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HomeMy WebLinkAbout20231101_HW_SWPeerReview_HSA Response - - HANCOCK ASSOCIATES ,!Wurvoyors ScieirniW. November 1, 2023 Ms.Jean Enright, Planning Director North Andover Planning Board 120 Main Street North Andover, MA 01845 Dear Ms. Enright and Board Members, On behalf of Home Grown Lacrosse, LLC, Hancock Associates hereby submits this response to Horsley Witten Group's initial stormwater peer review letter regarding 492 Sutton Street dated October 18, 2023. Comments issued by the various departments are shown below with Hancock Associates' responses italicized and in red. Stormwater Management Design Peer Review In accordance with the North Andover Zoning Bylaw§195-8.14. E. (8)A Stormwater management plan is required for all site plan review applications. The stormwater management plan shall be prepared in accordance with the latest version of the Massachusetts Stormwater Handbook(MSH) and demonstrate full compliance with the Massachusetts Stormwater Standards and the North Andover Stormwater Management and Erosion Control, Chapter 165 of the Town Bylaws. Chapter 165 further references Chapter 250. Stormwater Management and Erosion Control. HW offers the following comments concerning the stormwater management design. We have used the Massachusetts Stormwater Standards as the basis for organizing our comments. However, in instances where the additional criteria established in §250-27 of the North Andover Code requires further recommendations; we have referenced these as well. 1. Standard 1:No new storm water conveyances (e.g., outfalls)may discharge untreated storm water directly to or cause erosion in wetlands or waters of the Commonwealth. a. The Applicant has evaluated two discharge points from the project site. Under existing conditions stormwater from Subcatchment 1S flows northwest towards Terminal Road. Stormwater from Subcatchment 2S flows southeast towards Old Clark Street.The existing site consists of grass and woods.There are no existing stormwater practices. HSA Response:Acknowledged. b. The Applicant proposes to construct a porous pavement parking lot with a subsurface reservoir to infiltrate runoff from the proposed building roof and parking lot.The reservoir overflows to the municipal stormwater system on Sutton Street.The remainder of the site flows into the Terminal Road and Sutton Street/Old Clark Road drainage system.The site is not discharging to wetlands or waters of the Commonwealth. HSA Response:Acknowledged. 2. Standard 2:Stormwater management systems shall be designed so that post-development peak discharge rates do not exceed pre-development peak discharge rates. a. In accordance with §250-22 B. (6) a summary of pre-and post-development peak rates and volumes of stormwater demonstrating no adverse impacts should be provided as part of the narrative.The Applicant has provided the peak flows and the peak volumes for the 2-year, 10- 34 Chelmsford Street, 2nd Floor I Chelmsford, MA 01824 1 V 978-244-0110 F:978-244-1133 HancockAssociates.com II II I , I',:? 1 � " II A, C h 1 I II I:::°� I L;;;:�„ C', II"MJ l;,',',',I ";, I A I I ¢)II 9 U�.;:r l 1 M "'I""'I II"I II I J C I:I�:;+II\„i p IIA A I S All II',', V„ "`„ol lh...l year, 25-year, and 100-year storm events under Documenting Compliance in the Stormwater Management Report. HW recommends that the Applicant provide a revised table if needed based on the comments below. b. In accordance with §250-22 B. (5) (a) a summary of proposed land area to be disturbed and existing and proposed impervious area should be provided as part of the narrative. HW recommends that the Applicant include the proposed land area to be disturbed and the existing and proposed impervious area in the narrative. HSA Response: A land disturbance summary has been added to the starmwater report (Background Information,part C'). Total Disturbance=88,000 S.F± New Impervious=599,515 S,F c. The Applicant has modeled the porous pavement with a 597-minute time of concentration (Tc) and then routed it through a pond. HW does not agree with this methodology.The stormwater should flow through the porous pavement quickly and then will be held in the pond for an extended period as it infiltrates. Including the lengthy Tc and the pond is doubling the affect that the porous pavement will have. HW recommends that the Applicant revisit the model or justify its methodology. HSA Response: The intent of modelling an extended Tc was to represent the impact of the multiple courses of materials in providing treatment and attenuation to flow through the system. The Tc value of the porous pavement subcatch ent has been reduced to a standard 5 minutes to reflect water quickly flowing through the porous layer of the pavement. In doing this however, it eliminates the benefits of the porous pavement system in regards to attenuation. In order to accurately model the effects of the overlaying courses of material to the reservoir course a modified CN is used rather than a C'N=98 which would essentially model the porous system as a parking lot free flowing to a conventional infiltration practice such as underground chambers which is not an accurate representation. To determine a CN for special conditions the SC'S equation for potential maximum retention can be utilized. Porous Cross Section Void Ratio Depth S=VR x D 4"porous pavement n/a n/a n/a 4"crush stone 0.4 4 1.6 1000 10 12"BR gravel 0.3 12 3.6 CN 3"peastone 0.4 3 1.2 where S is in inches 7S=6.4 Rearranged: 1000 1000 CN =6.4+10 CN = S + 10 CN= 60.98 = 61 The main issue with attempting to model porous pavement is that programs such as HydroC'AD can effectively model volume reduction or peak reduction but not bath. To estimate bath the volume and peak reductions the modified CN is used since there is currently no way to simultaneously model lag time through the system AND have a 6 minute Tc through the permeable pavement layer. Modifying the CN as shown above►Weill estimate the weak flow reduction but will not estimate the outflow volume since volume is being last by modeling the subcatchment with a louver CN value. The previously submitted report accurately represented volume going into the system due to the 98 CN but relied on are extended lag time to reflect the impacts of the system on freak outflow. The revised HydroCAD worksheets provide peak reduction calculations using the modified CN=61 for the porous pavement subcatchment. d. The Applicant has provided a detail for the porous pavement. HW has thefollowing comments: i. Note#10 in the General Construction Sequence—Porous Pavement calls for 6 inches of 3/4"to 1" diameter stone. However, the figure and schedule of elevations show the depth to be 8 inches. HW recommends that the Applicant revise the depth listed in the note. HSA Responses!vote#10 updated to reflect 8"reservoir depth. ii. HW recommends that the Applicant add the installation of the underdrains, cleanouts, and OCS to the General Construction Sequence—Porous Pavement. HSA Response:installation instructions have been added to the construction sequence of the porous pavement for underdrains, cleanouts, and OCS. iii. The figure calls out 4" SCH40 4" Perf. Pipe for the underdrain. However,the Porous Pavement Area Connections and Grading & Drainage Plan call for 6" Perforated ADS Pipe. HW recommends that the Applicant revise the detail accordingly. HSA Response:Detail updated to show 6"perforated ALAS pipe. iv. HW recommends that the Applicant confirm if inspection ports are proposed for the porous pavement area and show their locations on the Grading& Drainage Plan. HSA Response: inspection ports are shown at the each underdrain intersection on the GDU sheet and ore noted in the C?&M plan for the porous pavement. V. It appears that the reservoir layer for the porous pavement extends beyond the surface porous pavement area. HW recommends that the Applicant explain the installation process for this section of the stormwater practice and confirm if additional instructions or details are necessary on the plans. HSA Response:(Vote added to GDU sheet e. The porous pavement reservoir is proposed to overflow into the proposed OCS and be piped to a proposed offsite drain manhole.The connecting pipe is located very close to an existing catch basin (RIM = 153.88) on Old Clark Street. It is unclear how the existing catch basin ties into the street drainage system. HW recommends that the Applicant verify that the proposed pipe has adequate separation from the existing catch basin and that it does not conflict with the existing street drainage system. HW further recommends that the Applicant confirm that the North Andover Department of Public Works has reviewed the proposed drain manhole and the connection to the municipal system. HSA Response.- The edge of the proposed pipe is located 6 feet away from the center of the existing catch basin, assuming a standard 4 foot inner diameter structure, this leaves adequate room to install the proposed pipe. Plans have also been submitted to the North Andover DPW for review and comment. f. The Applicant has provided existing and proposed subcatchment plans. HW recommends that the Applicant include the Tc Flow Paths for the existing subcatchment plan. HSA Response: Tc flow paths have been added to fare and Rost development subcatchment plans. g. HW recommends that the Applicant provide a typical pavement detail for the proposed driveway. HSA Response:Bituminous concrete crass-section detail added to Detail sheet 2 of 2 h. The Applicant has provided a grass swale detail. HW recommends that theApplicant label the proposed grass swale on the north side of the site. HSA Response: Grass swale label added to GDU sheet. i. The Applicant has provided a typical plan view detail for the outlet control structure (OCS). HW recommends that the Applicant provide the cross-section detail for the OCS as well. HSA Response: Cross section detail has been added to CICS detail. j. The proposed HydroCAD model for the porous pavement uses a 4-foot sharp crested rectangular weir for the OCS. HW recommends that the Applicant add this dimension to the OCS detail. HSA Response:4-foot weir labeled in OCS detail. k. The Applicant has provided a Cape Cod berm detail. HW recommends that the Applicant clarify where Cape Cod berm is proposed on the site and call it out in the plans. HSA Response: Curbing has been added to the driveway entrance and shown on all sheets of the plan set. I. The Applicant has used precipitation values equal to or greater than the values provided by National Oceanic and Atmospheric Administration (NOAA) Atlas 14 for the 24-hour storm events, as outlined in §250-23 E. (19). No further action required. HSA Responses Acknowledged 3. Standard 3 requires that the annual recharge from post-development shall approximate annual recharge from pre-development conditions. a. The Applicant has provided recharge volume and drawdown calculations. HW recommends that the Applicant provided the stage storage data for the porous pavement system to confirm the volume provided below the lowest outlet(elevation 159.52). HSA Responses Stage storage table has been added to the stormwater report showing storage volume equal to 4,933 CF at elevation 159.52. b. The separation from the bottom of the porous pavement system to the Estimated Seasonal High Groundwater(ESHGW) is 2 feet.The Applicant has provided a mounding analysis. It appears that mounding will not affect the recharge and drawdown provided by the proposed porous pavement system. HW has no further comment. HSA Response:Acknowledged 4. Standard 4 requires that the storm water system be designed to remove 80% Total Suspended Solids(TSS)and to treat 1-inch of volume from the impervious area for water quality. a. The Applicant has provided a TSS worksheet that lists the porous pavement to provide the 90%TSS removal per the Town's requirements.According to MA MS4 General Permit 2.3.6a.ii.3.a3.2, the TSS removal efficiency of porous pavement is 90% if the storage bed is sized to retain 1" water quality volume drained within 72 hours. HW recommends that the Applicant address the comments under Standard 3 to satisfy this requirement. HSA Response:Acknowledged b. Per§250-23 B. (1)the Applicant is required to remove 60%of the average annual load of Total Phosphorus.The Applicant has noted that it removes 62%of the Phosphorus load via the 12-inch filter course in the porous pavement according to the MA MS4 General Permit Table 3-22 of Appendix F, Attachment 3.The Applicant has provided sufficient phosphorus removal. No further action required. HSA Response:Acknowledged c. The Applicant has noted in its narrative that the proposed stormwater system has been designed to treat one inch of water quality volume. Per§250-23 B. (1)(b) new developments are required to retain the volume of runoff equivalent to one inch multiplied by the total post-construction impervious surface or meet a combination of retention and treatment that achieves the above standards listed under§250-23 B. (1). It appears that the criteria have been met. No further action required. HSA Response:Acknowledged 5. Standard 5 is related to projects with a Land Use of Higher Potential Pollutant Loads (LUHPPL). a. The project is not considered a LUHPPL. Standard 5 is not applicable. HSA Response:Acknowledged 6. Standard 6 is related to projects with storm water discharging into a critical area, a Zone ll, or an Interim Wellhead Protection Area of a public water supply. a. A portion of the project site closest to Old Clark Street is within the North Andover Watershed Protection District. In accordance with §195-4.19. B. (4)All construction in the Watershed Protection District shall comply with best management practices for erosion, siltation, and stormwater control in order to preserve the purity of the groundwater and the lake, to maintain the groundwater table,and to maintain the filtration and purification functions of the land. HW has listed comments under Standard 8 regarding erosion control practices for the project site. b. The existing conditions plan indicates that the boundary of the Watershed Protection District is through the middle of the project area.The proposed site layout illustrates the Non- Discharge Zone Watershed protection District only minimal crossing the project area. HW recommends that the Applicant clarify where the boundary is on the siteplans. HSA Response:Existing conditions plan and site plan have been revised to show both general Watershed Protection District and lion-Discharge Zane Watershed Protection District. 7. Standard 7 is related to projects considered Redevelopment. a. The project is considered new development. Standard 7 is not applicable. HSA Response:Acknowledged 8. Standard 8 requires a plan to control construction related impacts including erosion, sedimentation, or other pollutant sources. a. The Applicant has included an erosion control barrier along the lease limit of the site and catch basin inlet protection to the Grading and Drainage Plan. HW recommends that the Applicant create an Erosion &Sediment Control Plan on a separate sheet in the plan set.The Erosion &Sediment Control Plan should also include a stabilized construction entrance and temporary stockpile locations. HSA Response: Temporary stabilized construction entrance has been added to the Erosion and Sedimentation Control Plan. b. HW recommends that the Applicant include the Limit of Work (LOW) on alldrawings within the plan set. HSA Response:Limit of Work has been labeled can all sheets of the plan set. c. The Applicant has provided a straw wattle detail that also shows a silt fence. HW recommends that the Applicant add more information about silt fence installation to the detail. HSA Response:Additional detail for silt fence installation has been added to the Erosion and Sedimentation Control Plan. d. According to the HydroCAD models,the Applicant proposes to decrease the woods on site by approximately 6,000 sf. HW recommends that the Applicant demonstrate which trees are proposed to be removed and which trees will be protected on the plans. HSA Responses Proposed tree line has been added to the GDU sheet. Proposed limit of work shall serve as the limit of clearing.All trees outside of the limit shall be protected. e. HW recommends that the Applicant add a note stating, prior to any land disturbance activities commencing on the site,the developer shall physically mark limits of no land disturbance with tape, signs, or orange construction fence, so that workers can seethe areas to be protected.The physical markers shall be inspected daily. HSA Response:Note stating that physical markers shall be installed prior to any construction activity has been added to the Erosion and Sedimentation Control Plan. f. The Applicant is proposing to disturb more than one acre of land. In accordance withthe EPA Construction General Permit, the Applicant is required to file a Notice of Intent with the EPA and prepare a Stormwater Pollution Prevention Plan (SWPPP). HW recommends that the Applicant provide the Town of North Andover with a copy of the SWPPP a minimum of 14 days prior to land disturbance.The Planning Board may choose to require receipt of the final SWPPP signed by the contractor as a condition of approval. HSA Response: Note stating that the contractor shall be responsible for filing a CPG with the EPA no less than 30 days prior to the anticipated land disturbance over one(1) acre. 9. Standard 9 requires a Long-Term Operation and Maintenance(O& M)Plan to be provided. a. The Applicant has provided an Operation and Maintenance Plan in the Stormwater Report. HW recommends that the O&M Plan become a standalone document to be signed by the owner. HSA Response; O&M plan has been removed from the stormwoater report and shall be submitted as a standalone document. b. The Applicant has included the pervious pavement as a maintenance item in theO&M Plan. HW recommends that the Applicant clarify if inspection ports are proposed and mention them in the O&M Plan. HSA Response; The monitoring and inspecting of proposed inspection ports has been noted in the O&M Plan under the Porous Pavement item: "Inspect surface and inspection ports after storm events to insure proper drainage" c. HW recommends that the Applicant include the maintenance of the OCS and roof drains in the O&M Plan. HSA Response; Outlet control structure and roof drain leader operation and maintenance plans and lags have been added to the O&M Flan. d. HW recommends that the Applicant include a budget in the O&M Plan. e. HW recommends that the Applicant provide a simple plan, drawn to scale clearly noting all stormwater practices requiring long term maintenance. 10. Standard 10 requires on Illicit Discharge Compliance Statement be provided. a. The Applicant has provided an Illicit Discharge Compliance Statement in the Stormwater Report. HW recommends that the Town require the submission of the Illicit Discharge Statement signed by the property owner prior to discharge of stormwater to post- construction best management practices as a condition of approval. HSA Response:Acknowledged