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December 22,2011 _VLInasse_IIa—gen RrustUn, T1w-
Mr.John Simons,Chairman
North Andover Planning Board
1600 Osgood St.
North Andover,MA 01845
Mr.Louis Napoli,Chairman
North Andover Conservation Commission
1600 Osgood Street,Suite 2-36
North Andover,MA 01845
Re: Response to Stormwater Peer Review Comments
DEP File#:242-1531
Volpe Athletic Center Expansion-Merrimack College
North Andover,Massachusetts
Dear Chairmen,Board Members and Commissioners,
On behalf of Merrimack College,VHB provides the following information in response to the peer
review comment letter prepared by Eggleston Environmental on October 26,2011.
The Eggleston Environmental comments are listed below,followed by the response in italics.
Comment:
1. Additional information regarding the scope of the 2005 modifications to the Stormwater
Master Plan,as well as copies of the Certificates of Compliance referenced in the response
letter should be provided to the Commission.
Response: Based on further conversations with the College,it is understood that Certificates of
Compliance have not been issued for the drainage improvements,as the Order remains open.
It is understood that a sitewalk was conducted on November 16"`to observe the constructed
stormwater master plan improvements.
Please refer to the attached plans of the 2005 stormwater modifications at the "Athletic Game Field".
101 Walnut Street
Post Office Box 9151
Watertown, Massachusetts 02471-9151
617.924.1770 ® FAX 617.924.2286
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www.vhb.com
Stormwater Response to Comments
Project No.: 11625.00
December 22,2011
Page 2
Comment:
2. In response to my comment#5,VHB has indicated that the plumber and architect will need
to incorporate the stormwater drainage areas used in the design into the design of the
building,and suggested that the submission of the plumbing plans be made a condition of
approval.Instead of asking the Town boards or their agents to verify the design,I suggest
that this be made a requirement of the as-built certification provided by a registered
Professional Engineer at the completion of construction.
Response: Agreed,this requirement can be added to the Order of Conditions.
Comment:
3. The proposed plan calls for two rain gardens to be located along the eastern edge of the
project site;rain garden#1 would receive runoff from a portion of the new roof area,and rain
garden#2 would receive runoff from a portion of the new parking area.The primary purpose
of the rain gardens is to provide some degree of recharge on the site,despite the relatively
low-permeability soils,and to retain the runoff within the drainage area to the onsite
wetlands.Rain garden#2 will also provide treatment of the pavement runoff.VHB has noted
that the 2 ft of separation called for in the DEP guidelines may not be attainable on the site,
and I concur that this may well be the case.The DEP guidelines also do not permit infiltration
structures within 50 ft of the wetlands,and both rain garden locations are located within the
50-ft wetland no-build zone.However,given that this is a redevelopment project and the
areas proposed for the rain gardens seem to be the only feasible locations for infiltration on
the site,I do not believe that strict compliance with the DEP guidelines is either necessary or
preferable.Unless they are totally below the normal groundwater level,the proposed rain
gardens will provide some degree of recharge during low groundwater periods, and will
help to attenuate runoff flows to the wetland.In addition,the vegetative uptake coupled with
infiltration and/or filtration in rain garden#2 will provide water quality enhancement for the
pavement runoff.If the groundwater is at or near the bottom of the basins they may need to
be constructed and planted as pocket wetlands;while the groundwater recharge would be
minimal they would still provide recharge to the onsite wetlands and water quality treatment
for the pavement runoff.
Response: Agreed,based on discussions with the peer reviewer,it was suggested that the application of
Rain gardens be explored,with the understanding that they would be located in areas where minimal
infiltration could be attained. Therefore, the Rain Gardens are proposed in order to provide recharge to
,
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Stormwater Response to Comments
Project No.: 11625.00
December 22,2011
Page 3
the maximum extent practicable. It is understood that due to soil conditions, the infiltration
systems will not meet the requirements set forth by DEP;however they will provide additional means
of water quality and infiltration.
Test pit data,performed by Soil Exploration Corp.,has been attached to this response letter in a report
from Kevin Martin,P.E.dated November 4,2011. Soil information at the proposed Rain Garden
locations indicate groundwater at 4-ft. below existing grade(Elev.239±). This groundwater elevation
would allow for the 2-ft.separation required,however the seasonal high groundwater elevation has not
been confirmed.
Comment:
4. It is not clear how the roof drainage from area 11.313 will drain to rain garden#1 as no roof
drain connection is shown.If gutters or roof drains are not proposed for that part of the
building addition I would suggest adding dripline trenches to further enhance infiltration.
Response: Runoff from the portion of the building included in area 11.313 shall be collected in a roof
drain and discharged via a downspout to Rain Garden 1. The proposed downspout location along with
associated stone protection has been added to the plans.
Comment:
5. Additional pretreatment,e.g. a filter strip,stone diaphragm,sediment forebay,or some
combination thereof,is needed prior to the pavement runoff entering rain garden#2.
Response: The plans have been updated to include a grass and gravel combination filter strip per the
Massachusetts Stormwater Handbook,which requires a minimum 8 inches of gravel followed by 3 to 5
feet of sod. Adjacent to the proposed edge of pavement,the design plans shall include a 12-inch gravel
strip followed by 20 ft. of sod prior to sheet flowing into Rain Garden 1.
Comment:
6. The rain garden detail shown on Sheet C-6 is not consistent with the proposed design,which
calls for an overflow Swale and no landscape drain.The detail should also specify the
bioretention soil mix.Additional detail on the proposed plantings for the rain gardens will
need to be provided;I do not believe they were included on the landscape plan submitted to
the Planning Board.Final determination of the plantings should be based on the groundwater
hydrology when the basins are excavated.
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Stormwater Response to Comments
Project No.: 11625.00
December 22,2011
Page 4
Response: The Rain Garden detail on Sheet C-6 has been revised to reflect the design shown
on the plans by removing the landscape drain. Sheet L-1—Planting Plan has been updated and
provided,detailing proposed plantings at the Rain Gardens. Refer to Attachment A: Section 329500—
Bioretention Areas for clarification on the bioretention soil mixture. This specification section shall be
included in the project documents.
Comment:
7. Per the attached 8/31/11 NJCAT certification letter,the proposed STC-900 units have an
approved TSS removal rate of 50%for field(vs.laboratory)installations,not 75%as is used in
the TSS calculations.Hence,the treatment train for the lower portion of the new parking lot,
comprised of deep sump catch basins and the Stormceptor units,does not meet the 80%TSS
removal called for in the DEP regulations.I believe this is offset at least to some extent by the
net improvements in water quality provided by the proposed upgrades to the existing
drainage system in Cullen Ave.The college does also sweep the streets and parking areas
several times per year,which will help with TSS removal.
Response: According to the manufacturer's sizing criteria,both STC-900 Units have been sized via
the PCSWMM Stormceptor Sizing program which documents TSS Removal Efficiencies for WQU-A1
and WQU-A2of 91%and 80%,respectively. Sizing was based off of providing a minimum TSS
Removal Efficiency of 80%for the required water quality volume(0.5"runoff depth)relative to each
unit's tributary impervious area,per Standard 4 of the Massachusetts Stormwater Handbook.
However,based on the NJCAT certification letter dated August 31,2011,the Stormceptor STC
proprietary separators have been certified by NJDEP with a 50% TSS removal rate based on the
criteria provided therein,therefore, the assumed TSS Removal efficiency rates have been adjusted.
As shown on the attached, Weighted Average TSS Removal Calculations,a majority of the proposed
parking lot(±6,745 s.f.of impervious area) is diverted via sheet flow runoff to Rain Garden 2,which,
with the use of the gravel/sod filter strip shall achieve treatment train of 90%TSS Removal per
MassDEP. The remaining portion of new impervious area associated with the new parking lot and
additional parking along Cullen Avenue(±4,535 s.f.of impervious area) is collected in the closed
drainage system and diverted to the STC-900 unit(WQU-A1)which shall achieve a treatment train of
64% TSS Removal per the updated NJCAT certification and consequently,MassDEP. By performing
a weighted average of these treatment trains based on the impervious areas,a removal efficiency of 80%
can be attained for the new impervious area proposed as part of the project.
As noted in the comment above,the project treats existing parking/road areas as well as the proposed
new lot. Overall,the Stormceptor STC-900(WQU-B1)treats approximately 1.5-acres of impervious
AIRL
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Stormwater Response to Comments
Project No.: 11625.00
December 22,2011
Page 5
area(±1.7-acres of total area), roughly 1-acre of which is the existing parking lot and roughly
0.33-acres of which is part of the proposed building expansion.
Considering that the project treats a significant portion of existing impervious areas,a majority of the
proposed impervious area is comprised of roof runoff,and as a weighted TSS removal efficiency of 80%
can be attained for the additional impervious area requiring treatment, VHB believes that sufficient
measures are proposed in order to meet the MassDEP requirements to the maximum extent
practicable.
In addition to the Eggleston Environmental review, the proponent has also received
comments from the Town of Andover Conservation Commission's peer reviewer (ESS).
The Andover correspondence and related plan updates are appended to this letter.
Merrimack College is appreciative of the additional input provided on the project and we
look forward to the opportunity to present these updates at the January 17th Planning
Board meeting Conservation Commission meeting and the January 25th Conservation
Commission meeting.
Very truly yours,
VANNASE HANGEN BRUSTLIN,Inc
ristopher M.Lovett,�I�E,LEE AP
Senior Project Mana �r
Cc: Lisa Eggleston—Eggleston Environmental
Jeff Doggett—Merrimack College—Chief of Staff
Robert Coppola—Merrimack College—Director of Facilities
Attachments:
• Stormwater Improvements—Football Basin-Construction Drawings
• Geotechnical Memorandum
• Updated Site Plans
• Andover Peer Review Correspondence
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