TE 72 - Storm Water Pollution Prevention Plan.pdf

July 2015

U.S. Army Garrison – Fort Wainwright, Alaska

Storm Water Pollution Prevention Plan

Storm Water Pollution Prevention Plan For Compliance with the APDES 2015 Multi-Sector General Permit (MSGP)

Fort Wainwright, Alaska U.S. Army Garrison

July 2015

Fort Wainwright Industrial Storm Water Pollution Prevention Plan i July 2015

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Storm Water Pollution Prevention Plan

1.2 Regulatory Framework

1.3 History of Industrial Storm Water Compliance at Fort Wainwright

2.0 FACILITY DESCRIPTION AND CONTACT INFORMATION

2.1 Facility Description Information

2.2 Discharge Information

2.3 Post Hydrology

2.4 Contact Information/Responsible Parties

2.5 Storm Water Pollution Prevention Team

2.6 MSGP Compliance Maps

3.0 SUMMARY OF POTENTIAL POLLUTANT SOURCES

3.1 Industrial Activities and Associated Pollutants

3.2 Spills and Leaks

3.3 Non-Storm Water Discharges

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3.4 Sampling Data Summary from Previous Permit Term

4.0 STORM WATER CONTROL MEASURES

4.1 Minimize Exposure

4.2 Good Housekeeping

4.3 Preventive Maintenance

4.4 Spill Prevention and Response

4.5 Erosion and Sediment Controls

4.6 Management of Runoff

4.7 Salt Storage Piles or Piles Containing Salt

4.8 Employee Training

4.9 Allowable Non-Storm Water Discharges

4.10 Waste, Garbage, and Floatable Debris

4.11 Dust Generation and Vehicle Tracking of Industrial Materials

4.12 Fueling and Fuel Storage

4.13 Vehicle, Aircraft, and Equipment Maintenance

4.14 Vehicle, Aircraft, and Equipment Washing

4.15 Loading and Unloading

4.16 Industrial Waste Management

4.17 Outdoor Storage

5.0 SECTOR-SPECIFIC REQUIRMENTS

5.1 Sector J – Non-Metallic Mineral Mining and Dressing

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5.2 Sector L – Landfills, Land Application Sites, and Open Dumps

5.3 Sector P – Land Transportation and Warehousing

5.4 Sector S – Air Transportation

6.0 SCHEDULES AND PROCEDURES FOR MONITORING

6.1 Monitoring Procedures

6.2 Benchmark Monitoring

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6.3 Effluent Limitations Monitoring

6.4 Impaired Waters Monitoring

6.5 Other Monitoring Required by ADEC

6.6 Monitoring Responsibilities and Procedures

6.7 Storm Water Monitoring Summary

7.0 INSPECTIONS

7.1 Routine Facility Inspections

7.2 Quarterly Visual Assessment of Storm Water Discharges

7.3 Comprehensive Site Inspections

8.0 REPORTING AND RECORD KEEPING

8.1 Reporting Monitoring Data to ADEC

8.2 Annual Report

8.3 Noncompliance Notification for Numeric Effluent Limits

8.4 Additional Reporting

8.5 Record Keeping

8.6 Addresses for Reports

8.7 Request for Submittal of Records

9.0 TERMINATING COVERAGE

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9.1 Submitting a Notice of Termination

9.2 When to Submit an NOT

10.0 SWPPP CERTIFICATION

11.0 SWPPP MODIFICATIONS AND AVAILABILITY

11.1 Required SWPPP Modifications

11.2 SWPPP Availability

LIST OF TABLES

Table 1. List of Industrial Facilities and Activities

Table 2. Installation-Wide Storm Water Pollution Prevention Team Members and Responsibilities

Table 3. List of Industrial Activities and Associated Pollutants

Table 4. Fort Wainwright Analytical Monitoring Program

Table 5. Storm Water Monitoring at Fort Wainwright

APPENDICES

A Figures

B 2015 Multi-Sector General Permit

C Summary of Spills and Leaks

D Non-Storm Water Discharge Certification

E DPW Clean Soil Stockpile Environmental Compliance Guidelines

F Forms vi July 2015

LIST OF ACRONYMS AND ABBREVIATIONS

AAFES Army and Air Force Exchange Service

ACGP Alaska Construction General Permit

ADEC Alaska Department of Environmental Conservation

AHA Alert Holding Area

AKA Also known as

APDES Alaska Pollutant Discharge Elimination System

AST Aboveground storage tank

BLM Bureau of Land Management

BMP Best management practice

BOD5 Biochemical oxygen demand

BRTA Black Rapids Training Area

CBI Confidential business information

CEMML Center for Environmental Management of Military Lands

CFR Code of Federal Regulations

CHPP Central Heat and Power Plant

CRTC Cold Regions Test Center

CWA Clean Water Act

DLA Defense Logistics Agency

DoD Department of Defense

DPW Directorate of Public Works

DTA Donnelly Training Area

ELG Effluent limitations guidelines eNOI Electronic Notice of Intent

EPA U.S. Environmental Protection Agency

ESCP Erosion and Sediment Control Plan

FOD Foreign object damage

FRP Facility Response Plan

HAZWOPER Hazardous Waste Operations and Emergency Response

HEMTT Heavy expanded mobile tanker truck

HM Hazardous material

HMAP Hazardous Material Accumulation Point

HMWMP Hazardous Material and Waste Management Plan

HW Hazardous waste

HWAA Hazardous waste accumulation area vii July 2015

JD Jurisdictional Determination

JP Jet propellant

MDMR MSGP Industrial Discharge Monitoring Report

MS4 Municipal Separate Storm Sewer System

MSDS Material Safety Data Sheets

MSGP Multi-Sector General Permit

NFA No further action

NOI Notice of Intent

NOT Notice of Termination

NPDES National Pollutant Discharge Elimination System

NWTC Northern Warfare Training Center

ODPC Oil discharge and pollution control

OWS Oil/water separators

OASys Online Application System

POC Point of contact

POL Petroleum, oil, and lubricant

POV Privately owned vehicle

PWE Public Works Environmental

RAA Recyclable materials accumulation area

RCRA Resource Conservation and Recovery Act

SAA Satellite accumulation area

SIC Standard Industrial Classification

SPCC Spill Prevention, Control, and Countermeasure

SWMP Storm Water Management Plan

SWPPP Storm Water Pollution Prevention Plan

TMDL Total Maximum Daily Load

TSDF Treatment, storage, or disposal facility

TSS Total suspended solids

UAA Universal waste accumulation area

USACE United States Army Corps of Engineers

USAG United States Army Garrison

USARAK United States Army Alaska

UST Underground storage tank

Waters of the U.S. Waters of the United States

WQS Water Quality Standards

1 July 2015

1.0 INTRODUCTION

This document has been prepared for Fort Wainwright to satisfy the Storm Water Pollution Prevention Plan (SWPPP) requirements of the Alaska Pollutant Discharge Elimination System (APDES) 2015 Multi-Sector General Permit for Storm Water Discharges Associated With Industrial Activity (MSGP).1 This SWPPP documents storm water management practices at industrial facilities at Fort Wainwright, Alaska, and is a guide for the installation’s storm water pollution prevention team.

1.1 Storm Water Pollution Prevention Plan

The MSGP requires the permittee to prepare a SWPPP and specifies what must be included in that plan (e.g., identification of potential sources of storm water pollution, descriptions of practices on the installation to reduce storm water pollution, and measures to ensure compliance with the terms and conditions of the MSGP). Part 5 of the MSGP details the information required in the SWPPP. The body of this document comprises Fort Wainwright’s SWPPP for industrial activities at Fort Wainwright properties.

This plan is organized as follows:

Section 1.0 describes the different Environmental Protection Agency (EPA) and Alaska Department of Environmental Conservation (ADEC) storm water permits and their requirements; discusses the purpose of the SWPPP and the Storm Water Management Plan (SWMP), and responsibilities of the storm water pollution prevention team under the 2015 MSGP and SWPPP; and explains the history of storm water compliance at Fort Wainwright.

Section 2.0 provides facility and contact information, and describes Fort Wainwright’s location, topography, and drainage.

Section 3.0 provides a discussion of industrial activities at Fort Wainwright and potential pollutant sources associated with them.

Section 4.0 discusses control measures that all industrial facilities at Fort Wainwright must implement, as applicable, to address activities and potential pollutants described in Section 3.0.

Section 5.0 discusses sector-specific requirements for the four industrial sectors active at Fort Wainwright.

Section 6.0 presents schedules and procedures for monitoring.

1 The MSGP is included in this SWPPP as Appendix B.

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Section 7.0 details required storm water pollution prevention inspections under the MSGP, including routine facility inspections, the quarterly visual assessment of storm water discharges, and comprehensive site inspections.

Section 8.0 discusses reporting and record keeping requirements of the MSGP.

Section 9.0 explains the protocols for terminating permit coverage.

Section 10.0 describes the SWPPP signatory requirements and certification.

Section 11.0 addresses SWPPP modifications and availability requirements for this document.

1.2 Regulatory Framework

Under the authority of the Clean Water Act (CWA), the EPA established rules to protect waters of the United States (waters of the U.S.) from pollutants transported by storm water runoff.

These regulations are part of the National Pollutant Discharge Elimination System (NPDES) regulations found in Title 40 of the Code of Federal Regulations Part 122.26 (40 CFR 122.26) and mandate that storm water dischargers obtain permits for point source discharges to waters of the U.S. In October 2009, EPA authorized ADEC to administer and enforce the NPDES program in the State of Alaska. As a result of this change, facilities in Alaska requiring storm water permits are required to obtain an APDES permit from ADEC. There are three basic categories of discharges that necessitate obtaining APDES storm water discharge permits:

Discharges associated with industrial activity

Discharges from municipal separate storm sewer systems (MS4s)

Discharges associated with construction

1.2.1 Industrial Storm Water Permit

Operators of industrial facilities in Alaska that discharge storm water to waters of the U.S., either directly or through an MS4, must obtain an APDES industrial storm water permit. They may apply either for an individual APDES permit or make use of the general permit established for this purpose. “Storm Water Discharges Associated With Industrial Activity” is a regulatory term defined in 40 CFR §122.26(b)(14)(i-xi).

1.2.2 Municipal Separate Storm Sewer System Permit

The APDES storm water program requires operators of regulated small MS4s (i.e., MS4s serving populations less than 100,000) to obtain authorization to discharge storm water under an APDES permit. EPA considers Fort Wainwright to own and operate a regulated small MS4 “by rule.” This determination required Fort Wainwright to submit a small MS4 permit application to ADEC. The main provision of MS4 permits is to prepare and implement a SWMP that

3 July 2015 explains how the permittee will minimize potential pollution of waters of the U.S. from MS4 storm water runoff. In 2011, Fort Wainwright submitted to ADEC an individual MS4 permit application and a SWMP2 that had been developed according to a template prepared by EPA for Region 10.3 Fort Wainwright’s SWMP documented anticipated MS4 program goals and associated best management practices (BMPs), also referred to as control measures, to achieve the goals.

On July 23, 2015, ADEC sent Fort Wainwright a letter requesting the installation submit a new MS4 permit application no later than 180 days from the date of the letter. As there is currently no general permit available for use by small MS4s, ADEC intends to issue Fort Wainwright an individual permit. Fort Wainwright’s MS4 permit will cover facilities and activities that discharge storm water runoff to the Fort Wainwright storm sewer system, including discharges from residential areas, construction activities, and the industrial activities managed by the MSGP that are discussed in this SWPPP. The Fort Wainwright SWMP will likely be updated to address specific requirements of the MS4 permit, once issued.

The MS4 program is the umbrella program for all storm water management at Fort Wainwright, and this industrial SWPPP is one component of storm water management on the installation.

1.2.3 Construction Storm Water Permits

Although federal and State of Alaska storm water regulations consider construction to be an industrial activity, the MSGP does not regulate storm water discharges from construction activities. A construction storm water permit must be obtained for construction disturbing one or more acres of land. In the State of Alaska, ADEC’s 2011 Alaska Construction General Permit4 (ACGP) is the typical mechanism for obtaining such coverage. Additionally, to reinforce protection of receiving waters in areas that drain to regulated MS4s during and after construction, Fort Wainwright’s SWMP includes minimum control measures for construction and post-construction runoff control. Thus, construction projects at Fort Wainwright must comply with the installation’s SWMP in addition to the terms of the ACGP.

1.3 History of Industrial Storm Water Compliance at Fort Wainwright

Fort Wainwright was initially granted storm water discharge permit coverage under EPA’s original MSGP in 1996. It has continued to operate under subsequent MSGPs.

2 Storm Water Management Plan, Fort Wainwright, U.S. Army Garrison, Alaska, September 2011.

3 Preliminary Draft Proposed Phase II Municipal Storm Water Permit, EPA Region 10 Template, September 2005

4 Alaska Pollutant Discharge Elimination System General Permit for Discharges from Large and Small Construction

Activities, July 2011 (at time of SWPPP preparation); consult ADEC website for current permit.

4 July 2015

1.3.1 Inventory of Industrial Facilities

Facilities currently operating at Fort Wainwright that meet the regulatory definition of industrial include the installation’s rock quarries (Sector J – Non-Metallic Mineral Mining and Dressing), landfill (Sector L – Landfills, Land Application Sites, and Open Dumps), warehousing, maintenance, and fueling facilities (Sector P – Land Transportation and Warehousing), and airfield service facilities both on and off the Ladd Army Airfield (Sector S – Air Transportation).

The primary SIC code for Fort Wainwright is 9711, National Security. The primary industrial activity is Sector S. Co-located activities on the installation include Sectors J, L, and P.

Many facilities exist throughout the installation that support land transportation related activities.

These include motor pools, fuel points, trade shops, and the like, that perform vehicle maintenance, lubrication, fueling, washing, outdoor storage, etc. These facilities, which do not meet the MSGP’s Standard Industrial Classification (SIC) codes, do not meet the regulatory definition of “industrial”. If they were off-post performing identical functions, MSGP coverage would be unnecessary but because they occur on a military installation, they are managed as industrial activities and included in this SWPPP for management under the MSGP. The closest sector with narrative descriptions that define these facilities is Sector P (Land Transportation and Warehousing). Two warehouses on post have also been incorporated into this sector at Fort Wainwright as Sector P best describes activities that occur there.

The coal-fired Central Heat and Power Plant (CHPP) was covered under previous MSGPs at Fort Wainwright. The CHPP is now privately owned and operated on Fort Wainwright property by Doyon Utilities. Doyon is currently responsible for environmental compliance for this facility and other utility buildings and infrastructure on post. Doyon facilities operate under their own environmental permits, as applicable. For this reason, industrial activity at the CHPP is not discussed in this SWPPP or included for coverage under Fort Wainwright’s MSGP.

Building 3489 functions as the installation’s Hazardous Material Accumulation Point (HMAP), operated by the Public Works Environmental (PWE) waste turn-in contractor. At one point, under a previous MSGP and associated SWPPP, this facility had been defined as Sector K (Hazardous Waste Treatment, Storage, or Disposal Facilities [TSDFs]). Subsequently, operations at the facility changed, thus changing its designation from a TSDF to a short-term (less than 90 day) hazardous waste consolidated collection facility and recyclable materials transfer facility. At that time, Sector K was removed from the installation’s SWPPP, but Building 3489 remained in the SWPPP, to provide additional oversight of operations and ensure activities there do not contaminate storm water.5

5 Due to removal of Sector K designation, Building 3489 will be managed according to Sector P requirements for warehousing activities.

5 July 2015

The Defense Logistics Agency (DLA) Document Services, formerly the Document Automation and Production Service, operated out of the basement of Building 3401. Although this facility did not conduct activities with the potential to contaminate storm water, it was included in previous SWPPPs due to Sector X (Printing and Publishing) designation. As DLA Document Services is no longer present on Fort Wainwright properties, it has been removed from subsequent coverage.

A list of industrial facilities and their associated activities is included in Table 1.

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Table 1. List of Industrial Facilities and Activities

In d u st ri al s ec to r

Building number

Description

Activity with Potential to Pollute Storm Water

F u el in g /D e-fu el in g

A b o ve

G ro u n d

L iq u id

S to ra g e T an ks

V eh ic le

, A ir cr af t, E q u ip m en t M ai n te n ce ic le

, A ir cr

E q u ip m en t W as h o ad in g /U n lo ad

M at er ia ls

In u st ri al

W as te ag em en t

O u td o o r

S to ra e

S al t S to ra g e

Fort Wainwright Main Cantonment

P 1185 Birch Hill Ski Area X X X X X X

L 1191 Directorate of Public Works (DPW) Landfill X X X X X

P 1500 Bureau of Land Management (BLM) Maintenance Facility and Fuel Pump

X X X X X

S 1510 BLM Bulk Fuel Issue and Hazardous Material (HM) / Hazardous Waste (HW) Management Storage

X X X X X

P 1544 BLM Fire Cache Warehouse X X X

S - - BLM Fire Retardant Storage and Issue X X X

S 1557 Hangar 1 X

S 1565 Aviation Fueling and Fuel Storage X X X X

S 2077 (east) Hangar 8 X X X X X X

S 2077 (west) Hangar 7 X X X X X X

S 2078 Aviation Re-fuel Facility X X X

S 2088 Hangar 6 X X X X X X

P 2095 & 2096 Chena Bend Golf Course Maintenance Facility X X X X X X X

P 2116 Alert Holding Area (AHA) X

S 2120 Fueling/De-fueling Island at AHA X X

S 2132 Hangar 5 X X X X X X

P

(north & south) Vehicle/Equipment Maintenance Facility X X X X X

P 2297 Brigade Motor Pool X X X X X

7 July 2015

Table 1. List of Industrial Facilities and Activities (continued)

In d u st ri al s ec to r

Building number

Description

Activity with Potential to Pollute Storm Water

F u el in g /D e-fu el o ve

G ro u u id

S to ra g e T ic le

, A ir cr

E q u ip m en t M ai n te n ic le

, A ir cr

E q u ip m en t W as h ad in g /U n lo ad er u st ri al

W ag em en t

O u td o o r

S to ra t S to ra g e

S 3007 Hangar 4 X X X X X X

S 3015 DPW Contractor Maintenance X X X X X X X

P 3018 DPW Contractor Shops X X X

P 3026 Pest Management Shop X X X X

P 3030 Logistics Readiness Center X X

P 3380 Stryker Wash Facility X X

P 3425 Vehicle/Equipment Maintenance Facility X X X X X

P 3467 Vehicle/Equipment Maintenance Facility X X X X X

P 3470 Vehicle/Equipment Maintenance Facility X X X X

P 3484 Defense Fuel Supply Point (Bulk Fuel Issue) X X X X

P 3485 Vehicle/Equipment Maintenance Facility X X X X X

P 3487 Brigade Warehouse X X

P 3489 Hazardous Material Accumulation Point X X X

P 3490 DOL Installation Maintenance Division X X X X X

P

(north & south) Vehicle/Equipment Maintenance Facility X X X X X

P

(north & south) Vehicle/Equipment Maintenance Facility X X X X X

P 3496 Warm and Outdoor Storage Facility X X

P 3498 Consolidated Brigade Motor Pool X X X X X

P 3562 American Tire X X X X

8 July 2015

Table 1. List of Industrial Facilities and Activities (continued)

In d u st ri al s ec to r

Building number

Description

Activity with Potential to Pollute Storm Water

F u el in g /D e-fu el o ve

G ro u u id

S to ra g e T ic le

, A ir cr

E q u ip m en t M ai n te n ic le

, A ir cr

E q u ip m en t W as h ad in g /U n lo ad er u st ri al

W ag em en t

O u td o o r

S to ra t S to ra g e

P 3730 Automotive Skills Center X X X X X

P 4050 MWR Outdoor Recreation Equipment Issue Shop X X X X X

P 4058 Army and Air Force Exchange Service (AAFES) Express Fueling Station

X X X X

P 5010 DLA Disposition Services Complex

X X

P 5109 Fort Wainwright Range Control X X X X X X

J FWA Quarry Badger Pit X

Fort Wainwright properties at Donnelly Training Area (DTA)

P 1343 Beales Range Maintenance Facility X X X X X X

P 1610 Texas Range Complex X X X X X X

P 1844 & 1848 Mobility Test Complex X X X X X X

P 1881 Meadows Shelter X X X X X X X

P 1930 Bolio Lake Complex X X X X X X

J DTA Quarry Firing Point Sally Pit X

Fort Wainwright property at Black Rapids Training Area

P 2020 Black Rapids Maintenance Facility X X X X X X X

* This list is subject to change; some facilities that were classified as “industrial-like” in previous SWPPPs, as well as some that don’t strictly meet the definition of “industrial” may be managed under the MS4 SWMP, once ADEC issues Fort Wainwright an MS4 Permit.

9 July 2015

1.3.2 No Exposure Certification

Appendix C (Definitions) of the MSGP defines “No Exposure” as:

No exposure – all industrial materials or activities are protected by a storm-resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff.

Facilities that do not conduct industrial activities that are exposed to storm water, including materials storage, and that do not have industrial residues or historic contaminants exposed to storm water, may claim conditional exclusion from MSGP coverage. EPA guidance6 on No Exposure states that facility operators claiming No Exposure must regularly evaluate conditions at their facility to ensure that conditions have not changed that would influence exposure to storm water. If conditions change that result in exposure, operators must apply for a storm water permit.

EPA guidance also states that only an entire facility can apply for No Exposure exclusion, not individual outfalls or parts of a facility. Therefore, if an industrial activity at Fort Wainwright is conducted in a manner that eliminates exposure to storm water, but meets the requirements for coverage under the MSGP, it must remain covered by the installation MSGP and be managed accordingly in the SWPPP. Only if all industrial activities met the No Exposure criteria could the exclusion be utilized by Fort Wainwright.

A circumstance in which a Fort Wainwright facility may not have to implement all requirements of the MSGP during all calendar quarters is if the facility is inactive and unstaffed.

Requirements for inactive and unstaffed facilities are discussed in Section 1.3.3, below.

1.3.3 Exception for Inactive and Unstaffed Sites

If no industrial activities or materials are exposed to storm water at a facility while temporarily inactive and unstaffed, benchmark monitoring requirements do not apply. Part 7.2.1.6 of the MSGP lists three actions/conditions that facilities must satisfy to exercise this exclusion:

Permittees must maintain a statement onsite with the SWPPP stating that the site is inactive and unstaffed, and that there are no industrial materials or activities exposed to storm water in accordance with the substantive requirements in 40 CFR 122.26(g) and sign and certify the statement in accordance with Appendix A, Subsection 1.12.

If circumstances change and industrial materials or activities become exposed to storm water or the facility becomes active and/or staffed, this exception no longer applies and the permittee must immediately begin complying with the applicable benchmark

6 Guidance Manual for Conditional Exclusion from Storm Water Permitting Based on “No Exposure” of Industrial

Activities to Storm Water, EPA, undated (found at: http://www.epa.gov/region6/6en/w/sw/phaseii/no_exp4.pdf)

10 July 2015 monitoring requirements under Part 7.2 as if they were in their first year of permit coverage. The permittee must indicate in their first benchmark monitoring report that their facility has materials or activities exposed to storm water or has become active and/or staffed.

If the permittee is not qualified for this exception at the time they are authorized under this permit, but during the permit term they become qualified because their facility is inactive and unstaffed, and there are no industrial materials or activities that are exposed to storm water, then the permittee must notify ADEC of this change in their next benchmark monitoring report. A permittee may discontinue benchmark monitoring once they have notified ADEC, and prepared and signed the certification statement described above concerning their facility’s qualification for this special exception.

Additional exclusions from MSGP requirements are granted to facilities identified by Sectors G, H, and J. Of these three sectors, only Sector J (Non-Metallic Mineral Mining and Dressing) applies to Fort Wainwright. Gravel quarrying operations sometimes occur on the cantonment and at DTA. Sector J facilities that meet the criteria detailed in MSGP Part 11.J.8.1 may waive additional assessments and inspections. This is discussed in more detail in Section 5.1.1 of this

SWPPP.

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2.0 FACILITY DESCRIPTION AND CONTACT INFORMATION

2.1 Facility Description Information

2.1.1 Overview of Fort Wainwright Facility

Fort Wainwright is a military reservation located in central Alaska, north of the Alaska Range, in the Tanana River Valley. The installation consists of the main post, or cantonment, and outlying training and maneuver areas. These areas include Tanana Flats Training Area, Yukon Training Area, DTA, Gerstle River Training Area, Black Rapids Training Area (BRTA), and Whistler Creek Rock Climbing Area. The cantonment lies within the Fairbanks North Star Borough, east of Fairbanks, in the Chena River drainage basin. The location of the cantonment is shown on the General Location Map: Fort Wainwright Cantonment and Vicinity in Appendix A; training areas are displayed on the Location of Fort Wainwright Lands figure, also in Appendix A. Fort Wainwright’s cantonment is composed of approximately 5,785 acres of urban area, residential developments, support facilities, and the Ladd Army Airfield.

Fort Wainwright’s primary industrial activities occur at the cantonment. To a lesser extent, industrial activities also occur at DTA and BRTA. DTA is south of Delta Junction, approximately 100 miles southeast of Fairbanks. Industrial activities at DTA occur at Cold Regions Test Center (CRTC) facilities, maintenance facilities associated with DTA ranges, a DPW-contractor maintenance facility, and a quarry. Although CRTC command and control is located at Fort Greely (also south of Delta Junction), the test facilities and ranges are located on DTA property.

This explains why Fort Wainwright is responsible for environmental compliance at CRTC facilities. The Northern Warfare Training Center (NWTC) operates a training facility at BRTA, located south of DTA, just off the Richardson Highway. NWTC’s administrative control is located at the Fort Wainwright cantonment. The activities that occur at these respective locations are discussed further in this document.

Fort Wainwright has historically been tasked with commanding, training and maintaining assigned military units at a state of readiness required for ground defense of Alaska. Currently, Fort Wainwright is the home of the United States Army Garrison (USAG) and units of the United States Army Alaska (USARAK) including the 1st Stryker Brigade Combat Team, 25th Infantry Division, the 16th Combat Aviation Brigade (Alaska), and the Medical Department Activity- Alaska. The 1st Stryker Brigade Combat Team’s mission is "… to rapidly deploy and conduct decisive operations in the Pacific region, in order to build capabilities in partnered countries and deter hostile actions from threats to national security."7

Fort Wainwright PWE is the office within the DPW that manages environmental compliance.

PWE at Fort Wainwright is located at 3023 Engineer Place, Building 3023, Fort Wainwright, AK

7 http://www.wainwright.army.mil/1_25_SBCT/mission.html

12 July 2015

99703-4500. Fort Wainwright is a federal facility, not located in Indian Country. Geographical coordinates for the center of Ladd Army Airfield at Fort Wainwright are: N 64º 50’ 15” Latitude and W 147º 36’ 52” Longitude.8

2.1.2 Industrial Activity Area

Part 2.1.8.3 of the MSGP requires the SWPPP to include an estimate of the area of industrial activity exposed to storm water. Due to the size of the installation and the fact that industrial activities are spread out across the cantonment, it is difficult to arrive at an exact figure. Adding together the respective sub-catchment (i.e., mini-watershed) areas of outfalls that discharge industrial storm water, however, provides a conservative estimate of the area of industrial activity exposed to storm water. The combined area of sub-catchments with industrial activity occurring within them equals 1,660 acres.9 However, it should be noted that an entire sub-catchment area might not be exposed to industrial activity or runoff from those activities. The approximate area of industrial activity exposed to storm water at DTA is 25 acres, and just over four acres at BRTA.

2.2 Discharge Information

Industrial activities at Fort Wainwright discharge to the Fort Wainwright regulated small MS4.

See Section 1.2.2 of this document for MS4 background. The Fort Wainwright MS4 discharges storm water to the Chena River, Badger Pit, Clear Creek Channel10 (a semi-ephemeral, channelized, and ditched stream that flows through the cantonment), Monterey Lakes, and various wetlands on the installation. These bodies are all considered waters of the U.S. for purposes of APDES compliance.

The MSGP defines impaired waters as those which have been listed pursuant to Section 303(d) of the CWA and states that if the permittee discharges to an impaired water body, each pollutant for which the water body is impaired must be monitored (if there is a standard analytical method for that parameter). The Chena River is 303(d) listed as an impaired water body for sediment.

No completed total maximum daily load (TMDL) for sediment in the Chena River had been established at the time this SWPPP was prepared.

It is unlikely that sediment would be present in discharges from industrial activities at Fort Wainwright. With the exception of Sector J activities, ground disturbance does not occur during normal activities at industrial facilities on the installation. Most conveyances are comprised of

8 www.wainwright.army.mil.

9 Sub-catchment data from Center for Environmental Management of Military Lands, Colorado State University, February 2013

10 Clear Creek Channel has been heavily modified over the years; unless a Jurisdictional Determination states otherwise, Fort Wainwright will manage Clear Creek Channel as a water of the U.S.

13 July 2015 long, permeable ditches, swales, and vegetated buffers, which largely allows sediment to settle out prior to reaching the Chena River. Sediment on vehicles, equipment, and aircraft is typically rinsed off at contained wash racks. Sector J activities at Fort Wainwright discharge to Badger Pit, not the Chena River, and construction activities are regulated, as applicable, by the ACGP and/or an Erosion and Sediment Control Plan (ESCP). Section 6.4 of this SWPPP details impaired waters monitoring requirements at Fort Wainwright.

Industrial sectors at Fort Wainwright subject to Effluent Limitations Guidelines (ELGs) monitoring under the MSGP include Sectors J and L. Doyon Utilities is responsible for environmental compliance at the CHPP at Fort Wainwright; at the time this SWPPP was prepared, Doyon had certified No Exposure at the CHPP, thus terminating MSGP coverage for that facility. See Section 6 of this SWPPP for a more detailed discussion of monitoring requirements at Fort Wainwright.

ELGs for Sector J that may be applicable at Fort Wainwright involve mine dewatering discharges at construction sand and gravel mining facilities. This monitoring is only applicable if such activities are conducted at Fort Wainwright. See Part 11.J.9 of the MSGP and Section 6.3 of this SWPPP for more discussion of ELGs for Sector J.11

Non-hazardous waste landfills subject to effluent limitations in 40 CFR Part 445 Subpart B are presented in Part 11.L.10 of the MSGP. Monitoring of the parameters listed in that section of the permit must occur prior to discharges from the landfill mingle with other flows.

2.3 Post Hydrology

2.3.1 Overview of Hydrology at Fort Wainwright

Fort Wainwright lies within the floodplain of the Chena and Tanana Rivers. The main post area is underlain by an alluvial aquifer fed during high flow periods by both the Tanana and Chena Rivers. The Tanana River is fed by rainfall and melt-water from glaciers and snowfields in the Alaska Range; maximum discharge typically occurs in July. Minimum discharge from the Tanana usually occurs in late winter when the river is fed by groundwater. Low flow in the Chena typically occurs during winter months. Flow in the Chena River tends to peak earlier than the Tanana, since the Chena is primarily non-glacier fed.

Fort Wainwright’s main post relies on the Chena River Lakes Flood Control Project for flood protection. The project consists of an earth-fill dam across the Chena River east of the cantonment, a levee along the north bank of the Tanana River, and a series of drainage ditches.

Large drainage ditches on Fort Wainwright are part of the flood control system, providing

11 At the time this SWPPP was prepared, no mine dewatering activities were occurring or planned; this requirement is included for future reference.

14 July 2015 temporary detention capacity for excess Chena River flows. This explains why river water backs up outfall channels during high water when there are no discharges.

The surface water drainage system at Fort Wainwright is almost entirely comprised of grass-covered surface channels. Soils in the Fort Wainwright area are generally Chena alluvium, consisting mainly of silty gravel. These soils are well drained and have high permeability, when not frozen. The presence of permafrost under various portions of the cantonment area inhibits infiltration of surface water in those areas. Permafrost still remaining in the cantonment area is generally restricted to undeveloped areas supporting forested and scrub shrub wetlands, which are areas generally unsuitable for industrial activities and future construction.

The topography of the cantonment area is generally flat, except for Birch Hill in the northern part of the cantonment area. Much of the cantonment area is unpaved, except for roads, parking areas, airfield runways and ramps. Fort Wainwright receives an average of approximately 10.9 inches of precipitation per year,12 of which about 6.5 inches falls in June through September. A significant portion of the annual precipitation occurs as snowfall (the average annual snowfall is 65 inches).13 An extreme rainfall event in Fairbanks (the 25-year, 24-hour storm) is about 2.7 inches. A more typical large rainfall event (the 2-year, 24-hour storm) is about 1.25 inches.

Under typical rainfall conditions, storm water runoff from the post is low. Most annual runoff is expected to be generated by initial snowmelt in spring (usually April). Due to the flat topography and generally permeable soils in the area, much of the non-snowmelt water infiltrates before it reaches a surface water body. Water tends to accumulate in low areas during spring break-up, due to the relatively flat terrain (United States Army Corps of Engineers [USACE] 1987). Once thawed, soil permeability increases allowing for relatively quick drainage. Standing water is more common in the south post area than elsewhere on post.

2.3.2 Industrial Outfalls at Fort Wainwright

The following outfalls were managed under the 2008 MSGP and associated Fort Wainwright SWPPP: 1, 2, 3, 4, 5, 6, 7, 8a, 8b, 9, 10, and 11. In February 2013, the Center for Environmental Management of Military Lands (CEMML) conducted a storm water survey and model to detail surface runoff drainage features on the installation. To determine which outfalls on the installation required coverage under the 2015 MSGP, facility-specific information was considered along with data from the 2013 CEMML study. At the time this SWPPP was prepared, two outfalls had been removed from the previous list, and three were added, for a total of 13 industrial outfalls currently active on the installation: Outfalls 1, 2, 3, 4, 5, 7, 8a, 8b, 9, 10, 12, 13, and 14.14 At the time this SWPPP was prepared, Fort Wainwright did not intend on

12 http://www.fairbanks.climatemps.com/

13 http://www.currentresults.com/Weather/Alaska/annual-snowfall.php

14 See the Fort Wainwright Cantonment figure in Appendix A for outfall locations.

15 July 2015 exercising the “substantially identical outfall” monitoring exception described in Part 7.2.2.2 of the MSGP.

2.3.2.1 Industrial Outfalls Removed from MSGP Coverage

Industrial activities are no longer performed within the sub-catchment area of Outfall 6, and there is no reason to believe that previous activities left any legacy pollutants that could adversely affect runoff to the outfall. Therefore, Outfall 6 has been removed from MSGP coverage.

Outfall 11 was referred to in Fort Wainwright’s previous industrial SWPPP as a “point of compliance” because rather than an actual outfall to waters of the U.S., it was a simply a sampling location under the previous permit term; River Road intersected a ditch extending from the inactive portion of the landfill at that location. Runoff from the active portion of the landfill drains to wetlands on the northwest, north, and east side of the facility, but in the form of sheet flow (i.e., there is no point source discharge). The active portion of the landfill drains to a sub-catchment separate from the sub-catchment that contained the former Outfall 11.

During an ADEC compliance audit in 2011, the PWE Water Program Manager, ADEC compliance inspector, and PWE storm water compliance consultant evaluated the drainage area for potential flows to the Chena River. Because there was no apparent outfall to waters of the U.S. and no runoff from the active portion of the landfill is directed to the Chena River, The ADEC compliance inspector recommended removing Outfall 11 from MSGP coverage during the next major SWPPP update.15

During SWPPP preparation, Fort Wainwright was in the process of requesting a Jurisdictional Determination (JD) from the USACE Regulatory Division concerning the areas around, and down-slope of the landfill. This JD will identify any waters around the landfill area that would require coverage under the CWA. Should conditions change such that a point source discharge from active landfill activities can reach an outfall to waters of the U.S., Fort Wainwright will manage that outfall under the MSGP and include it in this SWPPP.16

2.3.2.2 New Industrial Outfalls Included for Coverage Under the 2015 MSGP

Existing outfalls that have been established for many years have retained their names, to reduce confusion that would likely result if their names were changed in this SWPPP. Since former Outfall 11 was the highest number previously identified, new outfalls are numbered

15 In the compliance report resulting from this audit that was provided to Fort Wainwright on February 17, 2011, the

ADEC compliance inspector stated the following: “OF11 is supposed to receive drainage from the landfill area. Due to topography, it is doubtful that any runoff from the landfill would ever reach the Chena River.”

16 The landfill facility continues to be managed under the MSGP and this SWPPP.

16 July 2015

“Outfall 12” and up. Outfall 1217 discharges to wetlands adjacent to the Chena River northeast of Outfall 4 and southwest of Outfall 5, and drains the northwest portion of the airfield. Outfall 13 discharges to the Chena River at the east end of the airstrip, between Outfalls 8a and 8b.

Outfall 1318 receives runoff from a portion of the tarmac north of the Aviation Re-fuel Facility (Building 2078, previously referred to as the Forward Area Refueling Point), and portions of the west end of the airfield. Outfall 1419 discharges to Badger Pit and is located between Outfalls 9 and 10. Outfall 14 receives runoff from the motor pools west of Badger Pit.

2.4 Contact Information/Responsible Parties

2.4.1 Facility Operator/Owner

US Army Garrison Fort Wainwright ATTN: IMFW-PWE (C. Seibel) 1060 Gaffney Road #4500, Fort Wainwright, AK 99703-4500

2.4.2 SWPPP Contact

Sarah Runck or current PWE Water Program Manager Directorate of Public Works ATTN: IMFW-PWE (S. Runck) 1060 Gaffney Road, #4500 Fort Wainwright, AK 99703-4500 Phone: (907) 361-9687 Email:…