2016_185ARW_Industrial_Storm_Water_P2_Guide.pdf

INDUSTRIAL STORM WATER

POLLUTION PREVENTION GUIDE

IOWA AIR NATIONAL GUARD

185TH AIR REFUELING WING

SIOUX CITY, IOWA

MAY 2009

(Updated February 2010/July 2013/April 2016)

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185th Air Refueling Wing – IA ANG Industrial Storm Water Pollution Prevention Guide

Sioux City, Iowa Table of Contents

May 2009/Updated February 2010/July 2013/April 2016 Page i

TABLE OF CONTENTS

Page

1. ISWP2 GUIDE REQUIREMENTS

1.1. INTRODUCTION

1.2. ISWP2 RESPONSIBILITY

1.3. ISWP2 GUIDANCE

1.3.1. Record Keeping

1.3.2. Personnel Training

1.3.3. Comprehensive Site Compliance Evaluation

1.3.4. Non-Storm Water Discharges

1.3.5. Releases from Secondary Containment Structures

1.3.6. Existing Environmental Plans

1.3.6.1. Oil and Hazardous Substances Spill Prevention and Response Plan

1.3.6.2. Installation Restoration Program

1.3.6.3. Installation Emergency Management Plan (IEMP)

1.3.6.4. Hazardous Waste Management Plan

1.4. VISUAL MONITORING

1.5. INSPECTIONS

1.6. ANALYTICAL MONITORING

1.7. SPECIAL REQUIREMENTS

1.7.1. Management of Water Priority Chemicals

1.7.2. Sediment and Erosion Control Requirements

1.8. NOTICE OF INTENT FILING

1.9. INDUSTRIAL NPDES DISCHARGE PERMITS

1.10. CONSTRUCTION ACTIVITY PERMITS

1.11. NOTICE OF DISCONTINUATION

2. BASE ASSESSMENT AND BMP ACTION PLAN

2.1. BASE LOCATION AND DESCRIPTION

2.2. INDUSTRIAL-TYPE ACTIVITIES DESCRIPTION

2.3. BASE SECURITY

2.4. BASE DRAINAGE

2.5. BASE SPILL HISTORY

2.6. RISK ASSESSMENT

2.6.1. Civil Engineering (Buildings 220 and 221)

2.6.2. ANG Paint Facility (Building 241)

2.6.3. AGE (Building 252)

2.6.4. Main Hangar (Building 261)

2.6.5. Fuel Cell/Corrosion Control Facility (Building 278)

2.6.6. Base Supply Warehouse (Building 280)

2.6.7. HazMart Pharmacy (Building 281)

2.6.8. Hazardous Waste Central Accumulation Point (Building 282 Area)

2.6.9. Vehicle Maintenance Complex (Building 283)

2.6.10. Aircraft Parking Apron

2.6.11. POL Management Facility

3. BMP SCHEDULE & PROPOSED IMPLEMENTATION

185th Air Refueling Wing – IA ANG Industrial Storm Water Pollution Prevention Guide

Sioux City, Iowa Table of Contents

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TABLE OF CONTENTS (cont.)

TABLES Page

Table 1: Visual Monitoring Parameters Table 2: Base Storm Water Discharge Outfalls Table 3: Outfall Drainage Characteristics Table 4: Potential Pollutant Source by Building Number Table 5: Existing Best Management Practices Table 6: Baseline Best Management Practices Table 7: Site-Specific Best Management Practices

FIGURES

Figure 1: Site Location Map ......................................................................................... APPENDIX F Figure 2: ISWP2 Guide Site Map ................................................................................. APPENDIX F

APPENDICES

ACRONYMS AND DEFINITIONS ................................................................................ APPENDIX A

SIOUX GATEWAY AIRPORT STORM WATER DISCHARGE PERMIT....…...….…. APPENDIX B

BEST MANAGEMENT PRACTICES ........................................................................... APPENDIX C FORMS & REPORTS ................................................................................................... APPENDIX D COMPLETED INSPECTION FORMS & REPORTS .................................................... APPENDIX E SITE MAPPING………………………………………………… ....................................... APPENDIX F

185th Air Refueling Wing – IA ANG Industrial Storm Water Pollution Prevention Guide Sioux City, Iowa Section 1. ISWP2 Guide Requirements

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1. ISWP2 GUIDE REQUIREMENTS

1.1. INTRODUCTION

EPA regulations in 40 CFR 122 require that industrial and construction activities apply for a National Pollutant Discharge Elimination System (NPDES) permit for storm water discharged to surface waters of the United States. Associated with the permitting is the need to characterize the storm drainage areas, monitor the storm water quality and implement best management practices (BMPs) to improve storm water 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 storm water 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.

This Industrial Storm Water Pollution Prevention (ISWP2) Guide, hereafter referred to as the Guide, was prepared to compliment information in the EPA’s 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 Guide was developed utilizing information provided by the EPA1 and the State of Iowa2 regarding preparation of a Guide document. This Guide also complied with Air Force Instruction (AFI) 32-7041, prior to the AFI’s recision.

The State of Iowa has issued a general permit for storm water discharges associated with industrial activities, General Permit No. 1, to Sioux Gateway Airport. The effective date of this renewed permit is October 31, 2012 through October 31, 2017. The 185th Air Refueling Wing (185ARW), Iowa Air National Guard, hereafter referred to as the Base, is covered under Sioux Gateway Airport’s discharge permit (see Appendix B). Sioux Gateway Airport is hereafter referred to as the Airport. Iowa is a delegated NPDES state with general permitting authority.

The Iowa Department of Natural Resources (DNR) contact for storm water permitting is:

Storm Water Coordinator Iowa Department of Natural Resources 502 E. 9th St.

Des Moines, IA 50319-0034 515/281-5918

The Base has industrial-type activities that warrant consideration of control for reducing or eliminating the discharge of pollutants to the storm water system. This Guide will address those activities and identify appropriate controls. This Guide was prepared to provide storm water pollution prevention instruction to the Base.

In general, the Base and its personnel will:

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

1 USEPA, Storm Water Management for Industrial Activities: Developing Pollution Prevention Plans and Best Management Practices, July 1992 2 Iowa Department of Natural Resources, NPDES General Permit No. 1, Storm Water Discharge

Associated with Industrial Activity.

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Learn and implement storm water pollution prevention procedures and requirements;

Follow written standard operating procedures for hazardous materials handling and storage;

Perform comprehensive site compliance evaluations annually (or more frequently); and, Maintain records to document successful completion of ISWP2 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 consider. Additional BMPs, including structural controls, will be evaluated during annual Guide 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 Guide: Appendix A contains ISWP2-related acronyms and definitions. Appendix B contains Sioux Gateway Airport’s storm water discharge permit. Appendix C contains a BMP guidance document. Appendix D contains the necessary inspection forms and reports. Appendix E is provided for record keeping purposes and serves as a place to store completed inspection forms and reports. Appendix F contains the site maps for the Base.

1.2. ISWP2 RESPONSIBILITY

A key step in developing and implementing an ISWP2 program is to establish a Base population that is familiar with environmental pollution prevention and operational activities. This Guide provides information that is applicable to a wide range of Base personnel - from unit commanders to airmen.

The Base’s Environmental Manager (EM) will serve as the ISWP2 Coordinator. Storm water management issues needing review or action will be identified and presented in semi-annual Environmental, Safety and Occupational Health (ESOH) Council meetings, or sooner, as deemed necessary. A series of forms and reports are provided in this Guide to assist Base personnel in the evaluation of their assigned areas. These forms and reports, or comparable documents generated by the Base, will be completed by Base personnel for each building/area at the Base with the ability to impact storm water runoff. The Environmental Management Office (EMO) will make revisions to the Guide where changes to the Base significantly affect potential risks to storm water quality. These revisions will be incorporated into this Guide, with a summary of changes recorded on Form 3-Record of Plan Reviews/ISWP2 Guide Amendments, found in Appendix D.

Most of the information provided in this Guide requires effort by the EMO and Base personnel.

The Base will assist the ISWP2 Coordinator regarding those areas under their specific management control.

The responsibility of the ISWP2 Coordinator is to:

Review the Guide and implement BMPs;

Ensure appropriate employees are trained and familiar with Guide requirements;

Conduct Comprehensive Site Compliance Evaluations annually (or more frequently);

Maintain forms and reports relevant to the Guide; and, Evaluate the adequacy of the Guide at least annually and modify, as necessary.

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1.3. ISWP2 GUIDANCE

1.3.1. Record Keeping

This Guide will be maintained by the EMO, as well as on its Virtual Environmental Management Office (VEMO) website. The Guide will be reviewed and updated when changes are made at the Base that will impact the exposure of significant materials to storm water or the overall effectiveness of the Guide, when an inspection determines that changes to the Guide are necessary, or when the Guide is ineffective in accomplishing the stated objectives. The Guide will be reviewed by the EMO at least annually.

As part of this Guide, the ISWP2 Coordinator will document the completion of tasks. Master blank inspection forms and reports are provided in Appendix D. The ISWP2 Coordinator will provide copies of the blank inspection forms and reports to Base personnel, as necessary.

Records of inspection and maintenance activities such as cleaning and repairing storm water control and treatment facilities will also be maintained. The ISWP2 Coordinator will insert copies of all completed forms and reports into Appendix E. The ISWP2 Coordinator will also retain records of any storm water monitoring information that is collected at the Base. Records will be maintained with the Guide for a minimum of three years.

Form 1, Training Documentation Sheet, may be used each year to document Guide-related training at the Base. The ISWP2 Coordinator should identify Base supervisory personnel to train, such as shop supervisors, and train them regarding the goals and components of this Guide. Annual ISWP2 training is part of a comprehensive training program that everyone on Base is required to complete. The 185ARW Annual Environmental Training covers three topics: waste management, storm water pollution prevention, and spill prevention and response. The training can be accessed through a link on the 185ARW’s SharePoint Home Page. The link is:

Unit training managers are responsible for recording completion of training for their personnel.

Form 2, Comprehensive Site Compliance Evaluation, will be completed once each year upon completion of the annual site inspection.

Form 3, Record of Plan Reviews and ISWP2 Guide Amendment Records, will be used each year to document the completion of annual reviews by the ISWP2 Coordinator and EMO and to document annual amendments to the Guide. The ISWP2 Coordinator will amend the Guide 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.

Form 4, Release of Rainwater from a Secondary Containment Structure, or a shop log equivalent will be completed each time accumulated precipitation is released from exposed secondary containment structures where potential pollutant sources are located. The Base uses Form 3, Secondary Containment Drainage and Inspection Log, in Appendix D of the Base’s spill prevention and response plan (SPRP) in lieu of Form 4 in this Guide. Form 3 of the SPRP is completed by AGE for its bowser’s secondary containment pad and by EMO for Service’s kitchen grease AST secondary containment. The Base’s POL section completes AFTO Form 39 to record secondary containment releases.

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Form 5, Significant Spill Report, may be used to document significant spill incidents that may occur. The ISWP2 Coordinator, or Fire Department personnel, will maintain a record of incidents of spills or leaks of significant materials that could impact storm water runoff, along with corrective actions, surface water discharges (if any), and other relevant information. The Base uses Form 2 in Appendix E of the Base spill plan to record hazardous material/hazardous waste releases.

Forms 4 and 5 will not be completed on a regular schedule, but will be completed after particular incidents occur at the Base.

Form 6, Non-Storm Water Discharge Assessment, will be reviewed annually (or more frequently) as part of the non-storm water discharge investigation component of the Guide. The Airport’s discharge permit requires that existing non-storm water 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 storm water.

Form 8, Outfall Inspection Form, will be completed for each outfall annually, or more frequently, as needed.

Form 9, Structural Controls Inspection Report, will be completed for each structural control located at the Base at least once annually or more frequently, as needed.

Form 10, Routine Storm Water Inspection Form, will be completed by each facility/area included in the Guide at least annually or more frequently, as needed. Findings requiring action shall require revising the Guide within two weeks of the inspection. Hand-written changes will suffice until the Guide is more appropriately revised. Any recommended corrective actions as a result of the inspection findings should be implemented within 12 weeks of the inspections. The completed forms and reports can be kept in Appendix E of this Guide. A brief report summarizing the findings of the inspections, recommendations and corrective action implementation shall be developed and kept with the Guide for at least three years.

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 ISWP2 information in the Guide.

Personnel at all levels of responsibility should be trained in the components and goals of the NPDES program and the Guide. Training should be conducted at least annually or more frequently if needed, and may be conducted concurrently with the Base waste management and spill prevention and response training.

Storm water pollution prevention training is part of a comprehensive training program that everyone assigned to industrial shops on Base are required to complete on an annual basis.

The 185ARW Annual Environmental Training program covers three training topics: waste management, storm water pollution prevention, and spill prevention and response. The training can be accessed through a link on the 185ARW’s SharePoint Home Page. The link is provided in section 1.3.1 on page 3 of this Guide.

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Unit training managers are responsible for recording completion of training for their personnel.

Personnel will be trained to:

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

Recognize toxic and hazardous materials located on-site; and, Prevent, or minimize to the extent practical, storm water pollution at the Base.

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 materials;

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

Preventive maintenance of equipment and storm water controls;

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

Spill prevention and response; and, Safe fuel handling procedures.

1.3.3. Comprehensive Site Compliance Evaluation

A comprehensive site compliance evaluation is required to 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 Guide. 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 the Guide and related records (outfall characteristics, inspection records, training records, etc.);

evaluating potential pollution sources (maintenance, cleaning, and fueling areas, exposed material storage, loading/unloading areas); evaluating the effectiveness of storm water management controls (good housekeeping practices, preventive maintenance program, spill prevention and response, employee training, visual inspections, etc.); and evaluating the storm water outfalls. The annual evaluations are used to compare actual site conditions to identify changes required in the Guide.

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

Completed copies of the form will be kept in Appendix E or designated alternate location for at least three years.

1.3.4. Non-Storm Water Discharges

The term “storm water 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-storm water discharges that shall be allowed in the storm water conveyance system under the Airport’s general permit are:

185th Air Refueling Wing – IA ANG Industrial Storm Water Pollution Prevention Guide Sioux City, Iowa Section 1. ISWP2 Guide Requirements

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All other discharges that are authorized by a non-storm water NPDES permit;

Water line flushing; landscape irrigation; diverted stream flows; rising groundwater;

uncontaminated groundwater infiltration (as defined at 40 CFR 35.2005(20));

uncontaminated pumped groundwater; discharges from potable water sources; foundation drains; air conditioning condensation; irrigation water; springs; water from crawl space pumps; footing drains; and lawn watering; and, Discharges or flows from fire-fighting/fire-training activities.

A non-storm water discharge survey (illicit discharge survey), dated February 2007, was conducted by CH2MHILL. The CH2MHILL survey assessed the Base outfalls for the presence or absence of dry-weather flow in the storm sewer system. This survey did not identify any dry weather flows at the Base. This survey did not evaluate for the presence of illicit connections to the storm sewer system.

In addition to developing this plan, AMEC also reviewed the as-built construction plans of the industrial buildings at the Base to determine if there were any illicit connections to the storm sewer system. AMEC did not identify any illicit connections to the storm sewer system.

1.3.5. 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 controlled releases. The drain valves will be secured with a locking mechanism. Any storm water 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 storm water. After each significant precipitation event that results in storm water 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 be opened to release the clean storm water to the drainage system. Since storm water is released through POL’s oil/water separator (OWS), oils that appear to be present are also slowly drained through the OWS for collection/retention in the OWS system.

The drain valve openings and releases will be documented. POL personnel will record secondary containment releases on the AFTO Form 39. Copies of the form will be retained at the POL Complex. 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.

1.3.6. Existing Environmental Plans

Existing environmental management plans have been evaluated and applicable portions have been incorporated into the Guide. Future storm water management practices required by other

185th Air Refueling Wing – IA ANG Industrial Storm Water Pollution Prevention Guide Sioux City, Iowa Section 1. ISWP2 Guide Requirements

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1.3.6.1. Oil and Hazardous Substances Spill Prevention and Response Plan

A spill prevention and response plan (SPRP) has been prepared for the 185ARW to comply with 40 CFR 112. This CFR section states that it is 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 material storage and use. The SPRP was reviewed and the applicable elements were incorporated by reference into this Guide.

The SPRP significantly reduces the potential for a spill to become incorporated in storm water runoff. The ISWP2 Coordinator has a thorough understanding of the SPRP and the response actions included for each area under his responsibility. Spills impacting or having the potential to impact the on-going storm water quality associated with the Base will be documented as a subsection in Section 2.5 of this Guide. The ISWP2 Coordinator will also review the SPRP updates and changes as they are made to determine applicable portions to be incorporated into the Guide.

1.3.6.2. Installation Restoration Program

Investigation and remediation activities have been completed and closed out at the Base.

1.3.6.3. Installation Emergency Management Plan (IEMP)

The 185ARW IEMP 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 and off the Base. The plan references existing plans of the airport and other Federal, state, and local agencies. The members of the Initial Response Force (IRF) have been identified along with their duties and responsibilities in the IEMP. 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 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.

1.3.6.4. Hazardous Waste Management Plan

The Base maintains a management plan for employees who deal with hazardous wastes. The plan identifies initial accumulation points (IAPs) and types of waste associated with each IAP.

General procedures are outlined for storage, handling, packaging and labeling, and transportation of hazardous waste. The procedures of this plan comply with Federal legislation and regulations. The plan meets the requirements set forth by the Resource Conservation and Recovery Act (RCRA). The Base has also developed a shortened version of the plan for shop personnel, referred to as the 185ARW Waste Management Guide. This guide is included in Tab C of each shop’s Hazardous Waste IAP Manager’s Folder.

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1.4. VISUAL MONITORING

Storm water discharge monitoring will be performed at the designated outfall points that are shown on the Base’s ISWP2 Site Map, Figure 2 in Appendix F of this Guide. Storm water discharge monitoring is required at least once each year while storm water is discharging from the Base. The visual examination will include observations of the parameters that are identified in Table 1. The information to be reported includes the inspection date, the inspection personnel, the visual quality of the storm water discharge, and probable sources of any observed storm water contamination.

Table 1: Visual Monitoring Parameters

Color Oil Sheen

Odor Floating Solids

Turbidity (Clarity) Settled Solids

Foam Suspended Solids

Other Indicators of Storm Water Pollution

The inspection will be made by the ISWP2 Coordinator or EMO personnel 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 visual monitoring will be conducted in a well-lit area. No samples will be collected or analytical tests performed as a result of the visual monitoring process.

Visual observation reports will be maintained on-site. Form 8 of Appendix D of the Guide was 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 storm water discharge, presence of suspected non-storm water discharges and probable sources of any observed storm water contamination.

The results of the visual monitoring will be used to determine the effectiveness of the BMPs that were implemented as a part of the Guide. Visual examinations will not assess chemical properties of the storm water; however, they will provide results on which the Base will react quickly. In order to maximize the utility of the information obtained from visual monitoring, conduct the visual inspections nearest the beginning of a precipitation event as practicable. This will allow the ISWP2 Coordinator or EMO personnel 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-storm water discharges, the Guide will need to be amended and corrective actions implemented as soon as possible.

1.5. INSPECTIONS

Site inspections shall be conducted at least once annually. Inspections shall be conducted by the ISWP2 Coordinator or EMO personnel. 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 Guide. Form 10 is included in Appendix D for documenting inspections. The following compliance items will be inspected, and documented where appropriate:

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Evaluate the facility to determine if the Guide 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 Guide - document any new significant materials;

During an inspection conducted during a runoff event, observe the runoff to determine if it is discolored or otherwise visibly contaminated - document observations; and, Determine if non-structural and structural BMPs are installed and functioning properly.

1.6. ANALYTICAL MONITORING

At this time, the Base is not required to perform any sample analysis. The Airport is required to conduct sampling and analysis to meet its permit requirements according to the following:

“During the period beginning on the effective date and lasting through the expiration date of this permit, storm water discharge associated with industrial activity from runways and areas used for aircraft deicing at airports with over 50,000 flight operations per year are subject to the following monitoring requirements during a deicing event:

Oil and grease (mg/L);

Five-day biochemical oxygen demand (BOD5) (mg/L);

Chemical oxygen demand (COD) (mg/L);

Total suspended solids (TSS) (mg/L);

Total Kjeldahl nitrogen (TKN) (mg/L);

Total phosphorus (mg/L);

pH;

Ethylene glycol (mg/l);

Date and duration (in hours) of the storm event(s) sampled;

Rainfall measurements or estimates (in inches) of the storm event which generated the sampled runoff;

Duration between the storm event sampled and the end of the previous measurable (greater than 0.1 inch rainfall) storm event; and, Estimate of the total volume (in gallons) of the discharge sampled shall be provided.”

Sampling shall be conducted at least annually during a deicing event.

1.7. SPECIAL REQUIREMENTS

The Guide must identify pollutants that are likely to contaminate storm water 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 storm water:

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

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

3. Any 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 storm water.

The Water Priority Chemicals include those chemicals which are listed in 40 CFR 372.65, Appendix E 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;

4. Any other toxic or hazardous pollutants from present or past activities at the site that remain in contact with precipitation or storm water 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.

If the Base has reporting requirements for any SARA Title III Section 313 Water Priority Chemical then the following requirements apply. During the period beginning on the discharge authorization date and lasting through the expiration date of this permit, facilities subject to requirements to report releases into the environment under Section 313 of SARA Title III for chemicals which are classified as Section 313 water priority chemicals are subject to the following monitoring requirements for storm water discharges associated with industrial activity that comes into contact with any equipment, tank, container or other vessel used for storage of a Section 313 water priority chemical, or located at a truck or rail car loading or unloading area where a Section 313 water priority chemical is handled. Sampling and analysis will be conducted for the following parameters:

Oil and grease (mg/l);

Five-day biochemical oxygen demand (BOD5) (mg/l)

Chemical oxygen demand (COD) (mg/l);

Total suspended solids (TSS) (mg/l);

Total Kjeldahl nitrogen (TKN) (mg/l);

Total phosphorus (mg/l);

pH;

Any Section 313 water priority chemical for which the facility is subject to reporting requirements under Section 313 of the Emergency Planning and Community Right to Know Act of 1986;

Date and duration (in hours) of the storm event(s) sampled;

Rainfall measurements or estimates (in inches) of the storm event which generated the sampled runoff;

Duration between the storm event sampled and the end of the previous measurable (greater than 0.1 inch rainfall) storm event; and, Estimate of the total volume (in gallons) of the discharge sampled.

Sampling shall be conducted at least annually.

3 42 U.S.C. s 11023(c)

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1.7.1. 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 storm water. 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 storm water run-on;

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

and, 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.

1.7.2. 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, storm water 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.

All areas that are erosion-prone or where construction is occurring on the Base should be inspected regularly using the Routine Storm Water Inspection Form (Form 10) in Appendix D.

1.8. NOTICE OF INTENT FILING

There are two categories of general permits for storm water 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 storm water general permit, the prospective permittee must file a Notice of Intent (NOI) to be covered under the appropriate permit. The Base is currently covered under the airport’s permit. 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 Discontinuation (NOD) is needed.

1.9. INDUSTRIAL NPDES DISCHARGE PERMITS

The Iowa DNR has developed guidance and application forms for coverage under the National Pollutant Discharge Elimination System (NPDES) General Storm Water Permit for Industrial Activity, Permit No. 1.

The NPDES storm water general permits, permitting guidance, and application forms can be found at the following web address:

185th Air Refueling Wing – IA ANG Industrial Storm Water Pollution Prevention Guide Sioux City, Iowa Section 1. ISWP2 Guide Requirements

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The first step in the storm water permitting process is to complete a NOI for an industrial permit.

The NOI must contain the following information:

Facility and owner information (name, address, telephone number, owner status as federal, state, public, private or other entity;

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

Facility location (section, township and range) and additional mapping information;

Anticipated discharge start date;

An indication of whether analytical or visual monitoring is required;

Name of receiving water body;

Preparation of a storm water pollution prevention plan that meets the requirements of the general permit;

Indication and proof that a public notice has been published in an area newspaper; and, Certification of application to include name, title, signature and date.

In response to the filing of a 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. The Base is currently covered under the airport’s general storm water permit in which a NOI was filed.

1.10. CONSTRUCTION ACTIVITY PERMITS

A Notice of Intent (NOI) Form must be filed with the Iowa DNR before any construction occurs that disturbs one or more acres. The NOI must be submitted to obtain coverage under the Construction General Permit, Permit No. 2. The exact requirements for a construction activity NOI are described at the web address shown on the previous page.

The NOI for a construction permit must contain the same information as for an industrial permit, with the following additions:

Description of the project (what is being constructed);

Number of acres to be disturbed; and, Estimated timetable for construction/project activities.

Authorization to discharge starts on the day the NOI is received by the IDNR or the date construction is scheduled to begin, whichever is later. 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 IDNR may deny coverage following review of the NOI, request additional information or require an individual permit.

Additional county and local ordinances may apply, especially 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.

http://www.iowadnr.gov/Environmental-Protection/Water-Quality/NPDES-Storm-Water/Permits-Guidance-Forms http://www.iowadnr.gov/Environmental-Protection/Water-Quality/NPDES-Storm-Water/Permits-Guidance-Forms

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1.11. NOTICE OF DISCONTINUATION

A Notice of Discontinuation (NOD) must be submitted within 30 days after final stabilization has been achieved at the construction site.

The NOD forms may be obtained by visiting the web address shown on the previous page.

Completed forms are submitted to Iowa’s Storm Water Coordinator at the address indicated on the forms. Coverage is terminated upon submittal of the NOD. A copy of the NOD must be retained in facility project files 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 Guide is to ensure to the maximum extent practicable that only the highest quality of storm water runoff is discharged from the Base. To achieve this goal, a site assessment was conducted at the Base on June 17-19, 2008 to assess storm water pollution potential and identify BMPs to reduce pollutant loading. The results of the assessment have been organized into the following sub-sections:

Base Location & Description Base Spill History

Base Security Risk Assessment

Base Drainage BMP Schedule

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 storm water 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 Guide.

2.1. BASE LOCATION AND DESCRIPTION

The Base is located at Sioux Gateway Airport (SUX) in Sioux City, Iowa (see Figure 1, Appendix F). The Base consists of approximately 300 acres that are leased from the Airport and approximately 16 acres that are owned by the Air Force. Runways are shared with SUX according to a joint use agreement with the Airport.

This Guide 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, aircraft painting, and hazardous material and hazardous waste storage areas. Figures 1 and 2 in Appendix F illustrate the Base layout in relation to the Airport and the Base drainage areas. Additionally, Figure 2 shows locations of industrial activity as they relate to storm water runoff.

2.2. INDUSTRIAL-TYPE ACTIVITIES DESCRIPTION

This Base has the following industrial-type activities:

Aircraft, Vehicle and Equipment Maintenance Storm water 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, anti-freeze, hydraulic fluid, grease lubes, batteries, tires, or oil and fuel filters.

Vehicle and Aircraft Refueling Operations Storm water 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.

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Aircraft Deicing Operations Storm water 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, primarily in an area designed to contain deicing fluid runoff and convey it to the sanitary sewer.

Aircraft Painting Operations Storm water discharges covered in this category include runoff from outdoor areas where aircraft are temporarily parked before entering one of the facility’s work bays for sanding, painting, or curing. Aircraft to be painted are towed from the Base’s main ramp to the concrete area in front of the paint facility. While the aircraft are outside, small amounts of fuel and oil may be released and deposited on the concrete for subsequent movement during a precipitation event. The minor releases would enter the seams in the concrete or reach the surrounding vegetated areas.

Hazardous Materials Storage Storage areas for hazardous materials typically include paints, solvents, adhesives, pesticides, fuel, oil, lubricants, deicing fluid, aqueous film forming foam (AFFF), high expansion foam (HEF), and batteries. Hazardous materials negatively impact storm water when the storage areas are either directly exposed to rainfall or when spills or leaks from these areas have the potential to enter the storm drainage system.

Raw Material Stockpiles Storm water discharges covered in this category typically include runoff from stockpiles, bins, scrap piles, and storage areas. Aggregate is often exposed to precipitation and causes storm water 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 force patrols the Base at all times.

2.4. BASE DRAINAGE

For purposes of the Airport’s industrial activity storm water permit and the Base’s influence on it, there are 11 primary drainage basins at the Base. The main Base area discharges to the city storm sewer system along Harbor Drive, which borders the main Base area on the east and discharges to Bull Ditch, the airport perimeter drainage ditch. Bull Ditch starts at the point where the city’s storm sewer ends. Bull Ditch flows south then turns west and runs along the south side of the Airport property. The Base’s POL Management Facility area discharges storm water into Bull Ditch on the south side of the Base and Airport property. Storm water discharges from the Base may ultimately flow to the Missouri River, approximately 1.75 miles west of the Base. Storm water at the Base drains to storm water inlets and a few vegetated swales and is conveyed through pipes to outfall locations shown on Appendix F’s Figure 2.

“Industrial” activities associated with Drainage Area #1 (DA-1) and Outfall #1 (Figure 2) include:

Fuel Cell Hangar (Bldg. 278);

Base Supply Complex (Bldg. 280);

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Hazardous Materials Pharmacy (Bldg. 281);

Hazardous Waste Central Accumulation Point (Bldg. 282);

Vehicle Maintenance (Bldg. 283);

Security Forces (Bldg. 284); and, Fire Department (Bldg. 286).

Storm water flows to storm drains and storm sewer piping and is then conveyed east through a 48-inch reinforced concrete pipe (RCP) to the city’s storm sewer, which drains south along Harbor Drive. Outfall #1 is located on the east property line where storm water leaves Base property through the city’s storm sewer. A spill control valve is located at Outfall #1.

There are no “industrial” activities associated with Drainage Area #2 (DA-2) and Outfall #2. This area consists of landscaped areas, paved roads and parking areas and a grass swale along Harbor Drive. Storm water mainly flows to a storm drain in the paved area, and also sheet flows into the grass swale.

“Industrial” activities associated with Drainage Area #3 (DA-3) and Outfall #3 are as follows:

Maintenance Hangar (Bldg. 261).

Outfall #3 discharges to the city storm sewer along Harbor Drive. Storm water flows to storm drains in the area.

There are no “industrial” activities associated with Drainage Area #4 (DA-4) and Outfall #4. This area consists of landscaped areas, paved roads and parking areas and grass swales along Harbor Drive and MacArthur Street. Storm water sheet flows into the grass swales and is conveyed to a pipe end and two storm drains that discharge at Outfall #4.

There are no “industrial” activities associated with Drainage Area #5 (DA-5) and Outfall #5. This area consists of landscaped areas, paved roads and parking areas and administrative buildings.

Storm water mainly flows to storm drains and is conveyed to the outfall.

There are no “industrial” activities associated with Drainage Area…