HomeMy WebLinkAbout2026/07/28 - 3rd Stormwater Peer Review - 492 Sutton Street Horsley W*itten Grou
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112 t r Street,® 'Floor Boston,MA 02109
July 28, 2026
Ms. Jean Enright, Planning Director
Planning Department
Town of North Andover
120 Main Street
North Andover, Massachusetts 01845
Re: Third 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 third 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 additional documents and plans were received by HW in response to our second
peer review letter dated July 24, 2026:
• Letter to Planning Department, regarding Response to Second Peer Review Comments,
prepared by McClure Engineering Company, dated July 28, 2026 (8 pages).
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.
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Town of North Andover
July 28, 2026
Page 2 of 10
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.
The following comments correlate with our second peer review letter dated July 24, 2026.
Follow-up comments are provided in bold underlined font as needed.
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.
July 24, 2026: No further action is requested.
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.
July 24, 2026: No further action is requested.
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.
July 24, 2026: No further action is requested.
Town of North Andover
July 28, 2026
Page 3 of 10
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.
July 24, 2026: The Applicant has revised the total proposed land
disturbance area to be 59,300 sf. No further action is requested.
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.
July 24, 2026: The Applicant has updated the Pre-Development Drainage Map
and the associated calculations as suggested. HW has reviewed the revised Tc
path and calculation and finds it to be reasonable. No further action is
requested.
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.
July 24, 2026: No further action is requested.
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.
July 24, 2026: The Applicant has updated the calculations associated with the
revised Tc flow path and the calculation error previously highlighted has been
corrected. The 2-year peak flow towards DP-1 experiences a minimal increase
(0.03 cubic feet per second). The overall peak flow to the north is decreasing.
No further action is requested.
Town of North Andover
July 28, 2026
Page 4 of 10
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.
July 24, 2026: The Applicant has updated the calculations associated with the
revised Tc flow path and the calculation error previously highlighted has been
corrected. The 100-year proposed volume in the HydroCAD model appears to
be 1.716 af. However, in the table, the proposed volume is listed as 1.713 af.
HW recommends that the Applicant review the runoff volume results and
correct if necessary. HW notes that the total increase volume during a 100-year
storm event to the catch basin listed as DP-1 is 0.015 of(653 cf). The total
volume directed towards the north is reduced by 0.041 of(1,786 cf). It is HW's
opinion that the minor increase in volume to the existing catch basin is
insignificant.
July 28, 2026: The Applicant has provided the updated table. No further action
is requested.
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.
July 24, 2026: The Applicant has updated the plans to show the pipe between
AD-3 and EX-4. No further action is requested.
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.
July 24, 2026: The Applicant has added a note on Drawing C509 stating that all
fill material below the Detention Area or Stormwater Basin will be removed to
the depth of native soils and replaced with clean borrow material. No further
action is requested.
Town of North Andover
July 28, 2026
Page 5 of 10
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.
July 24, 2026: The Applicant has provided impervious areas for the
Stormwater Basin and the Vegetated Detention Areas. HW has been able to
confirm the impervious areas for the recharge calculations. No further
action is requested.
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.
July 24, 2026: The Applicant has provided the stage storage calculations to
verify the volume available within the basins below the overflows. No
further action is requested.
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.
July 24, 2026: The Applicant has provided the requested mounding
analyses for the detention areas and the background information for the
Hantush spreadsheet. In the Mounding Analysis Supporting
Documentation, the Half Length is (y) and the Half Width is (x). However, in
the Mounding Analysis calculations, the Half Length is (x) and the Half
Width is (y). Additionally, sometimes the Supporting Documentation Half
Width is listed as the Half Length within the calculations, and the Half
Town of North Andover
July 28, 2026
Page 6 of 10
Length is used in the place of the Half Width. HW recommends that the
Applicant clarify which values represent the Half Length and which values
represent the Half Width.
July 28, 2026: The Applicant has revised the mounding calculations
adjusting the x and y inputs appropriately. As presented groundwater
should not rise up into the infiltration systems. No further action is
requested.
d. HW recommends that the Applicant add the location of test boring B-4 to
Drawings EX-1 and C105.
July 24, 2026: The Applicant prefers not to alter the EX-1 survey file, as it is
a stamped survey that was provided to the Owner prior to this phase of the
project. The boring information has been added to Sheet C-105. No further
action is requested.
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.
July 24, 2026: The Applicant has revised the draw down calculations. HW
has reviewed the revised calculations and finds them acceptable. No
further action is requested.
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.
July 24, 2026: The Applicant has included the recharge volume from the
Stormwater Basin as part of the total provided recharge. 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 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.
Town of North Andover
July 28, 2026
Page 7 of 10
July 24, 2026: The Applicant has provided third-party documentation for
the TSS removal of the Rain Guardian in Appendix L. No further action is
requested.
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.
July 24, 2026: No further action is requested.
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.
July 24, 2026: 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.
July 24, 2026: The Applicant has provided Total Phosphorous Reduction
Calculations and has provided sources on the percent cumulative
phosphorous load reduction. HW finds the cumulative phosphorous load
reduction for all values reasonable. 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 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.
July 24, 2026: The Applicant has provided an analysis estimating the
number of vehicle trips per day. A conservative estimate of 640 trips per
day has been provided. No further action is requested.
Town of North Andover
July 28, 2026
Page 8 of 10
6. Standard 6 is related to projects with stormwater discharging into a critical area, a Zone
H. 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.
July 24, 2026: 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.
July 24, 2026: 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, 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.
July 24, 2026: The Planning Board may choose to require receipt of 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.
July 24, 2026: The Applicant has revised Sheet C107 to provide a stockpile
surrounded by erosion controls. No further action is requested.
Town of North Andover
July 28, 2026
Page 9 of 10
c. HW recommends that the Applicant includes inlet protection on catch basins
within 100 feet of the construction entrance.
July 24, 2026: The Applicant has added a note to Sheet C107 to provide
inlet protection on catch basins within 100 feet of the construction
entrance. No further action is requested.
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.
July 24, 2026: The Applicant has delineated the limits of work around the
proposed stormwater basin, including the Contractor Staging Area. HW
finds the delineated limit of work reasonable.
e. HW recommends that the Applicant clearly illustrate on Drawing C102 the
emergency access route that must remain accessible throughout construction.
July 24, 2026: The Applicant has illustrated the emergency access route on
Sheet C102. The Planning Board may choose to confirm with the Fire
Department that the route is acceptable.
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.
July 24, 2026: 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.
July 24, 2026: The Planning Board may choose to require receipt of an Illicit
Discharge Statement signed by the property owner as a Condition of
Approval.
Town of North Andover
July 28, 2026
Page 10 of 10
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.
July 24, 2026: The Applicant has clarified in the plans that relief is requested from
Section 195-8, Part 1 of the North Andover Bylaw. No further action is requested.
Conclusions
HW is satisfied that the Applicant has adequately addressed our 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(c-D-horsleywitten.com if you have any questions regarding these
comments.
Sincerely,
HORSLEY WITTEN GROUP, INC.
Janet Carter Bernardo, PE Ariel Shramko, EIT
Principal Staff Engineer