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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.; Page 2 of 8 • 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. Page 3 of 8 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 Page 4 of 8 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. Page 5 of 8 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 Page 8 of 8 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 [EXTERNAL EMAIL WARNING] This email originated from outside of the City of Federal Way and may not be trustworthy. Please use caution when clicking links, opening attachments, or replying to requests for information. If you have any doubts about the validity of this email please contact IT Help Desk at x2555. 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