J. Sargeant Reynolds Community College Chesapeake Bay TMDL ...reynolds.edu/who_we_are/.../pdf/...Plan_2017-03-30.pdf · Chesapeake Bay TMDL Action Plan 1 1.0 Introduction The J. Sargent

J. Sargeant Reynolds

Community College

Chesapeake Bay TMDL Action Plan

Prepared for: J. Sargeant Reynolds Community College

Parham Road Campus Facilities Management & Planning

1651 E. Parham Road Richmond, VA 23228

June 30, 2015

Revised November 10, 2015

Revised March 30, 2017

Prepared by: Timmons Group 1001 Boulders Parkway, Suite 300

Richmond, VA 23225 (804) 200-6500

J. Sargeant Reynolds Community College


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Table of Contents

1.0 Introduction ................................................................................................................................... 1

2.0 Current MS4 Program and Existing Legal Authority ...................................................................... 2

3.0 New or Modified Legal Authority ................................................................................................... 2

4.0 Means and Methods to Address Discharges from New Sources ................................................... 2

5.0 Estimated Existing Source Loads and Calculated Total POC Required Reductions ...................... 2

5.1. Existing Source Loads ............................................................................................................... 6

5.2. Existing POC Required Reductions ........................................................................................... 6

6.0 Means and Methods to Meet the Required Reductions and Schedule .......................................... 7

7.0 Means and Methods to Offset Increased Loads from New Sources Initiating Construction between July 1, 2009 and June 30, 2014 ................................................................................................ 9

8.0 Means and Methods to Offset Increased Loads from Grandfathered Projects that began Construction after July 1, 2014 ................................................................................................................ 9

9.0 List of Future Projects, and Associated Acreage that Qualify as Grandfathered ............................ 9

10.0 An Estimate of Expected Cost and Schedule to Implement the Necessary Reductions ................ 9

11.0 Public Comments on Draft Action Plan ....................................................................................... 10

Figures

Figure 5-1: JSRCC Regulated Area ......................................................................................................... 4

Figure 5-2: 2009 Baseline Land Cover Type ........................................................................................... 5

Figure 6-1: Proposed Parking Lot Retrofit ................................................................................................ 8

Tables

Table 5-1: Existing Sources Land Cover Type ........................................................................................ 3

Table 5-2: Calculation for Estimating Existing Source Loads .................................................................. 6

Table 5-3: Calculation Sheet for Determining Total POC Required ......................................................... 6

Table 6-1: Calculation for Proposed Retrofit Pollutant Loadings & Removals .......................................... 7

Table 10-1: Parking Lot Retrofit Implementation Estimate ....................................................................... 9



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1.0 Introduction

The J. Sargent Reynolds Community College (JSRCC) has developed this Chesapeake Bay TMDL Action Plan (Action Plan) pursuant to the Special Condition for the Chesapeake Bay TMDL (General Permit Section I.C) as required by JSRCC’s Municipal Separate Storm Sewer System (MS-4) Permit. To assist with the development of the Action Plan, JSRCC has utilized both the General VPDES Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems, which became effective July 1, 2013 and the Department of Environmental Quality’s (DEQ) Chesapeake Bay TMDL Special Condition Guidance Document (Guidance Memo No. 15-2005). Furthermore, JSRCC utilized the Virginia Geographic Information Network (VGIN), and Virginia Environmental Geographic Information Systems (VEGIS) coupled with campus GIS data to meet the technical requirements of the Action Plan.

The focus of the Action Plan is driven by the Chesapeake Bay Total Maximum Daily Load (TMDL), which was approved by the US Environmental Protection Agency (EPA) in December of 2010. Nitrogen, Phosphorous, and Sediment are the Pollutants of Concern (POC) driving the need for required pollutant reductions in the Chesapeake Bay watershed, which includes the entire JSRCC campus. Three five-year permit cycles have been adopted to address the percent pollutant reduction required by a Municipal Separate Storm Sewer System (MS4) in Virginia. A 5% POC load reduction is required by the end of the first permit cycle on June 30, 2018, followed by a 35%, and 60% reduction in the following 2 cycles respectively. For the purposes of this Action Plan, the primary focus will be on Permit Cycle 1 and the associated 5% reduction requirements, although the loadings and reductions have been provided for the 35% and 60% cycles for reference. Projects implemented as part of this Action Plan that exceed the required 5% reductions will be tracked to meet future cycle requirements and referenced in the Permit Cycle 2 Action Plan. JSRCC may modify the Action Plan during the permit cycle to include new opportunities for reductions or address projects that are deemed infeasible. Any updates will be submitted to DEQ in accordance with the Program Plan Modification section of the permit (GP Section II.F.1).

This Action Plan includes the following components as required by the General Permit:

• Current Program and Existing Legal Authority - Permit Section I.C.2.a.(1)

• New or Modified Legal Authority – Permit Section I.C.2.a.(2)

• Means and Methods to Address Discharges from New Sources – Permit Section

I.C.2.a.(3)

• Estimated Existing Source Loads and Calculated Total (POC) Required

Reductions – Permit Section I.C.2.a.(4) and I.C.2.a.(5)

• Means and Methods to Meet the Required Reductions and Schedule – Permit

Section 1.C.2.a.(6)

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

Construction between July 1, 2009 and June 30, 2014 – Permit Section 1.C.2.a.(7)

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

begin Construction after July 1, 2014 – Permit Section 1.C.2.a.(8)

• A List of Future Projects, and Associated Acreage that Qualifies as Grandfathered

– Permit Section 1.C.2.a.(10)



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• A Estimate of the Expected Cost to Implement the Necessary Reductions – Permit

Section 1.C.2.a.(11)

• Public Comment Process – Permit Section I.C.2.a.(12)

2.0 Current MS4 Program and Existing Legal Authority

JSRCC has performed a review of the its current MS4 Program Plan and existing legal authorities in order to evaluate its ability to comply with the Special Condition for the Chesapeake Bay TMDL (Section I.C) in the MS4 Permit. Based on this review, JSRCC will not require any new or modified legal authorities or policies at this time in order to meet the requirements of this special condition. The following is a list of JSRCC’s relevant existing legal authorities and policies:

• MS4 Program Plan

• Illicit Discharge Detection and Elimination Policy

• Annual Standards and Specifications for Erosion and Sediment Control (through the

Virginia Community College System, VCCS)

• JSRCC’s Stormwater Master Plan

• Bacteria TMDL Action Plan

• Stormwater Pollution Prevention Plan for High Priority Facilities

JSRCC will coordinate with Henrico County (adjacent MS4) to establish a memorandum of understanding (MOU) to further clarify MS4 service boundary line(s) and inter-jurisdictional responsibilities for POC loads and subsequent required POC load reductions in the future.

3.0 New or Modified Legal Authority

JSRCC has no new or modified legal authorities such as ordinances, state and other permits, orders, specific contract language and/or inter-jurisdictional agreements implemented or needing to be implemented to meet the requirements of this special condition.

4.0 Means and Methods to Address Discharges from New Sources

All new sources developed or redeveloped after July 1, 2009 on the JSRCC campus meet an average impervious land cover condition of 16% for the design of post developed stormwater management facilities. As such, no additional offsets are required under this permit’s Special Conditions beyond those for existing development.

5.0 Estimated Existing Source Loads and Calculated Total POC Required Reductions

JSRCC’s Existing Sources Land Cover Types, provided in

Table 5-1 below shows the estimated existing sources (2009 baseline cover area) impervious, pervious, forested, and open water cover types and areas for the JSRCC Campus.



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Table 5-1: Existing Sources Land Cover Type

Land Cover Type Area (ac)

Impervious 24.5

Pervious 26.0

Forested 63.0

Open Water 0.3

Total 113.8

All land cover types were delineated using JSRCC’s GIS data and 2009 VGIN aerial photography. Forested lands were observed to meet the tree density requirements of Guidance Memo 15-2005, Appendix V.H, were undeveloped, and met a minimum area of 900m2. Figure 5-1 shows JSRCC’s property boundary and regulated MS4 area. Lands outside of the regulated area are operated by Henrico County and will be included as part of their MS4 regulated area. Figure 5-2 shows the 2009 baseline land cover types within the regulated area of the JSRCC campus.



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Figure 5-1: JSRCC Regulated Area

¯0 600 1,200300Feet

Legend

MS4 Regulated Area

JSRCC Property Boundary

Figure 1: JSRCC Regulated Area

E. Parham Rd




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Figure 5-2: 2009 Baseline Land Cover Type

¯0 500 1,000250Feet

Figure 2: 2009 Baseline Land Cover Types

Legend

2009 Land Cover

Forest

Open Water

Pervious

Impervious

MS4 Regulated Area

JSRCC Property Boundary

Aerial Imagery taken from VGIN - 2009

2009 Land Cover %

Impervious 24.5 21.5%

Pervious 26.0 22.9%

Forest 63.0 55.4%

Open Water 0.3 0.3%

Total Acreage 113.8



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5.1. Existing Source Loads

Table 5-2 and Table 5-3 provide the baseline existing source loads and required pollutant reductions based on JSRCC’s 2009 baseline cover area.

Table 5-2: Calculation for Estimating Existing Source Loads

*Based on Chesapeake Bay Program Watershed Model Phase 5.3.2 for the James River Basin

Subsource Pollutant Total Existing Acres

Served by MS4 (06/30/09)

2009 EOS Loading Rate

(lbs/acre)

Estimated Total POC Load based on 2009

Progress Run

Regulated Urban Impervious

Nitrogen 24.47 9.39 229.75

Regulated Urban Pervious

26.03 6.99 181.95

Regulated Urban Impervious

Phosphorus 24.47 1.76 43.06


26.03 0.5 13.01

Regulated Urban Impervious Total Suspended

Solids

24.47 676.94 16,562.96


26.03 101.08 2,631.08

5.2. Existing POC Required Reductions

Table 5-3: Calculation Sheet for Determining Total POC Required


Subsource POC

Total Existing Acres Served

by MS4 (06/30/09)

Required Reduction in Loading Rate

(lbs/acre)

5% Total Reduction

Required (lbs)

35% Total Reduction

Required (lbs)

60% Total Reduction

Required (lbs)

100% Total Reduction

Required (lbs)

First Permit Cycle

First 5yr Permit Cycle

Second 5yr Permit Cycle

Third 5yr Permit Cycle

All Permit Cycles

Regulated Urban

Impervious Nitrogen

24.5 0.04 0.98 6.85 11.74 19.57

Regulated Urban

Pervious 26.0 0.02 0.52 3.64 6.25 10.41

POC Total: 1.50 10.50 17.99 29.99

Regulated Urban

Impervious Phosphorus

24.5 0.01 0.24 1.71 2.94 4.89

Regulated Urban

Pervious 26.0 0.002 0.05 0.36 0.62 1.04

POC Total: 0.30 2.08 3.56 5.93

Regulated Urban

Impervious Total Suspended

Solids

24.5 6.67 163.20 1,142.38 1,958.37 3,263.95

Regulated Urban

Pervious 26.0 0.44 11.45 80.17 137.44 229.06

POC Total: 174.65 1,222.55 2,095.81 3,493.01



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6.0 Means and Methods to Meet the Required Reductions and Schedule

JSRCC intends to meet the required reductions and schedule through the retrofit of an existing parking lot that currently has no stormwater management. Two bioretention basins will be installed to treat approximately 1.0 acre of impervious parking area that currently discharges directly to an unnamed tributary of North Run. Figure 6-1 shows the location of the proposed retrofit project.

Table 6-1 has been developed to show the pollutant removal calculation of the two facilities, using the Chesapeake Bay Program BMPs established efficiencies. The project area is located in hydrologic soil group “B” per Natural Resources Conservation Service (NRCS) soil survey information for the area, and as such the bioretention facility in A/B soils with an underdrain removal rate was used for these calculations.

Table 6-1: Calculation for Proposed Retrofit Pollutant Loadings & Removals


Subsource Pollutant Area

Treated (Ac)

2009 EOS

Loading Rate*

(lbs/acre)

Pollutant Loading Rate to

Bioretention Facility

Bioretention in A/B Soils, w/underdrain

Pollutant Removal

Rate

Pollutant Removal

(lb/yr)

Regulated Urban Impervious Nitrogen

1.0 9.39 9.39 70% 6.57

Regulated Urban Pervious 0.0 6.99 0.00 70% 0.00

Regulated Urban Impervious Phosphorus

1.0 1.76 1.76 75% 1.32


Regulated Urban Impervious Total Suspended

Solids

1.0 676.94 676.94 80% 541.55


The removal rates for TP, TN, and TSS will significantly exceed the 5% reduction requirements for the first permit cycle ending June, 30th, 2018, and will count toward the anticipated second permit cycle reduction requirements.

JSRCC reserves the right to revise this Action Plan as needed as the implementation process continues.



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Figure 6-1: Proposed Parking Lot Retrofit



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7.0 Means and Methods to Offset Increased Loads from New Sources Initiating Construction between July 1, 2009 and June 30, 2014

All new sources developed or redeveloped after July 1, 2009 on the JSRCC campus meet an average impervious land cover condition of 16% for the design of post developed stormwater management facilities. As such, no additional offsets are required under this permit’s Special Conditions beyond those for existing development.

8.0 Means and Methods to Offset Increased Loads from Grandfathered Projects that began Construction after July 1, 2014

JSRCC has a Stormwater Master Plan that was approved by the State before July 1, 2012. Therefore, in accordance with 9VAC25-870-48, projects outlined in the Master Plan may be considered grandfathered. However, all grandfathered projects would still meet the average impervious land cover condition of 16% and therefore not require any further offsets under the Special Condition.

9.0 List of Future Projects, and Associated Acreage that Qualify as Grandfathered

JSRCC has a Stormwater Master Plan that was approved by the State before July 1, 2012. Therefore, in accordance with 9VAC25-870-48, projects outlined in the Master Plan may be considered grandfathered. However, all grandfathered projects would still meet the average impervious land cover condition of 16% and therefore not require any further offsets under the Special Condition.

10.0 An Estimate of Expected Cost and Schedule to Implement the Necessary Reductions

The estimated expected cost to retrofit the existing parking lot with two bioretention facilities is provided in Table 10-1 below. This summary is not based on a detailed cost estimate derived from design plans or contractor/vendor agreements and is subject to change upon implementation.

Table 10-1: Parking Lot Retrofit Implementation Estimate

Design Cost $40,000

Construction Cost $120,000

Total Cost $160,000

JSRCC intends to design the two facilities during fiscal year 2016 (July 2015-June 2016) and will look to fund and construct one or both of the facilities during fiscal year 2017. It is the intent that the 5% pollutant removal requirements will be in place by June 30, 2018.



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11.0 Public Comments on Draft Action Plan

The Draft Action Plan was posted to the College website for at least 30 days in order to receive comments and feedback from the public. No comments or feedback were received during the comment period.

Documents

J. Sargeant Reynolds Community College Chesapeake Bay TMDL ...reynolds.edu/who_we_are/.../pdf/...Plan_2017-03-30.pdf · Chesapeake Bay TMDL Action Plan 1 1.0 Introduction The J. Sargent