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HomeMy WebLinkAboutWPO201900068 Review Comments WPO VSMP 2020-03-26COUNTY 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: Red Hill Elementary School — VSMP Project file number: WP02019-00068 Plan preparer: Jonathan Showalter, Timmons Group f onathan.showalterC&timmons.com] 608 Preston Ave., Suite 200 / Charlottesville, VA 22903 Owner or rep.: Albemarle County School Board (Joe Letteri) Plan received date: 26 Nov 2019 — Digital (Rev. 1) 6 Feb 2020 —Digital Date of comments: 13 Dec 2019 (Rev 1) 26 Mar 2020 Reviewer: 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 reasons listed below. 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. This SWPPP is disapproved, and the reasons are provided in the comments below. 1. Section 1, Registration Statement /Sec. V.C.: Check `No,' unless land disturbance has commenced. (Rev. 1) Addressed. 2. Section 1, Registration Statement /Pg. 4: Sign /Date. (Rev. 1) Comment persists. Applicant response: `The registration statement will be signed by the contractor as soon as one has been chosen.' 3. Section 6.A. /Exhibit (p. 21-22, .PDF): Indicate initial location of rain gauge. (Rev. 1) Addressed. 4. Section 6.A. /Exhibit (p. 21-22, .PDF): Revise LOD: SWPPP Exhibit + SWM /ESC inserts + VSMP /WPO Plan. 0.94 Ac. as shown is unrealistic, and includes isolated areas without connection to CE, or material storage /laydown (unless access is through Ex. building). Assume areas crossed with equipment during construction are disturbed by virtue of compaction or end -of -project typical need to till /amend soil, clear debris, restore, or install temporary /permanent stabilization. nor isolated areas of proposeLOD, image, bed. Image removed with Rev. 1 comments. Again, disturbance will likely exceed proposed limits as a practical matter. Engineering questions need for limiting LOD < 1 Ac. There is no appreciable delay when applying for a DEQ VPDES VAR10 permit, and no additional requirements since LOD >10,000 SF in Albemarle triggers VSMP requirements identical-ements that apply to projects with LOD > 1 Ac. (Rev. 1) Addressed. Applicant response: `LOD has been revised and is now connected throughout the site.' Rev. LOD z1.39 Ac. 5. Section 6.A. /Exhibit (p. 21-22, .PDF): Indicate initial location of temporary solvent /chemical storage (temporary material storage trailer). (Rev. 1) Addressed. 6. Section 7, Impaired Waters: Revise proposed enhanced inspection frequency (item (2)) consistent with VAR10, Part H G 2. a. (2.) (Ref. pg. 13 /VAR10). (Rev. 1) Addressed. 7. Section 7: Furnish missing (TMDL /impaired) data for North Fork Hardware River, since designated for enhanced inspection. (Rev. 1) Addressed. 8. Section 9, Signed Certification: Sign — date. (Rev. 1) Comment persists. Note: Albemarle cannot register this project with DEQ, or schedule a preconstruction meeting until the project is registered with DEQ. Applicant response: `Section 9 will be completed when a contractor has been selected.' 9. Section 12: Revise proposed enhanced inspection frequency (item (2)). Also, item 6., above. (Rev. 1) Engineering Review Comments Page 2 of 4 Addressed. 10. Sec. 1, Registration Statement, p.2, Sec. IV, E —MS4: Leave blank since project does not discharge to Albemarle County MS4. See County GIS /Map Themes (Layer) /Utilities /Water-Wastewater-Stormwater /Albemarle County MS4 boundary. Red Hill is well outside /south of Albemarle County MS4 boundary. (Rev. 1) Addressed. 11. Revise SWPPP title to include reference to WPO201900068. (Rev. 1) Addressed. B. Stormwater Management Plan (SWMP) VSMP Regulation 9VAC25-870-108 requires the VSMP authority to approve or disapprove a SWMP. This plan is approved pending purchase of 0.50 lb. phosphorus nutrient credits. 1. Revise title to: Red Hill Elementary School Additions and Renovations VMSP WPO201900068. Please QC: do not submit plan titled Site Plan, or Site Plan Amendment as a VSMP /WPO Plan. (Rev. 1) Addressed. 2. C2.0: Revise to show TMP 08700-00-00-060BO (Thomas Brendt) since design proposes to release runoff to a LS, then a slope leading to this property, rather than a defined channel. Show residence at 3947 Red Hill School Road. Show property boundaries consistent with GIS. Label TMP # 08700-00-00-060130. (r,,,,, ty GIS image, below; image removed with Rev. 1 comments.) (Rev. 1) Withdrawn. Applicant response: `The LS location has been revised to direct stormwater into the existing roadside ditch. See Sheet C5.0' 3. C6.0: Water quality calculations /surplus removal: Plan proposes to utilize 0.44 lb. surplus phosphorus from Scottsville Elementary School Addition project (0.44 lb. of 0.44 lb. total); plan also proposes to use 0.06 of 0.15 lb. surplus phosphorus from Woodbrook Elementary School project to meet Red Hill projects 0.50 lb. TP Load Reduction requirement. This works only if Woodbrook and Scottsville Elementary are located in the same HUC or upstream HUC (skew; Images removed with Rev. 1 comments), and Woodbrook and Scottsville schools are not in the same HUC or upstream HUC. Revise WQ compliance plan. (Ref. images /link, below. Also: Scottsville — W 0201900051; Woodbrook — WPO201600074): (Rev. 1) Addressed. Applicant response: `Stormwater quality calculations have been revised. Ownership to purchase nutrient credits to satisfy quality requirements.' Note: plan requires phosphorus nutrient credit (purchase): 0.50 lb. (C6.0) 9VAC25-870-69A. /Offsite Compliance Options (5.): `5. When an operator has additional properties available within the same HUC or upstream HUC that the land -disturbing activity directly discharges to or within the same watershed as determined by the VSMP authority, offsite stormwater management facilities on those properties may be utilized to meet the required phosphorus nutrient reductions from the land -disturbing activity.' 9VAC25-870-10 /Definitions: "'Hydrologic Unit Code" or "HUC" means a watershed unit established in the most recent version of Virginia's 6th Order National Watershed Boundary Dataset unless specifically identified as another order.' Link NA 6' order HUC Map: https://www.deg.vir ig nia.gov/Portals/0/DEQ/Water/WaterQualityAssessments/IntegratedReyort/2016/maysNA NWBD_v4.pdf --- Red Hill Elementary, HUC JM46 Seel s*il e glefnertafy H!Tq Tra44 Image removed with Rev. 1 comments. FrAm VA 6t11 order- 14 it Map QN44 6 TN44 n AM); image Above e _ Image removed with Rev. 1 comments. Woodb.eek Eleme.t..,.,, urr! ,ono — Image removed with Rev. 1 comments. C5.0: 4. Post -developed runoff may not release to undefined channel so close to a neighboring residential property. Revise design. (Rev. 1) Addressed. Applicant response: `Post -developed run-off has been redesigned to outflow to existing channel parallel with road.' 5. Str. 100 /outfall: Evaluate effect of existing impervious runoff on existing channel along Red Hill School Road. Evaluate 10-year event, whether Ex. roadside ditch has adequate capacity, and whether ditch flow bypasses driveway entrance to 3947 Red Hill School Road to reach tributary to South Branch. (Rev. 1) Addressed. Applicant response: `The existing ditch has been analyzed for the 10-year event. See detail "Road Side Ditch Calculation" on Sheet C6.0.' Engineering Review Comments Page 3 of 4 6. LS in this location is problematic. Ref. 9VAC25-870-66.D., which cautions against downslope effects. Also, item 4., above. LS releases to featureless slope toward 3947 Red Hill School Road (Brendt property). (Rev. 1) Addressed. Applicant response: `The LS has been relocated to prevent downslope effects to 3947 Red Hill School Road property.' 9VAC25-870-66.D. 7. C5.2, C6.0: Consider effect of relocated (impervious) modular trailers on post -developed ground cover. Analyze trailer DA (C5.2). Show trailer leader line outfalls. Adjust post -redeveloped ground cover (C6.0). (Rev. 1) Addressed. Applicant response: `Per change in direction, ownership will provide one (1) trailer to be located over the existing asphalt pavement. Trailer is temporary and will not cause disturbance to the asphalt surface.' 8. C7.0: Provide Std. VDOT MH with STR206-STR200 profile. Nyloplast® does not meet Drainage Plan checklist, ACDSM, or VDOT drainage manual guidance. Nyloplast is appropriate only for yard grates, or limited conveyance over limited distance. Use Std. VDOT MH Str. with 12" RCP storm pipe. (Rev. 1) Addressed. Applicant response: `Nyloplast basins have been changed to VDOT standard structures as requested.' 9. C7.0: Str 218 - 214: Revise 4" storm line to 6" Min. (Rev. 1) Addressed. Applicant response: `Storm has been re -designed. All storm line is a minimum 6".' 10. Remove sheet E0.4, Site Plan Photometrics. (Rev. 1) Addressed. C. Erosion and Sediment Control Plan (ESOP) Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESOP. This plan is disapproved for minor reasons listed at items 6 and 11, below. The erosion control plan content requirements can be found in County Code section 17-402. 1. C3.1: Include ACDSM paved construction entrance detail. (Rev. 1) Addressed. 2. C3.2, C3.3: Revise LOD. Also, SWPPP comment, item 4., above (Rev. 1) Addressed. 3. C3.3, C3.4: Label mulched areas, trails, etc. (blue arrows, below; image removed with Rev. 1 comments). Confirm whether trails or play areas are to be constructed on existing grade, with no disturbance, whatsoever (i.e. outside LOD). Label circular features shown below. (Rev. 1) Addressed. C3.2: 4. Label ST floor dimensions. (Rev. 1) Addressed. 5. Provide break in SF at ST stone weir (outfall). (Rev. 1) Addressed. 6. Revise CE label to PCE (paved construction entrance). (Rev. 1) Not addressed. 7. Revise ST L:W ratio to more nearly resemble (VESCH Std. & Spec. 3.13) 2.1 length -width ratio. (Rev. 1) Addressed. 8. C3.3: Provide labels to identify five circular areas material surface type. Show proposed grading for level circular areas, if areas are to be level. If grading is required, revise LOD /VaRRM.xls. Also, see SWPPP item 4., ESCP item 3., above. (Rev. 1) Addressed. 9. C3.2, C3.3: Show PS, MU for five circular area, within areas of land disturbance, or grading. (Rev. 1) Addressed. 10. C5: Show grading required to level pads for relocated modular trailers, an activity included with this project (Note Ex. contours: 723, 722, 721). Revise LOD. (Rev. 1) Addressed. Applicant response: `Per change in direction, ownership will provide one (1) trailer to be located over the existing asphalt pavement. Trailer is temporary and will not cause disturbance to the asphalt surface.' 11. C6.0 Riprap channel detail: It is unclear whether this detail defines C3.3 ESC feature, or permanent feature. Please clarify. (Rev. 1) Partially addressed. Applicant response: `The riprap channel detail located on C6.0 will be a permanent feature.' As follow-up: Please revise detail caption, C6.0, to include descriptor permanent. D. Pollution Prevention Plan (PPP)-SWPPP, Sec. A, items 3, 4, 5, above. (Rev. 1) Addressed. The PPP content requirements can be found in County Code section 17-404; PPP is approved. Engineering Review Comments Page 4 of 4 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: Since LOD >_ 1 Ac., 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 (CDD /En ine eering). After DEQ coverage is issued, via the coverage letter, the County can hold a pre -construction conference. Applicant will need to complete the request for a pre -construction conference form. The form identifies the contractor and responsible land disturber, and the fee remaining to be paid QNL& for Red Hill Elementary, a county project). 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.orp-/dotfonns.asp?department=cdengno WPO201900068 Red Hill Elementary VSMP 032620revl.doc