HomeMy WebLinkAbout03/08/2024 - Second Stormwater Peer Review - - %�.
Horsley Wiften Group
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SUStainable, Ehvirownental Solutions
112 W'at r `tr t-61 Floor-Boston,MBA 02109 ..........
February 8, 2024
Ms. Jean Enright, Planning Director
North Andover Planning Board
120 Main Street
North Andover, Massachusetts 01845
Ref: Second Stormwater Peer Review
Redevelopment of North Andover Mall
North Andover, Massachusetts
Dear Ms. Enright and Board Members:
The Horsley Witten Group, Inc. (HW) is pleased to provide the North Andover Planning Board
with this letter report summarizing our second review of the Stormwater Report and Site Plan for
the proposed redevelopment of the North Andover Mall at 350 Winthrop Ave, North Andover,
MA. The plans and Stormwater Report were prepared by R.J. O'Connell & Associates, Inc. on
behalf of DSM Realty, Inc. (Applicant). The redevelopment project proposes the renovation of a
portion of the existing 244,415 square foot (sf) building, involving the exchange of store
locations for two of the current tenants and the relocation of existing loading docks in
association with the tenant location exchange. The proposed redevelopment will mostly match
existing edge of pavement locations except in areas adjacent to an intermittent stream, where
the edge of pavement will be moved further away from the stream. The removal of this portion
of existing pavement as well as the addition of proposed landscape islands will result in an
overall reduction of impervious cover from 581,918 sf in existing conditions to 528,121 sf in
proposed conditions. This is a decrease of 54,650 sf of impervious surface.
The proposed redevelopment's stormwater management system includes wet basins with
sediment forebays, a water quality swale, and trench drains that direct runoff to hydrodynamic
particle separators. The proposed parking lot area has also been regraded to provide additional
flood storage capacity. A large portion of the parking lot is within the 100-year flood zone (Zone
AE) and the floodway associated with the Shawsheen River bisects the northwest corner of the
parcel. There are also wetland resource areas and buffer zones within the northern and
southern portions of the property.
The following documents and plans were received by HW in response to our intital peer review
letter dated January 16, 2024:
• Stormwater Report, North Andover Mall, 350 Winthrop Avenue, North Andover, MA,
prepared for DSM Realty, Inc. (Applicant), prepared by R.J. O'Connell &Associates,
Inc., revised January 26, 2024 (330 pages);
• Letter to Jean Enright, regarding response to peer review, prepared by R.J. O'Connell &
Associates, Inc. on behalf of Delta M B LLC, dated February 5, 2024 (67 pages);
• Site Plan for Redevelopment of North Andover Mall — North Andover, MA, prepared for
DSM Realty, Inc. (Applicant), prepared by R.J. O'Connell &Associates, Inc., dated
December 8, 2023, revised through February 2, 2024 (28 sheets);
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Town of North Andover
February 8, 2024
Page 2of7
• Compensatory Flood Storage Plan (Existing), Sheet FS-1, prepared by R.J. O'Connell &
Associates, Inc., revised January 26, 2024; and
• Compensatory Flood Storage Plan (Proposed), Sheet FS-2, prepared by R.J. O'Connell
&Associates, Inc., revised January 26, 2024.
Stormwater Management Design Peer Review
HW offers the following comments concerning the stormwater management design as per the
Massachusetts Stormwater Handbook (MSH) dated February 2008, and the North Andover
Chapter 165 Stormwater Management and Erosion Control Bylaw (Bylaw), and the Chapter 250
Stormwater Management and Erosion Control regulations (Stormwater Regulations) adopted
June 21, 2022.
In accordance with Stormwater Regulations, Article V- Applicability, §250-9 activities entailing
land disturbance of over 43,560 square feet must obtain a Land Disturbance Permit. In
accordance with the Stormwater Regulations, Article VII - Stormwater Management Plan, §250-
21. B. The Stormwater Management Plan shall be designed to meet the most recent version of
the Massachusetts Stormwater Standards. Therefore, we have used the Massachusetts
Stormwater Standards as the basis for organizing our comments. However, in instances where
the additional criteria established in §250-22 of the North Andover Code requires further
recommendations; we have referenced these as well.
The following comments correlate to our initial review letter dated January 16, 2024. Follow up
comments are provided in bold font.
1. Standard 1: No new stormwater conveyances (e.g., outfalls) may discharge untreated
stormwater directly to or cause erosion in wetlands or waters of the Commonwealth.
a. The Applicant has analyzed the pre- and post-development stormwater runoff to three
points of analysis (POA).
i) POA-1 is where the site discharges to the Shawsheen River on the northwest side of
the parcel. The large parking lot west of the building flows towards the intermittent
stream and the Shawsheen River. Under proposed conditions the impervious surface
towards POA-1 is being reduced by more than 50,000 sf and the Applicant has
proposed several stormwater practices for water quality. The wet basins reduce the
peak flow rate, and the outfall weirs will reduce the velocity at the discharge point. No
further action requested.
HW (02.08.24): No further action requested.
ii) POA-2 is the existing wetland resource area (series A) located along the north side
of the property. The existing building and parking area on the east side of the
building flows towards POA-2 via a closed drainage system that outlets at the edge
of the wetland. Under proposed conditions the Applicant is reducing the impervious
cover slightly, adding water quality units, and adding a 4-foot-wide French Drain
along the edge of the pavement. The Applicant is maintaining the existing drainage
system and outfalls. HW recommends that the Applicant confirm that the existing
outfalls are not causing erosion in the wetland (Series A). HW notes that the
Applicant has included calculations for riprap aprons which it may be proposing at
the two existing outfalls. However, it is not clear where the aprons are to be located.
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Town of North Andover
February 8, 2024
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HW also notes that if riprap aprons are proposed in the wetlands this should be
included as fill when submitting a Notice of Intent to the Conservation Commission.
HW (02.08.24): The Applicant has explained that erosion was observed at the
twin 36" drainpipes and that the area will be repaired and stabilized with rip rap
stone. The Applicant is working with the Conservation Agent to conduct the
work. HW has no further comment.
iii) POA-3 is the existing wetland resource area (Series C) on the south side of the
parcel. The proposed catchment area is identical to the existing catchment area.
There are no impervious areas within the watershed to POA-3. No further action
requested.
HW (02.08.24): No further action requested.
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. HW has reviewed the Existing and Proposed Drainage Conditions figures and the
HydroCAD model. The subcatchment areas, surface materials, curve numbers, times of
concentrations, and flow patterns appear reasonable. No further action requested.
HW (02.08.24): No further action requested.
b. The Applicant has designed two wet basins that overflow towards the Shawsheen River.
The dimensions of the proposed spillways are not consistent between the HydroCAD
model, and the Grading and Drainage Plan (Sheet C-3). HW recommends that the
Applicant review the design and confirm the dimensions are consistent.
HW (02.08.24): The Applicant has revised the dimensions of the wet basins to be
consistent with the HydroCAD model. HW has no further comment.
c. HW recommends that the Applicant provide a detail of the proposed Drainage Channel
and check dams in the plan set.
HW (02.08.24): The Applicant has added the requested details to Sheet C-8. HW
has no further comment.
d. 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-year, 25-year, and 100-year storm events to show that post-
development rates and volumes do not exceed pre-development rates and volumes.
HW (02.08.24): The Applicant has added a narrative to the Stormwater Report. No
further action requested.
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Town of North Andover
February 8, 2024
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Point of Analysis #1
Storm Existing Flow Proposed Flow Existing Proposed
Frequency Rate (cfs) Rate (cfs) Volume (af) Volume (af)
2-Year 26.0 1.9 1.94 0.68
10-Year 51.3 32.1 3.83 2.43
25-Year 67.8 48.9 5.09 3.63
100-Year 93.4 71.2 7.09 5.56
Point of Analysis #2
Storm Existing Flow Proposed Flow Existing Proposed
Frequency Rate (cfs) Rate (cfs) Volume (af) Volume (af)
2-Year 12.8 12.7 1.00 1.00
10-Year 33.4 33.3 2.44 2.43
25-Year 47.7 47.6 3.46 3.46
100-Year 70.8 70.7 5.14 5.13
Point of Analysis #3
Storm Existing Flow Proposed Flow Existing Proposed
Frequency Rate (cfs) Rate (cfs) Volume (af) Volume (af)
2-Year 0.00 0.00 0.00 0.00
10-Year 0.00 0.00 0.00 0.00
25-Year 0.10 0.10 0.05 0.05
100-Year 0.60 0.60 0.18 0.18
3. Standard 3 requires that the annual recharge from post-development shall approximate
annual recharge from pre-development conditions.
a. The Applicant has reduced the total impervious surface by more than 1 acre. The annual
recharge from post-development is greater than the pre-development conditions. No
further action requested.
HW (02.08.24): No further action requested.
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Town of North Andover
February 8, 2024
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4. Standard 4 requires that the stormwater 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 states an Oil Grit Separator has a
TSS Removal Rate of 80%. Page 11, Chapter 1, Volume 1 of the Massachusetts
Stormwater Handbook states that an Oil Grit Separator has a TSS Removal Rate of
25%. HW recommends that the Applicant justify the use of the 80% TSS Removal Rate
and provide applicable documentation from a third-party reviewer supporting the listed
TSS removal rate.
HW (02.08.24): The Applicant has provided the requested documentation and has
justified the use of 80% TSS removal. HW has no further comment.
b. HW recommends that the Applicant clarify the impervious area directed towards CDS
Units 1 and 2.
HW (02.08.24): The Applicant has provided a CDS Unit Contributing Area Plan to
clarify the impervious area directed towards each CDS unit. HW has no further
comment.
c. Per §250-23 C. (1)(b) redevelopments sites are required to retain the volume of runoff
equivalent to 0.8 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 C. (1). The Applicant should clarify the Phosphorous removal
calculations. A curve for porous pavement was included but not one for the Water
Quality Swale.
HW (02.08.24): The Applicant has provided the Phosphorous removal curves for
the Water Quality Swale and for the Wet Pond. The total Phosphorus removed for
this redevelopment is 51%. HW has no further comment.
5. Standard 5 is related to projects with a Land Use of Higher Potential Pollutant Loads
(LUHPPL).
a. The MSH states that a LUHPPL includes parking lots with high intensity uses such as
the parking lot of a mall. The Applicant has proposed stormwater practices that the MSH
has determined suitable to treat runoff from such land uses. These stormwater practices
include oil grit separators, sediment forebays, drainage channel, and wet basins. No
further action requested.
HW (02.08.24): No further action requested.
6. Standard 6 is related to projects with stormwater discharging into a critical area, a Zone II, or
an Interim Wellhead Protection Area of a public water supply.
a. The proposed development is not discharging near or into a critical area, Zone II or an
IWPA area. However, the Applicant has acknowledged that some endangered species
including bald eagles may be within the Project Area which may trigger Standard 6. The
Applicant has proposed stormwater practices that the MSH has determined suitable to
treat runoff from such land uses. No further action requested.
HW (02.08.24): No further action requested.
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Town of North Andover
February 8, 2024
Page 6of7
7. Standard 7 is related to projects considered Redevelopment.
a. This project is a redevelopment and is required to comply with the Stormwater
Management Standards to the maximum extent practicable.
HW (02.08.24): No further action requested.
8. Standard 8 requires a plan to control construction related impacts including erosion,
sedimentation, or other pollutant sources.
a. The Applicant has provided a draft Stormwater Pollution Prevention Plan (SWPPP) as
required by EPA for land disturbance of greater than 1 acre. The plan includes source
control and pollution prevention measures, stormwater practices to address erosion and
sedimentation, stabilization measures, and procedures for operating and maintaining the
BMPs. The plan also identifies the parties responsible for implementing the plan. The
Planning Board may choose to require a final signed SWPPP a minimum of 14 days
prior to land disturbance.
HW (02.08.24): The Planning Board may choose to require a final signed SWPPP a
minimum of 14 days prior to land disturbance as a Condition of Approval.
b. The Applicant has included a 9-inch straw wattle as an erosion control barrier.
Considering the proximity of the resource areas and the Shawsheen River, HW
recommends that the Applicant include a more robust erosion control barrier for any
work within 25 feet of a wetland. Details of all erosion controls practices should be
included in the Plan Set.
HW (02.08.24): The Applicant has provided additional erosion control measures as
requested. HW has no further comment.
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 Appendix E of the
Stormwater Report. The O&M Plan can be removed from the Stormwater Report and be
a standalone document for use by the property owner.
HW (02.08.24): HW has no further comment.
b. HW recommends that the Applicant include an estimated budget within the O&M Plan.
HW (02.08.24): The Applicant has included an estimated budget in the revised
O&M Plan. HW has no further comment.
c. HW recommends that the Applicant include a simple sketch within the O&M Plan that is
drawn to scale and shows the location of stormwater BMPs in each treatment train along
with the discharge point.
HW (02.08.24): The Applicant has included a Stormwater Structure Plan in the
revised O&M Plan. HW has no further comment.
d. HW recommends that the Planning Board reference this document and consider
requesting receipt of a signed O&M Plan as a condition of approval.
HW (02.08.24): The Planning Board may choose to require a final signed O&M Plan
as a Condition of Approval.
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Town of North Andover
February 8, 2024
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10. Standard 10 requires an Illicit Discharge Compliance Statement be provided.
a. The Applicant has provided an Illicit Discharge Compliance Statement as part of the
Operation & Maintenance Plan. The Planning Board may choose to require receipt of a
signed statement prior to land disturbance.
HW (02.08.24): The Planning Board may choose to require receipt of a signed Illicit
Discharge Compliance Statement prior to land disturbance.
11. 100-year Flood Plain
a. The Applicant has provided compensatory flood storage calculations in the Stormwater
Report. HW notes that it appears that the Applicant has included the storage volume in
the wet basins and sediment forebays. In accordance with paragraph 10.57(4)(a)l. of
the Wetlands Protection Act, "Such compensatory volume shall have an unrestricted
hydraulic connection to the same waterway or water body."The vol u me below elevation
26 that is not hydraulically connected to the waterway should not be included as storage.
HW recommends that the Applicant confirm it has provided adequate storage in
accordance with 310 CMR 10.57.
HW (02.08.24): The Applicant has revised the Compensatory Flood Storage figures
and calculations as requested. HW has no further comment.
b. A large portion of the property appears on the Federal Emergency Management Agency
(FEMA) Flood Insurance Map as being in Zone AE, which is associated with elevation
33 on the map dated September 17, 2012. FEMA has produced a preliminary map dated
February 20, 2023, where a larger portion of the parcel is within the 100-year flood plain
and it is assigned elevation 33.6. HW notes that when an elevation is assigned to a flood
zone the land survey should delineate the extent of the flood plain by the actual contour
elevation and not by the shape outlined on the FEMA map. HW recommends that the
Applicant redraw the 100-year flood plain line under existing and proposed conditions
using the more conservative elevation of 33.6.
HW (02.08.24): The Applicant has revised the Compensatory Flood Storage figures
and calculations as requested. The Applicant has increased the flood storage at
every foot evaluated between elevation 25 and elevation 33.6. HW has no further
comment. (Figures eliminated for simplicity).
Conclusions
HW is satisfied that the Applicant has adequately addressed our comments. Please contact
Janet Bernardo at 508-833-6600 or at jbernardo@horsleywitten.com if you have any questions
regarding these comments.
Sincerely,
HORSLEY WITTEN GROUP, INC.
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Janet Carter Bernardo, P.E.
Associate Principal
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