plan year 1 report vpdes phase ii ms4 program

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Plan Year 1 Report VPDES Phase II MS4 Program Permit Compliance Assessment Permit # VAR040059 July 1, 2009 – June 30, 2010 Town of Leesburg, Virginia 25 West Market Street Leesburg, VA 20176 DRAFT VERSION FOR REVIEW

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Page 1: Plan Year 1 Report VPDES Phase II MS4 Program

Plan Year 1 Report VPDES Phase II MS4 Program

Permit Compliance Assessment Permit # VAR040059

July 1, 2009 – June 30, 2010

Town of Leesburg, Virginia

25 West Market Street Leesburg, VA 20176

DRAFT VERSION FOR REVIEW

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Town of Leesburg NPDES Annual Report, October 2010

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Table of Contents

Introduction ..................................................................................................................................... 3 MCM #1   Public Education and Outreach on Stormwater Impacts .......................................... 4 MCM #2   Public Involvement and Participation ..................................................................... 17 MCM #3   Illicit Discharge Detection and Elimination ........................................................... 19 MCM #4   Construction Site Stormwater Runoff Control ....................................................... 23 MCM #5   Post-Construction Stormwater Management .......................................................... 24 MCM #6   Pollution Prevention and Good Housekeeping ....................................................... 26 

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Town of Leesburg NPDES Annual Report, October 2010

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Introduction The following report has been prepared by the Department of Public Works to comply with the requirements of the Virginia Pollution Discharge Elimination System (VPDES) General Permit for Discharges of Stormwater from Small Municipal Separate Storm Sewer Systems. The Town of Leesburg developed and submitted a stormwater management plan, designed to meet the following six minimum control measures intended to reduce the discharge of pollutants into the storm sewer system.

1. Public Education and Outreach

2. Public Involvement and Participation

3. Illicit Discharge and Detection

4. Construction Site Stormwater Runoff Controls

5. Post Construction

6. Pollution Prevention and Good House Keeping The Department of Environmental Quality (DEQ) issued General Permit #VAR040059 to the Town of Leesburg. Under the requirements of this permit, the Town must provide verification of compliance with the six minimum control measures mentioned above. The following report documents the progress made by the Town towards achieving these minimum control measures. At the beginning of each section is a summary table which provides the status of the required tasks for Plan Year 1 and the progress the Town has made towards completion of those objectives. At the end of the report are appendices with some representative samples of the work the Town has done with regard to the 6 minimum control measures.

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Town of Leesburg NPDES Annual Report, October 2010

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MCM #1 Public Education and Outreach on Stormwater Impacts Throughout the most recent permit cycle, the Town of Leesburg has continued to employ a strong public education and outreach campaign and pursued new avenues to reach a broader audience and expand on interactions with citizens and businesses. The Town has maintained its objective to actively connect with a broad demographic population and encourage the community to work cooperatively with the Town to promote stormwater pollution prevention and efforts towards maintaining a clean and safe water supply. With the inception of the Community Enhancement Team, the Town now has an additional means of working with HOAs and communities to distribute information and work one-on-one with residents to promote stormwater pollution prevention. In this permit cycle, The Town of Leesburg has continued to use conventional means of distribution to convey the stormwater pollution prevention mention (newspaper ads, direct mail campaigns, website posting, etc.) In addition, the Town now also has begun utilizing social media (Facebook, Twitter, etc.) to reach a more diverse audience. Activities this permit cycle included: BMP Task 1A General pollution prevention education and outreach

Storm Drain Marking Program The Town of Leesburg has continued to advertise storm drain marking opportunities on the Town’s website and through informational brochures made available at various outreach events such as the Town’s Annual Flower and Garden Festival, Loudoun County’s Family Stream Day, and other local events. The Town has also posted information on the local cable access channel. In this permit cycle, the Town engaged residents in an increased effort to promote the program by including the activity as part of the 6th Annual Keep Leesburg Beautiful community cleanup event. In 2010, the event ran the entire month of April to allow for additional opportunities to participate in the program. This effort netted additional volunteers including students, individuals seeking community service hours, at-risk youth and local businesses and employees. During this event, over 120 storm drains were marked, including numerous inlets in newly developed parts of town, and volunteers were given information on preventing stormwater pollution. Several businesses participated, including staff from Wegmans, one of the largest businesses to establish occupancy in the Town this cycle.

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Town of Leesburg NPDES Annual Report, October 2010

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Clean Water Partners Participation The Town of Leesburg has continued to participate with the Northern Virginia Regional Commission’s Clean Water Partners program. The participation in this group has afforded the Town with networking opportunities with other neighboring communities and the ability to share ideas and resources otherwise unavailable to the Town on its own. In 2009, Clean Water Partners continued to use traditional methods of advertising such as radio ads, but added a new layer to the campaign with the use of a revised/updated website and the use of social media as an outlet for distributing information to a younger audience and drawing new interest to the campaign. The group has continued to work with a consultant to continue updating the the program’s website and developing new approaches for information and education opportunities. The main site boasts 3 key sections: Used Oil Disposal Information, Pet Waste Pollution Pickup, and Environmentally Friendly Landscaping Practices. The participating jurisdictions are each responsible for their page under each heading and provide information relevant to local residents and businesses in their respective areas. In 2010, a new site has been developed to specifically target pet waste pollution. The Clean Water Partners group worked with the consultant to engage the services of a professional blogger to create an interactive site for dog owners. The Northern Virginia Dog Blog began in June 2010 and offers informational articles on pet care, with the underlying message of responsible pet ownership and pet waste pollution prevention. Interested visitors may also sign up for an e-mail list to receive additional promotional offers and information on pollution prevention practices. The contemporary site design and continuously updated article repository make the site a great source of education that will draw readers to continue to return to the site, accessing new and updated information.

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Town of Leesburg NPDES Annual Report, October 2010

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Northern Virginia Dog Blog

Northern Virginia Clean Water Partners

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Town of Leesburg NPDES Annual Report, October 2010

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Text Messages on Utility Bills or Pollution Prevention Ad The Town’s utility bills have been revised and are unable to carry the additional line message we have previously used. As indicated in our plan, as an alternative, the Town ran an additional household hazardous waste disposal ad, promoting the safe disposal of unwanted/unused chemicals and hazardous products. The ad features dates for the four remaining events for 2010. This information is also included on the Town’s Public Works website and links to the Loudoun County Office of Solid Waste Management’s site.

Loudoun Times Mirror Ad

Distributing Educational Materials In April 2010 the Public Works Department again teamed up with Parks and Recreation and Planning and Zoning staff to coordinate the Annual Keep Leesburg Beautiful community cleanup event. The event provides communities and individual citizens with materials to perform cleanup activities in and around their neighborhoods. This year’s event ran the entire month of April, 2 weeks longer than last year’s campaign. In all, over 160 volunteers collected 220 bags of trash as well as numerous bulky items such as mattresses, tree stumps and tires from local parks, community open spaces and creeks/streams. Volunteers included citizens groups from individual neighborhoods as well as several youth groups such as Boy Scouts, Girl Scouts and Kids With Purpose, a youth organization that meets for several weeks at a time to teach young children about conservation efforts, community spirit, and volunteerism.

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Town of Leesburg NPDES Annual Report, October 2010

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This year’s campaign also saw the participation of several businesses, including Wegmans, Cardinal Bank, eTitle and Atlantic Law Group, LLC. Volunteers from each business performed cleanups along streams and creeks in local communities or near their business. Volunteers also marked storm drains to promote awareness of the flow of stormwater directly to local waterways. The Town gave participants safety vests, gloves and orange trash bags to make the special pickups easily identifiable for Street Division crews to collect. The Town will continue to make such supplies available throughout the year for any residents or volunteer groups who wish to participate in a community cleanup activity. In addition, we will promote the availability of materials on our website and through direct-mail campaigns to HOAs, businesses, community groups and schools.

KLB Opening Day at Ida Lee Park Volunteer performing stream cleanup

Stream cleanup and storm drain marking volunteers Tree planting at local park

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Town of Leesburg NPDES Annual Report, October 2010

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Website Development/Maintenance The Town has maintained its educational outreach efforts through information posted on the Public Works website. The site offers visitors an opportunity to learn about stormwater pollution prevention, storm drain marking and the importance of protecting our water supplies. In addition to maintaining and updating the current website, the Town has recently adopted the use of Facebook and Twitter accounts to provide additional access for citizens to find information about Town programs. The Town’s goal is to create a customized page for the Public Works Department to promote participation in outreach events, volunteer opportunities, and behavior modification suggestions (i.e., fertilize in fall, if at all) The Town will continue to seek ways to update and improve the interest of the stormwater management program pages, and expand the information specifically geared towards children to promote interest in pollution prevention and caring for our environmental resources. In addition, the Town is seeking translation assistance to provide information in Spanish on the website as well as through direct-mail pieces and informational flyers and brochures.

Notifying Local Organizations of Outreach Opportunities The Town has posted information for non-profit organizations and community groups to have their stormwater pollution prevention related activities and events posted on the Town’s website. Interested parties may contact the Town and upon review of their information, the Town will post the activity or event on the website to provide additional access to potential volunteers. In the spring of 2010, the Town posted information from the Rust Sanctuary Audubon Society for 3 environmental stewardship opportunities, including assisting with the maintenance of the riparian buffer planted along the Town Branch. The Town worked with the Environmental Advisory Commission, the Loudoun Watershed Committee and the Piedmont Environmental Council to plant trees, shrubs and perennials along the creek to restore the natural buffer and

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Town of Leesburg NPDES Annual Report, October 2010

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improve the natural habitat for wildlife. This volunteer opportunity allowed participants to see the progress made since the initial planting and to help to care for existing plants and replace those that did not make the transition.

1B Targeted Residential Pollution Prevention Strategies Pet Waste Pollution Prevention The Town has contacted additional local retailers and pet care service providers to find new partners for displaying and promoting pet waste pollution prevention. In the most recent permit cycle, the Town has developed additional partnerships with Doggy Do Right and Dog Day Afternoon. The new partners have agreed to hang posters (which will be updated quarterly or as appropriate) and make available flyers and information on the importance of picking up after pets. In addition, the Town has used other local events, such as Keep Leesburg Beautiful, as a means of distributing additional information to pet owners on the importance of cleaning up after pets. During this permit cycle, the Town also sent out direct mailings to pet owners in Town reminding them of the need to clean up after pets. Several HOA’s also requested bundles of these flyers for distribution to residents. The Tuscarora Creek Apartments was one of the communities requesting posters and flyers. The installed pet waste disposal stations throughout their community and worked with the Town to educate residents on the importance of pet waste pollution prevention.

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Town of Leesburg NPDES Annual Report, October 2010

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Sample Pet Waste Poster Brochure Mailed to Dog Owners

Press Releases/Advisories The Public Works Department developed a newsletter which was distributed to all HOA and property management companies with communities in Leesburg. Specific information was included regarding pet waste pollution prevention. The article was also available in a document format to allow for use in community newsletters. In addition to the customary press release format through newspaper and media outlets, the Town also maintains an archive with links to these files on our stormwater management/water quality website. Distributing Educational Materials During the Town’s annual Keep Leesburg Beautiful event in April 2010, Public Works helped draw attention to the need for storm drain marking volunteers by publicizing the event in local papers, on the Town’s website and through direct-mail campaigns to community groups, businesses and schools. Several businesses participated in the program, as well as students and families in the community. The annual Flower and Garden Festival provided another outreach opportunity for conveying the stormwater pollution prevention message. The event draws several thousand residents from around the region each year. In the spring of 2010, Public Works joined together with the Environmental Advisory Committee to co-host a booth providing information on environmental issues specific to the Town of Leesburg. Brochures promoting pollution prevention strategies and volunteer opportunities for the Town’s storm drain marking program were also given to festival visitors.

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Town of Leesburg NPDES Annual Report, October 2010

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The annual Flower and Garden Festival draws crowds of 15-20,000 people to Leesburg

PW provided handouts and information to citizens on various pollution prevention topics including pet waste pickup, proper lawn and garden care, and stormwater pollution awareness. In addition, the festival allowed for one-on-one conversations with citizens concerned about the environment and stormwater pollution issues. In addition, the partnership with the Environmental Advisory Commission was beneficial in promoting a common interest in volunteers for stream restoration and cleanup projects. This June the Town held its first Community Enhancement Team outreach event at the Loudoun Hills community park. Town staff worked with the HOA and property management company to host an evening of interaction with resident and sharing of information on Town services and initiatives. This community has experienced issues with illegal dumping and unsafe disposal of household hazardous waste. By providing information on Town and County services, the residents had more options for safe disposal of unwanted items. The Public Works Department also provided a gift for attendees – a biodegradable sport water bottle with the “only rain down the storm drain” message imprinted as well as information on pollution prevention. The Community Enhancement Team is currently working with several other communities in Town to establish similar outreach opportunities.

Loudoun Hills Community Enhancement Team Outreach Event June 2010

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Town of Leesburg NPDES Annual Report, October 2010

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On October 17th, 2010, the Town of Leesburg partnered with Loudoun County to host a booth at the Annual Family Stream Day held at Claude Moore Park in Sterling, Virginia. In spite of the rain, numerous families and students came out to participate in a circuit of activities designed to promote environmental awareness and stewardship. This year the Town and County chose Illicit Discharge and Illegal Dumping as the focus for the booth. Display boards were used to illustrate examples of both undesired behaviors and a short quiz was given after viewing the information to obtain a stamp for a passbook – the students participating received additional school credits for participating in and completing activities at the event. In April 2010 the Public Works Department again teamed up with Parks and Recreation and Planning and Zoning staff to coordinate the Annual Keep Leesburg Beautiful community cleanup event. This year’s event ran the entire month of April, 2 weeks longer than last year’s campaign. Although seeing a slight decrease in the total number of volunteers, over 160 volunteers still participated and collected 220 bags of trash – more than collected in last year’s event. In addition, Town staff volunteered alongside citizens and businesses in a high-risk area of Town to clean up behind businesses and near apartment complexes. Volunteers removed several truck-loads of brush and weeds, freeing up access to storm drain inlets and reducing the risk of clogged storm pipes. Several businesses, including Wegmans, Cardinal Bank, eTitle and Atlantic Law Group, LLC. Volunteers from each business performed cleanups along streams and creeks in local communities or near their business. Volunteers also marked storm drains to promote awareness of the flow of stormwater directly to local waterways. The Town gave participants safety vests, gloves and orange trash bags to make the special pickups easily identifiable for Street Division crews to collect. The Town will continue to make such supplies available throughout the year for any residents or volunteer groups who wish to participate in a community cleanup activity. In addition, we will continue to promote the availability of materials on our website and through direct-mail campaigns to HOAs, businesses, community groups and schools. Advertising Hazardous Household Waste Collection Opportunities The Town of Leesburg has continued to work with Loudoun County’s Office of Solid Waste Management to advertise and promote the various HHW events sponsored by Loudoun County throughout the year. These events have been advertised in the Leesburg Today newspaper and will be advertised in the Loudoun Times Mirror, in brochures and flyers from the Public Works Department and are publicized on the Town’s refuse and recycling website. The website provides information on where residents may take used/extra motor oil, antifreeze and automotive batteries for safe disposal and recycling. The Loudoun County Solid Waste Management Facility accepts these items year-round at no cost. In June 2010 the Town placed an ad in the Loudoun Times Mirror listing the dates of the remaining collection events and their

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Town of Leesburg NPDES Annual Report, October 2010

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locations for the remainder of 2010 to draw attention to these opportunities for local residents.

An ad was placed in the Loudoun Times Mirror to promote HHW events as well as a listing on the Town’s updated website

linking to Loudoun’s HHW schedule.

1C Targeted Commercial and Industrial Pollution Prevention Strategies The Town has continued to partner with ESI to ensure that incoming plans meet all the criteria for compliance with the Town’s stormwater management and pollution prevention goals. The Town has continued to promote pollution prevention for commercial entities through variuos industry-specific publications on the Town’s website. Aslo during PY2, in conjunction with the Utilities Division, the Public Works Department focused efforts on eliminating Fats, Oils and Grease (FOG) from sanitary and storm sewer systems. The Town concentrated efforts in the downtown business district and sent 2 direct mailings during PY2 to restaurants in this high-risk area. With the configuration of in-ground drains in the alleyways behind restaurants, there is a high potential for improperly contained FOG to enter the storm sewer system. Restauarants were given information on safe cleanup methods, spill prevention and containment methods for storage cooking liquids.

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Town of Leesburg NPDES Annual Report, October 2010

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1D Outreach to minors, disadvantaged audiences and minorities Working with Schools and Local Community Organizations Loudoun County Public Schools The Town of Leesburg continues to work with local schools to promote awareness of pollution prevention measures and the various opportunities for participating in pollution prevention activities. This year’s Keep Leesburg Beautiful campaign involved participation by students at Smartts Mill Elementary School and individual students seeking community service hours. Several students participated in cleanup and tree planting efforts, and an individual student took on storm drain marking in two neighborhoods. Kids With Purpose, Scout Troops The Town worked with a number of Scouts and an after-school group (Kids With Purpose) in coordinating stream and community pickup events as part of Keep Leesburg Beautiful. The Town established a database of these groups as well as local church groups with youth programs to provide a means for distributing information about outreach programs and volunteer opportunities. Family Stream Day On October 17th, 2010, the Town of Leesburg partnered with Loudoun County to host a booth at the Annual Family Stream Day held at Claude Moore Park in Sterling, Virginia. In spite of the rain, numerous families and students came out to participate in a circuit of activities designed to promote environmental awareness and stewardship. This year the Town and County chose Illicit Discharge and Illegal Dumping as the focus for the booth. Display boards were used to illustrate examples of both undesired behaviors and a short quiz was given after viewing the information to obtain a stamp for a passbook – the students participating received additional school credits for participating in and completing activities at the event. Community Enhancement Team (CET) In June 2010, the CET joined forces with Loudoun Hills to hold the Town’s first community outreach event. This partnership between the Town and community HOAs offers new opportunities to get into communities and interact directly with citizens in their neighborhoods. Many citizens have concerns about environmental issues but are unaware of how they can participate in efforts to prevent stormwater pollution and keep their communities safe and clean. The current outreach efforts include neighborhoods in disadvantaged areas with at-risk youth and a higher rate of citizens who speak English as a second language. The Town is also working with its IT department and private citizens/groups to make information on the website available in Spanish as well as finding methods for translating brochures and flyers into multiple languages for distribution to high-risk industries such as auto shops and restaurants. Currently, website visitors can use Google Translate to have entire pages translated into the language of their choosing.

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MCM #2 Public Involvement and Participation The Town of Leesburg has sought to develop fresh and innovative methods to broaden its public education and outreach efforts and keep the community informed regarding the negative impacts of storm water pollution and how Best Management Practices (BMPs) can be implemented to reduce and ideally prevent it. As with previous permit years, the Town’s goal has been to actively connect with a broad demographic population and encourage the community to work cooperatively with the Town to promote stormwater pollution prevention and efforts towards maintaining a clean and safe water supply. The Town has continued to use a variety of media outlets, such as newspaper organizations, local cable access channels, and direct mail to reach target audiences and reach as many citizens in our community as possible in the most effective manner possible. Activities this permit cycle included:

2A Public Notice and Participation

Post Annual Reports on the Town’s Website The Town will post the Plan Year II Report once it has been completed and forwarded to DCR for review.

2B Environmental Advisory Commission The Town has continued to work with the EAC to develop new outreach and community programs, meet program requirements with regard to new projects and development in town, and share information on new program components as they are developed. Public Works Department staff joined members of the EAC at the Flower and Garden Festival to promote common interests in the areas of environmental stewardship including utilizing rain barrels, reducing fertilizer use and looking at more environmentally friendly alternatives such as the use of TLC (Tuscarora Landscapers Choice), a biosolids fertilizer product produced by the Town of Leesburg Utilities Department and distributed at no cost to Town residents. The Town and EAC have also been discussing utilizing videos to demonstrate stormwater pollution prevention practices and encourage behavioral change among citizens. The Town now has permission to post on YouTube and Facebook, and can use video messages to reach a younger audience and generate new interest in programs.

2C Promote Non-Governmental Volunteer Opportunities The Town has taken additional steps to offer volunteer opportunities and coordinate efforts with organizations and groups within the community. In the spring of 2010, the Town posted information from the Rust Sanctuary Audubon Society for 3 environmental stewardship

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opportunities, including assisting with the maintenance of the riparian buffer planted along the Town Branch. The Town worked with the Environmental Advisory Commission, the Loudoun Watershed Committee and the Piedmont Environmental Council to plant trees, shrubs and perennials along the creek to restore the natural buffer and improve the natural habitat for wildlife. This volunteer opportunity allowed participants to see the progress made since the initial planting and to help to care for existing plants and replace those that did not make the transition.

The Town will continue to reach out to community organizations, Loudoun County Public Schools and youth groups to offer assistance in promoting and advertising environmental activities pertaining to stormwater pollution prevention, such as stream cleanups, storm drain marking, riparian buffer plantings and other environmental projects.

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Town of Leesburg NPDES Annual Report, October 2010

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MCM #3 Illicit Discharge Detection and Elimination Under this Minimum Control Measure, the Town has continued work on updating the storm sewer system maps and adding data on other water features in Town such as including BMP ponds not covered under the current permit requirements, but that still require oversight and maintenance. BMP TASK 3.A Storm Sewer Infrastructure Map

The Town of Leesburg continues to add data to the GIS maps of the Town’s storm sewer system as new data becomes available. The Town works with Loudoun County’s mapping department to import new layers and data as they update their mapping files.

3.B Authority to Address Illicit Discharge Article II of Chapter 14 of the Town Code of Leesburg, Virginia, provides authority for enforcement and right-of-way entry related to prohibited non-stormwater discharges in the Town. During PY2, there were no reported incidents of illicit discharge occurring within the Town of Leesburg.

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Town of Leesburg NPDES Annual Report, October 2010

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3.C Illicit Discharge Detection and Elimination Program/Outfall Reconnaissance As per the inspection protocol established in the SWM plan, Town staff inspected approximately 35 outfalls in TMDL WLA affected areas and an additional 15 outfalls in various locations through the corporate limits. In addition, several dry and wet ponds were also visually inspected to establish a baseline for status and maintenance needs. The Town will continue inspections throughout each plan year and continue to gather baseline data for all BMPs and ponds in the Town.

Sample inspection photos

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Town of Leesburg NPDES Annual Report, October 2010

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3.D Household Hazardous Waste Program The Town of Leesburg does not run a HHW program, but is an active supporting partner in Loudoun County’s HHW program. The Town places ads in the Loudoun Times Mirror and posts updated on the Town Intranet and Internet site advising citizens of upcoming events. As an added promotional opportunity, as members of the NVRC Clean Water Partners, the e-newsletter and the Clean Water Partners website also link to and list information on the HHW events Loudoun County has scheduled.

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Town of Leesburg NPDES Annual Report, October 2010

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3.E Storm Drain Marking Program The Town continues to track storm drain marking through an Excel spreadsheet and continues the process of incorporating this information into the GIS mapping system. In PY2, several teens volunteered to mark storm drains in communities around Leesburg. Areas with new construction were included in the coverage areas, as well as locations in older neighborhoods were decals had worn off or been removed from inlets. In addition, as part of Keep Leesburg Beautiful, volunteers from Wegmans in Leesburg went through the newly opened Village at Leesburg shopping and commerce center to mark storm drains in their area. Between the business and youth volunteers, approximately 150 storm drains were marked this permit cycle. The youth volunteers also assisted with updating counts and verification of existing markers in older communities. Information for potential volunteers is posted on the website and the local government cable access channel. Brochures are handed out at Keep Leesburg Beautiful and Family Stream Day events each year. The Town will also continue to highlight the program during Keep Leesburg Beautiful events and offer volunteers more opportunities to participate in storm drain marking and education activities.

3.F High Risk Facility Evaluation for Sediment

The Town has utilized the ArcGIS mapping system to build an inventory of Town-owned/operated facilities. After reviewing the list of Town owned and operated facilities, the Town has prioritized the facilities in order of risk and potential adverse impact on the storm sewer system. The prioritized list is included in the Appendix.

3.G Estimate of WLA Discharge and Drainage Area for Each Impaired Water The Town has been working with its SWM consultant – AMEC – and the Department of Conservation and Recreation to obtain the formulas to be used to calculate this data. At this time, the formulas are not available. As soon as this information is received, the Town will calculate the discharge and drainage areas and submit this information to DCR.

PL15

PL15PL15

PL16

PL05

I

4,000 0 4,0002,000 Feet

1 inch equals 4,000 feet

Scale

y

LegendVA HU Level 6 Watersheds

PL 05: 818.56 Acres

PL 16: 6,339.48 Acres

PL 15: 542.61 Acres

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MCM #4 Construction Site Stormwater Runoff Control Under this Minimum Control Measure, the Town is continuing to monitor construction activities as well as active BMPs. 4.A Erosion and Sediment Control Legal Authority and Implementation

The Town and Loudoun County completed and ratified the Memorandum of Understanding allowing the County to provide E&S Control services to the Town. A final copy of the executed agreement was forwarded to DCR last fall, upon its completion. An additional copy has been included in the Appendix for reference. The Town has 4 staff members who maintain E&S Control certification. Staff members participate in training and recertification as required each year. Copies of the certification information are included in the Appendix.

4.B Track and Report Land Disturbing Activities Loudoun County, as provided for by the Memorandum of Understanding, issues grading permits for projects in the Town of Leesburg and monitors Erosion and Sediment Control measures. The Town has access to the County’s Land Management Information System (LMIS) and tracks projects within the corporate limits that have been issued a grading permit by the County. A list of all land disturbing activities for which permits were issued during PY2 is enclosed in the Appendix.

4.C Citizen Complaint and Reporting Mechanism The Town has continued to promote illicit discharge and illegal dumping information to citizens and staff members in order to increase awareness and facilitate reporting of such activities. The new website has several pages dedicated to this topic. Citizens may report suspected incidents by calling the Public Works Department office, police department, or by completing an on-line reporting form.

4.D VSMP Permits for Construction Activities Loudoun County implements this requirement on behalf of the Town of Leesburg. The county requires confirmation that all permits, including the VSMP stormwater permit for construction activities, have been issued prior to issuance of a grading permit. A list of projects for which grading permits were issued in PYI is included in the Appendix.

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MCM #5 Post-Construction Stormwater Management As part of this Minimum Control Measure, the Town will continue to develop, implement and enforce measures to address stormwater runoff from all new and re-development sites within the town. The Town will continually review existing protocol and work to ensure that the procedures in place will adequately protect the Town’s resources, adjusting and revising those procedures as new information and/or technology becomes available. 5.A Post Construction BMP Legal Authority and Implementation

The Town Code was updated in November 2007 to include a section on stormwater management, thereby giving the Town the authority to review, inspect, monitor and impose penalties for violations of the Code. Previously Chapter 21, the stormwater management portion of the Code has been updated and is now listed under environmental statutes in Article II of Chapter 14. Section 5-300 of the Design and Construction Standards Manual sets the policy for stormwater management in the Town. Both the Town Code and DCSM are periodically reviewed to ensure the standards set forth are appropriate and relevant to current industry and government requirements.

5.B Track and Report Required BMP Information The Town continues to populate data in the ASIST software database used for tracking stormwater management structures and facilities. In addition, a summary report in an Excel spreadsheet has been provided in the Appendix for quick reference.

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Town of Leesburg NPDES Annual Report, October 2010

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5.C BMP Maintenance and Inspection Program With the inspection and enforcement regulations in place through the Town Code, the Town has established a list of active BMPs and notified the owners of these facilities of their maintenance and reporting requirements. The list of BMPs is continuously updated based on projects reaching completion in the Town. Reports were received from the active/operational BMPs in Town from the previous plan year. Notification letters will be sent to the owners of the newly added BMPs, detailing inspection and maintenance reporting requirements. In addition to the letter, a copy of the BMP Owner’s Guidebook will be included as well as information from manufacturers for the relevant BMP structure on each site. The Town requires that a maintenance report be certified by a PE or Landscape Architect and be submitted to the Town no later than December 31st of each year. Town staff visually inspects operating BMPs and completes a report with digital photos documenting the conditions of the BMPs to form a baseline from which future inspections can be based/evaluated. This information is also stored in the ASIST database for monitoring and tracking purposes.

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MCM #6 Pollution Prevention and Good Housekeeping As part of this Minimum Control, the Town will promote stormwater management practices throughout the Town by educating staff members on the importance of good housekeeping practices and engaging in work methods that minimize the possible damaging effects of stormwater pollution and illicit discharge. By educating new and existing staff members on the signs of illicit discharge and general good business practices, the Town can expand its eyes for alerting to possible illicit activities and preventing pollution from municipal operations. 6.A Street Sweeping Program

The Street Maintenance Division operates its own street sweeper as part of the Town’s efforts to keep trash and debris from entering the storm drain system. The street sweeper collected 1,974 cubic yards of particles that were taken to the landfill for disposal. The sweeper covers over 244 lane miles in the Town. The downtown historic district is swept on Monday and Friday mornings. The NE/NW quadrants are swept on Monday and Thursday; the SE/SW are swept on Tuesday and Friday. Areas unable to be swept on the scheduled dates due to weather or other conditions are swept on Wednesdays.

6.B Herbicide and Pesticide Applicator Certifications The Town of Leesburg Department of Parks and Recreation works with the Public Works Department to ensure all employees who apply herbicides or pesticides are properly trained in safe application procedures and maintain any and all required certifications. Copies of the most recent certificates have been included in the Appendix.

6.C Parks and Recreation Nutrient Management Plan The Department of Parks and Recreation coordinates the plan for management of nutrients within the Town. No changes have been made since the plan was submitted in previously reports.

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Town of Leesburg NPDES Annual Report, October 2010

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6.D Employee Training As described in the stormwater management plan, all new employees receive information as part of their new employee orientation regarding stormwater pollution prevention and good housekeeping measures. The employees receive an overview of the department and take with them a handout with additional information and resources for continued learning about Best Management Practices and good housekeeping procedures. The Street Maintenance Division has weekly staff safety meetings in which they discuss a variety of topics including good housekeeping practices and pollution prevention practices. In PY2, the Town contracted with APEX to conduct stormwater management pond inspection training for Public Works, Parks and Recreation and Plan Review staff. During the course of the training, staff members visited active dry and wet ponds as well as outfalls in town and were given additional information on inspection criteria. APEX also assisted with updating pond inspection forms and protocol.

Staff members receiving training on-site at various pond locations in town

Other Departments/Divisions within the Town who have their own SWPPP also engage employees in annual training to ensure the BMPs established in their SWM plans are being adhered to and to educate employees on the importance of being vigilant when in the field and reporting potential suspect illicit discharges and responding quickly to such situations.

6.E Implement Industrial Stormwater Pollution Prevention Plans In June 2009, the Town of Leesburg contracted with AMEC to provide oversight and development of the Water Pollution Control Facility and Central Maintenance Facility Industrial Permit renewals. AMEC provided on-site staff as well as office personnel to review and develop plans for the two facilities. The Leesburg Airport also contracted with AMEC to update and renew the Industrial Permit for their location. Each individual facility has implemented their own specific program and continues to implement put their plans into action.

6.F Standard Operating Procedures The Town continues to annually review the Standard Operating Procedures plan for relevance and validates the processes and information provided in this guide. At this time there have been no changes to the policy since the last submission to DCR.