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  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN FORT MONROE AUTHORITY TABLE OF CONTENTS

    i

    SWMP CERTIFICATION ................................................................................. III

    1. INTRODUCTION ................................................................................... 1-1 1.1 FACILITY DESCRIPTION ..................................................................... 1-1 1.2 GENERAL ...................................................................................... 1-22 1.3 ALLOWABLE DISCHARGES UNDER THE MS4 GENERAL PERMIT ............. 1-2

    2. TOTAL MAXIMUM DAILY LOAD .......................................................... 2-4

    3. MINIMUM CONTROL MEASURES AND BEST MANAGEMENT PRACTICES ................................................................................................. 3-1

    3.1 PUBLIC EDUCATION AND OUTREACH ON STORMWATER IMPACTS .......... 3-2 3.1.1 Newspaper/Bulletin Articles ................................................ 3-2 3.1.2 Website and/or Facebook Page ......................................... 3-3

    3.2 PUBLIC INVOLVEMENT AND PARTICIPATION ......................................... 3-3 3.2.1 Storm Drain Marking ........................................................... 3-5 3.2.2 Environmental Awareness Events ...................................... 3-6

    3.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION ............................... 3-6 3.3.1 Illicit Discharge Survey and Removal ................................. 3-7 3.3.2 Stormwater Map ................................................................. 3-7 3.3.3 Public Education ................................................................. 3-8

    3.4 CONSTRUCTION SITE STORMWATER RUNOFF CONTROL ...................... 3-8 3.4.1 Erosion and Sediment Control Policy/ Construction Permit

    Requirement ....................................................................... 3-9 3.4.2 Review of Erosion and Sediment Control Plans ............... 3-10 3.4.3 VSMP Construction General Permit Policy ....................... 3-10 3.4.4 Inspection ......................................................................... 3-11 3.4.5 Tracking Land Disturbing Activities ................................... 3-11

    3.5 POST-CONSTRUCTION STORMWATER MANAGEMENT IN NEW DEVELOPMENT AND REDEVELOPMENT .......................................... 3-11

    3.5.1 Post-Construction Runoff Control Policy/Construction Permit Requirement ..................................................................... 3-13

    3.5.2 BMP Inspection and Maintenance .................................... 3-13 3.5.3 BMP Tracking Program .................................................... 3-14

    3.6 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS .............................................................................. 3-14

    3.6.1 Pollution Prevention and Good Housekeeping Guidance . 3-15 3.6.2 Environmental Awareness Training Program .................... 3-16 3.6.3 Brochures and Posters ..................................................... 3-17

    4. EVALUATION AND ASSESSMENT ..................................................... 4-1 4.1 EVALUATION AND ASSESSMENT ......................................................... 4-1 4.2 RECORDKEEPING ............................................................................. 4-1 4.3 ANNUAL REPORT ............................................................................. 4-2

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN FORT MONROE AUTHORITY TABLE OF CONTENTS

    ii

    5. STORMWATER MONITORING ............................................................ 5-4

    A. GENERAL PERMIT REGISTRATION STATEMENT FOR STORMWATER DISCHARGES FROM SMALL MS4S AND GENERAL PERMIT

    B. STORMWATER SYSTEM MAP

    C. DISCHARGE MONITORING REPORT

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN FORT MONROE AUTHORITY SWMP CERTIFICATION

    iii

    SWMP CERTIFICATION

    I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

    Signature

    Designated Representative

    Fort Monroe Authority

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN FORT MONROE AUTHORITY SWMP CERTIFICATION

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  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 1 FORT MONROE AUTHORITY INTRODUCTION

    AH Environmental Consultants (original) 1-1 Last Revised August 8, 2014 107-03

    1. INTRODUCTION

    This Registration Statement (‘Registration Statement’) and stormwater Program Plan

    (‘Program Plan’) is for the Fort Monroe property owned by the Commonwealth of

    Virginia (CoVA) and managed by the Fort Monroe Authority (FMA). The Virginia

    Stormwater Program (VSMP) General Permit became effective on July 9, 2008 and

    ran for five year, being subsequently renewed. This Registration Statement and

    Program Plan were prepared to establish the basis for a permit for these lands to begin

    July 2014 under the new VSMP.

    The FMA expanded on documents initially by consulting engineers and environmental

    managers at AH Environmental of Newport News, VA. The Program Plan was updated

    following the June 2013 transfer of some of the lands at Fort Monroe from the U.S.

    Army to the Commonwealth of Virginia (~312.75 acres), the summer 2013 transfer of

    the VSMP program from the Virginia Department of Conservation and Recreation

    (DCR) to the Department of Environmental Quality (DEQ), and subsequent

    correspondence and meeting with between DEQ and the FMA.

    1.1 FACILITY DESCRIPTION

    Fort Monroe consists of approximately 565 acres of which 108 are submerged and 85

    are wetlands. Fort Monroe is located at the southeastern tip of the Virginia Lower

    peninsula between Hampton Roads to the southwest and the Chesapeake Bay to the

    east. Fort Monroe formerly served as U.S. Army Garrison Fort Monroe, a largely

    administrative post with few troop and industrial activities. In September 2011, the

    Army decommissioned Fort Monroe as an active Army base and transferred by

    quitclaim deed a portion of the lands at Fort Monroe to the Commonwealth of Virginia

    in June 2013 (~312.75 acres). The Fort Monroe Authority Act establishes the Fort

    Monroe Authority as responsible for the preservation, conservation, protection, and

    maintenance of the Commonwealth’s real property interests at Fort Monroe and the

    renewal of Fort Monroe as a vibrant and thriving community. Established as a US Army

    coastal fortification in 1817, Fort Monroe is built on the site of earlier colonial-era forts

    at Old Point Comfort. Fort Monroe is a registered National Historic Landmark.

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 1 FORT MONROE AUTHORITY INTRODUCTION

    AH Environmental Consultants (original) 1-2 Last Revised August 8, 2014 107-03

    1.2 GENERAL

    This Plan covers the Virginia Stormwater Management Program (VSMP) requirements

    for the Fort Monroe property. Fort Monroe is designated as small municipal separate

    storm sewer system (MS4) under the Virginia Department of Environmental Quality

    (DEQ) VSMP.

    This Plan details a comprehensive program to minimize stormwater pollution by

    establishing best management practices (BMPs), measurable goals, and responsible

    parties to achieve compliance with the minimum control measures of the Phase II

    VSMP. The BMPs utilized to address each minimum control measure are described in

    this Plan. Operators of small MS4s covered under the general permit that continue to

    discharge must file a “General Permit Registration Statement for Stormwater

    Discharges from Small MS4s” (which is included in Appendix A) for continued

    coverage. A stormwater system map depicting the area to be covered by the general

    permit is included in Appendix B.

    1.3 ALLOWABLE DISCHARGES UNDER THE MS4 GENERAL PERMIT

    All discharges that are not completely comprised of stormwater runoff are not allowed

    under the MS4 General Permit except where discharges have been identified by the

    FMA, or the State Water Control Board as not a significant source of pollution.

    Discharges included by the General Permit as not significant sources of pollution

    include;

    Water line flushing

    Landscape irrigation

    Diverted stream flows

    Rising ground water

    Uncontaminated ground water infiltration

    Uncontaminated pumped ground water

    Discharges from potable water sources

    Foundation drains

    Air conditioning condensation

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 1 FORT MONROE AUTHORITY INTRODUCTION

    AH Environmental Consultants (original) 1-3 Last Revised August 8, 2014 107-03

    Irrigation water

    Springs

    Water from crawl space pumps

    Footing drains

    Lawn watering

    Individual residential car washing

    Flows from riparian habitats and wetlands

    Dechlorinated swimming pool discharges

    Street wash water

    Discharges or flows from firefighting activities

    De minimis flows, as identified in writing by the Department of Environmental

    Quality, as not being a significant source of pollutants to state waters and not

    requiring a VPDES permit.

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 1 FORT MONROE AUTHORITY INTRODUCTION

    AH Environmental Consultants (original) 2-4 Last Revised August 8, 2014 107-03

    2. TOTAL MAXIMUM DAILY LOAD

    The Chesapeake Bay total maximum daily load (TMDL) was published on December

    29, 2010 based on the Watershed Implementation Plans (Phase I) submitted by the

    states that are contained in the Chesapeake Bay watershed. The TMDL is written for

    excessive nitrogen, phosphorus, and sediment. The TMDL established waste load

    allocations (WLA) for each of the subject pollutants for the major rivers and

    watersheds that discharge in the Chesapeake Bay. Virginia has written a Watershed

    Implementation Plan (Phase II) that includes WLAs for specific sections of the major

    rivers in the state that discharge to the Chesapeake Bay. The Virginia Phase II WIP

    was submitted in the draft stage to the EPA on March 30, 2012. It has not yet been

    finalized. FMA will develop an action plan for reduction of TMDLs by 2018 in year five

    of the VSMP

    It is not calculated at this time WLAs for nitrogen, phosphorus, and total suspended

    solids based on the location of Fort Monroe in conjunction with the Chesapeake Bay

    TMDL WLAs. This calculation will be made as a part of the development of the Fort

    Monroe Authority TMDL Action Plan which will be submitted with the Annual Report

    detailing actions undertaken during the 2014-2015 permit year no later than October

    10, 2015. The TMDL Action Plan will identify the current loading for nitrogen,

    phosphorous and total suspended solids, the allowable loading in accordance with

    Virginia’s allocation to regulated MS4s and the means and methods for achieving a

    5% reduction of these loads by the end of this permit term in 2018. The Action Plan

    will also identify the goals and strategies intended to be incorporated into future

    program plans to achieve an additional 35% of the required reduction in the second

    consecutive permit term and the final 60% required reduction by the end of the third

    consecutive permit term.

    This MS4 Program Plan will be updated at the conclusion of the development of the

    Action Plan to include measureable goals, schedules, and strategies to ensure MS4

    Program consistency with the assumptions of the assigned WLAs, as per General

    Permit Number VAR04 Section I. B. 1.

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 2 FORT MONROE AUTHORITY MINIMUM CONTROL MEASURES & BEST MANAGEMENT PRACTICES

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    3. MINIMUM CONTROL MEASURES AND BEST

    MANAGEMENT PRACTICES

    Fort Monroe Authority, as an operator of a small MS4, will develop, implement, and

    enforce a MS4 Program designed to reduce the discharge of pollutants in the storm

    water to the maximum extent practicable. This is done to protect water quality, to en-

    sure compliance with water quality standards, and to satisfy the appropriate water qual-

    ity regulations and requirements of the Clean Water Act.

    The General Permit requires best management practices (BMPs) and measurable

    goals be established in six minimum control measures. These minimum control

    measures are;

    1. Public education and outreach on stormwater impacts,

    2. Public involvement/participation,

    3. Illicit discharge detection and elimination,

    4. Construction site stormwater runoff control,

    5. Post-construction storm water management in new development and redevel-opment, and,

    6. Pollution prevention/good housekeeping for municipal operations.

    BMPs are measures used to prevent or reduce the potential of pollution from any type

    of activity. BMPs are a very broad class of measures and may include processes, pro-

    cedures, scheduling activities, prohibitions on practices, and other management prac-

    tices to prevent or reduce stormwater pollution. In essence, they are anything that may

    be identified as a method, short of actual treatment, to reduce stormwater pollution.

    The following sections outline the FMA BMPs and goals in the six minimum control

    measures as required in the General Permit. A summary schedule is provided at the

    end of this section.

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    3.1 PUBLIC EDUCATION AND OUTREACH ON STORMWATER IMPACTS

    The General Permit requires that the FMA implement a public education program to

    distribute educational materials to the community or conduct equivalent outreach

    activities about the impacts of stormwater discharges on water bodies and the steps

    that the public can take to reduce pollutants in stormwater runoff.

    The goals outlined for this minimum control measure include;

    Increased individual and household knowledge about the steps that they can take to reduce stormwater pollution.

    Increased public employee, business, and general public knowledge of hazards associated with illegal discharges and improper disposal of waste, including pertinent legal implications.

    Increased individual and group involvement in local water quality improvement initiatives including the promotion of local restoration and cleanup projects, programs, groups, meetings and other opportunities for public involvement.

    Create diverse strategies to target audiences specific to the areas serviced by the small MS4.

    Improved outreach program to address viewpoints and concerns of target audiences.

    Targeted strategies towards local groups of commercial, industrial, and institutional entities likely to have significant stormwater impacts.

    The following BMPs will be implemented in order to achieve the above stated goals of

    public education and outreach.

    3.1.1 Newspaper/Bulletin Articles

    Articles and advertisements will be placed in local newspapers/bulletins addressing stormwater pollution prevention. Possible topics include information about pollution reduction programs such as recycling opportunities, composting, lawn maintenance, car maintenance, and illicit discharges. The FMA will seek to coordinate articles with the permitted operators of nearby MS4s including the US Army and the City of Hampton. The FMA will promote the website(s) where additional community information can be found.

    Measurable Goal

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    In Years 2 – 5, include at least two articles in a newspaper/bulletin each year addressing stormwater pollution prevention.

    Reporting and Record Keeping

    Maintain copies of articles and advertisements and record published dates.

    Responsible Party

    The Fort Monroe Authority, Operations, Communications and Heritage Assets departments.

    3.1.2 Website and/or Facebook Page

    Develop an environmental website that includes stormwater outreach activities. The website will include information on environmental training for residents, personnel, and contractors. It will include fact sheets, links to other websites, points of contact, and/or notification of stormwater problems. Website can also inform residents of the availability of the MS4 Program Plan and Annual Report for their review and comment. This also can be used to fulfill a Public Involvement measurable goal and an Illicit Discharge measureable goal, and construction measureable goal. Facebook will provide a forum for public comments and help with the construction minimum control measures.

    Measurable Goal

    In Permit Year 2, develop environmental portion of the FMA website. In Year 2 – 5, continue to provide stormwater related information to be included in the website as needed.

    Reporting and Record Keeping

    Maintain a log of revisions that includes nature and date of changes.

    Responsible Party

    The Fort Monroe Authority, Operations, Communications and Heritage Assets departments.

    3.1.3 Identification of High Priority Stormwater Issues

    Identify three high priority stormwater issues that will be the focus of public education efforts targeted to the stakeholders whose actions or responsibilities can influence the potential adverse impact that these actions have on the MS4 system at Fort Monroe. The list of potential issues will be identified and ranked based upon the potential ad-verse impact each can have on the MS4 system.

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 2 FORT MONROE AUTHORITY MINIMUM CONTROL MEASURES & BEST MANAGEMENT PRACTICES

    AH Environmental Consultants (original) 3-4 Last Revised August 8, 2014 107-03

    The three highest ranked issues will then be concentrated on and educational materials will be developed to reach the party(ies) responsible for conducting these issues and minimizing the discharge of pollutants related to these issues. This education cam-paign will coordinated with other public outreach activities at Fort Monroe for residents, tenants and visitors.

    Measureable Goal

    During Permit Year 2, develop the list of issues that can adversely affect the MS4 sys-tem and rank them in order of the potential risk they pose to the MS4 system. Develop educational materials focused on the three issues ranked highest in terms of their po-tential adverse impact to the MS4 system and the audience(s) whose activities most closely relate to these issues.

    During Permit Years 2 – 5, deliver targeted educational messages to the audience(s) whose actions most closely are related to each issue. The goal of these activities will be to reach at least 25% or each target audience each year to provide 100% coverage by the end of the permit term. The educational materials will be completely developed by the end of Permit Year 3 and these materials will be assessed for their effectiveness annually.

    Reporting and Recordkeeping

    The list of the critical stormwater issues and the prioritization of them will be included in the Annual report for Permit Year 2 submitted by October 10, 2015. Copies of the educational materials developed for each of the three highest ranked critical issues will be provided to the Department in each subsequent Annual Report. Records of the creation of educational handouts, brochures, fliers and door hangers will be maintained along with records of the numbers of each distributed in each permit year to the target audience(s) with an estimation of the total percentage of each audience reached each year.

    Where the issue and outreach to the target audience is passive in nature (posted signs, instructions, labelling), surveys will be taken of the targeted audience(s) to assess the awareness of the issue(s) by the audience each year and the results evaluated to de-termine if additional educational/outreach efforts are needed.

    Responsible Party

    The Fort Monroe Authority, Operations, Communications and Heritage Assets depart-ments.

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 2 FORT MONROE AUTHORITY MINIMUM CONTROL MEASURES & BEST MANAGEMENT PRACTICES

    AH Environmental Consultants (original) 3-5 Last Revised August 8, 2014 107-03

    3.2 PUBLIC INVOLVEMENT AND PARTICIPATION

    The FMA will use applicable state, and local public notice requirements to identify,

    schedule, implement, evaluate and modify, as necessary, BMPs to meet the following

    public involvement/participation goals.

    Promote the availability of the MS4 Program Plan and any modifications for public review and comment. Provide access to or copies of the MS4 Program Plan or any modifications, upon request of interested parties, in compliance with all applicable freedom of information regulations.

    Provide access to or copies of the annual report upon request of interested parties.

    Participate, through promotion, sponsorship, or other involvement, in local activities aimed at increasing public participation to reduce stormwater pollutant loads and improve water quality.

    The following BMPs will be performed by Fort Monroe volunteers and FMA employees

    to address the public involvement and participation minimum control measure

    requirement. Records of public communications regarding stormwater will be kept and

    made available to the public, in compliance with all applicable freedom of information

    regulations.

    3.2.1 Storm Drain Marking

    Implement a storm drain marking program to educate residents, contractors, and visitors that only clean runoff should go down the drain. Involve FMA personnel and residents, on a volunteer basis, as available.

    Measurable Goal

    In Year 2, evaluate areas on Fort Monroe with high traffic and dense populations and implement storm drain marking in these identified areas. Hold two (2) storm drain marking events in each of permit years 2-5.

    Reporting and Record Keeping

    Record location, date, number of storm drains marked, and number of volunteer participants at each storm drain marking event.

    Responsible Party

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 2 FORT MONROE AUTHORITY MINIMUM CONTROL MEASURES & BEST MANAGEMENT PRACTICES

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    The Fort Monroe Authority, Operations and Heritage Assets departments.

    3.2.2 Environmental Awareness Events

    Host or promote or establish an two annual events in conjunction with the Chesapeake Bay Foundation and other interested environmental advocacy groups where Fort Monroe volunteers pick-up trash and debris from property and shorelines (Clean the Bay Day, the Great American Cleanup and/or Earth Day will be used to increase awareness/participation of these outreach activities).

    Measurable Goal

    In Years 2 – 5, participate in/host at least four events annually.

    Reporting and Record Keeping

    Retain a copy of the event brochure, poster, or announcement. Track the type and number of participants.

    Responsible Party

    The Fort Monroe Authority, Operations and Heritage Assets departments.

    3.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION

    Illicit discharges are those not made entirely of stormwater and are not otherwise

    allowed to be combined with stormwater runoff by the permit. Refer to Section 1.3 for

    a list of allowable non-stormwater discharges. Illicit discharge examples include

    vehicle wash water where detergents/degreasers are used, fuel spills, and industrial

    wastewater (cross-connections).

    The General Permit contains the following goals for this minimum control measure;

    Develop, implement and enforce a program to detect and eliminate illicit discharges into the small MS4.

    Develop and maintain an updated storm sewer system map, showing the location of all know outfalls, the associated surface water that receive discharges from those outfalls, the hydrologic unit codes (HUC), and an estimate of the acreage within the MS4 that discharges to each HUC and impaired water.

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 2 FORT MONROE AUTHORITY MINIMUM CONTROL MEASURES & BEST MANAGEMENT PRACTICES

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    To the extent allowable under state or local law, effectively prohibit, through ordinance, or other regulatory mechanism, non-stormwater discharges into the storm sewer system and implement appropriate enforcement procedures and actions.

    Develop and implement procedures to detect and address non-stormwater discharges, including illegal dumping to the small MS4.

    Prevent or minimize to the maximum extent practicable, the discharge of hazardous substances or oil in the stormwater discharge from the MS4. In addition, the MS4 Program must be reviewed to identify measures to prevent the recurrence of such releases and to respond to such releases, and the program must be modified where appropriate.

    Track the number of illicit discharges identified, provide narrative on how they were controlled or eliminated, and submit the information in the annual report.

    3.3.1 Illicit Discharge Survey and Removal

    Initial stages will involve prioritizing the location and extent of proposed survey work. Emphasis will be placed on any heavily used areas and new construction or operational changes.

    Measurable Goal

    In Year 2, prioritize areas for illicit discharge surveys and begin conducting surveys. In Year 3, conduct surveys and request funding to remove identified illicit discharges. By the end of Year 2, all outfalls and associated drainage areas at Fort Monroe should be examined at least once. New construction may require more than one inspection.

    Reporting and Record Keeping

    Retain all illicit discharge survey documentation and any corrective actions taken to remove non-stormwater discharges.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.3.2 Stormwater Map

    Develop a stormwater system database in GIS that includes catch basins, curb inlets, manholes, piping, culverts, outfalls, and drainage basins.

    Measureable Goal

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    In Year 2 establish stormwater information to capture in existing GIS database. In Year 3 review GIS database against wanted stormwater information for holes in database. In Year 4 gather wanted GIS database information for all stormwater features.

    Reporting and Record Keeping

    Retain records of stormwater information to capture, number of database shortfalls to fill, and number of database information shortfalls filled.

    Responsible Party

    The Fort Monroe Authority, Operations and Heritage Assets departments.

    3.3.3 Public Education

    Measurable Goal

    In Years 2 - 5, include information addressing illicit discharges in the public education BMPs from the public outreach and education minimum control measure.

    Reporting and Record Keeping

    Retain copies of materials published. Provide publication/distribution dates of the materials in the SWMP Annual Report.

    Responsible Party

    The Fort Monroe Authority, Operations, Communications and Heritage Assets departments.

    3.4 CONSTRUCTION SITE STORMWATER RUNOFF CONTROL

    Fort Monroe is located in a jurisdiction designated as subject to the Chesapeake Bay

    Preservation Area Designation and Management Regulations adopted pursuant to the

    Chesapeake Bay Preservation Act. As such, specific construction goals are required

    for construction site stormwater runoff controls.

    The General Permit contains the following goals for this minimum control measure;

    Develop, implement and enforce procedures to reduce pollutants in any stormwater runoff to the MS4 from construction activities that result in a land disturbance of greater than or equal to 2,500 square feet. Procedures must include;

  • MUNICIPAL SEPARATE STORM SEWER SYSTEM PROGRAM PLAN SECTION 2 FORT MONROE AUTHORITY MINIMUM CONTROL MEASURES & BEST MANAGEMENT PRACTICES

    AH Environmental Consultants (original) 3-9 Last Revised August 8, 2014 107-03

    o An ordinance or other mechanism to require erosion and sediment controls, as well as sanctions to ensure compliance with the Erosion and Sediment Control Law and regulations.

    o Requirements for construction site owners and operators to implement appropriate erosion and sediment control BMPs as part of an erosion and sediment control plan.

    o Requirements for construction site owners and operators to secure authorization to discharge stormwater from construction activities under a VSMP permit for construction activities that result in land disturbance of 2,500 square feet or greater.

    o Create procedures for receipt and consideration of information submitted by the public.

    o Procedures of site inspection and enforcement of control measures.

    Ensure that plan reviewers, inspectors, program administrators and construction site owners and operators obtain the appropriate certifications as required under the Erosion and Sediment Control Law.

    Track regulated land-disturbing activities and submit total number of regulated land-disturbing activities, and the total disturbed acreage in the annual report.

    3.4.1 Erosion and Sediment Control Policy/ Construction Permit

    Requirement

    The FMA is governed by a Board of Trustees with staff management of CoVA lands at Fort Monroe without police power ordinances. An Erosion and Sediment Control policy/construction permit requirement will be implemented that requires erosion and sediment controls on construction activities that result in land disturbance of greater than or equal to 2,500 square feet. This program will be consistent with the Virginia Erosion and Sediment Control Regulations found at 9 VAC 25-850-10 et seq. and the approved Erosion and Sediment Control Annual Standards and Specifications filed with the Department each year.

    Measurable Goal

    In Years 2 - 5, enforce and update the Erosion and Sediment Control policy as necessary. In Permit Years 2 – 5, file Erosion and Sediment Control Annual Standards and Specifications with the Department for approval by the State Water Control Board.

    Reporting and Record Keeping

    Retain a copy of the policy and any implementation information.

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    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.4.2 Review of Erosion and Sediment Control Plans

    FMA staff will begin reviewing the Erosion and Sediment Control Plans submitted by construction contractors, or others, for adherence to the state Erosion and Sediment Control Law and the approved Fort Monroe Erosion and Sediment Control Annual Standards and Specifications..

    Measurable Goal

    In Years 2 through 5, all construction activities disturbing at least 2,500 square feet shall undergo an Erosion and Sediment Control plan review in accordance with the Erosion and Sediment Control policy to ensure appropriate consideration of potential water quality impacts. FMA staff will attend DEQ training programs to become certified in Erosion and Sediment Control plan review, inspection, and program administration in Year 2.

    Reporting and Record Keeping

    Maintain a copy of the Erosion and Sediment Control plan for each applicable construction activity. Maintain log of all projects reviewed by Fort Monroe.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.4.3 VSMP Construction General Permit Policy

    A construction permit policy has been implemented that mandates VSMP Construction General Permits be obtained for construction activities that result in a land disturbance of greater than or equal to 43,560 square feet (one acre) or for smaller land disturbance amounts that are part of a common plan of development that disturbs greater than or equal to 43,560 square feet (one acre).

    Measurable Goal

    In Years 2 - 5, enforce and update the VSMP Construction General Permit policy as necessary.

    Reporting and Record Keeping

    Retain a copy of the policy and any implementation information.

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    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.4.4 Inspection

    Provide oversight inspection for construction activities to ensure compliance with state standards for erosion and sediment control and the VSMP Construction General Permit Programs.

    Measurable Goal

    In Year 2, develop inspection checklist before any land disturbing activities and begin inspections as needed. In Years 3 - 5, review and revise inspection checklist and continue inspection of land disturbing activities.

    Reporting and Record Keeping

    Retain a copy of the completed inspection forms and any corrective actions.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.4.5 Tracking Land Disturbing Activities

    Implement a program to track and report the total number of land disturbing activities and the total number of acres disturbed be receiving water body (Chesapeake Bay and Mill Creek).

    Measurable Goal

    In Years 2 – 5, implement and maintain program.

    Reporting and Record Keeping

    Report the total number of land disturbing activities and the total disturbed acreage.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

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    3.5 POST-CONSTRUCTION STORMWATER MANAGEMENT IN NEW DEVELOPMENT

    AND REDEVELOPMENT

    Fort Monroe is located in a jurisdiction designated as subject to the Chesapeake Bay

    Preservation Area Designation and Management Regulations adopted pursuant to the

    Chesapeake Bay Preservation Act (CBPA). As such, specific post-construction goals

    are required for post-construction runoff controls. In addition, Fort Monroe has adopted

    Stormwater Management Annual Standards and Specifications in accordance with the

    Virginia Stormwater Management Regulations (9 VAC 25-870 et seq.).

    The General Permit contains the following goals for this minimum control measure;

    Develop, implement and enforce procedures to reduce pollutants in any stormwater runoff to the MS4 from new development and redevelopment projects that result in a land disturbance of greater than or equal to 2,500 square feet. Procedures must ensure that controls are in place that would prevent or minimize water quality and quantity impacts.

    o Develop and implement strategies which include a combination of structural and/or nonstructural BMPs appropriate for the community. Encourage the use of structural and nonstructural design techniques to create a design that has the goal of maintaining or replicating predevelopment runoff characteristics and site hydrology.

    o Use an ordinance, regulation or other mechanism to address post-construction runoff from new development and redevelopment projects to ensure compliance with the Virginia Stormwater Management Act and attendant regulations. Update ordinance as necessary.

    o Require construction site owners and operators to secure authorization to discharge stormwater from construction activities under a VSMP permit for new development and redevelopment projects that result in land disturbance of 2,500 square feet or greater.

    o Require the owner of structural stormwater management facilities to provide adequate long-term operation and maintenance by requiring the owner to develop a recorded inspection schedule and maintenance agreement or other legal mechanism. The agreement must include a mechanism for enforcement of maintenance responsibilities by the operator if they are neglected by the owner. There may be private land ownership at Fort Monroe in the future, and some revision of the responsible parties for long-term O&M of structural stormwater management facilities.

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    o Conduct site inspection and enforcement measures consistent with the Virginia Stormwater Management Act and attendant regulations.

    o Track all know permanent stormwater management facilities that discharge to the MS4 and submit the following information in the annual report; the type of structural stormwater management facility installed, the geographic location (HUC), the impaired receiving surface water, and the number of acres treated.

    3.5.1 Post-Construction Runoff Control Policy/Construction Permit

    Requirement

    Fort Monroe has developed and filed with the Department annual Stormwater Management Standards and Specifications that address post-construction site runoff on construction activities that result in a land disturbance of greater than or equal to 2,500 square feet consistent with the Virginia Stormwater Management Regulations (9 VAC 25-870 et seq.).

    Measurable Goal

    In Years 2 – 5, file, implement and enforce Stormwater Management Standards and Specifications as required by the Virginia Stormwater Management Regulations.

    Reporting and Record Keeping

    Retain a copy approved annual Stormwater Management Standards and Specifications and any implementation information.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.5.2 BMP Inspection and Maintenance

    Implement a program to inspect and maintain all permanent stormwater BMPs.

    Measurable Goal

    In Year 2, develop inspection checklists and implement the inspection and maintenance program. Complete inspections on a yearly basis. In Years 3 – 5, continue to inspect yearly and maintain the program.

    Reporting and Record Keeping

    Maintain records of inspection and any associated BMP corrective actions.

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    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.5.3 BMP Tracking Program

    Track all permanent BMPs installed by developing an inventory and submit BMP data in the annual reports to DEQ using tracking information requested by DEQ.

    Measurable Goal

    In Years 2 through 5, implement tracking procedure.

    Reporting and Record Keeping

    Document in an inventory database all permanent BMPs installed and submit the following information with the annual reports: type of BMP installed, geographic location (Hydrologic Unit Code), waterbody the BMP is discharging into, number of total acres treated, number of impaired acres treated, whether or not the BMP is inspected or maintained, and how often the BMP is maintained.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.6 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL

    OPERATIONS

    An operation and maintenance (O&M) program consistent with the MS4 Program Plan

    will have the ultimate goal of preventing or reducing pollutant runoff from municipal

    operations.

    The General Permit contains the following goals for this minimum control measure;

    Identify facilities with a high potential for discharging pollutants into the storm-water system and developing stormwater pollution prevention plans for these facilities.

    Develop and implement a training component for employee training to prevent and reduce stormwater pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land dis-turbances, and MS4 maintenance.

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    O&M programs including activities, schedules, and inspection procedures shall include provisions and controls to reduce pollutant discharges to the MS4 and receiving surface waters.

    Illicit discharges shall be eliminated from storage yards, fleet or maintenance shops, outdoor storage areas, rest areas, waste transfer stations, and other municipal facilities.

    Waste materials shall be disposed of properly.

    Materials that are soluble or erodible shall be protected from exposure to pre-cipitation.

    Materials including but are not limited to fertilizers and pesticides that have the potential to pollute receiving surface waters shall be applied according to man-ufacturer’s recommendations.

    3.6.1 Identification of High Risk Facilities

    Identify facilities under Fort Monroe control, including those operated by contract support service providers that have a high potential for discharging pollutants into the stormwater system at Fort Monroe.

    Measurable Goal

    In Permit Year 2, identify the facilities that are determined to have a high risk of polluting the storm drainage system based on the nature of the activities undertaken at each facility and the potential pollutant sources and activities exposed to stormwater.

    Recordkeeping and Reporting

    Report the list of identified facilities to DEQ in the Annual Report for Permit Year 2 and include a schedule for the development of stormwater pollution prevention plans (SWPPP) for each facility identified as high risk.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    3.6.2 Pollution Prevention and Good Housekeeping Guidance

    A SWPPP will be developed and implemented for each facility identified as posing a high risk for the discharge of pollutants to the storm drainage system. Develop guidance that requires pollution prevention and good housekeeping practices be

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    incorporated into other in-house facility activities with the goal of preventing and reducing stormwater runoff.

    Each SWPPP will contain the following information:

    A site description that includes a site map identifying all outfalls, direction

    of flows, existing source controls, and receiving water bodies.

    A discussion and checklist of potential pollutants and pollutant sources.

    A discussion of all potential non-stormwater discharges.

    Written procedures designed to reduce and prevent pollutant discharge.

    A description of the employee stormwater awareness training received.

    Training is discussed further in Section3.6.3.

    Procedures to conduct an annual comprehensive site compliance evalu-

    ation.

    An inspection and maintenance schedule for site specific source con-

    trols. The date of each inspection and associated findings and follow-up

    shall be logged in each SWPPP.

    Measurable Goal

    In Permit Year 3, develop and implement facility specific SWPPPs for each facility determined to be a high risk for polluting the stormwater system.

    In Years 3 - 5, develop and distribute good housekeeping guidance documents to other facilities that, while not high risk, still have the potential for discharging pollutants into the stormwater system.

    Reporting and Record Keeping

    Document the SWPPPs have been developed and implemented and that the guidance documents that have been developed and distributed.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

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    3.6.3 Environmental Awareness Training Program

    Develop an Environmental Awareness training program for municipal personnel, and contractors which will emphasize stormwater pollution prevention program goals. The training will also provide information on the requirements of any SWPPP that the employee must conduct their operations in accordance with. Training programs will be conducted either in person or online.

    Measurable Goal

    In Year 1, develop environmental awareness training program. In Year 2, evaluate and update materials utilized as part of the Environmental Awareness training program.

    Reporting and Record Keeping

    Record and report dates of training presentations, attendance at the training presentations, and the number and frequency of website visitors.

    Responsible Party

    The Fort Monroe Authority, Operations and Heritage Assets departments.

    3.6.4 Brochures and Posters

    Distribute brochures and posters to operations buildings to inform FMA personnel what can be done to prevent stormwater pollution. Brochures and posters will be displayed in public and municipal buildings on an annual basis and will cover topics such as stormwater pollution prevention, boater pollution prevention, water conservation, decreased pollution from car and lawn maintenance, and proper disposal of hazardous waste and household products.

    Measurable Goal

    In Year 1, develop and distribute brochures and posters to Fort Monroe departments for prominent display. In Year 2, evaluate previous brochures and posters, make revisions as needed, and distribute to all departments for prominent display.

    Reporting and Record Keeping

    Retain a copy of the brochures and posters and dates of distribution.

    Responsible Party

    The Fort Monroe Authority, Operations, Communications and Heritage Assets departments.

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    3.6.5 Development and Implementation of Turfgrass Nutrient Manage-

    ment Plans

    The Fort Monroe Authority provides landscape management for areas beyond residen-tial yards within the portion of Fort Monroe under the control of the Authority. This landscape maintenance is performed by contract personnel. Nutrient management plans developed by an individual certified as a Virginia Nutrient Management Planner must be developed for all areas of contiguous lands equal to or greater than one acre in size where nutrients are applied.

    Measurable Goal

    Within Permit Year 2, Fort Monroe will identify and map all land contiguous land units equal to or exceeding one acre where nutrients are applied.

    During Permit Years 3 – 5, nutrient management plans for identified regulated land units will be developed by a certified Virginia Nutrient Management Planner. At least forty percent of the regulated land units will have nutrient management plans prepared in Permit Year 3 with nutrient management plans developed for an additional thirty-five percent of regulated lands in Permit Year 4 and the remaining twenty-five percent in Permit Year 5.

    Reporting and Recordkeeping

    Fort Monroe will annually track the acreage of lands requiring the implementation of nutrient management plans and the acreage of lands covered by nutrient management plans for Permit Years 2 – 5.

    Responsible Party

    The Fort Monroe Authority, Operations Department.

    IMPLEMENTATION SCHEDULE for Minimum Control Measures (MCMs)

    MCM Actions Period

    One Public education and outreach

    1. Develop schedule for public

    engagement

    2. Implement schedule for publications

    and outreach

    3. Identification of High Priority Issues

    FMA Permit Year

    1. Two

    2. Two and subsequent

    3. Permit Year 2

    4. Permit years Two and

    subsequent

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    4. Development of public outreach

    materials for each high Priority Issue

    Two Public involvement/participation

    1. Develop schedule for public notification

    and training for FMA employees and

    contractors

    2. Implement marking project

    3. Hold environmental awareness events

    FMA Permit Year

    1. Two

    2. Two and subsequent

    3. Two and subsequent

    Three Illicit Discharge Detection and Elimination

    1. Survey, including for dry weather

    2. Removal

    3. Map

    4. Public Education

    FMA Permit Year

    1. Plan in Two, Conduct in

    Three

    2. Three and subsequent

    3. Two and Three

    4. Two and subsequent

    Four Construction Site Stormwater Runoff

    Control

    1. Enforce and update as needed

    2. Review E&S control plans

    3. Consistency with VSMP general permit

    4. Inspection

    5. Track Land Disturbing Activities

    FMA Permit Year

    1. Two and subsequent

    2. Two and subsequent

    3. Two and subsequent

    4. Two and subsequent

    5. Two and subsequent

    Five Post-Construction Stormwater Management

    in New Development and Redevelopment

    1. Develop Runoff Control Policy

    2. BMP Inspection and Maintenance

    2.1. Develop checklists and implement

    3. BMP Tracking

    3.1. Develop inventory and submit to

    DEQ

    FMA Permit Year

    1. Two and subsequent

    2. Two and subsequent

    3. Two and subsequent

    Six Pollution Prevention and Good

    Housekeeping for Operations

    FMA Permit Year

    1. Two

    2. Three - Five

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    1. Identify High Priority Facilities needing

    SWPPPs

    2. Develop SWPPPs for High Priority

    Facilities

    3. Develop guidance for in-house O&M

    4. Environmental Awareness Training

    5. Distribute brochures and posters to

    FMA buildings

    6. Develop nutrient management plans

    3. Two and subsequent

    4. Two and subsequent

    5. Two and subsequent

    6. Three and subsequent

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    4. EVALUATION AND ASSESSMENT

    In order to ensure compliance with the MS4 Program Plan, the FMA will evaluate and

    assess, keep the required records, and submit annual reports to the DEQ.

    4.1 EVALUATION AND ASSESSMENT

    Evaluation and assessment of the MS4 program will be done on an annual basis. The

    FMA will evaluate;

    Program compliance.

    The appropriateness of the identified BMPs and their effectiveness in addressing discharges to impaired waters.

    Progress towards achieving the identified measurable goals.

    At least once during the 5-year permit cycle, the stormwater management program

    must be evaluated using the U.S. EPA EPA-833-R-07-003 “Municipal Stormwater

    Program Evaluation Guidance.” This evaluation will be used when reapplying for

    permit coverage. Results of this evaluation should be kept on file and made available

    during audits and inspection.

    4.2 RECORDKEEPING

    Required records will be kept for at least three (3) years. Records will be made avail-

    able to the public at reasonable times during regular business hours. Records to be

    retained include those needed for minimum control measure goals, written public com-

    ments regarding the MS4 Program Plan, illicit discharges found and corrected, land

    disturbing activities and acreage impacted, all stormwater monitoring data, and any

    other as listed in the General Permit.

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    4.3 ANNUAL REPORT

    An annual report for the reporting period from July 1 through June 30 is due to DEQ by

    the following October 1. The annual report will contain the status of the MS4 in meeting

    the yearly goals set and whether the BMPs selected are appropriate and effective. All

    other items to be included in the annual report can be found in the General permit

    Section II.E.3. These items include;

    Name and permit number

    Annual report year

    Any modifications to the FMA department’s roles and responsibilities under this MS4 Program Plan

    Number of new MS4 outfalls and associated acreage added in the past year

    Signed certification

    Status of compliance with permit conditions, an assessment of the appropriateness of the BMPs selected and progress towards achieving the identified measureable goals for each minimum control measure

    Results of information collected and analyzed, including monitoring data, if any, during the year using a Discharge Monitoring Report (DMR) form (See Appendix C)

    A summary of the stormwater activities FMA plans to undertake in the next year

    Any changes to the BMPs or measureable goals, including steps to address any deficiencies

    Notice that the FMA is relying on another government entity to satisfy some of the permit obligations (if applicable), including as applicable the U.S. Army, the National Park Service and/or the City of Hampton

    Any updates to the Program Plan due to the TMDL.

    The estimated volume of stormwater discharge, in cubic feet, and the quantity of the pollutant identified in the WLA

    The number of illicit discharge identified and how they were controlled or eliminated

    Total land-disturbing activities and total acreage disturbed.

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    All known permanent stormwater management facility data tracked under the Post-construction in new and redevelopment minimum control measure (first year). Subsequent years will include only those permanent stormwater management facilities that are new.

    List of third party agreements, new or terminated.

    Copies of any written public comments received during the public comment period regarding the MS4 Program Plan.

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    5. STORMWATER MONITORING

    The FMA will collect a total of two stormwater samples from a representative outfall to

    be identified. One sample will be taken during each of the following six-month periods:

    October through March, and April through September. The samples will be analyzed

    for the WLA pollutant, when specified by the DEQ.

    All collected samples will be grab samples and collected within the first 30 minutes of

    a runoff producing event that is greater than 0.1 inches in magnitude and that occurs

    at least 72 hours from the previous measureable (greater than 0.1 inch rainfall) storm

    event.

    Monitoring records will include the;

    Date, exact place and time of sampling.

    Individual who performed the sampling.

    Dates and time analyses were performed.

    Individual who performed the analysis.

    Analytical technique used in the analysis.

    Analysis results

    Monitoring records will be kept for at least three years from the time the sample was

    collected. Discharge Monitoring Report (DMR) forms are found in Appendix C. DMRs

    will be submitted with the annual report.

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    APPENDIX A – GENERAL PERMIT REGISTRATION FORM

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    APPENDIX B – STORMWATER SYSTEM MAP

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    APPENDIX C – DISCHARGE MONITORING REPORT FORM

    MS4 Notice Letter August 21 2013fma ms4 registration signed_JGFMA SWMP 2014_submittal_2014_08_08