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HomeMy WebLinkAboutWPO201500031 Correspondence 2015-07-06 40 Atlanta Environm Mana:ement Inc. Environmental Consulting.Engineering.Hvdrogeologic Services July 6, 2015 County of Albemarle Department of Community Development 401 McIntire Road, Room 227 Charlottesville, Virginia 22902-4596 Re: Response to VSMP Permit Plan Review Dated June 8, 2015 Wilson Jones Company RCRA Corrective Action 5327 Three Notch'd Road, Crozet, Virginia 22932 Project File Number: WPO-2015-00031 AEM Project No. 1426-1306-1502.1 Dear Mr. Deel: On behalf of Wilson Jones Company, Atlanta Environmental Management, Inc. (AEM) is providing this response to your comments regarding the Storm Water Pollution Prevention Plan dated May 11, 2015. Comment 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. Provided SWPPP appears to adequately address all items in County Code section 17-405. Please reflect below requested changes in resubmitted SWPPP. Response: No edits, additions, or deletions required. Comment B: Pollution Prevention Plan (PPP)—The PPP content requirements can be found in County Code section 17-404. 1. Provided PPP appears to adequately address all items in County Code section 17- 404. Response: No edits, additions, or deletions required. Comment 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. 1. Please explain what is to be done with the excavated material. Response: Figure 6 was revised to indicate that "Excavated materials will be properly manifested and transported off-site for landfill disposal. Soils and debris will be disposed of in permitted facilities." 2. Are the "refurbished and/or installed access roads"to be permanent or temporary? If they are intended to remain in place, a nutrient (phosphorus) load reduction is 2580 Northeast Expressway • Atlanta,Georgia 30345 Telephone:(404)329-9006 • Fax:(404)329-2057 County of Albemarle—Departnt of Community Development -r✓ July 6, 2015 Page 2 �+- required, as there will be an increase in impervious cover. Please remove the access roads once excavations are complete or provide SWM to account for the increase in imperviousness. Additionally, the existing roads or paths on this parcel do not appear to have cover, therefore refurbishment (adding crushed stone) will result in an increase in impervious cover requiring load reduction. Load reduction calculations [must] be performed using the Virginia Runoff Reduction Method (VRRM) spreadsheet, which can be found at http://www.deq.virginia.gov/Programs/Water/Laws,Regulations,Guidance/Guidance/ Storm waterManagementGuidance.aspx Response: The refurbished gravel roads are permanent. Under the direction of Mr. Justin Deel, County of Albemarle, Department of Community Development, the Virginia Runoff Reduction Method (VRRM) spreadsheet model was run and the results were evaluated in accordance with the appropriate evaluation criteria. Figure 6 was revised to include the identification of "grass channels" and "conserved open space." The VRRM spreadsheet results have been included in Section 5—Storm Water Management Plan. Comment D: 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, 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. Please show "construction entrance" (CE) [Virginia Erosion & Sediment Control Handbook, 3.02]on E&SC plan. Response: Figure 4 was revised to indicate the location of the construction entrance and the location of the stockpile areas. 2. Please show staging and stockpile areas on plan. Response: Figure 4 was revised by the addition of Note 7 to indicate that "Any soil staged or stockpiled will be covered by polyethylene sheeting." If you need anything else or have any questions, please call us at 404-329-9006. Sincerely, Atlan • E , tal Management, Inc. Arr ✓tw • 1111 Stern, P. . Project Man-ger /krf '%J.- c: Allyson Wilcox (Wilson Jones Company) Janet Hart (AEM) AEM 15-082RTGRESPONSE TO VSMP PERMIT PLAN REVIEW GATED JULY 6,2015