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P:\841 Segale Properties\841008 Renton Fill Site\Correspondence\2022 Permit Mod Rqst Ltr\2022-06-27 Permit_Mod_Rqst_Ltr.docx Your Challenges. Our Priority. | farallonconsulting.com
June 27, 2022
Clark Close, Senior Planner City of Renton 1055 South Grady Way
Renton, Washington 98057
RE: REQUEST FOR PERMIT MODIFICATION UPPER BALCH PIT SPECIAL GRADE/FILL PERMIT (LUA-18-000703) 301 MONROE AVENUE NORTHEAST RENTON, WASHINGTON
FARALLON PN: 841-008
Dear Clark Close:
Farallon Consulting, L.L.C. (Farallon) has prepared this letter on behalf of Segale Properties LLC to support its request for a permit modification to the Special Grade/Fill Permit Number LUA-18-000703 (Grade/Fill Permit) for the property at 301 Monroe Avenue Northeast in Renton,
Washington (Upper Balch Pit). Specifically, this letter includes additional information requested by the City of Renton (City) to further support the proposed modification of the Grade/Fill Permit to exclude the requirement for completion of the City’s Fill Source Statement. An initial request for the permit modification was submitted to the City in the letter regarding Upper Balch Pit Special Grade/Fill Permit (LUA-18-000703), Request for Permit Modification dated April 21,
2022, from Jamie Schroeder of CPH Consultants to Clark Close of City of Renton (April 2022 Request Letter) and is attached for reference (Attachment A).
This letter includes a summary of Farallon’s review and evaluation of the following main documents:
• City of Renton, Water System Plan Update, A Comprehensive Water System Plan,
December 2012 (2012 Plan); and
• City of Renton, Water System Plan Update, Final May 2021 (2021 Plan).
The purpose of the review was to evaluate the delineation of the City’s Aquifer Protection Areas (APAs) at the Upper Balch Pit property in the 2012 Plan versus the updated 2021 Plan, and to
provide conclusions and recommendations regarding the potential exclusion of the Fill Source Statement requirement from the Grade/Fill Permit.
City of Renton
June 27, 2022 Page 2
P:\841 Segale Properties\841008 Renton Fill Site\Correspondence\2022 Permit Mod Rqst Ltr\2022-06-27 Permit_Mod_Rqst_Ltr.docx Your Challenges. Our Priority. | farallonconsulting.com
WATER SYSTEM PLANS
2012 WATER SYSTEM PLAN
In the 2012 Plan, the Upper Balch Pit property was included within APA Zone 2 as shown on Figure 2-3 (2012 Plan, Appendix L). However, it should be noted that the Upper Balch Pit property was outside of the modeled 10-Year Capture Zone for the Downtown Wellfield Capture Zones (2012 Plan, Appendix L, Figure 2-3).
2021 WATER SYSTEM PLAN
According to the 2021 Plan, the APAs were updated to be consistent with the modeled Wellhead Protection Area Capture Zones (WHPAs), which include 6-Month, 1-Year, 5-Year, and 10-Year Capture Zones as shown on Figure 1 (2021 Plan, Appendix J). The Upper Balch Pit property is
outside of the 10-Year Capture Zone (2021 Plan, Appendix J, Figure 1). In addition, the updated
2021 Plan included an assessment of parcels of possible elevated risk within the WHPAs in the City, including the Downtown WHPA. The Upper Balch Pit was/is not included as a parcel with possible elevated risk (2021 Plan, Appendix J, Figure 3). The updated 2021 Plan also included an evaluation of potential contaminant sources in the City WHPAs. No confirmed or potential
contaminant sources were identified at the Upper Balch Pit property (2021 Plan, Appendix J,
Figure 5).
CONCLUSIONS AND RECOMMENDATIONS
These data confirm that the Upper Balch Pit property is outside of the 10-year Capture Zone for the Downtown WHPA and has not been identified as a parcel with possible elevated risk and/or potential contaminant source, which is consistent with the historical and current land use. Further,
Segale Properties LLC plans to continue with requiring compliance with the Segale Fill Acceptance Standards and completion of a Segale Fill Source Statement prior to acceptance of fill material from future source sites as described in Exhibits B and C of the April 2022 Request Letter, respectively (Attachment A).
Based on these data, Farallon, on behalf of Segale Properties LLC, requests that the City update
the Grade/Fill Permit to exclude the requirement for a Fill Source Statement for the upper Balch Property.
City of Renton
June 27, 2022 Page 3
P:\841 Segale Properties\841008 Renton Fill Site\Correspondence\2022 Permit Mod Rqst Ltr\2022-06-27 Permit_Mod_Rqst_Ltr.docx
Your Challenges. Our Priority. | farallonconsulting.com
CLOSING
Farallon trusts this letter provides sufficient information to meet the requirements for the requested permit modification. Please contact me at (425) 295-0804 if you have questions or require additional information.
Sincerely,
Farallon Consulting, L.L.C.
J. Riley Conkin, L.G., L.H.G.Principal Geologist
Attachments: Figure 2-3, City of Renton 2012 Downtown Wellfield Capture Zones (2012 Plan, Appendix L)
Figure 1, City of Renton 2018 Wellhead Protection Area Capture Zones (2021 Plan, Appendix J)
Figure 3, Zoning and Parcels of Possible Elevated Risk Within Downtown WHPA
(2021 Plan, Appendix J)
Figure 5, Potential Contaminant Sources Within City of Renton Downtown WHPA (2021 Plan, Appendix J)
Attachment A, CPH Consultants April 21, 2022 Letter and Exhibits
cc: Mike Pruett, Mark Segale: Segale Properties LLC
Jamie B. Schroeder; CPH Consultants
JRC:cm
P:\841 Segale Properties\841008 Renton Fill Site\Correspondence\2022 Permit Mod Rqst Ltr\2022-06-27 Permit_Mod_Rqst_Ltr.docx
FIGURES
REQUEST FOR PERMIT MODIFICATION
Upper Balch Pit
Renton, Washington
Farallon PN: 841-008
2-7
Figure 2-3 Downtown Wellfield Capture Zones
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UPPER BALCH PIT(301 MONROE AVE NE)UPPER BALCH PIT(301 MONROE AVE NE)
P:\841 Segale Properties\841008 Renton Fill Site\Correspondence\2022 Permit Mod Rqst Ltr\2022-06-27 Permit_Mod_Rqst_Ltr.docx
ATTACHMENT A CPH CONSULTANTS APRIL 21, 2022 LETTER AND EXHIBITS
REQUEST FOR PERMIT MODIFICATION
Upper Balch Pit
Renton, Washington
Farallon PN: 841-008
Site Planning
Civil Engineering
Landscape Architecture
Project Management
Land Use Consulting
1 1 3 2 1 - B N E 1 2 0
t h S tr e e t | K i r kl a n d , WA 9 8 0 3 4 | ( 4 2 5 ) 2 8 5 - 2 3 9 0
1 0 1 S o u t h W e n a t c h e e A v e . , S u i t e C 3 | W e n a t ch e e , W A 9 8 8 0 1 | ( 5 0 9) 2 9 3 - 7 7 3 1
w w w . c p h c o n s u l t a n t s . c o m
April 21, 2022
Mr. Clark Close, Senior Planner
City of Renton
1055 South Grady Way
Renton, WA 98057
Sent via email: cclose@rentonwa.gov
RE: Upper Balch Pit Special Grade/Fill Permit (LUA-18-000703)
Request for Permit Modification
Mr. Close,
Our client, Segale Properties LLC, is requesting a permit modification to remove the requirement for a Fill
Source Statement by a professional engineer or geologist for the Upper Balch Pit Special Grade/Fill permit.
The site is located at 301 Monroe Ave NE and the permit was approved with the Hearing Examiner’s final
decision dated March 29, 2019 and the Determination of Non-significance-Mitigated (DNS-M) and
Environmental Review Committee Report dated February 18, 2019 (City Land Use File Nos. LUA18-000703,
ECF, SP). Condition no. 2 of the SEPA mitigation measures requires a Fill Source Statement to mitigate for
adverse impacts to the aquifer protection zone.
The request to remove the requirement is based on the fact that the project site is no longer delineated within
a Wellhead Protection zone per current City of Renton critical area mapping as shown on the COR Maps
website. The pit site was mapped within the Maplewood Wellhead Protection area at the time of the original
permit approval. Since that time, further studies by others have determined that the Upper Balch Pit site is
actually outside of wellhead and aquifer protection area. As such, a Fill Source Statement CERTIFIED BY A
PROFESSIONAL ENGINEER OR GEOLOGIST should no longer by applicable for the site and the permit.
The project will continue to meet requirements for clean fill sources; however, a certified statement would no
longer be required. The following documents are provided for your reference:
· Exhibit A – Original fill source statement (to be replaced with Exhibits B and C below)
· Exhibit B – Proposed Fill Acceptance Standards
· Exhibit C – Proposed Fill Source Statement
Please contact me directly at (425) 285-2392 or by e-mail at jamie@cphconsultants.com if you have
questions or need any additional information to complete your approval of this request. Thank you.
Sincerely,
CPH Consultants
Jamie B. Schroeder, PE
Vice President
Enclosures: Exhibits A, B, and C
Cc: Mike Pruitt, Segale Properties
DEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
1
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
A Fill Source Statement CERTIFIED BY A PROFESSIONAL ENGINEER OR GEOLOGIST licensed in
the State of Washington is required in the following circumstances:
1.More than 50 cubic yards of fill will be imported to a project site located in Zone 1 of
the Aquifer Protection Area.
2.More than 100 cubic yards of fill will be imported to a project site located in Zone 2 of
the Aquifer Protection Area.
Exception: A Fill Source Statement is not required if documentation is provided that the fill to
be imported comes from a Washington State Department of Transportation approved source.
It is required that fill material be sampled AT THE FILL SOURCE SITE and analyzed by a
laboratory to rule out contamination (see #11 below). A fill source site may qualify for an
ABBREVIATED FILL SOURCE STATEMENT (answer only #1 - #7 below) ONLY if the source site has
never been filled, developed, or subjected to use that could have introduced chemical
contamination to the site. The abbreviated format does not require sampling and analysis of fill
to detect contamination and, therefore, reduces applicant costs. Please see #12 and check the
appropriate certification.
A SEPARATE SOURCE STATEMENT IS REQUIRED FOR EACH FILL SOURCE SITE.
A copy of the Renton Municipal Code section requiring the Fill Source Statement is attached for
your information (RMC 4-4-060N).
CONTACT DEVELOPMENT ENGINEERING TO DETERMINE IF THE PROJECT SITE IS LOCATED IN
THE APA.
NOTE: The Department has the authority to request additional information regarding imported
fill material and to reject a source statement if it does not demonstrate that the fill material
meets City standards and/or the Department has reason to suspect that the fill material could
be contaminated. Such requests or rejections shall be made in writing to the applicant.
1.Project Site Address:
2.Project Site King County Tax Assessor Account Number:
3.In which Aquifer Protection Area Zone is the project site located 1 or 2? 1 2
4.Cubic yards of fill to be imported to project site:
5.Project applicant name:
6.Fill source site address:
7.Fill source site King County Tax Assessor Account Number:
FILL SOURCE
STATEMENT
FOR PROJECTS IN THE AQUIFER PROTECTION AREA (APA)
Planning Division | Development Engineering Section
1055 South Grady Way | Renton, WA 98057
(425) 430-7200 | www.rentonwa.gov
2
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
8. Current and all previous land uses at fill source site: (attach additional information if necessary)
a.
b.
c.
d.
9. Has the fill source site appeared on the following lists of contaminated sites?
a. Hazardous Sites List (per State Model Toxics Control Act) Yes No
b. National Priority List (Federal “Superfund” List) Yes No
10. Is the fill to be imported native to the fill source site? Yes No
11. Attach a copy of a SUMMARY ONLY of the results of sampling and analysis of fill
material from samples COLLECTED AT THE SOURCE SITE as required by RMC 4-4-
060N4 for projects located in Zone 1 and 2 of the Aquifer Protection Area. Follow
sampling and analysis procedures specified in N4 of the regulations.
12. Engineer’s or Geologist’s certification:
I, _________________________________________, a licensed professional engineer
or geologist in the State of Washington, certify that the above information is true and
correct and that the fill to be imported to the project site meets the City of Renton
fill quality standards stated in the Renton Municipal Code 4-4-060N4a and b.
ABBREVIATED FILL SOURCE STATEMENT CERTIFICATION:
I, _________________________________________, a licensed professional engineer
or geologist in the State of Washington, certify that the above information is true and
correct and that the source site does not appear on the Hazardous Sites List (per
State Model Toxics Control Act) or the National Priority List (Federal “Superfund
List”). To the best of my knowledge, fill to be imported to the project site meets the
City of Renton fill quality standards stated in the Renton Municipal Code 4-4-060N4a
and b and the source site has never been filled, developed, or subjected to use that
could have introduced chemical contamination to the site.
Signature: Date:
Mailing Address: Phone:
City/State: Zip:
Engineer’s or Geologist’s Stamp:
3
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
STAFF USE ONLY
Imported fill sources statement accepted Yes No
Reviewer Name: Date:
Comments:
4
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
Renton Municipal Code 4-4-060
Grading, Excavation, and Mining Regulations
N. FILLS:
1. Applicability and Exemptions: Unless otherwise recommended in the approved soil
engineering report, fills shall conform to the provisions of this Section. In the absence of an
approved soil engineering report, these provisions may be waived for minor fills not intended
to support structures. For minor fills or waste areas, humps, hollows or water pockets shall be
graded smooth with acceptable slopes.
2. Fill Location: Fill slopes shall not be constructed:
a. On natural slopes steeper than two-and-one-half horizontal to one vertical (2.5:1) that
are fifteen feet (15') or greater in height (except in conjunction with a modification
granted per RMC 4-9-250D1 for filling against the toe of a natural rock wall – see RMC 4-
3-050N2a(ii)(b)); or
b. Where the fill slope toes out within twelve feet (12') horizontally of the top of existing
or planned cut slopes that are fifteen feet (15') or greater in height and steeper than two-
and-one-half horizontal to one vertical (2.5:1). (Amd. Ord. 4835, 3-27-2000; Ord. 4851, 8-
7-2000)
3. Preparation of Ground: The ground surface shall be prepared to receive fill by removing
vegetation, noncomplying fill, topsoil and other unsuitable materials as determined by the soil
engineer, and where the slopes are five to one (5:1) or steeper, by benching into sound bedrock
or other competent material.
4. Fill Material: Fill materials shall have no more than minor amounts of organic substances and
shall have no rock or similar irreducible material with a maximum dimension greater than eight
inches (8"). Fill material shall meet the following requirements:
a. Construction, Demolition, and Land Clearing Waste Prohibited: Fill material shall be
free of construction, demolition, and land clearing waste except that this requirement
5
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
does not preclude the use of recycled concrete rubble per Washington State Department
of Transportation Standard Specifications for Road, Bridge, and Municipal Construction.
b. Cleanliness of Fill Material: Fill material shall not contain concentrations of
contaminants that exceed cleanup standards for soil specified in WAC 173-340-740,
Model Toxics Control Act.
c. Special Requirement for Projects Located in Zone 1 of the Aquifer Protection Area and
Which Will Involve Placement of More than Fifty (50) Cubic Yards of Imported Fill: A
source statement certified by a professional engineer or geologist licensed in the State of
Washington shall be provided to the Department and shall be reviewed and accepted by
the Department prior to stockpiling or grading imported fill at the project site. The source
statement, as defined in RMC 4-8-120D19, shall be required for each source location from
which imported fill will be obtained.
d. Special Requirement for Projects Located in Zone 2 of the Aquifer Protection Area
and Which Will Involve Placement of More than One Hundred (100) Cubic Yards of
Imported Fill: The source statement described in RMC 4-8-120D19 is required for each
source location from which imported fill will be obtained.
e. Abbreviated Source Statement for Aquifer Protection Area: The Department may
accept a source statement, as defined in RMC 4-8-120D19, that does not include results of
sampling and analysis of imported fill if a professional geologist or engineer licensed in
the State of Washington certifies that the source location from which fill will be obtained
has never been filled, developed, or subjected to use that could have introduced chemical
contamination to the site.
f. Department Authority to Request Additional Information or Reject Certified Source
Statement: The Department has the authority to request additional information regarding
imported fill material and the source thereof and to reject a source statement or
abbreviated source statement if they do not demonstrate that the fill material to be
imported to a project site meets fill material standards in subsections L4a and L4b of this
Section and/or the Department has reason to suspect that the fill material could be
contaminated. Such requests or rejections shall be made in writing to the applicant.
6
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
g. Source Statement Not Required for Imported Fill Obtained from Washington State
Department of Transportation Approved Source: The source statement defined in RMC
4-8-120D19 is not required for those projects located in the aquifer protection area if
documentation is provided that imported fill will be obtained from a Washington State
Department of Transportation approved source. (Amd. Ord. 4851, 8-7-2000)
h. Sampling and Analysis Procedures: The licensed professional engineer or geologist or
person under their supervision who samples earth materials to be used as imported fill,
oversees analysis, and prepares the source statement required by subsections L4c and
L4d of this Section shall follow procedures specified in WAC 173-340-820 and 173-340-
830 of the Model Toxics Control Act Cleanup Regulation.
i. Permittee Subject to Required Actions after Illegal Placement of Imported Fill: A
permittee who stockpiles or grades imported fill at the site without Department review
and acceptance of the source statement required by subsections L4c and L4d of this
Section or who stockpiles or grades fill at the site that does not meet the fill quality
standards of subsections L4a and L4b of this Section is subject to measures specified by
the Department to reduce risk of contamination of the site due to illegal placement of fill.
Such measures may include, but are not limited to, any or all of the following and shall be
implemented at the permittee’s expense:
i. Provide the Department with the source statement defined in RMC 4-8-120D19
within a time-period specified by the Department;
ii. Immediately cover fill with a waterproof cover;
iii. Immediately remove fill;
iv. Installation of monitoring wells and monitoring of ground water quality;
v. Remediation of contamination of the site caused by the illegal placement of fill
according to a schedule specified by the Department and in accordance with cleanup
standards for soil and groundwater described in the Model Toxics Control Act
Cleanup Regulation, chapter 173-340 WAC.
7
H/CED/Data/Forms-Templates/Self Help Handouts/Pubic Works/Fill Source Statement.doc Rev: 08/2015
j. Department Authority to Conduct Independent Sampling and Analysis: The
Department shall have the authority to enter on to private property to conduct
independent sampling and analysis of fill. If the Department determines that fill does not
meet fill quality standards of subsections L4a and L4b of this Section, then it may require
the permittee to accomplish any or all of the measures listed in subsection L4i of this
Section at his or her own expense.
k. Department Authority to Implement Removal and Remediation Measures: The
Department or its authorized agents shall have the authority to implement measures
listed in subsection L4i of this Section if the permittee fails to accomplish such measures
in a timely manner. The permittee shall be responsible for any costs incurred by the
Department or its authorized agents in the conduct of such activities. (Amd. Ord. 4740, 7-
19-1999; Ord. 4992, 12-9-2002)
5. Minimum Compaction: All fills shall be compacted to a minimum of ninety five percent (95%)
of maximum density as determined by American Public Works Association (APWA)
specifications. Field density shall be determined in accordance with APWA standards.
6. Maximum Slope: The slope of fill surfaces shall be no steeper than is safe for the intended
use. Except in conjunction with a modification granted per RMC 4-9-250D1 for one of the
circumstances listed in RMC 4-3-050N2a(ii) (Geologic Hazards – Modifications), fill operations
associated with a plat, short plat, subdivision or dedication, or other permitted land
development activity which would result in the creation of permanent slopes forty percent
(40%) or greater which are fifteen feet (15') in height, i.e., protected slopes, shall not be
approved. (Amd. Ord. 4835, 3-27-2000)
7. Drainage and Terracing: Drainage and terracing shall be provided and the area above fill
slopes and the surfaces of terraces shall be as required by subsection N of this Section. (Ord.
5526, 2-1-2010)
2029 002 ma05d404q6
EXHIBIT B
FILL ACCEPTANCE STANDARDS
Fill material shall have no amount of organic substances and shall have no rock or
similar irreducible material with a maximum dimension greater than eight inches (8”). It
shall be free of construction, demolition, concrete or concrete rubble, and land clearing
waste.
No soil or other material shall contain any detectable listed “dangerous wastes” as
defined under Chapter 173-303 WAC.
No soil or other material shall contain any detectable “hazardous substances” as defined
under the Model Toxics Control Act, Chapter 70.105D RCW, and its implementing
regulations, Chapter 173-340 WAC. All soil or other material shall be classified as a
Category 1 Soil1 that contains no detectable petroleum hydrocarbons, constituents, or
additives.
No soil or other material shall contain any “problem waste” as defined under Chapter
173-304 WAC including without limitation asbestos and biological wastes such as
sludge or sewer solids.
No soil or other material shall contain any liquid or putrescible waste.
For purposes of these Fill Acceptance Standards, “detectable” concentrations shall be
those identified by the use of the appropriate laboratory analytical methods as required
under federal and/or state regulatory standards and/or guidance. All laboratory
analyses shall be conducted by a Washington State Department of Ecology-accredited
laboratory.
1 Department of Ecology Publication No. 10-09-057, June 2016, table 12.2
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Rev: 4/2022
FILL SOURCE STATEMENT
SP#___________
A Fill Source Statement is required when any amount of fill will be imported to the
Facility.
It is required that fill material be sampled AT THE FILL SOURCE SITE and
analyzed by a laboratory to rule out contamination.
A SEPARATE SOURCE STATEMENT IS REQUIRED FOR EACH FILL SOURCE SITE.
NOTE: Segale has the authority to request additional information regarding
imported fill material and to reject a Fill Source Statement if it does not
demonstrate that the fill material meets Fill Acceptance Standards and/or Segale
has reason to suspect that the fill material could be contaminated. Such requests
or rejections shall be made in writing to the Customer.
Fill out #1 – 10 below to complete the Fill Source Statement:
1. Facility Address: 301 Monroe Ave NE, Renton
2. Facility King County Tax Assessor Account Number: 1623059059
3. Cubic Yards of Fill to be Imported to Facility:
4. Project Customer Name:
5. Fill Source Site Address:
6. Fill Source Site King County Tax Assessor Account Number:
7. Current and all previous land uses at Fill Source Site: (attach additional information if
necessary)
a.
b.
c.
d.
8. Has the fill source site appeared on the following lists of contaminated sites?
a. Hazardous Sites List (per State Model Toxics Control Act) Yes No
b. National Priority List (Federal “Superfund” List) Yes No
9. Is the fill to be imported native to the Fill Source Site? Yes No
10. Attach a copy of all environmental reports for the Fill Source Site and results
of sampling and analysis of fill material from samples COLLECTED AT THE
FILL SOURCE SITE.