Attachment 5(i) - APG Marinas SWP3_Final.pdf

Environmental Health Engineering Study No. S.0073148-20, June 2020 Environmental Health Sciences and Engineering

Marinas Storm Water Pollution Prevention Plan Update, Aberdeen Proving Ground, Maryland, June 2020

Prepared by: Ms. Melissa Torralbes, Environmental Health Engineering

Approved for public release; distribution unlimited.

General Medicine: 500A Public Health

Environmental Health Engineering Study No. S.0073148-20, Marinas Storm Water Pollution Prevention Plan Update, Aberdeen Proving Ground, Maryland, June 2020 i

TABLE OF CONTENTS

Page

1. INTRODUCTION

2. SWP3 FORMAT

3. STORM WATER POLLUTION PREVENTION TEAM

4. SITE MAP

5. POTENTIAL POLLUTANT SOURCES

5.1 Material Inventory

5.2 Significant Spills and Leaks

5.3 Non-Storm Water Discharges

5.4 Salt Storage

5.5 Visual Monitoring Summary

6. STORM WATER CONTROL MEASURES

7. SCHEDULE AND PROCEDURES

8. EMPLOYEE TRAINING

9. MONITORING, INSPECTIONS, AND REPORTING

9.1 Effluent Limitations

9.2 Routine Facility Inspections

9.3 Quarterly Visual Monitoring

9.4 Comprehensive Site Compliance Evaluation

9.5 Record Retention

10. CORRECTIVE ACTIONS

10.1 Conditions Requiring Review and Revision

10.2 Conditions Requiring Review to Determine if Modifications are Necessary

10.3 Corrective Action Deadlines

10.4 Corrective Action Report

11. REFERENCES

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APPENDICES

A NPDES PERMIT MDG99 ............................................................................................ A-1 B NOI AND CERTIFICATION ......................................................................................... B-1 C ATC BOAT DOCK ....................................................................................................... C-1 D GUNPOWDER NECK MARINA ................................................................................... D-1 E NON-STORM WATER DISCHARGE CERTIFICATIONS ............................................ E-1 F INSPECTION AND MAINTENANCE RECORDS ..........................................................F-1 G TRAINING RECORDS ................................................................................................ G-1 H ROUTINE FACILITY INSPECTIONS ........................................................................... H-1 I QUARTERLY VISUAL MONITORING ........................................................................... I-1 J COMPREHENSIVE SITE COMPLIANCE EVALUATIONS ........................................... J-1 K CORRECTIVE ACTION REPORTS ............................................................................ K-1

FIGURES

1. General Location Map

TABLES

1. SWPPT

ENVIRONMENTAL HEALTH ENGINEERING STUDY NO. S.0073148-20

MARINAS STORM WATER POLLUTION PREVENTION PLAN UPDATE

ABERDEEN PROVING GROUND, MARYLAND

JUNE 2020

1. INTRODUCTION

Federal regulations require that storm water discharges from marinas, in which maintenance and/or equipment cleaning operations are conducted, be permitted under the National Pollutant Discharge Elimination System (NPDES) or a state-administered NPDES [Environmental Article, Title 9, Subtitle 3 (Maryland Department of the Environment (MDE), 2019a); Code of Maryland Regulation (COMAR) 26.08.01 through 26.08.04) (MDE, 2019b); and Title 40 Code of Federal Regulation (CFR) Parts 122, 123, 124, and 125 (40 CFR 122–125, 2020a–d, respectively)]. The MDE General Discharge Permit No. 16-MA (NPDES Permit No. MDG99) authorizes the discharge of storm water and certain wastewater from marinas, boat yards, and yacht basins to waters of the State (MDE, 2017). This permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWP3) designed to minimize pollution through training, awareness, and source control. Implementation of this SWP3 and best management practices (BMPs) allows Aberdeen Proving Ground (APG) to comply with MDE requirements. Appendix A provides a copy of the permit. The letter authorizing coverage under this permit will be kept alongside a copy of the Notice of Intent (NOI) in Appendix B of this SWP3.

APG owns and operates three marinas: the Aberdeen Test Center (ATC) Boat Dock (Building

627) and the Spesutie Island Marina (Building 36) located on APG-North and the Gunpowder Neck Marina (Building E-2168) located on APG-South. The Spesutie Island Marina does not provide or allow boat maintenance or equipment cleaning; therefore, this marina does not require coverage under the general permit and will not be included in this SWP3. Figure 1 illustrates the general location of the ATC Boat Dock and Gunpowder Marina on the installation.

2. SWP3 FORMAT

This document contains a marina-wide SWP3 and two facility-specific plans in Appendices C and D. Each marina will receive and implement the SWP3. At each facility, materials and pollutants of concern are identified, along with existing and proposed BMPs. The SWP3 will be amended whenever there is a change in design, construction, operation, or maintenance that has a significant effect on the marinas’ pollution potential, or if the SWP3 proves ineffective in controlling pollutants in storm water discharges from these facilities.

3. STORM WATER POLLUTION PREVENTION TEAM

The APG Storm Water Pollution Prevention Team (SWPPT) is responsible for developing, implementing, and modifying the SWP3, and providing required reports and inspections. The team is also responsible for maintaining and implementing BMPs. Table 1 provides the responsibilities of the SWPPT leader and members.

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Table 1. SWPPT Member Responsibilities SWPPT Leader Richard Wiggins Water Quality Program Manager Environmental Compliance Branch DPW Environmental Division 410-436-3808

Assume overall responsibility for implementation of the plan.

Coordinate all stages of plan development.

Oversee all team member activities.

Review and approve all plan modifications and updates.

If delegated, signs certifications and correspondence to the State concerning storm water as necessary.

SWPPT Members Teresa Bartley Water Program Team Environmental Compliance Branch DPW Environmental Division 410-417-0690

Maia Kaiser Water Program Team Environmental Compliance Branch DPW Environmental Division 410-306-2199

Assist the SWPPT Leader as necessary.

Coordinate quarterly inspections and visual assessments.

Coordinate updates to the SWP3 as needed.

Maintain all records.

Update the SWP3 to reflect reported spills.

Track annual storm water management training for marina personnel.

Sarah Kryston ATC Boat Dock 410-278-4049

Kevin Reich Gunpowder Neck Marina 410-278-4124

Monitor compliance with scheduled activities in SWP3.

Provide technical assistance and guidance to SWPPT Leader as necessary.

Legend:

SWPPT = Storm Water Pollution Prevention Team DPW = Directorate of Public Works SWP3 = storm water pollution prevention plan SWPPT = Storm Water Pollution Prevention Team ATC = Aberdeen Test Center

4. SITE MAP

Storm water site maps for each marina are included in Appendices C and D. The storm water site maps include—

The pattern of storm water drainage, Structural features that control pollutants in runoff, Surface water bodies, and Significant materials that are stored or exposed to rainfall and runoff.

5. POTENTIAL POLLUTANT SOURCES

This SWP3 describes activities and materials at the marinas on APG. The potential pollutant sources for each marina are described in Appendices C and D. A narrative assessment of the storm water pollution risk associated with each source is also included. Potential pollutant sources will be updated annually.

5.1 Material Inventory

An inventory of significant materials that are or may be exposed to storm water is included in Appendices C and D for each marina. Included in the inventories is a description of existing storm water management controls.

5.2 Significant Spills and Leaks

Significant spills and leaks of toxic or hazardous substances that have occurred at APG’s marinas in the past 3 years are presented in Appendices C and D. The date of release, location, content, capacity, and response procedures are described. These descriptions will be updated annually. The APG Facility Response Plan and Emergency Response Action Plan detail spill response, notification, and reporting procedures. Spills and leaks are tracked and recorded in Appendix K of the Facility Response Plan.

5.3 Non-Storm Water Discharges

Non-storm water discharges authorized under the permit (MDE, 2017) include:

Wastewater from washing of boats and engines.

Bilge water collected from vessels to containment and treated prior to discharge, except where emulsifiers or detergents/soaps are added to bilge.

Uncontaminated non-contact cooling water or condensate from machinery including, but not limited to ice machines, coolers, and refrigeration units. Any discharge, which contains additives, may only be authorized by a separate individual NPDES permit.

Water from non-pressurized rinsing of boats without using soaps, cleaning agents, or additives.

Water used to fight active fires (not from fire system cleaning or testing).

Pavement and docks (Part III.A.3.a) wash waters where no detergents are used and no spills or leaks of toxic or hazardous materials have occurred (unless all spilled material has been removed).

Landscape watering, only if all pesticides, herbicides, and fertilizer have been applied in accordance with the approved labeling.

Routine external building wash down that does not use detergents and any dislodged paint chips are filtered.

Irrigation drainage.

Uncontaminated ground water or spring water.

Foundation or footing drains where flows are not contaminated with process materials.

Incidental windblown mist from cooling towers that collects on rooftops or adjacent portions of your facility, but not intentional discharges from the cooling tower (e.g., “piped” cooling tower blowdown or drains).

The following activities or discharges are not eligible for coverage under the permit

(MDE, 2017):

Storm water discharges whose NPDES permit has been terminated (other than at the request of the permittee) or denied, or those for which MDE requires an individual permit.

Sanitary wastewater discharges, including commingled sanitary wastewater discharges.

Wastewater discharges from chemical stripping operations and any storm water, which commingles with such wastewaters.

In-water washing of boat bottoms painted with soft ablative paints, or paints which create a visible plume.

Removal of any paints while vessel is in water.

Discharges that contain visible oil sheen, persistent foam, or floating solids.

Any wash water containing soaps or any detergents, regardless of whether they are labeled ‘biodegradable’ or ‘green.’

The marinas will eliminate non-storm water discharges not authorized by a NPDES or State discharge permit.

Storm water conveyance systems at the marinas will be evaluated annually for the presence of non-storm water discharges in conjunction with comprehensive site compliance evaluations.

Non-storm water certifications will be maintained in Appendix E.

5.4 Salt Storage

Piles of salt are not located at the marinas; however, small volume bags may be kept onsite.

The locations of any salt stored at the facilities are included in Appendices C and D.

5.5 Visual Monitoring Summary

Appendices C and D present summaries of visual monitoring conducted under the permit

(MDE, 2017).

6. STORM WATER CONTROL MEASURES

APG has implemented storm water control measures to meet the non-numeric technology-based effluent limits in Part III.B of the permit (MDE, 2017). BMPs are defined as physical, structural, and/or managerial practices that, when used singly or in combination, prevent or reduce storm water pollution. Appendices C and D identifies the existing BMPs at APG marinas along with a schedule of implementation.

Recommended BMPs and implementation dates are proposed annually during the comprehensive site compliance evaluation. Proposed BMPs and schedules will be listed in the annual comprehensive report.

7. SCHEDULE AND PROCEDURES

The permit requires the development of schedules and procedures for good housekeeping and maintenance control measures to include (MDE, 2017):

A schedule for regular pickup and disposal of waste materials;

Routine inspections for leaks and conditions of drums, tanks, and containers; and A schedule for preventive maintenance activities, including regular inspections, testing, maintenance, and repair of all industrial equipment and systems, and control measures.

Appendices C and D identifies schedules for the inspection and maintenance of existing control measures at each marina. Documentation of inspection, maintenance, and repairs of control measures will be maintained in Appendix F. Documentation will include:

Date(s) of inspection and regular maintenance;

Date(s) of discovery of areas in need of repair/replacement, and for repairs;

Date(s) that the control measure(s) returned to full function; and The justification for any extended maintenance/repair schedules.

8. EMPLOYEE TRAINING

Once per calendar year, training will be conducted for all marina personnel responsible for implementing the activities identified in this SWP3. Training will address the following activities, where applicable:

Used oil management, Spent solvent and paint management, Disposal of spent abrasives, Spill prevention and control, Fueling procedures, General good housekeeping practices, Used battery management, Waste recycling, and Used container controls, etc.

Training records will be maintained in Appendix G.

9. MONITORING, INSPECTIONS, AND REPORTING

9.1 Effluent Limitations

Monitoring is required for marinas that discharge boat bottom wash water and/or collected bilge water to surface or ground waters. Marinas are required to collect all pressure washer wastewater generated from boat bottom washing activities and either: 1) meet numeric effluent limits for total suspended solids, oil and grease, copper, zinc, and lead, or 2) eliminate discharges to surface waters by directing it to one or more locations for treatment (i.e., a closed loop recycling system, utilizing off-site disposal, or connect to a sanitary sewer system with permission of the local sewer authority). While the permit does not mandate the collection of bilge water, bilge water that has been collected from a vessel, in order to prevent an incidental discharge to waters of the State, is subject to numeric effluent limits for oil and grease.

Pressure washing at the ATC Boat Dock is conducted outdoors and wash water is captured in a containment area. Wash water is then pumped out and taken to an off-site industrial wastewater facility. ATC Boat Dock personnel visually inspect bilge water for contamination prior to discharge from a vessel directly into Spesutie Narrows. Since bilge water is not collected and boat bottom wash water discharges to surface waters have been eliminated, monitoring is not required at the ATC Boat Dock.

Currently, wash water from pressure washing activities at the Gunpowder Neck Marina is discharged directly to the ground or to surface waters. Once approved for coverage under the permit, wash water will be captured in a containment area and discharged to the sanitary sewer system. Bilge pump-out is not conducted at the marina. Since bilge water is not collected and boat bottom wash water discharges to surface waters have been eliminated, monitoring is not required at the Gunpowder Neck Marina.

9.2 Routine Facility Inspections

Once per quarter, a site assessment will be conducted at each marina to review the effectiveness of the SWP3. At least once per calendar year, this inspection will be conducted while a storm water discharge is occurring. The inspection will be documented with a checklist or other summary signed by the Duly Authorized Representative, with at least one member of the SWPPT taking part. The checklist will include—

The inspection date and time, Name and signature of inspector, Control measures in need of maintenance, Incidences of noncompliance and associated corrective actions, and Certification that the site complies with the SWP3 and permit.

Routine facility inspections will be maintained in Appendix H, where a copy of the form has been provided.

9.3 Quarterly Visual Monitoring

Once each quarter, visual monitoring of storm water discharges will be conducted at each marina. Grab samples will be collected within the first 30 minutes of a storm event where there is a measurable discharge. In areas subject to snow, one quarterly visual assessment must capture snowmelt discharge. Samples will be assessed for visual indicators of storm water pollution including color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, and other qualitative markers of pollution. Results will be documented on the Quarterly Visual Monitoring Form, provided in Appendix I. The samples are not required to be collected consistent with 40 CFR 136 procedures, but should be collected to be representative of the storm water discharge (40 CFR 136, 2020e). Visual assessments must be conducted at all outfalls, although if several outfalls are “substantially identical” then only one visual assessment must be conducted on the set of outfalls. Visual monitoring will be performed at these quarterly intervals: January 1 – March 31; April 1 – June 30; July 1 – September 30; and October 1 – December 31. Visual monitoring results will be maintained in Appendix I.

9.4 Comprehensive Site Compliance Evaluation

Comprehensive site compliance evaluations will be performed annually at each marina.

Evaluations will be conducted by a member of the SWPPT or hired contractor. The evaluation is conducted to assess the effectiveness of this SWP3 and subsequent storm water BMPs, as well as identify any activity changes in material inventory and/or contaminant handling procedures. If a scheduled compliance evaluation overlaps with a routine facility inspection, the annual compliance evaluation may be used as one of the four routine facility inspections.

A report will summarize the scope of the evaluation, name(s) of personnel performing the evaluation, the date of the evaluation, and all observations relating to the implementation of the SWP3. The compliance evaluation report will identify any incidents of noncompliance.

Deficiencies and corrective actions are documented as proposed BMPs within the evaluation.

Any proposed or recommended management practices will be implemented as soon as practically feasible to prevent non-storm water discharges. Based on the results of the evaluation, the SWP3 must be modified as necessary. Refer to paragraph 10.3 (Corrective Action Deadlines) and paragraph 10.4 (Corrective Action Report) of this SWP3 for appropriate time frames. Comprehensive site compliance evaluations will be maintained in Appendix J, where a copy of the report form has been provided.

9.5 Record Retention

All records and information resulting from the monitoring activities required by the permit, including all records of analyses performed, calibration and maintenance of instrumentation, and original recordings from continuous monitoring instrumentation, must be retained for a minimum of 5 years.

10. CORRECTIVE ACTIONS

10.1 Conditions Requiring Review and Revision

If any of the following conditions occur, APG will review and revise the selection, design, installation, and implementation of control measures at the marinas to ensure the condition is eliminated and will not be repeated in the future:

An unauthorized release or discharge (e.g., spill, leak, or discharge of non-storm water not authorized by any MDE NPDES permit) occurs at the facility.

A discharge violates a numeric effluent limit.

APG becomes aware, or MDE determines, that the control measures are not stringent enough for the discharge to meet applicable water quality standards.

An inspection or evaluation of the facility by MDE, determines that modifications to the control measures are necessary to meet the non-numeric effluent limits in this permit.

APG finds in the routine facility inspections, quarterly visual assessments, or comprehensive site compliance evaluations that its control measures are not being properly operated and maintained.

10.2 Conditions Requiring Review to Determine if Modifications are Necessary

APG will review the selection, design, installation, and implementation of control measures to determine if modifications are necessary to meet the effluent limits in the permit if construction or a change in design, operation, or maintenance at the facility significantly changes the nature of pollutants discharged in storm water from the facility, or significantly increases the quantity of pollutants discharged (MDE, 2017).

10.3 Corrective Action Deadlines

APG will document discoveries of any of the conditions listed in Sections 10.1 and 10.2 within 24 hours of making the discovery. Subsequently, within 14 days of a discovery, APG will document any corrective action(s) to be taken to eliminate or further investigate the deficiency, or if no corrective action is needed, the basis for that determination. If APG determines that changes are necessary following its review, any modifications to control measures will be made before the next storm event, or as soon as practicable. If a deficiency cannot be addressed fully within 30 days, APG will call MDE’s Compliance program and make them aware of the situation.

10.4 Corrective Action Report

Within 24 hours of discovery of any condition listed in Sections 10.1 and 10.2, the following information must be documented:

Identification of the condition triggering the need for corrective action review.

Description of the problem identified.

Date the problem was identified.

In cases where this condition is a failure to comply with any of the numeric effluent limitations in this permit, APG will call MDE’s Compliance Program within 24 hours and log the results into NetDMR within 5 days. The following information will be provided with those results as an attachment:

A description of the noncompliant discharge, including its impact on the receiving water.

The cause of the noncompliance.

The anticipated time the cause of the noncompliance is expected to continue, or, if the condition has been corrected, the duration of the period of the noncompliance.

Steps taken to eliminate the noncompliant discharge.

Steps planned or implemented to prevent the recurrence of the non-compliance.

A description of accelerated or additional monitoring to determine the nature and impact of the noncompliant discharge.

Within 14 days of discovery of any condition listed in Sections 10.1 and 10.2, the following information must be document:

Summary of corrective action taken or to be taken (or, for triggering events identified in Section 10.2 where it was determine a corrective action is not necessary, the basis for this determination).

Notice of whether SWP3 modifications are required as a result of this discovery or corrective action.

Date corrective action initiated.

Date corrective action completed or expected to be completed.

This documentation with be included in the annual report (Section 9.4, Comprehensive Site Compliance Evaluation). Corrective action reports will be maintained in Appendix K of this

SWP3.

11. REFERENCES

MDE. 2017. NPDES Discharge Permit No. MDG99, effective date 9 November 2017.

MDE. 2019a. COMAR. Title 9, Part 3, Water Pollution Control.

MDE. 2019b. COMAR. Title 26, Part 4, Subtitle 8, Water Pollution.

CFR. 2020a. Title 40 Part 122, EPA Administered Permit Programs: The National Pollutant Discharge Elimination System.

CFR. 2020b. Title 40 Part 123, State Program Requirements.

CFR. 2020c. Title 40 Part 124, Procedures for Decisionmaking.

CFR. 2020d. Title 40 Part 125, Criteria and Standards for the National Pollutant Discharge Elimination System.

CFR. 2020e. Title 40 Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants.

MELISSA A. TORRALBES

Biologist Water Resources Protection

REVIEWED:

KEVIN R. RUSSELL, P.E.

Branch Chief Water Resources Protection

APPROVED:

KENT B. PRINN, P.E.

Division Chief Environmental Health Engineering

TORRALBES.MELI

SSA.ANNE.106034

Digitally signed by

TORRALBES.MELISSA.ANNE.1

060343272 Date: 2020.06.17 09:24:42 -04'00'

RUSSELL.KEVIN.R

OBERT.125847469

Digitally signed by

RUSSELL.KEVIN.ROBERT.1258

474690 Date: 2020.06.17 10:30:19 -04'00'

PRINN.KENT.

B.1229341525

Digitally signed by

PRINN.KENT.B.1229341525

Date: 2020.06.17 17:11:42 -04'00'

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APPENDIX A

NPDES PERMIT NO. MDG99

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APPENDIX B

NOI AND CERTIFICATION

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APPENDIX C

ABERDEEN TEST CENTER (ATC) BOAT DOCK

ADDRESS: Building 631 SITE COORDINATOR: Sarah Kryston

PHONE: 410-278-4049

C-1. FACILITY DESCRIPTION

The ATC Boat Dock is located at the east end of Mulberry Point Road (39.446788°N, -76.100813°W) and encompasses approximately 2 acres. This facility serves as a marina, fueling point, and maintenance and light repair facility for Coast Guard and APG security vessels. Activities at this boat dock include fueling, surface preparation, pressure washing, engine repair, fiberglass repair, and other mechanical work. Maintenance activities are conducted in Building 627. Building 631 serves as an administrative building for the facility.

C-2. SITE MAP

A site map of the ATC Boat Dock is presented in Figure C-1. The surface of the site is primarily grassed with a couple buildings, paved access road, and gravel parking areas. Storm water flows south and southeast overland where it discharges directly into Spesutie Narrows (APG Watershed; 02130705). The site map includes the location of potential pollutant sources, receiving waters, and the direction of storm water flow.

C-3. POTENTIAL POLLUTANT SOURCES

Table C-1 describes the potential pollutant sources at the boat dock. The site activities, materials, and physical features possibly affecting storm water are identified in the table. For each potential pollutant source, a narrative assessment of its risk to storm water quality is included. Additionally, visual observations and pollutants of concern are addressed for all potential sources. Table C-1 will be updated as necessary to reflect any changes that occur at the facility.

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Table C-1. Potential Pollutant Sources Activity Potential Pollutant Source Pollutants of Concern Contamination

Potential Engine maintenance and repair

Fluid spills, fluid replacement, used oil filters, disposal of used POLs and coolants

Solvents, heavy metals, petroleum hydrocarbons, ethylene glycol, POLs

Low

Vessel maintenance Pressure washing – paint chips, petroleum residue

Surface preparation – mechanical grinding, scraping, paint stripping, petroleum residue

Painting – paint and paint thinner spills

Paint solids, solvents, heavy metals, petroleum hydrocarbons, sediment

Low

Bilge pump out Oil and fuel residue Fuel, oil, heavy metals, ethylene glycol

Medium

Materials handling Fueling – overfills, leaks

Liquid storage in AST – spills, overfills, leaks, external corrosion, piping system failure

Waste material storage and disposal

Fuel, POLs, heavy metals, petroleum hydrocarbons, ethylene glycol, solvents, paints

Low

Boat lift Residues on vessels, vehicles, and equipment

Fuel, POLs Low

Legend:

POLs = petroleum, oils, and lubricants AST = aboveground storage tank

C-3.1 Material Inventory

Table C-2 provides an inventory of the types of materials handled at the boat dock that have the potential to be exposed to storm water. Included in this inventory is a description of existing storm water management controls. Table C-2 will be updated as necessary to record any changes in material inventory at the facility.

Table C-2. Inventory of Materials

Material Quantity (container) Existing Storm Water Management Controls

JP8 (2) 500-gallon ASTs Tanks are surrounded by built-in secondary containment

Diesel (1) 10,000-gallon AST Tank is surrounded by built-in secondary containment

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Management Controls

Heating Oil (1) 275-gallon AST Tank is surrounded by built-in secondary containment

Used Oil (1) 500-gallon AST Tank is surrounded by built-in secondary containment

Paints, Coatings, Solvents Various <1-gallon containers Stored within flammable storage lockers located inside Building 627

POLs (9) 55-gallon drums and various <1-gallon containers

Stored inside the HAZMAT building that has built-in secondary containment in the form of a sunken floor

Cleaning Chemicals Various <1-gallon containers Stored within flammable storage lockers located inside Building 627

Legend:

JP = jet propellant AST = aboveground storage tank

HAZMAT = hazardous materials

C-3.2 Significant Spills and Leaks

Table C-3 presents significant spills and leaks of toxic or hazardous substances that have occurred at the boat dock in the past 3 years. Table C-3 will be updated as necessary to record all significant spills and leaks of toxic or hazardous pollutants that occur at the facility.

Table C-3. Significant Spill and Leaksa

Date (month/day/year)

DESCRIPTION RESPONSE PROCEDURES

Location Type of Material Quantity Amount

Recovered Material Still Exposed?

No spills or leaks occurred in the last 3 years.

N/A N/A N/A N/A N/A

Legend:

N/A = not applicable Note:

a Significant spills include, but are not limited to, releases of oil or hazardous substances in excess of reportable quantities.

C-3.3 Salt Storage

There are no salt piles at this facility. A small volume of salt is kept in a wheelbarrow and stored inside a small storage room in Building 631.

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C-3.4 Visual Monitoring Summary

The site has not historically had problems with materials contacting storm water runoff.

C-4 STORM WATER CONTROL MEASURES

Existing BMPs at the boat dock are defined for each of the storm water control measures outlined below and will continue to be implemented by facility personnel.

C-4.1 Minimize Exposure

There is minimal storage of materials and equipment outdoors. Loading and unloading of materials occurs at the hazardous materials (HAZMAT) building. Loading and unloading operations are limited during storm events. All materials are kept in the manufacturer’s sealed container until use. Materials are transferred using a forklift or hand carried from the HAZMAT building to Building 627 or to the pier in closed containers. Facility personnel inspect vessels, vehicles, and equipment for leaks and exposed contaminants prior to entering the boat lift area and minimize operations at the boat lift during storm events.

C-4.2 Good Housekeeping

All areas of the facility are maintained in a clean and orderly manner. Paved areas of the facility are regularly inspected and swept to prevent the accumulation of sediment. Liners and drip pans are used in work areas and the floors of Building 627 are swept, cleaned, and maintained to be kept free of residues. The boat lift area is inspected after every haul-out and launch for signs of spills and leaks. The entire facility is inspected regularly for miscellaneous trash and other materials. Garbage and recyclable materials are placed in appropriate covered receptacles, which are picked up regularly. See Table C-4 for a schedule of the good housekeeping activities implemented at the boat dock.

Table C-4. Schedule for Good Housekeeping Activities

Activity Task Frequency

Litter control Visually inspect facility and grounds for trash and debris. Dispose of materials in appropriate trash or recycling receptacles.

Weekly

Haul-out/launch Inspect the boat lift area after every haul-out and launch for signs of spills and leaks. After every operation

Waste disposal Inspect trash/recycling receptacles for waste materials that are improperly disposed of and for leaks.

Weekly

Pavement sweeping Visually inspect paved areas for sediment or materials tracking. Sweep these areas as needed. As needed

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C-4.3 Preventive Maintenance

Facility vessels, vehicles, equipment, and systems are inspected regularly and cleaned or repaired as necessary. Preventive maintenance of the boat lift is performed onsite. Preventive maintenance of facility equipment, such as forklifts, is performed offsite. Due to the types of equipment at this facility, vessel maintenance is performed outside or while the vessel is docked at the pier. Spill response supplies are maintained onsite inside and outside Building 627 and personnel are appropriately trained in spill response. Table C-5 outlines the schedule for preventive maintenance activities.

Table C-5. Schedule for Preventive Maintenance Activities

Inspection Frequency Maintenance Boat lift Monthly As needed Fork lift Monthly As needed

Fueling system Quarterly As needed

C-4.4 Maintenance Activities

Maintenance activities conducted at the facility include motor repair, painting (minimal), grinding, scraping (minimal), and pressure washing (minimal). All maintenance activities, except grinding, are performed outdoors within a containment area. The containment area is a large bermed rubber tarp that ensures no materials or wash waters escape into the nearby waterways. Wash water is pumped from the containment area and taken to an offsite industrial wastewater facility.

Grinding activities are conducted inside Building 627 on small parts only. The outdoor maintenance activities are conducted once per year and occur all together to ensure all materials are captured for waste turn in. Scraping activities are conducted using stainless steel shafts and rudders. Painting activities are conducted using brushes. Spray painting does not take place at this facility. No soaps or detergents are used in pressure washing operations.

C-4.5 Material Storage and Handling Areas

A HAZMAT building is located onsite and is the designated area for bulk storage of POLs. The building is equipped with built-in secondary containment in the form of a sunken floor. Bulk POL containers, primarily 55-gallon drums, may also be stored inside Building 627 on wooden pallets for use during maintenance operations.

Four fueling dispensers are located along the facility’s pier. Boats that are docked along the pier may dispense fuel from four stationary dispensers. All fueling areas are equipped with spill kits and all staff trained in spill response. Fueling instructions, emergency response phone numbers, and “Do Not Top Off” signs are posted at each fueling station.

C-7

C-4.6 Engine Maintenance and Repair Areas

Engine maintenance and repair are performed indoors at Building 627. The floors of Building 627 are not hosed down and dry cleanup methods are utilized.

C-4.7 Salt Storage

There are no salt piles at this facility. A small volume of salt is kept in a wheelbarrow and stored inside a small storage room in Building 631. The salt does not come into contact with storm water and is used sparingly.

C-4.8 Management of Runoff

Structural control measures for the management of storm water runoff are not in place at the facility; however, storm water pollution prevention is maintained by implementing all other control measures discussed in this SWP3. Maintenance activities are conducted in the containment area to ensure no materials or wash waters escape into surface waters.

C-4.9 Erosion and Sediment Control

The area surrounding the facility is primarily vegetated or paved with no evidence of erosion.

Erosion occasionally occurs along the sea wall during storms and higher than average tides, but is repaired when needed. Storm water at this site flows overland before discharging into Spesutie Narrows. There are no obvious signs of erosion caused by storm water at the facility.

C-4.10 Spill Prevention and Response Procedures

Facility personnel are formally trained in spill prevention and response procedures. Spill response equipment is kept onsite, located near areas where spills may occur or where easily accessible for rapid response. An emergency shut-off valve is located on the boat dock. APG’s site-specific Spill Prevention, Control, and Countermeasure Plan contains spill prevention and response information that will be implemented in the event of a spill.

Quarterly, facility personnel will inspect the condition of all containment structures to ensure no leaks or cracks are present. Facility personnel will also check that plugs are properly affixed and that any valve is in working condition and not leaking. In the event of a spill, regardless of size, source, or the cause, APG will notify MDE via their 24-hour Emergency Spill Response number at 866-633-4686.

C-4.11 Waste, Garbage, and Floatable Debris

Facility personnel will ensure waste, garbage, and floatable debris are not discharged to receiving waters by keeping exposed areas free of such materials or by intercepting them before they are discharged. Facility personnel will inspect the site weekly for trash and litter and properly dispose of such materials in the garbage and recycling containers located onsite.

C-8

C-4.12 Dust Generation and Vehicle Tracking of Industrial Materials

Facility personnel will minimize generation of dust and offsite tracking of raw, final, or waste materials. Access roads and parking areas are paved or gravel-covered, with relatively minimal potential for generating dust. If materials are found to be accumulating from vehicle tracking, sweeping will be conducted to mitigate it.

D-1

APPENDIX D

GUNPOWDER NECK MARINA

ADDRESS: Building E-2171 SITE COORDINATOR: Kevin Reich

PHONE: 410-278-4124

D-1 FACILITY DESCRIPTION

The Gunpowder Neck Marina is located at the east end of 20th Street (39.403641°N, -76.274632°W) and encompasses approximately 7.5 acres. This facility is a marina for privately owned boats and is operated by Army Family and Morale, Welfare, and Recreation (MWR). The facility has 108 slips and operates seasonally (closed November through March). Activities at this marina include fueling, surface preparation, and pressure washing. Engine repair and maintenance activities are not conducted at this facility. The marina has outdoor storage for 90 boats and inside storage for 70 boats at Buildings E-2168 and E-2170.

D-2 SITE MAP

Figure D-1 presents a site map of the Gunpowder Neck Marina. The surface of the site is primarily grassed with a few small buildings and a paved access road and parking lot. Storm water flows north overland where it discharges directly into Lauderick Creek (Bush River Watershed; 02130701). The site map includes the location of potential pollutant sources, receiving waters, and the direction of storm water flow.

D-3 POTENTIAL POLLUTANT SOURCES

Table D-1 describes the potential pollutant sources at the marina. The site activities, materials, and physical features possibly affecting storm water are identified in the table. For each potential pollutant source, a narrative assessment of its risk to storm water quality is included.

Additionally, visual observations and pollutants of concern are addressed for all potential sources. Table D-1 will be updated as necessary to reflect any changes that occur at the facility.

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D-3

Table D-1. Potential Pollutant Sources Activity Potential Pollutant Source Pollutants of

Concern Contamination

Potential Vessel maintenance Pressure washing – paint chips, petroleum residue

Surface preparation – mechanical grinding, scraping, paint stripping, petroleum residue

Painting – paint and paint thinner spills

Paint solids, solvents, heavy metals, petroleum hydrocarbons, sediment

Low

Materials handling Fueling – overfills, leaks

Liquid storage in UST – spills, overfills, leaks, external corrosion, piping system failure

Waste material storage and disposal

Fuel, POLs, heavy metals, petroleum hydrocarbons, ethylene glycol, solvents, paints

Low

Boat lift and ramp Residues on vessels, vehicles, and equipment

Fuel, POLs Low

Legend:

UST = underground storage tank

D-3.1 Material Inventory

Table D-2 provides an inventory of the types of materials handled at the marina that have the potential to be exposed to storm water. Included in this inventory is a description of existing storm water management controls. Table D-2 will be updated as necessary to record any changes in material inventory at the facility.

Table D-2. Inventory of Materials

Management Controls

Gasoline (1) 2,000-gallon UST Underground

Diesel Various small-quantity (5- to 10-gallon) containers

Located inside an enclosed shed next to the boat lift area

Gasoline (4) 5-gallon cans Located inside Building E-2171

Legend:

UST = underground storage tank

D-4

D-3.2 Significant Spills and Leaks

Table D-3 presents significant spills and leaks of toxic or hazardous substances that have occurred at the marina in the past 3 years. Table D-3 will be updated as necessary to record all significant spills and leaks of toxic or hazardous pollutants that occur at the facility.

Table D-3. Significant Spill and Leaksa

Date (month/day/year)

DESCRIPTION RESPONSE PROCEDURES

Location Type of Material Quantity Amount

Recovered Material Still Exposed?

No spills or leaks occurred in the last 3 years.

N/A N/A N/A N/A N/A

Legend:

N/A = not applicable Note:

a Significant spills include, but are not limited to, releases of oil or hazardous substances in excess of reportable quantities.

D-3.3 Salt Storage

Salt is not stored at this facility.

D-3.4 Visual Monitoring Summary

The site has not historically had problems with materials contacting storm water runoff.

D-4 STORM WATER CONTROL MEASURES

Existing BMPs at the marina are defined for each of the storm water control measures outlined below and will continue to be implemented by facility personnel.

D-4.1 Minimize Exposure

There is minimal storage of materials and equipment outdoors. Gas cans for the fueling of facility lawn mowers are kept inside Building E-2171. Small volume containers of diesel for the boat lift are kept inside a shed located next to the boat lift area. Power washers are also kept in this shed. All materials are kept in the manufacturer’s sealed container until use. Materials are hand carried in closed containers and loading/unloading operations are limited during storm events. Tools and power equipment for the maintenance of the facility are kept inside Building E-2171. Facility personnel inspect vessels, vehicles, and equipment for leaks and exposed contaminants prior to entering the boat lift area and minimize operations at the boat lift during storm events.

D-5

D-4.2 Good Housekeeping

All areas of the facility are maintained in a clean and orderly manner. Paved areas of the facility are regularly inspected and swept to prevent the accumulation of sediment. The launch ramp and boat lift areas are inspected after every haul-out and launch. The entire facility is inspected regularly for miscellaneous trash and other materials. Garbage and recyclable materials are place in appropriate covered receptacles and removed from the site regularly. See Table D-4 for a schedule of the good housekeeping activities implemented at the marina.

Table D-4. Schedule for Good Housekeeping Activities

Activity Task Frequency

Litter control Visually inspect facility and grounds for trash and debris. Dispose of materials in appropriate trash or recycling receptacles.

Weekly

Haul-out/launch Inspect the launch ramp and boat lift areas after every haul-out and launch. After every operation

Waste disposal Inspect trash/recycling receptacles for waste materials that are improperly disposed of and for leaks.

Weekly

Pavement sweeping Visually inspect paved areas for sediment or materials tracking. Sweep these areas as needed. As needed

D-4.3 Preventive Maintenance

Facility vehicles, equipment, and systems are inspected regularly and cleaned or repaired as necessary. Preventive maintenance to the boat lift is done by a private contractor onsite on level ground away from water. Forklift maintenance is performed inside Building E-2168 by a contractor. Spill response supplies are maintained onsite and personnel are appropriately trained in spill response. Table D-5 outlines the schedule for preventive maintenance activities.

Table D-5. Schedule for Preventive Maintenance Activities

Inspection Frequency Maintenance Boat lift Monthly As needed Fork lift Monthly As needed

Fueling system Quarterly As needed

D-4.4 Maintenance Activities

Maintenance activities conducted at the facility include boat bottom painting, grinding, scraping, sanding, and pressure washing and are performed outdoors. For painting, grinding, scraping, and sanding activities, rolls of felt fabric are deployed under each boat with a raised perimeter to catch paint chips and other solids. When dry, these paint chips/solids are deposited into a drum

D-6 located in a shed near the boat lift area and the fabric is disposed of in dumpsters located onsite. The fabric is regularly inspected for rips, tears, or holes and replaced as necessary. No washrack is located onsite, though patrons may scrub or pressure wash boats without soaps or detergents. Wash water from these activities are captured in a containment area and discharged to the sanitary sewer system.

D-4.5 Material Storage and Handling Areas

Fuel is delivered and offloaded to the UST by tanker truck. The piping from the UST to the dispenser is double-walled and is located under Pier A. A fuel dispenser for gasoline is located at the end of Pier A. Gas cans are not allowed for fueling boats. Gas cans are used on land for fueling equipment used in maintenance (e.g., boat lift, fork lift, lawn mowers). Fuel cans for equipment are unloaded from a truck by hand. Larger equipment is transferred by forklift, hand truck, or hand carried. The fueling area is equipped with a spill kit and all staff is trained in spill response. Patrons of the marina are not permitted to perform fueling operations themselves.

Trained personnel from MWR’s Fueling Committee perform fueling operations at the marina.

Fueling instructions and emergency response phone numbers are posted at the fueling area.

D-4.6 Engine Maintenance and Repair Areas

Engine maintenance and repair does not occur at the marina. Marina patrons take their boats elsewhere for such activities.

D-4.7 Salt Storage

There is no salt storage at this facility.

D-4.8 Management of Runoff

Pressure washing activities are conducted in a containment area to ensure no materials or wash waters escape into surface waters. Structural control measures for the management of storm water runoff are not in place at the Gunpowder Neck Marina; however, storm water pollution prevention is maintained by implementing all other control measures discussed in this SWP3.

D-4.9 Erosion and Sediment Control

The area surrounding the facility is primarily vegetated or paved. Storm water at this site flows overland before discharging into Lauderick Creek. There are no obvious signs of erosion caused by storm water at the facility.

D-4.10 Spill Prevention and Response Procedures

Facility personnel are formally trained in spill prevention and response procedures. Spill response equipment is kept onsite, located near areas where spills may occur or where easily accessible for rapid response. An emergency shut-off valve is located near Building E-2172 and

D-7 on Pier A. APG’s site-specific SPCC Plan contains spill prevention and response information that will be implemented in the event of a spill.

Quarterly, facility personnel will inspect the condition of all containment structures to ensure no leaks or cracks are present. Facility personnel will also check that plugs are properly affixed and that any valve is in working condition and not leaking. In the event of a spill, regardless of size, source, or the cause, APG will notify MDE via their 24-hour Emergency Spill Response number at 866-633-4686.

D-4.11 Waste, Garbage, and Floatable Debris

Facility personnel will ensure that waste, garbage, and floatable debris are not discharged to receiving waters by keeping exposed areas free of such materials or by intercepting them before they are discharged. Facility personnel will inspect the site weekly for trash and litter and properly dispose of such materials in the garbage and recycling containers provided.

D-4.12 Dust Generation and Vehicle Tracking of Industrial Materials

Facility personnel will minimize generation of dust and offsite tracking of raw, final, or waste materials. The parking areas are mostly gravel-covered, with relatively minimal potential for generating dust. Other travel areas are paved with asphalt. If materials are found to be accumulating from vehicle tracking, sweeping will be conducted to mitigate it.

E-1

APPENDIX E

NON-STORM WATER DISCHARGE CERTIFICATIONS

CERTIFICATION OF NON-STORM WATER DISCHARGES

Site: ATC Boat Dock Date: 10/24/2019

Evaluated Outfall: Entire Site

Method Used: Dry weather visual observation.

Description of Results: No non-storm water discharges were observed.

Authorized Non-Storm Water Discharges: None observed.

Unauthorized Non-Storm Water Discharges: None observed.

Assessment Performed By:

MELISSA A. TORRALBES

Biologist Water Resources Protection Branch U.S. Army Public Health Center

CERTIFICATION OF NON-STORM WATER DISCHARGES

Site: Gunpowder Neck Marina Date: 12/5/2019

Evaluated Outfall: Entire Site

Method Used: Dry weather visual observation.

Description of Results: No non-storm water discharges were observed.

Authorized Non-Storm Water Discharges: None observed.

Unauthorized Non-Storm Water Discharges: None observed.

Assessment Performed By:

MELISSA A. TORRALBES

Biologist Water Resources Protection Branch U.S. Army Public Health Center

F-1

APPENDIX F

INSPECTION AND MAINTENANCE RECORDS

G-1

APPENDIX G

TRAINING RECORDS

H-1

APPENDIX H

ROUTINE FACILITY INSPECTIONS

Routine Quarterly Facility Inspection Checklist

Industrial Site Name: Date:

Qualified Person:

SWPP TeamMember:

Discharging? Yes / No

BMP Adequate? Comments Good Housekeeping

Preventive Maintenance

SpillPrevention and Response

Routine Inspections

Sediment and Erosion Control

Structural Controls

OtherPollution Prevention

D…