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Environmental Health Engineering Study No. S.0073148-20, June 2020 Environmental Health Sciences and Engineering
Storm Water Pollution Prevention Plan Update, Aberdeen Proving Ground, Maryland, May 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, Storm Water Pollution Prevention Plan Update, Aberdeen Proving Ground, Maryland, May 2020 i
TABLE OF CONTENTS
Page
1. INTRODUCTION
1.1 Purpose
1.2 Installation Overview
1.3 Storm Water Drainage System
1.4 Industrial Activities
1.5 Permitted Outfalls
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 Routine Facility Inspections
9.2 Quarterly Visual Monitoring
9.3 Comprehensive Site Compliance Evaluation
9.4 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
ii
Page
11. CONSISTENCY WITH OTHER PLANS
12. REFERENCES
APPENDICES
A. NPDES PERMIT MDR0000 ........................................................................................ A-1 B. NOI AND CERTIFICATION ......................................................................................... B-1 C. NERF .......................................................................................................................... C-1 D. PYROTECHNIC FORMULATION ............................................................................... D-1 E. EXPLOSIVES FORMULATION ................................................................................... E-1 F. OBF OD UNIT ..............................................................................................................F-1 G. J-FIELD OD UNIT ....................................................................................................... G-1 H. HAZARDOUS WASTE TSDF ...................................................................................... H-1 I. PHILLIPS ARMY AIRFIELD .......................................................................................... I-1 J. WEIDE AASF ............................................................................................................... J-1 K. SALT STORAGE FACILITY ........................................................................................ K-1 L. VEHICLE MAINTENANCE FACILITY .......................................................................... L-1 M. VEHICLE MAINTENANCE FACILITY ......................................................................... M-1 N. VEHICLE MAINTENANCE FACILITY ......................................................................... N-1 O. NON-STORM WATER DISCHARGE CERTIFICATIONS ............................................ O-1 P. INSPECTION AND MAINTENANCE RECORDS ........................................................ P-1 Q. TRAINING RECORDS ................................................................................................ Q-1 R. ROUTINE FACILITY INSPECTIONS .......................................................................... R-1 S. QUARTERLY VISUAL MONITORING ......................................................................... S-1 T. COMPREHENSIVE SITE COMPLIANCE EVALUATIONS ...........................................T-1 U. CORRECTIVE ACTION REPORTS ............................................................................ U-1
FIGURES
1. Industrial Activities – Aberdeen Area
2. Industrial Activities – Edgewood Area
TABLES
1. Receiving Waters
2. Storm Water Industrial Activities
3. Permitted Outfalls
4. APG SWPPT
ENVIRONMENTAL HEALTH ENGINEERING STUDY NO. S.0073148-20
STORM WATER POLLUTION PREVENTION PLAN UPDATE
ABERDEEN PROVING GROUND, MARYLAND
MAY 2020
1. INTRODUCTION
1.1 Purpose
Federal regulations require storm water discharges from regulated industrial activities be permitted under the National Pollutant Discharge Elimination System (NPDES), or a state administered NPDES (40 Code of Federal Regulation (CFR) 122.26(b)(14)(i)-(xi)) ( U.S.
National Archives and Records Administration, 2020a). The Maryland Department of the Environment (MDE) State Discharge Permit No. 12-SW-A (NPDES Permit No. MDR0000) covers general discharges from storm water associated with industrial activities as defined by the permit (MDE, 2014). The 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) will allow Aberdeen Proving Ground (APG) to comply with MDE requirements. Appendix A provides a copy of the general permit. The letter authorizing coverage under the permit will be kept alongside a copy of the Notice of Intent (NOI) in Appendix B of this SWP3.
1.2 Installation Overview
APG, located within Harford County, Maryland, occupies more than 72,500 acres. The installation occupies two peninsulas separated by the Bush River and consists primarily of the Aberdeen Area (APG North) to the northeast and the Edgewood Area (APG South) to the southwest. The installation is bordered by U.S. Route 40 to the west, Swan Creek and the mouth of the Susquehanna River to the north, Chesapeake Bay to the east and southeast, and Gunpowder River to the south. Satellite properties include the Churchville Test Track, Van Bibber Water Treatment Plant, and Hanson Reservoir located within Harford County, Maryland, and Carroll Island and Graces Quarters located within Baltimore County, Maryland.
In operation since 1917, APG is a military installation involved in the research, development, and testing of weapons systems, ordnance, and biological and chemical defenses. Historically, operations at APG have included the production and testing of explosives and chemical munitions, Soldier training in the use and disposal of chemical agents, and the disposal of chemical agent-contaminated materials.
APG is home to more than 80 tenants and a host of satellite and private activities. APG provides general, administrative, and logistical support to the installation’s tenants and satellite activities and is responsible for the management and operation of the entire installation. Among the major tenants are—
U.S. Army 20th Chemical, Biological, Radiological, Nuclear, and Explosives (CBRNE) Command;
U.S. Army Evaluation Center; U.S. Army Research Laboratory (ARL);
U.S. Army Communications and Electronics Command;
U.S. Army Civilian Human Resource Agency, Northeast Region;
U.S. Army Combat Capabilities Development Command, Chemical Biological Center
(CCDC CBC);
Kirk U.S. Army Health Clinic;
U.S. Army Medical Research Institute of Chemical Defense;
U.S. Army Public Health Center;
Program Executive Office Intelligence Electronic Warfare and Sensors;
U.S. Army Contracting Command, APG;
U.S. Army Materials Systems Analysis Activity;
U.S. Army Test and Evaluation Command;
U.S. Army Communications-Electronics Research, Development, and Engineering
Center;
Mid-Atlantic Region Network Enterprise Center;
Joint Program Executive Office for Chemical and Biological Defense;
Maryland Army National Guard (MDARNG);
Program Executive Office Command, Control, and Communications-Tactical; and U.S. Research, Development, and Engineering Command.
1.3 Storm Water Drainage System
Storm water runoff from APG originates primarily from the highly developed cantonment area of APG North and the lesser developed area of APG South. These developed areas are served by a series of storm water drainage systems. The storm water drainage systems discharge into intermittent and/or perennial stream channels, which ultimately lead to the Bush River, Gunpowder River, and Chesapeake Bay. Storm water in undeveloped portions of the installation follows natural surface drainage patterns and discharges to the same stream channels as noted above.
Water bodies impacted by storm water from industrial activities at APG are listed in Table 1, along with their associated watershed, impairments, and approved total maximum daily loads (TMDL) as identified by MDE pursuant to paragraph 303(d) of the Clean Water Act (U.S.
National Archives and Records Administration, 1972).
Table 1. Receiving Waters Watershed
(8-Digit Identifier) Impairment Approved TMDL
Bush River (02130701)
4a – Nutrients 4c – Channelization 4c – Lack of Riparian Buffer 5 –PCBs 5 – Sediment 5 – Chlorides 5 – Sulfates
Approved TMDL for nutrients
Gunpowder River (02130801)
4a – Nutrients 4a – Sediment 5 – PCBs
Approved TMDL for nutrients and sediment
Aberdeen Proving Ground (02130705)
4a – Nutrients 4c – Channelization 5 – Phosphorus 5 – Toxics
Approved TMDL for nutrients
Swan Creek (02130706) 4a – Nutrients Approved TMDL
Legend:
TMDL = total maximum daily loads PCBs = polychlorinated biphenyls
1.4 Industrial Activities
Industrial activities at APG fall into the following Standard Industrial Classification (SIC) Codes and Sectors as defined in 40 CFR 122.26(b)(14) (U.S. National Archives and Records Administration, 2020a) and are listed in Table 2. See Figure 1 and Figure 2 for the general locations of the following industrial activities within APG.
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Figure 1. Industrial Activities – Aberdeen Area
Figure 2. Industrial Activities – Edgewood Area
1.5 Permitted Outfalls
APG’s individual NPDES Permit No. MD0003565 authorizes the discharge of non-storm water discharges commingled with storm water from five permitted outfalls (MDE, 2017). Storm water discharges from these outfalls must also be included in the SWP3. See Table 3 for an overview of these outfalls.
Table 3. Permitted Outfalls
Outfall Number Location Surface Water Authorized Discharge
005 Churchville Test Track Deer Creek Vehicle Washwater
006 H-Field Gunpowder River Vehicle Washwater
012 Research and Development Facilities Dipper Creek Noncontact Cooling Water
013 Building 423 Woodrest Creek Noncontact Cooling Water
014 UNDEX Facility Bush River Water Containing Products of Explosives Detonations
Legend:
UNDEX = Underwater Explosives
1.5.1 Outfall 005
Permitted Outfall 005 is located at the Churchville Test Track in Churchville, Maryland and encompasses the permitted site Building 10301. Storm water from the test track and fueling area drains towards the northern end of the facility where it is diverted into a series of catch basins that empty into a sedimentation pond before discharging into Deer Creek. Storm water from the maintenance building area and the vehicle washrack flows east into a sedimentation pond and passes through an oil/water separator (OWS) before discharging to a sedimentation pond and finally into Deer Creek.
1.5.2 Outfall 006
Permitted Outfall 006 is located in the APG South and encompasses the permitted site Building E-1464 (also known as H-Field). Storm water from the fueling area and hazardous materials storage building drains west to the vehicle washrack. The vehicle washrack (not in use) discharges to an OWS before emptying into a sedimentation pond and finally discharging to the Gunpowder River. Storm water from the maintenance building, materials storage building, and parking area drains to the north where it is collected in a drainage ditch and is channeled to the western edge of the site.
1.5.3 Outfall 012
Permitted Outfall 012 is located in APG North. Storm water from this area drains primarily from residential and office buildings. The majority of this drainage area is composed of developed and paved surfaces. Noncontact cooling water from adjacent research and development buildings is discharged through this outfall.
1.5.4 Outfall 013
Permitted Outfall 013 is located in APG North. Storm water from this area drains primarily from undeveloped and gravel roadways. The facility adjacent to the outfall (Building 423) discharges cooling water from test equipment through this outfall. Recent renovations to the facility and conversion of the equipment to air-cooled systems have decreased the overall volume of discharge received by this outfall.
1.5.5 Outfall 014
Permitted Outfall 014 is located in APG North at the Underwater Explosives (UNDEX) facility.
This area utilizes large quantities of water for the purpose of munitions testing. Tests are conducted inside a manmade reservoir. Depending upon the testing being conducted at the facility, water may be added or drained from the facility. If it is necessary to drain water from the site, discharge must pass through a series of four settlement ponds before finally discharging into the Bush River.
2 SWP3 FORMAT
This document contains an installation-wide SWP3 and 12 activity-specific plans in Appendices C–N. Each industrial activity will receive and implement the SWP3. At each site, materials and pollutants of concern are identified, along with existing BMPs. The SWP3 will be amended whenever there is a change in design, construction, operation, or maintenance that has a significant effect on the installation’s pollution potential, or if the SWP3 proves ineffective in controlling pollutants in storm water discharges from industrial activities.
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 4 provides the responsibilities of the SWPPT leader and members.
Table 4. APG 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.
Responsible for NetDMR access in accordance with the General Permit No. 12-SW-A.
SWPPT Members Teresa Bartley Water Program Team Environmental Compliance Branch DPW Environmental Division 410-417-0690
Karen Jobes and Maia Kaiser Water Program Team Environmental Compliance Branch DPW Environmental Division 410-436-4429/410-306-2199
Attend SWP3 meetings and assist the SWPPT Leader as necessary.
Coordinate quarterly inspections and visual assessments.
Coordinate annual inspections and certifications of non-storm water discharges.
Coordinate updates to the SWP3 as needed.
Maintain all records.
Update the SWP3 to reflect reported spills.
Track annual storm water management training for all industrial activity personnel.
NERF and Explosives Formulation James Lariviere 410-278-9017
Pyrotechnic Formulation Bruce Steltzer 410-436-6581
OBF OD Unit and Phillips Army Airfield Sarah Kryston 410-278-4049
J-Field OD Unit Lloyd Wallace 410-436-9259
Hazardous Waste TSDF Christy Hornyak 410-436-2754
Weide AASF CSM Gregory Kecken 410-436-9317
Monitor compliance with scheduled activities in
SWP3.
Provide technical assistance and guidance to SWPPT Leader as necessary.
Member Responsibilities
Salt Storage Facility Frankie Thompson 410-436-2066
LRC Vehicle Maintenance Facilities Richard McDonald 410-306-3633 Legend:
APG SWPPT = Aberdeen Proving Ground Storm Water Pollution Prevention Team DPW = Directorate of Public Works SWP3 = storm water pollution prevention plan OBF = Old Bombing Field OD = Open Detonation TSDF = Treatment, Storage, or Disposal Facilities AASF = Army Aviation Support Facility LRC = Logistics Readiness Center
4 SITE MAP
Storm water site maps for each industrial activity are included in Appendices C–N. 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 industrial sites on APG. The potential pollutant sources for each of the industrial activities are described in Appendices C–N. 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–N for each industrial activity. 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 industrial activities in the past 3 years are presented in Appendices C–N. 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 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, 2014) include:
Water used to fight active fires (not from fire system cleaning or testing);
Pavement 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;
Uncontaminated condensate from air conditioners, coolers, and other compressors and from the outside storage of refrigerated gases or liquids;
Irrigation drainage;
Uncontaminated groundwater or spring water;
Foundation or footing drains where flows are not contaminated with process materials;
and, 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).
All storm water conveyance systems at the industrial sites 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 O.
5.4 Salt Storage
There is one salt storage facility with a point source discharge located on APG, which is discussed in detail in Appendix K.
5.5 Visual Monitoring Summary
Appendices C-N present summaries of visual monitoring conducted under the permit
(MDE, 2014).
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, 2014). 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–N identifies the existing BMPs at APG industrial activities 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, 2014):
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–N identifies schedules for the inspection and maintenance of existing control measures at each industrial facility. Documentation of inspection, maintenance, and repairs of control measures will be maintained in Appendix P. 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
Training is required for all employees who work in areas where industrial materials or activities are exposed to storm water, or who are responsible for implementing the BMPs necessary to meet the conditions of the permit, including all members of the SWPPT. Training will be conducted annually, at a minimum, and cover the specific control measures and monitoring, inspection, planning, reporting, and documentation requirements of the permit. 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, Used container controls, etc.
Training records will be maintained in Appendix Q.
9 MONITORING, INSPECTIONS, AND REPORTING
9.1 Routine Facility Inspections
Once per quarter, a site assessment will be conducted at each industrial facility to review the effectiveness of the SWP3. Inspections will be conducted at all areas of a site where industrial materials or activities are exposed or have the potential to be exposed to storm water.
Inspections will also include storm water control measures used to comply with permit conditions. 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 R, where a copy of the form has been provided.
9.2 Quarterly Visual Monitoring
Once per quarter, visual monitoring of storm water discharges will be conducted at each industrial facility. 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 S. 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 (U.S. National Archives and Records Administration, 2020b). 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 S.
9.3 Comprehensive Site Compliance Evaluation
Comprehensive site compliance evaluations will be performed annually at each industrial facility. 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 T, where a copy of the report form has been provided.
9.4 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 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 the permit; or APG finds in the routine facility inspection, quarterly visual monitoring, or comprehensive site compliance inspection 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, 2014).
10.3 Corrective Action Deadlines
APG will document discoveries of any of the conditions listed in paragraphs 10.1 or 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 paragraphs 10.1 or 10.2, the following information must be documented:
Identification of the condition triggering the need for corrective action review;
Description of the problem identified; and Date the problem was identified.
Within 14 days of discovery of any condition listed in paragraphs 10.1 or 10.2, the following information must be documented:
Summary of corrective action taken or to be taken (or, for triggering events identified in paragraph 10.2 where it was determined 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; and Date corrective action completed or expected to be completed.
This documentation will be included in the annual comprehensive report. Corrective action reports will be maintained in Appendix U of this SWP3.
11. CONSISTENCY WITH OTHER PLANS
This SWP3 and Appendices C–N have incorporated relevant information and requirements from the Spill Prevention, Control, and Countermeasure (SPCC) Plan by reference. The SPCC Plan is kept alongside this SWP3 in the DPW Environmental Office.
12. REFERENCES
MDE. 2014. NPDES Discharge Permit No. MDR0000, effective date 1 January 2014.
MDE. 2017. NPDES Discharge Permit No. MD0003565, effective date 1 January 2017.
U.S. Army Environmental Hygiene Agency. 1992. NPDES Sampling Protocol for Storm Water Permit Application, Water Quality Information Paper No. 37, April 1992.
U.S. Environmental Protection Agency. 1992. NPDES Storm Water Program Question and Answer Document, Volume 1, March 1992.
U.S. Environmental Protection Agency. 1993. NPDES Storm Water Program Question and Answer Document, Volume 2, September 1993.
U.S. National Archives and Records Administration. 1972. Public Law 92-500, Clean Water Act.
U.S. National Archives and Records Administration. 2020a. Code of Federal Regulations. Title 40 CFR Part 122.26 Storm water discharges (applicable to State NPDES programs, see §123.25).
U.S. National Archives and Records Administration. 2020b. Code of Federal Regulations. 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 15:56:02 -04'00'
RUSSELL.KEVIN.R
OBERT.125847469
Digitally signed by
RUSSELL.KEVIN.ROBERT.1258
474690 Date: 2020.06.17 16:06:24 -04'00'
PRINN.KENT.
B.1229341525
Digitally signed by
PRINN.KENT.B.1229341525
Date: 2020.06.17 16:17:07 -04'00'
A-1
APPENDIX A
NPDES PERMIT MDR0000
B-1
APPENDIX B
NOI AND CERTIFICATION
C-1
APPENDIX C
NOVEL ENERGETIC RESEARCH FACILITY (NERF)
LOCATION: Building 1171 SITE COORDINATOR: James Lariviere
PHONE: 410-278-9017
C-1. INDUSTRIAL ACTIVITY DESCRIPTION
ARL operates NERF at Building 1171. NERF is an Energetic Materials Development Facility for experimental energetics (explosives, propellants, and pyrotechnics) formulation, processing, and manufacturing. Material handling and storage is conducted at this facility. All operations at this facility are conducted indoors. Experimental design is performed in Building 1171 and facility equipment is kept inside Building 1176. Hazardous materials are stored inside 7 storage buildings located in front of Building 1171. There are 6 explosives magazines located at the facility. Two of these magazines are protected by large bags of soil. Floor drains inside Building 1171 have been sealed. Bays inside Building 1171 are occasionally washed down and the wash water collected in the facility’s holding tank.
C-2. SITE MAP
The area surrounding the facility is primarily vegetated with paved access roads. Storm water from the facility discharges into a storm water detention basin via overland flow (Outfall 001). A site map of the area is presented in Figure C-1.
C-3. POTENTIAL POLLUTANT SOURCES
Table C-1 describes the potential pollutant sources at the site and their potential to pollute storm water discharges. 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 site.
Table C-1. Potential Pollutant Sources
Potential Pollutant Source
Pollutants of Concern Visual Observations Contamination
Potential
Materials Handling and
Storage
Hazardous materials and explosives
All hazardous materials are located in chemical lockers or explosives magazines with built-in secondary containment. Loading and unloading operations are performed outdoors. Materials are transferred from the storage units to the laboratory in closed containers and according to the safety requirements of each material.
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C-3
C-3.1 Material Inventory
Table C-2 provides an inventory of the types of materials handled at the site that may contact storm water. Included in this inventory is a description of existing storm water management controls. The table will be updated as necessary to record any changes in the material inventory.
Table C-2. Inventory of Materials
Material Quantity (container)
Existing Storm Water Management Controls
Explosives Various Stored in explosives magazines with built-in secondary containment.
Hazardous Materials Various Stored inside structures with built-in secondary containment.
C-3.2 Significant Spills and Leaks
Significant spills and leaks of toxic or hazardous substances that have occurred at the site in the past 3 years are presented in Table C-3. The table will be updated as necessary to record all significant spills and leaks of toxic or hazardous pollutants that occur.
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 at the site 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 Visual Monitoring Summary
The facility has not historically had problems with materials contacting storm water runoff. In recent years, the large bags of soil protecting two of the explosives magazines have deteriorated and soil has spilled out; however, there has been no evidence of sediment tracking from the immediate area.
C-4
C-4. STORM WATER CONTROL MEASURES
Existing BMPs at the site are identified in Table C-4 and will be implemented by site personnel.
Table C-4. Existing BMPs
Existing BMPs Description
MINIMIZE EXPOSURE
Materials undercover Materials are stored undercover in hazardous materials storage sheds or explosives magazines that have built-in secondary containment.
Security at critical points Security measures are in place at the facility to help prevent an accidental or intentional release of materials to storm water.
Access to the site is remote and restricted.
GOOD HOUSEKEEPING
General good housekeeping All work and storage areas are kept neat and orderly.
PREVENTIVE MAINTENANCE
Preventive maintenance program Facility vehicles and equipment are regularly inspected for leaks. Maintenance is conducted offsite.
SPILL PREVENTION AND RESPONSE
SPCC Plan The installation SPCC Plan contains spill prevention and response information.
Spill response equipment Spill kits and absorbent materials are kept onsite at various locations.
Employee training Personnel have been formally trained in spill prevention and response procedures.
EROSION AND SEDIMENT CONTROLS
Paved Access roads at the facility are paved.
Vegetated areas Grassy areas at the facility are well vegetated.
MANAGEMENT OF RUNOFF
Storm water controls Storm water from the site discharges to a storm water detention basin.
SALT STORAGE PILES
N/A Salt is not kept onsite.
C-5
WASTE, GARBAGE, AND FLOATABLE DEBRIS
Covered trash receptacles Trash and recycling receptacles are located onsite and are kept closed.
DUST GENERATION AND VEHICLE TRACKING OF INDUSTRIAL MATERIALS
Paved Access roads at the facility are paved.
Legend:
BMPs = best management practices SPCC = Spill Prevention, Control, and Countermeasure N/A = not applicable
C-5. SCHEDULE
Table C-5 provides a schedule for the inspection and maintenance of the existing control measures at the site. This table will be updated as necessary to address any changes in BMPs.
Table C-5. Schedule for Inspection and Maintenance of Control Measures
Task Frequency Visually inspect facility and grounds for trash and debris. Dispose of materials in appropriate receptacles.
Weekly
Inspect hazardous and explosives material storage for leaks and overall condition. Monthly
Sweep the facility’s access areas to minimize dust and offsite tracking of materials. As Needed
Inspect and perform preventive maintenance on facility equipment.
Inspect Monthly/ Maintenance As Needed
Inspect and perform preventive maintenance on the storm water basin.
Inspect Quarterly/ Maintenance As Needed
D-1
APPENDIX D
PYROTECHNIC FORMULATION
LOCATION: Building E-3580 SITE COORDINATOR: Bruce Steltzer
PHONE: 410-436-6581
D-1. INDUSTRIAL ACTIVITY DESCRIPTION
CCDC CBC performs experimental pyrotechnic testing as well as design and fabrication at Building E-3580. Materials handling and storage are conducted at this site. All materials are stored within storage sheds with built-in secondary containment. Buildings E-3581 and E-3582 are 90-day hazardous waste satellite accumulation sites (SAS). Buildings E-3583, E-3584, and E-3585 are utilized for the storage of various energetic materials and munitions. Solvents are stored in Building E-3587. Chemical components of explosives (oxidizers, inerts, solid fuels, organics, metals, powders) are stored in Buildings E-3588 and E-3589. Various materials, including hexachloroethane, dyes, and oils can be found in Building E-3580 as part of everyday operations. Flammable cabinets are also located throughout Building E-3580 and contain various materials, including spray paint cans.
Materials are transferred from their designated storage areas to Building E-3580 in small quantities and as appropriate for safety standards. All loading areas are paved and sloped away from the buildings. A canopy surrounds the outside of Building E-3580, including the loading area. Spill response equipment is located outside, at the west end of Building E-3580 under the canopy. A trough-style drain is located along the exterior perimeter of Building E-3580. The drain captures washwater from the cleaning of work areas and testing cubicles and drains to two 250-gallon polypropylene aboveground storage tanks (ASTs). These tanks are located within a concrete berm. Both the tanks and the trough drain are located outside under the canopy. When the tanks are full, the facility adjusts the pH of the washwater and obtains approval before discharging to the sanitary sewer system.
Maintenance of facility vehicles is performed offsite. Maintenance of facility equipment is performed onsite and indoors. When not in use, facility vehicles and equipment are kept inside a storage shed behind Building E-3580 or under the canopy.
D-2. SITE MAP
The facility is primarily grass. Storm water from the hazardous and explosive material storage areas permeates into the ground. Storm water from the front of Building E-3580 flows north towards a grated trench drain at the entrance to the facility and discharges via Outfall 003. A site map of the area is presented in Figure D-1.
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D-3
D-3. POTENTIAL POLLUTANT SOURCES
Table D-1 describes the potential pollutant sources at the site and their potential to pollute storm water discharges. 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
Table D-1. Potential Pollutant Sources
Potential Pollutant Source
Pollutants of Concern Visual Observations Contamination
Potential
Materials Handling and Storage
Energetics materials and munitions, fuel solids, solvents, oxidizers, hexachloroethane, POLs, dyes, spray paint
All materials are stored indoors and have secondary containment.
The loading area for Building E-3580 is covered. All loading areas are paved and slope away from the buildings.
Low
Liquid Storage in ASTs Washwater
The polypropylene tanks are located outside within a concrete berm and under a canopy.
Low
Legend:
POLs = petroleum, oil, and lubricants AST = aboveground storage tanks
D-3.1 Material Inventory
Table D-2 provides an inventory of the types of materials handled at the site that may contact storm water. Included in this inventory is a description of existing storm water management
Table D-2. Inventory of Materials
(container)
Existing Storm Water Management Controls
Energetic Materials and Munitions Various Stored on pallets behind security caging inside
Buildings E-3583, E-3584, and E-3585.
Washwater (2) 250-gallon polypropylene AST
Stored under the canopy outside Building E-3580, within secondary containment.
Fuels 5-gallon cans Stored inside Building E-3587, which has built-in secondary containment.
Solvents Various Stored inside Building E-3587, which has built-in secondary containment.
D-4
(container)
Existing Storm Water Management Controls
Oxidizers Various Stored inside Building E-3588, which has built-in secondary containment.
POLs 55-gallon drums Stored inside Building E-3587, which has built-in secondary containment.
Hazardous Waste Various Stored inside Buildings E-3581 and E-3582, which have built-in secondary containment.
Legend:
D-3.2 Significant Spills and Leaks past 3 years are presented in Table D-3. The table will be updated as necessary to record all
Table D-3. Significant Spill and Leaksa
(month/day/year)
DESCRIPTION RESPONSE PROCEDURES
Location Type of Material Quantity Amount Recovered
Material Still Exposed?
No spills or leaks occurred at the site 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
D-3.3 Visual Monitoring Summary
In the past, facility personnel have noted water inside Building E-3581. It is believed that the roof is not functioning properly. A work order is in place to have the roof repaired. The facility is primarily grass and does not show signs of erosion.
D-5
D-4. STORM WATER CONTROL MEASURES
Existing BMPs at the site are identified in Table D-4 and will be implemented by site personnel.
Table D-4. Existing BMPs
MINIMIZE EXPOSURE
Materials under cover Materials are stored indoors, in appropriate containers and storage areas.
Security at critical points Security measures are in place at the facility to help prevent an accidental or intentional release of materials to storm water. Access to the site is restricted.
GOOD HOUSEKEEPING
General good housekeeping Work and testing areas are maintained in a clean and orderly manner.
The facility floor is washed after each testing operation.
PREVENTIVE MAINTENANCE
Preventive maintenance program
Scheduled maintenance of facility vehicles are performed offsite.
Scheduled maintenance of facility equipment is performed onsite and indoors. Facility vehicles/equipment is inspected regularly for leaks.
SPILL PREVENTION AND RESPONSE
SPCC Plan The installation SPCC Plan contains spill prevention and response information.
Spill response equipment Spill kits and absorbent materials are kept onsite at various locations.
Employee training Personnel have been formally trained in spill prevention and response procedures.
EROSION AND SEDIMENT CONTROLS
Vegetation The area surrounding the facility is primarily grass, with no evidence of erosion.
MANAGEMENT OF RUNOFF
Storm water controls Storm water is diverted to swales (via overland flow and/or trench drain) at which point it infiltrates the ground.
N/A Salt is not stored at the facility.
D-6
WASTE, GARBAGE, AND FLOATABLE DEBRIS
Covered trash receptacles Trash and recycling receptacles are located onsite and are kept closed.
DUST GENERATION AND VEHICLE TRACKING OF INDUSTRIAL MATERIALS
Paved Access roads to the facility and parking area are paved.
Legend:
BMPs = best management practices
D-5. SCHEDULE
Table D-5 provides a schedule for the inspection and maintenance of the existing control
Table D-5. Schedule for Inspection and Maintenance of Control Measures
Visually inspect facility and grounds for trash and debris. Dispose of materials in appropriate receptacles. Weekly
Inspect material storage tanks and buildings for leaks and overall condition. Monthly
Sweep the facility’s access areas to minimize dust and offsite tracking of materials. As Needed
Inspect and perform preventive maintenance on facility equipment.
Inspect Monthly/
E-1
APPENDIX E
EXPLOSIVES FORMULATION
LOCATION: 1119B, 1124 SITE COORDINATOR: James Lariviere
PHONE: 410-278-9017
E-1. INDUSTRIAL ACTIVITY DESCRIPTION
ARL formulates explosive prototypes for experimental purposes at Buildings 1119B and 1124.
Material handling and storage is conducted at this facility. All operations at this facility are performed indoors. Explosives are stored offsite when not in use. Only quantities needed for a day’s use are transferred to the facility (up to 2 grams). Occasionally, explosives are authorized to be stored overnight in two magazines located inside Building 1124. High security, lockdown systems are in place. Small quantities of materials are hand carried in closed containers.
Loading and unloading operations are conducted indoors or on the loading dock using a forklift.
The forklift is kept indoors and maintenance is conducted offsite. Building 1124 has four flammable cabinets and a Hazardous Waste SAS. Building 1119B has three flammable cabinets, hazardous materials storage closet and two labs that contain flammable cabinets and explosives and acid lockers.
E-2. SITE MAP
The facility is primarily paved. The area surrounding the facility is primarily grass. Storm water sheet flows to a grassy area and ponds (Outfall 004). Figure E-1 presents a site map of the area.
E-3. POTENTIAL POLLUTANT SOURCES
Table E-1 describes the potential pollutant sources at the site and their potential to pollute storm water discharges. 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 E-1 will be updated as necessary to
Table E-1. Potential Pollutant Sources
Potential Pollutant Source Pollutants of Concern Visual Observations Contamination
Potential
Materials Handling and Storage
Explosives, acids, organic solvents, reagents, oxidizers, aerosols
All materials are stored indoors.
Loading and unloading operations are conducted indoors.
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E-3
E-3.1 Material Inventory
Table E-2 provides an inventory of the types of materials handled at the site that may contact storm water. Included in this inventory is a description of existing storm water management
Table E-2. Inventory of Materials
(container)
Existing Storm Water Management Controls
Explosives Various Stored indoors inside an explosives magazine with extra security measures in place.
Acids Various -…
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