HomeMy WebLinkAboutWPO201800047 Review Comments WPO VSMP 2018-08-31COUNTY 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
(Rev. 1)
31 Aug 2018 (.PDF)
Date of comments:
12 Jul 2018
(Rev. 1)
31 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. 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 ESOP, (3) a SWN4P, and (4)
any TMDL measures necessary.
1. Provide Project number [WP0201800047] 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:
httn://www.albemarle.orQ/unload/ima2es/forms center/deuartments/Community Develonment/forms/Engineering and
_WPO Forms/Stormwater _Pollution _Prevention _ Plan_ SWPPP_template.pdf
3. Provide Sec. 6 SWPPP exhibit. (Rev. 1) Partially addressed. As follow-up: Please provide downslope SF
or berm containment, as with Minor Hill. Also, applicant response to ESC Plan review comment 30.h.
indicates concrete may be used. Provide /show concrete clean -out on Sec. 6 SWPPP Exhibit.
4. Include Ecosystem Name, Address, Telephone, principal contact on SWPPP cover. (Author... _ . (Rev. 1)
Addressed.
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.
Engineering Review Comments
Page 2 of 6
1. Provide with Sec. 6 of Albemarle County SWPPP template. (Rev. 1) Addressed.
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 listed, below. The erosion control plan content requirements can be found in
County Code section 17-402.
1. Revise Sheet List Table sheet number and title to match plan set. (Rev. 1) Addressed.
2. Revise plan title to: NIFI Rivanna Greenway Stabilization WPO201800047 NESCP Plan. (Rev. 1)
Addressed.
3. Title sheet Project Narrative description of 24" HDPE pipe is inconsistent with sheet 6, 18" RCP. Revise.
(Rev. 1) Addressed.
Sheet 2
4. Label Sandown Lane. (Rev. 1) Addressed.
5. Provide PE -seal (sign /date) All sheets. (Rev. 1) Addressed. Applicant response: Final approved plans
will be signed.
6. Show stockpile location; revise LOD. (Rev. 1) Addressed.
7. Label LOD Area (ft2). (Rev. 1) Addressed. Title sheet /Project information Note 4.
Sheets 3, 4
8. Label trail or cart path. (Rev. 1) Addressed.
9. Show and label 100-yr floodplain. (Rev. 1) Addressed.
10. Provide TMP data for all parcels shown, or affected. (Rev. 1) Addressed.
11. Depict existing trees. Label tree line relative to clearing limits (LOD). (Rev. 1) Addressed. Applicant
response: No trees are present in the LOD
.. le T.T..ps image
12. Location B is difficult to locate relative to property /golf course features with information provided: (Rev.
1) Addressed.
a. On sheet 4, show and label any streets, tee -boxes, etc.
b. Check Fairway label; ensure location B is on a fairway /see Legation n B image, bolwv.
Sheets 5, 6
13. Estimate base flood elevation (BFE) at Location A and Location B. (Rev. 1) Addressed. Location A:
297.5'; Location B: 296.8'.
14. Estimate quantity fill (cy) to be placed below BFE. Provide Note to list Qty.: Location A, Location B.
(Rev. 1) Addressed. [Location A: 16 cy; Location B: 6.5 cy]
15. Provide additional contour labels. (Rev. 1) Addressed.
16. Show proposed stone in profile view. (Rev. 1) Not addressed. Recommend hatching to clearly delineate
proposed stone (sheet 5 [riprap], 6 [stone sill]). Also, please revise plan date on sheets 5, 6.
17. Label class of stone stabilization (A) and sill stone (B). (Rev. 1) Addressed.
18. Estimate qty. stabilization stone, Location A. (Rev. 1) Addressed.
19. Indicate and label areas to receive topsoil (TO). (Rev. 1) Not Addressed. TO area around Location A not
visible on sheet 5 or 8.
20. Show TP, sheets 5 and 8. (Rev. 1) Addressed. Applicant response: No TP proposed. No trees within LOD.
21. Show Outfall Protection, sheets 5, 6, 8. Dimension and label OP (L X W X D). (Rev. 1) Addressed.
Applicant response: No outfall protection.
22. Provide reference/s to sheet 11 details. (Rev. 1) Not addressed. Applicant response: Erosion and
Sediment control note added. Reviewer cannot locate ESC note on sheet 5 or 6.
23. Indicate and provide narrative for trees to be removed, Location A. (Rev. 1) Addressed. Applicant
response: No trees are present in the LOD.
24. Provide hydraulic calculations for proposed 2-42 12" HDPE pipe. (Rev. 1) Addressed.
Engineering Review Comments
Page 3 of 6
25. Revise pipe label consistent with title sheet Project Narrative (24" HDPE). (Rev. 1) Addressed.
26. Provide detailed profile of stabilization, consistent with plan view, to guide construction and inspection.
(Rev. 1) Partially addressed. See comment 16, above.
27. Sheets 5, 6, 7, 8: Show /label steep slopes. (Rev. 1) Addressed.
Sheet 7 (ESC)
28. Provide ESC measures, if required, along proposed access route. (Rev. 1) Partially addressed. Please add
MU (straw mulch) symbol along proposed access route. MU hatch symbol shown for small area near
Location A. Use leader lines to clarify areas to receive MU (coincident with areas to receive TS /PS).
29. Show construction entrance at Sandown Lane, graphically, as well as with symbol. (Rev. 1) Addressed.
30. Revise ESC Legend to include: (Rev. 1) Addressed. As follow-up, include SAF in Legend
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) T-r€eProtestion
£ 011(3.19) 011tlet pr-Atestier}
g. RR (3.19) — Riprap
h. SSS (33..23) Staquetur-ad She; ank Stabilization (Rev. 1) Applicant response: `Not applicable: will not be
using gabion baskets, log cribbing, concrete, or grid pavers.' —Ref. comment 40, below.
i. TO (3.30) — Topsoiling
j. DS (3.26) — Dewatering Structure
31. Provide /label topographic contours. (Rev. 1) Not addressed. (Applicant response: Added.)
32. Label dark gray shaded areas. (Rev. 1) Addressed. (Removed dark gray hatch.)
33. Show Areas to receive mulch (MU) on plans. (Rev. 1) Partially addressed. See comment 428, above.
34. Provide 1' =50' scale of Area of Disturbance between end of Sandown Lane and Location A. (Rev. 1)
Partially addressed. As follow-up: provide contour elev. labels, sheet 8.
35. Provide 1' =50' scale of LOD between Location A and B. Provide ESC measures, as needed. (Rev. 1)
Partially addressed. As follow-up: provide contour elev. labels, sheet 9.
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.(L). (Rev. 1) Addressed.
37. ESC VSMP Waiver Conditions, Note 1: Revise per SWM Plan comment section, above. (Rev. 1)
Addressed.
38. ESC VSMP Waiver Conditions, Note 2: Note is inconsistent with total disturbance estimated at 0.77 Ac.
Revise or delete note. (Rev. 1) Addressed.
39. ESC VSMP Waiver Conditions, Note 5/a.: Show PPP measures on SWPPP Exhibit. (Rev. 1) Addressed.
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. (Rev. 1) Partially addressed. Asfollow-up: Applicant
response to 40 (No concrete proposed) conflicts with Applicant response to 30.h (`will be using gabion
baskets, log cribbing, concrete, or grid pavers.'). Please reconcile, and show concrete washout on Exhibit,
if concrete is proposed (See. A, comment 3).
41. ESC General Notes
a. Note 4: Revise consistent with requirement at ESC Note 9, Sheet 9, which is accurate. (Rev. 1)
Addressed.
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. (Rev. 1)
Not addressed. Since notes consolidated, possibly overlooked. Please direct reviewer to location
of this note. (Applicant response: Addressed. Revised note.)
42. ESC Notes 5, 8 (sheet 9): Delete ref. to Developer /Developer's Representative. SWPPP identifies
Engineering Review Comments
Page 4 of 6
qualified and responsible personnel responsible for environmental compliance. Ref. SWPPP. (Rev. 1)
Addressed.
43. Sequence of Construction (Rev. 1) All comment #43 items addressed.
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) (Rev. 1) Sheet 8 comments addressed.
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 (Rev. 1) All Sheet 9 comments addressed.
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 f+em eveF ° ter d*y 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.
Engineering Review Comments
Page 5 of 6
D. Floodplain Development Permit Application (FDP Application; 18-30.3.12) — Ref. Ecosystem email,
8/31/2018 2:01 PM — FDP Application submitted, today. Engineering will review /comment as soon as possible.
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:
http://www.albemarle.orgu2load/images/forms center/departments/Communily Development/forms/En ing eeriniand
_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 (gy; total of Location A + Location B). Report
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): bq://cmap2.vims.edu/VaFloodRisk/vfris2.html
Engineering Review Comments
Page 6 of 6
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;
htt2://www.albemarle.org/deptforms.asp?departrnent--cdengMo
Thank you.
J. Anderson — 434.296-5832 —0069
N1F1-Rivanna Greenway Stabilization WPO201800047-083118revl.doc