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HomeMy WebLinkAboutWPO201800045 Review Comments WPO VSMP 2018-08-02COUNTY 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: Minor Hill Biretention Retrofit Project file number: WP0201800045 Plan preparer: Kip Mumaw, Ecosystems Services [Kip@ecosystemservices.us] Owner or rep.: Albemarle County / FES-Environmental Services Division [scalos(&albemarle.org; wharris(a)albemarle.org] Plan received date: 14 June 2018 (Rev. 1) 26 Jul 2018 Date of comments: 13 July 2018 (Rev. 1) 2 Aug 2018 Reviewers: 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 in 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 [WP0201800045] on the SWPP document cover, and Title sheet of plans. (Rev. 1) Addressed. 2. Use Albemarle County SWPPP template (see email sent July 11, 2018 2:40 PM; EcoSystem response: 7/12/2018 8:07 AM). (Rev. 1) Addressed. Link, county template: http://www.albemarle.orL,/unload/imaaes/forms center/denartments/Community Development/forms/Enein eerine and WPO Forms/Stormwater Pollution Prevention Plan SWPPP template.pdf 3. Provide Sec. 6 SWPPP Exhibit. (Rev. 1) Addressed. 4. Include Ecosystem Name, Address, Telephone, principal contact on SWPPP cover. (Authorship) (Rev. 1) Addressed. New As follow-up (first review of County template SWPPP), please see email to Ecosystem, 8/2/2018 1:07 PM 5. Sec. 1, Registration Statement /item 1.: check `}_es' -DEQ may transmit correspondence, electronically. 6. Sec. 1, Registration Statement /item 6.: please list 12-digit HUC, for Registration (020802040401 ) 7. Sec. 3, Item #5 —ref. filter logs. Will filter logs be used on this project? 8. Sec. 3, Item #5 —The statement: "All Virginia state and Albemarle County regulations will be followed, unless otherwise specified," is ambiguous, and may be misconstrued. Why would regulations not be followed? Delete "unless otherwise specified." 9. Sec. 3, Item #22 —Please underline or bold 51h sentence. 10. Sec. 3, Item #26 /28 —Please reference application of lime /fertilizer, per VESCH, Third Edit. 1992. SWM Plan The Stormwater Management Plan requirements can be found in County Code section 17-403. 1. Water quality: This project proposes replacement of a nearly 40 year -old poor -performing SWM facility Engineering Review Comments Page 2 of 4 (detention pond designed for detention, only) with clogged and broken outlet structure and pipe with a Level 1 bioretention filter (VA DEQ Stormwater Design Specification No. 9) that provides 25% phosphorus removal. By contrast, an extended detention pond (nearest VRRM.xls equivalent to 40 year -old facility) provides 15% phosphorus removal. Once design comments are addressed, the SWM Plan can be approved. (Rev. 1) Addressed. See Ecosystem Minor Hill Hydrologic Analysis Memorandum, d. 7/24/18. 2. Water quantity: Ref. B. Aubrey Huffman & Associates, Ltd., letter dated 10/2/79 that references initial (pond) design maximum theoretical discharge of 11.3 cfs. EcoSystem Service in cover letter dated 6/11/18 presents (table value) proposed peak QI0-year outflow of 11.03cfs, which is slightly less than initial design. No impervious area is added. No ground cover is converted. Runoff characteristics of upslope watersheds are not altered. Energy balance calculation is waived by reviewer as this project provides channel and flood protection benefits by retrofitting a decades -old facility with a newly constructed properly designed stormwater management facility, and the Energy Balance equation is an inappropriate analytic measure for evaluating the proposed bioretention filter. Once design comments are addressed, the SWM Plan can be approved. (Rev. 1) Addressed. Applicant response: Noted. 3. General Note 13, plan sheet 9, states: "The construction of this project will not result in the development of any new impervious surfaces. This project is a stormwater retrofit that treats a previously developed area, and improves the water quality through construction of a bioretention area." This project would be exempt from the VSMP if its only purpose were routine project maintenance (17-303.G). As it is, the project delivers quality benefits that exceed original design. (Rev. 1) Addressed. Applicant response: Noted. 4. Water Quantity: a. Provide routings that support 6/11/18 letter proposed post -development peak outflow (Q2, Qio). (Rev. 1) Addressed. Ref. Hydro Memo (item #1 above). b. Ensure Q2 outlet velocity at Ex. 15" CPP outfall is <15fps. Calculate and report outfall velocity. (Rev. 1) Addressed. c. Provide B/M channel protection at Ex. 15" CPP, as needed, once Velz_n calculated. (Rev. 1) Not Addressed. Applicant response: Outlet pipe velocity is 14.28 fps. Engineering: Ref, VESCH Std. & Spec. 3.36; 14.28 fps exceeds design range even for soil stabilization blanket and matting Treatment 2. Provide design with dimensions for EC-1 (riprap) outfall protection for Ex. 15" CPP. d. Provide riprap outfall protection at Ex. 15" CPP outfall. Dimension riprap (L x W x D). (Rev. 1) Not Addressed. 5. Water quality: Explain and report methodology used to prepare the phosphorus reduction comparison table included with 6/11/18 EcoSystem Services cover letter. Provide supporting calculations. Remove reference to stream restoration; this does not appear to be a stream restoration project. (Rev. 1) Addressed. 6. Sheet 2: Label all tax map parcels affected by project activity. (Rev. 1) Addressed. 7. Sheet 3: Provide emergency spillway unless bioretention filter contains the 100-year event. (Rev. 1) Addressed. The 100-yr event is contained. 8. Sheet 3, 5: a. Show /provide Access easement from Westfield Road to SWM Facility. Record with Deed of Dedication prior to VSMP Approval. (Rev. 1) Addressed. Temporary Construction Easement plats are under review, SUB201800126. b. Show /provide SWM /drainage easement that includes bioretention filter and that extends from biofilter through outfall to natural channel. Record with Deed prior to VSMP Approval. (Rev. 1) Not addressed. Ref. email to W. Harris, 8/2/2018 2:36 PM. PMD meeting with CAO to discuss. 9. Sheet 4: a. Sec. B-B proposed bioretention 10-year WSE (468') will cause slight backwater condition at Sec. D-D inlet channel, and more pronounced backwater condition at Sec. E-E forebay weir. Revise such that 10-year storm event is contained within features shown in profile Sec. A -A, and plan view. b. Sec. B-B: i. Label riser bottom of base elev. (Rev. 1) Addressed. ii. Label riser base depth /thickness. (Rev. 1) Addressed. iii. Provide base bedding detail. (Rev. 1) Not Addressed. Show and label bedding material and depth beneath riser base. iv. Provide pipe (6" Sch 40; 12" HDPE) INV elev. in riser. (Rev. 1) Addressed. v. Provide floor of riser (MH) elevation (< INV/out, 12" HDPE elev.). (Rev. 1) Addressed. Engineering Review Comments Page 3 of 4 c. Label Sec. C-C 6" ponding elevation=465.1'. (Rev. 1) Addressed. d. Label stone surface elevation at bottom of channel, and top of sideslope, similar to labels provided with Sec. E-E. Label sideslope slope; 1:1 for example. (Rev. 1) Addressed. Applicant response: This section is to be used by the contractor as a typical section. Labeling elevations and sideslopes would detract from the intended communication. Stakeout will provide elevations throughout channel. e. Recommend Sec. E-E provide > 1" proposed freeboard between top of weir and 10-yr WSE. (Rev. 1) Addressed. Applicant response: Taken into consideration; however, evaluated as sufficient [given] likelihood of failure and costs. 10. New: Asfollow-up: provide manway in riser cap for periodic maintenance inspection; see detail, sheet 11. B. Pollution Prevention Plan (PPP) The PPP content requirements can be found in County Code section 17-404. 1. Provide with Sec. 6 of Albemarle County SWPPP template. (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 reasons provided in comments below. The erosion control plan content requirements can be found in County Code section 17-402. 1. Sheets 5, 6, 7: Provide reference to sheet 10 details, as required. 2. Sheet 5 a. Revise sheet title to match index. (Rev. 1) Addressed. b. Label residential buildings. (Rev. 1) Addressed. c. Provide contour labels (Rev. 1) Addressed. d. Label street at PCE. (Rev. 1) Addressed. e. Show Ex. trees. (r,.ogle image, b) (Rev. 1) Addressed. f. Note trees TBR. (Rev. 1) Addressed. g. Provide TP, especially since working within stream buffer* (Rev. 1) Addressed. * Mitigation offset plantings not required; this is not a stream crossing. 3. Sheet 6: a. Show existing trees. b. Provide SF and berm containment downslope of SWPPP elements /staging area. (Rev. 1) Partially addressed. Revise berm design to provide containment and prevent release around lower end of berm. c. Provide grading for containment (recommend depression). (Rev. 1) Not Addressed, but provided 3.b., above, is addressed (containment provided), comment will be withdrawn. 4. Sheet 7: Provide terrain contour labels. (Rev. 1) Addressed. 5. Sheet 9: a. Construction Sequence (Note 2): Revise to read, "Install paved construction entrance and mulch access road where indicated on plans." (Rev. 1) Addressed. b. Include VA DEQ Design Specification No. 9, Sec. 8.2, Bioretention Installation, p. 34 and 35. Include these two pages (Narrative Steps) of the DEQ specification in their entirety. Link: https://www.vwrrc.vt.edu/swc/documents/2013/DEQ%20BMP%20Spec%20No%209 BIORETENTION Fi nalDraft_vl-9_03012011.pdf (Rev. 1) Addressed. c. Install Periodic Inspection checklist attached to these comments, in its entirety. (Rev. 1) Addressed. 6. Sheet 10: a. Provide paved construction entrance with wash rack detail located at pg. 8 /Albemarle County Design Standards Manual (ACDSM) —Link: http://www.albemarle.org/upload/images/forms_center/departments/community development/forms/design s tandards manual/Albemarle County Design Standards Manual 2015-04-25 draft.pdf (Rev. 1) Addressed. Engineering Review Comments Page 4 of 4 b. Provide drainage pipe bedding detail. (Rev. 1) Addressed. c. Provide Filter Log Detail. (Rev. 1) Addressed. 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, it is my understanding a SWM Facilities Maintenance Agreement will need to be completed and recorded, but Engineering will confirm. It likely depends on whether Minor Hill Townhouses HOA is relieved of future Maintenance responsibility with this retrofit project, or not. If an Agreement is required, 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. A Deed of Dedication is required whether Albemarle County assumes maintenance responsibility for bioretention filter and outfall pipe, or whether future SWM facility maintenance is an HOA responsibility. The deed will dedicate easement/s to the county across HOA and individual private parcels. Eagineer-ing will lee ii4e this fiH4 .o.. PMD and CAO are considering this. Easement plats are (may be) required. Deed of Dedication of Easement must be recorded prior to VSMP plan approval. After agreement is complete and deed recorded, Applicant (Albemarle County /FES) will need to complete request for a pre -construction conference form. The form identifies the contractor and responsible land disturber. Since this is a county project with less than 1.0 Ac. land disturbance, no state -portion of a VPDES permit fee is required. The form 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 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; htt-D://www.albemarle.orp-/deDtforms.asi)?deDartrnent--cdena"o Thank you. J. Anderson — 434.296-5832 —0069 Minor Hill BMP Retrofit WP0201800045 080218revl.doc