HomeMy WebLinkAboutWPO201400082 Review Comments 2014-09-15 John Anderson
From: John Anderson
Sent: Monday, October 20, 2014 3:34 PM
To: Frank Pohl
Cc: Glenn Brooks; Justin Deel; Max Greene; Michelle Roberge
Subject: RE: WP0201400082-Church Road SWM Facility
Frank,
Water protection ordinance, County Code, Ch-17:
1. A project is subject to the VSMP if land disturbance> 10,000sf(§17-302.A), and if not specifically
exempt(§17-303.A-H).
2. §17-304—Determining status of a land disturbing activity or a site condition. The Administrator shall
determine: A. "whether an activity is subject to this chapter. Whether an activity is a land disturbing
activity and, if it is so, whether it is subject to the VESCP, the VSMP, or both, or whether it is exempt
therefrom."
3. SWPPP, dated 5-Sep-2014, lends this description: "The proposed project will be a stormwater
management facility. The facility will be a constructed wetland, approximately 0.485 acres in size. The
subject property is located off Seminole Trail at the intersection of Hillside and Incarnation Drive. The
proposed area of disturbance is 1.73 acres."
4. With area of disturbance>10,000 sf, this project evades categorization. It creates stormwater
management,but not a need for it. The project is biological in design. It improves water quality via
pools and marshes planted as riparian buffer, high marsh wetland, and low marsh wetland using a range
of plant species. 4 wetland cells (sheet 4)provide 0.250, 0.034, 0.015, and 0.186 Ac of treatment.
5. §17-700 applies to "Activities that cause or allow to be caused direct or indirect illicit discharges, illicit
connections, and the prohibited dumping of refuse and pollutants, or which negatively impede the flow
capacity of the County's MS4 or State waters that: (i) are not covered by other articles of this chapter
and (ii) are not expressly exempt from this article."
6. §17-701,Illicit discharges prohibited; exempt and authorized discharges., A. Conditionally exempt
discharges. "The following discharges are not prohibited discharges provided that the administrator
determines that the discharge is not adversely impacting State waters: (§17-701.A.4): "Discharges
associated with any activity by the County, its employees and agents, in the maintenance of any
component of a County-maintained stormwater management facility conducted in accordance with
applicable State and Federal regulations and standards."
7. §17-300: "Land disturbance of 10,000 square feet or more is subject to all applicable requirements of the
VESCP in this chapter and under State law."
The project requires an ESCP. The only permanent constructed element of this project is a SWM facility(4
wetland cells), with proposed project activity confined to lower elevations of an existing basin. There is no
potential for increased runoff, once stabilized. Once stabilized, plants and biotic aquatic communities will
effect natural removal of phosphorus. No additional stormwater management facilities are required or
recommended. A SWPPP—an element of a VSMP permit application—is not required (§17-401).
Thank you, Frank—I appreciate your note. I'll see you tomorrow.
John/434.296-5832—x3069
From: Frank Pohl
Sent: Monday, October 20, 2014 1:55 PM
To: John Anderson
Cc: Max Greene; Glenn Brooks; Dar f Pait @kimley-horn.com; rachel.watts @kim horn.com
Subject: RE: WPO201400082 -Church Road SWM Facility
John,
Thanks for your help in reviewing the resubmittal.As mentioned and noted during the application meeting a few weeks
ago, this project does not need to meet SWM requirements,just ESC requirements,which is why the first 5 comments
were not addressed. I thought we needed to submit the revised SWPPP, but you seem to think a SWPPP is not required
if there are no SWM requirements. Please confirm.
Please note that Max previously mentioned that full size plans were not needed for the SWPPP. I didn't think about the
ESC portion of the review and will submit full-size plans tomorrow.
We also discussed the silt fence limits.There is approximately 15 ft between the SF and LOD, which isn't enough, as you
pointed out,to accommodate the construction of the proposed improvements,which needs about 25-ft.We will revise
this with the ESC drawings that will be submitted tomorrow.
I'll hand deliver the drawings when they come in and hopefully you will have less than 5 minutes to look at this with me
to confirm Glenn's comments were addressed.
Thanks,
Frank
Frank V. Pohl,PE
Senior Project Manager
Office of Facilities Development
County of Albemarle
401 McIntire Road, Room 228
Charlottesville,Virginia 22902-4596
T (434) 872-4501 ext. 9-7914
F (434) 972-4091
C (434)466-7458
From: John Anderson
Sent: Monday, October 20, 2014 9:32 AM
To: Frank Pohl
Cc: Max Greene; Glenn Brooks
Subject: WPO201400082 -Church Road SWM Facility
Frank,
I reviewed plan sheets included with revised SWPPP we received 10/9/14. I am only able to review sheets included with
the SWPPP since full-size sheets were either misplaced, or not included. We need full-size plan sheets. I hope you can
help with this—in the interim, I've compared SWPPP (10/07/14 rev. plans) against 24-Sep-14 Engineering review
comments:
Unofficial response to revised SWP/ESC plans.
SWMP comments, 1-5:
1. Not addressed; SWPPP project description insufficient
2. Not addressed—no information, cannot evaluate design against comment.
3. Not addressed.
2
4. Not addressed. wow `'"`
5. Not addressed.
ESCP comments, 1-4:
1. Not addressed.
2. Addressed.
3. Not addressed. The hard corners persist. Room is needed to work outside wetlands near stream inlet to
complex.
4. Uncertain if addressed—need clarification.
Anything you can do to facilitate revisions I can review officially would be helpful. Also,while SWPPP,Sec. C.,
Construction Phase "Best Management Practices" states that `the locations of solid waste containers must be shown on
the site maps,'they are not. Location of sanitary facilities is likewise not shown on site maps, as stated. Minor: sheet 4
label—`Diversion Weir Elev. =432.4' does not match any weir detail elevation (4 Elev.shown in detail); would like
clarification.
I can send official comments, if helpful. I cannot approve project on basis of plans included with SWPPP (in light of 24-
Sep comments—Attached)
Thanks for your patience
John E.:Anderson,PE 1 Civil Engineer II
Department of Community Development I County of Albemarle,Virginia
401 McIntire Road(Charlottesville,VA 22902
434.296.5832 ext.3069
3
OF Al
vIRG1,
COUNTY OF ALBEMARLE
Department of Community Development
401 McIntire Road, Room 227
Charlottesville, Virginia 22902 -4596
Phone (434) 296 -5832 Fax (434) 972 -4126
Project title:
Project file number:
Plan preparer:
Owner or rep.:
Plan received date:
Date of comments:
Reviewers:
VSMP Permit plan review
Church Road Basin
WP0201400082
Kimley Horn and Assoc., Inc. [email]
Albemarle County, c/o Frank Pohl [fpohl @albemarle.org]
10 Sep 2014
24 Sep 2014
Max Greene, Glenn Brooks
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 ESOP, (3) a SWMP, and (4) any TMDL measures necessary.
1. A generic SWPPP document was provided, but it was unsigned and incomplete, including a blank
registration statement. Please complete all documents.
A. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17 -404.
1. A PPP was not found.
B. 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.
1. Please provide a narrative to explain the purpose and methods of this plan. As there is no removal
requirement for the project itself, which appears to be a basin enhancement, some explanation is
needed.
2. The drainage area to the basin needs more explanation. Please show all the pipe and conveyance
systems which direct runoff to the basin. It has been our understanding that many of the developments
across Hillsdale Drive are not draining to this basin.
3. There is not enough information provided to check the VRRM input. Provide soils data on the
drainage maps.
4. There is not enough information provided to check the wetland design. Provide a complete check of
Table 13.2 criteria from the specification.
Engineering Review Comments
Page 2 of 3
5. There appears to be some sort of channelization and flow splitting in the basin, but there were no
details or computations found for this feature.
C. 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. Silt fence will not keep sediment laden waters from going downstream when the basin fills. A
dewatering strategy is needed, along with a temporary riser on the culvert structure. It appears the
entire area will act as a sediment basin.
2. Increase the limits to include work noted outside the limits on the plan.
3. Draw realistic limits of disturbance. The hard corners are not realistic, and room is needed to work
outside the wetlands.
4. The CE is shown over a steep slope, with a turn. Show grading to accomplish this.
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
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
Engineering Review Comments
Page 3 of 3
work may begin.
County forms can be found on the county website forms center under engineering;
http://www.albemarle.org/deptforms.asp?department=cdengwpo