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HomeMy WebLinkAboutNOI Package 1 PROJECT NARRATIVE OUTBOARD RIGGING BUILDING RECONSTRUCTION SHIP SHOPS, INC. 0 SAILING VILLAGE WAY, SO. YARMOUTH, MA THE SITE - The area subject to this Notice is land on the west shore of Bass River in So. Yarmouth. Ship Shops is a full service, small boat marina in existence since the early 1950’s. The surrounding terrain comprises the complex of existing buildings, paved drive / parking areas, crushed stone boat storage areas. Along the immediate shore are the pile-supported piers, marine bulkhead, ramps and floats comprising the berthing slips. The immediate zone of the project is the gently sloping site of an existing wood framed building used for outboard motor boat rigging. COASTAL WETLAND RESOURCES - The nearby coastal resource complex consists of Land under the Ocean, Land Containing Shellfish, Coastal Bank and Land Subject to Coastal Storm Flow. The site is within the Riverfront Area associated with Bass River, a tidal river. Please see the plan for the location of pertinent resource area boundaries. Utility lines are underground. Drive areas are both paved with bituminous pavement and of an earth, gravel, shell texture. Runoff is largely intercepted by catch basin inlets with broad infiltration beds and a variable width crushed stone apron along the upland side of the landward edge of the marine bulkhead THE PROJECT - The proposed project involves controlled demolition of the existing wood framed work shop building and construction of a replacement, building effectively in the same site location with a 2.8 ft. length increase and 1.8 ft. width increase for a 192 s.f. area increase. The reconstruction maintains the site function, general layout, surfacing as existing. No significant changes are proposed to the site except for the replacement of the building and rehabilitation of associated services relating to the buildings, e.g. electric utility reconnections. The shallow foundation excavation shall be formed as the material is excavated and inspected for strength and compacted to accommodate the new foundation. The drainage patterns of the site will not change. Any incidental pavement or crushed stone areas damaged or altered shall be restored in kind with current conditions. As a functional drainage mitigation component, stone- filled drainage infiltration trenches, approximately 2 ft. wide, 2 ft. deep shall be installed to the lengths shown beneath the two building eave drip edges. Gutters and downspouts can be employed transmit the runoff volume to the infiltration trenches. The flood zone location, dynamic sediment behavior are both disadvantageous factors affecting formalized surface drainage facilities. Infiltration for the larger roof component is the optimal choice to preserve long term drainage function and to protect surface water quality. After the initial building exterior construction, an interior work phase will follow to prepare the building for the shop function. Existing utility services shall be re-connected from existing sources. Debris material control disposal - In addition to the demolition volume expected to be completely removed from the site prior to new construction, a suitably-sized roll-off dumpster container shall be kept at the immediate construction site for regular pickup and disposal of day- 2 to-day construction-related refuse. Upon completion of the work, the existing drive areas shall be established to a functional condition and returned to the pre-construction extent and layout. Utilities - Underground utilities shall be located, marked with markings maintained. Utility and facility service cables and pipes shall be properly terminated in a manner that permits re- connection. Site Controls -Work activity limits shall be established with the primary interest of confining workers, vehicles and equipment from locations near the lower zone of the site nearer to the marine bulkhead. Establishing these limits with a weighted straw wattle system with extra wattles on site is an adequate means of restricting activity. The soil of the project area consists of very clean, medium to coarse sands to a depth exceeding the excavation depth. Relevant Performance Standards - Wetland Act / Yarmouth Wetland By-Law • Storm damage and Flood Control - The facility restoration has only positive impacts to the wetland interest of Storm damage prevention and Flood Control because the work makes improvements to flood proofing the buildings and related facilities. • Prevention of Pollution - As with the above, the building improvements foster a structure that will withstand flood forces therefore containing any incidental materials or wreckage that might result from building damage. • Protection of shell fisheries and finfish and wildlife habitat - The proposed site and building improvements will occur within an area already completely developed with no outward expansion of developed land area. The outer lying land areas of the River and nearby coastal wetland resource areas with habitat value will be physically unaffected. However, benefits accrue to these areas due to the threat reduction resulting form the building and facility improvements as reasoned in the two above - mentioned interests. • Riverfront Area - The project is a 'redevelopment project' as defined under 310 CMR 10.58.(5). The predominant building portion is proposed in the same location are within the outer RA. 192 s.f. of expanded building area is proposed. This footprint change occurs in an area already used as a crushed stone storage use surface. In effect therefore, no net change occurs to the degraded areas within the RA. Temporary activities associated with construction will occur within the outer riparian zone such as vehicle deliveries, construction staging, repair of the work area at completion of the work. These activities will be confined and controlled by the work activity limits with complete return to pre-construction condition. Improved drainage catchment for the replacement building will reduce storm water runoff volume released to the outer and inner riparian zone compared with existing conditions thus reducing the collateral effects that such runoff may have on riverine water quality and related interests. The applicant’s intent is to maintain the site function and flow as it exists today but enhanced protection for resource area as described. Alternatives – Alternatives discussed are commensurate with the defined scope of the proposed project. • In the interest of respecting the provisions of 310 CMR 10.58 (4) we suggest that the alternatives analysis can be commensurate with the scope of the Riverfront portion of the project which is very small and limited to the replacement of a shop building with a similar-sized, modernized shop building. The goal of the renovation is to maintain the site function or the project becomes an unwieldy exercise in choosing a slightly different building position with the objective of removing it from the RA or selecting a different 3 location within the R.A. An evaluation of such options demonstrates the creation of a greater scope of work and more significant alterations. • Selecting a building the same footprint was obviously feasible to do but offset the project purpose as defined by the applicant. Use of the existing building over its useful life of approx. 74 years revealed a need for design improvements relating to changes to equipment, modern boat sizes and related products. The 192 s.f. proposed increase appears to meet the performance standards relating to pre- and post-construction degraded area and falls below the proportional limitations contained in the regulations. Yarmouth Wetland By-Law – The primary departure from the Mass Wetland Regulations relates to Flood Zone activities – Paraphrased and reviewed as follows: A project shall not have an adverse impact upon : • reducing the ability of the land to absorb and contain flood waters; The building shall meet the flood code provisions and is in the same location as the existing. • reducing the ability of the land to buffer more inland areas from flooding and wave damage; Should flood waters encounter the building within the AE zone the flow energy is not sufficient to cause for collateral damage to adjoining inland areas which are not within the AE zone. • increasing the elevation or velocity of flood waters, or by redirecting or increasing flows or causing channelization, in each case at the project site, adjacent or nearby properties, or any public or private way. • displacing or diverting flood waters to other properties or resource areas. Fences and privacy walls, including walls separating one property from another, may obstruct or divert flood flow and waves toward buildings and protected areas. No fences exist or are proposed so we omit that section. Flood waters will not be significantly diverted to an extent to cause damage in the AE zone • causing ground, surface or saltate pollution triggered by coastal storm flowage; The building is an improved enclosure with appropriate storage of materials. Ship Shops long term presence in the flood zone, hazardous material management contracts appropriately ensures against saltate pollution resulting from flooding. • reducing the ability of the resource to serve as a wildlife habitat and migration corridor through activities such as, but not limited to the removal of substantial vegetative cover and/or installation of fencing and other structures which prevent wildlife migration across property. Several disadvantaged oaks must be removed and can be mitigated. No fences are proposed and the land area is not defined as “ important habitat”. • prevention of the migration of resource areas such as salt marshes due to sea level rise. If flood control and storm damage protection functions have already been impaired, redevelopment must improve existing conditions by reducing impervious surfaces, restoring flood control and storm damage protection functions, installing native plantings, or by restoring or creating other wetland resource areas. In this instance, there are no resource area impacts to cause for offsetting or migration of coastal wetland resource areas. Given the ongoing marina use properly managed with safeguards in place, construction controls relating to accomplishing the work, we believe the careful effort to undertake the 4 proposed building reconstruction as outlined and with the reasoning given in the above discussion concerning performance standards and related project purpose, the Commission can make the finding that project will not have an adverse impact upon the interests of the Mass Wetland Act or the Town of Yarmouth Wetland By-Law. This project, which serves to perpetuate a highly resourceful, significantly important marinafacility with a history at the site of more than 60 years, approved for renovation as defined in this application and accompanying plan, compliant with a resulting Order of Conditions will have a positive impact upon the facility itself, and the surrounding coastal resources. 1 Stormwater Management Checklist SHIP SHOPS, INC. – RECONSTRUCTION OF AN OUTBOARD RIGGING SHOP BUILDING The tasks outlined in the NOI involve building replacement in the approximate foundation footprint with drainage improvements and flood protection improvements. The proposed activity as described in the Notice of Intent fits to the category "redevelopment project” (Standard 7) and causes for no significant changes to the pervious areas nor changes in runoff volume but does present opportunity for improvements for pollution control by creating intercept, mainly along the building drip edge for building runoff interception. The site is within the coastal flood zone. Standard 7 is given here. 7. A redevelopment project is required to meet the following Stormwater Management Standards only to the maximum extent practicable: Standard 2, Standard 3, and the pretreatment and structural best management practice requirements of Standards 4, 5, and 6. Existing stormwater discharges shall comply with Standard 1 only to the maximum extent practicable. A redevelopment project shall also comply with all other requirements of the Stormwater Management Standards and improve existing conditions. A review of the Stormwater Standards is provided below: Standard 1: (Untreated discharges) No new storm water conveyances (e.g., outfalls) may discharge untreated stormwater directly to or cause erosion in wetlands or waters of the Commonwealth. There are no changes proposed that will alter the current conditions. Approx. 210 s.f. of added roof will be mitigated by the long trench drains. Standard 2: (Peak rate control and flood prevention) Storm water management systems must be designed so that post-development peak discharge rates do not exceed pre- development peak discharge rates. This Standard may be waived for land subject to coastal storm flowage. No changes to conditions that will significantly increase runoff volume are proposed. The proposed drip edge drains are expected to reduce any potential discharge. Site is within the 100-year coastal flood “AE” zone. Standard 3: (Recharge to Ground water) Loss of annual recharge to ground water shall be eliminated or minimized through the use of infiltration measures, including environmentally sensitive site design, low impact development techniques, best management practices, and good operation and maintenance. At a minimum, the annual recharge from the post-development site shall approximate the annual recharge from the pre-development conditions based on soil type. This Standard is met when the stormwater management system is designed to infiltrate the required recharge volume as determined in accordance with the Massachusetts Stormwater Handbook. Soil type is clean sand. Distance to groundwater from the bottom each trench is approx. 7 ft. Back fill soil for the building shall be a sand texture with high proportion (98%) of medium grain sand. No significant change from pre- construction runoff volume is anticipated. To the contrary, there will be a reduction. Infiltration will not significantly recharge groundwater with any significance in such proximity to the coastal interface because it is tidally influenced. Site is close to tidal waters and poses no potential for water supply concern. Standard 4: (80% TSS Removal) Stormwater management systems must be designed to remove 80% of the average annual post-construction load of Total Suspended Solids (TSS). This standard is met when: a. Suitable practices for source control and pollution prevention are identified in a long-term pollution prevention plan and thereafter are implemented and maintained; b. Stormwater BMPs are sized to capture the required water quality volume determined in accordance with the Massachusetts Stormwater Handbook; and c. Pretreatment is provided in accordance with the Massachusetts Stormwater Handbook. 2 Improvement is anticipated from the existing conditions relating to TSS removal. The project of building reconstruction is in a very limited area and it is not practical to change the over-land drainage character of the site. However, the roof drains with infiltration capability will reduce on-site surface volume that might otherwise reach the tidewaters. Standard 5 (Higher Potential Pollutant Loads (HPPL) For land uses with higher potential pollutant loads, source control and pollution prevention shall be implemented in accordance with the Massachusetts Stormwater Handbook to eliminate or reduce the discharge of stormwater runoff from such land uses to the maximum extent practicable. If through source control and/or pollution prevention, all land uses with higher potential pollutant loads cannot be completely protected from exposure to rain, snow, snow melt and stormwater runoff, the proponent shall use the specific stormwater BMPs determined by the Department to be suitable for such use as provided in the Massachusetts Stormwater Handbook. Stormwater discharges from land uses with higher potential pollutant loads shall also comply with the requirements of the Massachusetts Clean Waters Act, M.G.L. c. 21, §§ 26-53, and the regulations promulgated thereunder at 314 CMR 3.00, 314 CMR 4.00 and 314 CMR 5.00. Ships Shops, Inc. as a marina serving relatively small boating traffic has a management program currently in place that is stated to comply. The reconstruction of the existing shop building will incorporate a floor drain / holding tank system mandated by the Mass Plumbing Code. That, in combination with improved infiltration of clean roof stormwater further reduces threats related to high pollutant load activity. Standard 6 (Critical Areas) Stormwater discharges to a Zone II or Interim Wellhead Protection Area of a public water supply and stormwater discharges near or any other critical area require the use of the specific source control and pollution prevention measures and the specific stormwater best management practices determined by the Department to be suitable for managing discharges to such area, as provided in the Massachusetts Stormwater Handbook. A discharge is near a critical area if there is a strong likelihood of a significant impact occurring to said area, taking into account site- specific factors. Stormwater discharges to Outstanding Resource Waters or Special Resource Waters shall be set back from the receiving water and receive the highest and best practical method of treatment. A “stormwater discharge,” as defined in 314 CMR 3.04(2)(a)1. or (b), to an Outstanding Resource Water or Special Resource Water shall comply with 314 CMR 3.00 and 314 CMR 4.00. Stormwater discharges to a Zone I or Zone A are prohibited unless essential to the operation of the public water supply. Not applicable. No project relationship to such critical areas exists. Standard 7 (Redevelopment) 7. A redevelopment project is required to meet the following Stormwater Management Standards only to the maximum extent practicable: Standard 2, Standard 3, and the pretreatment and structural best management practice requirements of Standards 4, 5, and 6. Existing stormwater discharges shall comply with Standard 1 only to the maximum extent practicable. A redevelopment project shall also comply with all other requirements of the Stormwater Management Standards and improve existing conditions. The project is defined as “redevelopment” because it involves replacing a building. This checklist is reviewed under the Standard 7 Criteria with all Standards discussed. Standard 8: (Erosion, Sediment Control) A plan to control construction-related impacts, including erosion sedimentation and other pollutant sources during construction and land disturbance activities (construction period erosion, sedimentation, and pollution prevention plan), must be developed, and implemented. • With the existing surfaces remaining as they are pre-construction within the area affected by construction, a weighted system of straw wattles in place for the relatively short term ( two months) of construction the runoff / siltation threat can be minimized. 3 • For good measure, a supply of easily placed, adjustable and effective suitable straw wattle products shall be available, stored on site to be implemented on – demand for siltation intercept along the boundary surrounding the work area, focused on down gradient areas where necessary. Observations can best target the placement of the wattles. • An ample-sized dumpster or roll off container will be placed and maintained on site for the term of construction for demo -debris disposal. Debris ranging from worker lunch wrap and coffee cups to construction material remnants shall be controlled and sequestered in a covered bin. A portable toilet will be stationed on site during the work effort or the Ship Shops store lavatory shall be made available for workers. With exception of staging certain equipment and supplies, demolition work and related removal will be advanced quickly with material taken directly off site resulting in minimal threat. Standard 9: (Operation and Maintenance) A long-term operation and maintenance plan must be developed and implemented to ensure that stormwater management systems function as designed. The facility is a well-managed, operational, small boat marina within the coastal flood zone. A material management plan is in place. The roof drains are readily maintained. The limited drainage features resulting from past activities, e.g. the stone drains along the 650 ft. marine bulkhead cap and the extensive infiltration beds on the south portion of locus are evaluated periodically for suitability. • Ship Shops, Inc. management will be the responsible party for the management of the site drainage function as they have been. Pollution prevention measures are part of the ongoing practice at the facility. Ship Shops has an EPA storm water runoff permit program in place (NPDES ID: MAR05354) with reports made to EPA quarterly. • Ships Shops has an ongoing contract with Safety Kleen a Clean Harbors company for waste and hazardous material management. Standard 10 (Illicit Discharges) All illicit discharges to the stormwater management system are prohibited. Based upon my knowledge, information and belief, there are no illicit discharges to the storm water management systems at the property. Existing roof runoff volume is of a relatively clean nature not anticipated to contain illicit material. The intent of the regulation is fulfilled by the important relationship that Ship Shops, Inc has to the land and tidewaters it occupies and its obligation to properly manage its on-going practice of boat service, storage and fueling and for the cleanliness and condition of the immediate surroundings.