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CR 98-66 Environmental Assesment WorksheetApril 29, 1998 Supporting Documents. • Analysis of Issues • Resolution 98 -24 • Response to comments • Letter from Derek Johnson • Letter from agencies Nancy '1 Anderson, AICP Planner Council Report 98 -66 ENVIRONMENTAL ASSESSMENT WORKSHEET-- HENNEPIN COUNTY SITE Proposed Action. Staff recommends the following motion: Move to approve Resolution 98 -24, accepting the EAW for the redevelopment of the Hennepin County site and determining that an EIS is not needed. Overview. An EAW (environmental assessment worksheet) is required for the redevelopment of the Hennepin County site. An EAW is a brief document that is designed to set about the basic facts necessary to determine whether an EIS (environmental impact statement) is required for a proposed project or to initiate the scoping process for an EIS. An EAW is also required to be distributed to various governmental agencies for their comments. The EAW that was prepared was for the larger development first proposed by SuperValu. The development has been scaled down to a smaller development. Based on the comments reviewed from the various agencies that responded, staff is recommending that an EIS in not required based, on the finding that the proposed development does not have the potential for significant environmental effects. Rob Bouta, a senior environmental scientist from Westwood Professional Services, Inc., prepared a response to comments on the EAW. Mr. Bouta determined, based on the responses to comments and the Findings of Fact, that the City Council should make a "Negative Declaration" and an EIS is not required. The response to comments from Mr. Bouta is attached. Derek Johnson, an environmental project specialist from HKS, reviewed the EAW for the . City and in his opinion an EIS is not needed. The letter from Mr. Johnson is attached. Primary Issues to Consider. • Have there been any comments about the EAW from the agencies reviewing the EAW? • Have there been any negative comments from the agencies submitted? • What was the scope of the project reviewed? CR98 -6 6 2 Primary Issues to Consider. o Have there been any comments about the EAW from agencies reviewing the EAW? The following agencies have submitted comments on the EAW: • Minnesota Department of Natural Resources • Metropolitan Council • Minnesota Department of Health The following are the comments: Metropolitan Council Items 8 — Permits and Approvals Required Sanitary sewer service connection plan for the proposed project will need to be submitted to the Metropolitan Council Environmental Services Municipal Services staff in addition to the Minnesota Pollution Control Agency for review, comment, and issuance of a construction permit before connection can be made to either the municipal or metropolitan wastewater disposal system. Minnesota Department of Health 1. Asbestos. MDH regulates removal or disturbance of asbestos - containing material from commercial or residential buildings for the protection of public health. These regulation mandate licensure of contractor and individuals conduction asbestos - related work and the safe work practices associated with this type of work. The Minnesota Pollution Control Agency regulated proper handing and disposal of asbestos - containing material, and the Minnesota Department of Labor and Industry regulated protection of asbestos workers. For additional information, please contact the MDH asbestos program. 2. Plumbing Code. Please not the Minnesota Plumbing Code Specifies that a buried sewer or drain be located at least 10 feet from a buried water service line or if this distance cannot be maintained, the installation and materials must comply with Minnesota Rules Chapter 4715.1710, subp. 2 ( Minnesota Plumbing Code). Questions should be directed to the local plumbing administrative authority or the state plumbing regulation program. 3. Plumbing Plan Approval. Plumbing plan approval will be necessary for this project, prior to beginning any construction. Please call the state plumbing regulation program. 4. Sewer Stubs. We recommend careful planning to consider where to locate stubs for any city trunk sewers and future service lines or other connection, in order to maintain the isolation distance from wells and buried water service lines. 5. Well Inventory. Item 13. A. (p.8) stated that a Phase I Environmental Site Assessment (ESA) was completed by Braun Intertec. We acknowledge the information found in the CR98 -66 3 EAS was that three monitoring wells were installed in 1993 on the Hennepin County public Works site, and one of them has since been removed. We appreciate the effects that were made to find wells on the site. However, because this project involves several different properties and there and some ambiguities involving past ownership and /or control of same of the properties, we feel that the level in investigation in the past may not have been adequate to definitively locate all wells which may exist on the project site. For example, the EAW stated no wells were found in the County Well Index (CWI); however, Appendix A (p. A41) acknowledges that CWI in an incomplete database. Although several people were interviewed to determine information about wells, the appendix acknowledges that no personnel form Engineered Building Components (EBCO) were available to be interviewed (p. A45), and that two of the interviewees did not know about the monitoring wells (p. A41) on the Hennepin County property. We acknowledge that Braun Intertec stated that on their site reconnaissance no wells were observed on the EBCO, General Resources Corporation (GRC) or Robert Lawrence properties (p.41). However, it is stated that they were not diver access to the Robert Lawrence property at that time (pp. A4, A40, and A45), so their observation was from adjacent propertied and public rights -of -way. Also, the time labeled as "Figure 1 Study Area" (cp. C4) in Appendix C lists Thompson Lumber Company and Former Country Club Market on part of the project site; however, no information about possible wells connected the these two businesses is given. In addition, excerpts in Appendix A (p. A25) indicate that numerous other companies were previously listed as having addresses on different part of the project site, but it is ambiguous whether all of these businesses were only lease tenant or whether any of them own(ed) any part of the project property. In any case, no well information was noted in the included excerpts relative to any of their other business names. Finally, there in no information suggesting the site reconnaissance evaluated the road or railroad rights -of -way. Sometimes forgotten wells are discovered along such right -of- way. As an example, our database shows three wells were installed by the Hennepin County Regional Railroad Authority in T117N R19W, Section 19 in 1996, and they were sealed in 1997. It is not clear whether the property where these wells were installed will become part of this project site. However, we caution project proposes that data bases are not all encompassing, so reviewing records is not a substitute for a field survey. It has been our experience that wen old wells exist form part land uses, information frequently not passed on when the land is sold or transferred. Therefore, we recommend that a field well inventory be performed to determine if there are any existing water supply wells (active or unused, unsealed) specifically across the portion of the property where any construction or demolition will take place. Special attention should be made along the proposed routes or new sewer lines, any sewer line(s) to be replaced, and any large diameter stormwater pipes, to ensure that isolation distance will be met. Additional specific areas to search include the vicinity of all building pads, and all proposed roadways, driveways, and parking lots. Particular attention should be made in the areas shown on air photos, old maps etc. where any homes, farmsteads, or old industrial well may have been located on this property, where any digging or grading will take place, as will a along property boundaries where wells on adjacent properties may still exist. Pleas CR98-66 4 note that, in addition to wells used for providing drinking water, the inventory should include any other monitoring wells, irrigation wells, sand - point, and other wills used for non - potable purposes. 6. Community Public Water Supply. Pleas note, however, the isolation distance from a community public water supply well is no less than 50 feet for all types of sewer lines or sewage contamination sources. 7. Stormwater Drain Pipes. Minnesota Rules, Chapter 4725 specify that the setback distance between water supply wells and stormwater pipes or conduits must be 20 feet if the pipe is 12 inches is diameter or greater; there is no setback distance requirement if the pipe is less than 12 inches in diameter. If the pipe carries sewage or sewage can back up in the pipe, the piping is considered a sewer, not a stormwater drain. 8. Construction Activities. Minnesota Rules, Chapter 4725 also require that construction activities not bury any well. 9. Unused Wells. MDH requires that any unused, unsealed wells be brought into operation condition or be sealed by a licensed well contractor, according to the Minnesota Rules, Chapter 4725. An unused, unsealed well may also be addressed by obtaining an annual maintenance permit ($100 fee) form the MDH. Maintenance permits are granted only if the well meets certain conditions. Once a well is sealed by a licensed well contractor I accordance with requirements of the rules, the isolation distance is no longer an issue. 10. Sealing Well(s) Prior to Other Work. We recommend that the work be completed for any well(s) to be sealed before beginning other types of construction, because the isolation distances apply in all cases until a well is sealed. In case the water supply for the site would ultimately not be able to connect to city water service, please not the following: 11. New Well. Any new well must be installed by a licensed well contractor and meet all other requirements of Minnesota Rules, Chapter 4725. 12. Public Water Supply. If a drinking water supply well would serve 25 or more persons for more than 60 days a year, the owners should be aware that the water supply will have to comply with Minnesota Rules, Chapter 4720 (public water supply program). 13. Human Remains. We note that a cemetery was located on this land parcel at one time. Appendix A (p.A3) State that the human remains were relocated to another site in 1953, but due to poor records it is possible that additional remains may yet be present in the site. The rules specify that the minimum isolation distance between a water supply well and a grave is 50 feet, Therefore, if a well must be construct, we recommend a complete site investigation be made in the area chosen for the well, to determine if there could by any human remains within the setback distance, if any remains or to the evidence of the cemetery is found, we recommend that the area be surveyed and staked prior to well construction, so the location information is available to the well contractor(s). • CR98 -' Fk 5 Minnesota Department of Natural Resources Our only comment on the project pertains to issues of stormwater runoff management discussed in Item 18. There are recurrent problems with sediment filling a ditch tributary to None Mile Creek that comes off the property. Operation at the Hennepin County Public Works Department likely contributed to this sedimentation problem. Because the runoff generated by the project will be treated to Nation Urban Runoff Program (NURP) standards, we believe the project will result in an improvement of the water quality of runoff leaving the site. As such, ongoing impacts to Nine Mile Creek will likely be reduces as a result of the project. The letters from the agencies are attached. o Have there been any negative comments from the agencies submitted? None of the agencies has submitted comments that would require an environmental impact statement. A response to the comments is contained within the report from Westwood Professional Services, Inc. 0 What was the scope of the project reviewed? The EAW reviewed a larger project than is proposed now. The following was the scope of the project reviewed: Alternatives. • 27,840 square feet of office • 537,200 square feet of warehouse • 35,000 square feet of a maintenance area. The project also involved accuring several abutting properties and vacating abutting streets. 1. Accept the EAW and determine that an EIS is not needed. By accepting the EAW and determining the redevelopment of the Hennepin County site poses no potential for significant environmental effects, an environmental impact statement is not needed. 2. Do not accept the EAW and determine that an EIS is needed. By not accepting the EAW, the City Council must determine that there are significant environmental effects and that an environmental impact stated is needed. If the City Council considers this alternative, findings will have to be identified that support this alternative. 3. Continue for further information. If the City Council indicates that further information is needed, the item should be continued. CITY OF HOPKINS • Hennepin County, Minnesota RESOLUTION NO: 98 -24 RESOLUTION MAKING FINDINGS OF FACT AND ACCEPTING AN ENVIRONMENTAL ASSESSMENT WORKSHEET AND DETERMINING THAT AN ENVIRONMENTAL IMPACT STATEMENT IS NOT NEEDED WHEREAS, Minnesota Rules Part 4410.4300 subp. 14.A(2) requires that an EAW be prepared for construct of a warehousing or light industrial facility equal to or greater than 300,000 square feet in a third or fourth class city; and WHEREAS, Minnesota Rules Part 4410.1700 Subp. 9 require that multiple phases be considered as a single project; and WHEREAS, on March 12, 1998, an EAW was completed for a commercial warehouse development project known as the SuperValu Distribution Center, which is ultimately planned to include 600,040 square feet of warehouse and office to be located in the vicinity of the existing Hennepin County Public Works facility; WHEREAS, on March 12, 1998, copies of the EAW were distributed to all person and agencies on the official Environmental Quality Board (EQB) mailing list and other interested parties; and WHEREAS, on March 23, 1998, the EAW was publicly noticed in the EQB Monitor, commencing the 30 -day public comment period;and WHEREAS, on March 12, 1998, a press release was submitted for publication in the Hopkins Sun Sailor announcing the completion of the EAW , its availability to interested parities, and the process for submitting comments on the EAW, and this press release was subsequently replace by a legal notice that was published in the paper; and WHEREAS, the 30 -day comment period ended April 22, 1998 at 4:30 p.m. and the City of Hopkins accepted and responded to all written comments received; and WHEREAS, none of the comments received recommended preparation of an EIS; NOW, THEREFORE, BE IT RESOLVED THAT: 1. The EAW was prepared in compliance with the procedures of the Minnesota Environment Policy Act and Minnesota Rules, Parts 4410.100 to 4410.1700 (1997) 2. The EAW satisfactorily addressed all of the issues for which existing information could have been reasonably obtained, 3. Based on the criteria established in Minnesota Pules Part 4410.1700, the project does not have the potential for significant environmental effects, • 4. The City makes a "Negative Declaration," 5. An EIS is not required, and 6. The City planner is directed to maintain a Record of Decision including the Response to Comments on the EAW and to notify in writing the project proposer and the EQB. Adopted this 5th day of May 1998. ATTEST: Terry Obermaier, City Clerk Charles D. Redepenning, Mayor Apr -24 -98 03:36P HKS Associates, Inc. April 24, 1998 CIVIL ENGINEERING LANDSCAPE ARCHITECTURE ENVIRONMENTAL SERVICES URBAN PLANNING Mr. Jim Kerrigan Director, Planning and Economic Development City of Hopkins 1010 First Street South Hopkins, MN 55343 Re: SuperValu Distribution Center Environmental Assessment Worksheet (EAW) 612 - 659 -0891 P.02 Dear Mr. Kerrigan: HKS Associates, Inc. has received and reviewed the comments from the Metropolitan Council, the Department of Natural Resources, and the Department of Health regarding the SuperValu Distribution Center EAW. The RGU is required to make a specific written response to each substantive and timely comment received on the EAW as part of the record of decision, and send a copy to the commenter. (A substantive comment is one that addresses the completeness and accuracy of the EAW.) Items that will need to be addressed are the 1) permits and approvals needed, and 2) a pre - demolition survey for potentially hazardous demolition debris and wells. Additional permits and approvals noted in the comments can be addressed by simply stating that the pertinent information will be submitted to the noted agencies. The Department of Health's comments regarding asbestos and wells will need to be addressed by conducting surveys prior to any demolition activities. Demolition specifications should be prepared to deal with asbestos and other hazardous materials associated with structures on the site. A well survey, as specified in the Department of Health's comments, should be conducted and any unnecessary wells properly sealed prior to the commencement of construction activities. If the above items are properly addressed, it is our opinion that the preparation of an environmental impact statement (EIS) is not needed. If you have any further questions, please give us a call. Sii%cerel Derek (sir Johnson Enviro ental Project Specialist HKS ASSOCIATES INC 821 RAYMOND AVENUE SUITE 100 ST. PAUL, MN 55114 PHONE 612/659 -9732 FAX 612/659 -0891 1 • U4/LP/U8 15:5( VAX 9J(StSZZ RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION FOR THE SUPERVALU DISTRIBUTION CENTER ENVIRONMENTAL ASSESSMENT WORKSHEET (EAW) C I T Y 0 F H O P K I N S RGU City of Hopkins Mr. Jim Kerrigan Planning & Economic Development 1010 First Street South Hopkins, MN 55343 Phone (612) 939 -1355 FAX (612) 935 -1834 CONSULTANT Westwood Professional Services, Inc. 7599 Anagram Drive Eden Prairie, MN 55344 Phone (612) 937 -5150 FAX (612) 937 -5822 westwooa Yroi . services 42 004 To be considered by the City of Hopkins City Council on May 5, 1998 APRIL 1998 PROPOSER Planmark/SuperValu Mr. Tom Peterson 6533 Flying Cloud Drive, Suite 100 Eden Prairie, MN 55344 Phone (610) 914 -5833 FAX (610) 914 -5850 04/2.9/98 18:57 FAX 9375822 Westwood Prof. Services L 005 CITY OF HOPKINS RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION FOR THE SUPERVALU DISTRIBUTION CENTER ENVIRONMENTAL ASSESSMENT WORKSHEET (EAW) APRIL, 1998 TABLE OF CONTENTS Page INTRODUCTION 1 RESPONSE TO COMMENTS 1 EAW Notification, Distribution, and Comment Period 1 Comments Received 1 Responses to Comments 1 Minnesota Department of Natural Resources, Thomas W. Balcom, April 20, 1998 2 Metropolitan Council, Helen Boyer, April 17, 1998 2 Minnesota Department of Health, David Wulff, April 22, 1998 2 FINDINGS OF FACT 4 Project Description 4 Proposed Project 4 Site Description and Existing Conditions 4 Criteria Used in Deciding Whether the Project has the Potential for Significant Environmental Effects 5 Criteria A: Type, Extent, and Reversibility Of Environmental Effects 5 Criteria B: Cumulative Potential Effects of Related or Anticipated Future Projects 6 Criteria C: Extent to Which the Environmental Effects are Subject to Mitigation 7 Criteria D: Extent to Which Environmental Effects can be Anticipated and Controlled 7 RECORD OF DECISION 8 04/29/98 18:57 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) INTRODUCTION SuperValu is proposing construction of a grocery warehouse on 55.7 acres located in the North Y2 of the Northeast 1/4 of Section 25, and the Southeast VI of the Southeast 1/4 of Section 24, T17N, R22 W, Hopkins, Minnesota. An Environmental Assessment Worksheet (EAW) was prepared for the SuperValu Distribution Center pursuant to Minnesota Rules Chapter 4419.4300 Subp. 14.A.(2). The EAW and the respective comments have been reviewed in accordance with Minnesota Rules Chapter 4410.1700 to determine if the project has potential for significant environmental effects. This document includes responses to comments received by City of Hopkins (City), the Findings of Fact supporting the decision, and the Record of Decision that indicates an Environmental Impact Statement (EIS) is not necessary for this project. RESPONSE TO COMMENTS EAW Notification, Distribution, and Comment Period In accordance with Minnesota Rules Chapter 4410.1500, the EAW was completed and distributed on March 12, 1998 to all persons and agencies on the official Environmental Quality Board (EQB) mailing list and other interested parties. The notification was published in the EQB Monitor on March 23, 1998, initiating the 30 -day public comment period. The comment period ended on April 22, 1998. Comments Received Three written comment letters were received by the City prior to the April 22 deadline. Comments were received from the following sources: Minnesota Department of Natural Resources (DNR) - letter dated April 20, 1998. • Metropolitan Council, Environmental Services Division - letter dated April 17, 1998. • Minnesota Department of Health - letter dated April 22, 1998. R ponses to Comments PAGE 1 Z006 Copies of the written comments are attached to the end of this document. Comments on the EAW generally dealt with one or more of the following categories: Item 8: Permits and Approvals Required, Item 9: Land Use, Item 13: Water Use, Item 18: Water Quality - Surface Water Runoff, and Item 22: Traffic. The DNR comment letter stated that preparation of an Environmental Impact Statement (EIS) is not warranted for this project. Because only three comment letters were received, this documents responds to the comments on a letter - by- letter basis. Many responses are confined to substantive issues that "address the accuracy and completeness of the material contained in the EAW, potential impacts that may warrant further investigation before the project is commenced, and the need for an EIS on the proposed project," as set forth under Minnesota Rules Chapter 4410.1600. Comments and recommendations that do not address these areas have been duly noted for the record and may not be specifically addressed in the responses. 04/29/98 18:58 FAX 9375822 Westwood Prof. Services J RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) JVlinnesota Department of Natural Resources. Thomas W. Balcom. April 20. 1998 The DNR noted recurrent problems with sediment filling a ditch tributary to Nine Mile Creek that comes off the property. The DNR believes the current land use on the site contributes to the sediment load. Because the proposed project will comply with Nationwide Urban Runoff Program (NURP) standards, the DNR believes the proposed project will result in an improvement of runoff water quality leaving the site. Response: So noted for the record. Metropolitan Council. Helen Boyer. April 17. 1998 0 007 The Metropolitan Council noted that sanitary sewer service connection plans for the proposed project will need to be submitted to the Metropolitan Council Environmental Services, Municipal Services staff in addition to the Minnesota Pollution Control Agency for review, comment, and issuance of a construction permit before connection can be made to the wastewater disposal system. Response: So noted for the record. The City and the project proposer appreciate the clarification of permits needed. Minnesota Department of Health. David Wulff. April 22. 1998 The Minnesota Department of Health (MDH) provided information regarding their authority to regulate removal and disturbance of asbestos- containing materials. The telephone number for the MDH asbestos program is (612) 215 -0900. Response: So noted for the record. The City and project proposer appreciate the clarification ofjurisdiction for asbestos handling and removal. As stated in the EAW under Item 9, "areas of the site that have potential contamination will be investigated in more detail prior to redevelopment of the site." An asbestos survey will be carried out prior to site redevelopment during the detailed site investigation. Any necessary disturbance and /or removal of asbestos - containing building materials will be coordinated with the MDH to ensure compliance with applicable rules. The MDH provided information regarding the Minnesota Plumbing Code, Minnesota Rules Chapter 4715.1710 Subp. 2. The MDH indicated plumbing plan approval will be necessary for this project in coordination with the state plumbing regulation program. The MDH stated that questions regarding this code should be directed to the local plumbing administrative authority or the state plumbing regulation program at (612) 215 -0836. Response: So noted for the record. The project proposer will submit the Plumbing Plan and the Site Plan showing sewer and water service to the MDH prior to construction as required. PAGE 2 04/29/98 18:59 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) The MDH recommended careful planning when locating sewer stubs for any City trunk sewers and future service lines or other connections, in order to maintain required isolation distances from wells and water service lines. Response: So noted for the record. Response: Information regarding applicable Minnesota Rules is duly noted for the record. A complete field well inventory will be conducted prior to redevelopment of the site. The consultant retained to conduct this inventory will be informed of the MDH's concerns, and the project will be designed to comply with all well setbacks and other setbacks referenced in the MDH's comments. The project will be designed to comply with all the MDH Rules and the Minnesota Plumbing Code, and will be constructed by licensed. contractors. The MDH's comments regarding human remains have been noted for the record. As stated in the EAW, the project will be connected to the City of Hopkins public water supply and will not involve the installation of any new wells. With respect to human remains, the concerns of the Minnesota State Historic Preservation Office (SHPO) have been addressed, and additional efforts will be made to verify that all human remains have been removed from the site prior to site redevelopment. Response: These businesses are located outside of the EAW project area. As noted on page 14 of the EAW under Item 22: "It should be recognized that the Traffic Study for SuperValu Expansion evaluated potential future expansion and redevelopment of other property in addition to the project evaluated under this EAW. For comparison purposes, the portion of the comprehensive traffic study identified as `New Grocery' and anticipated for completion in the year 2000 is comparable to the project addressed by this EAW." PAGE 3 e1008 The MDH expressed concerns regarding Item 13a of the EAW, including the accuracy and completeness of well location data for the subject property and the potential need for further investigation for wells in areas that were inaccessible during the site reconnaissance. The MDH recommended a field well inventory to determine if any additional wells exit, especially in areas of proposed construction or demolition. MDH cited required separation distances for placement of new sewer lines, replaced sewer lines, large diameter stormwater pipes, and stormwater drain pipes in relation to any well or public water supply. The MDH also noted that a cemetery was formerly located on the subject property, and stated that water supply wells must be separated from human graves by 50 feet. The MDH noted that Figure 1 of Appendix C of the EAW (Traffic Study for SuperValu Expansion in Hopkins) referenced the Thompson Lumber Company and the Former Country Club Market, but the EAW provided no information about wells connected with these businesses. 04/2,9/98 18:59 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) The MDH provided information regarding their requirement that any unused, unsealed well be brought into operating condition or sealed by a licensed well contractor in accordance with Minnesota Rules Chapter 4725. The MDH also recommended that wells be sealed prior to the start of other types of construction in compliance with the isolation distance requirements. Response: As stated in the EAW under Item 13a, Water Use: "Remaining monitoring wells will be abandoned and sealed in accordance with Minnesota Department of Health regulations when it becomes apparent that they are no longer necessary. " Any additional wells identified during the complete field well inventory will also be sealed in a similar manner by licensed contractors. As stated in the EAW, the site will be connected to the City of Hopkins public water supply following project completion and the project will not involve the installation of any new wells. The MDH provided information applicable to new well installation, including information applicable to a public water supply. Response: As stated under Item 13 in the EAW: "The proposed project will be served by the City of Hopkins municipal water system and will not involve the installation of any wells." The City of Hopkins water supply has DNR Water Appropriation Permit Number 75 -6245 and utilizes groundwater aquifers as its water source. Proj ct Description Proposed Project The proposed SuperValu Distribution Center will entail 572,200 square feet of warehouse and 27,840 square feet of office development supported by 375 passenger vehicle parking stalls, 250 semi truck stalls and loading bays, and 2.9 acres of stormwater ponding. Z009 FINDINGS OF FACT Minnesota Rules 4410.4300 Subp. 14.A,(2) state that the mandatory EAW threshold for "construction of a new or expansion of an existing warehousing or light industrial facility" in a third or fourth class city is 300,000 square feet. The proposed SuperValu Distribution Center exceeds this mandatory EAW threshold. Site Description and Existing Conditions The site is located in the North V2 of the Northeast 'A of Section 25, and the Southeast V4 of the Southeast 'A of Section 24, T117N, R22W. The site is located west of Highway 169, south of County Road 3 (Excelsior Blvd.), north of 5 Street South, and east of 6 Avenue South in the City of Hopkins. The site has been in developed industrial use since the 1960s and includes the Hennepin County Public Works Facility, the General Resources Corporation (GRC) facility, the Engineered Building Components (EBCA) property, and portions of existing street right -of -way. PAGE 4 04/29/98 19:00 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) Criteria Used in Deciding Whether the Project has the Potential for Significant Environmental Effects Criteria A: Type. Extent, and Reversibility Of Environmental Effects According to Minnesota Rules 4410.1700 Subp. 7 (A), the first factor that the City must consider is the "type, extent, and reversibility of environmental effects." The City's findings are set forth below. 1. Project Site. The site is currently occupied by the Hennepin County Public Works Facility, the General Resources Corporation (GRC) facility, the Engineer Building Components (EBCA) property and portions of existing street right of way. The site has been in developed industrial use since the 1960s. 2. Fish, Wildlife, and Ecologically Sensitive Resources. The project is expected to result in some local decline in wildlife abundance, but the site has been impacted by heavy industrial uses since the 1960s and was impacted by agricultural uses prior to development. The proposed project does not represent a significant alteration of land use. The site does not include any habitat types or wildlife species known to be especially unique or rare to the area. 3. Water Resources. The site does not contain any jurisdictional wetlands. PAGE 5 5. Water - related Land Use Management Districts. The project is not located within a shoreland district or 100 -year floodplain. Rion 4. Water Use. The site will be connected to the City of Hopkins public water supply. The demand is anticipated at approximately 28,133 gallons per day on a maximum potential average daily basis. 6. Erosion and Sedimentation. Steep slopes on the site are limited to stockpile areas. All site grading and erosion control activities are subject to the National Pollutant Discharge Elimination System (NPDES) permit for construction activities. 7. Water Quality - Surface Water Runoff. The project will maintain runoff rates at existing levels and sediment and nutrient removal from stormwater will meet NURP (Nationwide Urban Runoff Program) guidelines. All stormwater ponding will meet Nine Mile Creek Watershed District permitting standards. Significant negative downstream impacts are not anticipated. 8. Water Quality - Wastewaters. The estimated maximum potential wastewater production has been estimated at 25,575 gallons per day. All wastewater will be discharged to the City of Hopkins sanitary sewer system. No infrastructure facility upgrades will be needed. 9. Ground Water - Potential for Contamination. No toxic or hazardous materials other than vehicle fuels and normal cleaners are expected to be used on the project site. The project will include an emergency generator fueled by natural gas. All hazardous materials identified on the site during the Phase I Environmental Site Assessment will be removed and treated in accordance with regulations. 04/29/98 19:01 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) 0011 10. Solid Wastes; Hazardous Wastes; Storage Tanks. The maximum potential solid waste generation for development has been estimated at 600 tons per year. No animal manure, sludge, or ash generation is anticipated. City of Hopkins ordinances require mandatory recycling of eligible materials. Non - recycled waste will be hauled to either to the Hennepin Energy Resource Company Waste to Energy Facility or a sanitary landfill. The proposed development will not involve installation of any storage tanks. All storage tanks currently on the property will be removed and disposed of properly prior to construction. 11. Traffic. The proposed project is not expected to impact on the regional roadway system. Compared to existing land uses, the proposed project will result in lower net trip generation during the am and pm peak hours. There are no intersection level of service traffic problems associated with the proposed project. 12. Air Quality. The project is expected to have a negligible impact on air quality. No stationary source air emissions are anticipated as a result of this project. 13. Noise and Dust. Noise levels are expected to increase locally during project construction, but hours of construction will be limited to help mitigate effects of noise. It is not anticipated that fugitive dust will be generated in objectionable quantities. 14. Compatibility with Plans. The proposed project is consistent with current land uses and zoning for the project site. No land use conflicts are anticipated. Criteria B: Cumulative Potential Effects of Related or Anticipated Future Projects According to Minnesota Rules 4410.1700 Subp. 7 (B), the second factor the City must consider is the "cumulative potential effects of related or anticipated future projects." The City's findings are set forth below. The Concept Plan shows that the 55.7 -acre site will include approximately 16.1 acres of lawn and landscaping, and SuperValu intends to reserve opportunities to expand the proposed Distribution Center in the future in response to market conditions. Future development may be proposed within the current project boundaries, or SuperValu may consider acquisition of additional adjacent property for expansion purposes. The Robert Lawrence property located west of 6 Avenue is Iocated outside the EAW project boundaries and may be considered by SuperValu for future expansion. However, no project expansion concepts have been developed at this time, and it is not currently possible to assess environmental impacts that may be associated with potential future expansion. The EAW was based on Preliminary Concept Plans, which may be subject to change or refinement. However, as long as the project boundaries, scope, and environmental effects do not change substantially, the EAW and the Findings of Fact will remain accurate and valid. The need for environmental review of any future expansion, whether located inside or outside the project boundary, will be determined according to the rules discussed in the paragraph below. Any future expansion applications will not likely be filed until at least three years after construction of this project has begun. Assuming this becomes the case, future development applications will fall under a separate environmental review, as set forth under Minnesota Rules Part 4410.4300 Subpart 1. PAGE 6 Unit of Government 1 Type of Application _ _ City of Hopkins Preliminary and Final Plat and Site Plan City of Hopkins Grading Permit City of Hopkins Building Permit City of Hopkins Municipal Water Connection Permit City of Hopkins Sanitary Sewer Connection Permit Nine Mile Creek Watershed District Grading and Stormwater Management Metropolitan Council Sanitary Sewer Connection Permit Minnesota Pollution Control Agency NPDES /General Stormwater Permit Minnesota Pollution Control Agency Sanitary Sewer Extension Minnesota Department of Health Water Main Extension Minnesota Department of Health Site and Plumbing Plan Approval 04/29/98 19:02 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) If future development exceeds a mandatory EAW threshold and is separated from this project by at least three years, a separate EAW will be completed at that time. If future development is separated from this project by at least three years and does not exceed an EAW threshold, no future environmental review will be necessary. If future development is separated from this project by less than three years, this EAW will be amended before future development proceeds. Criteria C: Extent to Which the Environmental Effects are Subject to Mitigation According to Minnesota Rules 4410.1700 Subp. 7 (C), the third factor the City must consider is the "extent to which the environmental effects are subject to mitigation by ongoing public regulatory authority." The following permits and approvals are required for this project: The potential environmental effects associated with this project are less than significant and will be mitigated in accordance with all applicable rules and regulations. The City of Hopkins therefore finds that the potential environmental effects of the project are "subject to mitigation by ongoing public regulatory authority" and an EIS need not be prepared. Criteria D: Extent to Which Environmental Effects can be Anticipated and Controlled According to Minnesota Rules 4410.1700 Subp. 7 (D), the final factor the City must consider is the "extent to which environmental effects can be anticipated and controlled as a result of other environmental studies undertaken by public agencies or the project proposer, or of EIS's previously prepared on similar projects." The City's findings are set forth below. 1. The proposed project is similar to other warehouse development projects within fully- developed urban areas. Other projects of similar scope, accompanied by similar traffic studies and stormwater ponding, have, in general, successfully mitigated potential off -site environmental impacts. 2. The EAW, in conjunction with this document, contains or references the known studies that provide information or guidance regarding environmental effects which can be anticipated and controlled. 3. Because the maximum build alternative of the proposed project (600,040 square feet) falls 149,960 square feet short of the mandatory EIS threshold (750,000 square feet), no EIS that addresses a similarly sized project was available at the City of Hopkins PAGE 7 e012 04/29/98 19:02 FAX 9375822 Westwood Prof. Services RESPONSE TO COMMENTS, FINDINGS OF FACT, AND RECORD OF DECISION SuperValu Distribution Center Environmental Assessment Worksheet (EAW) 4. In light of the results of environmental review and permitting processes for similar projects, the City of Hopkins finds that the environmental effects of the project can be adequately anticipated and controlled. C RECORD OF DECISION Based on the EAW, the response to comments, and the Findings of Fact, the City of Hopkins, the RGU for this environmental review, concludes the following: 1. The EAW was prepared in compliance with the procedures of the Minnesota Environmental Policy Act and Minnesota Rules, Parts 4410.1000 to 4410.1700 (1997), 2. The EAW satisfactorily addressed all of the issues for which existing information could have been reasonably obtained, 3. Based on the criteria established in Minnesota Rules Part 4410.1700, the project does not have the potential for significant environmental effects, 4. The City makes a "Negative Declaration," and 5. An EIS is not required. PAGE 8 a013 Metropolitan Council Working for the Region, Planning for the Future April 17, 1998 Mr. Jim Kerrigan Director, Planning & Economic Development City of Hopkins 1010 First Street South Hopkins, MN 55343 RE: EAW- Hopkins, Super Valu Distribution Center Metropolitan Council District 3, Council Member Mary H. Smith Referral File No. 16738-1 Dear Mr. Kerrigan: The Council's Environmental Services staff has conducted a review of this EAW to determine its adequacy and accuracy in addressing regional concerns. The proposal is intending to develop a 55.7 -acre industrial site for a 600,040 square foot grocery warehouse. The staff review has concluded that the EAW is complete and accurate with respect to regional purposes. However, staff provides the following comment for your consideration. Item 8 - Permits and Approvals Required Sanitary sewer service connection plans for the proposed project will need to be submitted to the Metropolitan Council Environmental Services, Municipal Services staff in addition to the Minnesota Pollution Control Agency for review, comment, and issuance of a construction permit before connection can be made to either the municipal or metropolitan wastewater disposal system. No formal action will be taken on this EAW by the Council. Council staff recommends that the city evaluate and respond to the comment contained herein before making a negative declaration on this EAW. This will conclude the Council's review of the EAW. If you have any questions or need further information with respect to these matters, please contact Linda O'Connor, principal reviewer, at 602 -1098. Sincerely, C J Helen Boyer Director, Environmental Services Division cc: Mary H. Smith, Metropolitan Council District 3 Keith Buttleman, Director, MCES Environmental Planning and Evaluation Department Richard E. Thompson, Supervisor, Comprehensive Planning Tom Caswell, Sector Representative Lynda Voge, Linda O'Connor, Metropolitan Council Staff 230 East Fifth Street St. Paul, Minnesota 55101 -1634 (612) 291 -6359 Fax 291 -6550 TDD /TTY 291 -0904 Metro Info Line 229 -3780 An Equal Opportuntty Employer MDH EHD Minnesota D partment of Health 121 East Seventh Place PO. Box 64975 St. Paul, MN 55164 -0975 April 22, 1998 Mr. Jim Kerrigan, Director Planning and Economic Development City of Hopkins 1010 First Street South Hopkins, Minnesota 55343 Fax:6122150979 Apr 22 '98 16:17 P.01 P st-it' Fax Note 7671 Dear Mr. Kerrigan: Minnesota Department of Health (MDH) staff has reviewed the Environmental Assessment Worksheet (EAW) for the Hopkins SuperValu Distribution Center project, Hennepin County, Minnesota. We understand that the project proposes to construct a new facility within an existing city industrial area in Hopkins, for the SuperValu Distribution Center. Concomitant development work will include demolition of existing facilities; site grading; erosion controls; construction of a stormwater management system including stormwater ponding, and lawn and landscaping with tree planting; rights-of-way to be vacated; development of new roadway(s), driveways, parking lots, and truck loading bays; construction of all buildings, including warehousing, maintenance, and office space; as well as connection to city water and sewer services, and other possible utilities. We also understand that the environmental review process for this EAW is proceeding concurrently with EAW processing for a similar SuperValu Distribution Center proposal in Shakopee, Minnesota. Although this EAW states that at least one of these centers will be built, and potentially both may proceed, this EAW only addresses the site - specific issues at the Hopkins site. We will address our site - specific comments in this letter only to the Hopkins SuperValu Distribution Center site. However, most, if not all, of our comments would apply to the Shakopee site, if that site is ultimately developed. Because this EAW does not actually address the question of whether another EAW document will be formally reviewed for that site, please be aware that all parts of Minnesota Statutes and Rules will also be required to be followed at that site, and our recommendations would undoubtedly pertain as well. We have the following comments for your consideration: 1. Asbestos. MDH regulates removal or disturbance of asbestos - containing material from commercial or residential buildings for the protection of public health. These regulations mandate licensure of contractors and individuals conducting asbestos - related work and the TDD: (612) 623 -5522 (Twin Cities) 1 -800- 627 -3529 (Greater Minnesota) An Equal Opportunity Employer MDH EHD Fax :61221509 ?9 Apr 22 '98 16 :1? P.02 Mr. Jim Kerrigan April 22, 1998 Page 2 safe work practices associated with this type of work. The Minnesota Pollution Control Agency regulates proper handling and disposal of asbestos - containing material, and the Minnesota Department of Labor and Industry regulates protection of asbestos workers. For additional information, please contact the MDH asbestos program at (612)215 -0900. 2. Plumbing Code. Please note that the Minnesota Plumbing Code specifies that a buried sewer or drain be located at least 10 feet from a buried water service line, or if this distance cannot be maintained, the installation and materials must comply with Minnesota Rules Chapter 4715.1710, subp. 2 (Minnesota Plumbing Code). Questions should be directed to the local plumbing administrative authority or the state plumbing regulation program at (612)215 -0836. 3. Plumbing Plan Approval. Plumbing plan approval will be necessary for this project, prior to beginning any construction. Please call the state plumbing regulation program at (612)215 -0836 if you have any questions. 4. Sewer Stubs. We recommend careful planning to consider where to locate stubs for any city trunk sewers and future service lines or other connections, in order to maintain the isolation distances from wells and buried water service lines. 5. Well Inventory. Item 13.a. (p. 8) states that a Phase I Environmental Site Assessment (ESA) was completed by Braun Intertec. We acknowledge the information found in the ESA was that three monitoring wells were installed in 1993 on the Hennepin County Public Works site, and one of them has since been removed. We appreciate the efforts that were made to find wells on the site. However, because this project involves several different properties, and there are some ambiguities involving past ownership and/or control of some of the properties, we feel that the level of investigation in the past may not have been adequate to definitively locate all wells which may exist on the project site. For example, the EAW states no wells were found in the County Well Index (CWI); however, Appendix A (p. A41) acknowledges that CWI is an incomplete database. Although several people were interviewed to determine information about wells, the appendix acknowledges that no personnel from Engineered Building Components (EI3CO) were available to be interviewed (p. A45), and that two of the interviewees did not know about the monitoring wells (p. A41) on the Hennepin County property. We acknowledge that Braun Intertec states that on their site reconnaissance no wells were observed on the EBCO, General Resources Corporation (GRC) or Robert Lawrence properties (p. A41). However, it is stated that they were not given access to the Robert Lawrence property at that time (pp. A4, A40, and A45), so their observations were from adjacent properties and public rights -of -way. Also, the item labeled as "Figure 1 Study Area" (p. C4) in Appendix C lists Thompson Lumber Company and Former Country Club Market on parts of the project site; however, no information about possible wells connected with • these two businesses is given. In addition, excerpts in Appendix A (p. A25) indicate that MDH EHD Fax :6122150979 Apr 22 '98 16:18 P. 03 Mr. Jim Kerrigan April 22, 1998 Page 3 numerous other companies were previously listed as having addresses on different parts of the project site, but it is ambiguous whether all of these businesses were only lease tenants or whether any of them own(ed) any part of the project property. In any case, no well information was noted in the included excerpts relative to any of these other business names. Finally, there is no information suggesting the site reconnaissance evaluated the road or railroad rights-of-way. Sometimes forgotten wells are discovered along such rights -of -way. As an example, our database shows three wells were installed by the Hennepin County Regional Railroad Authority in T1 1 7N, R19W, Section 19 in 1996, and they were sealed in 1997. It is not clear whether the property where these wells were installed will become part of this project site. However, we caution project proposers that databases are not all - encompassing, so reviewing records is not a substitute for a field survey. It has been our experience that when old wells exist from past land uses, information is frequently not passed on when the land is sold or transferred. Therefore, we recommend that a field well inventory be performed to determine if there are any existing water supply wells (active or unused, unsealed) specifically across the portions of the property where any construction or demolition will take place. Special attention should be made along the proposed routcs of new sewer lines, any sewer line(s) to be replaced, and any large diameter stormwater pipes, to ensure that isolation distances will be met. Additional specific areas to search include the vicinity of all building pads, and all proposed roadways, driveways, and parking lots. Particular attention should be made in the areas shown on air photos, old reaps, etc. where any homes, farmsteads, or old industrial wells may have been located on this property, where any digging or grading will take place, as well as along property boundaries where wells on adjacent properties may still exist. Please note that, in addition to wells used for providing drinking water, the inventory should include any other monitoring wells, irrigation wells, sand - points, and other wells used for non - potable purposes. We further recommend that a field well inventory be performed across the entire property at the Shakopee location, if one has not already been done. The specific types of areas on which to focus special efforts would be similar to the areas noted above. We offer the following information in case any wells are discovered on the project site or nearby on adjacent properties: 6. Well Setbacks. Minnesota Statutes, section 1031.205 prohibits the placement of buried sewers, individual sewer lines, or any other regulated source of contamination, any closer to an existing water supply well (active or unused, unsealed) than the distances prescribed by Minnesota Rules, Chapter 4725. a. 50 feet. The rules specify a setback distance of 50 feet between a water supply well and a component of a community sewage system, such as a sewage lift station, a nonwatertight sewage sump, a waste interceptor, or a sewage septic or holding tank of any size. MDH EHD Fax Apr 22 '98 16 :18 P.04 Mr. Jim . Kerrigan April 22, 1998 Page 4 b. The rules also specify the following setback distances between water supply wells and buried sanitary sewers or individual sewer lines, including building drains connected to the building sewer line: 50 feet: A minimum setback distance of at least 50 feet must be maintained between a well and a buried sewer if the sewer: i. is a collector or municipal sewer; ii. is pressurized and serves more than a single family residence; iii. is open jointed; or iv_ is constructed of materials that do not meet the material, installation and testing requirements in the Minnesota Plumbing Code. 20 feet: The 50 foot separation distance may be reduced to 20 feet if the sewer meets the material, installation and testing requirements in the Minnesota Plumbing Code, AND it is: i a buried, gravity sewer that serves a single family residence or a single facility such as a business, church, school, or single commercial property. (This does not include collectors or municipal sewers); or ii. a buried, pressurized sewer that serves a single family residence. 7. Community Public Water Supply. Please note, however, the isolation distance from a community public water supply well is no less than 50 feet for all types of sewer lines or sewage contamination sources. 8. Stormwater Drain Pipes. Minnesota Rules, Chapter 4725 specify that the setback distance between water supply wells and stormwater pipes or conduits must be 20 feet if the pipe is 12 inches in diameter or greater; there is no setback distance requirement if the pipe is less than 12 inches in diameter. If the pipe carries sewage or sewage can back up in the pipe, the piping is considered a sewer, not a stormwater drain. 9. Construction Activities. Minnesota Rules, Chapter 4725 also require that construction activities not bury any well. 10. Unused Wells. MDH requires that any unused, unsealed wells be brought into operating condition or be sealed by a licensed well contractor, according to the Minnesota Rules, Chapter 4725. An unused, unsealed well may also be addressed by obtaining an annual maintenance permit ($100 fee) from the MDH. Maintenance permits are granted only if the well meets certain conditions. Once a well is sealed by a licensed well contractor in accordance with requirements of the rules, the isolation distance is no longer an issue. 11 Sealing Well(s) Prior to Other Work. We recommend that the work be completed for any well(s) to be sealed before beginning other types of construction, because the isolation distances apply in all cases until a well is sealed. MDH EHD Fax : 61221509 ?9 Apr 22 '98 16:19 P.05 Mr. Jim Kerrigan April 22, 1998 Page 5 In case the water supply for either site would ultimately not be able to connect to city water service, please note the following: 12. New Well. Any new well must be installed by a licensed well contractor and meet all other requirements of Minnesota Rules, Chapter 4725. 13. Public Water Supply. If a drinking water supply well would serve 25 or more persons for more than 60 days a year, the owners should be aware that the water supply will have to comply with Minnesota Rules, Chapter 4720 (public water supply program). For information regarding public water supply requirements, please contact Gerald Smith at (612)215 - 0765. 14. Human Remains. We note that a cemetery was located on this land parcel at one time. Appendix A (p. A3) states that the human remains were relocated to another site in 1953, but due to poor records it is possible that additional remains may yet be present on the site. The rules specify that the minimum isolation distance between a water supply well and a grave is 50 feet. Therefore, if a well must be constructed, we recommend a complete site investigation be made in the area chosen for the well, to determine if there could be any human remains within the setback distance. If any remains or other evidence of the cemetery is found, we recommend that the area be surveyed and staked prior to well construction, so the location information is available to the well contractor(s). Thank you for the opportunity to review this EAW. If you have questions or need further information, please call the contacts noted above or Betty Wheeler at (612)215 -0807. Sincer David Wul ' , Supervisor Policy, Planru :, and Anal Unit Environmental Health Division DWW:BJW :sig cc: Gerald Smith Betty Wheeler DNR PLANNING April 20, 1998 Jim Kerrigan. Director Planning & Economic Development City of Hopkins 1010 First Street South Hopkins, MN 55343 Sincerely, 52a-a- Thomas W. Balcom, Supervisor Environmental Review and Assistance Unit Office of Management and Budget Services c! Kathleen Wallace Con 'Christianson Bret Anderson Lynn. M. Lewis, USFWS Gregg Downing, EQB Tom Peterson, Planmark/SuperVaIu #980287-01 /S UPERVAL, WP7 Fax :612- 296 -604? Rpr 20 '98 13:59 P. 01/01 Minnesota Department. of Natural Resources 50() Lafayeiw Road Sc. Paul. Minnesota 55155 40 10 Post it Fax Note 7671 T ``.!j oa f - Co. /Dept. .. i a ol.l Phone 1t G� - ,) - S - Fax # 4:' . /CS3 Date Co. -DV ( :r #L. ( C E v I41or . pages From it.-. e) - Phone # , � ,e 6 . ,• ' - (7 5 Fax 4 // ciV 7 RE; SuperValu Distribution Center Environmental Assessment Worksheet (EAW) Dear Mr. Kerrigan: The Department of Natural Resources (DNR) has reviewed the LAW for the SuperValu Distribution Center project. We offer the following comments for your consideration. Our only comment on the project pertains to issues of stormwater runoff management discussed in Item 18. There are recurrent problems with sediment filling a ditch tributary to Nine Mile Creek that comes off the property. Operations at the Hennepin County Public Works Department likely contributed to this sedimentation problem. Because the runoff generated by the project will be treated to National Urban Runoff Program (NURP) standards, we believe the project will result in an improvement of the water quality of runoff leaving the site. As such, ongoing impacts to Nine Mile Creek will likely be reduced as a result of the project. Thank you for the opportunity to review this project. The preparation of an environmental impact statement (EIS) is not required in our opinion. We look forward to receiving your record of decision and responses to comments. Minnesota Rules part 4410.1700. subparts 4 & 5, require you to send us your Record of Decision within five days of deciding this action. Please contact Bill Johnson of my staff at (612) 296 -9229 if you have questions regarding this letter. DNR information, 612 -296 6157. 1 X(1(1. 4 -600(1 - '1'•i'Y• 612-'796 541X 1 -800-657 '4929 / \I1 ls.lu 1I Opputtuttgv I•mpI v r gter I'snnp ,,n lt.. l'apor l'out:twiny :, Who V,thu:. 1)rveiStly ILO) Minimum .11' 1O'4 l'u.; W0,1.•