City of Richmond, Virginia Chesapeake Bay TMDL Action Plan · 2016-08-19 · Chesapeake Bay TMDL...

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City of Richmond, Virginia Chesapeake Bay TMDL Action Plan Permit No. VAR040005 2013-2018 Department of Public Utilities

Transcript of City of Richmond, Virginia Chesapeake Bay TMDL Action Plan · 2016-08-19 · Chesapeake Bay TMDL...

City of Richmond, Virginia

Chesapeake Bay TMDL

Action Plan

Permit No. VAR040005

2013-2018

Department of Public Utilities

Chesapeake Bay TMDL Action Plan Permit No. VAR040005

2013-2018

Department of Public Utilities, Richmond, Virginia September 2015

City of Richmond Chesapeake Bay TMDL Action Plan Table of Contents

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Table of Contents

List of Figures .............................................................................................................................................. iii

List of Tables ............................................................................................................................................... iv

List of Abbreviations .................................................................................................................................... v

Executive Summary .................................................................................................................................... vi

1. Introduction ....................................................................................................................................... 1-1

2. Legal Authority for TMDL Implementation ....................................................................................... 2-1

2.1 Current Program and Existing Legal Authority ...................................................................... 2-1

2.2 New or Modified Legal Authority ............................................................................................ 2-1

2.3 Means and Methods to Address Discharges from New Sources ........................................ 2-1

3. POC Loads and Required Reductions .............................................................................................. 3-1

3.1 Definition of the MS4 Service Area ........................................................................................ 3-1

3.1.1 City of Richmond Boundary ...................................................................................... 3-2

3.1.2 2000 US Census Urban Areas ................................................................................. 3-2

3.1.3 Combined Sewer System ......................................................................................... 3-2

3.1.4 VPDES Permittees .................................................................................................... 3-2

3.1.5 Other MS4 Permittees ............................................................................................. 3-4

3.1.6 Forested Lands and Wetlands ................................................................................. 3-5

3.1.7 Agricultural Lands ..................................................................................................... 3-6

3.1.8 James River and Open Waters ................................................................................ 3-6

3.1.9 Stormwater Runoff between Jurisdictions .............................................................. 3-6

3.1.10 Delineation of the Final MS4 Service Area ............................................................. 3-7

3.2 Estimated Existing Source Loads........................................................................................... 3-8

3.2.1 2009 Pervious and Impervious Land Cover ........................................................... 3-8

3.2.2 Annual POC Load Calculations – Existing Sources as of 2009 .......................... 3-10

3.3 Calculated Pollutant of Concern Required Reductions ..................................................... 3-11

3.4 Additional Source Loads and Required Reductions .......................................................... 3-12

3.4.1 Means and Methods to Offset Increased Loads from New Sources Initiating

Construction between July 1, 2009 and June 30, 2014 ................................... 3-12

3.4.2 Means and Methods to Offset Increased Loads from Grandfathered Projects that

Begin Construction after July 1, 2014 ................................................................ 3-14

3.5 Total First Permit Term Required Reductions .................................................................... 3-15

4. Means and Methods to Meet Required Reductions and Schedule ............................................... 4-1

4.1 Historical BMP Data ................................................................................................................ 4-1

4.2 Pollutant Reduction Project Types ......................................................................................... 4-1

4.3 Projects for Pollutant Removal Credit.................................................................................... 4-1

4.3.1 Reedy Creek Stream Restoration ............................................................................ 4-2

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4.3.2 Rattlesnake Creek Stream Restoration ..................................................................4-3

4.3.3 Albro Creek Stream Restoration ..............................................................................4-4

4.3.4 Pocosham Creek Stream Restoration .....................................................................4-5

4.3.5 Maury Cemetery Stream Restoration ......................................................................4-7

4.3.6 First Permit Term Pollutant Reduction Credit .........................................................4-8

4.3.7 Other Water Quality Projects in Planning or Implementation ................................4-9

4.4 Implementation Schedule and Estimated Cost to Complete ...............................................4-9

4.5 A List of Future Projects and Associated Acreage that Qualify as Grandfathered ..............4-9

5. Public Comments on Draft Action Plan ............................................................................................5-1

6. Conclusion .........................................................................................................................................6-1

7. Limitations .........................................................................................................................................7-1

8. References ........................................................................................................................................8-1

Appendix A: Maps.......................................................................................................................................A-1

Appendix B: Source Data…………………………………………………………………………………………………………....B-1

Appendix C: List of Existing Legal Authority..............................................................................................C-1

Appendix D: BMPs Constructed Between June 30, 2009 and July 1, 2014……………………………….…..D-1

Appendix E: Modifications to the Plan ......................................................................................................E-1

List of Figures

Figure ES-1. City of Richmond MS4 service area ...................................................................................... vii

Figure ES-2. Current condition of Pocosham Creek (dated October 2013) ............................................. x

Figure ES-3. Current condition of Maury Cemetery Creek (dated December 2013) ............................... xi

Figure 1-1. Richmond and the extents of the James River Basin. .........................................................1-1

Figure 3-1. VPDES Permits within the City ...............................................................................................3-4

Figure 3-2. VDOT ROW within the City ......................................................................................................3-5

Figure 3-3. Forested land within the City .................................................................................................3-6

Figure 3-4. Impervious areas within the MS4 service area ....................................................................3-8

Figure 4-1. Approximate location of Reedy Creek stream restoration ...................................................4-2

Figure4-2. Approximate location of the Rattlesnake Creek stream restoration ....................................4-3

Figure 4-3. Approximate location of the Albro Creek stream restoration ..............................................4-5

Figure 4-4. Approximate location of the Pocosham Creek stream restoration .....................................4-6

Figure 4-5. Approximate location of the Maury Cemetery Creek stream restoration ...........................4-7

Figure 1: MS4 Service Area Delineation ..................................................................................................... 2

Figure 2: First Permit Term Projects ........................................................................................................... 2

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List of Tables

Table ES-1 Overview of the Chesapeake Bay TMDL Action Plan Document Requirements................... vi

Table ES-2. Areas of Inclusion and Exclusion from the MS4 Service Area ............................................ viii

Table ES-3. Existing Source Loads for the James River Basin ............................................................... viii

Table ES-4. Total Reductions Required During First Permit Cycle ............................................................ ix

Table ES-5. First Permit Term Pollutant Reduction Credits ...................................................................... xii

Table ES-6. First Permit Term Pollutant Reduction Requirements and Second Permit Term Credit ...xii

Table ES-7. First Permit Term Implementation Schedule and Estimated Cost to Complete ............... xiii

Table 3-1. Individual VPDES Permittees ..................................................................................................3-2

Table 3-2. General VPDES Permittees .....................................................................................................3-3

Table 3-3. Other Municipal Separate Storm Sewer Systems .................................................................3-4

Table 3-4. Areas of Inclusion and Exclusion from the MS4 Service Area .............................................3-7

Table 3-5. MS4 Service Area Land Cover in 2009 and 2014 ................................................................3-9

Table 2-6. Surface Runoff into the MS4 from Other Jurisdictions ...................................................... 3-10

Table 3-7. Existing (2009) Source Loads for the James River Basin .................................................. 3-11

Table 3-8. Required POC Reduction Rates from Existing (2009) Sources for the James River

Basin…………………………………………………………………………………………………………………………………3- 11

Table 3-9. First Permit Term Required Reductions from Existing (2009) Sources for the James River

Basin ............................................................................................................................................... 3-12

Table 3-10. Post-Development Conditions July 1, 2014 ..................................................................... 3-13

Table 3-11. Total Load Changes from New Sources between June 30, 2009 and July 1, 2014 ..... 3-13

Table 3-12. Net Load Change (Total Load Change Minus Reductions from Implemented BMPs)... 3-14

Table 3-13. Additional Reductions Required During First Permit Cycle ............................................. 3-14

Table 3-14. Total Reductions Required During First Permit Cycle ...................................................... 3-15

Table 4-1: Pollutant Removal Calculations for Reedy Creek Stream Restoration ................................4-3

Table 4-2: Pollutant Removal Calculations for Rattlesnake Creek Stream Restoration ......................4-4

Table 4-3: Pollutant Removal Calculations for Albro Creek Stream Restoration ..................................4-5

Table 4-4: Pollutant Removal Calculations for Pocosham Creek Stream Restoration .........................4-6

Table 4-5: Pollutant Removal Calculations for Maury Cemetery Stream Restoration ..........................4-8

Table 4-6. First Permit Term Pollutant Reduction Credits .....................................................................4-8

Table 4-7. First Permit Term Pollutant Reduction Requirements and Second Permit Term Credit ...4-8

Table 4-8. First Permit Term Implementation Schedule and Estimated Cost to Complete ................ 4-9

Table D-1. BMPs Constructed between 7/1/2009 and 7/1/2014 (Filtered from 'City of Richmond

SCM Database 10-1-14.xlsx') ............................................................................................................... 2

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List of Abbreviations

1 Ac acre(s) 21 Plan Chesapeake Bay TMDL Action Plan

2 Ac-ft acre-foot(feet) 22 POC pollutant of concern

3 BMP best management practice 23 ROW right-of-way

4 CIP Capital Improvement Plan 24 SLAF Stormwater Local Assistance Fund

5 City City of Richmond 25 TMDL total maximum daily load

6 CSS combined sewer system 26 TN total nitrogen

7 DEQ Virginia Department of Environmental 27 TP total phosphorus

8 Quality

9 DOF Virginia Department of Forestry

10 EOS edge of stream

11 FIA Forest Inventory and Analysis

12 FWS Fish and Wildlife Service

13 GIS geographic information system

14 lb pound(s)

15 lf linear foot/feet

16 MS4 municipal separate storm sewer

17 system

18 NED National Elevation Dataset

19 NLCD National Land Cover Dataset

20 NWI National Wetlands Inventory

28 TSS total suspended solids

29 USFS United States Forest Service

30 USGS United States Geological Survey

31 VAG11 General VPDES Permit for Concrete

32 Products Facilities

33 VAG84 Nonmetallic Mineral Processing

34 General Permit

35 VAR05 General VPDES Permit for Stormwater

36 Associated with an Industrial Activity

37 VDOT Virginia Department of Transportation

38 VPDES Virginia Pollutant Discharge Elimination

39 System

40 yr year(s)

41

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City of Richmond Chesapeake Bay TMDL Action Plan Executive Summary

Executive Summary

The City of Richmond (City) has developed this first permit term Chesapeake Bay Total Maximum

Daily Load (TMDL) Action Plan (Plan) as required in the 2013-2018 General Permit for Discharges of

Stormwater from Small Municipal Separate Storm Sewer Systems (Permit Term II MS4 Permit) and in

accordance with the Virginia Department of Environmental Quality (DEQ) Chesapeake Bay TMDL

Action Plan Guidance Document (Guidance Document) dated May 18, 2015. This Plan required an

evaluation of the 2009 MS4 boundary, calculation of the pollutant of concern (POC) loading and first

permit term required reductions, projects to meet the reductions, a legal authority review of the City’s

ordinances and other documents that allow the City to meet the requirements of the Plan, and a

summary of the public comment process. Table ES-1 provides an overview of the Phase II MS4

Permit requirements and the corresponding section where the requirement is addressed.

Table ES-1 Overview of the Chesapeake Bay TMDL Action Plan Document Requirements

General Permit Section

Description of Requirement Corresponding Section(s)/Appendix of

this TMDL Action Plan Page Number(s)

I.C.2.a.(1) Current program and existing legal authority Section 2.1 2-1

I.C.2.a.(2) New or modified legal authority Section 2.2 2-1

I.C.2.a.(3) Means and methods to address discharges from new sources Section 2.3 2-1

I.C.2.a.(4) Estimated existing source loads Section 3.2 3-8

I.C.2.a.(5) Calculated total pollutant of concern required reductions Section 3.3 3-11

I.C.2.a.(6) Means and Methods to meet the required reductions and schedule Sections 4.3 and 4.4 4-1 and 4-9

I.C.2.a.(7) Means and methods to offset increased loads from new sources initiating construction between July 1, 2009 and June 30, 2014

Sections 3.4.1 and 4.3 3-13 and 4-1

I.C.2.a.(8) Means and methods to offset increased loads from grandfathered

projects that begin construction after July 1, 2014 Section 3.4.2 3-15

I.C.2.a.(9) Modifications to the TMDL or watershed implementation plan Appendix D D-1

I.C.2.a.(10) A list of future projects and associated acreage that qualify as

grandfathered Section 4.5 4-9

I.C.2.a.(11) An estimate of the expected cost to implement the necessary

reductions Section 4.4 4-9

I.C.2.a.(12) Public comments on the draft action plan Section 5 5-1

The 2009 MS4 service area was delineated with spatial data provided by the City, as well as

datasets obtained from the US Census Bureau, DEQ, and US Geological Survey (USGS) National

Elevation Dataset (NED). The list of datasets collected for this Plan is included in Appendix B. The

service area is the City boundary, excluding the combined sewer system (CSS) service area, VPDES

permittees and other MS4s, forested areas greater than half an acre, open water, and areas that

drain by surface runoff out of the MS4 service area. The areas of direct surface runoff into the MS4

from other jurisdictions were delineated and added to the MS4 service area. Figure ES-1 shows the

exclusion areas and the MS4 service area. Table ES-2 lists each exclusion type and the incremental

change in the MS4 service area.

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Figure ES-1. City of Richmond MS4 service area

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Table ES-2. Areas of Inclusion and Exclusion from the MS4 Service Area

Area Category Area (Ac)

City of Richmond Boundary 40,011

Exclusion Areas

CSS 10,618

VPDES permits and other MS4s (excluding VDOT) 1,043

VDOT Roads 597

Forested Lands and Wetlands 5,188

Agricultural Lands 0

Open Water 2,222

Surface Flow 483

Total Exclusion Area (Non-Overlapping)a 18,631

Total MS4 Service Area within the City Boundary 21,380

Inclusion Areas:

Surface Inflow 22

Total Inclusion Area 22

Total MS4 Service Area 21,402

a. The total exclusion area is less than the sum of the individual exclusion areas because some of the individual exclusion

areas overlap.

The 2009 land cover characteristics were estimated from the current (2014) impervious land cover

provided by the City in geographic information systems (GIS) files. The annual POC loads for existing

development were calculated from the 2009 land cover using the edge of stream (EOS) loading rates

provided in the Phase II MS4 Permit for the James River Basin, as shown in Table ES-3.

Table ES-3. Existing Source Loads for the James River Basin

Subsource

Pollutant

Total Existing Acres

Served by MS4

(06/30/09)

2009 EOS

Loading Rate

(lb/Ac/yr)

Estimated Total POC

Load Based on 2009

Progress Run (lb/yr)

Estimated Total

POC Load

(lb/yr)

Regulated Urban

impervious

Total Nitrogen

7,231.38

9.39

67,902.69

166,955.30

Regulated Urban Pervious 14,170.62 6.99 99,052.51

Regulated Urban

impervious

Total

Phosphorus

7,231.38

1.76

12,727.23

19,812.54

Regulated Urban Pervious 14,170.62 0.5 7,085.31

Regulated Urban

impervious Total

Suspended

Solids

7,231.38

676.94

4,895,212.70

6,327,578.62

Regulated Urban Pervious 14,170.62 101.08 1,432,365.92

After the existing source loads were calculated, the first permit term progress of five percent was

calculated for existing development and new sources initiating construction between July 1, 2009,

and June 30, 2014 (Special Condition 7).

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The required reductions for new sources were calculated using the aggregate accounting method as

described in Example II.2 of the Guidance Document dated May 18, 2015. The total first permit

term required reductions are summarized in Table ES-4. The City does not anticipate the

construction of any grandfathered projects (Special Condition 8) initiating construction after July 1,

2014.

Table ES-4. Total Reductions Required During First Permit Cycle

Pollutant

Existing Development

Required Reductions

(lb/yr)

New Sources (Special Condition 7)

Required Reductions

(lb/yr)

Grandfathered Projects (Special Condition 8)

Required Reductions

(lb/yr)

Total First Permit Term

Required Reductions

(lb/yr)

Total Nitrogen 602.72 15.51 0 618.23

Total Phosphorus 127.50 8.95 0 136.45

Total Suspended Solids 55,218.73 4,041.69 0 59,260.42

The City is currently operating a program to select and implement projects to achieve the required

reductions for the current and future permit cycles. Five projects have been identified by the City for

this Plan:

Reedy Creek Stream Restoration

Rattlesnake Creek Stream Restoration

Albro (Goode’s) Creek Stream Restoration

Pocosham Creek Stream Restoration

Maury Cemetery Stream Restoration

Reedy Creek Stream Restoration

Reedy Creek is a tributary of the James River draining approximately 3,075 acres of urban and

suburban lands in the southwestern portion of the City. The project will restore approximately 2,200

linear feet of the Reedy Creek and the downstream portion of an unnamed tributary. The land on

which the project will be conducted is owned by the City and is administered by the Department of

Parks, Recreation and Community Facilities.

The two stream channels to be restored receive stormwater from a total of approximately 2,310

acres. The land cover of the contributing drainage area consists of seventeen percent forest and

open space, forty-four percent managed turf, and thirty-nine percent impervious areas. Restoration

of the stream channels is needed to restore geomorphic stability of the impaired stream channels,

remove pollutants from the upstream watersheds, and improve water quality in these stream

reaches and downstream.

Rattlesnake Creek Stream Restoration

Rattlesnake Creek is a tributary of the James River draining around 1,000 acres of mostly suburban

lands in the northwestern corner of the City of Richmond and south side of the James River. The

proposed stream restoration project will address 1,500 linear feet of the Rattlesnake Creek between

E. Weyburn Road and Chippenham Parkway.

The stream proposed for restoration receives drainage from approximately 840 acres of suburban

lands. The land cover of the contributing drainage area consists of thirty-five percent forest, forty-six

percent managed turf, and nineteen percent impervious. The current conditions of the stream reach

exhibit near vertical stream banks that are actively eroding. The stream provides minimal removal of

pollutants from the upstream watershed and contributes to downstream pollution.

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Restoration of the stream channel is needed to restore geomorphic stability of the impaired stream

channel and remove pollutants from stormwater and the upstream watershed.

Albro Creek Stream Restoration

The Albro Creek project will restore approximately 1,281 linear feet of stream and create 3.0 acres

of wetlands to restore and improve the water quality of Albro Creek (also called Bellemeade Creek),

which flows to the James River via Goode’s Creek. The local project site is separated from the

upstream section of Albro Creek by a large diversion pipe. The local drainage area upstream of the

restoration site is 35.17 acres, and the upstream portion of Albro Creek drains approximately 1,200

acres. Because the restored stream will have the potential to remove more nutrients than the local

drainage area (35.17 acres) is generating, a flow splitting structure will be utilized to convey

additional flows to the restored section of Albro Creek during wet weather events. Opportunities may

also exist for establishment of a conservation buffer around this tributary of Goode’s Creek. This

project is intended to improve water quality, provide flood protection, and reduce bank erosion.

Pocosham Creek Stream Restoration

The Pocosham Creek stream restoration project (Project) is located on a tributary of Pocoshock

Creek that flows into Falling Creek, which ultimately flows to the James River. This tributary drains

approximately 3,625 acres of mostly suburban and forest lands in the southwestern side of the City,

west of the James River. Approximately half of the watershed is located within the City-limits and the

other half is located in Chesterfield County. The restoration project will restore approximately a

5,990 linear feet of stream channel. Figure ES-2 is an example of the current condition of the creek.

Figure ES-2. Current condition of Pocosham Creek (dated October 2013).

A 6-foot wide trail will be constructed as part of the Pocosham Creek Stream Restoration project.

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The path will run the length of the restoration segment (approximately 6,000 linear feet) and will

utilize the access corridor created by the Contractor to construct the project. Access to the path will

be from the multiple construction entrances at the various locations along the project.

Maury Cemetery Creek Stream Restoration

The Maury Cemetery Stream Restoration project is located within the City’s Maury Cemetery and will

restore approximately 1,980 linear feet of stream channel. The project is bounded to the north by

Maury Street, to the south by North Hopkins Road, to the east by an existing CSX railroad, and to the

west by Maury Cemetery. This work is being performed to improve the overall function of the Maury

Cemetery Stream, including but not limited to preventing erosion, restoring habitat, and improving

the water quality function of the stream. Figure ES-3 is an example of the current condition of the

creek. The project is expected to include the following elements:

Modifying grades of the existing Maury Cemetery Stream

Demolition and removal of existing masonry and stone structures

Installation of new storm sewer pipe and/or extending existing storm sewer pipe

Installation of in-stream structures such as log J-hooks and fieldstone cross vanes

Vertical off setting of existing waterline

Adjusting rim of existing sanitary structures

Landscaping and restoration of all disturbed areas

Figure ES-3. Current condition of Maury Cemetery Creek (dated December 2013).

Each project is currently in design or in the planning process. The POC reduction for each project is

shown in Table ES-5. At a minimum, the City will ensure that projects will be in construction by June

30, 2018 to meet the five percent required progress. Progress greater than five percent will be

credited toward the second permit term Plan.

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Table ES-5. First Permit Term Pollutant Reduction Credits

Project

Total

Nitrogen

(lb/yr)

Total

Phosphorus

(lb/yr)

Total

Suspended

Solids

(lb/yr)

Reedy Creek Stream Restoration

165.00

149.60

98,736.00

Rattlesnake Creek Stream Restoration

112.50

102.00

67,320.00

Albro Creek Stream Restoration

96.08

87.11

57,491.28

Pocosham Creek Stream Restoration

449.25

407.32

268,831.20

Maury Cemetery Stream Restoration

148.50

134.64

88,862.40

Total

919.58

833.75

550,273.68

The first permit term required reductions will be exceeded and the additional credit will be included

in the second permit term Plan. The second permit term will require that the City meet a 35 percent

reduction requirement. The credit from this Plan to be applied in the second permit term includes

2.44 percent TN, 25.55 percent TP, and 41.43 percent TSS, as shown in Table ES-6.

Table ES-6. First Permit Term Pollutant Reduction Requirements and Second Permit Term Credit

Project

Total

Nitrogen

(lb /yr)

Total

Phosphorus

(lb /yr)

Total

Suspended

Solids

(lb /yr)

First Permit Term Reduction Credit 919.58 833.75 550,273.68

First Permit Term Required Reduction 618.23 136.45 59,260.42

Credit to be Applied in Second Permit Term 301.35 697.30 491,013.26

Percent Reduction to be Applied in Second Permit Term 2.44% 25.55% 41.43%

Table ES-7 provides the current project status, implementation schedule, and cost estimate for each

project. Pocosham Creek Stream Restoration and Maury Cemetery Stream Restoration are in the

planning process and anticipated to begin construction in August 2015. Reedy Creek, Rattlesnake

Creek, and Albro Creek are currently in design with construction anticipated to begin in late 2015.

The total cost of implementation is approximately $7 million.

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Table ES-7. First Permit Term Implementation Schedule and Estimated Cost to Complete

Project

Project Status

Estimated

Construction Start

Date

Estimated Cost to

Complete

Reedy Creek Stream Restoration In Design October 2015 $1,270,000

Rattlesnake Creek Stream Restoration In Design December 2015 $1,104,000

Albro Creek Stream Restoration In Design December 2015 $1,432,000

Pocosham Creek Stream Restoration Design Complete August 2015 $2,500,000

Maury Cemetery Stream Restoration Design Complete August 2015 $905,000

Total Estimated Cost to Complete Projects $7,211,000

In addition to the stream restoration projects described previously, the City is currently implementing

or planning to implement other projects throughout the City. The City currently conducts a street

sweeping program City-wide. The City is also conducting a green alleys program. This program is

creating buffer strips and other pervious areas in highly impervious areas throughout the City.

The City is also planning additional projects in fiscal years 2016 and 2017. Specific project data is

not yet available for inclusion in the first permit term Plan; however, the City will document these

projects as they are designed and constructed and incorporate them into future Plans.

In addition to the development of the MS4 service area and projects to meet the five percent

required reduction, the City has provided a review of the legal authority it has to implement the

Chesapeake Bay TMDL. This review is provided in Section 2. An overview of the public review

process is included in Section 5.

This first permit term TMDL Action Plan will become effective within 90 days of its submittal to DEQ,

unless the City is otherwise notified. It represents the City’s plan for meeting its Phase II MS4 Permit

requirements for the Chesapeake Bay TMDL Special Condition through 2018.

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Richmond Chesapeake Bay TMDL AP - final

Section 1

Introduction

The City of Richmond (City) has developed this first permit term Total Maximum Daily Load (TMDL)

Action Plan (Plan) for the Chesapeake Bay nutrient and sediment TMDL, as required by the 2013-

2018 General Permit for Discharges of Stormwater from Small (Phase II) Municipal Separate Storm

Sewer Systems (MS4s) Number VAR040005. This Plan was developed following the Virginia

Department of Environmental Quality (DEQ) Chesapeake Bay TMDL Action Plan Guidance Document

(Guidance Document) dated May 18, 2015. This Plan is the first of three permit terms of

Chesapeake Bay TMDL Action Plans to be developed by the City to reduce the total nitrogen (TN),

total phosphorus (TP), and total suspended solids (TSS) loads from urban stormwater runoff.

The City is located within the James River Basin in central Virginia, and has a total land area of

40,011 acres, as shown in Figure 1-1. It is bordered by Chesterfield and Henrico Counties, and is

bisected by the James River. The City is located within the 2000 US Census Urban Cluster named

Richmond, Virginia.

Figure 1-1. Richmond and the extents of the James River Basin.

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Richmond Chesapeake Bay TMDL AP - final

City of Richmond Chesapeake Bay TMDL Action Plan Section 1

The following sections explain the methods for the delineation of the 2009 City MS4 service area,

calculation of the pollutant of concern (POC) loads and reduction requirements, and the projects that

the City plans to implement to meet the reductions.

Maps of the MS4 service area and a list of the spatial datasets used for this evaluation are provided

in Appendices A and B, respectively. In addition, this Plan includes an evaluation of the current and

future legal authority to implement the Plan, a description of the public comment process, and an

estimate of implementation costs.

Section 2

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Richmond Chesapeake Bay TMDL AP - final

Legal Authority for TMDL

Implementation

The Phase II MS4 Permit requires that the Plan document the current program and legal authority,

new or modified legal authority, and the means and methods to address discharges from the new

sources.

2.1 Current Program and Existing Legal Authority

Richmond has reviewed its current MS4 Program Plan and has determined that the authority as

stated in the current MS4 Program Plan is sufficient for compliance with this special condition.

Please refer to Appendix C for a list of relevant existing legal authority.

A list of the current program and existing legal authority will be provided by the City in the final Plan.

2.2 New or Modified Legal Authority

As described in Section 2.1, existing authority is sufficient for compliance with this special condition.

Therefore, no new or modified legal authority is considered necessary to meet the requirements of

this special condition.

2.3 Means and Methods to Address Discharges from New Sources

Richmond will adhere to the VSMP regulations for the implementation of post-development

stormwater management facilities.

3-1

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Section 3

POC Loads and Required

Reductions

In accordance with the MS4 permit and Guidance Document dated May 18, 2015, POC loads and

first permit required reductions were calculated from the City’s MS4 service area and land cover as

of June 30, 2009. The MS4 service area was developed from the City boundary and 2000 US

Census Urban Area; excluding the combined sewer system (CSS) service area, other MS4 and VPDES

permittees, forested areas, open water bodies, and areas of surface runoff away from the MS4.

After the MS4 service area was delineated, the surrounding areas were reviewed for areas of surface

runoff into the MS4. Figure 1 in Appendix A identifies the final MS4 service area and exclusion and

inclusion areas.

After the MS4 service area was defined, the land cover characteristics as of June 30, 2009 were

estimated, and POC loads and reductions were calculated based upon the James River Basin rates

provided in the Phase II MS4 Permit. Finally, additional loads from new sources were evaluated and

the total first permit term required reduction was calculated. Each of these steps is described

further in sections below.

3.1 Definition of the MS4 Service Area

The Guidance Document dated May 18, 2015 defines the initial MS4 service area as the 2000 US

Census Urban Areas within the municipality’s boundary. Areas occupied by the CSS, other MS4 and

VPDES permittees, forested areas, and open water bodies may be excluded from the MS4 service

area. Land areas that drain by surface runoff away from the MS4 may be excluded from calculations

of the City’s pollutant removal requirement. Similarly, areas that drain by surface runoff onto lands

currently served by the City MS4 must be included in calculations of the City’s pollutant removal

requirement.

The MS4 service area was delineated using spatial data provided by the City or obtained from other

sources, as documented in Appendix B. In accordance with the Guidance Document dated May 18,

2015, the initial MS4 service area was defined using the 2000 US Census Urban Areas and the City

boundary. Individual exclusion area files were created for VPDES and other MS4 permittees,

forested areas and wetlands, agricultural lands, and open waters. Some areas fall into more than

one exclusion category, and so exclusion areas are partially overlapping. The initial MS4 service area

was clipped in geographic information systems (GIS) program using each of the exclusion area files

to create an interim MS4 service area.

After the interim MS4 service area was developed, areas that drain by surface flow away from the

City MS4 were delineated in GIS and excluded from calculations of the City’s pollutant removal

requirement. Similarly, land areas outside of the City boundary that drain by surface flow onto lands

currently served by the City MS4 were delineated, because they contribute to the City’s pollutant

removal requirement. These surface flows out of and into the MS4 service area were subtracted

from or added to the interim service area to create the final MS4 service area for the first permit

term Plan.

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3.1.1 City of Richmond Boundary

The City boundary GIS file was downloaded from the City’s website in March 2014. This file consists

of a single polygon that represents the entire City including the James River. The total area of the

City, as represented in this file, is approximately 40,011 acres.

3.1.2 2000 US Census Urban Areas

The US Census Bureau defined urban areas during the 2000 census as a core of census blocks with

a minimum population density of 1,000 people per square mile and surrounding census blocks with

a minimum population density of 500 people per square mile. The 2000 US Census urban areas, as

revised in 2011, were downloaded from the US Census website in January 2015. The City boundary

is located entirely within the Richmond, Virginia Urban Cluster.

3.1.3 Combined Sewer System

Although the CSS service area is not specifically listed in Guidance Document dated May 18, 2015

as an exclusion area from the MS4, the CSS service areas are not part of the MS4, and are regulated

separately by DEQ. The CSS service area is delineated in a GIS file provided by the City in March

2014. The GIS file includes revisions dated February 2014 and represents the current system.

The CSS is primarily located in the northeastern portion of the City including the Virginia

Commonwealth University campus, with a smaller CSS located across the James River. The CSS

area encompasses approximately 10,618 acres of the City. Figure 1 in Appendix A displays the CSS

service area.

3.1.4 VPDES Permittees

Lands regulated under an Individual VPDES Permit for Industrial Stormwater Discharges—or any

General VPDES Permit that addresses industrial stormwater—may be excluded from the City MS4

service area. These permittees must meet stormwater discharge requirements as stated in their

permits. DEQ documents individual and general VPDES Permits in a statewide database and

provides permittee data on the DEQ website in Microsoft Excel spreadsheets. The spreadsheets

were accessed from the DEQ website in January 2015, and active permits located within the City

were selected from the files for GIS mapping.

There are five Individual VPDES permittees located within the City, as shown in Table 3-1. The table

includes permit number, facility name and address, permit type, and facility type.

Table 3-1. Individual VPDES Permittees

Permit No. Facility Address Permit Type Facility Type

VA0087734 Dominion - Materials and Metering Services Center 4307 Castlewood Rd Minor Industrial

VA0058378 Kinder Morgan Southeast Terminals LLC - Richmond 2 4110 Deepwater Terminal Rd Minor Industrial

VA0086151 Kinder Morgan Transmix Company LLC 3302 Deepwater Terminal Rd Minor Industrial

VA0063177 Richmond WWTP 1400 Brander St Major Municipal

VA0085499 Spruance Genco LLC 5001 Commerce Rd Minor Industrial

There are three types of General VPDES permits that may be excluded from the MS4 service area;

the General VPDES Permit for Stormwater Associated with Industrial Activity (VAR05), the General

VPDES Permit for Concrete Products Facilities (VAG11), and the General VPDES Permit for

Nonmetallic Mineral Mining (VAG84).

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Each of these permits addresses industrial stormwater discharge requirements that the operator

must achieve prior to discharging stormwater runoff from the permitted facility. The concrete

products facilities and nonmetallic mineral mining permits were added to the allowable exclusions in

the Guidance Document dated May 18, 2015. There are twenty-three general permittees within the

City, as shown in Table 3-2. Twenty of the permits are for industrial activities, one permit is for

concrete products facilities, and two permits are for nonmetallic mineral mining.

Table 3-2. General VPDES Permittees

Permit No. Facility Address Permit Type

VAR050554 Spruance Genco LLC 5001 Commerce Rd Industrial Activity

VAR050563 Smith Iron and Metal Company Inc. 3000 Bells Rd Industrial Activity

VAR050588 SMM Southeast LLC - Richmond 3220 Deepwater Terminal Rd Industrial Activity

VAR050603 Eubank Trucks Incorporated 3708 N Hopkins Rd Industrial Activity

VAR050613 Carpenter Company Richmond Division 2400 Jefferson Davis Hwy Industrial Activity

VAR050657 UPS Freight - Richmond 5401 Midlothian Tpke Industrial Activity

VAR050910 Upaco Adhesives - Division of Worthen Industries 4105 Castlewood Rd Industrial Activity

VAR051019 Philip Morris USA Incorporated - Manufacturing Ctr 3601 Commerce Rd Industrial Activity

VAR051020 Port of Richmond 5000 Deepwater Terminal Rd Industrial Activity

VAR051027 Liphart Steel Company Incorporated 3308 Rosedale Ave Industrial Activity

VAR051103 Sonoco Products Company 1850 Commerce Rd Industrial Activity

VAR051133 Estes Express Lines 1200 Commerce Rd Industrial Activity

VAR051151 Packaging Corporation of America 2000 Jefferson Davis Hwy Industrial Activity

VAR051176 International Paper Company - Richmond Plant 2811 Cofer Rd Industrial Activity

VAR051484 Branscome Richmond - Deepwater Terminal Rd 2106 Deepwater Terminal Rd Industrial Activity

VAR051549 International Paper - Richmond Recycling Center 1308 Jefferson Davis Hwy Industrial Activity

VAR051818 Richmond Recycling Company 2500 Decatur St Industrial Activity

VAR051888 Kenan Transport LLC - 506 E Clopton St 506 E Clopton St Industrial Activity

VAR052028 Greater Richmond Transit Co – O/M 301 E Belt Blvd Industrial Activity

VAR052128 Alloy Polymers Incorporated 3310 Deepwater Terminal Rd Industrial Activity

VAG110308 Hanson Pipe and Precast - Richmond 2900 Terminal Dr Concrete Products Facility

VAG840078 Luck Stone - South Richmond Plant 2100 Deepwater Terminal Rd Nonmetallic Mineral Mining

VAG840120 Vulcan Construction Materials LP - Richmond Quarry 1500 Goodes St Nonmetallic Mineral Mining

A VPDES Permittee GIS file was developed from the City parcel GIS file and the VPDES permittee

spreadsheets. The City parcel GIS file was downloaded from the City website in January 2015. The

permittees were located by property address in GIS using the City parcel attributes and the permit

number and permit type were added as new attribute fields. The permit locations were then

reviewed with aerial imagery and surrounding parcel ownership data to determine whether

neighboring parcels appear to be contiguous permittee lands of the same land use. Figure 3-1

displays the locations of the land areas associated with the permits.

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Figure 3-1. VPDES Permits within the City.

3.1.5 Other MS4 Permittees

In addition to removing the VPDES permittees from the MS4 service area, other MS4 permittees

were identified within the City boundary. The MS4 permittees Excel spreadsheet was accessed from

the DEQ website in January 2015. Two other Phase II General MS4 permittees are located within the

City, as shown in Table 3-3. The Hunter Homes McGuire Veteran Affairs Hospital was identified using

the same process as the VPDES permittees, as discussed in Section 3.1.4 and shown in Figure 3-1.

Table 3-3. Other Municipal Separate Storm Sewer Systems

Permit No. Owner/Operator Designation Type

VAR040133 Virginia Department of Transportation Phase II State

VAR040074 Hunter Homes McGuire Veteran Affairs Hospital Phase II Federal

The roadways maintained by the Virginia Department of Transportation (VDOT), which owns a

statewide Phase II MS4 permit, were identified in two stages. First, the City parcel GIS file and the

City boundary GIS file were evaluated to identify undelineated areas in the parcel file. These voids

are typically roadway rights-of-way (ROWs), including VDOT-maintained roads. A VDOT ROW GIS file

was created by clipping a copy of the City boundary GIS file with the parcel information so that only

the roadway ROWs remained.

Next, the interstates within the City were identified. These include I-64, I-95, and I-195 and

associated on and off ramps. It is assumed that VDOT will be responsible for all stormwater within

their ROW areas, so no other modifications were made to the GIS file. The VDOT ROWs are

approximately 597 acres within the City boundary. Figure 3-2 includes the location of the VDOT

ROWs.

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Figure 3-2. VDOT ROW within the City.

3.1.6 Forested Lands and Wetlands

A raster image file was downloaded from VA Department of Forestry (DOF) website in April 2015.

The VA DOF file was created in 2005 using 2004 aerial imagery to identify forests that meet the US

Forest Service (USFS) Forest Inventory and Analysis (FIA) Program. The raster image classifies land

in three categories; water, forest, and non-forest. The resolution of the raster image is a 30 meter

grid.

The US Fish and Wildlife Service (FWS) National Wetlands Inventory (NWI) GIS file was downloaded

from the FWS website in June 2014. The FWS NWI metadata indicates that the wetlands within the

City were identified between 1994 and 2000. A review of the locations of NWI wetlands within the

City boundary indicated that the same locations were also included in the VA DOF raster image or the

open waters GIS files discussed in Section 3.1.8. As such, the FWS and NWI GIS file was not needed

for this analysis.

The raster image file was converted into a polygon GIS file and clipped to the City boundary. The

resulting file was then evaluated to isolate the forest land category and remove polygons that are

less than 0.5 acres. The final GIS file indicates approximately 5,188 acres of forested lands within

the City boundary. Figure 3-3 displays the locations of forested lands.

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3.1.7 Agricultural Lands

Figure 3-3. Forested land within the City.

DEQ added agricultural lands as a category of allowable MS4 service area exclusions in the

Guidance Document dated May 18, 2015.

A review of the current aerial imagery, as well as the 2011 US Geological Survey (USGS) National

Land Cover Dataset (NLCD), indicated that there were no significant agricultural lands within the City

boundary. As such, a City GIS file of agricultural lands was not created for this Plan.

3.1.8 James River and Open Waters

The James River and open waters GIS files were derived from two basemap GIS files accessed from

the City website in January 2015. The James River was selected from the StreamPolys GIS file. This

new James River exclusion area file was modified to include the small islands that drain directly into

the river. The other open waters are defined in the Lakes GIS file. This file was reviewed for

accuracy and used in its entirety to exclude surface waters from the MS4 service area. The total

area of the open waters, as represented in these files, is approximately 2,222 acres. Figure 1 in

Appendix A displays the Open Waters exclusion areas.

3.1.9 Stormwater Runoff between Jurisdictions

Although the drainage basin delineation for each outfall is an ongoing effort by the City, an initial

assessment of areas that drain by surface runoff into and out of the MS4 service area was

completed for the first permit term Plan. Surface runoff areas were delineated in GIS using current

aerial imagery, the City boundary, the stormwater conveyance system, the City contours, and USGS

National Elevation Dataset (NED) topography. The stormwater conveyance system GIS files were

provided by the City in March 2014 and represent the best available data for the current system.

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Contour lines were also provided by the City in March 2014 and represent the topography in two foot

intervals within the City boundary. The USGS NED files were accessed in January 2015 from the

USGS NED website. The NED GIS file is a regional raster image containing elevation data on a ten

meter grid. This file allowed for the review of locations outside of the County boundary.

Some areas within City boundary drain by surface runoff away from the City’s conveyance system

and out of the City, and thus are not served by the City MS4. These areas were excluded from the

POC load and required reduction calculations. Most of these areas are along the James River,

whereas others drain into the Chesterfield or Henrico MS4 service areas. The outflow areas

recommended for removal from the MS4 area are shown on Figure 1 in Appendix A. The total area

that drains by surface runoff out of the system is approximately 483 acres.

The City is responsible for treating the POC loads and meeting the required reductions for any area

served by the MS4, including those areas outside of the City boundary that reach the stormwater

conveyance system by surface runoff. Contour data and the USGS NED DEM were used to identify

these areas, which are displayed on Figure 1 in Appendix A. The total area that drains by surface

runoff into the system is approximately twenty-two acres.

The areas that drain by surface runoff incorporated into this first permit term Plan are an initial

assessment of the MS4 service area and drainage areas. It is recommended that the surface flow

GIS files be reevaluated after the outfall drainage basin delineation is complete, and that the revised

surface flows are included in the second permit term Plan.

3.1.10 Delineation of the Final MS4 Service Area

The development of the final MS4 service area was completed in GIS using the datasets described in

Sections 3.1 through 3.1.9 (Table 3-4). The first step was to evaluate the City boundary and the

2000 US Census Urban Areas, because the entire City boundary is included in the Urban Areas. The

initial MS4 service area is identical to the City area.

Table 3-4. Areas of Inclusion and Exclusion from the MS4 Service Area

Area Category Area (Ac)

City of Richmond Boundary 40,011

Exclusion Areas

CSS 10,618

VPDES permits and other MS4s (excluding VDOT) 1,043

VDOT Roads 597

Forested Lands and Wetlands 5,188

Agricultural Lands 0

Open Water 2,222

Surface Flow 483

Total Exclusion Area (Non-Overlapping)b 18,631

Total MS4 Service Area within the City Boundary 21,380

Inclusion Areas:

Surface Inflow 22

Total Inclusion Area 22

Total MS4 Service Area 21,402

b. The total exclusion area is less than the sum of the individual exclusion areas because some of the individual exclusion

areas overlap.

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The second step in delineation of the MS4 service area was to remove the exclusion areas from the

initial MS4 service area because the exclusion areas overlap. The sum of the individual exclusion

areas is greater than the total of the exclusions, as noted in Table 2-4. The final step to delineate

the MS4 service area was to add the surface flow inclusion area, also shown in Table 2-4. The final

MS4 service area to be used in the POC load and required reduction calculations is 21,402 acres.

3.2 Estimated Existing Source Loads

The baseline (2009) annual POC loading rates, as documented in the Phase II MS4 Permit and the

Guidance Document dated May 18, 2015, were estimated by the Chesapeake Bay Program using

the Watershed Model Phase 5.3.2. The 2009 pervious and impervious land cover within the service

area was estimated using the current impervious land cover and the historical USGS NLCD land

cover GIS files. The annual POC loads for the City were then calculated using the 2009 pervious and

impervious lands cover conditions within the MS4 service area.

3.2.1 2009 Pervious and Impervious Land Cover

The 2009 land cover characteristics were estimated from the 2014 impervious area in the City and

an estimate of the annual average change in land cover, which itself was derived from the 2006 and

2011 USGS NLCD GIS files. First, the current impervious cover GIS files within the City boundary was

accessed from the City website in January 2015. The City impervious areas are shown in three GIS

files: transportation surfaces, buildings, and road edge. Each type of impervious area was

delineated from aerial imagery. The road edge GIS file included lines at the edge of the pavement.

This file was converted to polygons and reviewed for accuracy. The impervious cover files were

clipped to the MS4 service area and the pervious cover was calculated as the remaining area, as

shown in Figure 3-4 and Table 3-5.

Figure 3-4. Impervious areas within the MS4 service area.

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Table 3-5. MS4 Service Area Land Cover in 2009 and 2014

Land Cover

2014 MS4

Land Cover

(ac)c

2006 NLCD

Land Cover

(ac)d

2011 NLCD

Land Cover

(ac)d

2006-2011

USGS Average

Annual Change

Estimated

2009 MS4

Land Cover

(ac)e

Impervious 7,378 5,799 5,953 0.144% 7,224

Pervious 14,002 15,544 15,390 -0.144% 14,156

Total Area 21,380 21,343 21,343 21,380

c. Impervious land cover provided by the City from the GIS basemap dataset. Impervious land cover was digitized from

aerial imagery.

d. Pervious and Impervious land covers calculated from USGS land cover raster imagery. Data resolution is a 30 meter

grid.

e. Dataset is an estimate of the historical land cover. GIS datasets from 2009 were not available.

The next step required evaluating the 2006 and 2011 USGS NLCD GIS files to calculate an annual

average change in land cover. These files were accessed from the NLCD website in January 2015.

The files contain raster images on a thirty meter grid that are classified as one of twenty land cover

types. The raster images were clipped to the MS4 service area and the raster images were

converted to polygons. The land cover within the City MS4 service area includes fifteen land cover

classifications:

Open Water

Developed Open Space

Developed, Low Intensity

Developed, Medium Intensity

Developed, High Intensity

Barren Land

Deciduous Forest

Evergreen Forest

Mixed Forest

Shrub/Scrub

Grassland/Herbaceous

Pasture/Hay

Cultivated Crops

Woody Wetlands

Emergent Herbaceous Wetlands.

Each location identified as the pasture/hay or cultivated crops land cover classifications were

evaluated with aerial imagery, and determined to be sites that were under construction. Therefore,

these sites were categorized as their pre-development land cover (pervious land cover types) for this

calculation. The impervious area for each dataset was calculated from the four developed land

cover classes and the open water land cover.

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The average impervious area for each developed land cover was estimated for each land cover type

based upon the NLCD definition; ten percent for Developed Open Space, thirty-five percent for

Developed Low Intensity, sixty-five percent for Developed Medium Intensity, and ninety percent for

Developed High Intensity. The percentage of impervious area was multiplied by the total area of

each developed classification and the open water area was added to the developed acreage. The

open water areas are locations that do not align with the more accurate lakes file which was used to

delineate the open water exclusion area, as described in Section 3.1.8. The pervious area included

all other land cover classifications and the remaining developed areas. The results are shown in

columns 3 and 4 of Table 2-5. Due to the raster image clipping, some edge areas were not included

in the polygon GIS files, but the small excluded area (thirty-seven acres) was consistent between

both datasets.

After calculating the land cover in 2006 and 2011, the average annual change in land cover was

calculated, as shown in Table 2-5. The average annual change was applied to the 2014 City land

cover to estimate the land cover conditions in 2009. The total impervious area within the MS4

service area in 2009 was estimated to be 7,224 acres, which is approximately thirty-four percent of

the MS4 service area. The urban pervious cover in 2009 was estimated to be 14,156 acres, which

is approximately sixty-six percent of the MS4 service area.

Based upon a review of aerial imagery, areas that surface runoff into the MS4 surface area from

outside of the City boundary were estimated to have the same proportion of pervious and impervious

land cover as areas within the City. These areas included seven acres of impervious cover and

fifteen acres of pervious cover, as shown in Table 3-6.

Table 2-6. Surface Runoff into the MS4

from Other Jurisdictions

Land Cover 2009

% Land Cover

Estimated 2009 Surface

Runoff Area (Ac)

Impervious 34% 7

Pervious 66% 15

Total Area 22

3.2.2 Annual POC Load Calculations – Existing Sources as of 2009

The final MS4 service area defined in Section 3.1.10, and the land cover estimates described in

Section 3.2.1, were used to calculate the annual pollutant loads for existing sources under 2009

conditions. The annual pollutant loading rates are prescribed in the Phase II MS4 Permit by drainage

basin. Pollutant loading rates have been defined for pervious and impervious urban lands for TN, TP,

and TSS at the edge of stream (EOS).

Table 3-7 presents the existing source loads for the City, within the James River Basin, as calculated

from loading rates in Table 2a of the Phase II MS4 Permit. The existing source loads are 166,956

pounds per year of TN, 19,812 pounds per year of TP, and 6,327,579 pounds per year of TSS.

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Table 3-7. Existing (2009) Source Loads for the James River Basin

Subsource

Pollutant

Total Existing

Acres Served by

MS4 (06/30/09)

2009 EOS

Loading Rate

(lb/Ac/yr)

Estimated Total POC

Load Based on 2009

Progress Run (lb/yr)

Estimated

Total POC Load

(lb/yr)

Regulated Urban

impervious

Total

Nitrogen

7,231.38

9.39

67,902.69

166,955.30

Regulated Urban

Pervious

14,170.62

6.99

99,052.51

Regulated Urban

impervious

Total

Phosphorus

7,231.38

1.76

12,727.23

19,812.54

Regulated Urban

Pervious

14,170.62

0.5

7,085.31

Regulated Urban

impervious

Total

Suspended

Solids

7,231.38

676.94

4,895,212.70

6,327,578.62

Regulated Urban

Pervious

14,170.62

101.08

1,432,365.92

3.3 Calculated Pollutant of Concern Required Reductions

The required reductions of POCs from existing (2009) sources in the Phase II MS4 Permit are

consistent with the Chesapeake Bay TMDL and the Virginia Permit Terms I and II Watershed

Improvement Plans, and are based on the Chesapeake Bay Model Phase 5.3.2 L2 scoping run for

existing developed lands. The total required reductions from the annual pollutant loading rates vary

for each pollutant and land cover. As specified in the Virginia Permit Term I Watershed Improvement

Plan, the required first permit term pollutant reductions are five percent of the total required

reductions specified in the L2 scoping run. The City has identified projects to achieve the required

pollution reductions to the maximum extent practicable for the first permit term as detailed in

Section 4 of this Plan. The total required reductions and first permit term reductions for the James

River Basin are identified in Table 3-8.

Table 3-8. Required POC Reduction Rates from Existing (2009) Sources for the James River Basin

Subsource

Pollutant

2009 EOS Loading

Rate (lb/ac/yr)

Total % Required

Reduction

Total Required

Reduction

(lb/ac/yr)

First Permit Term

Required Reduction

(lb/ac/yr)

Regulated Urban

impervious

Total Nitrogen

9.39

9%

0.8451

0.042255

Regulated Urban Pervious 6.99 6% 0.4194 0.02097

Regulated Urban

impervious

Total Phosphorus

1.76

16%

0.2816

0.01408

Regulated Urban Pervious 0.5 7.25% 0.03625 0.0018125

Regulated Urban

impervious

Total Suspended

Solids

676.94

20%

135.388

6.7694

Regulated Urban Pervious 101.08 8.75% 8.8445 0.442225

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Table 3-9 presents the required reductions from existing sources, as calculated from reduction rates

in Table 3a of the Phase II MS4 Permit. The first permit term required reductions for existing sources

within the City are 602.72 pounds of TN, 127.50 pounds of TP, and 55,218.73 pounds of TSS.

Table 3-9. First Permit Term Required Reductions from Existing (2009) Sources for the James River Basin

Subsource

Pollutant

Total Existing Acres

Served by MS4

(06/30/09)

First Permit Cycle

Required Reduction

in Loading Rate

(lb/ac/yr)

Total Reduction

Required First

Permit Cycle (lb/yr)

Total Reduction

Required First

Permit Cycle

(lb/yr)

Regulated Urban

impervious

Total Nitrogen

7,231.38

0.042255

305.56

602.72

Regulated Urban

Pervious

14,170.62

0.02097

297.16

Regulated Urban

impervious

Total Phosphorus

7,231.38

0.01408

101.82

127.50

Regulated Urban

Pervious

14,170.62

0.0018125

25.68

Regulated Urban

impervious

Total Suspended

Solids

7,231.38

6.7694

48,952.13

55,218.73

Regulated Urban

Pervious

14,170.62

0.442225

6,266.60

3.4 Additional Source Loads and Required Reductions

In addition to the required pollution reductions for existing development, the City must account for

any increased pollutant loads from new sources and grandfathered projects. New sources are

addressed under Phase II MS4 Permit Special Condition 7 and grandfathered projects are addressed

under Phase II MS4 Permit Special Condition 8. For the first permit term Plan, the City is required to

provide additional treatment to remove five percent of the net increase in pollutant loads for any

developments that meet the criteria of Special Condition 7. The City must provide treatment for the

net increase in pollutant loads for any project that meets the criteria of Special Condition 8.

3.4.1 Means and Methods to Offset Increased Loads from New Sources Initiating

Construction between July 1, 2009 and June 30, 2014

Special Condition 7 is a Phase II MS4 permit requirement that pertains to certain projects that

initiated construction between July 1, 2009 and June 30, 2014 and meet the following criteria:

Greater than one acre land disturbance

Increase in the POC loads from existing condition

An impervious land cover condition greater than 16 percent for the design of post-

development stormwater management facilities

The City is required to provide additional POC load reductions for any project that meets the Special

Condition 7 criteria. The aggregate accounting method was selected to determine the additional

treatment requirements from new sources, as described in Example II.2 in the Guidance Document

dated May 18, 2015.

The additional POC reductions associated Special Condition 7 were calculated by several steps.

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First, the “post-development” POC loads as of July 1, 2014 were calculated with the 2014 land cover

within the City shown in Table 3-5 and the estimated surface water runoff from other jurisdictions

shown in Table 3-6, using the same EOS loading rates as the 2009 “pre-development” condition

included in Table 3-7. Table 3-10 shows the estimated “post-development” POC loading within the

MS4 service area.

Table 3-10. Post-Development Conditions July 1, 2014

Subsource

Pollutant Total Existing Acres Served by the MS4

(07/01/14)

2009 EOS Loading

Rate (lb/Ac)

Estimated Total POC Load as of

07/01/1

4 Regulated Urban

Impervious

Total Nitrogen

7,385.59 9.39 69,350.71

Regulated Urban

Pervious 14,016.41 6.99 97,974.69

Regulated Urban

Impervious

Total Phosphorus

7,385.59 1.76 12,998.64

Regulated Urban

Pervious 14,016.41 0.50 7,008.20

Regulated Urban

Impervious

Total Suspended

Solids

7,385.59 676.94 4,999,602.62

Regulated Urban

Pervious 14,016.41 101.08 1,416,778.53

After the pre and post development POC loads were defined, the total change in loads was

calculated. Table 3-11 shows the estimated change in loads from June 30, 2009 to July 1, 2014.

The estimated loads increased due to the increase in impervious area from 2009 to 2014.

Table 3-11. Total Load Changes from New Sources between June 30, 2009 and July 1, 2014

Subsource

Pollutant

Estimated Total POC Load

as of 07/01/14 (lb/yr)

Estimated Total POC Load

as of 06/30/09 (lb/yr)

Load Change

(lb/yr)

Total Load

Change (lb/yr)

Regulated Urban

Impervious

Total Nitrogen

69,350.71 67,902.69 1,448.02

370.10 Regulated Urban

Pervious 97,974.69 99,052.51 (1,077.92)

Regulated Urban

Impervious

Total Phosphorus

12,998.64 12,727.23 271.41

194.30 Regulated Urban

Pervious 7,008.20 7,085.31 (77.10)

Regulated Urban

Impervious

Total Suspended

Solids

4,999,602.62 4,895,212.70 104,389.91

88,802.52 Regulated Urban

Pervious 1,416,778.53 1,432,365.92 (15,587.40)

Next, the best management practices (BMPs) that were implemented between June 30, 2009 and

July 1, 2014 were evaluated to determine the total treatment provided. The City provided a

spreadsheet of all known BMPs within the City boundary in January 2015.

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The BMP list was filtered to remove sites within the CSS service area and to remove sites that were

constructed outside of the new sources timeframe. The filtered BMP list is included in Appendix D.

The total POC reduction from BMPs is 59.90 pounds for TN, 15.40 pounds for TP, and 7,968.70

pounds for TSS. The POC reduction from BMPs was subtracted from the total change in loads, as

shown in Table 3-12.

Table 3-12. Net Load Change

(Total Load Change Minus Reductions from Implemented BMPs)

Pollutant Total Load Change

(lb/yr)

Reductions from on-site

BMPs (lb/yr)

Net Load Change

(lb/yr)

Total Nitrogen 370.10 59.90 310.2

Total Phosphorus 194.30 15.40 178.90

Total Suspended Solids 88,802.52 7,968.70 80,833.82

The City will be required to treat the entire net load change to the maximum extent practicable during

the three permit terms in 5 percent, 35 percent, and 60 percent increments. In the current permit

term, the City is required to offset five percent of the net load change to the maximum extent

practicable (Table 3-13) associated with new sources. The method utilized by the City to achieve the

required reductions is discussed in Section 4.

Table 3-13. Additional Reductions Required During First Permit Cycle

Pollutant

Net Load

Change(lb/yr)

Required Reduction

during first permit cycle

Additional Reductions Required during First

Permit Cycle

(lb/yr)

Total Nitrogen 310.2 5% 15.51

Total Phosphorus 178.90 5% 8.95

Total Suspended Solids 80,833.82 5% 4,041.69

3.4.2 Means and Methods to Offset Increased Loads from Grandfathered Projects that

Begin Construction after July 1, 2014

Special Condition 8 is a Phase II MS4 permit requirement that applies to all projects with

construction initiated after July 1, 2014 and designs that meet the following requirements:

Greater than one acre land disturbance

Increase in the pollutant loads from existing condition

An impervious land cover condition greater than 16 percent for the design of post-

development stormwater management facilities

The City is required to provide additional pollutant load reductions for any project that meets the

Special Condition 8 requirements above prior to project construction completion. The reduction

requirement is calculated as the difference between (1) the post-development loading rate; and (2)

the loading rate associated with sixteen percent impervious cover.

The City revised its VSMP requirements to meet the 16 percent impervious land cover requirements

for the design of post-development stormwater management facilities in 2009, as discussed in the

Legal Authority Review in Section 2. Since the requirements were revised in 2009, the City does not

anticipate that any projects will meet the criteria for Special Condition 8.

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3.5 Total First Permit Term Required Reductions

The total required reductions during the first permit cycle are the combined total POC loads from

existing developments and new sources. The total first permit term required reductions are 618.23

pounds of TN, 136.45 pounds of TP, and 59,260.42 pounds of TSS, as shown in Table 3-14.

Table 3-14. Total Reductions Required During First Permit Cycle

Pollutant

Existing Development

Required Reductions

(lb/yr)

New Sources (Special Condition 7)

Required Reductions

(lb/yr)

Grandfathered Projects (Special Condition 8)

Required Reductions

(lb/yr)

Total First Permit Term

Required Reductions

(lb/yr)

Total Nitrogen 602.72 15.51 0 618.23

Total Phosphorus 127.50 8.95 0 136.45

Total Suspended Solids 55,218.73 4,041.69 0 59,260.42

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Section 4

Means and Methods to Meet

Required Reductions and Schedule

The Phase II MS4 permit requires that the Plan identify the means and methods to meet the required

reductions. The City will primarily rely on stream restoration projects to meet the first permit term

required reductions. All methods discussed in this Plan are prescribed by expert panels approved by

the Chesapeake Bay Program. The following sections discuss projects in planning, design or

construction to meet the first permit term pollutant reduction requirement.

4.1 Historical BMP Data

The City previously provided DEQ with information on BMPs installed prior to July 1, 2009. No

additional historical projects are provided as a part of this Plan.

4.2 Pollutant Reduction Project Types

The City intends to achieve the required reductions of TN, TP, and TSS through five urban stream

restoration because these projects have been initiated after January 1, 2006. Pollutant reduction

credits have been calculated using the interim approved removal rates developed by the Bay

Program Stream Restoration Expert Panel, as presented in Appendix V.I of the Guidance Document

dated May 18, 2015. The removal rates are 0.075 lb/lf/yr for TN, 0.068 lb/lf/yr for TP, and 44.88

lb/lf/yr for TSS. All the streams are 0-3rd order streams and not tidally influenced. These efficiencies

are the minimum efficiencies for stream restoration projects within this Plan and these removal rates

may be adjusted to reflect future increases in efficiency rates. All the project sites are within the

city’s MS4 service area and, therefore, no adjustments to computed credits are required.

4.3 Projects for Pollutant Removal Credit

The City is currently conducting a program to select and implement projects to achieve the required

reductions for the current and future permit cycles. Five projects have been identified by the City for

this Plan:

Reedy Creek Stream Restoration

Rattlesnake Creek Stream Restoration

Albro (Goode’s) Creek Stream Restoration

Pocosham Creek Stream Restoration

Maury Cemetery Stream Restoration

These projects are currently in design or planning process at a minimum. The City anticipates

beginning construction of projects prior to the end of the current permit term to achieve the five

percent first permit term required reduction. All projects will have funds approved as a part of an

adopted Capital Improvement Plan (CIP) by the end of the current Phase II MS4 Permit term in 2018

in order to maintain the current POC reductions calculated in the following sections.

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Each project location is identified on Figure 2 in Appendix A. Alternative projects may be substituted

during the current permit cycle at the City’s discretion to achieve the POC reductions.

4.3.1 Reedy Creek Stream Restoration

Reedy Creek is a tributary of the James River draining approximately 3,075 acres of urban and

suburban lands in the southwestern portion of the City. The project will restore approximately 2,200

linear feet of the Reedy Creek and the downstream portion of an unnamed tributary. The land on

which the project will be conducted is owned by the City and is administered by the Department of

Parks, Recreation and Community Facilities. The approximate project location is shown in

Figure 4-1.

Figure 4-1. Approximate location of Reedy Creek stream restoration.

The two stream channels to be restored receive stormwater from a total of approximately 2,310

acres. The land cover of the contributing drainage area consists of seventeen percent forest and

open space, forty-four percent managed turf, and thirty-nine percent impervious areas. Restoration

of the stream channels is needed to restore geomorphic stability of the impaired stream channels,

remove pollutants from the upstream watersheds, and improve water quality in these stream

reaches and downstream.

The Reedy Creek stream restoration project is included in the City’s Stormwater Master Plan, and will

be partially funded using DEQ’s matching Stormwater Local Assistance Fund (SLAF) Grant. The

project will employ natural channel design practices to emphasize contribution to stream functional

improvements while reducing stormwater pollutants. The Reedy Creek project will also include the

creation of constructed wetlands and reconnection of the stream channels with the floodplain.

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Using the approved pollutant removal rates, it is estimated that the project will remove 165.00 lb/yr

of TN, 149.60 lb/yr of TP, and 98,736.00 lb/yr of TSS as shown in Table 4-1.

Table 4-1: Pollutant Removal Calculations for Reedy Creek Stream Restoration

Pollutant Total Nitrogen Total Phosphorus Total Suspended

Solids

Approved Removal Rates (lb/lf/yr) 0.075 0.068 44.88

Stream length (lf) 2,200 2,200 2,200

Pollutant Removal (lb/yr) 165.00 149.60 98,736.00

The project design began in January 2015 and construction is anticipated to be completed in June

2016, with an estimated total cost of $1,270,000.

4.3.2 Rattlesnake Creek Stream Restoration

Rattlesnake Creek is a tributary of the James River draining around 1,000 acres of mostly suburban

lands in the northwestern corner of the City of Richmond and south side of the James River. The

proposed stream restoration project will address 1,500 linear feet of the Rattlesnake Creek between

E. Weyburn Road and Chippenham Parkway. The approximate project location is included in Figure

4-2.

Figure4-2. Approximate location of the Rattlesnake Creek stream restoration.

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The stream proposed for restoration receives drainage from approximately 840 acres of suburban

lands. The land cover of the contributing drainage area consists of thirty-five percent forest, forty-six

percent managed turf, and nineteen percent impervious. The current conditions of the stream reach

exhibit near vertical stream banks that are actively eroding. The stream provides minimal removal of

pollutants from the upstream watershed and contributes downstream pollution. Restoration of the

stream channel is needed to restore geomorphic stability of the impaired stream channel and

remove pollutants from stormwater and the upstream watershed.

The restoration project is included in the City’s Stormwater Master Plan and will be partially funded

using DEQ’s matching SLAF Grant. The project will employ natural channel design practices to

emphasize contribution to stream functional improvements while reducing stormwater pollutants.

Stream restoration efforts will involve grading the stream channel banks, installing in-channel flow

and re-directive and grade control boulder structures, as well as riparian plantings. These restorative

measures are intended to provide pollutant abatement and improve water quality, improve diversity

of aquatic habitat areas, reduce bank erosion, and enhance riparian habitats.

Using the approved pollutant removal rates, it is estimated that the project will remove 112.50 lb/yr

of TN, 102.00 lb/yr of TP, and 67,320.00 lb/yr of TSS as shown in Table 4-2.

Table 4-2: Pollutant Removal Calculations for Rattlesnake Creek Stream Restoration

Pollutant Total

Nitrogen

Total

Phosphorus

Total Suspended

Solids

Approved Removal Rates (lb/lf/yr) 0.075 0.068 44.88

Stream length (lf) 1,500 1,500 1,500

Pollutant Removal (lb/yr) 112.50 102.00 67,320.00

The project design began in October 2014 and construction is anticipated to be completed in July

2016 with an estimated total cost of $1,104,000.

4.3.3 Albro Creek Stream Restoration

The Albro Creek project will restore approximately 1,281 linear feet of stream and create of 3.0

acres of wetlands to restore and improve the water quality of Albro Creek (also called Bellemeade

Creek), which flows to the James River via Goode’s Creek. The local project site is separated from the

upstream section of Albro Creek by a large diversion pipe. The local drainage area upstream of the

restoration site is 35.17 acres, and the upstream portion of Albro Creek drains approximately 1,200

acres. Because the restored stream will have the potential to remove more nutrients than the local

drainage area (35.17 acres) is generating, a flow splitting structure will be utilized to convey

additional flows to the restored section of Albro Creek during wet weather events. Opportunities may

also exist for establishment of a conservation buffer around this tributary of Goode’s Creek. This

project is intended to improve water quality, provide flood protection, and reduce bank erosion. The

approximate project location is shown in Figure 4-3.

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Figure 4-3. Approximate location of the Albro Creek stream restoration.

Using the approved pollutant removal rates, it is estimated that the project will remove 96.08 lb/yr of

TN, 87.11 lb/yr of TP, and 57,491.28 lb/yr of TSS as shown in Table 4-3.

Table 4-3: Pollutant Removal Calculations for Albro Creek Stream Restoration

Pollutant Total

Nitrogen

Total

Phosphorus

Total Suspended

Solids

Approved Removal Rates (lb/lf/yr) 0.075 0.068 44.88

Stream length (lf) 1,281 1,281 1,281

Pollutant Removal (lb/yr) 96.08 87.11 57,491.28

The project design began in October 2014 and construction is anticipated to be completed in

October 2016, with an estimated total cost of $1,432,000.

4.3.4 Pocosham Creek Stream Restoration

The Pocosham Creek stream restoration project (Project) is located on a larger tributary of

Pocoshock Creek that flows into Falling Creek, which ultimately flows to the James River. This larger

tributary drains approximately 3,625 acres of mostly suburban and forest lands in the southwestern

side of the City, west of the James River. Approximately half of the watershed is located within the

City-limits and the other half is located in Chesterfield County. The restoration project will restore

approximately a 5,990 linear feet of stream channel. The approximate project location is shown in

Figure 4-4.

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Figure 4-4. Approximate location of the Pocosham Creek stream restoration.

A 6-foot wide trail will be constructed as part of the Pocosham Creek Stream Restoration project.

The path will run the length of the restoration segment (approximately 6,000 linear feet) and will

utilize the access corridor created by the Contractor to construct the project. Access to the path will

be from the multiple construction entrances at the various locations along the project.

This project is included in the City’s Stormwater Master Plan. The goals of this project are to reduce

pollutants in the watershed by repairing the eroding sections of the creek and adding a bankfull

floodplain bench to reduce velocities and erosion. In-stream structures, such as cross vanes, j-hook

vanes, and vanes will be implemented into the project to improve stability and create and enhance

habitat within the creek corridor. The project will also incorporate walking trails to improve access

and amenities in Pocosham Park.

Using the approved pollutant removal rates, it is estimated that completion of the Pocosham Creek

stream restoration project will remove 449.25 lb/yr of TN, 407.32 lb/yr of TP, and 268,831.20 lb/yr

of TSS as shown in Table 4-4.

Table 4-4: Pollutant Removal Calculations for Pocosham Creek Stream Restoration

Pollutant Total

Nitrogen

Total

Phosphorus

Total Suspended

Solids

Approved Removal Rates (lb/lf/yr) 0.075 0.068 44.88

Stream length (lf) 5,990 5,990 5,990

Pollutant Removal (lb/yr) 449.25 407.32 268,831.20

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Construction is planned to begin in August 2015 and is anticipated to be completed in April 2016

with estimate total cost of $2,500,000.

4.3.5 Maury Cemetery Stream Restoration

The Maury Cemetery Stream Restoration project is located within the City’s Maury Cemetery and will

restore approximately 1,980 linear feet of stream channel. The project is bounded to the north by

Maury Street, to the south by North Hopkins Road, to the east by an existing CSX railroad, and to the

west by Maury Cemetery. This work is being performed to improve the overall function of the Maury

Cemetery Stream, including but not limited to preventing erosion, restoring habitat, and improving

the water quality function of the stream. The approximate project location is shown in Figure 4-5.

The project is expected to include the following elements:

Modifying grades of the existing Maury Cemetery Stream

Demolition and removal of existing masonry and stone structures

Installation of new storm sewer pipe and/or extending existing storm sewer pipe

Installation of in-stream structures such as log J-hooks and fieldstone cross vanes

Vertical off setting of existing waterline

Adjusting rim of existing sanitary structures

Landscaping and restoration of all disturbed areas

Figure 4-5. Approximate location of the Maury Cemetery Creek stream restoration.

Using the approved pollutant removal rates, it is estimated that completion of the Maury Cemetery

stream restoration project will remove 148.50 lb/yr of TN, 134.64 lb/yr of TP, and 88,862.40 lb/yr

of TSS as shown in Table 4-5.

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Table 4-5: Pollutant Removal Calculations for Maury Cemetery Stream Restoration

Pollutant Total

Nitrogen

Total

Phosphorus

Total Suspended

Solids

Approved Removal Rates (lb/lf/yr) 0.075 0.068 44.88

Stream length (lf) 1,980 1,980 1,980

Pollutant Removal (lb/yr) 148.50 134.64 88,862.40

Construction is planned to begin in August 2015 and is anticipated to be completed in January 2016

with a total cost of $905,000.

4.3.6 First Permit Term Pollutant Reduction Credit

Credits from all of the above five urban stream restoration projects are summarized, and the total

credits from these projects are calculated and shown in Table 4-6.

Table 4-6. First Permit Term Pollutant Reduction Credits

Project

Total

Nitrogen

(lb /yr)

Total

Phosphorus

(lb /yr)

Total

Suspended

Solids

(lb /yr)

Reedy Creek Stream Restoration 165.00 149.60 98,736.00

Rattlesnake Creek Stream Restoration 112.50 102.00 67,320.00

Albro Creek Stream Restoration 96.08 87.11 57,491.28

Pocosham Creek Stream Restoration 449.25 407.32 268,831.20

Maury Cemetery Stream Restoration 148.50 134.64 88,862.40

Total 919.58 833.75 550,273.68

The first permit term required reductions will be exceeded and the additional credit will be included

in the second permit term Plan. The second permit term will require that the City meet a 35 percent

reduction requirement. The credit from this Plan to be applied in the second permit term includes

2.44 percent TN, 25.55 percent TP, and 41.43 percent TSS, as shown in Table 4-7.

Table 4-7. First Permit Term Pollutant Reduction Requirements and Second Permit Term Credit

Project

Total

Nitrogen

(lb /yr)

Total

Phosphorus

(lb /yr)

Total

Suspended

Solids

(lb /yr)

First Permit Term Reduction Credit 919.58 833.75 550,273.68

First Permit Term Required Reduction 618.23 136.45 59,260.42

Credit to be Applied in Second Permit Term 301.35 697.30 491,013.26

Percent Reduction to be Applied in Second Permit Term 2.44% 25.55% 41.43%

City of Richmond Chesapeake Bay TMDL Action Plan Section 4

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4.3.7 Other Water Quality Projects in Planning or Implementation

In addition to the stream restoration projects described previously, the City is currently implementing

or planning to implement other projects throughout the City. The City current completes a street

sweeping program City-wide. The City is also completing a green alleys program. This program is

creating buffer strips and other pervious areas in highly impervious areas throughout the City.

The City is also planning additional projects in fiscal years 2016 and 2017. Specific project data is

not yet available for inclusion in the first permit term Plan; however, the City will document these

projects as they are designed and constructed and incorporate them into future Plans.

4.4 Implementation Schedule and Estimated Cost to Complete

Table 4-8 shows the current project status, anticipated construction start date and the cost of

construction for each of the stream restoration projects. All projects are currently in design or ready

for construction. The total cost to complete the projects is approximately $7,200,000.

Table 4-8. First Permit Term Implementation Schedule and Estimated Cost to Complete

Project

Project Status

Estimated

Construction Start

Date

Estimated Cost to Complete

Reedy Creek Stream Restoration In Design October 2015 $1,270,000

Rattlesnake Creek Stream Restoration In Design December 2015 $1,104,000

Albro Creek Stream Restoration In Design December 2015 $1,432,000

Pocosham Creek Stream Restoration In Design August 2015 $2,500,000

Maury Cemetery Stream Restoration In Design August 2015 $905,000

Total Estimated Cost to Complete Projects $7,211,000

4.5 A List of Future Projects and Associated Acreage that Qualify as

Grandfathered

The City does not anticipate any developments that will meet the criteria for grandfathered projects,

as defined in Section 3.4.2.

Section 5

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Public Comments on Draft Action

Plan

The City plans to make the draft Plan available for comment on the website at

http://www.richmondgov.com/PublicUtilities/StormwaterUtility/index.aspx during June 2015 and

advertise the plan through a public announcement in several local newspapers. The City will also

publicize the plan via announcements on the web and distribution through social media (utility blogs,

twitter and Facebook).

The summary of comments received will be addressed through the plan update submitted with the

Annual Report in September 2015 and posted on the city’s website.

September 2015 update: The city received no comments on the Action Plan during the public

comment period which ended August 1, 2015. We were asked for two extensions, which were

agreed to. No comments were submitted during the extended period, which ended August 15, 2015.

We did receive comments on September 21, 2015 from the Reedy Creek Coalition

(www.reedycreekcoaltion.org) with concerns about the ultimate success of the stream restoration in

Reedy Creek. Even though the comments were received outside the allotted public comment period,

the city provided a response to the organization and since we are a partner with them in analyzing

the samples collected in the creek, we hope that we can address the concerns expressed by them

with future communication on the stream restoration.

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Section 6

Conclusion

The City developed this first permit term Plan as required in the 2013-2018 Phase II MS4 Permit

Number VAR040005 and in accordance with the DEQ Guidance Document dated May 18, 2015.

This Plan concludes that the first permit term pollutant reduction requirements calculated in Section

3 are met by the five stream projects identified in Section 4 of the Plan. Modifications to this Plan

will be documented in Appendix E.

During the second permit cycle, permittees will be required to reduce meet and additional thirty-five

percent POC reductions to the maximum extent practicable. The existing projects identified in this

first permit term Plan exceed the required five percent reductions and the additional reductions will

be applied toward achieving the additional 35 percent reductions required by the second permit

term. The City will continue to plan for compliance and the Plan will be updated accordingly.

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Section 7

Limitations

This document was prepared solely for the City of Richmond in accordance with professional

standards at the time the services were performed, and in accordance with the contract between the

City of Richmond and Brown and Caldwell dated December 4, 2014. This document is governed by

the specific scope of work authorized by the City of Richmond; it is not intended to be relied upon by

any other party except for regulatory authorities contemplated by the scope of work. We have relied

on information or instructions provided by the City of Richmond and other parties and, unless

otherwise expressly indicated, have made no independent investigation as to the validity,

completeness, or accuracy of such information.

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Section 8

References

Brown and Caldwell. Site Plans: Maury Cemetery Creek Stream Restoration. December 23, 2014

Brown and Caldwell. Site Plans: Pocosham Creek Stream Restoration. November 25, 2014

Schueler, Tom and Bill Stack. Recommendations of the Expert Panel to Define Removal Rates for Individual Stream

Restoration Projects, Chesapeake Bay Program, September 8, 2014.

Virginia Department of Environmental Quality. SLAF Grant Application: Albro Creek Stream Restoration. October 24,

2014.

Virginia Department of Environmental Quality. SLAF Grant Application: Albro Creek Stream Restoration. October 24,

2014.

Virginia Department of Environmental Quality. SLAF Grant Application: Pocosham Creek Stream Restoration. October

24, 2014.

Virginia Department of Environmental Quality. SLAF Grant Application: Rattlesnake Creek Stream Restoration.

October 24, 2014.

Virginia Department of Environmental Quality. SLAF Grant Application: Reedy Creek Stream Restoration. October 24,

2014.

Virginia Department of Environmental Quality Water Division, Chesapeake Bay TMDL Special Condition Guidance,

August 18, 2015, draft revisions March 19, 2015.

City of Richmond Chesapeake Bay TMDL

Plan Appendix A

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Appendix A: Maps

Maps

Figure 1: MS4 Service Area Delineation

Figure 2: First Permit Term Projects

I-64

US 60

US 360

0 1 2

Miles

City of RichmondFigure 1Figure 1

MS4 Service Area MS4 Service Area DelineationDelineation

June 2015

LegendCityBoundary

CSS Service Areas

Forested Areas

MS4 Boundary

Surface Runoff into MS4

Surface Runoff Out

Surface Waters

VDOT Right of Way

VA Hospital

VPDES Concrete ProductsFacilities General Permit

VPDES Individual Permit

VPDES Nonmetallic MineralMining General Permit

VPDES Stormwater GeneralPermit

James River

I-64

US 60

0 1 2

Miles

City of RichmondFigure 2Figure 2

First Phase First Phase ProjectsProjectsJune 2015

LegendCityBoundary

Stream

Water Features

MS4 Boundary

ProjectAlbro Creek

Maury Cemetary Creek

Pocosham Creek

Rattlesnake Creek

Reedy Creek

James River

Scherer Dr

N Hugu

enot

Road

Arch

dale

Road

Elm

Road

WWeyb

urn

Road

Custi

sRoad

Trabue Road

Abbey Road

Kenm

oreRo

ad

Stratf

ordRo

ad

E Weyb

urnRo

ad

Darnl

eyDr

Genev

a DrElk Road

Walmsley Blvd

Wimbleton Dr Pocosham Dr

Zurich Dr

Holborn Road

Susten Lane

Commander Road

Chippenham Pkwy

HeyRoadSt Moritz Dr

W 42nd

St Dunston Ave

Norcroft Ter

Northrop St

Crutchfield St

W 44th

St

Norcroft Cir

W46thSt

Royall Ave

Gunn St

Minef

eeSt

Wright Ave

Warwick Ave Ridgem

ontRo

ad

Jefferson Davis Hwy

N Hopkins Road

Maury StE 29th St Kern St

Brinser St

Perdue Ave

City of Richmond Chesapeake Bay TMDL Plan Appendix B

B-1

Use of contents on this sheet is subject to the limitations specified at the end of this document.

Richmond Chesapeake Bay TMDL AP - final Action Plan - Final

Appendix B: Source Data

Source Data

The following is a list of the GIS datasets, dates, and sources of GIS data used to develop the TMDL

Action Plan.

Data Collected from the City

Basemap Files – Downloaded January 2015

City Boundary – dated January 2015

Road Edge – dated January 2015

Structures – dated January 2015

Stream Polygons – dated January 2015

Transportation Surfaces – dated January 2015

Parcels – Downloaded January 2015

Parcels ASR – dated January 2015

Parcels PINS – dated January 2015

Utility Data – Received April 2014

Combined Sewer Area – dated February 2014

Storm Canals – dated March 2014

Storm Culverts – dated January 2014

Storm Drop Inlets – dated March 2014

Storm Manholes – dated March 2014

Storm Open Channels – dated February 2014

Storm Pipes – dated March 2014

Utility Data – Received January 2015

Storm Outfalls – dated January 2015

BMP Excel Spreadsheet – dated October 2014

Data Collected from Tiger Census

2000 Census – Downloaded January 2015

Census Urban Area – dated June 2002

2010 Census – Downloaded January 2015

Census Urban Area – dated 2012Data Collected from DEQ

City of Richmond Chesapeake Bay TMDL Plan Appendix B

B-2

Use of contents on this sheet is subject to the limitations specified at the end of this document.

Richmond Chesapeake Bay TMDL AP - final Action Plan - Final

VPDES Permittees – Downloaded January 2015

Individual Permittees Spreadsheet – dated January 2015

Stormwater General Permittees Spreadsheet – dated January 2015

Individual MS4s – Downloaded January 2015

Phase I and Phase II MS4s Spreadsheet – dated January 2015

Data Collected from USGS NED

National Elevation Dataset– Downloaded January 2015

Regional Elevation Raster Imagery – Dated 2013

Data Collected from VA DOF

Forested Lands– Downloaded April 2015

Virginia Forest Cover Map 2005 – dated May 2005

C-1

Use of contents on this sheet is subject to the limitations specified at the end of this document.

Richmond Chesapeake Bay TMDL AP - final

City of Richmond Chesapeake Bay TMDL Action Plan Appendix C

Appendix C: Existing Legal Authority

List of Existing Legal Authority

Chapter 50 Richmond City code: Floodplain Management, Erosion and Sediment Control, and

Drainage Generally

(Includes Floodplain management, Erosion and Sediment Control, Chesapeake Bay Preservation

Areas, and Richmond Stormwater Management Program)

https://www.municode.com/library/va/richmond/codes/code_of_ordinances?nodeId=CH50FLMAE

RSECODRGE

Chapter 106 Richmond City code: Utilities

(Includes Wastewater Sewers and Collection System, Stormwater)

https://www.municode.com/library/va/richmond/codes/code_of_ordinances?nodeId=CH106UT_AR

TVIIIST

Chapter 90 Richmond City Code: Streets, Sidewalks and Public Ways

https://www.municode.com/library/va/richmond/codes/code_of_ordinances?nodeId=CH90STSIPU

WA

Chapter 46.1 Richmond City code: Fire Protection and Protection

(Includes spill abatement)

https://www.municode.com/library/va/richmond/codes/code_of_ordinances?nodeId=CH46.1FIPRP

R

City of Richmond Chesapeake Bay TMDL Plan Appendix D

D-1

Use of contents on this sheet is subject to the limitations specified at the end of this document.

Richmond Chesapeake Bay TMDL AP - final

Appendix D: BMPs Constructed Between June 30,

2009 and July 1, 2014

Table D-1. BMPs Constructed between 7/1/2009 and 7/1/2014 (Filtered from 'City of Richmond SCM

Database 10-1- 14.xlsx')

City of Richmond Chesapeake Bay TMDL Action Plan Appendix E

E-1

Use of contents on this sheet is subject to the limitations specified at the end of this document.

Richmond Chesapeake Bay TMDL AP - final

Appendix E: Modifications to the Plan

Reserved for future use

City of Richmond TMDL Action Plan Appendix D

Use of contents on this sheet is subject to the limitations specified in this documentBMPs for SPCon7and8_SCM DatabaseFilter_20150313.xlsx D-2

Latitude Longitude Sediment Phosphorus Nitrogen00036 4300 Commerce Road 37.4669 -77.4275 Filtering Practices 0.22 0.16 0.06 Impermeable Barrier 91.5 0.2 0.8 7/22/200900037 4300 Commerce Road 37.4669 -77.4275 Filtering Practices 0.16 0.12 0.04 Impermeable Barrier 68.2 0.1 0.6 7/22/200900038 4300 Commerce Road 37.4669 -77.4275 Filtering Practices 0.11 0.08 0.03 Impermeable Barrier 45.8 0.1 0.4 7/22/200900035 10655 Cherokee Road 37.5537 -77.5939 Dry Extended Detention Ponds 0.89 0.89 0 B 361.5 0.3 1.7 9/1/200900020 6501 Buckhill Road 37.5415 -77.5113 Bioretention A/B Soils, Underdrain 0.23 0.23 0 B 124.6 0.3 1.5 9/10/200900030 9131 Cherokee Road 37.5547 -77.5640 Filtering Practices 0.26 0.26 0 D 140.8 0.3 1.0 9/30/200900031 9131 Cherokee Road 37.5547 -77.5640 Filtering Practices 0.75 0.75 0 D 406.2 0.8 2.8 9/30/200900032 9131 Cherokee Road 37.5547 -77.5640 Filtering Practices 1.05 1.05 0 D 568.6 1.1 3.9 9/30/200900033 9131 Cherokee Road 37.5547 -77.5640 Filtering Practices 1.05 1.05 0 D 568.6 1.1 3.9 9/30/200900034 9131 Cherokee Road 37.5547 -77.5640 Filtering Practices 0.23 0.23 0 D 124.6 0.2 0.9 9/30/200900181 33A Westhampton Way 37.5743 -77.5415 Bioretention A/B Soils, Underdrain 0.23 0.13 0.1 B 78.5 0.2 1.3 10/7/200900009 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.46 0.46 0 Impermeable Barrier 249.1 0.5 1.7 1/15/201000010 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.5 0.5 0 Impermeable Barrier 270.8 0.5 1.9 1/15/201000011 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.32 0.32 0 Impermeable Barrier 173.3 0.3 1.2 1/15/201000012 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.5 0.5 0 Impermeable Barrier 270.8 0.5 1.9 1/15/201000013 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.33 0.33 0 Impermeable Barrier 178.7 0.3 1.2 1/15/201000014 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.5 0.5 0 Impermeable Barrier 270.8 0.5 1.9 1/15/201000015 301 Belt Boulevard 37.5067 -77.4791 Filtering Practices 0.36 0.36 0 Impermeable Barrier 195.0 0.4 1.4 1/15/201000159 9200 Stony Point Pkwy 37.5496 -77.5717 Hydrodynamic Structures 1.48 1.48 0 Impermeable Barrier 100.2 0.3 0.7 3/1/201000018 2845 Broad Rock Blvd 37.4788 -77.4800 Dry Detention Ponds 0.22 0 0.22 B 2.2 0.0 0.1 11/9/201000042 1800 Crenshaw Way 37.5722 -77.5416 Filtering Practices 0.54 0.38 0.16 B 217.8 0.4 1.9 4/27/201100084 301 Hillwood Road 37.5625 -77.5149 Infiltration Practices w/o Sand, Vegetation 0.043 0.043 0 D 27.7 0.1 0.3 10/1/201100085 301 Hillwood Road 37.5625 -77.5149 Infiltration Practices w/o Sand, Vegetation 0.039 0.039 0 D 25.1 0.1 0.3 10/1/201100106 2412 Lakeview Ave 37.5456 -77.4746 Filtering Practices 0.073 0.073 0 Impermeable Barrier 39.5 0.1 0.3 1/13/201200024 4200 Cary Street Road 37.5606 -77.4960 Filtering Practices 0.777 0.59 0.187 Impermeable Barrier 334.6 0.7 2.7 5/2/201200025 4200 Cary Street Road 37.5606 -77.4960 Filtering Practices 0.749 0.572 0.177 Impermeable Barrier 324.1 0.7 2.6 5/2/201200164 3903 Walmsley Blvd 37.4683 -77.4682 Filtering Practices 0.36 0.36 0 B 195.0 0.4 1.4 6/13/201200114 5609 New Kent Road 37.5315 -77.4981 Bioretention A/B Soils, No Underdrain 0.035 0.035 0 B 21.3 0.1 0.3 7/27/201200145 5204 Riverside Dr. 37.5297 -77.4900 Bioretention C/D Soils, Underdrain 0.059 0.039 0.02 C 15.6 0.0 0.1 10/15/201200115 5615 New Kent Road 37.5319 -77.4982 Bioretention A/B Soils, No Underdrain 0.063 0.063 0 B 38.4 0.1 0.5 5/4/201300165 2409 Webber Ave 37.4966 -77.4431 Bioretention C/D Soils, Underdrain 0.22 0.17 0.05 C 66.1 0.1 0.5 6/20/201300166 2409 Webber Ave 37.4966 -77.4431 Bioretention C/D Soils, Underdrain 0.36 0.29 0.07 C 111.9 0.2 0.8 6/20/201300167 2409 Webber Ave 37.4966 -77.4431 Bioretention C/D Soils, Underdrain 0.67 0.56 0.11 C 214.6 0.5 1.5 6/20/201300168 2409 Webber Ave 37.4966 -77.4431 Bioretention C/D Soils, Underdrain 0.3 0.27 0.03 C 102.2 0.2 0.7 6/20/201300169 2409 Webber Ave 37.4966 -77.4431 Bioretention C/D Soils, Underdrain 0.35 0.32 0.03 C 120.8 0.3 0.8 6/20/201300170 2409 Webber Ave 37.4966 -77.4431 Dry Extended Detention Ponds 1.84 1.17 0.67 C 515.8 0.5 3.1 6/20/201300183 603 Westover Hills Blvd 37.5142 -77.4874 Filtering Practices 0.72 0.64 0.08 Impermeable Barrier 353.1 0.7 2.6 7/11/201300184 603 Westover Hills Blvd 37.5142 -77.4874 Filtering Practices 0.71 0.63 0.08 Impermeable Barrier 347.6 0.7 2.6 7/11/201300103 2600 Jefferson Davis Hwy 37.4879 -77.4470 Hydrodynamic Structures 0.51 0.51 0 Impermeable Barrier 34.5 0.1 0.2 8/1/201300109 302 Long Lane 37.5543 -77.5050 Vegetated Open Channels A/B Soils, No Underdrain 0.94 0.28 0.66 B 179.4 0.4 3.3 8/5/201300098 1250 Ingram Ave 37.5076 -77.4346 Dry Detention Ponds 2.54 2.54 0 D 171.9 0.4 1.2 1/3/201400099 1250 Ingram Ave 37.5076 -77.4346 Dry Detention Ponds 3.28 3.28 0 D 222.0 0.6 1.5 1/3/2014

7968.7 15.4 59.9

Table D-1. BMPs Constructed between 7/1/2009 and 7/1/2014 (Filtered from 'City of Richmond SCM Database 10-1-14.xlsx')

BMP Database

ID

Street Number

Street NameGPS Coordinates

SCM TypeTotal Treated Area (Acres)

Impervious Treated Area

(Acres)

Pervious Treated Area

(Acres)

Soil Type/ Underlying Conditions

Projected Pollutant Removal (lb/year)

Date Brought Online

Total Treatment Volume