HomeMy WebLinkAbout2024/11/15 - 3rd Stormwater Peer Review - - Horsley Witten Group "I'll,...................."I
rf
MPo
ustainable,Environmental Solutions
112 ftiter Shur -60 bcw w osioni,MA 02109
8,57-263-8193 hursleywitterl.com if+
November 15, 2024
Mr. Robert Douglas
Director of Conservation
Andover Conservation Commission
36 Bartlett Street
Andover, MA 01810
Re: Third Peer Review of the Stormwater Design
Merrimack College Lecture Hall
Andover, MA
MassDEP File No. 090-1441
Dear Mr. Douglas and Commission Members:
The Horsley Witten Group, Inc. (HW) is pleased to provide the Andover Conservation
Commission with this letter summarizing our third peer review of the construction of the
Merrimack College Lecture Hall. The plans were prepared by VHB, Inc., on behalf of Merrimack
College (Applicant). The Applicant proposes to construct a lecture hall building, with associated
walkways, landscaping, stormwater management system, and utility infrastructure. It does not
appear that there are any wetland resource areas within 100 feet of the proposed development.
The Applicant proposes the construction of stormwater management system comprised of a
series of catch basins to direct stormwater runoff to a subsurface infiltration system and
subsequently to the existing stormwater basins currently managing stormwater runoff from the
college campus and incorporated in the college master plan. HW has provided a second letter,
dated October 28, 2024, updated though November 15, 2024, regarding extending the 2001
Order of Conditions for the existing stormwater basins (DEP File No. 090-0750). A portion of the
runoff from the Lecture Hall site is directed to a water quality unit prior to entering the
subsurface infiltration system.
The following additional documents and plans were received by HW for review in response to
our November 7, 2024, review letters:
• Letter to Andover Conservation Commission, Response to Comments— Second Peer
Review, Merrimack College Lecture Hall, prepared by VHB, dated November 13, 2024
(5 pages);
• Letter to Andover Conservation Commission, Response to Comments— Second Peer
Review, Extension of Order of Conditions, prepared by VHB, dated November 13, 2024
(3 pages);
• Stormwater Management System Operations and Maintenance Manual, Lecture Hall at
Merrimack College, prepared by VHB, Inc., Revised November 13, 2024 (57 pages); and
Andover Conservation Commission
November 15, 2024
Page 2of6
• Stormwater Management Report, Lecture Hall at Merrimack College prepared by VHB,
Inc., dated September 12, 2024, revised November 13, 2024 (264 pages).
Stormwater Review
HW has reviewed the documents listed above and has the following comments concerning the
stormwater management design in accordance with the Massachusetts Stormwater Handbook
(MSH) dated February 2008, and the Town of Andover Stormwater Management and Erosion
Control Bylaw and Regulations dated February 10, 2009 (Stormwater Bylaw).
In accordance with Article 195-8.14 information required with a Site Plan Review application
includes a Stormwater Management Plan. The Stormwater Management Plan has been
submitted for review and comments have been addressed in a separate letter. We have used
the Massachusetts Stormwater Standards as the basis for organizing our comments. However,
in instances where the additional criteria established in §250-23 of the North Andover Code
requires further recommendations; we have referenced these as well.
The following comments correlate with our second peer review letter dated November 7, 2024.
Follow up comments are provided in bold underlined font where applicable.
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 at design
point DP-1 A-1 A. DP-1 A-1 A is located in Parking Lot B, adjacent to the project area.
Under existing conditions, the parking lot sheet flows into the existing stormwater
drainage system for Merrimack College. Under proposed conditions, impervious cover
will increase from 3,150 sf to a total of 21,350 sf, accounting for roof cover and paved
areas. Runoff from the majority of impervious cover is directed to either a water quality
unit and then a subsurface infiltration system or to the subsurface infiltration system
directly. Based on Figure 4 of the Stormwater Report, runoff from proposed concrete
sidewalk will sheet flow to the Parking Lot B Drainage System. No further action
requested.
November 7, 2024: No action is 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 Pre-Development and Post-Development Drainage Plans and the
HydroCAD model. The subcatchment areas, surface materials, curve numbers, times of
concentrations, depths of precipitations, and flow patterns appear reasonable.
November 7, 2024: In the Merrimack College Detention Basin Flow Monitoring
Letter, the 2-year rainfall depth used (3.4 inches) is larger than the design depth
used in the Lecture Hall project's stormwater analysis (3.17 inches). HW notes that
the Applicant appears to have used higher values in the original Merrimack
College Stormwater Management Plan and prior design projects. HW recommends
the Applicant use consistent methodology for all proposed projects within the
College campus, including the Lecture Hall Design.
. f III � . � � � II �. lii� � ��� � I .
� � � II� ��� � IIL...... III
..........
III III............e U III&........ i ck,C III IIIege .
Andover Conservation Commission
November 15, 2024
Page 3of6
November 15, 2024: The Applicant has revised the HydroCAD model to use the
higher of the rainfall precipitation data between the Original 1999 Stormwater Plan
and the current NOAA Atlas 14 for the project site. No further action is requested.
b. The Applicant has conducted four soil borings within the parcel for the Lecture Hall. The
borings are comparable primarily indicating glacial till, with groundwater only observed in
the deepest boring at 16 feet below ground surface. The Applicant has used an
exfiltration rate of 0.52 inches per hour (iph) for the subsurface infiltration system. HW
recommends that prior to construction the Applicant conducts additional soil testing
within the footprint of the subsurface infiltration system to confirm the infiltration rate and
depth to seasonal high ground water is appropriate.
November 7, 2024: The Applicant agreed to conduct additional soil testing within
the footprint of the subsurface infiltration system. HW recommends that the
Applicant provide the soil testing data to the Conservation Commission prior to
significant land disturbance to support the infiltration rate and estimated seasonal
high groundwater (ESHGW) values used in the design.
November 15, 2024: The Applicant conducted an additional test pit within the
footprint of the proposed stormwater system. The test pit confirmed the
assumptions previously made and no changes to the stormwater practice is
needed. The Applicant has updated the HydroCAD model to reflect the information
gathered. No further action is requested.
3. Standard 3 requires that the annual recharge from post-development shall approximate
annual recharge from pre-development conditions.
a. VHB performed a Frimpter adjustment to determine the estimated seasonal high
groundwater table (ESHGWT) based on conditions found at soil test pit TB-4. HW
recommends conducting additional soil testing within the footprint of the subsurface
infiltration system prior to construction. HW further recommends that the Applicant
provides documentation to the Andover Conservation Commission confirming that the
design as presented is appropriate or provides a modified design as necessary.
November 7, 2024: As stated above, HW recommends that the Applicant provide
the additional soil testing data to the Conservation Commission prior to
significant land disturbance.
November 15, 2024: The Applicant conducted an additional test pit within the
footprint of the proposed stormwater system. The test pit confirmed the
assumptions previously made and no changes to the stormwater practice is
needed. The Applicant has updated the HydroCAD model to reflect the information
gathered. No further action is requested.
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 the Water Quality Unit has a
TSS Removal Rate of 50%. The Applicant shows a CDS hydrodynamic separator as the
water quality unit in the Site Details, Sheet 8 of 8. HW recommends that the Applicant
justify the use of the 50% TSS Removal Rate and provide documentation from a third-
party reviewer supporting the listed TSS removal rate.
��u
� . �� . � � . u
� II . IIo I I I 1 1 III IL...... . II. � �I i II� � �� � 1 � II
..........
III III............eGkHI&lh...... i ck,C III IIege
Andover Conservation Commission
November 15, 2024
Page 4 of 6
November 7, 2024: The Applicant has provided a "CDS Estimated Net Annual
Solids Reduction" Sheet in Appendix D of the Stormwater Management Report,
revised October 30, 2024. Based on the calculations, the water quality unit
provides approximately 90% efficiency. The Applicant has used a TSS Removal
Rate of 50% in the TSS Removal Calculation Worksheet to be conservative. HW
recommends that the Applicant provide documentation from a third party peer
reviewer of the CDS Hydrodynamic separator that indicates that the TSS removal
rating for the proprietary product is greater than 50%.
November 15, 2024: The Applicant has provided documentation from NJCAT
referencing the proposed Contech product. The documentation indicates that the
TSS removal rating for the proprietary product is greater than 50%. No further
action is requested.
b. Per §250-23 B new development sites are required to retain the volume of runoff
equivalent to, or greater than 1.0 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. The Applicant has provided calculations documenting
that the system can provide water quality for 0.5 inches of runoff. HW has confirmed that
the system is adequately sized to retain the 1.0 inch of runoff. However, we recommend
that the Applicant revise the calculations for documentation purposes, confirming it
complies with the local regulations.
November 7, 2024: The Applicant has updated the Stormwater Management
Report to reflect the required water quality runoff depth as required by local
regulations. No further action is requested.
5. Standard 5 is related to projects with a Land Use of Higher Potential Pollutant Loads
(LUHPPL).
a. The proposed use is not considered a LUHPPL, therefore Standard 5 is not applicable.
No further action requested.
November 7, 2024: No further action is 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, Therefore Standard 6 is not applicable. No further action requested.
November 7, 2024: No further action is requested.
7. Standard 7 is related to projects considered Redevelopment.
a. The project at 315 Turnpike Street is considered new development, and therefore,
Standard 7 is not applicable. No further action requested.
November 7, 2024: No further action is requested.
8. Standard 8 requires a plan to control construction related impacts including erosion,
sedimentation, or other pollutant sources.
a. The proposed project will be disturbing greater than one acre of land. A SWPPP is
required by EPA for land disturbance of greater than 1 acre. The Applicant has provided
recommended erosion controls to be included in a SWPPP in Appendix E of the
Stormwater Report. The SWPPP should include source control and pollution prevention
.Vll.,l "...
V.. ii� i � s 2 0 I � � � iii IL...... iir
..........
III lii III Gk ilial.......11l III III III iii iii.� :;m�' Co� III ge( :'
Andover Conservation Commission
November 15, 2024
Page 5 of 6
measures, stormwater practices to address erosion and sedimentation, stabilization
measures, and procedures for operating and maintaining the proposed stormwater
practices. The plan should also identify the parties responsible for implementing the
plan. HW recommends that the Conservation Commission require receipt of a final
signed SWPPP a minimum of 14 days prior to land disturbance.
November 7, 2024: HW acknowledges that the Applicant intends to provide the
finalized SWPPP to the Conservation Commission and the Planning Board at least
14 days prior to land disturbance. The two boards may choose to require receipt
of the SWPPP as a condition of approval.
November 15, 2024: Suggested Special Condition.
b. The Applicant has provided a Site Preparation and Erosion Control Plan, Sheet 2 of 8,
that includes silt socks at the back of curb openings along Aherne Road. HW
recommends that the Applicant include an additional silt sock at the curb opening across
from the construction exit.
November 7, 2024: The Applicant updated the Site Preparation and Erosion
Control Plan (Sheet C2.0) to include an additional silt sock at the curb opening
across from the construction exit. No further action is requested.
9. Standard 9 requires a Long-Term Operation and Maintenance (O & M) Plan to be provided.
a. In the Stormwater Management Report, under Standards 4 and 9, the Applicant has
noted that a Long-Term O&M Plan is included under a separate cover as part of the
O&M Plan. HW did not receive the Operation & Maintenance Plan for review. We
recommend that the Applicant provide a complete O&M Plan to the Conservation
Commission that includes the entire campus if feasible. The O&M Plan should include
the responsible parties, descriptions of the various stormwater practices, clear
descriptions on how they should be maintained and the frequency of inspections. A
simple schedule, with a simple sketch to illustrate where the practices are located on the
site and a budget, so that the property owner understands what to expect.
November 7, 2024: The Applicant has provided an O&M Plan for the Lecture Hall
project and has included responsible parties and maintenance logs within the
plan. HW recommends that the Applicant provides a description and delineation
of public safety features and an estimated operations and maintenance budget.
The Commission may choose to request maintenance log records annually as a
condition of approval. In the Response to Comments Letter, the Applicant stated
the intent to prepare and provide a campus-wide O&M Plan as part of the Order of
Conditions Peer Review.
November 15, 2024: The Applicant has updated the O&M Plan as suggested. The
Applicant has stated the intent to prepare and provide a campus-wide O&M Plan
as part of the Order of Conditions Peer Review.
10. Standard 10 requires an Illicit Discharge Compliance Statement be provided.
a. The Applicant has provided a signed Illicit Discharge Compliance Statement in Appendix
F of the Stormwater Report. No further action requested.
November 7, 2024: No further action is requested.
� . i '.... i . V � � I �� ����µ� � � iii II'....... . i�� � �.� �I... i� � i � �� III
..........
kHi&lh.......11l III IIL.........III iii iii�iii i ..,mk C III III e(� ..
Andover Conservation Commission
November 15, 2024
Page 6of6
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.
It
q�^w,
Janet Carter Bernardo, P.E.
Principal
CC: Jean Enright— North Andover Planning Board
m
m
.. ���� ���� ����..� ��iii� �.. iii�IIL...... .�.iii�Ilh�. iii� � ��� �. �III �.III .�,iii���Iliµ iu,.��:��III� � III III. III �. ..iii ��� �� � � iii��IIL...... iii�
.� �� III ..........
III III............edLHi&lh......11l �III III III ��iii��������iii����i „..,mk�,C III IIege