Attachment 5(n) - APG MS4 SWMP Final.pdf
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DEPARTMENT OF THE ARMY
US ARMY PUBLIC HEALTH CENTER
BUILDING 5158
8252 BLACKHAWK ROAD
ABERDEEN PROVING GROUND MARYLAND 21010-5403
MCHB-PH-WTR
MEMORANDUM FOR Aberdeen Proving Ground, Directorate of Public Works (IMAP-PWE/Mr. Richard Wiggins), 8356 Brigade Street, Building E-4630, Aberdeen Proving Ground, MD 21010
SUBJECT: Environmental Health Engineering Study No. S.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020
1. Subject document is enclosed.
2. The U.S. Army Public Health Center (APHC) strives to provide high quality products and services in a timely manner. We would appreciate a few moments of your time to tell us how we did. Please visit the following link:
https://usaphcapps.amedd.army.mil/Survey/se.ashx?s=25113745052C38DC. To help ensure we evaluate the proper project:
a. For Question 1 “Directorate/Division” please indicate:
(1) Directorate: Environmental Health Sciences and Engineering
(2) Division: Environmental Health Engineering
b. For Question 2 “Type of product or service received,” please indicate:
Technical or Surveillance Report
3. The point of contact for this plan is Ms. Melissa Torralbes, APHC, at 410-436-3897, DSN 584-3897, or melissa.a.torralbes.civ@mail.mil.
FOR THE DIRECTOR:
Encl ALICK E. SMITH
COL, MS
Director, Environmental Health Sciences and Engineering https://usaphcapps.amedd.army.mil/Survey/se.ashx?s=25113745052C38DC i
Environmental Health Engineering Study No. S.0073145-20, June 2020 Environmental Health Sciences and Engineering
Small Municipal Separate Storm Sewer System Storm Water Management 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.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020 i
TABLE OF CONTENTS
Page
1. INTRODUCTION
1.1 Purpose
1.2 Installation Overview
2. REFERENCES
3. MCMS AND BMPS
3.1 Public Education and Outreach
3.2 Public Participation and Involvement
3.3 IDDE
3.4 Construction Site Storm Water Runoff Control
3.5 Post Construction Storm Water Management
3.6 Pollution Prevention and Good Housekeeping
4. CHESAPEAKE BAY RESTORATION AND MEETING TOTAL MAXIMUM
DAILY LOADS
5. REPORTING
6. RECORDKEEPING
APPENDICES
A REFERENCES ............................................................................................................ A-1 B NPDES PERMIT MDR055501 .................................................................................... B-1 C NOI AND CERTIFICATION ......................................................................................... C-1 D GOOD HOUSEKEEPING PLAN.................................................................................. D-1 E GOOD HOUSEKEEPING INSPECTIONS ................................................................... E-1 F SPILL LOGS ................................................................................................................F-1 G MS4 PROGRESS REPORTS ..................................................................................... G-1
Use of trademarked name(s) does not imply endorsement by the U.S. Army but is intended only to assist in identification of a specific product.
ENVIRONMENTAL HEALTH ENGINEERING STUDY NO. S.0073145-20
SMALL MUNICIPAL SEPARATE STORM SEWER SYSTEM
STORM WATER MANAGEMENT PLAN UPDATE
ABERDEEN PROVING GROUND, MARYLAND
MAY 2020
1. INTRODUCTION
1.1 Purpose
Federal regulations require storm water discharges from small municipal separate storm sewer systems (MS4s) as defined under Title 40 of the Code of Federal Regulations (CFR) 122.26(b)(16)(iii) be permitted under the National Pollutant Discharge Elimination System (NPDES), or a state administered NPDES (40 CFR 122.26(b)(14)(i)-(xi))( U.S. National Archives and Records Administration, 2020). The Maryland Department of the Environment (MDE) General Discharge Permit No. 13-SF-5501 (NPDES Permit No. MDR055501) (MDE, 2018) covers storm water discharges from eligible small MS4s including those properties that—
Are owned or operated by the State of Maryland or the United States and located within an urbanized area; and
Serve developed land area greater than 5 acres and have at least 10% impervious area property wide; or
Are already covered under an NPDES small MS4 Phase II general permit.
The permit requires the implementation of six minimum control measures (MCMs) by all entities covered by a general permit. These six measures are—
Public Education and Outreach, Public Involvement and Participation, Illicit Discharge Detection and Elimination (IDDE), Construction Site Runoff Control, Post-Construction Management, and
Pollution Prevention and Good Housekeeping.
In addition to the six MCMs, the permit establishes requirements for impervious area restoration for 20% of existing developed lands that have little or no storm water management. This Storm Water Management Plan (SWMP) contains best management practices (BMPs), measurable goals, schedules of implementation, and other information required by the permit.
Implementation of this SWMP and BMPs allows Aberdeen Proving Ground (APG) to comply with MDE requirements. A copy of the general permit is located in Appendix B. The letter authorizing coverage under the permit is kept alongside a copy of the Notice of Intent (NOI) in Appendix C of this SWMP.
1.2 Installation Overview
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.
APG occupies 72,283 acres and is located on the western shore of the northern Chesapeake Bay. The installation lies approximately 20 miles northeast of the city of Baltimore. The installation is geographically divided into two areas, separated by the Bush River. The Edgewood Area is to the west of the river, and the Aberdeen Area lies to the east. The Edgewood Area consists of the Edgewood peninsula, Pooles Island, Graces Quarters, and Carroll Island. The Aberdeen Area consists of the Aberdeen peninsula and Spesutie Island.
APG also includes several smaller noncontiguous properties: Churchville Test Area, Atkisson Dam and Reservoir, Van Bibber Water Treatment Plant and Hanson Reservoir, and Eastern Shore Towers. All of APG lands lie in Harford County, except for Carroll Island and Graces Quarters which lie in Baltimore County, and the Eastern Shore Towers, which are located in Kent County. Nearly half of APG’s total acreage is open water including numerous tidal and nontidal creeks, as well as portions of the Chesapeake Bay and two estuarine Rivers (Gunpowder River and Bush River).
2. REFERENCES
Appendix A contains a list of references used in this plan.
3. MCMS AND BMPS
3.1 Public Education and Outreach
Information distribution and community outreach are means to raise the awareness of APG employees, residents, and visitors as to how their actions impact storm water runoff and water quality. Appropriate BMPs include activities such as storm drain stenciling, annual training for personnel, and distributing educational materials (e.g., posters, brochures, and fact sheets) to the public.
APG publishes storm water related informational articles in the APG community newspaper, APG News, semiannually. The articles serve to educate the public about the effects of pollutants in storm water and encourage public involvement in pollution prevention. In addition, environmentally friendly displays are showcased at various community events. APG promotes annual training of installation personnel in spill reporting and response and basic storm water pollution prevention.
The majority of storm sewer drains on APG have been marked with colorful signs that read “No Dumping – Drains to Waters of the State.” APG’s storm drain marker program raises public awareness about the connection between storm drains and the health of local waters.
APG has established a successful recycling program for all tenant organizations. The recycling program includes single stream collection of #1–7 plastics, excluding styrofoam. APG also maintains a qualified recycling program that collects steel, copper, brass, oils, and tires. The private contractor in charge of installation housing provides residential recycling. Public education and outreach BMPs and measurable goals are located in Table 1.
Table 1. Public Education and Outreach Measurable Goals and BMPs
BMP Metric for Goal Schedule Responsible Entity
Publish periodic storm water articles in the installation newspaper
Publish storm water and related environmental articles in APG News.
Semi-Annual DPW-ED
Educational displays at event participation
Distribute and display educational materials at community events.
Annually DPW-ED
Vehicle washing brochure
Distribute brochures to residents and personnel of APG.
Annually DPW-ED
Storm water pollution prevention training
Conduct in person storm water training every other month to APG personnel.
Provide training in CD format for residents and visitors. Training is also available in PowerPoint® format for online training.
Bimonthly DPW-ED
Storm drain marker program
Inspect at least 50 storm drain markers for deterioration and replace as needed.
Annually DPW-ED
Residential and industrial waste recycling program
Distribute information regarding on-post recycling opportunities and ways to reduce waste to tenants and businesses.
Annually DPW-ED
Legend:
BMPs = best management practices DPW-ED = Directorate of Public Works – Environmental Division APG = Aberdeen Proving Ground
3.2 Public Participation and Involvement
Employees and local residents should have an active role in the development and implementation of the storm water program. The work of just a few motivated individuals can have a significant impact on storm water management. If employees and residents have an active role in implementing storm water controls, then they are more likely to maintain and support the BMPs implemented, rather than raise public challenges. BMPs supporting this MCM are continually evaluated and monitored. In accordance with the general permit, APG will comply with State and Federal public notice requirements for storm water management actions or decisions.
APG facilitates public involvement through key partnerships and collaborative efforts. These partnerships include regular meetings with Maryland Environmental Partnership and the Chesapeake Bay Action Team to discuss updates and information on the Chesapeake Bay Program and to discuss regional and local compliance updates, sustainability, pollution prevention, and miscellaneous networking issues. APG hosts awareness-focused events for the APG community on Earth Day and during Pollution Prevention Week. In addition, twice a year, in partnership with the Alliance for the Chesapeake Bay Project Clean Stream, APG hosts a shoreline cleanup. APG encourages the public to report storm water issues, including illicit discharges and storm water pollution to their dedicated storm water hotline. The hotline has been advertised via APG News, social media, and the APG website. Public participation and involvement BMPs and measurable goals are located in Table 2.
Table 2. Public Participation and Involvement Measurable Goals and BMPs
Responsible Entity
Key partnerships
Actively participate in quarterly meetings with the Chesapeake Bay Action Team. Actively participate in periodic meetings with the Maryland Environmental Partnership.
Quarterly/ Periodically
DPW-ED
Storm water hotline
Oversee the hotline and maintain records from community reporting of illicit discharges and storm water pollution.
Annually DPW-ED
Spill reporting Track spills through periodic inspections and reporting by tenants and employees.
Annually DPW-ED
Community events
Host awareness-focused events for the APG community (Earth Day, Pollution Prevention Week).
Annually DPW-ED
Shoreline cleanup
Hold a cleanup event semiannually where volunteers help pick up trash and debris along the installation’s shorelines.
Semi-Annual DPW-ED
Legend:
BMPs = best management practices DPW-ED = Directorate of Public Works – Environmental Division APG = Aberdeen Proving Ground
3.3 IDDE
Federal regulations define an illicit discharge as “...any discharge to an MS4 that is not composed entirely of storm water...” with some exceptions. These exceptions include discharges from NPDES-permitted industrial sources and discharges from fire-fighting activities.
Examples of illicit discharges are domestic and industrial wastewater, paint, chemicals, auto fluids, vehicle wash water, and fuel spills.
APG has an established IDDE Program, the purpose of which is to determine the types and sources of illicit discharges and effectively eliminate them. This program includes maintaining an updated storm sewer system map, establishing and implementing an IDDE policy and IDDE plan, and illicit discharge educational outreach.
APG maintains a storm sewer system map detailing drainage areas, storm drain and outfall locations, and storm water BMP locations and descriptions. APG drafted an IDDE Policy to prohibit non-storm water discharges into the MS4 and outline appropriate enforcement procedures and actions. This policy will be incorporated into APG Regulation (APGR) 200-40, Environmental Quality (APG, 2017). In May 2017, APG developed an IDDE Plan to detect and address non-storm water discharges, including illegal dumping, into the MS4. The plan includes:
Procedures to field screen storm drain outfalls on a consistent basis;
Inspection procedures for identifying the source of any suspected illicit discharges to the storm drain system;
Enforcement and penalty procedures;
Procedures to address spills and illegal dumping; and
Means to inform military personnel, employees, and residents of illegal discharges and improper waste disposal.
Public education and outreach regarding ways to detect and eliminate illicit discharges is an integral part of this MCM. APG’s storm water hotline publicizes and facilitates public reporting of illicit discharges. Informative brochures and guidance, specific for different audiences (installation employees versus residents), has been developed and disseminated to educate the public on illicit discharges. IDDE BMPs and measurable goals are located in Table 3.
Table 3. IDDE Measurable Goals and BMPs
Responsible Entity
IDDE Plan Implement the IDDE Plan. Review and update as needed.
Annually DPW-ED
Inspect installation outfalls
Inventory and inspect 100 outfalls per year for illicit discharges. Record any degradation or maintenance necessary for each outfall.
Annually DPW-ED
Responsible Entity
Maintain an accurate storm sewer system map
Maintain the APG General Storm Drainage Map and update regularly at completion of construction projects and as otherwise needed. Maintain MS4 geographic information system data layers for site information and links to regulatory requirements.
Annually DPW-ED
Storm water hotline Oversee the hotline and maintain records from community reporting of illicit discharges and storm water pollution.
Annually DPW-ED
Vehicle washing guidelines
Enforce vehicle washing guidelines for residential and industrial/commercial patrons.
Annually DPW-ED
Spill notification procedures
Follow spill notification procedures to ensure appropriate Army personnel and required regulatory notifications are followed during a spill event. The APG Facility Response Plan contains emergency notification procedures and contact information.
Annually DPW-ED
SPCC Plan Implement the APG SPCC Plan in the event of spills. Review the plan annually and update as needed.
Annually DPW-ED
Legend:
BMPs = best management practices DPW-ED = Directorate of Public Works – Environmental Division APG = Aberdeen Proving Ground MS4 = municipal separate storm sewer systems IDDE = illicit discharge detection and elimination SPCC = Spill Prevention, Control, and Countermeasure
3.4 Construction Site Storm Water Runoff Control
The purpose of construction site runoff control is to minimize erosion, retain sediment onsite, and manage storm water discharges so they do not cause or contribute to violations of applicable water quality standards. Construction sites have the potential to contribute more sediment to local rivers and streams than nonconstruction sites. Sediment runoff rates from construction are typically 10 to 20 times greater than those of agricultural lands and 1,000 to 2,000 times greater than those in forest lands. These sediment discharges cause physical, chemical, and biological harm to the nation’s waters.
Maryland has a statewide erosion and sediment control (ESC) program. The Environment Article, Title 4, Subtitle 1, Annotated Code of Maryland requires ESC for earth disturbances greater than 5,000 square feet (MDE, 2019a). ESC Plans for State and Federal development projects are approved and enforced by MDE. APG intends to rely on this “qualifying local program” as defined in the general permit to comply with this MCM. MDE believes this is sufficient for general permit compliance. APG will track ongoing and new construction projects.
In order for construction to commence, construction sites must be properly permitted and ESC Plans and SWMPs approved. Construction sites that disturb one or more acres of land must submit a NOI for coverage under MDE’s General Permit for Storm Water Associated with Construction Activity. All new construction at APG will require separate permitting for pollutant run-off control and ESC for construction activities that disturb 5,000 square feet or more of earth or involve 100 cubic yards or more of earth movement.
Currently, operators of construction projects are required to submit ESC Plans and SWMPs to MDE for approval before commencement of construction, which satisfies one of the metrics for this MCM. Directorate of Public Works (DPW) – Environmental Division (ED) receives copies of all construction plans during the planning process and reviews all plans before construction projects are approved. Table 4 lists the measurable goals and BMPs for this MCM.
Table 4. Construction Site Storm Water Runoff Control Measurable Goals and BMPs
Responsible Entity
Compliance with Maryland Storm Water Management Regulations set forth in the COMAR.
Comply with pertinent storm water management regulations set forth in COMAR 26.17.02 (MDE, 2019b).
Annually DPW-ED
APGR 200-40 (APG, 2017)
Comply with APGR 200-40.
Review and update every 2 years, if needed.
Annually/ Biennial
DPW-ED
MDE enforcement of ESC requirements.
Ensure plans are submitted for all projects disturbing 5,000 square feet or more of earth to MDE for ESC approval.
Annually DPW-ED
Ensure site plans are reviewed and approved by MDE prior to project start. Ensure NPDES and construction permits are obtained by contractors for applicable projects on APG.
Construction projects are properly permitted and approved before start of construction.
Annually DPW-ED
Review construction site plans and inspect ESC BMPs regularly
Maintain records of review and inspections.
Annually DPW-ED
Responsible Entity
ESC training
Staff or contractors overseeing the installation and maintenance of ESC practices complete Responsible Personnel Certification training (as required by COMAR 26.17.01.06 (MDE, 2019c) and Environment Article § 4-104 (MDE, 2019d)). Active construction site contractors are responsible for the training and certification of their personnel in
ESC.
Annually DPW-ED
Storm water hotline Record and address complaints of dirt tracking from construction sites reported via the hotline.
Annually DPW-ED
Legend:
BMPs = best management practices COMAR = Code of Maryland Regulation DPW-ED = Directorate of Public Works – Environmental Division APGR = APG Regulation MDE = Maryland Department of the Environment ESC = erosion and sediment control NPDES = National Pollutant Discharge Elimination System
3.5 Post Construction Storm Water Management
The purpose of this MCM is to maintain natural runoff cycles from new development and redevelopment projects that disturb 5,000 square feet or more. A post construction storm water management program can increase infiltration and decrease runoff effects with the use of low-impact development (LID), site-specific storm water designs, and inspections of storm water controls.
Maryland has a statewide storm water management program. The Environment Article, Title 4, Subtitle 2, Annotated Code of Maryland requires storm water management implementation for earth disturbances greater than 5,000 square feet (MDE, 2019e). SWMPs for State and Federal development projects are approved and enforced by MDE. APG intends to rely on this “qualifying local program” as defined in the general permit to comply with this MCM. MDE believes this is sufficient for general permit compliance. APG developed a program to track, inspect, and maintain post construction storm water BMPs in 2017.
In an effort to reduce energy consumption and optimize life cycle performance, Leadership in Energy and Environmental Design (LEED) Silver Certification is required for all new vertical building construction projects by Army policy dated 17 January 2017, Sustainable Design and Development Policy Update (Office of the Assistant Secretary of the Army (OASA), 2017).
The Army’s Sustainable Design and Development Policy Update also mandates LID measures be incorporated into new and renovation construction projects (OASA, 2017). LID is also required by Department of Defense (DOD) policy dated 19 Jan 2010, DOD Implementation of Storm Water Requirements under Section 438 of the Energy Independence and Security Act (EISA) (Office of the Under Secretary of Defense (OUSD), 2010). The U.S. Environmental Protection Agency (EPA) has EISA guidance to reduce storm water discharges from development at Federal facilities (U.S. Code, 2007). LID designs are essential in minimizing runoff created from development. Post-construction site runoff control BMPs and measurable goals are located in Table 5.
Table 5. Post Construction Storm Water Management Measurable Goals and BMPs
Responsible Entity
Inspection and Maintenance Plans for post-construction site BMPs
Implement Inspection and Maintenance Plans. Inspect all storm water BMPs every 3 years
Annually/ Triennial
DPW-ED
APGR 200-40 (APG,
2017)
Comply with APGR 200-40. Review and update every 2 years, if needed.
Annually/ Biennial
DPW-ED
MDE enforcement of storm water management requirements
Ensure plans are submitted for all projects disturbing 5,000 square feet or more to MDE for storm water management approval.
Annually DPW-ED
Permanent storm water BMP database
Maintain database with the location, description, photos, initial inspection, and grade ranking the condition of the BMP for all storm water management facilities on the installation. Update database annually at the time of the DOD Chesapeake Data Call.
Annually DPW-ED
LEED Silver certification All new occupied facilities are designed to the minimum LEED silver rating.
Annually DPW-ED
LID designs and measures
LID designs are incorporated, where feasible, at construction sites.
Annually DPW-ED
Legend:
BMPs = best management practices DPW-ED = Directorate of Public Works – Environmental Division APGR = APG Regulation MDE = Maryland Department of the Environment DOD = Department of Defense LEED = Leadership in Energy and Environmental Design LID = low-impact development
3.6 Pollution Prevention and Good Housekeeping
Good housekeeping measures are designed to reduce pollution that collects on streets, parking lots, open spaces, and vehicle maintenance areas, which discharges to local water bodies. The pollutants that are discharged can affect receiving water quality or impair the storm sewer system. Pollution prevention and good housekeeping BMPs are designed to maintain the storm sewer system and its outfalls by preventing damage caused by neglect. All pollution prevention and good housekeeping policies should be documented in the annual reports submitted to MDE. APG prevents or reduces polluted storm water runoff from operations through the development and implementation of a good housekeeping program, inspections, employee training, and runoff controls for fleet and building maintenance activities.
All storm water discharges on APG are properly permitted. Facilities discharging comingled storm water and wastewater are permitted under NPDES Discharge Permit No. MD0003565 (MDE, 2017). The permit establishes effluent limitations and monitoring requirements.
Discharges from storm water associated with industrial activities are permitted under General Discharge Permit No. 12-SW-A (MDE, 2014). Under the general permit, routine inspections and visual assessments are conducted.
APG has developed and implemented a Good Housekeeping Plan, located in Appendix D. This plan identifies the facilities that conduct municipal operations and fell outside the definition of an industrial activity, but were considered potential sources of pollution. These facilities will be periodically inspected for proper implementation of good housekeeping BMPs. These inspections will be maintained onsite at each facility and in Appendix E. The Good Housekeeping Plan also contains the APG Spill Prevention and Response Standard Operating Procedure, which details spill response, notification, and reporting procedures. Spills and leaks at APG facilities will be tracked on a spill log and maintained in Appendix F.
APG implements an Integrated Pest Management Plan that details pesticide and herbicide management on the installation. APG also discourages the use of fertilizer by individuals or groups throughout the installation. The DPW Pest Management Branch determines the minimum pest management requirements for the installation, while the Directorate of Family and Morale, Welfare, and Recreation (MWR) determines the minimum pest management requirements for the golf courses.
APG will continue the recycling efforts on the installation to reduce the amount of materials sent to the landfill and support environmental stewardship. Pollution prevention training is also available to the public on the APG website and in CD format. Pollution prevention and good housekeeping BMPs and measurable goals are located in Table 6.
Table 6. Pollution Prevention and Good Housekeeping Measurable Goals and BMPs
BMP Metric for Goal Schedule Responsible Entity
Storm water discharges properly permitted
Implement permit requirements and adhere to reapplication timeframes. Conduct monitoring and inspections as required.
Annually DPW-ED
SWP3s
Implement the Installation SWP3, Edgewood Area Wastewater Treatment Plant SWP3, and Marinas SWP3. Review and update SWP3s as needed. Conduct routine inspections and visual assessments.
Address any findings and maintain documents.
Quarterly/ Annually
DPW-ED
Good housekeeping inspections
Conduct inspections and maintain records.
Address any findings.
Quarterly/ Annually
DPW-ED
Vehicle washing guidelines
Enforce vehicle washing guidelines for residential and industrial/commercial patrons.
Annually DPW-ED
Spill notification procedures
Follow spill notification procedures to ensure appropriate Army personnel and required regulatory notifications are followed during a spill event. The APG Facility Response Plan contains emergency notification procedures and contact information.
Annually DPW-ED
Spill reporting Track spills through periodic inspections and reporting by tenants and employees.
Annually DPW-ED
Integrated Pest Management Plan
Implement the Integrated Pest Management Plan. Review and update annually.
Annually DPW-Pest Management Branch; MWR
Properly store pavement deicing chemicals
Pavement deicing chemicals are stored within covered, storm resistant shelters.
Annually DPW-ED
Residential and industrial waste recycling program
Continue recycling program efforts. Annually DPW-ED
Legend:
BMPs = best management practices DPW-ED = Directorate of Public Works – Environmental Division SWP3s = Storm Water Pollution Prevention Plans MWR = Morale, Welfare, and Recreation
4. CHESAPEAKE BAY RESTORATION AND MEETING TOTAL MAXIMUM DAILY LOADS
In 2010, the Chesapeake Bay total maximum daily loads (TMDLs) was established by the EPA for the six Bay States (Delaware, Maryland, New York, Pennsylvania, Virginia, and West Virginia) and the District of Columbia. The TMDL describes the level of effort that is necessary to meet water quality standards and restore the Chesapeake Bay. The TMDL is an aggregate of the load allocations for nonpoint sources, the wasteload allocations for point sources, and margins of safety.
Maryland’s Watershed Implementation Plan specifies the nutrient and sediment load reductions required to address the Chesapeake Bay TMDL by 2025 (MDE, 2010). The general permit makes progress toward that strategy by requiring small MS4s to commence restoration efforts for 20% of existing developed lands that have little or no storm water management. Restoration efforts may include the use of environmental site design practices, structural storm water BMPs, retrofitting, stream restoration, or other alternative restoration practices. The permit requires permittees to—
Develop a baseline impervious area assessment and submit within the first year of permit issuance for MDE review;
Develop and implement an impervious area restoration work plan within the first year of permit issuance, which outlines the development of a new restoration program for the agency and includes appropriate budget, staffing, and resources to comply with impervious area restoration requirements;
Develop a restoration activity schedule and provide a list of water quality improvement projects that will be implemented by 2025 to meet Chesapeake Bay restoration targets; and
Develop a BMP database to track implementation, and comply with inspection and maintenance requirements.
APG is currently exceeding the Chesapeake Bay restoration requirement through the removal of impervious surface, installing, or retrofitting storm water management in areas with little or no storm water treatment and shoreline stabilization. These efforts are outlined in the U.S. Army Corps of Engineers Chesapeake Bay Total Maximum Daily Load Restoration Plan for Aberdeen Proving Ground (U.S. Army Corp of Engineers, 2019).
5. REPORTING
APG will evaluate progress toward achieving compliance with all permit requirements and the appropriateness of implemented BMPs by submitting annual progress reports to MDE.
Reporting for the six MCMs and progress towards meeting the 20% impervious area restoration requirement will include all required information specified in the MS4 Progress Report (provided in Appendix D of the permit). Reporting for the six MCMs will be submitted in years 2 and 4 of the permit term. The reporting period is based on State fiscal year (i.e., July 1 – June 30). MS4 Progress Reports will be submitted no later than October 31 of each year with the first report due October 31, 2019. Annual reports will be signed by the duly authorized representative and maintained in Appendix G.
6. RECORDKEEPING
APG will maintain records for at least 3 years after termination of the general permit. In addition to the information required in MS4 Progress Reports, APG will submit any additional supporting documentation at the request of MDE. Records and information pertaining to APG’s MS4 program will be made available to the public during regular business hours.
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
A-1
APPENDIX A
REFERENCES
APG. 2017. Regulation 200-40, Environmental Quality.
EPA. 2005. EPA 833-F00-005, Storm Water Fact Sheet 2.3: Public Education and Outreach
Minimum Control Measure. https://www.epa.gov/sites/production/files/2015- 11/documents/fact2-3.pdf
EPA. 2005. EPA 833-F-00-006, Storm Water Fact Sheet 2.4: Public Participation/Outreach
Minimum Control Measure. https://www3.epa.gov/npdes/pubs/fact2-4.pdf
EPA. 2005. EPA 833-F-00-007, Storm Water Fact Sheet 2.5: Illicit Discharge Detection and
Elimination Minimum Control Measure. https://www3.epa.gov/npdes/pubs/fact2-5.pdf
EPA. 2005. EPA 833-F-00-008, Storm Water Fact Sheet 2.6: Construction Site Runoff Minimum
Control Measure. https://www3.epa.gov/npdes/pubs/fact2-6.pdf
EPA. 2005. EPA 833-F-00-009, Storm Water Fact Sheet 2.7: Post-Construction Runoff Control
Minimum Control Measure. https://www3.epa.gov/npdes/pubs/fact2-7.pdf
EPA. 2005. EPA 833-F-00-010, Storm Water Fact Sheet 2.8: Pollution Prevention/Good
Housekeeping Minimum Control Measure, December 2005.
https://www3.epa.gov/npdes/pubs/fact2-8.pdf
MDE. 2010. Maryland’s Watershed Implementation Plan.
https://mde.maryland.gov/programs/Water/TMDL/TMDLImplementation/Pages/wip.aspx
MDE. 2014. National Pollutant Discharge Elimination System (NPDES) Discharge Permit No.
MDR0000, State Discharge Permit No. 12-SW-A, effective date 1 January 2014.
MDE. 2017. NPDES Discharge Permit No. MD0003565, effective date 1 January 2017.
MDE. 2018. NPDES General Permit for Discharges from State and Federal Small MS4, General
Discharge Permit No. 13-SF-5501, effective date 31 October 2018.
MDE. 2019a. COMAR. Title 4, Subtitle 1, Sediment Control.
MDE. 2019b. COMAR. Title 26, Part 3, Subtitle 17, Chapter 2, Stormwater Management.
MDE. 2019c. COMAR. Title 26, Part 3, Subtitle 17, Chapter 1, Subchapter 6, Training and
Certification Program.
https://www.epa.gov/sites/production/files/2015-11/documents/fact2-3.pdf https://www.epa.gov/sites/production/files/2015-11/documents/fact2-3.pdf https://www3.epa.gov/npdes/pubs/fact2-4.pdf https://www3.epa.gov/npdes/pubs/fact2-5.pdf https://www3.epa.gov/npdes/pubs/fact2-6.pdf https://www3.epa.gov/npdes/pubs/fact2-7.pdf https://www3.epa.gov/npdes/pubs/fact2-8.pdf https://mde.maryland.gov/programs/Water/TMDL/TMDLImplementation/Pages/wip.aspx
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MDE. 2019d. COMAR. Title 4, Subtitle 4, Section 104, Training of Responsible Personnel.
MDE. 2019e. COMAR. Title 4, Subtitle 2, Stormwater Management.
OASA. 2017. Sustainable Design and Development Policy Update, 17 January 2017.
https://www.wbdg.org/ffc/army-coe/policies-and-guidance-army-design-and-construction/army-sdd-policy-update
OUSD. 2010. DOD Implementation of Storm Water Requirements under Section 438 of the
Energy Independence and Security Act, 19 January 2010.
U.S. Code. 2007. “Storm water runoff requirements for Federal development projects” Title 42, Chapter 152, Section 17094.
U.S. Army Corp of Engineers. 2019. Chesapeake Bay Total Maximum Daily Load Restoration
Plan for Aberdeen Proving Ground.
U.S. National Archives and Records Administration. 2020. Code of Federal Regulations. Title 40
CFR Part 122.26 Storm water discharges (applicable to State NPDES programs, see §123.25).
https://www.wbdg.org/ffc/army-coe/policies-and-guidance-army-design-and-construction/army-sdd-policy-update https://www.wbdg.org/ffc/army-coe/policies-and-guidance-army-design-and-construction/army-sdd-policy-update
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APPENDIX B
NPDES PERMIT MDR055501
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APPENDIX C
NOI AND CERTIFICATION
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APPENDIX D
GOOD HOUSEKEEPING PLAN
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D-1. BACKGROUND
Municipal operations can be a significant source of pollutants in storm water runoff, especially when uncontrolled. The National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges from State and Federal Small Municipal Separate Storm Sewer Systems (NPDES No. MDR055501) requires the development and implementation of a good housekeeping plan for facilities where maintenance of vehicles or heavy equipment is conducted and handling of any of the following materials occurs: deicers, anti-icers, fertilizers, pesticides, road maintenance materials such as gravel and sand, or hazardous materials (Maryland Department of the Environment (MDE), 2018). The Aberdeen Proving Ground (APG) Good Housekeeping Plan has been developed to meet the requirements of minimum control measure #6 as outlined in the general permit, with the intent to reduce the discharge of pollutants from municipal-type facilities at APG.
D-2. FACILITY INFORMATION
APG owns or operates facilities that conduct municipal operations, which have the potential to contribute pollutants to storm water runoff. For the purpose of this plan, municipal-type facilities at APG are those not classified as industrial activities (which would require separate NPDES permits). APG has also chosen to include non-municipal facilities with the potential for significant impact on storm water.
A complete list of APG facilities and operations covered under this plan can be found on the Facility Inventory List, located in Table D-1. The inventory includes a description of the facility, associated municipal operations, and site-specific good housekeeping measures being implemented. Pollutants of concern associated with municipal operations are listed in Table D-2.
D-3. BEST MANAGEMENT PRACTICES
The installation and maintenance of control measures for municipal operations is a critical step to managing an effective storm water program. Based on the Facility Inventory List, a set of best management practices (BMPs) have been selected. Table D-3 identifies the appropriate control measures APG will implement to prevent or reduce the amount of storm water pollution generated by municipal operations.
D-4. INSPECTIONS
APG will inspect facilities for compliance with the selected BMPs. The inspection will be documented with a checklist, found in Table D-4. The checklist will include date of inspection, name of inspector, and identify whether good housekeeping BMPs are being implemented.
Facilities are inspected either quarterly or annually. Inspection frequency was determined based on a facility’s potential to impact storm water due to operations. The inspection schedule is detailed in the Facility Inventory List. Good housekeeping inspections will be maintained in Appendix E of the APG Storm Water Management Plan (SWMP).
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D-5. SPILLS AND LEAKS
The APG Spill Prevention and Response Standing Operating Procedure (SOP) details spill response, notification, and reporting procedures. The SOP can be found in Annex 1. Spills and leaks will be tracked and recorded in Appendix F of the APG SWMP where a copy of the spill log has been provided. Documentation with include the date of release, location, content, capacity, and response actions.
D-6. REFERENCES
MDE. 2018. NPDES Discharge Permit No. MDR055501, effective date 27 April 2018.
U.S. Army Public Health Center. 2020. Aberdeen Proving Ground Storm Water Management Plan.
Environmental Health Engineering Study No. S.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020
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Table D-1. Facility Inventory List
Tenant Bldg. # Facility Description Municipal Operation BMP Inspection Frequency
AAFES 2514 Gas station
ASTs and USTs AST is equipped with built-in secondary containment. USTs are equipped with a spill bucket at the fill port and overfill protection devices.
Quarterly
Vehicle and Equipment Fueling
Fueling operations take place on a concrete pad covered by a canopy. “No Topping Off” signs are posted and all dispenser nozzles have automatic shut-off and emergency break away shut-off. Spill kits are located at the facility.
AAFES E-4010 Gas station
Liquid Storage in USTs USTs are equipped with a spill bucket at the fill port and overfill protection devices.
Quarterly
Vehicle and Equipment Fueling
Fueling operations take place on a concrete pad covered by a canopy. “No Topping Off” signs are posted and all dispenser nozzles have automatic shut-off and emergency break away shut-off. Spill kits are located at the facility.
ARL 740B
Indoor and outdoor experimental testing facility for ballistics
Materials Handling and Storage
The majority of materials are stored indoors. Flammable materials are stored in flammables cabinets. Film developers are stored inside on secondary containment pallets. Outdoor storage of materials consists of scrap metal, gun tubes, and heavy equipment storage. All items are stored on paved or gravel areas and on pallets whenever possible.
Annual
Liquid Storage in ASTs and USTs
ASTs are equipped with built-in secondary containment. USTs are equipped with a spill bucket at the fill port and overfill protection devices.
Vehicle and Equipment Fueling
Spill kits are located at the facility.
Vehicle & Equipment Maintenance
Some maintenance is performed by a contractor onsite. Maintenance is performed indoors or undercover whenever possible.
ARL 1053
Assembly, testing, and detonation of aircraft engines and equipment
Liquid Storage in ASTs ASTs are equipped with built-in secondary containment and are located under canopies.
Annual
Vehicle and Equipment Fueling
Spill kits are located at the facility.
Vehicle and Equipment Maintenance
Minor maintenance is performed inside.
Painting Painting of vehicles and equipment is conducted indoors.
ARL
(demolished) ARL fueling station
Liquid Storage in AST AST is equipped with built-in secondary containment.
Quarterly
Vehicle and Equipment Fueling
Dispenser nozzle is equipped with automatic shut-off. Spill kits are located at the facility.
Environmental Health Engineering Study No. S.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020
D-4
Tenant Bldg. # Facility Description Municipal Operation
BMP
Inspection Frequency
ARL 1116B
Waste processing facility for used testing materials and equipment
Materials Handling and Storage
Materials that have been processed as waste are stored in bins marked as scrap. POLs are stored inside and dispensed from a rack, which has built-in secondary containment.
Annual Vehicle and Equipment
Maintenance Minor maintenance to facility equipment is performed indoors. Spill kits are located at the facility.
Liquid Storage in ASTs
ASTs are equipped with built-in secondary containment.
ARL 1134B
Waste storage facility for contaminated range waste, including materials contaminated with DU
Materials Handling and Storage
Waste range materials contaminated with DU are stored in a designated building whenever possible. Larger pieces of DU contaminated waste materials are stored outdoors in a designated location.
Annual
Vehicle and Equipment Fueling
Spill kits are located at the facility.
Liquid Storage in
AST
AST is equipped with built-in secondary containment.
Vehicle and Equipment
Maintenance Scheduled maintenance of facility equipment is performed indoors.
ARL 1145B
Outdoor explosives testing facility with digital photo and x-ray processing
Materials Handling and Storage
Testing materials are stored inside whenever possible but may also be stored outside on wooden pallets. Flammable materials are stored in flammables cabinets. Explosive materials are stored indoors in a magazine.
Annual Liquid Storage in
AST
AST is equipped with built-in secondary containment.
Vehicle and Equipment
Maintenance Minor maintenance is performed indoors. Spill kits are located at the facility.
ARL 1150
Ranges used for experimental testing of ballistics and armor
Materials Handling and Storage
Whenever possible, operations are performed indoors. The majority of materials are stored indoors. Flammable materials are stored in flammables cabinets or in the hazardous materials shed which has built-in secondary containment. Materials kept outside are stored on paved or gravel areas.
Annual
Liquid Storage in ASTs
ASTs are equipped with built-in secondary containment.
Vehicle and Equipment Fueling
Spill kits are located at the facility.
Vehicle and Equipment
Maintenance All scheduled maintenance to facility equipment is performed inside.
Painting Spray paint cans are stored in flammables cabinets when not in use.
Environmental Health Engineering Study No. S.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020
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Municipal Operation
BMP
Inspection Frequency
ARL 1193C
Experimental indoor testing facility for ballistics and body armor
Materials Handling and Storage
Whenever possible, operations are performed indoors. The majority of materials are stored indoors. Materials kept outside are stored on wooden pallets or on paved areas.
Annual Liquid Storage in
ASTs ASTs are equipped with built-in secondary containment.
Vehicle and Equipment Fueling
Spill kits are located at the facility.
ATC 315 Welding and machine shop
Materials Handling and Storage
Most operations are performed indoors with the exception of some cutting and welding operations outside. Hazardous materials are stored indoors and with secondary containment. Flammable materials are stored within flammable cabinets. Scrap metals are stored outside off the ground on racks. Spill kits are located at the facility.
Annual
Liquid Storage in
AST
AST is equipped with built-in secondary containment. A 300-gallon tote is located inside.
ATC 338
Maintenance and repair to heavy equipment and wheeled/track vehicles
Vehicle and Equipment
Maintenance All maintenance activities are performed indoors. Spill kits are located at the facility.
Annual
Vehicle and Equipment Washing
The wash rack is a closed-loop water recycling system located inside.
Vehicle and Equipment Storage and Parking Vehicles awaiting maintenance and finished vehicles are stored outdoors on paved areas within the facility fence line.
Materials Handling and Storage
Bulk POLs and batteries are stored inside with secondary containment. Flammable materials are kept in flammable cabinets. Used or waste POLs are transferred to the outdoor storage tanks in closed containers. Many used parts are stored in the paved yard.
Liquid Storage in ASTs
ASTs are equipped with built-in secondary containment.
Environmental Health Engineering Study No. S.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020
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Municipal Operation
BMP
Inspection Frequency
ATC 402
Maintenance and repair to heavy and light equipment, tactical vehicles, and track vehicles
Vehicle and Equipment
Maintenance All maintenance activities are performed indoors. Spill kits are located at the facility.
Quarterly
Vehicle and Equipment Washing
The wash rack is located indoors. The wash rack discharges to a collection pit, which then flows into a settlement pond before discharging into an OWS, and finally to a holding tank for recirculation.
Vehicle and Equipment Storage and Parking Vehicles awaiting maintenance and finished vehicles are stored outdoors on paved areas.
Materials Handling and Storage
Pea gravel is located outside and has containment on two sides. POLs are dispensed from (2) 125-gallon ASTs using a pressurized system. All other bulk POLs are dispensed from drums (15 to 55 gallons in size) on rolling containment carts. Flammable materials are kept in flammable cabinets. Salt is stored on pallets indoors.
Liquid Storage in ASTs
ASTs are equipped with built-in secondary containment.
ATC 421
Fueling station for Munson
Test Track
Liquid Storage in AST and USTs
AST is equipped with built-in secondary containment. USTs are equipped with a spill bucket at the fill port and overfill protection devices.
Quarterly
Vehicle and Equipment Fueling
Fueling operations take place in the fueling area, which contains 4 dispensers. The fueling area is concrete but not covered due to the size of the vehicles that utilize the facility. Spill kits are located at the facility.
ATC 460A Generator test site
Vehicle and Equipment
Maintenance
Minor maintenance and repairs is performed on generators. All maintenance is performed indoors. Spill kits are located at the facility.
Quarterly
Materials Handling and Storage
Bulk POLs are stored outside in a bermed area under a canopy. Flammable materials are stored in flammables cabinets. Used or waste POLs are transferred to the outdoor storage tanks in closed containers. Old generators and control boxes are drained of fluids and stored outdoors until disposal. Scrap metals and various new materials are stored outdoors in designated areas on pallets. Concrete berms surround each generator test pad, with valves for emptying accumulated storm water.
Liquid Storage in ASTs
ASTs are equipped with built-in secondary containment.
Vehicle and Equipment Fueling
Generators receive fuel via hard-pipes from three ASTs.
Environmental Health Engineering Study No. S.0073145-20, Small Municipal Separate Storm Sewer System Storm Water Management Plan Update, Aberdeen Proving Ground, Maryland, May 2020
D-7
Municipal Operation
BMP
Inspection Frequency
ATC 525
Processing, proof testing, repairs, and shipment of weapons; painting of tactical weapons and vehicles
Painting and Blasting
Two paint booths are located at the facility. An outdoor blasting area is maintained at the facility. Only environmentally friendly materials, such as walnut shells and baking soda, are used for blasting. Outdoor painting is done as-needed (spot spray-painting).
Annual
Materials Handling and Storage
Bulk POLs and other hazardous materials are stored indoors with secondary containment. Flammable materials are stored within flammable cabinets. Spill kits are located at the facility.
Vehicle and Equipment Washing
The wash rack is located indoors, but is no longer in use.
Vehicle and Equipment Storage and Parking Some parts and materials are stored outdoors. Scrap materials are store outdoors in bins before being sent for recycling/disposal.
Liquid Storage in ASTs
ASTs are equipped with built-in secondary containment.
ATC 896
Experimental testing…
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