M RIVANNA RIVER

SEDIMENT TMDL

ACTION PLAN (2013‐2018 MS4 General Permit)

A Plan for Achieving Sediment Load Reductions to Meet PVCC’s TMDL Waste Load Allocation

July 1, 2016

This document addresses Section 1, Part B of the General Pollution Discharge Elimination System (VPDES) Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4). This document serves as a campus-specific Total Maximum Daily Load (TMDL) Action Plan to identify the best management practices and other interim milestone activities to be implemented to address the sediment waste load allocation (WLA) assigned to PVCC’s regulated EEE Consulting, Inc. MS4 area in the “Benthic TMDL Development for the Rivanna River Watershed, Virginia” approved by the State Water Control Board on April 27, 2009. Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

Executive Summary

Piedmont Virginia Community College (PVCC) is authorized to discharge stormwater from its municipal separate storm sewer system (MS4) under the Virginia Pollutant Discharge Elimination System (VPDES) General Permit for Discharge of Stormwater from Small MS4s (MS4 General Permit). To maintain permit compliance, PVCC implements an MS4 Program Plan that includes best management practices (BMPs) to address six minimum control measures (MCMs) and special conditions for the “Benthic Total Maximum Daily Load (TMDL) Development for the Rivanna River Watershed, Virginia.” The Benthic TMDL for the Rivanna River Watershed, approved by the State Water Control Board on April 27, 2009, was required to be developed under the authority of the Clean Water Act (CWA) in response to the river’s listing as impaired by the Department of Environmental Quality (DEQ) for not meeting water quality standards.

The Environmental Protection Agency (EPA) describes a TMDL as a “pollution diet” that identifies the maximum amount of a pollutant the waterway can receive and still meet water quality standards. In the case of the Rivanna River Watershed Benthic TMDL, sediment was identified as a pollutant of concern and MS4s within the watershed were assigned a waste load allocation (WLA). The WLA determines the allowable pollutant loadings from the MS4s to meet water quality standards. The existing daily load of sediment calculated for PVCC’s MS4 is 7lbs/day from land‐ based sources and 21 lbs/day for in‐stream sediment erosion. PVCC is assigned a WLA of 12 lbs/day in order to meet the TMDL goals, representing a 59.3% reduction of existing loads. The MS4 General Permit serves as the regulatory mechanism for addressing the load reductions described in the TMDL, predominantly through the requirement of a TMDL Action Plan.

The PVCC 25‐year Stormwater Master Plan, developed as a separate effort, demonstrates that 80% of the sediment reduction required by the TMDL will be achieved through the installation of a regional retention pond. Consistent with an approach taken by numerous MS4s throughout the country to achieve sediment load reductions, this Action Plan identifies street sweeping as the primary practice to achieve the remaining 20% reduction. This Action Plan addresses each of the special conditions described in the MS4 General Permit and defines scheduled steps that will be taken to achieve the sediment load reduction target through:  Implementation of the campus’s MS4 Program Plan and Stormwater Master Plan, and  A defined Street Sweeping Program that includes collected material sampling, documentation and tracking of areas swept and targeting of areas for sweeping.

Implementation of this Action Plan is consistent with the provisions of an iterative MS4 Program, which constitutes compliance with the MS4 General Permit standard of reducing pollutants to the maximum extent practicable (MEP).

i Piedmont Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

Table of Contents Executive Summary ...... i 1.0 Introduction and Purpose ...... 1 1.1 TMDL Maximum Daily Loads ...... 2 1.2 PVCC’s Applicable Sediment TMDL ...... 3 1.3 MS4 General Permit Special Conditions ...... 4 2.0 PVCC’s Sediment Action Plan ...... 5 2.1 Site Characterization for Sources of Sediment ...... 5 2.2 Current Legal Authority ...... 5 2.3 Additional Practices and Controls ...... 7 2.3.1 Stormwater Facility ...... 7 2.3.2 Street Sweeping ...... 7 2.4 Enhanced Public Outreach & Employee Training ...... 9 3.0 Plan Implementation ...... 10 3.1 Street Sweeping Schedule ...... 10

Appendices Appendix A: Sediment Reduction Tracking Summary Appendix B: Enhanced Street Sweeping Program Schedule

ii Piedmont Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

Acronyms BMP Best Management Practice CWA Clean Water Act DEQ Virginia Department of Environmental Quality EPA Environmental Protection Agency GIS Geographic Information System IDDE Illicit Discharge Detection and Elimination IP Implementation Plan LA Load Allocation MCM Minimum Control Measure MEP Maximum Extent Practicable MOS Margin of Safety MS4 Municipal Separate Storm Sewer System MS4 GP General Permit for Discharge of Stormwater from Small MS4s NPDES National Pollutant Discharge Elimination System PVCC Piedmont Virginia Community College SWCB State Water Control Board SWM Stormwater Management SWPPP Stormwater Pollution Prevention Plan TMDL Total Maximum Daily Load VPDES Virginia Pollutant Discharge Elimination System VSMP Virginia Stormwater Management Program WLA Wasteload Allocation

iii Piedmont Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

1.0 Introduction and Purpose

Mandated by Congress under the Clean Water Act (CWA), the National Pollutant Discharge Elimination System (NPDES) storm water program includes the Municipal Separate Storm Sewer System (MS4), Construction, and Industrial General Permits. In Virginia, the NPDES Program is administered by the Department of Environmental Quality (DEQ) through the Virginia Stormwater Management Program (VSMP) and the Virginia Pollutant Discharge Elimination System (VPDES). Piedmont Virginia Community College (PVCC) in Albemarle County, Virginia, is authorized to discharge stormwater from its MS4 under the VPDES General Permit for Discharge of Stormwater from Small MS4s (MS4 GP). As part of the permit authorization, PVCC developed and implements an MS4 Program Plan that includes best management practices (BMPs) to address the six minimum control measures (MCMs) and special conditions for applicable total maximum daily loads (TMDLs) outlined in the MS4 GP. Implementation of these BMPs is consistent with the provisions of an iterative MS4 Program, which constitutes compliance with the standard of reducing pollutants to the "maximum extent practicable,” or MEP.

The Virginia Department of Environmental Quality (DEQ) listed segments of the Rivanna River (1996, 2006) in the piedmont area of central Virginia on their biennial 303(d) Total Maximum Daily Load (TMDL) Priority List and Report due to violations of the General Standard for water quality (benthic impairment). The watershed study subsequently identified excessive sediment as the cause of the benthic impariment. As a consequence, the Virginia DEQ developed the “Benthic TMDL Development for the Rivanna River Watershed” approved by the State Water Control Board (SWCB) on April 27, 2009.

The TMDL assigns PVCC a WLA for sediment loads to the Rivanna River watershed. The WLA represents the allowable load from PVCC’s municipal separate storm sewer system (MS4) to prevent instances of exceedance of water quality standards. The WLA for PVCC was assigned to be 12 lbs/day. This represents a 59.3% reduction from the existing condition.

PVCC operates an MS4 within a census urbanized area and is therefore required to maintain compliance with its General Virginia Pollution Discharge Elimination System (VPDES) Permit for Discharges of Stormwater from the Small MS4. The permit requires an operator to implement an MS4 Program Plan that includes six minimum control measures (MCMs) to reduce the discharge of pollutants from its MS4 to the maximum extent practicable (MEP). The Program Plan must also include a specific TMDL Action Plan for pollutants allocated to the MS4 in an approved TMDL. Since PVCC was assigned a WLA for sediment, it is therefore required to be

1 Piedmont Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

consistent with special conditions in the permit. The special conditions generally require an Action Plan to incorporate:

 An identification and assessment of facilities that are owned and operated by the MS4, not covered under a separate VPDES permit, with the potential to be significant sources of sediment discharge to the MS4;  A list of legal authorities applicable to reducing discharge of sediment from the MS4;  A list of management practices and controls, in addition to the MCMs otherwise required by the MS4 General Permit, that are implemented as part of PVCC’s MS4 Program and applicable to reductions in sediment discharge from the MS4;  Promotion of methods to eliminate or reduce discharges of sediment into PVCC’s MS4 through PVCC’s Public Education and Outreach Plan and employee training program;  A methodology to assess the effectiveness of PVCC’s Action Plan in reducing the discharge of sediment from its MS4.

The purpose of this Action Plan is to address each of the MS4 General Permit special conditions listed above. As an adaptive and iterative approach to meet surface water quality goals, the Action Plan may be revised from time to time to reduce sediment discharges from PVCC’s MS4 to the MEP. The Action Plan is incorporated, by reference, into PVCC’s MS4 Program Plan, which outlines the BMPs that address the entirety of the conditions set forth in the MS4 General Permit. PVCC’s MS4 Program Plan is available electronically at the PVCC Stormwater Webpage.

1.1 TMDL Maximum Daily Loads

A TMDL is the total maximum daily load, or the amount of pollutant a water body can assimilate and still meet water quality standards for its designated use. Subsequent to being listed as impaired, the TMDL with sediment loading limits was developed by DEQ for the Rivanna River.

Typically, TMDLs are represented numerically in three main components:

 Wasteload Allocations (WLA) for point source contributions,  Load Allocations (LA) for non‐point source contributions, and a  Margin of Safety (MOS).

Point source pollution is any single identifiable source from which pollutants are discharged. If point source discharges, including a permitted MS4, are present in the TMDL watershed, then any allocations assigned to that permittee must be in the form of a WLA. PVCC’s MS4 outfalls, as a point source, fall under this category in the TMDL. Pollution that is not from an identifiable source, such as a pipe or a ditch, but rather originates from multiple sources over a relatively large area it is considered to be non‐point source pollution. For sediment loads, it is broken into land‐based sources and instream erosion sources based on hydrologic input. The Margin of Safety (MOS) is a required component that accounts for the uncertainty in the response of the waterbody to loading reductions, and it was implicitly incorporated into the TMDL for the watershed.

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The TMDL is expressed in the following equation:

TMDL = ∑ WLA + ∑ LA + MOS

The TMDL represents the sum of calculable sources plus a margin of safety that is required to not exceed the state water quality General Standard. This standard states the following:

“All state waters, including wetlands, shall be free from substances attributable to sewage, industrial waste, or other waste concentrations, amounts, or combinations which contravene established standards or interfere directly or indirectly with designated uses of such water or which are inimical or harmful to human, animal, plant, or aquatic life.”

Excess sediment, resulting in a benthic impairment, interferes with fish and insect life cycles, and specifically in the TMDL this refers to impaired benthic invertebrate communities.

1.2 PVCC’s Applicable Sediment TMDL

The Rivanna River TMDL wasteload allocations for MS4s are land area based and apply to all MS4s in the TMDL watershed, including PVCC, City of Charlottesville, Virginia Department of Transportation (VDOT), University of Virginia, and Albemarle County MS4s. The TMDL directs that the WLA is achieved with a “Percent Reduction Method” that compares water quality data to applicable water quality criteria. It identifies a percent reduction of the current sediment load required to meet water quality standards for the watershed.

The Rivanna River TMDL describes a modeling approach that used a modified reference watershed, where data from several unimpaired watersheds defines the TMDL endpoint. Data was collected from several DEQ monitoring stations in the Northern Piedmont, Piedmont, and Blue Ridge ecoregions, and in similar 4th order streams to the monitoring stations within the Rivanna River watershed. TMDL endpoints, and the associated WLAs for sediment, were based on High, Moist, Mid‐Range, Dry and Low flow conditions in the unimpaired watersheds, and where such loads would be sufficient for benthic community recovery in the impaired watershed. An area‐weighted sediment load for land‐based sources was determined for the MS4s and WLAs

A waste load allocation for sediment was assigned to PVCC and was calculated as a combined reduction from land‐based and instream erosion sources. The total existing load of 29 lbs/day is reduced by 59.3% to 12 lbs/day in order to meet water quality standards. This amount is equivalent to a sediment reduction of 17 lbs/day, or 3.1 tons less per year (6,205 lbs/year). The following sections define how PVCC will achieve this goal.

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1.3 MS4 General Permit Special Conditions

PVCC operates its regulated MS4 within a portion of the Rivanna River TMDL watershed and is therefore subject to the WLAs assigned therein. The special conditions for the TMDL listed in the MS4 General Permit require PVCC to develop a TMDL Action Plan that identifies the BMPs and other interim milestone activities to be implemented during the remaining terms of this state permit that specifically includes:

• A list of legal authorities applicable to reducing sediment loads from the MS4 • A list of management practices and controls, beyond those required within the six minimum control measures of the MS4 General Permit, that are implemented as part of PVCC’s MS4 Program and applicable to reductions in sediment loading from the MS4; • Enhancement of PVCC’s Public Education and Outreach Plan (PEOP) and employee training program to promote methods to eliminate and reduce sediment loading into its MS4; • An identification and assessment of facilities that are owned and operated by the MS4, not covered under a separate VPDES permit, with the potential (greater than the average expected loading) to be significant sources of sediment loading to the MS4; • A methodology to assess the effectiveness of PVCC’s Action Plan in reducing sediment loading from its MS4.

PVCC submits reporting on the implementation of the MS4 program annually to the Virginia DEQ. The TMDL Action Plan shall be submitted with the 2016 Annual Report and in subsequent years when any significant modifications occur. Implementation and measures of effectiveness will be reported annually, as required by PVCCs Program Plan.

4 Piedmont Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

2.0 PVCC’s Sediment Action Plan

The purpose of PVCC’s Action Plan for the Rivanna River TMDL is to address each of the MS4 General Permit special conditions listed in Section 1.3. As an adaptive and iterative approach to meet surface water quality goals, the Action Plan may be revised from time to time to reduce sediment loadings from PVCC’s MS4 to the maximum extent practicable (MEP). The Action Plan is incorporated, by reference, into PVCC’s MS4 Program Plan, which outlines the BMPs that address the entirety of the conditions set forth in the MS4 General Permit.

PVCC’s MS4 Permit covers stormwater discharges from the property. Its collective efforts, as described in the Program Plan and Annual Report, result in significant reduction of pollutants that may be discharged from its regulated MS4. BMPs already included in the PVCC Program Plan that address sediment are described in the following sections. Each subsection is provided to address the referenced special condition in the MS4 General Permit.

2.1 Site Characterization for Sources of Sediment

A field inspection of the PVCC campus did not identify any significant source of sediment other than facilities associated with the campus maintenance operations, such as stockpiling areas, that could potentially release sediment into stormwater runoff. However, the PVCC Good Housekeeping and Pollution Prevention Manual, along with annual staff training, addresses these concerns with the implementation of best management practices. The assessment addresses the following MS4 General Permit Special Condition:

 Assess all significant sources of pollutant(s) from facilities of concern owned and operated by the MS4 operator that are not covered under a separate VPDES permit and identify all municipal facilities that may be a significant source of the identified pollutant. [Section I(B)(2)(b)]

2.2 Current Legal Authority

PVCC’s current MS4 Program provides appropriate policies and procedures to implement a compliant program that is aligned with the goals and requirements of the Creek TMDL. As a non‐traditional MS4, PVCC does not have the ability to create legal authorities and has not identified any legal authorities necessary to meet the requirements of the special conditions. PVCC’s MS4 Program includes Minimum Control Measures that achieve this, as described in the summary below.

This summary addresses the following special condition:

 “Develop and maintain a list of its legal authorities such as ordinances, state and other permits, orders, specific contract

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language, and inter‐jurisdictional agreements applicable to reducing the pollutant identified in each applicable WLA.” [Section I(B)(2)(a)]

 MCM 1 (Public Education and Outreach) – PVCC has incorporated information regarding TMDL POCs into the relevant message of the high‐priority water quality issue #2 in PVCC’s Public Education and Outreach Plan (PEOP). As such, public education and outreach incorporates sediment concerns related to water quality in outreach to the general public.

 MCM 2 (Public Participation) – PVCC will post this Action Plan on the PVCC Stormwater Web Page. Availability of the Action Plan will increase awareness of the TMDL with web page visitors.

 MCM 3 (Illicit Discharge Detection and Elimination) – PVCC’s MS4 Program includes an Illicit Discharge Detection and Elimination (IDDE) Program that includes written procedures to detect, identify, and address non‐stormwater discharges, including illegal dumping, to the small MS4 with policies and procedures for when and how to use legal authorities. PVCC prohibits non‐stormwater discharges into the storm sewer system through language provided within the Standards of Conduct for employees and the Student Handbook for students. IDDE BMPs are described in the Minimum Control Measure 3 BMPs in the PVCC MS4 Program Plan. The IDDE Program is effective at addressing the POC through staff training, prohibition of illicit discharges, and annual outfall screening.

 MCM 4 (Construction Site Runoff Control) – PVCC’s MS4 Program includes a Construction Site Runoff Control Program that includes mechanisms to ensure compliance and enforcement on regulated construction sites with implementation of the DEQ‐approved “VCCS Annual Erosion and Sediment Control and Stormwater Management Standards and Specifications.” The standards and specifications are consistent with the Virginia Erosion and Sediment Control and Stormwater Management Laws and Regulations and includes: o Required plan approval prior to commencement of a regulated land disturbance activity; o Construction site inspections and enforcement; and o Certification of post‐construction stormwater management facilities.

 MCM 5 (Post‐Construction) – PVCC’s MS4 Program includes a Post‐Construction SWM Program that ensures water quality criteria in the Virginia Stormwater Management Regulations has been achieved on new developments and developments on prior developed land. Included among these requirements are written policies and procedures in the “VCCS Annual Erosion and Sediment Control and Stormwater Management Standards and Specifications” to ensure that stormwater management facilities are designed and installed in accordance with appropriate law and regulations. Although the facilities are designed to achieve target phosphorus reductions, many water quality BMPs also are effective at sediment removal. Post‐construction, the Program includes schedules and written procedures to ensure long‐term inspections and maintenance of stormwater management

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BMPs. Minimum Control Measure 5 BMPs in the PVCC MS4 Program Plan describe post‐ construction stormwater management BMPs.

 MCM 6 (Good Housekeeping) – PVCC’s MS4 Program includes a Pollution Prevention/Good Housekeeping Program that includes policies and procedures to ensure that day‐to‐day operations minimize the exposure of pollutants to rainfall on campus grounds to the maximum extent practicable. The program is supported with PVCC’s Pollution Prevention & Good Housekeeping Manual and annual training for applicable staff. Minimum Control Measure 6 BMPs in the PVCC MS4 Program Plan describe pollution prevention and good housekeeping BMPs.

No new policies and procedures or modifications to existing policies and procedures were identified as necessary to meet the requirements of the special conditions.

2.3 Additional Practices and Controls

PVCC proposes a combined approach to meet the reduction defined in the TMDL, beyond what will occur through the implementation of the MS4 Program Plan. Though likely significant, reductions associated with the Program Plan are not quantified and do not have a numerical value that is applicable to the WLA. As such, the stormwater facility outlined in the PVCC 25‐year Stormwater Master Plan and the practice of street sweeping will solely achieve the reductions.

2.3.1 Stormwater Facility

The PVCC 25‐year Stormwater Master Plan demonstrates that a Level 2 wet pond, appropriately sized to meet water quality and quantity standards for the proposed full development of the campus, will also achieve an additional 5,363.2 lbs/year reduction in sediment load downstream. The equivalent reduction is summarized below:

Table 2‐1: Level 2 Wet Pond Sediment Reductions

Annual Required Reduction Annual Level 2 Wet Pond Reduction Percentage Pollutant in Rivanna River TMDL Reduction Achieved with Wet (lbs/yr) (lbs/yr) Pond Sediment 6,205 5,363.2 86.4%

2.3.2 Street Sweeping

PVCC will implement street sweeping in order to satisfy the remaining 13.6% of sediment reductions. It will utilize the “Mass Loading Approach” described in the “ TMDL Special Condition Guidance” (Guidance) provided by DEQ and dated May 18, 2015 for computing total suspended solid load reductions, or sediment for the purposes of this Action Plan. This method is based on actual measurement of collected material from street sweeping. The method provides conversion factors to translate the material collected to sediment by converting the 7 Piedmont Virginia Community College Rivanna River Watershed Sediment TMDL Action Plan

total weight of material collected to a dry weight using a multiplier of 0.7. The dry weight is then translated to sediment with a multiplier of 0.3. This results in a sediment load representing 21% of the total weight of the collected material.

Required reductions and sweeping efforts are summarized below:

Table 2‐2: Street Sweeping Sediment Reductions

13.6% of Annual POC Required Street Sweeping Dry Weight Pollutant Required Reduction Multiplication Material Weight Factor (lbs/yr) Factor (lbs/yr) Sediment 841.8 0.7 0.3 4,008.6

PVCC will develop a regular schedule for street sweeping efforts which will be amended based on seasonal or event‐related accumulation of sediment on its roads, parking areas, sidewalks, and plazas. Consistent with an iterative Program, PVCC will also seek to verify previous estimates of sediment reduction and establish reliable methods for predicting reduction based on future enhancements of the street sweeping program.

Street sweeping efforts will be enhanced with the following action steps, each aimed to increase reduction of sediment loads: 1. Develop improved documentation for tracking areas swept, type of sweeper used, man hours employed, and other information determined relevant for characterization of collected materials. Documentation may include mapping for incorporation of a GIS database. 2. Conduct sampling of collected street sweeping materials to correlate dry weight and sediment fraction to verify computational methods for determining sediment reductions from collected street sweeping material. Sampling will be based on technically defensible analytical methods and be based on environmental and technical variables. 3. Assess PVCC’s current street sweepers to determine their sediment removal efficiencies and cost effectiveness. The assessment will consider alternatives to the current sweeping equipment. 4. Conduct an assessment to identify target areas and optimal frequency of sweeping based on areas swept that produce the largest yield of sediment collected per acre and variables identified as the result of implementation of Step 2. The assessment will consider types of locations swept, time span between sweeping, and weather conditions at the time of sweeping. 5. Concentrate sweeping in areas identified as target areas from implementation of Step 4 at the optimal frequencies identified in the evaluation. Additional areas for sweeping will be identified, if necessary.

The action steps identified above are intended to serve as a defined method that inherently aids as an adaptive iterative approach to achieve the WLA.

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This process addresses the following special condition:

 “Identify and maintain an updated list of all additional management practices, control techniques and system design and engineering methods, beyond those identified in Section II V, that have been implemented as part of the MS4 Program Plan that are applicable to reducing the pollutant identified in the WLA.” [Section I(B)(2)(b)]

2.4 Enhanced Public Outreach & Employee Training

PVCC’s MS4 program has enhanced public education and outreach and employee training programs to promote methods to eliminate or reduce the discharge of sediment from the MS4. This enhancement is described as follows:

 PEOP: The Plan incorporates information regarding TMDL POCs, including sediment, into the relevant message of the high‐priority water quality issue #2. The Plan includes annual outreach efforts to the general public with information related to the Rivanna River TMDL, including methods to reduce the discharge of sediment.  Increased Frequency of Employee Training: PVCC’s PEOP also identifies staff as a target audience and requires annual training, a more frequent training schedule than the biennial training required by the MS4 General Permit. Staff training material, PVCC’s Good Housekeeping/Pollution Prevention Manual, includes information regarding TMDL pollutants of concern.

The inclusion of information regarding sediment sources in stormwater runoff into the PEOP and staff training materials addresses the following permit special condition:

 “Enhance [its] public education and outreach and employee training programs to also promote methods to eliminate and reduce discharges of the pollutants identified” [Section I(B)(2)(c)]

For further detail on the PEOP and employee training, PVCC’s MS4 Program Plan and Annual Report are available at the PVCC Stormwater Webpage.

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3.0 Plan Implementation

PVCC will implement the MS4 Program components described to reduce the potential of sediment loading to surface waters to the MEP, including the installation of a new stormwater facility as described in PVCC’s Stormwater Master Plan, as well as a new street sweeping program. The method of assessment is implemented through the annual reporting process with the review of the effectiveness of each MS4 Program Plan BMP, implementation of the master plan and collected sweeper wastes. If necessary after quantification of street sweeping reductions, PVCC will attempt to quantify reductions achieved by programmatic reductions based on research and other methods as additional information becomes available.

Effectiveness of the street sweeping efforts will be measured through explicit accounting of sediment reductions using the “Mass Loading Approach” to convert total material collected into sediment reductions. As the steps in Section 2.3.2 are implemented, the measure of effectiveness will be dependent on the annual average increase in the sum of sediment collection from street sweeping until the WLA is achieved. In the case that reductions decrease in a given year, the difference will be made up in subsequent years. The difference may also be addressed with quantification of reductions achieved with the implementation of PVCC’s MS4 Program Plan. The “Sediment Reduction Tracking Form” provided in Appendix A will serve as the annual documentation for tracking effectiveness. It is anticipated that sediment reduction will increase as the Action Plan steps are implemented.

PVCC’s plan addresses the following MS4 General Permit special condition:

 “Develop and implement a method to assess TMDL Action Plans for their effectiveness in reducing the pollutants identified in the WLAs.” [Section I(B)(2)(e)]

3.1 Street Sweeping Schedule

Appendix B summarizes the schedule for completion of the Action Plan’s Street Sweeping Program steps described in Section 2.3.2. At the time that three consecutive annual reports find reductions necessary to achieve the WLA have been accomplished, the sweeping schedule in place at that time will be maintained and completion of all of the steps presented may be ceased.

10 Appendix A

Appendix A: Sediment Reduction Tracking Summary (To be provided with data collected from implementation of Action Plan)

Appendix A

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Appendix B

Appendix B: Enhanced Street Sweeping Program Schedule

Appendix B

Table 1: Schedule for PVCC’s TMDL Action Plan Street Sweeping Program.* Completion Step General Description Measurable Goal Date (prior) Methods for Written report and supporting materials for tracking 1 Oct. 2016 tracking areas swept documentation. Training for staff Training materials and documentation of training 2 identified in the Oct. 2017 implementation Written Program Conduct collected Written report incorporating a summary of relevant Oct. 2016 – 3 material sampling sampling data and analysis for computing sediment July 2017 and analysis fraction Target area Written reporting building on field collected data identification and 4 from Steps 1 and 3 to target areas for sweeping to July 2017 sediment reduction maximize sediment reduction assessment Written report assessing the effectiveness and appropriateness of PVCC’s sweepers. The 5 Sweeper evaluation Jan. 2018 assessment will be utilized in the consideration of future sweeper purchases. Implementation of Implementation of the identified target areas Annually, begin 6 targeted areas for resulting from Step 4 and remaining reductions July 2018 sweeping necessary to achieve the WLA. * As necessary to achieve the WLA.