W9124J-20-B-0001_Attachment 06_fort belvoir esc technical bulletin #3_final I_012420.pdf

Fort Belvoir MS4 Program Bulletin #1, Stormwater Management and Erosion and Sediment Control Design, Review & Plan Approval Procedures and ESC Compliance Procedures During Construction (Revised 5/7/19) Page 1

Fort Belvoir Directorate of Public Works (DPW)

Municipal Separate Storm Sewer System (MS4) Program

Bulletin #1: STORMWATER MANAGEMENT (SWM) AND

EROSION AND SEDIMENT CONTROL (ESC) DESIGN,

REVIEW AND PLAN APPROVAL PROCEDURES AND SWM AND ESC

COMPLIANCE PROCEDURES DURING LAND DISTURBANCE

1. APPLICABILITY

This bulletin is applicable to Garrison, Tenant and Contractor Operations for stormwater and erosion and sediment control design for projects disturbing land areas of 2,500 square feet and greater.

2. BACKGROUND

To comply with the Fort Belvoir General Permit for Discharges of Stormwater from Small

Municipal Separate Storm Sewer Systems (MS4 Permit #VAR040093), Energy

Independence and Security Act Section 438 (EISA 438) and the Virginia Erosion and

Sediment Control, Stormwater Management and Chesapeake Bay laws and regulations, specific guidelines must be followed during design and construction of projects disturbing areas of 2,500 square feet and greater. As of July 1, 2014 Virginia Department of

Environmental Quality (VADEQ) has review and approval authority for erosion and sediment control design plans for construction projects disturbing 10,000 feet or greater of land and stormwater management design plans for projects disturbing one acre or greater of land on properties owned by Fort Belvoir.

3. LAND DISTURBANCE PROJECT PLAN APPROVAL - STORMWATER

MANAGEMENT AND EROSION AND SEDIMENT CONTROL PLANS

a. Plan Development - Land Disturbance Thresholds

Project Size Plans Required Review Authority

Less than 2,499 sq.ft. None DPW-Environmental Division

Between 2,500 sq.ft. and

9,999 sq.ft.

ESC & SWM

Plans

DPW-Environmental Division (for ESC &

SWM)

Between 10,000 sq.ft. and

43,559 sq.ft.

ESC & SWM

Plans

DPW-Environmental Division (for ESC &

SWM) & VADEQ (for ESC portion only)

Greater than or equal to one (1) acre

ESC & SWM

Plans

DPW-Environmental Division (for ESC &

SWM) & VADEQ (for ESC & SWM)

If your project involves land disturbance of greater than 5,000 square feet, AND includes the construction of a federal facility (building), stormwater design must also comply with

EISA 438.

(Revised 5/7/19) Page 2

b. Construction General Permit (CGP) Thresholds – Does Your Project Need a CGP?

*Virginia Code 62.1-44.15:34 C.7, which states that “routine maintenance that is performed to maintain the original line and grade, hydraulic capacity, or original construction of a project.” A maintenance project means you are ONLY exempt from requiring a Construction General Permit and SWPPP. All other requirements still apply;

please consult with DPW-Environmental to determine if your project can be considered maintenance.

c. Stormwater Management Plan Requirements

(1) If the project includes the construction of a federal facility and disturbs greater than

5,000 square feet, the SWM Plan shall comply with Section 438 of the Energy

Independence and Security Act (EISA 438). Technical guidance is located online at:

https://www.epa.gov/sites/production/files/2015-08/documents/epa_swm_guidance.pdf.

(2) Incorporation of Low Impact Development Best Management Practices will be used to meet requirements of EISA 438. The design objective of LID is to maintain or restore the hydrology of the site prior to the planned project being constructed with regard to the temperature, rate, volume and duration of flow. See https://mrsi.erdc.dren.mil/sustain/cx/lid for further guidance.

(3) The Stormwater Management (SWM) Plan must address all components outlined in

9VAC25-870-55.

Is your project greater or equal to one (1) acre in disturbance?

Yes No

No CGP

Required

Is this a maintenance project?*

Yes No

No CGP

Required

CGP

Required https://mrsi.erdc.dren.mil/sustain/cx/lid

(Revised 5/7/19) Page 3

(4) Per 9VAC25-870-63 and 65, the SWM Plan must utilize stormwater management BMPs from the Virginia BMP Clearinghouse to obtain the required water quality pollutant reductions. The required water quality pollutant reductions shall be calculated by using the Virginia Runoff Reduction Method (VRRM) Spreadsheet for site-specific project conditions. The VRRM Spreadsheets (currently version 3.0) are located online at:

https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/C onstructionGeneralPermit.aspx

(5) Per 9VAC25-870-66, each stormwater outfall location on the project site must be evaluated for Channel Protection and Flood Protection to the defined Limits of Analysis.

Different design criteria are specified in the regulation dependent on whether the outfall is discharging into a natural or manmade system.

(6) The SWM Plan shall comply with Chapter 6 of the Fairfax County Public Facilities

Manual (PFM), located online at:

https://www.fairfaxcounty.gov/landdevelopment/public-facilities-manual

(7) The VADEQ SWM Plan Review Checklist must also be completed by the designer and provided with plan submittal. This checklist is located online at:

http://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/Co nstructionGeneralPermit.aspx

(8) Per 9VAC25-870-55, stormwater management plans shall be appropriately sealed and signed by a professional registered in the Commonwealth of Virginia pursuant to Article

1 of Chapter 4 of Title 54.1 of the Code of Virginia.

d. Erosion and Sediment Control Plan Requirements

(1) Erosion and Sediment Control (ESC) plans must be developed to comply with the 19

Virginia Minimum Standards (9VAC25-840-40). The plan shall also utilize erosion and sediment control standards and specifications listed in Chapter 3 of the Virginia Erosion and Sediment Control Handbook (VESCH). Nomenclature for erosion and sediment control measures shall be consistent with the VESCH and the ESC Plan must follow the

Virginia Uniform Coding System:

http://www.deq.virginia.gov/Portals/0/DEQ/Water/StormwaterManagement/Erosion_Sed iment_Control_Handbook/Uniform%20Coding.pdf

(2) Guidance on development of ESC Plans can be found in Chapter 6 of the VESCH at the

Virginia Department of Environmental Quality (VADEQ) website:

http://www.deq.virginia.gov/Programs/Water/Laws,Regulations,Guidance/Guidance/Stor mwaterManagementGuidance.aspx

(3) The ESC Plan shall also comply with Chapter 11 of the Fairfax County Public Facilities

Manual (PFM) and is located online at:

https://www.fairfaxcounty.gov/landdevelopment/public-facilities-manual http://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx http://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx http://www.deq.virginia.gov/Portals/0/DEQ/Water/StormwaterManagement/Erosion_Sediment_Control_Handbook/Uniform%20Coding.pdf http://www.deq.virginia.gov/Portals/0/DEQ/Water/StormwaterManagement/Erosion_Sediment_Control_Handbook/Uniform%20Coding.pdf http://www.deq.virginia.gov/Programs/Water/Laws,Regulations,Guidance/Guidance/StormwaterManagementGuidance.aspx http://www.deq.virginia.gov/Programs/Water/Laws,Regulations,Guidance/Guidance/StormwaterManagementGuidance.aspx

(Revised 5/7/19) Page 4

(4) The VADEQ ESC Plan Review Checklist must also be completed by the designer and provided with plan submittal. The checklist is located online at:

http://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/Co nstructionGeneralPermit.aspx

e. Plan Review and Approval

The following steps are required for SWM and ESC plan approval. Table 1 (found in

Section 3.a.) specifies the type of plan(s) necessary for submittal to DPW-Environmental and VADEQ based on land disturbance thresholds.

Projects Requiring DPW Plan Approval Only (Less than 10,000 square feet of Land

Disturbance):

(1) The project proponent is responsible for submitting one (1) hard copy and one (1) CD of the required plan(s) and supporting documentation (Ex: computations, geotechnical reports, etc.) to the DPW-Environmental Division National Environmental Policy Act

(NEPA) Point of Contact (POC)(See Section 7.). Plan(s)/documents will be reviewed by Virginia certified ESC and SWM plan review personnel to ensure the plans meet federal, state, and county requirements, and permit requirements specified in the Fort

Belvoir Small Municipal Separate Stormwater System (MS4) Permit.

(2) Comments will be generated from the review and provided to the project proponent through USACE ProjNet (formerly Dr. Checks), email, or other means identified by the project proponent. The project proponent is responsible for responding to all comments in writing and for making all required revisions to the project plan(s) before re-submitting. This process will continue until the plan(s) is determined to be adequate for signature by the Director of Public Works.

(3) The DPW-Environmental Division has a minimum review time of two (2) weeks for initial submittal and subsequent re-submittals.

(4) Once the plans are determined to be adequate, four (4) hard copies of the plans will be submitted to the DPW-Environmental Division Stormwater POC (See Section 7.)

for signature by the Director of Public Works. Once signed, two hard copies will be returned to the project proponent (one for construction contractor, one for the contracting authority) and two copies will be retained by the DPW (one hard copy for

DPW ESC/SWM inspector and one hard copy for file). The project proponent is responsible for submitting one (1) CD that contains signed plans and any supporting documentation (calculations), if applicable, to the DPW-Environmental Division

Stormwater POC (See Section 7.) for the Fort Belvoir permit files.

http://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx http://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx

(Revised 5/7/19) Page 5

Projects Requiring DPW and VADEQ Approval (10,000 square feet and greater of

Land Disturbance):

In addition to Steps (1) – (3) outlined above, if the project plan(s) also requires VADEQ approval (See Table 1, Section 3.a.), the following steps will be completed prior to construction commencement.

(1) A cover letter will be provided to the project proponent/designer by DPW-

Environmental Division for submittal to VADEQ. This cover letter is signed by Fort

Belvoir’s Director of Public Works once the project is ready for submittal. In order for the cover letter to be completed and signed, the final total disturbed acreage of the project and the names of all documents in the VADEQ submittal (geotechnical report, SWM report, checklists, etc) must be provided to the DPW-Environmental Division

Stormwater POC (See Section 7.), along with the dates listed. The project proponent should allow for two weeks to receive the signed cover letter.

(2) The designer is responsible for submittal of all required documents to VADEQ for review and approval. Required submittal documents include, but are not limited to:

one (1) copy of the cover letter, one (1) hard copy of SWM and/or ESC plans, one (1) copy of all supporting documents (calculations, geotechnical reports, etc.), one (1) copy of the applicable SWM and/or ESC checklists, one (1) copy of the Completed

Construction General Permit Registration Statement (original ink, signed and dated), one (1) electronic copy (CD) of all documents submitted, and designer POC, phone number and email address. The complete package should be sent to:

Virginia Department of Environmental Quality

Northern Regional Office

Attn: Margaret Dannemann

13901 Crown Court

Woodbridge, VA 22193

(3) The designer is also responsible for submittal of (1) CD to the DPW-Environmental

Division Stormwater POC (See Section 7.) that contains all documents (plans and supporting stormwater calculations, geotechnical reports, plan review checklists, etc.)

that were submitted to VADEQ for review and approval.

(4) The designer is responsible for addressing any comments received by VADEQ during the review and approval process and subsequent resubmittals until the plan is approved. For subsequent resubmittal(s) to VADEQ, one (1) copy of all documents

(response to VADEQ comments, corrected plan set, corrected stormwater calculations, etc.) must be provided. In addition, one (1) CD of all documents resubmitted to VADEQ must be provided to the DPW-Environmental Division

Stormwater POC at the time of resubmittal.

(Revised 5/7/19) Page 6

Per 9VAC25-870-108, VADEQ has 15 calendar days to determine if plan is complete, 60 calendar days to review initial submittal and 45 days to review for each subsequent resubmittal. Based on past plan submittals, this process takes an average of three months to obtain VADEQ approval. Approval time may be less, dependent upon the size of the project, amount of VADEQ comments, and the turnaround time for document correction by the designer. Once the plan set is approved by VADEQ, the designer is responsible for submitting to the DPW-Environmental Division

Stormwater POC (See Section 7.) the following: four (4) hard copies of the VADEQ approved plans (with approval block) and one (1) CD that contains the VADEQ approved plans with the VADEQ stamped cover sheet, all supporting documents

(final stormwater calculations, geotechnical reports, plan review checklist(s), etc.)

submitted to VADEQ and the VADEQ Approval Letter.

(5) Upon approval from VADEQ, the designer will also submit to VADEQ one (1) CD of the approved plans and all supporting documents within 10 calendar days of receipt. Please keep in mind that a project must commence within 180 calendar days from receiving VADEQ approval. Plans that will begin outside of this time frame may be required to re-submit to VADEQ to start the review and approval process over again.

4. PRE - CONSTRUCTION APPROVAL PROCESS (ALL PROJECTS)

Projects 2,500 Square Feet – Less Than One Acre of Land Disturbance:

Once plans are approved and the construction contractor has been selected, the following steps are required prior to issuance of the Land Disturbance Letter by DPW.

(1) The construction contractor will provide DPW-Environmental Stormwater POC (See

Section 7.) with the contractor POC responsible for insuring that SWM and/or ESC plans are executed. This POC should be a VADEQ certified Responsible Land

Disturber (RLD), and record of certification shall also be provided to DPW-

Environmental Division at this time. Information on what an RLD is and certification can be found here:

http://www.deq.virginia.gov/ConnectWithDEQ/TrainingCertification/RLDGeneralInf ormation.aspx

(2) The construction contractor will complete and submit a Fort Belvoir Excavation

Permit Application (Dig Permit) for processing to Janet Salyars at DPW-Business

Office and Integration Division. A blank Excavation Permit Application can be picked up from Building 1442. Seven (7) copies of a to-scale map or plans are necessary for submittal with the Application. For questions about the process, please contact Janet Salyars at (703) 806-0057.

http://www.deq.virginia.gov/ConnectWithDEQ/TrainingCertification/RLDGeneralInformation.aspx http://www.deq.virginia.gov/ConnectWithDEQ/TrainingCertification/RLDGeneralInformation.aspx

(Revised 5/7/19) Page 7

Projects One Acre or Greater of Land Disturbance:

For projects greater than or equal to one acre of land disturbance (determined by the limits of construction), the construction contractor will complete steps (1) and (2) listed above and the additional requirements listed below:

(1) A Construction General Permit (CGP) must be obtained from VADEQ by the construction contractor. The contractor is responsible for completing and submitting the Registration Statement prior to construction commencement. Please see https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermit s/ConstructionGeneralPermit.aspx for more information on the Registration

Statement and associated CGP fees. As a reminder, if the construction contractor signs the Registration Statement, they are certifying that a SWPPP has already been prepared for the site. Land disturbance cannot start until the VADEQ CGP approval letter is received and provided electronically to DPW-Environmental Division

Stormwater POC.

(2) In addition to applying for the CGP, the contractor must also simultaneously prepare a Stormwater Pollution Prevention Plan (SWPPP) (see 9VAC25-870-54). For EPA guidance and SWPPP templates, please see: https://www.epa.gov/npdes/construction-general-permit-resources-tools-and-templates#swppp The SWPPP must be submitted to DPW-Environmental along with a completed DPW-Environmental SWPPP checklist for review prior to construction project commencement (9VAC25-880-70

Part II). The DPW-Environmental Division Stormwater POC (See Section 7.) may be contacted to obtain a copy of the SWPPP checklist.

Final Approval (DPW Land Disturbance Letter):

After the appropriate plan approval has been obtained, the CGP (if required) obtained, the

Excavation Permit approved and all project documentation received by the DPW-

Environmental Division Stormwater POC, the Land Disturbance Letter (LDL) will be issued by DPW. This letter documents that all stormwater requirements have been met and authorizes construction commencement.

5. ESC/SWM COMPLIANCE DURING CONSTRUCTION

Prior to groundbreaking, the construction contractor is required to contact the DPW-

Environmental Division Stormwater POC (See Section 7.) for assignment to a Fort

Belvoir DPW-Environmental Division, Virginia certified, ESC and SWM inspector. The contractor will make arrangements with the assigned inspector for a pre-construction meeting to review requirements of ESC plans, SWPPP and the CGP.

https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx https://www.epa.gov/npdes/construction-general-permit-resources-tools-and-templates#swppp https://www.epa.gov/npdes/construction-general-permit-resources-tools-and-templates#swppp

(Revised 5/7/19) Page 8

Once the construction project has started, the DPW-Environmental Division ESC/SWM inspector will conduct routine site inspections once every two weeks and within 48 hours after a rainfall event which produces greater than 0.5” of rain, and provide a written report of any deficiencies noted during the inspection. The RLD and a contracting officer’s representative is required to accompany the DPW-Environmental Division

ESC/SWM inspector. ESC inspections are based upon the requirements identified in the

Virginia Minimum Standards found at 9VAC25-840-40: http://leg1.state.va.us/cgi-bin/legp504.exe?000+reg+9VAC25-840-40 and conditions specified in the General

Permit for Discharges of Stormwater from Construction Activities (General Permit No.

VAR10 (9VAC25-880-70)). The DPW-Environmental Division ESC/SWM inspector will periodically conduct site inspections during the construction of the permanent stormwater management facilities.

Table 2 outlines the progressive compliance and enforcement strategy that Fort Belvoir

DPW will implement to ensure that contractors are conducting land disturbance responsibly and in accordance with Virginia Department of Environmental Quality stormwater management and erosion and sediment control regulations.

Table 2. Progressive Compliance and Enforcement Strategy

Non-Compliance Item DPW-ENVIRONMENTAL Response

Failure to obtain a Construction

General Permit (CGP) and/or an approved SWM and/or ESC plan from VADEQ prior to start of construction.

Email notice of Non-Compliance sent to the Contracting

Officer (CO); VADEQ Northern Regional Office notified via telephone within 24 hours of discovery.

Failure to provide copies of approved SWM and/or ESC plans, CGP authorization letter, SWPPP and/or Responsible Land

Disturber certification to DPW-

Environmental.

Email notice of Non-Compliance sent to the Contracting

Officer’s Representative (COR); Land disturbance letter not issued by DPW until applicable plans, permits, SWPPP and Responsible Land Disturber certification are received by DPW-Environmental.

Non-compliance with ESC minimum standards (9VAC25-

840-40), failure to update

SWPPP, failure to install ESC measures as a first step before any land disturbance

1st violation: DPW-Environmental Inspector notes on

ESC inspection report and contractor is expected to correct;

2nd repeat violation: Email warning notice sent to the

Contract Representative from the MS4 Stormwater

Program Manager;

3rd repeat violation: Warning Letter sent to the Contract

Representative signed by the Director of Public Works, VADEQ notified;

4th repeat violation: Notice of Non-Compliance sent to the Contract Representative signed by the Garrison

Commander;

http://leg1.state.va.us/cgi-bin/legp504.exe?000+reg+9VAC25-840-40 http://leg1.state.va.us/cgi-bin/legp504.exe?000+reg+9VAC25-840-40

(Revised 5/7/19) Page 9

Table 2. Progressive Compliance and Enforcement Strategy

Non-Compliance Item DPW-ENVIRONMENTAL Response

5th repeat violation: Referred to VADEQ for compliance assistance.

Release of any substance causing a reportable spill (including concrete wash out, paint runoff, or excess sediment)

DPW director notified and email warning notice sent to the Contract Representative.

6. ESC/SWM COMPLIANCE UPON CONSTRUCTION COMPLETION

(1) Upon completion of the construction project, the DPW-Environmental Division ESC/

SWM inspector will perform a final inspection and release the contractor when all deficiencies that were noted have been corrected. The contractor is responsible for submission of the Notice of Termination (NOT) of the CGP to the VADEQ

(Department of Environmental Quality, Office of Stormwater Management, Suite

1400, P.O. Box 1105, Richmond, Virginia 23218, constructiongp@deq.virginia.gov.

A blank VADEQ NOT is located online at:

https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermit s/ConstructionGeneralPermit.aspx. As part of this submission, the contractor is required to submit the construction as-built drawings (9VAC25-870-55) to the

VADEQ on one (1) CD. The construction as-built drawing shall be appropriately sealed and signed by a professional registered in the Commonwealth of Virginia, certifying that the SWM facilities have been constructed in accordance with the approved plan.

(2) Contractor cannot close out the CGP without complete and final permanent stabilization of the project site. VADEQ defines this as a stand of grass that is mature enough to survive and inhibit erosion.

(3) Copies of the NOT, construction as-built drawings, and any manufacturer maintenance specifications for permanent SWM facilities will also be submitted to the DPW-Environmental Division Stormwater POC on one (1) CD for records purposes.

mailto:constructiongp@deq.virginia.gov https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx https://www.deq.virginia.gov/Programs/Water/StormwaterManagement/VSMPPermits/ConstructionGeneralPermit.aspx

(Revised 5/7/19) Page 10

7. DPW-ENVIRONMENTAL DIVISION NEPA POC:

Name: Mr. Christopher Yesmant, NEPA Program Support

Physical Location: Bldg 1442, 2nd Floor, Room 227

Mailing Address: 9430 Jackson Loop, Bldg 1442 Directorate of Public Works Fort Belvoir, VA 22060

Telephone: 703-806-4008

Email: christopher.k.yesmant.civ@mail.mil

DPW-ENVIRONMENTAL DIVISION STORMWATER POC:

Name: Ms. Pamela Couch, MS4 Permit Compliance

Physical Location: Bldg 1442, 2nd Floor, Room 227

Mailing Address: 9430 Jackson Loop, Bldg 1442 Directorate of Public Works Fort Belvoir, VA 22060

Telephone: 703-806-3406

Email: pamela.j.couch2.civ@mail.mil mailto:christopher.k.yesmant.civ@mail.mil mailto:pamela.j.couch2.civ@mail.mil