Tech_Exhibit_0506_Stormwater_Management_Plan.pdf

FORT HAMILTON MILITARY COMMUNITY

MUNICIPAL SEPARATE STORM SEWER SYSTEM

STORMWATER MANAGEMENT PROGRAM

PREPARED BY

DIRECTORATE OF PUBLIC WORKS

FORT HAMILTON, NEW YORK

FEBRUARY 2003

FORT HAMILTON MILITARY COMMUNITY

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)

MS4 STORMWATER MANAGEMENT PROGRAM

PROTOCOL

Stormwater Management Plan

Fort Hamilton Military Community

Brooklyn, New York

TABLE OF CONTENTS

Section____________________________________________________________________Page

1 INTRODUCTION…………………………………………………………………….…1

1.1 FORT HAMILTON GENERAL INFORMATION…………………………….1

1.2 APPLICABILITY TO FORT HAMILTON MILITARY COMMUNITY……..1

1.3 PHASE-IN SCHEDULE………………………………………………………..2

1.4 FORT HAMILTON MS4 PROTOCOLS……………………………………….2

1.5 LEGISLATIVE HISTORY ………………..……………………………………3

2 PUBLIC EDUCATION AND OUTREACH ON STORMWATER IMPACTS..……….4

2.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL

MEASURE………………………………………………………………………4

2.2 PUBLIC EDUCATION PLAN………………………………………………….5

2.3 EDUCATION PROGRAM IMPLEMENTATION……………………………..5

3 PUBLIC INVOLVEMENT AND PARTICIPATION………………………………… ..8

3.1 SUMMARY OF COMPOPNENTS OF THIS MINIMUM CONTROL

MEASURE………………………………………………………………………8

3.2 PUBLIC INVOLVEMENT AND PARTICIPATION…………………………..8

4 ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDD&E)………………10

4.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL

MEASURE………………………………………………………………...……10

4.2 STORM SEWER SYSTEM MAPPING………………………………………..10

4.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION…………………11

4.4 ILLICIT DISCHARGE DETECTION AND ELIMINATION

PUBLIC EDUCATION OUTREACH………………………………………….13

5 CONSTRUCTION STORMWATER RUNOFF MANAGEMENT…………………….14

5.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL

MEASURE……………………………………………………………………...14

5.2 CONSTRUCTION SITE STORMWATER PROGRAM………………………15

5.3 DEVELOPER/CONTRACTOR EDUCATION………………………………..16

6 POST-CONSTRUCTION STORMWATER RUNOFF MANAGEMENT……………..17

6.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL

MEASURE……...………………………………………………………………17

6.2 POST-CONSTRUCTION STORMWATER RUNOFF MANAGEMENT…….18

6.3 OPERATION AND MAINTENANCE OF POST-CONSTRUCTION BMPs…18

Stormwater Management Plan

Fort Hamiliton Military Community

Brooklyn, New York

TABLE OF CONTENTS (CONTINUED)

7 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR

OPERATION AND MAINTENANCE………………………………………………….19

7.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL

MEASURE…..………………………………………………………………….19

7.2 POLLUTION PREVENTION PROGRAM FOR MUNICIPAL TYPE

OPERATIONS………………………………………………………………….20

7.3 POLLUTION PREVENTION & GOOD HOUSEKEEPING TRAINING...…..21

7.4 OTHER GOOD HOUSEKEEPING BMPs……………………………………..21

8 MONITORING, RECORDKEEPING, REPORTING AND

CERTIFICATION REQUIREMENTS………………………………………………….24

8.1 MONITORING………………………………………………………………….24

8.2 RECORDKEEPING…………………………………………………………….24

8.3 REPORTING……………………………………………………………………24

8.4 CERTIFICATION………………………………………………………………25

9 COST ESTIMATE ………………………………………………………………………26

9.1 COST ESTIMATE………………………………………………………….…..26

10 REFERENCES……………………………………………………………………….….27

APPENDICES

APPENDIX A: SPDES GENERAL PERMIT

APPENDIX B: SPDES GENERAL PERMIT FOR CONSTRUCTION ACTIVITY

APPENDIX C: NOTICE OF INTENT FOR COVERAGE

APPENDIX D: STORMWATER SYSTEM MAP

SECTION 1

INTRODUCTION

1.1 FORT HAMILTON GENERAL INFORMATION

Fort Hamilton Military Community occupies approximately 169 acres with 67 government owned buildings. Approximately 50 of the 169 acres are outgranted to NYC for use by

Triborough Bridge and Tunnel Authority (TBTA). Fort Hamilton is located in the Borough of

Brooklyn, Kings County, City of New York. The installation is bounded by the Verrazano

Narrows Bridge approach to the west, the belt Parkway to the south, Dyker Beach Park to the east, and Poly Place and Polytechnic Preparatory School to the north. Geographically, it is at the western end of Long Island and is situated on the northern shore of Gravesend Bay, approximately 6.5 miles south of the Battery, the southerly tip of Manhattan, New York.

Fort Hamilton provides administrative, intelligence, operational, financial, managerial, legal, security, and logistical support for all assigned and attached army units. The installation also provides administrative, logistical, and medical support to retirees and their dependents; reserve centers and National Guard units; and active duty personnel (including tenant and satellite units) in New York City and surrounding counties. The installation provides housing for military and key and essential civilian personnel working on-post and in the New York City Metropolitan area. The surrounding neighborhood consists primarily of residential use and parks, with a blend of commercial activity. There is no industrial activity on Fort Hamilton. The population on Fort

Hamilton totals approximately 3,500 military and civilian personnel.

The Fort Hamilton storm sewer system predominately discharges to the New York City combined storm/sanitary sewer system. A small section at the southern end of Fort Hamilton, designated a

MS4 for this Program, discharges to the Gravesend Bay. This MS4 section includes approximately forty (40) stormwater catch basins and two outfalls to the Gravesend Bay, a 36-inch and a 15-inch outfall. The remaining sewer sytem, which discharges into the New York City combined-sewer system, is operated and maintained the same as the MS4 designated section.

1.2 APPLICABILITY TO FORT HAMILTON MILITARY COMMUNITY

Under the federal Phase II stormwater program, Fort Hamilton Military Community, which is located within an “Urbanized Area” as defined by the U.S. Census and operates a Municipal Type

Separate Storm Sewer System (MS4) is required to obtain a SPDES permit coverage for stormwater discharges under its’ jurisdiction and control (per 40CFR Part 122 & 122.26.32) as a regulated MS4. The Phase II NPDES stormwater regulations also require regulated MS4s to address stormwater runoff from construction activities by obtaining a SPDES permit when applicable.

MS4s covered under Phase II are not required to show numerical results to substantiate that they are improving their water quality as planned. Instead they are allowed to rely on the so-called narrative standard. An MS4 can set measurable goals for the completion of actions and programs it believes will improve water quality, rather than setting measurable goals for numeric improvements in water quality.

The NYSDEC has two general permits, one for MS4s in urbanized areas: SPDES “General

Permit for Stormwater Discharges from Municipal Separate Stormwater Sewer Systems (MS4s)”

Permit Number GP-02-02” (Appendix A) and one for construction activities SPDES “General

Permit for Stormwater Discharges from Construction Activity Permit Number GP-02-01”

(Appendix B). These permits are part of the State Pollutant Discharge Elimination System

(SPDES).

Fort Hamilton Military Community, a regulated MS4, must apply for permit coverage by March

10, 2003. Operators of construction activities that exist on or after March 10, 2003 and that involve one acre or more of land disturbance must obtain SPDES permit coverage through either an Individual Permit or the General Construction Permit.

The NYSDEC Phase II program for MS4s is designed to accommodate a general permit approach using a Notice of Intent (NOI) as the permit application (Appendix C). The operator of a regulated small MS4 must include in its permit application, or NOI, its chosen BMPs and measurable goals for each minimum control measure.

1.3 PHASE-IN SCHEDULE

The Fort Hamilton Military Community is located in the New York State Department of

Environmental Conservation (NYSDEC) designated “urbanized area” of Kings County and automatically must file a NYSDEC State Pollution Discharge Elimination System (SPDES)

General Permit for Stromwater Discharges from Municipal Separate Stormwater Sewer Systems

(MS4s) with NYSDEC by March 10, 2003. The full MS4 program must be phased in and totally implemented by March 2008. The permit term will be for five years, followed by subsequent permits for similar timeframes. The MS4 permittee must, within the permit term, implement and enforce a stormwater management program in conformance with the General Permit and approved by NYSDEC. The stormwater management program must be designed to reduce the discharge of pollutants from its MS4 to the maximum extent practicable, with the goal of protecting water quality and satisfying the appropriate water quality requirements of the federal

Clean Water Act and applicable New York State Environmental Conservation Law. The program must contain a schedule, best management practices (BMPs) and measurable goals for the six

Minimum Control Measures detailed below, and must be approved by NYSDEC.

1.4 FORT HAMILTON MS4 PROTOCOLS

The Fort Hamilton Stormwater Management Program Protocol ("Protocol") meets the six

Minimum Control Measures required of municipal permittees under the Phase II NPDES

Stormwater Regulations (found at 40 CFR §§ 122.26 123.35). The implementation of this

Protocol by Fort Hamilton will satisfy the federal NPDES permit requirements for municipal separate storm sewer systems ("MS4s") in those regulations, described in detail at 40 CFR

§122.34. Portions of the federal regulations, which are incorporated into New York State regulations by reference in “SPDES General Permit for Stormwater Discharges from Municipal

Separate Stormwater Sewer Systems (MS4s)” Permit Number GP-02-02, establish six categories of Best Management Practices ("BMPs") that must be met by permittees. These are "narrative" permit effluent limitations. Those BMPs must be designed to reduce the discharge of pollutants from MS4s to the maximum extent practicable, to protect water quality and to satisfy the appropriate requirements of the federal Clean Water Act.

The six BMP categories, also called "minimum control measures" in the federal regulations, are:

1. Public Education and Outreach on Stormwater Impacts,

2. Public Participation and Involvement,

3. Illicit Discharge Detection and Elimination,

4. Construction Site Runoff Control,

5. Post-Construction Stormwater Management in New Development and Redevelopment, and

6. Pollution Prevention and Good Housekeeping for Municipal Operations and Maintenance

1.5 LEGISLATIVE HISTORY

Clean Water Act (CWA) - The 1987 CWA Amendments (40 CFR Parts 122, 123 & 124) launched a national effort to regulate the discharge of pollutants into waterways during runoff events. The CWA identifies specific activities that need authorization under Section 402 of the

CWA (the NPDES program) before discharging stormwater runoff to a “Water of the United

States.” New York State (NYS) is a National Pollution Discharge Elimination System (NPDES)-approved state, having its State Pollution Discharge Elimination System (SPDES) program first approved by the EPA in 1975 and is thus charged with administering this program in the state.

Phase I - EPA published stormwater regulations on November 16, 1990. These Phase I regulations focused on large and medium municipalities and stormwater runoff from certain specified types of activities and required that they obtain NPDES authorization (coverage under a permit issued pursuant to the NPDES program) by October 1, 1994. As the NPDES permitting authority, the NYS Department of Environmental Conservation (DEC) issued two general permits in 1993, one dealing with industrial site runoff and another addressing stormwater runoff from construction projects involving a disturbance of five (5) or more acres.

Phase II - EPA’s Phase II stormwater regulations were promulgated on December 8, 1999. They significantly expanded the scope of activities that are subject to NPDES permitting and set March 10, 2003 as the date by which new and ongoing Phase II construction activities would need to obtain a permit. The Phase II regulations reduced the threshold for construction activities from five (5) to one (1) or more acres of disturbance. These construction activities are regulated by the NYSDEC SPDES General Permit for Stormwater Discharges from Construction

Activity Permit Number GP-02-01. The Phase II regulations also identified publicly owned and/or operated municipal separate storm sewer systems (MS4s) which lie within areas designated as urbanized (as defined by the United States 2000 Census) as automatically needing a permit under the NPDES program. These “regulated MS4s” are regulated by the NYSDEC

SPDES General Permit for Stormwater Discharges from Municipal Separate Stormwater Sewer

Systems (MS4s)” Permit Number GP-02-02. These regulated MS4s must submit a Notice of

Intent (NOI) by March 10, 2003. The NOI outlines how these regulated MS4s will adopt appropriate measures to address stormwater.

SECTION 2

PUBLIC EDUCATION AND OUTREACH

ON STORMWATER IMPACTS

MINIMUM CONTROL MEASURE

Distributing educational materials and performing outreach to inform citizens about the impacts polluted stormwater discharges can have on water quality.

2.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL MEASURE

Develop a Public Education Plan

Implement the Plan, including dissemination of educational materials (including those provided by NYSDEC) to appropriate target audiences

PERMIT

YEAR

SUMMARY OF MINIMUM CONTROL MEASURE

PERMIT REQUIREMENTS

Education Plan Education Program

Year 1

Determine Target Audience

Develop Public Education Plan

Disseminate materials to all target audiences using appropriate distribution channels –

Brochures, Posters and Fact Sheets

Biannual Newspaper advertisement

Other components of Plan - Weblinks.

Year 2

Implement the plan

Revise Plan as needed using appropriate distribution channels -

Brochures, Posters and Fact Sheets

Annual Newspaper advertisement

Other components of Plan - Weblinks

Year 3 using appropriate distribution channels -

Brochures, Posters and Fact Sheets

Year 4 using appropriate distribution channels -

Brochures, Posters and Fact Sheets

Year 5 using appropriate distribution channels -

Brochures, Posters and Fact Sheets

Develop a Public Education and Outreach Plan effective in implementing a public education program. The public education plan will reach the following key audiences of:

2.2 PUBLIC EDUCATION PLAN

1) Installation residents;

2) Installation personnel;

3) Installation Base Operations Contractor;

4) Businesses; and

5) Developers/Contractors.

The people that comprise each of these groups have the potential to impact the quality of stormwater in the community. The Plan will effectively educate them on the connection between their actions, stormwater runoff, and water quality. They will most likely have a positive impact on the stormwater management efforts. The target audiences are also stakeholders since they have the ability to impede or assist in implementing the stormwater management program. The program will use several methods to get educational materials to the target audiences.

The plan at minimum shall describe:

1. The impacts of stormwater discharges on waterbodies.

2. The pollutants of concern and their sources.

3. The steps contributors of these pollutants can take to reduce pollutants in stormwater runoff.

4. The steps contributors of non-stormwater discharges can take to reduce pollutants

(example: use commercial car wash instead of residential car washing).

Year 1: Develop a Public Education Plan

Collect information on the target audience categories. Become familiar with the communication channels most used by each target audience. Through this activity, create a comprehensive inventory of the newsletters, newspapers, websites, meetings, magazines, organizations, associations, etc. used by the target audiences.

Years 2, 3, 4 and 5: Update Target Audience Information

During the remaining years of the permit, ensure that information in the plan is accurate and current. The target audiences may expand (or condense) in size during the course of a permit year. Ways of communicating may also change from year to year. As we learn of new communication channels (e.g., newsletters, websites, meetings, etc.), this information will be entered into the plan and strategies will be modified for distributing educational materials. The new information may help leverage resources for distributing educational materials.

2.3 EDUCATIONAL PROGRAM IMPLEMENTATION

The program focuses on distributing the educational materials that contain messages related to the stormwater management program. Implementing the educational program will also help meet permit requirements for other Minimum Control Measures that have public education components. These minimum measures include Illicit Discharge Detection and Elimination;

Construction Stormwater Runoff Management; and Pollution Prevention and Good Housekeeping for Municipal Type Operations and Maintenance. Educational material will be obtained from federal, state and commercial sources.

There will be two stages of educational outreach:

1) Raising the awareness of the target audiences

2) Educate the target audiences about the problems and potential solutions

These two stages of educational outreach will drive the schedule for the educational program, along with the assumption that most people do not know 1) what stormwater is and 2) how stormwater affects water quality. The public education plan will be used to determine the most effective means of getting educational materials into the hands of target audiences.

To fulfill the permit requirements associated with this component of the Public Education and

Outreach Minimum Control Measure, the following task will be completed during each year of the permit as shown:

Year 1: Raise Target Audiences’ Awareness of Your Stormwater Management Program

Distribute a Stormwater Information pamphlet to all target audiences.

Review available federal, state and commercial pamphlets and select an appropriate pamphlet for distribution to target audiences. The pamphlet will address the issue of pollution related to stormwater runoff and activities that everyone can use to improve stormwater quality. It may also provide an overview of a typical stormwater management program. Using the information on distribution channels in the Public Education Plan, these pamphlets will be disseminated to all target audiences categories in the community. Distribution methods will be selected that have confidence that the target audience will notice and use the information.

Run an annual Stormwater Informative advertisement in the New York Harbor Watch local newspaper.

Year 2: Continue to Raise Awareness and Begin to Educate all Target Audiences

Distribute Fact Sheets to developers/contractors.

Distribute Fact Sheets and/or Brochures prepared by EPA or NYSDEC to developers/contractors who propose or are contracted to perform construction activities on Fort Hamilton.

Developers/contractors in general operate under the oversight of the Directorate of Public Works

(DPW). Awareness activities for developers/contractors will be coordinated through the DPW

Division with oversight responsibility for the particular project/work. The Public Education Plan will have identified distribution opportunities related to developers/contractors.

Run a annual Stormwater Informative advertisement from the series in the New York Harbor

Watch local newspaper.

Most people get their information from local newspapers. This is an effective way to reach target audiences. Sample advertisements provided by Federal and State governments that focus on the issue of stormwater, and practices to reduce the impacts to water quality from stormwater runoff will be used. The ad will be repeated in the local newspaper so that members of the target audiences have repeated exposure to it.

Distribute posters to locations with public audiences on Fort Hamilton.

Distribute posters to general public locations with a high pedestrian foot-traffic flow, such as a shopping area. Topics such as vehicle maintenance and household hazardous waste disposal are important to stormwater management. The Federal and State governments have developed a series of posters that convey messages about these and other topics. Applicable posters can be distributed to public locations on Fort Hamilton.

Storm Drain Stenciling.

Any storm drain stenciling, if performed, will contribute to meeting permit requirements for

Minimum Control Measures. The Federal and State governments have information available for stenciling.

Provide a link to EPA’s or NYSDECs’ stormwater website. The internet is a popular way to distribute information that can be used a part of the stormwater educational program.

Years 3-5: Continue Outreach

Continue to distribute Fact Sheets to Developers/Contractors and assess effectiveness.

Continue to distribute Fact Sheets through the DPW Division with oversight responsibility for the particular project/work.

Run another stormwater ad from the series in the local newspaper.

Continue ad campaign by selecting and running another stormwater ad in the local newspaper at least once a year, so that the target audiences have repeated exposure to it, each year.

Distribute another poster from the series to locations with public audiences on Fort Hamilton.

Select another poster containing a stormwater management message from a series and distribute it to locations with public audiences on Fort Hamilton.

Ensure links to EPA and NYSDEC stormwater websites are maintained.

The links to websites may change from permit year to permit year. Links to stormwater websites will be checked and updated as necessary.

SECTION 3

PUBLIC INVOLVEMENT AND PARTICIPATION

Providing opportunities for installation residents/personnel to participate in program development and implementation including effectively publicizing public hearings and/or encourage installation representatives on a stormwater management panel.

3.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL MEASURE

Develop a Public Involvement/participation plan

Implement the Plan

Permit Year Public Involvement and Participation Program

Year 1 Develop public involvement/participation program

Year 2 Notify and solicit public input/involvement on Stormwater Management

Plan development and implementation

Year 3 Notify public as needed

Year 4 Notify public as needed

Year 5 Notify public as needed

3.2 PUBLIC INVOLVEMENT AND PARTICIPATION PLAN

Steps will be taken to involve the public with issues related to actions to address stormwater impacts on water quality including planning initiatives, plans and procedures, and impacting new regulations. Installation residents/personnel, watershed organizations and businesses will be involve as much as practicable, to obtain broad support for the stormwater plan. Public

Participation is closely linked to the Public Education and Outreach. Success in educating the community will have an effect on the community’s willingness to participate in stormwater related activities.

Develop A Public Involvement and Participation Plan

Develop a mailing list.

Using information in the plan, produce strategies for recruiting participation from the six categories of stakeholders: installation residents, installation personnel, installation base operations contractor, businesses, watershed associations and other volunteer groups and developers. Develop a mailing list of stakeholders generated from the Public Education and

Outreach Program. The mailing list will include mailing address, phone number, fax number, and email address.

Public review and comment.

Provide copies of the Stormwater Management Program to interested stakeholders for review and comment. A copy will be placed in the Fort Hamilton Library for public review. This will educate stakeholders about the Stormwater Management Program and solicit feedback on how the program will work in the community. The goal is to raise awareness about stormwater issues, determine what your community will do to better manage stormwater, and develop opportunities for them to participate. If sufficient interest is generated, a public meeting could be scheduled.

Conduct public meetings and solicit stakeholder input.

Public meetings will be scheduled only if sufficient public interest is generated by the Public

Education and Outreach Minimum Control Measure. Sufficient public interest is not anticipated due to the small size of Fort Hamilton’s MS4. Preparation activities would include setting a day and time for the meeting, selecting a meeting site, developing the agenda, creating and distributing the meeting announcement, and generating meeting materials. The agenda will include the overview presentation on the stormwater program. The agenda will allot enough time for people to ask questions and provide feedback. Public comments and the responses they receive will be recorded. A public comment form will be available for each participant. A meeting summary of questions and answers discussed or received on comment forms at the meeting will be prepared. The contact list will be updated. This meeting summary will be made available to the public upon requested.

Volunteer Program

By providing stakeholders with an opportunity to get involved in the stormwater management efforts, we may obtain the support needed to successfully implement many aspects of the

Stormwater Management Program.

The type of volunteer program that may best suit Fort Hamilton is a volunteer storm drain stenciling program. If volunteer support can be generated, information on developing and implementing a storm drain stenciling program will be obtained from Federal and State governments sources.

SECTION 4

ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDD&E)

Developing and implementing a plan to detect and eliminate illicit discharges to the storm water system (includes developing a system map and informing the community about hazards associated with illegal discharges and improper disposal of waste).

4.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL MEASURE

Develop map of municipal separate storm sewer system outfalls and receiving surface waterbodies

Prohibit illicit discharges

Implement a IDD&E Program that includes 1) field screening program and procedures and 2) elimination of illicit discharges (none currently known of)

Conduct public awareness and reporting program (see also the Public Education and

Outreach portion of this Program)

Permit

Year

PERMIT REQUIREMENTS AND MEASURABLE GOALS

Mapping Ordinance Program Education

Complete map of all outfalls

Adopt and enact

Update Storm Sewer

System Maps to reflect current conditions.

Distribute educational material

(see Public Education and

Outreach Minimum Measure)

Establish priority areas for

25% of system

Implement

And enforce

Screen Priority Areas

Take corrective actions to remove illicit discharges

(as needed)

Distribute educational material priority areas for

25% of system

Implement

And enforce

Screen Priority Areas

Take corrective actions to remove illicit discharges

(as needed)

Distribute educational material priority areas for

25% of system

Implement

And enforce

Screen Priority Areas

Take corrective actions to remove illicit discharges

(as needed)

Distribute educational material priority areas for

25% of system

Implement

And enforce

Screen Priority Areas

Take corrective actions to remove illicit discharges

(as needed)

Distribute educational material

4.2 STORM SEWER SYSTEM MAPPING

A mapping component is required for the Illicit Discharge Detection and Elimination (IDD&E)

Minimum Control Measure. The federal regulations define an outfall as “a point source” (as defined by 40 CFR 122.2) at the point where a municipal separate storm sewer discharges to the waters of the United States. A “point source” is defined as “any discernable, confined and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, vessel, or other floating craft from which pollutants are or may be discharged.

Storm Sewer System Map (Appendix D)

Map Scale

The map is a 1” = 100’ scale that shows street-level detail and extends beyond the service boundaries of the Fort Hamilton storm sewer system. This map scale best depicts specific location information for each outfall, as technicians in the field may need street-level detail in order to effectively locate and monitor outfalls.

System features

System mapping identifies all stormwater catch basins, manholes and outfalls and the name/location of the receiving water bodies, to support an effort to detect and eliminate illicit discharges. This activity will be accomplished by reviewing records, drainage maps and existing storm drain maps.

Map format

A geographic information system (GIS) may be used to electronically generate the system map.

Priority Areas

Portions of the system will be selected by the 1) likelihood of problems (none known) and 2) the significance of the problems (no known). The highest priorities are the areas within the community that are at risk for dumping to storm sewer system inlets and illegal connections to the system, such as sections of the system with older sanitary sewer lines or industrial activity. In addition, conduct visual outfall screening during dry weather. If dry weather flows are observed, field test of selected pollutants will be performed to establish priority areas. Beginning in Year 2, each year identify the highest priority areas for 25% of the system until the entire system is prioritized by the end of the permit term.

4.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION

This section establishes procedures for identifying and eliminating prohibited discharges of non-stormwater to the storm sewer system. The program consists of the following three elements:

Conduct Field Screening

Identify Source of Illicit Discharges

Strategy to Remove or Correct Illicit Discharges

4.3.1 Conduct Field Screening:

Field screening is necessary to identify source(s) of actual illicit discharges and must be started in

Year 2 of the permit. Every outfall in the Priority Areas will be screened once a year. The staff designated to conduct field screening will go out into the Priority Areas and collect visual data.

The screening will be conducted at least 72 hours since the last precipitation event, and at least 48 hours should pass between the first screening at a particular outfall and the second screening at that outfall. If someone conducting the field screening discovers a dry-weather flow, a sample of that flow will be collected for analysis. Such a discovery triggers the requirements under the other two program elements of:

Identify Source of Illicit Discharges

Strategy to Remove or Correct Illicit Discharges

4.3.2 Identify Source of the Illicit Discharge:

The following IDD&E Program elements only apply if a dry-weather flow is identified during field screening activities in Years 2, 3, 4 and/or 5.

Collect and analyze samples of the dry-weather flow.

If dry-weather flow is identified at an outflow during field screening, take two grab samples of the flow. Analyze the samples for the characteristics and pollutants listed in the Table below.

Dry-Weather Flow Sampling Analysis Requirements

Characteristic/Pollutant Method

Color Visual observation

Odor Visual observation

Turbidity Visual observation

Sheen/scum Visual observation

PH In-field analysis

Total chlorine In-field analysis

Total copper In-field analysis

Total phenol In-field analysis

Detergents/surfactants In-field analysis

Flow In-field analysis

Bacteria Laboratory analysis

As shown in the Table, some parameters only require visual observations while others require more analytical testing. Inexpensive colorimetric field test kits can be used to analyze grab samples for total chlorine, total copper, total phenol, and detergents. This information will be used to effectively determine the type of pollutants and pinpoint the source of the discharge.

Identify the source of the discharge.

The data obtained from visual, in-field, and laboratory analysis will provide the information necessary to determine the source of the dry-weather flow or floatables. Based on the pollutants contained in the grab sample, we should have an idea if the source is from illegal dumping in a storm drain, a cross-connection, or a leak in a pipe. Using this information, we will be able to narrow down the potential sources of the dry-weather flow and begin storm drain investigations by tracing the flow upstream using storm drain maps and by inspecting upgradient manholes and storm drains. If needed, more focused testing can be used to pinpoint the source.

4.3.3 Remove or Correct the Illicit Discharge:

Determine if the flow is from illegal dumping or an improper connection.

Once the source is identified, determine if it is a case of improper dumping or an improper physical connection to the storm sewer system. If it is a case of improper dumping, the only recourse may be to conduct intensified education of installation residents/personnel living and traveling through that area.

Take the appropriate action to correct the discharge.

If a violation is found, notify the Directorate of Public Works of the violation. Develop a timeframe for removal of the source. After the violation has been corrected, screen the outfall again at which the dry-weather discharge was identified.

Document all steps taken.

The results of all discussions, inspections, tests, and screenings, will be documented for follow-up purposes. Progress evaluation of the IDD&E program depends on the ability to tabulate the number of illicit connections corrected and the status of those in the process of being corrected.

4.4 ILLICIT DISCHARGE DETECTION AND ELIMINATION

PUBLIC EDUCATION AND OUTREACH

Conduct more public education and outreach activities when trying to correct an illicit discharge.

Distribute educational materials on the impacts of illicit discharges through the storm sewer system to water quality during Years 1 through 5.

SECTION 5

CONSTRUCTION STORMWATER RUNOFF MANAGEMENT

Developing, implementing, and enforcing an erosion and sediment control program for construction activities that disturb one or more acres of land (controls may include silt fences, temporary detention ponds, etc.).

5.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL MEASURE

Enact, implement and enforce a stormwater control program, The developer will be a contractor of the Government with oversight from DPW, Require review and approval of Erosion and Sediment Control Plans: (1) for any earth disturbance one acre or more causing runoff to the MS4 (or any earth disturbance five acres or more regardless of the planned runoff), and (2) as a prerequisite for the formal approval of land development and redevelopment plans or the issuance of building permits use DPW-Engineering, Plans, and Services to review E&S Plans, Regular inspections during construction, and

Distribute educational materials to land developers/contractor with the applications for building/digging permits and other land development/redevelopment permits or approvals.

Construction Site Stormwater Program Developer Education

Year 1 Enact a Stormwater Control Plan Requiring:

The review and approval of Erosion and

Sediment (“E&S”) Control Plans, For any earth disturbance one acre or more with runoff to the MS4, or five acres or more regardless of the planned runoff, and

As a prerequisite for the formal approval of land development plans or the issuance of building permits.

Process:

Use DPW-Engineering, Plans, and Services to review E&S Plans.

Standard:

Require that the Erosion and Sediment Control

Plans be developed in accordance with the requirements of the NYSDEC regulation and project specifications.

Meet permit requirement and measurable goals for

Year 1 under Public

Education and Outreach minimum control measure.

Construction Site Stormwater Program Developer Education

Year 2 Implement the Erosion and Sediment Control Program for review of Erosion and Sediment Control Plans

Meet permit requirement and measurable goals for

Year 2 under Public

Education and Outreach minimum control measure.

Year 3

Implement the Erosion and Sediment Control Program for review of Erosion and Sediment Control Plans

Meet permit requirement and measurable goals for

Year 3 under Public

Education and Outreach minimum control measure.

Year 4 Implement the Erosion and Sediment Control Program for review of Erosion and Sediment Control Plans

Meet permit requirement and measurable goals for

Year 4 under Public

Education and Outreach minimum control measure.

Year 5 Implement the Erosion and Sediment Control Program for review of Erosion and Sediment Control Plans

Meet permit requirement and measurable goals for

Year 5 under Public

Education and Outreach minimum control measure.

5.2 CONSTRUCTION SITE STORMWATER PROGRAM

The Construction Site Stormwater Program addresses the requirements for developing and implementing a program to control stormwater runoff from construction sites during earth disturbance activities consisting of one acre or more where there will be runoff to the MS4 (or five acres or more regardless of the planned runoff).

A SPDES Stormwater Construction Permit is required for earth disturbance activities (hereinafter referred to as “construction”) where (1) the construction disturbs five acres or more, or (2) there is a discharge from a site to the MS4 where earth disturbance is one acre or more.

By review and approval of Erosion and Sediment Control Plans (and proof of SPDES Stormwater

Construction Permits where required), and by coordinating building permits and other land development permits or approvals, we will meet the MS4 permit requirements for this component of the Construction Stormwater Runoff Management Minimum Control Measure. Satisfaction of these review and approval requirements will be met by a letter from the Directorate Of Public

Works Environmental Division indicating that (1) the Environmental Division has reviewed and approved the applicant’s Erosion and Sediment Control Plan developed in accordance with the regulatory requirements and, where required, (2) a SPDES Stormwater Construction Permit has been issued.

5.3 DEVELOPER/CONTRACTOR EDUCATION

Through this Minimum Control Measure component, we will distribute educational materials on the impacts of stormwater runoff and construction site stormwater management requirements to the developers/contractors planning to build/construct on Fort Hamilton. This educational element must be performed to be in compliance with permit requirements. Educational materials will include stormwater brochures and fact sheets.

SECTION 6

POST-CONSTRUCTION STORMWATER RUNOFF MANAGEMENT

Developing, implementing, and enforcing a program to address discharges of post-construction stormwater runoff from new development and redevelopment areas.

6.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL MEASURE

Enact, implement and enforce a stormwater control program, Coordinate the review and approval of post-construction Best Management Practices

(BMPs) simultaneously with the review and approval for construction Erosion and

Sediment Control Plans as described in the Construction Minimum Control Measure, Ensure long-term operation and maintenance of the BMPs

SUMMARY OF MIMIMUN CONTROL MEASURE

Stormwater Management Program

Long Term Operation and Maintenance

Year 1 Requirements:

No formal approval of land development/construction plans or issuance of building permits without DPW Environmental

Division of post-construction stormwater controls, For development and redevelopment activities with earth disturbance of one acre or more with runoff to the MS4, or five acres or more reguardlss of the planned runoff, be conducted in accordance with the Construction Stormwater

Runoff Management Program.

Process:

Rely on DPW Environmental Division or DPW-

Engineering, Plans, and Services review of permits where applicable for coordination of post-construction BMP approvals.

Standard:

Require post-construction structural and non-structural BMPs be designed, constructed and maintained to meet the NYSDEC statewide water quality requirements.

Ensure that stormwater

BMPs are built, installed, operated and maintained as designed

SUMMARY OF MIMIMUN CONTROL MEASURE

Stormwater Management Program

Long Term Operation and Maintenance

Year 2 Implement the post-construction BMP approval process

Ensure that stormwater

BMPs are built, installed, operated and maintained as designed

Year 3 Implement the post-construction BMP approval process

Ensure that stormwater

BMPs are built, installed, operated and maintained as designed

Year 4 Implement the post-construction BMP approval process

Ensure that stormwater

BMPs are built, installed, operated and maintained as designed

Year 5 Implement the post-construction BMP approval process

Ensure that stormwater

BMPs are built, installed, operated and maintained as designed

6.2 POST-CONSTRUCTION STORMWATER RUNOFF MANAGEMENT

This part of the management program applies to management of stormwater runoff after construction is complete. Fort Hamilton construction projects one acre or greater in size are controlled by construction specifications that stipulate Construction and Post-Construction

Stormwater Runoff Management Requirements and Inspections.

The management of post-construction runoff goes hand-in-hand with the Construction Minimum

Control Measure component. Approval for construction activities will be dependent on post-construction issues address in this section of the Program. For example, if an applicant’s plan for a land development or redevelopment project adequately addresses stormwater issues during construction but does not do so for post-construction impacts, then it will not be approved until the post-construction issues are addressed.

6.3 OPERATION AND MAINTENANCE OF POST-CONSTRUCTION BMPs

This section addresses the responsibility to ensure that the post-construction BMPs required and approved are constructed, operated, and maintained. This will be accomplished as part of the regular construction-inspection process.

SECTION 7

POLLUTION PREVENTION AND GOOD HOUSEKEEPING

FOR OPERATIONS AND MAINTENANCE

Developing and implementing a program with the goal of preventing or reducing pollutant runoff from municipal type operations. The program must include staff training on pollution prevention measures and techniques.

7.1 SUMMARY OF COMPONENTS OF THIS MINIMUM CONTROL MEASURE

Comprehensive Pollution Prevention Program for municipal type operations, focusing on vehicle maintenance, fueling and washing, heating oil deliveries, maintenance of stormwater facilities and employee training.

O&M Program training for employees.

Permit

Year

O&M Program Training Storm Water Facility

Operation, Maintenance and Inspection

Vehicle Maintenance, Fueling, and Washing

Gather information on existing facilities and programs.

Gather information on existing operations and programs.

No requirement.

Develop an operation, maintenance and inspection program for stormwater facilities

Develop pollution prevention based O&M Program for vehicle maintenance, fueling and washing , and heating oil deliveries.

Conduct basic awareness training for employees.

Implement O&M Program for stormwater facilities.

Implement O&M program for vehicle maintenance, fueling and washing, and heating oil deliveries.

Train employees on new procedures developed for stormwater facility operation, maintenance and inspection and vehicle maintenance, fueling and washing.

for stormwater facilities.

Implement O&M program for vehicle maintenance, fueling and washing, and heating oil deliveries.

Train new employees for stormwater facilities.

Implement O&M program for vehicle maintenance, fueling and washing, and heating oil deliveries.

Update training on procedures.

Continue training.

7.2 POLLUTION PREVENTION PROGRAM FOR MUNICIPAL TYPE OPERATIONS

This section of the program assures we have pollution prevention and good housekeeping programs for municipal type operations that minimize stormwater impacts to the MS4. The focus is on (1) inspection, operation, maintenance and repair of municipal type stormwater facilities such as detention and retention basins and other Best Management Practices, (2) pollution prevention related to municipal type vehicle operations, and (3) training of employees.

Compile information on existing facilities, operations/maintenance, inspection and pollution prevention programs.

MS4 stormwater system features, such as catchment and detention basins.

Programs to ensure proper operations and maintenance of the MS4 stormwater system features.

Municipal type vehicle operations, in particular vehicle maintenance, fueling, and washing; paying specific attention to: (1) frequency of activities, (2) types of substances used, (3) materials storage, handling, and disposal practices, and (4) employee training.

Develop O&M Program.

Storm water facilities: Fort Hamilton has no municipal like storm facilities. The Fort

Hamilton MS4 system consist of swales, curb and gutter, storm runoff catch basins, and underground piping that discharges through two outfalls into the Gravesend Bay.

Vehicles: Fort Hamilton Base Operations currently has an effective vehicle O&M program.

Heating Oil Delivery: Fort Hamilton currently has an effective regulatory required Spill

Prevention, Control and Countermeasures Plan (SPCCP)/Installation Spill Contingency

Plan (ISCP).

Fort Hamilton Base Operations has had an effective on-going O&M program for several years.

Fort Hamilton has had an effective on-going SPCCP/ICP program for several years.

Facility Areas

Facility areas exposed to stormwater are cleaned as needed to reduce debris and trash.

Vehicle Maintenance, Fueling, and Washing & Heating Oil Deliveries

Fueling: Underground storage tanks are equipped with overfill protection equipment.

Aboveground storage tanks have secondary containment. Fuel transfers are constantly watched to prevent overfilling and spilling. Topping off of fuel tanks is discouraged through training. Fueling area pavements are cleaned by applying absorbent, brooming, and disposing of spent absorbent into a proper receptacle for proper disposal. Spills are controlled and cleaned immediately with absorbent and are not washed into storm drains.

Maintenance: 1) Greasy rags, oil filters, air filters, batteries, spent coolant, degreasers, etc. are properly disposed into appropriate receptacles. 2) Waste and recycling drums and tanks are located in properly controlled area with a concrete slab and secondary containment. 3) Work areas are cleaned by brooming and are not hosed down. 4) Drip pans are placed under dripping vehicles. 5) Liquid waste is not poured into floor drains, sinks, outdoor storm drain inlets, or other storm drains or sewer connections. 6) Oil filters are recycled.

Washing: Vehicle washing takes place in a designated washing area. Wash fluid drains into an oil/water separated where it is treated prior to discharge to the NYC combined stormwater/sanitary sewer system.

Spills: Petrolum and chemical spills (rare) are cleaned up promply, throughly and cleanup waste disposed of properly in accordance with the SPCCP/ISCP.

Stormwater Facility Maintenance

Inspect and clean catch basins: Inspect each catch basin at least once annually to determine if it needs cleaning and note any repair needs. If the depth of deposits is greater than or equal to one-third the depth from the basin bottom to the invert of the lowest pipe or opening into or out of the basin, have the catch basin cleaned as soon as possible. Inspect catch basins in which debris significantly exceeds the one-third depth standard twice annually.

Disposal: Dispose of sediment and debris removed from catch basins in a proper manner.

Years 4 – 5

Continue to implement the O&M Program throughout Years 4 & 5.

7.3 POLLUTION PREVENTION & GOOD HOUSEKEEPING TRAINING

To meet this requirement employees will be given basic awareness training in stormwater management and in new procedures developed in the previous O&M section. The educational materials developed under the Public Education and Outreach Minimum Control Measure will be used for awareness training.

7.4 OTHER GOOD HOUSEKEEPING BMPs

Deicing Operations

Cover all salt/deicing material storage piles with tarps, hard shelters or contain them with dikes or berms.

Apply deicing materials according to manufacturer’s recommendations for the given circumstance. When determining the amount to apply, consider road width, traffic concentration, and road temperature to prevent overapplication.

Use trucks with calibration devices on their spreaders.

Avoid applying deicing materials near environmentally sensitive areas.

Clean each snow storage area after snow has melted by collecting debris and trash picked up in the snow removal process. This will aid in preventing floatables from entering stormwater catch basins.

Landscaping & Pest Control

Maintain landscaped stormwater drainage areas to minimize erosion and sedimentation.

Disturb as little vegetation as possible.

Minimize the period of time that the bare soil is exposed to precipitation.

Prevent surface runoff from flowing across disturbed areas.

Stabilize disturbed soils as soon as possible.

Provide adequate drainage for increased runoff.

Remove sediment from stormwater runoff before it leaves a construction site through the use of silt fences and haybales.

Significant nutrient loading to both surface and groundwater can result from over-application of lawn fertilizer. Limiting the amount of fertilizer applied to the minimum quantity needed for optimum plant growth will reduce the potential for surface and groundwater contamination.

Pretest soils to determine proper application rates.

Apply fertilizer, herbicides, fungicides, and pesticides exactly according to manufacturer guidelines, as more is not always better in the case of chemical application.

Use properly maintained and calibrated equipment.

Apply soil amendments evenly.

Keep soil amendments off all paved and sidewalk areas.

Use an adequate layer of topsoil that includes organic matter to reduce the need for fertilizers and pesticides.

Apply nutrients in small amounts several times a year, at periods of maximum turf need.

Ensure all applicators are licensed by the state. Require applicators to attend training to keep abreast of proper application techniques.

Pet Waste

Waste from pets results in three primary pollutant: Nutrients, Organic Matter, and

Pathogens. There is no significant pet population on Fort Hamilton and pet waste is not…