HomeMy WebLinkAbout2013-07-16 Planning Board Supplemental Materials (42) Eggleston Environmental
32 Old Framingham Rd Unit 29 Sudbury MA 01776 tel 508.259.1137 fax 866.820.7840
July 15, 2013
North Andover Planning Board
1600 Osgood Street
North Andover, MA 01845
Attn: Judy Tymon, Town Planner
North Andover Conservation Commission
1600 Osgood Street
North Andover, MA 01845
Attn: Jennifer Hughes, Conservation Coordinator
RE: Butcher Boy Marketplace, 1077 Osgood Street
Stormwater Management Review
Dear Ms. Tymon, Ms. Hughes and Board Members:
Per your request, I have reviewed the June 26, 2013 Response to Comments and revised
plans and calculations submitted by Lynnfield Engineering for the proposed Pentucket
Bank at the Butcher Boy Marketplace (1077 Osgood Street), with respect to stormwater
management. My comments on the revised submittal are summarized below:
1. The HydroCAD report for proposed conditions that was included in the revised
submittal does not include the invert, structure and pipe size data necessary for me
to verify the calculations with respect to the rate and volume of runoff from the site.
2. The proposed plan relies on flow attenuation in subsurface structures for all design
storms, however it is not clear that the drainage system delivering the runoff to the
subsurface structures has been designed to convey the 100-yr event, or that the
drainage system downgradient of the site has the capacity to accommodate the
increased flow volume.
3. While the revised plan does call for recharging the roof runoff from the proposed
bank building, it does not compensate totally for the loss of recharge r epresented
by this project as the roof represents only a fraction of the added impervious cover
on the site and the calculations do not account for capture area. The Watershed
Protection District regulations (Section 4.136(4)(g) of North Andover Zoning
Bylaw) do require that the runoff from impervious surfaces be recharged onsite to
the maximum extent practicable. This is particularly important for this site since
much of the surface runoff would also be diverted away from the Lake
Cochichewick watershed under proposed conditions. While the soils within the
project area are relatively poorly draining HSG C soils, the existing topography of
the area and the surface detention basin likely enhance the amount of recharge that
currently occurs. As stated in my April 10th review comments, consideration should
be given to providing compensatory recharge elsewhere on the Butcher Boy site, a
Butcher Boy Marketplace, Stormwater Review 2
July 15, 2013
large portion of which is outside of the Zone A but still within the Lake
Cochichewick watershed.
4. The proposed roof infiltration systems will be located mostly in fill, and one system
within the stone-lined footprint of the existing detention basin. The plans should
specify the type of fill to be used on the site and should call for removal of
unsuitable material beneath the systems. Confirmatory testing will also be needed
to verify the soil type and depth to groundwater in proposed infiltration areas.
5. The roof infiltration units should be set back as far as possible from the retaining
walls in order to prevent breakout of infiltrated flow.
6. The architectural plans appear to show metal roof and/or roofing elements on the
bank building; runoff from metal roofs (galvanized steel or copper) cannot be
infiltrated within the Zone A.
7. Overflow from the roof infiltration systems should not discharge through the
proposed CDS units in order to maximize their effectiveness for treating pavement
runoff.
8. The proposed treatment train for the pavement runoff on the site is comprised of
deep sump catchbasins, in-line hydrodynamic separators, and subsurface “extended
detention basins”. The TSS removal calculations claim 80 percent TSS removal in
the CDS hydrodynamic separators, based on the predicted removal rates provided
by the manufacturer. The DEP Handbook calls for proprietary separators to be used
only as pretreatment devices and only in an off-line configuration. Since
Massachusetts has not established TSS removal rates for the devices, the Handbook
encourages Conservation Commissions to rely on other studies such as the NJCAT
one referenced on the MASTEP Technology Review website to determine likely
removal rates. The NJCAT study, conducted using modified TARP protocols,
resulted in a certified TSS removal rate for the CDS units of 50 percent. Based on
my recent conversations with Tom Maguire, the Regional Consistency Coordinator
for MaDEP, the expected removal rates for these units in the field may be
substantially less than even the 50 percent assigned by NJCAT.
9. The proposed “extended detention basins” appear to be designed specifically for
purposes of flow attenuation and not for water quality treatment. As subsurface
structures they are not at all consistent with the design guidelines for extended
detention basins in the DEP Handbook, which call for above-ground basins with
sediment forebays, vegetation and low flow channels to facilitate pollutant removal.
The DEP Handbook does not grant any TSS removal credit for subsurface detention
structures except when they also provide infiltration. I would also add that the 80
percent TSS removal requirement for this site should be provided upgradient of the
proposed subsurface detention structures as any sediment that does accumulate in
the subsurface systems will be difficult to remove.
Butcher Boy Marketplace, Stormwater Review 3
July 15, 2013
10. DMH3 and DMH5 are outlet control structures and should be labeled as such on
the plan (or the OCS detail should identify the structure numbers).
11. Similarly, WQ1 and WQ2 should be labeled as to which model CDS unit they
pertain to.
12. The Grading and Drainage Plan (Sheet C-6) needs to show the re-grading of the
landscaped area to the northwest of the proposed parking area, where the existing
detention basin will be filled in.
13. It is not clear whether the silt fence line on the Erosion & Sediment Control Plan
delineates a Limit of Work, as is called for in the Zoning Regulations. I note that
the Landscape plan appears to call for tree planting and loaming and seeding in
areas outside of the silt fence.
14. New landscaped areas should be constructed in such a manner as to minimize the
maintenance that is required, e.g. the soil should be well aerated, it should have a
minimum of 6-inches of topsoil and, where possible, native vegetation should be
planted to minimize the need for fertilizer and watering. As with similar projects
permitted within the Watershed Protection District, both the limits of approved
work and the restriction on landscaping chemicals to be used on the site should be
permanently recorded on the deed to the property.
15. I did not receive a copy of the Watershed Special Permit application and am unable
to verify that a written certification by a professional engineer stating that the
project will not cause any significant degradation in the quality or quantity of water
in or entering Lake Cochichewick was included. I have also not seen evidence that
the applicant has submitted proof that there is no reasonable alternative outside of
the Non-Discharge Zone for the proposed project, or components thereof, to occur,
as is required by the Zoning Regulations.
16. I have the following comments on the revised O&M Plan:
Other than the name, it is not clear that the revised O&M plan is intended
to apply to the entire Butcher Boy Marketplace property, as is suggested in
the Response to Comments. The plan should identify all stormwater BMPs
to be maintained on the site (including a map showing their locations) and
should identify specific measures aimed at improving existing conditions.
Catchbasins and hydrodynamic separator units should be cleaned a
minimum of once per year, with a vacuum truck.
It is unclear which detention system the O&M Plan refers to – the roof
infiltration systems or the “extended dry detention systems”. The O&M
Plan does not call for sediment removal from the systems, as would be
required for the “extended dry detention systems, and the attached
manufacturers O&M guidelines are for Cultec units, similar to the
Stormtech units specified for the roof infiltration systems.
Butcher Boy Marketplace, Stormwater Review 4
July 15, 2013
The O&M Plan refers to designated snow storage locations shown on the
plan, but I could not find any such locations identified on the plans. To the
maximum extent possible, snow storage should be located outside of the
Zone A and upgradient of stormwater BMPs; untreated meltwater from
plowed snow should not be infiltrated within the Zone A, and particularly
not within the Non-Discharge Zone.
Once again, I appreciate the opportunity to assist the North Andover Conservation
Commission and Planning Board with the review of this project, and hope that this
information is suitable for your needs. Please feel free to contact me if you or the applicants
have any questions regarding the issues addressed herein.
Sincerely,
EGGLESTON ENVIRONMENTAL
Lisa D. Eggleston, P.E.