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HomeMy WebLinkAboutsecond Peer Revew 9.11.2024 westonandsampson.com 427 Main Street, Suite 400, Worcester, MA 01608 Tel: 508.762.1676 September 11, 2024 Yarmouth Conservation Commission C/O Brittany DiRienzo, Conservation Administrator 1146 Route 28 Yarmouth, MA 02664 Re: Engineering Review of Stormwater Management Permit Application 770 Route 28 SECOND REVIEW Dear Commissioners: In accordance with your request, Weston & Sampson is pleased to present our review of the above referenced application. The purpose of this letter report is to provide comments on the proposed stormwater drainage as it currently relates to regulatory compliance with the Town of Yarmouth Conservation Commission Stormwater Management Regulations (Effective July 1, 2021) and the Massachusetts Stormwater Handbook as referenced therein. Our review is based on information submitted to the Town by Conserv Group, Inc. and Atlantic Design Engineers, Inc., the “Engineer”, on behalf of Mash Realty, LLC., the “Owner”. Weston & Sampson performed an initial review of this project and provide comments in a letter dated August 16, 2024. We received revised submission materials on September 4, 2024. These documents, listed below, are the subject of this current review letter.  A plan set entitled “Site Plans for Cape & Islands Nissan”, revised August 28, 2024 (10 sheets)  A letter and attachments from the Engineer responding to our initial peer review letter, dated August 28, 2024 (16 pages) Comments from our previous review are reproduced below in gray text, followed by our updated comments based upon review of the revised submission materials. Town of Yarmouth Conservation Commission Stormwater Management Regulations Compliance Review Section 2.04 Stormwater Management Site Plan WSE 8/16/2024 COMMENT: The applicant has submitted all of the items required for submission under this section, subject to the comments presented below. Section 2.05 Stormwater Management Performance Standards 2.05(1) Low Impact Development WSE 8/16/2024 COMMENT: Under this standard the applicant is required to “document in writing why LID strategies are not appropriate when not used to manage stormwater.” LID examples cited in this standard include infiltrating roof runoff at the source, planting large canopy trees over impervious areas and using porous paving materials, etc. where feasible. The applicant has provided a brief statement indicating that it is their belief that LID strategies have been implemented as much as feasible, and that such measures include the planting of as many grassed/landscaped areas as possible. We offer no objection to the rationale presented by the applicant, but the commission may wish for the applicant to further discuss what other LID approaches may have been considered for this site. 2.05(2) Good Housekeeping Procedures WSE 8/16/2024 COMMENT: We have noted the following in our review related to this standard: Page 2 westonandsampson.com  This standard requires provisions for car washing to occur “on lawns or pervious areas using biodegradable and phosphate free detergent.” This is not discussed in the O&M plan. We recommend that the engineer address the item noted above. WSE COMMENT: The Engineer has submitted a revised O&M plan stating that vehicles will be washed at the abutting dealership or at a commercial car wash. This comment has been addressed. 2.05(3) Stormwater Management Systems Design WSE 8/16/2024 COMMENT: We have noted the following in our review related to this standard:  The Engineer has shown that peak discharge rates do not exceed pre-development discharge rates for the 2, 10, 25, 50 and 100-year 24-hour storm events. Runoff from all areas of onsite improvement discharge to either an above-ground stormwater basin or subsurface chambers. These retain runoff from stormwater events including the 50-year and 100-year event with no offsite runoff from these BMPs. These standards have been met.  This section includes a standard requiring pretreatment of runoff from metal rooftops if the site is discharging to a Zone II or interim wellhead protection area. The Engineer is proposing to discharge roof runoff into the subsurface infiltration system with no pretreatment, but the site does not appear to be within the areas described above. This standard has been met.  This standard requires the use of NOAA Atlas 14 rainfall data for stormwater modeling, or alternative datasets at the discretion of the commission. It appears that the Engineer has used NOAA Atlas 14 data in the analysis. This standard has been met. 2.05(4) Stormwater Management System Pollutant Removal Requirements (new development) WSE 8/16/2024 COMMENT: We have noted the following in our review related to this standard:  Under this standard, the engineer is given the option to provide a retention volume equal to or greater than one inch multiplied by the impervious area of the site. It is presumed that the engineer intends to meet this standard via the option for retaining the volume of runoff equivalent to or greater than 1-inch multiplied by the post-construction impervious surface, and this standard is likely met since the systems retain the 100-year storm event. That being said, a calculation of water quality flow was provided, but a calculation of static (i.e. not taking into account dynamic recharge) water quality volume (required vs proposed) was not found. We recommend that the Engineer provide this. WSE COMMENT: The Engineer has responded by indicating where to find the requested calculation within the previously submitted stormwater report. Upon further review, we have located the requested calculation in that report. The calculation indicates that the water quality volume for the site is provided by both the underground chambers and the stormwater basin to the rear of the site. The calculation indicates that the latter provides 13,126 cubic feet of storage. Elsewhere in the Hydrocad analysis it appears that this reported volume is associated with stormwater staging up to an elevation of 6.50. The basin is only capable of staging up to an elevation of 5.8 which is the spillway elevation, so in reality this basin only has a water quality volume capacity of somewhere between 6,000 and 10,000 cubic feet based on the Hydrocad report. That being said, this lower actual storage volume value still exceeds the minimum required volume for the basin for both water quality and recharge volume. This standard has been met. The board can consider whether it wishes for the Engineer to submit a revised calculation to address this minor numerical discrepancy. 2.05(5) Stormwater Management System Pollutant Removal Requirements (redevelopment) WSE 8/16/2024 COMMENT: This standard is not applicable since the site is a new development. Page 3 westonandsampson.com 2.05(6) Stormwater Management System EPA Tool Analysis WSE 8/16/2024 COMMENT: We have noted the following in our review related to this standard:  The applicant has not used the EPA Region 1 BMP Accounting and Tracking Tool to evaluate average yearly pollutant removal for the BMPs. Under this standard, applicants are required to provide this analysis or are otherwise allowed to use other federal or state approved performance standards when the EPA tools are not applicable for the proposed BMPs. If the presumption stated under 2.05(4) is correct and the Engineer is using 1-inch of retention as a means of satisfying the nutrient removal standards, then the EPA Tool Analysis would not be required. We recommend that the Engineer clarify the approach being used. WSE COMMENT: The Engineer has clarified that the 1-inch retention approach has been used to satisfy this requirement. This standard has been met. 2.05(7) Discharges to water bodies subject to TMDL WSE 8/16/2024 COMMENT: The site does not discharge to a water body subject to a TMDL. Section 2.06 Erosion and Sediment Control Plan Standards 2.06(1) Contents of Erosion and Sediment Control Plan The applicant has submitted plans for Erosion and Sediment Control which are substantially complete, subject to further comments below. 2.06(2) Stormwater Pollution Prevention Plan (SWPPP) Submission WSE 8/16/2024 COMMENT: The project will disturb more than one acre of land, therefore it will be subject to coverage under the NPDES Construction General Permit. Under this section, the applicant is required to submit a complete copy of the SWPPP for the project. We recommend that the applicant submit a copy of the SWPPP. The commission may wish to consider adopting a condition of approval requiring the submission of the SWPPP prior to any ground disturbing activity since the contractor will ultimately be the party responsible for the SWPPP. WSE COMMENT: The Engineer has stated that the applicant is amenable to a condition similar to what is stated above. We offer no further comment. 2.06(3) Design of erosion and sediment controls The applicant’s erosion and sediment control plan substantially conforms to this standard.: 2.06(4) Erosion and Sedimentation Control Plan Content WSE 8/16/2024 COMMENT: We have noted the following in our review related to this standard:  This standard calls for the inclusion of 100-year flood elevation information based on FEMA mapping, this was not found on the plan. The engineer should address this.  This standard calls for a description of how fueling of vehicles/equipment and fuel/chemical storage will be conducted. This was not found on the plan. The engineer should address this.  This standard calls for the identification of “trees with a caliper twelve (12) inches diameter breast height or larger, noting specimen trees and forest communities.” This was not found in the submitted materials. We recommend that the applicant either clarify whether this is applicable, submit the applicable information, or request a waiver from the commission if that is the applicant’s intent. Page 4 westonandsampson.com  A description of procedures for construction vehicle fueling, temporary chemical storage and construction vehicle washing/washout was not found. The engineer should address this. WSE COMMENT: The Engineer has addressed the comments listed above, with the exception of the requirement for identification of individual trees on the plans that are of 12-inches or larger. The Engineer has requested a waiver from this requirement. We offer no further comment on this, the board may wish to consider whether it will grand a waiver from this requirement. 2.07 Operation and Maintenance (O&M) Plan 2.07(1) Stand-alone O&M plan requirements WSE 8/16/2024 COMMENT: We have noted the following in our review related to this standard:  There are comments noted farther above that the applicant should address related to the O&M plan.  The O&M plan is currently formatted as a chapter within the stormwater report. The commission may wish to advise whether it is desirable to have it separated as a “stand-alone” report. WSE COMMENT: The Engineer has submitted a copy of the O&M plan as a “stand-alone” document as an attachment to the response letter. We offer no further comment. Under these standards, compliance with the MA Stormwater Handbook is required. Compliance with the Handbook is further discussed below. Massachusetts Stormwater Handbook Compliance Review Under Section 2.04(1) of the Yarmouth Conservation Commission Stormwater Management Regulations, the standards of the Massachusetts Stormwater Handbook are adopted by reference. These standards are listed below, followed by our review comments. Standard 1: Untreated Stormwater WSE 8/16/2024 COMMENT: No new point discharges of untreated stormwater are proposed. The proposed stormwater improvements for the site include deep sump hooded catch basins, drain manholes, underground stormwater chambers, hydrodynamic separators and an infiltration basin. The design proposed no new outfalls for stormwater to leave the site and proposes to retain stormwater up to and including the 100-year storm event. This standard has been met. Standard 2: Post Development Peak Discharge Rates WSE 8/16/2024 COMMENT: The stormwater report analyzed the site for storm events with recurrence intervals of 2-, 10-, 25-, 50- and 100-years. The analysis indicates that the post-redevelopment peak discharge rates will be less than existing condition peak discharge rates. This standard has been met, subject to comments under the heading of other standards below. Standard 3: Recharge to Groundwater WSE 8/16/2024 COMMENT: This standard requires that the site infiltration mimic preconstruction conditions for small storms based on the proposed increase in impervious area. The engineer has submitted calculations showing that onsite stormwater BMPs have been designed to retain and recharge far above the minimum required Page 5 westonandsampson.com recharge volume. The Engineer has shown test pit data for the site, and adequate separation to groundwater appears to be provided for the subsurface infiltration system. The following issues were noted:  The test pit data for one of the test pits (TP-5) could not be found in the report, so adequate separation to seasonal high groundwater could not be confirmed.  The subsurface chambers are called out as proprietary precast structures from Shea Concrete. While we are familiar with this product and the design appears to be consistent with the product, we would recommend that a detail/cross section for the chamber system should be in the plans for clarity. We recommend that the Engineer address the items above. WSE COMMENT: The requested information has been provided in the submitted materials. This standard has been met. Standard 4: Total Suspended Solids (TSS) Removal WSE 8/16/2024 COMMENT: The town standards for TSS removal and stormwater quality treatment are more stringent than this standard. Compliance with the town’s standards is discussed in the preceding comments. We believe that this standard has been met. Standard 5: Land Uses with Higher Potential Pollutant Loads (LUHPPLs) WSE 8/16/2024 COMMENT: The Engineer has indicated that the proposed development is not a LUHPPL. We agree with this assessment. Standard 6: Protection of Critical Areas WSE 8/16/2024 COMMENT: The applicant’s submission indicates that the site is not within a critical area. Even so, the proposed stormwater BMPs are in keeping with what is required under this standard. This standard has been addressed. Standard 7: Redevelopments WSE 8/16/2024 COMMENT: This project qualifies as a new development. The applicant is required to fully comply with these standards. This standard has been addressed. Standard 8: Construction Period Pollution Prevention and Erosion/Sedimentation Control WSE 8/16/2024 COMMENT: The engineer has provided an erosion and sedimentation control plan. Due to the fact that the site will disturb more than one acre, a Stormwater Pollution Prevention Plan (SWPPP) will be required to obtain coverage under the NPDES Construction General Permit. The town’s standards related to this are more stringent. Provided that the applicant addresses the preceding comments, this standard from the Handbook will be satisfied. Standard 9: Operations & Maintenance Plan WSE 8/16/2024 COMMENT: A long-term pollution prevention and operations and maintenance plan have been provided. Further comments that related to this standard are provided above under the analysis of the town’s similar standard. Provided that those comments are addressed, this standard from the Handbook will be satisfied. Standard 10: Illicit Discharge Compliance Statement WSE 8/16/2024 COMMENT: The Engineer has stated that an Illicit Discharge Compliance Statement will be signed by the responsible party prior to the start of construction. The Commission may wish to include this as a condition of approval for the project. Page 6 westonandsampson.com WSE COMMENT: The Engineer has stated that the applicant will accept the recommended condition of approval. We offer no further comment. Weston & Sampson appreciates the opportunity to present our findings. We are available at your earliest convenience to discuss our report. Please contact me if you have any questions. I may be reached at (978) 532-1900 or pearsonj@wseinc.com. Sincerely, WESTON & SAMPSON ENGINEERS, INC. James I. Pearson, PE Technical Leader