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HomeMy WebLinkAboutNCS000335_04_Illicit Discharge and Elimination PlanSeymour Johnson AFB IDDE- Illicit Discharge Detection and Elimination Plan July 31, 2020 1r1:1gBE0 W1411WIIWNV 1.0 Objectives of the Illicit Discharge Program ............................................. 2.0 National Pollutant Discharge Elimination System Permit NCS000335.. 3.0 Community Outreach............................................................................... 4.0 Dry Weather Field Screening................................................................... 4.1 Sanitary Sewer Overflow Procedures 4.2 Sanitary Sewer Overflow Reporting 5.0 GIS Storm Water Distribution Map ......................................................... 6.0 Structural Defects..................................................................................... 7. Enforcement Actions.................................................................................. 8.0 Documentation............................................................ .. 1 2 ........................................3 ............. ............ ..3 3 ....... ...... 4 .......................................... 5 .......... 5 6 1.0 Obiectives of the Illicit Discharge Detection and Elimination Program (IDDE) — (NPDES Permit - NCS000335, Section D) Storm water runoff from developed land on a military base can harm surface water resources by changing natural hydrologic patterns and elevating pollutant concentrations and loadings. Storm water runoff may contain or mobilize high levels of contaminants, such as sediment, suspended solids, nutrients, heavy metals, oils, fuels, and pathogens. Pollutants from cross -connections (sanitary pipes or drains connected to storm) can be a harmful source of illicit discharges. The base National Pollutant Discharge Elimination System (NPDES) Permit NCS000335 (Section D) requires SJAFB to detect and eliminate illicit discharges to storm water on SJAFB. Most of the objectives for SJAFB IDDE are spelled out in its NPDES permit. A summary of objectives for the storm water illicit discharge program is to: • Enforce the illicit program to detect, address, and eliminate discharges and illegal dumping into the SJAFB Stormwater Distribution System (AFI 32-1067) • Prohibit non-stormwater discharges into SJAFB (NCS000335, SPCC, and SWP) • Develop written procedures for conducting investigations and sanitary sewer overflows • Track all investigations and document dates of illicit discharges • Inform employees and train personnel who may come into contact with illicit discharges and the hazards of illicit discharges and illegal disposal of waste • Address illicit or non-stormwater discharges that are not excluded by NCS000335 The IDDE Plan is managed by the 4th Civil Engineering Squadron / Environmental Element. Essentially, an illicit discharge is any non-stormwater discharge to the storm sewer that is not specifically authorized under a separate permit or NCS000335 (Part I (7)). The United States Environmental Protection Agency defines an illicit discharge as, "any discharge into a storm drain system that is not composed entirely of stormwater." This means that anything other than simply the water that falls from the sky is an illicit discharge. Seymour Johnson AFB IDDE- Illicit Discharge Detection and Elimination Plan July 31, 2020 Examples of illicit discharges include (but are not limited to) the following: • Runoff from improperly stored materials • Improper disposal of vehicle maintenance fluids or household chemicals into a storm drain inlet • Leaking dumpsters flowing into a storm drain inlet • Old or damaged sanitary sewer line leaking fluids into a cracked or damaged storm sewer line • Allowing wash water with soaps or detergents to discharge to a storm drain inlet • Washing or depositing silt, sediment, concrete, cement or gravel into a storm drain inlet • Oil or Fuel Spills resulting from vehicle or aircraft accidents • Foam solutions from firefighting testing and training exercises. • Sanitary sewer piping connected directly from a building to the storm drainage system or SSOs • A shop floor drain that is connected to the storm water drainage system. Notel: SJAFB equipment or vehicle washing must be conducted inside or at authorized car wash station that discharges the wash water to the sanitary sewer. Corvia Residential Guide requires vehicle maintenance to be completed at the auto hobby shop or at service stations - not in base housing. SJAFB has two dog parks for residents. Pickup after your pets. The Rule: AFI 32-1067 requires that wastewater and stormwater discharges associated with industrial activities must be permitted as required by applicable NPDES regulations. Ordinance: Section 4.3.1.4 of the AFI requires Air Force installations to conduct cross -connections and illicit discharge inspections, elimination, construction, or repair. 2.0 National Pollutant Discharge Elimination System Permit (NPDES) NCS000335 requires: • SJAFB maintain a map of the storm sewer system and major outfalls (Located on GIS). • Detect dry weather flows (Biannual Qualitative Analysis, CEI Inspections, UEC Inspections, Construction Site Manager Inspections) • Investigate source of identified illicit discharges (Contractors, Utility Shop, Grounds Maintenance, CEO, CEI, UEC) • Employee Training — Illicit Discharge Training provided annually (slides, bulletins, emails). Illicit discharge training slides are provided to UECs and base personnel to help identify, detect, and report illicit discharges. Training slides can be found on EDASH: https://cs2. eis. afniil/sites/ 10623/Seymour/Shared%20Documents/Environmental%20Documents/Water%20Quality/2020 %20I11icit%20Dischar,ge%20Training.pdf • Inform employees and businesses of hazards of illegal discharges. Newsletters on EDASH: https://cs2.eis.af mil/sites/10623/Seymour/Shared%2ODocuments/Environmental%2ODocuments/Water%20Qualiiy/2020 %20 Storm%2OWater%20Plan%20(S WP)/2020%20JULY%20NEW SLETTER%2022juLY20.ppt?Web=1 • Reporting — For oil spills and illicit discharges contact the base Fire Department (SPCC) and 4' CES/CEI. Contact 4' CES/CEI for any non-stormwater or illicit discharges — 7822-5168. • Stormwater (Course # SWM100AFIT00026) and Spill Response Awareness Training (COURSE # POL100AFIT00014) provide through "Teach" — hLTs://usaf.leaminjzbuilder.com/account/login/?RetumUrl=%2F. 2 Seymour Johnson AFB IDDE- Illicit Discharge Detection and Elimination Plan July 31, 2020 3. Community Outreach: Effective promotion and publication of the base IDDE prohibition policy and methods for illicit discharge detection are an integral part of the IDDE Program for SJAFB. Outreach initiatives that SJAFB conducts include: • Operation and publication of an illicit discharge hotline - 4th CES/CEI 722-5168. For Oil or Fuel Spills contact the Fire Department • Storm drain marking activities via contracts in base housing. *IDDE Awareness Info in SJAFB Biannual Environmental Storm Water News Bulletin • Educational signs are posted at various facilities (e.g., outfalls, dog parks, etc.) regarding illegal dumping. • Clean Water Education Partnership Facebook and Videos. • EMS Cross Function Team (CFT) Meetings • Environmental, Safety, and Occupational Health Council (ESOHC) Meetings • Storm Water Pollution Prevention Team Comment/Review Meetings • Adopt -A -Highway Program • Stormwater Bulletins • EDASH Stormwater Webpage 4.0 Dry -Weather Field Screening: Dry -weather field screening of storm water outfalls is an effective method of detecting illicit discharges to the storm water system. Some of the base outfall screening is completed by contractor BHATE/ZAPATA twice a year. Internal Inspections are performed by CEI personnel. Reports are kept in Appendix E of the SWP. SJAFB has 10 industrial outfalls and 3 representative major outfalls that must be inspected biannually (NCS000335- Section J). These outfalls discharge to various receiving water bodies on SJAFB including Hospital Creek, Golf Course Lake, Burge Ditch, Stoney Creek, Mayfield's Ditch, and Prison Ditch. During outfall screening, the contractor will visually inspect each major outfall and the immediate surrounding area, photograph the current conditions, and complete a Dry -Weather Outfall Screening Form provided in Appendix E. Special attention will be paid to major outfalls that are flowing when no rain has occurred within the last 48 hours and/or outfalls where foul odors or discolored water is noted. When the screening of an outfall indicates a potential illicit discharge, the SJAFB Water Quality Program Manager will be notified by contractor immediately or at least within one business day. Contractor is required to look upstream to identify (if possible) source of illicit discharge. Base personnel will also use base stormwater maps, dye testing, or pull manhole covers to search for illicit discharges. Any identified oil/fuel spills or conditions that represent a serious threat to personnel safety or equipment damage will be reported to SJAFB Fire and Emergency Services IAW SPCC Plan. 4' CES/CEI will report oil spills within 24 hrs to the Washington Regional Office — [(252)946- 648 1 ] [(or NC Emergency Management if after normal business hrs — (800)858-0368)] for any spill greater than or equal to 25 gallons; Any spill that has a sheen on state surface waters; Any spill within 100 feet of state surface waters; and, Any spill less than 25 gallons that cannot be cleaned up within 24 hrs. 4.1 Sanitary Sewer Overflow Procedures. SJAFB will follow NC procedures and reporting for any sanitary sewer overflows (SSO). Contact CE Customer Service 722-5397 if you suspect or see any sewer overflows. State contacts will be notified and reports will be made by 4` CES/CEI. Reports will made as soon as possible but no less than 24 hours. LECs or shop personnel who discover illicit cross -connections in streams or ditches near their locations will contact the 4m CES/CEI office — 722-5168. 4.2 Sanitary Sewer Overflow Reporting. A reportable SSO is a SSO greater than 1,000 gallons to the ground or a SSO of any amount that reaches surface water (includingthrough ditches, storm drains, etc). Below is the procedure to use for reporting SSOs to the Division. Seymour Johnson AFB IDDE- Illicit Discharge Detection and Elimination Plan July 31, 2020 Report by telephone to a Division of Water Quality staff member (not facsimile or voicemail) at your regional DWQ office during regular business hours (Monday to Friday, 8AM to 5PM) as soon as possible, but in no case more than 24 hours after the SSO is known or discovered. Address: 943 Washington Square Mall, Washington, NC 27889. Phone: 252-946-6481. o To report outside of regular business hours, call (800) 858-0368. o Follow up the verbal report by sending a completed written report on the most current Division approved form within five days. o A new spill reporting form has been developed (October 2003). Form CS-SSO consists of two parts. Part I serves to provide to the Division the required information that has always been necessary. Part II serves as an area to provide a justification for the spill, as optional under Condition I (2) of your permit. Form CS- SSO can be downloaded from https:Hdeq.nc.gov/about/divisions/water- resources/water-resources-permits/wastewater-branch/collection-systems/sewer- system-overflow-documents from the SSO Reporting area. o To estimate sewer amounts use this guidance doc: htlps://files.nc. aov/ncdeq/\Vater%20Qualijy/Surface%2OWater%2OProtection/PERC S/W C S%20%28 S SO%20Documents%29/S SOF1owEstimationGuideREVI.pdf o Please be prepared to provide information related to your facility, such as Permit Number, Owner Name, Contact Name, Contact E-mail and Telephone Number. 5. The GIS Stormwater Distribution System Map is shown in Figure 5.1. The SJAFB GIS Stormwater Distribution System Map is maintained by the GEOBASE Office and 4t' CES/CEI Office. Seymour Johnson AFB has a network of piped and open -channel storm water drainage systems that collect and transport rainfall runoff on the installation. The storm water drainage system consists of approximately 50 miles of drainage pipe which collects and empties storm water into nearby surface water bodies through a system of outfalls. Of the 50 miles of drainage pipe, 20 miles of pipe are associated with Military Family Housing (MFH). The distribution system mapping displays oil water separators, two detention ponds, one green roof, catch basins, streams, ditches, industrial areas, and major outfalls. Base permitted streams and ditches include Burge Ditch, Hospital Creek, Prison Ditch, Golf Course Lakes (3), and Mayfield's Ditch. A Stormwater Asset Inventories and Condition Assessment Study Project was completed 5 May 2010 to confirm the connectivity of the base mapping system, assess the condition of selected storm water system assets on SJAFB, and complete a deficiency report. The data from this study was used to program future work to fix defects in structural storm water assets (pipes, manholes, etc.). 4 Seymour Johnson AFB IDDE- Illicit Discharge Detection and Elimination Plan July 31, 2020 Figure 5.1 Storm Distribution Map �, u xw i�a,awu r�vc 6. Structural Defects: Structural issues or defects will sometimes require a construction action to eliminate the illicit discharge. Repair projects for structural issues should be initiated through completion of a service order request to the 4th CES/CEO Service Order Desk. The 4th CES/CEO will determine whether the issue can be addressed with a service order or whether an AF Form 332, Base Civil Engineer Work Request, will be required. Funding for the repair will be determined once the work request has been submitted and reviewed by 4' CES/CEO. Repair work can be completed either in-house by the CES Heavy Repair Shop or by contract. Current projects investigating or repairing stormwater structural controls include project VKAG 15-1040 - Repair Stormwater System Base -wide, VKAG 19-7005 - Streambank Stabilization, and VKAG 18-1099 - Illicit Cross -connections at Buildings 4531 and 4533. 7. Enforcement Actions: Illicit discharge or illegal dumping to the storm water system is prohibited by various SJAFB AFIs, policies, and instructions. Prohibition is also addressed through contract language for contractors performing work on base. Corrective actions focus first on education to promote voluntary compliance and escalate to increasingly severe enforcement actions if voluntary compliance is not obtained. The SJAFB community is comprised of military and civilian personnel and residents and enforcement actions associated with illicit discharges will depend on the organization of the responsible party or parties. SJAFB will generally follow a step enforcement action policy for confirmed illicit discharges; however, more serious violations or continued, egregious non-compliance may warrant a more aggressive approach. Violations of State Water Quality Rules and Regulations can result in penalties (oil and hazardous waste) up to $5,000 per day. Illegal discharges carry up to $25,000 per day. Actions conducted under each enforcement step include stop work orders issued by 4t1i CES/CEN or further penalties issued by base Contracting Office. More serious actions may call for removal from base for contractors; and, or loss of housing lease for residents in base housing. Seymour Johnson AFB IDDE- Illicit Discharge Detection and Elimination Plan July 31, 2020 8. Documentation: Record keeping is an important component of the illicit discharge elimination process. Qualitative Analysis Reports (State forms SWU-242) and the Non -Storm Water and Illicit Discharge Survey are kept with the Storm Water Plan in the CES/CEI Office. Internal storm water inspections are kept by the Water Quality Manager. Spill reports are documented and tracked by 4t' CES/CEI using the base GIS mapping and the Air Force EASIER Website. Unit Environmental Coordinators are required to be involved for any spills that involve their organizations. 4t' CES/CEN maintain contract documents and folders on projects involving structural fixes to cross -connections in buildings or drains. Biannual Storm Water News Bulletin is provided to the base for awareness of illicit discharges and what people can do to prevent those discharges. Operations and maintenance of the stormwater distribution system is tasked to 4t' CES/CEO Heavy Repair. 8.1 EASIER Website EASIER — Spills June 2019 • EASIER (Enforcement Actions, Spills, and Inspections Environmental Reporting) is the Total Air Force's centralized database to report, track, and analyze environmental events, including enforcement actions (EA), spills, and inspections. This user guide provides instructions on how to manage spills in EASIER. • Contents include: • Spill Process • Adding a New Spill Event • Navigating Spill Details • Tab Icons • Points of Contact (POCs) • Updati ng Coordinates Using the Map • Materials • AF Reportable Quantities • Release Details • External Communications • Attachments • Related Events • Corrective Actions • Notifications History/Updates • Submitting and Closing a Spill • Marking a Spill as "Read and Received" • Reporting a Spill to HAF • Re-Qpenine a Spill Event • Deleting a Spill Event • Reportable Spill Email Notifications • Non -Reportable Spill Email Notifications • Additional Information SPILL-001074 (Pending Submittdl) kafolletion U=« —COI.i Sh.tc rn,.n fwonc Sub La<.rtiorc 9tandi a mod. 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