TE SW13 ISW.docx

TECHNICAL EXHIBIT SW13

INDUSTRIAL STORMWATER

1. The roads and grounds facility at 16th street is located inside the Industrial Stormwater Drainage Area Outfall 015. The permit requires stormwater sampling for constituents. The permit established benchmark concentration limits that cannot be exceeded. The Contractor shall ensure that the facility operates in compliance and such that benchmark concentration limits are not exceeded. The site and by the permit regulated operations shall be in compliance with the Industrial Stormwater Major Permit VA0092771 at all times.

2. The Contractor shall ensure that activities that any activities that will be carried out that fall under this permit and/or occur in drainage areas under this permit, must comply with all conditions of this permit, the Clean Water Act, and the Virginia State Water Control Law.

3. Stormwater Pollution Prevention Plan (SWPPP)

The permit requires that a SWPPP be established, followed and enforced. A SWPPP will be provided to the Contractor for the facility covered under this permit that shall implemented, as required in the permit, in order to reduce the pollutants in stormwater discharges at Fort Belvoir. The SWPPP provides guidance on control measures, Best Management Practices (BMPs) and other regulatory required actions by tenant organizations. The SWPPP is a “living document” and represents a guide to achieve compliance with regulatory requirements.

3.1 The contractor shall review, maintain and update the SWPPP regularly, at a minimum once yearly, based on the results of the Annual Comprehensive Site Compliance Evaluation. When deficiencies are encountered during an inspection, the SWPPP shall be reviewed and revised, if necessary, to address areas that have deficiencies. Any deficiency shall be rectified and/or addressed no later than 30 days from inspection. The SWPPP shall be also reviewed if:

a. There is construction or a change in design, operation, or maintenance at the facility.

b. Routine inspections or compliance evaluations determine that there are deficiencies in the control measures or BMPs.

c. Inspections by local, state, or federal officials determine that modifications to the SWPPP are necessary.

d. There is a spill, leak, or other release at the facility.

e. There is an unauthorized discharge from the facility.

f. The DPW notifies the tenant organization that a TMDL Action Plan was implemented or if benchmark exceedances of pollutants were detected.

g. If deficiencies were identified during the quarterly inspections and corrective actions must be completed to achieve compliance with the permit.

h. If there are mission changes or facility expansions anticipated or planned.

3.2 Copies of all quarterly visual compliance inspections, quarterly compliance inspections and annual inspections during rain events that were completed by the Contractor’s environmental Point of Contact (POC) and Annual Comprehensive Compliance Evaluation completed by the Directorate of Public Works (DPW) staff shall be completed and documented both in the facility SWPPP and the Master SWPPP at DPW. Corrective Actions that lead to changes of the SWPPP must be submitted to DPW for review and approval within 30 days of an inspection with the completed Record of Corrective Action Form. Any changes to the SWPPP must be maintained on site with the SWPPP with copies of any changes submitted to DPW for documentation in the master SWPPP copy maintained at DPW.

3.3 Routine Training shall be completed at least annually and a copy of the training records (sign in sheets and a copy of the training materials/slides) must be maintained in the SWPPP. Special training will be provided to each tenant organization’s Environmental POC. Each unit is required to keep DPW abreast of staff changes and provide seamless transition of Environmental POCs.

3.4 The SWPPP shall be kept up-to-date at all times. Updates to the SWPPP can include, but are not limited to the following: inspection reports, Record of Corrective Action forms, regulatory updates, maintenance records, spill reports, any illicit discharges, changes to practices resulting in up-dates to BMPs, Water Quality Sampling results (Chain of Custody and Certificate of Analysis) that show benchmark exceedances of constituents, and training records.

4. Site Assessment/Inspections

The Industrial Stormwater Major Permit #VA0092771 requires that Annual Comprehensive Site Compliance Evaluations (inspections) shall be completed by Fort Belvoir DPW staff, an annual facility inspection during a storm event shall be completed by Fort Belvoir DPW staff and completion of the Routine Facility Inspections quarterly that shall be completed by the trained Environmental POC of each tenant organization or facility operator.

4.1 All environmental POCs shall receive annual training for completing the routine facility inspections. The Contractor’s facility operators shall maintain sufficient trained staff to complete the quarterly inspections as required by the permit.

4.2 The quarterly Routine Facility Inspections shall be performed for the periods of January 1 through 30 March, April 1 through June 30, July 1 through September 30, and October 1 through December 31 as prescribed by the permit. For each Routine Facility Inspection, the Facility Stormwater Inspection Checklist, and the Quarterly Inspection form shall be used. The completed form shall be submitted to the Industrial Stormwater Program within DPW along with the completed Quarterly Facility Inspection Verification Form within two business days of completion of the inspection.

4.3 Completed corrective actions that were identified during the quarterly inspection shall be submitted within 30 days of the inspection. Provide to the Corrective Action Forms to DPW staff as indicated on the Quarterly Facility Inspection Verification Form.

4.4 If there are features or facilities that are in disrepair or require maintenance in close vicinity of the Contractor’s facility or uses such a facility, but the feature or facility is not under a specific units’ responsibility for maintenance or repair, the Environmental POC shall provide notice to the agency or unit that is responsible for maintenance and repair of this feature or facility and maintain records of the notification or work order request in the SWPPP.

5. Record Keeping

This permit imposes extensive record keeping requirements. The Environmental POC and the tenant organization’s commander are responsible to meet the record keeping and reporting requirements under this permit. Records shall be easily locatable, complete and kept in an organized manner. The reporting shall be completed on time and complete to ensure permit compliance. Each tenant organization is subject to inspections by DPW staff, the Army Environmental Command and regulatory agencies such as the Virginia Department Environmental Quality and the U.S. Environmental Protection Agency. Inspection of the records such as the updated SWPPP, facility maintenance records, training records, inspection forms and corrective action of deficiencies documentation shall be readily available for inspections.

6. Facility Maintenance

The permit requires in Part II.Q, Proper Operation and Maintenance, that “the permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed by the permittee to achieve compliance with the conditions of this permit.” This requires that each tenant organization ensures that wash racks, Oil-Water separators, containment BMPs, outdoor storage facilities, etc. are in good working order and regularly inspected and maintained as required. If deficiencies are observed and a tenant organization is not responsible for the maintenance activities, then the proper channels must be notified to initiate and complete any required maintenance activities. The DPW Industrial Stormwater Program shall also be notified (provide service order or IJO number, date when the issue was discovered and action(s) taken) and receive periodic updates and when the work has been completed.

7. Reporting Requirements

The permit has a host of reporting requirements, however, the tenant organizations or facility operators will be responsible for the following:

a. Spills shall be reported in accordance with the established spill response procedures.

b. The tenant organization or facility operator shall immediately report noncompliance activities which may adversely affect state water or may endanger public health.

c. The tenant organization or facility operator shall notify the Industrial Stormwater Program regarding any staff changes as to environmental POCs or contact information.

d. The Contractor shall be responsible for evaluating and reporting any contributing or primary sources of constituents when a benchmark exceedance(s) have occurred and propose a corrective action plan to eliminate or substantially reduce the constituent source that led to benchmark exceedance(s) at the roads and grounds facility at Industrial Stormwater Outfall 015. The corrective action plan must be submitted to the Industrial Stormwater Program for review and approval within 14 working days of the notification. The Industrial Stormwater Program will make notification of exceedances(s) to the respective tenant organizations or facility operators.

e. Provide notice of any mission changes that may affect the permit in advance (as much as possible) and any facility expansion activities at the on-set of the project.

f. Any activity that has occurred or will occur which would result in the discharge, on a routine or frequent basis, or on a non-routine or infrequent basis of a toxic pollutant.

g. Any use of deicing and anti-icing chemicals used during prescribed, routine operations must be documented, reported monthly to the Industrial Stormwater Program, and available for review and submission to the regulatory agency (VADEQ), which includes the date of use, the chemical, and the total volume used. Note: for aircraft deicing activities, 60% or more of the spent product must be recovered and documentation provided to Industrial Stormwater Program.

8. Substances and non-stormwater discharges that are not authorized

The permit specifically prohibits the use of and specific non-stormwater discharges. The tenant organizations must be mindful and shall comply with the following:

a. The use of Ethylene Glycol and Urea are prohibited. No products containing Ethylene Glycol or Urea shall be used for any reason.

b. Discharges of stromwater from areas where there may be contact with chemical formulations sprayed to provide surface protection.

c. Inks, paints, or substances (hazardous, nonhazardous, etc.) resulting from an on-site spill, including materials collected in drip pans, washwaters from material handling and processing areas, washwaters from any aircraft/facility/vehicle, or washwaters from drum, tank, or container rinsing and cleaning.

d. Leachate, gas collection condensate, drained free liquids, contaminated groundwater, laboratory derived wastewater and contact washwater from washing trucks, equipment, and surface areas that have come in direct contact with solid waste at a landfill facility.

e. Vehicle, aircraft, equipment, or surface washwater, including tank cleaning operations.

f. Bilge and ballast water, sanitary wastes, pressure wash water, and cooling water originating from vessels.

g. Aircraft, ground vehicle, runway and equipment washwaters, and dry weather discharges of deicing and anti-icing chemicals. Any use of deicing and anti-icing chemicals during must be documented as per Section 7.g.

9. The Contractor shall provide qualified staff at all times to perform oversight on activities that are regulated under this permit.