11_2_2022_-_PAFB_NPDES_MS4_(FLR04E074)_FDEP_YR_2_Audit_Report_-_Feb_2021_0002.pdf

FLORIDA DEPARTMENT OF

Environmental Protection

Bob Martinez Center

2600 Blair Stone Road Tallahassee, FL 32399-2400

Ron DeSantis Governor

Jeanette Nuñez

Lt. Governor

Noah Valenstein Secretary

April 12, 2021

Patrick Giniewski Chief, Installation Management Patrick Air Force Base 45 CES/CEI, 1224 Jupiter St Patrick AFB, FL 32925

Subject: Patrick Air Force Base Municipal Separate Storm Sewer System (MS4) NPDES Permit ID Number: FLR04E074 Cycle 4 Year 2 Audit Report

Dear Patrick Giniewski:

An audit of the Patrick Air Force Base Phase II MS4 Stormwater Management Program (SWMP) was conducted by the Florida Department of Environmental Protection (Department) on February 19, 2021 under the State’s federally approved National Pollutant Discharge Elimination System (NPDES) stormwater program.

Based on the findings in the audit, the Department has determined that Patrick Air Force Base has satisfied SWMP elements as required by the Generic Permit for Discharge of Stormwater from Phase II Municipal Separate Storm Sewer Systems (MS4) (Rule 62-621.300(7)(a), F.A.C.) and as specified in your approved Notice of Intent (NOI) for coverage under the generic permit.

If you have any questions, please contact Jason Maron at 850-245-7568, Jason.Maron@floridadep.gov or Borja Crane-Amores at 850-245-7520, Borja.CraneAmores@floridadep.gov.

Sincerely, Jason D. Maron Phase II MS4 Coordinator NPDES Stormwater Program

Attachments: Patrick Air Force Base Cycle 4 Year 2 Audit Report mailto:Jason.Maron@floridadep.gov mailto:Borja.CraneAmores@floridadep.gov

Phase II Municipal Separate Storm Sewer System (MS4) NPDES Stormwater Audit Report

I. BACKGROUND INFORMATION

MS4 Permittee: Patrick Air Force Base Permit Number: FLR04E074 Audit Year: Year 2 Reporting Period: August 22, 2019 through August 21, 2020 Audit Date/Time: February 19, 2021 @ 8:00 am

Inspector(s):

Name Title Email / Phone:

Jason Maron Phase II MS4 Coordinator Jason.Maron@floridadep.gov

(850) 245 - 7568 Hector Rivera Phase II MS4 Coordinator Hector.Rivera@floridadep.gov

(850) 245-8667

Permittee Representative(s):

Name Title Email / Phone:

Steven Baker Water Program Manager steven.baker.44@spaceforce.mil

(321) 494-9387 Heather Goslin EMS Coordinator heather.goslin.1@usspacecom.mil

(321) 494-9268

II. SWMP IMPLEMENTATION REVIEW

BMP Department Comments:

Element 1 – Public Education and Outreach

1a-01 The permittee published a stormwater related article titled “How Can You Prevent Stormwater Pollution” in “Shark Bites” - an on-base weekly news e-mail that is distributed. The article included a hotline number and the steps the public can take to reduce pollutants in stormwater runoff.

The requirement of this BMP is being satisfied.

1a-02 The Solid Waste Manager holds a monthly newcomer briefing of EMS staff which includes a slide on illicit discharges. This is presented to any new individuals on the base and is tracked with a newcomer orientation sign-in sheet.

Please ensure this presentation includes information on the impacts of stormwater discharges on water bodies and the steps that the public can take to reduce pollutants in stormwater runoff, not only illicit discharges.

The requirement of this BMP is being satisfied.

mailto:Jason.Maron@floridadep.gov mailto:Hector.Rivera@floridadep.gov mailto:steven.baker.44@spaceforce.mil mailto:heather.goslin.1@usspacecom.mil

Patrick Air Force Base Audit Report

Element 2 – Public Involvement/Participation 2a-01 The SWPPT includes representatives from each organization on base who review stormwater requirements of the SWMP. The representatives are expected to educate those from their respective organization that did not attend. During this training, general stormwater concerns and awareness are discussed, and MSGP sector BMPs are reviewed when necessary. Attendance is tracked through memorandums and sign-in sheets. Four meetings took place during the reporting period.

The requirement of this BMP is being satisfied.

2a-02 There was no community clean up event due to COVID-19. The base has intentions of initiating this BMP as soon as COVID-19 restrictions have lifted, as the base still cannot have gatherings of more than 10 individuals.

Events are advertised in “Shark Bites” (weekly newsletter) and are included on the website. The permittee usually hosts clean up events on the beach. When preparing for hurricanes or large storms, the base inspects and cleans trash from parking lots as well.

2a-03 All brochures listed in BMP 3d-01 list both the phone number and email of the flight chief. No comments were received during the reporting period.

The requirement of this BMP is being satisfied.

Element 3 – Illicit Discharge Detection and Elimination 3a-01 The permittee maintains 31 outfalls to waters of the State specifically from the MS4.

They have also mapped MSGP outfalls using ArcGIS. All outfalls discharge to the Banana River Lagoon.

The requirement of this BMP is being satisfied.

3a-02 The Permittee maintains a map in ArcGIS identifying the inlets, manholes, open drainage, gravity lines, culverts, and “storage reservoirs” (i.e. stormwater ponds). This map is maintained by the permittee’s ArcGIS department.

The requirement of this BMP is being satisfied.

3b-01 The following was provided to convey the base has met the requirements of Element 3b:

Air Force Manual (AFMAN) 32-1067 Water and Fuel Systems; all Air Force guidance documents begin with the statement “Compliance with this publication is mandatory.”

2.9.3. Operate and maintain drinking water, wastewater, stormwater, natural gas, and liquid fuel systems, using the AF Civil Engineer (AFCE) Operations Flight Playbooks as guides.

2.9.7. Ensure all systems have required regulatory permits and sufficient resources to operate in compliance with applicable federal, state, and local regulations and standards.

2.9.17. Operate and manage other discharges to waters of the U.S. in accordance with NPDES requirements including municipal separate storm sewer system permits, industrial multi-sector general stormwater permits, stormwater construction general permits, installation specific stormwater permits and any other applicable water discharge permits.

The CE Operations Flight Playbook states:

To prevent harmful pollutants from being washed or dumped into an MS4, operators must obtain a National Pollutant Discharge Elimination System (NPDES) permit and develop a Storm Water Management Program (SWMP). Each regulated MS4 is required to develop and implement a SWMP to reduce the contamination of stormwater runoff and prohibit illicit discharges.

The 45 SW SWMP Illicit Discharge Detection SOP:

2.3.1 Illicit Discharge Detection SOP:

All non-stormwater discharges are strictly prohibited on PAFB property. The following SOP is used to detect and address illicit discharges.

Step 1: Identify problem areas – Illicit discharges will be identified through periodic inspections by MSGP industrial users, public complaints/comments and outfall visual screening during dry weather.

Step 2: Determine the source – Problem areas or discharges will be traced and investigated to identify the potential source.

Step 3: Remove/correct illicit connections – The responsible party of an illicit discharge will be notified and directed to correct the problem immediately. Noncompliance will be dealt with on an escalating scale.

Step 4: Document actions taken – All actions taken under this Plan will be documented, including the location of identified illicit discharge, source of the discharge and corrective actions taken, as applicable.

The 45 SW Environmental Office may employ any combination of the following actions for noncompliance and may escalate when necessary to address persistent or repeat non-compliance, or incidents of major environmental harm.

First offense - Additional education is provided on the proper disposal, prohibition of illicit discharges and the importance of protecting the stormwater system. The immediate supervisor also is informed to initiate appropriate corrective action which may include, but is not limited to, additional retraining or reassignment.

Second offense – Unit commander is notified the actions of his/her unit are in noncompliance and corrective action is required.

The requirement of this BMP is being satisfied.

3c-01 There were no illicit discharges identified during the inspections of the 31 outfalls. The permittee has a log identifying the location of the outfall, date of inspection, and if any color, odor, clarity, floating solids, settled solids, suspended solids, foam, or oil sheen is observed.

The requirement of this BMP is being satisfied.

3c-02 The permittee’s formal SWMP includes a standard operating procedure to detect and address illicit discharges as well as how to locate problem areas, determine the source, remove/correct illicit connections, and document actions taken.

There were 73 MSGP inspections conducted during the reporting period, and 38 additional inspections for ERPs. One inspection takes place for each permitted facility annually.

The permittee uses a checklist for the inspections identifying BMPs for equipment material storage, waste management, spill prevention and clean up, employee training, industrial processes, authorized non-stormwater discharges, and illicit discharges.

The requirement of this BMP is being satisfied.

3d-01 The permittee distributes brochures during the newcomer orientation as seen in BMP 1a-

02. The base had 31 employees, 15 businesses, and 273 base personnel, a total of 319, individuals received brochures. These brochures include: Don’t Let Your Pet Pollute, Illicit Discharge Detection and Elimination, EMS Handout, Water Conservation Neighborhood Guide to Stormwater Systems, and Pollution Prevention.

The permittee also had an illicit discharge detection and elimination presentation at PPT meetings. Please consider including this in your permit renewal for Cycle 5.

The requirement of this BMP is being satisfied.

Element 4 –Construction Site Runoff 4a-01 The following was provided to convey the base has met the requirements of Element 4a.

The statutory authority of Contracting Officers in the Code of Federal Regulations (CFR) states:

48 CFR 1.602-1 Authority of Contracting Officers

(a) Contracting officers have authority to enter into, administer, or terminate contracts and make related determinations and findings. Contracting officers may bind the Government only to the extent of the authority delegated to them. Contracting officers shall receive from the appointing authority (see 1.603-1) clear instructions in writing regarding the limits of their authority. Information on the limits of the contracting officers' authority shall be readily available to the public and agency personnel.

(b) No contract shall be entered into unless the contracting officer ensures that all requirements of law, executive orders, regulations, and all other applicable procedures, including clearances and approvals, have been met.

48 CFR 1.602-2 Responsibilities

Contracting officers are responsible for ensuring performance of all necessary actions for effective contracting, ensuring compliance with the terms of the contract, and safeguarding the interests of the United States in its contractual relationships

The Federal Acquisition Regulations (FAR) 52.212-4 (attached) states:

The Contracting Officer (CO) has the authority (granted by their warrant) to direct a contractor to provide all documents required as stated within the contract. If the contractor continues to be non-compliant (putting the contract at risk) then the CO has the authority to terminate contract. The authority the CO would use would be 52.212-4 Contract Terms and Conditions-Commercial Items.

52.212-4(m) Termination for cause.

The Government may terminate this contract, or any part hereof, for cause in the event of any default by the Contractor, or if the Contractor fails to comply with any contract terms and conditions, or fails to provide the Government, upon request, with adequate assurances of future performance. In the event of termination for cause, the Government shall not be liable to the Contractor for any amount for supplies or services not accepted, and the Contractor shall be liable to the Government for any and all rights and remedies provided by law. If it is determined that the Government improperly terminated this contract for default, such termination shall be deemed a termination for convenience.

Additionally, as an example below are paragraphs from Master Specifications of an existing contract:

1.25 COMPLIANCE WITH POST/BASE REGULATIONS

a. The Site of the work is on a military reservation and all rules and regulations issued by the Commanding Officer covering general safety, security, sanitary requirements, pollution control and traffic regulations, shall be observed by the Contractor. Information regarding these requirements may be obtained by contacting the Contracting Officer, who will provide such information or assist in obtaining same from appropriate authorities.

1.10 NOTIFICATION OF NONCOMPLIANCE

The Contracting Officer will notify the Contractor of any detected noncompliance with the requirements of this specification. Take immediate corrective action after receipt of such notice.

3.11 NOTIFICATION OF NONCOMPLIANCE

The Contracting Officer will notify the Contractor of any detected non-compliance with the foregoing (quality control) requirements. The Contractor shall take immediate corrective action after receipt of such notice. Such notice, when delivered to the Contractor at the Work Site, shall be deemed sufficient for the purpose of notification. If the Contractor fails or refuses to comply promptly, the Contracting Officer may issue an order stopping all or part of the work until satisfactory corrective action has been taken.

No part of the time lost due to such stop orders shall be made the subject of claim for extension of time or for excess costs or damages by the Contractor.

The requirement of this BMP is being satisfied.

4b-01 The permittee has a document titled “Final Design Submittal Specifications” required to be followed by contractors. This is included with the contract and requires erosion and sediment controls. The base also has a “Temporary Stormwater Pollution Control” document identifying BMPs to be used on site.

The permittee tracks the number of active sites through site that have submitted a Construction Generic Permit design review list.

The requirement of this BMP is being satisfied.

4c-01 The permittee has “Construction Waste Management and Disposal” language in contracts requiring control of waste on construction sites. Active sites are documented in a list.

The requirement of this BMP is being satisfied.

4d-01 The permittee’s Water Program Manager receives the site plans and reviews design, permit application, and erosion control plan. Site plans are reviewed per requirements and regulations in the contract. After the first design review, if the CGP/ERP is not there, the contractor is notified. This is a requirement of the site plan submittal. After the plan is reviewed, the EMS Department summarizes all comments and these comments are sent to the contractor.

Design reviews are tracked by the Contracting Officer and Project Manager. The permittee provided a sheet identifying all active projects during the reporting period.

The requirement of this BMP is being satisfied.

4e-01 All brochures listed in BMP 3d-01 list both the phone number and email of the flight chief to contact if an issue is observed.

The requirement of this BMP is being satisfied.

4f-01 The permittee conducts an inspections three times during the project: prior, during, and post. The contractor is required to do inspections per the CGP, and the base ensures they do inspections as well as inspect it themselves. The Water Program Manager uses a checklist to conduct inspections of the site and the contractor of the site is required to be there at the time of inspection. If an issue is found by the Water Program Manager, the inspection will be forwarded to the contracting officer to tell the site to correct the deficiency.

The requirement of this BMP is being satisfied.

Element 5 – Post Construction Stormwater Management 5a-c Patrick Air Force Base relies on the St. Johns River Water Management District and the

Florida Department of Environmental Protection for implementation of post-construction stormwater management requirements.

The requirement of this BMP is being satisfied.

Element 6 – Pollution Prevention/ Good Housekeeping for Municipal Operations 6a-01 The permittee’s Heavy Equipment Shop conducts street sweeping at least twice a year.

Receipt records show the amount of debris removed. The permittee sweeps eight miles of road every day which are tracked with e-mails from the Heavy Equipment Shop.

The requirement of this BMP is being satisfied.

6a-02 There is a contracting company that conducts inlet/catch basin maintenance. They identify the amount of debris removed and inlets inspected using a checklist. That same checklist can also be used to track nine other maintenance operations when necessary.

The base quantifies the amount of liquid removed, amount of debris removed, and maintains receipts for these values.

The requirement of this BMP is being satisfied.

6b-01 The Stormwater Awareness training is available on the PAFB website and all personnel in the area that can pollute are required to conduct training on an annual basis. The shops or divisions are required to submit record of who took this stormwater training and the date. They also have certificates of training if people have taken it individually from the website. The presentation given was viewed during the audit and had information on stormwater basics, runoff, sources of pollution, federal laws, NPDES, problems and causes, environmental resource permits in Florida, non-point source, and BMPs.

The requirement of this BMP is being satisfied.

6b-02 A consultant of the Hazardous Waste Program Manager provides the number of employees trained and performs inspections to ensure the shop has conducted a hazardous waste training. Quarterly site inspections and the training is validated.

The Water Program Manager has a checklist when conducting inspections which includes a check to ensure inspection by the Hazardous Waste Program Manager were completed.

The requirement of this BMP is being satisfied.

III. SITE VISITS

☐ Satisfactory ☐ Unsatisfactory ☒ Not Applicable