SWPPP 2020 IEPA Submittal_FINAL.pdf

Naval Station Great Lakes

Storm Water Pollution Prevention Plan (SWPPP) for

Storm Water Discharges from Industrial Activities 2020 - 2023

January 2020

Industrial SWPPP Naval Station Great Lakes

Revised January 2020 by Naval Station Great Lakes, Public Works Department Environmental Division

January 2020 i

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Purpose

1.2 Document Organization

1.3 Facilities Addressed

2.0 OVERALL SITE DESCRIPTION/FACILITY LOCATION

2.1 Storm Water Pollution Prevention Personnel

3.0 STATION-WIDE PERMIT NO. ILR00 CONSIDERATIONS

3.1 Industrial Storm Water Outfall Monitoring

3.2 SWPPP Design Criteria

3.3 Other Considerations………………………………………………………………………………...9

4.0 EVALUATION

4.1 General

4.2 Comprehensive Site Compliance Evaluation

5.0 INDIVIDUAL SWPPPS

5.1 Marina Fueling Site / Private Boat Storage Area

5.2 Hunt Military Communities Storage Yard

LIST OF FIGURES

FIGURE 1: INDUSTRIAL SWPPP FACILITY LOCATIONS

FIGURE 2: MARINA FUELING SITE/PRIVATE BOAT STORAGE AND MAINTENANCE AREA

FIGURE 3: HUNT MILITARY COMMUNITES STORAGE YARD

LIST OF TABLES

TABLE 1: FACILITIES CONSIDERED AS REQUIRING AN INDIVIDUAL SWPPP

TABLE 2: POTENTIAL SPILL SOURCES AT THE MARINA

TABLE 3: PREVIOUSLY REPORTED SPILLS AT THE MARINA

LIST OF APPENDIX

APPENDIX A: GENERAL NPDES PERMIT NO. ILR00-2630

APPENDIX B: STORMWATER MONITORING WORK PLAN

APPENDIX C: FORMS AND CHECKLISTS (MONTHLY, QUARTERLY VISUAL, ANNUAL)

APPENDIX D: SWPPP AWARENESS LEVEL TRAINING MATERIAL

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1.0 INTRODUCTION

1.1 Purpose

The purpose of this document is to describe practices in place for prevention of pollution in storm water discharges from industrial facilities in operation at Naval Station Great Lakes (NSGL). This Storm Water Pollution Prevention Plan (SWPPP) has been developed in accordance with Part E of the Illinois National Pollutant Discharge Elimination System (NPDES) general permit for storm water discharges from industrial activities (Permit No. ILR00-2630).

1.2 Document Organization

This document is divided into two parts. The first part (Sections 1.0 – 4.0) gives station-wide background, introduces the individual facilities addressed, describes SWPPP personnel, and discusses station-wide requirements and evaluation procedures. The second part (Section 5.0) contains standalone SWPPPs for individual industrial sites at NSGL.

1.3 Facilities Addressed

A total of twenty five (25) facilities (Table 1) were assessed to determine whether an individual SWPPP would be required based on operations and/or individual SIC code.

In 2009-2010 NSGL retained the services of a professional consultant (HDR) to update and revise NSGL’s Industrial SWPPP Program. Major revisions to the station’s program included:

1. Reclassification of standard industrial classification (SIC) codes for applicable NSGL operations which reduced regulated facilities under ILR00; and

2. Revision of individual industrial SWPPPs to meet requirements of ILR00 issued April 3, 2009.

After facility inspections by HDR personnel on January 20 - 21, 2009, review of facility operations and review of applicable SIC codes, HDR determined that industrial SWPPPs were only required for three (3) of the sites listed in Table 1. According to HDR, SIC codes were not strictly applicable to those regulated for storm water discharge. Some sites covered in the previous industrial SWPPP were found to have inaccurate SIC codes, which excludes them from the requirements of Permit No.

ILR00. These sites included the Golf Course Maintenance Facility, the Grounds Maintenance Trailer, the Vehicle Maintenance Facility, and the Assault Craft Maintenance Facility.

As of 2009, the following facilities required an industrial SWPPP under Permit No. ILR00.

1. Marina – Bldg 13 / Private Boat Storage

2. Defense Reutilization and Marketing Office (DRMO) Storage Facility and Yard - Bldg 3212C

3. Navy Recycling Center – Bldg 3219

Since 2009, the following changes have been made in permit-covered facilities:

1. The recycling center at Bldg 3219 is no longer in operation (as of April of 2012). The individual

SWPPP for the recycling center was removed and coverage for storm water discharges under Permit No. ILR00 for the site is no longer required.

2. In 2019, the DRMO Storage Facility and Yard phased out operations. Inspections have continued to ensure permit compliance until the change could be formalized in this SWPPP revision. Inspections will cease upon submittal of the revised SWPPP to IL EPA.

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3. The Hunt Military Communities outdoor storage yard is being added as a covered facility in this 2020 SWPPP update. The storage yard is adjacent to the former DRMO storage yard and operations are similar in nature. The Hunt operations could potentially impact two outfalls; SCR07, the same outfall previously monitored for the former DRMO Storage Facility and Yard and SCR05.

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TABLE 1: FACILITIES EVALUATED FOR INDIVIDUAL SWPPPs

Facility Building Number(s) Applicable Standard Industrial Classification (SIC) Code(s)

Vehicle Maintenance Facility 1506, 1507, 1516, 1517 7538 – General Automotive Repair Shops / 1611 – Highway and street construction, except elevated highways.

Golf Course Maintenance Building 3311 7332 – Public Golf Courses

Power Plant 11/12 4911 – Electric Services

Marina / Private Boat Storage 51/13 4493 – Marinas

Assault Craft Storage 52 9711– National Security

DRMO Storage Facility and Yard 3212C 5093 – Scrap and Waste Material.

No longer active. Removed from monitoring.

Recycling Center 3219 5093 – Scrap and waste material

Grounds Maintenance Trailer 3511A 0782 – Lawn and Garden Services

Naval Reserve Vehicle Maintenance 1712 9711 – National security

Auto Skills Center 2110 7538 – General Automotive Repair Shops

Hazardous Material Pharmacy (HAZMAT) 3502 4593 – Refuse systems

Dry Cleaning Building 3501 7218 – Industrial Launderers

Naval Exchange Main Store 3542 5399 – Miscellaneous General Merchandise Stores

Goodwill Vehicle Maintenance 3213/2166 7538 – General Automotive Repair Shops

Club Liberty 525 5813 – Drinking Places

Port O’Call Club 140 5813 – Drinking Places

Marine Corps Maintenance 3200 7538 – General Automotive Repair Shops

Golf Clubhouse 8400 7992 – Public golf courses

Carwash 2712 7542 - Carwashes

Sewage Lagoon 4500 4952 – Sewerage systems

Galley 535 5812 – Eating Places

McDonald’s Restaurant 590 5812 – Eating Places

NEX Gas Station/Recruit Store 1326 5541 – Gasoline Service Stations /5399 – Miscellaneous General Merchandise Stores

Post Office 112 43 – US Postal Service*

Hunt Military Communities Storage Yard 3212C 5093 – Scrap and Waste Material

*This site does not require a SWPPP because there are no on‐site transportation facilities involved in vehicle maintenance.

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2.0 OVERALL SITE DESCRIPTION/FACILITY LOCATION

NSGL is the United States Navy’s Headquarters Command for training, located in Great Lakes, Lake County, Illinois. Tenant commands include the Recruit Training Center, Training Support Center, and Naval Recruiting District Chicago. NSGL is the largest military installation in Illinois and the largest training center in the Navy. NSGL includes approximately 1,500 buildings on 1,628 acres, uses 50 miles of roadway to provide access to the NSGL’s facilities and supports a total population of 39,000 active duty and reserve sailors along with civilian employees, Federal contractors, retirees, and family members. Individual facilities identified as requiring an Industrial SWPPP per Permit No. ILR00-2630 are shown on Figure 1.

NSGL lies adjacent to the southwestern shore of Lake Michigan. Water resources within NSGL includes mapped wetlands, the headwaters of Skokie Creek (a.k.a. Skokie River), and Pettibone Creek (Figure 1).

Surface water within NSGL generally drains in two directions. The eastern portion of NSGL (east of Green Bay Rd) drains east to Lake Michigan via the North and the South Branches of Pettibone Creek. Note, Pettibone Creek also collects storm water flows from outside of Navy properties.

The western portion of NSGL (west of Green Bay Rd) drains south via the Skokie Creek, a tributary of the North Branch of the Chicago River. The North Branch of the Chicago River ultimately flows to the Mississippi River via the Chicago, Des Plaines, and Illinois rivers. Stormwater connections from north and west of Navy property also flow into Skokie Creek.

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2.1 Storm Water Pollution Prevention Personnel

The SWPPP team and key facility personnel are responsible for developing, implementing, maintaining, and revising this document and the individual SWPPPs. The SWPPP team will be responsible for implementing certain BMPs and delegating implementation of other BMPs where necessary to key facility personnel, and overall NSGL compliance with Permit No. ILR00-2630, including quarterly visual outfall monitoring and annual IEPA reporting. The key facility personnel are familiar with the management and operations of the facilities for which SWPPPs have been prepared and will be responsible for staff training and BMP implementation. Chart 1 shows organization and responsibilities of the SWPPP team and key facility personnel.

CHART 1:

Contact Title email Phone No.

Bruce Mack Matt Wollert Tara Lester

Environmental Director Environmental Operations Manager Storm Water Program Manager bruce.g.mack@navy.mil matthew.wollert@navy.mil tara.lester@navy.mil

847-688-5395 x 266 847-688-5395 x 270 847-688-5395 x 272

Storm Water Manager

IEPA Reporting BMP Implementation

Quarterly Visual Outfall

Monitoring

Annual Facility Inspection SWPPP Training

Monthly Inspections

(EV Personnel)

Comprehensive Site Compliance

Evaluation

SWPPP Review and Update

Key Facility Personnel

BMP

Implementation

January 2020 5 mailto:bruce.g.mack@navy.mil mailto:matthew.wollert@navy.mil mailto:tara.lester@navy.mil

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3.0 STATION-WIDE PERMIT NO. ILR00 CONSIDERATIONS

3.1 Industrial Storm Water Outfall Monitoring

According to Permit No. ILR00-2630 Section E.10(a), NSGL is required to perform and document routine facility inspections and quarterly visual assessments of storm water discharges associated with industrial activity. Monitoring locations and procedures designed to meet this requirement are detailed in NSGL’s Stormwater Monitoring Work Plan provided in Appendix B.

3.2 SWPPP Design Criteria

According to Permit No. ILR00-2630 Section E.1(a), NSGL is required to develop its SWPPPs to meet a storm event equal to or greater than the 25-year 24-hour rainfall event because storm water from the applicable sites drain to either Skokie River or Lake Michigan, which are impaired pursuant to Section 303(d) of the Clean Water Act. This design criterion is applicable only to storm water basins and other collection ponds and was not applied to the BMPs for each individual SWPPP because none are of the permanent, post-construction variety.

3.3 Other Considerations

In accordance with Permit No. ILR00-2630 Section E.5(f), each SWPPP contains a summary of existing sampling data describing pollutants in storm water discharges. No chemical data was collected in 2019 related to industrial storm water discharges associated with the two areas requiring individual SWPPs (the Marina and the DRMO Storage Yard) due to timing issues associated with laboratory analysis of fecal coliform. Details on that issue are provided in the NSGL 2019 Annual Report. However, NSGL will attempt in 2020 to complete all required analyses. If fecal coliform limits our ability to address all parameters, the remaining parameters will be analyzed, with fecal coliform to be completed when the opportunity arises.

In addition to the storm water inspection work required under ILR00-2630, the Navy has completed additional studies within Pettibone Creek, Skokie Creek, and along the Lake Michigan shoreline to ensure that NSGL is not a source of industrial contaminants associated with the 303(d) impairments within the stream. A 2017 Pettibone Creek study report and associated cross connection technical memorandum inventoried outfalls and evaluated discharges to Pettibone Creek. The studies found evidence of potential cross connections, and those cross connections (due to damaged pipes) were corrected by the Navy via line replacement. A supplemental 2019 study of Skokie Creek and the Lake Michigan shoreline also inventoried outfalls and identified areas where additional investigation is necessary to assess potential cross connections. The Navy is continuing investigations and will make any repairs /corrections that are necessary.

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4.0 EVALUATION

4.1 General

Inspections and review activities are an essential part of the continued successful implementation of this SWPPP. Specifically, SWPPP evaluations are conducted to:

• Confirm the accuracy of potential pollution sources in each individual SWPPP;

• Determine effectiveness of each individual SWPPP; and

• Assess compliance with terms and conditions of the permit.

Each individual SWPPP should also be amended whenever there is a change in design, construction, operation, or maintenance at the facility that may impact the potential for pollutants to be discharged or if the SWPPP proves to be ineffective in controlling the discharge of pollutants.

To accomplish the inspection and review process, the two following types of evaluations will take place as part of the Annual Facility Inspection Report:

• Comprehensive site compliance evaluations

• SWPPP review and update

4.2 Comprehensive Site Compliance Evaluation

4.2.1 Procedure

The storm water pollution prevention team leader or team member will conduct site compliance evaluations once a year. The following will be included in the evaluation:

• Inspection of storm water drainage areas for evidence of pollutants entering the drainage system.

• Evaluation of the effectiveness of measures to reduce pollutant loadings and whether additional measures are needed.

• Observation of structural measures, sediment controls, and other storm water BMPs to ensure proper operation.

• Inspection of any equipment needed to implement the SWPPP (i.e., spill response equipment).

4.2.2 Evaluation Guidelines

• On an annual basis, complete the station-wide checklist and an individual site checklist for each site with an individual SWPPP (Appendix C).

• Complete Illinois Environmental Protection Agency (IEPA) Annual Facility Inspection Report for the station.

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• Submit checklists and Annual Facility Inspection Report along with quarterly outfall monitoring reports (SWMP Appendix B).

• Based on the results of the evaluation, revisions to the potential pollution sources and measures and controls must be revised within 2 weeks of the evaluation.

• Changes in procedural operations for non-structural measures and controls should be implemented within 12 weeks of the evaluation.

• Procedural changes in structural measures and controls are allowed up to 3 years for implementation.

• Each record must be kept for a minimum of 3 years.

4.2.3 SWPPP Review/Update

This document and each individual industrial SWPPP should be reviewed annually after the site compliance evaluation to determine if the requirements of Permit No. ILR00-2630 are being met.

Amendments to this document and individual industrial SWPPPs should be made at this time.

The procedure for SWPPP review consists of:

• Assembling storm water pollution prevention team and go through SWPPP review form.

• Addressing all pertinent matters.

• Making necessary contacts to update the existing SWPPP and finalize and adapt a new version.

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5.0 INDIVIDUAL SWPPPS

The following sections contain individual industrial SWPPPs for required facilities under Permit No.

ILR00-2630.

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Naval Station Great Lakes Storm Water Pollution Prevention Plan

(SWPPP) for Marina Fueling Site and Private Boat

Storage/ Maintenance Area

2020-2023

JANUARY 2020

This SWPPP is excerpted from NSGL’s facility-wide industrial SWPPP and is designed to stand alone for use by the facility operator in implementing the industrial SWPPP for the selected facility. This SWPPP will aid the facility operator in understanding pollutants sources identified and BMPs selected for the specific industrial facility.

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5.1 Marina Fueling Site / Private Boat Storage Area

5.1.1 Site Description

The Marina Fueling Site and Private Boat Storage Area are located adjacent to the Lake Michigan inner harbor. These sites have been covered in one individual industrial SWPPP due to their proximity to one another, common SIC code, and function of servicing privately owned boats.

The Marina Fueling site is located east of the Marina (Building 13) and is used for fueling recreational boats. The total site area is approximately three fourths of an acre with mostly paved surfaces and some grass.

The Private Boat Storage Area includes boat storage and parking areas northeast of Building 13 along the harbor. The site is used for storage and maintenance of private civilian boats. The total site area is approximately 4 acres and consists mostly of pervious gravel and grass. Private boats stored outside are locked.

5.1.2 Drainage

Drainage from the site is primarily by sheet flow east directly to Lake Michigan and south to the Lake Michigan boat basin and inner harbor. Some stormwater may flow into the storm water infrastructure, and two outfalls have been selected for monitoring.

5.1.3 Pollutant Source Assessment

Material Inventory and Risk Identification

The following materials and activities have been identified as potential storm water pollution sources.

Boat engine/part leaks

Boats are stored at the site outdoor throughout the year. There can be several to many (~50) boats stored at the site depending on the season. There is risk for leaks from the boat engines and other parts. These leaks could consist of oil, grease, petroleum, solvents, and lubricants. These leaks could infiltrate into the porous soil or, as a worst case condition, could be washed directly to Lake Michigan.

Routine boat washing

Boat owners wash the exterior of their boats at the site on a routine basis. There is potential for storm water contamination from particulates washed from the boats and detergents used for cleaning. These particulates and detergent could, as a worst case condition, run off directly to Lake Michigan.

Paint spills/particulates

Boat owners paint and sand their boats on-site. Prior to painting, it is common for owners to pressure wash the boats. Painting and washing introduce the risk of paint spills and contamination of storm water due to particulates washed and sanded from the boats.

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As a worst case condition, paint spills and particulates from boat washing and sanding could be washed directly to Lake Michigan.

Equipment maintenance

Boats are maintained on-site. Maintenance activities include work on engines. Oil and grease could leak from boat parts and engines during maintenance and runoff directly to Lake Michigan under a worst case scenario.

Gas pump/ fuel storage tank

The gas pump located within the fueling site is used by private citizens for fueling recreational boats.

The pump is used for withdrawing gasoline from an above ground storage tank located directly adjacent to the pump. The fuel is contained in a secondarily contained tank that is double-walled and has a volume of 1,000 gallons. There is potential for gasoline contaminating storm water from tank leaks, a spill during tank loading, and spills during fueling. As a worst case condition, storm water contaminated with gasoline could sheet flow directly to Lake Michigan.

Marine vehicle sanitary waste pump-out station

The marina has a marine vehicle waste pump-out station located at the southeast corner of the marina near the fuel storage tank. This station is used for unloading sanitary waste from private recreation boats. Waste is discharged directly to the sanitary sewer system. There is a potential for biological pollutants to be released with storm water during unloading due to loss of containment (i.e. hose break, spill, improper unloading procedure).Under a worst case scenario, storm water contaminated with biologic pollutants may be discharged directly into Lake Michigan.

Outdoor fuel storage

The marina stores gasoline, diesel, and oils in small containers on the southwest corner of Building

13. These containers, no bigger than 5 to 6 gallon capacity, are stored within flammable liquid lockers. The lockers protect contents from exposure to storm water and provide secondary containment. There exists a potential for discharge of fuel or oils with storm water as a result of improper storage of these items or improper operation or maintenance of the locker storage area.

Under a worst case scenario, storm water contaminated with fuel/oils will be discharged directly to Lake Michigan.

Recreational vehicle sanitary discharge station

The marina has a recreational vehicle sanitary discharge station east of Building 13. This station is used for discharging sanitary waste from private recreational vehicles. Waste is discharged directly to the sanitary sewer system. There is a potential for biological pollutants to be released with storm water during unloading due to loss of containment (i.e. hose break, spill, improper unloading procedure).Under a worst case scenario, storm water contaminated with biologic pollutants may be discharged directly into Lake Michigan via sheet flow.

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Significant Spills and Leaks

Table 2 contains a list of potential spill sources at the Marina/Private Boat Storage Area according to the NSGL Spill Prevention Control and Countermeasures (SPCC) Plan dated October 2016.

TABLE 2:

POTENTIAL SPILL SOURCES AT THE MARINA

Source of Potential Spill Material Location of Unit Potential

Source of Spill Direction of Spill Flow Rate of

Spill (gpm)

Estimated Maximum Spill

Quantity (gal)

Building 13 Gasoline East Side of

Building / Eastern Portion of Boat

Basin

Ruptured tank and failure of secondary containment

Southwest to catch basin and eventually to Boat Basin / NSGL Inner Harbor /

Lake Michigan

Variable 1,000

Building 13 Gasoline

East Side of Building / Eastern

Portion of Boat Basin

Failure during fueling over water

Southwest to catch basin and eventually to Boat Basin

/ NSGL Inner Harbor / Lake Michigan

Variable Variable

Below is a list of the previously reported spills at the Marina.

TABLE 3:

PREVIOUSLY REPORTED SPILLS AT THE MARINA

Location Volume (gal)

Material Spilled

Date Description

Building 13 0.0078 (1 oz)

Oil and gasoline

July 2000 A boat sank in the harbor while docked and an insignificant amount of oil/gasoline was released to the water.

Building 13 50 Transformer

Oil January 2008

Transformer tipped over spilling contents when being moved on forklift by electric Contractor, < 1 gallon flowed into inner boat harbor adjacent to building.

Building 13 < 10 Diesel Fuel October 2013 Spill contained to inner harbor. Response by FRT.

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Non-Storm Water Discharges

A non-storm water discharge assessment was performed on October 3, 2018 by MECx , Inc., as part of an inventory of NSGL outfalls. No non-storm discharges were observed at associated outfalls.

NSGL will continue to visually monitor discharges from the site to ensure that no non-storm water discharges are present. D the elevated water level in Lake Michigan, an assessment of non-storm flows at associated outfalls should be via inspection of water flow in upgradient storm water manholes.

5.1.4 BMP Identification and Implementation

Best management practices (BMPs) are physical, structural, and/or managerial techniques used to prevent or reduce storm water pollution from industrial activities. BMPs are a very broad class of measures and may include process modifications, procedure implementation, prohibitions on practices, structural controls and other management practices. The baseline BMPs are not optional and must be considered for incorporation into SWPPPs during their preparation. However, implementation of all baseline BMPs is not appropriate in all cases: some baseline BMPs may already be in place, while others are not applicable. Baseline BMPs include the following:

• Good housekeeping

• Preventative maintenance

• Spill prevention and response

• Storm water management practices

• Sediment and erosion control

• Employee training

• Visual inspections

• Recordkeeping and reporting

Good Housekeeping

NSGL has a policy of good housekeeping for the purpose of maintaining a clean and orderly work environment. A clean and orderly work area reduces the possibility of accidental spills caused by mishandling of chemicals and equipment and could reduce safety hazards to personnel. Well-maintained material and chemical storage areas will reduce the potential for introduction of pollutants to the storm water. The following housekeeping BMPs are implemented at the facility:

BMPs:

• Ground surfaces are maintained and kept clear near stored boats and gas pump.

• Areas around boats are cleaned up after maintenance activities.

• Private boat owners are required to place tarps on ground during maintenance activities.

• Private boat owners are required to remove all waste after maintenance activities.

• Awareness signs are placed at the marina fueling station and private boat storage area educating users on potential storm water impacts and BMP requirements.

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Preventative Maintenance

Preventative maintenance involves the regular inspection and testing of equipment and operational systems. The purpose of such inspections is to uncover conditions such as cracks or slow leaks, which could cause breakdowns or failures resulting in discharges of chemicals to storm sewers and surface waters. A preventative maintenance program should prevent breakdowns and failures by adjustment, repair, or replacement of equipment on a timely basis.

BMPs:

• Fuel storage tank, gas pump, and hose are inspected regularly for leaks.

• Gas pump emergency disconnect is inspected regularly for structural integrity.

Spill Prevention and Response

Establishing standard operation procedures, such as safety and spill prevention procedures, along with proper employee training can reduce accidental releases of pollutants into storm water.

Avoiding spills and leaks is preferable to cleaning them up after they occur, not only from an environmental standpoint but also because spills cause increased operating costs and lower productivity.

BMPs:

• Private boat owners are required to remove all excess raw materials associated with boat maintenance that could spill or leak.

• Requirements for all private citizens with storage contracts are posted in several areas on the site.

• Any spill or hazardous material release by boat owners shall be reported immediately to the harbor master and/or the Emergency Dispatch Center. The Public Works Department Great Lakes Environmental Division (PWD-GL-EV) personnel are responsible for notification to all agencies.

• The gasoline pump is equipped with an emergency disconnect.

• Tanker trucks park immediately south of the gas pump in a cement containment to fuel the tank.

• Spill response equipment is stored nearby, south of Building 13 across the inner harbor.

• Protocols established in the NSGL SPCC plan are implemented for spills.

Visual Inspections

Conduct monthly, quarterly, and annual visual site inspections to ensure that BMPs are being effectively implemented. Current practices associated with visual inspection are listed as follows:

BMPs:

• Environmental Department personnel or supporting contractors will inspect the facility (monthly, quarterly visual, annual) using the inspection forms found in Appendix C.

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• Deficiencies noted will be tracked for corrective action through the Environmental Management System (EMS).

Annual Analytical Sampling

Pursuant to Permit No. ILR00-2630 Section C.2, NSGL shall perform annual analysis of discharges to verify that the industrial area is not contributing to contamination associated with 303(d) impairments.

Sampling will be from Outfalls LMBHW21 and LMBHW09 (formerly OF32 and OF33, respectively). Note that due to the water level of Lake Michigan, samples must be collected from upgradient manholes.

BMPs:

• Environmental Department personnel or supporting contractors will collect samples for analysis and will review analytical results.

• Any elevated contaminants will be identified and follow-up investigations will be performed to determine the source(s) and develop corrective actions.

Storm Water Management Practices

Storm water management practices are practices other than those which control the source of pollutants.

BMPs:

• The vegetative buffer along the lake shore will be maintained.

Sediment and Erosion Control

Not applicable.

Training

Employee training programs are used to inform personnel at all levels of responsibility of the components and goals of the SWPPP. Training should address each component of the SWPPP;

including how and why tasks are to be implemented.

BMPs:

• Training is provided to key facility personnel on spill response and management as described in the NSGL 2016 SPCC Plan.

• Signs are placed on the gas pump warn people not to dispense gasoline without attendant and not to dispense gasoline into unapproved containers.

• Sign on gas pump emergency disconnect is clearly visible.

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Recordkeeping and Reporting

Proper recordkeeping and recording of all information associated with storm water runoff is important to monitor the effectiveness of the SWPPP and to improve storm water management.

BMPs:

• Monthly inspections related to storage tanks at the Marina, as outlined in the NSGL SPCC Plan, are documented by the Environmental Department.

• Monthly, quarterly, and annual storm water inspections are performed utilizing the forms found in Appendix C. Any findings associated with industrial operations are tracked and resolved.

Note: There are erosion issues associated with the slopes along Ziegemier St. which can cause sediment to show up in nearby storm water manholes. Slope failure issues are unrelated to industrial activities, and the Navy is pursuing funding to address slope erosion. Outfalls OF32 and OF33 (LMBHW21 and LMBHW09, respectively, under the updated outfall nomenclature) are included in the routine monitoring program. Outfall OF31 is being removed from the monitoring program, as an assessment of the storm water system in the area found the water flowing to that outfall is not from industrial activities associated with the Marina or the Boat Storage / Maintenance Area.

• Storm water reports including annual, quarterly, and monthly inspection reports in addition to spill data are kept on file for at least 3 years as required by the general permit.

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FIGURE 2:

MARINA FUELING SITE/PRIVATE BOAT STORAGE AND MAINTENANCE AREA

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Industrial SWPPP Quarterly Outfall Monitoring Plan Naval Station Great Lakes

Storm Water Pollution Prevention Plan

(SWPPP) for Hunt Military Communities Storage Yard

2020-2023

January 2020

This SWPPP is excerpted from NSGL’s facility-wide industrial SWPPP and is designed to stand alone for use by the facility operator in implementing the industrial SWPPP for the selected facility. This SWPPP will aid the facility operator in understanding pollutants sources identified and BMPs selected for the specific industrial facility.

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5.2 Hunt Military Communities Storage Yard

5.2.1 Site Description

The Hunt Military Communities (Hunt) Scrap Yard is located adjacent to the southwest corner of Building 3212C and is used for storage of equipment and materials awaiting disposal or recycle. Equipment and materials potentially stored at the site include the following: pallets, discarded furniture and appliances, wood debris, metal scrap, electronic recyclables, tires, waste and recycling containers, and an assortment of other debris. The site is approximately 4 acres and consists of pervious areas (gravel and grass) and impervious surfaces (building and pavement).

5.2.2 Drainage

The Hunt Storage Yard is located adjacent to the Skokie Creek, also known as Skokie River. Runoff from the site drains to Skokie Creek through the storm sewer and ultimately drains through the same outfall that was previously monitored for the former DRMO storage / scrap yard. Industrial activities occurring within Bldg. 3212C are not exposed to storm water.

5.2.3 Pollutant Source Assessment

Material Inventory and Risk Identification

The following have been identified as potential storm water pollution sources.

Outdoor Vehicle/Equipment Parking & Storage

Vehicles and other equipment are stored outdoors throughout the yard. Gasoline and oil leaks from vehicle engines and fuel tanks can potentially contaminate storm water. Leaks would be mobilized by runoff and drain directly to Skokie Creek via the storm water infrastructure.

Runoff from stored debris

Pallets, used appliances, tires, metal scrap, empty waste and recycling containers, and other debris are stored outdoors within the yard. Particulates can be dislodged by precipitation and storm water sheet flow. Leaks are possible from used equipment and appliances that are staged in the area prior to removal. Additionally, waste electronics are consolidated in a roll-off box for recycling, but if not covered, the equipment could contribute metal contamination to storm water.

Stored Chemicals

Landscaping and housekeeping chemicals and fuels are stored in lockers within the Storage Yard. Spills or improper use of the chemicals could lead to releases that could enter the storm water system, ultimately discharging in Skokie Creek.

Unpaved areas

Sediment and soil in unpaved areas can be dislodged by precipitation and sheet flow and can contaminate storm water. As a worst case condition, runoff from these areas could drain southeast, directly to Skokie Creek.

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5.2.4 Pollutant Source Assessment

Significant Spills and Leaks

This is a new area of monitoring / inspection. NSGL has no record of spills in the Hunt Storage Yard.

Non-Storm Water Discharges

This is a new area of monitoring / inspection. A non-storm water discharge assessment will performed in 2020.

5.2.5 BMP Identification and Implementation

General

Best management practices (BMPs) are physical, structural, and/or managerial techniques used to prevent or reduce storm water pollution from industrial activities. BMPs are a very broad class of measures and may include process modifications, procedure implementation, prohibitions on practices, structural controls and other management practices. The Baseline BMPs are not optional and must be considered for incorporation into storm water plans during their preparation. However, implementation of all Baseline BMPs is not appropriate in all cases: some Baseline BMPs may already be in place, while others are not applicable. The Baseline BMPs include the following:

• Preventative maintenance

• Good housekeeping

• Spill prevention and response

• Storm water management practices

• Employee training

• Visual inspections

• Recordkeeping and reporting

Preventative Maintenance

Preventative maintenance involves the regular inspection of materials with potential to cause storm water contamination. The purpose of such inspections is to uncover conditions such as cracks or leaks in materials which could cause breakdowns or failures resulting in discharges of chemicals to storm sewers and surface waters. A preventative maintenance program should prevent failures by timely removal of materials.

BMPs:

• All debris containing fluids (vehicles and equipment) checked regularly for leaks

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Good Housekeeping

NSGL has a policy of good housekeeping for the purpose of maintaining a clean and orderly work environment. A clean and orderly work area reduces the possibility of accidental spills caused by mishandling of chemicals and equipment and could reduce safety hazards to plant personnel. Well-maintained material and chemical storage areas will reduce the potential for introduction of pollutants to the storm water.

BMPs:

• Regularly remove garbage and waste material

• Maintain space between debris piles and vehicles for inspection and spill cleanup access

• Store waste and recycling containers in an inverted position

• Cover electronics recycling accumulation container.

Spill Prevention and Response

Establishing standard operation procedures, such as safety and spill prevention procedures, along with proper employee training can reduce accidental releases of pollutants into storm water.

Avoiding spills and leaks is preferable to cleaning them up after they occur, not only from an environmental standpoint, but also because spills cause increased operating costs and lower productivity.

BMPs:

• Follow protocol established in the Spill Prevention, Control, and Countermeasure Plan dated October 2016 or as amended.

Storm Water Management Practices

Storm water management practices are practices other than those which control the source of pollutants. They include measures such as installing oil and grit separators or diverting storm water away from potential sources of pollution.

BMPs:

• None in place at this time.

Sediment and Erosion Control

Unpaved areas and uncovered soil piles may undergo erosion. These areas are to be inspected and maintained as necessary.

Existing BMPs:

• Maintain pavement where it exists as ground cover.

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Recommended Future BMPs:

• Seed and stabilize any bare areas not required for storage of materials

• Install and maintain inlet protection in storm drain in road adjacent to storage yard if there is indication of particulate / sediment movement from the area

Visual inspections

Conduct monthly, quarterly, and annual inspections to identify conditions that could cause contamination of storm water runoff and to ensure that the BMPs are being effectively implemented.

Current practices associated with inspections are listed as follows:

BMPs:

• Environmental Department personnel or support contractors will inspect the facility using the inspection forms found in Appendix E.

• Deficiencies noted will be tracked for corrective action through the Environmental Management System (EMS).

• Access to monitored outfalls is difficult due to a steep slope and requires 2 persons for safety. Collection of a visual sample from the location can sometimes cause disturbance of the surrounding area, leading to leaves and soil / sediment sometimes entering the sampling container. If funding can be secured, recommend the design and installation of a structure that would allow safe collection of undisturbed samples.

Annual Analytical Sampling

Pursuant to Permit No. ILR00-2630 Section C.2, NSGL shall perform annual analysis of discharges to verify that the industrial area is not contributing to contamination associated with 303(d) impairments. Sampling will be from Outfall SCR07 (formerly OF15) and SCR05.

BMPs:

• Environmental Department personnel or supporting contractors will collect samples for analysis and will review analytical results.

• Any elevated contaminants will be identified and follow-up investigations will be performed to determine the source(s) and develop corrective actions.

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Training

Employee training programs are used to inform personnel at all levels of responsibility of the components and goals of the SWPPP. Training should address each component of the SWPPP; including how and why tasks are to be implemented. The Hunt Storage Yard is a new area of monitoring / inspection. SWPPP training will be provided to staff in the 1st quarter of 2020, and annually thereafter.

Recordkeeping

Proper recordkeeping and recording of all information associated with storm water runoff is important to monitor the effectiveness of the SWPPP and to improve storm water management.

Existing BMPs:

Storm water reports including annual, quarterly, and monthly inspection reports in addition to spill data are kept on file for at least 3 years as required by the general permit.

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Figure 3:

HUNT MILITARY COMMUNITIES STORAGE YARD

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APPENDIX A:

GENERAL NPDES PERMIT NO. ILR00-2630

January 2020 Appendix A

January 2020 Appendix A

January 2020 Appendix B

APPENDIX B:

STORMWATER MONITORING WORK PLAN

(Continuation of Work under a Contract Option from 2018 Award)

Work Plan will be updated to reflect Jan 2020 SWPPP Updates.

* Excludes Appendix B SOPs * See Standalone Work Plan for Complete Document

UPDATE IN FUTURE YEARS AS APPROPRIATE

FOR OFFICIAL USE ONLY

STORMWATER MONITORING

WORK PLAN

Naval Station Great Lakes, Illinois

HGS Engineering, Inc.

1121 Noble Street

Anniston, AL 36201 Bruce R. Tucker

256.236.1848 T

256.239.2970 C

bruce@hgsengineeringinc.com

Environmental Monitoring and Technologies, Inc.

8100 N. Austin Avenue

Morton Grove, IL 60053-3203 Tim Witrzek

847.324.3320 T

twitrzek@emt.com

30 July 2018

Stormwater Monitoring Work Plan i

TABLE OF CONTENTS

List of Abbreviations ....................................................................................................... iii Section 1: Introduction

1.1 Current Operations

1.2 Monitoring Program Goals and Objectives

SECTION 2 : Monitoring Design and Methodology

2.1 Monthly Outfall Inspection

2.2 Quarterly Visual Observation

2.3 Annual Storm Event Sampling and AnalysisError! Bookmark not defined.

2.4 Sampling Methodology

2.3.1 Collection Methods

2.3.2 Sampling Handling

2.3.3 Laboratory Analyses

2.3.4 Quality Assurance/Quality Control

SECTION 3 : Reporting and Assessment

3.1 Monthly Inspection Reports

3.2 Quarterly Visual Sampling Reports

3.3 Comparison Report

3.2 Annual Report and Assessment

SECTION 4 : References

LIST OF TABLES

Table 1 Analytical parameters for annual monitoring Table 2 List of storm event monitoring parameters Table 3 Parameters and SOPs Table 4 Parameters and analytical laboratory methods

LIST OF FIGURES

Figure 1 Monthly Industrial Facility Storm Water Inspection Report Figure 2 NSGL Industrial SWPPP Outfall Inspection Log

LIST OF APPENDICES

Appendix A Standard Operating Procedures:

1) Surface Water Sampling EMT-SOP-GW-325 Rev 1 Effective October 13, 2016 ii

2) Storm Water Monitoring EMT-SOP-WW-352 Rev 1 Effective February 1,

3) Completion of Chain of Custody EMT-SOP-WW-242 Rev 9 Effective July 9,

4) EMT Analytical QC and Limits

5) Total Suspended Solids (Residue, Non-Filterable) and Volatile Suspended

Solids (VSS) EMT-SOP-I-047 Rev 10 Effective November 9, 2016

6) Total Kjeldahl Nitrogen EMT-SOP-I-006 Rev 8 Effective April 20, 2016

7) Total Phosphorous and Orthophosphate (Colorimetric Ascorbic Acid

Reduction) EMT-SOP-I-034 Rev 9 Effective August 8, 2016

8) A. Fecal Coliform by Membrane Filtration SOPM-007 FC-MF Rev 1 Effective

January 11, 2017 B. Microbiology Media Preparation SOPM-003 Media Prep Rev 1 Effective February 22, 2016 C. Membrane Filtration Technique SOPM-004 General MF Rev 0 Effective February 6, 2012

9) Chloride (Titrometric, Mercuric Nitrate) EMT-SOP-I-011 Rev 5 Effective September 21, 2016

10) Inorganic Anions by Chromatography EMT-SOP-I-029 Rev 11 Effective November 30, 2016

11) Oil and Grease Total and Polar/Non-Polar by Hexane (N-Hexane Extractible Material, Total and Silica Gel Treated) by Separatory Funnel Extraction and Gravimetry EMT-SOP-I-044 Rev 11 Effective January 13, 2016

12) Method 245.1/7470A. Mercury in Liquid Waste and Drinking Water EMT- SOP-I-102 Rev 17 Effective October 13, 2016

13) Determination of Trace Elements in Water and Wastes by Inductively Coupled Plasma-Mass Spectrometry (ICP-MS), Method 200.8 EMT-SOP-I-188 Rev 6 Effective November 9, 2016

14) Polychlorinated Biphenyls (PCBs) as Aroclors by Gas Chromatography Electron Capture Detection (GC/ECD) EMT-SOP-0-8080-608 Rev 5 Effective January 13, 2016

15) Field pH Measurements EMT-SOP-GW-323 Rev 1 Effective October 13, 2016

16) Dissolved Oxygen Measurements EMT-SOP-GW-314 Rev 1 Effective October

13, 2016

17) Field Turbidity Meter Measurements EMT-SOP-GW-326 Rev 1 Effective

February 1, 2016

18) Field Specific Conductivity Measurements EMT-SOP-GW-313 Rev 1

Effective October 13, 2016

19) Quality Assurance Manual Rev 16 Effective November 3, 2016 iii

LIST OF ABBREVIATIONS

BMP Best Management Practice

CWA Clean Water Act

DLA Defense Logistics Agency

DO Dissolved Oxygen

DQI Data Quality Indicators

EDD Electronic Data Deliverable

EMT Environmental Monitoring and Technologies, Inc.

GPS Global Positioning System

LCS Laboratory Control Sample

LCSD Laboratory Control Sample Duplicates

LIMS Laboratory Information Management Systems

MS Matrix Spike

MS4 Municipal Separate Storm Sewer System

MSD Matrix Spike Duplicates

NAVFAC Naval Facilities Engineering Command

NPDES National Pollutant Discharge Elimination System

NSGL Naval Station Great Lakes

NTR Navy Technical Representative

PCBs Polychlorinated Biphenyls

QC Quality Control

RPD Relative Percent Difference

RSD Relative Standard Deviations

SOP Standard Operating Procedure

SWPPP Strom Water Pollution Prevention Plan

TKN Total Kjeldahl Nitrogen

TPH Total Petroleum Hydrocarbons

TSS Total Suspended Solids

SECTION 1: INTRODUCTION

Naval Station Great Lakes (NSGL) currently operates under the state’s National Pollutant Discharge Elimination System (NPDES) Storm Water Industrial Activity permit (permit number ILR00). It is essential that NAVFAC continues to ensure that stormwater from their properties is not adding pollutants to the receiving waters and that installed Best Management Practices (BMPs) are functioning properly. On behalf of NAVFAC, HGS Engineering, Inc. (HGS) and Environmental Monitoring Technologies, Inc. (EMT) (herein referred to as the HGS Team) will create and implement, throughout the second half of 2018, a Stormwater Monitoring Program that supports their NPDES permitting requirements, as well as establishes a baseline of stormwater quality data. The HGS Team will work with NAVFAC to ensure that the monitoring program meets the requirements of the permit and the needs of NSGL are implemented.

1.1 Current Operations

NSGL complies with the industrial NPDES requirements through the “Naval Station Great Lakes Storm Water Pollution Prevention Plan (SWPPP) for Storm Water Discharges from Industrial Activities 2017-2020” revised September 2017 by the Environmental Division, Public Works Department, Naval Station Great Lakes. The permit requires monthly outfall inspections, quarterly visual observation, and annual sampling and analysis at four outfalls located at the Marina Fueling Site/Private Boat Storage Area (3 outfalls) and the Defense Logistics Agency (DLA) Scrap Yard (1 outfall). The HGS Team proposes to continue this permit compliance, as described under Section 2: Monitoring Design and Methodology.

1.2 Monitoring Program Goals and Objectives

HGS and EMT will work closely with NAVFAC to: i) ensure that current NPDES monitoring requirements are met at select NSGL industrial areas and ii) provide a comparison of storm water quality to 303(d) impaired water data at select NSGL locations using information collected during the 2018 monitoring efforts (i.e., monthly outfall inspections, quarterly visual observation, and annual sample collection and analysis).

SECTION 2: MONITORING DESIGN AND METHODOLOGY

Three monitoring programs, monthly outfall inspections, quarterly visual observations, and annual storm event sampling and analysis, will be conducted to verify outfall maintenance, identify potential pollutant impacts in storm water discharge, and compare data to 303(d) impaired water parameters and support NPDES compliance, including the current General NPDES Permit No.

ILR00 for Storm Water Discharges from Industrial Activities. Each monitoring program is described below, with further description provided on each sampling location, including parameters for laboratory testing and frequency. Standard Operating Procedures (SOPs), quality assurance, and chain of custody are described further below and included in Appendix A.

2.1 Monthly Outfall Inspection

The HGS Team will conduct monthly industrial facility outfall inspections at the four designated storm water discharge locations. Inspections will be documented to reflect the potential storm water pollution sources and best management practices employed to minimize or eliminate the potential impacts posed by these sources. Inspections are documented using the Monthly Industrial Facility Storm Water Inspection Report (Figure 1) for both the Marina & Private Boat Storage Area and the DRMO/DLA Scrap Yard.

2.2 Quarterly Visual Observation

The HGS Team will complete two full quarters (3Q & 4Q, CY18) of visual monitoring at 4 sample locations, as shown on Figure 2, NSGL SWP3, for the Pettibone Creek and Lake Michigan watersheds and Figure 3, NSGL SWP3, for the Skokie River watershed, to establish a baseline of stormwater quality data. A field technician will mobilize to each of the outfalls within 1 hour or as soon as practicable after the first hour of a precipitation event greater than or equal to 0.25 inch in a 24-hour period. During one of the quarterly visual monitoring events, stormwater samples will be collected to meet the annual sampling and analysis requirement. The 4 sample locations include one point (OF-33) within the Pettibone Creek watershed, two points (OF-31, OF-32) within the Lake Michigan watershed, and one point (OF-15) within the Skokie River.

2.3 Annual Storm Event Sampling and Analysis

Table 1 presents a summary of the analytical parameters for annual monitoring for each receiving waterbody (i.e., Pettibone Creek, Lake Michigan, and the Skokie River). The analytical parameters have been identified based on examining the following factors: i) land use; ii) industrial activities within the drained area; iii) the receiving waterbody (Pettibone, Lake Michigan, or Skokie); iv) the impairments of the receiving waterbody; and v) other pertinent available data.

The annual stormwater samples are analyzed for these parameters to demonstrate the effect of land use on water quality and to compare the results to 303(d) impairment in the receiving waters. These parameters include total suspended solids (TSS), total phosphorus, fecal coliform, chlorides, and the impaired pollutants of the receiving water body, as needed.