TE-H-21 SWPPP_Final_2024-with-appendices.pdf

STORM WATER POLLUTION PREVENTION PLAN

(SWPPP)

USAG STUTTGART

Effective Date:

July 2005 USAG Stuttgart Revision Date:

September 2024

Storm Water Pollution Prevention Plan (SWPPP) Document Owner:

Environmental Division Update Requirements:

Annual

USAG Stuttgart

September 2024

This page intentionally left blank.

APPROVALS

This Storm Water Pollution Prevention Plan (SWPPP) is an engineering and management strategy prepared specifically for the U.S. Army Garrison (USAG) Stuttgart to improve the quality of the storm water runoff and thereby improve the quality of receiving waters.

This SWPPP satisfies the requirement to develop and implement a storm water pollution prevention plan contained in the German Final Governing Standards (GFGS), Chapter 4, Wastewater, and Section 4.3.4.1. This plan must be updated annually.

Approved By:

ANJA EMMENECKER

DPW, Chief Environmental Division

MARISA K., BARRIE

Director of Public Works

G. Kirk Alexander

COL,

Commanding

USAG Stuttgart Storm Water Pollution Prevention Plan

Executive Summary

This Storm Water Pollution Prevention Plan (SWPPP) is an engineering and management strategy prepared specifically for the USAG Stuttgart to reduce the pollutant load in storm water runoff and thereby improve the quality of receiving waters. The SWPPP consists of a series of steps and activities to identify potential sources of storm water pollutants and to implement best management practices (BMPs). BMPs can range from low-cost measures, such as good housekeeping practices, to higher cost measures, such as the construction of secondary containment for a tank.

Several higher cost BMPs are identified in this SWPPP and are summarized below.

Since the last update, significant progress has been made in keeping stormwater infrastructure inspections up to date and identifying deficiencies. Diligence is now required to correct deficiencies to ensure the functionality of existing BMPs.

The structural and potentially high-cost BMPs identified throughout USAG Stuttgart during the 2024 SWPPP update, with few exceptions, consist of the repair of existing infrastructure. Numerous major deficiencies were identified during General Inspections of the Oil Water Separators (OWS) around the garrison which must be repaired to ensure their functionality. Units requiring major repairs according to current maintenance reports include:

• Stuttgart Army Airfield (SAAF): OWS # 7722-3

• Panzer Kaserne: OWS # 7725-4

• Patch Barracks: OWS # 7727-4

• Kelley Barracks: 7737-2

Additionally, OWS # 7727-3 at the Patch Barracks Power Plant #2 is beyond repair and a replacement is programmed.

At Kelley Barracks, further structural BMPs which are recommended for Kelley Barracks are the addition of an OWS to the parking area behind Building 3320 which contains several shops performing vehicle maintenance. The addition of an OWS would be particularly needed if disabled vehicles are parked or repairs are conducted in the parking lot. An additional BMP would be the enlargement of the 405th AFSB BASOPS workspace to allow indoor maintenance of oversized equipment. The unit must currently send such equipment offsite if it does not fit in the current work center.

It is recommended to review and re-structure the drainage system at the Family Morale, Welfare, and Recreation (FMWR) car wash at Patch Barracks, to ensure all water associated with the wash system is routed through the OWS and to the combined sewer system. It is also recommended to curb and treat the bulk fuel transfer area at Power Plants #1, #2, and #3 with functional OWS.

Finally, vegetation growth was observed in the secondary containment for Power Plant #2, which can indicate that the containment is no longer tight.

At the SAAF, it is recommended to treat runoff from the fire department wash rack with an OWS before it enters the combined sewer as well as renewing the surface of the wash rack which has numerous cracks and vegetation growth. It is additionally, at the mobile fuel point near Facility 3215 it is recommended to curb and cover the fuel transfer area and treat runoff from that location with an OWS. The fuel point at the Golf Course should also be covered with a sealed roof structure to protect the Fueling Pad area from storm water.

Finally, it is generally recommended to improve the accuracy of the stormwater infrastructure maps though surveying, particularly at Robinson Barracks.

USAG STUTTGART STORM WATER POLLUTION PREVENTION PLAN

RECORD OF REVISIONS

This SWPPP was originally prepared in July 2005 and must be reviewed and updated annually in accordance with Section 4.3.4.1 of the Final Governing Standards for Germany (GFGS). To fulfill this requirement, the following table is provided for tracking revisions to this plan. Revisions may include:

• new activities;

• discontinued activities; and/or

• changes at an existing activity, such as the use of a new fuel or solvent.

It may also be necessary to amend this SWPPP to include more effective pollution prevention technologies and BMPs, if implementation will reduce the likelihood of storm water contamination.

Revision No. Date Name and Title Signature Pages Affected

1 Nov 2006 Joseph Waring DPW Environmental Engineer

As per Sec. 4.2 of this plan, an annual activity

& site eval. was performed in Nov 06

2 Dec 2006 Joseph Waring DPW Environmental Engineer

Cover, ASG to USAG throughout, and various other changes Pgs. 3-5, 3-6, 4-17, Appendix 2

3 Dec 2006 Joseph Waring DPW Environmental Engineer

Wash Rack near Bldg 2992 has been permanently taken out of service

4 Feb 2010

DPW Environmental Division and

AMEC Earth & Environmental GmbH

All

5 May

Anja Emmenecker, DPW Environmental Division

Cover, Table of contents, Chapters 1, and 2

6 Dec 2015 DPW Environmental

Division and URS International Inc.

All

7 Dec.

DPW Environmental Division and

AECOM International Inc.

Predominantly up-date of storm water situation at Panzer Kaserne and Kelley

Barracks http://www.denix.osd.mil/denix/DOD/Library/Intl/FGS/final-gov-stds-dod.html

Revision No. Date Name and Title Signature Pages Affected

8 June

DPW Environmental Division and

Tetra Tech Inc.

Comprehensive Update.

Significant changes include Panzer

Kaserne Vehicle Maintenance area

USAG Stuttgart Storm Water Pollution Prevention Plan i

TABLE OF CONTENTS

SECTION PAGE NUMBER

SWPPP FACT SHEET

1 INTRODUCTION ................................................................................................................... 1-1

1.1 PURPOSE ....................................................................................................................... 1-1

2 KEY PERSONNEL ................................................................................................................ 2-1

2.1 USAG Stuttgart Commander ........................................................................................... 2-1

2.2 SWPP Manager ............................................................................................................... 2-1

3 SITE OVERVIEW .................................................................................................................. 3-1

3.1 INDUSTRIAL ACTIVITY SUMMARY............................................................................... 3-1

3.1.1 Aircraft Ground Support Equipment Maintenance .............................................. 3-1

3.1.2 Aircraft / Runway Deicing Operations .................................................................. 3-1

3.1.3 Aircraft / Vehicle Fueling Operations .................................................................... 3-2

3.1.4 Aircraft / Vehicle Maintenance and Repair ........................................................... 3-2

3.1.5 Aircraft / Vehicle Washing ...................................................................................... 3-2

3.1.6 Bulk Fuel Storage Areas ........................................................................................ 3-3

3.1.7 Construction / Land Disturbing Activities ............................................................ 3-3

3.1.8 Corrosion Control Activities .................................................................................. 3-3

3.1.9 Hazardous Substance Storage .............................................................................. 3-3

3.1.10 Outdoor Material Storage Areas ............................................................................ 3-4

3.1.11 Pesticide and Herbicide Operations ..................................................................... 3-4

3.1.12 Power Production ................................................................................................... 3-4

3.1.13 Vehicle Storage Yards ............................................................................................ 3-4

3.1.14 Typical Pollutants ................................................................................................... 3-5

3.1.15 Other Industrial Activities and Pollution Sources ............................................... 3-6

3.2 STORM WATER DRAINAGE SUMMARY ...................................................................... 3-6

3.2.1 Kelley Barracks ....................................................................................................... 3-8

3.2.2 Panzer Kaserne ....................................................................................................... 3-9

3.2.3 Patch Barracks ...................................................................................................... 3-10

3.2.4 Stuttgart Army Airfield (SAAF) ............................................................................ 3-10

3.2.5 Kornwestheim Golf Course .................................................................................. 3-12

ABBREVIATIONS

(continued)

USAG Stuttgart Storm Water Pollution Prevention Plan ii

3.2.6 Robinson Barracks ............................................................................................... 3-12

3.3 LICENSED WASTEWATER TREATMENT FACILITY .................................................. 3-13

3.4 SITE MAPS.................................................................................................................... 3-13

4 BMP AND SITE ASSESSMENT PROCESS ........................................................................ 4-1

4.1 BEST MANAGEMENT PRACTICES ............................................................................... 4-1

4.2 ACTIVITY AND SITE EVALUATION ............................................................................... 4-1

4.3 PROPOSED BMP IMPLEMENTATION ........................................................................ 4-21

5 TRAINING ............................................................................................................................. 5-1

USAG Stuttgart Storm Water Pollution Prevention Plan iii

LIST OF TABLES

Table 1-1 Regulatory Cross Reference Matrix

Table 2-1 SWPP Key Personnel

Table 3-1 Typical Pollutants Associated with Industrial/Construction Activities

Source Activities by Building Number

Table 4-1a Kelley Barracks: Source Activities by Building Number

Table 4-1b Panzer Kaserne: Source Activities by Building Number

Table 4-1c Patch Barracks: Source Activities by Building Number

Table 4-1d Stuttgart Army Airfield: Source Activities by Building Number

Table 4-1e Kornwestheim Golf Course: Source Activities by Building Number

Table 4-1f Robinson Barracks: Source Activities by Building Number

Potential Storm Water Pollutants

Table 4-2a Kelley Barracks: Potential Storm Water Pollutants

Table 4-2b Panzer Kaserne: Potential Storm Water Pollutants

Table 4-2c Patch Barracks: Potential Storm Water Pollutants

Table 4-2d Stuttgart Army Airfield: Potential Storm Water Pollutants

Table 4-2e Kornwestheim Golf Course: Potential Storm Water Pollutants

Table 4-2f Robinson Barracks: Potential Storm Water Pollutants

USAG Stuttgart Storm Water Pollution Prevention Plan iv

Storm Water Best Management Practices

Table 4-3a Kelley Barracks: Storm Water Best Management Practices

Table 4-3b Panzer Kaserne: Storm Water Best Management Practices

Table 4-3c Patch Barracks: Storm Water Best Management Practices

Table 4-3d Stuttgart Army Airfield: Storm Water Best Management Practices

Table 4-3e Kornwestheim Golf Course: Storm Water Best Management Practices

Table 4-3f Robinson Barracks: Storm Water Best Management Practices

Storm Water Outfalls

Table A-2.1.a Kelley Barracks: Outfalls with Industrial Activities

Table A-2.1.b Panzer Kaserne: Outfalls with Industrial Activities

Table A-2.1.c Patch Barracks: Outfalls with Industrial Activities

Table A-2.1.d Stuttgart Army Airfield: Outfalls with Industrial Activities

Table A-2.1.e Kornwestheim Golf Course: Outfalls with Industrial Activities

Table A-2.1.f Robinson Barracks: Outfalls with Industrial Activities

APPENDICES

APPENDIX 1 USAG Stuttgart Maps – SWPPP-Specific

Figure A-1.1 Kelley Barracks [GE 44F]

Figure A-1.2 Kelley Barracks [GE44F] Overview Map

Figure A-2.1 Panzer Kaserne (Northern Part) [GE 643]

Figure A-2.2 Panzer Kaserne (Southern Part) [GE 643]

Figure A-2.3 Panzer Kaserne (Elementary and High Schools) [GE 643]

Figure A-3 Patch Barracks [GE 656]

Figure A-4 Stuttgart Army Airfield (SAAF) [GE 19B] Figure A-5 Kornwestheim Golf Course [GE 46J]

Figure A-6 Robinson Barracks [GE 72T]

APPENDIX 2 Storm Water Outfalls

APPENDIX 3 BMP Checklists

APPENDIX 4 SWPPP Training Form

APPENDIX 5 Storm Water Compliance Plan

USAG Stuttgart Storm Water Pollution Prevention Plan v

LIST OF ABBREVIATIONS

AAFES Army & Air Force Exchange Service

ACP Access Control Point

AE Army in Europe

AFSB Army Field Support Brigade

AST Aboveground Storage Tank

BMC Base Maintenance Contract

BMP Best Management Practice

DLA Defense Logistics Agency

DPW Directorate of Public Works

ED Environmental Division

EO Executive Order

FGDC Federal Geographic Data Committee

FMWR Family and Morale, Welfare and Recreation

FSG Airport Stuttgart (“Flughafen Stuttgart”)

GFGS German Final Governing Standards

GSE Ground Support Equipment

HM Hazardous Material

HW Hazardous Waste

HWAP Hazardous Waste Accumulation Point

HWSA Hazardous Waste Storage Area

LTA Local Training Area

MEP Maximum Extent Practicable

MOGAS Motor Gasoline

MP Military Police

NCO Non-Commissioned Officer

NSWU/2 Naval Special Warfare Unit 2

O&M Operation and Maintenance

OWS Oil/Water Separator

POC Point of Contact

POL Petroleum, Oil, and Lubricant

POV Privately Owned Vehicles

SAAF Stuttgart Army Airfield

SDS Spatial Data Standards

SFG Special Forces Group

SWPPP Storm Water Pollution Prevention

SWPPP Storm Water Pollution Prevention Plan

USAG Stuttgart Storm Water Pollution Prevention Plan vi

TOC Total Organic Content

TLSC-E / MAV Theater Logistics Support Center Europe / Maintenance Activity Vilseck

USAG United States Army Garrison

USAREUR United States Army in Europe

USAG Stuttgart Storm Water Pollution Prevention Plan vii

USAG Stuttgart Storm Water Pollution Prevention Plan viii

USAG Stuttgart Storm Water Pollution Prevention Plan 1-1

1 INTRODUCTION

This Storm Water Pollution Prevention Plan (SWPPP) is an engineering and management strategy prepared specifically for the United States Army Garrison (USAG) Stuttgart to reduce the pollutant load in storm water runoff and thereby improve the quality of receiving waters.

The SWPPP consists of a series of steps and activities to identify potential sources of storm water pollutants and to implement best management practices (BMP). BMPs are processes, procedures, and schedules of activities, prohibitions on practices, and other management practices that could prevent or reduce the concentration of pollutants in storm water runoff.

1.1 PURPOSE

This SWPPP satisfies the requirement to develop and implement a SWPPP contained in Section 4.3.4.1 of the Final Governing Standards for Germany (GFGS). Each of the components of this SWPPP correspond to GFGS requirements, as documented in Table 1-1.

This SWPPP has been prepared in accordance with standard engineering practices. The pollution prevention approach in this SWPPP focuses on three major objectives.

1. Identifying sources of pollution potentially affecting the quality of storm water discharges from areas of the USAG Stuttgart associated with industrial and/or construction activities.

2. Describing practices to minimize and control the pollutant load in storm water discharges from areas of the USAG Stuttgart associated with industrial and/or construction activities.

3. Training personnel to ensure effective implementation of the SWPPP. Personnel who handle hazardous substances or perform activities that could contribute pollution to wet weather events should be trained in the components and objectives of the SWPPP.

The Directorate of Public Works (DPW), Environmental Division (ED) is responsible for maintaining an updated and accurate version of the SWPPP. They should maintain the updated document in a permanent location to facilitate ongoing interdepartmental reviews, public inquiries, or unannounced reviews conducted by a regulatory agency.

Table 1-1. Regulatory Cross Reference Matrix

Storm Water Pollution Prevention Plan (SWPPP)

GFGS Section Description SWPPP Section Remarks

C4.3.4.1 Develop and Implement SWPPP 2.0 / 3.0 / 4.0

C4.3.4.2 Employee Training 5.0

C4.3.4.3 Licensed Wastewater Treatment Facility

3.3 N/A

USAG Stuttgart Storm Water Pollution Prevention Plan 1-2

USAG Stuttgart Storm Water Pollution Prevention Plan 2-1

2 KEY PERSONNEL

2.1 USAG Stuttgart Commander

The USAG Stuttgart Commander is responsible for all activities at the Garrison, including ensuring compliance with the SWPPP. The USAG Stuttgart Commander shall also be responsible for approval of any major revisions to the SWPPP. Minor revisions may be made by the Storm Water Pollution Prevention (SWPP) Manager without the approval of higher command.

2.2 SWPP Manager

The SWPP Manager, identified in Table 2-1, is responsible for implementing the SWPPP, preparing annual revisions to the SWPPP, and ensuring compliance with SWPPP requirements at all tenant/unit facilities throughout the USAG Stuttgart. The SWPP Manager shall review plans for new construction or remodeling for erosion control, maintenance, and recommended BMPs, to determine if a revision to the SWPPP is required.

The SWPP Manager shall also coordinate training in storm water pollution prevention, to include the elements identified in Section 3.

Table 2-1: SWPP Key Personnel

Position/Task Unit/Activity Name Telephone Number E-mail Address

USAG Stuttgart Commander

USAG

Stuttgart Commander

COL G. Kirk Alexander

596-1300 N/A

Director of Public Works

DPW MARISA K. BARRIE 596-6101 N/A

SWPP Manager DPW-ED PAT GRIFFIN 596-6136 patrick.m.griffin26.civ@army.mil mailto:christoph.j.leiss.LN@army.mil

USAG Stuttgart Storm Water Pollution Prevention Plan 2-2

USAG Stuttgart Storm Water Pollution Prevention Plan 3-1

3 SITE OVERVIEW

A review of the industrial activities occurring at the USAG Stuttgart is necessary to facilitate pollution prevention. During this evaluation, the Garrison identifies industrial or construction activities that could potentially affect the quality of storm water discharges from the USAG Stuttgart (both point sources and non-point sources). The Garrison then identifies the specific pollutants associated with these activities. The industrial activities and pollutant sources at the USAG Stuttgart are identified on base maps including the outline of the Garrison storm drainage system. The maps are attached as Appendix 1.

3.1 INDUSTRIAL ACTIVITY SUMMARY

The USAG Stuttgart commands six geographically separate installations that house activities considered industrial in nature and that will be addressed in this SWPPP. The installations are:

• Kelley Barracks [GE44F],

• Panzer Kaserne [GE643],

• Patch Barracks [GE656],

• Stuttgart Army Airfield (SAAF) [GE19B],

• Kornwestheim Golf Course [GE46J], and

• Robinson Barracks [GE72T].

The remaining installations under USAG Stuttgart command do not support activities that are industrial in nature and will not be considered in this plan.

The below activities are classified as industrial in nature. Changes to the type of activities being performed and/or their locations are included in the below activity summary and in the Activity and Site Evaluation results in Tables 4-1a. to Table 4-1f.

3.1.1 Aircraft Ground Support Equipment Maintenance

Storm water discharges covered in this category include runoff from areas where the following aircraft ground support equipment maintenance activities may occur: fluid changes, mechanical repairs, parts cleaning, sanding, refinishing, painting, washing, storage of vehicles and equipment waiting for repair or maintenance, and storage of the related materials and waste materials such as oil, fuel, batteries, tires, or oil filters.

Aircraft ground support equipment (GSE) storage and minimal maintenance occurs only at Building 3227 (Hangar 5) at the SAAF.

3.1.2 Aircraft / Runway Deicing Operations

Storm water discharges covered in this category include runoff from areas where aircraft deicing operation occur. These activities include deicing fluid storage, deicing fluid handling, and deicing of aircraft.

According to the SAAF Airfield Manager, aircraft deicing is not conducted at the SAAF. When aircraft require deicing, they are taxied to areas designated and controlled by Flughafen Stuttgart (FSG) and deicing is conducted in accordance with their requirements.

Runway deicing operations occur anywhere along the flight line and taxiways at SAAF. Deicing of taxiway in front of Hangars 1 through 4 is permitted only when the gate valve to the rainwater retention

USAG Stuttgart Storm Water Pollution Prevention Plan 3-2 basin South is closed according to the above cited memorandum. Deicing operations are the responsibility of the host airport, FSG. FSG is responsible for any leaks or spills and any mitigation efforts that could result from leaks and spills of the deicing fluid.

3.1.3 Aircraft / Vehicle Fueling Operations

Storm water discharges covered in this category include runoff from areas where fueling operations occur for aircraft, motor vehicles, ground support equipment, various fixed generators, and fuel-oil-fired heaters. These activities include fuel delivery to the USAG Stuttgart site, aircraft fuel storage, refueler and pump cart operations, fueling and defueling of aircraft, diesel and motor gasoline (MOGAS) storage, and fuel dispensing.

Aircraft fueling operations are the responsibility of the host airport FSG, which is responsible for any fuel leaks or spills and any mitigation efforts that could result from a fuel leak or spill. According to the Airfield Manager, aircraft are fueled at their designated parking locations on the airfield.

According to airfield policy, fueling is only permitted if the entire footprint of the aircraft is located on paved surface or hardstand. Aircraft fueling should also only be conducted on OWS-connected surfaces.

Vehicle fueling occurs at all installations. Army & Air Force Exchange Service (AAFES) operates a gas station at Patch Barracks (Building 2349). Combined Defense Logistics Agency (DLA) and AAFES fuel points are operated at Kelley Barracks (Building 3324). A DLA gas station is operated at Panzer Kaserne (Building 2953) and a Family Morale, Welfare & Recreation (FMWR) fuel point is operated at Kornwestheim Golf Course (north of Building 977A). An unoccupied mobile fuel point is present near Building 3215 at SAAF. Contractors also occasionally operate small mobile fuel points for their equipment, machines, and vehicles.

3.1.4 Aircraft / Vehicle Maintenance and Repair

Storm water discharges covered in this category include runoff from areas where aircraft and vehicle maintenance activities occur, including fluid changes, mechanical repairs, tire and wheel maintenance, parts cleaning, sanding, refinishing, painting, washing, storage of aircraft and vehicles waiting for repair or maintenance, and storage of the related materials and waste materials such as oil, fuel, batteries, tires, or oil filters.

Outdoor aircraft maintenance occurs on the maintenance pad just north of Hangar 2 (Building 3220) at SAAF; it is also possible that maintenance activities take place in front of the hangars. Hangar 3 (Building 3222) was used for storage and recreation during the 2024 up-date. However, it cannot be excluded that maintenance could occur in front of the hangars.

Vehicle maintenance occurs at all installations except for Patch Barracks and Robinson Barracks.

Vehicle maintenance and repair primarily occurs indoors.

3.1.5 Aircraft / Vehicle Washing

The primary discharge from aircraft and vehicle washing activities is direct runoff from wash racks and other outdoor wash areas.

Aircraft washing only occurs on the aircraft wash rack northwest of Building 3226 at SAAF with the associated OWS system which discharges to the off-post Rainwater Retention Basin South and is strictly enforced. Vehicle wash racks are maintained at all installations except for Robinson Barracks.

USAG Stuttgart Storm Water Pollution Prevention Plan 3-3

3.1.6 Bulk Fuel Storage Areas

Storm water discharges covered in this category include runoff from areas of bulk fuel storage, such as aboveground storage tanks (AST). This activity includes aircraft and vehicle fuel storage, waste fuel storage, heating oil storage, boilers and generators, and mobile tankers.

Aircraft fuel storage at SAAF is managed by the FSG. Petroleum, oil, and lubricant (POL) storage exists throughout all installations, except for Robinson Barracks. A list of POL storage locations is maintained by the DPW-ED and should be referenced for the most up-to-date information on tank locations and status.

3.1.7 Construction / Land Disturbing Activities

Storm water runoff from construction/demolition activities can be detrimental to the water quality of a receiving stream. Sediment runoff caused by the erosion of exposed soil (and entrainment of contaminants) is the primary source of water quality impacts generated during construction activities such as clearing, grubbing, grading, and landscaping.

Construction / land disturbing activities occur on an irregular, as-needed basis at the USAG Stuttgart installations. Large construction projects must be reviewed by the DPW-ED prior to breaking ground.

The DPW-ED will determine if the construction plans are in accordance with the environmental GFGS and Army regulations for new construction.

Major construction projects planned or underway during the 2024 up-date include the Patch sewer line replacement project where major renovation and restoration of the storm and sewer system will be conducted, upgrade of Power Plant 2 at Patch Barracks, renovation of the Child Care Center at Patch Barracks, upgrade of the sewer lines at Robinson Barracks, and construction of a new commissary at Panzer Kaserne. Smaller construction projects were also underway throughout the Garrison.

Requiring and enforcing BMPs such as silt fences and stabilized construction entrances for construction sites will reduce soil entering and clogging the combined sanitary and storm sewer collection systems.

3.1.8 Corrosion Control Activities

Storm water discharges covered in this category include runoff from areas where corrosion control processes occur. The activities associated with corrosion control include aircraft washing operations, aircraft and aircraft parts painting and paint removal, and paint and related product storage.

Large-scale painting operations are contracted out rather than performed by USAG Stuttgart personnel. Paint and related product storage is in accordance with Hazardous Substance Storage regulations and is managed by the DPW-ED.

3.1.9 Hazardous Substance Storage

Storm water discharges covered in this category include runoff from hazardous substance storage, handling, and disposition areas directly exposed to rainfall, such as outdoor storage of product drums or containers. Hazardous substances include both hazardous materials and hazardous wastes.

The USAG Stuttgart maintains one Hazardous Waste Storage Area (HWSA) at Kelley Barracks (Building 3371) and Hazardous Waste Accumulation Points (HWAP) throughout each of the other installations. Hazardous Waste (HW) is managed by the DPW-ED with all HW disposal is contracted out. Hazardous Materials (HM) are stored throughout the installations and managed by their respective

USAG Stuttgart Storm Water Pollution Prevention Plan 3-4 units. The 405th Army Field Support Brigade (AFSB_ Reuse Center at Panzer Kaserne manages the collection of and redistribution of unused HM.

3.1.10 Outdoor Material Storage Areas

Storage areas for new and used materials such as oil, paints, batteries, tires, and filters are included in this plan when either directly exposed to rainfall or when discharges (via building drains or spills to the ground surface) can enter the drainage system.

There are few outdoor material storage areas in the USAG Stuttgart. Roofed structures for material storage do exist at Kelley Barracks (e.g. open storage Building 3370 at DPW Yard); however, due to surface drainage patterns in these areas, there is potential for the materials stored there to be exposed to storm water. Hazardous substances such as antifreeze, oil, and/or cleaner are stored in a partly roofed storage area associated with the AAFES Gas Station (Building 2349) at Patch Barracks.

Released materials may be exposed to storm water and/or enter the drainage system. Storage of propane cylinders in outdoor cages exposed to precipitation is prevalent throughout the garrison but of minimal risk to storm water.

An additional outdoor material storage area was established near Buildings 2338 and 2366 at Patch Barracks. Facility management and ground keepers store various building materials including soil and/or sand at this location. During rain events, this soil/sand material is drained with the surface water run-off into the drainage system; the drainage system is predominantly clogged in this area.

3.1.11 Pesticide and Herbicide Operations

Storm water discharges covered in this category include runoff from areas where chemical pesticide and herbicide applications occur. The associated activities include the preparation and storage of pesticides and herbicides for application.

Kornwestheim Golf Course is the only installation that directly manages pesticide and herbicide operations; storage, handling, and transfer is exclusively conducted in roofed and lockable areas of the Building Complex 979. Pesticide and herbicide application at Robinson Barracks is contracted out and is executed on a just-in-time basis.

3.1.12 Power Production

Storm water discharges covered in this category include runoff from areas where power production processes occur. These activities include generation and distribution of electrical power in support of the Garrison mission, stability and support operations, and emergency operations.

Power production occurs at Patch Barracks at three separate power plants. Diesel ASTs provide the fuel. The AST at Power Plant #3 (adjacent to Building 2374) is covered with a metal roof structure. Power Plant #2 (Building 2316) and the associated infrastructure is currently being upgraded into a larger and a more energy efficient plant. Mobile power generators are facilitated at Kelley Barracks, SAAF, Patch Barracks, and Panzer Kaserne.

3.1.13 Vehicle Storage Yards

Storage areas for vehicles and related support equipment, such as batteries, tires, and filters, are addressed in this plan when either directly exposed to rainfall or when discharge (via building drains or spills to the ground surface) can enter the drainage system.

Vehicle storage yards exist at Kelley Barracks, SAAF, Kornwestheim Golf Course, and Panzer Kaserne. Most long-term vehicle storage at the USAG Stuttgart occurs at Panzer Kaserne. At Kelley Barracks, vehicles are parked at the DPW Yard at Building 3370 and a large parking lot for privately

USAG Stuttgart Storm Water Pollution Prevention Plan 3-5 owned vehicles (POV) is in the center of the installation. The Transportation Motor Pool of the 405th AFSB is situated at the SAAF as well as a lot for unserviceable vehicles. A closed Golf Caddy Garage (Building 980) was built at Kornwestheim Golf Course.

The typical pollutants associated with the industrial activities listed above are presented in a matrix format in Table 3-1.

3.1.14 Typical Pollutants

Table 3-1. Typical Pollutants Associated with Industrial/Construction Activities

ACTIVITY POL

and

Waste POL

Solvents, Antifreeze, Deicing Chem.

Battery Acid

Pesticides and

Herbicides

Detergents and

Cleaners

Oil and Latex

Paints, byproducts

Sediment and

Particulates

Aircraft GSE (1) Maintenance X X X

Aircraft / Runway Deicing X

Aircraft / Vehicle Fueling Operations X

Aircraft / Vehicle Maintenance and Repair

X X X

Aircraft / Vehicle Washing X X X X

Bulk Fuel Storage Areas X

Construction Activities X X

Corrosion Control Activities X X X

Hazardous Substance Storage X X X X X X

Outdoor Material Storage Areas X X X X X X X

Pesticide Operations X

Power Production X

Vehicle Storage Yards X X X X

Notes:

(1) GSE - Ground Support Equipment file://urs.corp.int/Germany-Jobs/Kaiserslautern-Jobs/2%20Archive/43813863_FY14%20Compl+PreventMgmt_Stuttgart/7%20-%20Execution/7.2%20Environmental/7.2.1%20Reports/SWPPP/Final/160405_SWPPP_CD/SWPPP_Update_2015_final_151209%20-%20revised%20SAAF.doc#Table3_1

USAG Stuttgart Storm Water Pollution Prevention Plan 3-6

3.1.15 Other Industrial Activities and Pollution Sources

During the 2023 site walk, the following additional operations or non-point sources where observed:

- Road salt storage facilities (e.g., bunkers or silos) were observed in Robinson Barracks (northeast of Building 146), at Kelley Barracks (contractors’ area north of DPW Yard), Patch Barracks (near Bldg. 2339), and Panzer Kaserne (east of Building 2952). These facilities are managed by contractors.

- Road salt application occurs throughout USAG Stuttgart during the winter season on road surfaces, parking lots, and walkways. Although this application is not industrial in nature, it has a measurable impact on the storm water quality. The salt will be potentially discharged with the storm water into open water bodies and the environment via the outfalls such as the new Stuttgart Elementary and High Schools and the Panzer Hotel (both are located on Panzer Kaserne). In accordance with agreements with the local environmental authority, road salt application is tracked and stormwater outflows are monitored at the Stuttgart School and Panzer Hotel outfalls. Chemical analyses continue to show that ion concentrations and electric conductivity readings appear to be elevated in the discharged storm waters during the winter season when compared to non-winter periods. Application of salt represents an alteration of the physical and chemical conditions of the storm water.

This is a violation of applicable storm water discharge regulations and the storm water discharge permits; only unaltered rain water can be discharged into open water bodies and the environment. Elevated electrical conductivities and ion concentrations may pose a threat to the flora and fauna of the affected creeks, ponds, and the environment. According to the regulations, split and/or sand should be used as an alternative for deicing purposes.

This topic is not considered individually for the installations rather in Section 4 because salt application for deicing purposes is conducted throughout the USAG by the responsible contractor.

- Although routine maintenance and inspections of OWS are performed as required, several separators require major repairs and lack functionality.

- Some gullies, storm water inlets, linear storm water drainage inlets, etc. are not well maintained and are filled with soil, sediments, leaves, and dirt – particularly in areas with land disturbing activities / construction. BMPs which would prevent such issues were not observed during the site walks. Regular inspections and cleaning is required to maintain the functionality of the drainage system.

- Fertilization is conducted frequently at the Kornwestheim Golf Course. Granular fertilizer is stored and mixed in a locked shed at the Building Complex 979 and spread out at the golf greens (this observation dates to the 2015 up-date). Application of fertilizer should be minimized to protect storm water.

3.2 STORM WATER DRAINAGE SUMMARY

In addition to identifying industrial activities throughout the USAG Stuttgart, it is important to locate these activities in relation to any areas where storm drainage may flow off-post rather than to the sanitary sewer during heavy rain. The relative locations of the potential sources and drainage will assist in selecting BMPs that are appropriate to the surrounding environment.

For purposes of this plan, drainage areas and associated outfalls regarding flow that may not drain to the sanitary sewer system were identified for each industrial area. These drainage areas and outfalls were developed using available mapping of the Garrison, including the existing storm sewer systems and topographic contours. All industrial activities are located within these defined

USAG Stuttgart Storm Water Pollution Prevention Plan 3-7 drainage areas. The combined storm and sanitary sewer systems, overland flow paths, drainage areas, outfalls, and receiving stream(s) are noted on the USAG Stuttgart maps included in Appendix 1.

Most of the storm water from Patch Barracks and Robinson Barracks flows to the respective local wastewater treatment plants; most of the storm water flow from SAAF is directed to subsurface drainage beds or to the receiving “Katzenbach” Creek. Storm water at Panzer Kaserne is discharged either to open water bodies or to the local wastewater plant. At Kelley Barracks, storm water is predominantly discharged to the receiving “Koersch” and “Weidach” Creeks. Specific outfall information for flow that may not drain to the sanitary sewer is provided in Appendix 2, including the assigned outfall number, associated industrial activities, building and structure numbers, and the receiving stream.

Changes to the stormwater and sewer infrastructure since the previous (2017) SWPPP were identified from interviews with DPW personnel in the Environmental Division, Operations and Maintenance (O&M) Division, and Utilities Branch, review of provided maps and plans, and interviews and observations during site visits. These changes to the stormwater infrastructure and relevant industrial activities at USAG Stuttgart since the previous SWPPP Update include the following:

• Sewer lines at Kelley Barracks along Maple Street, Spruce Street, and Building 3310 were replaced. According to DPW O&M points of contact (POC), this project upgraded and restored functionality of existing infrastructure. This existing infrastructure repair has minimal impact to stormwater pollution prevention.

• Building 2926 on Panzer Kaserne, the former FMWR Auto Skills Center, was demolished.

This project displaced several industrial activities associated with vehicle maintenance and took one wash rack and OWS out of service.

• A new OWS was installed in 2022 on Panzer Kaserne near Building 2958. It was not yet on the 6-month maintenance item list at the time of the O&M interviews and should be added.

• The discharge permit for the Panzer Hotel rain retention basin is under review. The terms of the permit will need to be incorporated into future plans once responsibilities have been clarified, specifically regarding the base maintenance contract (BMC) tasks.

• OWS #7737-5 is no longer on the BMC routine inspection list and is presumed no longer in place. The associated rain retention basin remains.

• OWS #7725-1 at the Holding Yard with Wash Rack at Building 2928 is inactive. The General Inspection was not performed in 2022 and it scheduled for permanent shut down.

• OWS #7725-2 was removed. It has been removed from the list in this plan.

• OWS #7725-4 at the Hard Stand at Building 2966 was repaired and functionality was restored in 2018/2019.

• Substantial defects were identified for OWS #7725-6 during the April 2022 inspection and immediate decommission is required. The OWS was previously identified as abandoned but remains connected to an in-use industrial area.

• OWS #7725-11 inside Building 2968 was associated with bilge water treatment but was shut down and removed 5 Feb 2020.

• OWS #7725-12, which is connected to the FMWR Vehicle Maintenance bays at Building 2930 was added to the plan.

USAG Stuttgart Storm Water Pollution Prevention Plan 3-8

• OWS #7727-3 at the Power Plant #2 at Bldg. 2316 is inactive as it is damaged beyond repair and programmed for replacement.

• (Underway) Sewer lines are being upgraded at Patch Barracks. According to DPW O&M Division POCs, this project repairs and restores functionality to existing infrastructure with minimal impact to storm water. At the time of writing, sediment control measures are recommended to reduce particulate pollution from the construction activities.

• (Underway) Power Plant 2 (Bldg. 2316) at Patch Barracks is undergoing a significant upgrade. This project replaces generators and addresses deficiencies associated with the facility. Upon completion the associated BMPs for power production and bulk fuel storage should be re-assessed.

• (Underway) The Child Care Center is under renovation. This facility update is not significant to the SWPPP after completion. At the time of writing, sediment control measures are recommended to reduce particulate pollution from the construction activities.

• (Planned) Construction of new commissary at Panzer Kaserne. BMPs associated with this project are expected to impact future SWPPPs but the project remains in planning at the time of writing.

The storm drainage systems of each installation are discussed below.

3.2.1 Kelley Barracks

Storm water is predominantly drained by a separate storm sewer system. A storm water drainage divide splits the Barracks in two, with the northwest corner draining through the North Storm Water Retention and Sedimentation Basin and the remainder of the Barracks draining to the South Storm Water Retention Basin (see Appendix 1 - Figure A-1.1). The two (2) storm water retention basins serve as outflow control devices. Storm water from the Access Control Point (ACP)(opened in January 2017) is collected in an underground cistern, and reportedly is pumped (outflow controlled) to the discharge line from the South Storm Water Retention Basin to the Koersch Creek (see Appendix 1 - Figure A-1.1).

Outflow from the northern portion of the installation enters the Weidach Creek and eventually the Koersch Creek. The majority of the storm water in the north is collected and discharged to the North Storm Water Retention and Sedimentation Basin. This facility itself acts as an oil-water-separator and as an outflow control device. The basin connects to the Weidach Creek via outfall No. 001A and an underground drainage pipe, which predominantly runs outside of the installation boundary. The northern Spruce Street discharges directly to an open ditch via Outfall No. 001B (see Appendix 1 - Figure A-1.1). This open ditch connects to the drainage pipe of Outfall No. 001A off-post (see Outfall No. 001C on Appendix 1 - Figure A-1.1).

Outflow from the southern portion of the base eventually enters the Koersch Creek via the South Storm Water Retention Basin and Outfall No. 002 (Appendix 1 - Figure A-1.1). An OWS is not associated with Outfall No. 002 of the South Storm Water Retention Basin to the Koersch Creek and the ACP cistern. The drainage to the Koersch Creek consists partly of an underground pipe but is also in parts an open ditch.

Although the drainage lines to the Weidach (northern part) and the Koersch (southern part) are running predominantly outside of the site, surveillance, maintenance, and repairs are the responsibility of the USAG Stuttgart. The garrison initiated a major renovation and restoration program for the sewer / storm water systems at Kelley Barracks in 2017 to restore drainage lines to the Koersch and Weidach Creeks and replace and/or restore storm water lines.

USAG Stuttgart Storm Water Pollution Prevention Plan 3-9

There are two active OWS integrated into the storm drainage system at strategic locations across the Barracks.

• OWS #7737-2 is associated with the Wash Rack north of Building 3390 and discharges to the municipal sewer system and ultimately to the wastewater treatment plant Moehringen (Outfall No. 003 on Figure A-1.1). The OWS #7737-2 was replaced during the 2016 sewer project at Kelley Barracks but has outstanding deficiencies identified during the 2022 General Inspection.

• OWS #7737-6 is associated with the AAFES / DLA Gas Station (Building 3324).

3.2.2 Panzer Kaserne

Storm water is either drained by a combined sanitary and storm sewer collection system at Panzer Kaserne, infiltrated to the ground (e.g., Panzer Exchange), or discharged to open water bodies (Panzer Hotel and new Stuttgart Elementary and High Schools). All storm water associated with industrial activity areas flows to the Wastewater Retention Basin located to the west and outside the fenceline of the horseshoe-shaped Kaserne (see Appendix 1 - Figures A-2.1 or A-2.2).

Combined sanitary and storm water from the northern part of the Panzer Kaserne discharges via Outfall No. 001 into the Wastewater Retention Basin (Appendix 1 - Figure A-2.1). Combined sanitary and storm water from the southern part of the Panzer Kaserne discharges via Outfall No. 002 into the same Wastewater Retention Basin (Appendix 1 - Figure A-2.2). The Wastewater Retention Basin discharges to the local wastewater treatment plant Böblingen.

Storm water from the roof of the Panzer Exchange (Bldg. 2903) is discharged to a rainwater retention and infiltration basin north of the building; during major rain events, the storm water is also discharged to the combined sewer system via an overflow (Appendix 1 - Figure A-2.1).

Drains located at the western (Outfalls No. 003, 004, and 005) and eastern (Outfalls No. 006 and

007) end of the road that borders the southern edge of the Kaserne drain directly to a drainage ditch just outside the Kaserne’s southern fence line (Appendix 1 - Figure A-2.2).

Storm water from the driveway, parking lot, walkways, and roof of the new Stuttgart Elementary and High Schools (Bldgs. 3080 and 3081) drain through an underground storm water storage basin or a fire water / rain water reservoir and via Outfalls No. 008A and 008B (emergency overflow) directly to the protected, open ditch “Waldklinge” just outside of the Kaserne’s southern fence line and on the Böblingen Local Training Area (LTA) (Appendix 1 – Figure A-2.3). Down-gradient, there are several protected ponds and biotopes that receive the storm water from the schools.

Storm water collected from the roof, walkways, driveway, and the parking lot of the Panzer Hotel (Bldg. 2905) is collected and discharged via a storm overflow shaft, a successive pre-treatment shaft with constant water table into an open rainwater retention basin located to the south of the hotel complex (Appendix 1 – Figure A-2.1). Rain water infiltrates into the soil and is drained through three underground drainage pipes into a collection shaft at the eastern end of the basin.

The storm water discharges via outfall No. 009 to the open ditch “Wolfsburger Hau” outside of the installation (Appendix 1 – Figure A-2.1) and eventually discharges into the down-gradient Ganssee Lake.

Panzer Kaserne is elevated in respect to the land immediately surrounding it. There may be some minor off-post storm water flow from areas close to the installation boundary and other areas during very heavy rains.

The following six (6) active OWSs are integrated into the combined sewer system at strategic locations throughout the Panzer Kaserne:

USAG Stuttgart Storm Water Pollution Prevention Plan 3-10

• #7725-3 at the Wash Rack at Building 2935B;

• #7725-4 at the Hard Stand at Building 2966; deficiencies were repaired and functionality was restored in 2018/2019.

• #7725-7 at the DLA / 405th AFSB Gas Station (Building 2953);

• #7725-10 at the Wash Pad at Building 2969; and

• #7725-12 for the Vehicle Maintenance bays at Building 2930.

• New OWS for the Vehicle storage and maintenance area at Building 2958

The OWS #7725-1 at the Holding Yard with Wash Rack at Building 2928 is inactive. The General Inspection was not performed in 2022 and it is scheduled for permanent shut down.

OWS #7725-6 at the south side of Building 2935; is inactive due to serious deficiencies identified in the 2022 DIN 1999 inspection. Decommissioning was recommended in the inspection report.

OWS #7725-11 inside Building 2968 was associated with bilge water treatment but was shut down and removed 5 Feb 2020.

3.2.3 Patch Barracks

Storm water is drained by a combined sanitary and storm sewer collection system at Patch Barracks. Drainage from the majority of the Barracks (including all areas associated with industrial activities) flows to the northeast (Outfall No. 001 on Appendix 1 - Figure A-3). Drainage from Kurmäker Straße, east of the eastern side of Kefurt Loop, and along “Katzenbach Straße” from the Main Gate south drains to the southeast (Outfall No. 002 on Appendix 1 - Figure A-3). Almost all storm water from Patch Barracks flows to the main wastewater treatment plant at Stuttgart- Muehlhausen (Outfalls No. 001 and 002 on Appendix 1 – Figure A-3).

There may be some minor off-post storm water flow from areas close to the installation boundary and other areas during very heavy rains, e.g., at the western or northeastern site boundary where an open drainage system exists. Outfalls No. 003 and 004 (Appendix 1 – Figure A-3) at the northern boundary drain directly into the “Katzenbach” Creek. Storm water from the open material storage area which is located near Bldgs. 2338 and 2366 is drained via Outfall No. 003. The area of the Patch Theater and the Non-commissioned Officer (NCO) Club discharges via Outfall No.

004. However, these facilities and the surrounding area are not considered to be industrial in nature. The western portion of Patch Barracks falls within Water Protection Zone IIIB as designated by the City of Stuttgart…