USCG_YARD_SWPPP_April2024_20SW.pdf
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About this file
This document is a Stormwater Pollution Prevention Plan (SWPPP) for the U.S. Coast Guard Yard in Baltimore, Maryland, covering industrial stormwater management for a 24.83-acre ship repair facility. The SWPPP details the facility's stormwater management strategies, including multiple best management practices (BMPs) installed during the Shiplift Expansion project, such as a diversion structure (DV-1), a Jellyfish filter (BMP-1), underground storage basins (BMP-2A and BMP-2B), and a cartridge filter system (BMP-3). The facility has a 20-digit permit number (20SW3060) and discharges to Curtis Creek, with specific focus on managing potential pollutants from ship repair activities including hydroblasting, paint removal, and equipment maintenance. The SWPPP includes provisions for monitoring, inspecting, and maintaining stormwater control measures, with particular attention to managing potential contaminants like petroleum products, paint chips, metals, and chemical additives.
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Text version
July 2015
STORM WATER POLLUTION PREVENTION PLAN
AND
RESTORATION PLAN
UNITED STATES COAST GUARD YARD
BALTIMORE, MARYLAND
COAST GUARD CONTRACT NUMBER HSCG50-14-D-PSL005
TASK ORDER NUMBER HSCG83-15-J-NES001
April 2024
Stormwater Pollution Prevention Plan (SWPPP)
U.S. Coast Guard YARD April 2024
MDE Industrial SWPPP Template, February 7, 2023 i
Industrial SWPPP Template
Introduction
To help you develop a Stormwater Pollution Prevention Plan (SWPPP) that is consistent with industrial stormwater permits, MDE recommends using this template, which a modified version of the one that the U.S Environmental Protection Agency (EPA) has created. Use of the Template will help ensure that your SWPPP addresses necessary elements required in industrial stormwater permits.
Before completing the Template, make sure you read and understand the requirements in the General Permit (20SW, 15MM, 16MA, etc). A copy of all the General Permits are available on our website, as is a guide for creating a SWPPP. You may also call us at 410-537-3323, if you have questions about this process.
Using the Industrial SWPPP Template
Tips for completing the Template:
• This Template is designed for use by all facilities eligible for coverage. The Template is NOT tailored to your individual industrial sector. Depending on which industrial sector you fall under (see Appendix A of the General Permit 20-SW, 15-MM, 16-MA, etc) and on where your facility is located, you will need to address additional SWPPP requirements outlined in the permit SWPPP requirements in the permit or Appendix D and/or Chesapeake Bay Restoration Requirements of the permit.
• Complete a SWPPP before submitting your Notice of Intent (NOI) for permit coverage.
• Each section includes “instructions” and space for your facility’s specific information.
You should read the instructions for each section before you complete that section.
• The Template was developed in Microsoft Word so that you can easily add tables and additional text. Some sections may require only a brief description while others may require several pages of explanation.
• To make it easier to complete, the Template generally uses blue text where the operator is expected to enter information.
MDE recognizes that while every effort has been made to ensure the accuracy of all instructions and guidance contained in the Template, the actual obligations of regulated industrial facilities are determined by the relevant provisions of the permit, not by the Template. In the event of a conflict between the Template and any corresponding provision of the General Permit, the permit controls. MDE welcomes comments on the Template at any time and will consider those comments in any future revision of this document.
MDE Industrial SWPPP Template, February 7, 2023 i
Stormwater Pollution Prevention Plan for:
U.S. Coast Guard YARD
2401 Hawkins Point Road
Baltimore, MD, 21226-1797
410-636-7026
SWPPP Contact(s):
Brandace Timbers
United States Coast Guard
Coast Guard YARD
2401 Hawkins Point Road
Baltimore, MD, 21226
410-636-3775 brandace.t.timbers@uscg.mil
Justin Locus
United States Coast Guard
Coast Guard Yard
2401 Hawkins Point Road
Baltimore, MD, 21226
410-636-7070 justin.w.locus@uscg.mil
SWPPP Preparation Date:
_April 2024_
MDE Industrial SWPPP Template, February 7, 2023 ii
Contents
1. FACILITY DESCRIPTION AND CONTACT INFORMATION
1.1. Facility Information
1.2. Contact Information/Responsible Parties
1.3. Stormwater Pollution Prevention Team
1.4. Activities at the Facility
1.5. General Location Map
1.6. Site Map
2. POTENTIAL POLLUTANT SOURCES
2.1. Industrial Activity and Associated Pollutants
2.2. Spills and Leaks
2.3. Non-Stormwater Discharges Documentation
2.4. Salt Storage
2.5. Visual Monitoring Summary
2.6. PFAS and PCB Source Identification
3. STORMWATER Control Measures
3.1. Minimize Exposure
3.2. Good Housekeeping
3.3. Maintenance
3.4. Spill Prevention and Response
3.5. Erosion and Sediment Controls
3.6. Management of Runoff
3.7. Salt Storage Piles or Piles Containing Salt
3.8. Sector-Specific Non-Numeric Effluent Limits
3.9. Employee Training
3.10. Non-Stormwater Discharges
3.11. Waste, Garbage and Floatable Debris
3.12. Dust Generation and Vehicle Tracking of Industrial Materials
4. Schedules and Procedures FOR MONITORING
5. Inspections
6. SWPPP CERTIFICATION
7. SWPPP MODIFICATIONS
SWPPP ATTACHMENTS
Attachment A – General Location Map Attachment B – Site Maps Attachment C – Past Spill Log Attachment D – Non-Stormwater Evaluation Attachment E – Discharge Permit 20-SW Attachment F – Quarterly Visual Monitoring Attachment H – Shiplift Expansion Stormwater Management System Description Attachment I – Notice of Intent
MDE Industrial SWPPP Template, February 7, 2023 1
1. FACILITY DESCRIPTION AND CONTACT INFORMATION
1.1. Facility Information
Facility Information
Name of Facility: U.S. Coast Guard Yard
Street: 2401 Hawkins Point Road
City: Baltimore State: MD ZIP Code: 21226-1797
County: United States of America
Permit Registration Number: 20SR3060 (if covered under a previous permit)
Latitude/Longitude (Use decimal format)
Latitude: Longitude:
1. 39.1997 º N (decimal) 1. 76.5672 º W (decimal)
Estimated area of industrial activity at site exposed to stormwater: 24.83 (acres)
Primary SIC Code or 2-letter Activity Code: 3731, 3732, 9711
(refer to Appendix A of the General Permit)
Identify your applicable sector and subsector: Sector R (Ship and Boat Building Repair Yards)
Name and 8 digit identifier of the receiving water body: Curtis Creek and Arundel Cove (Baltimore Harbor basin number 02130903)
Are any of your discharges directly into any segment of an “impaired” water? ☒ Yes ☐ No
Instructions:
― You will need the information from this section to complete your NOI.
― For further instruction, refer to the General Permit NOI form and instructions.
― Detailed information on determining your site’s latitude and longitude can be found at http://www.wikihow.com/Find-the-GPS-Coordinates-of-an-Address-Using-Google-Maps, or by using a search engine on your web browser and searching for “determining latitude and longitude of location”.
― You must include a copy of the Permit, or a reference or link to where a copy can be found, in Attachment C of your SWPPP.
about:blank
MDE Industrial SWPPP Template, February 7, 2023 2
If Yes, identify name of the impaired water (and segment, if applicable): Curtis Creek
Identify the pollutant(s) causing the impairment: PCBs, Copper, and Zinc
For pollutants identified, which do you have reason to believe will be present in your discharge? Copper and Zinc
For pollutants identified, which have a completed TMDL? PCBs
Do you discharge into a high quality receiving water designated as a Tier 2 water? ☐ Yes ☒ No
Do you discharge into a high quality receiving water designated as Use III or Use IV? ☐ Yes ☒ No
1.2. Contact Information/Responsible Parties
Facility Operator (s):
Name: U.S. Coast Guard YARD
Address: 2401 Hawkins Point Road
City, State, Zip Code: Baltimore, MD, 21226
Telephone Number: 410-636-4098
Email address: holly.m.moore@uscg.mil
Fax number: 410-636-3775
Facility Owner (s):
Name: U.S. Coast Guard YARD
Address: 2401 Hawkins Point Road
City, State, Zip Code: Baltimore, MD, 21226
Telephone Number: 410-636-4098
Email address: holly.m.moore@uscg.mil
Fax number: 410-636-3775
SWPPP Contact(s):
Name: Brandace Timbers
Telephone number: 410-636-3775
Email address: brandace.t.timbers@uscg.mil
Instructions:
― List the facility operator(s), facility owner, and 24 hour emergency contact. Indicate respective responsibilities, where appropriate.
― You will need the information from this section of the SWPPP Template for your NOI.
― Refer to the NOI instructions.
MDE Industrial SWPPP Template, February 7, 2023 3
Name: Justin Locus
Telephone number: 410-636-7070
Email address: justin.w.locus@uscg.mil
1.3. Stormwater Pollution Prevention Team
Staff Names Individual Responsibilities
Commanding Officer (CO) • Repsonsible for the implementation of the SWPPP
• Ensure resources are available should any noncompliance or violations arise.
Facility Engineer (FE) • Repsonsible for ensuring timely payment of permit fees, permit renewal, submitting required reports, required monitoring, maintaining required records and documentation, water quality equipment maintenance repairs and upgrades, and correspondence with local officials
• Notify the Commanding Officer (CO) immediately should any noncompliance or violations arise
• Responsible for the permitting, with regards to stormwater quality compliance, of facility construction or other activity not named in this SWPPP
• Ensure salt storage pile(s) are covered
• Ensure Yard roadways are swept prior to snow event if snow is to be deposited into surface waters
Industrial Manager (IM) • Ensure that stormwater, wastewater and hydroblasting environmental requirements are included in planning, scheduling, implementation, and completion of all industrial work including hydroblasting, de-painting, painting, dock-side repair availabilities, top-side maintenance, work hauled-out and placed in drydock/shiplift and shop work.
• Ensure that hydroblasting is performed in accordance with the USCG YARD Environmental Management System Manual (EMSM), Sections C8 and C9 – Hydroblasting and Pressure Washing and the USCG YARD Quality System Manual MOP- 088 – Drydock Industrial Waste Control
• Ensure that all industrial activities, including work performed by
Instructions (see General Permit Part III.C.1):
− Identify the staff members (by name or title) that comprise the facility’s stormwater pollution prevention team as well as their individual responsibilities.
− Your stormwater pollution prevention team is responsible for assisting the facility manager in developing and revising the facility’s SWPPP, implementing and maintaining control measures/BMPs, and taking corrective actions where required. Each member of the stormwater pollution prevention team must have ready access to either an electronic or paper copy of applicable portions of the General Permit and your SWPPP.
MDE Industrial SWPPP Template, February 7, 2023 4 outside contractors, are conducted in accordance with all relevant references.
• Ensure lead ballast management is conducted in accordance with this SWPPP.
Facilities Management Department, Environmental Branch (FMDEB)
• Provide annual training on stormwater pollution prevention for all YARD campus personnel and contractors performing outdoor work at the Yard.
• FMDEB shall also, at the IM’s request, review the language in any proposed solicitation to ensure compliance with this
SWPPP.
• Report spills and exceedances immediately to MDE and/or the National Response Center within the prescribed time limits
• Conduct stormwater facility inspections
• Conduct quarterly visual examinations of stormwater quality
• FMDEB shall be responsible for inspection of each permitted outfall and recording inspection information for each outfall detailed in the YARD’s NPDES Permit. Inspections must be entered into the field log book, signed and dated
• Prepare quarterly DMR's and submit to MDE prior to the 28th day of the month following the end of the quarterly reporting period. The reporting periods end in March, June, September, and December. If an outside contract Laboratory is used, maintain all original analytical results, Chain of Custody, name, and phone number of Laboratory and sample collector. Retain records indefinitely
• Coordinate housekeeping inspections with the environmental audits
USCG YARD Tennant Units and Contractors
• Ensure that stormwater wastewater and hydroblasting requirements are included in planning, scheduling, implementation and completion of their work
• Immediately notify Facilities Management upon identification of any event or arrangement that could result in the discharge of any solid or liquid material, other than stormwater, to surface water or in a location that could impact a catch basin or other stormwater collection device during a precipitation event
• Ensure all contractors/subcontractors receive Environmental Training prior to the start of any outdoor work at the Yard
MDE Industrial SWPPP Template, February 7, 2023 5
1.4. Activities at the Facility
The U.S. Coast Guard YARD repairs and renovates ships for the U.S. Coast Guard. It is the Cast Guard’s largest ship repair facility and part of the Coast Guard’s core industrial base and fleet support operations.
1.5. General Location Map
A general location map for this facility in Attachment A.
Instructions (see General Permit Part III.C.2):
− Provide a general description of the nature of the industrial activities at your facility.
Instructions (see General Permit Part III.C.2):
− Provide a general location map (e.g., U.S. Geological Survey (USGS) quadrangle map) with enough detail to identify the location of your facility and all receiving waters for your stormwater discharges (include as Attachment A of this SWPPP Template).
MDE Industrial SWPPP Template, February 7, 2023 6
1.6. Site Map
“SWPPP Facility Map” is included in Appendix B. This map has been prepared to identify the organization within the facility that is responsible for each area and the associated relevant stormwater fixtures and potential pollutant sources including:
• Outfall locations;
• Stormwater drainage areas;
• Structural stormwater quality measures; and,
• Areas of activities that could potentially impact stormwater quality.
MDE Industrial SWPPP Template, February 7, 2023 7
Instructions (see General Permit Part III.C.2):
− Include a map showing the following information. The site map should be included as Attachment B of this SWPPP Template.
▪ the size of the property in acres;
▪ the location and extent of significant structures and impervious surfaces;
▪ directions of stormwater flow (use arrows);
▪ locations of all existing structural control measures;
▪ locations of all receiving waters in the immediate vicinity of your facility, indicating if any of the waters are impaired and, if so, whether the waters have TMDLs established for them;
▪ locations of all stormwater conveyances including ditches, pipes, and swales;
▪ locations of potential pollutant sources identified under General Permit Part III.C.3.b;
▪ locations where significant spills or leaks identified under General Permit Part III.C.3.c have occurred;
▪ locations of all stormwater monitoring points;
▪ locations of stormwater inlets and outfalls, with a unique identification code for each outfall
(e.g., Outfall No. 1, No. 2, etc), indicating if you are treating one or more outfalls as “substantially identical”, and an approximate outline of the areas draining to each outfall;
▪ municipal separate storm sewer systems, where your stormwater discharges to them;
▪ locations and descriptions of all non-stormwater discharges identified under General Permit
Part III.C.3.d;
▪ locations of the following activities where such activities are exposed to precipitation:
o fueling stations;
o vehicle and equipment maintenance and/or cleaning areas;
o loading/unloading areas;
o locations used for the treatment, storage, or disposal of wastes;
o liquid storage tanks;
o processing and storage areas;
o immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-products used or created by the facility;
o transfer areas for substances in bulk;
o machinery; and
▪ locations and sources of run-on to your site from adjacent property that contains significant quantities of pollutants.
MDE Industrial SWPPP Template, February 7, 2023 8
2. POTENTIAL POLLUTANT SOURCES
2.1. Industrial Activity and Associated Pollutants
Industrial Activity Associated Pollutants
Fueling large vessels, boiler plant tanks, small watercraft and motor vehicles, defueling vessels, lubrication in machinery associated with shipbuilding and maintenance
Petroleum products (gasoline, diesel, various lubrication oils and hydraulic oils)
Facility/vessel maintenance, specialty coatings, primers and solvents
Various paints, acetone, methanol, methyl ethyl ketone, methyl isobutylene, mineral spirits, n-butyl alcohol, naphthalene, toluene, and xylene
Grit blasting (indoor and sometimes outdoor activity)
Granular metallurgical furnace slag ranging in size from 150 microns to 2000 microns
Hydroblasting – machine and hand-based Paint chips and associated residue (copper, zinc, and other metals)
Slurry blasting Grit material, paint chips and associated residue (copper, zinc, and other metals)
Ship repair and fabrication activities Waste and scrap metal
Welding and soldering, electrical insulation, pest control, cleaning and polishing
Hazardous materials/waste (paints and related products, preservative and sealing compounds, adhesives, solid fuels, petroleum based fuels, chemical based fuels, fuel oils, lubricating oils, waxes, oils and fats, wire and wire rope
Instructions (see General Permit Part III.C.3):
− In this section, you are required to describe areas at your facility where industrial materials or activities are exposed to stormwater or from which allowable non-stormwater discharges are released.
Instructions (see General Permit Parts III.C.3.a and III.C.3.b):
− Include a list of industrial activities exposed to stormwater (e.g., material storage; equipment/vehicle fueling, maintenance, and cleaning; cutting steel beams) and the pollutants or pollutant constituents (e.g., motor oil, fuel, battery acid, and cleaning solvents) associated with these activities.
− In your list of pollutants associated with your industrial activities, include all significant materials that have been handled, treated, stored, or disposed, and that have been exposed to stormwater in the 3 years prior to the date you prepare your SWPPP.
MDE Industrial SWPPP Template, February 7, 2023 9
2.2. Spills and Leaks
Areas of Site Where Potential Spills/Leaks Could Occur
Location Outfalls
Loading/unloading operations - The vehicle refueling areas adjacent to Building 20, Building 24, and Building 30; The fuel/oil delivery area located to the north of Building 91; The two 10,000 gallon used oil tanks at Building 62B; The bulk blast grit delivery area located adjacent to Building 34; All waterfront areas where vessels/equipment can be fueled/defueled
All areas
Outdoor storage areas throughout the facility All areas
Outdoor manufacturing and processing areas throughout the Facility
All areas
Boiler fuel tank storage in Building 7 Area E
Shiplift area Area C
Electrical oil filled equipment (outside transformers/switches) Emergency generators
All areas All areas
Description of Past Spills/Leaks See Appendix C for a description of significant spills and leaks in the past 3 years.
Instructions (See General Permit Part III.C.3.c):
− Include the following in this section:
o Potential spills and leaks: A description of where potential spills and leaks could occur at your site that could contribute pollutants to your stormwater discharge, and specify which outfall(s) are likely to be affected by such spills and leaks.
o Past spills and leaks: A description of significant spills and leaks in the past 3 years of oil or toxic or hazardous pollutants that actually occurred at exposed areas, or that drained to a stormwater conveyance.
− Note: Significant spills and leaks include, but are not limited to, releases of oil or hazardous substances in excess of quantities that are reportable under CWA Section 311 (see 40 CFR 110.6 and 40 CFR 117.21) or Section 102 of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42
USC §9602.
MDE Industrial SWPPP Template, February 7, 2023 10
2.3. Non-Stormwater Discharges Documentation
• Date of evaluation: April 12, 2024
• Description of the evaluation criteria used: A visual inspection was conducted on April 12, 2024 during dry weather. A summary of the evaluation is in Attachment D.
• List of the outfalls or onsite drainage points that were directly observed during the evaluation:
Visible outfalls in substantially identical effluent areas A-E.
• Different types of non-stormwater discharge(s) and source locations: No non-stormwater discharges were identified.
• Action(s) taken, such as a list of control measures used to eliminate unauthorized discharge(s), if any were identified. For example, a floor drain was sealed, a sink drain was re-routed to sanitary, or an NPDES permit application was submitted for an unauthorized cooling water discharge: No unauthorized discharges were identified. During June 2015 two floor drain were discovered, one in Building 40 and one in Building 58. Attempts to determine their discharge points by dying were unsuccessful. Following the dye tests both drains were sealed with hydraulic cement to render them unusable.
2.4. Salt Storage
Salt for deicing is stored in a covered enclosure at Building 53 to reduce the potential for stormwater contact. The salt storage area is maintained following loading and unloading activities by shoveling, sweeping or other form of dry clean up to minimize the potential for stormwater contact with spilled or displaced deicing salt.
Instructions (see General Permit Part III.C.3.d):
− The questions below require you to provide documentation of the following:
o Your evaluation for the presence of non-stormwater discharges at your site; and o Your elimination of any unauthorized non-stormwater discharges.
Instructions (see General Permit Part III.C.3.e):
− Document the location of any storage piles containing salt used for deicing or other commercial or industrial purposes.
− Note: You will be asked additional questions concerning salt storage in Section 3.7 of this SWPPP template, below.
2023 11
2.5. Visual Monitoring Summary
Grit/paint chips/dust accumulation observed throughout the industrial area where hydroblasting, grit, and slurry blasting occur appears to be the most consistent issue found during visual monitoring inspections.
2.6. PFAS and PCB Source Identification
Potential current PFAS sources at the Yard are AFFF concentrate. AFFF deluge system is located at Building 20 the Flammable Material Storage Buidling and 90-day hazardous waste accumulation area for the Yard. The system is used to control and extinguish Class B fire consisting of hydrocarbon fuels and flammable liquids. AFFF is stored in two 600-gallon vertical bladder tanks and filled with 413 gallons of 6 percent AFFF concentrate. Building 20 trench and floor drains are connected to a concrete vault designed to hold AFFF/water when the deluge system discharges. AFFF/water generated in the concrete vault is removed and disposed of in accordance with regulations.
Firehouse located at Building 79 handles fires related to ship repair, fuels in storage, and structural fires at the Yard. Since 2023 the Firehouse no longer uses or stores AFFF in fire trucks or at Building 79. The Yard temporarily stores vessels on the shiplift for maintenance and repairs that may contain AFFF/water in their fire suppression systems.
Historic sources of PCBs were transformer substations containing PCB dielectric fluids. The dielectric fluids were removed approximately 30 years ago from transformers and switched to alternatives (mineral oil). In 2004 and 2007 environmental investigations involved collecting soil and wipe samples at substations, manholes, and electric poles throughout the Yard for PCBs. A removal action was completed at substation 102 near Building 30 in 2008 which involved a 1-ft excavation of soil. Occasionally PCB industrial waste may come from ships docked at the Yard, this industrial waste is disposed of in accordance with regulations.
Instructions (See General Permit Part III.C.3):
− Summarize what you have observed as potential problems from stormwater during the previous permit term.
Instructions (See General Permit Parts III.C.3.ii, and III.C.3.iii):
− In Section 2.6 of this SWPPP template, you are asked to describe potential sources of per- and polyfluoroalkyl (PFAS) and Polychlorinated Biphenyls (PCBs). See the 20SW permit Part III.C.3.ii for a list of SIC codes that have a higher likelihood of containing PCBs. For please see Part III.C.3.iii for the chemicals we are looking for as well as the following link to the EPA’s PFAS website https://www.epa.gov/pfas/basic-information-pfas for more detailed information. Provide a narrative summary below any potential current or historic uses of PFAS or PCB’s below.
2023 12
3. STORMWATER Control Measures
3.1. Minimize Exposure
All containerized materials (fuels, paints, solvents, used oil, antifreeze, batteries, etc.) must be stored as to protect them from mixing with stormwater. Best management practices associated with these materials include the following:
• Containers must be clearly marked as to their contents. Wipe down the outside of 55 gallon drums;
• Containers must be kept in secure locations away from storm drains;
• Secondary containment measures for 55 gallon drums and tanks will be kept clean and free of debris;
• Accumulated precipitation within containment structures will be drained in accordance with the
USCG
EMSM, Section B6 – Spill Control and Countermeasure (SPCC) Plan;
• Lead-acid batteries must be stored in an area that is protected from stormwater and is capable of containing any fluid leaks as detailed in USCG EMSM, Section C12– Recycling Lead-Acid Batteries. Store in plastic box or on containment at Building 66 - Garage;
• Spent abrasive materials must be recovered and containerized for offsite disposal;
• Hazardous wastes and hazardous materials will be maintained as outlined in USCG EMSM, Section C2 – Hazardous Materials and Waste Transportation Within the YARD; and, Instructions (See General Permit Parts III.C.4, III.A and III.B.1.b):
− In Sections 3.1 - 3.12 of this SWPPP template, you are asked to describe the stormwater control measures that you have installed at your site to meet each of the permit’s “non-numeric effluent limits” in Part III.B of and in some cases “Chesapeake Bay Restoration Requirements” in Part III.A.
Instructions (see General Permit Part III.B.1.b.):
− Describe any structural controls or practices used to minimize the exposure of industrial activities to rain, snow, snowmelt, and runoff. Describe where the controls or practices are being implemented at your site.
2023 13
• Scrap metals shall be managed in accordance with USCG EMSM, Section C11 – Recycling Scrap Metal.
3.2. Good Housekeeping
Maintaining good general housekeeping practices at the YARD is essential to the prevention of contamination of stormwater. Procedures for managing materials used by the facility that could potentially impact stormwater quality are outlined in the USCG YARD Environmental Management System Manual and in this Plan. However, the management of other miscellaneous materials is necessary to maintain the cleanliness of the general YARD areas. Housekeeping tasks include:
General Maintenance o Perform a general site cleanup to remove miscellaneous trash as needed. Outdoor areas shall be kept free of spills, rusty metal, paint chips, grit, bagged or loose chemicals, oily equipment, oily drums and all potential water pollutants.
o Remove debris for disposal or recycling at regular intervals to prevent overfill of receptacles o Provide trash receptacles at areas throughout the facility, including each pier and on board each vessel being repaired.
o Keep flammable liquids lockers orderly and clean.
o Dispose of hazardous materials properly.
o Wipe up leaks and spills.
• Spent solvent management. Used paint thinner must be added to Paint Slop drums. Do not put used solvent into a used oil container.
• Vessel wastewaters. Sewage connections must be connected to Hotel sewage connections.
Overboard cooling water discharges must have hoses on them to direct the water to a drain (Shiplift Work Area). Used oil and water must be collected in a used oil tank or drum.
Only ballast water that does not have any oil (or any other pollutants) in it can be discharged to the creek (Environmental Branch must be notified prior to discharge. Clean accessible areas of the drydock prior to flooding and final cleanup following removal of the vessel and raising the drydock.
Include procedures for cleaning up oil, grease, or fuel spills occurring on the drydock.
• Spent abrasives management. Blast grit, soft blast, glass beads, walnut shells cannot be left outside. If spent abrasives do escape a booth/machine, they must be swept up prior to the end of the workday. Place spent abrasives in drums or a collection point inside of the building.
Instructions (see General Permit Parts III.C.5. and III.B.1.b.):
Describe any practices you are implementing to keep exposed areas of your site clean. Describe where each practice is being implemented at your site. Include here your schedule for: (1) regular pickup and disposal of waste materials, and (2) routine inspections for leaks and of the condition of drums, tanks, and containers.
MDE Industrial SWPPP Template, February 7, 2023 14
• Painting and Blasting. Keep paint and blast media out of the water. Do not spray paint on windy days (See EMSM Section C5). Use knockdown curtains to contain paint chips from any painting or blasting operations. The containment and treatment of runoff from hydroblasting activities is covered under NPDES Permit MD0067300. When blasting, no visible emissions are allowed.
When necessary, regularly clean stormwater conveyances of deposits of abrasive blasting debris and paint chips.
• Bulk liquid transfers. Stage the drums onboard the vessel on containment decks. Block the scuppers near the drums, so the vessel’s deck will act as a secondary containment if needed.
Absorbent pads, rags, buckets and appropriate PPE must be present before transfer operations begin.
• Fueling vessels. A spill kit must be at the location of transfer. Drip pans or buckets must be placed under connections and tank vents or vessels. All hoses must be continuous with fittings used to connect hoses. The hose and fittings must be visually inspected before each use to ensure good condition. During the transfer, one person must be next to the tank/drum to ensure that the tank is not overfilling.
• Fueling vehicles. No smoking during fueling. If filling a container, place container on the ground. If a fire starts, do not remove the nozzle, back away immediately. Report all spills promptly.
• Vehicle/boat washing. CG owned vehicles can be washed at Bldg 66’s wash area. GSA vehicles can be washed at a commercial car wash. Boats out of water can be washed with detergents at Bldg 66 or Bldg 30. Fresh water wash downs of boats (in water) are allowed using a garden hose or bucket only. The discharge water must be free of contaminates (paint chips and detergents).
Pressure washing is not permitted.
• Material Storage Areas. Store and plainly label all containerized materials (e.g., fuels, paints, solvents, waste oil, antifreeze, batteries) in a protected, secure location away from drains. Minimize the contamination of precipitation or surface runoff from the storage areas.
3.3. Maintenance
Preventive maintenance is conducted to ensure proper operation of all engineered stormwater treatment devices. Oil/water separators and sediment collection units are inspected on a monthly basis as part of the documented visual facility inspection. Conditions identified that could result in equipment failure are documented and repaired within 30 days of the inspection.
Instructions (see General Permit Parts III.C.5 and III.B.1.b.):
− Describe procedures (1) to maintain industrial equipment so that spills/leaks are avoided, and (2) to maintain any of your site’s control measures in effective operating condition. Include the schedule you will follow for such maintenance activities. Describe where each applicable procedure is being implemented at the site.
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Temporary sediment collection systems designed to capture debris resulting from blasting and paintingactivities are subjected to daily undocumented visual inspections and quarterly documented inspections to ensure the systems are adequate to serve the intended purpose.
The YARD is investing the use of cartridge filters in storm drains several locations on the shiplift platform.
Depending on the effectiveness of these filters, their use may be expanded to additional areas on the
YARD.
Industrial Equipment Maintenance: monthly SPCC tank inspections and Yellow Gear Maintenance
3.4. Spill Prevention and Response
The YARD has prepared a Spill Prevention, Control and Countermeasure (SPCC) plan and Facility Response Plan (FRP) in accordance with 40 CFR 112. The SPCC plan outlines measures for the containment and mitigation of a potential discharge of petroleum/oils that could adversely impact the environment. The SPCC Plan is incorporated into this SWPPP by USCG EMSM, Section B6– Spill Control and Countermeasure (SPCC) Plan.
Specific BMPs to prevent spills and stormwater contamination include:
• Keep all oils on secondary containment
• Maintain and operate equipment properly
• Identify potential spill areas and drainage routes
Instructions (see General Permit Parts III.C.5. and III.B.1.b.):
− Describe any structural controls or procedures used to minimize the potential for leaks, spills, and other releases. You must implement the following at a minimum:
▪ Procedures for plainly labeling containers (e.g., “Used Oil,” “Spent Solvents,” “Fertilizers and Pesticides,” etc.) that could be susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills or leaks occur;
▪ Preventative measures such as barriers between material storage and traffic areas, secondary containment provisions, and procedures for material storage and handling;
▪ Procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases; and
▪ Procedures for notification of appropriate facility personnel, emergency response agencies, and regulatory agencies.
Describe where each control is to be located or where applicable procedures will be implemented.
− Note: Some facilities may be required to develop a Spill Prevention Control and Countermeasure (SPCC) plan under a separate regulatory program (40 CFR 112). If you are required to develop an SPCC plan, or you already have one, you should include references to the relevant requirements from your plan.
MDE Industrial SWPPP Template, February 7, 2023 16
• Implement spill response procedures. When using stay-dry to absorb a spill, the stay-dry must be swept up. Do not leave the stay-dry on the ground as it will wash into the storm drain.
• Report all spills to x3000 or 410-636-3993
3.5. Erosion and Sediment Controls
The general topography of the facility is relatively flat with a gentle slope towards Curtis Creek or Arundel Cove in most locations. A portion of the facility surface is paved, with unpaved areas being covered by gravel or grass and other vegetation. All disturbed soils or soil stockpiles resulting from earthmoving activities at the facility will be stabilized with vegetation or an impermeable cover (i.e. plastic) in accordance with the State of Maryland sediment and erosion control procedures.
All construction activities that take place at the YARD must be conducted in accordance with the measures outlined for the permitting and control of erosion and sediment established in COMAR 26.17.01 which requires approval of a Sediment and Erosion Control Plan by the Maryland Department of the Environment for all land clearing, grading or other earth disturbance that involves:
1. Greater than 100 cubic yards of grading; or
2. Greater than 5,000 square feet of grading.
Instructions (see General Permit Part III.B.1.b.):
Describe structural or non-structural controls used at your site to stabilize exposed areas and contain runoff to minimize onsite erosion and potential offsite discharges of sediment. Note: You must at a minimum implement flow velocity dissipation devices at outfalls and discharge channels. Describe the location at your site where each control will be implemented.
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3.6. Management of Runoff
Restoration Plan. See attachment G for a copy of the restoration plan and restoration activity schedule from 2017 to 2024.
Oil/Water Separators. The facility maintains engineered stormwater treatment devices to address the potential for fugitive oils or sediment resulting from surface preparation activities. Oil/water separators are installed in three areas at the facility as a means of removing oil that may result from maintenance or cleaning activities. The oil/water separators located adjacent to Building 5 (Outfall 24 and 25) and Building 30 (Outfall1) are subsurface units that are installed to collect drainage from areas where small marine vessel washing and maintenance activities are performed. Additionally, an oil/water separator is installed adjacent to Building 66 (Outfall 16 and 18) to collect rinse water from the equipment/machine maintenance activities performed in this area.
Sediment traps for blast grit. Two sediment trapping devices are maintained in the western portion of the facility to prevent the migration of fugitive blast grit to a stormwater outfall. These units are located across the paved surface of Ridgley Street (Outfall 2) and Gunther Way (Outfall 3) near the intersections with Adams Street in the vicinity of Building 35. Additionally, mobile tankers are utilized for the storage of hydroblast water and residue that is captured during surface preparation activities prior to painting.
Instructions (See General Permit Part III.B.1.b. and III.A.2):
Describe controls used at your site to divert, infiltrate, reuse, contain, or otherwise reduce stormwater runoff.
Describe the location at your site where each control will be implemented.
For facilities required to meet Chesapeake Bay Restoration Requirements, develop a plan by completing all the steps in Part III.A.2 of the permit and document in this section of the SWPPP the results of each step.
a.
These steps will include the following:
Provide the total impervious surface area for your facility (in square feet).
Provide the the untreated impervious surface area (in square feet).
Provide the impervious surface area subject to the 20% control measure requirement (in acres).
Provide the selected practices from the options that you will implement to comply with the control measure requirement of this permit.
If after evaluating your potential options for nutrient reductions, you determine it is infeasible to meet the nutrient reduction requirements at your facility, provide your rationale and describe your alternate plan and schedule consistent with Part III.A.1.d for coordinating with the local jurisdiction to implement equivalent off-site projects.
Document your selection of BMPs and equivalent measures, including calculations that show your approach will achieve the nutrient reduction requirement.
Provide a schedule and basis for all options you selected that cannot be implemented within 30 days of registration under this permit.
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3.7. Salt Storage Piles or Piles Containing Salt
Salt for deicing is stored in a covered enclosure at Building 53 to reduce the potential for stormwater contact. The salt storage area is maintained following loading and unloading activities by shoveling, sweeping or other form of dry clean up to minimize the potential for stormwater contact with spilled or displaced deicing salt.
3.8. Sector-Specific Non-Numeric Effluent Limits
The good housekeeping measures described in Appendix D of the 20-SW are included in Section 3.2 (Good Housekeeping) of this SWPPP.
3.9. Employee Training
The Facility Engineer is the facility designee and is responsible for stormwater discharge prevention, control and response preparedness activities at the facility. Employee training is conducted at the facility in order to teach personnel at all levels of responsibility the components and goals of the Stormwater Pollution Prevention Plan. Topics covered in the training program will be focused on the implementation of the Best Management Practices established for storage, use and disposal of potential pollutants and include the following topics:
• Spill Prevention and Response Procedures;
Instructions (see General Permit Part III.B.1.b.):
If applicable, describe structures at your site that either cover or enclose salt storage piles or piles containing salt, or that prevent the discharge of stormwater from such piles. Also, describe any controls or procedures used to minimize exposure resulting from adding to or removing materials from the pile. Describe the location at your site where each control and/or procedure will be implemented.
Instructions (see General Permit Part III.B.1.b. and Appendix D):
− Describe any controls or procedures that will be used at your site to comply with any sector-specific requirements that apply to you in Appendix D of the General Permit. Describe the location at your site where each control and/or procedure will be implemented.
− Note: Sector-specific effluent limits apply to Sectors A, D, E, F, G, H, I, J, L, M, N, O, P, Q, R, S, T, U, V, X, Y, Z, and AA, AD.
Instructions (see General Permit Parts III.C.5 and III.B.1.b):
Describe your plan for training the employees who work in areas where industrial materials or activities are exposed to stormwater, or who are responsible for implementing activities necessary to meet the conditions of the General Permit, including all members of your Pollution Prevention Team. Included in your description must be the frequency of training (note: recommended at least one time per year), and the schedule you will follow.
2023 19 o Identifying potential spill areas and drainage routes;
o Implementing spill response procedures;
o Spill reporting procedures;
• Good Housekeeping Practices;
• Materials Management Practices;
o Used oil management;
o Spent solvent management;
o Proper disposal of spent abrasives;
o Proper disposal of vessel wastewaters;
o Fueling procedures;
o Bulk liquid transfers;
o Proper painting and blasting procedures; and, o Used battery management.
Employee training for personnel at all levels of responsibility shall be conducted at least once per calendar year. Records of training dates and attendance will be kept by the Environmental Office and/or the YARD Quality Office Training Coordinator for YARD personnel for a minimum of three years. Tenant unit personnel will be responsible for the retention of training records for three years. YARD Tennant Commands and Contractors and customers must be made aware of Best Management Practices for the prevention of stormwater pollution prior to the initiation of work at the facility.
3.10. Non-Stormwater Discharges
• During routine ISO 14001 Audits Environmental Branch personnel investigated the drainage path of floor drains in all of the buildings of the facility to verify no connection to the stormwater drainage system. All floor drain inspections that resulted in a pathway to a stormwater system were sealed to prevent their use.
Instructions (see General Permit Part III.B.1.b.):
Describe how you eliminated any unauthorized non-stormwater discharges at your site. The unauthorized non-stormwater discharges include any non-stormwater discharges that are not specifically identified in Part 1.1.3 of the General Permit. Note: If this section is already addressed by your documentation for Section 2.3 of the SWPPP template, you can simply include a cross-reference to that section of your SWPPP.
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• Investigated the drainage path of outdoor stormwater conveyance system to verify the outfall of each of the stormwater catch basins, a stormwater system drawing exists.
• In 2008, the YARD sealed floor drains in Building 15 that drained to Arundel Cove.
• In 2009, the YARD eliminated the infiltration of contaminated groundwater to the stormwater system in the area of Building 30. In 2012, the YARD sealed a floor drain in the Battery Storage Room in Building 30 that was believed to drain to Curtis Creek.
• Eliminate or make provisions to include in the NPDES permit the discharge of all boiler system, air compressor and air conditioner condensate to stormwater drains as identified.
During June 2015 two floor drains were discovered, one in Building 40 and one in Building 58. Attempts to determine their discharge points by dying were unsuccessful. Following the dye tests both drains were sealed with hydraulic cement to render them unusable.
3.11. Waste, Garbage and Floatable Debris
Maintaining good general housekeeping practices at the YARD is essential to the prevention of contamination of stormwater. Procedures for managing materials used by the facility that could potentially impact stormwater quality are outlined in the USCG YARD Environmental Management System Manual and in this Plan. However, the management of other miscellaneous materials is necessary to maintain the cleanliness of the general YARD areas. Housekeeping tasks include:
• Perform a general site cleanup to remove miscellaneous trash as needed;
• Remove debris for disposal or recycling at regular intervals to prevent overfill of receptacles; and,
• Provide trash receptacles at areas throughout the facility, including each pier and on board each vessel being repaired.
3.12. Dust Generation and Vehicle Tracking of Industrial Materials
Instructions (see General Permit Part III.B.1.b):
Describe controls and procedures that will be used at your site to minimize discharges of waste, garbage, and floatable debris. Describe the location at your site where each control and/or procedure will be implemented.
Instructions (see General Permit Part III.B.1.b.):
Describe controls and procedures you will use at your site to minimize the generation of dust and off-site tracking of raw, final, or waste materials. Describe the location at your site where each control and/or procedures will be implemented.
MDE Industrial SWPPP Template, February 7, 2023 21
Most of the industrial area is paved or covered with gravel to minimize the creation of dust. Any construction project would have appropriate control measures (truck wash down, etc.) as part of that project and would be done as close to the source as possible. Hand sweeping/vacuuming is performed near the shiplift platform and other areas where dust/debris have accumulated from blasting activity.
Surfaced Areas Sweeping: All roadways and other paved areas, excluding areas designated for vehicle parking, are swept monthly. This includes sweeping of all paved YARD Industrial areas, including the waterfront and all piers. Parking areas are swept quarterly.
Off-site shipment of Industrial Materials are transported in either covered roll-offs or vacuum boxes.
Documentation of shipments is retained by the Environmental Branch.
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4. Schedules and Procedures FOR MONITORING
The YARD is not required to conduct benchmark sampling under the MDE Industrial stormwater general permit because sector R, Ship and Boat Building and Repair Yards, which the YARD falls under, does not have separate benchmark monitoring requirements. However, the YARD is still required to conduct quarterly visual monitoring and will use the substantially identical outfalls identified in Attachment B for this.
Instructions (see General Permit Part III.C.5):
− Describe your procedures for conducting the five types of analytical monitoring specified by the General Permit, where applicable to your facility, including:
▪ Benchmark monitoring (General Permit Part V.B and relevant requirements in Appendix D); and
▪ Impaired waters monitoring as required by MDE (General Permit Part III.B.2);
− Depending on the type of facility you operate, and the monitoring requirements to which you are subject, you must collect and analyze stormwater samples and document monitoring activities consistent with the procedures described in General Permit Part V.B and relevant requirements in Appendix D. Refer to
General Permit Part V.E for reporting and recordkeeping requirements. Note: All monitoring must be conducted in accordance with the relevant sampling and analysis requirements at 40 CFR Part 136. Include in your description procedures for ensuring compliance with these requirements.
− If you are invoking the exception for inactive and unstaffed sites for benchmark monitoring, you must include in your SWPPP the information to support this claim as required by General Permit Part V.B.5.
− If you plan to use the substantially identical outfall exception for your benchmark monitoring requirements in
General Permit Part V.B.6 and/or your quarterly visual assessment requirements in General Permit Part V.A.3.d, you must include the following documentation:
▪ Location of each of the substantially identical outfalls;
▪ Description of the general industrial activities conducted in the drainage area of each outfall;
▪ Description of the control measures implemented in the drainage area of each outfall;
▪ Description of the exposed materials located in the drainage area of each outfall that are likely to be significant contributors of pollutants to stormwater discharges;
▪ An estimate of the runoff coefficient of the drainage areas (low = under 40%; medium = 40 to 65%; high
= above 65%); and
▪ Why the outfalls are expected to discharge substantially identical effluents.
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5. Inspections
For the routine facility inspections and the comprehensive site inspections to be performed at your site, include a description of the following:
▪ The names of the person(s), or the positions of the person(s), responsible for inspection: A member of the Environmental Branch
▪ The schedules to be used for conducting inspections: Quarterly at a minimum and
▪ Specific areas of the facility to be inspected, including schedules for specific outfalls: Areas where the following activities are performed:
▪ Pressure washing;
▪ Hydroblasting;
▪ Sanding and painting;
▪ Material storage areas (fuels, lubricants, solvents, paints, metals, blast grit, etc.);
▪ Engine maintenance and repair;
▪ Material handling (fueling, material transfers, etc.);
▪ Drydock activities; and,
▪ General Facility maintenance.
For the quarterly visual assessments to be performed at your site, include a description of the following:
▪ The names of the person(s), or the positions of the person(s), responsible for…
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