TMDL) Action Plan Permit Cycle: 2013-2018 General Permit No.: VAR040073

Rivanna River Combined Benthic and Bacteria Total Maximum Daily Load (TMDL) Action Plan Permit Cycle: 2013-2018 General Permit No.: VAR040073

July 1, 2016

Prepared by: University of Virginia Facilities Management, Environmental Resources Division 575 Alderman Rd, Charlottesville, VA 22904 (434) 982-4901

Table of Contents

Background ...... 1 1. The names of the Final TMDL reports ...... 2 2. The pollutants causing the impairments ...... 2 3. The WLAs assigned to the MS4 as aggregate or individual WLAs ...... 3 4. Significant sources of POCs from facilities of concern owned or operated by the MS4 operator that are not covered under a separate VPDES permit...... 5 5. Existing or new management practices, control techniques, and system design and engineering methods , that have been or will be implemented as part of the MS4 Program Plan that are applicable to reducing the pollutant identified in the WLA ...... 5 6. Legal authorities such as ordinances, state and other permits, orders, specific contract language, and interjurisdictional agreements applicable to reducing the POCs identified in each respective TMDL ...... 10 7. Enhancements to public education, outreach, and employee training programs to also promote methods to eliminate and reduce discharges of the POCs for which a WLA has been assigned ...... 11 8. A schedule of interim milestones and implementation of the items in 5, 6, and 7 ...... 14 9. Methods to assess TMDL Action Plans for their effectiveness in reducing the pollutants identified in the WLAs ...... 15 10. Measurable goals and the metrics that the permittee and Department will use to track those goals (and the milestones required by the permit)...... 16

List of Appendices

Appendix A - Rivanna River Benthic Impaired Segments and Delineated Watershed

Appendix B - Location of Bacteria Impaired Segments of the Rivanna River mainstem, North Fork Rivanna River, Preddy Creek and tributaries, Meadow Creek, Mechums River, and Beaver Creek Watersheds

Appendix C - Potential Sources of Significant POCs

Background The University of Virginia (UVA) occupies approximately 1,100 acres and is located within the borders of both the City of Charlottesville and Albemarle County. The University is also situated in the headwaters of the Meadow Creek watershed and the headwaters of tributaries to the Moores Creek watershed. Both of these watersheds drain to the Rivanna River on the eastern boundary of the City of Charlottesville. The Rivanna River flows to the James River, and ultimately discharges to the lower Chesapeake Bay.

As a predominately urbanized state entity with separate storm and sanitary sewer conveyance systems, the University is classified as a Small Municipal Separate Storm Sewer System (MS4). Therefore, UVA is mandated to follow the regulations of the Environmental Protection Agency as outlined in the Clean Water Act, the Virginia Stormwater Act and the MS4 General Permit granted by the Department of Environmental Quality (DEQ). The MS4 service area consists of 782 acres.

In compliance with Section I.B of the General Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems (Permit No.: VAR040073), and the Special Condition described therein, the University of Virginia, an MS4 Operator, has developed a Combined Benthic and Bacteria Total Maximum Daily Load (TMDL) Action Plan for the Rivanna River.

The TMDL for the Rivanna sets limits on the amount of pollutants of concern (POCs), including total suspended solids (TSS) and E.coli bacteria that can be discharged to the river without detrimentally impacting water quality. The MS4 Permit Special Condition for approved TMDLs other than the Chesapeake Bay TMDL requires all MS4 operators to reduce existing levels of these POCs to a level that will be protective of water quality. This process typically requires that the MS4 operator install best management practices (BMPs) that will, through various means, lower the contaminant levels in stormwater discharged to local streams and other water bodies.

This TMDL action plan has been prepared in accordance with the requirements in the Virginia Department of Environmental Quality General Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems and the DEQ Draft Local TMDL Guidance Memo (Guidance Memo), dated April 2015. The sections of this action plan correlate with the items identified as “Action Plan Content” on page four of the Guidance Memo. Additionally, the University has coordinated with Albemarle County and the City of Charlottesville in the preparation of this Action Plan.

1. The names of the Final TMDL reports (General Permit Section I.B; DEQ Local Stream TMDL Action Plan Guidance Document, Item 1)

Wasteload allocations (WLAs) were assigned to the University for the Rivanna River Watershed in the approved Final TMDL reports as follows:

Benthic TMDL • Benthic TMDL Development for the Rivanna River Watershed, Final Report (dated March 2008)

Bacteria TMDL • Bacteria TMDL Development for the Rivanna River Mainstem, North Fork Rivanna River, Preddy Creek and Tributaries, Meadow Creek, Mechums River, and Beaver Creek Watersheds (dated March 2008)

2. The pollutants causing the impairments (General Permit Section I.B; DEQ Local Stream TMDL Action Plan Guidance Document, Item 2)

Benthic TMDL The Benthic TMDL report noted above (Section 1) identified two separate stream segments with benthic impairments for the mainstem Rivanna River; Segment VAV-H28R-01 and Segment VAV-H29R-01 (See Appendix A). These segments, which are applicable to UVA, are included in Virginia’s 303(d) Lists of Impaired Waters as well as the Water Quality Assessment 305(b)/303(d). As of 2004, the source of the benthic macroinvertibrate impairment for the upstream segment (VAV-H28R-01) was attributed to non-point source urban runoff. The source of the benthic macroinvertebrate impairment for segment VAV-H29R-01 is unknown. However, analysis of the candidate stressors indicate that sedimentation is the most probable cause of the impairment and the basis of the TMDL.

Bacteria TMDL The Bacteria TMDL report noted above (Section 1) listed two stream segments with impairment listings relevant to the University and its watersheds. Those segments are the Rivanna River mainstem (VAV-H28R-RVN01A00) and Meadow Creek (VAV-H28R-MWC01A00). These segments were first identified as having impairment listings for E. coli and for fecal coliform bacteria on Virginia’s 303(d) List of Impaired waters between 2002 and 2006.

The initial impairment listings for the noted stream segments were expressed as fecal coliform bacteria, as was required with the Virginia Bacteria Water Quality Standard at that time. These segments are now both listed for E.coli impairments under the TMDL report for the Rivanna River Watershed in accordance with current applicable water quality standards (See Appendix B).

The TMDL, under the new water quality standards limits the geometric mean concentration of E.coli to 126 E. coli counts per 100 ml of water within a calendar month, or a concentration of 235 counts per 100 ml of water at any time.

Potential sources for the pollutant(s) causing the impairment, specific to the University’s MS4, are as follows: • Failed sanitary sewer systems, straight pipes and failed septic systems • Direct and indirect depositions from wildlife • Loading contributions from domesticated pets. Other sources that were considered and contribute to the aggregated wasteload allocation include: • Permitted point source facilities • Livestock grazing • Land application of manure • Land application of biosolids

3. The WLAs assigned to the MS4 as aggregate or individual WLAs (General Permit Section I.B; DEQ Local Stream TMDL Action Plan Guidance Document, Item 3)

Benthic TMDL The University has been assigned a WLA in the final Benthic TMDL report of 139 lbs/day as is shown in the table below.

Table 1

Benthic TMDL Development Report - Table 7-2: Wasteload Allocation by MS4 Location Within the Rivanna River Benthic Impaired Watershed

Land- Existing Instream Allocated Permit MS4 Permit Based Total Percent Erosion Load Number Holder Loads Load Reduction (lbs/day) (lbs/day) (lbs/day) (lbs/day)

University of Virginia 17 49 65 27 59.3 (Charlottesville) VAR040073 University of Virginia 70 206 277 112 59.3 (Albemarle)

Total 87 255 342 139 59.3

Bacteria TMDL The University, in addition to other MS4s, has been assigned an aggregated WLA of 3.27E+10 cfu/day for E. coli for the Rivanna River mainstem (see Table 2).

Table 2 Bacteria TMDL Development Report - Table 5-4: Rivanna River Distribution of Annual Average E. coli Load under Existing Conditions and TMDL Allocation Average E.coli Loads Percent Allocation Land Use/Source (cfu/yr) Reduction (cfu/day) Existing Allocation (%) Forest 5.74E+12 5.74E+12 5.74E+10 0% Cropland 1.33E+13 6.65E+11 6.65E+09 95% Pasture 3.86E+14 1.93E+13 1.93E+11 95% Urban Residential 7.49E+13 3.75E+12 3.75E+10 95% Water/Wetland 4.85E+07 4.85E+07 4.85E+05 0% Cattle - direct deposition 1.91E+13 0.00E+00 0.00E+00 100% Wildlife - direct deposition 4.84E+13 1.16E+13 1.16E+11 76% Failed Septic - direct deposition 1.43E+11 0.00E+00 0.00E+00 100% Point Source 8.29E+11 1.66E+12 4.54E+09 0% MS4s 6.54E+13 3.27E+12 3.27E+10 95% Total loads / Overall reduction 6.14E+14 4.60E+13 4.48E+11 92%

The University, in addition to other MS4s, has been assigned an aggregated WLA of 4.06E+10 cfu/day for E. coli for Meadow Creek (see Table 3).

Table 3 Bacteria TMDL Development Report - Table 5-18: Meadow Creek Distribution of Annual Average E. coli Load under Existing Conditions and TMDL Allocation Average E.coli Loads Percent Allocation Land Use/Source (cfu/yr) Reduction (cfu/day) Existing Allocation (%) Forest 1.15E+10 1.15E+10 1.22E+08 0% Cropland 0.00E+00 0.00E+00 0.00E+00 0% Pasture 2.40E+08 1.20E+07 1.27E+05 95% Urban Residential 3.12E+13 1.56E+12 1.65E+10 95% Water/Wetland 2.85E+06 2.85E+06 3.02E+04 0% Cattle - direct deposition 3.35E+10 0.00E+00 0.00E+00 100% Wildlife - direct deposition 1.27E+12 6.59E+11 6.99E+09 48% Failed Septic - direct deposition 3.94E+09 0.00E+00 0.00E+00 100% Point Source 0.00E+00 6.06E+10 1.66E+08 0% MS4s 7.66E+13 3.83E+12 4.06E+10 95% Total loads / Overall reduction 1.09E+14 6.12E+12 6.44E+10 94%

4. Significant sources of POCs from facilities of concern owned or operated by the MS4 operator that are not covered under a separate VPDES permit (General Permit Section I.B.2.d; DEQ Local Stream TMDL Action Plan Guidance Document, Item 4)

The Guidance Memo states: “A significant source of pollutant(s) from a facility of concern means a discharge where the expected pollutant loading is greater than the average pollutant loading for the land use identified in the TMDL”.

Since the University owns and operates all of the facilities within the MS4 boundary, an evaluation process was established to identify any potential sites with significant sources of sediment and bacteria. The process involved analyzing sites that could traditionally be considered as areas with the potential for generating POCs within the MS4 service area.

The emphasis focused on sites with municipal operations or high-priority facilities that require SWPPPs per Minimum Control Measure 6 in the Annual Report (i.e. Heat Plant, Recycle Center and FM maintenance yards). Emphasis was also given to all retention ponds (for their potential to attract dog-walkers and geese), and known properties with septic systems. The search was then broadened to include all properties that were immediately upstream of a DEQ MS4 regulated outfall. Field investigations were then made to sites that required further analysis of runoff characteristics, which resulted in a total of 75 potential facilities of concern. Active construction sites or any areas that have industrial permits were not included in the evaluation.

Through desktop and site inspection analysis it was determined that the University does not contain any sites that are significant sources of sediment or E. coli. However, the sites identified on the list will continue to be monitored. Any facilities that are identified in the future as possible sources will be added to the list and incorporated into the TMDL Action Plan. Refer to Appendix C for a full listing of the evaluated sites.

5. Existing or new management practices, control techniques, and system design and engineering methods, that have been or will be implemented as part of the MS4 Program Plan that are applicable to reducing the pollutant identified in the WLA (General Permit Section I.B.2.b; DEQ Local Stream TMDL Action Plan Guidance Document, Item 5)

Before the issuance of the most recent Permit, the University of Virginia had taken a proactive stance, and made an aggressive effort to reduce POCs within their watersheds. The University’s MS4 Program Plan includes a wide array of Best Management Practices (BMPs) that aim to reduce pollutants including sediment and bacteria. The list of BMPs below outlines some of those practices and correlates with the Minimum Control Measures found in the Annual MS4 Report:

BMPs 1. Websites and Social Media (Sediment and Bacteria) – The University Environmental Resources webpage contains links to the E&S website as well as the Stormwater Management page. Links can also be found through the websites for the Office for Sustainability. Additionally, a Facebook page, and a Flickr account have been created in conjunction with the University formed “Stormwater Task Force” to promote the same practices and behaviors.

2. Public Awareness Events (Sediment and Bacteria) - The University tables at events such as: World Water Day, Earth Week (at UVA as well as in the City of Charlottesville) for education and outreach.

3. Rivanna Stormwater Education Partnership Member – As a member of RSEP, the University strives to make citizens aware of stormwater issues to help reduce impacts and improve local water quality. Membership in this partnership is an effective and fundamental part of the education and outreach program.

4. Advertising (Sediment and Bacteria) –As part of the Rivanna Stormwater Educational Partnership (RSEP) further described in section 7, advertisements are displayed in a local newspaper (Cville Weekly), movie theaters and buses addressing methods to reduce sediment and bacteria with car washing tips and pet waste reminders, etc.

5. Utility Bill Mailings (Sediment and Bacteria) – Mailings are coordinated via RSEP and are sent to all water customers in the City and Albemarle County. Mailings address POC awareness and mitigation methods.

6. Educational Lectures (Sediment and Bacteria) – Members of the Environmental Resources team routinely guest lecture in classes for Engineering, Architecture and Environmental Science at the University to talk about the importance of POC awareness and reductions.

7. Stream Cleanups (Sediment and Bacteria) –UVA students, faculty and staff are encouraged to participate in stream enhancement and education projects and programs where possible.

8. Illicit Discharge Program (Sediment and Bacteria) – The University’s program involves monitoring, detection and elimination of illicit discharges. The University maintains a 24 hour response team for reported discharges. Additionally, the RSEP website provides an online reporting tool for illicit discharges which are distributed to the appropriate MS4 operator. Utility mapping is updated regularly and illegal discharges are discouraged through public education. The University follows procedures for reporting and tracking illicit discharges and procedures for enforcing policies. An SOP has been written for illicit discharge removal.

9. Stormwater Stenciling Program (Sediment and Bacteria) - Staff and volunteers label stormwater catch basins and inlets to reduce potential illicit discharges.

10. MS4 Outfall Inspections/Dry Weather Discharge Inspections (Sediment and Bacteria) - Inspection program for all stormwater outfalls utilizes written IDDE procedures to detect illicit discharges, report them, investigate them, and document the investigation. Procedures were revised and updated to ensure compliance with new MS4 program requirements.

11. Inflow and infiltration Detection (Bacteria) – The University proactively inspects sanitary sewer lines to identify problems before they occur. The program includes sanitary sewer lining and replacement.

12. Sanitary Sewer Overflow Response Team (Bacteria) - The University maintains an in- house 24-7 response/repair team to respond, document, and notify DEQ of sanitary sewer overflow (SSO) reports.

13. Erosion and Sediment Control Program (Sediment) –UVA follows Annual Standards and Specifications for E&SC in compliance with the Virginia E&SC Law and Regulations. UVA tracks land disturbing activities and provides disturbed acreage to the DEQ monthly in accordance with the Annual Standards. E&SC Plans are required for all land disturbances over 10,000 square feet (sf) in Albemarle County and 6,000 sf in the City of Charlottesville. UVA requires E&SC controls to be installed on all land disturbing projects, even if a formal E&SC plan is not required. Additionally, plan approval is required prior to commencement of any land disturbing activity.

14. VSMP and Construction General Permit (Sediment and Bacteria) - Land disturbances over 1 acre require a construction site Virginia Stormwater Management Program (VSMP) permit, which includes a Stormwater Pollution Prevention Plan (SWPPP). UVA has provided a SWPPP template for construction activities to help guide contractors to plan for appropriate controls to prevent non-stormwater discharges. All stormwater management plans are reviewed for compliance with State Regulations.

15. E&SC Construction Site Inspections (Sediment and Bacteria) - UVA inspectors conduct E&SC inspections for applicable land disturbing activities: 1) upon initial installation 2) at least once within every 2 week period 3) within 48 hours of a runoff producing storm event 4) upon completion of the project.

16. Stormwater Management Master Plan (Sediment and Bacteria) The University has developed a Stormwater Management Master Plan as a proactive effort to implement a range of stormwater management related projects that not only provide solutions to drainage, and flooding issues but for water quality improvement needs on a watershed level. The plan strategically identifies projects that would meet pollutant load reduction

targets associated with the Total Maximum Daily Loads (TMDL) assigned to the University.

17. Stormwater Management Project Review (Sediment and Bacteria) – UVA follows Annual Standards and Specifications for stormwater management in compliance with the Virginia SWM Act and Virginia SWM Program (VSMP) Regulations as related to municipal separate storm sewer systems (MS4) and construction activities. An internal plan review and approval program was implemented to maintain compliance with new stormwater regulations and to ensure stormwater runoff from UVA construction sites is managed appropriately.

18. Structural BMPs (Sediment and Bacteria) - There are currently over 100 structural BMPs that are either installed or under construction to help reduce the pollutant load to local streams. Additionally, construction projects occurring within the MS4 are encouraged to oversize their proposed BMPs to facilitate additional reductions. All newly constructed or retrofitted BMPs will be built in accordance with the latest version of the Virginia BMP Clearinghouse.

19. Stormwater Management Facility Inspections (Sediment and Bacteria) - UVA inspects and maintains all structural BMPs on its property. Inspectors conduct routine inspections and complete maintenance as needed. Debris is cleaned from catch basins and conveyances within the stormwater drainage system on a routine basis as well (and after large storms).

20. Street Sweeping and Vacuuming (Sediment and Bacteria) - UVA is responsible for the cleaning of streets, parking lots and permeable pavement (under our control) which includes the removal of trash and leaves at least once per year. Parking lots are monitored and cleaned as necessary.

21. Municipal Facility Pollution Prevention and Good Housekeeping (Sediment and Bacteria) - UVA has implemented a general Pollution Prevention Plan to cover all UVA operations. UVA will develop and implement specific SWPPPs for all municipal high priority facilities.

22. Annual Staff Training Plan (Sediment and Bacteria) – UVA will continue to update the annual training plan as needed to provide necessary training on IDDE, good housekeeping, pollution prevention, spill prevention, environmental awareness, and other required training. Training is provided to appropriate staff at least annually.

23. Rivanna Conservation Alliance - Science Advisory Board Member – UVA’s Associate Director for Environmental Resources, and MS4 Manager, serves on the Science Advisory Board for the Rivanna Conservation Alliance. The board evaluates and makes suggestions to improve the biologic (and bacteria) monitoring program.

The minimum control measures and the associated BMPs under the MS4 Program Plan are further detailed at: http://www.fm.virginia.edu/docs/operations/UVaMS4ProgramPlan.pdf

As shown in the most recent master plan, the University strives to continue to reduce the POC loading on the Rivanna River. The following lists are examples of potential projects currently under consideration to continue this effort:

Table 4 Potential Stream Restoration Segments on University Grounds Estimated Restoration Stream Location Adjacent Redevelopment Zone Length (ft)

Distillery Branch Copeley Housing 700 Nameless Field – Stream Daylighting N/A 1,000

Stream through Ivy Mountain Area Ivy Mountain / KCRC 700

Table 5 Potential Stormwater Basin Retrofit Opportunities Stormwater Facility Name Existing BMP Type Proposed BMP Type Darden #1 Basin (North) Dry Extended Detention Wet Pond Darden #2 Basin (South) Dry Extended Detention Wet Pond The Park Basin Dry Detention Wet Pond FM Basin Dry Detention Wet Pond Gooch Dillard Basin Dry Detention Bioretention or Wetland Extended Det. & Add Gilmer Basin Dry Detention Forebay

The following list contains examples of potential projects, identified in the master plan, currently under consideration to reduce bacteria loading in the watershed:

Table 6 Potential Septic System Replacement Opportunities Building Design Flow (gal/day) Proposed Treatment Connect to Centralized Duke House/ Sunnyside 1,366 Treatment Connect to Centralized KCRC 767 Treatment

6. Legal authorities such as ordinances, state and other permits, orders, specific contract language, and interjurisdictional agreements applicable to reducing the POCs identified in each respective TMDL (General Permit Section I.B.2.a; DEQ Local Stream TMDL Action Plan Guidance Document, Item 6)

The University of Virginia owns, operates and maintains its own small MS4. The entirety of UVA’s MS4 is located on UVA owned property. The Facilities Management Department at the University has developed a comprehensive stormwater program and is responsible for enforcement and compliance with the standards of the Clean Water Act under the General Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems. The requirements stipulated in the University’s Annual Standards & Specifications (AS&S) for Stormwater Management and Erosion and Sediment Control (SWM/E&SC) along with their MS4 program plan provide the authority to enforce the Special Conditions for approved TMDLs in accordance with the General Permit. In addition, Facilities Management applies a stormwater utility fee to all supported departments, the medical center, and auxiliary entities in order to establish a renewable funding source to maintain the stormwater program.

All projects on UVA property involving land-disturbing activity subject to Virginia SWM/E&SC Laws and Regulations are bound by the UVA AS&S for SWM/E&SC. UVA’s AS&S have been developed to ensure that all land-disturbing activities undertaken by UVA will proceed in accordance with all applicable laws and regulations as related to municipal separate storm sewer systems and land disturbing activities. UVA’s AS&S for SWM/E&SC are approved by DEQ and are composed of general specifications. The general specifications that apply to the land- disturbing activities include the following:

1. Virginia Stormwater Management Act (§62.1-44.15:24-50) 2. Virginia Stormwater Management Program (VSMP) Regulations (9VAC25-870) 3. General Permit for Discharges of Stormwater from Construction Activities (9VAC25-880) 4. General Permit for Discharges of Stormwater from Small MS4s (9VAC25-890) 5. Virginia Stormwater BMP Clearinghouse (http://vwrrc.vt.edu/SWC/index.html) 6. Virginia Erosion and Sediment Control Law (§62.1-44.15:51-66) 7. Virginia Erosion and Sediment Control Regulations (9VAC25-840) 8. Virginia Erosion and Sediment Control Certification Regulations (9VAC25-850) 9. Virginia Erosion and Sediment Control Handbook, 1992 10. E&SC Technical Bulletins, as amended (http://www.deq.state.va.us/Programs/Water/StormwaterManagement/Publications.as px)

Additionally, in order for the University to discharge its stormwater into state surface waters, the University is required to have a General Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4). The MS4 permit requires the University to implement pollution control measures addressing the following six program areas in order to minimize the amount of pollution entering state waterways:

1. Public Education and Outreach 2. Public Involvement/Participation 3. Illicit Discharge Detection and Elimination 4. Construction Site Stormwater Runoff Control 5. Post-Construction Stormwater Management 6. Pollution Prevention/Good Housekeeping

Refer to http://www.fm.virginia.edu/docs/operations/UVaMS4ProgramPlan.pdf for the current MS4 Program Plan.

UVA also completed a Stormwater Master Plan update in 2015 which reviewed the existing regulatory requirements that shape University strategy for implementation and compliance to future development. This Master Plan addressed the TMDL compliance issues within each cycle of the General Permit and outlined planning considerations and potential projects for various situations and the associated pollutant removal methods.

7. Enhancements to public education, outreach, and employee training programs to also promote methods to eliminate and reduce discharges of the POCs for which a WLA has been assigned (General Permit Section I.B.2.c; DEQ Local Stream TMDL Action Plan Guidance Document, Item 7)

Education, Outreach and Public Participation Program One of the most important and effective BMPs in controlling and reducing sediment and bacteria in local streams is the Education and Outreach program at the University.

In addition to the programs and initiatives organized or supported by UVA to promote healthy waterways, the University is also able to take advantage of the services and activities supported by the Rivanna Stormwater Education Partnership (RSEP), as a founding member and sponsor. RSEP is a collaborative effort among local MS4 permit holders to provide public education, outreach and opportunities for participation in stormwater related issues in the area to help improve local water quality.

Many students, faculty, and staff live in the areas targeted by RSEP campaigns. In this way, UVA is able to convey the same stormwater related messages at the University which are also promoted in the local community, further reinforcing their importance beyond jurisdictional or MS4 boundaries.

The objective of all public education and outreach efforts, whether they are implemented by the University directly or as part of RSEP are to 1) focus public outreach campaigns to address the viewpoints and concerns of target audiences and 2) utilize diverse media (including TV and radio PSAs, print ads, flyers on buses, mailings, etc.) to increase public awareness about stormwater pollution prevention.

The University’s Environmental Resources division maintains a webpage (http://www.fm.virginia.edu/depts/operations/environmental/index.html) which provides information on stormwater, best management practices, the University’s MS4 permit, TMDLs and a link to the RSEP website. RSEP‘s website (http://www.rivanna-stormwater.org/), provides links to public service announcements, publications, stormwater education articles as well as videos, and other useful stormwater pollution prevention related tools. Both the University’s and the RSEP’s webpage also provide methods for the public to report illicit discharges.

Some of the resources or publications that are available on the RSEP website include:

• Rain, Runoff and Your Backyard Pamphlet • Raingarden Brochure • Septic System Information Brochure • Stormwater Runoff Management Brochure • Vehicle Washing Brochure • Pet Waste Education Initiative Pamphlet • RSEP Stormwater PSA Video • After the Storm (EPA) Video • Prevent Storm Drain Pollution Video • “Dog Doogity” Dog Waste PSA Video

Employee Training Programs Another way that the University helps prevent or reduce the release of pollutants to stormwater is through employee training. All training presentations are updated yearly and incorporate specific language for both sediment and bacteria with respect to stormwater pollution. In addition, other environmentally related topics are covered in order to minimize impacts to stormwater from UVA operations. Customized presentations are made to all of the operations staff at the University and the associated auxiliary departments whose job responsibilities may have the potential to impact stormwater.

At a minimum, each presentation includes information about spill prevention, stormwater pollution prevention and reviews the specifics of the illicit discharge detection and elimination program. The training focuses on stormwater pollution prevention programs, recommendations for good housekeeping practices, standard operating procedures (SOPs), proper erosion and sediment control practices on construction sites, and the importance of post construction stormwater management and BMPs. Presentations are made in the classroom setting and are reinforced with site visits in the field.

Table 7 UVA Training Plan and Frequency Stormwater Hazardous Pollution SPCC Plan and Radioactive Targeted Staff / Department and Chemical Prevention / Spill Waste Waste Good Response Housekeeping Athletics Annually Annually Building Services Annually Health System Physical Plant Annually Annually Heat Plant Annually Annually Intramural-Recreation Sports Annually Landscaping Annually Annually New Employees Upon hire Parking and Transportation Annually Annually Parking and Transportation Student Drivers Upon hire Recycling Annually Annually Utilities System Distribution Annually Annually Researchers, students, and faculty who work with or dispose of chemical waste in laboratories (Identified by EHS) Upon hire Researchers, students, and faculty who work with radioactive material in laboratories (Identified by EHS) Annually Annually

8. A schedule of interim milestones and implementation of the items in 5, 6, and 7 (General Permit Section I.B.1.b; DEQ Local Stream TMDL Action Plan Guidance Document, Item 8)

The University is committed to using a variety of management practices and control techniques for the purposes of reducing the pollutants identified in the WLAs. The University intends to use an adaptive iterative approach for the implementation of these BMPs and milestones over multiple permit cycles, as referenced in the MS4 General Permit, Section I.B.1, and in the Guidance Memo. These milestones or schedules may need to be modified in order to achieve the POC reductions necessary to restore the water quality of the Rivanna River, and ultimately removing the impairment listing.

Table 8 Best Management Practices and Implementation Schedule BMP/ Scheduled Completion/ Milestone Item Description Frequency BMP 1 Websites and Social Media Update as needed BMP 2 Public Awareness Events At least 4 annually BMP 3 Rivanna Stormwater Education Partnership Member Ongoing BMP 4 Advertising Semi - Annually BMP 5 Utility Bill Mailings Annually BMP 6 Educational Lectures At least 2 annually BMP 7 Stream Cleanups At least 1 annually BMP 8 Illicit Discharge Program As needed / annually BMP 9 Stormwater Stenciling Program As needed / ongoing BMP 10 MS4 Outfall Inspections/Dry Weather Discharge Inspections Annually BMP 11 Inflow and Infiltration Detection As needed / annually BMP 12 Sanitary Sewer Overflow Response Team As needed BMP 13 Erosion and Sediment Control Program Ongoing / annually BMP 14 VSMP and Construction General Permit Ongoing / annually BMP 15 E&SC Construction Site Inspections As needed / annually BMP 16 Stormwater Management Master Plan Ongoing / annually BMP 17 Stormwater Management Project Review As needed / ongoing BMP 18 Structural BMPs As needed / ongoing BMP 19 Stormwater Management Facility Inspections Monthly BMP 20 Street Sweeping and Vacuuming At least 2 annually BMP 21 Municipal Facility Pollution Prevention and Good Housekeeping Ongoing/ annually BMP 22 Annual Staff Training Plan Annually BMP 23 Rivanna Conservation Alliance - Science Advisory Board Member Ongoing Milestone 1 Combined Benthic and Bacteria(Local) TMDL Action Plan to DEQ October 2016 Initiate Water Quality Monitoring Program with Third Party February 2017 / Milestone 2 ongoing Milestone 3 Evaluate Water Quality Monitoring Program Annually Milestone 4 Identify Proposed BMPs for Upcoming Permit Cycle January 2018

9. Methods to assess TMDL Action Plans for their effectiveness in reducing the pollutants identified in the WLAs (General Permit Section I.B.2.e; DEQ Local Stream TMDL Action Plan Guidance Document, Item 9)

The University plans on utilizing two separate methods to assess the effectiveness of this combined TMDL action plan.

Benthic TMDL UVA will model sediment load reductions pursuant to the Chesapeake Bay TMDL Action Plan Guidance Document published by DEQ (Guidance Memo No. 15-2005) as well as any additional guidance received from DEQ to track both the effectiveness and progress toward the TMDL requirement. The Guidance Memo (for Local TMDLs) indicates that

“[p]ermittees may refer to the Chesapeake Bay TMDL Action Plan Guidance (GM14- 2002) for strategies and information on how to calculate reductions from BMPs in watersheds with local nutrient and sediment TMDLs.”

This sediment reduction modeling and accounting program will include any reductions of sediment loads from BMPs within the regulated MS4 boundary and will include the facilities identified in Section 4 of this report.

DEQ Staff have indicated that using the edge of stream sediment loading rates provided in The Chesapeake Bay TMDL Action Plan Guidance Document Table 2a is not acceptable. These loading rates reflect average sediment delivery into the Chesapeake Bay (not the Rivanna River) as a function of land use type. DEQ staff have recommended that a generalized loading rate of 0.3lbs/day/acre to model land-based sediment loads should be used. The loading rate of 0.3 lbs/day/acre is the average loading rate per acre for UVA, Albemarle County, and the City of Charlottesville’s MS4 areas outlined in the Benthic TMDL Development for the Rivanna River Watershed, Final Report (dated March 2008).

Bacteria TMDL The University plans to rely on an existing local water quality monitoring program, organized by the Rivanna Conservation Alliance (RCA) (formerly Stream Watch) to track and assess the effectiveness in bacteria reductions. The University currently has access to the testing results for this program which collects monthly samples (February to October) at several outfall locations that discharge to the Rivanna River. Many of these sampling locations are directly downstream of the University’s MS4 boundary and are mapped on RCA’s website (http://www.rivannariver.org/bacteria/). These water quality samples are monitored for E.coli using Coliscan© Easygel.

The University, Albemarle County (the County), and the City of Charlottesville (the City), have begun coordination to determine how RCA’s existing bacteria sampling program may be used and potentially augmented to assess bacteria reductions along impaired reaches. The

University, in cooperation with the County and the City, will analyze the data to recognize trends and make any adjustments in the program as necessary to achieve the required reduction thresholds. The University also plans to use this water quality data to identify and mitigate potential sources of pollutants.

All results will be included in the University’s Annual Report submitted to DEQ.

10. Measurable goals and the metrics that the permittee and Department will use to track those goals (and the milestones required by the permit) (General Permit Section I.B.1.b; DEQ Local Stream TMDL Action Plan Guidance Document, Item 10)

As a part of the MS4 Annual Report, the University will incorporate the progress and completion of the interim milestones and BMPs listed in Section 8 of this Action Plan. All accounting and monitoring results obtained will be provided with respect to the associated proposed schedule. In accordance with the MS4 General Permit, the University will utilize an adaptive iterative approach to implement this action plan, in order to progressively reduce the discharge of the identified POCs over multiple subsequent permit cycles. Therefore, this plan may be changed or adjusted as necessary in order to achieve the assigned WLAs.

Appendix A

Rivanna River Benthic Impaired Segments and Delineated Watershed

D D LYNC Y H R R IV D U ER O N BU Y C L K B E M E R S O E U AV IV R N E R N R IV T D A A U S E IN M C R N R RE K E N C U A R T R M E F E I H R K S O P W P R I S R O N E A E M Y C M D K R D E Y R E N U C O K R R F JACOBS K K RUN E H L E R E T E E O K R C R C O K Y N G

C N R I E W H E A IS K R M DS F OOR C MANS RIVER RE EK

K E E R C R G BRA L FLAN IGAN BRA E N N L F N IV I O N R P C E ST E C S M H W R M B H U O R PO B U J A W E H P NC E A C H L V E LS E M C R CREEK VAV-H28R-01 R E K REDBUD E EE C LICK K R R IN C C E GH W R E O EK Y O E K L E CRE IV D E A K E M VAV-H29R-01 K OCKTON CREE EK C E ST R A C

R K R N K O U EE L H CR REEK H LLINS S C L C DO E C C E R N O A M O R IV R M A N R N E

B E A N K U W R O R IV C E T I H R

U O DDLE U MI C BRAN L C C S E H H I E I B N N J S O O C R N R T E E H S E C K H F R ANC O E K BR RK E E H HA K E T RD R U W C O A ND S R LA E M IS K R U I C V R BU E P R SOUTH H F Y ORK HA RDWARE RIVER C

H R C E N H E A H A K R NC B RA R ER B D N Legend M M ER K W U A V E A R H A E R E Y E R E K VAV-H29R-01 B C R K R S K IV U E E E ER T VAV-H28R-01 E E G P R R P C R E S C E A Streams E OM E N TO TH V C TIE Rivanna River Watershed O R R C E C

Source: Figure 1-1: Benthic TMDL 0 1.5 3 Development for the Rivanna River Rivanna River Benthic Impaired Miles Watershed, Final Report Geospatial Engineering Services (dated March 2008) 1490 Leake Drive Segments and Delineated Watershed Charlottesville, VA 22904 Date: 7/1/2016 [email protected]

Appendix B

Location of Bacteria Impaired Segments of the Rivanna River mainstem, North Fork Rivanna River, Preddy Creek and tributaries, Meadow Creek, Mechums River, and Beaver Creek Watersheds

D D LYNC Y H R R IV Preddy Creek and Tribs D U ER O N BU Y C L K B VAV-H27R_PRD01A00 E M E R S O E U AV IV R N E R N R IV T D A A U S E IN M C R N R RE K E N C U A R T R M E F E I H R K S O N.F. PRivanna River W P R I S R O N E A E M Y VAV-H27C R-RRN01A00 M D K R D E Y R E N U C O K R R F JACOBS K K RUN E H L E R E T E E O K R C R C O K Y N G

C N R I E W H E A IS K R M DS F OOR C MANS RIVER RE EK Beaver Creek K E E VAV-H23R-BVR02A04 R C R G BRA L FLAN IGAN BRA E N N L F N MeIVadow Creek I O N R P C E ST E C S M H W R M B H U O R PO B U VAV-H28R-MWCJ 01A00 A W E H P NC E A C H L V E LS E M C R CREEK R E K REDBUD E EE C LICK K R R IN C C E GH W R E O EK Y O E K L E CRE IV D E A K E M

K OCKTON CREE EK C E ST Rivanna River R A C

R K VAV-H28R- R VN01A0N0 K O U EE L H CR REEK H LLINS S C L C DO E C C E R N O A M O R IV R M A N R N E

B E A N K U W R O R IV C E T I H R

U O DDLE U MI C BRAN L C C S E H H I E I B N N J S O O C R N R T E E H S E C K H F R ANC O E K BR RK E E H HA K E T RD R MechUums River W C O A ND S R LA VAV-H23R-MCM01A00 E M IS K R U I C V R BU E P R SOUTH H F Y ORK HA RDWARE RIVER C

H R C E N H E A H A K R NC B RA R ER B D N M M ER K W U A V E A R H A E R E Y E R E K Legend B C R K R S K IV U E E E ER T 303d Listed Segment E E G P R R P C R E S C E A Streams E OM E N TO TH V C TIE Rivanna River Watershed O R R C E C

Source: Figure 1-1: Bacteria TMDL Development Location of Bacteria Impaired Segments of the 0 1.5 3 for the Rivanna River Mainstem, North Fork Rivanna River, Preddy Creek and Tributaries, Meadow Creek, Rivanna River mainstem, North Fork Rivanna Miles Mechums River, and Beaver Creek Watersheds Geospatial Engineering Services (dated March 2008) River, Preddy Creek and tributaries, Meadow 1490 Leake Drive Charlottesville, VA 22904 Date: 7/1/2016 Creek, Mechums River, and Beaver Creek Watersheds [email protected]

Appendix C

Potential Sources of Significant POCs

Potential Sources of Significant POC(s) STID / MS4 Item Outfall Site Name / Location Pollutant of Concern Site Condition 1 STUV390305 Emergency Communications Center Sediment Stable 2 STUV390320 KCRC Sediment and Bacteria Stable. No Depositions (E.coli) 3 STUV390325 Police Building Sediment Stable 4 STUV390367 Nuclear Reactor - East 1 Sediment Stable 5 STUV390375 Stadium Road 2504 - East Sediment Stable 6 STUV390380 Stadium Road 2504 - West Sediment Stable 7 STUV390405 Stadium Road 2504 - North Sediment Stable 8 STUV390410 Piedmont Housing - North Sediment Stable 9 STUV390465 FM Yard Sediment and Bacteria Stable. No Depositions (E.coli) 10 STUV390480 Alderman Road Pumping Station Sediment and Bacteria Stable. No Depositions (E.coli) 11 STUV390495 Gilmer Hall Sediment Stable 12 STUV390497 Biology Greenhouse - West Sediment and Bacteria Stable. No Depositions (E.coli) 13 STUV390500 Biology Greenhouse - East Sediment and Bacteria Stable. No Depositions (E.coli) 14 STUV390501 McCormick Road Chiller Plant - Chemistry Sediment Stable 15 STUV390510 Courtenay House Sediment Stable 16 STUV390550 Scott Stadium Parking - West Sediment Stable 17 STUV390615 Piedmont Housing - South Sediment Stable 18 STUV390820 Emmet/Ivy Parking Garage Sediment Stable 19 STUV391040 Stone Hall Sediment Stable 20 STUV391050 Nuclear Reactor - East 2 Sediment Stable 21 STUV391060 Nuclear Reactor - South Sediment Stable 22 STUV590035 Printing Service Center Sediment Stable 23 STUV590045 Darden Parking Garage - North Sediment Stable 24 STUV590075 Darden Center - West Sediment Stable 25 STUV590110 Copeley Apartments #28 - Massie Road Sediment Stable 26 STUV590131 Faulkner House Sediment Stable 27 STUV590140 JAG School - North Sediment Stable 28 STUV590160 JAG School - West Sediment Stable 29 STUV590170 Copeley Mech. Plant Pumping Station - East Sediment Stable 30 STUV590215 Distillery Branch - West 2 Sediment Stable 31 STUV590270 The Park - Parking Lot - North Sediment and Bacteria Stable. No Depositions (E.coli) 32 STUV590285 The Park - Softball Field - West Sediment and Bacteria Stable. No Depositions (E.coli) 33 STUV590295 Lambeth Access Road - North Sediment Stable 34 STUV590297 Lambeth Access Road - South Sediment Stable 35 STUV590300 Lambeth Field Housing - South Sediment Stable 36 STUV590310 Culbreth Road Parking Garage Sediment Stable 37 STUV590830 Copeley Substation - West Sediment Stable 38 STUV591030 Goodwin Pedestrian Bridge Sediment Stable 39 STUV591100 Darden Classroom - Leonard Sandridge Rd. Sediment Stable 40 STUV591195 JPJ Arena - Meadow Creek - North Sediment Stable 41 STUV790015 South Parking Garage Sediment and Bacteria Stable. No Depositions (E.coli) 42 STUV790595 Bice House Sediment Stable 43 STUV790640 Cavalier Substation Sediment Stable 44 STUV790655 Outpatient Surgery Center Sediment Stable 45 STUV790660 VASC Parking Sediment Stable 46 STUV792930 FM Landscape Shop - West Sediment Stable 47 STUV792935 The Park - Softball Field - North Sediment and Bacteria Stable. No Depositions (E.coli) 48 STUV792940 The Park - Softball Field - East Sediment and Bacteria Stable. No Depositions (E.coli) 49 STUV792945 Motorcycle Storage Sediment Stable

Potential Sources of Significant POC(s) STID / MS4 Item Outfall Site Name / Location Pollutant of Concern Site Condition 50 STUV792950 Lambeth Parking Lot - North Sediment Stable 51 STUV792955 Lambeth Parking Lot - South Sediment Stable 52 STUV792960 Carr's Hill Chiller Plant - East Sediment Stable 53 STUV792965 Carr's Hill Chiller Plant - West Sediment Stable 54 STUV792970 Distillery Branch - East Sediment Stable 55 STUV792975 Copeley Road/ Seymour Road Intersection Sediment Stable 56 STUV792985 JPJ Arena - Meadow Creek - South Sediment Stable 57 STUV792990 JPJ Water Quality Swale - East Sediment Stable 58 STUV793080 Distillery Branch - West 1 Sediment Stable 59 Facilities Management Yard Sediment Stable 60 Old Ivy Road/ Fontana Storage Yard Sediment Stable 61 Ruffin Hall - Art School Project Yard Sediment Stable 62 Campbell Hall - Architecture Project Yard Sediment Stable 63 Main Heat Plant (FM Yard) Sediment Stable 64 North Grounds Mechanical Plant (FM Yard) Sediment Stable 65 Recycle Center Bacteria No Depositions (E.coli) 66 Hospital Loading Dock/ Transfer Area Bacteria No Depositions (E.coli) 67 Fontaine Compost Site Sediment and Bacteria Stable. No Depositions (E.coli) 68 Davenport/ Klockner/ Lannigan Sports Fields Sediment Stable 69 Scott Stadium Sediment Stable 70 The Park Bacteria No Depositions (E.coli) 71 Health Systems Pond Bacteria No Depositions (E.coli) 72 Dell Pond Bacteria No Depositions (E.coli) 73 Emmet/ Ivy Pond Bacteria No Depositions (E.coli) 74 KCRC Septic System Bacteria No Depositions (E.coli) 75 Duke House Septic System Bacteria No Depositions (E.coli)

Tjaglcs School Addition 0534 Tjaglcs School 0532 Darden Parking Garage Slaughter Hall 0555 0528 Abbott Center Withers-Brown Hall 0553 0527 Darden Classroom Sponsors Hall West 0551 0556 Darden Faculty Parking & Transit 0552 North Grounds Recreation Addition 0583 5562 Ivy Road 2405 (Piedmont Center) NO North Grounds Recreation Ctr 3579 5561

Carruthers Hall 0580

Printing Service Center 0596

Fontana Food Center 0595 Arena Parking Garage 5575 Klockner Stadium 5502 John Paul Jones Arena Baseball Stadium 5574 KCRC Children's Rehab Center 5506 1600 Frank C. McCue III Ctr University Hall 5577 5576 Onesty Hall 5592 George Welsh Indoor Practice Facility 5591

Emmet/Ivy Garage 0401

Culbreth Road Garage 0446 Drama Education Building 0442

Campbell Hall 0438 Shelburne Hall/Highway Research Alumni Hall NO 0261 3432 Memorial Gymnasium 5087 Stone Hall (NRAO) 0254 Alderman Library Bookstore/Central Grounds Parking 0082 0125 Newcomb Hall Rotunda Astronomy Building 0122 0252 0001 Slaughter Recreation Center Ruffner Hall Ohill Dining Facility Monroe Hall 5262 0201 0260 0083 Gilmer Hall Physics/J Beams Lab Medical School Bldg 0210 0221 Clinical Department Wing 1181 Gibbons House Chemistry Building 1176 Stacey Hall Multistory Building 2375 0256 1985 Clark Hall 1172 Aquatic & Fitness Center Wilsdorf Hall Thornton Hall Old Cabell Hall Robertson Hall Emily Couric Clinical Cancer Center 0068 McKim Hall 5271 0267 0204 0059 0057 1146 Republic/W Main 853 NO 1195 Mechanical Engineering New Cabell Hall Cobb Hall 11th Street Parking Garage 3990 Olsson Hall 0259 0060 1194 1149 0202 Jordan Hall East Parking Garage Rice Hall Elson Student Health Center 1142 1148 0214 0131 Primary Care Center University Hospital 1143 Bryant Hall At Scott Stadium 1150 5280 Medical Research Lab (MR-4) Scott Stadium Stadium Parking Garage South Parking Garage 1157 5307 0315 1154 Carter-Harrison Research Building (MR-6) 1161 UVA Outpatient Surgery Center W Scott Stadium Parking 3708 Legend Runk Dining Hall 0319 0396 PollutantOfConcern

Bacteria

Sediment

Sediment and Bacteria

MS4 Boundary Ray C. Hunt Drive 400 3759

This map was prepared in accordance with National Map Accuracy Standards, using Virginia State Plane coordinates, South Zone, 0 600 1,200 and North American Datum 1983 (NAD83). Feet The data in the drawing is based on the best available Geospatial Engineering Services information. Absolute accuracy is not guaranteed. Field 1490 Leake Drive verification recommended for exact dimensions. Potential Sources of POCs Charlottesville, VA 22904 Date: 7/1/2016 [email protected]