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HomeMy WebLinkAboutWPO201800027 Review Comments WPO VSMP 2020-05-26COUNTY 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: Martha Jefferson Hospital Apartments — VSMP Plan Amendment 1 Project file#: WP02018-00027 Plan preparer: Scott Collins; Collins Engineering [200 Garrett St., Suite K, Charlottesville, VA 22902, scott(&collins-en ing eeriee com] Owner or rep.: Martha Jefferson 6015 Poplar Hall Drive, Suite 214 / Norfolk, VA 23502 Developer: Alan Taylor [ alanAriverbenddev.com ] Plan received date: 23 Apr 2020 Date of comments: 26 May 2020 Reviewer: John Anderson Also, please see emails sent 5/25/2020 12:41 PM, 5/26/2020 12:06 PM. 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. 1. Revise WP0201800027 SWPPP a. Include SWPPP title reference to WP0201800027 Amendment 1. b. Include rev. ESC and SWM plan sheets, once comments addressed. 2. Engineering needs two (2) print copies, once Plan Amendment is approved. B. Pollution Prevention Plan (PPP) — See, above. Revise Exhibit, as needed. The PPP content requirements can be found in County Code section 17-404. C. Stormwater Management Plan (SWMP) VSMP Regulation 9VAC25-870-108 requires the VSMP authority to approve or disapprove a SWMP. This Amendment plan is disapproved for reasons listed below. The stormwater management plan content requirements can be found in County Code section 17-403. 1. Provide design features required with a Level II wet pond, including aeration (see VA DEQ Design Specification 14, p. 3, Level 11 Design Guidance, table 14.2). Note: MJH Apartments contributing DA is insufficient for proposed wet pond to function reliably as a Level 11 wet pond, but the practice was approved with WP0201800027. Ref. VA DEQ Stormwater Design Specification No. 14, .55, Contributing Drainage Area: `A contributing drainage area of 10 to 25 acres is typically recommended...' 2. Provide calculation or table showing that wetlands constitute > 10% of level II pond area. Withdrawn. Ref. sheet 7. As follow-up: List surface area of wet pond at elev. 380' on sheet 7. 3. Provide water balance calculation to assess whether the wet pond will draw down by more than 2 feet after a 30-day summer drought. (Contributing Drainage Area (spec. 14)) Withdrawn, see email sent 5/26/2020 12:06 PM. Also, p. 20 Cale. packet, 4/22/20. Engineering Review Comments Page 2 of 3 4. If wet pond level drawdown exceeds 2-ft during a 30-day summer drought, provide remedy. See equations in Sec. 6.2 of VA DEQ Stormwater Design Specification No. 14. Withdrawn, pond drawdown does not exceed 2-ft.; see email sent 5/26/2020 12:06 PM 5. On -site requirement: Consider 9VAC25-870-69.B.3. which requires 75% of phosphorus nutrient reductions be achieved on -site. 6. Provide 75% on -site reduction, else demonstrate that alternative site designs have been considered to accommodate on -site best management practices. 7. Consider additional on -site practices; for example: biofilters or Filterra units. Filterras offer promise since they may be installed in 100% impervious parking areas. 8. Note: Albemarle request does not penalize developer or designer, or create new requirements; rather, request is to comply with 9VAC25-870-69.B.3., a requirement applicable to initial application. 9. Note: Initial third -party comments should have noted requirements listed at 9VAC25-870-69.B.3., and requested demonstration satisfying requirements at 9VAC25-870-69.B.3. We regret we did not catch it, then. 10. Reviewer is of the opinion that while WPO201800027 Approval stands, initial approval does not grant or convey approval to an Amendment that must meet applicable design requirements. 11. At present, VRRM.xls New Development worksheet indicates 13.60 lb. reduction required. Amended limits of disturbance=17.17ac. (sheet 4B); therefore, the project is ineligible to purchase more than 25% of total reduction required, or more than 3.4 lb. 12. By bill of sale dated 15 May 2020, project provides 6.24 lb. nutrient credits to be applied to WPO201800027. These credits are accepted as applicable to approved plan WPO201800027. 13. While 6.24 lb. purchase is accepted, sheet 6 of Amended plan states that `the remaining water quality balance of 6.68 lbs/year of phosphorus will be met by the best management practice of purchasing nutrient credits.' There is a 0.441b. deficit. 14. Engineering requests that at a minimum, design be revised to propose additional on -site best management practices (filterra units, for example) that provide, at a minimum, 0.44 lbs./phosphorus reduction. 15. Provide sheet 1 Narrative explaining Amendment to approved WPO201800027. 16. Engineering encourages consistency between WPO and Final Site Plan titles: one reads Martha Jefferson Hospital Apartments while the other reads Martha Jefferson Hospital Presidio Apartments. Also, owner listed with final site plan (Presidio Pantops, LLC /Castle Development Partners, LLC) differs from owner listed with WO plan. 17. Incorporate pond aeration included with Fig. 14.1 (sheet 9) in plan view of level II wet pond on sheet 7. 18. Sheet 7: Revise Aquatic bench (Zone 1) Planting Schedule for SWM Facility table to include quantities estimated required to provide listed coverage (sf). 19. Calc. packet p. 10: DA A + DA B area =11.71 Ac. Calc. packet /Site Information (VRRM.xls), n. 30, lists 17.17 Ac. project site. Provide narrative description and calculations addressing compliance for site areas not included with DA A or DA B. Note I: Sheet 6 indicates proposed grading /project activity outside DA A and DA B. These areas appear to discharge (as sheet flow) without detention. Consider these areas. Provide narrative relative to 9VAC25- 870-66. Note2: Area of wet pond calculated at elev. 380' should be listed (in future project) tables of post - developed impervious areas. 20. Sheet 7: Include labels requiring Warning /'No trespassing' signs (unless overlooked) since permanent pools present risk of drowning, esp. to youth /children. Signs must be prominent, lettering highly visible. Text, sign material /type, and placement are at Applicant's discretion, but Engineering recommends several signs at approaches to wet pond at each end of tiered retaining walls. D. Erosion and Sediment Control Plan (ESCP) - Approved with WPO201800027 / Amendment, NA Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESCP. This Amendment does not substantially revise or affect the Approved ESC Plan. See WPO201800027. The VSMP permit application and all plans may be resubmitted for approval when all comments have been satisfactorily addressed. Please provide digital version of revised plan /SWPPP with a completed application form. Engineering Review Comments Page 3 of 3 Process: Once review comments addressed: • SWM Facility Maintenance Agreement recorded at bk.-pg. 5263-485. • 6.24 lb. Nutrient credits are purchased /valid for use with this project. (15 May 2020) Note: Project must provide a minimum 0.44lb/yr. additional phosphorus reduction on -site. • SWM Facility Easement plat recorded at bk.-pg. 5276-400, 2/12/20. • VAR10 permit required prior to receiving a Grading Permit. • VSMP /WPO plan bond is prerequisite to a Grading Permit. • Engineering understand WPO plan bond is in process. County forms can be found on the county website forms center under engineering; hLtp://www.albemarle.ory/deptfonns.asp?departinent=cdengMo WP0201800027_MJH Apts_VSMP Plan Amend_1 _052620