citing criteria
adopted in accordance with Chapter 70.105 RCW.
• Hazardous waste treatment and storage facilities will comply with Chapter 70.105 RCW
recodified as RCW 70A.300.005. In addition, plant employees will be provided hazardous
waste training.
8. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 9.
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9. Outdoor storage areas shall be located to the rear and/or side(s) of the principally permitted
structure.
• The 40 feet storage silos and special materials storage area are located to the rear of the
plant and shop/storage building.
9. Please explain in detail how the proposed use and operation complies with FWRC
19.240.040 Note 10.
10. The subject property must be designed so that truck parking, loading, and maneuvering
areas; areas where noise generating outdoor uses, storage, and activities may occur; and vents
and similar features are located as far as possible from any residential zone, conforming
residential use, natural systems, and public rights-of-way.
• The nearest residential zone and residential use is approximately 2,000 l.f. south of the site,
it is not anticipated that any regular noise will be heard at that distance. Truck parking,
loading, and maneuvering areas, noise generating outdoor uses, storage and activities are
located centrally and to the rear of the site as far away from public rights-of way.
10. Please explain in detail how the proposed use and operation complies with FWRC
19.125.170 (3)(b & d).
(3) Specific use and development requirements. The city will administratively review and either
approve or deny any application for outdoor use, activity, or storage based on the following
standards:
(b) A minimum six-foot-high solid screening fence, wall, or other appropriate architectural
screening, surrounded by five feet of Type I landscaping as defined by FWRC 19.125.050(1),
or combination of architectural and landscape features, approved by the director of community
development services is required around the outside edges of the area devoted to the outdoor
use, activity or storage area, unless determined by the director that such screening is not
necessary because the use or stored materials are not visually obtrusive. Proposed architectural
and landscape screening methods shall be consistent with Chapter 19.115 FWRC, Community
Design Guidelines, and Article I of this chapter (Landscaping).
• A six-foot high solid screening concrete fence surrounded by Type II landscaping will be
installed around the perimeter of the site to provide visual screening.
(d) The height of uncontained items stored outdoors shall not exceed six feet above finished
grade, unless the director approves a different height limitation after considering the zoning of
the site and the surrounding properties and the extent to which the location or methods of
screening the items minimizes visibility from adjacent streets and properties, and the items are
not visually obtrusive and do not detract from the aesthetic quality of the overall development.
• There are no outdoor uncontained items above six feet proposed to be stored on-site.
11. The preliminary landscape plans meet the spatial requirements for the perimeter landscape
areas.
FWRC 19.125.060(9) requires Type II landscaping in all four perimeter landscape buffer
areas. Type III landscaping is proposed on the submitted preliminary landscape plan. The
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landscape plan will need to be updated to show Type II landscaping, which is more intensive
screening than Type III landscape, with trees spaced closer, and more and larger shrub layer
to provide visual screen.
Final landscape plan review will occur with review of the building permit application.
• The landscape plan has been revised to show the required Type II landscaping in all four
perimeter landscape buffer areas.
12. A tree and vegetation retention plan as required under FWRC 19.120.130 must be submitted
with the Process IV application. The tree and vegetation retention/replacement plan must be
prepared by a certified arborist or certified landscape architect. The FWRC standards require
each development in the CE zone to maintain a minimum tree unit density of 20 tree units
per acre.
A tree unit is a value assigned to existing trees retained on the property or replacement trees.
The larger the tree, the greater value it is assigned. Required tree density can be composed of
retained trees and replacement plantings per FWRC 19.120.130. (Note: required landscaping
trees may be counted in the tree density.) The tree and vegetation plan must clearly show
where the required tree units are to be located. The formal landscape plan must detail
information about tree unit credits and replacement.
• A revised Landscape Plan dated 03/28/2023 is included with this submittal. A tree unit
calculation is detailed on page L-1.
13. Parking lot landscape islands are required per FWRC 19.125.070 and are required at the end
of all parking rows, per FWRC 19.125.070(3)(a), and this is not shown on the plans. Provide
end of parking row landscaping and meet the landscape island dimensional requirements of
FWRC 19.125.070(2 &3).
• Parking row landscaping has been added to the site plan.
14. Please identify dimensions of typical proposed interior parking lot landscape islands. Six-foot
minimum width is required per FWRC 19.125.070(3) for interior lot landscape islands.
• Parking lot island dimensions have been added to the site plan.
15. Please provide a detail or identify where plans show typical dimensions of parking stalls and
drive aisles. See enclosed parking lot dimensional handout.
• Parking stall dimensions and drive aisle widths have been added to the site plan.
16. Please supplement the June 2, 2022 Heath Associates parking assessment with additional
supporting information including a discussion of the existing adjacent concrete plant parking
data and parking adequacy. Also, the site plan shows parking for five commercial trucks
along the east property perimeter. Please provide information regarding these truck parking
stalls and the intent for these parking stalls, such as if trucks are parked overnight or daily.
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Where will the operators of these trucks park their personal vehicles when driving to the site
and leaving in a commercial truck stored on site? Provide additional information regarding
potential circumstances when additional workers are needed at the site for activities such as
but not limited to: maintenance and repair of on-site machinery and facilities etc.
• Parking assessment supplement memo dated 03/30/2023 is included with this submittal.
17. In order to further evaluate aesthetic impacts under SEPA and Process IV review, please
provide visual renderings of the site as proposed from each of the north, south and west
directions. The renderings should show all proposed improvements to scale on one single
plan sheet for each rendering. Identify any potential visual impacts and proposed mitigation
measures.
• Visual renderings are included with this submittal.
18. City staff does not see compelling arguments and evidence that the decisional criteria in
FWRC 19.45.030 has been met for the requested height variance. The Hearing Examiner will
be the final decision maker on the height variance application following staff analysis and
recommendation and Hearing Examiner public hearing.
• Noted.
19. Please see the attached October 18, 2022 Technical Memo from Landau Associates in regard
to review of the Lombardi Geologic, Hydrogeologic Assessment. Please update the
Hydrogeologic Assessment and provide all the information requested and discussed in the
October 18, 2022 Landau memo.
• Hydrogeologic Assessment update 03/17/ 2023 is included with this submittal together
with Addendum A providing responses to the Landau 10/18/2022 memo.
20. For your information, the City did not receive any written comments on the Notice of
Application.
• Noted.
21. City staff will provide comment on the pending binding site plan (22-102751-SU) and
boundary line adjustment application file (22-102750-SU) within the next few weeks. Review
of the SU applications does not appear to be a critical path and typically would occur
following land use review and decision.
• No comments on the binding site plan (22-102751-SU) and boundary line adjustment
application file (22-102750-SU) have been received to date.
Public Works – Development Services Division
Brent Cummings, (253) 835-2734, brent.cummings@cityoffederalway.com
SEPA-
Page 6 of 8
1: As stated by Landau Associates the proposed vault is an open bottom vault that will discharge
into the critical aquifer recharging area. Please defer to the City’s third party comments and
explain.
• Hydrogeologic Assessment update 03/17/2023 from Lombardini Geological Services is included with
this submittal.
2: The City will require based on recommendations from Lakehaven monitoring well be placed
between the storm vault and the City’s ROW along Pacific Highway. To identify if discharge of
pollutants are present, example; hazardous chemicals, contaminant in ground water etc. The
required testing will be based upon recommendations of the Geotech, and verified by the City’s
on call Geotech.
• Noted.
3: Based upon research regarding the Fortrans 5000B treatment unit. This unit appears to be
designed to inject into a large vault over a large area for residence time. Please explain how
installing this unit into the Type 2 60 inch flow splitter is a better option then a closed vault
system like the presettling vault.
• The layout was revised to indicate that the pH control system will pump/inject within the
presettling vault, rather than the catch basin.
4: Please clarify how the proposal protects the critical area wells 15 and 15A, given the proposed
infiltration storm vault.
• Hydrogeologic Assessment update 03/17/2023 from Lombardini Geological Services is
included with this submittal.
5: Clarify why the storm settling vault and storm vault does not provide an emergency overflow
in accordance with the 2021 KCSWDM 5.2.4/5.1.4/5.1.3A regarding overflow riser.
• An overflow tee has been added within both the presettling vault and infiltration vault.
6: It appears the treatment train storm system (oil/water separator, PH adjustment , presettling
vault and the water quality treatment) will need to be modified during plan review. This
comment goes with #3.
• The layout was revised to indicate that the pH control system will pump to the presettling
vault. Additional modifications can be made during plan review as necessary.
7: Reverse pressure RPBDs will be required on all service connections in accordance with
WDOH (Washington Department of Health).
• Noted.
Page 7 of 8
8: The flow splitter proposed on page 5 of 14 under clearing and grading needs to comply with
2021 KCSWDM 5.1.4.A
• The flow splitter detail has been updated to better comply with the typical detail from the
KCSWDM, 6.2.5.B.
Land Use-
1: It is unclear on the residence time for the PH Treatment Unit. It’s also unclear where the
monitoring /sampling intake is located in any drawings.
• Per discussions with the pH control system manufacturer, the presettling vault should
provide adequate residence time for the pH control. The pH control system indicated on
sheet 4 will have a monitoring system for the pH.
2: Explain what kind of system redundancy is proposed for drinking water safety.
• Runoff will be treated though a treatment train of multiple facilities. These include a
coalescing plate oil/water separator, presettling vault, pH control system, and BioPod
Biofilter for enhanced treatment prior to discharge to the infiltration vault.
Public Works – Development Services Division
Soma Chattopadhyay - (253) 835-2731,
soma.chattopadhyay@cityoffederalway.com
The Public Works Traffic Division have the following comments:
1. The project will generate 13 new PM peak hour trips according to the ITE trip generation
manual 11th edition for (land use number 140) manufacturing. As no trip generation study
is submitted City staff will perform concurrency analysis according to the ITE trip
generation manual 11th edition. According to 2022 impact fee rates, the estimated traffic
impact fee for a 17,006 sq. ft. manufacturing plant is $ 96,645.35
• Noted.
2. Per FWRC 19.135.280, there may be only one driveway for every 330 feet of lot frontage.
This property does not have the 660 feet minimum street frontage to allow second access.
The project has one access through S 351st private street. Please apply for a modification
request for second access on Pacific Highway.
• Per your email dated 01/26/2021 (attached) the second access meets the WSDOT spacing
standard of 250 feet, therefore a modification is not applicable.
3. According to the City development standard for driveway cuts that serve uses other than
single-family residential uses, the maximum driveway width is 30 ft. for the two-lane two-
way driveway. Please submit an auto-turning diagram and apply for a modification
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request for the proposed 60 ft driveway width.
• A modification request has been submitted 22-102754-AD-Deviation Commercial Driveway
Width-06-15-2022-V1. Auto-turn diagram was incorporated into our initial site plan.
4. In case the driveway is approved, the project is required to relocate the streetlight on Pacific
Highway S shown on the driveway access. The streetlight calculation and plans are required
to submit. Also, install streetlights according to City standards on S 351st St.
• Noted.
5. Driveways accessing roadways with a speed limit greater than 35 mph, or commercial
driveways with higher percentages of trucks or large vehicles are required to provide a 50-
foot throat length.
• Noted.
Sincerely
Colleen M. Harris
Senior Project Manager
From: Soma Chattopadhyay <Soma.Chattopadhyay@cityoffederalway.com>
Sent: Tuesday, January 26, 2021 11:37 AM
To: Colleen Harris
Subject: RE: Valley Ave LLC Concrete Batch Plant
Hi Colleen,
How are you doing? I enjoyed working with you in Puyallup. I am working for Federal Way since I left
Puyallup. I worked with FW earlier and they called me back for the ITS projects. I enjoy my work. This is
also closer to home.
WSDOT spacing standard is 250 ft. Looks like your interpretation is meeting the WSDOT standard with
50 ft. wide driveway.
Please feel free to contact me if you have any question.
Thank you.
Soma
Soma Chattopadhyay, PE
Traffic Operation Engineer
City of Federal Way
253-8352731
From: Colleen Harris [mailto:Harris@apexengineering.net]
Sent: Thursday, January 21, 2021 8:58 AM
To: Soma Chattopadhyay
Subject: RE: Valley Ave LLC Concrete Batch Plant
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Hello Soma –
It was so nice to hear from you – how are things? Federal Way still treating you well I hope!
As a follow-up to the pre-app, I worked up a site plan following your road standards which seems to
indicate that there is sufficient spacing along the Pac Hwy frontage to accommodate a single 50’ wide
driveway – could you take a look at the attached and let me know if you agree with my interpretation of
your standards?
Thanks so much,
Colleen
Colleen M. Harris
Project Manager
2601 S. 35th St. Ste. 200 | Tacoma, WA 98409 | O 253.473.4494 x1116 | F 253.473.0599
harris@apexengineering.net
www.apexengineering.net
From: Tina Piety <Tina.Piety@cityoffederalway.com>
Sent: Tuesday, January 19, 2021 4:36 PM
To: Colleen Harris <Harris@apexengineering.net>
Cc: Steve Corliss <Stevec@corlissresources.com>; Sean Nichols <sean.nichols@southkingfire.org>; Brian
Asbury <basbury@lakehaven.org>; Greg Kirk <Greg.Kirk@cityoffederalway.com>; Kevin Peterson
<Kevin.Peterson@cityoffederalway.com>; Soma Chattopadhyay
<Soma.Chattopadhyay@cityoffederalway.com>; Jim Harris <Jim.Harris@cityoffederalway.com>
Subject: Valley Ave LLC Concrete Batch Plant
Hello,
Attached you will find a preapplication summary letter (and enclosures) regarding a new concrete batch
plant. Please contact Senior Planner Jim Harris, at 253-350-9283, or jim.harris@cityoffederalway.com, if
you have any comments and/or questions regarding this letter.
Regards,
E. Tina Piety, CAP, OM
Administrative Assistant II
Community Development Department
33325 8th Avenue South
Federal Way, WA 98003-6325
Phone: 253/835-2601 Fax: 253/835-2609
www.cityoffederalway.com