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Storm Water Pollution Prevention Plan May 2011
Joint Base Charleston - Air
ADVENT Project 810006.0010
STORM WATER POLLUTION PREVENTION PLAN
Joint Base Charleston - Air May 2011
Points of Contact AFCEE Project Manager
Antonio Lodico
3300 Sidney Brooks Brooks-City Base, TX 78235-5112
(210) 395-8634 antonio.lodico@us.af.mil JB CHS - Air Storm Water Manager
Charles Wanamaker
100 W Stewart Ave Joint Base Charleston, SC 29404-4827
(843) 963-2705 charles.wannamaker@us.af.mil ADVENT Project Manager
Eric S. Miller, P.E., PMP esmiller@adventenv.com ADVENT Project Principal Jeffrey C. Smoak, P.E.
jcsmoak@adventenv.com Prepared by:
ADVENT Environmental, Inc.
498 Wando Park Blvd. Suite 500
Mount Pleasant, South Carolina 29464
843.388.1851 phone
843.388-1891 fax
ADVENT Project 810006.0010
TABLE OF CONTENTS
iiiACRONYMS
EXECUTIVE SUMMARY
vi 1.0
INTRODUCTION
1-1 1.1 Purpose 1-1 1.2 Regulations and Compliance 1-2 1.3 Storm Water Pollution Prevention Team 1-3 2.0
FACILITY DESCRIPTION
2-1 2.1 Facility Information 2-1 2.2 Activities at the Facility 2-1 2.3 Storm Water System Overview 2-2 2.4 Site Maps 2-4 2.5 Water Quality-Based Effluent Limitations 2-4 3.0
POTENTIAL POLLUTANT SOURCES
3-1 3.1 Industrial Activity and Associated Pollutants 3-1 3.2 Material Inventory 3-1 3.3 Spills and Leaks 3-5 3.4 Non-Storm Water Discharges 3-5 3.5 Salt Storage and Pavement Deicing 3-6 3.6 Aircraft and Runway Deicing 3-6 4.0
STORM WATER CONTROL MEASURES
4-1 4.1 Basewide Best Mangement Practices 4-2 4.2 BMPs Associated With Industrial Activity 4-6 4.3 Spill Prevention and Response 4-11 4.4 Requirments for Sector S – Air Transportation 4-14 5.0
INSPECTIONS
5-1 5.1 Routine Facility Inspections 5-1 5.2 Quarterly Visual Inspections 5-3 5.3 Comprehensive Site Compliance Evaluation 5-3 6.0
MONITORING REQUIREMENTS
6-1 6.1 Monitoring Requirements 6-1 6.2 Benchmark Monitoring 6-2 6.3 Monitoring Based on Effluent Guidelines 6-3 6.4 Impaired Waters Monitoring 6-3 6.5 Follow-up Actions if Discharge Exceeds Numeric Effluent Limit 6-5 6.6 Monitoring Procedures 6-6 7.0
REPORTING AND RECORDKEEPING
7-1 7.1 Reporting Monitoring Data to SCDHEC 7-1 7.2 Exceedance Report for Numeric Effluent Limits 7-1 7.3 Additional Reporting 7-2 7.4 Recordkeeping 7-3 8.0
SWPPP CERTIFICATION
8-1 9.0
SWPPP MODIFICATION
9-1
LIST OF TABLES
Table 1 Storm Water Pollution Prevention Team
Table 2 Summary of Drainage Areas
Table 3 TMDLs and 303(d) Listed Impaired Waters Impacted by JB CHS - Air Table 4 Summary of Required Sampling and Inspections
Table 5 Sampling Requirements for Benchmark Monitoring Table 6 Summary of Industrial Activity Potential Sources of Pollutants of Concern in
Storm Water
LIST OF FIGURES
Figure 1 Site Location Map Figure 2 Site Drainage Area Map Figure 3 Site Drainage Area Map – North West Quadrant Figure 4 Site Drainage Area Map – North East Quadrant Figure 5 Site Drainage Area Map – South West Quadrant Figure 6 Site Drainage Area Map – South East Quadrant
LIST OF APPENDICES
A Industrial Storm Water General NPDES Permit B Acknowledgement Letter from SCDHEC with Coverage Certification Number C Notice of Intent D Impacted Water Quality Monitoring Stations Report E Exposed Material Inventory
F Spill History
G Non-Storm Water Discharge Inventory
H Analytical Results
I OWS Maintenance Schedule
J Annual Comprehensive Site Compliance Evaluation K Quarterly Visual Inspections L Site Photos
ACRONYMS
AAFES
Army and Air Force Exchange Service
AFB
Air Force Base
AFTO
Air Force Technical Order
APS
437 Mission Support Group, Aerial Port Squadron
AST
Aboveground Storage Tank
ATOC
Air Terminal Operations Center
AW
Airlift Wing
AVGAS
Aviation Gasoline
BMP
Best Management Practice
BOD5
5-Day Biochemical Oxygen Demand
CBT
Computer Based Training
CEANQ
628 Mission Support Group, Civil Engineer Squadron, Asset Management Flight
CEF
628 Mission Support Group, Civil Engineer Squadron, Fire Protection Flight
CEOIH
628 Mission Support Group, Civil Engineer Squadron, Operations Flight, Heat, Vent, and Air Conditioning
CEOFP
628 Mission Support Group, Civil Engineer Squadron, Operations Flight, Electrical Power Production
CEOIE
628 Mission Support Group, Civil Engineer Squadron, Operations Flight, Entomology
CEIOU
628 Mission Support Group, Civil Engineer Squadron, Utilities Systems
CEX
628 Mission Support Group, Civil Engineer Squadron, Readiness and EM Flight
CFR
Code of Federal Regulations
COD
Chemical Oxygen Demand
ERAP
Emergency response action plan
ETC
Engine Test Cell (Boeing)
FRP
Facility Response Plan
HAZMAT
Hazardous Materials
HVAC
Heating, Venting and Air Conditioning
IGP
Industrial Storm Water General NPDES Permit JB CHS - Air Joint Base Charleston - Air
JP-8
Jet Fuel
LGRF
628Mission Support Group, Logistics Readiness Squadron, Fuels Management Flight
LGRV
628 Mission Support Group, Logistics Readiness Squadron, Vehicle Maintenance Flight
LS-2
Low Sulfur Diesel Fuel
MSDS
Material Safety Data Sheets
MUR
Motor Unleaded Regular Gasoline
MXS/AGE
437 Maintenance Group, Maintenance Squadron, Aircraft Ground Equipment Flight
NOI
Notice of Intent
NPDES
National Pollutant Discharge Elimination System
OWS
Oil-Water Separator
POL
Petroleum, Oil, and Lubricants
PPT
Pollution Prevention Team
SCDHEC
South Carolina Department of Health and Environmental Control
SGGB
Bioenvironmental Engineering
SPCC
Spill Prevention, Control, and Countermeasures
SVS
628 Mission Support Group, Services Squadron
SWPPP
Storm Water Pollution Prevention Plan
SWPPT
Storm Water Pollution Prevention Team
TMDL
Total Maximum Daily Load
TSDF
Treatment Storage and Disposal Facility
TSS
Total Suspended Solids
TKN
Total Kjeldahl Nitrogen
USAF
U.S. Air Force
USEPA
U.S. Environmental Protection Agency
UST
Underground Storage Tank
WLA
Wasteload Allocation
EXECUTIVE SUMMARY
The following list provides the major changes for the SWPPP based on changes from the 2005 South Carolina Permit to the new IGP.
· Previously, the base was divided into seven (7) drainage areas. Based upon further review, the base has been divided into twelve (12) drainage areas.
· Sampling requirements have changed for JB CHS - Air.
1. JB CHS - Air is required to conduct Benchmark monitoring (Part 8, Subpart K, Sector K) for Outfall 003 where the Hazardous Waste Storage Yard is located.
2. JB CHS - Air must conduct Impaired Waters Monitoring for Outfalls 001, 002 and 003. Submittal of monitoring data is not required.
3. The storm water monitoring requirements related to the SARA Title III, Section 313 inventories have been removed.
· The SWPPP does not have to be signed and certified by a professional engineer.
· A qualitative quarterly visual assessment of the site’s storm water discharges is required. Corrective action is expected upon finding anything outside of the typical characteristics.
· JB CHS - Air must review SC’s list of approved TMDL annually during each comprehensive site inspection and carry out monitoring and consequent actions.
1.0
INTRODUCTION
1.1 Purpose
Joint Base Charleston - Air (JB CHS - Air) has implemented a Storm Water Pollution Prevention Plan (SWPPP) to minimize the risk of storm water pollution in drainage areas located within the base boundaries. This plan has been prepared to comply with the South Carolina Department of Health and Environmental Control (SCDHEC) General Permit SCR000000 (November 12, 2010) requirements for authorization to discharge storm water associated with industrial activity under the National Pollutant Discharge Elimination System (NPDES) Program. A copy of the permit is included in Appendix A, a copy of the acknowledgement letter from SCDHEC assigning a coverage certification number is included in Appendix B and a copy of the NOI is included in Appendix C.
The goal of the SWPPP is to prevent or reduce pollutants at the source that can be conveyed by storm water discharges. The objectives of the plan are to identify and evaluate sources of storm water pollution and to describe and implement pollution reduction measures. To attain the goal of the SWPPP, a four-step process is employed, focusing on the following objectives:
· Formation of a team of qualified personnel, Storm Water Pollution Prevention Team (SWPPT), that is responsible for preparing or assisting in the implementation of the SWPPP
· Assessment of potential storm water pollution sources by conducting a Comprehensive Site Compliance Evaluation
· Selection and implementation of Best Management Practices (BMPs) and controls
· Periodic evaluation of the SWPPP’s effectiveness
Results of the Comprehensive Site Compliance Evaluation are used to select and implement appropriate BMPs to reduce the quantities of pollutants entering the system. Once in place, BMPs are scheduled for periodic evaluation to measure their effectiveness. The SWPPP is then revised accordingly.
The purpose of this SWPPP is to facilitate the management of activities that may impact water quality and to satisfy the regulatory requirements associated with South Carolina’s DHEC’s NPDES General Permit for Storm Water Discharges Associated with Industrial Activities (IGP), Permit No. SCR000000, effective January 1, 2011. This document will serve as the primary reference for descriptions of current industrial activities that have the potential to impact storm water discharges and for existing and planned storm water management practices.
1.2 Regulations and Compliance Section 402(p) of the Water Quality Act of 1987 requires that operators of facilities which discharge storm water associated with industrial activity to obtain permits under the National Pollutant Discharge Elimination System (NPDES) to reduce pollutant loadings and improve the quality of storm water discharges. In response to these statutes, the U.S. Environmental Protection Agency (USEPA) promulgated final regulations for permit applications associated with storm water discharges from industrial activities on November 16, 1990 (USEPA storm water regulations; 55 CFR 47989, 56 CFR 12097, 56 CFR 56547, 57 CFR 11393, 40 CFR Parts 122 through 124; and additional related regulations promulgated by State and local regulatory agencies; USEPA, 1990, p. 47990).
In the State of South Carolina, the South Carolina Department of Health and Environmental Control (SCDHEC) has been authorized to issue the general permit for these discharges. SCDHEC’s Industrial, Agricultural and Storm Water Permitting Division of the Bureau of Water oversees the permits under the IGP (Permit No. SCR000000).
The IGP requires the industrial discharger to develop and implement a storm water management plan that will either prevent pollution or remove pollutants from storm water before it leaves the facility. This plan is called a SWPPP. The SWPPP identifies a SWPPT, assesses the potential for storm water pollution, identifies BMPs, provides an implementation plan, and defines procedures for annual inspections and evaluations of effectiveness.
1.3 Storm Water Pollution Prevention Team A requirement of the SWPPP is the designation of a SWPPT whose responsibility is to develop, implement, maintain, and revise the pollution prevention plan. The SWPPP will be reviewed annually and amended whenever there is a change in operation, maintenance, or construction likely to result in the discharge of pollutants to storm water. The SWPPT meets quarterly to discuss goals, BMP implementation and timelines, and SWPPP evaluation and revision.
The Base Command will commit the necessary resources to implement the SWPPP and is required to sign legal certifications associated with the SWPPP. The names, titles, and specific duties of each SWPPT member can be found in Table 1.
2.0
FACILITY DESCRIPTION
2.1 Facility Information JB CHS - Air is a 3,772 acre facility located along the southeastern coast of South Carolina approximately 10 miles northwest of the City of Charleston. JB CHS - Air is bordered by Ashley Phosphate Road on the north; Interstate 26 on the east; Interstate 526 (the Mark Clark Expressway) on the south; and Dorchester Road on the west.
The host unit at JB CHS - Air is the 628th Military Airlift Wing (AW). Major units within the Wing include Operations, Maintenance, Medical and Mission Support Group. Their mission is to command assigned airlift and supporting units; provide for the airlift of troops and passengers, military equipment, cargo and aeromedical airlift and to participate in operations involving the airland or airdrop of troops, equipment, and supplies when required. Apart from the heavy airdrop commitment and the humanitarian mission, JB CHS - Air supports U.S. Embassies, supplies humanitarian airlift relief to victims of disasters, and supports contingency operations.
Effective October 1, 2010, The Office of the Secretary of Defense and the Base Realignment and Closure (BRAC) committee consolidated Charleston Air Force Base (AFB) and Naval Weapons Station (NWS) Charleston into a single installation, Joint Base Charleston (JB CHS - Air) under the command of the Air Force. This SWPPP is applicable to the portion of JB CHS - Air formerly known as JB CHS - Air.
2.2 Activities at the Facility The northern and eastern portion of JB CHS - Air is primarily flat and consists of paved areas interspersed with grasslands. The paved areas include taxiways and runways. The flight control tower and other associated buildings are located in this portion of the base. Industrial facilities are found in the central area, which is located adjacent to the flightline area. Facilities of concern include aircraft maintenance areas (hangars), aircraft parking, and a bulk fuel storage area. Topography in this area is primarily level and includes small grassy areas between buildings and roads. The southern and western portions of JB CHS - Air comprise base housing, community services facilities, recreational areas, and the base golf course. There is also a recreational vehicle camping area located in this portion of JB CHS - Air, which is primarily grassy or wooded. Activities at JB CHS - Air fall under the following industrial sectors as defined in Section 8 of the IGP:
| Sector |
| Description |
| Drainage Areas |
| K |
| Hazardous Waste Treatment, Storage or Disposal Facilities. |
| 3 |
| S |
| Air Transportation Facilities |
| 1, 2, 3 |
2.3 Storm Water System Overview The majority of the storm water runoff from the base drains into one of the following three streams:
· Golf Course Creek, located along the western portion of the base, flows west from the base into Popperdam Creek, a tributary of the Ashley River.
· Runway Creek, located near Runway 03/21, flows south from the base into the Ashley River.
· Turkey Creek, located near Runway 15/33, flows east from the base into Goose Creek, a tributary of the Cooper River.
· Filbin Creek, located southeast of the base, flows east from the base into Goose Creek, a tributary of the Cooper River.
A major drainage divide is located along the western edge of Runway 15/33. Surface water collected at areas east of the drainage divide eventually drains into Goose Creek and the Cooper River. These areas include the airfield and associated pavements.
The majority of the maintenance facilities along the flightline, base shops, and housing areas eventually drain into the Ashley River. A small area at the southwest edge of the base drains to a tributary of the Ashley River. Flooding occasionally occurs due to flat topography, high water table, and extensive wetlands.
JB CHS - Air drainage areas comprise approximately 3,772 acres. The base is divided into thirteen (13) individual drainage areas. The boundaries for the drainage areas were determined from the existing base storm sewer maps, topographical maps, and the previous field survey. A summary of the Drainage areas is included in Table 2.
· Drainage Area 1 - 1,249 acres, approx. 28% impervious area. This drainage area contains a storm water retention basin near Building 182. Drainage in the immediate vicinity of the buildings and airfield facilities flows to storm ditches and ultimately storm drains. Drainage Area 1 discharges through Outfall 001 into Runway Creek;
· Drainage Area 2 – 478 acres, approx. 23% impervious area. Large grassy areas in and around the runways and taxiways direct storm water towards drainage pipes and eventually to drainage ditches. Drainage in the vicinity of the industrialized portion, including the JP-8 Fuel Storage facilities, flows to storm drains that lead to Outfall 002 that discharges into Turkey Creek which flows east from the base into Goose Creek;
· Drainage Area 2A - 10 acres, approx. 0.15% impervious area. Drainage in this area includes a former firing range and discharges through Outfall 002A into open ditches and ultimately into Popperdam Creek;
· Drainage Area 3 – 752 acres, approx. 30% impervious area. Drainage in this area include the main industrial facilities and discharges through Outfall 003 into Popperdam Creek, a tributary of the Ashley River;
· Drainage Area 4 – 64 acres, approx. 14% impervious area. Drainage in this area is primarily Base housing and flows to Outfall 004 (MS4-D), which is a culvert that flows under Dorchester Road and discharges into the Ashley River;
· Drainage Area 5 – 211 acres, approx. 7% impervious area. A storm water retention basin manages storm water runoff from this area. Drainage from the retention basin flows to Outfall 005, which is a culvert that runs under Arthur Drive and discharges into a system of ditches and eventually into Popperdam Creek and the Ashley River;
· Drainage Area 6 – 36 acres, approx. 12% impervious area. Drainage in this area flows through drainage swales and parallels Arthur Drive. Drainage eventually flows through Outfall 006, an open channel ditch, and discharges into Turkey Creek, a tributary of Goose Creek;
· Drainage Area 7 – 28 acres, approx. 5% impervious area. Drainage in this area flows through drainage swales and eventually flows overland into a wetland that borders S. Aviation Avenue. Drainage eventually flows through an open channel ditch through Outfall 007 into Turkey Creek, a tributary to Goose Creek;
· Drainage Area 7A – 190 acres, approx 13% impervious area. Drainage in this area flows through a series of swales, culverts and open channels and eventually flows overland into a wetland that borders S. Aviation avenue. Drainage eventually flows through a culvert under S. Aviation Ave and into an unnamed tributary of Filbin Creek.
· Drainage Area 8 – 66 acres, approx. 7% impervious area. Drainage from Base housing, open spaces and grassed areas flows through the storm water system and discharges through Outfall 008 (MS4-A) into the Ashley River;
· Drainage Area 9 – 56 acres, approx. 37% impervious area. Drainage from Base housing, open spaces and grassed areas flows through the storm water system and discharges through Outfall 009 (MS4-B) into the Ashley River;
· Drainage Area 10 – 24 acres, approx. 43% impervious area. Drainage from Base housing, open spaces and grassed areas flows through the storm water system and discharges through Outfall 010 (MS4-C) into the Ashley River; and
· Drainage Area 11 – 50 acres, approx. 17% impervious area. Drainage from Base housing, open spaces and grassed areas flows through the storm water system and discharges through Outfall 011 (MS4-E) into the Ashley River.
2.4 Site Maps A general site location map identifying the location of the facility and all receiving waters of storm water discharges from the facility is included as Figure 1. A site layout map, indicating an outline of the drainage area of each storm water outfall; each existing structural control measure to reduce pollutants in storm water runoff; locations of potential pollutant sources and activities; and surface water bodies is included as Figure 2. Higher resolution maps of each quadrant of the base are included in Figures 3 though 6.
2.5 Water Quality-Based Effluent Limitations JB CHS - Air must control its discharge as necessary to meet applicable water quality standards. If at any time, JB CHS - Air or SCDHEC determine, that the discharge causes or contributes to an exceedance of applicable water quality standards, corrective action must be taken as required in Part 3.1 of the IGP. Additionally, SCDHEC may impose additional water quality-based limitations.
2.5.1 Discharges to Water Quality Impaired Waters Numerous water quality monitoring stations are located within approximately 10 miles of JB CHS - Air. ADVENT utilized the modeling tool developed by SCDHEC at the following website to select the WQMS that are potentially affected by industrial activities at the base:
http://gisweb00.dhec.sc.gov/water/Stormwater.html?mode=1 The reports from this modeling tool and information regarding the 303(d) listed stream segments is summarized in Appendix D. Specifically two WQMS correspond to impaired stream segments identified on the 303(d) list that are potentially affected by industrial activities at JB CHS - Air, MD-049 on the Ashley River, MD-249 on Filbin Creek and MD-039 on Goose Creek.
Facilities that discharge to an impaired water with an EPA approved or established Total Maximum Daily Load (TMDL) must comply with the requirement(s) stated in the TMDL that maybe applicable to industrial storm water discharges. Industrial storm water, as a point source, is subject to the wasteload allocation (WLA) of TMDL. Any conditions applicable to the discharge necessary for consistency with the assumptions and requirements of such TMDL must be incorporated into the SWPPP. Currently, JB CHS - Air discharges to Water Quality Monitoring Station (WQMS) MD-049 on the Ashley River, which has an EPA approved TMDL for Dissolved Oxygen. Monitoring requirements related to this TMDL are discussed further in Section 6.0. In addition, according to the State of South Carolina Section 303(d) List for 2010 (SCDHEC Bureau of Water, 2010), Goose Creek at WQMS MD-039 is an impaired water without an EPA approved or established TMDL.
JB CHS - Air is required to verify the above information annually (during the comprehensive site evaluation) to determine (1) 303(d) listed stream segments and impairments potentially affected by JB CHS - Air and (2) development status of TMDLs for applicable 303(d) listed stream segments. Should a TMDL be developed for a stream segment potentially affected by industrial activities at JB CHS - Air, TMDL contribution and compliance must be addressed in the SWPPP through outfall monitoring and/or BMPs, as approved by the SCDHEC (IGP No. SCR000000, Section 2.2.2 and 6.2.4).
3.0
POTENTIAL POLLUTANT SOURCES
3.1 Industrial Activity and Associated Pollutants Potential sources associated with materials that could be exposed to storm water runoff include loading and unloading operations, outdoor storage, waste disposal practices, aircraft and vehicle washing and fueling facilities. Pollutants of concern include fuel, oil and grease, and washwater. These sources are summarized in Table 6 and described in more detail below:
· Loading and unloading operations: The primary storm water concerns originate from fuel handling on the airfield runways and aprons. Fuels such as jet fuel (JP-8) are transferred, loaded, unloaded, and stored on base and are exposed to rain events. A pollutant of concern, naphthalene, is a component of JP-8.
· Outdoor storage: Outdoor storage of significant materials is limited to aboveground storage tanks (ASTs) with secondary containment and hazardous materials and hazardous waste stored mainly in contained and covered sheds or hazardous materials (HAZMAT) lockers.
· Onsite waste disposal practices: Hazardous waste is collected and stored in HAZMAT lockers at various points at JB CHS - Air. This waste is shipped to the hazardous waste storage yard (at Building 691). Please refer to Section 4.2.2.3 for further information on this facility.
· Aircraft and vehicle washing: All aircraft washing activities are performed indoors. Wash water discharges to oil water separators (OWSs). Vehicles on base are washed at wash racks across the base, which discharge to OWSs. All OWSs that receive wash water from aircraft or vehicle washing discharge to the sanitary sewer system.
3.2 Material Inventory This section describes potential sources at JB CHS - Air, focusing on materials that may be exposed to precipitation or storm water runoff. In general, the materials found on-site are typical of an air force base. They include gasoline, diesel fuel, kerosene, jet fuel and oils. These materials are mainly stored in ASTs, underground storage tanks (USTs), mobile bowsers, or fuel trucks.
“Significant materials”, as defined in 40 CFR 122.26(b)(12), are substances related to industrial activities such as process chemicals, raw materials, fuels, pesticides, and fertilizers. When these substances are exposed to storm water runoff, they may be carried to a receiving stream with the storm water flow. Therefore, identification of these materials helps to determine and address a contamination potential.
The majority of significant materials identified at JB CHS - Air include petroleum, oils, and lubricants (POL), and HAZMAT. Sections 3.2.1 through 3.2.12 describe the major facilities of concern located within each drainage area. All facilities of concern, their exposed significant materials, storage method, and quantities stored are listed in Tables E‑1 through E-11, provided in Appendix E, by drainage areas.
3.2.1 Drainage Area 1
Drainage Area 1 is located in the southern portion of JB CHS - Air. This area includes a portion of the runways and taxiways and approximately half of the base housing. The flightline tanks associated with Building 97 have a capacity of approximately 850,000 gallons of JP-8. Tanks that store diesel fuel for emergency generators are located at various buildings in this drainage area and total approx. 9,400 gallons. Additionally, the aircraft and mobile equipment along the flightline account for approx. 35,500 gallons of JP-8 and engine POLs although the exact volume fluctuates daily.
3.2.2 Drainage Area 2
Drainage Area 2 is located in the northeast section of JB CHS - Air. This area includes a portion of the runways and taxiways and the Bulk Fuel Farm, Buildings 680 and 684. The total amount of fuel capacity at this facility is approximately 3.2 million gallons of JP-8, low sulfur diesel fuel (LS-2), and motor unleaded gasoline (MUR). This amount accounts for the majority of significant material stored at the JB CHS - Air.
3.2.3 Drainage Area 2A Drainage Area 2A is located in the northern section of JB CHS - Air. It encompasses a former firing range and a wooded area along the base property line. No significant materials are stored in this drainage area.
3.2.4 Drainage Area 3
Drainage Area 3 is located in the western section of JB CHS - Air. The majority of the base industrial area is located in this drainage area; in addition, a large portion of this area is occupied by the base golf course and base housing. The industrial area in Drainage Area 3 houses several facilities that store HAZMAT, hazardous waste (handling and storage), and liquid fuel, including Building 1951 (Army and Air Force Exchange Service [AAFES] station) with a capacity of 30,000 gallons of MUR, and Building 545 and 548 (Engine Test Cell and 437 Maintenance Group, Maintenance Squadron, Aircraft Ground Equipment Flight [MXS/AGE)]) with a capacity of 30,000 gallons of JP-8. Building 691, the Hazardous Waste Yard, has a storage capacity of 20,000 gallons of Used POL products. These buildings account for the majority of the significant material stored in Drainage Area 3.
Other buildings included in this area containing significant materials are: Building 406 (Military Vehicle Fueling Station), Building 713 (HAZMAT Pharmacy), Building 717 (Entomology) and various buildings with LS-2 tanks associated with emergency generators.
3.2.5 Drainage Area 4
Drainage Area 4 is located in the southwestern section of JB CHS - Air. The majority of the drainage area comprises base housing. Building 1800 and 1477 contain diesel fuel ASTs associated with emergency generators. These are the only areas that store significant materials.
3.2.6 Drainage Area 5 Drainage Area 5 is located in the northern portion of JB CHS - Air. The majority of the drainage area is a grassy area bordered by Arthur Drive, which parallels the eastern portion of the base. No significant materials are stored and no facilities of concern are located in Drainage Area 5. JB CHS - Air does have an earthen retention basin to assist in the management of runoff from Area 5.
3.2.7 Drainage Area 6 Drainage Area 6 is located in the eastern portion of JB CHS - Air. The drainage area is primarily grassy, but also contains portions of the base runway system. No significant materials are stored and no facilities of concern are located in Drainage Area 6.
3.2.8 Drainage Area 7
Drainage Area 7 is located in the southeastern portion of JB CHS - Air. This area includes a portion of the Aero Club. Building 2035 (Aero Club) is the only facility of significance located in this drainage area. A single AST containing 5,800 gallons of aviation gasoline (AVGAS) is located in this area.
3.2.9 Drainage Area 7A Drainage Area 7A is located in the southeastern portion of JB CHS - Air. This area includes a portion of the runways and taxiways as well as grassy and wetland areas. No significant materials are stored and no facilities of concern are located in Drainage Area 7A.
3.2.10 Drainage Area 8 Drainage Area 8 is located in the western portion of JB CHS - Air. This drainage area comprises base housing. No significant materials are stored and no facilities of concern are located in Drainage Area 8.
3.2.11 Drainage Area 9 Drainage Area 9 is located in the western portion of JB CHS - Air. This drainage area comprises base housing. No significant materials are stored and no facilities of concern are located in Drainage Area 9.
3.2.12 Drainage Area 10 Drainage Area 10 is located in the western portion of JB CHS - Air. This drainage area comprises base housing. No significant materials are stored and no facilities of concern are located in Drainage Area 10.
3.2.13 Drainage Area 11 Drainage Area 11 is located in the western portion of JB CHS - Air. This drainage area comprises base housing. No significant materials are stored and no facilities of concern are located in Drainage Area 11.
3.3 Spills and Leaks Spills and leaks can occur during routine loading and unloading operations of ASTs and USTs, during the transport of drums, maintenance operations, and during vehicle and aircraft fueling activities. Additionally, malfunctioning, old, and faulty equipment can cause accidental leaks. These activities are conducted in Drainage Areas 1 through 3 and Outfalls 001, 002, and 003 could potentially be affected should a release occur.
No significant spills or leaks of oil, toxic, and/or hazardous pollutants have occurred at JB CHS - Air in the past three years. Future spills and leaks will be documented in Appendix F.
3.4 Non-Storm Water Discharges No evidence of illicit discharges was observed during the site inspection in September 2010. This plan includes a certification stating that storm water discharges have been tested or evaluated for the presence of non-storm water discharges. The certification indicates the method used to evaluate the discharges, results from the test/evaluation, identification of potential significant sources, and the persons who conducted the test or evaluation. See Appendix G for the certification.
SCDHEC NPDES Permit #SCG750000, General Permit for Vehicle Wash Water Discharges provides coverage for washing fire department vehicles and the AAFES community car wash.
3.5 Salt Storage and Pavement Deicing There are no storage piles containing salt or deicing materials at JB CHS - Air.
3.6 Aircraft and Runway Deicing Section 4.2.3.2 describes the BMPs established for the management of aircraft deicing operations. Deicing operations have not occurred at the base in the last 5 years; however, these BMPs are in place if the need to use aircraft deicing fluid arises.
4.0
STORM WATER CONTROL MEASURES
Storm water control measures or BMPs are measures or practices used to reduce the amount of pollutants entering surface water, air, land, or groundwater. BMPs may take the form of processes, activities, or physical structures. In essence, they are anything that may be identified as a method, short of actual treatment, to prevent or minimize storm water pollution, or to prevent toxic or hazardous substances from entering the environment in general. Photographs of the outfalls, storm water retention ponds and selected BMPs are included in Appendix L.
Section 4 discusses management practices that are used at JB CHS - Air to minimize pollution in stormwater. Management guidelines have been developed specifically for the following:
· Hazardous materials management
· Hazardous waste management
· Pesticide management
· POL management
· Shop operations
This section also describes JB CHS - Air’s plan for spill prevention and control, and management practices for personnel training, facility inspections, and preventive maintenance.
In controlling or maintaining stormwater discharge rates and volumes, the pollutant load normally found in stormwater runoff from a specific drainage area would be controlled or maintained. JB CHS - Air does not anticipate an increase of stormwater discharge rates or volumes in the delineated drainage basins due to an additional net increase of impervious cover.
BMPs are measures to prevent or mitigate pollutants entering surface water, air, land, and groundwater. Most BMPs involve good management and common sense, while others require activity specific controls or practices. BMPs can be categorized as structural (that is, consisting of constructed facilities such as detention basins) or nonstructural (that is, practices or procedures). Whenever possible, nonstructural BMPs are implemented first. Structural BMPs are implemented when nonstructural measures fail to achieve the desired results. Basic nonstructural BMPs include the following:
· Good housekeeping
· Preventive maintenance
· Visual inspections
· Spill prevention and response
· Sediment and erosion control
· Management of runoff or stormwater management system
· Employee training
· Record keeping and reporting
· Non-stormwater discharge controls
JB CHS - Air presently conducts an annual ECAMP inspection to assess environmental compliance. Findings of areas of concern noted during the ECAMP inspection are documented and reported to the supervisor of the specific operation.
4.1 Basewide Best Mangement Practices The following BMPs are associated with basewide activities:
· Employee training
· Erosion control
· Preventive maintenance
· Record keeping and reporting requirements.
4.1.1 Employee Training
Employee training is essential to effective implementation of the SWPPP. The purpose of the stormwater training is to teach personnel at all levels of responsibility the components and goals of the SWPPP. Training provides personnel with an increased capability to prevent spills, respond safely and effectively to a spill, and recognize situations that could lead to stormwater contamination.
Stormwater and spill prevention training is provided at the eTEST computer based training (CBT) Web site, https://etest.amc.af.mil/. After reviewing the eTEST training video, trainees take the 10 question test and print a certificate of successful completion for records. Completed training records can be accessed electronically by CEAN.
The three main training areas (and associated topics) include the following:
· Spill prevention and response
· Identifying potential spill areas and drainage routes, including information on past spills and causes.
· Reporting spills and initial notification requirements.
· Location of posted Site-specific contingency plans.
· Specifying material handling procedures and storage requirements.
· Implementing spill response procedures (including immediate spill response actions including location of spill response equipment, shut-off valves, etc).
· Use and maintenance of alarms and monitoring equipment.
· Good housekeeping
· Maintaining a clean and orderly work environment.
· Prompt clean-up of spilled materials to prevent polluted run-off.
· Identifying areas where spill clean-up material (including sorbents) is stored and other housekeeping tools.
· Displaying signs reminding employees of the importance and procedures for good housekeeping.
· Discuss updated procedures and report on the progress of practicing good housekeeping procedures.
· Provide instructions on securing drums and containers and frequently checking for leaks and spills.
· Outline a regular schedule for housekeeping activities to determine that the job is being conducted.
· Conducting daily, weekly and monthly visual inspections.
· Material management practices
· Neatly organize materials for storage.
· Identify toxic and hazardous substances stored, handled, and produced onsite.
· Discuss handling procedures for these materials.
Contractors working in areas associated with oils or hazardous materials are responsible for training their personnel in spill response and reporting procedures. The contract administrator for the USAF is responsible for providing these contractors with a summary of spill response and reporting procedures.
4.1.2 Erosion Control
JB CHS - Air has identified several areas on base that are prone to erosion resulting from stormwater runoff. Eroded areas of Golf Course Creek, specifically along the first and eighth fairways, were identified during the 1999 Annual Stormwater Inspection. Measures to reduce erosion, such as planting grass, shrubs, and other natural erosion barriers were implemented to control the erosion. The flightline drainage ditch was previously identified as an area where erosion is occurring. Remediation efforts have successfully controlled the stormwater erosion.
4.1.3 Management of Runoff JB CHS - Air has an extensive storm water collection system to handle storm water received during periods of heavy rainfall. Thirteen outfalls, numbered 001, 002, 002A, 003, 004, 005, 006, 007, 007A, 008, 009, 010, and 011 were constructed based on surface runoff patterns on the base, with consideration given to the presence of existing storm sewers. These outfalls consist of a system of open drainage swales and underground storm sewers that discharge to culverts and pipes. During rain events, inlets in paved areas and roadways collect storm water runoff from industrial and developed portions of the base. Runoff from the unpaved areas is generally routed into open drainage channels. Irrigation waters, hydrant flushings, potable water piping repair flushings, and various other non-storm water runoffs are discharged to the storm water system, but account for only a small fraction of the total flow. No super-chlorination is conducted on water that is flushed from repaired piping or fire hydrants. All flushed water is within drinking water standards for chlorine levels.
4.1.4 Preventive Maintenance
The preventive maintenance program involves the periodic lubrication, adjustment, and replacement of worn parts in equipment, for example pump bearings and engine parts, where equipment failure could result in a spill of oils or hazardous materials that impede response efforts. Documentation of preventive maintenance is kept on Air Force Technical Order (AFTO) Form 39. The program includes:
· Periodic testing of equipment for integrity
· Calibration of monitoring equipment
· Periodic adjustment, cleaning, lubrication, and repair or replacement of parts and equipment as recommended by the manufacturer or required by good maintenance practices
Stormwater management device inspections are conducted by designated personnel. As part of these inspections, walk-throughs of outdoor areas around stormwater management devices (such as OWS, retention ponds, and catch basins) are conducted to identify any obvious problems. Any problems noted during the inspections are reported through work orders. All inspections are recorded and include the date, time, and name of the person making the inspections, corrective measures taken, and routine equipment maintenance, repair, or replacement performed. Inspections are normally performed monthly. Annual inspections are documented in a Stormwater Inspection Log. Annual inspection records are retained with the SWPPP. Follow-up procedures are used to ensure that appropriate actions are taken in response to the inspections.
4.2 BMPs Associated With Industrial Activity This section describes the following BMPs that are associated with industrial activity at JB CHS - Air.
· Traditional stormwater management practices and good housekeeping
· Spill prevention and response
· Facility inspections 4.2.1 Practices at Industrial Sites
4.2.1.1 Aircraft fueling/defueling operations
Aircraft fueling/defueling operations take place on the aircraft parking aprons. Aircraft are fueled either through the hydrant system or from refueling vehicles. Refueling vehicles (including Bowsers) are stored in designated areas with secondary containment when not in use. There are several areas along the ramp where these operations take place. BMPs conform to U.S. Air Force (USAF) guidance documents in POL storage and dispensing. Small spills are absorbed with a dry absorbent or pads and disposed of in accordance with applicable regulations. Daily inspection records are maintained on Air Force Technical Order (AFTO) Form 39. Deficiencies noted on AFTO Form 39 are submitted to Operations Service Contracts (CEOSS) and a work order is created to repair the problem. Larger spills are reported to the Fire Department.
4.2.1.2 Aircraft maintenance
Aircraft maintenance shops are either government or contractor operated. BMPs include:
· Placement of drip pans under bulk material dispensers
· Daily inspections
· Spill absorption materials readily available and used
· Training of personnel in proper handling of materials and spill response
4.2.1.3 Vehicle washing
Full aircraft washes occur inside Building 63. Wash water runoff discharges to OWSs. Other vehicles are washed at wash racks across the base, which discharge to OWSs that discharge to the sanitary sewer.
4.2.1.4 Power production
Power production maintains and changes oil for emergency generators on base. The emergency generators include emergency power systems for fire pumps and lift stations. Maintenance records are maintained for each piece of equipment. Each shop maintains a daily operating log for each individual piece of equipment.
4.2.2 Practices at Material Storage and Dispensing Areas
4.2.2.1 POL Storage
JB CHS - Air has the storage capacity for approximately 4.6 million gallons of POL, in USTs, ASTs, and drums ranging from 55-gallons to the largest AST containing 2.4 million gallons. The following POL materials are present in large quantities at JB CHS - Air:
· JP-8
· LS-2
· MUR
The Logistics Readiness Squadron, Fuels Management Flight (LGRF) program also maintains USTs, ASTS, and pipelines. The monthly throughput for JP-8 on the base is approximately 4.6 million gallons, including fueling and defueling operations. The monthly average fuel consumption for LS-2 and MUR is 13,000 gallons each. The base service station has three 10,000-gallon USTs containing MUR.
The main POL storage facility is located in Drainage Area 2. This area has five ASTs; each tank has secondary containment in the form of concrete dikes large enough to contain the entire contents of the respective tank, plus sufficient freeboard to allow for a 25-year, 24 hour storm event. The total JP-8 capacity in this POL area is approximately 3.2 million gallons. A pipeline transfers fuel from the fuel farm to the flightline tanks. This pipeline crosses through Drainage Areas 1, 2, and 3. The flightline bulk ASTs are contained by separate concrete containment dikes.
A pipeline transfers fuel from the fuel farm to the flightline tanks (ASTs 6 and 7). This pipeline crosses through Drainage Areas 1, 2, and 3. The flightline bulk ASTs 6 and 7 are contained by separate containment dikes. The secondary containment walls are constructed of concrete, and the floors are constructed of a liner and collection system consisting of geomembrane and geotextile liner overlaid with 1 foot of gravel. The secondary containment for ASTs 6 and 7 is sufficient to retain the entire contents of the respective tank, plus sufficient freeboard to allow for a 25-year, 24-hour storm event (SPCC, 2008).
The regulated USTs have leak detection devices and overfill protection. Most ASTs, including emergency generator tanks, are double-walled or have some other form of secondary containment (such as berms or dikes). Tanks are located in each drainage area, except Drainage Areas 5, 6, 7A, 8, 9, 10, 11.
4.2.2.2 HAZMAT Pharmacy JB CHS - Air has established procedures for procuring, issuing, tracking, and disposing of hazardous materials. The HAZMAT Pharmacy ensures that HAZMAT is purchased and issued in the quantities necessary to accomplish base activities. Building 713, the HAZMAT Pharmacy, is located in Drainage Area 2. The building is divided into two storage areas, a drum storage area and a flammables warehouse. Both of these storage areas are bermed and have emergency containment valves. There are no floor drains within the Building 713 storage areas. The storage areas contain spill equipment and eye wash stations.
4.2.2.3 Hazardous Waste Management The Hazardous Waste Yard (Building 691), which accumulates waste from many of the various shops on base and from aircraft and vehicle maintenance, is located in Drainage Area 3. The Hazardous Waste Yard is a RCRA Part B Permitted storage area for hazardous waste. Hazardous waste accumulated on base is stored at the Hazardous Waste Yard before shipment to an off-base facility through Defense Reutilization and Marketing Office (DRMO). Hazardous wastes can be stored in the Hazardous Waste Yard for up to 1 year from the accumulation start date.
The Hazardous Waste Yard contains four used oil storage tanks, a pumping facility, and an open bay facility that houses hazardous waste drums and cabinets. The tank storage area consists of four 5,000-gallon ASTs containing used mixed oil, used synthetic oil, used hydraulic oil, and used oil fuel. Used oils and fuels are pumped from bowsers and drums into the storage tanks. The storage tank area and pumping facility is equipped with overfill alarms and secondary containment. The secondary containment discharges to an OWS. After a rain, excess water is pumped through the OWS to the storm sewer. The BMP implemented at Building 691 requires that the OWS will not be used to process oily water.
The open bay facility serves as a drum storage area and is segregated by type of waste, including flammable liquids, non-regulated waste, flammable solids, and Class 9 Miscellaneous. Drums are stored on pallets that provide secondary containment. Valves in drum storage secondary containment are closed. The facility is covered by a roof and is surrounded by a concrete containment dike. Spill response equipment (booms, pads, and rags) as well as spill kits are located throughout the yard. . The Hazardous Waste Storage Yard facilities are located inside of a secured, fenced area that is accessed through a locked gate. Two storm water ditches are located just outside the perimeter of the yard near the access gate.
Tank contents are off-loaded to trucks for recycling using pumps. The valve arrangement varies during loading/off-loading depending on the material being transferred; each product has a dedicated pump.
4.2.3 Practices in Areas with Potential Surface Pollution
4.2.3.1 Airfields and Aprons
There are several potential sources of storm water pollution that are associated with operations and maintenance activities conducted on the airfield runways and aprons, located in Drainage Area 1. The primary storm water concerns originate from fuel handling. JP-8 is transferred, loaded, unloaded, and stored in proximity to storm drainage ditches and storm drains. Spill contingency plans have been developed to optimize spill recovery and response time.
Fueling is conducted using pressurized hydrant systems located in designated fueling areas along the flightline or directly from 6,000-gallon-capacity fuel trucks. The JP-8 fuel hydrants are located in the C-17 apron. JP-8 jet fuel is typically delivered from ASTs to the C-17 fuel hydrant pits through Pumphouse I and II.
Spills may occur during fuel loading and unloading operations. Spill response equipment, kits, and mobile trailers, located at Pumphouse II and on the flightline, contain absorbent booms, pigs, pads, shovels, and storm drain covers for immediate response. In addition, portable spill response kits are located on each refueler truck. Drip pans are used beneath each hose connection. No fuel loading and unloading operation are conducted during storm events. Should a catastrophic release occur, the Emergency Response Action Plan (part of the JB CHS - Air Facility Response Plan) will be followed. In addition, the CEF is located on the flightline and is able to respond immediately to spills from aircraft, 24 hours a day, 7 days a week, 365 days a year.
4.2.3.2 Aircraft Deicing Operations The base has BMPs established for the management of aircraft deicing operations. The BMP measures are designed to eliminate or reduce the environmental impact of airfield operations. The instructions are in place to prevent the introduction of deicing fluid into the base storm water system. A memorandum entitled “Using Deicing Best Management Practices (BMP)” was distributed on 28 January 2000 by the Deputy Commander of the Logistics Group to establish BMPs for aircraft deicing operations. The use of deicing operations at the base has not occurred in the last 5 years; however, these BMPs are in place if the need to use aircraft deicing fluid arises.
4.2.3.3 Pesticide Management
The pesticide management activities at JB CHS - Air consist of the application of insecticides, herbicides, and rodenticides to control insects and disease vectors of public health importance.
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