SWPPP_Jan_2013.pdf

STORMWATER POLLUTION PREVENTION PLAN

MARYLAND AIR NATIONAL GUARD

th

WING GROUP

BALTIMORE, MARYLAND

Updated by:

13825 Sunrise Valley Drive, Suite 250 Herndon, Virginia 20171

June 2013

175 WG – MDANG

Baltimore, Maryland

June 2013

Stormwater Pollution Prevention Plan

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TABLE OF CONTENTS

Page

1 SWPPP REQUIREMENTS ............................................................................................1-1

1.1 INTRODUCTION ................................................................................................1-1

1.2 SWPPP RESPONSIBLE PARTIES ....................................................................1-2

1.3 PLAN GUIDANCE ..............................................................................................1-4

1.3.1 Record Keeping ......................................................................................1-4

1.3.2 Personnel Training .................................................................................1-5

1.3.3 Non-Stormwater Discharges...................................................................1-6

1.3.4 Releases from Secondary Containment Structures................................1-6

1.3.5 Existing Environmental Plans .................................................................1-7

1.4 INSPECTION AND MONITORING PROGRAMS ...............................................1-8

1.4.1 Quarterly Visual Inspections ...................................................................1-8

1.4.2 Routine Visual Inspections .....................................................................1-9

1.4.3 Comprehensive Site Compliance Evaluation..........................................1-9

1.4.4 Analytical Monitoring.............................................................................1-10

1.5 SPECIAL REQUIREMENTS ............................................................................1-10

1.5.1 Management of Water Priority Chemicals ............................................1-11

1.5.2 Sediment and Erosion Control Requirements ......................................1-11

1.6 NOTICE OF INTENT FILING ...........................................................................1-11

1.7 INDUSTRIAL NPDES DISCHARGE PERMITS................................................1-12

1.8 CONSTRUCTION ACTIVITY PERMITS ..........................................................1-13

1.9 NOTICE OF TERMINATION ............................................................................1-13

2 BASE ASSESSMENT AND BMP ACTION PLAN ........................................................2-1

2.1 BASE LOCATION AND DESCRIPTION ............................................................2-1

2.2 INDUSTRIAL-TYPE ACTIVITIES DESCRIPTION .............................................2-1

2.3 BASE SECURITY...............................................................................................2-2

2.4 BASE DRAINAGE ..............................................................................................2-2

2.5 BASE SPILL HISTORY ......................................................................................2-4

2.6 RISK ASSESSMENT..........................................................................................2-4

2.6.1 Drainage Area 001..................................................................................2-7

2.6.2 Aircraft Parking Aprons.........................................................................2-10

2.6.3 Drainage Area 002................................................................................2-12

2.6.4 Drainage Area 011................................................................................2-22

2.6.5 Drainage Area 015................................................................................2-23

3 BMP SCHEDULE AND PROPOSED IMPLEMENTATION ...............................................3-1

4 STORMWATER RESTORATION REQUIREMENTS ........................................................4-1

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TABLES

Page

Table 1 – Pollution Prevention Team Organization ................................................................... 1-3 Table 2 – Base Stormwater Discharge Outfalls ......................................................................... 2-4 Table 3 – Outfall Drainage Characteristics ................................................................................ 2-4 Table 4 – Potential Pollutant Source by Building Number ......................................................... 2-6 Table 5 – Existing Best Management Practices ........................................................................ 3-1 Table 6 – Baseline Best Management Practices ....................................................................... 3-2 Table 7 – Site-Specific Best Management Practices ................................................................. 3-3

FIGURES

Figure 1 Site Location Map ............................................................................................. APPENDIX E Figure 2 Drainage Area Map ........................................................................................... APPENDIX E Figure 3 Industrial Activities in Drainage Area 001.................................................. APPENDIX E Figure 4 Industrial Activities in Drainage Area 002 (N)............................................ APPENDIX E Figure 5 Industrial Activities in Drainage Area 002 (S) ............................................ APPENDIX E Figure 6 Industrial Activities in Drainage Area 002 (POL) ....................................... APPENDIX E Figure 7 Industrial Activities in Drainage Areas 011 and 015 .................................. APPENDIX E

APPENDICES

APPENDIX A: BMP GUIDANCE DOCUMENT

APPENDIX B: ACRONYMS AND DEFINITIONS

APPENDIX C: INSPECTION CHECKLISTS/ FORMS

APPENDIX D: COMPLETED INSPECTION CHECKLISTS/ FORMS

APPENDIX E: MAPS AND FIGURES

APPENDIX F: STORMWATER NPDES PERMIT

APPENDIX G: WASTEWATER DISCHARGE AUTHORIZATION

APPENDIX H: GREEN INFRASTRUCTURE AND STORMWATER RESTORATION

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SWPPP CERTIFICATION

This Stormwater Pollution Prevention Plan (SWPPP) was prepared for the Maryland Air National Guard (MDANG) in accordance with good engineering practices and in accordance with the factors outlined in 40 CFR 122.26 as appropriate. It has the full approval of management at a level of authority to commit the necessary resources to ensure full SWPPP implementation. This SWPPP will be implemented as described herein, and will be reviewed and evaluated annually.

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the site, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. In addition, I certify under penalty of law that, based on the inquiry of persons directly under my supervision, to the best of my knowledge and belief; the provisions of this document adhere to the provisions of the stormwater permit for the development and implementation of a SWPPP.

Best engineering practice recommendations noted herein will be considered and may or may not be implemented depending on the priority of funding available.

Signature Date

Scott Kelly, Brigadier General, MDANG Commander, 175 Wing Group Name Title

Peter Loebach, Lt. Colonel, MDANG Environmental Manager, 175 Wing Group

Walter Moddison, Lt Colonel, MDANG Base Civil Engineer, 175 Wing Group

Peter.Loebach Typewritten Text

Peter.Loebach Typewritten Text

Peter.Loebach Typewritten Text 25 June 2013

Peter.Loebach Typewritten Text 24 June 2013

Peter.Loebach Typewritten Text 2 August 2013

Peter.Loebach Typewritten Text

Peter.Loebach Typewritten Text

Peter.Loebach Typewritten Text

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1 SWPPP REQUIREMENTS

1.1 INTRODUCTION

Environmental Protection Agency (EPA) regulations in 40 Code of Federal Regulations (CFR) 122 require that industrial and construction activities apply for a National Pollutant Discharge Elimination System (NPDES) permit for stormwater discharged to surface waters of the United States.

Associated with the permitting is the need to characterize the storm drainage areas, monitor the stormwater quality and implement Best Management Practices (BMPs) to improve stormwater quality. BMPs include structural and operational (non-structural) practices. Non-structural practices are also referred to as source controls. In addition, the activity is required to have spill containment procedures, drainage control, and security measures. Personnel involved with industrial activities are to be instructed on proper stormwater pollution prevention procedures and requirements.

Standardized written operating procedures are to be implemented, inspections are to be routinely performed, and records are to be maintained to document the successful implementation of these requirements.

Maryland is a delegated NPDES state with general permitting authority. In the past, the 175th Wing Group (WG), Maryland Air National Guard, hereafter referred to as the Base, maintained stormwater discharge authorization under a General Discharge Permit for Storm Water Associated with Industrial Activities, Permit No. 02-SW, NPDES Permit No. MDR0000. This permit expired November 30, 2007 and was administratively extended by the Maryland Department of the Environment (MDE) for several years. However, the State of Maryland is developing a General Permit for Discharges from Stormwater Associated with Industrial Activities, Permit No. 12-SW.

The effective date of the revised permit has not been established; however, in order to continue stormwater permit coverage, the Base will need to submit a Notice of Intent (NOI), a copy of this Stormwater Pollution Prevention Plan (SWPPP), and applicable permit fee to MDE within 90 days after the effective date. The MDE contact for stormwater permitting is:

Maryland Department of the Environment Water Management Administration P.O. Box 2057 Baltimore, MD 21203-2057

(410) 537-3323

This SWPPP has been prepared to comply with the EPA NPDES program under the Federal Water Pollution Control Act, as amended by the Clean Water Act of 1977 (33 U.S.C. 1251 et seq). The SWPPP has been developed utilizing information provided by the EPA1 and the State of Maryland2 regarding preparation of a SWPPP. This SWPPP also complies with Air Force Instruction (AFI) 32- 7041.

This Base has industrial-type activities that warrant consideration of control for reducing or eliminating the discharge of pollutants to the stormwater system. This SWPPP will address those activities and identify appropriate controls. This SWPPP has been prepared to provide stormwater pollution prevention guidance to the Base.

USEPA, Stormwater Management for Industrial Activities: Developing Pollution Prevention Plans and Best

Management Practices, July 1992

MDE, National Pollutant Discharge Elimination System General Permit for Discharges from Stormwater

Associated with Industrial Activities, Discharge Permit No. 12-SW

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In general, the Base and its personnel will:

Establish spill containment procedures, drainage control, and security measures;

Learn and implement stormwater pollution prevention procedures and requirements;

Follow written standard operation procedures for hazardous material handling and storage;

Perform Comprehensive Site Compliance Evaluations (CSCEs) annually (or more frequently); and

Maintain records to document successful completion of SWPPP requirements.

Technical and economic feasibility issues are a baseline consideration in choosing BMPs that will be performed. Expensive or unproven technologies are generally dismissed early in the selection process. The result is a list of practical BMPs that the Base will complete. Additional BMPs, including structural controls, will be evaluated during annual Plan reviews. Expensive BMPs deemed necessary for permit compliance, may be phased in over longer time periods.

The following appendices are included as part of this SWPPP:

Appendix A contains a BMP Guidance Document;

Appendix B contains SWPPP-related acronyms and definitions;

Appendix C contains the necessary inspection checklists and forms;

Appendix D is provided for record keeping purposes and serves as a place to store completed inspection checklists and forms;

Appendix E contains the figures and maps;

Appendix F contains the stormwater NPDES permit;

Appendix G contains the wastewater discharge authorization; and

Appendix H contains green infrastructure and stormwater restoration examples.

1.2 SWPPP RESPONSIBLE PARTIES

A key step in developing and implementing a SWPPP for the Base is to establish an organizational hierarchy familiar with environmental pollution prevention plans and operational activities. The Stormwater Pollution Prevention Team (SWPPT) consists of Base commanders and other personnel that the Base commander or SWPPT Leader appoints.

The Base Environmental Manager will serve as the SWPPT Leader. Stormwater management issues needing review or action will be identified in the quarterly Environmental Safety and Occupational Health (ESOH) Council meetings. A series of forms are provided in this Plan to assist the team in the evaluation of their assigned areas. These forms, or comparable forms generated by the Base, will be completed by Base personnel for each building/area at the Base with the ability to impact stormwater runoff. The SWPPT will make revisions to the Plan where changes to the Base significantly affect potential risks to stormwater quality. These revisions will be brief narratives inserted as amendments to the original Plan.

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Most of the information provided in this Plan requires effort by the Base SWPPT and on-site employees. The on-site team members or their designees will assist the SWPPT Leader in regards to those areas under their specific management control. Base resources indicated below the chart will provide support and technical assistance. The organizational arrangement of the SWPPT is presented in Table 1.

Table 1 – Pollution Prevention Team Organization

TEAM

DESIGNATION

NAME

PHONE NUMBER

Base Commander

Brigadier General Scott Kelly 410-918-6464

SWPPT Leader Lt. Col. Peter Loebach 410-918-6486

Civil Engineering Lt Col. Walter Moddison 410-918-6537

POL Manager SMSgt. David Horner 410-918-6125

Fire Department Captain

MSgt. John Miles

410-918-6257

Bioenvironmental Engineering

MSgt. William Forkgen

410-918-6613

C-27 Engine I&R TSgt. Jennifer Dehn 410-918-6348

State Environmental Representative

Mr. Abel Folarin

410-918-6062

C-27 AGE TSgt. John Jones 410-918-6205

Vehicle Maintenance

TSgt. Stefan Friesl

410-918-6239

A-10 Engine I&R MSgt. Dave Markowski 410-918-6249

A-10 AGE SSgt. Chris Krzysiak 410-918-6612

HAZMART MSgt Teddy Whitaker 410-918-6215

A-10/C-27 Fuel Cell MSgt. David Markel 410-918-6595

A-10 Structural MSgt. Anthony Bahur 410-918-6264

C-27 Structural MSgt. Bryan Altvater 410-918-6570

C-27 Flight Line TSgt. Lindsey Desoto 410-918-6020

A-10 Flight Line TSgt. Joseph Sedlock 410-918-6329

The responsibility of the Wing commander is to:

Implement the SWPPP at all commands;

Appoint SWPPT Leader; and

Approve plan.

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The responsibilities of the SWPPT Leader and Members are to:

Review the SWPPP and implement BMPs;

Ensure appropriate employees are trained and familiar with SWPPP requirements;

Conduct CSCEs annually (or more frequently);

Maintain records and forms relevant to SWPPP; and

Evaluate the adequacy of the SWPPP at least annually (or as facilities change) and modify as necessary.

1.3 PLAN GUIDANCE

1.3.1 Record Keeping

This SWPPP will be maintained on-site at the office of the SWPPT Leader. The SWPPP will be reviewed and updated when changes are made at the Base that will impact the exposure of significant materials to stormwater or the overall effectiveness of the SWPPP, when an inspection determines that changes to the SWPPP are necessary, or when the SWPPP is ineffective in accomplishing the stated objectives. The SWPPP will be reviewed by the SWPPT at least annually.

As part of Plan, the SWPPT will complete and document the completion of tasks. Master blank inspection checklists and forms are provided in Appendix C. The SWPPT Leader will provide copies of the blank inspection checklists and forms to SWPPT members as needed. The SWPPT Leader will either insert copies of all completed forms and records into Appendix D or ensure that records are maintained on the Base shared electronic network. Records of inspection and maintenance activities such as cleaning and repairing stormwater control and treatment facilities will also be maintained. The SWPPT Leader will also retain records of any stormwater monitoring information that is collected at the Base.

Form 1 (Training Documentation Sheet) may be used each year to document SWPPP-related training at the Base.

Form 2 (Comprehensive Site Compliance Evaluation) may be completed once each year during the annual Comprehensive Site Compliance Evaluation.

Form 3 (Record of Plan Reviews and SWPPP Amendment Records) will be used each year to document the completion of intermediate and annual reviews by the SWPPT Leader and SWPPT members and to document annual amendments to the SWPPP. The SWPPT Leader will amend the Plan whenever there is a change in design, construction, operation, or maintenance, which has a significant effect on the potential for the discharge of pollutants to surface waters.

Amendments should include a brief description of the change, date of change, any new recommended BMPs, target dates and completion dates.

Forms 4 and 5 will not be completed on a regular schedule, but will be completed after a particular incident occurs at the Base. Form 4 (Release of Rainwater from a Secondary Containment Structure) or a shop log equivalent will be completed each time that accumulated rainwater is released from exposed secondary containment structures where potential pollutant sources are located. The Base Spill Prevention and Response Plan (SPRP) may also have a

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Page 1-5 similar form that can be used. The SWPPT Leader will maintain a record of incidents of spills or leaks of significant materials that could impact stormwater runoff, along with corrective actions, surface water discharge (if any), and other relevant information. Form 5 (Significant Spill Report) may be used to document significant spill incidents that may occur. Base personnel may use another documentation method in lieu of this form, if another spill documentation method is available.

Form 6 (Non-Stormwater Discharge Assessment) will be reviewed annually (or more frequently) as part of the non-stormwater discharge investigation component of the SWPPP. The permit requires that existing non-stormwater discharges are identified. No annual updates are required, but are recommended.

Form 7 (Exposed Significant Materials Assessment) will be completed annually (or more frequently) to assess significant materials exposed to stormwater (aggregate or salt stockpiles, scrap metal/materials storage areas, etc.).

Form 8 (Quarterly Visual Monitoring Form) should be completed for all outfalls once per quarter during precipitation events.

Form 9 (Structural Controls Inspection Report) should be completed for each structural control located at the Base at least once annually (the Facility Managers or Base Civil Engineer (BCE) may also keep/have similar records).

Form 10 (Stormwater Inspection Form) will be completed by each facility/area included in the SWPPP quarterly.

Form 11 (Standard Construction Inspection Form) should be completed as part of self-inspections performed by the Base at construction sites.

Several tables are provided in Section 3 to describe the existing BMPs at the Base (Table 5);

new baseline BMPs for the Base (Table 6); and site-specific BMPs for specific Base buildings and areas (Table 7). Dates that BMPs are implemented at the Base will be entered in these tables.

1.3.2 Personnel Training

Personnel training is essential to the effective performance of the SWPPP. Personnel at all levels of responsibility should be trained annually in the components and goals of the NPDES program and the SWPPP.

Personnel will be trained to:

Identify and manage potential spills that can occur from equipment and containers of petroleum and hazardous substances;

Recognize toxic and hazardous substances located on-site; and

Prevent, or minimize to the extent practical, stormwater pollution at the Base.

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Personnel will be trained in:

Proper and safe spilled material cleanup;

Instruction on securing drums and containers;

Frequent checking for leaks and spills;

Proper handling and storage of hazardous substances;

Identification of toxic and hazardous substances and wastes stored, handled, used, and produced on-site;

Preventative maintenance of equipment and stormwater controls;

Preventing exposure of petroleum-based fuels, oils, and lubricants, hazardous substances, and waste materials to stormwater;

Spill prevention and response;

Safe fuel handling procedures;

Specific control measures implemented at the Base to achieve effluent limitations; and

Monitoring, inspection, planning, reporting, and documentation requirements of the NPDES permit.

1.3.3 Non-Stormwater Discharges

The term “stormwater conveyance system” includes all catch basins, drop inlets and similar structures, pipes, ditches, channels, swales, and canals that discharge to receiving waters or other municipal separate storm sewer systems. The only non-stormwater discharges that shall be allowed in the stormwater conveyance system under the General Permit are:

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; or

Routine external building wash down that does not use detergents.

1.3.4 Releases from Secondary Containment Structures

Secondary containment devices for bulk storage of liquid materials will be controlled by manually activated valves or other similar devices. The drain valves for containment structures will be closed at all times except when making a controlled release. The drain valves will be secured with a locking mechanism. Any stormwater that accumulates in the containment area will be visually observed for color, foam, outfall staining, visible sheen, and dry weather flow prior to release of the accumulated stormwater. After each significant precipitation event that results in stormwater accumulation in the containment area that does not evaporate within a 24-hour period, Base operators will inspect the precipitation that has accumulated in the containment areas. If there is no evidence of oil or chemical contamination, the valves can then be opened to release the clean stormwater to the drainage system. If oil or chemicals appear to be present, the contaminants will be removed and disposed of in accordance with local, state, June 2013

Page 1-7 and federal regulations. It may be necessary to remove and dispose of all the accumulated rainwater as a contaminated waste.

The drain valve openings and releases will be documented. A blank form (Form 4) is provided in Appendix C to document the releases. Completed copies of the form will be inserted into the SWPPP document, maintained at the shop where the containment structures are located, or maintained on the Base shared electronic network and kept on-site for at least five (5) years. After releasing accumulated rainwater, the drain valve will be closed and locked.

An accidental release from a secondary containment structure, including diked or bermed areas, should be treated like an accidental release or spill from any aboveground storage tank (AST). Appropriate spill response and reporting procedures will be followed to document the release.

1.3.5 Existing Environmental Plans

Existing environmental management plans have been evaluated and applicable portions have been incorporated into the SWPPP. Future stormwater management practices required by other regulations will be evaluated by the SWPPT and incorporated into the SWPPP during the annual update. The SWPPT Leader will maintain a current copy of plans relevant to stormwater management at this Base.

1.3.5.1 Oil and Hazardous Substances Spill Prevention and Response Plan

An SPRP dated February 2013 has been prepared for the 175 WG to comply with 40 CFR 112, which makes it illegal to discharge oil, in any quantity, to the surface waters of the United States. The regulation requires facilities with petroleum storage and handling facilities to prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan. The SPRP encompasses the requirements of an SPCC Plan, and also addresses spill potential due to hazardous substance storage and use. A comprehensive list of storage tanks at the Base can be found in the SPRP. The SPRP has been reviewed and the applicable elements have been incorporated by reference into this SWPPP.

The SPRP significantly reduces the potential for a spill to become incorporated in stormwater runoff. The SWPPT has a thorough understanding of the SPRP and the response actions included for each area under their responsibility. Spills impacting or having the potential to impact the on-going stormwater quality associated with this Base will be documented as a subsection in Section

2.5 of this SWPPP. The SWPPT will also review the SPRP updates and changes as they are made to determine applicable portions to be incorporated into the SWPPP.

1.3.5.2 Installation Restoration Program

Investigation and remediation activities are ongoing at the Base related to the former A-10 test firing pad soil berm.

1.3.5.3 Comprehensive Emergency Management Plan (CEMP)

The 175 WG CEMP provides a complete briefing of the disaster and threat response plan for the Base. The plan is intended to serve as the response guide for major disasters, both on Base and off. The plan references existing plans of the airport authority and other Federal, state, and local agencies. The members of the Initial Response Force (IRF) are identified and their duties and responsibilities are described. The Base telephone extensions are provided for all primary and alternate members of the IRF and for all primary and alternate members of the follow-on

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Page 1-8 element. The major peacetime incidents that would need to be dealt with at this Base are major spills and explosions, and accidents involving military aircraft.

1.3.5.4 Hazardous Waste Management Plan

The Base maintains a management plan for employees who deal with hazardous waste. The plan identifies the satellite accumulation points (SAPs) and the type of waste associated with each SAP. General procedures are outlined for storage, handling, packaging and labeling, and transportation of hazardous waste. The procedures of this plan comply with Federal and State legislation and regulations. The plan meets the requirements set forth by the Resource Conservation and Recovery Act (RCRA).

1.4 INSPECTION AND MONITORING PROGRAMS

1.4.1 Quarterly Visual Inspections

Stormwater discharge monitoring should be performed at the designated outfall points that are described in Section 2.4 and shown on the Base Drainage Maps (see Appendix E). This monitoring should be conducted quarterly at each outfall while stormwater is discharging from the Base. A blank Quarterly Visual Monitoring Form (Form 8) is provided in Appendix C. The information to be reported includes the inspection date, the inspection personnel, the visual quality of the stormwater discharge, and probable sources of any observed stormwater contamination. The visual examination should include observations of the following parameters:

Color;

Clarity (turbidity);

Oil sheen;

Odor;

Floating solids;

Suspended solids;

Settled solids;

Foam; and

Other visible indicators of pollution.

The inspection will be made by a member of the SWPPT and will be made during daylight hours.

The same individual will attempt to conduct the visual monitoring to ensure the greatest degree of consistency. The inspection of collected samples will be conducted in a well-lit area. No analytical tests will be performed on visual samples.

Visual observation reports will be maintained on-site. Appendix D of the SWPPP has been set aside for this record keeping. The report will include the examination date and time, personnel, the nature of the discharge, visual quality of the stormwater discharge, presence of suspected non-stormwater discharges and probable sources of any observed stormwater contamination.

The results of the visual monitoring will be used to determine the effectiveness of the BMPs that have been implemented as a part of the SWPPP. Visual examinations will not assess chemical properties of the stormwater; however, they will provide results on which the Base will react quickly.

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In order to maximize the utility of the information obtained from visual monitoring, conduct the visual inspections nearest the beginning of a precipitation event (within the first 30 minutes) as practicable.

This will allow the SWPPT members to identify conditions that may be responsible for potential problems indicated by the visual monitoring. If either the visual inspections and/or the visual monitoring indicate the presence of significant sources of non-stormwater discharges, the SWPPP will need to be amended and corrective actions implemented as soon as possible.

1.4.2 Routine Visual Inspections

Routine facility inspections shall be conducted at least quarterly. Inspections shall be conducted by a SWPPT member. The purpose of inspections is to: 1) determine whether structural and non-structural BMPs require maintenance or changes, and 2) evaluate the completeness and accuracy of this Plan. At least one inspection during a reporting period shall be conducted while stormwater is discharging from the Base. Form 10 is included in Appendix C for documenting routine inspections. The following compliance items will be inspected and documented where appropriate:

Evaluate the facility to determine that the Plan accurately reflects site conditions and document any inaccuracies;

Evaluate the facility to determine whether new exposed materials have been added to the site since completion of the Plan and document any new significant materials;

During the inspection conducted during the runoff event, observe the runoff to determine if it is discolored or otherwise visibly contaminated and document observations; and

Determine if the non-structural and structural BMPs as indicated in the Plan are installed and functioning properly.

Additional inspection requirements apply to MDANG due to the Base’s capacity for aircraft deicing. During the deicing season (October through April), routine facility inspections should be conducted monthly.

1.4.3 Comprehensive Site Compliance Evaluation

A Comprehensive Site Compliance Evaluation (CSCE) shall be conducted annually, but may be performed more frequently. The evaluations will assess current site conditions and determine if the conditions are in compliance with the SWPPP. Items assessed during the site compliance evaluations include:

Evaluating the accuracy of the site map (drainage boundaries and outfalls, land use, material storage areas that are exposed to precipitation);

Determining accuracy of SWPPP and related records (SWPPPT members, outfall characteristics, inspection records, training records, etc.);

Evaluating potential pollution sources (maintenance, cleaning, and fueling areas, exposed material storage, loading / unloading areas);

Evaluating effectiveness of stormwater management controls (good housekeeping practices, preventative maintenance program, spill prevention and response, employee training, visual inspections, etc.); and

Evaluating the stormwater outfalls.

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The evaluations are used to compare the actual site conditions to the SWPPP to identify changes required in the SWPPP. The annual CSCE should be conducted during periods of actual deicing operations, if possible. If not practicable during active deicing because of weather, the inspection should be conducted during the season when deicing operations occur and the materials and equipment for deicing are in place.

A blank Comprehensive Site Compliance Evaluation (Form 2) is provided in Appendix C.

Completed copies of the form will be kept for at least five (5) years.

1.4.4 Analytical Monitoring

Analytical sampling and analysis of stormwater at MDANG has not been conducted in the past, and the Base is not required to perform sampling. The MDE General Permit for Discharges from Stormwater Associated with Industrial Activities, Permit No. 12-SW requires sector-specific benchmark monitoring, and MDANG is regulated under Sector S – Air Transportation of the NPDES permit. However, Sector S does not include benchmark parameters for which the Base would need to conduct monitoring. There are several technology-based effluent limits that apply to air transportation facilities; the Base’s compliance with these limits is discussed in Section 2.6.

1.5 SPECIAL REQUIREMENTS

The SWPPP must identify pollutants that are likely to contaminate stormwater discharges to waters of the state following implementation of source controls. Past sampling data collected at the facility or at sufficiently similar outfalls at other facilities may be used in making this determination. At a minimum, the following pollutants shall be considered for their potential to contaminate stormwater:

1. Any pollutant for which an effluent limitation is contained in any discharge permit issued to the permittee;

2. Any pollutant contained in a categorical effluent limitation or pre-treatment standard to which the permittee is subject for this facility;

3. Any Superfund Amendments and Reauthorization Act (SARA) Title III Section 313 “Water Priority Chemical3” for which the permittee, for this facility, has reporting requirements and which has the potential for contaminating stormwater The Water Priority Chemicals include those chemicals which are listed in 40 CFR 372.65, Appendix D of 40 CFR 122 Tables II, III, or V, or are listed hazardous substances in 40 CFR 116.4. These chemicals include volatile organic compounds, semi-volatile organic compounds, metals, and pesticides/herbicides;

4. Any other toxic or hazardous pollutants from present or past activity at the site that remain in contact with precipitation or stormwater and which could be discharged to the waters of the state, and which are not regulated by another environmental program; and

5. Any of the following parameters which might be present in significant concentrations: oil and grease, pH, total suspended solids, 5-day biological oxygen demand, and chemical oxygen demand.

42 U.S.C. s 11023(c)

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1.5.1 Management of Water Priority Chemicals

Extra precautions are needed for facilities managing SARA Title III, Section 313, “water priority chemicals” to prevent the discharge of these materials into stormwater. These include:

Drainage controls, such as roofs, covers, or other means to prevent exposure of chemicals to precipitation; or curbs, culverts, gutters, sewers, or other means to reduce exposure of materials to stormwater run-on.

Containers and piping compatible with chemicals stored to minimize chemical discharges.

Proper operation of chemical storage areas to minimize accidents and spills.

Periodic site inspections are required to detect existing leaks or conditions that could lead to a potential discharge.

The Base has submitted Toxic Release Inventory (TRI) Form R reports in the past for the threshold exceedance of naphthalene. Past exceedances were due to the quantity of fuels and oils used at the Base; however, the Base has not been required to submit a Form R for naphthalene for several years. In addition to this Plan, the Base implements an SPRP to significantly reduce the potential for a spill to become incorporated in stormwater runoff.

Naphthalene is a component of the fuels used at the Base. Fuel storage at the Base is closely managed according to 40 CFR 112 and use of the SPRP, which includes the use of secondary containment structures, covered storage, and proper rainwater release procedures. These procedures meet the requirements for management of the water priority chemicals.

1.5.2 Sediment and Erosion Control Requirements

Sites where soils are exposed to water, wind, or ice can have erosion and sedimentation problems.

Sedimentation occurs when soil particles are suspended in surface runoff or wind and are deposited in streams or other water bodies. Construction and other ground surface disturbing activities can accelerate erosion by removing vegetation, compacting, or disturbing the soil, changing natural drainage patterns, and by covering the ground with impermeable surfaces (pavement, concrete, buildings). When the land surface is impermeable, stormwater can no longer infiltrate, resulting in larger amounts of water that can move more quickly across a site and which can carry larger amounts of sediment and other pollutants to streams and rivers.

Stream bank stabilization is used to prevent stream bank erosion from high velocities and quantities of stormwater runoff. Stream bank stabilization is used where vegetative stabilization practices are not practical and where the stream banks are subject to heavy erosion from increased flows or disturbance during construction. Stabilization should occur before any land development in the watershed area. Stabilization can also be retrofitted when erosion of a stream bank occurs.

All areas that are erosion-prone or where construction is occurring on the Base should be inspected regularly using the Standard Construction Inspection Form (Form 11) in Appendix C.

1.6 NOTICE OF INTENT FILING

There are two categories of general permits for stormwater discharges related to industrial activities; one is related to construction (temporary) activities and the other to operational (permanent) activities. In order to obtain permit coverage under a stormwater general permit, the

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Page 1-12 prospective permittee must file an NOI to be covered under the appropriate permit. The Base is currently covered under its own industrial stormwater permit but will need to submit a new NOI when Permit No. 12-SW is finalized by MDE. The following sections explain the procedures involved in filing a NOI for either industrial activities or for future construction activities, as well as the procedures required when a Notice of Termination (NOT) is needed.

1.7 INDUSTRIAL NPDES DISCHARGE PERMITS

MDE will be developing an NOI and instructions for applying for coverage under the NPDES General Permit for Discharges from Stormwater Associated with Industrial Activities, Permit No.

12-SW. The forms and information will be available at the following web address:

http://www.mde.state.md.us/programs/Permits/WaterManagementPermits/WaterDischargePer mitApplications/Pages/Permits/watermanagementpermits/water_permits/index.aspx

NOIs for the general permit must contain the following information:

Operator's name, address, telephone number, ownership status, and status as federal, state, private, public or other entity;

Facility name, address, latitude, longitude and additional mapping information;

Name of municipality if discharge is to municipal separate storm sewer system;

Name of receiving water body;

An indication of whether analytical or visual monitoring is required;

Standard Industrial Classification (SIC) code that represents principal activities at the facility according to the permit categories;

Permit number of additional permits for any discharges from the site that currently are authorized by a permit;

Signature and date by Base Commander.

In response to the filing of an NOI, the permitting agency will either issue approval that is based on the general permit, or general permit coverage will be denied and the permittee will be instructed to submit a permit application for an individual permit. A copy of the NOI should be maintained with this SWPPP.

Because discharges from the Base (Outfall 001) enter the Baltimore County municipal separate storm sewer system (MS4) prior to reaching a receiving water, the Base will need to notify the Baltimore County Department of Environmental Protection and Sustainability that it is covered under the General Permit. The County may have additional requirements that will need to be included in this SWPPP and with which the Base will be required to comply. Contact information for the County is provided below:

Baltimore County Department of Environmental Protection and Sustainability 105 West Chesapeake Avenue, Suite 400 Towson, Maryland 21204

(410) 887-4488

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1.8 CONSTRUCTION ACTIVITY PERMITS

An NOI Form must be filed with the MDE before any construction occurs that disturbs one or more acres. The NOI must be submitted to obtain coverage under the General Permit for Stormwater Associated with Construction Activity, General NPDES Permit Number MDR10, State Discharge Permit Number 09 GP. The exact requirements for a construction activity NOI are described at:

mitApplications/Pages/Permits/watermanagementpermits/water_applications/gp_construction.a spx

NOIs for the general permit must contain the following information:

Operator's name, address, telephone number, ownership status, and status as federal, state, private, public or other entity;

Facility name, address, latitude, longitude and additional mapping information;

Name of municipality if discharge is to municipal separate storm sewer system;

Name of receiving water body;

Types of BMPs that will be implemented (silt fence, ponds, seeding, mulching, etc.)

Estimated timetable for start and completion dates;

Estimate of number of acres of the site on which soil will be disturbed; and, Certification that the SWPPP provides compliance with approved state or local sediment and erosion site plans or stormwater management plans.

Signature and date by Base Commander.

In response to the filing of an NOI, coverage is effective upon receipt of the NOI by MDE. All conditions of the permit, which include the development and implementation of a site sediment and erosion control plan, will also be in force immediately. The permit also describes requirements for obtaining approved erosion and sediment control plans in accordance with Title 4, Subtitle 1 of the Environment Article, Annotated Code of Maryland prior to commencement of construction activities.

Additional county and local ordinances may apply when construction activities are to occur in floodplain or wetland areas. All applicable Federal, State, and local permits must be obtained prior to commencement of construction activity.

1.9 NOTICE OF TERMINATION

An NOT must be submitted when all stormwater discharges associated with industrial activity authorized by the General Permit, or all stormwater discharges from construction activities authorized by the Construction General Permit, are eliminated or when the operator of the facility discharging stormwater associated with industrial activity changes.

The NOT forms may be obtained by visiting the same sites at which the NOI forms were obtained.

Completed forms are submitted to the MDE address indicated on the NOT form, which can be found at the above website. Coverage is terminated upon written confirmation from MDE. A copy of the NOT must be retained in facility archives for a minimum of one year after it is submitted.

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2 BASE ASSESSMENT AND BMP ACTION PLAN

The goal of the SWPPP is to ensure to the maximum extent practicable (MEP) that only the highest quality of stormwater runoff is discharged from the Base. To achieve this goal, a site assessment was conducted at the Base on 13-14 November 2012 to assess stormwater pollution potential and identify BMPs to reduce pollutant loading. The results of the assessment have been organized into the following sub-sections:

Section 2.1: Base Location and Description;

Section 2.2: Industrial-Type Activities Description;

Section 2.3: Base Security;

Section 2.4: Base Drainage;

Section 2.5: Base Spill History; and

Section 2.6: Risk Assessment.

The information collected during the assessment is used to develop the needed components for a BMP action plan. Existing BMPs are identified that need to be continued. In addition, baseline and site-specific BMPs are identified to improve stormwater quality and bring the Base into compliance.

The BMPs identified in this section will be implemented during the permit term based on the priorities set in the SWPPP.

2.1 BASE LOCATION AND DESCRIPTION

The Base is co-located at the Martin State Airport (see Figure 1, Appendix E). The airport is located in Baltimore County, about 10 miles northeast of the City of Baltimore. The airport lies directly southwest of Frog Mortar Creek, which is a tributary of Middle River. Middle River discharges into the Chesapeake Bay, approximately 1.5 miles east of the airport. The Base is a tenant of the Martin State Airport and is responsible only for the operation and maintenance of the approximately 179 acre tract on the north side of the airport property. The 135th Airlift Group (AG) and the 104th Fighter Squadron (FS) are components of the 175 WG. Runways are shared with the airport according to a joint use agreement with the City.

This SWPPP applies only to areas defined as industrial activity areas in 40 CFR 122. The Base has industrial activities that include aircraft, equipment and vehicle maintenance and cleaning operations, bulk fuel and chemical storage and dispensing locations, and hazardous material and hazardous waste storage areas. The figures in Appendix E (Figures 1 and 2) illustrate the base layout in relation to the airport and the base drainage areas.

2.2 INDUSTRIAL-TYPE ACTIVITIES DESCRIPTION

This Base has the following industrial-type activities:

Aircraft, Vehicle and Equipment Maintenance Stormwater discharges covered in this category include runoff from areas where the following maintenance activities may occur: fluid changes; mechanical repairs; parts cleaning; vehicle washing; storage of vehicles and equipment waiting for repair or maintenance; and storage of the related materials and waste materials, which typically include: oil, fuel, solvents, antifreeze, hydraulic fluid, grease lubes, batteries, tires, or oil and fuel filters.

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Vehicle and Aircraft Refueling Operations Stormwater discharges covered in this category include runoff from areas where motor vehicle and aircraft refueling operations may occur. These activities include fuel delivery to the facilities, fuel storage both in separate containers and in vehicle tanks, and fuel dispensing.

Aircraft Deicing Operations Stormwater discharges covered in this category include runoff from areas where aircraft deicing operations occur. These activities include: deicing fluid storage; deicing fluid handling; and deicing of aircraft. These activities currently occur on the Parking Apron.

Hazardous Materials Storage Stormwater discharges covered in this category include storage areas that are either directly exposed to rainfall or where spills or leaks from these areas have the potential to enter the storm drainage system. Storage areas for new and waste materials typically include paints, solvents, herbicides, pesticides, oil, lubricants, potassium acetate, aqueous fire-fighting foam (AFFF), batteries, and filters.

Raw Material Stockpiles Stormwater discharges covered in this category typically include runoff from stockpiles, bins, scrap piles, and storage areas. Aggregate is often exposed to precipitation and causes stormwater pollution due to sediment in the runoff.

2.3 BASE SECURITY

The Base, by nature of its operation, has significant security measures in place. The Base only allows authorized personnel onto its premises. A full-time security detail is patrolling the well-lit Base at all times.

2.4 BASE DRAINAGE

For purposes of the Base’s industrial stormwater permit, there are four primary drainage areas and outfalls on Base property. The numbering convention for the drainage areas and outfalls follows the system utilized by Martin State Airport. The Base is located in the watershed of Frog Mortar Creek, which flows southeast from the Base until it discharges into the Middle River, about 1.0 mile downstream. Drainage from the site is either channeled into a ditch that runs north of the Base along Eastern Boulevard, or discharged directly into Frog Mortar Creek at one of two discharge points. Stormwater at the Base drains to stormwater inlets and is conveyed through pipes to outfall locations shown on Figure 2.

The industrial activities associated with Drainage Area 001 and Outfall 001 (Figure 3) are as follows:

C-27 Aerospace Ground Equipment (AGE) Maintenance (Bldg. 1050);

C-27 Aircraft Maintenance Shops (Bldg. 1060);

A-10 Aircraft Maintenance Hangar (Bldg. 1070);

Base Supply (Bldg. 1120);

Hazardous Materials Pharmacy (HAZMART, Bldg. 1150); and

A-10 Aircraft Parking Apron.

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Stormwater in this drainage area either enters the stormwater conveyance system or sheet flows to the north-northeast towards a ditch that runs along Eastern Boulevard. The ditch terminates at a drop inlet northwest of the Main Gate on Hercules Boulevard before passing under the road and continuing along Eastern Boulevard in underground pipes; the drop inlet is identified as Outfall 001.

Some of the discharges from the northwestern corner of the drainage area may flow onto Martin State Airport property.