HomeMy WebLinkAboutWPO201800073 Review Comments WPO VSMP 2019-07-17COUNTY OF ALBEMARLE
Department of Community Development
401 McIntire Road, Room 227
Charlottesville, Virginia 22902-4596
Phone (434) 296-5832 Fax (434) 972-4126
Project:
Plan preparer:
Owner or rep.:
Plan received date:
(Rev. 1)
(Rev. 2)
(Rev. 3)
Date of comments:
(Additional)
(Rev. 1)
(Rev. 2)
(Rev. 3)
Reviewer:
WP0201800073
VSMP Permit Plan review
Lewis and Drive Road Extension — VSMP
Jonathan Showalter /Aaron Mabee, Timmons Group
f onathan.showalter(a)timmons.com; aaron.mabee(a),timmons.com]
608 Preston Ave., Suite 200 / Charlottesville, VA 22903
University of Virginia Foundation / P.O. Box 400218
Charlottesville, VA 22904 [tmarshall(a)uvafoundation.com]
24 Sept 2018
20 Dec 2018 (Digital)
27 Mar 2019 (Digital)
5 Jul 2019 (Digital)
9 Nov 2018 (initial)
14 Nov 2018
7 Jan 2019
15 Apr 2019
17 Jul 2019
John Anderson
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 for relatively few reasons (see
below). The application may be resubmitted for approval if all comment items 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. Link to County template:
http://www.albemarle.orgLuuload/images/forms_center/departments/Community Development/forms/En ing eering_and
_WPO_Forms/Stormwater Pollution _Prevention _ Plan_ SWPPP_template.pdf
SWPPP
a. Sign Sec. 1, VPDES Certification (Print, sign, title, date) (Rev. 1) Not addressed. Registration
Statement is now completely blank. Provide all required registration information. (Rev. 2) Not
addressed. (Rev. 3) Not addressed. Although SWPPP includes (Sec. 1) 2019 VPDES Permit
Registration Statement, the form is incomplete. Please carefully complete 2019 Registration
Statement in its entirety, accurately and completely, prior to resubmittal.
b. Lat./Lon. provided appear to be a location in Louisa County. Please revise Lat./Lon. (Rev. 1) Not
addressed. See a, above. Provide and ensure Lat./Lon. coordinates match project location. (Rev.
2) Addressed.
c. Sec. 5: Provide SWM Plan. (Rev. 1) Not addressed. Provide narrative that at a minimum
references op nd 1 and approved SDP199800043. (Rev. 2) Addressed.
d. Sec. 9, Signed Certification: please sign. (Rev. 1) Not addressed. (Rev. 2) Not addressed. (Rev.
3) Not addressed.
Engineering Review Comments
Page 2 of 7
e. Revise inspection log to provide space for description of inspection observations —see image,
below. (Rev. 1) Not Addressed. Possible misunderstanding: please revise (:..,,.,.w) to
provide adequate space. Expand space for recording description of inspection observation. (Rev.
2) Addressed.
f. New: p. 16 of SWPPP (.PDF) is the Road Plan title sheet; please remove. (Rev. 2) Addressed.
g. New: Revise SWPPP cover to include reference to WP0201800073. (Rev. 2) Not addressed.
(Rev. 3) Addressed.
SWM Plan —Note: Overlap /redundancy likely in SWM Plan comments, below
1. Show ponds 1 and 2 approved with SDP1997-00046, on current VSMP /WPO Application. (Also, please
see email including initial review comments sent 11/9/2018 12:07 PM, and review -related email with photo
attachments sent 11/13/2018 1:17 PM.) (Rev. 1) Partially addressed. As follow-up: Label ponds 1 and 2
on VSMP, especially if pond 2 provides runoff detention /treatment under SDP 199800043. There is
uncertainty concerning role of pond 2. Pond 1 is labeled in Exhibit, p. 17, Design Calculations and
Narrative, rev. 12/19/18, p. 17. Please label ponds 1 and 2 on the VSMP Plan as well. Note: Stormwater
Runoff Considerations, C3.0, states `disturbed area drains to a large wet pond that was designed [approved
SDP 199800043] to handle quantity and quality for the full build out of the research park.' Please confirm,
this is the case; if so, request for pond 2 narrative or label is withdrawn. (Rev. 2) Comment withdrawn.
Applicant response: `The runoff from this project drains to Pond 1 not Pond 2 which is to the north below
sub basin B2. Since no stormwater from the project drains to Pond 2 no label is required. Pond 1 has been
labeled on sheet CO. I'
2. Review SDP1997-00046 (Dewberry Davis plans), and include relevant information, graphics, plan or
profile information required to establish design of ponds 1 and 2 for comparison with As -built conditions.
(Rev. 1) Addressed.
3. Provide As -built plan /profile drawings (or As -built information on WP0201800073) for ponds 1 and 2.
No As -built drawings or information has been located in Engineering or Water Resource Division files.
(Rev. 1) Not addressed. May be discussed in comment response letter; comment response letter requested
via county email sent 1/7/2019 8:55 AM. (Rev. 2) Addressed. Applicant response: `As -built plans
SDP 199800043 have been located by county records and scanned into their records per email and link
provided by James Smith in his email 12/19/2018' [J. Howard -Smith email: 12/19/2018 7:07 AM]
4. Show ponds 1 and 2 on VSMP /WP0201800073. (Rev. 1) Partially addressed. If pond 2 is shown,
please label —also, please see item 1, above (label ponds 1 and 2 on VSMP Plan). (Rev. 2) Comment
withdrawn. Also, see item 1, above.
5. Please correlate: (Rev. 1) Addressed. (Note: See CV documents /SDP199800043.)
a. Approved SDP 1997-00046 Dewberry Davis plans;
b. WP0200600087 Cox Company plans (titled SDP2006-00113; available in CV under this
Application number);
c. Dewberry & Davis report titled UVA Research Park at North Fork, subtitled Stormwater
Management /BMP Analysis and Floodplain Study for the UVA Research Park at North Fork, d.
October 1997
d. The Cox Company Engineering Calculations /report titled UVA Research Park, Town Centers III
and 1V, d. 8-Mar 2007; with
Impervious area (SF) treated by ponds 1 and 2 at full build -out (SDP1997-00046), with
impervious area to date routed to ponds 1 and 2, and with additional impervious area proposed
with WP0201800073.
6. Per conversation between Jonathan Showalter and J. Anderson on 11/13, please provide Narrative outlining
efforts to minimize stream impacts with proposed roadway alignment. Discuss wetland versus stream
impact trade-off with proposed alignment. (Rev. 1) Addressed. Ref. Timmons email, 12/18/2018 11:09
AM, with Exhibit comparing original KHA v. current Timmons' roadway alignment, with 400 LF less
stream disturbance and 223 SF less wetland disturbance. Exhibit also in CV.
Engineering Review Comments
Page 3 of 7
Avoid wetlands to extent practicable. Discuss roadway CL shift to the west to avoid wetlands to extent
practicable. Compare shift west stream impacts with current alignment wetland impacts. (Rev. 1)
Addressed. See item 7, above.
Stormwater Management Note, C0.0 references "Stormwater Management /BMP Analysis and Floodplain
Study for the UVA Research Park at Northfork" by Dewberry & Davis, October 1997." The note
continues: `The Research Park has been master planned for Stormwater Management for the future build -
out of the research park. The Majority of this road project drains to the large wet pond to the east that was
designed and constructed to handle quantity and quality for the future build -out of the research park
including this road connection.' End note.
(Ref. document /link [CV]: http://www.albemarle.or,g-/weblink/search.aspx?dbid=3&searchcommand=%7b%5bCDD-
Plannin,g%5 d: %5bApplicationNumber%5 d=%22 WPO200600087%22%7d
Also/same link: "UVA Research Park, Town Centers III and IV, Engineering Calculations," prepared for UVA Real Estate
Foundation by Frank D. Cox, Jr., PE /Cox Company, 220 E. High St., Charlottesville —Nov. 30, 2006, Rev. March 8, 2007.
This document appears highly -relevant and useful to VMSP /WPO Plan submittal. Review and include salient information
from this document. See Exhibit 1, beginning p. 18 of .PDF. Also: pre -development drainage map, p. 7; a road design not
identical with design proposed with WPO201800073, p. 8-9; etc.)
a. Title sheet notation does not of itself sufficiently address plan requirements if compared with VA
Administrative Code stormwater quality or quantity regulations. It is unclear if Applicant is
requesting Engineering accept existence of a study as sufficient basis for issuing a VSMP VPDES
permit under 9VAC25-870-48, without additional detail or context, including: narrative, data,
routings, pond plan /profile, As -built for Ex. large wet pond, drainage maps, calculations, etc.
Engineering recommends Timmons take a conventional approach and piece together information;
that is, provide rationale that guides plan review, including whether 9VAC25-870-48 is basis of
VSMP /WPO Plan Application (Grandfathering). Please provide reference to SDP1997-00046,
which includes BMPs designed to meet then -current stormwater management requirements (also,
ref. 1997 Dewberry and Davis study). The reference study is twenty-one years old. There are a
few immediately recognizable approved SDPs or WPOs in Albemarle County's online document
system (CV) that align with the 1997 study (WP02006-00087 does). Timmons must provide
information sufficient for Engineering to approve WP0201800073 without pulling past plans,
many of which are listed in CV as not approved. 9VAC25-870-48, -93 /94 (Definitions
/Applicability), -95 (General), -96 (Water Quality), -97 (Stream Channel Erosion), and -98
(Flooding) likely govern proposed roadway construction. Engineering recommends query CV (or
visit CDD to request /consider and review) the following possibly relevant Applications (listed by
type, then chronologically): (Rev. 1) Addressed. Timmons Design Calculations and Narrative,
Rev. 12/19/18: p. 3, Stormwater Mana eg ment narrative; p. 4, Table 1, Drainage Areas and CN
values; p. 16, UVA Research Park at North Fork (Exhibit); and p. 17, SWM Exhibit for Pond 1,
12/19/18, provide link to prior -approved SDP199800043, and sufficient detail. Also email: Paul
Bjomsen (Records Management Officer, December 07, 2018 9:01 AM) to Timmons; James
Howard -Smith, Records and Imaging Technician (12/19/2018 7:07 AM), to Timmons.
i. ZMA2005-00002
ii. SP2008-00062
iii. SDP 1997-00046
iv. SDP 1998-00043
v. SDP2000-00025
vi. SDP2000-00077
vii. SDP2000-00098
viii. SDP2001-00005
ix. SDP2001-00011
x. SDP2001-00047
xi. SDP2002-00064
xii. SDP2002-00072
xiii. SDP2002-00110
xiv. WP0200600087 (Approved plan not shown in CV; documents only.)
Engineering Review Comments
Page 4 of 7
9. Remove Road Plan sheets from VSMP /WPO Plan, including: C1.1 - C1.3, C4.4 - C4.9; C6.0, C6.1, C7.0,
C8.0 - C8.3: these sheets present road plan detail/s. (Rev. 1) Addressed.
10. Copy Construction Record Drawing (As -built) Policy to plans: (Rev. 1) Addressed.
http://www.albemarle.orgLupload/images/forms center/departments/Community_ Development/forms/Eng_i
neering_and _WPO _Forms/WPO _VSMP _Construction_ Record_ Drawings_ Policy _23 Ma.. 2�pdf
C3.0
11. Stormwater Runoff Considerations: Expand to provide descriptive narrative connection to prior -approved
site plan (SDP 1997-00046) to affirm proposed development meets state stormwater quality and quantity
requirements. (Rev. 1, 2) Addressed. Also, see item 8, above. Me: please label ponds 1 and 2 on VSMP
Plan (item 1, above).
12. Include note that requires Owner to obtain all required state or federal permits, including VDEQ Individual
Permit, VMRC General Permit, or US ACE Nationwide permit (wetland impacts), etc. (Rev. 1)
Addressed.
13. List Mecial conditions of US ACE permit on the plans. Identify, number, and quantify area impact to
wetlands (SF). Identify wetland type/s using text, labels/notes, graphic symbols. (Rev. 1) Partially
addressed. Also, see items 15, 19, Sec. C. (ESCP), below. (Rev. 2) Comment persists.
14. New: Please revise plan title to include reference to VSMP/WPO201800073. (Rev. 2) Addressed.
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
1. See A /Sec. 6 comments, above. Revise Sec. 6 Exhibit, as needed, if plan revised.
C. Erosion and Sediment Control Plan (ESCP)
Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESCP. This plan
is disapproved for reasons outlined, below. The erosion control plan content requirements can be found in
County Code section 17-402.
C3.0
1. Include ACDSM Paved (construction entrance) Wash Rack detail. Measure required. See ACDSM, p. 8.
(Rev. 1) Addressed.
2. Define /specify slope stabilization seed mix (Ref. legend, C3.2). (Rev. 1) Addressed.
3. C3.0: It appears 2nd C3.0 (details) should be labeled sheet C3.1. (Rev. 1) Addressed.
4. C3.1 (relabeled): Include stream diversion detail; for example, VESCH plate 3.25-1, or variation showing
sandbag dam /pump -around diversion. (Rev. 1) Addressed.
5. Provide culvert inlet protection detail. (box culvert, TSDs, etc.) (Rev. 1) Addressed.
6. Provide super silt fence detail. (Rev. 1) Addressed.
C2.0
7. Provide at least one hundred (100) Ex. contour labels. No legible contour labels appear to be shown. (It is
difficult verging on impossible to interpret existing conditions.) (Rev. 1) Addressed.
8. Label development parcel TMP. Label each adjoining parcel with TMP#. (Rev. 1) Addressed.
9. Provide Mitigation Plan for stream crossings (2:1 mitigation required). Label WPO buffer areas, if
multiple areas. Provide landscape schedule for each WPO buffer area. (Rev. 1) Addressed. Note:
Timmons may want to review areas to which 2:1 planting requirement applies, i.e., impacts to buffer at
stream crossings only. If the area impact to stream buffers at all perennial stream crossings combined is <
1.105 Ac., then 2:1 mitigation planting requirement is < 2.21 Ac. (of plantings). Albemarle accepts
proposed 2.21 Ac. if total stream buffer impact at all crossings combined is > 1.105 Ac.
10. Revise critical slopes labels. Replace with managed or preserved steep slopes labels. (Rev. 1) Partially
addressed. Revise labels to show preserved slopes, consistent with GIS. Image, below.
County GIS (green shading indicates preserved (steep) slopes). (Rev. 2) Addressed.
Engineering Review Comments
Page 5 of 7
11. C3.2 — C3.5: Increase Ex. contour labels so legible. (Rev. 1) Addressed.
C3.2
12. Label ST 1 floor dimensions in plan view. (Rev. 1) Addressed.
13. ST1 design treats Max. limit, 3.0 Ac. Show 3.0 Ac. drainage area boundaries for this sediment trap. (Rev.
1) Addressed.
14. ST 1: Avoid wetlands. Relocate ST 1 since this sediment trap discharges to downslope wetlands, by design.
This means, any event that exceeds capacity of ST1 will discharge sediment to wetlands, by design, which
may cause permanent or irrevocable and not incidental impact. Do not propose sediment trapping
measures upslope of or immediately adjacent to wetlands. (Rev. 1) Addressed (comment discussed with
Timmons): Location coincides with roadway corridor. ST1 is sized for 3 Ac. DA, with SSF downslope of
trap (provide break in SFF at weir). Trap, if maintained, should limit impact to downslope wetlands.
Albemarle accepts the design rationale.
15. Relocate roadway if necessary to avoid and minimize wetland impacts. Alternatively, provide copy of
USACE Permit authorizing proposed wetland impacts. (Rev. 1) Addressed/Acknowledged. Applicant
response (to SUB201800171 /Road Plan review comment (C3.0), item 8; response d. 12/20/18): `Permit
will be filed with Army Corps of Engineers. A copy of the permit will be included once approved.'
16. Label dimensions 39 cy Culv-3 inlet protection to aid review, construction, and inspection. (Rev. 1)
Addressed.
17. Label Area (acreage) of Limits of Clearing and Grading, x.xx Ac. (Rev. 1) Addressed.
18. Calculate velocity (Q2) for channel at bottom of future fill slope, upslope of Culv-3. Provide soil
stabilization, permanent riprap, or concrete conveyance channel as required for this channel. (Rev. 1)
Addressed.
19. Show, estimate, label area of wetland impacts (SF). Identify wetland type: emergent, riverine, palustrine.
(Rev. 1) Not addressed. Also, see Sec. A, item 13. Note: Copy of USACE permit will likely address.
(Rev. 2) Addressed. Applicant response: `The above requirements ... See plan sheets WIM1.0-WIM3.0'
20. List U.S. Army Corps of Engineers Nationwide permit (USAGE NWP-27 /other) issued for this project.
List date of permit issuance. VSMP /WPO cannot be approved without copy of current USACE permit
authorizing specific impacts to specific areas identified, shown and labelled on the VSMP /WPO plan.
(Rev. 1) Addressed/Acknowledged —see item 15, above. (Rev. 2, 3) Comment persists.
21. Show wetland protective measures; for example, timber matting and fencing equivalent to tree protection,
for wetlands to be preserved and not authorized by USACE permit to be disturbed or impacted, either
temporarily or permanently, by project activity. Plans identify no wetlands to be preserved, except by
Engineering Review Comments
Page 6 of 7
virtue of location outside LOD. Recommend wetland preservation as cornerstone of design. See other
comments on topic of impact avoidance and minimization, especially concerning Applicant need to acquire
and provide copy of relevant federal or state wetland, stream, or aquatic resource permits. (Rev. 1) Not
addressed. Note: Copy of USACE permit will likely address. (Rev. 2, 3) Comment persists. Applicant
response: We currently have tree protection fencing just inside our LOD wherever they border the
wetlands. This will serve a physical barrier and marker of the limits disturbance in the field. The permit
silt fence inside LOD to which will serve as a physical item in the field between land disturbance and
wetlands. A copy of the permit will be provided once available.' [ Emphasis added.]
C3.3
22. Label ST2 floor dimensions in plan view. (Rev. 1) Addressed.
23. ST2 design treats Max. limit, 3.0 Ac. Show 3.0 Ac. drainage area boundaries for this sediment trap. (Rev.
1) Addressed.
24. Revise Legend to include FD and TSD. (Rev. 1) Addressed.
25. Label TSD in plan view. Label TSD CIP in plan view. (Rev. 1) Addressed.
26. Label TSDs TSD1 and TSD2. (Rev. 1) Partially addressed. As follow-up: Please label TSD-2. (Rev. 2)
Addressed.
27. Increase pitch of wetlands label downslope of proposed box culvert. Apply item #19, above to sheet C3.3.
(Rev. 1) Not addressed. (Rev. 2) Addressed.
28. Increase pitch of dense trees label, so it is readable and useful. Examine /increase microscopic labels.
(Rev. 1) Addressed.
29. Provide sufficient and legible contour labels to guide review, inspection and construction. (Rev. 1)
Addressed.
30. If TSDs convey sediment -laden storm runoff, provide sediment trapping measure at TSD outfalls. (Rev. 1)
Not addressed. Provide trapping measure for sediment -laden storm runoff in plan view, or, alternatively,
detail and with plan view (label) re£ to detail. (Rev. 2) Addressed. C3.4 Note. Also county email,
2/8/2019 5:28 PM.
31. Provide break in SSF at sediment trap weir outfalls (ST2, ST3). Provide break in SSF for ST1 (0.2).
(Rev. 1) Partially addressed. Provide break in SFF for ST1. (Rev. 1) Not addressed. Note: Siltfence
break detail shared via email (2/8/2019 4:56 PM) is not included with rev. VSMP plan. Ensure information
shared with county via email 2/8/19 is included with plans. (Rev. 3) Addressed.
32. ST3: Design table and plan label top of dam elevation should match. (Rev. 1) Not addressed. 492' v.
494'. (Rev. 2) Addressed.
C3.4
33. Provide CL roadway stationing since blanket matting labels ref. stations. (Rev. 1) Not addressed. (Rev.
2) Addressed.
34. Apply comments regarding readable labels and readable contour labels elsewhere to this sheet. (Rev. 1)
Addressed.
35. CWDs must end at trapping measure, even if only a limited -volume depression defined by label. (Rev. 1)
Comment withdrawn.
36. Calculate and list permanent stream impacts (LF), this /other sheets. (Rev. 1) Addressed. Ref. `Original
Alignment (120' wide road section)' Exhibit in CV. 665 LF stream disturbance.
37. C3.5: Apply C3.4 review comments. (Rev. 1) Addressed.
Design Calculations & Narrative, 9/24/18 (No item #1):
2. Culvert 1 Table breaks across 2 pages; reformat so visible as single sheet. (Rev. 1) Addressed.
3. Culverts 1, 2, 3 design outfall velocity exceeds 10.0 fps. Ensure labels, notes etc. identify locations
requiring VESCH Std. & Spec. 3.36, and identify which type stabilization matting is required. (Rev. 1)
Addressed.
4. (RP comment) Max. outfall velocity is 15fps. Ref. Drainage Plan checklist (drainage computations, p. 2).
Revise design such that outfall velocity for all culverts is < 15fps (Q2). (Rev. 1) Addressed. Q1o, culverts
1,2,3<l5fps.
Engineering Review Comments
Page 7 of 7
Provide outfall protection calculations. Ref. VESCH Std. & Spec. 3.18 plates 3.18-3 and /or 3.18-4. (Rev.
1) Partially addressed. Asefollow-up: please correlate p. 13-15, Design Calculations and Narrative to
culverts 1, 2, 3. It is not readily apparent which plates are assigned to culverts 1, 2 3. (Rev. 2) Addressed.
Culvert 3 OP width 2 is insufficient. Width 1 =6.0' is likely adequate (ref. comment #31). Ref. VESCH.
(Rev. 1) Addressed.
The VSMP permit application and all plans may be resubmitted for approval when all comments have been
addressed. For re -submittal, please provide 2 copies of the 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 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 may 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 (likely) need to enter project information in a DEQ
database (unless proposed activity is covered under an existing VAR10 /VPDES permit). 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.
Easements must be recorded prior to VSMP approval.
After DEQ coverage is issued, 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;
htt2://www.albemarle.orWdeptforms.asp?departinent--cdengMMo
If you have questions /concerns, please contact me at janderson2@albemarle.org or at 434.296-5832 ext.
3069.
Thank you
J. Anderson, Engineering Division
WP0201800073 Lewis and Clark Drive Road Ext 071719rev3