HomeMy WebLinkAboutWPO201800019 Review Comments WPO VSMP 2018-07-20COUNTY 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: River Run Stream Restoration
Project file number: WP0201800019
Plan preparer: Kip Mumaw, Ecosystems Services [Kip@ecosystemservices.us]
Owner or rep.: City of Charlottesville [stephensm@charlotesville.org]
Plan received date: March 15th, 2018
Date of comments: March 26th, 2018
Reviewers: Bobby Jocz
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 ESCP, (3) a SWMP, and (4) any TMDL measures necessary.
1. Provide Project number [WP0201800019] on the SWPP document and cover sheet of plans.
2. No SWPPP document provided, please provide a project SWPPP.
3. Please provide a completed DEQ registration statement.
4. Project narrative on cover sheet references the project to be in Harrisonburg, VA, which is
incorrect. Please correct.
5. Provide copy ofpermit(s) (COE, DEQ, etc.) allowing stream impacts.
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
No PPP provided. Please provide a PPP as part of the SWPPP document.
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, 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. Provide detail for construction road per VESCH Spec. 3.03.
2. Indicate locations where Permeant and Temporary Seeding will be applied.
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 Review Comments
Page 2 of 2
Engineering plan review staff are available from 2-4 PM on Thursdays, should you require a meeting to
discuss this review.
County forms can be found on the county website forms center under engineering;
http://www.albemarle.or /g deptforms.asp?department=cdengnoo
Bobby Jocz
Albemarle County
Community Development — Engineering
rjocz@albemarle.org
(434) 296-5832 ext. 3283
COUNTY 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:
River Run Stream Restoration
Project file number:
WP0201800019
Plan preparer:
Kip Mumaw, Ecosystems Services [Kip@ecosystemservices.us]
Owner or rep.:
City of Charlottesville [stephensm@charlotesville.org]
Plan received date:
March 151, 2018
(Rev. 1)
April 10, 2018
Date of comments:
March 26', 2018
(Rev. 1)
May 14, 2018
Reviewers:
Bobby Jocz / John Anderson (Rev.)
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 ESCP, (3) a SWMP, and (4) any TMDL measures necessary.
1. Provide Project number [WP0201800019] on the SWPP document and cover sheet of plans. (Rev. 1)
Partially Addressed; initial intent was to revise plan Title to include WPO#. Please revise plan title to
read River Run Stream Restoration. VSMP /WP02018-00019 (delete ref. to 90% plans).
2. No SWPPP document provided, please provide a project SWPPP. (Rev. 1) Partially Addressed; as
follow- u , see New comments below
3. Please provide a completed DEQ registration statement. (Rev. 1) Addressed.
4. Project narrative on cover sheet references the project to be in Harrisonburg, VA, which is incorrect. Please
correct. (Rev. 1) Addressed.
5. Provide copy of permit(s) (COE, DEQ, etc.) allowing stream impacts. (Rev. 1) Addressed.
New (Rev. 1)
SWPPP
Link county template:
httD://www.albemarle.ore/uDload/imaRes/forms center/departments/Community Develmment/forms/Eneineerine and WPO Forms/Stormwater
Pollution_ Prevention_ Plan SWPPP_template.pdf
6. Compare SWPPP provided with county template. Applicants are encouraged but not required to use county
template, which provides all required items. Certain items are not included with SWPPP, including copy of
GP2014 (Sec. 11, v. Ecosystem Appendix B), Delegation of Authority form (Sec. 10), ESC plans (Sec. 4,
11" x 17" reduced plans, v. Ecosystem Appx. C), SWPPP Exhibit (Sec. 6.A.), etc. Provide items consistent
with Albemarle County SWPPP template.
7. Include Ecosystem Name, Address, Telephone, principal contact on SWPPP cover. (Authorship)
8. Sec. 2, Ecosystem SWPPP: Delete ref. to Kenny Thacker. Albemarle County staff is not assigned SWPPP
compliance responsibility. Environmental compliance will be delegated from initial Construction Activity
Operator, Walter Harris /County of Albemarle, to Contractor.
9. Applicant should contact Engineering to confirm plan to either revise existing SWPPP, or, alternatively,
Engineering Review Comments
Page 2 of 5
transfer SWPPP data to County template. If intent is to revise existing, additional review comments on
Ecosystem tailored-SWPPP will be sent within 5 business days. Please notify Engineering of intent.
SWM Plan
10. Title Sheet, General Note 1: Note does not ensure compliance with storm quality or quantity requirements.
Ref. 9VAC25-87065 and -66. The SWM Plan content requirements can be found in County Code section
17-403. Provide a SWM Plan.
11. Ensure SWM Plan compares pre -development (Existing SWM Facility ID 0091-02) with post -developed
conditions (restored stream —BMP modified, or removed).
12. Clarify whether existing SWM Facility ID 0091.02 is removed with project. Analyze effect of removal on
stormwater quality and quantity.
13. Provide pre- and post -development drainage area maps.
14. Provide pre- and post -development storm routings, Q2, Qio.
15. Use VaRRM .xls to calculate total Phosphorus load removal requirement, or credit. This is a TMDL
project, so Engineering anticipates Phosphorus credits. Provide calculations.
16. SWM Quantity: Recommend provide general statement similar to that provided by A/E on similar project:
"This stream restoration project seeks to reestablish a floodplain connection in order to dissipate energy associated
with higher flow events. The design recognizes the suburban nature of the contributing drainage area and includes
elements, such as reinforced bed material, to create a more stable natural channel. The project anticipates future
watershed development and techniques used, in combination with state stormwater legislation (the Energy Balance
Method, for instance), will help guard against future degradation. Native riparian plantings are included to enhance
the sites forested conditions and will be protected through establishment of permanent conservation easements.
Thus, this project meets the requirements of State Code 9VAC25-870-66.8.3." (WSSI, Chapel Hills Stream Restoration)
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
1. No PPP provided. Please provide a PPP as part of the SWPPP document. (Rev. 1) Partially addressed; as
Engineering Review Comments
Page 3 of 5
ollow-u,see SWPPP comments above (New rev). County template includes PPP table that is acceptable;
reviewer has not performed detailed evaluation of PPP provided.
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, 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. Provide detail for construction road per VESCH Spec. 3.03. (Rev. 1) Partially addressed; as follow-up,
revise Hardwood Mat and Mulch Access Road Detail Note 3 to read "(see detail, left)". Also, recommend
emphasize equipment selection may trigger hardwood mat requirement for roads that may approach 1,000'
in total length. Also, provide ESC measures along construction road/s —ref. New comments, below.
2. Indicate locations where Permeant and Temporary Seeding will be applied. (Rev. 1) Not Addressed.
Provide PS / TS /MU (straw mulch) symbols to Sheet 6. Also, see additional New ESC Plan comments.
New (Rev. 1)
Sheet 6
3. Revise to require 4 day inspection frequency, wherever text indicates 7 or 10 day inspection frequency.
VPDES CGP requires enhanced frequency inspections for impaired waters. This is an upstream tributary of
Meadow Creek, a TMDL impaired stream. Ref. VAR10, Part I, B.4.d.(1).
4. Sequence of Construction Note 7 —require rain gauge. Delete NOAA as an onsite inspection indicator.
NOAA is a planning resource not reliable as onsite check of measurable precipitation events (>0.25").
5. Sequence of Construction Note 8 is problematic: compare proposed /existing streambed grade, Sheet 3.
Revise note, consistent with proposed /existing grade.
6. Sequence of Construction Note 8: "Upstream dam and current culvert conditions will be utilized as a
temporary erosion and sediment control trap" requires clarification. Clarify graphically: include plan labels
to make clear intent of this statement. Explain further.
7. Sequence of Construction Note 9: Revise note to require approval of county ESC inspector.
8. Provide sequence that details removal of existing BMP.
9. For proposed sediment trap/s (ST), provide profile per VESCH. Calculate and show drainage area to STs.
10. For proposed ESC measures, provide profile detail to aid construction and inspection, per VESCH.
11. ESC VSMP Waiver Conditions, Note 1: This note does not provide or establish design principles useful to
SWM plan approval. Ref. SWM Plan comments, above.
12. ESC VSMP Waiver Conditions, Note 2: This note is inconsistent with requirement to stabilize disturbed
areas by the end of each work day. Total land disturbance estimated at 2.02 Ac. Revise or delete note.
13. ESC General Note 4: "Alternative methods shall be discussed and determined to prevent downstream
sedimentation from active construction activities," is ambiguous, and appears to obligate contractor or
owner to ongoing ESC plan design. A/E must develop an ESC plan, including sequence of construction that
reasonably anticipates and prevents downstream sedimentation. Delete or revise statement.
14. There are 3 or more references to multiple and varying stabilization schedules for street cleaning, temporary
seeding, permanent seeding and general seeding. Multiple references to stabilization, inspection, ESC
measure monitoring and repair, street debris removal, etc., create confusion. Tie all references to
stabilization or inspection or ESC measure monitoring and repair to VESCH, Third Edition, 1992, and
VPDES CGP (2014). Delete, revise, or eliminate inaccurate or extraneous reference —for example, to
Stabilization Note 1, sheet 8; General Seeding (delete).
15. ESC General Notes, 6, 7, 8: Define how quickly stabilization measures will occur; specify timeline.
16. Plans lack clear layout for ESC Measure notes, narrative, conditions, sequence, and unnecessary,
duplicative, or inaccurate references, statements, commitments or requirements. Much of the text on sheet 6
is repeated on Sheet 8. Review text closely with goal to revise for clarity, and eliminate inaccurate or non-
essential text. Please make a determined focus in this regard with next submittal.
17. Label contours.
18. Show grading required for construction roads, if any.
19. Silt fence (SF) is inadequate; SF is required downslope of construction roads, at point roads turn at foot of
slope, as an example.
20. Provide an array of ESC measures, including: tree protection, diversions, check dams, culverts, and traps at
Engineering Review Comments
Page 4 of 5
lower limits of construction roads.
21. Provide ESC measure legend using VESCH symbols. (soil stockpile, topsoil, permanent /temporary
seeding, straw mulch, items listed immediately above)
22. Label construction roads.
23. Show construction roads tying to existing paved surface.
24. Show project design /clearing limit impact on existing forest. Plans must show limits of forest clearing.
25. Provide separate plan sheet at V =20' scale so plan view details readable.
Sheet 8
26. Eliminate ESC Minimum Standards (column of text), entirely.
27. Incorporate ESC Minimum Standard requirements in ESC Plan design.
28. Review all text, this plan sheet, for internal consistency —see Sheet 6 comments, above.
29. ESC Narrative Site Description includes reference to Blacks Run -Lower North River Watershed and South
Fork Shenandoah River. Revise.
30. ESC Note 5: Eliminate reference to Developer /Developer's Representative. Contractor responsible.
Revise.
31. ESC Note 9: Ref. VESCH Std. and Spec. 3.31 for correct timing of stabilization. Revise.
32. Delete ref. to Temporary Soil Stabilization under Permanent Seeding Std. & Spec. 3.32.
33. Critical Erosion Areas: Expand, clarify, explain, and provide measures deemed adequate to protect critical
erosion areas. If this statement is general reference to existing conditions, explain how or why this matters.
34. Revise Off -Site Areas ref. that reads: "... a proper disposal location with an approved SWPPP and ESC Plan
will be provided," to state Contractor is to provide SWPPP and ESC Plan for off-site areas.
35. Stormwater Runoff Considerations Note. Delete; see comments on SWM Plan requirements, above.
36. Revise roadway debris cleanup timeline from immediately to read, "immediately, but not later than the end
of each workday."
37. Provide VAR10, VAC, or VESCH reference in support of statement: "Maintenance shall be performed
before the next anticipated storm event," else revise statement consistent with VAR10, VESCH, etc.
38. Acquire and provide copy of all required easements prior to plan approval.
Title Sheet —
39. General Note 16: revise to require approval of county ESC inspector.
40. Provide Vicinity Map that shows county /city limits boundary.
Engineering Review Comments
Page 5 of 5
41. List TMP#s (City of Charlottesville; Albemarle County).
42. Provide project location: List nearest physical address.
43. Sheets 2/3: Label LOD Area (SF). Provide 1" =30' scale view or plan sheet that shows full extents of LOD.
Sheet 2:
44. Label existing BMP, include Facility ID (0091-02); identify type of BMP.
45. Label stream, if perennial.
46. Show /label steep slopes.
47
48
49
Show tree line. If entire site is forested, provide note that entire site is forested.
Sheet 3: Show and provide site access grading.
Sheet 7: Provide temporary stream crossing detail, if needed.
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.
County forms can be found on the county website forms center under engineering;
http://www.albemarle.org/deptforms.asp?department=cdengMTo
John Anderson
Albemarle County
Community Development — Engineering
Janderson2 na,albemarle. org
(434) 296-5832 ext. 3069
VSMP River Run Stream Restoration WP0201800019-revO5l4l8.doc
COUNTY 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:
River Run Stream Restoration
Project file number:
WP0201800019
Plan preparer:
Kip Mumaw, Ecosystems Services [Kip@ecosystemservices.us]
Owner or rep.:
City of Charlottesville [stephensm@charlotesville.org]
Plan received date:
March 151, 2018
(Rev. 1)
April 10, 2018
(Rev. 2)
June 11, 2018
Date of comments:
March 26th, 2018
(Rev. 1)
May 14, 2018
(Rev. 2)
July 17, 2018
Reviewers:
Bobby Jocz / John Anderson (Rev. 1, 2)
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 ESCP, (3) a SWMP, and (4) any TMDL measures necessary.
1. Provide Project number [WP0201800019] on the SWPP document and cover sheet of plans. (Rev. 1)
Partially Addressed; initial intent was to revise plan Title to include WPO#. Please revise plan title to
read River Run Stream Restoration, VSMP AVP02018-00019 (delete ref. to 90% plans). (Rev. 2)
Addressed.
2. No SWPPP document provided, please provide a project SWPPP. (Rev. 1) Partially Addressed; as
follow-up, see New comments below
3. Please provide a completed DEQ registration statement. (Rev. 1) Addressed.
4. Project narrative on cover sheet references the project to be in Harrisonburg, VA, which is incorrect. Please
correct. (Rev. 1) Addressed.
5. Provide copy of permit(s) (COE, DEQ, etc.) allowing stream impacts. (Rev. 1) Addressed.
New (Rev. 1)
SWPPP - see email, 7/11/2018 2:40 PM; County SWPPP template required. Also, a meeting to discuss Engineering
plan review comments is scheduled 7/18, 1pm, Engineering Conference Room.
Link, county template:
htto://www.albemarle.orv/uDload/imaues/forms center/departments/Community Develonment/forms/Eneineerine and WPO Forms/Stormwater
Pollution Prevention Plan SWPPP template.pdf
6. Compare SWPPP provided with county template. Applicants are encottr ge but nOt (Rev. 2) required to use
county template, which provides all required items. Certain items are not included with SWPPP, including
copy of GP2014 (Sec. 11, v. Ecosystem Appendix B), Delegation of Authority form (Sec. 10), ESC plans
(Sec. 4, 11" x 17" reduced plans, v. Ecosystem Appx. C), SWPPP Exhibit (Sec. 6.A.), etc. Provide items
consistent with Albemarle County SWPPP template. (Rev. 2) As follow-up, see email, 7/11/2018 2:40
PM; County SWPPP template required.
Engineering Review Comments
Page 2 of 6
7. Include Ecosystem Name, Address, Telephone, principal contact on SWPPP cover. (Authorship) (Rev. 2)
Not addressed.
8. Sec. 2, Ecosystem SWPPP: Delete ref. to Kenny Thacker. Albemarle County staff is not assigned SWPPP
compliance responsibility. Environmental compliance will be delegated from initial Construction Activity
Operator, Walter Harris /County of Albemarle, to Contractor. (Rev. 2) Addressed.
9. Applicant should contact Engineering to confirm plan to either revise existing SWPPP, or, alternatively,
transfer SWPPP data to County template. If intent is to revise existing, additional review comments on
Ecosystem SWPPP will be sent within 5 business days. Please notify Engineering of intent. (Rev. 2) As
follow-up, see email, 7/11/2018 2:40 PM; County SWPPP template required..
SWM Plan — (Rev. 2) Comments 10.-16., below, not Addressed (see email sent 7/13/2018 6:02 PM). Also,
meeting to discuss Engineering plan review comments is scheduled 7/18, 1pm, Engineering Conference Room.
10. Title Sheet, General Note 1: Note does not ensure compliance with storm quality or quantity requirements.
Ref. 9VAC25-870-65 and -66. The SWM Plan content requirements can be found in County Code section
17-403. Provide a SWM Plan. (Rev. 2) Not addressed.
11. Ensure SWM Plan compares pre -development (Existing SWM Facility ID 0091-02) with post -developed
conditions (restored stream —BMP modified, or removed). (Rev. 2) Not addressed.
12. Clarify whether existing SWM Facility ID 0091.02 is removed with project. Analyze effect of removal on
stormwater quality and quantity. (Rev. 2) Not addressed.
13. Provide pre- and post -development drainage area maps. (Rev. 2) Not addressed.
14. Provide pre- and post -development storm routings, Qz, Q10. (Rev. 2) Not addressed.
15. Use VaRRM .xls to calculate total Phosphorus load removal requirement, or credit. This is a TMDL
project, so Engineering anticipates Phosphorus credits. Provide calculations. (Rev. 2) Not addressed.
Data provided lacks context. Recommend discuss during review comment meeting, 7/18, 1pm.
16. SWM Quantity: Recommend provide general statement similar to that provided by A/E on similar project:
"This stream restoration project seeks to reestablish a floodplain connection in order to dissipate energy associated
with higher flow events. The design recognizes the suburban nature of the contributing drainage area and includes
elements, such as reinforced bed material, to create a more stable natural channel. The project anticipates future
Engineering Review Comments
Page 3 of 6
watershed development and techniques used, in combination with state stormwater legislation (the Energy Balance
Method, for instance), will help guard against future degradation. Native riparian plantings are included to enhance
the sites forested conditions and will be protected through establishment of permanent conservation easements.
Thus, this project meets the requirements of State Code 9VAC25-870-66.8.3." (WSSI, Chapel Hills Stream Restoration)
(Rev. 2) Not addressed.
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
1. No PPP provided. Please provide a PPP as part of the SWPPP document. (Rev. 1) Partially addressed; as
follow-up, see SWPPP comments above (New rev). County template includes PPP table that is acceptable;
reviewer has not performed detailed evaluation of PPP provided. (Rev. 2) Anticipate with County SWPPP
template (Sec. 6). Also, Sec. 6 Exhibit required. Samples available.
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; reasons are provided, below. The erosion control plan content requirements can be found in
County Code section 17-402.
1. Provide detail for construction road per VESCH Spec. 3.03. (Rev. 1) Partially addressed; as follow-up,
revise Hardwood Mat and Mulch Access Road Detail Note 3 to read "(see detail, left)". Also, recommend
emphasize equipment selection may trigger hardwood mat requirement for roads that may approach 1,000'
in total length. Also, provide ESC measures along construction road/s ref. New comments, below. (Rev.
2) Addressed.
2. Indicate locations where Permeant and Temporary Seeding will be applied. (Rev. 1) Not Addressed.
Provide PS / TS /MU (straw mulch) symbols to Sheet 6. Also, see additional New ESC Plan comments.
(Rev. 2) Partially addressed. Add MU (straw mulch) to legend; show MU on plans.
New (Rev. 1)
Sheet 6
3. Revise to require 4 day inspection frequency, wherever text indicates 7 or 10 day inspection frequency.
VPDES CGP requires enhanced frequency inspections for impaired waters. This is an upstream tributary of
Meadow Creek, a TMDL impaired stream. Ref. VAR10, Part I, 13.4.d.(1). (Rev. 2) Addressed.
(Rev. 2) Comments 4.-9., below, not Addressed. Comment items 4-9 relate to Sequence of Construction,
removed from plans with Rev. 2. Restore sequence of construction as it relates to, or impacts, VSMP plan.
4. Sequence of Construction Note 7 —require rain gauge. Delete NOAA as an onsite inspection indicator.
NOAA is a planning resource not reliable as onsite check of measurable precipitation events (>0.25").
5. Sequence of Construction Note 8 is problematic: compare proposed /existing streambed grade, Sheet 3.
Revise note, consistent with proposed /existing grade.
6. Sequence of Construction Note 8: "Upstream dam and current culvert conditions will be utilized as a
temporary erosion and sediment control trap" requires clarification. Clarify graphically: include plan labels
to make clear intent of this statement. Explain further.
7. Sequence of Construction Note 9: Revise note to require approval of county ESC inspector.
8. Provide sequence that details removal of existing BMP. (Rev. 2) Not Addressed.
9. For proposed sediment trap/s (ST), provide profile per VESCH. Calculate and show drainage area to STs.
(Rev. 2) Not addressed. Plan detail is diminished rather than clarified. If VSMP plan proposes to utilize
the Ex. upstream dam as a temporary erosion sediment control trap, then please address Rev. 1 comment.
10. . (Rev.
2) Withdrawn.
11. ESC VSMP Waiver Conditions, Note 1: This note does not provide or establish design principles useful to
SWM plan approval. Ref. SWM Plan comments, above. (Rev. 2) Addressed.
12. ESC VSMP Waiver Conditions, Note 2: This note is inconsistent with requirement to stabilize disturbed
areas by the end of each work day. Total land disturbance estimated at 2.02 Ac. Revise or delete note.
(Rev. 2) Addressed.
Engineering Review Comments
Page 4 of 6
13. ESC General Note 4: "Alternative methods shall be discussed and determined to prevent downstream
sedimentation from active construction activities," is ambiguous, and appears to obligate contractor or
owner to ongoing ESC plan design. A/E must develop an ESC plan, including sequence of construction that
reasonably anticipates and prevents downstream sedimentation. Delete or revise statement. (Rev. 2)
Addressed.
14. There are 3 or more references to multiple and varying stabilization schedules for street cleaning, temporary
seeding, permanent seeding and general seeding. Multiple references to stabilization, inspection, ESC
measure monitoring and repair, street debris removal, etc., create confusion. Tie all references to
stabilization or inspection or ESC measure monitoring and repair to VESCH, Third Edition, 1992, and
VPDES CGP (2014). Delete, revise, or eliminate inaccurate or extraneous reference —for example, to
Stabilization Note 1, sheet 8; General Seeding (delete). (Rev. 2) Addressed.
15. ESC General Notes, 6, 7, 8: Define how quickly stabilization measures will occur; specify timeline. (Rev.
2) Addressed.
16. Plans lack clear layout for ESC Measure notes, narrative, conditions, sequence, and unnecessary,
duplicative, or inaccurate references, statements, commitments or requirements. Much of the text on sheet 6
is repeated on Sheet 8. Review text closely with goal to revise for clarity, and eliminate inaccurate or non-
essential text. Please make a determined focus in this regard with next submittal. (Rev. 2) Addressed.
17. Label contours. (Rev. 2) Not addressed.
18. Show grading required for construction roads, if any. (Rev. 2) Partially addressed. As follow -un, confirm
no Access grading required.
19. Silt fence (SF) is inadequate; SF is required downslope of construction roads, at point roads turn at foot of
slope, as an example. (Rev. 2) Addressed.
20. Provide an array of ESC measures, including: tree protection, diversions, check dams, culverts, and traps at
lower limits of construction roads. (Rev. 2) Addressed.
21. Provide ESC measure legend using VESCH symbols. (soil stockpile, topsoil, permanent /temporary
seeding, straw mulch, items listed immediately above) (Rev. 2) Partially addressed. Revise legend to
include MU.
22. Label construction roads. (Rev. 2) Addressed.
23. Show construction roads tying to existing paved surface. (Rev. 2) Not addressed. Show /label paved
street at street /CE tie-in. Revise contours to reflect paved street.
24. Show project design /clearing limit impact on existing forest. Plans must show limits of forest clearing.
(Rev. 2) Partially addressed. Recommend discuss 7/18, if necessary.
25. Provide separate plan sheet at 1' =20' scale so plan view details readable. (Rev. 2) Addressed.
Engineering Review Comments
Page 5 of 6
Sheet 8
26. Eliminate ESC Minimum Standards (column of text), entirely. (Rev. 2) Addressed.
27. Incorporate ESC Minimum Standard requirements in ESC Plan design. (Rev. 2) Addressed.
28. Review all text, this plan sheet, for internal consistency —see Sheet 6 comments, above. (Rev. 2)
Addressed.
29. ESC Narrative Site Description includes reference to Blacks Run -Lower North River Watershed and South
Fork Shenandoah River. Revise. (Rev. 2) Addressed.
30. ESC Note 5: Eliminate reference to Developer /Developer's Representative. Contractor responsible.
Revise. (Rev. 2) Addressed.
31. ESC Note 9: Ref. VESCH Std. and Spec. 3.31 for correct timing of stabilization. Revise. (Rev. 2)
Addressed.
32. Del€t€Few. toTempor-ar-y Soil Stabilization undeF Pefmanent Seeding Std. & Spee. 3.32. (Rev. 2)
Withdrawn, review error.
33. Critical Erosion Areas: Expand, clarify, explain, and provide measures deemed adequate to protect critical
erosion areas. If this statement is general reference to existing conditions, explain how or why this matters.
(Rev. 2) Addressed.
34. Revise Off -Site Areas ref. that reads: "...a proper disposal location with an approved SWPPP and ESC Plan
will be provided," to state Contractor is to provide SWPPP and ESC Plan for off-site areas. (Rev. 2)
Addressed.
35. Stormwater Runoff Considerations Note. Delete; see comments on SWM Plan requirements, above.
(Rev. 2) Addressed.
36. Revise roadway debris cleanup timeline from immediately to read, "immediately, but not later than the end
of each workday." (Rev. 2) Addressed.
37. Provide VAR10, VAC, or VESCH reference in support of statement: "Maintenance shall be performed
before the next anticipated storm event," else revise statement consistent with VAR10, VESCH, etc. (Rev.
2) Not addressed.
38. Acquire and provide copy of all required easements prior to plan approval. (Rev. 2) Addressed. As
follow-up, please see plan review email, SUB2018-00091, 7/16/2018 11:14 AM (`No objection')
Title Sheet —
39. General Note 16: revise to require approval of county ESC inspector. (Rev. 2) Addressed.
40. Provide Vicinity Map that shows county /city limits boundary. (Rev. 2) Addressed.
41. List TMP#s (City of Charlottesville; Albemarle County). (Rev. 2) Addressed.
42. Provide project location: List nearest physical address. (Rev. 2) Addressed.
43. Sheets 2/3: Label LOD Area (SF). Provide 1" =30' scale view or plan sheet that shows full extents of LOD.
(Rev. 2) Partially addressed. As follow -un, add Area Acreage label (Ac. /ft).
Sheet 2:
44. Label existing BMP, include Facility ID (0091-02); identify type of BMP. (Rev. 2) Addressed.
45. Label stream, if perennial. (Rev. 2) Addressed.
46. Show /label steep slopes. (Rev. 2) Addressed.
r_rc ic.e S ei)eseree«�
47. Show tree line. If entire site is forested, provide note that entire site is forested. (Rev. 2) Not addressed.
Recommend discuss 7/18/18.
48. Sheet 3: Show and provide site access grading. (Rev. 2) Partially addressed. Please confirm no site
access grading is required.
49. Sheet 7: Provide temporary stream crossing detail, if needed. (Rev. 2) Partially addressed. Label
temporary stream (temporary bridge) crossing. A temporary bridge crossing detail is provided.
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 plans to meet with Applicant /PMD, 7/18/18, 1pm, Engineering conference room, to discuss plan review
Engineering Review Comments
Page 6 of 6
comments on two Water Resource projects (Minor Hill, River Run) and one NIFI project (Rivanna Greenway).
County forms can be found on the county website forms center under engineering;
hllp://www.albemarle.orp-/deptforms.asp?dei2artinent--cdengmMo
John Anderson
Albemarle County
Community Development — Engineering
Janderson20)albemarle. org
(434) 296-5832 ext. 3069
VSMP River Run Stream Restoration WPO201800019-rev2-071718
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:
(Rev. 1)
(Rev. 2)
(Rev. 3)
Date of comments:
(Rev. 1)
(Rev. 2)
(Rev. 3)
Reviewers:
VSMP Permit plan review
River Run Stream Restoration
WP0201800019
Kip Mumaw, Ecosystems Services [Kip@ecosystemservices.us]
City of Charlottesville [stephensm@charlotesville.org]
March 151, 2018
April 10, 2018
June 11, 2018
20 Jul 2018 (.PDF)
March 26th, 2018
May 14, 2018
July 17, 2018
20 Jul 2018 —Eligible for approval pending receipt of recordation of easement/s.
Bobby Jocz / John Anderson (Rev. 1, 2, 3)
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 but eligible for approval
pending recordation of easements (in process). Engineering appreciates Applicant response, and
willingness to meet 7/18, and for your forbearance.
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.
Prior Engineering review comments Addressed; prior comments removed for clarity.
1. Please arrange for Kyle Ashmun to sign Sec. 9 of SWPPP.
SWM Plan — (Rev. 3) Prior Engineering review comments Addressed (scroll for details). Also, Applicant
met with Engineering to discuss review comments on 7/18; this meeting was helpful. This SWM Plan is
approved.
2. Title Sheet, General Note 1: Note does not ensure compliance with storm quality or quantity requirements.
Ref. 9VAC25-870-65 and -66. The SWM Plan content requirements can be found in County Code section
17-403. Provide a SWM Plan. (Rev. 2) Not addressed. (Rev. 3) Addressed. Ref. Kip Mumaw email w/
Attachments (7/20/2018 9:09 AM). Attachments in CV titled: River Run Hydrologic Analysis Overview,
7/19/18 (Ecosystem Services, 24-p.); Pollution Reduction Report —River Run, 12/19/17 (Ecosystem, 8-p.).
3. Ensure SWM Plan compares pre -development (Existing SWM Facility ID 0091-02) with post -developed
conditions (restored stream —BMP modified, or removed). (Rev. 2) Not addressed. (Rev. 3) Addressed.
4. Clarify whether existing SWM Facility ID 0091.02 is removed with project. Analyze effect of removal on
stormwater quality and quantity. (Rev. 2) Not addressed. (Rev. 3) Addressed. Existing SWM Facility is
nonfunctional (pipes broken /blocked, etc.). Discussed 7/18/18.
GIS (Ex. PAIN4 F
5. Provide pre- and post -development drainage area maps. (Rev. 2) Not addressed. (Rev. 3) Addressed.
6. Provide pre- and post -development storm routings, Q2, Q10. (Rev. 2) Not addressed. (Rev. 3) Addressed.
7. Use VaRRM .xls to calculate total Phosphorus load removal requirement, or credit. This is a TMDL
project, so Engineering anticipates Phosphorus credits. Provide calculations. (Rev. 2) Not addressed.
Engineering Review Comments
Page 2 of 4
Data provided lacks context. Recommend discuss during review comment meeting, 7/18, 1pm. (Rev. 3)
Addressed. Discussed 7/18/18; also, see #1, above.
SWM Quantity: Recommend provide general statement similar to that provided by A/E on similar project:
"This stream restoration project seeks to reestablish a floodplain connection in order to dissipate energy associated
with higher flow events. The design recognizes the suburban nature of the contributing drainage area and includes
elements, such as reinforced bed material, to create a more stable natural channel. The project anticipates future
watershed development and techniques used, in combination with state stormwater legislation (the Energy Balance
Method, for instance), will help guard against future degradation. Native riparian plantings are included to enhance
the sites forested conditions and will be protected through establishment of permanent conservation easements.
Thus, this project meets the requirements of State Code 9VAC25-870-66.B.3." (WSSI, Chapel Hills Stream Restoration)
(Rev. 2) Not addressed. (Rev. 3) Addressed /review error; comment addressed with Rev. 2.
B. Pollution Prevention Plan (PPP)
The PPP content requirements can be found in County Code section 17-404.
1. PPP included with SWPPP is adequate.
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 approved.
Provide detail for construction road per VESCH Spec. 3.03. (Rev. 1) Partially addressed; as follow-up,
revise Hardwood Mat and Mulch Access Road Detail Note 3 to read "(see detail, left)". Also, recommend
emphasize equipment selection may trigger hardwood mat requirement for roads that may approach 1,000'
in total length. Also, provide ESC measures along construction road/s —ref. New comments, below. (Rev.
2) Addressed.
Indicate locations where Permeant and Temporary Seeding will be applied. (Rev. 1) Not Addressed.
Provide PS / TS /MU (straw mulch) symbols to Sheet 6. Also, see additional New ESC Plan comments.
(Rev. 2) Partially addressed. Add MU (straw mulch) to legend; show MU on plans. (Rev. 3) Addressed.
New (Rev. 1)
Sheet 6
3. Revise to require 4 day inspection frequency, wherever text indicates 7 or 10 day inspection frequency.
VPDES CGP requires enhanced frequency inspections for impaired waters. This is an upstream tributary of
Meadow Creek, a TMDL impaired stream. Ref. VAR10, Part I, 13.4.d.(1). (Rev. 2) Addressed.
(Rev. 2) Comments 4.-9., below, not Addressed. Comment items 4-9 relate to Sequence of Construction,
removed from plans with Rev. 2. Restore sequence of construction as it relates to, or impacts, VSMP plan.
(Rev. 3) Addressed.
4. Sequence of Construction Note 7 —require rain gauge. Delete NOAA as an onsite inspection indicator.
NOAA is a planning resource not reliable as onsite check of measurable precipitation events (>0.25").
5. Sequence of Construction Note 8 is problematic: compare proposed /existing streambed grade, Sheet 3.
Revise note, consistent with proposed /existing grade.
6. Sequence of Construction Note 8: "Upstream dam and current culvert conditions will be utilized as a
temporary erosion and sediment control trap" requires clarification. Clarify graphically: include plan labels
to make clear intent of this statement. Explain further.
7. Sequence of Construction Note 9: Revise note to require approval of county ESC inspector.
8. Provide sequence that details removal of existing BMP. (Rev. 2) Not Addressed. (Rev. 3) Addressed.
9. For proposed sediment trap/s (ST), provide profile per VESCH. Calculate and show drainage area to STs.
(Rev. 2) Not addressed. Plan detail is diminished rather than clarified. If VSMP plan proposes to utilize
the Ex. upstream dam as a temporary erosion sediment control trap, then please address Rev. 1 comment.
(Rev. 3) Addressed.
10. For proposed ESG measures, provide profile detail to aid eonstmetion and inspeetion, per NIESC14. (Rev.
2) Withdrawn.
11. ESC VSMP Waiver Conditions, Note 1: This note does not provide or establish design principles useful to
Engineering Review Comments
Page 3 of 4
SWM plan approval. Ref. SWM Plan comments, above. (Rev. 2) Addressed.
12. ESC VSMP Waiver Conditions, Note 2: This note is inconsistent with requirement to stabilize disturbed
areas by the end of each work day. Total land disturbance estimated at 2.02 Ac. Revise or delete note.
(Rev. 2) Addressed.
13. ESC General Note 4: "Alternative methods shall be discussed and determined to prevent downstream
sedimentation from active construction activities," is ambiguous, and appears to obligate contractor or
owner to ongoing ESC plan design. A/E must develop an ESC plan, including sequence of construction that
reasonably anticipates and prevents downstream sedimentation. Delete or revise statement. (Rev. 2)
Addressed.
14. There are 3 or more references to multiple and varying stabilization schedules for street cleaning, temporary
seeding, permanent seeding and general seeding. Multiple references to stabilization, inspection, ESC
measure monitoring and repair, street debris removal, etc., create confusion. Tie all references to
stabilization or inspection or ESC measure monitoring and repair to VESCH, Third Edition, 1992, and
VPDES CGP (2014). Delete, revise, or eliminate inaccurate or extraneous reference —for example, to
Stabilization Note 1, sheet 8; General Seeding (delete). (Rev. 2) Addressed.
15. ESC General Notes, 6, 7, 8: Define how quickly stabilization measures will occur; specify timeline. (Rev.
2) Addressed.
16. Plans lack clear layout for ESC Measure notes, narrative, conditions, sequence, and unnecessary,
duplicative, or inaccurate references, statements, commitments or requirements. Much of the text on sheet 6
is repeated on Sheet 8. Review text closely with goal to revise for clarity, and eliminate inaccurate or non-
essential text. Please make a determined focus in this regard with next submittal. (Rev. 2) Addressed.
17. Label contours. (Rev. 2) Not addressed. (Rev. 3) Addressed.
18. Show grading required for construction roads, if any. (Rev. 2) Partially addressed. As follow-up, confirm
no Access grading required. (Rev. 3) Addressed. Discussed 7/18/18 —No site access grading required for
site access.
19. Silt fence (SF) is inadequate; SF is required downslope of construction roads, at point roads turn at foot of
slope, as an example. (Rev. 2) Addressed.
20. Provide an array of ESC measures, including: tree protection, diversions, check dams, culverts, and traps at
lower limits of construction roads. (Rev. 2) Addressed.
21. Provide ESC measure legend using VESCH symbols. (soil stockpile, topsoil, permanent /temporary
seeding, straw mulch, items listed immediately above) (Rev. 2) Partially addressed. Revise legend to
include MU. (Rev. 3) Addressed.
22. Label construction roads. (Rev. 2) Addressed.
23. Show construction roads tying to existing paved surface. (Rev. 2) Not addressed. Show /label paved
street at street /CE tie-in. Revise contours to reflect paved street. (Rev. 3) Addressed.
24. Show project design /clearing limit impact on existing forest. Plans must show limits of forest clearing.
(Rev. 2) Partially addressed. Recommend discuss 7/18, if necessary. (Rev. 3) Addressed. Discussed
7/18/18; also, see 447, below. (eagle ms ,
25. Provide separate plan sheet at 1' =20' scale so plan view details readable. (Rev. 2) Addressed.
Sheet 8
26. Eliminate ESC Minimum Standards (column of text), entirely. (Rev. 2) Addressed.
27. Incorporate ESC Minimum Standard requirements in ESC Plan design. (Rev. 2) Addressed.
28. Review all text, this plan sheet, for internal consistency —see Sheet 6 comments, above. (Rev. 2)
Addressed.
29. ESC Narrative Site Description includes reference to Blacks Run -Lower North River Watershed and South
Fork Shenandoah River. Revise. (Rev. 2) Addressed.
30. ESC Note 5: Eliminate reference to Developer /Developer's Representative. Contractor responsible.
Revise. (Rev. 2) Addressed.
31. ESC Note 9: Ref. VESCH Std. and Spec. 3.31 for correct timing of stabilization. Revise. (Rev. 2)
Addressed.
32. (Rev. 2)
Withdrawn, review error.
33. Critical Erosion Areas: Expand, clarify, explain, and provide measures deemed adequate to protect critical
Engineering Review Comments
Page 4 of 4
erosion areas. If this statement is general reference to existing conditions, explain how or why this matters.
(Rev. 2) Addressed.
34. Revise Off -Site Areas ref. that reads: "...a proper disposal location with an approved SWPPP and ESC Plan
will be provided," to state Contractor is to provide SWPPP and ESC Plan for off-site areas. (Rev. 2)
Addressed.
35. Stormwater Runoff Considerations Note. Delete; see comments on SWM Plan requirements, above.
(Rev. 2) Addressed.
36. Revise roadway debris cleanup timeline from immediately to read, "immediately, but not later than the end
of each workday." (Rev. 2) Addressed.
37. Provide VAR10, VAC, or VESCH reference in support of statement: "Maintenance shall be performed
before the next anticipated storm event," else revise statement consistent with VAR10, VESCH, etc. (Rev.
2) Not addressed. (Rev. 3) Not addressed —not an impediment to approval, but renew request for
response to comment.
38. Acquire and provide copy of all required easements prior to plan approval. (Rev. 2) Addressed. As
follow-up, please see plan review email, SUB2018-00091, 7/16/2018 11:14 AM (`No objection')
Title Sheet —
39. General Note 16: revise to require approval of county ESC inspector. (Rev. 2) Addressed.
40. Provide Vicinity Map that shows county /city limits boundary. (Rev. 2) Addressed.
41. List TMP#s (City of Charlottesville; Albemarle County). (Rev. 2) Addressed.
42. Provide project location: List nearest physical address. (Rev. 2) Addressed.
43. Sheets 2/3: Label LOD Area (SF). Provide 1" =30' scale view or plan sheet that shows full extents of LOD.
(Rev. 2) Partially addressed. As follow-up, add Area Acreage label (Ac. /ft2). (Rev. 3) Addressed.
Discussed 7/18/18 —comment withdrawn.
Sheet 2:
44. Label existing BMP, include Facility ID (0091-02); identify type of BMP. (Rev. 2) Addressed.
45. Label stream, if perennial. (Rev. 2) Addressed.
46. Show /label steep slopes. (Rev. 2) Addressed. GTS (Steep S,
47. Show tree line. If entire site is forested, provide note that entire site is forested. (Rev. 2) Not addressed.
Recommend discuss 7/18/18. (Rev. 3) Addressed. Discussed 7/18/18. Trees to be removed identified via
(plan) table; no tree removal beyond LOD.
48. Sheet 3: Show and provide site access grading. (Rev. 2) Partially addressed. Please confirm no site
access grading is required. (Rev. 3) Addressed. Discussed 7/18/18 —No site access grading required.
49. Sheet 7: Provide temporary stream crossing detail, if needed. (Rev. 2) Partially addressed. Label
temporary stream (temporary bridge) crossing. A temporary bridge crossing detail is provided. (Rev. 3)
Addressed.
Please submit 2 print copies of the SWPPP to Engineering (ensure Section 9 is signed, a VSMP Permit Application
with Authorized signature, and four (4) copies of the plan with PE -seal original signature /date.
Once Engineering receives items listed above (plans /SWPPP for stamped approval), VSMP Application with
Authorized signature, and receipt of recordation of easements, we will upload project data to DEQ database. DEQ
will send email request for payment of state -portion of VPDES permit fee to Walter Harris, PMD.
Once DEQ fee is paid, FES /PMD may complete a preconstruction meeting request form, at time that suits you best.
Link to preconstruction meeting request form:
http://www.albemarle.orgLupload/images/forms_center/departments/CommunitaDevelopment/forms/applications/WPO_V irgini
a Erosion_ and Sediment_ Control_Program _Pre -Construction _ Meeting_ andPermitRequest.pdf
Thank you J. Anderson 434.296-5832 —x3069
VSMP_River_Run—Stream_Restoration_WP0201800019-rev3-072018ApprovaI pending