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C_PSE_Response_Letter_230816_v1
Puget Sound Energy P.O. Box 97034 Bellevue, WA 98009-9734 PSE.com July 27, 2023 Clark H. Close Principle Planner City of Renton Community & Economic Development Re: LUA23-000180 – PSE Responses to “On hold” Notice for Thermal Survey Borings for Replacement Cable Crossings Dear Mr. Close: Puget Sound Energy (PSE) would like to thank the City in its evaluation of its proposal and appreciates the opportunity to engage the City regarding the permitting. Please let this this document serve as a response to the City’s “On Hold” Notice letter dated June 28, 2023, regarding the above-mentioned permit application submitted by Puget Sound Energy (PSE). If you have any further questions or require further clarification feel free contact me at (206) 716-2754 or at Dylan.Marcus@pse.com. Sincerely, Dylan Marcus (He/Him) Associate Municipal Land Planner 6500 Ursula Place South | Seattle, WA 98108 (206) 716-2754 (office) | (206) 225-7568 (cell) Dylan.Marcus@pse.com Comments: 1. Address the following items from the U.S. Environmental Protection Agency (EPA): a. Update the No Effects Biological Evaluation Letter to acknowledge that Location I is within a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or Superfund site boundary so that the National Oceanic and Atmospheric Administration (NOAA) is made aware while reviewing the “No effects” determination. Response: To avoid disturbance to the CERCLA/Superfund site boundaries, Puget Sound Energy (PSE) has relocated Location I to approximately 150’ outside of the CERCLA/Superfund site boundary (see attached figure). Puget Sound Energy (PSE) has notified NOAA of this change and at this time does not anticipate changes to the “No effects” evaluation are necessary. i. See attached Quendall Terminals (QTS) Site Map (Figure 1.1-2) with the power transmission line compared to the offshore Operable Unit 2 (OU2) boundary for the cleanup of the QTS Superfund site. The offshore portion of the QTS Superfund site extends into Lake Washington (OU2) and covers about 29 acres. The figure shows that proposed borings/sampling would occur in an Enhanced Natural Recovery (ENR) area. Response: The bore/sample (Location I) has been relocated outside of the Operable Unit 2 (OU2) boundary and Enhanced Natural Recovery (ENR) area. b. Identify any action taken by Puget Sound Energy (PSE) to notify Quendall Terminals Responsible Parties (RPs) of PSE’s proposed sampling effort within OU2 and the proposed future plans to replace the cable crossings that go through OU2. If RPs have not yet been notified, provide a notification plan. Response: The bore/sample (Location I) has been relocated outside of the Enhanced Natural Recovery (ENR) area and therefore notification to the Quendall Terminals Responsible Parties (RPs) is not required at this time. However, if future plans to replace the cable crossing occur within the OU2 boundary, notification to RPs will be completed. c. Identify any BMPs that would contribute to no sediment disturbance or water quality impacts. Response: The bore/sample (Location I) has been relocated outside of the OU2 boundary. Best Management Practices (BMPs) include the use of an outer casing around the hollow-stem auger that encases the apparatus so turbidity cannot escape during the bore work. Drilling fluid and sediment generated during the bore will be collected into containment drums on the barge. The material will be characterized to identify the appropriate disposal process of the samples at an upland location once work is complete. i. Because the OU2 remedy has not occurred yet, PSE is able to anchor and collect a sample in OU2. Once OU2 is cleaned up, there will be Institutional Controls (ICs) that will restrict certain uses or activities. For example, no anchoring/no disturbances to protect the remedy. d. Provide a detailed timeline of the proposed borings and future plans to replace the cable crossings. Response: The bore/sample (Location I) has been relocated outside of the OU2 boundary. The sample at Location I is scheduled to be collected 9/26/23 and take approximately four (4) hours to complete. The purpose of the bore sample is to aid in the design and planning of a future potential replacement of the cable crossing. At this this time, there is not enough detail to share regarding a possible replacement. However, when a potential plan is identified, PSE will share and discuss with stakeholders. i. If possible, the EPA recommends that the replacement cable crossings be completed prior the OU2 Remedial Action (RA) activities or the location of the cable crossings be adjusted to avoid OU2 area. The RA includes placing a six-inch (6”) layer of clean sand to address low level contaminants in the sediment and to accelerate the rate of natural recovery. There will be institutional controls post remedy restricting OU2 remedy disturbance. If the remedy is disturbed, there will likely be requirements to characterize the area post disturbance, replenish and replace the cap and ENR material, and demonstrate the mitigation meets performance standards. Response: This is acknowledged. The timeline and design of a potential replacement of the cable crossing will be dependent on several factors such the results of the bore samples, permitting, and manufacturing of the cable. The timeline will also be driven by the integrity of the existing cable which is nearing the end of its life expectancy. If its replacement cannot avoid the OU2 area, the design will incorporate considerations of the OU2 area to meet any requirements before or after the remediation has occurred. e. Boring samples are proposed to be collected and removed from QTS Superfund site with the OU2 area. Characterize the material and identify the appropriate disposal process of the samples collected from the OU2 area. Response: The bore/sample (Location I) has been relocated outside of the QTS Superfund site and the OU2 boundary. However, PSE still intends to collect drilling fluid and sediment into containment drums on the barge. The material will be characterized to identify the appropriate disposal process of the samples at an upland location once work is complete Sources: Esri, Airbus DS, USGS, NGA, NASA, CGIAR, N Robinson, NCEAS, NLS, OS, NMA, Geodatastyrelsen, Rijkswaterstaat, GSA, Geoland, FEMA, Intermap and the GIS user community, Esri Community Maps Contributors, City of Bellevue, WA, City of Renton, King County, WA State Parks GIS, © OpenStreetMap, Microsoft, Esri, HERE, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, EagleView Technologies, Inc. The information on the attached map is subject to change without notice.Puget Sound Energy makes no representation or warranty of suitability of thisinformation for any purpose. This map is not to be used for determining theactual location of any PSE facilities. This document may contain Critical Energy Infrastructure Information (CEII), the use or disclosure ofwhich is restricted. Copyright ©2012. All rights reserved Property of Puget Sound EnergyMaps, Records and Technology355 110th AVE NE, BELLEVUE, WA, 98004NAD_1983_StatePlane_Washington_North_FIPS_4601_Ft Date: 7/25/2023 ± 0 90 180 27045US Feet Quendall Cable Station Parcel #29240HYDR Submarine Cable Thermal Testing 1:2,950 Boring Location I OU2 Boundary OU1 Boundary Aquatic Area King County Parcel Boundaries