Att_4_-_EPA-RTP_SWPP_Plan.pdf

Stormwater Pollution Prevention Plan

October 29, 2013

Office of Administration and Resource Management (OARM) and

Office of Research and Development (ORD)

Safety, Health and Environmental Management Office

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

Attachment 4

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Research Triangle Park (RTP) Campus

Stormwater Pollution Prevention Plan (SWPPP)

October 2013

1. Introduction

2. Contact Information / Responsible Parties

2.1 Stormwater Pollution Prevention Team

3. Definitions

4. Facility Description and Layout

4.1 Facility Operations

4.2 Outfalls & Site Drainage

4.2.1 Research and Administration Facility

4.2.2 National Computer Center (NCC)

4.2.3 First Environments Early Learning Center (FEELC)

5. Potential Pollutant Sources

5.1 Industrial Activity and Associated Pollutants

5.1.1 Hazardous Waste Management

5.1.2 Pesticides & Fertilizers

5.1.3 Highbay Building

5.1.4 Loading/Unloading Deliveries

5.1.5 Outdoor Storage Area/Old Jenkins Road

5.1.6 Petroleum Storage Tanks

5.2 Spills and Leaks

5.2.1 Maintenance of Spill Response and Containment Materials

5.2.2 EPA-RTP Spill Response

5.2.3 EPA-RTP Spill History

5.3 Non-Stormwater Discharges

5.3.1 Authorized non-stormwater discharges

5.3.2 Unauthorized non-stormwater discharges

6. Best management practices

6.1 Stormwater Management Systems

6.2 Good Housekeeping

6.3 Inspection & Maintenance

6.3.1 Stormwater Drains - Parking Decks, Areaways, and the Courtyard

6.3.2 Stormwater Drains – Highbay Fuel Farm

6.3.3 Stormwater drains – Loading/Unloading Trench drains

6.3.4 Roof Drains

6.3.5 Wet Retention Basins & Bioretention Cells

6.3.6 FEELC Rain Cisterns

6.4 Erosion and Sediment Controls

6.5 Staff Training

7. Stormwater management deficiencies & corrective action plan

8. Construction & LAND disturbance

9. Certification / Annual Review

Stormwater Pollution Prevention Plan Page i

EPA Research and Administration Campus, RTP, North Carolina October 2013

Appendices

Appendix A Site Location Map Appendix B Facility Site Map Appendix C Emergency Spill Equipment Appendix D Standard Operating Procedure: Response to Releases and Spills Appendix E Spill Remediation Agreement Appendix F Monthly Visual Inspection Form

Tables

Table 2.1 Stormwater Pollution Prevention Team Table 5.1 Potential Pollutants Table 5.2 EPA-RTP Spill History Table 6.1 Stormwater Management Systems

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Plan Updates & Reviews

Plan Review Date Reviewer Reviewer Signature Updates Made

1 Oct. 2013 - Original plan.

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1. INTRODUCTION

This Stormwater Pollution Prevention Plan (SWPPP) has been prepared for the Environmental Protection Agency in Research Triangle Park, North Carolina (EPA-RTP) as a best management practice to control and monitor activities on-site which may affect stormwater discharges from the EPA-RTP facility. While EPA-RTP is not regulated under either state or federal stormwater regulations; development and implementation of this plan is part of an EPA-RTP initiative and best management practice, with the intent to align its standards with EPA’s 2008 Multi-Sector General Permit (MSGP).

The purpose of this SWPPP is to describe the existing activities on-site, temporary and permanent erosion and sediment control (TESC) measures, pollution prevention measures, inspection/monitoring activities, and recordkeeping that will be implemented. The objectives of the SWPPP are to:

1. Implement Best Management Practices (BMPs) to prevent erosion and sedimentation, and to identify, reduce, eliminate or prevent stormwater contamination and water pollution from daily activities.

2. Prevent violations of surface water quality, ground water quality, or sediment management standards.

3. Prevent adverse water quality impacts including impacts on beneficial uses of the receiving water by controlling peak flow rates and volumes of stormwater runoff at the outfalls and downstream of the outfalls.

4. Develop a stormwater corrective action plan to address noted stormwater management concerns (see section 7).

This plan is designed to work in conjunction with the following plans and policies adopted by the EPA-RTP:

EPA RTP Campus Facility Plan Purpose Spill Prevention, Control and Countermeasures (SPCC) Plan

Prevent oil discharges from reaching navigable waters of the United States or adjoining shorelines.

Slug and Spill Control and Prevention (SSCPP) Plan

Prevent discharges from entering the sanitary sewer system.

The requirements and procedures outlined in this SWPPP are applicable to, and shall be observed by all government, cooperative agreement, and contractor personnel working at the facility or providing support to the facility.

In order to properly convey these requirements and provide adequate reference throughout the facility, hardcopies of the complete SWPPP are available at the locations outlined below, and an electronic copy is available on the OARM SHEM intranet site.

Stormwater Pollution Prevention Plan Page 1 EPA Research and Administration Campus, RTP, North Carolina October 2013 http://cfpub.epa.gov/npdes/stormwater/msgp.cfm http://intranet.epa.gov/rtp/orgs/hssd/info.htm

Plan No. Location Custodian 1 EPA-RTP Office of Administration and

Resources Management (OARM), Facility Management and Support Division (FMSD)

Shawn Lafferty, Safety and Occupational Health Manager

2 EPA-RTP OARM FMSD Bill Gaines, O&M Project Manager 3 EPA-RTP OARM FMSD Office Copy 4 EPA-RTP OARM FMSD Pete Scubert, Landscaping Project

Manager/ OARM EMS Representative 5 EPA-RTP Office of Research and

Development (ORD), Safety, Health and Environmental Management (SHEM) Office

Alan Call, Environmental Compliance Coordinator

6 EPA-RTP High Bay Building Richard Valentine, High Bay Building Manager

This document must be reviewed annually and amended whenever there is a change in design, construction, operation or maintenance, which has a significant effect on the potential for the discharge of pollutants, or if the Stormwater Pollution Prevention Plan (SWPPP) proves ineffective in achieving the general objectives of controlling pollutants in stormwater discharges associated with industrial activity.

2. CONTACT INFORMATION / RESPONSIBLE PARTIES

Facility Name: U.S. EPA, Research Triangle Park, Research and Administration Facility

Owner / Operator: U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460

Facility Physical Address: 109 T.W. Alexander Drive Research Triangle Park, NC 27711 Durham County

Facility Latitude 35 Degrees 52 Minutes 57 Seconds Facility Longitude: 78 Degrees 52 Minutes 27 Seconds Facility Telephone Number, 24-hour Line: (919) 541-2900, Facility Security

Facility SWPPP Contact:

Shawn Lafferty OARM SHEM Occupational Health and Safety Manager Phone #: 919-541-5449 Fax #: 919-685-3449 Email: lafferty.shawn@epa.gov

Stormwater Pollution Prevention Plan Page 2 mailto:lafferty.shawn@epa.gov

2.1 Stormwater Pollution Prevention Team

The EPA-RTP Stormwater Pollution Prevention Team is responsible for assisting the OARM Occupational Health and Safety Manager in developing and revising the facility’s SWPPP, for implementing and maintaining control measures and best management practices (BMPs), and taking corrective action where required. The Stormwater Pollution Prevention Team will meet at least annually, and as unauthorized non-stormwater discharges or other concerns are identified.

Training requirements for the Stormwater Pollution Prevention Team is detailed in Section 6.5 of this plan. The team consists of the following:

Table 2.1 – Stormwater Pollution Prevention Team Facility Personnel Phone #

FMSD Director Alex Montilla 919-541-0324 Occupational Health & Safety Manager, OARM Shawn Lafferty 919-541-5449 Environmental Compliance Coordinator, ORD Alan Call 919-541-3690 High Bay Building Representative Richard Valentine 919-541-4437 Preventative Maintenance/Facility Manager Carol Purvis 919-541-7519 Landscaping Project Manager/ OARM EMS Representative

Peter Schubert 919-541-7526

O&M Project Manager Bill Gaines 919-541-3563 Janitorial Project Manager Al Little 919-541-5107

3. DEFINITIONS

Industrial Activity - Industrial Activity, for the purposes of this plan, is defined as facility related activities which occur outdoors and are exposed to the elements. Activities may include loading and unloading operations, outdoor storage, outdoor process activities, dust or particulate generating processes, non stormwater discharges (see Section 5.3), and waste management.

Bioretention Cells - A bioretention cell or rain garden is a depressed area with porous backfill (material used to refill an excavation) under a vegetated surface. These cells often have an underdrain to encourage filtration and infiltration, especially in clayey soils. Bioretention cells provide groundwater recharge, pollutant removal, and runoff detention.

Constructed Wetlands – A constructed wetland, for the purposes of this plan only, are locations onsite which were originally designated to become bioretention cells; however, due to inappropriate soil additions and inappropriate or no plantings, do not currently work as designed.

Vegetated Filter Strips - Filter strips are bands of dense vegetation planted downstream of a runoff source. The use of natural or engineered filter strips is limited to gently sloping areas where vegetative cover can be established and channelized flow is not likely to develop.

Wet Retention Ponds - Wet retention ponds (a.k.a. stormwater ponds, wet ponds, wet extended detention ponds) are constructed basins that have a permanent pool of water throughout the year (or at least throughout the wet season). Ponds treat incoming stormwater runoff by allowing particles to settle and

Stormwater Pollution Prevention Plan Page 3 algae to take up nutrients. The primary removal mechanism is settling as stormwater runoff resides in this pool, and pollutant uptake, particularly of nutrients, also occurs through biological activity in the pond.

4. FACILITY DESCRIPTION AND LAYOUT

The EPA-RTP campus is located on a 132-acre site in Research Triangle Park, Durham County, NC. The site is bounded by Discovery Lake and the National Institute of Environmental Health Sciences (NIEHS) to the West; the NIEHS and North Carolina State Highway 54 and 147 to the North; the Triangle Expressway to the East and Hopson Road to the South. The site contains a 23-acre manmade lake formed by the damming of a small tributary of Burdens Creek. The main EPA campus, the Research and Administration Facility, sits on the east side of the lake and is comprised of six buildings, two parking structures and associated surface parking lots. Across from East Loop Road, to the northeast is the EPA’s National Computer Center (NCC), the First Environments Early Learning Center (FEELC) and a surface parking lot.

The remainder of the site is undeveloped, except for a portion of abandoned Jenkins Road which is being used for outdoor storage and field testing facilities. Facility location and site maps are available in Appendix A and B.

Is this facility considered a Federal Facility? Yes No Does this facility discharge stormwater into a Municipal Separate Storm Sewer (MS4)? Yes No Name(s) of water(s) that receive stormwater from your Facility: Burdens Creek, Cape Fear River Basin Receiving water(s) class: WS-IV NSW1

Receiving water(s) TMDL: Nitrogen & Phosphorus

4.1 Facility Operations

No production or commercial activities are conducted at this facility. The activities performed relate solely to research and all associated administrative and regulatory support. EPA-RTP has three

(3) laboratories conducting research and two (2) administrative offices. The three national laboratories that operate out of EPA-RTP include the National Exposure Research Laboratory (NERL), the National Health and Environmental Effects Research Laboratory (NHEERL) and the National Risk Management Research Laboratory – Air Pollution Prevention Control Division

(NRMRL-APPCD).

NRMRL-APPCD investigates the combustion of various materials, reagent grade chemicals, and fuel oil. The building occupied by APPCD (Highbay building) houses several research combustion units and a Flue Gas Cleaning System (FGCS) for air emissions control. Due to the research nature of these activities they are exempt from air emissions permitting.

In addition to research activities on site, EPA-RTP employs operations and maintenance (O&M), custodial and grounds staff for day to day operations of the facility. Activities include building

1 Receiving waters class was obtained from the NC DENR NC Water Quality Classifications for the Cape Fear River Basin.

WSIV is a water body designated as a source of water supply for drinking, culinary or food processing and are generally in moderately to highly developed watersheds or Protected Areas; NSW designates a Nutrient Sensitive Water, requiring additional nutrient management.

Stormwater Pollution Prevention Plan Page 4 http://portal.ncdenr.org/c/document_library/get_file?uuid=10c60296-dcc8-439f-a41c-d475ea7ad1fa&groupId=38364 maintenance, cleaning, grounds maintenance, and small construction jobs. The facility also has loading/unloading operations, aboveground and underground storage tanks for use by both research and facilities operations, covered drum storage, coal storage and small storage buildings for equipment, tanks or other materials.

4.2 Outfalls & Site Drainage

The site drainage system includes a variety of stormwater routings with the ultimate outlet going into the Burdens Creek subbasin of the Northeast Creek subbasin in the Cape Fear drainage basin. Drainage from the site is directed into an underground storm sewer system or discharged directly to grade. The storm sewer system may be directed to the lake or connected to one of the numerous stormwater management systems on-site, which includes four (4) bioretention cells, three (3) wet retention ponds, and seven (7) constructed wetlands. The Facility Site Map detailing the storm sewer system, including locations of bioretention cells, wet retention ponds, constructed wetlands and outfalls, is located in Appendix B.

4.2.1 Research and Administration Facility

The research and administration facility consists of six buildings (separated into 4 sections for this Plan: North Lab/Office Building, administration building, South Lab/Office Building and the Highbay Building), two parking garages and two surface parking lots.

The stormwater drainage from the east portion the Highbay Building and the South Parking Garage, and the south portion of the South Surface Lot discharge into the pre-existing wetland area upstream of Wet Detention Pond 1. The drainage from the northeast portion of the South Lab/Office Building, the south portion of the courtyard, the remainder of the South Parking Garage and Highbay Building and the South Office/Lab Building discharge into Wet Detention Pond 1.

The stormwater drainage from the North Parking Garage, the southeast portion of the North Lab/Office Building and the North Parking Garage discharges directly into the lake. The visitor’s surface lot flows into Constructed Wetland 6. The drainage from the west portion of the South Lab/Office Building flows directly into the lake.

4.2.2 National Computer Center (NCC)

Parking lot drainage from the NCC discharges to Wet Retention Pond 2, located northwest of the intersection of East Loop Road and North Loop Road. Wet Retention Pond 2 releases into the unnamed tributary of Burden’s Creek, north of the Discovery Lake dam. Roof drainage and limited parking lot drainage is discharged to Wet Retention Pond 3, located north of the NCC building.

Wet Retention Pond 3 also releases into the Burdens Creek drainage system.

4.2.3 First Environments Early Learning Center (FEELC)

FEELC’s stormwater drainage, including roof and parking lot drainage, is drained toward Bioretention Cell 11, which is then carried to the lake through the storm sewer system serving the north surface lot of the Main Building. Additionally, the FEELC collects rain water from a portion of

Stormwater Pollution Prevention Plan Page 5 the center’s roof in two (2) 1,500-gallon rain cisterns, which is used to irrigate food gardens within the FEELC playground.

5. POTENTIAL POLLUTANT SOURCES

5.1 Industrial Activity and Associated Pollutants

This section includes all industrial activities on site. Those industrial activities with a potential to impact stormwater have been briefly described below.

5.1.1 Hazardous Waste Management

EPA-RTP shares a RCRA Part B permit for the storage of hazardous waste with the National Institute of Environmental Health Sciences (NIEHS); waste management storage activities are conducted at NIEHS. EPA-RTP does have two permitted hazardous waste management units on-site (Chemical Service Areas), which are storage and bulking areas for hazardous waste and are located indoors. Waste generated throughout the EPA-RTP campus is routed through one of these two Chemical Service Areas prior to transferring to the main hazardous waste storage building on the NIEHS campus prior to ultimate disposal. All waste management areas are inspected by qualified environmental, health and safety professionals from the ORD SHEM Office on a weekly basis, using a standardized form to assist the auditor in assessing storage practices, duration of storage, compatibility, secondary containment, and general housekeeping. Past inspection logs are kept on file for reference, and are available upon request.

5.1.2 Pesticides & Fertilizers

Pesticides and fertilizers are utilized throughout the site. Pesticides include insecticides, herbicides, and fungicides. These chemicals are not stored at EPA-RTP but are applied on the grounds by a licensed contractor per manufacturer instructions. Fertilizers are generally not used on-site; however, occasional application may occur. EPA-RTP does have an Integrated Pesticide Management Plan dated June 2013 and maintains a pesticide application log, which is available upon request.

5.1.3 Highbay Building

The Highbay building conducts large scale pilot air pollution control technology research and uses numerous different types of combustion materials in its research activities. As part of this research the facility stores, up to a total of 64, 55-gallon drums of miscellaneous fuel oil and coolants located in a covered outdoor storage area next to the Highbay building. The Highbay also stores coal for its research activities, which is stored in an outdoor storage area in a covered space. All of the combustors in the Highbay are mainfolded into a dedicated Air Pollution Control System (APCS).

The APCS consists of a 1.2 MW (4,000,000 Btu/hr) thermal input afterburner followed by a spray quench, baghouse, and wet scrubber. The APCS will remove excess hazardous organic air pollutants, acid gases and particulate matter as required by current North Carolina regulations. The scrubber filter media are routinely changed out and disposed of appropriately through Chemical Services, depending on the type of research being conducted.

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5.1.4 Loading/Unloading Deliveries

There are four loading/unloading docks at EPA-RTP; two of which are used for the majority of material receipt into the facility (Building A and E loading docks). These two primary loading dock areas both have a chemical receiving area where chemicals brought on-site are received and stored until requested by laboratory staff. The loading dock in Building C is primarily used for the café, janitorial and O&M contractor’s material receipt. Chemicals may be delivered to this dock;

however, in much smaller quantities and generally consist of cleaning chemicals. Additionally, the Building C loading dock houses EPA-RTP trash, material to be composted, recycling, kitchen waste grease oil, and the main storage room for universal waste lamps is also within the Building C loading dock. The NCC also has a loading dock which primarily receives office equipment, as well as batteries for use in UPS systems on site.

The outdoor drains in all loading dock areas are stormwater drains; however, spill equipment, including socks and/or booms are present at all loading docks to prevent a spill from reaching the drain. See Appendix D for spill response procedures.

5.1.5 Outdoor Storage Area/Old Jenkins Road

EPA-RTP also utilizes an outdoor storage area located off of the abandoned Jenkins Road.

Outdoor storage consists mostly of parked, covered trailers used for various research and development travel related activities and small storage buildings; however, there is also a coal pulverizer, coal storage, sand storage for inclement weather, and recycling collection.

Coal is transported to the outdoor storage area from numerous off-site locations for research and development activities for use in the Highbay building. The coal must be stored in covered totes or in open dumpsters. Dumpsters are placed under shelter whenever feasible or are covered with a tarp. Coal dust is a byproduct of this outdoor operation.

The sand is stored outdoors near the entrance to outdoor storage and is stored in a location where it is unlikely to reach any nearby waterways or storm drains. The sand is covered with a tarp when feasible. The sand is used during the winter months to provide better road conditions in icy weather and is removed at the end of the winter season.

The recycling collection is collected in numerous closed trash receptacles used for the collection of items for recycling, primarily household recycling items.

5.1.6 Petroleum Storage Tanks

EPA-RTP has ten (10) aboveground storage tanks (ASTs) and five (5) underground storage tanks (USTs) containing different types of fuel. In addition, the site has a covered drum storage area containing different test fuels/oils for research and development purposes. The site is required to have a Spill Prevention Control and Countermeasures (SPCC) Plan which details spill prevention and control procedures on-site. The site’s UST and AST locations are noted in Appendix B, and include tank location, capacity, construction, and product content.

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Table 5.1 - Potential Pollutants Industrial Activity Associated Pollutants

Petroleum Storage Tanks (AST & UST) & Drum Storage

Petroleum hydrocarbons

Drum Storage; Outdoor storage Petroleum hydrocarbons Outdoor storage Dust, Total Suspended Solids (TSS), Total

Dissolved Solids (TDS), turbidity, sulfates and iron.

Loading/Unloading operations Various pollutants Pesticide & Fertilizer Applications Insecticides, herbicides and fungicides, nitrates, and sulfates Hazardous Waste Accumulation Points Various pollutants

5.2 Spills and Leaks

Areas at EPA-RTP where spills are most likely to occur are detailed in the above section, Industrial Activity and Potential Pollutants, Section 5.1. The storage of petroleum fuels presents the largest source of potential spills and/or leaks; however, EPA-RTP has developed a Spill Prevention Control and Countermeasures (SPCC) Plan to address this potential. Additionally, a majority of other storage on site (such as research chemicals, mechanical systems, etc.) are located indoors and are not exposed to the elements, posing a minimal chance for spills or leaks to reach storm systems. Activities conducted outdoors, such as loading/unloading and the application of pesticides on-site are done so by trained employees and contractors. Refer to the EPA-RTP Integrated Pest Management Plan for a detailed description of pesticide application on site.

5.2.1 Maintenance of Spill Response and Containment Materials

The EPA-RTP Facility has a dedicated spill response supply room (E179B) directly across from the Chemical Services Area in Building E. In this room, multiple spill booms, pillows, mats, containers of various absorbents, personal protective equipment, spill response material and a spill cart (Appendix C contains an Emergency Spill Equipment inventory) are available. These materials can be transported from E179B to anywhere in the Main Building within five minutes. These spill response materials are inventoried and maintained by the SHEM Office.

Additionally, spill control materials are maintained around the campus in locations where the highest spill potential exists. Appendix C details the spill control materials and locations. For spills beyond the capabilities of EPA-RTP, EPA-RTP has a spill remediation agreement with a third party vendor, which is included in Appendix E for reference.

5.2.2 EPA-RTP Spill Response

In the unlikely event of a spill, EPA-RTP has established a general response procedure with the following priorities: (1) protect people from chemical exposure and other potential harm, (2) secure and isolate the area and prevent the point source from further discharge, (3) initiate the pre determined notification process and (4) clean the spill material. Spill guidance standard operating procedures (SOPs) can be found in Appendix D and are also detailed in the EPA-RTP Spill Prevention, Control and Countermeasures (SPCC) Plan and the Slug and Spill Control and

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Prevention (SSCPP) Plan.

For spill response outside of EPA-RTP capabilities, EPA-RTP has an emergency response contract with Agra Environmental.

5.2.3 EPA-RTP Spill History

The table below outlines EPA-RTP’s spill history. The table below shall be updated annually to describe any significant oil or toxic or hazardous pollutant spills/leaks that occur at EPA-RTP and are in exposed areas (i.e. outdoors) or that drain to a stormwater conveyance. A significant spill for the purposes of this plan is any spill which enters a stormwater conveyance system, is a reportable quantity per NC DENR, the Clean Water Act Section 311 (40 CFR 110.6 and 40 CFR 117.21) and/or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (42 USC §9602) or is a spill that had a reasonable chance of entering a nearby stormwater conveyance system or waterway.

Table 5.2 – EPA-RTP Spill History Date Spill Location Description* Outfall

12/30/2005 NCC Parking Lot, Contractor POV

5-10 gallons of gasoline were released to pavement due to a vehicle fire. The fire department extinguished the fire and an absorbent material was put down to clean up the spill.

N/A

1/18/2008 Hopson Rd. Guard Shack

Approximately 1 quart of motor oil leaked from a vehicle. Oil-Dri was used to absorb the oil, which was then swept up and properly disposed of.

N/A

* The description of the spill must include a description of the incident, the circumstances leading up to the release, actions taken in response to the release and measures to prevent a recurrence.

5.3 Non-Stormwater Discharges

A non-stormwater discharge is any discharge from the facility that is not composed entirely of rainfall or snowmelt runoff. Non-stormwater discharges often come from potable water sources or process wastewater discharges.

Upon initial site evaluation through visual observation and discussions with facility personnel, EPA-RTP evaluated all non-stormwater discharges. Upon review, the following non-stormwater discharges were identified:

5.3.1 Authorized non-stormwater discharges

Acceptable non-stormwater discharges from EPA-RTP, and allowed under EPA’s General Permit, include:

• Discharges from fire-fighting activities and authorized fire hydrant flushings;

• Potable water

• Uncontaminated condensate

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• Landscape watering, provided all pesticides, herbicides and fertilizers have been applied in accordance with approved labeling per the manufacturer;

• Pavement wash waters where no detergents are used and no spills or leaks of toxic or hazardous materials have occurred (unless spilled material has been removed);

5.3.2 Unauthorized non-stormwater discharges

Process waters discharged to the stormwater system which are not listed above in section 5.3.1 are considered “unauthorized non-stormwater discharges” and may include, but are not limited to sanitary sewer system overflows, high temperature hot water line breaks, water from washing vehicles or equipment, wash water with detergents, wash water from clean-up of loading docks or condensate from equipment blow-down. Process wastewater may not comingle with stormwater or enter storm drains; and must be collected in a tank for off-site disposal, or discharged to the sanitary sewer, with the written approval from the Durham County Triangle Wastewater Treatment Plant.

Upon initial evaluation, five unauthorized discharges were identified. The first discharge being a water/detergent solution used by Janitorial to spray goose feces from walkways throughout EPA RTP. This practice has since been stopped and Janitorial has been told to use only water with no detergent. Additionally, the main building exteriors are washed on an annual basis with a detergent; the onsite daycare is routinely washed due to algae growth on the exterior walls;

condensate from the building HVAC system is routed to a penthouse storm drain in D building; and high temperature ground water in the proximity of the underground hot water loop system is pumped out as necessary. Upon implementation of this SWPPP, the Stormwater Pollution Prevention Team will review the current unauthorized non-stormwater discharges and identify alternate procedures which would reduce or discontinue the pollutant load to stormwater.

The Stormwater Pollution Prevention Team will periodically review campus activities for unauthorized non-stormwater discharges and will meet to discuss and resolve identified discharges, as required.

6. BEST MANAGEMENT PRACTICES

EPA-RTP has developed an on-site stormwater management system and numerous best management practices to reduce the likelihood of pollutants from reaching the Burden’s Creek subbasin. This section further details those systems currently in place at EPA-RTP.

6.1 Stormwater Management Systems

The majority of stormwater at EPA-RTP flows into a series of stormwater management systems (i.e.

stormwater catchment basins, wet retention ponds, bioretention areas etc.), en route to Discovery Lake or an unnamed tributary to Burden’s Creek. Bioretention cells, wet detention ponds and constructed wetlands help to remove pollutants prior to reaching the on-site lake and/or Burden’s Creek. For those locations where stormwater is discharged directly to the lake, EPA-RTP minimizes the outdoor storage and/or

Stormwater Pollution Prevention Plan Page 10 industrial activities in these locations. The site map located in Appendix B illustrates the site’s stormwater flow, the stormwater management systems and industrial activities, while section 4.2 further discusses stormwater drainage on site.

EPA-RTP currently has four (4) bioretention cells, three (3) wet retention ponds, and seven (7) constructed wetlands which help the facility treat stormwater. The current stormwater treatment systems at EPA-RTP are a result of initial building design and construction, maintenance inadequacies, and limited post-construction alterations to correct these inadequacies (see Section 7 for more information). The table below summarizes the systems currently present on site.

Table 6.1 – Stormwater Management Systems

System ID Stormwater Management System Associated

Treatment Area*

Associated Outfall Initial Design Intent Current Function

CW-1 Bioretention Cell Constructed Wetland

For development in next phase of plan development.

For development in next phase of plan development.

CW-2 Bioretention Cell Constructed Wetland CW-3 Bioretention Cell Constructed Wetland CW-4 Bioretention Cell Constructed Wetland CW-5 Bioretention Cell Constructed Wetland CW-6 (BR-6) Bioretention Cell Constructed Wetland CW-7 (BR-7) Bioretention Cell Constructed Wetland BR-8 Bioretention Cell Bioretention Cell BR-9 Bioretention Cell Bioretention Cell BR-10 Bioretention Cell Bioretention Cell BR-11 Bioretention Cell Bioretention Cell WDP-1 Wet Retention Pond Wet Retention Pond WDP-2 Wet Retention Pond Wet Retention Pond WDP-3 Wet Retention Pond Wet Retention Pond *See Appendix B for reference.

6.2 Good Housekeeping

“Good housekeeping” refers to material and equipment organization, general cleanliness, and proper storage of materials. Good housekeeping is a necessity in order to reduce stormwater pollution. Good housekeeping measures practiced at EPA-RTP include:

unpermitted stormwater discharges;

are stored outdoors they must be covered;

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• Outdoor storage is prohibited unless it is covered;

• Maintain storm drains and keep clear of debris and liter;

• Vehicle maintenance and cleaning is not performed on-site.

6.3 Inspection & Maintenance

EPA-RTP has established a routine inspection and maintenance program for stormwater conveyance systems on-site, as well as locations where industrial activity occurs on-site. Any noticed deficiencies will be corrected as soon as practical. General stormwater facility walkthroughs are conducted monthly and are documented on the Monthly Visual Inspection Form, located in Appendix F and maintained in the OARM SHEM files. Additional stormwater maintenance inspections are listed below by each management system and are scheduled by the OARM Facilities Manager and the Landscaping Project Manager.

6.3.1 Stormwater Drains - Parking Decks, Areaways, and the Courtyard Stormwater drains throughout the EPA-RTP site are inspected by the O&M contractor and maintained annually. Inspection and maintenance programs are scheduled by the OARM Facilities/PM Manager. Inspections include checking for debris and obstructions which may prevent the drains from working properly and removing obstructions when noticed. In addition, any significant weeds or vegetation are to be removed and any debris collected and disposed of.

6.3.2 Stormwater Drains – Highbay Fuel Farm

Stormwater drain valves located in the Highbay Fuel Farm are maintained in a closed position at all times. After a rain event, the impounded runoff is inspected by Highbay personnel for an oily sheen or other abnormalities prior to opening the drain to be discharged to the stormwater management system (Wet Retention Pond 1) and ultimately to the lake. Stormwater drains in this area are inspected after rain events, as well as on a monthly basis during SPCC inspections. Any maintenance concerns are brought to the attention of the OARM Facility Management and Support (FMSD) Division.

6.3.3 Stormwater drains – Loading/Unloading Trench drains

Stormwater drains located at the Loading/Unloading areas are connected to the stormwater management system on site; however, spill kits are maintained at each loading/unloading area to react and contain a spill as necessary. All Loading/Unloading areas are inspected monthly by the OARM SHEM office.

6.3.4 Roof Drains

Roof drains are inspected and maintained twice per year by the O&M contractor to ensure there are no blockages and stormwater is flowing unobstructed. During inspections, all roof drains are inspected for debris and obstructions which would prevent the proper flow of stormwater.

Additionally, weep holes along the roof skylights are inspected for debris. Any noted obstructions are removed; debris is swept and removed; and drains are cleaned with a metal brush. In addition, any weeds or vegetation growing on the roof are removed.

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6.3.5 Wet Retention Basins & Bioretention Cells

Wet retention basins and bioretention cells are inspected monthly, after a 24 hour rain event (with greater than 1.0 in), by the landscaping contractor. During inspections, the wet retention basins are inspected for debris or trash; areas of bare soil or evidence of erosion; concerns with the inlet/outlet device (i.e. clogged/cracked pipe); concerns with the depth of soil (greater than the original design depth); & evidence of dead or dying plant life. Any noted concerns will be brought to the attention of the Landscaping Project Manager and will be corrected as feasible.

6.3.6 FEELC Rain Cisterns

FEELC Rain Cisterns are inspected monthly by FEELC staff to ensure there are no obstructions or other concerns and downspout filters are also inspected for debris or obstructions at least twice per year. The cisterns are emptied prior to any forecasted rain event and are winterized every fall to allow for flushing as well as to prevent freeze damage to associated piping. Additionally, it is recommended that rain water does not stay in the barrel for longer than one month.

6.4 Erosion and Sediment Controls

EPA-RTP controls erosion on site through proper landscaping and grading. All permeable surfaces are mulched, seeded or have vegetative cover. During monthly inspections, personnel will report if an area on site appears to have evidence of erosion or sediment dislodgement. This will be reported to the Landscaping Project Manager who will in turn remedy the situation.

6.5 Staff Training

Training will occur annually and can be combined with annual Spill Prevention Control and Countermeasures (SPCC) Plan training. Employees and contractors who work in areas where industrial activities or material handling activities are exposed to stormwater, who have inspection and/or maintenance responsibilities or are a part of the SWPPP Team are required to receive SWPPP training. In addition, FMSD project officers are also required to take annual SWPPP training. The training will cover the contents of this SWPPP, implementing pollution prevention/good housekeeping techniques, such as maintaining open/green spaces, building maintenance, new construction and land disturbances, and stormwater system maintenance;

inspection and maintenance activities; and proper spill response and cleanup procedures. The OARM SHEM Occupational Health and Safety Manager is responsible for ensuring this training is conducted. The training will be documented and maintained for a period of three years.

Additionally, the OARM Occupational Health & Safety Manager and at least one other SWPPP team member will obtain stormwater management training that includes a regulatory overview of federal stormwater regulations for both general industry and construction activities.

Furthermore, select EPA staff and contractors are fully trained in spill discovery, notification, minor response, and management in accordance with the OSHA HAZWOPER standards, which requires annual 8-hour refresher training. Furthermore, personnel involved in chemical storage and management activities are annually instructed in the laboratory operations required to minimize the discharge of chemicals, through SHEM refresher courses and site specific training.

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Appendix A – Site Location Map

Source: USGS 2013 US Topo Quadrangles: Southwest Durham, Southeast Durham, Green Level and Cary

Appendix A:

Site Location Map

US EPA-RTP

109 T.W. Alexander Drive

Appendix B – Facility Site Map

Appendix B:

Facility Site Map

US EPA-RTP

Research Triangle Park, NC

Source: EPA-RTP Stormwater Management Report – 2007, SSOE, Inc.

Appendix C –

Emergency Spill Equipment

Indoors, Spill Response Cart, Room HBB-106

Polyethylene Gloves, Pair Of Silver Shield Gloves, Chemical Splash Goggles, Dust Mask

Indoors, Room E179B Item Use

85-gallon overpack Overpacking leaking drums up to 55 gallons Universal spill pillows Absorbing of liquid spills Hg Absorb Mercury spill cleanup Storm drain guards Preventing spills from entering storm drains Sponges Decon and wipe-down Decon pools Decon line Face shields Face protection Drum liners (various sizes) Containment of spill wastes Booms (oil-only and universal) Absorption of spilled liquids and petroleum products Oil –only spill socks Absorption of spilled petroleum products Activated charcoal Liquid absorption and odor control Ram-Sorb © Absorption of spilled liquids Resisorb © Mercury Vapor Absorbent Mercury vapor control Mercon © Mercury Vapor Suppressant Mercury vapor control Acid neutralizer Neutralization of acid spills Base neutralizer Neutralization of caustic spills Oil-Dri Absorption of petroleum spills Sand Absorption of liquids and containment of spills Small hand pumps Transfer of liquids from containers Soda ash Absorption of spilled liquids Pig Peat Absorbent Absorption of spilled liquids Lite-Dri Absorbent Absorption of oils, coolants, solvents, water Petroleum sorbent rolls Absorption of petroleum spills Universal pads Absorption of spilled liquids Oil-only pads Absorption of petroleum spills Tyvek labcoats – non coated Protection from spill exposures Tyvek coveralls (Non-coated, QC coated, SL coated, and BR coated) Protection from spill exposures

Tyvek coveralls with booties and hood (SL coated) Protection from spill exposures Tyvek Sleeves (QC coated) Protection from spill exposures Tyvek boot covers (Non-coated and QC coated) Protection from spill exposures N95 masks Respiratory protection Duct tape Sealing of waste bags, securing plastic covers, etc Step ladder Brushes Decontamination Scoop(s) Transfer of solids and absorbed liquids pH strips Measurement of acidity or alkalinity Mop/Mop Bucket Cleanup/Decontamination Metal shovels Collection of solids or absorbed liquids Dust pan Collection of solids or absorbed liquids Push brooms Collection of solids or absorbed liquids Whisk broom Collection of solids or absorbed liquids Plastic shovel Collection of solids or absorbed liquids

Item Use Measuring Tape (100’) Measurement of distances for exclusion zones Tool Box (screwdrivers, utility knife, pliers, duct tape, hammers, caution tape) Various uses

Door chocks Holding doors open Small spray bottles Dispensing of decon solutions 5-gallon pails/lids Collection of spill wastes Rubber tie-downs Securing equipment Rope Securing equipment

Outdoors, Highbay Drum Storage Spill Control Shed

• 95-Gallon Overpack Drums

• Ultra Drain Covers

• Universal Spill Dikes

• Dri-Zorb Multi-Purpose Absorbent

• Anti-Static Scoop, 1 Quart Capacity

• 2-Piece Nonsparking Safety Shovel

• Broom

• Universal Plus Spill Sorbent Pads

• Hand Pump, Polyurethane Valves, Buna-N Seals, Vinyl Hose

• Nonsparking Standard Drum Plug Wrench

• Tyek Coveralls

• Nitrile Gloves

• Silver Shield Gloves

• Chemical Splash Goggles

• Chemical Splash Boot Covers

Outdoors, E-Building Spill Control Shed

• Universal Spill Dike

• Envirosorb Petroleum Drum Collars

• Oil-Dri Floor Absorbent

• Envirosorb Cellulose Pillows

• Tyvek Coveralls

• Nitrile Gloves

• Safety Glasses

• Broom

Outdoors, B-Building UST

• Sorbent Pads

• Sorbent Booms

• Large Trash Bags With Ties

• 20-Gallon Overpack

Outdoors, NCC UST

• Sorbent Pads

• Sorbent Booms

• Large Trash Bags With Ties

• 20-Gallon Overpack

Appendix D –

Standard Operating Procedure: Response to Releases and Spills

This is a guide designed to provide a list of steps to be taken by authorized EPA-RTP personnel upon the initial discovery of a material spill. Please note the clean-up of spills shall be conducted by designated, trained personnel only.

Upon discovery of a suspected spill, the initial responder(s) shall:

prepared to offer the following information: (1) injuries sustained, (2) material spilled and approximate quantity, (3) location, (4) estimated time, (5) direction of spill flow and proximity to a storm drain and/or a surface water.

3. From a safe area, attempt to identify the type and/or source of the discharge. During this time, prevent personnel from entering the immediate area and restrict access by placing caution tape (see Appendix C) around the hazard area. If it is apparent that the spill can be contained and conditions are safe for implementing countermeasures, proceed to steps 4 and 5.

4. Avoid direct contact with the spilled material at all times. Put on chemical resistant safety goggles and nitrile gloves. Using the Ultra Drain Seals and Universal Spill dikes, block potential flow to all stormwater drains in the immediate area. If material is spilling on the ground surface, proceed to step 5.

5. Avoid direct contact with the spilled material at all time. Dress in additional personal protective equipment, if necessary. Contain the spill using the Universal Spill Dikes, Dri-Zorb and Universal Sorbant to control/contain the flow and absorb the product. The Universal Spill Dikes can be used as a dam to contain the released product into a poll and prevent any further spreading of the spill.

The Universal Sorbent Pads and Dri-Zorb can be spread over the pool to absorb the spilled material.

6. After cleanup efforts have been completed, report all findings to the SHEM office, including a list of spill response equipment used, if any.

Emergency Contacts

Organization/Title Name/Phone Number Police/Ambulance/Fire/Emergency via EPA Security 1-2900 (919-541-2900) Local Fire Department/Fire Marshal – Parkwood FD 911

919-361-0927 (non-emergency) Triangle Wastewater Treatment Plant 919-544-8280 Facility SWPPP Contact Shawn Lafferty

919-541-5449 (w); 919-225-5387 (c) ORD SHEM Office 1-2613 (919-541-2613) SPCC Coordinator Alan Call

919-541-3690 Facility Manager Carol Purvis

919-541-7519 (w); 919-423-8500 (c)

A Spill of a Reportable Quantity

In accordance with North Carolina’s Oil Pollution Act, §143-215.85(a. and b.), a reportable quantity is defined as a petroleum discharge, release, or spill to the environment that meets one of the following conditions:

• Is 25 gallons or more;

• Causes a sheen on a surface water;

• Is 100 feet or less from a surface water; or

• Is less than 25 gallons released to the ground and not cleaned up within 24-hours.

If there is a non-petroleum spill to the environment, the ORD SHEM office must be notified immediately in order to determine if the spill meets any non-petroleum reportable quantity notification requirements, per

CERCLA.

If a reportable quantity is released, the following agencies must be notified:

Organization Phone Number

National Response Center 800-424-8802 North Carolina Emergency Management Division 800-858-0368 Durham County Fire Marshall & Emergency Management Agency

(LEPC)

919-560-0660

Upon notification, the reported may be asked to provide the following [40 CFR 112.7(a)(4)]:

• Exact address or location and phone number of facility,

• Date and time of the discharge,

• Type of material discharged,

• Estimate of the total quantity discharged,

• Source of the discharge,

• Description of all affected media,

• Cause of the discharge,

• Damages or injuries caused by the discharge,

• Actions being undertaken to stop, remove and mitigate the effects of the discharge,

• Whether an evacuation may be needed,

• Name and phone numbers of individuals and/or organizations that have also been contacted.

Appendix E –

Spill Remediation Agreement

Appendix F –

Monthly Visual Inspection Form

Facility Name EPA-RTP NPDES Tracking No. N/A Date of Inspection Insert Date Start/End Time Insert Start/End Time Inspector’s Name(s) Insert Name

Weather Information Weather at time of this inspection?

Clear Cloudy Rain Sleet Fog Snow High Winds Other: Approximate Temperature:

Have any previously unidentified discharges of pollutants occurred since the last inspection?

Yes No

If yes, describe: Describe

Are there any discharges occurring at the time of inspection? Yes No If yes, describe: Describe

Bioretention Areas

BR-8 BR-9 BR-10 BR-11

Assessment Comments / Corrective Action Needed

(identify needed maintenance and repairs, or any failed control measures that need replacement)

Overgrown Vegetation Yes No Plants are dead, diseased or dying

Yes No

Mulch is breaking down or is displaced

Yes No

Soils/mulch clogged with sediment

Yes No

Standing water (>24 hours after storm)

Yes No

Evidence of erosion Yes No

Wet Detention Ponds

WDP-1 WDP-2 WDP-3

Assessment Comments / Corrective Action Needed

(identify needed maintenance and repairs, or any failed control measures that need replacement)

Overgrown Vegetation Yes No Mulch is breaking down or is displaced

Yes No

The riser is blocked or filled with excess material (debris, trash, rocks, etc.)

Yes No

Assessment Comments / Corrective Action Needed

(identify needed maintenance and repairs, or any failed control measures that need replacement)

The riser is damaged/deteriorated.

Yes No

Evidence of algal growth or odors

Yes No

Evidence of erosion on embankment

Yes No

Evidence of structural damage to embankment

Yes No

Stormwater Outfalls Outfall A Outfall B Outfall C Outfall D Outfall E Outfall F Outfall G Outfall H Outfall I Outfall J Outfall K

Assessment Comments / Corrective Action Needed

(identify needed maintenance and repairs, or any failed control measures that need replacement)

Overgrown Vegetation Yes No Plants are dead, diseased or dying

Yes No

Evidence of algal growth or odors

Yes No

Color Yes No Evidence of Turbidity Yes No Presence of Floatables Yes No Sewage Suds and Foam Petroleum (oil sheen) Other Damage to outfall structure Yes No…