HomeMy WebLinkAboutWPO201800069 Review Comments WPO VSMP 2018-10-05COUNTY OF ALBEMARLE
Department of Community Development
401 McIntire Road, Room 227
Charlottesville, Virginia 22902-4596
Phone (434) 296-5832 Fax (434) 972-4126
VSMP Permit plan review
Project title: Oak Forest Pump Station Abandonment Project
Project file number: WP0201800069
Plan preparer: Susan Stalnaker — Obrien&Gere [susan.stalnaker@obg.com]
Owner or rep.: Jeremy Lynn — ACSA blynn@serviceauthority.org]
Plan received date: 05 Sept 2018
Date of comments: 05 Oct 2018
Reviewers: Emily Cox
County Code section 17-410 and Virginia Code §62.1-44.15:34 requires the VSMP authority to
act on any VSMP permit by issuing a project approval or denial. This project is denied. The
rationale is given in the comments below. The application may be resubmitted for approval if all
of the items below are satisfactorily addressed. The VSMP application content requirements can
be found in County Code section 17-401.
A. Stormwater Pollution Prevention Plan (SWPPP)
The SWPPP content requirements can be found in County Code section 17-405. A SWPPP must
contain (1) a PPP, (2) an ESCP, (3) a SWMP, and (4) any TMDL measures necessary.
1. Provide a signed registration statement (Section 1).
2. Provide a signed certification (Section 9).
3. The last note of the intended construction sequence section should say that erosion & sediment
control measures shall only be removed once approved by the Albemarle County VSMP Inspector.
4. The last paragraph of Section 4, stabilization practices should read "as determined by ASCA
inspector & Albemarle County VSMP inspector"
5. In Section 4 please add that "any materials taken offsite must be taken to a permitted site and
noted in the SWPPP.
6. The registration statement says 0.83 AC of disturbed area, and the plan says 0.91. Please clarify
and ensure they are the same.
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
Once the contractor decides the specific location of PPP items, ensure that the SWPPP is updated.
Currently, the PPP is a generic example of what is required.
C. Stormwater Management Plan (SWMP)
VSMP Regulation 9VAC25-870-108 requires the VSMP authority to approve or disapprove a
SWMP. This plan is disapproved, and the reasons are provided in the comments below. The
stormwater management plan content requirements can be found in County Code section 17-403.
Engineering Review Comments
Page 2 of 3
1. Please reference Guidance Memo No. 15 -2003 (attached to this letter) and include bullet points
from pages 3 & 4 on the plans. This shows that you are exempt from the VSMP stormwater
requirements.
2. Provide VDOT approval/permit of plans for work in the right-of-way.
D. Erosion and Sediment Control Plan (ESOP)
Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESCP.
This plan is disapproved, and the reasons are provided in the comments below. The erosion control
plan content requirements can be found in County Code section 17-402.
1. The Project Manual, Section 31-25, has an E&S bond amount. Is this for ACSA or through the
County? If through the County, be aware we may calculate a different amount. Bonds are
calculated once the plans are approved.
2. Parcel #'s on the cover sheet should not say N/A. List all tax map parcels affected.
3. Topography should at least be field verified within a year. Please add date to cover sheet.
4. Provide the construction entrance detail with pavement and wash rack from page 8 of the design
standards manual on the plans. This may not be required in the field based on discussions with the
County inspector, it must be shown on the plans. However, a wash rack will always be required.
Please show plans/detail for wash water and a sediment trapping device.
http://www. albemarle. org/upload/images/forms_center/departments/community_development/for
ms/design_standards_manual/Albemarle_County_Design_Standards_Manual_2015 -04-
25_draft.pdf
5. In order to protect all trees that are intended to be saved, the County suggests showing tree
protection on all sheets of the plan, not just E&S.
6. Show Temporary Seeding, Permanent Seeding and Dust Control on the plans.
7. Ensure all existing contour elevations are labeled.
8. There appears to be a stream linetype near the matchline for Sheet ESC-3 & 4. Is there a stream
crossing? If so, provide details and any required permits.
9. Please update the northern matchline label on ESC-4 to say ESC-3.
10. Please clarify the outlet protection and check dams on Sheet ESC-4. Are they proposed or
existing? Provide design calculations (drainage area, flow, detail, etc). Outlet protection detail was
provided, however, flow and dimensions must be specified. No information was provided on the
Check Dams.
11. The Critical Areas section of the Narrative referenced a storm basin. Please show the location on
the plans.
12. Provide details of how bore pits will be dewatered if necessary on the plans.
The VSMP permit application and all plans may be resubmitted for approval when all comments have
been satisfactorily addressed. For re -submittals please provide 2 copies of the complete permit package
with a completed application form.
Engineering plan review staff are available from 2-4 PM on Thursdays, should you require a meeting to
discuss this review.
Process;
After approval, plans will need to be bonded. The bonding process is begun by submitting a bond estimate
Engineering Review Comments
Page 3 of 3
request form and fee to the Department of Community Development. One of the plan reviewers will
prepare estimates and check parcel and easement information based on the approved plans. The County's
Management Analyst will prepare bond agreement forms, which will need to be completed by the owner
and submitted along with cash, certificates or sureties for the amounts specified. The agreements will need
to be approved and signed by the County Attorney and County Engineer. This may take 2-4 weeks to
obtain all the correct signatures and forms.
Stormwater Management Facilities Maintenance agreements will also need to be completed and recorded.
The County's Management Analyst or other staff will prepare the forms and check for ownership and
signature information. The completed forms will need to be submitted along with court recording fees.
After bonding and agreements are complete, county staff will need to enter project information in a DEQ
database for state application processing. DEQ will review the application information based on local
VSMP authority approval. At this time, the DEQ portion of the application fees will need to be paid
directly to the state. For fastest processing, this is done electronically with the emails provided on the
application. DEQ should notify applicants with instructions on how to pay fees. When DEQ approves the
application, they will issue a permit coverage letter. This should be copied to the county.
After DEQ coverage is issued, via the coverage letter, the County can hold a pre -construction conference.
Applicants will need to complete the request for a pre -construction conference form, and pay the remainder
of the application fee. The form identifies the contractor and responsible land disturber, and the fee
remaining to be paid. This will be checked by county staff, and upon approval, a pre -construction
conference will be scheduled with the County inspector. At the pre -construction conference, should
everything proceed satisfactorily, a joint VSMP and grading permit will be issued by the County so that
work may begin.
County forms can be found on the county website forms center under engineering;
hLtp://www.albemarle.org/deptforms.asp?department--cdengwpo
COMMONWEALTH OF VIRGINIA
DEPARTMENT OF ENVIRONMENTAL QUALITY
WATER DIVISION
Subject: Guidance Memo No. 15-2003
Postdevelopment Stormwater Management Implementation Guidance for Linear Utility
Projects under the Virginia Stormwater Management Program Regulation, 9VAC25-870
To: Regional Directors and Local VSMP Administrators
From: Melanie D. Davenport, Director MAAQ
Date: April 23, 2015
Copies: James Golden, Jeff Steers, Fred Cunningham, Joan Salvati, Allan Brockenbrough,
Jerome Brooks, Regional Stormwater Compliance Managers
Summary:
Section 76 (Linear Development Projects) of the Virginia Stormwater Management Program (VSMP)
Regulation, 9VAC25-870, sets forth the postdevelopment stormwater management requirements for
linear development projects. The purpose of this guidance document is to clarify the implementation of
Section 76 with regards to the construction of linear utilities (e.g., waterlines, sewer lines, electric lines,
telephone lines, oil and gas distribution pipelines, etc.) and was developed for use by the Department and
local VSMP Authorities.
Electronic Copy:
An electronic copy of this guidance document in PDF format is available for staff internally on DEQNET,
and for the general public on DEQ's website at:
http://www.deq.vir ing is og v/Programs/Water/Laws,Reolations,Guidance/Guidance/WaterPermitGuidan
ce.asnx.
Contact Information:
Please contact Drew Hammond, Office of Stormwater Management, at (804) 698-4037 or
Andrew.Hammondkdeq.vir ig nia.gov with any questions regarding the application of this guidance.
Disclaimer:
This document is provided as guidance and, as such, sets forth standard operating procedures for
the agency. However, it does not mandate or prohibit any particular action not otherwise required
or prohibited by law or regulation. If alternative proposals are made, such proposals will be
reviewed and accepted or denied based on their technical adequacy and compliance with
appropriate laws and regulations.
Postdevelopment Stormwater Management Implementation Guidance
for Linear Utility Projects under the
Virginia Stormwater Management Program Regulation, 9VAC25-870
Definitions:
"Land disturbance" or "land -disturbing activity" means a manmade change to the land surface that
potentially changes its runoff characteristics including clearing, grading, or excavation, except that the
term shall not include those exemptions specified in § 62.1-44.15:34 of the Code of Virginia.
"Linear development project" means a land -disturbing activity that is linear in nature such as, but not
limited to, (i) the construction of electric and telephone utility lines, and natural gas pipelines; (ii)
construction of tracks, rights -of -way, bridges, communication facilities and other related structures of a
railroad company; (iii) highway construction projects; (iv) construction of stormwater channels and
stream restoration activities; and (v) water and sewer lines. Private subdivision roads or streets shall not
be considered linear development projects.
"Postdevelopment" refers to conditions that reasonably may be expected or anticipated to exist after
completion of the land development activity on a specific site.
"Predevelopment" refers to the conditions that exist at the time that plans for the land development of a
tract of land are submitted to the VSMP authority. Where phased development or plan approval occurs
(preliminary grading, demolition of existing structures, roads and utilities, etc.), the existing conditions at
the time prior to the first item being submitted shall establish predevelopment conditions.
"Stabilized" means land that has been treated to withstand normal exposure to natural forces without
incurring erosion damage.
"Stormwater management plan" means a document(s) containing material for describing methods for
complying with the requirements of the VSMP Regulation, 9VAC25-870.
"Virginia Stormwater Management Program (VSMP) authority" means an authority approved by the
Board after September 13, 2011 to operate a Virginia Stormwater Management Program or the
Department.
Regulatory Text:
9VAC25-870-76. Linear development projects.
Linear development projects shall control postdevelopment stormwater runoff in accordance with a site -
specific stormwater management plan or a comprehensive watershed stormwater management plan
developed in accordance with these regulations.
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Guidance:
Section 76 of the VSMP Regulation, 9VAC25-870, establishes the requirement that linear development
projects control postdevelopment stormwater runoff in accordance with a site -specific stormwater
management plan or a comprehensive watershed stormwater management plan. The purpose of this
guidance document is to clarify the implementation of Section 76 with regard to the construction of linear
utilities (e.g., waterlines, sewer lines, electric lines, telephone lines, oil and gas distribution pipelines, etc.)
and was developed for use by the Department and local VSMP Authorities.
The VSMP Regulation does not distinguish between various types of linear development projects such as
aboveground or underground utilities, highway construction, rights -of -way, bridges, tracks and related
structures of a railroad company. The Department of Environmental Quality (DEQ) recognizes that the
construction of aboveground or underground linear utilities may not result in changes to the
predevelopment runoff characteristics of the land surface after the completion of construction and final
stabilization. Also, the application of the postdevelopment water quantity and water quality controls to
these types of projects and the preparation and implementation of a stormwater management plan may
provide minimum water quality benefit. Examples of such projects include:
• The installation of underground utilities (e.g., waterlines, sewer lines, oil and gas distribution
pipelines) beneath existing impervious cover (e.g., asphalt pavement, concrete pavement) that
will be returned to its predevelopment condition after the completion of construction and final
stabilization;
• The installation of underground utilities (e.g., waterlines, sewer lines, oil and gas distribution
pipelines) beneath existing pervious cover (e.g., forest/open space, managed turf) that will be
returned to its predevelopment condition after the completion of construction and final
stabilization; or
• The installation of aboveground (i.e., overhead) utility lines.
DEQ staff or the local VSMP authority should utilize their best professional judgment when evaluating
aboveground or underground linear utility projects. If the project will not result in significant changes to
the predevelopment runoff characteristics of the land surface after the completion of construction and
final stabilization, then DEQ or the local VSMP authority, at their discretion, may waive the requirement
for the preparation and implementation of a stormwater management plan. DEQ recognizes that on a site
specific basis a stormwater management plan may be required especially if the linear utility project will
significantly alter the predevelopment runoff characteristics of the land surface.
In addition, the construction of aboveground or underground linear utilities may be conducted without
requiring coverage under the General VPDES Permit for Discharges of Stormwater from Construction
Activities (Construction General Permit) provided that:
• The project does not significantly alter the predevelopment runoff characteristics of the land
surface after the completion of construction and final stabilization;
• The project is managed so that less than one (1) acre of land disturbance occurs on a daily basis;
• The disturbed land where work has been completed is adequately stabilized on a daily basis;
• The environment is protected from erosion and sedimentation damage associated with the land -
disturbing activity;
• The owner and/or construction activity operator designs, installs, implements, and maintains
pollution prevention measures to:
➢ Minimize the discharge of pollutants from equipment and vehicle washing, wheel wash
water, and other wash waters;
➢ Minimize the exposure of building materials, building products, construction wastes,
trash, landscape materials, fertilizers, pesticides, herbicides, detergents, sanitary waste,
and other materials present on -site to precipitation and to stormwater;
➢ Minimize the discharge of pollutants from spills and leaks and implement chemical spill
and leak prevention and response procedures;
➢ Prohibit the discharge of wastewater from the washout of concrete;
➢ Prohibit the discharge of wastewater from the washout and cleanout of stucco, paint,
form release oils, curing compounds, and other construction materials; and
➢ Prohibit the discharge of fuels, oils, or other pollutants used in vehicle and equipment
operation and maintenance.
• The owner and/or construction activity operator provides reasonable assurance to DEQ or the
local VSMP Authority that all of the above conditions will be satisfied. This may be
accomplished by incorporating these conditions into an erosion and sediment control plan
developed for the project.
As previously noted, DEQ staff or the local VSMP authority should utilize their best professional
judgment when evaluating aboveground or underground linear utility projects. If the owner and/or
construction activity operator provides reasonable assurance to DEQ or the local VSMP Authority that all
of the aforementioned conditions will be satisfied, then the linear utility project may be conducted without
requiring coverage under the Construction General Permit. Please note that this does not relieve the
owner and/or construction activity operator from complying with any and all other applicable federal,
state, and local requirements. DEQ or the local VSMP Authority reserves the right to require a
registration statement for Construction General Permit coverage if the aforementioned conditions are not
satisfied.
If the linear utility project will significantly alter the predevelopment runoff characteristics of the land
surface requiring postdevelopment stormwater management or if other site specific conditions warrant
Construction General Permit coverage, DEQ or the local VSMP authority may require a registration
statement for permit coverage.
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