HomeMy WebLinkAboutmem_thunder_permit analysis alt 1-2_Memo 9
CITY OF RENTON
Technical Memorandum No. 9
Permitting Assessment Alternatives No. 1 & 2
Thunder Hills Sanitary Sewer Interceptor Alternative Analysis
October 19, 2015
Prepared By:
Rebecca Saur
Stantec Consulting Services Inc.
11130 NE 33rd Place
Suite 200
Bellevue, WA 98004
425.869.9448
ALTERNATIVES NO. 1 & 2 Thunder Hills Sanitary Sewer Interceptor
Permitting Assessment
October 19, 2015
Contents
1.0 INTRODUCTION ............................................................................................................. 1
2.0 PERMIT REQUIREMENT SUMMARY ................................................................................. 1
2.1 CITY OF RENTON PERMITS ................................................................................................. 2
2.2 WILLIAMS NORTHWEST WILSOP ENCROACHMENT/FOREIGN LINE CROSSING
PERMIT ................................................................................................................................ 2
2.3 PUGET SOUND ENERGY CONSENT FOR USE ................................................................... 3
2.4 USARMY CORPS OF ENGINEERS (USACE) SECTION 404 PERMIT .................................. 3
2.5 NATIONAL POLLUTANT DISCHAGE ELIMINATION SYSTEM (NPDES) PERMIT................. 3
2.6 KCWTD APPROVAL ........................................................................................................... 3
2.7 HYDRAULIC PERMIT APPROVAL ....................................................................................... 4
2.8 NATIONAL HISTORIC PRESERVATION ACT SECTION 106 ............................................... 4
2.9 PERMIT MATRIX – ALTERNATIVES NO. 1 AND NO. 2 ....................................................... 5
3.0 ADDITIONAL STUDIES .................................................................................................... 6
4.0 CONCLUSION ................................................................................................................ 6
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx i
ALTERNATIVES NO. 1 & 2 THUNDER HILLS SANITARY SEWER INTERCEPTOR
PERMITTING ASSESSMENT
October 19, 2015
1.0 INTRODUCTION
This memorandum evaluates permitting requirements for design Alternatives No. 1 and 2 as
assessed during the Thunder Hills Sanitary Sewer Interceptor Alternative Analysis. The goals of the project are to provide a comprehensive assessment of improvement alternatives to the existing
sewer, accounting for ultimate flows, provide maintenance access to the entire project
alignment, and to protect the integrity of the sewer and access improvements from
environmental impacts and vice versa.
Alternative No. 1 proposes to improve the existing access from the portion of the interceptor
south of Interstate 405 to roughly Station 6+00. This portion of the access improvements will be
narrow, with only enough width to allow the City’s “easement” machine in this area to perform
the maintenance. From Station 6+00 south, proposed improvements include adding a turnaround at Station 6+50, building a new access road across PSE property at Station 15+00,
and rebuilding the entrance road at Station 30+00. Along the alignment, a new parallel sewer is
planned to be installed from approximately Station 3+28 to 11+20 and 13+08 to 15+44; the remaining portion of the existing sewer will be rehabilitated using CIPP technology. The existing rock buttresses will protect improvements north of Station 6+00.
Alternative No. 2 proposes to divert upstream flows from the Thunder Hills Interceptor at Grant
Avenue South. Alternative No. 2 also includes the same improvements as Alternative No. 1 from the interceptor south of Interstate 405, along the current alignment up to Station 24+00, but with
no additional sewer improvements proposed south of this station along Thunder Hills Creek.
Alternative No. 2 additionally proposes sewer main upgrades within the Talbot Hill Sewer Basin,
including upsizing a section of sewer within Benson Road South (between the north and south extents of Eagle Ridge Drive South) to 10-inch main, adding an 8-inch diversion pipe in South 18th
Street from Grant Avenue South to Eagle Lane South, upsizing main to 12-inch pipe from Eagle
Lane South to Eagle Ridge Drive, and upsizing sewer to 12-inch main in the vicinity of Benson
Drive South and Smithers Avenue South (between South 15th Street and Interstate 405). Preliminary plans for Alternative No. 2 are under development.
2.0 PERMIT REQUIREMENT SUMMARY
A route analysis has been completed for the project, taking into consideration environmental,
cost, and sewer system impacts of each alternative. The permitting is typical for this type of project with a primary concern of maintaining the integrity of the sensitive areas along the
project route. Project permits will be based on preliminary design plans dated August 21, 2015,
and are identified and discussed herein. For purposes of presenting a comprehensive permit
summary, both alternatives have been considered in the following discussion. A matrix detailing each alternative and associated permits, timelines, submittal fees, and submittal requirements is
included at the end of this section. The permitting assumptions and estimate herein were based
on the best available information at the time and are subject to update/modification.
Other independent sensitive area reviews are being conducted and preliminary assessment memorandums will be issued concurrently.
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx 1
ALTERNATIVES NO. 1 & 2 THUNDER HILLS SANITARY SEWER INTERCEPTOR
PERMITTING ASSESSMENT
October 19, 2015
2.1 CITY OF RENTON PERMITS
The project lays in its entirety within the City of Renton. A pre-application meeting with the City’s
Planning Department is recommended for this project due to the amount of sensitive areas along the project route.
A Land Use Permit Application (LUP) will be required which will be processed by the Planning
Department. There are other City permits which will be processed with the LUP, including the
following:
• Variance – The burden of proof in justifying proposed improvements lies with the permit applicant. A project narrative will be developed discussing project alternatives and
benefits of the chosen alternative, adverse environmental impacts avoided, adverse
environmental impacts mitigated, and requesting approval of construction parameters as well as permanent improvements within critical areas and their buffers.
• Grading – Approval of the proposed project grading plans, including review of
consultant reports, restoration/mitigation plans, site issues, etc. It is presumed any tree
removal will not trigger any additional permit requirements or reviews by the City.
• Environmental Review – This review includes processing of the project SEPA. The
preliminary plans show construction of permanent improvements within wetlands and
streams adjacent to the project route. A USACE 404 permit will be required due to this
work. The potential of dual lead agencies and NEPA are further discussed under Item No. 2.4 below. It is anticipated that the Determination for this project would be a
Mitigated DNS, where the City provides mitigation for specific project elements
impacting the environment. The City will review any sensitive area reports and mitigation
plans under this permit.
Additional City of Renton permits which may be required for this project include building permits
for the rockeries or gravity walls along the southern portion of the project, and right of way
permits for any work within City of Renton Right of Way.
This assessment does not take into consideration any permit exemptions the project owner, the City of Renton Public Works Department, may have with regard to obtaining permits from other
departments within the City.
It is anticipated that City of Renton permits will take 3 – 5 months.
2.2 WILLIAMS NORTHWEST WILSOP ENCROACHMENT/FOREIGN LINE CROSSING PERMIT
As the proposed project alignment crosses over Williams NW pipelines, Williams will need to review and approve the project design drawings. Williams will review project plans and set forth
guidelines the contractor will be required to adhere to in an effort to protect their pipeline
facilities long term as well as during construction, to be included in the City’s bid specification documents. A separate permit will be signed directly between the contractor and Williams prior
to constructing the pipeline crossing.
For purposes of this assessment, it is assumed that Williams NW is the pipeline owner. This has yet
to be verified, however.
The estimated timeline for Williams NW to approve the project plans is approximately 4 – 6
weeks.
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx 2
ALTERNATIVES NO. 1 & 2 THUNDER HILLS SANITARY SEWER INTERCEPTOR
PERMITTING ASSESSMENT
October 19, 2015
2.3 PUGET SOUND ENERGY CONSENT FOR USE
As the proposed project crosses through Puget Sound Energy (PSE) owned land, a PSE consent
for land use agreement is required. A PSE LUA in essence is an easement from PSE granting the City of Renton use of their property under a set of restrictions set forth in an agreement to protect PSE’s use and ability to maintain their property/facilities.
Recent experience with PSE LUA’s has taken 12 – 15 months for review and final execution of the
agreement, although the timeframe for this project may be less.
2.4 US ARMY CORPS OF ENGINEERS (USACE) SECTION 404 PERMIT
The proposed project plans show construction within and installation of permanent improvements within wetlands and streams adjacent to the project route. A USACE permit is
required prior to discharging dredged or fill material into the waters of the United States,
including special aquatic sites such as wetlands. Examples of activities which may trigger this permit are grading or clearing, placement of rip rap, or road fill within a wetland or stream.
Close communication with the USACE is prudent for this project. The project may be burdened
with additional requirements as a federal agency, the USACE, could be considered a second
lead agency for the project Environmental Checklist, as well as trigger requirements to follow federal NEPA regulations in addition to state requirements.
Once the project alignment and final alternative has been selected, prompt coordination with
the USACE is recommended to determine the level of USACE permit requirements the local
office would expect for this project. An ESA Section 7 Consultation could also be triggered by a 404 permit review, where the US Fish & Wildlife Service and National Marine Fisheries Service
would conduct a review of the project for impacts to endangered species found in the project
area. A Section 401 Water Quality Certification will also be required by the WA State
Department of Ecology (DOE), certifying that DOE anticipates the project will comply with state water quality discharge and aquatic resource protection standards.
USACE and associated permitting typically take 12 – 18 months for issuance.
2.5 NATIONAL POLLUTANT DISCHAGE ELIMINATION SYSTEM (NPDES) PERMIT
An NPDES permit is issued by DOE for construction projects disturbing an acre or more. The
permit process includes a public notice and comment period as part of the permit review process. Development of a project Stormwater Pollution Prevention Plan (SWPPP) is required for
this permit. The approved permit is typically transferred to the contractor to manage the SWPPP
during construction and permit close out with DOE.
It is estimated that an NPDES permit would be approved in 6 to 8 weeks.
2.6 KCWTD APPROVAL
King County Wastewater Treatment Division (KCWTD) reviews any proposed plans for sewer
improvement projects within King County.
KCWTD approvals typically take 2 – 4 weeks for approval.
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx 3
ALTERNATIVES NO. 1 & 2 THUNDER HILLS SANITARY SEWER INTERCEPTOR
PERMITTING ASSESSMENT
October 19, 2015
2.7 LIMITED ACCESS RIGHT OF WAY PERMIT
The Alternative No. 2 concept involves a sewer crossing of State Route 515 (aka Benson Drive
South). As such, a limited access right of way permit will be required from the Washington State Department of Transportation (WSDOT). The right of way permit from WSDOT could potentially take up to a year to obtain, however, for this type of work it is anticipated to take closer to six
months. The permit application process involves completing an application and submittal along
with project design plans, fees, and a performance bond to WSDOT for their review and
approval of the crossing design. WSDOT typically has a set of conditions the City’s contractor
will be required to follow during construction within their right of way.
2.8 HYDRAULIC PERMIT APPROVAL
The Washington State Department of Fish & Wildlife (DFW) administers Hydraulic Permit Approvals
(HPA). Any construction projects or activities in or near state waters are required to obtain permit coverage under an HPA. The HPA permit is required for the DFW review of the
improvements under Thunder Hills Creek as well as the work associated with culverting Stream G.
The application is submitted via an online portal which converts the data into a Joint Aquatic
Resources Permit Application form (which can also be utilized for other relevant permit applications for the project).
It is anticipated that a project HPA approval would be issued 4 – 6 weeks from submittal.
2.9 NATIONAL HISTORIC PRESERVATION ACT SECTION 106
Federal permitting for the project will also trigger a cultural resource review by the Washington
State Department of Archaeological and Historic Preservation (DAHP). This permit involves preparing a cultural resource inventory and evaluation report, submitting to DAHP for review,
monitoring during construction (if required by DAHP’s review of the initial report), and submitting
a monitoring report to DAHP if any field work is required during construction.
DAHP approvals are dependent on meaningful cultural information found on or near the project site. Provided the site has minimal cultural relevance, it is anticipated DAHP review of the
cultural resource inventory report would take approximately 4 – 6 weeks.
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx 4
ALTERNATIVES NO. 1 & 2 THUNDER HILLS SANITARY SEWER INTERCEPTOR
PERMITTING ASSESSMENT
October 19, 2015
2.10 PERMIT MATRIX – ALTERNATIVES NO. 1 AND NO. 2
*Alternatives No. 1 and No. 2 have the same basic components which in turn trigger similar permit requirements. While Alternative No. 2 shares the same design elements as Alternative No.
1, it has a greater amount of work in the right of way. Generally, both alternatives have the
same permit requirements, other than the additional right of way permits for Alternative No. 2.
There is also the potential for additional coordination with WSDOT for the right of way use permit
for work in State Route 515 with Alternative No. 2.
Agency Permit Timeline
from Submittal
Fees Alternative
No.*
City of Renton • Land Use
• Grading
• Variance
• Environmental Review
• Building
• Right of Way
4 – 6 Months Internal City Fees 1 & 2
2
Williams NW WilSOP Permit 4 – 6 Weeks No Review Fee 1 & 2
Puget Sound Energy Consent for Use 12 – 15
Months
To Be
Determined
1 & 2
US Army Corps of
Engineers
• Section 404
• ESA Section 7
• DOE Section 401
12 – 18
Months
Submittal Fee =
$100
1 & 2
Department of Ecology NPDES 6 – 8 Weeks Fees Relating
to Notice of
Intent Advertisement
1 & 2
King County Water Treatment
Division Review
2 – 4 Weeks No Review Fee 1 & 2
Washington State Department of
Transportation
Limited Access Right of Way
Permit
6 – 12 Months Submittal Fee = $300 2
WA State Department of
Fish & Wildlife
HPA 4 – 6 Weeks Submittal Fee =
$150
1 & 2
Washington State Department of
Archaeological and
Historic Preservation
DAHP Review 4 – 6 Weeks No Review Fee 1 & 2
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx 5
ALTERNATIVES NO. 1 & 2 THUNDER HILLS SANITARY SEWER INTERCEPTOR
PERMITTING ASSESSMENT
October 19, 2015
3.0 ADDITIONAL STUDIES
It is anticipated that the following consultant reports will be necessary to submit for permits on
the Alternative No. 1project:
• Biological/Habitat Assessment
• Wetland & Stream Delineation
• Geotechnical Evaluation
• Cultural Resource Inventory and Evaluation
4.0 CONCLUSION
This permitting assessment of Alternatives No. 1 and 2 is based on preliminary project plans.
Additional, more definitive information such as a determination of the quality of aquatic areas
surrounding the project site, redirection of/culverting of streams along the project route, and/or the installation of new/improving the existing rock buttresses/gabion walls within Thunder Hills
Creek or its bank could impact permit requirements.
A comprehensive list of permits and requirements will progress with the development of project
design plans and consultant reports. Advancement of the project design will allow for project impacts to be discussed and planned for with other agencies, to help streamline the permitting
process.
rs v:\2002\active\2002003607\analysis\permitting\mem_thunder_permit analysis alt 1-2_final.docx 6