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Rivanna River Sediment Tmdl Action Plan

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Rivanna River Sediment Tmdl Action Plan 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 Virginia 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. Piedmont 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
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