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HomeMy WebLinkAboutSR_Sounders_ERC_Addendum_DNS-M_FINALDEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT ADDENDUM TO ENVIRONMENTAL (SEPA) DETERMINATION OF NON-SIGNIFICANCE (DNS-M) - MITIGATED Pursuant to WAC 197-11-600(4)(c) and WAC 197-11-625 Addendum to the Seattle Sounders FC at Longacres Determination of Non-Significance - Mitigated (DNS-M) Date of Addendum: June 26, 2023 Date of Initial Threshold Determination: December 5, 2022 Applicant: Seattle Soccer, LLC, d/b/a Seattle Sounders FC, 406 Occidental Avenue S, Seattle, WA 98104 File Numbers: LUA22-000357, ECF, CU-H, SA-H, MOD Project Name: Sounders FC Center at Longacres Location: 1901 Oakesdale Ave SW, Renton. WA 98057 (Parcel Nos. 0886700220, 0886700110, 0886700120, 0886700130, 0886700210, 0886700370, and 0886700140) Lead Agency: City of Renton, Department of Community and Economic Development Review Process: Addendum to previously issued Determination of Non-Significance – Mitigated (DNS-M) Proposal / Purpose of Addendum: The applicant contends that the project’s DNS-M mitigation measures 3 and 4 are no longer necessary as the proposed synthetic field turf will be cork and not Styrene Butadiene Rubber (SBR) crumb rubber. Mitigation measures 3 and 4 DNS-M document originally read as follows: 3. The artificial turf field program, including field design, construction and operation, together with stormwater management and water quality treatment for drainage from the artificial turf fields, shall assure that the field materials do not result in a probable adverse environmental impact on fish and wildlife. The proposed water quality treatment facility shall be a Filterra Bioscape facility sized to treat the 2-year storm event or equivalent as DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Addendum to Environmental (SEPA) Review Page 2 of 3 June 26, 2023 approved by the City and the applicant shall undertake quarterly water quality tests of field drainage, during the life of the field or for a five (5) year period, whichever comes first. The applicant will submit a monitoring protocol to test for SBR Crumb Rubber constituents of concern in field drainage for City approval. 4. When the fill within the synthetic turf athletic fields is replaced, the applicant shall be required to go through a new Environmental Review. The above mitigation measures were adopted by the Environmental Review Committee (ERC) in response to the applicant’s proposal to utilize SBR crumb rubber as the fill material within the synthetic turf fields. Analysis: Staff concurs that if cork or another acceptable fill material is utilized in lieu of SBR crumb rubber that Mitigation Measures 3 and 4 would not be applicable to the proposed project. It has been determined that the environmental impacts of the proposal were adequately addressed under the analysis contained within the project’s issued DNS-M. Based on WAC 197- 11-600(4)c, the addendum process may be used if analysis or information is added that does not substantially change the analysis of significant impacts and alternatives in the existing environmental document. This Addendum is appropriate because it contains only minor information not included in the DNS-M and there are no environmental impacts related to inclusion of the new information. The proposed modification would not change the analysis or impacts in the initial SEPA Review, therefore an Addendum to the DNS-M may be issued pursuant to WAC 197-11-625. DECISION: The City of Renton is hereby issuing a SEPA Addendum pursuant to WAC 197 -11-600 to addend the Seattle Sounders FC Center at project to clarify that Mitigation Measures 3 and 4 would only be applicable if the proposed project utilizes SBR crumb rubber as t he fill material within the proposed synthetic fields. Mitigation Measures 3 and 4 would now read as follows: 3. The artificial turf field program, including field design, construction and operation, together with stormwater management and water quality treatment for drainage from the artificial turf fields, shall assure that the field materials do not result in a probable adverse environmental impact on fish and wildlife. If SBR crumb rubber is used as a fill material within the synthetic turf fields, then the proposed water quality treatment facility shall be a Filterra Bioscape facility sized to treat the 2-year storm event or equivalent as approved by the City and the applicant shall undertake quarterly water quality tests of field drainage, during the l ife of the field or for a five (5) year period, whichever comes first. The applicant will submit a monitoring protocol to test for SBR Crumb Rubber constituents of concern in field drainage for City approval. 4. If SBR Crumb Rubber is used as a fill material within the synthetic turf fields, when the fill within the synthetic turf athletic fields is replaced, the applicant shall be required to go through a new Environmental Review. DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Addendum to Environmental (SEPA) Review Page 3 of 3 June 26, 2023 Additional Information: If you would like additional information, please contact Jill Ding, Senior Planner, City of Renton Planning Division, Department of Community & Economic Development at (425) 430-6598. There is no comment period for this Addendum, dated June 26, 2023 issued by the City of Renton Environmental Review Committee. Exhibits Exhibit 1 DNS-M Addendum Exhibit 2 Original DNS-M Determination Reconsideration Memo Exhibit 3 Applicant's Narrative Exhibit 4 Coughlin Porter Lundeen Stormwater Memo Exhibit 5 Technical Memorandum from Herrera ENVIRONMENTAL REVIEW COMMITTEE SIGNATURES: Martin Pastucha, Administrator Public Works Department Date Anjela Barton, Fire Marshal Renton Regional Fire Authority Date Kelly Beymer, Administrator Parks and Recreation Department Date C.E. “Chip” Vincent, Administrator Department of Community & Economic Development Date DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 6/26/2023 | 1:18 PM PDT 6/26/2023 | 2:14 PM PDT 6/26/2023 | 1:20 PM PDT DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT M E M O R A N D U M DATE: December 5, 2022 TO: Environmental Review Committee (ERC) FROM: Jill Ding, Senior Planner SUBJECT: Sounders FC Center at Longacres (LUA22-000357) SEPA Request for Reconsideration The Environmental Review Committee (ERC) reviewed the above -mentioned site plan and conditional use permit application and issued a SEPA Determination of Non-Significance – Mitigated (DNS-M) on November 7, 2022 with six (6) mitigation measures: 1. Construction on the project site shall comply with the recommendations of the submitted Geotechnical Report, prepared by GeoEngineers, dated June 23, 2022. 2. The applicant’s geotechnical engineer shall review the project’s construction plans for the new fields and the building permit plans for the proposed maintenance building and elevated patio addition to verify compliance with the submitted geotechnical report. The geotechnical engineer shall submit a sealed letter stating that he/she has reviewed the construction and building permit plans and in their opinion the plans and specifications meet the intent of the report. 3. The fill material used on the synthetic fields shall be comprised of a material that would be non-toxic to fish and other wildlife. 4. The applicant shall demonstrate that the proposed underground storage chambers, to be utilized for compensatory storage, would not have an adverse impact on salmonids and would ensure that salmonids would not get trapped within the proposed underground storage chambers. 5. The applicant shall follow the Department of Ecology guidance for Tacoma Smelter Pl ume soil contamination testing and remediation as instructed in the agency’s letter (Exhibit 15). 6. The applicant shall submit an Inadvertent Discoveries Plan prepared by a qualified professional with the civil construction permit for review and approval by the Current Planning Project Manager prior to permit issuance. The DNS-M and related documents were sent to parties of record and posted online with an appeal period that ended on November 21, 2022. A request for reconsideration of the SEPA determination was received from the applicant (Unico Properties and Seattle Soccer, LLC). The request for reconsideration requests alternate wording for mitigation measure #3. Below is a summary of the concerns cited: DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Sounders FC Center at Longacres (LUA22-000357) Page 2 of 4 December 5, 2022 A. The applicant believes that the intent of the City’s mitigation measure #3 is that the artificial turf fields will not result in a probable significant adverse environmental impact to fish and wildlife. Sounders contend that they have designed their artificial turf fields to achieve that result. However, the wording of Condition 3 is problematic, because it asks the applicant to prove a negative, i.e. that the turf material itself is “non-toxic to fish and other wildlife.” The applicant cannot meet this standard, especially because of the limited peer-reviewed scientific studies analyzing field-related materials in constructed, operating synthetic turf athletic fields. This lack of information could cause confusion and uncertainty during subsequent permitting. Analysis of the impact of any particular material on the environment must also include the manner, intensity, and duration of exposure created. Notwithstanding the lack of definitive information regarding the materials themselves, there are many mitigation factors that can limit risk to the natural environment. Means of control to limit transfer of turf and turf components to the environment include field design, the stormwater management and water quality system for the fields, and operational practices that control and minimize material transport. Field Turf is the industry standard material for competitive and practice fields in Major League Soccer (MLS). Field Turf comes in several varieties, most of which include SBR Crumb Rubber as infill material. The playing surface in Lumen Field, the Sounders competition field, is made of Field Turf composed with SBR Crumb Rubber. Professional soccer best practices which manage professional athlete load and physiological impacts across a grueling 10-month calendar, require consistent field conditions for both match- competition pitches and training pitches. Because SBR Crumb Rubber is the industry standard for MLS, it would be a substantial impact to Sounders FC to have the City prohibit use of that material. The impact is felt in several ways. First, there is inadequate information available to know how the substitute materials perform for MLS play, and how the materials hold up as compared to the known standard: SBR Crumb Rubber. The ability to source less standard substitute materials and potential timing impacts also create uncertainty for the accelerated timeline to have the fields ready for World Cup use in 2026. To mitigate for potential impacts from crumb rubber on salmonids from 6PPD-q and other known toxins, the applicant is proposing to use a Filterra Bioscape, proprietary open filtration basin design for water quality treatment of the water flowing from this field complex. This system is sized to meet the Enhanced Basic level as required for this project by the City, and is sized to provide treatment for the 6-month event runoff as specified in the RSWDM. Flows exceeding the design treatment rate, will be directed around the Bioscape system via a flow splitter located above the facility. These higher flows will be directed into the existing water quality pond on site, Pond B. Per the Washington State Department of Ecology report titled 6PPD in Road Runoff (Publication 22-03-020) “Stormwater treatment infrastructures that use infiltration, sorption, filtration, and/or effectively capture tire wear particles are expected to reduce the toxicity from 6PPD-q.”, and “Filters that focus on reducing suspended particles (e.g., total suspended solids) will be effective at capturing tire particles and any other particulate matter with sorbe d contaminants including 6PPD-q.” The applicant notes that the code requirement for treating stormwater runoff DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Sounders FC Center at Longacres (LUA22-000357) Page 3 of 4 December 5, 2022 for all systems within this area is the 6-month storm event, to further mitigate the impacts of the use of SBR crumb rubber within the synthetic fields, the applicant is proposing to design their water quality treatment facility to treat the 2-year rainfall event runoff. This treatment rate means this facility would treat more of the rainfall events that this facility would experience. The applicant contends that this treatment level is a reasonable approach to address the concerns raised concerning the 6PPD-q and other pollutants. The concerns regarding the 6PPD-q pollutant have been based, to date, on studies of roadway runoff, which we believe to have important differences from the use of rubber in synthetic turf fields. Unlike in a roadway environment where tire dust and fine particles are blown or washed off of the road surface quickly into storm systems or directly into receiving waters containing fish, the granular crumb rubber in the synthetic turf fields at the proposed Sounders FC facility remains at the surface, prevented from entering the stormwater system. The crumb rubber used in fields is sieved and processed to reduce finer particles to the maximum extent possible, including the finest dust. Therefore the mechanisms believed to cause degradation of the rubber into 6PPD-q and the mobilization of those particles themselves are far less in the field context than in roadway runoff which is the current basis of research on the issue. The largest constituent of pollutant transport is broadly recognized to be the finer particles, down to dust-sized. Smaller particles both degrade quicker (producing pollutants such as 6PPD-q) and can be transported downstream more easily, for direct contact into waterways and aquatic organisms. Additionally, the potential for fugitive infill materials to directly leave the field s urface is further mitigated by 1) a continuous perimeter containment curb and windscreen/fence, and 2) controlled access and use, which limits potential unintended migration or transport. In conclusion, the applicant is requesting that the wording of mitig ation measure #3 be amended to read as follows: “The artificial turf field program, including field design, construction and operation, together with stormwater management and water quality treatment for drainage from the artificial turf fields, shall assu re that the field materials do not result in a probable significant adverse environmental impact on fish and wildlife. Sounders would undertake quarterly water quality tests of field drainage, during the 2 - year maintenance period for the stormwater system. The Sounders field and stormwater consultants will work with City of Renton to determine a reasonable and appropriate monitoring protocol to test for SBR Crumb Rubber constituents of concern in field drainage.” Staff Comment: Staff has reviewed the submitted request for reconsideration. The original intent behind mitigation measure #3 was to ensure that the proposed synthetic athletic fields would not result in an adverse environmental impact to fish and wildlife. Staff has concerns that the word “significant” in the proposed language would be difficult to quantify, therefore staff recommends removing the term “significant” from the applicant’s proposed language. The applicant’s proposal has been reviewed by the City’s Peer Review Consultant Otak, who concurs that the proposal to increase the size of the water quality treatment facility to treat the 2-year storm event, rather than the 6-month storm even would reduce the direct discharge into Pond B and would be more than is required by the current City DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Sounders FC Center at Longacres (LUA22-000357) Page 4 of 4 December 5, 2022 Renton Surface Water Design Manual (RSWDM). Otak also concurs that the applicant’s proposal to monitor the stormwater outflow would also minimize the risk of the SBR crumb rubber on aquatic wildlife. However, in lieu of the two (2) year monitoring timeframe proposed by the applicant, staff recommends that the field runoff shall be monitored for the life of the field or five (5) years, whichever comes first. Recommendation: Based on the additional information provided in the reconsideration request by the Applicant, staff recommends that the ERC retain SEPA mitigation measures 1 and 2 and amend mitigation measure 3 as stated below, add a new mitigation measure 4 and renumber and retain mitigation measures 4, 5, and 6 as 5, 6, and 7: 3. The artificial turf field program, including field design, construction and operation, together with stormwater management and water quality treatment for drainage from the artificial turf fields, shall assure that the field materials do not result in a probable adverse environmental impact on fish and wildlife. The proposed water quality treatment facility shall be a Filterra Bioscape facility sized to treat the 2-year storm event or equivalent as approved by the City and the applicant shall undertake quarterly water quality tests of field drainage, during the life of the field or for a five (5) year period, whichever comes first. The applicant will submit a monitoring protocol to test for SBR Crumb Rubber constituents of concern in field drainage for City approval. 4. When the fill within the synthetic turf athletic fields is replaced, the applicant shall be required to go through a new Environmental Review. Environmental Determination Appeal Process: Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on December 19, 2022. Appeals must be submitted electronically to the City Clerk at cityclerk@rentonwa.gov or delivered to City Hall 1st floor Lobby Hub Monday through Friday. The appeal fee, normally due at the time an appeal is submitted, will be collected at a future date if your appeal is submitted electronically. The appeal submitted in person may be paid on the first floor in our Finance Department. Appeals to the Hearing Examiner are governed by RMC 4-8-110 and additional information regarding the appeal process may be obtained from the City Clerk’s Office, cityclerk@rentonwa.gov. Enclosures: Request for Reconsideration SIGNATURES: Martin Pastucha, Administrator Public Works, Chair Date Anjela Barton, Fire Marshal Renton Regional Fire Authority Date for Kelly Beymer, Administrator Parks and Recreation Department Date Chip Vincent, Administrator Date Community and Economic Development DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6 12/5/2022 | 2:22 PM PST 12/5/2022 | 2:24 PM PST 12/5/2022 | 3:40 PM PST DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 From: Jeff Gray <Jeff.Gray@otak.com> Sent: Monday, December 5, 2022 7:58 AM To: Jill Ding Subject: RE: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico Follow Up Flag: Follow up Flag Status: Flagged Looks good to me. They’re sizing the facility to accommodate the 2-year storm rather than the 6-month storm event, which reduces direct discharge to Pond B, and is more than required per the stormwater regs. I think the condition to require monitoring after Ecology develops standard monitoring protocols and before the fields are replaced again is further insurance to minimizing risk to aquatic wildlife. Jeff Jeff Gray | Managing Senior Scientist Otak, Inc. Direct: 971.337.3047 | Cell: 609.532.4620 | Main: 425.822.4446 From: Jill Ding <JDing@Rentonwa.gov> Sent: Friday, December 2, 2022 3:29 PM To: Jeff Gray <Jeff.Gray@otak.com> Subject: FW: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico Please see attached the revised memo from the Sounders team. Let me know if you have any questions or concerns regarding this approach. Thanks, JILL DING, Senior Planner City of Renton | CED | Planning Division 1055 S Grady Way | 6th Floor | Renton, WA 98057 Virtual Permit Center | Online Applications and Inspections (425) 430-6598 | jding@rentonwa.gov From: Jeremy Eckert <jeremy@tharsis.land> Sent: Friday, December 2, 2022 3:23 PM To: Jill Ding <JDing@Rentonwa.gov>; Vanessa Dolbee <VDolbee@Rentonwa.gov> Subject: Re: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico Jill and Vanessa: CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless you know the content is safe. CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless you know the content is safe. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 We've attached a letter from CPL that answers your questions below. We've traded a handful of emails / letters on this topic. To help the ERC, the attached letter is an attempt to put all of the relevant information into one document. We're standing by if you have any follow up questions after you read the letter. Thank you, Jeremy On Fri, Dec 2, 2022 at 10:34 AM Jill Ding <JDing@rentonwa.gov> wrote: Jeremy, Thank you for sending over this memo, this provides a lot of helpful background information on the proposed water quality treatment facility with respect to 6PPD. During our meeting, additional information was provided that we think would be helpful to also include within the memo: 1. It sounds like the proposed water quality treatment facility is mentioned as a recommended facility within the 6PPD study prepared by Ecology, in the meeting Tim specified that while the proposed Filterra system has not yet been tested as a treatment for 6PPD, that he believes that it would perform as well or better than the 60-40 mix, which has been tested. If something to this effect could be added to the memo, that would be helpful to communicate to our Environmental Review Committee (ERC); 2. Eric provided a description of the cleaning process that the crumb rubber goes through before being placed in the field. A summary of this process would also be helpful for us to communicate to the ERC; and 3. A description of the vertical filtration that rainwater goes through when it hits the fields would also be helpful. If this information could be provided by the end of the day, this would give me sufficient time to prepare a presentation to the ERC on Monday. Thanks, JILL DING, Senior Planner City of Renton | CED | Planning Division 1055 S Grady Way | 6th Floor | Renton, WA 98057 Virtual Permit Center | Online Applications and Inspections DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 (425) 430-6598 | jding@rentonwa.gov From: Jeremy Eckert <jeremy@tharsis.land> Sent: Thursday, December 1, 2022 5:03 PM To: Jill Ding <JDing@Rentonwa.gov> Cc: Tom Chiado <tom@chiadollc.com>; Julia Reeve <juliar@unicoprop.com>; William Andres <williama@cplinc.com>; Tim Brockway <timb@cplinc.com>; Eric Gold <EricG@dahogan.com>; Vanessa Dolbee <VDolbee@Rentonwa.gov> Subject: Re: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico Hi Jill: I've attached CPL's response to your questions from Monday. You also sent follow-up questions. Responses to those questions are below: 1. At what frequency is stormwater expected to overflow/bypass the Filterra treatments and discharge directly into Pond B? What is the design capacity (storm event) of treatments? A: Flows above the 6-month rainfall event, as defined by King County and Ecology as the water quality storm event, will bypass the facility. The same 6-month flow rate will continue to be treated during larger storms, but as a percentage of the larger storm volume. 2. How much area (%) of the 3 synthetic fields will be treated by the Filterra system during those storm conditions? A: 100% of the synthetic field surface will be treated by the Filterra system for all rain events. To help facilitate a productive discussion, we propose working off of the following agenda at tomorrow's 9am meeting. The team is open to amending the agenda if that would be beneficial. CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless you know the content is safe. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Introductions Otak provides summary of its comments Project Overview Project Goals Sounders / Unico review of science in response to Otak/City questions and comments Operations / Proposed Mitigation / Treatment Design: o Overview of materials out for bid and cost associated with same o Field Maintenance Schedule and cost o Stormwater design / water quality treatment o Existing infrastructure at Longacres Discussion Thanks, Jeremy On Thu, Dec 1, 2022 at 8:58 AM Jeremy Eckert <jeremy@tharsis.land> wrote: Hi Jill: Here's the list of attendees for Friday's 9am meeting, with everyone cc'd to provide you with emails for your meeting invite. Tom Chiado, Sounders Project Manager Julia Reeve, Unico Project Manager DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 William Andres, CPL Tim Brockway, CPL Eric Gold, DA Hogan The attendees are consultants and the respective Unico/Sounders project managers. No lawyers. This team can speak to field materials, stormwater, and existing infrastructure at Longacres. CPL is preparing a short response to your email. We'll send that to you as soon as it is ready. Thanks again for the invitation to discuss this outstanding item. We're looking forward to the collaborative conversation. Jeremy On Tue, Nov 29, 2022 at 7:48 PM Jeremy Eckert <jeremy@tharsis.land> wrote: Thank you, Jill. Let me coordinate with the team and get back to you. 9am Friday should work. Also, CPL is preparing a response to your email from earlier today. We'll send that along as soon as it is available. More soon. Jeremy On Tue, Nov 29, 2022 at 3:14 PM Jill Ding <JDing@rentonwa.gov> wrote: Jeremy, DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Vanessa, myself, and Jeff Gray from Otak are available to meet Friday morning at 9am, does this work for your team? Do you want me to send out a Teams Meeting invite? If so, please let me know who I should invite. Thanks, JILL DING, Senior Planner City of Renton | CED | Planning Division 1055 S Grady Way | 6th Floor | Renton, WA 98057 Virtual Permit Center | Online Applications and Inspections (425) 430-6598 | jding@rentonwa.gov -- Tharsis Law P.S. tharsis.land -- Tharsis Law P.S. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 tharsis.land DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Second Request for Reconsideration of SEPA MDNS Condition #3 Second Request for Reconsideration of MDNS SEPA Condition Project File No.: PR22-000301 Project Name: Sounders FC Center at Longacres Land Use File No.: LUA22-000357; SA-H; CU-H; ECF; MOD Date: November 23, 2022 I. Second Request for Reconsideration of SEPA MDNA Condition #3: On behalf of Co-applicant Seattle Sounders FC, we write to ask the ERC to further reconsider the language of SEPA Condition 3. We had first asked the City not to set a standard that required the Sounders to prove a negative, regarding synthetic turf materials being non-toxic to fish and wildlife. We proposed alternative language that we believed met the purpose to assure the synthetic fields would not pose probable adverse environmental impacts to fish and wildlife.1 We appreciate the ERC willingness to consider the applicants’ concern with Condition 3. We understand that the ERC had questions on Friday, and is now considering imposing a prohibition on using crumb rubber manufactured from recycled tires (hereafter “SBR Crumb Rubber”) as infill material for synthetic turf field assemblies. For reasons explained below, this would be an intrusive condition on the proposal, which we believe to be unwarranted and not legally supportable under SEPA, and it would generate significant unanticipated costs to the proposal. We appreciate the opportunity to further explain why the proposed prohibition is unwarranted, and the impacts it would have on Sounders FC Center at Longacres. II. Impacts of Departing from Industry Standard Field Turf is the industry standard material for competitive and practice fields in Major League Soccer (MLS). Field Turf comes in several varieties, most of which include SBR Crumb Rubber as infill material. The playing surface in Lumen Field, the Sounders competition field, is made of Field Turf composed with SBR Crumb Rubber. Professional soccer best practices which manage professional athlete load and physiological impacts across a grueling 10-month calendar, require consistent field conditions for both match-competition pitches and training pitches. Because SBR Crumb Rubber is the industry standard for MLS, it would be a substantial impact to Sounders FC to have the City prohibit use of that material. The impact is felt in several ways. First, there is inadequate information available to know how the substitute materials perform for MLS play, and how the materials hold up as compared to the known standard: SBR Crumb Rubber. The ability to source less standard substitute materials and potential timing impacts also create uncertainty for the accelerated timeline to have the fields ready for World Cup use in 2026. Finally, replacing SBR Crumb Rubber with the known available substitute for two to three fields at Sounders FC Center is estimated to cost somewhere from $750,000 to more than $1 million. This would be a significant economic factor in addition to existing known costs of a new headquarters and training facility in the City of Renton. 1 The applicants’ language actually tracked SEPA phrasing to prevent “probable significant adverse environmental impacts.” We understand the City prefers to strike the word “significant” from that phrase, and the applicant does not object to that change. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 III. Stormwater Regulations Require Treatment for Constituents of Concern Renton has adopted the King County Surface Water Design Manual (2021) (KCSWDM or “Design Manual” as its stormwater regulations. These regulations are applicable to the Sounders FC Center at Longacres.2 The Design Manual classifies athletic fields as “pollution generating pervious surfaces,” and requires higher levels of water quality treatment for these uses in commercial zones.3 The applicant’s field designer and stormwater engineer have collaborated on a field design and drainage system that meets the Enhanced Basic Water Quality Treatment requirements of KCSWDM. The Enhanced Basic treatment system treats for metals in stormwater, which includes treatment to remove copper and zinc, the two main constituents of potential concern with regard to stormwater drainage from athletic fields using SBR Crumb Rubber if they were designed without this protection. The treatment type selected by the design team has been approved by the State Department of Ecology. If the City desires additional information about how the selected treatment works to remove these constituents of potential concern, we can arrange to have our consultants address those questions. Accordingly, the proposal with its elevated water quality treatment is already mitigating for the use of SBR Crumb Rubber infill. Further mitigation is not required, and a prohibition against using the material is not warranted. In addition, while Sounders acknowledge the ongoing conversation nationwide regarding the use of SBR Crumb Rubber in synthetic turf for playing fields, we can provide the City with a reputable, local study that looked carefully at the issue and concluded that synthetic field drainage does not pose an environmental impact to surface waters.4 The attached Woodland Park Study was two pronged, including both a survey of existing literature on the topic, including studies performed in Washington State, and a rigorous sampling program from synthetic turf fields at Seattle’s Woodland Park playfields. Those fields included a surface made from SBR Crumb Rubber infill (Playfield #7). The Report concluded that “Water quality results for the three base flow samples and eight storm samples collected from Playfield #7 drain show that pollutant concentrations were very low in synthetic turf field drainage and do not pose an environmental impact to Green Lake. None of the pollutant concentrations in synthetic turf field drainage exceeded Washington State surface water quality standards.”5 Although we find the Woodland Park Study well-conducted and persuasive, we are aware that other literature speculates differently. We are also aware that infill materials for synthetic athletic fields are under continual review and study by regulatory entities, primarily and importantly due to their prevalence in youth and amateur athletics. But the controlling factors here based on the proposed design outweigh the speculation: (1) the required Enhanced Basic water quality treatment addresses the zinc and copper constituents most associated with toxicity to fish; (2) the stormwater system effectively captures the stormwater drainage for treatment; (3) the fields are fenced and maintained as a professional MLS facility; and (4) access controls avoid inadvertent transfer of the infill material. We ask that the City not impose a condition prohibiting the industry standard 2 Renton has adopted a few amendments to the Design Manual, not relevant here. 3 See applicable excerpts from the KCSWDM at Exhibit A. 4 See attached Exhibit B, Water Quality Report, Woodland Park Synthetic Turf Field Stormwater Drainage Study, p. 51 (June 2010), prepared for Seattle Parks and Recreation by Herrera Consultants. 5 Id. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 material when there is not definitive science or standards that mandate such a condition. Nonetheless, we also want the City to know that Seattle Sounders FC cares deeply about its environmental footprint, and desires to be an environmentally responsible new member of the Renton community. For that reason, we would propose the following mitigation in lieu of the SBR Crumb Rubber prohibition. IV. Prohibition Exceeds Adopted SEPA Standards Under SEPA, mitigation measures must be based on policies, plans, rules, or regulations formally designated by the agency as a basis for the exercise of substantive authority and in effect when the DNS is issued.6 We can find no adopted policy or regulation of the City of Renton that would authorize the prohibition of the use of SBR Crumb Rubber on soccer fields in this case, where water quality measures will be in place. Moreover, before requiring mitigation measures, the agency must consider whether local, state or federal requirements and enforcement would mitigate an identified impact.7 As we have pointed out, the project is required by the city’s stormwater regulations to implement enhanced water quality measures that are specifically designed and adopted to prevent pollution from synthetic turf athletic fields. For these reasons, and because there is no specific, adverse environmental impact associated with the use of SBR Crumb Rubber identified in any environmental documents for the proposal, we ask that the City not condition the project to prohibit the use of SBR Crumb Rubber infill. V. Substitute Mitigation Proposal The Sounders FC Center at Longacres will implement Enhanced Basic water quality treatment for all playing field drainage. Although the KCSWDM does not require monitoring, Sounders would undertake quarterly water quality tests of field drainage, during the 2-year maintenance period for the stormwater system. The Sounders field and stormwater consultants will work with City of Renton to determine a reasonable and appropriate monitoring protocol to test for SBR Crumb Rubber constituents of concern in field drainage. This request for reconsideration is supported by the attached exhibits. We would be happy to answer any questions. Thank you for attention to this second request for reconsideration of SEPA Condition #3. Respectfully submitted on behalf of the co-applicants HILLIS CLARK MARTIN & PETERSON P.S. Ann Gygi Ann Gygi 999 Third Avenue | Suite 4600 | Seattle, WA 98104 (206) 470-7638 ann.gygi@hcmp.com 6 WAC 197-11-660(1)(a). 7 WAC 197-11-660(1)(e). DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Exhibit A Excerpts from King County Surface Water Design Manual KCSWDM, 2021, Ch. 1: Key Terms and Definitions. KCSWDM, 2021, Ch. 1, Sec. 1.2.8.2.A, p. 1-71, -72 DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 KCSWDM, 2021, Sec. 6.1.2, p. 6-7 DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Exhibit B Woodland Park Water Quality Study (Please Click on Attached pdf) 09-04418-000 Woodland Park Water Quality Report 2010 06 07 (1).pdf DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Request for Reconsideration of SEPA MDNS Condition #3 Request for Reconsideration of MDNS SEPA Condition Project File No.: PR22-000301 Project Name: Sounders FC Center at Longacres Land Use File No.: LUA22-000357; SA-H; CU-H; ECF; MOD Date: November 18, 2022 I. Request for Reconsideration of SEPA MDNA Condition #3: Co-applicants Unico Properties 1 and Seattle Soccer LLC, respectfully ask the Responsible SEPA Official for the City of Renton to reconsider the wording of Condition #3 of the Environmental Review Committee Report issued November 7, 2022 for the above-referenced application, for the reasons stated below. II. Current Condition #3: “The fill material used on the synthetic fields shall be comprised of a material that would be non - toxic to fish and other wildlife.” III. Proposed Substitute Condition #3: The applicant proposes the following alternative condition which, if approved, would satisfy the purpose of condition #3: “The artificial turf field program, including field design, construction and operation, together with stormwater management and water quality treatment for drainage from the artificial turf fields, shall assure that the field materials do not result in a probable significant adverse environmental impact on fish and wildlife.” IV. Explanation of Request for Reconsideration Sounders believe that the intent of the City’s Condition #3 is that the artificial turf fields will not result in a probable significant adverse environmental impact to fish and wildlife. Sounders have designed their artificial turf fields to achieve that result. However, the wording of Condition 3 is problematic, because it asks the applicant to prove a negative, i.e. that the turf material itself is “non-toxic to fish and other wildlife.” The applicant cannot meet this standard, especially because of the limited peer-reviewed scientific studies analyzing field-related materials in constructed, operating synthetic turf athletic fields. This lack of information could cause confusion and uncertainty during subsequent permitting. Analysis of the impact of any par ticular material on the environment must also include the manner, intensity, and duration of exposure created. Notwithstanding the lack of definitive information regarding the materials themselves, there are many mitigation factors that can limit risk to the 1 The Unico Properties applicant entities are: Unico Longacres South Building LLC, Unico Longacres South Campus Land LLC, Unico Longacres Central Drainage LLC. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 natural environment. Means of control to limit transfer of turf and turf components to the environment include field design, the stormwater management and water quality system for the fields, and operational practices that control and minimize material transport. This request for reconsideration is supported by the attached letter prepared by Eric Gold of DA Hogan, the field design consultant for Sounders FC Center at Longacres, which is attached as Exhibit A. Please see Exhibit A for further discussion of these mitigation factors, and how they have been incorporated into the proposal for two or more artificial t urf fields at the Sounders FC Center at Longacres. Respectfully submitted on behalf of the co-applicants, THARSIS LAW P.S. Jeremy Eckert DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 1450 114th Ave SE Page 1 of 2 p. 206-285-0400 Suite 225 f. 206-285-0480 Bellevue, WA 98004 www.dahogan.com EXHIBIT A MEMORANDUM To: Julia Reeve, UNICO Maya Mendoza-Exstrom, Seattle Sounders FC Tom Chiado, Chiado LLC Gretchen Blaine, Generator Studio Cc: File From: Eric Gold Date: November 17, 2022 Re: Seattle Sounders FC HQ / Longacres Property City of Renton SEPA Mitigation Condition 3 My Name is Eric Gold. I have over 20 years of experience on a wide range of public facilities, including parks, recreational, and sports field development projects throughout Western Washington. I am the landscape architect and field design consultant for the Sounders FC Center at Longacres. As the field design consultant for the Sounders FC Center at Longacres, DA Hogan has significant concerns with the wording of Condition #3 of the issued SEPA MDNS for the project. The condition reads: The fill material used on the synthetic fields shall be comprised of a material that would be non -toxic to fish and other wildlife. We are not aware of any synthetic field material that has been scientifically proven to meet this standard, so we do not know how we could meet it. Initially, I would like to note that I am not an industrial hygienist or chemist. However, a s a professional athletic field designer, I am very familiar with the ongoing conversations between grass and synthetic turf fields. Most of these conversations focus on the perceived negative aspects of synthetic turf. DA Hogan has no stake in this debate as we design grass and synthetic fields equally. ▪ Regarding the subject condition, its w ording selects a single attribute of synthetic fields, the “fill material,” as the sole means for controlling impacts to the environment. But other field attributes can also effectively protect the environment. Methods of field design, construction and operation can provide reasonable assurance that synthetic materials remain in place as intended, and are not transported off site in quantities that are anything more than incidental. The Sounders fields have been designed with these controls in place. ▪ Ways infill is prevented from “escaping into the wild” in the Project, as proposed, include: à Field Section is vertically draining, i.e., precipitation is infiltrated at a high rate directly downward by force of gravity, through the infill, turf backing, 2” of finely graded stone, 8”+ of coarse graded stone, collected in subsurface drainage pipes and collectors, and conveyed and discharged to a water quality treatment system. This is a closed system. à Water quality treatment meets GULD Enhanced Basic requirements as described by the King County Surface Water Design Manual. à Fields are surrounded by a perimeter concrete containment curb that is designed to meet and match to infill elevation at installation. Typically we can expect settlement of the initial 1.5” of infill by 15- 20%, meaning it is maintained slightly below the containment curb. à The synthetic turf fields are surrounded by security and ball control fencing, with a continuous woven vinyl wind screen material secured to it. This design would deflect most airborne material back onto the field. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 1450 114th Ave SE Page 2 of 2 p. 206-285-0400 Suite 225 f. 206-285-0480 Bellevue, WA 98004 www.dahogan.com à Operationally, this is the training facility for a professional sports franchise , and use of the fields is supervised. Random, unintended acts that might result in significant transport of infills off -site at a local park, such as a giant snowball rolled around by kids ending up in a creek, are not likely to occur. à The fields are designed at 1.5’ above flood stage (FG 21.50 over 20.00) to prevent material from migrating with floodwater in the event of flood. à The synthetic fields have been deliberately located further from Wetland A and its buffer, to provide additional protection against transport to sensitive areas. ▪ Current status of the Turf System Design: à The Project Team is finalizing a Request for Proposals (RFP) to be distributed to a shortlisted group of 3 synthetic turf vendors. à The structure of the RFP includes base bid and alternate bid options for a variety of synthetic turf assemblies, that specify a variety of infill materials including SBR Crumb Rubber, Granular Cork, TPE, and EPDM. We expect that sometime around mid-February sufficient pricing, availability, and performance criteria will be available to the Sounders to make an informed decision. à As stated at the beginning, we have no certification or surety that any of the materials described above “would be non-toxic to fish or wildlife”. Conclusion: In our experience, the field design, construction and operation measures are effective means to control the transport of synthetic field material off-site. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 December 2, 2022 City of Renton c/o Julia Reeve Unico Properties LLC 1215 Fourth Avenue, Suite 600 Seattle, WA 98161 RE Sounders Facility, Water Quality Treatment, and 6PPD-q Dear Julia: In 1998 the Boeing Master Plan for the Longacres site (approximately 158 acres in size) designed Pond B as a Large Wetpond per the King County Surface Water Design Manual (KCSWDM) and the Renton Surface Water Design Manual (RSWDM). Pollution generating impervious surfaces (PGIS) and non-pollution generating pervious and impervious surfaces (NPGPS, NPGIS) on the Longacres site, including some of the Kaiser Permanente Campus to the south, drains through Pond B. The site discharges to the managed stormwater system within the Longacres property which was sized and constructed in anticipation of receiving undetained and untreated runoff from this site. That system flows through a series of large ponds, small ponds, swales, and control vaults and weirs, prior to leaving the site. The system then drains to Springbrook Creek which in turn drains to the Black River and ultimately the Duwamish River and Puget Sound. The Sounders Facility proposes to construct up to five playing fields, three of which will be covered with a synthetic turf system. This project proposes to use a Filterra Bioscape, proprietary open filtration basin design for water quality treatment of the water flowing from this field complex. This system is sized to meet the Enhanced Basic level as required for this project by the City, and is sized to provide treatment for the 6-month event runoff as specified in the RSWDM. Flows exceeding the design treatment rate, will be directed around the Bioscape system via a flow splitter located above the facility. These higher flows will be directed into the existing water quality pond on site, Pond B. Per the Washington State Department of Ecology report titled 6PPD in Road Runoff (Publication 22-03-020) “Stormwater treatment infrastructures that use infiltration, sorption, filtration, and/or effectively capture tire wear particles are expected to reduce the toxicity from 6PPD-q.”, and “Filters that focus on reducing suspended particles (e.g., total suspended solids) will be effective at capturing tire particles and any other particulate matter with sorbed contaminants including 6PPD-q.” We offer the following information to explain our conclusion that the recommended treatment system (Bioscape) as currently sized. We should note that though the code requirement for treating stormwater runoff for all systems within this area is the 6-month storm event, this project will be designed to treat the 2-year rainfall event runoff, in a good-faith effort to even further reduce concerns regarding the field material. This treatment rate means this facility will treat all of even more of the rainfall events that this facility will experience. We believe that this treatment level is a reasonable approach to address the concern raised concerning the 6PPD-q pollutant. The concerns regarding this pollutant have been based, to date, on studies of roadway runoff, which we believe to have important differences from the use of rubber in synthetic turf fields. 1. WATER TREATMENT The selected Bioscape system as proposed, uses the recommended methods to treat water runoff to reduce or eliminate 6PPD-q, as stated in the most recent Ecology discussions of the research available. This system uses a combination of infiltration, filtration and sorption, as specifically DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 2 mentioned to reduce the toxicity concerns of this chemical. This system also is listed as a highly effective treatment for all stormwater systems designed to protect fish and other aquatic life from the negative effects of pollutants in general beyond 6PPD-q. 2. EXISTING SYSTEM PROTECTIONS This system is being installed within a larger water quality system for the original Boeing Longacres site. This site was permitted starting in 1995 using the best available science, as reviewed by City of Renton and by Ecology, to protect the downstream waterways from the pollutants created by urban development in the proposed Boeing Master Plan. This plan consisted of multiple asphalt parking lots around the future buildings. The Sounders project is adding the high-performance Bioscape water quality system above the existing system on site. Water from the proposed fields will be filtered and treated before flowing into the existing systems, in order to both comply with current standards and to apply the best available science for pollutant removal of all types further reducing potential for pollutant transport. 3. FIELD MATERIALS Unlike in a roadway environment where tire dust and fine particles are blown or washed off of the road surface quickly into storm systems or directly into receiving waters containing fish, the granular crumb rubber in the synthetic turf fields at the proposed Sounders FC facility remains at the surface, prevented from entering the stormwater system. The crumb rubber used in fields is sieved and processed to reduce finer particles to the maximum extent possible, including the finest dust. Therefore the mechanisms believed to cause degradation of the rubber into 6PPD-q and the mobilization of those particles themselves are far less in the field context than in roadway runoff which is the current basis of research on the issue. The largest constituent of pollutant transport is broadly recognized to be the finer particles, down to dust-sized. Smaller particles both degrade quicker (producing pollutants such as 6PPD-q) and can be transported downstream more easily, for direct contact into waterways and aquatic organisms. Additionally, the potential for fugitive infill materials to directly leave the field surface is further mitigated by 1) a continuous perimeter containment curb and windscreen/fence, and 2) controlled access and use, which limits potential unintended migration or transport. 4. FIELD DESIGN The synthetic fields are constructed in a manner that provides a certain level of drainage pre- treatment via filtration through gravel, in addition to preventing crumb rubber material from being transported downstream. It is almost impossible for the field material to migrate via surface runoff, which is the typical method of transport for both crumb rubber and the dissolved potential pollutants. No surface should come into contact with the rubber, as the fields are designed for surface infiltr ation into their under-drains, of the 100-year or larger storm event, more than twice the statistical storm size, in a much shorter time period. 10-inches of rain falling in an hour, vs 5-inches of rain falling in 24 hours. Once the water flows through the crumb rubber and then the underlying rock layers, the water is carried on a very flat prepared subgrade and geotextile surface. This surface is then drained via flat underdrain pipes. From a stormwater hydrology standpoint, Ecology has recognized that t hough under-drained, synthetic turf fields only behave as though they are 50% impervious, whereas all paved roadways are considered to be 100% impervious. Meaning significantly less water will ever leave the fields compared to roadways, for the majority of stormwater events. Also the field drainage design causes whatever water that does runoff beneath the fields, to move more slowly to enter the piped under-drains. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 3 This added residence time via longer runoff time, is a factor to reduce the likelihood or amount of pollutant runoff potential. Given the half-life of the 6PPD-q chemical that is quoted in the Ecology study, the longer it takes for runoff to occur, theoretically less pollutants are transported downstream. This runoff mechanism and time factor is very different than roadways which are the basis of the current studies, which have almost immediate runoff downstream into a collection system or a waterway. 5. FIELD MAINTENANCE Professional Sports Franchises are required to maintain their facilities at the highest established standards. In the case of the proposed Sounders fields, the design specifications require that the installation be “FIFA QualityPRO” certified, meaning they must pass a battery of very specific performance testing with very tight tolerances. Many characteristics are tested and measured against this standard to allow the fields to be certified. For these reasons, Pro Sports Facilities surfaces are typically replaced at a higher frequency than at park or school facilities, even high level collegiate facilities. From our design team’s experience, this replacement will typically occur every 4-5 years. By replacing the field surfaces systems more frequently, the crumb rubber used in the field construction will have less time to degrade within the life cycle of the fields. This theoretically will also reduce the opportunity for ozone related creation of the 6PPD-q pollutant, which occurs over the life cycle of the rubber. 6. PROXIMITY TO FISH Salmonids and other species of fish are not able to enter the Longacres site. The original design for the Longacres mitigation project (ponds, swales, wetlands, etc) included a fish-barrier at the outfall to Springbrook Creek. This helps to ensure that all of the existing and proposed systems on the campus have the ability to provide maximum effectiveness prior to contact with the fish. This concern had also been raised with regard to the potential flood mitigation storage currently proposed for the fields. Due to the screens present at the site’s outfall to Springbrook Creek, there should be no concerns about fish sequestration in the flood chambers and therefore the need to provide screens or other methods at those proposed systems. In summary, we believe this system, in addition to the existing downstream settlement ponds and the rigorous maintenance associated with a professional sports field system, should be considered an adequate precaution and appropriate design measure for this project with regard to this potential pollutant concern. Our conclusion is based on the reasons stated above, which are summarized as: 1. Redundant existing water quality systems and conveyance systems exist already on the Longacres site, as intended during the original and highly scrutinized design for the campus. 2. The best available science for mitigating potential runoff of 6PPD and 6PPD-q is proposed for this project in the form of the Bioscape system that utilizes the same treatment methods recommended by Ecology in the existing written documents concerning this pollutant. Even further, the system proposed will be designed to treat a 2-year flow rate, which is 2 to 4 times statistically less likely to occur than the 6-month storm standard requirement. The Bioscape system is widely recognized and utilized by public agencies in Puget Sound for its high- performance as tested by Ecology for regulated pollutants, and the higher treatment capacity increases that performance. DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 4 3. The rubber material used in the field construction is much more stable by its production method, which is sieved and processed to reduce fine particles, and is therefore less likely to generate pollutants through degradation or transport. 4. The field designs create a reduced volume and slower moving runoff regime, which works to allow more degradation of the 6PPD-q to occur before runoff occurs, as identified currently in available technical documents related to half-life of the pollutant. 5. The curbed design, and high-quality operations and maintenance of the professional sports fields in question, result in less potential migration and degradation of the crumb rubber. 6. The entire train of systems in place on the site will have a chance to filter and remove pollutants prior to discharge to the creek. This longer residency time should increase the chance for the 6PPD-q to biodegrade if present, before reaching the outfall. We appreciate your consideration of our proposal and conclusions. Sincerely, Tim Brockway, P.E. Principal COUGHLINPORTERLUNDEEN DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT Planning Division 1055 South Grady Way, 6th Floor | Renton, WA 98057 | 425-430-7200, ext. 2 www.rentonwa.gov OF ENVIRONMENTAL DETERMINATION RE-ISSUANCE OF A DETERMINATION OF NON-SIGNIFICANCE - MITIGATED (DNS-M) POSTED TO NOTIFY INTERESTED PERSONS OF AN ENVIRONMENTAL ACTION DNS-M: The City of Renton Environmental Review Committee (ERC) has determined that the proposed action has probable significant impacts that can be mitigated through mitigation measures. This DNS -M is issued after using the optional DNS process in WAC 197-11-355. There is no further comment period. DATE OF NOTICE OF ENVIRONMENTAL DETERMINATION: December 5, 2022 PROJECT NAME/NUMBER: PR22-000301 Sounders FC Center at Longacres / LUA22- 000357, CUP-H, SA-H, ECF, MOD PROJECT LOCATION: 1901 Oakesdale Ave SW (APN’s 0886700220, 0886700210, 0886700110, 0886700130, 0886700120, 0886700140, 0886700370) APPLICANT/PROJECT CONTACT PERSON: Julia Reeve /1215 Fourth Ave, Suite 600 Seattle, WA 98161 / juliar@unicoprop.com LOCATION WHERE APPLICATION MAY BE REVIEWED: Applicant documents are available online through the City of Renton Document Center website. See also https://cutt.ly/yBQ3iK7 DESCRIPTION: The applicant is requesting a Hearing Examiner Conditional Use Permit, Hearing Examiner Site Plan Review, Environmental (SEPA) Review, and a Street Modification for the use of a portion of an existing office building for Sounders FC office space and indoor training facilities and associated activities, outdoor recreation facilities including 5 full-size soccer fields a Goal Keepers Field and accessory structures, and reconfiguration of and existing surface parking lot. The overall project site totals approximately 30 acres in area and is zoned Commercial Office (CO). Access to the Site would be maintained via existing curb cuts off of Oakesdale Ave SW. The project site is currently developed with an existing 5-story office building totaling approximately 311,982 sq. ft., and the Sounders propose to lease approximately 50,000 sq. ft. of floors 1 and 2. A new accessory viewing deck proposed to overlook Field 1 from floor 2 would total be approximately 1,650 sq. ft. in area. Some existing surface parking would be removed for the placement of Fields 1 and 2 and additional parking would be removed to create a secure 1st team parking area in the existing southern parking lot. The total remaining parking area would include approximately 766 surface parking stalls. A maintenance building (approximately 4,000 sq. ft.) and future field restroom (approximately 800 sq. ft.) are proposed to be co-located between fields 2 and 4. A Modification to the City's Street Standards was requested to maintain the existin g frontage improvements around the project site. The project site is mapped with high seismic hazard areas, wetlands, and flood hazard areas. A Category II wetland was identified to the northwest of the project site, a Category II wetland has a standard buffer of 100 feet for low impact land uses and 150 feet for all other land uses. The proposal includes a reduction in the standard buffer width in the vicinity of the soccer fields and the paper fill of the wetland. Wetland buffer REVISED NOTICE DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Anyone that would like to be informed of future actions or would like to become a party of record on this proposal must fill out our online form at https://cutt.ly/SQvBak4 or complete this form and return to: City of Renton, CED Planning Division, 1055 So. Grady Way, Renton, WA 98057. Name/File No.: PR22-000301 Sounders FC Center at Longacres / LUA22-000357, CUP-H, SA-H, ECF, MOD Name: ____________________________________ Email: _________________________ Phone#:__________________ Mailing Address: ____________________________________________ City/State/Zip: ___________________________ Notice will be sent via email, unless a hard copy is specifically requested. Check box to receive via US Mail  enhancement plantings and the purchase of wetland mitigation bank credits are proposed to mitigate for the impacts to the wetland and buffer. DECISION: Based on the additional information provided in the reconsideration request by the Applicant, the ERC has retained SEPA mitigation measures 1 and 2 and amend mitigation measure 3 as stated below, add a new mitigation measure 4 and renumber and retain mitigation measures 4, 5, and 6 as 5, 6, and 7: 3. The artificial turf field program, including field design, construction and operati on, together with stormwater management and water quality treatment for drainage from the artificial turf fields, shall assure that the field materials do not result in a probable adverse environmental impact on fish and wildlife. The proposed water quality treatment facility shall be a Filterra Bioscape facility sized to treat the 2-year storm event or equivalent as approved by the City and the applicant shall undertake quarterly water quality tests of field drainage, during the life of the field or for a five (5) year period, whichever comes first. The applicant will submit a monitoring protocol to test for SBR Crumb Rubber constituents of concern in field drainage for City approval. 4. When the fill within the synthetic turf athletic fields is replaced, the applicant shall be required to go through a new Environmental Review. Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on December 19, 2022. Due to the ongoing state of emergency enacted by Governor’s Proclamation 20-28.14 (and as amended), the City Clerk’s Office is working remotely. For that reason, appeals must be submitted electronically to the City Clerk at cityclerk@rentonwa.gov or delivered to City Hall 1st floor Lobby Hub Monday through Friday. The appeal fee, normally due at the time an appeal is submitted, will be collected at a future date if your appeal is submitted electronically. Appeals to the Hearing Examiner are governed by RMC 4-8-110 and additional information regarding the appeal process may be obtained from the City Clerk’s Office, cityclerk@rentonwa.gov. PUBLIC HEARING: If the Environmental Determination is appealed, a public hearing will be set and all parties notified. DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 June 13, 2023 Via Email (jding@rentonwa.gov) Jill Ding, Senior Planner City of Renton CED Planning Division 1055 S. Grady Way, 6th Floor Renton, WA 98057 Re: Sounders FC Center at Longacres – Request for SEPA Addendum re Cork Infill Selection Dear Ms. Ding: We are pleased to let you know that the Seattle Sounders FC organization has made a determination that it will now use cork infill for the synthetic turf fields at Sounders FC Center at Longacres. This is a significant environmental commitment by the Sounders to avoid using SBR crumb rubber infill, which was under consideration and studied as the likely fill material. As you know, Conditions 1.c and 1.d of the Hearing Examiner’s Conditional Use Permit Decision incorporated a SEPA condition imposing water quality monitoring requirements for many years, and mandating a second environmental review to include those monitoring results when infill was to be replaced (following approximately five years of use). The stated condition also required the applicant to increase the size of the Bioscape water quality treatment system for the fields to a 2-year storm size, which exceeds what is required by applicable stormwater regulations. The basis for all of these requirements was the prospective use of SBR crumb rubber, a common form of synthetic field infill that was under consideration at the time. The concern was that SBR crumb rubber can include the constituent 6PPD-Q, which may be toxic to salmonids if it enters fish-bearing water bodies. The contaminant 6PPD-Q is not implicated with the use of cork infill materials. Please see the attached memorandum by Herrera Environmental Consultants, Inc., which addresses the safety of using cork infill for synthetic playfields, and its conformity to Washington State water quality standards. The water quality monitoring is not required by any applicable water quality regulation, and this expensive mitigation measure is unnecessary in the absence of SBR crumb rubber infill. The requirement to upsize the treatment facility also is inapplicable with the commitment to use cork infill instead of SBR crumb rubber. Please see the attached letter and sizing analysis provided by CPL, the Sounders’ civil engineer responsible for stormwater management, which proposes to adjust the size of the Bioscape facility consistent with applicable regulations. RECEIVED 06/15/2023 JDing PLANNING DIVISION DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Jill Ding, Senior Planner June 13, 2023 Page 2 of 2 Based upon the determination not to use SBR crumb rubber infill, the Sounders ask that the City confirm (1) that water quality monitoring specified in Condition 1.c and repeat environmental review specified in Condition 1.d are not required if the Project does not use SBR crumb rubber, and (2) if cork infill is used for the synthetic turf fields, then the Bioscape treatment system may be sized consistent with applicable regulations rather than for the 2-year storm, as demonstrated by CPL. In essence, the shift to cork infill provides equal or better environmental mitigation for the synthetic fields than would be accomplished by performing the condition as written. We understand that a SEPA addendum may be required for this request. An addendum may be used at any time during the SEPA process. WAC 197-11-706. Please let us know if you need anything additional from the applicant in that regard. Very truly yours, Ann M. Gygi Ann M. Gygi Attachment AMG:vjh E-Mail: ann.gygi@hcmp.com Direct Dial: (206) 470-7638 cc: Tom Chiado Maya Mendoza-Exstrom Julia Reeve Jeremy Eckert ND: 22873.003 4862-4626-5193v3 DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 June 8, 2023 Tom Chiado (206) 550-8363 tom@chiadollc.com RE Bioscape Size Reduction Due to Turf Infill Revision Dear Tom: With the recent decision to change the infill of the two turf fields on the Seattle Sounders Headquarters project we want to take the opportunity to review the requirements for water quality sizing that was identified in final decision from the Hearing Examiner for the City of Renton. The decision at that time was the Filterra Bioscape should be upsized from the standard 91% with applicable K factor, per the 2022 City of Renton Surface Water Design Manual, to the 2-year storm event due to the SBR Crumb Rubber infill and the concerns related to 6PPD-Q. Due to these changes, we propose revising the Filterra Bioscape sizing to align with the 2002 City of Renton Surface Water Design Manual standards. The Filterra Bioscape area will reduce from 825 sf to 638 sf. Attached are revised calculations for the bioscape sizing, as well as a comparison drawing showing the reduced size. Sincerely, COUGHLIN PORTER LUNDEEN, INC. William Andres, P.E. Civil Project Manager RECEIVED 06/15/2023 JDing PLANNING DIVISION DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Treatment Flow Rate* 91st % Storm WQ Q 1.3192 cfs (Determined from WWHM) k Factor 1.91 Treatment Flow Rate 2.52 cfs (City of Renton/KC factor) Bioscape Media Filtration Rate 175 in/hr 14.58 ft/hr 0.0041 ft/sec 100 in/hr 8.33 ft/hr 0.0023 ft/sec Bioscape Area Required (Enhanced Basic)622.0 sf 0.0143 (Phosphorus)1088.5 sf 0.0250 Area Provided 638 sf 0.0146 Sounders - Longacres Phosphorus Enhanced Basic Stormwater - Water Quality Calculations DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 3Bioscape Enlargement 15 15 20 16 16 16 17 18 19 21 15 15 20 16 16 16 17 18 21 73.2' 76' R5' R5'TE O F WASH I NGC ORB.BYHTOM WKCurrent Approved Design Proposed Reduction for Cork Infill 825 SF 638 SF DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TECHNICAL MEMORANDUM 2200 Sixth Avenue, Suite 1100 | Seattle, WA 98121 206.441.9080 herrerainc.com WASHINGTON | OREGON | CALIFORNIA | MONTANA | WYOMING pjj 22-08020-000_tm_corkinfill_wqassmt_20230531.docx Date: May 31, 2023 To: Tom Chiado, Sounders FC Copy to: Maya Mendoza-Exstrom and Tom Riley, Sounders FC; and Ann Gygi and Ryan Durkan, HCMP From: Rob Zisette, Herrera Environmental Consultants, Inc. Subject: Cork Infill Water Quality Assessment Cork Infill Water Quality Assessment There are no potential water quality concerns associated with using cork infill for the synthetic turf fields being constructed this summer at the Sounders FC Center in Renton, Washington. Cork infill is bark harvested from trees and processed without additives, including without the 6PPDQ compound associated with crumb rubber infill, which was the basis for the SEPA water quality monitoring condition. The material safety data sheet (MSDS) for Amorim Cork Composites (Appendix A) identifies the material as a natural product with no applicable hazards identification or toxicological information. A laboratory test report provided by AstroTurf (Appendix A, Labsport 2021) shows undetected to very low concentrations of heavy metals, polycyclic aromatic hydrocarbons (PAHs), phthalates (plasticizers), and chlorinated paraffins (n-alkanes) in bulk cork infill samples that are all less than criteria established for soil contaminants of ecological concern by the Washington State Model Toxic Control Act (Table 749-2 in WAC 173-340-900 1). Cork leachate samples (24-hour leaching) also exhibited undetected to very low concentrations of heavy metals and extractable organic halides that are all less than criteria established in France national standards for unbound mineral surfaces of outdoor sport areas (NF P90-112). Metals concentrations in the cork leachate samples were less than freshwater acute toxicity criteria established by Washington State Surface Water Quality Standards (Table 240 in WAC 173-201A). Testing of untreated drainage samples collected during five storm events from a cork infill synthetic turf field at Bobby Morris Playfield by Herrera in 2019 for Seattle Parks and Recreation showed undetected to low concentrations of heavy metals and semivolatile organic compounds that were all less than freshwater acute toxicity criteria established by Washington State Surface Water Quality Standards (Table 240 in WAC 173-201A) (see Table 4 from Herrera 2019 in Appendix A). This information clearly indicates that discharge of treated drainage from cork infill synthetic turf fields at Sounders Center will not impact aquatic life in Pond A or downstream receiving waters. Material testing shows that cork infill contains lower amounts of metals and organic compounds than crumb rubber infill (Massey et al. 2020). Thus, substituting cork infill for crumb rubber infill reduces the amount of chemical pollutants present in the synthetic playfields. 1 WAC = Washington Administrative Code RECEIVED 06/15/2023 JDing PLANNING DIVISION DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Technical Memorandum (continued) Cork Infill Water Quality Assessment 2 May 2023 References Herrera. 2019. Environmental Monitoring Report, Bobby Morris Playfield Enovation Pilot Program. Prepared for Seattle Parks and Recreation by Herrera Environmental Consultants, Inc. December 6. <https://www.herrerainc.com/publications/synthetic-turf-environmental-monitoring-report/>. Labsport. 2021. Test Report, Test on Infill Materials, Nature 130. Prepared for Amorim Cork Composites by Labsport, LeMans, France. Report nR201599-C1. March 16. Massey, R., L. Pollard, M. Jacobs, J. Onasch, and H. Harari. 2020. Artificial Turf Infill: A Comparative Assessment of Chemical Contents. NEW SOLUTIONS: A Journal of Environmental and Occupational Health Policy, Vol. 30(1):10–26. DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Appendix A Cork Infill Water Quality Information DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 MSDS-1002/10 Page 1 !"#$%&’()*)+,-. /01&23’%!4 5 6 710-)%%)8/801’’ 710-)%%)8/801’- 9 (. (. #$&-8:323:2: #9 ; #< #9 ;) #< !,9 =6 ">?"*%) !,@ "A B "*%) ,9 #9 ;) ,#<) ?9 C ;A "<<4 A 9 >) DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 MSDS-1002/10 Page 2 ?5 6A A <A 6 ) #9 ; #< ! ! 8)-! 8)-D 6 #9 9 ; #? 8)%4 6 8)%6 4 E <"6 A ) A "B B 2 ) " #$ "# 9 >F 4 9 "9 G ,6 ? +A 6 #??) 9 A >6 ?6 ’)0 ) @ 6 BA A 66 A ’)0 ) %& % 5 > A H A I6A +B A ! D #9 ; DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 MSDS-1002/10 Page 3 D #< <9 #9 ; +6 #< 5 9 #9 ; !6 #< J 9 K 1’’$ J6 K 1’’$ 2J <#9 ; 6 #< ,#9 ; ,#< <=6 J L @ <J < ’ $ ’ $ 6 9 1’’$9 <>,>,<) 6 6 <,<, <1’’$) # ( # #9 ;) #< ( <#9 < A #<A 9 # DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 MSDS-1002/10 Page 4 &) $ 9 ?A "4 <) @ J A <<" ) ?6 ;) +6 A <6 ) ) $ #9 6 #6 F ?;) B A A ) ) *5 A 6 "9 <9 9 ) MA A 5 <<A ) ?L 6 "?9 6 ) MA <A A A ?"BA <A A <B A ) %’’-N0:N ,%’’-N0:N DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 LAB99OTESTREPORTRAPPORTD’ESSAISIINFORMEDEENSAYOSTestoninfillmaterialsIEssaissurMaterialestierellenomatériauxderemplissage/TestrealizedaccordingtoNFP90-112,EN15330-I,NFEN71-3,REACHstandardsandFIFA,WORLDRUGBYhandbooksEssaisrealisosselonlesnormesNPP90-112.EN15330-1,NPEN71-3,REACHellesrélérentielsFIFA,WORLDRUGBYEnsayossegunlasnormasNFP90-112.EN15330-1,NPEN71-3,REACHylosreterencialesFIFA.WORLDRUGBYNATURE130AMORIMCORKCOMPOSITESReport/rapport/informen5R201599-C1Date:16/0312021ThelestreportreproyuctioeisalloceyonlyinitsintegrallOon‘LareproductiondarapportdessaisnestaatOriséeqae5055SeurIneiniègrale/Sepermitea,eprodscciOrdelesenle[stormeünicamenteensointegral.TheresultsarevalidonlytarInnassessedsample/Lesrdsultalscancementuniqaemenllesobjelssoumiseonessais/LosresaitadosdelpresenteinlormesereliereneeclasinaonenleaIanmoestrasobjetodoLosensapos.ILABOSPORTS-A-STechnuporcthuCircuitdes24Heures•CherrtinaLex80/uts•72100I.eHorns.FrancecunnLuct@labuspurt.corTnwww.labosDofl.comTdl,.33(0)243470840sPan.33(01243470828DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORTIRAPPORTD’ESSAIIINFORMELWENSAYOSAMORIMCORKCOMPOSITESINATURE130LABOSPSUMMARY!SOMMAIREIINDICEI•IDENTIFICATIONIIDENTIFICATIONIIDENTIFICACION2.AGEINGIVIEILLISSEMENTIENVEJECIMIENTO3.TOXICOLOGYANDENVIRONNEMENTITOXICOLOGIEETENVIRONNEMENTITOXICOLOGIAYMEDIOAMBIANTE3.1AnalysisofheavymetalsafterleadingIAnalysedesmétauxlourdsaprêslixiviationIAnálisisdemetalespesadosdespuesdeIalixiviación3.2EOX3.3PAHIHAP3.4AnalysisofheavymetalsIAnalysedesmétauxlourdsIAnálisisdemetalespesados3.5ChlorinatedparaffinsIChloroparaffinesIParafinaclorada3.6PhthalatesIPhtalatesIFtalatosSYNTHESISISYNTHESEISINTESISTestongranulesREPORTN°R201599-Cl16/03/20212113DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORTIRAPPORTO’ESSAIIINFORMEDEENSAVOSAMORIMCORKCOMPOSITESINATURE130I•IDENTIFICATIONIIDENTIFICATIONIIDENTIFICACIONABRInformationprovidndbythesupplier/CaraclCrstiqucslourniesparIaabricant/Caracteristicascomunicadaspar&abricanleAMORIMCORKCOMPOSITESMua00M0l5OS,ZbUP.O.BoxIMOZELOS-VFR4536-902PORTUGALSoeclmenInformatIon/Informationcoremantrechantitlon/OatossobreIamuostra18/11/2020AMORIMCORKCOMPOSITES20/11/2020029310ResultNFP90-112RésuttatFIFAWorldRugbyENI5330-1Resultado(2016)ParticleshapeI-)EN14955A3VVFormnJForms0.110.120,1BulkdensityW/cm°)EN1097-3VVVVDens’Ie/DensidadMoyenno0.11Particlesized(mm)EN933-11.000aO.5VVVD(mm)EN933-12,5003.15VVVColorBrown/marron/(-)visualVVVCouletjr/ColormarronPermeability(m/s)EN126160,0067a0.0001--PermeabilitéIPermeabilidadThermograVlmetrlcAnalysIsTGA/AnalysethermogravimétriqueATG/AnélisisTermoaravimét/coATGcharge/charge/carga(%)22.2-VVorganic/organique/orgãnico(%)77.8-VV“MasslossbetweenbeginningofsecondpeakISO9924-1(around400CIand650CIPerledemasseentreledebutdusecondpic(%)N/A20VV(aulourde4000)els5oC/Perdidsdemasaentre&iniciodelaecondopica(apr05.400C)ys5oCVrequiredforidentification/demandépouridentificationWatertemperature/Temperaturedel’eau/Temperaturadelagua195C‘elastomercontentasdefinedinFlEAmanual/‘teneurenélastomère’fetequedéfiniedansleréglementFIFAN/AFrenchstandardNEP90-112mentionsthepossibilitytouseorganicmlillforartificiallurts/LanormoNFP90-112mentionneIapossibleutilisaliondunremplissagodotypeorganiquepourlesgazonssynthetiquesTestongranulesREPORTN°R201599-ClI•I_ii-iNATURE130Brown/marron/marránVEGETALUsteotoroerDatedecommapteFechariepedkioEchamllloreprelevésparMueahatomadaD._DateotreceptionDatedereceptionFochade.xecioaRecetprmimbarNuméroderécepéonNmncc-DateattestsDaledewess&sFeobadeermavos-From/du20/11/202010/au15/03/202116/03/20213/13DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORT!RAPPORTD’ESSAIIINFORMEDEENSAYOSAMORIMCORKCOMPOSITES(NATURE130PafliciesizedIDGranulométrie/GranulomelrlaSieve/Tamis/Cribas1mm)0,0000.06302000,3150.4000,5000,6300,8001,0001,2501,6002,0002,5003,1504,000Refusal/fletus/Rechazo)g)78,478,3973,478.478,478.378,378,175,968,940,511,00.000Passing/PassanvPasante)%}000000013123786100100100RelusallRetuslRechazo)%)000000039254914000ParticleSize-sieveanalysis4Pass[ng/Passant/Pa,inte1%)Refusal/Refus/Rechazo)%)100901—_______+80.4-_______________________70-______________________________________________________________60-‘__________________________________________-___________________________________s0.-______40.÷30-____________——_____________________________________20---——++-L10-——0III-:-0,0000,5001,0001,5002,0002,5003,000Sieve(mm)Coleolmsd‘argessave‘pusgrandavis<50%0sr&eatsen/pl.apetiltans.90%TestongranulesREPORTN°R2O1599-Cl16/03/2021403,500302010—04,0004/13DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 0= 0 U, Co Co 0 C)’ w a 3 3 3 ag SIm 3 0 C, C 3 0 C, a) ‘S ‘3 H0 a 0 C C 3 n S H C) S 3a S 3 C 0 — S S 3 S‘H 1! ‘3$ C, 0 C) “3 C “3 a H ‘4 L I0 Ii’-, 10 DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORTIRAPPORTDESSAIIINFORMEDEENSAYOSAMORIMCORKCOMPOSITES(NATURE1302.AGEINGIVIEILLISSEMENTIENVEJECIMIENTOLABOSPHotwateragejn9thenhotaira9eingIVlellllncmontalesuchaudoputsalairchaud)Envojecimlontoa’aguacaitontoyalecaliontoTestnethod/Nonedaosai/MéiodaensaycEN13744lEN133!?TestongranulesREPORTN°R201599-C1ResultREsultatResultadoParticle—GranulomStneIGranulometriad(mm)EN933-1NFP90-112(2016)lOGONovariationNovariation0(mm)EN933-12500NovariationNovariationColorBrownImar09/(.)viSua-marronNoagglorneatonNoagotcnerntorVisualaspect-Anpoc!visualAspec:c(-)visuatNo:rackin9NocrackirgNowhiteIimNowtdetImViewofthenewproductViewafterageingPhYog’ap-advpro&dtneilPtiocgaol’iedvoroduitapralsv1%anrilFotog’apr4adelçroastorue-joFocaol’laJetprhx1oteaptthsdoterrjeecrTvenlo16/03/20216113DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 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TESTREPORTIRAPPORTD’ESSAIIINFORMEDEENSAVOSAMORIMCORKCOMPOSITES!NATURE130LABO3.TOXICOLOGYANDENVIRONNEMENTITOXICOLOGIEETENVIRONNEMENTITOXICOLOGIAYMEDIOAMBIANTE3.1AnalysisofheavymetalsafterleadingIAnalysedesmétauxlourdsaprèslixiviationIAnálisisdemetalespesadosdespuésdeIalixiviaciónbetween0.5and1mgIandbetween50and100mgI),theseconddustsatlerleadingwithoutbubbling48hours)isanatyzcdLeadingtestmethodEN12457-4./Lepremieréluataprésliaiviationsansbaóolage24heures)estanalyse.Sitesessaisconcernant[analyseduZincetduCOOnesontpasconformes)respcctiaementcomprisentre05elImgiletcompnisentre50et100mgI)),lesecondeluatapréslieiviationsansbarbotage(45heures)eatanalyse,FilethodedesaaispourIatiu’viationEN12457-4LeaaPbPlombIPtomoCadmiumCdCadmioChromiumtotalCrChrometotalICromototalTinSnElain/EslanoZincZnZincICincNFENISO11885txtractasieurganicnaliaestUAOrganobslogeneseatractibtesEOXmg/kgDIN38414.17EatraiblesOrganicaHalogenurosEOXTestongranulesParameter--UnitEMm.Munitenétadoda-Elemento-unidad-ResultRésultatNPP90-112(2016)Resultadomg/Img/img/Img/Img/I<0,005S0.0250,00350.0050,00350.050<0,005S0.040Eluat24H:0,029E)uat48H:50.5Eluat24H:DissolvedorganiccarboneDOCmg/INFEN1484N)A11550CarbonoOrganiqueDiaaousEluat48HChromiumhexavalentCrNPT90-0430,0080,008ChromeheuavslentICromoheeavalenlemg/IDIN38405.24NFEN13506MercuryMflmg/IDIN12846<0,000015S0.0010Mercure/MercuricN/A’4Fororganicmull,the000contentisnaturallyhigherandthereforeweconsiderthattherequ)rementcriteriaof50mg/Iisnotapplicabletarthistypeofmaterial(SourceRAL-GZ944,Antage0)/Pourlosrumplissagusdotypeorganique(chargenstureiucomposéedematériauxissusdurbgnevegétat),IateneurenCOOeatnaturellementplusOlevéeotdoncparconsequentnousoonsidOronsquolecniléred’oxigenceappliquédo50mg/In’eslpasapplicablepourcetypedematéniau(SourceRAL-GZ944,AnI)3.2EOXPanmeffirUnitElementuniteElnitododiunidad.nsfloResultRésultatNFP90-112(2016)Resultado335100REPORTN°R201599-C116/03/20219113DocuSign 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TESTREPORT!RAPPORTD’ESSAIIINFORMEDEENSAYOSAMORIMCORKCOMPOSITES(NATURE1303.3PAH-PolycyclicAromaticHydrocarbonIHAP-HydrocarburesAromatiquesPolycycliquesIHAP-HidrocarburosAromãticosPoliciclicosLABOSPTherubbergranulesusedasmliiimaterialforsyntheticturfsurfacesareclassifiedasmixturesbytheEuropeanREACHregulations./Lesgranulatsdecaoutchoucutiliséscommematériauxderemplissagepouressurfacesdegazonsynthétiquesentclassescommemélanges..paresréglementalionseuropéennesREACH111.Assuch,rubbergranulesneedtocomplywthentry28ofannexXVfItotheREACHregulations.PAHsispanoftheentry28ofannexXVIItotheREACHregulations.IEntantquetel,esgranulatsdecaoufchoucdoiventelreconformeaentrée28del’annexeXVIIduréglementREACH.LeoHAPsootunepartiedeentrée28deFannexeXVIIduréglementREACH.ECHA(EuropeanChemicalAgency),28-02-2017AnnexXVreport,anevaluationofthepossiblehealthrisksofrecycledrubbergranulesusedasinfidinsyntheticturfsportslelds.t..j.UJ;Mr4;,Benze(a)Py’êr.emg/kg<0.2100Benzo(e)Pyrénemg/kg<0,21000Benzo(A)Anthracénemg/kg<0.21000———USEPA827OChrysenemg/kg2’<0.21000Benzo(J—B)Fluoranthénemg/kgc0.22000Benzo{K)F..cranthenemg/kgc0.21000Dicenzo(A,HAntfvacénemg/kg<0.2100TotalSPAH<4,4Indeno1,2,3(CD)Pyrénemg/kg<0.2/Benzc(G,H.l)Peryènemg/kgc0,2/Nachtalènemg/kgc0,2/Aoenaphtènemg/kgc0,2/A:enapntylénemg;kgUSEPA8270<0.2/Arthracénemg/kg12)<0.2/Fluoranthenem3/cg0.2/Fk.o’enemg/c;c0.2/Phenanthreremg/c;c0.2/Pyrénemg/c;0.20/TotalISPANmg/kgc3,4IResultReach-MixtureRésultatReach-MélangeResultadoReach-MnclaECHAEuropeanCtsem,calAgcncylcempendiumattestmethods.March2016/Pecue,tdesmdihcdesd’essaiECHA(EuropeanChemicalAgencyl,mars2016TestongranulesREPORTN°R201599-Cl16/03/202110113DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORTIRAPPORTD’ESSAItINFORMEDEENSAYOSAMORIMCORKCOMPOSITES?NATURE13934AnalysisofheavymetalsIAnalysedesmétauxlourdsIAnálisisdemetalespesadosLABqTheEN71-3standardspecifiesthemaximummigrationlimitsfortoymaterials.Themigrationlimitsoftheelementsareexpressedin________—.milligramsperkilogramoftoymaterial.ThelimitstakenintoaccountarohosecfoategoryIll(polymers).TheselimitsareintendedtoLdIluliTlucITI/LiSOCITLOcesHhjilLesuehihhyidLiuTIbhldAiTiIdiWbdpphlLdufraspupsiihdLIidA-lUPL.LPSIIII‘‘Lasupbilly,dhhurIUusdlémentssontexpriméesenmilligrammesparkilogrammemalériau-jcuet.LeslimitesprisentencomptesontcellodeIacatogorieIll(polymeres).Ceslimilesvisentalimiterautantquepossiblel’exposiliondesenfantsacerlainsélêmenfspolentiellementtoxiquesResultflEsultatNFEN71-3(catIll)ResultadoAluminiummg4cgMSICP385<70000Antimonymg/kgMSICP0,3<560Arsenicmg/kgMSICP<0,05<47Bariummg/kgMSICP18,3<18750Boronmg/kgMSICP8,3<15000Cadmiummg/kgMSICP0,05<17Chromiumtotalmg/kgMSICP0,1-ChromiumIIImg/kgMSNEENISOl18S0,1c460ChromiumVImg/kgMSNFT90-043c0,053c0.053Cobaltmg/kgMSICPc0,05c130Coppermg/kgMSICP2,3c7700Leadmg/kgMSICPc0,25<23Manganesemg/kgMSICP34,6<15000Mercurymg/kgMSNEENISO17a5<0,00075<94Nickelmg/kgMSICP0,3c930Seleniummg/kgMSICP<0,25c460Strontiummg/kgMSlOP7,55<56000Tinmg/kgMSlOP<0,25<180000OrganicTinT”mg/kgMSICPNR<12Zincmg/kgMSlOP1,9<46000(1)NRNotdone/NonrêalisêTestongranulesREPORTN°R201599-Cl16/03/202111/13DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORTIRAPPORTDESSAIIINFORMEDEENSAYOSAMORIMCORKCOMPOSITESINATURE1303.5ChlorinatedparaffinsIChioroparaffinesIParafinacioradaResultRésultatResultado<10LABOSP3.6PhthalateslPhtalatesIFtalatos<1<1<1<6<115<6TestongranulesREPORTN°R201599-C1LJ!1ChlorinatedparafflnsCliloroparaflinesmg/kgDIN16035-7sf1ParahnacloradaPhthalatesPhlalatesFlalalosResultRésulistResultadoDimelhylphtalatemg/kgDiethylphtalatemg/kgDi-iso-bulyiphlalatemg/kgDi-n-butylphtstatemg/kgDIN16035-7sItBis•(2-mothoxyothyl)phlalatemg/kgBenzylbutylphlalatemg/kgBis-(2-ethylhexyl)phtalatemg/kgDi•noctyIpbtaIatemg/kgDi-iso-nonylphtatatemg/kgDi-iso-decylphtatatemg/kgTotalmglcgc13416/03/202112113DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 TESTREPORTIRAPPORTD’ESSAIIINFORMEDEENSAVOSAMORiMCORKCOMPOSITES?NATURE130SYNTHESISISYNTHESE)S’NTESIS1.Identification/jdcn’if’caton/dentiiicacionLABqcefllfficacion2.Aqeing/Vicillissemen/EnvejecimienloP.WPOfl.11’(‘nicsPaee/nnnfnrma/rnrnnia..-(CiEJWL.HotwaterageingthenhotairageingViailiissementareaudiaudepuiaaairchaNEP90-I12(2016)PassIconforme/cumpleEnvajacimienio&aguac&ienieysirecalienieUVB(313nm-4896kJ-2550H)ageingVieiirissementausUVENEP90-112(2016)PassIconforme/cumpreEnvajecimientoalosUVB3Toxicotoqyandenvironnement/Tosicologieatenvimnnemeni(Tosicologiaymedioambianie•RiqtdriñithiCàAtàmiHy---____AnalysIsofheavymetalsafterleadingNEP90-112(2016)Pass/conforme/cumpletixiviaciOnExtractableOrganicHalidesEOXOrgano-halogéiiesextractiblesEOX/NEP90-112(2016)Pass/conforme/cumpleEstralbiesOngánicaH&ogenuroaE0XPolycyclicAromaticHydrocarbonPAHHydrixarbszesAromatiquesPolycycliquesHAPREACHMixturePass/conformeIcumpleHkjrccathurosAromaticosPoiiclcijcoaHAPAnalysisofheavymetalsrisksbyIngestionNEEN71-3(catIll)Pass,?conforme/cumpleMalysedeamétautlourdstisquesparIngestionforthetestscarriedout!pourlesessamsrealisesNtdanelalesosearlosnissandaks,ectki,Date:16103/2021APPROBATEURBenoitBOSSUETResponsabteTechniqueSolsSynthétiques1’REDACTEURSteveBAZEILLEResponsabteduLaboratoireTestongranulesREPORTN°R201599-C116103/202113113DocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325 Median MeancMin. Max. Median MeancMin. Max. Median MeancMin. Max.ConventionalsHardness (mg CaCO3/L)--- 615942 76 90 87 74 98 142 150 93 211Total Suspended Solids (mg/L) --- 30 38 6.0 100 1.0 1.3 1.0 2.0 6.0 7.4 2.2 15Biochemical Oxygen Demand (mg/L) --- 2.3 4.7 1.4 16 1.2 1.5 1.2 2.4 --- --- --- ---Total Phosphorus (µg/L) --- 162 190 72 340 14 15 10 22 34 35 27 47Soluble reactive phosphorus (µg/L) --- 40 40 37 42 10 9 7 10 14 16 9 26Total Kjeldahl Nitrogen (mg/L) --- 0.8 0.9 <0.5 1.5 <0.5 <0.5 <0.5 <0.5 --- --- --- ---Nitrate+Nitrite (mg/L) --- 0.56 0.63 0.24 1.20 0.20 0.21 0.14 0.29 --- --- --- ---Fecal Coliform Bacteria (CFU/100 mL) 100/200 813609145330014 10 <1 63 15 11 <2 44Metals (µg/L)Copper, Total --- 8.9 8.6 4.9 11.7 5.7 5.2 3.6 6.2 2.9 3.5 2.0 5.8Copper, Dissolved 8.9 3.6 4.2 2.6 6.4 4.8 4.5 2.9 5.6 2.4 2.3 1.4 2.7Lead, Total --- 2.2 2.3 0.6 4.7 0.1 0.1 0.1 0.3 <1 <1 <1 <1Lead, Dissolved 30.1 <0.1 <0.1 <0.1 0.1 <0.1 <0.1 <0.1 <0.1 <1 <1 <1 <1Zinc, Total --- 35 36 24 51 2.4 2.1 1.2 2.7 <5 <5 <5 6Zinc, Dissolved 63.6 23 22 15 30 2.3 2.1 1.2 2.6 <5 <5 <5 <5Semivolatile Organic Compounds (µg/L)dAniline --- --- --- --- --- --- --- --- --- <0.10 0.31 <0.09 1.10Bis(2-ethylhexyl) phthalate --- <0.5 0.51 <0.5 0.6 J <0.5 0.62 <0.5 1.2 J <0.10 <0.10 <0.09 <0.10Di-n-butyl phthalate --- <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.10 <0.10 <0.09 0.12Pentachlorophenol 5.7 <2.6 <2.6 <2.6 <2.6<2.6 <2.6 <2.6 <2.6 <0.10 0.11 <0.09 0.16Bold values exceed surface water quality standard for freshwaters (FW) (WAC 173-201A).b Data for 8 storm event samples from a new crumb rubber field (Herrera 2010).c Geometric mean for fecal coliform bacteria, arithmetic mean for other parameters.d Results only for compounds detected in one or more samples. --- = Not analyzed or applicablea Fecal coliform criteria are based on the geometric mean/single sample maximum for primary contact recreation. Acute aquatic life criteria for dissolved metals are based on a 1-hour average concentration at a hardness of 50 mg/L as CaCO3. Acute aquatic life criterion for pentachlorophenol is based on a pH of 7.00 (WAC 173-201A).Table 4. Summary Statistics of Stormwater Quality at Bobby Morris, Miller, and Woodland Park Playfields.Bobby Morris Playfield Miller Playfield Woodland Park PlayfieldbParameterFW Acute Criteriona26December 2019Environmental Monitoring Report—Bobby Morris Playfield Renovation Pilot ProgramDocuSign Envelope ID: 529DAEA9-384A-4040-B382-5FEF2430D325