JB_CHS-AB_Bi-Annual_MS4_Report.pdf

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JB CHS AB Bi-Annual MS4 Report

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I. Special Conditions Applicable to Stormwater Discharges to Sensitive Waters

A. General (3.1)

1. Has an assessment been conducted to determine if the MS4 discharges to sensitive waters as described in the Permit Part 3? ☐ Yes ☐ No (what is the target date of completion of the assessment?)

2. Does the SWMP specifically address these sensitive waters through BMP, system design, etc.? ☐ Yes ☐ No

3. Does the MS4 discharge to waters classified as Outstanding Resource, Trout, or Shellfish Harvesting? If so, list the waters (3.5): ☐ No ☐ Yes

B. TMDL Monitoring and Assessment Plan (3.2)

1. Does the MS4 discharge to receiving waters within a TMDL watershed? If yes, list the water body and the pollutant(s) of concern. ☐ No ☐Yes Ashley River – dissolved oxygen

2. Which of the TMDL pollutant(s) of concern listed above have the potential to occur within the MS4? JB CHS is not a point source but rather has non-point source effects. This TMDL does not address non-point sources since there is a natural phenomenon effect on dissolved oxygen.

3. Report the current stage of development of a monitoring and assessment plan. Mark one or more that most accurately reflects the current status of the program as a whole:

☐ Not started ☐ Research/Development ☐ Implementation

4. Has the plan been submitted to the Department?

☐ Yes ☐ No, target date for submission: DO monitoring is not required

5. Has monitoring been conducted for the pollutant(s) of concern in the past reporting year?

☐ Yes (summary of data attached) ☐ No, target date to begin monitoring: NA

6. Are there any updates to the plan for this reporting year?

☐ No ☐ Yes (updates attached)

7. Provide a brief description of the progress made on the plan in this reporting year and evaluate its effectiveness.

C. Discharges to Impaired Water Bodies (3.4)

1. Does the MS4 discharge to receiving waters on the 303(d) list of impaired waters? If yes, list the water body and the pollutant(s) of concern. ☐ No ☐Yes Ashley River –fecal coliform & turbidity; Goose and Turkey Creek – fecal coliform

2. Which of the 303(d) pollutant(s) of concern listed above have the potential to occur within the MS4?

turbidity

Plan not prepared because contributing contaminant is not monitored.

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II. Storm Water Management Program

A. Ordinance Information (4.1) (Insert your website address if the ordinance is posted online. If your ordinance is not posted online, please submit a hard copy with this report.)

Website: http://static.epublishing.af.mil/production/1/af_a4_7/publication/afi32-7041/afi32-7041.pdf Hard copy attached: ☐

B. Storm Water Management Plan (SWMP) (4.1, 4.5) (Answer the questions below about the SWMP for the current reporting year.)

1. Have there been any changes to the area covered by the MS4? If yes, is this reflected by updates to the

SWMP?

☐ No ☐ Yes (explain):

2. Are there any proposed changes to the goals or BMP (best management practices) in the SWMP?

☐ No ☐ Yes (explain):

3. Do you have adequate resources to implement your SWMP?

☐ Yes ☐ No (explain):

4. Provide information below about staffing levels for each Minimum Control Measure (MCM). This information should be presented as the amount of individuals performing duties directly related to each MCM and the estimated percentage of their time spent doing so. If you share responsibility for the MCM with another entity, indicate that in the corresponding spaces.

• MCM 1: 2/10%

• MCM 2: 2/15%

• MCM 3: 8/10%

• MCM 4: 3/30%

• MCM 5: 1/10%

• MCM 6: 5/25%

5. Has training been provided to staff as required by the permit in the last reporting year?

☐ Yes (fill in the table below) ☐ No (explain, and provide implementation dates):

Date Topics Covered 2/19/2014 Annual refresher training for inspectors/approvers.

8/21/2014 Stormwater field inspections.

11/23/2015 Site inspections for run-off, drainage basins, residue/litter, material storage, etc.

1/26/2016 Construction site inspections.

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III. Minimum Control Measures (MCM)

A. Sharing Responsibility (4.4)

1. Is responsibility shared for any minimum measures through an agreement with another entity?

☐ No ☐ Yes (name the entity in the chart below)

MCM 1

MCM 2

MCM 3

MCM 4

MCM 5

MCM 6

If you have indicated that you are sharing responsibility above in any MCM, answer the questions below:

2. Have you submitted notice to the Department that you are relying on another entity?

☐ Yes No (submit a copy of any agreements that have not previously been sent to the Department)

3. If applicable, provide the date of submission of the agreement(s) to the Department:

4. Are all control measures as stringent as the permit requires?

Yes ☐No (if no, provide an explanation)

5. Did the other entity agree in writing to implement the measure on your behalf?

☐ Yes ☐No (if no, provide an explanation)

6. Did the other entity implement the measure and agree to report on your behalf?

☐ Yes ☐No (if no, provide an explanation)

7. Is the agreement maintained as part of the SWMP?

☐ Yes ☐No (if no, provide an explanation)

8. Have you dissolved any agreements with entities this reporting year?

☐ No ☐Yes (if yes, who?)

B. Minimum Control Measure 1: Public Education and Outreach on Storm Water Impacts (4.2.1, 5.3)

1. Use the table below to summarize outreach strategies, goals, and progress for the current reporting year. In the “activities conducted and planned” section, focus on activities that were conducted in the last reporting year and those that are planned for the upcoming reporting year, providing implementation dates. Add rows where needed and attach additional sheets if necessary.

Pollutant of Concern

Outreach Strategy

(include target audiences)

Measurable Goal(s) Progress on Goal(s)

Activities Conducted and Planned

(specific implementation dates)

Number of People

Reached

Turbidity, pet waste, petroleum/ oil/lubricants, pesticides/ herbicides/fertilizer

Computer based awareness training annually for AF and Government contractors

Document compliance of completion of required annual training

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Training certificates are computer generated and tracked through the environmental office (6/1/2014)

1,400

Same as above Resident agreement packet includes rules to manage pet waste, litter prevention, and vehicle parking

Decrease water quality violation notices issued annually to residents by the Housing Office

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Residences are visually inspected bi-weekly by trained property/lawn-care contractors that report to the Housing Office.

(6/1/2014)

Same as above Publish relevant water quality related entry in base newspaper, “Patriot Dispatch” and other printed material

One new entry published annually

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Copy of article and date published is maintained in the Environmental Office.(6/1/2014)

Base population

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation ☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

C. Control Measure Evaluation (5.3)

1. Evaluate the success of this MCM. Refer to goals implemented and achieved, and adherence to the implementation schedule: JB CHS AF personnel, private contractors, and civilians participating in public outreach and education programs have exhibited active involvement in the quality of stormwater management.

The program’s targeted audience has very good participation facilitating compliance success.

2. Provide an evaluation of where the program needs improvement and explain any actions that will be taken to achieve objectives: The program manager provides regular interaction with subject audiences. Hands-on interaction with Base personnel will continue to ensure a compliant stormwater program. No improvements are required at this time.

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D. Minimum Control Measure 2: Public Involvement/Participation (4.2.2, 5.3)

1. How can the public find information about the SWMP? The Federal Facility Base personnel have access to the Environmental Management System (EMS) through the computer based program designed for environmental policy statements. The EMS program contains continually improving operating procedures for the Base personnel roles and responsibilities.

2. Use the table below to summarize public involvement opportunities, goals, and progress for the current reporting year. In the “activities conducted and planned” section, focus on activities that were conducted in the last reporting year and those that are planned for the upcoming reporting year, providing implementation dates.

Add rows where needed and attach additional sheets if necessary.

Public Involvement

Opportunity Measurable Goal(s) Progress on

Goal(s) Activities Conducted and Planned

(specific implementation dates) Number of

Participants 24-hour phone lines for Base Service Desk

Analyze and improve response time to potential water quality impairment violations

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Maintain 24-hour Response Number for water quality related events including septic failures and accidental spills. (6/1/2014)

Base population

Organize Volunteer Monitor and Clean up Opportunities

Maintain sufficient number of volunteers to adequately man semi-annual clean-up and monitoring activities

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Volunteer logs will be reviewed and maintained in the Environmental Office.

(6/1/2014)

Base population

Utilize Stakeholders Meeting to solicit volunteers for various water quality related events

Bi-monthly briefing at EMS Cross Functional Team meeting on the progress of volunteer needs and activities.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Volunteer meeting minutes will be reviewed and maintained in the Environmental Office.

(6/1/2014)

Base population

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation ☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

E. Control Measure Evaluation (5.3)

1. Evaluate the success of this MCM. Refer to goals implemented and achieved, and adherence to the implementation schedule: JB CHS civilians, active/reserve duty AF personnel and contractors all contribute to the success of the public involvement program. The active voluntary JB CHS personnel roles with street sweeps, native plant transplanting, and community/school activities (Habitat for Humanity, Earth Day, and education contest involvement) has greatly improved since the programs were implemented June 1, 2014.

2. Provide an evaluation of where the program needs improvement and explain any actions that will be taken to achieve objectives: The public participation program has times with fluctuating involvement. The changes are not just seasonally influenced, but also affected by the relocation of AF active/reserve duty personnel. The civilian and long term contractors contribute the most to the volunteer program. Outreach and education programs continue to promote personnel involvement in compliant stormwater management.

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F. Minimum Control Measure 3: Illicit Discharge Detection and Elimination (IDDE) (4.2.3, 5.3)

1. How can the public notify the MS4 of suspected illicit discharges? Pamphlets and flyers are distributed educating JB CHS personnel on avenues for illicit discharge notifications either through service desk operated 24/7 or by report (phone or email) to the Environmental Office directly.

2. Complete the list below for the last reporting year:

• Total number of suspected illicit discharges:

• Total number of illicit discharges found:

• Number of illicit discharges with enforcement escalation (action taken beyond written warning):

• Total number of illicit discharges eliminated:

3. Use the table below to summarize priority areas (and associated rationale for selection) for screening. If these areas have changed since the last reporting year, provide a brief explanation. Add rows where needed and attach additional sheets if necessary.

Priority Areas Rationale for Selection Changed within last reporting year? (If so, provide an explanation.)

Material storage areas These area could contribute greatest to illicit discharges No Wetlands Wetlands can receive run-off from activities on the Base No JB CHS infrastructure Sanitary sewer systems are old No

4. Use the table below to summarize IDDE action items, goals, and progress for the current reporting year. In the “activities conducted and planned” section, focus on activities that were conducted in the last reporting year and those that are planned for the upcoming reporting year, providing implementation dates. Add rows where needed and attach additional sheets if necessary.

IDDE Action Item Measurable Goal(s) Progress on Goal(s)

Activities Conducted and Planned (specific implementation dates)

Prohibit Discharges Increased awareness of regulations; Attain 100% of base personnel to pass computer based quiz during annual refresher stormwater training.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Quiz questions during annual refresher training address illicit discharges. Records maintained in Environmental Office. Mandate adherence to the Housing community Handbook which defines prohibitions of illicit discharges and enforcement actions if violated. (6/1/2014)

JB CHS Storm Sewer System Map

Verify priority areas on map annually and assess for BMP effectiveness; update discharge reports to identify illicit activity trends.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Maintain current Storm Sewer Maps. Analyze for effectiveness of BMPs and for new "hot spots”.

Maps are maintained in the Environmental Office.

(6/1/2014)

Dry Weather Field Screening and Inspections

Inspection of 100% of outfalls annually.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Utilize Volunteer groups for locating and visually inspecting outfalls during dry weather. Conduct follow-up investigation for areas with no improvement. (6/1/2014)

Educational Flyers, brochures, bookmarks, crossword puzzles, etc.

Document and track 100% of calls/reports per year as a result of increased awareness.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Promote awareness of illicit discharges and the impacts on water quality through a mix of media styles to engage individuals from different demographics. (6/1/2014)

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

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G. Control Measure Evaluation (5.3)

1. Evaluate the success of this MCM. Refer to goals implemented and achieved, and adherence to the implementation schedule: JB CHS has in place personnel and procedures for inspection and/or screening for non-stormwater discharges. The MS4 stormwater map system is up-to-date and has “hot spot” areas identified for suspect illicit discharges. Training for JB CHS personnel is performed to educate employees in stormwater compliance. These requirements are implemented.

2. Provide an evaluation of where the program needs improvement and explain any actions that will be taken to achieve objectives: The program is implemented, but outreach to all employees is not 100% due to frequent military re-deployment. New employees are recognized at the bi-monthly Cross Function Team meetings. The Environmental Compliance MS4 operator visits shops routinely to review procedures and personnel status.

H. Minimum Control Measure 4: Construction Site Storm Water Runoff Control (4.2.4, 5.3)

1. How can the public notify the MS4 of possible noncompliance at construction sites? Complaints regarding non-compliance discharges are received at the Service Desk and/or the Environmental Office by postal mail, e-mail or phone call.

2. How does the MS4 communicate with construction operators to ensure understanding of requirements and improvements that may be needed? MS4 Environmental Program Manager directly communicates with construction operators and/or the contract officer. There are routine weekly progress meetings and in addition, meetings as specific issues arise.

3. Has an enforcement response plan (ERP) been developed and utilized?

☐ Yes ☐ No (explain):

4. Complete the list below for the last reporting year:

• Number of new construction sites: 7

• Total number of active construction sites: 11

• Total number of inspections performed: 250

• Number of sites with unsatisfactory/noncompliant inspection results: 0

• Number of sites with enforcement escalation (action taken beyond written warning): 0

• Number of sites inspected past the deadline specified in the permit: 0

5. Use the table below to summarize construction site action items, goals, and progress for the current reporting year. In the “activities conducted and planned” section, focus on activities that were conducted in the last reporting year and those that are planned for the upcoming reporting year, providing implementation dates. Add rows where needed and attach additional sheets if necessary.

Construction Site Action Item

Measurable Goal(s) Progress on Goal(s)

Activities Conducted and Planned (specific implementation dates)

Requirement from Base Commander for construction managers to comply with implementation of proper erosion and sediment controls.

Receive fewer than 10 water quality non-compliance findings during rain events, annually.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Joint Base Charleston Environmental Specifications (Section 01501-Page 6, Para 1.11). (6/1/2014)

Site Plan Reviews 100% of Construction site plan/NOIs reviewed by 628

CES/CEIE

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Correspondence with contractor until acceptable plan is met. (6/1/2014)

Site Inspections 628 CES/CEIE, CEMP and construction site contractors to complete weekly/monthly inspections of all construction sites with ground disturbing activities

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Inspection reports are completed by CE and contractors. Copies of reports are reviewed and maintained in the Environmental Office. (6/1/2014)

Construction Site Waste Management Plans

100% of plans/NOIs reviewed by 628 CES/CEIE

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Correspondence with contractor until acceptable plan is met. (6/1/2014)

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

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I. Control Measure Evaluation (5.3)

1. Evaluate the success of this MCM. Refer to goals implemented and achieved, and adherence to the implementation schedule: The JB CHS SMS4 site run-off control program is very successful. All land disturbance Projects on Base implement erosion and sediment control BMP’s. JB CHS has developed a NOI review program for all Projects ensuring there are sanctions in-place for non-compliance. The implementation schedule is on-track.

2. Provide an evaluation of where the program needs improvement and explain any actions that will be taken to achieve objectives: The program regulatory mechanisms used by JB CHS for erosion prevention and sediment controls for construction projects are well documented and function very well. Gaps in reporting records are addressed when discovered.

J. Minimum Control Measure 5: Post-Construction Storm Water Management (4.2.5, 5.3)

1. Complete the list below for the last reporting year:

• Number of newly completed construction sites: 5

• Number of inspections performed within 30 days of construction completion: 3

• Total number of inspections performed: 15

• Number of sites with unsatisfactory/noncompliant inspection results: 0

• Number of sites with enforcement escalation (action taken beyond written warning): 0

2. Use the table below to summarize post-construction action items, goals, and progress for the current reporting year. In the “activities conducted and planned” section, focus on activities that were conducted in the last reporting year and those that are planned for the upcoming reporting year, providing implementation dates. Add rows where needed and attach additional sheets if necessary.

Post-Construction Action Item

Measurable Goal(s) Progress on Goal(s)

Activities Conducted and Planned (specific implementation dates)

Base Construction Compliance Policy

628 CES/CEIE perform one oversight compliance inspection per year per construction site.

Ensure Compliance with Environmental Specification Section 01501

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Paper trail is generated with NOI and NOT notification system for post construction stormwater management.

Adhere to Project Review Process and the post construction maintenance plan

Track number of plans reviewed by 628 CES/CEIE

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

100% of all Construction site plans reviewed by 628 CES/CEIE include post-construction BMPs.

Annual Inspections Inspect previously closed construction projects for maintenance concerns and documenting required corrective actions.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Inspection reports are completed by 628 CES/CEIE and contractors. Copies of reports are reviewed and maintained in the Environmental Office.

Post-Construction Inspection Records

Inspect previously closed construction projects for maintenance concerns documenting corrective actions.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Inspection reports are completed by 628 CES/CEIE and contractors. Copies of reports are reviewed and maintained in the Environmental Office.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

K. Control Measure Evaluation (5.3)

1. Evaluate the success of this MCM. Refer to goals implemented and achieved, and adherence to the implementation schedule: JB CHS stormwater compliance manager performs annual routine inspections base wide including all BMPs installed. Inspection reports are maintained in the Environmental Office.

2. Provide an evaluation of where the program needs improvement and explain any actions that will be taken to achieve objectives: No program improvements are needed.

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L. Minimum Control Measure 6: Pollution Prevention/Good Housekeeping for Municipal Operations (4.2.6, 5.3)

1. Has a comprehensive assessment of the pollutant discharge potential for all municipally owned facilities been conducted? If not, indicate a status and planned completion date in the chart below.

☐ Yes ☐ No ☐ In Progress (explain):

2. Have yearly comprehensive inspections been conducted at high priority facilities? If not, indicate a status and planned completion date in the chart below.

☐ Yes ☐ No ☐ In Progress (explain):

3. Has training been conducted for employees? If not, indicate a status and planned completion date in the chart below.

☐ Yes ☐ No ☐ In Progress (explain):

4. Use the table below to summarize municipal facility pollution prevention action items, goals, and progress for the current reporting year. In the “activities conducted and planned” section, focus on activities that were conducted in the last reporting year and those that are planned for the upcoming reporting year, providing implementation dates. Ensure that the maintenance and inspection of MS4 catch basins and structural storm water controls are addressed in the chart. Add rows where needed and attach additional sheets if necessary.

Pollution Prevention Action Item

Measurable Goal(s) Progress on Goal(s)

Activities Conducted and Planned (specific implementation dates)

Annual Base Staff Training Increased awareness of regulations; Attain 100% of base personnel to pass quiz during annual refresher training.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Annual Staff and contractors training conducted and tracked using the eTEST computer based training website.

Maintain Municipal Facility and Stormwater Control Inventory

Maintain compliance with Spill Prevention, Control, and Countermeasures (SPCC) plans;

Collaborate with SPCC compliance team to ensure cross-program consistency.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Maintain material inventory of facilities not covered under another NPDES permit (i.e., landfill, golf course) Covered under SPCC plan requirements

Housing MS4 Instruction Issue fewer than 10 water quality related violation notices, annually to residents by the Housing Office with oversight by the WQ PM.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Residences are visually inspected daily, weekly and monthly by personnel from Housing Maintenance Office

Street Sweeping for flood management

Review street sweeping contractor agreement annually to ensure that maintenance schedules are in line with base water quality goals.

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

Maintain waste disposal and street sweeping program. Contract is managed through 628

CES/CEO

☐ In Planning ☐ Ongoing ☐ Completed ☐ Evaluation

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M. Control Measure Evaluation (5.3)

1. Evaluate the success of this MCM. Refer to goals implemented and achieved, and adherence to the implementation schedule: Implementation of the operation and maintenance program with the ultimate goal of preventing or reducing pollutant runoff and good housekeeping has been achieved. Storm sewer ditches and other areas are inspected (operational checks) during heavy rainfall events. Recycling drop-off points are inspected and debris removed. Lawn and garden debris is picked up weekly by the grounds maintenance contractor in the residential area. Street sweeping is conducted as needed and debris is segregated for disposal.

2. Provide an evaluation of where the program needs improvement and explain any actions that will be taken to achieve objectives: There are no changes required for pollution prevention and good house keeping.

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