Bacteria TMDL Action Plan Final Submittal to Virginia DEQ March 31, 2017

Fairfax County, Virginia Bacteria TMDL Action Plan Final Submittal to Virginia DEQ March 31, 2017

Permit No: VA0088587

Fairfax County Bacteria TMDL Action Plan

March 31, 2017

Table of Contents 1 Introduction ...... 1 Purpose ...... 1 Cooperative Approach with Towns of Herndon and Vienna ...... 2 Permit Compliance Crosswalk ...... 2 2 Bacteria TMDL Action Plan ...... 3 TMDL Reports ...... 3 Pollutant of Concern ...... 5 Wasteload Allocations ...... 5 2.3.1 Sugarland Run, Mine Run and Pimmit Run TMDL ...... 8 2.3.2 Difficult Run TMDL ...... 8 2.3.3 Four Mile Run TMDL...... 9 2.3.4 Hunting Creek, Cameron Run, and Holmes Run TMDL ...... 10 2.3.5 Accotink Creek TMDLs ...... 11 2.3.6 Bull Run and Popes Head Creek TMDL...... 12 Evaluation of Significant Sources of Bacteria ...... 12 Existing and Planned Management Controls ...... 15 Legal Authorities...... 18 Enhanced Education, Outreach, and Training ...... 18 Schedule and Milestones ...... 19 3 Assessment of Effectiveness ...... 19 4 Measurable Goals ...... 19 5 Public Comments ...... 20

Tables

Table 1A – Action Plan and Permit Compliance Crosswalk ...... 2 Table 2.A – Bacteria TMDLs with Aggregated WLAs Assigned to Fairfax County’s MS4 ...... 3 Table 2.B – Sugarland Run, Mine Run, and Pimmit Run TMDL Aggregated Wasteload Allocations to MS4s ...... 8 Table 2.C – Difficult Run TMDL Aggregated Wasteload Allocations to MS4s ...... 9 Table 2.D – Four Mile Run TMDL Aggregated Wasteload Allocations to MS4s ...... 10 Table 2.E – Hunting Creek/Cameron Run/Holmes Run TMDL Aggregated Wasteload Allocations to MS4s ...... 10 Table 2.F – Upper and Lower Accotink Creek TMDLs Aggregated Wasteload Allocations to MS4s ...... 11 Table 2.G – Bull Run and Popes Head Creek TMDL Aggregated Wasteload Allocations to MS4s ...... 12 Table 2.H – Fairfax County Park Authority Dog Parks ...... 13 Table 2.I – County Properties with Septic (County MS4 & Bacteria TMDL Watershed) ...... 14 Table 2J – Fairfax County Current Bacteria Reduction Program ...... 15 Table 2K – Schedule and Milestones for Program Enhancements ...... 19

TOC-1 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Figures

Figure 2A – Fairfax County MS4 Service Area and Bacteria TMDL Watersheds...... 6 Figure 2B – Fairfax County Bacteria TMDL Impaired Stream Segments ...... 7

Appendices

Appendix A Cooperative Agreement Between the Fairfax County Board of Supervisors and the Towns of Herndon and Vienna

Appendix B Public Comments

TOC-2

Fairfax County Bacteria TMDL Action Plan

March 31, 2017

1 Introduction

Purpose This Bacteria TMDL Action Plan documents how Fairfax County intends to meet the “TMDL Action Plans other than the Chesapeake Bay TMDL” in Part I.D.2 of its Phase I MS4 Permit (No. VA0088587). The county’s most recent MS4 permit was issued by the Virginia Department of Environmental Quality (DEQ) effective April 1, 2015 and will expire March 31, 2020.

The county’s MS4 permit requires the development of action plans for impaired streams where a TMDL approved by the State Water Control Board assigns a waste load allocation (WLA) to the county. A TMDL establishes the maximum amount of a pollutant that can enter a water body without violating water quality standards.

Fairfax County is subject to the following seven separate TMDLs for bacteria impairments (see Table 2A for more detail on the impairments):  Bacteria TMDL for Tributaries to the Potomac River: Sugarland Run, Mine Run, and Pimmit Run;  Bacteria TMDL for the Difficult Run Watershed;  Fecal Coliform TMDL for Four Mile Run, Virginia;  Bacteria TMDLs for the Hunting Creek, Cameron Run, and Holmes Run Watersheds;  Bacteria TMDL for the Lower Accotink Creek Watershed;  Fecal Coliform TMDL for Accotink Creek, Fairfax County, Virginia; and,  Bacteria TMDLs for Popes Head Creek, Broad Run, Kettle Run, Little Bull Run, Bull Run and the Occoquan River.

All seven TMDLs assign WLAs to the county’s MS4 for bacteria and were approved prior to permit issuance on April 1, 2015. Action plans to address them must be completed within 24 months of permit issuance or by March 31, 2017.

Contamination by fecal coliform bacteria is the most common cause of water quality violations in Virginia streams. According to DEQ and the United States Geologic Survey “Although fecal coliform bacteria are not necessarily dangerous to humans, their presence in streams indicates that the water is contaminated with fecal waste from warm-blooded animals… For this reason, fecal coliform bacteria are known as ‘indicator organisms;’ their presence in recreational waters indicates an increased risk to human health.”1 In Virginia, water quality standards for bacteria were changed in 2003 from more general fecal coliform bacteria to E. coli (Escherichia coli). E. coli is a subset of fecal coliform bacteria and is considered a better indicator of the pathogenic potential of contamination.

1 “Identifying Sources of Fecal Coliform Bacteria in Accotink Creek,” USGS and Virginia DEQ, undated.

Page 1 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

This plan addresses the requirements of the county’s MS4 permit by evaluating significant sources of bacteria, assessing the adequacy of existing programs and legal authorities, identifying new action items and associated schedules and milestones, and determining how the effectiveness of the plan will be assessed.

Cooperative Approach with Towns of Herndon and Vienna As allowed by Section I.D.1.b)2)(c) of the county’s MS4 permit, the county has entered into an agreement with the towns of Herndon and Vienna to cooperate in the development of TMDL action plans. The agreement, included as Appendix A, was adopted by the county on March 8, 2017.

In accordance with the agreement, the cooperating localities may develop joint strategies to reduce TMDL pollutants of concern. At this time there are no shared strategies for bacteria. Any changes will be documented to DEQ in the county’s MS4 annual reports.

Permit Compliance Crosswalk DEQ published Guidance Memo No. GM-16-2006 on November 21, 2016 for MS4s to use in the development of local TMDL action plans. Table 1A provides an overview of the organization of this plan and how each section addresses the county’s MS4 permit and the draft guidance.

Table 1A – Action Plan and Permit Compliance Crosswalk Action Plan Action Plan DEQ Local TMDL Action Plan Guidance MS4 Permit Element Section 1 Introduction Section Section 2.1 TMDL Report 1. The name(s) of the final TMDL report(s) I.D.2.a) Pollutant of Section Section 2.2 2. The pollutant(s) causing the impairment(s) Concern I.D.2.a) Wasteload 3. The WLA(s) assigned to the MS4 as aggregate or Section Section 2.3 Allocations individual WLAs I.D.2.a) 4. Significant sources of POC(s) from facilities of concern owned or operated by the MS4 operator that Evaluation of are not covered under a separate VPDES permit. A Significant significant source of pollutant(s) from a facility of Section Section 2.4 Sources of concern means a discharge where the expected I.D.2.b)4) Bacteria pollutant loading is greater than the average pollutant loading for the land use identified in the TMDL; 5. Existing or new management practices, control Existing and techniques, and system design and engineering Planned Section Section 2.5 methods that have been or will be implemented as Management I.D.2.b)2) part of the MS4 Program Plan that are applicable to Controls reducing the pollutant identified in the WLA; 6. Legal authorities such as ordinances, state and other permits, orders, specific contract language, Legal Section Section 2.6 and inter-jurisdictional agreements applicable to Authorities I.D.2.b)1) reducing the POCs identified in each respective TMDL;

Page 2 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Action Plan Action Plan DEQ Local TMDL Action Plan Guidance MS4 Permit Element Enhanced 7. Enhancements to public education, outreach, and Education, employee training programs to also promote Section Section 2.7 Outreach, and methods to eliminate and reduce discharges of the I.D.2.b)3) Training POC(s) for which a WLA has been assigned; Schedule and 8. A schedule of interim milestones and Section Section 2.8 Milestones implementation of the items in 5, 6, and 7; I.D.2.a) 9. Methods to assess TMDL Action Plans for their Assessment of Section Section 3 effectiveness in reducing the pollutants identified in Effectiveness I.D.2.b)5) the WLAs; and 10. 10. Measurable goals and the metrics that the permittee and Department will use to track those Measurable Section Section 4 goals (and the milestones required by the permit). Goals I.D.2.b)5) Evaluation metrics other than monitoring may be used to determine compliance with the TMDL(s). Public Section Section 5 11. Comments I.D.2.b)6)

2 Bacteria TMDL Action Plan Fairfax County is subject to seven separate TMDLs that assign WLAs for discharges of bacteria to impaired waters. The WLAs are assigned in aggregate to Fairfax County and combinations of the following other MS4 permit holders: Fairfax County Public Schools (FCPS), Arlington County, the City of Fairfax, the City of Alexandria, the City of Falls Church, the Town of Herndon, the Town of Vienna, the Northern Virginia Community College, the Virginia Department of Transportation (VDOT), George Washington Memorial Parkway, and Fort Belvoir. The details of each TMDL are provided in this section.

TMDL Reports This TMDL action plan addresses the TMDL reports summarized in Table 2.A.

Table 2.A – Bacteria TMDLs with Aggregated WLAs Assigned to Fairfax County’s MS4 Aggregated SWCB Wasteload Reduction TMDL Name Water Name Cause Approval Allocation Target (WLA) Sugarland Run Escherichia 2.01E+12 VAN_A10R_SUG01A00 97.3% Bacteria TMDL coli cfu/yr VAN-A10R_SUG01B06 for Tributaries to the Potomac Mine Run Escherichia 9.12+E10 94.1% River: 04/04/2014 VAN-A11R-MNR01A04 coli cfu/yr Sugarland Run, Pimmit Run Mine Run, and VAN-A12R_PIM01A00 Escherichia 2.41E+09 Pimmit Run 99.42% VAN-A12R_PIM02A00 coli cfu/day VAN-A12R_PIM02B06

Page 3 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Aggregated SWCB Wasteload Reduction TMDL Name Water Name Cause Approval Allocation Target (WLA) Little Pimmit Run Escherichia (nested) VAN-A12R_LIO01A10 coli Difficult Run: VAN-A11R_DIF02A02 VAN-A11R_DIF02B06 Van-A11R_DIF03A02 Captain Hickory Run: VAN-A11R_CAH01A04 Bacteria TMDL VAN-A11R_CAH01B06 Escherichia 9.44E+12 for the Difficult 04/28/2009 90% Little Difficult Run: coli cfu/yr Run Watershed VAN-A11R_LID01A02 Snakeden Branch: VAN-A11R_SNA01A02 Wolftrap Creek: VAN-A11R_WOT01A02 VAN-A11R_WOT01B06 Fecal Coliform TMDL for Four Four Mile Run Fecal 2.04E+13 06/17/2004 Mile Run, VAN-A12R_FOU01A00 Coliform counts/yr Virginia Hunting Creek Escherichia 1.02E+14 83% VAN_A13E_HUT01A02 coli cfu/yr Cameron Run/Hunting Escherichia 9.60E+13 Creek 83% coli cfu/yr Bacteria VAN_A13R_CAM01A04 TMDLs for the Holmes Run Escherichia 5.47E+13 Hunting Creek, 83% 08/04/2011 VAN_A13R_HOR01A00 coli cfu/yr Cameron Run, Holmes Run Escherichia and Holmes (nested) Run Watersheds VAN_A13R_HOR01B00 coli Tripps Run Escherichia (nested) VAN_A13R_TRI01A00 coli Backlick Run Escherichia (nested) VAN_A13R_BAL01A00 coli Accotink Creek Escherichia 1.73E+12 Bacteria TMDL 97% for the Lower VAN-A15R_ACO01A00 coli cfu/yr 04/28/2009 Accotink Creek Long Branch Escherichia (nested) Watershed VAN-A15R_LOA01A08 coli

Page 4 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Aggregated SWCB Wasteload Reduction TMDL Name Water Name Cause Approval Allocation Target (WLA) Fecal Coliform Accotink Creek Fecal 1.3E+14 col/yr 91.67% TMDL for VAN-A15R_ACO02A00 Coliform Accotink Creek, 06/17/2004 Accotink Creek Fecal Fairfax County, (nested) Virginia VAN-A15R_ACO04A02 Coliform Bacteria Cub Run: TMDLs for VAN-A22R_CUB01A00 Popes Head Elklick Run: Escherichia 7.61E+10 89% Creek, Broad VAN-A22R_ELC01A04 coli cfu/yr Run, Kettle 07/31/2008 Little Rocky Run: Run, Little Bull VAN-A23R_LIP01A06 Run, Bull Run and the Popes Head Creek Escherichia 6.83E+11 94% Occoquan River VAN-A23R_POE01A00 coli cfu/yr

Pollutant of Concern These stream segments were listed as impaired on Virginia’s 303(d) TMDL Priority List and Reports because of violations of the state’s water quality standards for E. coli and fecal coliform bacteria.

Wasteload Allocations This action plan applies to the areas covered under the bacteria TMDLs that drain to the county’s regulated MS4. The MS4 service area is defined in the MS4 permit as those areas draining to outfalls owned or operated by the County that discharge to surface waters. Storm sewer system GIS data (including MS4 outfalls) was used in conjunction with hydrologic features, local topographic data, and high-resolution aerial photos to delineate the MS4 boundaries and create MS4 boundary polygon layers. Artificial conveyances and natural drainage features were thoroughly reviewed in a GIS environment by engineers and planners in order to accurately account for storm sewer drainage areas and determine break points between the manmade and natural hydrologic systems.

The County considered the following MS4 permit holders in the development of its service area: Arlington County (VA0088579); City of Alexandria (VAR040057); Town of Herndon (VAR040060); City of Fairfax (VAR040064); City of Falls Church (VAR040065); Town of Vienna (VAR040066); Loudoun County (VAR040067); U.S. Army – Fort Belvoir (VAR040093); Northern Virginia Community College (VAR040095); Central Intelligence Agency (VAR040101); George Mason University (VAR040106); George Washington Memorial Parkway (VAR040111); Metropolitan Washington Airport Authority (VAR040120); U.S. Geological Survey (VAR040126); and, Virginia Department of Transportation (VAR040115).

Figure 2A shows the County’s MS4 service area delineation and the bacteria TMDL watersheds. The County submitted a detailed MS4 service area to DEQ by the deadline of October 1, 2016 established in the MS4 permit but has not received any feedback from DEQ on the submittal. As such, the approach outlined in GM16-2006 was used for the local TMDL Action Plans and it was assumed that the “overall reduction assigned to the aggregated WLA should be addressed consistently by all MS4 permittees.”

Page 5 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Figure 2A – Fairfax County MS4 Service Area and Bacteria TMDL Watersheds

Page 6 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Figure 2B shows the location of the impaired stream segments addressed in this Action Plan.

Figure 2B – Fairfax County Bacteria TMDL Impaired Stream Segments

Page 7 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

2.3.1 Sugarland Run, Mine Run and Pimmit Run TMDL The Sugarland Run watershed drains 22.7 square miles (14,258 acres) of land in Fairfax County, Loudoun County, and the Town of Herndon. In the TMDL, 3,727 developed acres were assigned to the Fairfax County “MS4 Geographical Area,” which includes portions of Fairfax County’s, FCPS’, and VDOT’s MS4 service areas. The county’s MS4 portion of the Sugarland Run watershed is 2,401 acres based on the MS4 service area map submitted by the county with its FY16 annual report.2 The Mine Run watershed drains 2.5 square miles (1,600 acres) of land in Fairfax County. In the TMDL, 91 developed acres were assigned to the Fairfax County “MS4 Geographical Area,” which includes portions of Fairfax County’s, FCPS’, VDOT’s, and the George Washington Parkway’s MS4 service areas. The county’s MS4 portion of the Mine Run watershed is 210 acres. The Pimmit Run watershed drains 10.1 square miles (6,464 acres) of land in Fairfax County. In the TMDL, 3,230 developed acres were assigned to the Fairfax County “MS4 Geographical Area,” which includes portions of Fairfax County’s, FCPS’, VDOT’s, and the George Washington Parkway’s MS4 service areas. The county’s MS4 portion of the Pimmit Run watershed is 2,631 acres. Table 2.B shows the aggregated existing bacteria load, allocated bacteria load, and target load reduction contained in the TMDL.

Table 2.B – Sugarland Run, Mine Run, and Pimmit Run TMDL Aggregated Wasteload Allocations to MS4s Existing Allocated Load Aggregated Bacteria Bacteria Water Name Reduction Reduction MS4s Load Load (cfu/yr) (cfu/yr)* (cfu/yr) Sugarland Run Fairfax County VAN_A10R_SUG01A00 FCPS 7.50E+13 2.01E+12 97.3% 7.30E+13 VAN-A10R_SUG01B06 VDOT Mine Run 1.53E+12 9.12E+10 94.1% 1.44E+12 VAN-A11R-MNR01A04 Fairfax County Pimmit Run FCPS VAN-A12R_PIM01A00 GW Parkway 1.51E+14 8.80E+11 99.42% 1.50E+14 VAN-A12R_PIM02A00 VDOT VAN-A12R_PIM02B06 *Based on distribution of allocated bacteria load from TMDL Table 4-2

The Bacteria TMDL for Sugarland Run, Mine Run, and Pimmit Run addresses implementation with the following statement: “For MS4s/VSMP individual and general permits, the Commonwealth expects the permittee to specifically address the TMDL wasteload allocations (WLA) for stormwater through the iterative implementation of BMPs that may include both structural and nonstructural controls.” The TMDL also states that “Virginia and USEPA are not proposing the elimination of natural wildlife to allow for the attainment of water quality standards. However, managing overpopulations of wildlife remains an option available to local stakeholders.”3

2.3.2 Difficult Run TMDL The Difficult Run watershed drains approximately 37,260 acres of land in Fairfax County, the City of Fairfax, and the Town of Vienna. Fairfax County’s MS4 service area portion of the watershed is 11,064

2 Unless otherwise noted, the county’s MS4 portion of a watershed is based on MS4 service area map submitted by the county with its FY16 annual report. 3 Sections 5.3.2 and 5.6 of the Bacteria TMDL for Sugarland Run, Mine Run, and Pimmit Run.

Page 8 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

acres. Table 2.C shows the aggregated existing bacteria load, allocated bacteria load, and target load reduction contained in the Difficult Run TMDL.

Table 2.C – Difficult Run TMDL Aggregated Wasteload Allocations to MS4s Existing Allocated Load Aggregated Bacteria Bacteria Water Name Reduction Reduction MS4s Load Load (cfu/yr) (cfu/yr) (cfu/yr) Difficult Run: VAN-A11R_DIF02A02 VAN-A11R_DIF02B06 Van-A11R_DIF03A02 Captain Hickory Run: FCPS VAN-A11R_CAH01A04 Fairfax County VAN-A11R_CAH01B06 City of Fairfax 9.44E+13 9.44E+12 90% 8.50E+13 Little Difficult Run: Town of Vienna VAN-A11R_LID01A02 VDOT Snakeden Branch: GW Pkwy VAN-A11R_SNA01A02 Wolftrap Creek: VAN-A11R_WOT01A02 VAN-A11R_WOT01B06

The Difficult Run TMDL addresses implementation with the following statement: “For MS4/VSMP general permits, the Commonwealth expects the permittee to specifically address the TMDL wasteload allocations for stormwater through iterative implementation of programmatic BMPs [best management practices]. BMP effectiveness would be determined through permittee implementation of an individual control strategy that includes a monitoring program that is sufficient to determine its BMP effectiveness.” The TMDL also states that “Virginia and EPA are not proposing the elimination of wildlife to allow for the attainment of water quality standards. This is obviously an impractical action. While managing over-populations of wildlife remains as an option to local stakeholders, the reduction of wildlife or changing a natural background condition is not the intended goal of a TMDL.”4

2.3.3 Four Mile Run TMDL The nontidal portion of the Four Mile Run watershed drains 10,874 acres of land in Fairfax County, Arlington County, and the cities of Alexandria and Falls Church. Fairfax County’s MS4 service area portion of the watershed is 402 acres. Table 2.D shows the allocated bacteria load contained in the Four Mile Run TMDL. The aggregated existing bacteria load and target load reduction were not available in the TMDL document.

4 Section 8.3.2 of the Bacteria TMDL for Difficult Run.

Page 9 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Table 2.D – Four Mile Run TMDL Aggregated Wasteload Allocations to MS4s Allocated Bacteria Water Name Aggregated MS4s Load (counts/yr fecal Reduction coliform) Four Mile Run Fairfax County 98% reduction from VAN-A12R_FOU01A00 Arlington County human and dog 2.04E+13 City of Alexandria sources; 95% reduction City of Falls Church from all wildlife

The Four Mile Run TMDL addresses implementation with the following statement: “For MS4/VPDES permits, VADEQ expects future permit revisions to require the implementation of BMPs to specifically address the TMDL pollutants of concern. VADEQ anticipates that BMP effectiveness would be determined through routine in-stream monitoring.” The TMDL also states that “Virginia and EPA are not proposing the elimination of wildlife to allow for the attainment of water quality standards. This is obviously an impractical action. While managing over-populations of wildlife remains as an option to local stakeholders, the reduction of wildlife or changing a natural background condition is not the intended goal of a TMDL.”5

2.3.4 Hunting Creek, Cameron Run, and Holmes Run TMDL The Hunting Creek, Cameron Run, and Holmes Run watersheds drain approximately 29,179 acres of land in Fairfax County, Arlington County, the City of Falls Church, and the City of Alexandria. Fairfax County’s MS4 service area portion of the watershed is 8,371 acres. Table 2.E shows the aggregated existing bacteria load, allocated bacteria load, and target load reduction contained in the Hunting Creek, Cameron Run, and Holmes Run TMDL.

Table 2.E – Hunting Creek/Cameron Run/Holmes Run TMDL Aggregated Wasteload Allocations to MS4s Existing Allocated Load Bacteria Bacteria Water Name Aggregated MS4s Reduction Reduction Load Load (cfu/yr) (cfu/yr) (cfu/yr) Hunting Creek FCPS 3.22E+14 5.47E+13 83% 2.67E+14 VAN_A13E_HUT01A02 Fairfax County Cameron Run/Hunting Arlington County Creek City of Alexandria 5.65E+14 9.60E+13 83% 4.69E+14 VAN_A13R_CAM01A04 City of Falls Church Holmes Run VDOT 6.00E+14 1.02E+14 83% 4.98E+14 VAN_A13R_HOR01A00 GW Pkwy

The Hunting Creek, Cameron Run, and Holmes Run TMDL addresses implementation with the following statement: “For MS4/VSMP general permits, the Commonwealth expects the permittee to specifically address the TMDL wasteload allocations for stormwater through iterative implementation of programmatic BMPs. BMP effectiveness is determined through permittee implementation of an individual control strategy that includes a monitoring program that is sufficient to determine its effectiveness.” The TMDL also states that “Virginia and USEPA are not proposing the elimination of

5 Sections 6.2 and 6.4 of the TMDL for Four Mile Run.

Page 10 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

natural wildlife to allow for the attainment of water quality standards. However, managing over- populations of wildlife remains an option available to local stakeholders.”6

2.3.5 Accotink Creek TMDLs The Accotink Creek watershed drains approximately 30,890 acres in Fairfax County, the City of Fairfax and the Town of Vienna. Fairfax County’s MS4 service area portion of the entire watershed is 10,434 acres. This action plan addresses both the Fecal Coliform TMDL for Accotink Creek, Fairfax County, Virginia and the Bacteria TMDL for the Lower Accotink Creek Watershed by virtue of the former being included as input to the latter. Table 2.F shows the aggregated existing bacteria load, allocated bacteria load, and target load reduction contained in the Lower Accotink Creek TMDL.

Table 2.F – Upper and Lower Accotink Creek TMDLs Aggregated Wasteload Allocations to MS4s

Existing Allocated Load Water Name Aggregated MS4s Bacteria Bacteria Reduction Reduction Load Load

Upper Accotink Creek Accotink Creek 1.56E+15 0.13E+15 1.43E+15 Fairfax County VAN-A15R_ACO02A00 (col/year (col/year (col/year City of Fairfax 91.67% fecal fecal fecal Town of Vienna coliform) coliform coliform) Lower Accotink Creek Accotink Creek FCPS VAN-A15R_ACO01A00 Fairfax County 5.75E+13 1.73E+12 5.58E+13 VDOT (cfu/year E. (cfu/year 97% (cfu/year E. Northern Virginia coli) E. coli) coli) Community College Fort Belvoir

The Lower Accotink Creek TMDL addresses implementation with the following statement: “For MS4/VSMP general permits, the Commonwealth expects the permittee to specifically address the TMDL wasteload allocations for stormwater through the iterative implementation of programmatic BMPs. BMP effectiveness would be determined through permittee implementation of an individual control strategy that includes a monitoring program that is sufficient to determine its BMP effectiveness.”7 The Fecal Coliform TMDL for Accotink Creek also states that “Virginia and EPA are not proposing the elimination of natural wildlife to allow for the attainment of water quality standards. This is obviously an impractical action. While managing over-populations of wildlife remains as an option to local stakeholders, the reduction of wildlife or changing a natural background condition is not the intended goal of a TMDL.”8

6 Sections 6.3.2 and 6.6 of the TMDL for the Hunting Creek, Cameron Run, and Holmes Run Watersheds. 7 Section 6.3.2 of the TMDL for the Lower Accotink Creek Watershed. 8 Section 7.4 of the Fecal Coliform TMDL for Accotink Creek.

Page 11 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

2.3.6 Bull Run and Popes Head Creek TMDL This TMDL covers streams in a large area with 17% of the TMDL area in Fairfax County, which includes the impaired segments of Bull Run and Popes Head Creek. The Bull Run watershed reflected in the TMDL drains 91,983 acres and includes nine MS4 permittees: Fairfax County, Prince William County, FCPS, VDOT, Loudoun County, the Northern Virginia Community College Manassas Campus, Prince William County Public Schools and the Cities of Manassas and Manassas Park. The portion of the Bull Run watershed in Fairfax County is 38,592 acres and Fairfax County’s MS4 service area portion of the Bull Run watershed is 8,875 acres. The Popes Head Creek watershed reflected in the TMDL drains 12,139 acres and includes four MS4 permittees: Fairfax County, VDOT, FCPS and the City of Fairfax. Fairfax County’s MS4 service area portion of the Popes Head Creek watershed is 1,023 acres. Table 2G shows the aggregated existing bacteria load, allocated bacteria load, and target load reduction contained in the Bull Run and Popes Head Creek TMDL.

Table 2.G – Bull Run and Popes Head Creek TMDL Aggregated Wasteload Allocations to MS4s Existing Allocated Load Bacteria Bacteria Water Name* Aggregated MS4s Reduction Reduction Load Load (cfu/yr) (cfu/yr) (cfu/yr) Cub Run: VAN-A22R_CUB01A00 Elklick Run: 6.81E+11 7.61E+10 89% 6.05E+11 VAN-A22R_ELC01A04 Fairfax County Little Rocky Run: FCPS VAN-A23R_LIP01A06 VDOT Popes Head Creek VAN-A23R_POE01A00 1.08E+13 6.83E+11 94% 1.01E+13

* Bull Run was delisted in the 2008 Integrated Report – Cub Run, Elklick Run and Little Rocky Run are nested with the WLA given for Bull Run.

The Bull Run and Popes Head Creek TMDL addresses implementation with the following statement: “For MS4/VSMP general permits, the Commonwealth expects the permittee to specifically address the TMDL wasteload allocations for stormwater through the implementation of programmatic BMPs. BMP effectiveness would be determined through ambient in-stream monitoring.” The TMDL also states that “Virginia and EPA are not proposing the elimination of wildlife to allow for the attainment of water quality standards. While managing over-populations of wildlife remains as an option to local stakeholders, the reduction of wildlife or changing a natural background condition is not the intended goal of a TMDL.”9

Evaluation of Significant Sources of Bacteria The MS4 permit requires Fairfax County to evaluate significant sources of bacteria from facilities of concern. This is defined in the permit as “a discharge where the expected pollutant loading is greater than the average pollutant loading for the land use identified in the TMDL.” As described in the TMDLs, the primary sources of bacteria assigned to MS4s in general are pet waste in the Difficult Run and Accotink Creek watersheds and pet waste and wildlife deposition assigned to land uses in the Sugarland Run, Holmes Run, Cameron Run, Hunting Creek, Bull Run, and Popes Head Creek watersheds. The predominant sources

9 Sections 6.4.3 and 6.4.5 of the Bacteria TMDL for Popes Head Creek and Bull Run.

Page 12 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

of bacteria in the Four Mile Run watershed were nonhuman sources with intimate association with the waterways, especially waterfowl. In addition, all human sources of bacteria are expected to be eliminated. Potential human sources to MS4s include failed septic systems (through infiltration) and sanitary sewer cross-connections.

Pet waste can enter the MS4 when it is left on a surface that drains to a storm sewer. Off-leash dog parks are an example of a specific land use with a potential high risk for bacteria to enter into the MS4. Fairfax County Park has nine off-leash dog parks. However, only two are located within the County MS4 service area and are in a watershed subject to a bacteria TMDL. These are summarized in Table 2.H. All of the dog parks are managed by the Fairfax County Park Authority.

Table 2.H – Fairfax County Park Authority Dog Parks

Subject to In County Park Name Address Watershed Bacteria MS4 Service TMDL? Area?

11300 Baron Cameron Baron Cameron Difficult Run Yes Yes Avenue, Reston Alpine Drive and Pinecrest Cameron Mason District Yes Yes Parkway, Annandale Run

Other potential areas where bacteria from pet waste could be concentrated include those areas where owners are likely to walk their pets. This includes walking trails, public parks and open space, and private open space such as community association common areas. Fairfax County offers over 900 miles of trails, bikeways and sidewalks and 427 parks that could be used for pet walking.

Potential human sources of bacteria identified in the TMDL include failing septic systems and sanitary sewer cross-connections, spills, or leaks. The majority of the county is connected to public sanitary sewer. Homeowners whose septic systems are failing, and deemed non-repairable by the county’s Division of Environmental Health, are required to connect to sewer if the property is within 300 feet of available public sanitary sewer. For failing septic systems where sanitary sewer is not available, property owners can coordinate with the Division of Environmental Health on available alternatives. The county enforces the Individual Sewage Disposal Facilities Code, Chapter 68 of the County Code.

With regard to the wastewater collection system, the county maintains approximately 3,400 miles of sanitary sewer pipe. The county’s Wastewater Collection Division (WCD) of the Department of Public Works and Environmental Services is responsible for the operation and maintenance of the county’s sanitary sewers, force mains, pumping stations and metering stations. WCD’s maintenance programs include:  Sewer Rehabilitation: 21 miles of 8” – 15” diameter gravity sewers (out of approximately 3,400 total miles) were rehabilitated using cured-in-place pile repair in FY 2015.  Inflow/Infiltration (I/I) and Flow Monitoring Program  Closed Circuit Television Inspection – 204 miles were inspected in FY15.  Stream Crossing Initiative: WCD works with Stormwater and Park Authority staff to identify and locate exposed pipes situated along and/or across streams. After identification, the crossing is inspected, catalogued, and repaired or monitored as necessary. In FY 2015, 206 manholes were repaired and nine pipes were protected or repaired in the vicinity of a stream crossing.

Page 13 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

 Cleaning and Maintenance: A total of 436 miles of sewer lines were cleaned in FY 2015.

The county also conducts a dry weather outfall monitoring program designed to detect illicit connections to the storm sewer system. The county’s program is described in its MS4 Program Plan, MS4 Action B.2.l.1.a.

As required in the MS4 permit, the county conducted a review of county owned or operated properties subject to a bacteria TMDL and located within the regulated MS4 service area to assess risk factors associated with bacteria. There are ten county owned or operated properties with septic systems within the County MS4 service area and in a watershed subject to a bacteria TMDL, which are summarized in Table 2.I. All sites comply with Chesapeake Bay Preservation Area Designation and Management Regulations regarding septic system maintenance and pump-outs.

Table 2.I – County Properties with Septic (County MS4 & Bacteria TMDL Watershed) Site Address and Tax Map PIN Watershed Subject to In Bacteria County TMDL? MS4 Service Area? Turner Farm: two 925 Springvale Road, Great Difficult Run Yes Partially parcels Falls (0121 01 0024; 0121 01 0024C) Raglan Road Park: two 8590 Raglan Road, Vienna Difficult Run Yes Partially parcels (0293 01 0015; 0293 01 0017) Clemyjontri Park: 6319 Georgetown Pike, Pimmit Run Yes Yes southern parcel McLean (0311 01 0011B) Marie Butler Leven 1501 Kirby Road, McLean Pimmit Run Yes Yes Preserve (0313 01 0186) Fred Crabtree Park: 2801 Fox Mill Road, Herndon Difficult Run Yes Partially southern parcel (0361 01 0026) Gabrielson Gardens 2514 Leeds Road, Vienna Difficult Run Yes Partially Park (0361 01 0026) John C & Margaret K 3301 Hawthorne Lane, Falls Cameron Run Yes Yes White Gardens Church (0602 01 0020) Twin Lakes Golf 6201 Union Mill Road, Clifton Johnny Moore Yes Partially Course: southern (0663 01 0009) Creek parcel Backlick Park: one 4510 Backlick Road, Cameron Run Yes Yes parcel Annandale (0711 01 0117) Beulah Park 7119 Beulah Road, Alexandria Dogue Creek/ Yes Yes (0913 01 0059) Accotink Creek

Page 14 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Existing and Planned Management Controls The county has in place a rigorous program aimed at preventing the discharge of bacteria from the MS4. Table 2J summarizes the county’s bacteria management controls.

Table 2J – Fairfax County Current Bacteria Reduction Program Source Document Description Implementation and Schedule MS4 Program The permit requires that discharges to The county will continue to implement Plan the MS4 not authorized by the permit and enforce Fairfax County Codes: Fire MS4 Action ID shall be effectively prohibited. Prevention Ordinance (Chapter 62); B.2.e. Stormwater Management Ordinance (Chapter 124); Food and Food-Service Establishments Ordinance (Chapter 43.1); Individual Sewage Disposal Facilities Ordinance (Chapter 68.1); Water Recreation Facilities Ordinance (Chapter 69.1); Sanitary Sewers and Sewage Disposal Ordinance (Chapter 67.1); and Solid Waste Management Ordinance (Chapter 109). MS4 Program The permit requires the county to The county must inspect a minimum of Plan continue implementing a sanitary 750,000 linear feet of sanitary sewer MS4 Action ID sewer inspection program to minimize during this permit cycle (April, 1, 2015 B.2.e.2. the exfiltration from the sanitary – March 31, 2020) system to the MS4. MS4 Program The permit requires the county to The following actions are contained in Plan continue to implement a program to the MS4 Program Plan: MS4 Action ID locate and eliminate illicit discharges  Continue the dry weather screening B.2.e.5. and improper disposal into the MS4. program (see MS4 Action ID B.2.l.1.a. below).  The county responds to reports of suspected illicit discharges and improper disposal (IDID) and notifies DEQ as specified in the Program Plan.  Sources of discharges are investigated and after the source of an illicit discharge has been identified, the appropriate agency is contacted to address the discharge. MS4 Program The permit requires the county to The county maintains proactive Plan promote and publicize the proper outreach through various media outlets MS4 Action ID disposal of pet waste and household targeting pet owners and households on B.2.j.1.e. yard waste. proper management of pet waste. Outreach and education on these topics are also performed by regional efforts through Clean Water Partners. Public education activities that include messages related to the proper disposal

Page 15 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Source Document Description Implementation and Schedule of pet waste are listed in Appendix R10 of the FY16 Annual Report and include:  Storm drain marking  Enviroscape watershed model presentations  Volunteer stream monitoring program  Conservation Currents newsletter  Technical assistance site visits  NVSWCD website  Conservation planning  Earth Friendly Suburban Horse Keeping publication online/print  Build-Your-Own Tumbler Composter program  Watershed friendly garden tour  Stream Crime Investigation Lab  Sewer Science  Floatable Monitoring Program  Meaningful Watershed Education Experience presentations  Scout badge programs MS4 Program The permit requires the county to County field personnel are trained in Plan provide biennial training to appropriate illicit discharge recognition and MS4 Action ID field personnel in the recognition and reporting, every other year in B.2.k.1. reporting of illicit discharges and accordance with the MS4 Program Plan. improper disposal. MS4 Program The permit requires that the county The county screens a minimum of 100 Plan implement a program of dry weather MS4 outfalls annually, as required. MS4 Action ID screening in areas of concern. The B.2.l.1.a. purpose of this BMP is to locate, identify and eliminate illicit discharges through a dry weather outfall screening program. The program includes bacteria pollution. County Code The county has enacted a “pooper- Ongoing. Section 41.1-2-6 – scooper” ordinance to reduce the Animals causing incidence of pet owners leaving pet unsanitary waste on surfaces where it can enter conditions. the storm drain. This section states “It shall be unlawful for the owner of any animal or animals to keep such animal or animals in such a manner as to cause unsanitary conditions. The owner or custodian of any dog shall be responsible for the removal of excreta deposited by such dog on the property

Page 16 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Source Document Description Implementation and Schedule of another, including public places.” Section 41.1-1-3 of the County Code states that “Violation of any provision of this Chapter constitutes a Class 4 misdemeanor unless otherwise stated.” A Class 4 misdemeanor is punishable by a fine of up to $250. County Code This chapter of the County Code is Ongoing. Chapter 68 – applied to protect public health and the Individual Sewage environment through locating, Disposal Facilities designing, inspecting, and approving functional individual sewage disposal facilities and the licensing/registration of sewage disposal facility contractors, sewage handlers, and system maintenance providers. Chapter 10 of the This chapter provides sanitary sewer Ongoing. Public Facilities design criteria, individual sewage Manual – Sewage disposal system design criteria and and Solid Waste solid waste and recycling system Disposal design standards and guidelines. Fairfax County The county routinely inspects Ongoing. Sanitary Sewer approximately 200 miles of sanitary Inspection sewer pipe for leaks and cross Program connections annually. Chesapeake Bay All septic systems in Fairfax County Ongoing. Preservation Area must be pumped out at least once Designation and every five years. Management Regulations County Deer The objective of this program is deer The program is implemented each year Management population control on public parklands. to manage the abundant local white- Program Management actions reflect a variety tailed deer population. of interests: protecting human health and safety, reducing environmental damage, conserving biodiversity and maintaining healthy deer herds. County Geese This program includes an addling Ongoing. Management activities to humanely reduce the Program goose population over time and a webpage with information on landscape modification and deterrence information. Support for the This regional campaign selects three Each annual campaign uses a Northern Virginia high priority water quality issues to combination of television, print, internet Clean Water focus on annually. Bacteria and advertising and website to distribute Partners Regional education of pet owners has been a messages. An online survey is Stormwater target of the campaign since inception. conducted annually to determine the

Page 17 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Source Document Description Implementation and Schedule Education effectiveness of the ads, aid in directing Program the future efforts of the campaign, and to reveal any changes in behavior.

In reviewing the remainder of the county’s program against the sources identified in Section 2.4, the county has identified the following program enhancements:

 Dog Park Site Assessment – The county will conduct an annual walk-through of the dog parks located in the bacteria impaired watersheds of the MS4 (Baron Cameron and Mason District). Off-leash dog parks have information kiosks with dog area rules and doggy bag dispenser boxes. The walk-through will be used to assess the effectiveness of implemented management strategies and make adjustments to this action plan as appropriate.  In the case of unsatisfactory dog park assessment, the county will meet with representatives of the partner organizations and FCPA to evaluate options to improve pet waste management at the dog parks. Mitigation measures identified will be implemented and follow-up assessments conducted within six months of implementation.

The schedule and milestones for implementing these program enhancements are provided in Section 2.8.

Legal Authorities The county prohibits all illicit discharges to the storm sewer system in Chapter 124 of the County Code. With regard to pet waste, failure to remove dog excrement is specifically addressed in Section 41.1-2-6 of the County Code. A Class 4 misdemeanor is punishable with a fine of not more than $250. With regard to septic systems, the County Code Chapter 68 covers use of individual sewage disposal systems. The county has not identified the need for additional legal authorities at this time.

Enhanced Education, Outreach, and Training The county’s education, outreach, and training program has been developed over time in an iterative manner based on periodic assessments of potential sources and the effective means of reducing these sources. As previously noted, education and outreach on proper disposal of pet waste is a requirement of Section I.B.2.j.1.e of the MS4 permit. The county’s education and outreach program on pet waste encompasses multiple areas of the MS4 program including illicit discharge prevention and litter prevention. Multiple media are used to educate the public to pick up pet waste including public service announcements, regional campaigns, website content educational activities for residents and school children.

The county plans to enhance its current education program by including inserts in dog license fee renewal reminders that are mailed to registered dog owners in the county annually. The inserts would provide information on the county’s Pooper Scooper Ordinance and encourage proper disposal of pet waste. The annual report will include an update on the status of this effort.

The county will review the effectiveness of its pet waste education annually and make changes as warranted. Further, the county’s training program (MS4 Action ID B.2.k.1.) addresses all potential sources of illicit discharges, including bacteria. Implementation is documented in annual reports to DEQ. The county believes that these education and outreach efforts meet the requirements for an enhanced program.

Page 18 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Schedule and Milestones The county will continue the existing program in accordance with Table 2J and the MS4 Program Plan. Additional actions identified in Section 2.5 will be implemented and documented in the MS4 annual report in accordance with Table 2K.

Table 2K – Schedule and Milestones for Program Enhancements Program Description Implementation Responsible Element Mechanism and Party Schedule Dog Park Site Conduct a walk-through of the dog parks Assessments will SWPD Assessment at Baron Cameron and Mason District occur annually parks to assess the effectiveness of beginning in FY18. implemented pet waste management strategies. Educational Include educational inserts about proper An update on the SWPD inserts in dog disposal of pet waste in dog license status and schedule for license renewal renewal mailers. the mailer will be mailers included in the FY17 annual report.

3 Assessment of Effectiveness The practices put in place to reduce bacteria pollution do not have well-documented reduction efficiencies like those for practices to reduce nutrients and sediment. Further, ambient in-stream water quality monitoring programs, while effective at measuring overall progress toward bacteria reduction targets, are not appropriate indicators of MS4 permit compliance.10

The county will assess the effectiveness of its efforts by reviewing the measures in Table 2J and the proposed enhancements in Table 2K as part of the annual report submitted to DEQ. The measure of effectiveness will be that any particular county property should not be a significant source of bacteria. In accordance with the MS4 permit, a significant source of bacteria means “…a discharge where the expected pollutant loading is greater than the average pollutant loading for the land use identified in the TMDL.” Should the review indicate that waste deposits are higher on a county owned or operated property than what would be expected for similar land use, then the county will adopt iterative implementation of additional practices to reduce bacteria loads.

The effectiveness of public education and outreach measures will be assessed based on metrics to be determined in the FY17 permit year. In addition, the county will utilize annual surveys conducted by the Clean Water Partners program to assess the overall effectiveness of regional public education and outreach efforts.

4 Measurable Goals The county’s measurable goal will be to reduce bacteria loads to the watersheds listed in Section 2.1 in accordance with the TMDLs through implementation of the management controls in Section 2.5 in

10 Several of the TMDLs contain the statement “Ambient instream monitoring would not be an appropriate means of determining permit compliance. Ambient monitoring would be appropriate to determine if the entire TMDL is being met by all attributed sources. This is in accordance with EPA guidance.”

Page 19 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

accordance with the schedule and milestones provided in Section 2.8. Progress toward implementing the actions in this plan will be reported annually to DEQ in each MS4 permit annual report.

5 Public Comments The draft Bacteria TMDL Action Plan was presented at public meetings on December 14 and 15, 2016 at the Fairfax County Government Center and on January 3, 2017 at the Mount Vernon Government Center. The action plan and presentation were also posted to the County’s website. The County invited public comment through January 27, 2017. The action plan and public comments were then presented to the Board of Supervisors Environmental Committee on February 7, 2017. Public comments and the County’s responses are provided in Appendix B.

Page 20

Appendix A

Cooperative Agreement Between the Fairfax County Board of Supervisors and the Towns of Herndon and Vienna

Appendix A Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Appendix A

Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Appendix A

Appendix B

Public Comments

The County’s public outreach efforts included an opportunity to comment on the Chesapeake Bay TMDL Action Plan, Benthic TMDL Action Plan, Bacteria TMDL Action Plan, and PCB TMDL Action Plan. This appendix includes comments specific to the Bacteria TMDL Action Plan and general comments applicable to all of the action plans.

Public Comment Commenter Plan Reference County Response Action Taken 1. The introductory materials for this action plan seem Fairfax County All Chesapeak The County will incorporate the MS4 Service MS4 Service Area to do a much better job of explaining the Fairfax Environmental e Bay Area Delineation Methodology section into the Delineation County MS4 service area than we found in the other Quality Action benthic, PCB, and bacteria TMDL action plans. Methodology added plans (Benthic, PCB, Bacteria). The rules are Advisory Plan It is important to note that the Chesapeake Bay to the benthic, PCB, necessarily complex for determining exactly where Council Section 4.1 TMDL is the only TMDL that provides and bacteria TMDL the County’s responsibilities lie. Perhaps these Wasteload Allocations (WLAs) specifically to action plans. should be copied by the other plans? the Fairfax County MS4. The other TMDLs contain WLAs that have been aggregated with other MS4s. The Fairfax County MS4 portion of the aggregated loads has not been determined. 2. Is it standard or required practice for TMDL action Fairfax County All N/A Virginia DEQ Guidance Memo 15-2005, No further action plans to present loads to a ridiculous number of Environmental Chesapeake Bay TMDL Special Condition required. significant digits – up to 10? This obviously is an Quality Guidance, Section II.2 requests that localities artifact of adding numbers of different magnitudes. Advisory compute pollutant loads to the nearest hundredth. For key tables, we suggest rounding to 3 figures. Council 3. In reading the plans, it sometimes was difficult to Fairfax County Bacteria; N/A The County uses the same stream terminology Virginia DEQ’s determine exactly to which water bodies the permits Environmental Benthic; used in the TMDLs based on Virginia’s “305(b) IDs” added applied. To avoid ambiguity, is it possible to Quality PCB 305(b)/303(d) Water Quality Assessment to the tables listing provide an appendix cross-referencing all water Advisory Integrated Report. The “305(b) ID” is used to water body names. bodies to the National Hydrography Dataset Council identify individual impaired water bodies and the (NHD)? impairments associated with each TMDL are listed in Appendix A of the County’s MS4 permit, which is available at http://www.fairfaxcounty.gov/dpwes/stormwate r/va0088587-fairfax-permit.pdf. The tables in the action plans have been revised to list these stream segments.

B-1 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Public Comment Commenter Plan Reference County Response Action Taken 4. It’s one thing to tell how many feet of sewer were Fairfax County Bacteria Section 2.4 The County agrees that it would be helpful to use Section 2.4 revised rehabilitated, but it needs to be placed in context Environmental consistent units of measurement to provide better to use miles instead and presented in units consistent with the sewers in Quality context for activities related to sanitary sewer of linear feet. the county: 21 miles (111,727 ft) rehabilitated out Advisory inspection and maintenance. of 3,400 mi total, a life-cycle of 162 years. Council Wastewater’s risk-based total lifecycle asset management program focuses on reducing asset risks and impacts through proactive and continuous asset condition assessment, multi- year planned CIP implementation, and operation and maintenance optimization. This holistic and systematic approach ensures the minimization of social, environmental, and financial impacts. Wastewater is currently implementing an Asset Management Decision Support System (DSS) that uses business data to improve decision making and to demonstrate program sustainability. The DSS also ensures the establishment of an appropriate balance among cost, desired level of service, and acceptable risk throughout the asset lifecycle. 5. How many miles per year are inspected by closed- Fairfax County Bacteria Section 2.4 In FY15, over 204 miles of sanitary sewer were Section 2.4 revised circuit television (230?)? Are all pipes that are Environmental inspected. to include the miles found to be damaged repaired or placed on a watch Quality Wastewater uses proactive and continuous of sanitary sewer list? Advisory CCTV inspections to establish asset conditions. inspected. Council Assets are prioritized bases on the severity of defects found and scheduled for either monitoring, repair or rehabilitation. 6. Do we know how many exposed pipes and Fairfax County Bacteria Section 2.4 Wastewater is currently incorporating exposed No further action manholes are situated along streams? This puts the Environmental pipes and manhole rehabilitation as part of stream required. 206 repaired manholes and 9 pipes in perspective. Quality restoration projects and also performing routine Advisory inspection and repairs as part of the maintenance Council program. Currently, the County has identified 128 exposed sanitary sewer gravity assets scheduled for frequent monitoring pending rehabilitation. Wastewater is also expanding its creek crossing inspection initiative. The program was first implemented in FY2012 to identify and locate exposed pipes along and/or across streams. This effort will generate data on all exposed pipes and manholes.

B-2 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Public Comment Commenter Plan Reference County Response Action Taken 7. How many individual sewage disposal facilities are Fairfax County Bacteria Section 2.4 Virginia DEQ’s Guidance Memo 16-2006 directs No further action there (970?)? Environmental MS4 permittees to assess significant sources of required. Quality the pollutant of concern from facilities owned or Advisory operated by the MS4 permittees that are not Council covered under a separate VPDES permit. In this action plan, the County has identified septic or individual sewage disposal facilities on County properties subject to a bacteria TMDL and draining to the MS4. The Health Department's Onsite Sewage and Water Program administers state and local regulations for sewage disposal systems and private well water supplies to ensure proper construction, operation, and maintenance in Fairfax County. There are currently 1,050 alternative onsite sewage systems in the inventory maintained by the Fairfax County Health Department. 8. How many septic systems are there? Have we Fairfax County Bacteria Section 2.4 Virginia DEQ’s Guidance Memo 16-2006 directs No further action mapped areas of failing septic systems? Of some Environmental MS4 permittees to assess significant sources of required. 21,000 (?) septic systems, there were about 4,200 Quality the pollutant of concern from facilities owned or pump-outs, which meets the 5-year requirement on Advisory operated by the MS4 permittees that are not average. Do we have a system for Council covered under a separate VPDES permit. In this recording/tracking pump-outs? action plan, the County has identified septic or individual sewage disposal facilities on County properties subject to a bacteria TMDL and draining to the MS4. The Health Department's Onsite Sewage and Water Program administers state and local regulations for sewage disposal systems and private well water supplies to ensure proper construction, operation, and maintenance in Fairfax County. There are currently 22,000 onsite sewage systems in the inventory maintained by the Fairfax County Health Department. Of those, 4,538 were pumped out between 1/1/2016 – 12/31/2016.

B-3 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Public Comment Commenter Plan Reference County Response Action Taken 9. Reduce large grassy areas on county properties to Friends of Chesapeake; N/A County properties have been evaluated to No further action reduce runoff, create more native habitat and deter Dyke Marsh Benthic; identify opportunities to reduce stormwater required. the geese population; Bacteria runoff and improve habitat. Where practicable, trees and buffers are planted to reduce managed turf areas. The UFMD provides input to Capital Facilities on tree planting and landscape plantings to reduce turf grass areas and employ natural landscaping practices during new project designs, including reducing maintenance requirements and costs. 10. Implement all of the watershed plans; Friends of All N/A The County is actively implementing the No further action Dyke Marsh watershed management plans designed to cover required. each of the County’s 30 watersheds. Potential projects identified in these plans are implemented based on an evaluation of project feasibility and cost/benefit analysis. For a list of projects implemented by watershed visit: http://www.fairfaxcounty.gov/dpwes/stormwate r/projects/project_list.htm 11. Expand public education efforts to persuade people Friends of Bacteria N/A The County promotes and publicizes the proper An evaluation of the to collect pet waste; Dyke Marsh disposal of pet waste per Section I.B.2.j)1)(e) of use of inserts in dog the MS4 permit, including a dog waste PSA and license fee renewal pet waste education activities such as Stormy the reminders that are Raindrop education materials for school children. mailed to registered The County also participates in a regional dog owners in the education campaign coordinated by the Northern county has been Virginia Clean Water Partners (see added to Section 2.7 www.onlyrain.org). of the Bacteria TMDL Action Plan. 12. Monitor and report runoff from dog parks; Friends of Bacteria N/A There are two dog parks that drain to bacteria Dog Park evaluation Dyke Marsh impaired waterbodies. These are listed in the included in Section TMDL action plan. The County will modify the 2.5 of the Bacteria action plan to include an evaluation of dog waste TMDL Action Plan. practices at these two dog parks. Visual assessment of the condition of the parks is a more cost-effective approach than actual water quality monitoring of runoff from the parks.

B-4 Fairfax County Bacteria TMDL Action Plan Final Submittal to DEQ – March 31, 2017

Public Comment Commenter Plan Reference County Response Action Taken 13. Create an aggressive public outreach program to Friends of All N/A The County promotes and publicizes the proper No further action discourage large grassy areas and use of fertilizers Dyke Marsh use, application, and disposal of pesticides, required. and lawn chemicals, to encourage people to create herbicides, and fertilizers per Section more native and natural habitat; I.B.2.j)1)(h) of the MS4 permit. The County partners with the NVSWCD to promote individual and group involvement in local water quality improvement initiatives and encourage private property owners to implement voluntary stormwater management techniques and/or retrofits in accordance with sections I.B.2.j)1)(b) and (i) of the MS4 permit. One such program is the Home Turf program, a Virginia Healthy Lawns program that provides assistance for homeowners to determine just what their lawn needs to be as healthy as possible (see www.fairfaxgardening.org/home-turf/). Efforts are being made to raise awareness of our collective impact on the environment and to change behaviors, but it is important to note that this kind of cultural change takes time.

B-5