HomeMy WebLinkAboutWPO201800047 Review Comments WPO VSMP 2018-07-12COUNTY 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: NIFI —Rivanna Greenway Stabilization
Project file number: WP0201800047
Plan preparer: Kip Mumaw, Ecosystems Services [Kip@ecosystemservices.us]
Owner or rep.: Albemarle County / FES-Environmental Services Division
[scalos(a)albemarle.org; wharris(a)albemarle.org]
Plan received date: 7 Jun 2018
Date of comments: 12 Jul 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. 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 is required due
to activity within mapped FEMA floodplain Zone AE floodway fringe. Project is exempt from the VSMP
(Project Maintenance); see below. A SWPPP must contain (1) a PPP, (2) an ESCP, (2) a SAIMP, and (4)
any TMDL measures necessary.
1. Provide Project number [WP0201800047] on the SWPP document cover, and Title sheet of plans.
2. Use Albemarle County SWPPP template (see email sent July 11, 2018 2:40 PM; EcoSystem response:
7/12/2018 8:07 AM).
Link, county template:
http://www.albemarle.ore/ul)load/imaees/forms center/departments/Community Development/forms/Enein
eerina and WPO Forms/Stormwater Pollution Prevention Plan SWPPP template.pdf
3. Provide Sec. 6 SWPPP exhibit.
4. Include Ecosystem Name, Address, Telephone, principal contact on SWPPP cover. (Authorship)
SWM Plan
The Stormwater Management Plan requirements can be found in County Code section 17-403. Proposed
activities are reviewed as Project Maintenance. Project Location A and B activities are designed to restore
original construction of the project by placing fill to stabilize against further down -cutting erosion along fringe
of golf course fairway, and Rivanna Greenway (17-303.G.). Project is exempt from requirements of the VSMP.
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.
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, for reasons provided in comments below. The erosion control plan content requirements can
be found in County Code section 17-402.
Engineering Review Comments
Page 2 of 6
1. Revise Sheet List Table sheet number and title to match plan set.
2. Revise plan title to: NIFI Rivanna Greenway Stabilization WPO201800047 /VESCP Plan.
3. Title sheet Project Narrative description of 24" HDPE pipe is inconsistent with sheet 6, 18" RCP. Revise.
Sheet 2
4. Label Sandown Lane.
5. Provide PE -seal (sign /date) All sheets.
6. Show stockpile location; revise LOD.
7. Label LOD Area (ft2).
Sheets 3, 4
8.
9.
10
11
Label trail or cart path.
Show and label 100-yr floodplain.
Provide TMP data for all parcels shown, or affected.
Depict existing trees. Label tree line relative to clearing limits (LOD).
12. Location B is difficult to locate relative to property /golf course features with information provided:
a. On sheet 4, show and label any streets, tee -boxes, etc.
b. Check Fairway label; ensure location B is on a fairway /see Location B image, below.
Sheets 5, 6
13. Estimate base flood elevation (BFE) at Location A and Location B.
14. Estimate quantity fill (cy) to be placed below BFE. Provide Note to list Qty.: Location A, Location B.
15. Provide additional contour labels.
16. Show proposed stone in profile view.
17. Label class of stone stabilization (A) and sill stone (B).
Engineering Review Comments
Page 3 of 6
18. Estimate qty. stabilization stone, Location A.
19. Indicate and label areas to receive topsoil (TO).
20. Show TP, sheets 5 and 8.
21. Show Outfall Protection, sheets 5, 6, 8. Dimension and label OP (L X W X D).
22. Provide reference/s to sheet 11 details.
23. Indicate and provide narrative for trees to be removed, Location A.
24. Provide hydraulic calculations for proposed 24" HDPE pipe.
25. Revise pipe label consistent with title sheet Project Narrative (24" HDPE).
26. Provide detailed profile of stabilization, consistent with plan view, to guide construction and inspection.
Location B imaee:
27. Sheets 5, 6, 7, 8: Show /label steep slopes.
Engineering Review Comments
Page 4 of 6
Sheet 7 (ESC)
28. Provide ESC measures, if required, along proposed access route.
29. Show construction entrance at Sandown Lane, graphically, as well as with symbol.
30. Revise ESC Legend to include:
a. TS (3.31) — Temporary Seeding
b. PS (3.32) — Permanent Seeding
c. MU (3.35) — Mulch
d. B/M (3.36) — Blankets and Matting
e. TP (3.38) — Tree Protection
f. OP (3.18) — Outlet Protection
g. RR (3.19) — Riprap
h. SSS (3.23) — Structural Streambank Stabilization
i. TO (3.30) — Topsoiling
j. DS (3.26) — Dewatering Structure
31. Provide /label topographic contours.
32. Label dark gray shaded areas.
33. Show Areas to receive mulch (MU) on plans.
34. Provide 1' =50' scale of Area of Disturbance between end of Sandown Lane and Location A.
35. Provide 1' =50' scale of LOD between Location A and B. Provide ESC measures, as needed
Sheet 7 (and /or 9)
36. Revise to require 5-day inspection frequency, wherever text indicates 7- or 10-day inspection frequency.
Ref. VAR10, Part II, F.2.A.G.).
37. ESC VSMP Waiver Conditions, Note 1: Revise per SWM Plan comment section, above.
38. ESC VSMP Waiver Conditions, Note 2: Note is inconsistent with total disturbance estimated at 0.77 Ac.
Revise or delete note.
39. ESC VSMP Waiver Conditions, Note 5/a.: Show PPP measures on SWPPP Exhibit.
40. ESC VSMP Waiver Conditions, Note 5/d.: If concrete proposed, show concrete washout on SWPPP
Exhibit. If no concrete is required, delete 5.d.
41. ESC General Notes
a. Note 4: Revise consistent with requirement at ESC Note 9, Sheet 9, which is accurate.
b. Note 7: Project is within 100-yr floodplain. Revise to read: ESC matting (EC-2) shall be applied to
all disturbed areas at pipe outfalls at Location A and B, and to any disturbed slope > 3:1.
42. ESC Notes 5, 8 (sheet 9): Delete ref. to Developer /Developer's Representative. SWPPP identifies
qualified and responsible personnel responsible for environmental compliance. Ref SWPPP.
43. Sequence of Construction
a. Note 3: Identify and show sensitive site features on plan. Design and provide protective measures
for sensitive site features.
b. Note 4: Show stockpile area/s on plans. Revise LOD; recalculate Area of LOD (0.77 AC.).
c. Note 6: Confirm Albemarle intends for GC to install SAF on Glenmore Country Club golf course
fairways. If so, show safety fence on plans. Show stockpile/staging area on plans.
d. Note 6: Clarify reference to permanent stockpile: No permanent fill, excess material, or stockpile
not otherwise required to stabilize eroded areas at Location A or B (within FEMA mapped 100-
year floodplain) are permissible, or allowed.
e. 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").
f. Note 7: SWPPP and Sequence of Construction Notes must include limits that restrict material or
equipment within FEMA mapped floodplain. No equipment may be stored in the floodplain.
g. Note 8: Revise note to require approval of county ESC inspector.
h. Note 9: Provide Planting Plan. Note requirements at 18-30.3.14.B.
Sheet 8 (Location A, B)
Engineering Review Comments
Page 5 of 6
44. Wrap outlets of each pipe with `horseshoe' SF. Install SF at toe of stabilized slopes at each outfall.
45. Provide /show /label TP, TO, B/M, SSS, RR, OP, SF, SAF, DS (if needed) and MU.
Sheet 9
46. ESC Narrative: Revise Albemarle River Watershed to read Rivanna River Watershed.
47. Provide detail to supplement Note that reads: The site is a critical area. Specify critical area protective
measures. Also, comment #57, below.
48. Maintenance Schedule /Note 1: Revise to include /make reference to public right-of-ways or private streets.
49. Maintenance Schedule /Note 1: Revise to require street cleanup of tracked material from immediately to as
soon as practicable but no later than the end of the work day.
50. Consolidate Stabilization Notes, ESC Notes, and Sheet 7 ESC General Notes. There is duplication,
inconsistency, and slight prioritization /ranking. It appears limited QC checks were performed.
51. Maintenance Schedule /First paragraph: Revise inspection frequency fr-e . every to day to at least once
every five business days and within 48-hours of...
52. (Please reference River Run Stream Restoration project 5/14/18 ESC Plan review comments.)
53. 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 9; General Seeding (delete).
54. Plans lack clear layout for ESC Measure notes, narrative, conditions, sequence, and unnecessary,
duplicative, or inaccurate references, statements, commitments or requirements. Text on sheet 7 is repeated
on Sheet 9. 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.
55. Eliminate ESC Minimum Standards (column of text), entirely.
56. Incorporate ESC Minimum Standard requirements in ESC Plan design.
57. 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.
58. 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.
59. 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.
D. Floodplain Development Permit Application (FDP Application; 18-30.3.12)
Floodplain development requirements can be found in County Code section 18-30.3, Flood Hazard Overlay
District
1. Note: Project is authorized by -right under 18-30.3.11 (Table /Environmental Restoration), which does not
relieve applicant of procedural requirements. Albemarle requests supportive statements relative to fill
quantities, BFE, No -rise, and design elements to be reviewed per 18-30.3.14. Project is located within
mapped FEMA Zone AE. Ensure environmental restoration measures (Location A and B) are resistant and
resilient to occasional flooding. Submit statements and analysis with an FDP Application. Reference
WP0201800047. Include cover letter with Application with narrative and supportive reference to Flood
Insurance Study (FIS) /Albemarle County, and on-line FEMA resources /LOR data.
Link to FDP Application:
hqp://www.albemarle.oriz/upload/imaizes/forms center/departments/Communiiy Development/forms/Engineering and
_WPO_Forms/Floodplain_ Development_Permit.pdf
2. Provide PE -seal `No Rise' Certification for WP0201800047 (see 18-30.3.12.A.5) affirmatively stating
there is no increase in the base flood elevation for Locations A and B, under proposed stabilization /fill
activities. Include reference to LOR data available via FEMA website (image below). Albemarle County
relies on Project Engineer to provide `No Rise' certificate (example Attached to this comment Memo).
3. Estimate /calculate total fill below BFE with this project (0; total of Location A + Location B). Report
Engineering Review Comments
Page 6 of 6
value on pg. 2 at item 4. of the FDP Application.
4. Compare and report proposed cross -sectional fill areas below BFE (sheets 5, 6) with approximate cross -
sectional Area for Rivanna River at a point midway between Location A and B; that is, Area between BFE
elevation, floodplain limits, and streambed for Rivanna River, at that point. Report proposed stabilization
fill cross -sectional area as a percentage of cross -sectional area of Rivanna River.
5. Modeling is not requested, or required. If `No Rise' Certificate is not possible without modeling, evaluate
options. A `No Rise' Certificate is required. `No Rise' Certificate may make reference to replacement of
lost material at project locations that is historically included in mapped floodplain limits, etc.
6. Note: Design of plantings, riprap, slope stabilization, tree -cutting, etc. will be evaluated against
encroachment standards at 18-30.3.14, A.-D. Please design accordingly.
7. This VESCP-FDP project cannot be approved until FDP Application is received, reviewed, and approved.
`No Rise' Certification is pre -requisite to VSMP (VESCP) Plan approval.
Image /VFRIS (Note: LOR References): b—q://cmap2.vims.edu/VaFloodRisk/vfris2.htm1
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?departinent--cdengmTo
Thank you.
J. Anderson — 434.296-5832 —0069
NIFI-Rivanna Greenway Stabilization—WP0201800047-071218.doc