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604597 NOI - Letter to ConCom regarding MassDEP.pdf TranSystems 101 Arch Street Suite 301 Boston, MA 02110 Tel 857 453 5483 Fax 857 453 4576 www.transystems.com [1] March 28, 2018 Sarah LaValley Conservation, Preservation, and Land Use Planner Planning & Sustainability 210 Main St., Room 11 City Hall Northampton, MA 01060 RE: Notification of Wetlands Protection Act File Number: WE 246-0713 Improvements on I-91 Interchange 19 at Route 9 and Damon Road MassDOT # 604597 Northampton, MA TranSystems Project Number: P701070053 Dear Conservation Commission members, In response to the six “please note the following” from Mr. Mark Stinson, MassDEP: (1) The increase in runoff to Design Point G is a direct correlation to an increase in impervious are in post construction. In post construction, I-91on-ramp and I-91 off- ramps have been increased in length and width, creating more impervious area. To handle the increased flow in post construction, the existing 24” pipe is up sized to a 30” pipe. If requested, designer can add language to clarify on page 7 of the Stormwater Report. (2) Designer interpreted the regulations for TSS removal as 25% TSS removal credit for deep sump catch basins, and 25% TSS removal credit for a sediment forebay. Using deep sump catch basins in combination with a sediment forebay the total pretreatment is 44% TSS removal. As an example, if the project proposed standard sump catch basins, which have a 0% TSS removal credit, and then a sediment forebay, the total pretreatment would be 25% TSS removal. In both cases, the infiltration basin requires a sediment forebay, and the TSS removal credit of 80% is applied to the infiltration basin. For each infiltration basin on this project the TSS removal credit is a total of 85% TSS removal credit (deep sump catch basin and infiltration basin) as opposed to 89% TSS removal credit (deep sump catch basin, sediment forebay, and infiltration basin) For this project, both Infiltration Basin B and Infiltration Basin J each provide 44% TSS removal as pretreatment. [2] Will include as an Attachment the TSS Removal Calculation Worksheet showing pretreatment and the TSS Removal Calculation Worksheet showing total treatment for each infiltration basin. (3) Test pit locations are shown on sheets 23 and 25. Test pits are shown within the area of the proposed basins. If requested, designer can provide the basin details sheets for added clarity in the NOI plans. (4) On page 4 of the Stormwater Report, Attachment B, which shows the Hydrologic Soil Group (HSG) characterizes the entire project site as HSG B soils. On page 8 (under Standard 3 – Groundwater Recharge), the recharge target depth is calculated based on HSG B soils. At the location of proposed recharge (Infiltration Basin B and Infiltration Basin J), test pits were done at the location of the basins. The layer of the soil from the test pits where re-charge is proposed (bottom of proposed basins) is used for calculations as opposed to what the NRCS Soil Survey identified. The intent of the NRCS Soil Survey for this project was to see if infiltration was feasible on this site before deciding to propose infiltration. Can add statement in section of report under Standard 3 – Groundwater Recharge clarifying that the results of the test pits override the NRCS Soil Survey identified from Attachment B. (5) MassDOT has been working with MassDEP in developing a new MassDOT Stormwater Management Design Handbook. This new handbook builds upon the Massachusetts Stormwater Handbook from February 2008. The design of deep sump catch basins adheres to the 2016 MassDOT construction standards details. The design of the sediment forebays and infiltration basins follows guidelines from the 2008 Massachusetts Stormwater Handbook, but also includes design elements that will be included in the MassDOT Stormwater Management Design Handbook (currently under review). All proposed BMP’s will be constructed per MassDOT specifications/and or special provisions and final contract drawings. The BMP’s will be operated and maintained per the Operation and Maintenance Plan included in the Drainage Report. The BMP’s will function to receive TSS removal credit. Because a new MassDOT Stormwater Management Design Handbook is under development, we are not planning on providing excerpts. (6) We received a letter from NHESP dated March 1, 2018 stating its Determination. This letter was forwarded to the conservation commission. Sincerely, Michael J. Rieger, PE Civil Engineer Encl: Notification of Wetlands Protection Act File Number dated March 19, 2018 [3] Cc: Mark Stinson, MassDEP; Susan McArthur, MassDOT – Highway Division; Robert Natario, MassDOT – Highway Division DATE:March 19, 2018 Municipality NORTHAMPTON (city/town) RE: NOTIFICATION OF WETLANDS PROTECTION ACT FILE NUMBER The Department of Environmental Protection has received a Notice of Intent filed in accordance with the Wetlands Protection Act (M.G.L. c. 131, §40): Applicant: Address: LOCUS: MASSDOT 10 PARK PLAZA INTERSTATE 91 INTERCHANGE AT RT. 9 AND DAMON ROAD Owner: Address: This project has been assigned the following file # :WE 246-0713 Although a file # is being issued, please note the following: Commissioner MARTIN SUUBERG Secretary MATTHEW A. BEATON Lieutenant Governor KARYN E. POLITO Governor CHARLES D. BAKER A FILE NUMBER ONLY INDICATES THAT THE APPLICATION CONTAINS THE MINIMAL SUBMITTAL REQUIREMENTS AND IS ADMINISTRATIVELY COMPLETE - NOT THAT THE INFORMATION IN THE APPLICATION IS ADEQUATE FOR ISSUANCE OF AN ORDER OF CONDITIONS. 436 DWIGHT STREET, SPRINGFIELD, MA 01103 413-784-1100 WESTERN REGIONAL OFFICE DEPARTMENT OF ENVIRONMENTAL PROTECTION EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS COMMONWEALTH OF MASSACHUSETTS BOSTON, MA 02116 [1] Please explain the significant post construction runoff vs. pre, for Design Point G and why this is or is not an issue. [2] A CB provides 25%TSS and a sediment forebay provides 25%. An infiltration basin requires that total of 44% TSS removal prior to the water entering the basin for HSG A or B soils. One only gets a total of 80% for an infiltration basin. One does not add the pretreatment TSS removal to the 80%. [3] Are the soils test pit locations shown on the plan and if so, were they taken in the area of the basins as required? [4] There should be a statement somewhere in the stormwater report, that the soils found onsite are, or are not, as those reported in the NRCS soil survey especially regarding HSG information. Please review figure 2.3.1, page 8, Determining HSG, from Volume 3, Chapter 1 of the Stormwater Handbook. [5] All Stormwater BMP's must be designed, constructed, operated and maintained per the Stormwater Handbook Volume 2 Chapter 2 in order to receive any presumptive TSS removal credit. It is recommended that the relevant This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD# 1-866-539-7622 or 1-617-574-6868. http://www.mass.gov/dep Printed on Recycled Paper MASSDOT 10 PARK PLAZA BOSTON, MA 02116 sections of the handbook pertaining to each individual BMP be cut and pasted into the Stormwater report, to assist in Commission review of the stormwater management system. [6] The Commission should wait to close the public hearing until NHESP has issued its Determination. If you have any questions regarding this letter, please contact: MARK STINSON @ (413)-755-2257 Cc: Northampton Conservation Commission, CITY HALL, 210 MAIN STREEET RM 11, Northampton, MA, 01060 Natural Heritage & Endangered Species Program, Div of Fisheries & Wildlife Route 135, North Drive, Westborough, MA, 01581 Representative: TranSystems, 101 Arch Street, BOSTON, MA, 02110 This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD# 1-866-539-7622 or 1-617-574-6868. http://www.mass.gov/dep Printed on Recycled Paper