HomeMy WebLinkAbout2026/07/06 - 1st Stormwater Peer Review - 492 Sutton Street Horsley W*itten Grou
Sustainable
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112 t r Street,® 'Floor Boston,MA 02109
July 6, 2026
Ms. Jean Enright, Planning Director
Planning Department
Town of North Andover
120 Main Street
North Andover, Massachusetts 01845
Re: Initial Stormwater Peer Review
492 Sutton Street
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 report summarizing our initial review of the Watershed Special Permit Application for
the proposed improvements at 492 Sutton Street in North Andover, MA. The plans were
prepared by McClure Engineering Company on behalf of the Lawrence Municipal Airport
(Applicant). The Applicant has noted that the Lawrence Municipal Airport property contains over
400 acres of land. The project proposes the construction of a new 7,069 square foot (sf)
administration building and the reconfiguring of the parking lot, as well as utility, stormwater, and
landscaping improvements. The stormwater improvements include the addition of a stormwater
infiltration basin, two vegetated detention ponds, and one manufactured cartridge filtration unit.
It appears that the proposed actions will increase the total impervious area on the site by
approximately 7,360 sf. The total land disturbance is somewhere between 49,300 sf and 53,500
sf. Based on the Resource Area Map in the Stormwater Management Report, there are no
wetland resource areas or buffer zones within 100 feet of the project area.
The following documents and plans were reviewed by HW:
• Stormwater Management Report, 492 Sutton Street, North Andover, MA, prepared by
McClure Engineering Company, dated June 16, 2026 (202 pages);
• Memorandum for Site Plan Review Special Permit, 492 Sutton Street, North Andover, MA,
prepared by McClure Engineering Company, dated June 16, 2026 (8 pages);
• Long Term Operation and Maintenance Plan, Lawrence Municipal Airport—Administration
Building, 492 Sutton Street, North Andover, MA, prepared by McClure Engineering
Company, dated June 16, 2026 (33 pages);
• Special Permit—Site Plan Review Application, 492 Sutton Street, North Andover, MA,
prepared by the City of Lawrence Municipal Airport Commission, dated June 17, 2026 (2
pages); and
Town of North Andover
July 6, 2026
Page 2of8
• Lawrence Airport Administration Building Permit Plans, 492 Sutton Street, North Andover,
MA, prepared by McClure Engineering Company, dated June 15, 2026:
o Cover Sheet C000
o Legend &Abbreviations C001
o Civil Notes C002
o Existing Conditions Plan EX-1 (CO03)
o Construction Phasing Plan C004
o Demolition Plan C101
o Overall Site Plan C102
o Site Plan C103
o Site Layout Plan C104
o Grading & Drainage Plan C105
o Utility Plan C106
o Erosion & Sedimentation Control Plan C107
o Signage & Pavement Markings Plan C108
o Landscape Plan C109
o Civil Details C501 — C509
o Vehicle Turning Movement Plan C601
o Architectural First Floor Plan A100
o Architectural Building Elevations A201
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 Chapter 250
Stormwater Management and Erosion Control regulations (Stormwater Regulations) adopted
June 21, 2022.
In accordance with §195-8.14.E.(8) All applications for site plan review shall include the
submittal of a stormwater management plan prepared in accordance with the latest version of
the Massachusetts Stormwater Handbook and additional criteria established herein and
demonstrating full compliance with the Massachusetts Stormwater Standards and the North
Andover Stormwater Management and Erosion Control Regulations promulgated under Chapter
165 of the Town Bylaws (Stormwater Management and Erosion Control Bylaw). 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.
Town of North Andover
July 6, 2026
Page 3of8
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 evaluated the pre-development site at two Design Points (DP).
i. DP-1 is an existing catch basin located on the northeast side of the
existing Administration Building. Within the existing parking lot there are
several catch basins that pipe the stormwater that falls within the project
area to DP-1.
ii. DP-2 is the remaining project area that is not piped to DP-1 but flows
offsite to the north towards the airfield. Stormwater from half of the
existing administration building flows towards DP-2.
b. The Applicant has evaluated the post-development site at the same two design
points. Additional catch basins and stormwater practices have been incorporated
to manage the stormwater from the reconfigured parking lot and the proposed
roof runoff prior to being piped to DP-1. The total area and the impervious cover
that overflows offsite towards DP-2 has been reduced under proposed
conditions.
c. The Applicant is not proposing any new untreated conveyance systems that
outfall into a wetland. It appears that the Applicant has complied with Standard 1.
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. Within Section 3 of the Stormwater Management Report, the Applicant states
that the total proposed land disturbance area is approximately 49,300 sf.
However, the Limit of Work on the Permit Plans appears to be closer to 53,500
sf. HW recommends that the Applicant confirm the total anticipated land
disturbance for documentation purposes.
b. The Applicant has submitted a Pre-Development Drainage Map. EX-2 shows a
time of concentration (Tc)flow path that passes through an area with an existing
silt fence. HW recommends that the Applicant revisit the Tc flow path for EX-2.
HW has reviewed the other Tc values and has no other comment.
c. HW has reviewed the Applicants HydroCAD model, including the routing
diagram, surface areas, curve numbers (CN), and precipitation depths and found
the values to be reasonable. No further action is required.
Town of North Andover
July 6, 2026
Page 4 of 8
d. In Section 2.4 of the Stormwater Management Report, the Applicant has
provided summary tables illustrating that the Proposed Design Storm Peak Flows
are less than the Existing Peak Flows. HW agrees that the peak flows are
reduced under proposed conditions for the 2-, 10-, and 25-year events. During
the 100-year event the peak flow to DP-1 increases slightly. However, the overall
reduction flowing north has been reduced. The Applicant has included a Net
Change column with the Table in Section 2.4. HW agrees that the Applicant has
reduced the peak flows but does not agree that the total percentage net change
is listed correctly.
e. The Applicant has provided tables showing that the Proposed Design Storm
Volumes are reduced compared to the Existing Design Storm Volumes. There is
a minimal increase of volume during the 100-year storm event to DP-1. However,
the total reduction from the project area is reduced over existing conditions. Like
the peak flows, HW agrees that the Applicant has reduced the peak volumes, but
we do not agree that the total percentage net change is listed correctly in Section
2.5 of the Stormwater Management Report.
f. The Applicant has proposed Area Drain AD-3 in Vegetated Detention Area 02
(VDA-02). It does not appear that the outfall pipe is shown on the plan view
indicating which structure the outfall pipe is directed to. HW recommends that the
Applicant includes the pipe from AD-3 to the existing catch basin EX-4 on
Drawing C105.
g. HW notes that the borings provided in the Stormwater Management Report
indicate several feet of fill was observed beneath the proposed stormwater
basins. HW recommends that the Applicant includes a note on Drawing C509
stating that all fill material below the Stormwater Basin or below the Vegetated
Detention Areas will be removed and replaced with clean fill meeting the design
criteria.
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 calculations in Appendix G of the
Stormwater Management Report. HW could not confirm the impervious area
listed for the Stormwater Basin or Vegetated Detention Area 01. The values
listed in Appendix G are not consistent with the HydroCAD model. HW
recommends that the Applicant confirm the impervious area directed towards
each of the stormwater basins. It is HW's opinion that the water surface is not
considered impervious for the recharge or water quality calculations. However,
using a CN of 98 for the water in the HydroCAD model is reasonable.
Town of North Andover
July 6, 2026
Page 5 of 8
b. The Applicant has provided recharge calculations. However, no stage storage
calculations have been provided to verify the volume available within the basins
below the overflows. HW recommends that the Applicant provides the stage
storage HydroCAD print out.
c. The Applicant has included the test boring logs for the borings conducted within
the footprints of the stormwater basins. It appears that the Applicant has provided
more than 2 feet but less than 4 feet of separation between the bottom of the
Basins and the estimated seasonal high groundwater (ESHGW) elevations.
Mounding analyses are required in compliance with Volume 3, Chapter 1, page
28 of the MSH. HW notes that the Applicant has included one mounding analysis
in Appendix K of the Stormwater Management Report. However, there are three
infiltration practices that should be evaluated. Furthermore, HW recommends
that the Applicant includes documentation for the various inputs used in the
Hantush spreadsheet.
d. HW recommends that the Applicant add the location of test boring B-4 to
Drawings EX-1 and C105.
e. The Applicant has provided draw down calculations. However, the volume
utilized in the calculation should be the volume stored below the outfall and not
the required recharge volume. HW recommends that the Applicant revised the
calculations in accordance with Volume 3, Chapter 1, page 26 of the MSH. HW
notes that the Applicant has included a calculation utilizing the provided recharge
volume. However, the volume listed for the Stormwater Basin is not consistent
with the volume listed under the recharge calculations provided previously.
f. HW appreciates that the Applicant has not included the recharge volume from
the Stormwater Basin in the total provided recharge. However, it is HW's opinion
that this volume can be included for total recharge.
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 third party documentation for the TSS removal for the
Contech Jellyfish Filter. HW notes that the Applicant has used a Rain Guardian
as pretreatment for the Vegetated Detention Areas. HW agrees that the Rain
Guardian does provide pretreatment. However, we recommend that the Applicant
provide the third-party documentation to be included in the project file.
b. The Applicant has provided the TSS removal calculations for the various
treatment trains prior to the stormwater reaching the existing catch basin at DP-1.
HW agrees that including the Jellyfish structure provides a minimum of 80% TSS
removal for the proposed development.
Town of North Andover
July 6, 2026
Page 6of8
c. The Applicant has provided water quality calculations to document whether the
proposed development is retaining 0.5 inches of runoff over the impervious area.
The Applicant has included the two Vegetated Detention Areas to calculate the
water quality volume. The Stormwater Basin has additional volume. However, it
is managing very little impervious area, so the Applicant has not included the
Stormwater Basin in its total water quality volume. HW agrees that the volume
retained in the Stormwater Basin should not be included in the water quality
volume calculation. The Jellyfish is providing additional means to improve water
quality for this redevelopment. No further action is requested.
d. The Applicant has included Total Phosphorous Reduction Calculations. It is not
clear how the SCM Load was calculated. HW recommends that the Applicant
document how the SCM Load (P) values provided were determined.
5. Standard 5 is related to projects with a Land Use of Higher Potential Pollutant Loads
(LUHPPL).
a. The proposed administration building with a 45-space parking lot is not
considered a LUHPPL assuming the site will not generate more than 1,000
vehicle trips per day. HW does not believe that Standard 5 is applicable.
However, we recommend that the Applicant confirm that the anticipated vehicle
trips per day are less than 1,000.
6. Standard 6 is related to projects with stormwater discharging into a critical area, a Zone
ll, 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 is
requested.
7. Standard 7 is related to projects considered Redevelopment.
a. The Applicant is increasing the impervious area by approximately 7,400 sf. The
proposed project is a mix of new and redevelopment. The Applicant is required to
comply with the Stormwater Management Standards for the new development
and is allowed to comply to the maximum extent practicable for the previously
developed portions of the site. The Applicant is also required to improve existing
conditions. On page 11 of the Stormwater Report the Applicant has outlined how
it is improving existing conditions. HW agrees that the proposed stormwater
improvements and Long-Term Operation & Maintenance Plan are an
improvement. No further action is requested.
Town of North Andover
July 6, 2026
Page 7of8
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, therefore
the Applicant is required to obtain a Construction General Permit and prepare a
Stormwater Pollution Prevention Plan (SWPPP) in accordance with the EPA
NPDES Program. The SWPPP should include source control and pollution
prevention measures, stormwater practices to address erosion and
sedimentation, stabilization measures, and procedures for operating and
maintaining the proposed stormwater practices during construction. The plan
should also identify the parties responsible for implementing the plan. The
Planning Board may choose to require a signed SWPPP a minimum of 14 days
prior to land disturbance as a Condition of Approval.
b. HW recommends that the Applicant include a stockpile location and confirm it is
surrounded by erosion controls.
c. HW recommends that the Applicant includes inlet protection on catch basins
within 100 feet of the construction entrance.
d. HW notes that on Drawings C102 and C107, the limits of work around the
proposed stormwater basin should include the Contractor Staging Area shown on
Drawing C004.
e. HW recommends that the Applicant clearly illustrate on Drawing C102 the
emergency access route that must remain accessible throughout construction.
9. Standard 9 requires a Long-Term Operation and Maintenance (O & M) Plan to be
provided.
a. The Applicant has provided a stand-alone Long-Term O&M Plan. The O&M Plan
includes a description of each stormwater practice with an inspection log, the
manufacture's guidelines for the proprietary structures, an estimated budget, and
a simple sketch illustrating where each of the stormwater practices is located
within the project area. The Planning Board may choose to require receipt of a
Long-Term Operation and Maintenance Plan signed by the property owner as a
Condition of Approval.
10. Standard 10 requires an Illicit Discharge Compliance Statement be provided.
a. The Applicant has provided an unsigned Illicit Discharge Statement. The
Planning Board may choose to require receipt of an Illicit Discharge Statement
signed by the property owner as a Condition of Approval.
11. Within the Permit Plans in the Overall Site Plan, the Applicant states "Relief is requested
from Section »»> of the North Andover Bylaw." HW recommends clarifying which
section of the North Andover Bylaw relief is requested from.
Town of North Andover
July 6, 2026
Page 8of8
Conclusions
HW recommends that the Planning Board requires the Applicant to provide a written response
to address these comments. The Applicant is advised that provision of these comments does
not relieve him/her of the responsibility to comply with all Town of North Andover Codes and By-
Laws, Commonwealth of Massachusetts laws, and federal regulations as applicable to this
project. We appreciate the opportunity to assist the Town of North Andover with this project
review. Please contact Janet Bernardo at 508-833-6600 or at ibernardo(cD-horsleywitten.com if
you have any questions regarding these comments.
Sincerely,
HORSLEY WITTEN GROUP, INC.
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Janet Carter Bernardo, PE Ariel Shramko, EIT
Principal Staff Engineer