Attachment_V_-_Final_SWPPP.pdf

SWPPP

DFSP, CHARLESTON, SC AUGUST 2013

STORM WATER POLLUTION

PREVENTION PLAN

Defense Fuel Support Point – Charleston

5862 North Rhett Avenue Hanahan, SC 29406

(843) 744-3884

Shaw Environmental, Inc.

A CB&I Company

2526 Westcott Blvd.

Knoxville, TN 37931

August 2013

FOR OFFICIAL USE ONLY

Contents

1.0 INTRODUCTION

1.1 Background

1.2 SWPPP Content

2.0 SWPPP COORDINATOR AND DUTIES

3.0 FACILITY DESCRIPTION

3.1 Facility Location

3.2 Site Activities

3.3 Site Description

3.4 Storm Water Drainage System

3.4.1 Diked Areas Drainage

3.4.2 Truck Loading Rack Drainage Collection System

3.4.3 Rail Car Loading Rack Drainage Collection System

3.4.4 Truck Off-Loading Facility (Adjacent to Railcar Off-Loading Area)

3.4.5 Main Office / Laboratory Area

3.4.6 Western Section

3.4.7 Eastern Section

3.4.8 Southern Section

3.4.9 Other Drainage Areas of Note

3.4.9.1 Northern Section

3.4.9.1 Fuel Pier (TC Dock)

4.0 IDENTIFICATION OF POTENTIAL STORM WATER CONTAMINANTS

4.1 Significant Material Inventory

4.2 Spill History

4.3 Potential Areas for Storm Water Contamination

4.4 Summary of Available Storm Water Sampling Data

5.0 STORM WATER MANAGEMENT CONTROLS

5.1 Compliance with Other Programs

5.2 Storm Water Management Practices

5.3 Storm Water Treatment

5.4 Sediment and Erosion Control

6.0 FACILITY MONITORING PLAN

6.1 Maintenance Program

6.2 Self-Inspection

7.0 COMPLIANCE AND REPORTING REQUIREMENTS

7.1 SWPPP and SWPPP Summary

7.2 Employee Training

7.3 Implementation Schedule

7.4 Record Retention Requirements

7.5 Principal Executive Officer Signature

7.6 Provisions for Amendment of the Plan

Appendix A: INSPECTION LOGS Appendix B: BMPs

LIST OF TABLES

Table 1 Characteristics of Storm Water Drainage Table 2 Significant Materials Used or Stored at the Facility Table 3 Potential Sources of Storm water Contamination Table 4 DMR Results for May 2010 to April 2013 Table 5 Implementation Schedule

LIST OF FIGURES

Figure 1 Facility Location Figure 2 Tank Locations, Piping and Drainage Map

LIST OF ACRONYMS AND ABBREVIATIONS

AFFF aqueous film forming foam AST Aboveground Storage Tanks BMP Best Management Practice BTEX benzene, toluene, ethylbenzene, and xylenes CERCLA Comprehensive Environmental Response, Compensation and Liability Act CWA Clean Water Act DFSP Defense Fuel Support Point EPA United States Environmental Protection Agency FWPCA Federal Water Pollution Control Act GOCO government owned, contractor operated GPM gallons per minute KW kilowatt MCAS Marine Corps Air Station NPDES National Pollution Discharge Elimination System OWS oil/water separator PREP National Preparedness for Response Exercise Program RCRA Resource Conservation and Recovery Act SPCC Spill Prevention Control and Countermeasure SWPPP Storm Water Pollution Prevention Plan USAF United State Air Force WQA Water Quality Act

1.0 INTRODUCTION

1.1 Background

In 1972, Congress passed the Federal Water Pollution Control Act (FWPCA), also known as the Clean Water Act (CWA), to restore and maintain the quality of the nation’s waterways. The ultimate goal was to make sure that rivers and streams were fishable, swimmable, and drinkable. In 1987, the Water Quality Act (WQA) added provisions to the CWA that allowed the United States (U.S.) Environmental Protection Agency (EPA) to govern storm water discharges from industrial activities. EPA published the final notice for Phase I of the Multi-Sector General Storm Water Permit Program (Federal Register Volume 60, No. 189, September 20, 1995, page 50804), which included provisions for the development of a Storm Water Pollution Prevention Plan (SWPPP) by each industrial facility discharging storm water.

Development, implementation, and maintenance of the SWPPP will provide the Defense Fuel Support Point (DFSP) with the tools to reduce pollutants contained in storm water discharges and comply with the requirements of the National Pollution Discharge Elimination System (NPDES) permit issued by the State of South Carolina (Permit No. SC 340022). The primary goals of the SWPPP are to:

Identify potential sources of pollutants that affect storm water discharges from the site, Describe the practices that will be implemented to prevent or control the release of pollutants in storm water discharges, and Create an implementation schedule, if necessary

- To ensure that the practices described in this SWPPP are, in fact, implemented and

- To evaluate the plan’s effectiveness in reducing the pollutant levels in storm water discharges.

1.2 SWPPP Content

This SWPPP includes all of the following:

Identification of the SWPPP coordinator, with a description of the duties of the position Identification of the SWPPP implementation team members Description of the facility, including information regarding the facility’s location and activities as well as a site description, two maps, and a summary of the storm water drainage system Identification of potential storm water contaminants Description of storm water management controls and various Best Management Practices (BMPs) necessary to reduce pollutants in storm water discharge Description of the facility monitoring plan Description of the implementation schedule and provisions for amendment of the plan

Appendix A provides a list of best management practices (BMPs), and Appendix B includes an example facility inspection log sheets.

2.0 SWPPP COORDINATOR AND DUTIES

The SWPPP coordinator for the facility is Mr. Mike Schultz (phone number: 703-767-1959). Mr. Schultz’s duties will include the following:

Create an SWPPP team to aid in the implementation of the SWPPP Implement the SWPPP Oversee maintenance practices identified as BMPs in the SWPPP Implement and oversee employee training Conduct or provide for inspection or monitoring activities Identify other potential pollutant sources and make sure they are added to the plan Identify any deficiencies in the SWPPP and make sure they are corrected Prepare and submit reports Ensure that any changes in facility operation are addressed in the SWPPP

To aid in the implementation of the SWPPP, the additional members of the SWPPP team are John Gilmer, and Jerry Allen. John Gilmer, the Terminal Superintendent, will ensure that all housekeeping and monitoring procedures are implemented as well as ensure the integrity of the structural BMPs. Jerry Allen will perform periodic checks to ensure that structural BMPs are properly maintained and will inform the SWPPP coordinator concerning changes needed in the BMPs.

3.0 FACILITY DESCRIPTION

This section presents general facility information, such as location, an overview of operations, site description, and storm water drainage system.

3.1 Facility Location

The DFSP Charleston is located at 5862 North Rhett Avenue Extension in Hanahan, South Carolina. The site is physically located on a property owned by the U.S. Air Force (USAF) and is near the U.S. Navy Transportation Depot (located east of the Joint Base Charleston between Interstate 26 and U.S. Highways 52/78 and the Cooper River). The map coordinates are 32 degrees 54 minutes 24 seconds north latitude and 79 degrees 57 minutes 16 seconds west longitude. Figure 1 shows the location of the DFSP Charleston facility.

The facility is bordered on the east by the U.S. Army Reservation Charleston Depot, on the south by the Trident Industrial Park, on the west by the Berkeley Business Center, and on the north by the Gold Cup Springs residential subdivision. Within the Berkeley Business Center, the Gregory Poole Area, Charleston Rubber and Gasket, and Hanahan’s Restaurant are located to the west, outside the boundaries of the DFSP facility.

Responsible Government Agency Defense Logistics Agency (DLA)

Installation Support for Energy, Room 2828

8725 John J. Kingman Rd.

Ft. Belvoir, Virginia 22060-6222

Telephone (703) 767-8308 [Laura Fleming]

(703) 767-8331 [Fax]

Contract Operator: Hawthorne Services, Inc.

5862 N. Rhett Avenue Hanahan, SC 29410 Telephone (843) 744-3884

Person Accountable for Spill Prevention and Response:

Mr. John Gilmer Terminal Superintendent

The superintendent is the senior contractor employee and the Facility Incident Commander.

3.2 Site Activities

The DFSP is a government owned, contractor operated (GOCO) fuel storage and distribution terminal supplying military customers in Charleston and surrounding areas with Jet-A grade jet fuel. DFSP, located adjacent to the Cooper River, is capable of .

The terminals storage tanks are filled at the rate of from . The

DFSP is also capable of issuing product to as well as to Joint Base Charleston. The DFSP’s main customer, the Joint Base Charleston in Charleston, South Carolina, is located approximately 5 miles to the west and is supplied by .

Other customers are the Joint Base Charleston South Annex on Goose Creek, Marine Corps Air Station (MCAS) Beaufort, and Coast Guard and Air Force operating units in the area. The facility is capable of receiving and transferring petroleum product from

, using the government-owned DFSP Charleston has the coordinates:

Latitude – 32.9070, Longitude – 79.9541. Normal terminal working hours are 0600 to 1600, Monday through Friday.

3.3 Site Description

DFSP Charleston consists of a fuel storage terminal and . The fuel terminal consists of an office, . The facility also encompasses the , which includes two associated valving required to

The , approximately 5.3 miles long, runs from the DFSP to Joint Base Charleston with a .

3.4 Storm Water Drainage System

The fuel terminal can be divided into eight drainage areas. Figure 2 shows the location of the drainage areas and the observed drainage patterns. Table 1 provides a summary of storm water characteristics for each of eight drainage areas at the fuel terminal.

The fuel terminal is situated on sandy and silty soil, and the terrain in the area is relatively flat; hence, much of the rainwater does not run off but infiltrates to the ground. Surface runoff to the west enters municipal storm drainage systems for the area, and surface runoff to the east enters drainage ditches that discharge to Cooper River via Filbin Creek or Goose Creek. Two primary drainage ditches are located adjacent to the property at the eastern boundary near the Chessie-Seaboard railroad tracks. The northern drainage ditch along the eastern property line discharges to Goose Creek while the southern ditch along the eastern property line discharges to Filbin Creek. Storm water entering these ditches flows south toward Remount Road.

For spill control purposes, drainage collection and control systems are in place for areas at the fuel terminal and dock where fuel is stored or transferred. Release of drainage from the collection and control systems located at the fuel terminal is controlled by one or more oil/water separators (OWS) that discharge into the primary ditch located at the eastern boundary and Chessie-Seaboard railroad tracks. All controlled drainage exits the fuel terminal facility through a 4,500 gallons-per-minute (gpm) OWS.

Controlled drainage at the fuel pier from a fuel spill will be pumped to a 500-gallon AST .

3.4.1 Diked Areas Drainage

Each of the is enclosed with a dike structure constructed of concrete walls and floors. Each dike basin drains into an 8-inch line fitted with a manually operated gate valve. All the drain valves in the dikes are closed and locked when not in use. The drain pipes from each dike basin lead to a 4,500-gpm OWS. Flow is by gravity. The dike basins are inspected for floating product and are drained whenever accumulation of rainwater necessitates. A control log is maintained for dike basin draining. If needed, the recovered fuel can be pumped into a 10,000 gallon AST using a portable pump or can be sent off-site for disposal. A 1,000 gallon mobile petroleum contact tank is stored within the bulk storage tank secondary containment areas.

3.4.2 Truck Loading Rack Drainage Collection System

Spill containment and drip collection for the is provided by concrete curbing, a wet well, a 50-gpm sump and transfer pump, and a 12,000-gallon, non-regulated underground OWS tank. The loading racks are underlain by a concrete pad that drains to the concrete wet well through a line with a valve that is normally closed. Truck loading is a manned operation that allows quick response in case of a spill. Storm water is normally treated in an OWS and discharged to NPDES-permitted Outfall 001 though the 4,500-gpm OWS.

Immediately to the north of the is a pump station. This pump station is provided with a concrete base and secondary containment curb. Inside this containment are three horizontal fuel additive ASTs that include SDA1 (180 gal), CI1 (180 gal), and FSII (8,000 gal). A 524 gallon horizontal Jet-A reclaim AST is also situated within the containment area. This containment system drains to the facility OWS system and ultimately to Outfall 001.

3.4.3 , Drainage-Collection System

Spill containment and drip collection for the is provided by fiberglass pans and drains, concrete curbing, bituminous paving, a 20,000-gallon holding trench, and a 500-gpm OWS. The racks drain into a 500-gpm OWS, then into a 4,500-gpm OWS, and is eventually discharged to NPDES permitted Outfall 001. Any product accumulated in this OWS is pumped to a 10,000-gallon AST equipped with automatic shut off. Concrete secondary containment for this AST has a capacity of 15,000 gallons.

Immediately adjacent to the is a pump station. This pump station is provided with a concrete base and secondary containment curb. Inside this containment are five horizontal fuel additive ASTs that include CI2 and CI3 (both 180 gal), SDA2 and SDA3 (both 180 gal), and FSII (8,000 gal). A 500 gallon horizontal Jet-A pressure relief tank is also situated within this area. Also situated within the pump station area are two mixing tanks A and B that are out of service. This containment system drains to the facility OWS system and ultimate to Outfall 001. The main, 8-inch, aboveground Jet-A issue pipe to Joint Base Charleston originates at the pump station and is routed to the south adjacent to the rail lines, and then toward N Rhett Avenue parallel to the eastern fence-line of the fuel terminal.

3.4.4 )

Spill containment and drip collection for the facility is provided by means of curbs and a sloped entrance and exit slab, with a central trench drain that empties to a concrete catchment basin. The catchment basin is of sufficient size to hold the entire contents of a fuel truck (approx. 10,000 gallons).

Liquids from this area drain to the adjacent 1,000-gallon, underground, Fuel Lift Station basin. A 1,000-gallon horizontal diesel AST is located in the vicinity. This tank, which has a concrete base and containment walls, drains to the 1,000-gallon underground Fuel Lift Station basin and is drained by gravity to an OWS prior to discharge through NPDES permitted Outfall 001.

3.4.5 Main Office / Laboratory Area

The area surrounding the main office and laboratory is mostly grassy, but is bordered by paved roads and parking areas. This area contains Transformer No. 7 with a dielectric oil capacity of 200 gallons. Storm water from this area enters municipal storm water drainage systems located on North Rhett Ave through a valved drainage pipe at unregulated Outfall 003. The drainage valve is normally open. The laboratory sink drains into a 280-gallon, horizontal tank located just outside the laboratory building. The tank is provided with a concrete base and curbing. A dumpster, equipped with lid, is stored near the main office area.

3.4.6 Western Section

The western section of the facility is primarily paved and contains Transformer Nos. 2, 3, and 4, offering dielectric oil capacities of 160, 160, and 217 gallons, respectively. A 250 kilowatt (KW) generator with a 1,000-gallon, diesel-fuel, belly tank is located just outside and along the southwest corner of the Tank 7 containment berm. Storm water from this area enters municipal storm water drainage systems located on North Rhett Avenue through three valved drainage pipes at unregulated Outfalls 004, 005, and 006. The drainage valves are normally open. Other operations of note within this drainage area include the

Dual-Phase SVE pad (groundwater remediation system), battery room (enclosed building), and Fire Foam Building No. 10 (houses a 300-gallon aqueous film forming foam (AFFF) AST.

3.4.7 Eastern Section

The eastern section of the facility is primarily grass, with some areas of paved road, a gravel area surrounding the rail road tracks, and Transformer Nos. 1, 5, and 6, with dielectric oil capacities of 117, 200, and <50 gallons, respectively. A horizontal, 250-gallon AST (T-101) associated with the Groundwater Treatment Plant is located in the northern portion of this area. The main facility OWS is also located in this area, along with a 10,000-gallon, water-bottom storage AST (provided with concrete containment). A small, 200-gallon mobile petroleum contact water tank is typically staged within the containment area at this tank. One of the OWS pumps is powered by a diesel engine with an associated 250-gallon, diesel belly tank. In the southern portion of this area are several buildings (Nos. 3, 9, and 11).

These buildings are used for maintenance and storage. Additive drums are stored inside Building No. 11.

The dual, 18-inch-diameter, Jet A lines from the ) also enter the fuel terminal within the southeastern corner of this section.

Storm water from the eastern section is discharged at unregulated Outfalls 007 and 008 to a drainage ditch that flows north toward Goose Creek.

3.4.8 Southern Section

The southern section of the site is primarily grass, with a paved road running through it, jet fuel , and the Bottle House (Building No. 4), which stores samples. An 8-inch-diameter, aboveground pipe (about 1,200 linear feet) is routed parallel to southern fence line and transitions to underground pipe just behind Building No. 2 near the facility entrance. Storm water from this area discharges through valves at unregulated Outfalls 002 and 009 to a drainage ditch that flows south toward Filbin Creek.

3.4.9 Other Drainage Areas of Note

3.4.9.1 Northern Section

The northern section of the site is primarily an asphalt-paved road that traverses a thin strip along the northern fuel terminal boundary. Storm water leaves the site as sheet runoff, toward the northeast and northwest drainage features. There are no exposed chemicals stored in this area of the facility.

3.4.9.1 Fuel Pier (TC Dock)

The is a that transfers Jet-A from to the DFSP. There are no chemicals or oil materials stored at this location. The consists of and associated containment curbing. Storm water from this area discharges through openings along the directly into the Cooper River. The containment curb is drained by a pump located inside the secondary containment dike to a 500-gallon, horizontal tank with concrete base and curbing, also situated on the pier.

Table 1 Characteristics of Storm Water Drainage

DRAINAGE AREA STORM WATER FLOW DESCRIPTION

TOTAL SIZE

(Approx. Sq. Ft.)

IMPERVIOUS

SURFACE AREA

(Approx. Sq. Ft. )

RUN-OFF

COEFFICIENT

DRAINAGE

DISCHARGE POINT

Diked Areas Storm water collects in the dikes and then drains to a 4,500-gpm OWS. See Section 3.4.1.

849,000 849,000 High Thru OWS to drainage ditch, Outfall 001

Storm water collects in curbed area and drains to an OWS. See Section 3.4.2.

15,500.

15,500. High Thru OWS to drainage ditch, Outfall 001 r Loading Rack

Storm water collects in 20,000 gallon trench then drains to a 500-gpm OWS.

See Section 3.4.3.

61,500

61,500 High Thru OWS to drainage ditch, Storm water collects in curbed area and drains to an OWS. See Section 3.4.4.

1500 High Thru OWS to drainage ditch, Main Office / Laboratory Area

Storm water drains to the southwest corner of the property. See Section 3.4.5 112,500

28,000 Medium To N. Rhett Ave municipal storm water, Outfall 003

Western Section Flows west towards three storm water manholes. See Section 3.4.6. 162,000

115,000 High To N. Rhett Ave municipal storm water, Outfalls 004, 005, and 006

Eastern Section Area surrounding and ASTs drain to a drainage ditch. See Section 3.4.7

267,000 60,000 Low

To a drainage ditch flowing north to Goose Creek, Outfalls 007 and 008

Southern Section

Grassy flat area results in sheet flow that eventually drains to Outfall 002 or 009 through drainage pipes. See Section 3.4.8

531,500 425,094 Low To drainage ditch flowing south to Filbin Creek, Outfalls 002 and 009

The is constructed of concrete on piling above the Cooper River. Storm water drains through slots in the concrete directly to the river.

is surrounding by a containment curb base.

1,000

1,000 High equipment is surrounded by a containment curb.

Surrounding pier drains through slots in the concrete directly to the river.

4.0 IDENTIFICATION OF POTENTIAL STORM WATER

CONTAMINANTS

This section identifies significant materials located at the facility that may potentially contaminate storm water. Additionally, the section presents a record of past spills and leaks, identifies potential areas for storm water contamination, and summarizes available storm water sampling data.

4.1 Significant Material Inventory

The significant materials used by the facility that has potential to be present in storm water include jet fuel (Jet-A) stored in the ASTs, fuel additives, diesel fuel, and dielectric oil. The facility also stores small quantities of laboratory and remediation chemicals. Most chemicals used in the laboratory are for fuel testing and are in small quantities (Table 2). Jet-A fuel additives include the following:

SDA – Stadis 450 Conductivity Improver (Static Inhibitor) or equivalent.

CI – DCI-4A Corrosion Inhibitor or equivalent

FSII – Diethylene glycol monoethyl ether

STADIS 450 contains petroleum distillates that include toluene and aromatics. The DCI-4A also contains petroleum distillates, including dimethyl benzene and ethyl benzene, and dilineoleic acid. SDA includes toluene, dinonylnaphylsulfonic acid, naphthalene, a trace (<0.01 %) of benzene, isopropanol, solvent naphtha, chloromethane (<0.1%), and methanol (<0.15%). Aquatic toxicity (fathead minnow) of the DCI-4A and SDA are consistent with those for hydrocarbon constituents. The FSII is considerably less toxic than the SDA and CI. The fuel product stored at the terminal is jet turbine fuel, Jet-A. The flashpoint of Jet-A is between 100 and 150°F. Hazardous materials used at the fuel terminal are documented by Material Safety Data Sheets, which are kept in the terminal office, the onsite remediation office, and the laboratory.

4.2 Spill History

A review of the recorded spill history since 1975 indicates a frequency of one spill every 10 years (FRP 2002). The largest was an 83,000-gallon land spill of jet fuel from an undetected leak in the bottom of an aboveground storage tank, which occurred in 1975. Approximately 20,000 gallons reached navigable waterways. Remediation of contaminated soils and groundwater has been implemented. Remediation systems include dual-phase soil vapor extraction, groundwater extraction, groundwater treatment, and injection/land application of treated water at an upgradient location. Since then, system upgrades have been implemented that include installation of a double bottom with monitoring devices in all seven aboveground tanks and dike structures constructed of concrete walls and floors.

The last reported spill occurred on March 31, 2008 when the operator who performed the daily draining of water from the bulk storage issue tank (Tank 4) left the product recovery system valve open. This resulted in overfilling the 300-gallons product recovery tank. Of the estimated 1,950 gallons JP-8 spill, approximately 1,750 gallons was recovered. An additional 200 gallons were soaked up using spill pads and were transferred into the 10,000-gallon, water-bottom storage AST. The dike drains were already closed and locked, so no fuel was allowed to leave the dike containment.

According to facility records, no spill has been recorded inside or outside the diked/contained areas of the facility in the past three years.

4.3 Potential Areas for Storm Water Contamination

The following potential source areas of storm water contamination were identified and evaluated:

Diked Jet Fuel ASTs: Structural failure could lead to a rupture or leak in the tank, piping, or valves; operational errors could lead to tank overflow, a drain valve left open or leaking, or a transfer valve leak. Any such leaks would be contained in the dikes, and resultant contamination would be removed in the OWS. Storm water contamination may include common petroleum constituents, such as benzene, toluene, ethylbenzene, and xylenes (BTEX); naphthalene; and petroleum distillates.

Metals such as Zinc, Copper, and Lead have been consistently detected above non-detect.

Area: Structural failure could occur in the piping or valves, and there could be a truck tank rupture or leak. Operational error could lead to a leak from the truck, the tank valve, or the transfer valve. Any such leaks would be contained in the curbed area, and resultant contamination would be removed in the OWS. Storm water contamination may include common petroleum constituents, such as BTEX, naphthalene, petroleum distillates, and oil and grease.

Area: Structural failure could occur in the piping or valves and there could be a rupture or leak. Operational error could lead to a leak from the , the tank valve, or the transfer valve. Any such leaks would be contained in the curbed area, and sump and resultant contamination would be removed in the OWS. Storm water contamination may include common petroleum constituents, such as BTEX, naphthalene, and petroleum distillates.

Area: Structural failure could occur in the piping or valves or there could be a truck tank rupture or leak. Operational error could lead to a leak from the truck, the tank valve, or the transfer valve. Any such leaks would be contained in the sump, and resultant contamination would be removed in the OWS. Storm water contamination may include common petroleum constituents, such as BTEX, naphthalene, petroleum distillates, and oil and grease.

Dielectric Oil for Transformers: Fuel could leak due to operational or structural failure. Storm water contamination may include dielectric oil.

Emergency Generators: Fuel could leak due to operational or structural failure. Any such leaks would be contained in concrete bermed areas or generator facility floor. Potential storm water contamination includes BTEX, naphthalene, petroleum distillates, n-hexane, 1,2,4-Trimethylbenzene, and Phenanthrene.

Laboratory: Chemicals used for testing could be spilled or containers rupture. Any such spill would be contained on the floor of the laboratory building. Furthermore, the quantity of laboratory chemicals used is small. Therefore, it is unlikely that a spill in the laboratory building would result storm water contamination. The 280-gallon, horizontal waste fuel tank located just outside the building could leak due to operational or structural failure. Any such leaks would be mostly contained in the concrete bermed area. Potential contaminants include Jet-A and trace amounts of chemicals handled at the laboratory.

Fuel Additive Storage: Chemicals used as fuel additives are stored in 55-gallon containers and in tanks. These containers and tanks could fail due to operator error during filling, leaks in associated piping and tubing, and structural failure. Such releases would normally drain to the facility OWS system.

The most probable reasons for spills and storm water contamination are listed below:

Equipment failures, leaks, malfunctions

Failure of pressure relief valves Leaks in piping Leaks from valves, flanges, and fittings Truck or overfill Tank overfill Valve misalignment Operator error Natural disaster

The worst-case analysis in the site’s FRP is based on catastrophic damage, including tank and piping ruptures, failure of main flow-control valves, natural disasters and damage due to fire or explosions.

Table 3 presents site-specific information regarding storm water pollution potential for each of the areas.

4.4 Summary of Available Storm Water Sampling Data

Previous storm water sampling data is summarized in Table 4.

Table 2 Significant Materials Stored or Used at Facility Defense Fuel Support Point, Hanahan, SC

Trade Name of Material Amount Stored Storm Water Pollutants ASTs, Transformers, USTs

Jet-A

BTEX, Naphthalene, petroleum distillate, oil & grease, Zinc, Copper, Lead, Surfactants, TSS

Diesel Fuel BTEX, Naphthalene, petroleum distillate, oil & grease

Dielectric Oil Mineral oil, glycols, heavy metals, petroleum distillate

Inside Testing Laboratory n-Heptane 1 gallon n-Heptane

Trisolvent 2 gallons Trisolvent

Petroleum Ether 3 gallons Petroleum Ether Outside Testing Laboratory

Lab Wastes 280 gallons (1 tank) Jet-A, and trace amounts of chemicals handled within the laboratory

Fuel Additive Storage (Inside Closed Tanks and Drums)

CI

BTEX, petroleum distillate, dimethyl benzene

SDA

BTEX, petroleum distillate, dinonylnaphylsulfonic acid

FSII

di(ethylene glycol) mono ethyl ether

(CAS: 111-90-0)

Storage Cabinet Behind Laboratory Building (Under Roof) n-Heptane 6 gallons n-Heptane

Petroleum Ether 16 gallons Petroleum Ether

Toluene 4 gallons Toluene

Hexadecane 6 bottles of 500 grams each Hexadecane

Acetone 8 gallons Acetone

2-Propanol 4 gallons 2-Propanol

Reagent Alcohol 5 gallons Reagent Alcohol

Note: Small amounts of remediation related chemicals are stored under roof at the facility.

Table 3 Potential Sources of Storm water Contamination

SOURCE AREA MAJOR TYPES OF POTENTIAL FAILURES

MAXIMUM

QUANTITY MAXIMUM RATE

DIRECTION

OF FLOW

SECONDARY

CONTAINMENT

STRUCTURES

Structural: Tank rupture or leak; piping or valve rupture. Operational: Tank overflow; drain valve open or leaking; transfer valve leak.

Contained Concrete dikes and concrete basin floor

Transfer Pumping Station and Manifold

Structural: Piping or valve rupture/leaks.

Operational: Improper pumping; valve leak. Variable

Contained OWS and lagoon/weir

Structural: Piping or valve rupture/leak; truck tank rupture or leak. Operational: Truck; tank valve leak; transfer valve leak.

2,500 gal

Variable (max. pumping rate is 600 gpm) Contained Curbing & quick drain system

Same as 20,000 gal

Variable (max. pumping rate is 600 gpm) Contained Curbing & quick drain system

Pipeline Connecting

(approx. 2.6 miles from DFSP)

Structural: Piping or valve rupture. Operational:

Improper pumping; valve or coupling break/leak; third party incident.

9,000 bbl

8,000 bbl/hr when receiving from Variable None

Pipeline Connecting

(approx. 5.35 miles from DFSP)

Structural: Piping or valve rupture. Operational:

Improper pumping; valve or coupling break/leak; third party incident.

1,750 bbl

1,400 bbl/hr when pumping to Joint Base Charleston Variable None

Facility

Structural: Piping or valve; truck tank rupture or leak. Operational; Truck; tank valve leak;

transfer valve leak.

2,500 gal

Gravity off-loading (150 gpm is anticipated max. rate) Contained

Curbing & quick drain system to catchment basin

Transformers Structural: Rupture or leak 200 gal (capacity of largest transformer) Variable Variable None

Structural: malfunction; piping or valve rupture/leaks; transfer valve leak App. 300 gallons(1) Variable Contained

Concrete dikes and concrete basin floor

+ adjacent 500

SOURCE AREA MAJOR TYPES OF POTENTIAL FAILURES

MAXIMUM

QUANTITY MAXIMUM RATE

DIRECTION

OF FLOW

SECONDARY

CONTAINMENT

STRUCTURES

gallon tank

Diesel Tanks Structural: Tank rupture or leak; piping or valve rupture. Operational: Tank overflow; drain valve open or leaking; transfer valve leak.

1,000 gal Estimate 250 gpm fill rate

Contained – to OWS, or surrounding ground

Concrete dikes and floors (200 KW generator AST), others to ground

Fuel Additive Tanks and Containers

Structural: Tank rupture or leak; piping or valve rupture. Operational: Tank overflow; drain valve open or leaking; transfer valve leak.

8,000 gal

Estimate 10-250 gpm fill rate

Contained – to OWS

Concrete dikes and base

(1) Based on the Jet-A contents of the loading arms draining out into the containment area.

Table 4 DMR Results for May 2010 to April 2013 Defense Fuel Support Point, Hanahan, SC

Quarter pH (su)

Total

Suspended Solids

(mg/L) Copper (mg/L)

Lead

(mg/L)

Zinc

(mg/L) Surfactant

(mg/L)

Diesel Range Organics

(mg/L)

Gas Range Organics

(mg/L)

May 2010 through July 2010 7.4 6.40 0.00100 0.000511 0.00389 ND ND ND

August 2010 through October 2010 8.3 1.07 0.00242 ND 0.00664 ND ND ND

November 2010 through January 2011 7.7 ND 0.00128 ND 0.00408 0.0236 ND ND

February 2011 through April 2011 7.1 1.20 0.00094 ND 0.00957 ND ND 0.1

May 2011 through July 2011 7.9 3.40 0.00410 ND 0.01080 0.0334 0.3390 0

August 2011 through October 2011 7.7 1.87 0.00145 ND 0.00471 0 0 0

November 2011 through January 2012 7.5 1.70 0.00124 ND 0.00375 0 0.0977 0

February 2012 through April 2012 8.4 2.00 0.00161 ND 0.00947 0 0 0

May 2012 through July 2012 7.6 2.40 0.00107 ND 0.00508 0.041 0.1370 0

August 2012 to October 2012 7.9 3.47 0.00192 ND 0.00890 0 0.0995 0

November 2012 through January 2013 8 2.40 0.00240 0.00055 0.01330 0 0.1230 0

February 2013 through April 2013 7.4 3.10 0.00123 ND 0.05800 ND 0.0943 0

Average 7.1 to 8.4 2.60 0.00172 <0.000511 0.01150 <0.0327 <0.1113 <0.1

Note 1: “mg/L” denotes milligrams per liter / “su” denotes standard units. / ND = non-detect Note 2: Also analyzed are acenaphthylene, fluorine, and naphthalene. All results have been non-detect.

Note 3: Acute toxicity monitored in 2011 and 2012 with both tests passing.

5.0 STORM WATER MANAGEMENT CONTROLS

This section discusses the storm water management controls required by the permit and describes the management practices selected to address the areas of concern identified in Section 4 of this SWPPP.

5.1 Compliance with Other Programs

Storage of Jet-A and other fluids complies with requirements under the US Environmental Protection Agency SPCC program (40 CFR 112) and related Coast Guard requirements. On occasion, the facility may generate wastes regulated under the Resource Conservation and Recovery Act (RCRA). Under RCRA, DFSP conducts weekly inspections of the area storing the fluids to verify placarding, storage times, and the integrity of the storage containers and discharge mechanisms. During the RCRA inspection, leaks or spills that may impact storm water are noted and cleaned immediately. Additionally, all of the storage tanks associated with the facility comply with UST and AST regulations. The BMPs included in this SWPPP are also intended to prevent soil and groundwater contamination, which could lead to CERCLA/ RCRA enforcement actions. DFSP has developed a Spill Prevention Control and Countermeasure (SPCC) Plan that includes BMPs for fuel storage. The BMPs in the SPCC Plan prevent storm water contamination by petroleum products. Since the primary source of potential storm water contamination is petroleum products and because related BMPs are included in the SPCC Plan, they are not included in this SWPPP.

5.2 Storm Water Management Practices

Upon reviewing the potential pollutants at the facility and the facility operations, it was determined that current operating procedures and storm water pollution prevention structures are generally adequate for major sources.

New BMPs identified with this plan revision are identified below.

Structural BMPs: Add permanent type fill box/funnel on SDA and CI tanks. None at this time.

Operational BMPs: Review procedures for fuel additive tank filling to ensure they address features to minimize the potential for spills during filling operation and include inspection of additive systems prior to filling for leaks from tanks, pumps, fittings, valves, and other associated equipment. At the fuel pier, complete the addition of a 500-gallon, horizontal AST and associated pumping system to supplement the secondary containment features at the Fuel Pier loading arms.

5.3 Storm Water Treatment

Storm water that is most likely to come in contact with petroleum products stored at DFSP is contained and treated by one or more on-site OWS before being discharged. Storm water from grass-covered fields, parking areas, and access roads is discharged to drainage ditches or municipal storm water system without further treatment.

5.4 Sediment and Erosion Control

The site consists of bulk storage tanks enclosed in a dike structure constructed of concrete walls and floors;

curbed truck loading rack, railcar loading rack, truck off-loading facility; paved access roads; and grassy fields.

These site features and relatively flat topography limits erosion and sediment transport. Strom water outfalls are constructed with rip-rap and/or concrete structures to limit erosion at discharge points. Therefore, no new BMPs were identified for sediment and erosion control.

FOR OFFICIAL USE ONLY

FOR OFFICIAL USE ONLY

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6.0 FACILITY MONITORING PLAN

6.1 Maintenance Program

The normal maintenance plan prescribed by the operating contract specifies mandatory daily, weekly, monthly, quarterly, and annual tests and inspections. The superintendent maintains a file of normal maintenance inspection lists and any other maintenance records.

General maintenance consists of touch-up painting and daily corrosion checks of tank surfaces, piping, and other equipment. Personnel at the facility do touch-up painting. Major painting is done by outside contractors. Tank equipment and gauges are inspected daily for proper operation. The interior inspection of bulk storage tanks by physical entry is accomplished, when necessary, in accordance with STANAG 3609, Option B, Frequency of Inspection and Cleaning of Petroleum Fuel Operating and Storage Tanks. More frequent inspection and cleaning may be required if the product deteriorates or if major maintenance or repair is needed.

6.2 Self-Inspection

The following must be inspected on a routine basis, as outlined in the site Operations and Maintenance Manual:

Oil Storage Tanks Secondary Containment Structures Response Equipment

The completed inspection logs should be maintained at the facility. Inspection logs must be maintained for five years. DFSP will perform quarterly visual inspections of all storm system inlets and outfalls during rain events to look for evidence of storm water contamination. The visual inspection shall include any observations of color, odor, turbidity, floating solids, foam, oil sheen, or other obvious indicators of storm water pollution. Information recorded during the quarterly inspection shall include date of inspection, storm system location, inspection results, and potential significant sources of storm water contaminants, if discovered. Blank quarterly inspection forms can be found in Appendix A of this SWPPP. Furthermore, outfalls will be inspected on biannual basis for structural integrity.

An annual storm water compliance inspection will be conducted to determine if site operations have changed since development of this SWPPP. If operational changes have been made, the SWPPP Coordinator will determine if those changes will impact storm water quality and develop new BMPs to address the changes. All operational changes and new BMPs will be recorded in this SWPPP. Additionally, the inspection date, the inspection personnel, the scope of inspection, major observations, and any needed revisions will be recorded.

Revisions to the plan shall occur within 30 days after the annual inspection. Blank annual compliance inspection forms can be found in Appendix A of this SWPPP.

7.0 COMPLIANCE AND REPORTING REQUIREMENTS

7.1 SWPPP and SWPPP Summary

Per the requirements of DFSP’s initial NPDES permit SC-340022, NPDES General Permit for Discharges from Bulk Petroleum Storage Facilities, DFSP was required to prepare a SWPPP by the effective date of June 1, 2005. This SWPPP was initially prepared in December 2004 and is updated to meet the requirements of the NPDES permit. The SWPPP will be kept at the facility and will be made available to the state or federal compliance officer upon request.

7.2 Employee Training

DFSP Charleston regularly trains its personnel for oil spill contingencies by following the triennial cycle of the National Preparedness for Response Exercise Program (PREP) guidance. This education program includes hands-on training in spill prevention and response, good housekeeping, proper material handling, disposal and control of waste, container filling and transfer and proper storage, washing and inspection procedures. The terminal superintendent maintains a record of all oil spill response training in accordance with TAB 8 of the Facility Response Plan (FRP). The training program will be reviewed annually by the SWPPP coordinator to determine its effectiveness and to make any necessary changes to the program.

7.3 Implementation Schedule

In accordance with the State of South Carolina, the SWPPP implementation schedule is presented in Table 5.

7.4 Record Retention Requirements

Records described in the SWPPP must be retained on site for 5 years and shall be made available to the state or federal compliance inspection officer upon request. Additionally, employee training records and waste and recycling receipts or vouchers shall also be maintained.

7.5 Principal Executive Officer Signature

In accordance with the State of South Carolina, this plan has been approved and signed by Ms. Laura Fleming, Chief, Environmental and Safety Management, Installation Support for Energy, Defense Logistics Agency.

Please refer to Section 7.7 for approval and signature.

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Table 5 Implementation Schedule

Storm water Pollution Prevention Action Items Implementation Date

Implement employee training Immediate, on-going

Quarterly visual monitoring during rain events Quarterly since January 2005

Biannual visual inspections of outfalls Biannually since March 2006

Annual facility site compliance inspection Annually since November

Implementation of Operational BMPs

Review and revise if necessary the fuel additive tank fill procedures to address SI, SDA, and FSII tank spill/leak inspection, and to include features to minimize the potential for spillage during filling, by December 2013. Reviewed - No additional Operational BMPs are necessary.

Implementation of Structural BMPs

1. Add CI and SDA tank overfill prevention equipment by December 2013.

2. Complete spill containment improvements at the Fuel Pier (500 gallon tank for supplemental containment) by December 2013.

7.6 Provisions for Amendment of the Plan

If the facility expands, experiences any significant storage increases or process modifications, or changes any significant material handling or storage practices which could impact storm water, the SWPPP will be amended appropriately. The amended SWPPP will have a description of the new activities that contribute to the increased pollutant loading and planned source control activities.

The SWPPP will also be amended if the state or federal compliance inspection officer determines that it is ineffective in controlling storm water pollutants discharged to waters.

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DFSP, CHARLESTON, SC AUGUST 2013

APPENDIX A

INSPECTION LOGS

DFSP, CHARLESTON, SC AUGUST 2013

Quarterly Visual Monitoring Inspection Log

Date / Time Outfall Location

Weather Conditions Observations

Probable Source of Any Observed Contamination

Outfall 001: Southeast corner of the site

Color: _____________ Odor: __________

Turbidity: __________________________

Oil Sheen: _________________________

Other: ____________________________

Outfall002: Southeast

Color: _____________ Odor: __________

Turbidity: __________________________

Outfall 003: Behind Office Building

Color: _____________ Odor: __________

Turbidity: __________________________

Outfall 004: Near Pump Station

Color: _____________ Odor: __________

Turbidity: __________________________

Outfall 005: South of

EW-03

Color: _____________ Odor: __________

Turbidity: __________________________

Outfall 006: Northwest

Color: _____________ Odor: __________

Turbidity: __________________________

Outfall 007: Northeast

Color: _____________ Odor: __________

Turbidity: __________________________

DFSP, CHARLESTON, SC AUGUST 2013

Date / Time Outfall Location

Weather Conditions Observations

Probable Source of Any Observed Contamination

Outfall 008: North of 4500 gpm oil/water separator

Color: _____________ Odor: __________

Turbidity: __________________________

Outfall 009: South of 500 gpm oil/water Separator

Color: _____________ Odor: __________

Turbidity: __________________________

Fuel Pier (TC Dock)

Color: _____________ Odor: __________ Turbidity: __________________________

Inspector’s Name:_______________________________________ Date _____________________

DFSP, CHARLESTON, SC AUGUST 2013

Annual Facility Site Compliance Inspection Log

Date Drainage

Area

Potential Pollutants and

Source

Change in Drainage Conditions or

Operations Since Last Inspection

BMP

Effective?

(Y/N) Proposed BMPs and

Schedule

Diked Areas

Facility

Main Office / Laboratory Area

Western Section

Eastern

Southern

Fuel Pier (TC Dock)

DFSP, CHARLESTON, SC AUGUST 2013

APPENDIX B

BMPs

DFSP, CHARLESTON, SC AUGUST 2013

APPENDIX B

BEST MANAGEMENT PRACTICES (BMP)

DFSP Charleston, SC

These BMPs have been developed for the DFSP Charleston Fuel Terminal to address storm water pollution prevention and control for ancillary functions under Storm water Permit # SCG340022, Section IC.G (Best

Management Practices Plan). These BMPs are required based on ancillary site industrial activities that use, store, manufacture, handle or discharge any pollutant listed as toxic under 40CFR 117 and Tables II and III of

Appendix D of 40 CFR 122.

The facility does not manufacture chemicals, but may use, store, and handle chemicals that are ancillary to the bulk terminal operations. Primary ancillary activities include:

- Diesel fuel handling, storage and use (generators, and pumps)

- Fuel additive handling , storage, and use (fuel additives)

- Remediation activities with associated chemical handling, storage, and use

- Use, storage, and handling of miscellaneous chemicals in small quantities required for day-to day operations

- Maintenance activities with associated chemical handling, storage, and use.

- Construction activities with associated chemical handling, storage, and use.

- Fuel quality control laboratory and related activities.

In addition to these BMPs the facility is regulated under the requirements of 40 CFR 112 (SPCC Regulations) and a separate stand-alone SPCC Plan has been prepared to address oil/petroleum handling ,storage, use, training, inspection, and emergency response.

Personnel involved in on-site activities should receive on-the-job training in these BMPs. Copies of these BMPs should also be provided to contractors during the bidding process, and when they arrive onsite for their designated work activities.

OPERATIONS/GENERAL HOUSEKEEPING

BMP -01-O

General – Maintain areas exposed to storm water in a clean, orderly manner. Take necessary steps to prevent pollutants from contacting storm water.

BMP-02-O

Shelter for Industrial Materials - Where practicable, industrial materials and activities should be protected by a storm resistant shelter to prevent exposure to storm water.

DFSP, CHARLESTON, SC AUGUST 2013

BMP-03-O

Outdoor Equipment Wash Areas - Outdoor washing operations (washing, steam cleaning, degreasing) should be controlled as follows:

- Maintain the area paved, and covered if possible.

- Area should be sloped/bermed to facilitate wash water collection.

- Collected wash and rinse water should be collected and discharged/routed to the sanitary sewer.

BMP-04-O

Motor Vehicle Washing – Use off-site commercial washing where possible. If vehicles are washed onsite they should be washed in a wash area per BMP-03-O. Vehicles may be rinsed provided no detergents are used, and contaminants are not likely to be transferred to storm water.

BMP-05-O

Leaking Equipment - Equipment that is leaking should be repaired as soon as practical. Use drip pans or specially designed absorbent pads to contain leaks, and cover with a tarp or other suitable shield to minimize the exposure to storm water. Complete repairs in an expeditious manner.

BMP-06-O

Temporary Parking of Tanker Trucks - Designate areas for parking tanker trucks and material transport vehicles where spills and leaks can be contained and effectively cleaned. Use covered loading and unloading areas for transfer of potential pollutants such as building overhangs, to reduce exposure of materials, vehicles, and equipment to storm water.

BMP-07-O

Material/Waste Handling - Transfer, use and store liquid materials only on paved or impervious areas, preferably within containment and under a cover.

BMP-08-O

Dispensing Liquids – Avoid dispensing from drums positioned horizontally in cradles. Dispensing materials from upright drums equipped with hand pumps is preferred. Always use secondary containment and self-closing spigots if dispensing from horizontally positioned drums.

BMP-09-O

Waste/Materials Storage - Designate central storage locations where materials are contained (i.e., diking , curbing, secondary containment, OWS for oils) and covered to prevent contact with storm-water runoff and to reduce the risk of accidental spills. Segregate wastes to improve handling and promote recycling.

BMP-10-O

Containers and Container Labeling - Store all materials sealed in their original containers or containers approved for that use. Clearly label all containers with contents to prevent co-mingling of materials, storage of incompatibles, and improver handling, and to promote proper material handling and storage. Utilize required labeling procedures for storage of all hazardous wastes. Identify and properly label or dispose of all unlabeled and unknown materials.

DFSP, CHARLESTON, SC AUGUST 2013

BMP-11-O

Used Battery Management - Recycle used batteries as soon as practical. Immediately upon removal of a battery, provide temporary storage within the facility’s battery storage shed. Where practical, recycle used batteries no later than 30 days after removal.

BMP-12-O

Used Oil Containers and Filters - Hot drain drain oil filters and containers (as appropriate) before recycling or disposal. Place empty containers/filters in a leak-proof container.