Fort_Jackson_Annual_Report_06.29.2018.pdf

July 2018 Fort Jackson

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YEAR 3-4 NPDES ANNUAL REPORT

Enter Permit Years

Name of Permittee: Fort Jackson

ENTER NAME OF SMS4 PERMITTEE ABOVE

Annual Report Information

The following information is applicable to the above referenced permittee:

§1.4 OBTAINING AUTHORITY

Sec. Item Yes No NA

1.4.8 Have there been any areas annexed into your SMS4 area after you received coverage under this general permit?

ANSWER / COMMENT

No areas have been annexed into Fort Jackson’s SMS4 area since receiving coverage under this general permit.

1.4.8 and 4.5.4.1

If yes, has your SWMP been updated to include these areas and a schedule for BMP implementation in these areas?

If yes, see the updated SWMP in Appendix A.

No areas have been annexed into Fort Jackson’s SMS4 area since receiving coverage under this general permit.

§3.1 DETERMINATION OF RECEIVING WATER CONDITIONS AND IMPACTS

3.1.1.1 Refer to the most recent CWA §303(d) list approved by EPA to determine WQMS impairment status. Have there been any impaired stations added to the 303(d) list that your SMS4 discharges to?

If yes, update this information in your SWMP and put the updated SWMP in Appendix A.

The 2016 303(d) list was verified and no impaired stations have been added to which Fort Jackson’s SMS4 contributes. In this 303(d) list, there was a change made related to the priority ranking and TMDL development schedule. This was changed accordingly in Fort Jackson’s SWMP in Table 2.

3.1.1.1 Refer to the most recent CWA §303(d) list approved by EPA to determine WQMS impairment status. Have there been any impaired stations removed from the 303(d) list that your SMS4 discharges to?

If yes, update this information in your SWMP and put the updated SWMP in Appendix A.

The 2016 303(d) list was verified and no impaired stations have been removed to which Fort Jackson’s SMS4 contributes.

3.1.1.1 If there have been impaired stations added to or removed from the 303(d) list that your SMS4 discharges to, identify the pollutant(s) of concern (POC) and update POCs in the SWMP.

Include updated SWMP in Appendix A with changes made.

Fort Jackson has two 303(d) impaired stations downstream of their SMS4 drainage area: Stations C-021 and C-068. These are listed in the updated SWMP in Appendix A and include the pollutants of concern.

3.1.1.2 Have any new TMDLs been approved that your SMS4 discharges to?

If yes, determine whether POC have potential to occur in SMS4 stormwater discharges and update SWMP accordingly.

Find updated SWMP in Appendix A.

ANSWER / COMMENT

Fort Jackson has not had any new TMDLs approved that their SMS4 drains to. They have TMDLs for fecal coliform and dissolved oxygen in the Gills Creek watershed.

§3.2 TMDL MONITORING AND ASSESSMENT

Sec. Item Yes No NA

3.2.1.2.1.d Does your SMS4 discharge to TMDL waters?

If yes, list each pollutant of concern and report on the progress of the characterization of the relative pollutant levels from various SMS4 discharges to the TMDL waters.

ANSWER / COMMENT

Fort Jackson’s SMS4 drains to the Gills Creek TMDL waterbody, impaired for dissolved oxygen and fecal indicator bacteria (previously fecal coliform, now E. coli). Monitoring at Fort Jackson for the pollutants of concern-dissolved oxygen (DO) and E. coli began in 2015. Dissolved oxygen has been collected continuously (with exceptions listed in Appendix B of this document) at 15-minute increments and analyzed on both an annual scale and a seasonal scale. Data recorded at the monitoring station showed DO concentrations that were consistently above the SCDHEC minimum standards throughout the 2016 – 2017 monitoring period.

More detailed progress of the characterization for DO is in the Continuous Water Quality Monitoring Report in Appendix B of this document.

Bacteria monitoring for E. coli was conducted at the same location as the continuous water quality monitoring station, and samples were collected quarterly, in accordance with the Fort Jackson TMDL Monitoring and Assessment Plan. The bacteria dataset collected during this monitoring period showed bacteria concentrations above the water quality standard, suggesting a bacteria source in the watershed. However, this limited data did not show a strong correlation with streamflow or any notable seasonality, making the source of the bacteria difficult to determine. Sampling will continue according to the TMDL Monitoring and Assessment Plan. Additionally, Fort Jackson may investigate the relationship of bacteria concentrations with stream flow dynamics, with particular attention paid to any future flow alterations made upstream of the monitoring station. Additional details on the progress of the E. coli monitoring is included in Appendix B.

3.2.1.2.1.d and 5.3.2

If yes, include the resulting data in Appendix B.

Include data in Appendix B.

ANSWER / COMMENT

Please find the Continuous Water Quality Monitoring Report in Appendix B. This report includes sample results and analysis on the monitoring completed during this reporting period.

3.2.1.2.2.c Have updates to the TMDL Monitoring and Assessment Plans been made?

Include updated Monitoring Plan(s) in Appendix C.

No updates have been made to the TMDL Monitoring and Assessment Plans. Monitoring is being carried out as described in these plans.

3.2.1.2.2.d and 3.3.6

Provide a brief narrative on the progress of the TMDL Monitoring and Assessment Plan.

Include narrative below.

As discussed above, monitoring for DO and E. coli were conducted according to their respective TMDL Monitoring and Assessment Plans. These were each submitted to SCDHEC in December 2014 and have not had updates made to them. They can also be found in Appendix D of the SWMP. Fort Jackson continues to maintain its permanent water quality monitoring station, collecting continuous water quality data at 15-minute increments. In addition to the continuous data, grab samples for bacteria are collected on a quarterly basis during a range of precipitation conditions. The results for the data collected during this reporting period are further discussed in Appendix B of this document. Samples will continue to be collected according to the TMDL Monitoring and Assessment Plans.

Appendix B (page 56)

Provide a brief narrative identifying the water quality improvements or degradation.

Results and a brief analysis of the pollutants of concern that have been monitored is included in Appendix B.

In summary, DO levels at Fort Jackson were well above SCDHEC minimum standards at the selected monitoring location and, though there were not enough samples to draw conclusions, the E. coli samples did not meet the water quality standard. However, SCDHEC considers Fort Jackson (the permittee) in compliance with the established bacterial criteria for recreational use of the waterbody if they are in compliance with their permit.

Palmetto State Utility Services (PSUS) continues to perform sewer system upgrades on Fort Jackson. These upgrades to the sewer system have reduced inflow and infiltration and has also significantly reduced the number of sanitary sewer overflows occurring on post.

§3.3 TMDL IMPLEMENTATION AND ANALYSIS

3.3.2 Was your SMS4 required to submit a TMDL Implementation Plan?

If yes, list the date that the document was submitted to SCDHEC.

ANSWER / COMMENT

Fort Jackson mailed the TMDL Implementation Plan to SCDHEC on December 27, 2017.

3.3.6 Provide a brief narrative on the progress of the TMDL Implementation and Analysis Plan.

Fort Jackson has submitted their TMDL Implementation Plan and will begin to implement the BMPs described in the plan during Year 5 of the permit term, as stated in the plan’s schedule. Progress on the TMDL Implementation Plan will be provided in the next annual report.

§4.1 PERMIT REQUIREMENTS

4.1.6.1, 5.3.1, and Appendix

B (page 56)

Has your SWMP been reviewed and updated to include the status of your compliance with permit conditions, an assessment of the appropriateness of the identified BMP, progress towards achieving the statutory goal of reducing the discharge of pollutants to the MEP, and the measureable goals for each of the minimum control measures.

See updated SWMP in Appendix A.

Fort Jackson’s SWMP was last updated in June 2018 and the revised version is included as Appendix A of this document. The majority of updates to the SWMP were made to the Minimum Measure Permit Requirement tables in order to adjust wording for items that have been completed and to the BMP Minimum Measure tables to reflect the current status of each milestone and to include descriptions of the progress made towards each measurable goal. With the update of the SWMP, the impaired stations list was updated, as appropriate, with the 2016 303(d). The BMPs listed in the SWMP are appropriate measures for Fort Jackson to implement as they work towards reducing the discharge of pollutants of concern to the MEP.

These BMPs have associated measurable goals that will ensure Fort Jackson’s program contributes to the reduction of the pollutants of concern.

4.1.6.2 and Appendix B (page 56)

Have your proposed changes to the stormwater management programs that are established as permit conditions been updated in your SWMP?

Include updated SWMP in Appendix A.

Updates to the BMPs listed in the SWMP were made based on what was completed during the permit year.

Dates specified by the permit were not changed, though some interim milestones were updated to reflect feasible time frames for completion.

4.1.6.3 and Appendix B (page 56)

Include/revise an assessment of controls and the fiscal analysis. In this, include a description of staff resources necessary to meet the requirements of this permit.

Include narrative on this assessment here.

In 2016 and 2017, Fort Jackson had the financial and staff resources to comply with their permit and carry out the BMPs addressed in their SWMP. Fort Jackson’s NPDES compliance is on the “must fund” list of Fort Jackson’s annual budget; therefore, funds should be available to execute programs listed in the SWMP according to the schedules. Fort Jackson currently employs two full time staff and several other program managers who assist in completing tasks listed in the SWMP for the Stormwater Program. These program areas include, but are not limited to, Hazardous Waste, Environmental Performance Assessment System (EPAS), Spill Prevention Control and Countermeasure (SPCC), Training/Outreach, and Solid Waste.

4.1.6.4, Has a summary of data, including monitoring data, that has been

5.3.2, and Appendix B accumulated been added to the appendix?

Include updated SWMP in Appendix A.

ANSWER / COMMENT

Please find the Continuous Water Quality Monitoring Report in Appendix B. This report includes sample results and analysis on the monitoring completed during this reporting period.

4.1.6.5 and Appendix B

Include a summary describing the number and nature of enforcement actions.

Include here.

No enforcement actions were taken during 2016 and 2017. Since the facilities, utilities, and operations are owned and/or managed by the federal government (Fort Jackson), corrective actions are typically delegated without enforcement actions.

4.1.6.5 and Appendix B

Include a summary describing the number and nature of inspections Include here.

ANSWER / COMMENT

In 2016 and 2017, the Fort has completed the following inspections.

NPDES Construction Sites

123 Inspections Conducted in 2016

215 Inspections Conducted in 2017

Potential Illicit Discharge Inspections

8 Inspections in 2016

14 Inspections in 2017

Dry-Weather Screening

4 Inspections in 2016

8 Inspections in 2017

Tank Inspections (at High Priority Facilities)

56 Inspections in 2016

57 Inspections in 2017

Hazardous Waste Inspections (at High Priority Facilities)

60 Inspections in 2016

60 Inspections in 2017

Environmental Performance Assessment System (EPAS)-Good Housekeeping (High Priority Facility Inspections)

2 Inspections in 2016

7 Inspections in 2017

Municipally-Owned Structural Control Inspections

11 Inspections in 2016

18 Inspections in 2017

No post-construction installation inspections were completed during 2016 and 2017 because no construction projects that contained post-construction stormwater controls filed an NOT.

Post-Construction Maintenance Inspections (to ensure Fort Jackson permitted BMPs are maintained properly)

11 Inspections in 2016

22 Inspections in 2017

4.1.6.5 and Appendix B

Include a summary describing the number and nature of public education programs.

The following table summarizes the event, target audience and the number of people reached for 2016 and 2017. Several trainings are listed below that the number of people reached was not able to be quantified, and the reason is provided.

Strategy Nature of Program Target Audience Number of People

Reached

Environmental Compliance Officers Course (ECOC)

The ECOC provides training for the appointed Environmental

Compliance Officer ensuring that they are compliant with updated/new requirements and are completing assessments properly and any deficiencies are corrected.

Military, Civilian, Industrial

2016: 180 (6 classes/year averaging

30 per class)

2017: 180 (6 classes/year averaging

30 per class)

Administrative ECOC ECO class offered to activities mostly administrative in nature.

Military, Civilian, Contractors

2016: 19

2017: 13

Environmental Quality Control Committee

(EQCC)

Committee functions to advise Commanders, Directors, and Staff on environmental priorities, policies, strategies, and programs.

Military, Civilian, Industrial

2016: 90

2017:30

Earth Day Events These events include

Environmental Series and educational events for all ages.

Military, Civilian, School Children

2016: 200

2017: 200

Environmental Awareness Training

This is a mandatory requirement that includes training for Army

Regulation (AR) 200-1, Environmental Protection and

Enhancement and Field Manual (FM) 3-34.5, Environmental

Considerations.

Military ,Civilian

2016: 840 (2 trainings/month averaging 35 per class)

2017: 840 (2 trainings/month averaging 35 per class)

America Recycles Day

This event includes the collection of recyclable products. In addition, non-recyclable materials, such as electronics, tires, etc., are collected from proper disposal.

Military, Civilian 2016: 50

2017: 75

Hazardous Substance Training

This training is held quarterly for personnel that store or manage hazardous waste or controlled waste, and organizations that have a high potential for hazardous waste generation or hazardous substance violations.

Military, Civilian, 2016: 153

2017: 147

Spill Prevention, Control, and Countermeasure

(SPCC) Training

This training covers spill response, regulations, and information in

Fort Jackson’s SPCC Plan.

Military, Civilian, 2016: 153

2017: 118

Safety Day

An annual event to promote safety throughout the community.

Attendees include people from on and off-post.

2016: 300

2017: 300

Clean-up Events Events held to clean up trash and debris that accumulates on portions of Fort Jackson.

2016: 0

2017: 10

Environmental Division Website

Provides information to the public regarding Fort Jackson’s environmental programs, including the Stormwater program.

Military, Civilian, Contractors

No Hit Counter

Meetings: Pre- Construction, Design

Review, Planning Charrettes

Meetings held prior to construction, including discussion of stormwater and erosion control requirements.

Civilian, Contractors Many throughout each year

Environmental Division Newsletter

A newsletter emailed post-wide that includes upcoming environmental training courses and environmental information.

Military, Civilian, Industrial

6 newletters each year

Fort Jackson/McCrady Environmental Field Cards

Environmental Field Cards provide phone numbers and frequencies

Military Post-wide distribution related to Fort Jackson, information regarding environmental concerns, and other relevant information.

4.2.3.2.3.b Include an assessment of the effectiveness of the Field Screening component of the IDDE program to determine if the level of effort is adequate in attaining the effective prohibition of non-stormwater discharges into the SMS4.

Include assessment here.

Fort Jackson has been conducting field screening of potential illicit discharges, as necessary, throughout the permit term. With this program, they have a consultant inspect selected outfalls for any dry weather flow and the appropriate investigations are performed according to the Illicit Discharge Detection and Elimination Guidance Document. Throughout the permit term, from 2014-2017, Fort Jackson has identified 33 potential illicit discharges, of which 14 have been identified as illicit discharges, and all 14 have been eliminated.

Based on these results, Fort Jackson has assessed the effectiveness of the IDDE program, and has confirmed that their level of effort is adequate in attaining the effective prohibition of non-stormwater discharges to the SMS4. Fort Jackson will continue their IDDE program to track and eliminate illicit discharges, to the MEP.

4.2.3.2.3.b Were there any updates found to be necessary to the Field Screening component?

If yes, make appropriate changes and include them as a part of the renotification. Include summary of updates made here.

ANSWER / COMMENT

Fort Jackson has assessed the effectiveness of the IDDE program, and has confirmed that their level of effort is adequate in attaining the effective prohibition of non-stormwater discharges to the SMS4. They will continue their IDDE program to track and eliminate illicit discharges to the MEP.

4.2.3.2.7.e Include any corrective actions taken/resulting enforcement actions to eliminate illicit discharges.

In 2016, Fort Jackson performed eight (8) inspections for potential illicit discharges and one (1) was confirmed to be an illicit discharge. This illicit discharge was eliminated and no enforcement actions were necessary. In 2017, Fort Jackson performed fourteen (14) inspections for potential illicit discharges and two

(2) were confirmed to be an illicit discharge. Both illicit discharges were eliminated and no enforcement actions were necessary.

Fort Jackson is unique in the aspect of how enforcement actions are handled to eliminate illicit discharges.

When an illicit discharge is located, it will be corrected by responsible Fort Jackson staff. Since the facilities, utilities, and operations are owned and/or managed by the federal government (Fort Jackson), corrective actions are typically delegated without enforcement actions.

§4.5 REVIEWING AND UPDATING STORMWATER MANAGEMENT PLANS

Sec. Item Yes No NA

4.5.1, 5.3.4, and

Appendix B (page 56)

Have you reviewed and updated your SWMP, including changes to any BMP or any identified measureable goals that apply to the program elements?

The updated SWMP can be found in Appendix A

Fort Jackson’s SWMP has been updated and is included in Appendix A. Appendix A of the SWMP includes the items that were changed in the SWMP. In general, changes were made to the Minimum Measure Permit Requirement tables to adjust wording for items that have been completed along with adjusting BMP Minimum Measure tables to include the status of the milestone and updates to the measurable goal.

5.3.3 Has a summary of the stormwater activities you plan to undertake during the next reporting cycle been developed and updated?

The implementation schedule can be found in Appendix D.

Fort Jackson’s SWMP has been updated and is included in Appendix A of this document. Appendix B of the SWMP includes deadlines for Fort Jackson associated with the SWMP. This table has been updated to include what has been completed along with the schedule for implementing items throughout the permit term.

The permit expires December 31, 2018, but milestones are set to continue throughout Year 6 of the permit term should permit coverage need to be continued. These items will be continued until the next permit is effective.

5.3.5 Is your SMS4 relying on another entity to satisfy some of your permit obligations?

If yes, please list and include agreement in Appendix.

Fort Jackson is not relying on another entity to satisfy any of the permit obligations.

Appendix B (page 56)

Provide annual expenditures and proposed budget, including legal restrictions in the use of such funds for the following year.

Provide information here.

In 2016 and 2017, Fort Jackson’s Environmental (ENV) Division annual expenditures were $199,651 and $225,332, respectively. The ENV Division is not allowed to use funds for BMP (stormwater structure) maintenance and repair, erosion control/repair projects, or installation of LID not required for permit compliance. Since the NPDES compliance is under Fort Jackson’s must fund list on the annual budget, comparable funds should be available for the following year. The budget set for 2018 is $306,704.

Appendix A

Fort JacksonFort Jackson

Updated/Revised SWMP

Appendix B

Continuous Water Quality Monitoring Report

Appendix C

Revised/Updated Monitoring and Assessment Plan

N/A-No updates were made to Fort Jackson’s Monitoring and Assessment Plans. The original TMDL

Monitoring and Assessment Plans are included in Appendix D of the SWMP that is located in Appendix

A of this document.

Appendix D

Fort Jackson

Implementation Schedule for Following Years

The implementation schedule for the remainder of the permit term, as well as the items that have been completed, are included in Appendix B of the SWMP that is located in Appendix A of this document.