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8030
Appendix T4 Storm
Water Management |
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1.0
Purpose
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.
2.0
Scope
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.
3.0
Responsibilities
Persons responsible for implementing, coordinating,
or providing oversight of the Jefferson Lab Storm Water Management Program
include:
See
references for specific responsibilities.
4.0
Expectations
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.
5.0
References
Permits
Laws and Regulations:
State Water Control Law
Virginia
Erosion & Sediment Control Handbook, 3rd Edition 1992
Laboratory Programs and Plans:
Jefferson
Lab Storm Water Pollution Prevention Plan
ES&H
Manual Chapters:
8030 Appendix R2 Best
Management Practices Under Permit No. VAR040079
8030
Appendix R3 MS4 Program Plan – General Permit No. VAR040079
DOE and
Executive Orders:
DOE
O 450.1A, Environmental Protection Program
DOE
O 5400.5 Radiation Protection of the Public and the Environment DOE
O 5400.5 Chg 2
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ISSUING
AUTHORITY |
TECHNICAL POINT-OF-CONTACT |
APPROVAL
DATE |
REVIEW
REQUIRED DATE |
REV. |
Page 1 of 7 |
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ESH&Q Division |
04/28/09 |
04/28/12 |
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