University of Mary WashingtonChesapeake Bay TMDL Action PlanProject No.: 04590-032

UNIVERSITY OF MARY WASHINGTON

FREDERICKSBURG, VIRGINIA

CHESAPEAKE BAY TMDL ACTION PLAN

VPDES PERMIT NO.: VAR040094

PROJECT NO.: 04590-032

Prepared For:

1301 College AvenueFredericksburg, Virginia 22401

DEQVPDES

629 E. Main StreetRichmond, Virginia 23219

(804)-698-4000

By:

Koontz-Bryant, P.C.1703 N. Parham Road, Suite 202

Richmond, Virginia 23229Phone: (804) 740-9200

September 2015

A. Leslie Johnson, Jr.University of Mary Washington

University of Mary WashingtonChesapeake Bay TMDL Action PlanProject No.: 04590-032

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INTRODUCTION

In accordance with the Virginia Pollution Discharge Elimination System (VPDES) GeneralPermit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems(GP), the University of Mary Washington (UMW) presents this Chesapeake Bay TMDL ActionPlan (Plan). The Plan fulfils the special condition for the Chesapeake Bay TMDL requirementsof the GP (VAR040094).

The Virginia Department of Environmental Quality (DEQ) Guidance Memo No. 14-2012 datedAugust 18, 2014, providing permittees in the Chesapeake Bay Watershed with backgroundinformation and procedures to meet the Chesapeake Bay TMDL Special Conditionsrequirements in the 2013-2018 General Permit for Discharges of Stormwater from Small (PhaseII MS4s), was used to develop this Action Plan.

According to the GP, “the plan shall include:

(1) A review of the current MS4 program implemented as a requirement of this state permitincluding a review of the existing legal authorities and the operator’s ability to ensurecompliance with this special condition;

(2) The identification of any new modified legal authorities such as ordinances, stateand other permits, orders, specific contract language, and interjurisdictional agreementsimplemented or needing to be implemented to meet the requirements of this specialcondition;

(3) The means and methods that will be utilized to address discharges into the MS4 from newsources;

(4) An estimate of the annual POC loads discharged from the existing sources as of June 30,2009, based on the 2009 progress run. The operator shall utilize the applicable versionsof Tables 2 a-d in the section based on the river basin to which the MS4 dischargesby multiplying the total existing acres served by the MS4 on June 30, 2009, and the 2009 Edgeof Stream (EOS) loading rate;

(5) The means and methods, such as management practices and retrofit programs that will beutilized to meet the required reductions included in subdivision 2 a (5) of this subsection, and aschedule to achieve those reductions. The schedule should include annual benchmarks todemonstrate the ongoing progress in meeting those reductions;

(6) The means and methods to offset the increased loads from new sources initiatingconstruction between July 1, 2009, and June 30, 2014, that disturb one acre or greater as aresult of the utilization of an average land cover condition greater than 16% impervious cover forthe design of post-development stormwater management facilities. The operator shallutilize Table 4 in this section to develop the equivalent pollutant load for nitrogen andtotal suspended solids. The operator shall offset 5.0% of the calculated increased load fromthese new sources during the permit cycle.

(7) The means and methods to offset the increased loads from projects as grandfathered inaccordance with 9VAC25-870-48, that disturb one acre or greater that begin constructionafter July 1, 2014, where the project utilizes an average land cover condition greaterthan 16% impervious cover in the design of post-development stormwater management

University of Mary WashingtonChesapeake Bay TMDL Action PlanProject No.: 04590-032

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facilities. The operator shall utilize Table 4 in this section to develop the equivalent pollutantload for nitrogen and total suspended solids.

(8) A list of future projects and associated acreage that qualify as grandfatehred in accordancewith 9VA25-870-48.

(9) An estimate of the expcected costs to implement the requirements of this special conditionduring the state permit cycle;

(10.a) An opportunity for receipt and conseration of public comment regarding the draftChesapeake Bay TMDL Action Plan;

(10.b) An opportunity for receipt and consideration of public comment on the draft ChesapeakeBay TMDL Action Plan; and a list of all comments received as a result of public comment andany modifications made to the draft Chesapeake Bay TMDL Action Plan as a result of the publiccomments.

University of Mary WashingtonChesapeake Bay TMDL Action PlanProject No.: 04590-032

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BACKGROUND

The University of Mary Washington’s MS4 program encompasses three campuses,Fredericksburg, Stafford, and Dahlgren. The Fredericsburg campus is +/-169.91-acresin size and the Stafford campus is +/-48.2-acres in size. Both of these campuses arewithin the Rapphanock water shed and total +/-218.11-acres. The Dahlgren campus is+/-28.41-acres in size and is within the Potomac River watershed. Figures 1-3 depict thelimits of the University’s MS-4 program.

1. CURRENT MS4 PROGRAM AND EXISTING LEGAL AUTHORITIES

The University of Mary Washington has established and implemented best managementpractices (BMPs), as required by the MS4 permit, including public education andoutreach, public involvement and participation, illicit discharge and removal, andconstruction site runoff control. The MS4 program is reviewed annually and revised, asneeded, to address any deficiencis and permit conditions, as necessary.

The Capitol Outlay Department and Landscape and Grounds implement the MS4program, providing construction management of all capitol projects involving landdisturbing activities. UMW prepares the erosion and sediment control plans for eachproject and the plans are submitted for approval from the Virginia Department ofEnvironmental Quality (DEQ). Sub-contractors are contractually obligated to meet theconditions of the approved E&SC and stormwater plans, as well as, local, state, andfederal regulations for the permitting and conduct of their projects. The Department ofLandscape and Grounds maintains the permanent stormwater controls, includingrequired post construction inspections.

2. NEW OR MODIFIED LEGAL AUTHORITY

The current contract language and policies established by The University of MaryWashington are suffiecient to meet the requirements of the GP Special Condition.

3. MEANS AND METHODS TO ADDRSS DISCHARGES FROM NEW SOURCES

New sources (developed or redeveloped on or after July 1, 2009) are limited toconstruction projects undertaken on the respective campuses. UMW has developed amaster plan for the management of stormwater that allows for the planning andimplementation of stormwater management conveyances, structural BMPs, and policies.This enables for the planning and implementation of the necessary components tocomply with the conditions of the GP. Through the construction management program,all new sources will be required to comply with the required POC reductions, as well as,discharge quantities. UMW is the local VSMP for land disturbing activities at theircampuses and approves E&SC plans for each land disturbing activity conducted on theircampuses. The Landscape and Grounds department conducts the required inspectionsof on-going projects, as well as, inspections and maintenance of permanent stormwaterunits.

University of Mary WashingtonChesapeake Bay TMDL Action PlanProject No.: 04590-032

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4. ESTIMATED EXISTING LOADS AND CALCULATED TOTAL POLLUTANT OFCONCERN (POC) REQUIRED REDUCTIONS

Information used to determine the pervious and impervious areas include theCommonwealth of Virginia – Virginia Geographic Information Network GIS Maps,Stormwater Quality and Quantity Management Study 2012 Update(Koontz-Bryant, 2012) and aerial photography (Google Earth) for each of the campuses.

The POC loads were calculated using Table 2c: Calculation Sheet for EstimatingExisting Source Loads for the Rappahannock River Basin for the Fredericksburg andStafford campuses and Table 2b: Calculation Sheet for Estimating Existing SourceLoads for the Potomac River Basin for the Dahlgren campus.

These tables are included in the summary table presented in the following section.

5. MEANS AND METHODS TO MEET THE REQUIRED REDUCTIONS AND SCHEDULE

The required 5% reductions were calculated using Table 3 c: Calculation Sheet forDetermining Total POC Reductions Required During the Permit Cycle for theRappahannock River Basin and Table 3 b: Calculation Sheet for DeterminingTotal POCReductions Required During the Permit Cycle for the Potomac River Basin.

The corrected values recommended in the DEQ Guidance were used for the loading ratecalculations.

The following tables summarize the reduction requirements for the University:

Impervious Pervious Total55.67 190.91 246.58

Subsource Pollutant

Total Existing AcresServed by MS4

(06/30/09)2009 EOS Loading

Rate (lbs/acre)

Estimated Total POC LoadBased on 2009 Progress

RunRegulated UrbanImpervious 0.00 16.86 0.00

Regulated UrbanPervious 28.41 10.07 286.09

Regulated UrbanImpervious 0.00 1.62 0.00

Regulated UrbanPervious 28.41 0.41 11.65

Regulated UrbanImpervious 0.00 1171.32 0.00

Regulated UrbanPervious 28.41 175.80 4994.48

Subsource Pollutant

Total Existing AcresServed by MS4

(06/30/09)2009 EOS Loading

Rate (lbs/acre)

Estimated Total POC LoadBased on 2009 Progress

RunRegulated UrbanImpervious 55.67 9.38 522.18

Regulated UrbanPervious 162.50 5.34 867.75

Regulated UrbanImpervious 55.67 1.41 78.49

Regulated UrbanPervious 162.50 0.38 61.75

Regulated UrbanImpervious 55.67 423.97 23602.41

Regulated UrbanPervious 165.50 56.01 9269.66

Dahlgren Campus

Compliance SummaryMS-4 Area

Acres

Fredericksburg/Stafford CampusesTable 2 c: Calculation Sheet for Estimating Existing Source Loads for the Rappahannock River Basin

(*Based on Chesapeake Bay Program Watershed Model Phase 5.3.2)

Nitrogen

Phosohorous

TotalSuspended

Solids

Table 2 b: Calculation Sheet for Estimating Existing Source Loads for the Potomac River Basin (*Based onChesapeake Bay Program Watershed Model Phase 5.3.2)

Nitrogen

Phosohorous

TotalSuspended

Solids

Subsource Pollutant

Total Existing AcresServed by MS4

(06/30/09)

First Permit CycleRequired

Reduction inLoading Rate(lbs/acre/yr)1

Total Reduction RequiredFirst Permit Cycle (lbs)

Regulated UrbanImpervious 0.00 0.08 0.00

Regulated UrbanPervious 28.41 0.03 0.86

Regulated UrbanImpervious 0.00 0.01 0.00

Regulated UrbanPervious 28.41 0.00 0.04

Regulated UrbanImpervious 0.00 11.71 0.00

Regulated UrbanPervious 28.41 0.77 21.85

Subsource Pollutant

Total Existing AcresServed by MS4

(06/30/09)

First Permit CycleRequired

Reduction inLoading Rate(lbs/acre/yr)1

Total Reduction RequiredFirst Permit Cycle (lbs/yr)

Regulated UrbanImpervious 55.67 0.04 2.35

Regulated UrbanPervious 162.50 0.02 2.60

Regulated UrbanImpervious

55.67 0.01 0.63

Regulated UrbanPervious 162.50 0.00 0.22

Regulated UrbanImpervious 55.67 4.24 236.02

Regulated UrbanPervious 162.50 0.25 39.82

1. Corrected loading rates per DEQ Guidance.

Dahlgren Campus

Nitrogen

Nitrogen

Table 3 b: Calculation Sheet for Determining Total POC Reductions Required During the Permit Cycle forthe Potomac River Basin (*Based on Chesapeake Bay Program Watershed Model Phase 5.3.2)

Phosohorous

TotalSuspended

Solids

Phosohorous

TotalSuspended

Solids

Fredericksburg/Stafford Campuses

Table 3 c: Calculation Sheet for DeterminingTotal POC Reductions Required During the Permit Cycle forthe Rappahannock River Basin (*Based on Chesapeake Bay Program Watershed Model Phase 5.3.2)

University of Mary WashingtonChesapeake Bay TMDL Action PlanProject No.: 04590-032

6. MEANS AND METHODS TO OFFSET INCREASED LOADS FROM NEW SOURCESINITIATING CONSTRUCTION BETWEEN JULY 1, 2009 AND JUNE 30, 2014

Projects constructed between July 1, 2009 and June 30, 2014 were subject to TechnicalCriteria II C under the VSMP regulations and the technology based criteria was used forthese projects. Therefore, no additional reductions are required.

7. MEANS AND METHODS TO OFFSET INCREASED LOADS FROMGRANDFATHERED PROJECTS THAT BEGAN CONSTRUCTION AFTER JULY 1,2014

8. A LIST OF FUTURE PROJECTS, AND ASSOCIATED ACREAGE THAT QUALIFY ASGRANDFATHERED

A list of grandfathered projects including acreages and stormwater calculations arelocated in the Stormawater Management Plan and MS-4 General Permit Annual Report.

9. AN ESTIMATE OF THE EXPECTED COST TO IMPLEMENT THE NECESSARYREDUCTIONS

10.b PUBLIC COMMENTS ON DRAFT ACTION PLAN (PHASE I PERMITREQUIREMENTS)

10.a PUBLIC COMMENTS ON DRAFT ACTION PLAN (GENERAL PERMITREQUIREMENTS)

The University will require that current and future projects be designed and constructedusing BMPs that meet current VSMP requirements and provide additional POC removal,in order to satisfy the removal goals. Based on previous cost of BMP installation, it isanticipated that the average cost for structural BMP installation is $60,000 per project.In the event that, due to funding, size, or construction constraints, BMPs are not feasible,the University will utilize nutrient credits to offset the deficiency. The cost for nutrientcredits is approximately $16,000 per pound.

The costs identified in this Action Plan are strictly planning level. There are manyunknowns that exist and can only be captured during the design phase of the individualprojects. During the design phase, the type of BMP, location and site constraints will beaddressed. Local watershed-specific permit requirements along with regional geologyand soils will affect costs. In addition, the type of design/build contracting mechanismthat is chosen will also affect the cost. All of these concerns are typically addressedduring the design phase, which will establish final construction cost estimates.

The Action Plan will be made available for public comment via the University’s web site. NOTE: per guidance, Public will be considered staff and students residing within the boundary of the Campus.