UMW Local (Chesapeake Bay) Bacteria TMDL Action Plan

UMW Local (Chesapeake Bay) Bacteria TMDL Action Plan

 for the Tidal Freshwater Rappahannock River Watershed


Facilities Services University of Mary Washington

1301 College Avenue

Fredericksburg, VA 22401



  1. Leslie Johnson, Jr.

 Capital Outlay Project Manager (540) 654-2100


Issued: November 2016

Revised: January 2017

Revised: May 2018

Revised: May 2020






Table of Contents


Attachment A – Stormwater Outfalls


Acronyms and Abbreviations


BMP                      Best Management Practice

CUA                       Census Urban Area

CWA                      Clean Water Act

CSS                         Combined Sewer System

DEQ                       Department of Environmental Quality

EPA                        Environmental Protection Agency

IDDE                      Illicit Discharge Detection and Elimination FM   Facilities Management

GIS                         Geographic Information Systems

GPS                        Global Positioning System

HUC                       Hydrologic Unit Code

LA                           Load Allocation

MEP                       Maximum Extent Practicable

MCM                     Minimum Control Measure

MS                         Minimum Standard

MS4                       Municipal Separate Storm Sewer System

NPDES                  National Pollution Discharge Elimination System POC                                Pollutants of Concern

SWM                     Stormwater Management

SWPPP                 Stormwater Pollution Prevention Plan TMDL      Total Maximum Daily Load

UA                          Urbanized Area

VAC                       Virginia Administrative Code

VPDES                   Virginia Pollution Discharge Elimination System VSMP   Virginia Stormwater Management Program WLA             Waste Load Allocation


University of Mary Washington




Stormwater discharges for the University of Mary Washington (UMW) campuses are regulated under the Commonwealth of Virginia 2013-2018 General Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4).   UMW is required to update their MS4 program plan to include approvable TMDL Action Plans for pollutants identified in TMDL waste load allocations (WLA) approved either on or after July 9, 2008.



  • Total Maximum Daily Loads


The Bacteria TMDL for the Tidal Freshwater Rappahannock River Watershed was developed in April of 2008 and approved by the EPA in May 2008 and the State Water Control Board in April 2009. This water body was listed as impaired on Virginia’s 303(d) Total Maximum Daily Load Priority List and Reports (DEQ 2002, 2004, and 2006) because the state’s water quality standards for E. coli and fecal coliform bacteria were exceeded. The watershed is located in the hydrologic unit (HUC) 02080104 in the Rappahannock River Basin. This basin includes the City of Fredericksburg, as well as portions of Caroline, King George, Spotsylvania, and Stafford Counties.



  • TMDL Special Conditions


The MS4 permit requires UMW to update its MS4 program plan to include a specific action plan for the Bacteria TMDL. Section I.B of the permit establishes special conditions for approved TMDLs other than the Chesapeake Bay TMDL. The MS4 permit requires UMW to include the following items in the Bacteria TMDL Action Plan:


Develop and maintain a list of legal authorities applicable to reducing bacteria


Identify and maintain a list of additional management practices (beyond minimum control measures) that have been implemented that are applicable to reducing bacteria

Enhance public education and outreach and employee training programs to promote methods to eliminate/reduce discharges of bacteria

Develop and implement a method to assess the TMDL Action Plan for its effectiveness in reducing bacteria.


  • UMW Tidal Freshwater Rappahannock River Watershed Action Plan


The Bacteria Action Plan has been developed to meet the requirements of the MS4 General Permit special conditions listed in section 1.2. An adaptive and iterative approach is being utilized to meet surface water quality goals, the Action Plan may undergo revisions to reduce levels of E. coli being discharged from the UMW service area to the maximum extent practicable (MEP). The Bacteria Action Plan is incorporated by reference into UMW’s MS4 Program Plan.


    • UMW Wasteload Allocation


The Bacteria TMDL report establishes an aggregate WLA for the MS4 permittees within the watershed. The MS4 WLA is listed at 389 trillion colony forming units (cfu)/year, resulting in a 62.8% reduction of the existing load. The Bacteria TMDL lists the following MS4 permittees for the watershed:


City of Fredericksburg Spotsylvania County* Stafford County

Stafford County Public Schools University of Mary Washington VDOT

*Spotsylvania County has been removed from the MS4 permittee list.



The Bacteria TMDL considered potential sources of E. coli for point and non-point sources of pollutants to the impair waters within the watershed. Included in the assessment were sanitary sewer and septic systems, livestock, non-point agricultural, urban run-off, and wildlife.

UMW does not operate or maintain a sanitary sewer system nor does the University utilize septic systems.  UMW is served by the City of Fredericksburg’s sanitary sewer system, with laterals from UMW buildings entering the system. No leaking sewer lines have been identified on the campus. In the event that there was a problem with a sewer line, it would be reported to the city for prompt repair. Based on this information sanitary sewer is not a “significant” source of the POC.

The majority of the UMW campus is comprised of dormitories and classrooms. The campus does not engage in industrial, commercial, or manufacturing activities. There are very small areas used for trash collection and some low volume grease traps in service. However, as stated in Section 3.2, UMW follows good housekeeping practices to prevent waste from accumulating, preventing these sources from becoming a significant source for the POC. The most recent waste collection contract requires use of liquid-tight dumpster containers. All containers are liquid-tight as of 01 July 2018. By contract, these containers are required to be inspected for compliance annually.


Urban run-off (pet waste and facilities) and wildlife are the only likely sources applicable to the UMW campuses.


  • Pet Waste


UMW will endeavor to reinforce through our normal outlets (such as student newspaper, Eaglevision television, and student, faculty, and staff newsletters) how prompt collection and proper disposal of pet waste prevents the introduction of fecal material into the storm sewer system, and hence to the Rappahannock River. These reminders will be issued on a semi-annual basis. UMW has installed four pet waste stations on the Fredericksburg campus, where pet owners can obtain waste collection bags. Additional pet waste stations are being considered. Station locations are shown on the campus map.



  • Facilities


There are no facilities in use at the UMW campuses that would be a significant source of E. coli. UMW maintains a full staff of grounds and maintenance personnel who are trained to follow good housekeeping practices which  preclude the accumulation of putrescible waste which could become a source of E. coli. Through its sustainability programs, which encourage and educate staff, faculty, and students, on the importance of recycling and litter control, UMW further reduces the potential for bacterial contamination entering the watershed.

UMW stream restoration projects have been shown to reduce E. coli levels by restoring the riparian buffers of the stream. These buffers are routinely inspected by UMW staff, and maintained as necessary.


  • Wildlife Sources


The Bacteria TMDL does not advocate wildlife reduction strategies unless it is necessary due to over population and then under the auspices of the Department of Game and Inland Fisheries (DGIF). The DEQ and EPA recognize that attainment may not be possible without a reduction in the wildlife sources but will concentrate on the anthropogenic sources and re-evaluate the watershed for improvement and/or possibly re-classification of segments of the watershed.


    • Legal Authority


As a University, UMW is a non-traditional MS4 and does not have the ability to create laws and regulatory authority. The MS4 program does include policies (UMW / Administration / University Policies / E.1.5 Illicit Discharge Detection and Elimination Policy), procedures, and contract language that are consistent with the goal of reducing bacteria in stormwater discharges. UMW maintains a collegial relation with MS4 coordinators in the City of Fredericksburg, Stafford County and VDOT. There is interdependency between the UMW Fredericksburg stormwater management systems in the city of Fredericksburg, while the Dahlgren campus in King George County, and UMW Stafford in Stafford County, remain ‘stand-alone’ entities. VDOT, of course, has general oversight of the roadways between the campuses.


  • Minimum Control Measures


MCM 1 (Public Education and Outreach)


UMW stresses education of the impact of human activity on water quality and how the actions of staff, faculty and students affect the quality our rivers and streams. UMW strives to inform the community on the proper collection and disposal of pet waste, disposal of human generated litter, and the stormwater reuse strategies that incorporate Virginia native plant materials.


MCM 2 (Public Participation)


UMW provides stormwater information on their web site, and offers many opportunities for the community to provide comments on programs being implemented on the campuses, including this Bacteria TMDL Action Plan.


MCM 3 (Illicit Discharge Detection and Elimination)


Staff Training Historical data indicates that the University’s front line service employees are, by nature of their duties, collectively more likely to observe and report unusual or aberrant conditions than any other constituent group on the University grounds. Consequently all grounds and maintenance services staff will be provided annual training to allow them to detect and eliminate illicit discharges. Illicit discharge detection, implies that any illicit discharge, whether a stormwater discharge or a sanitary sewer discharge, can be identified and reported in a


timely manner by UMW employees. Reinforcement through staff reiterative training is documented by meeting agendas and participant sign-in sheets.

MCM 4 (Construction Site Stormwater Runoff Control)


UMW regulates construction on the campuses in accordance with their DEQ-approved Annual Standards and Specifications. By utilizing inspections and enforcement of the stormwater pollution prevention plan (SWPPP) requirements, E. coli pollution (portable toilets, job-site waste, etc.) is minimized.


MCM 5 (Post-construction stormwater management in new development and re-development)


The University conducts both routine as well as event-generated inspection of storm water runoff for a two-year period following completion of construction or redevelopment work. Grounds maintenance staff will inspect sites following major rain fall in order to ensure that constructed storm water management devices are working as designed and intended. These practices have been demonstrated to reduce bacteria in runoff.


MCM 6 (Pollution prevention / good housekeeping for municipal operations)


The university is committed to responsible environmental stewardship and through the Nutrient Management Plan will maintain turf and field areas, as well as naturalized areas, with care to control storm water runoff of chemical and biological elements. For over fifteen years the university has operated a highly effective recycling program aimed not only at high volume materials such as paper, glass, and aluminum, but also including relative low volume, but equally important potential pollutants such as vehicle batteries, printer cartridges, and fats/greases, which contributes to minimizing the potential for E. Coli contamination.


  • Additional Practices and Controls


Potential Sources


As noted previously, UMW will continue to encourage pet owners to clean up after their pets, through the education and outreach programs. UMW will enhance the pet waste program and education to include semi- annual reminders to pet owners, through their web site and social media, of the impact uncontrolled pet waste has on the local streams and rivers.

UMW has identified several areas on the main Fredericksburg campus and the Battlefield Athletic Complex walking paths preferred by dog owners. Four pet waste station have been installed locations that are easily accessible and visible to the public. Activity is monitored by bag consumption, and additional pet station locations are under consideration.

Dry weather screening of the stormwater outfalls for non-stormwater discharges, including sanitary sewer discharges, will be incorporated into the MCM 3 protocols and conducted on a semi-annual basis. A list of stormwater outfalls is presented in Attachment A.

Livestock is not permitted on the campus and would be removed upon discovery. Wildlife is a source of E. coli contamination but in accordance with DEQ and EPA policies no programs for elimination are proposed.

Staff Training


Staff training as presented in Minimum Control Measures will be enhanced to increase awareness of potential E. coli sources and implementation of the appropriate actions to minimize the potential for E. coli contamination.


Public Outreach


The Public Outreach program has been enhanced to focus on the control of pet waste, the beneficial nature of urban forests, the universal benefits of litter control and the detection of illicit discharges, as detailed in the previous sections of this Action Plan.

UMW personnel participate in public information events such. These event participations become part of our Annual report, and such events will now also be celebrated in the various media outlets identified previously.



UMW will implement the MS4 Program components, to include the bacteria TMDL, as presented in this Action Plan to reduce the potential of E.coli discharge to surface waters to the maximum extent practicable. The MS4 Program Plan has been updated with this Bacteria Action plan and the training, education, and public outreach elements of this Plan will be included throughout the year as presented in the most recent MS4 Annual Report.


Activity Schedule
Submit revised TMDL Action Plan February 2017
Pet Waste Reminders Semi-annual
Pet Waste Doggie Station Installation April 2017
Public Outreach (across all media) Semi-annual
Education Semi-annual
Staff Training (including IDDE) Semi-annual
Dry Weather Screening for Non- Stormwater Discharges Semi-annual



It is impossible to determine UMW’s individual contribution of E.coli concentrations to the impaired waters, which precludes the use of numeric values to measure the effectiveness of the programs. The measurable goals of this Plan will be measured via the MS4 annual reporting process with the review of the effectiveness of each MS4 Program Plan BMP as presented in section 4. Interim milestone activities consist of the annually reported implementation of the Program components listed in this Action Plan.

UMW will track and report the number of visits to their web site,, as well as the number of “likes” on social media pages. Other measures include the amount of literature distributed as part of the outreach and education programs and the sign-in sheets demonstrating the number of staff trained in the identification, risk factors, and significant sources associated with E.coli. Results of the dry weather screening will be recorded and retained as part of the MCM 3 condition of the MS4 permit.









p-300                                        Attachment  A


University of Mary Washington



Site Development Solutions

1703 N. Parham Road Henrico, Virginia 23229

804.740.9200 Project No.: 04590-002






























0-##- – Outfalls


p-41## – pipe segments


Lettered sections  – outfall channels