8030 Appendix T4
Storm Water Management
Jefferson Lab storm water runoff flows naturally from the site, without treatment, through storm drains, culverts, drainage channels, etc., eastward into Brick Kiln Creek and the Chesapeake Bay, and westward into Deep Creek, which flows to the James River. Jefferson Lab ensures, to the maximum extent practicable, that storm water runoff from the site will not affect people and other living organisms, erode property, or negatively impact the Bay or the James River. The storm water management program is designed to implement and satisfy the requirements contained in the following:
This chapter summarizes the specific requirements listed above and references more detailed instructions, in the form of Reference, Appendices, and other ES&H Manual chapters where applicable. This chapter is also considered the site’s Municipal Separate Storm Sewer System (MS4) Storm Water Management Plan and also discusses some general storm water management program aspects that are not captured elsewhere.
The MS4 permit program is the result of the 1987 amendments to the Clean Water Act (CWA), commonly referred to as the Water Quality Act of 1987. In these amendments, Congress mandated that the Environmental Protection Agency (EPA) address non-point source pollution in storm water runoff. In essence, EPA defined urban storm water (previously considered a non-point source) as a point source because there was a physical location (or point) of discharge. In response to the Congressional action, EPA was required to develop a program to permit the discharge of the storm water from small municipal separate storm sewer systems (MS4), from specific industrial activities that it considered to be significant sources of pollution, and from construction site runoff.
To comply with the permit, Jefferson Lab addresses six obligatory Minimum Control Measures (MCMs) as implemented by 20 specific Best Management Practices (BMPs) and associated measurable goals. The MCMs are:
1. Public Education and Outreach on Storm Water Impacts
2. Public Involvement/Participation
3. Illicit Discharge Detection and Elimination
4. Construction Site Storm Water Runoff Control [disturbance of 5,000 SF or more]
5. Post-Construction Storm Water Management in New Development and Redevelopment
6. Pollution Prevention/Good Housekeeping for Municipal Operations
MS4 permit requirements are implemented through two documents:
Reference: ES&H Manual Chapter 8030 Appendix R2 Best Management Practices Under Permit No. VAR040079 provides specific requirements associated with the MCMs and BMPs.
Reference: ES&H Manual Chapter 8030 Appendix R3 MS4 Program Plan – General Permit No. VAR040079, documents Jefferson Lab’s performance against the MCMs and BMPs. For each BMP (and its associated measurable goals), the following information is provided:
· Implementation documentation
· Responsible organizational element(s)
· Objective(s) and results
· Schedule and milestones
· Effectiveness assessment methodology
Storm water protection during construction activities is addressed under the MS4 permit (2.1) and further regulated for larger projects under this existing permit. The key element of this permit is the requirement for a site-wide Storm Water Pollution Prevention Plan (SWPPP) which covers site-wide construction activities that affect one or more acres. Construction subcontractors adhere to the permit requirements by adhering to their approved project-specific Environmental Protection Plan. Any smaller construction activities not covered under the existing SWPPP (from 5,000 SF up to one acre) require a project-specific Erosion & Sediment Control (E&SC) Plan and/or the job-specific E&SC requirements described in the project scope or specifications.
2.3 Department of Energy (DOE) Order 450.1A, Environmental Protection Program and DOE Order 5400.5, Radiation Protection of the Public and the Environment
The Storm Water Management Program also satisfies requirements of DOE Orders 450.1A and 5400.5:
· Surface Water protection is implemented via a watershed approach (MS4 Permit requirements).
· Beneficial landscaping practices are incorporated to protect storm water (ES&H Manual Chapter 3110 Facility Design and Modification Review).
· Environmental monitoring is provided to detect and characterize pollutant releases, estimate dispersal patterns, characterize exposure pathways, and evaluate any impact on biota from releases from the Lab (ES&H Manual Chapters 8011 Environmental Monitoring Program, ES&H Manual Chapter 8030 Water Quality and Conservation Program, and ES&H Manual Chapter 8030 Appendix T3 Groundwater Protection).
· Minimizing the use of toxic chemicals and associated releases of pollutants to the environment that would otherwise require control, treatment, monitoring, and reporting (ES&H Manual Chapter 8070 Waste Minimization and Pollution Prevention (WMin/P2) Program).
· Any releases of radioactive constituents are to be performed under the ALARA principle: As Low As Reasonably Achievable. Waters with known activity are handled through the facility’s permit with the local wastewater treatment system; no activity is knowingly released to surface waters (ES&H Manual Chapter 8030 Water Quality and Conservation Program).
2.4 Virginia Erosion & Sediment Control Handbook
Reference Appendix EPS-33-T1 E&SC Criteria for Land Disturbing Activities, outlines the storm water management program requirements for planning any activities disturbing lands within the Jefferson Lab boundaries. Activities disturbing greater than 1 acre have additional requirements as discussed in Section 2.2 of this chapter.
Persons responsible for implementing, coordinating, or providing oversight of the Jefferson Lab Storm Water Management Program include:
See references for specific responsibilities.
In addition to the requirements referenced above, there are general requirements that should be implemented, where applicable, to ensure compliance with storm water protection elements is maintained.
4.1 Define the Scope of Work
Before you start any activity or task that could affect surface water, ensure that all the elements of work, whether a routine, repetitive task or a special project, are clearly defined, including the individual tasks, the schedule, associated work control documents, and any applicable lessons learned. Ensure you have considered the effects for setting up, performing the work, clean up, proper management of discarded materials, and restoring the work area to its proper condition. Examples associated with storm water include:
· Improper application to the ground of agents that could contaminate storm water, e.g., detergents, herbicides, and pesticides.
· Outdoor transfer or use of oil products or chemical solvents, cleaners, degreasers, rust removers, and similar products.
· Removal of ground cover or excavation activities.
You must have prior authorization to discharge materials, including water from any processes, to the surface or a storm drain. If you have a proposed discharge that would end up in the site surface channel system that is not covered in a permit or other approved authorization, contact Facilities Management & Logistics for authorization to discharge.
4.2 Analyze the Hazards
Recognizing the potential hazards inherent in each work element ensures that comprehensive hazard controls can be devised and properly applied. Items that could cause impacts to surface water (e.g. hazards to water quality) might include silt, oils, chemicals, detergents, and other potential storm water pollutants.
4.3 Develop and Implement Hazard Controls
Depending upon the scope of your project, ESH&Q may require the use of storm water hazard controls. Some examples include:
· Use of drop cloths when handling or using oils and chemicals in open, unprotected areas;
· Substitution of environmentally friendly solvents for those which are deemed potential pollutants;
· Careful storage of oils and chemicals awaiting disposal (covered storage or storage within secondary containment);
· Use of erosion and sediment control measures, such as silt fencing, when ground is disturbed;
· Seeding as soon as practical to stabilize ground cover following a disturbance;
· Monitoring and control programs for detection and response.
4.4 Perform Work Within Controls
All anticipated discharges will be governed through work control documents. Spill Prevention, Control and Countermeasure requirements will be applied, including prompt cleanup and disposal of spillage and restoration of the affected area (see Emergency Management Plan).
4.5 Provide Feedback and Continuous Improvements
By monitoring work progress, analyzing problems, and looking for better and safer alternatives, the program of continual improvement is enhanced. Lessons learned can be subsequently incorporated into the scope of future work so that the system prevents the recurrence of problems from the past. Examples might include:
· Substitution of non-toxic or less hazardous substances for pollutants that pose a threat to storm water. A hazardous substance spill, for example, can be a safety and health threat, as well as storm water contaminate and could potentially contaminate local creeks and the Bay. Therefore, efforts from a chemical hygiene perspective to minimize hazardous substance inventories and apply restrictions to their use will also benefit Jefferson Lab by minimizing risks of impacts covered under this (MS4) Storm Water Management Program.
· Improved storage arrangements for hazardous and other environmentally harmful substances;
· Permanently curbed, paved, and separately drained work areas where hazardous substances are used.
· Jefferson Lab requires that lessons learned about the storm water management program be recorded in accordance with its Lessons Learned Program.
Laws and Regulations:
State Water Control Law
Virginia Erosion & Sediment Control Handbook, 3rd Edition 1992
Laboratory Programs and Plans:
ES&H Manual Chapters:
DOE and Executive Orders:
DOE O 5400.5 Radiation Protection of the Public and the Environment DOE O 5400.5 Chg 2
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