Stormwater Management At US E.P.A Research Triangle Park, NC
Campus Overview 512-acre site Shared with NIEHS Designed in 1996 Constructed 19972001 Occupied in 2002 1.1 MSF of Office, Lab and Support spaces
Stormwater Risks 2 miles of roads 1760 parking spaces 29 storm drain outfalls 4 separate buildings 6 loading docks
Stormwater Risks Outdoor storage of research sampling equipment Outdoor coal handling area Over 53,000 gal. of fuel storage: 15 ASTs 4 USTs SPCC 8 dumpsters
Our Existing Stormwater Management By Design: Minimized curb and gutter Grassed shoulders Reduced parking half in decks Parking lot runoff treated by 11 bioretention cells & 3 water quality ponds (wet retention)
Our Existing Stormwater Management SW treatment all voluntary beyond compliance No construcdtion stormwater permit required (2001) Cisterns at our on-site day care (added in 2009)
But Do We Need A Stormwater Permit? Internal environmental audits 3x said YES Yet, in reality, REQUIRED only certain industry types, which we don t meet http://www.pneac.org/stormwater/ NIEHS (same campus) has a TSD, which triggers a formal SW Permit with State of NC (DENR) And, EPA s TSD operations are just INDOOR storage, so we asked DENR for Technical Assistance We are a candidate for a No Exposure Certification, based on the above, provided we manage our site properly
How Does NC-DENR See Sites Actively Reducing Their SW Regulatory Burden? 1. The No Exposure Exclusion from Permitting 2. Representative outfall status 3. Take advantage of the flexibility built into the permit text 4. Dormant site provisions 5. Achieve no point-source discharge? 6. General Permit coverage vs. Individual Permit coverage A facility that achieves no exposure conditions is doing the best possible job that an industrial facility can do to protect North Carolina s waters from pollutants transported by stormwater NC DENR
Our New Approach Pursue No Exposure Certification under review by NC DENR Develop and implement a Stormwater Pollution Prevention Plan as a Best Practice Write Plan around permit requirements (should the N.E.C. be denied) - done Document our infrastructure ongoing Assess condition of all SW devices - ongoing Obtain the means to perform inspections and repairs = incorporated into grounds maintenance and custodial SOWs - ongoing Train to the Plan appropriate federal & contractor staff - done
Our New Approach Minimize outdoor use of chemicals, pesticides, and herbicides Integrated Pest Management strategy Prohibiting: Exterior building washing Power washing of sidewalks Vehicle Washing ID and control/eliminate non-sw discharges Follow published recommendations: http://water.epa.gov/polwaste/npdes/stormwater/upload/industrial_ swppp_guide.pdf
So What s in Our SWPPP? 1. Introduction 2. Contact Information / Responsible Parties 2.1 Stormwater Pollution Prevention Team 3. Definitions 4. Facility Description and Layout 4.1 Facility Operations 4.2 Outfalls & Site Drainage 4.2.1 Research and Administration Facility 4.2.2 National Computer Center 4.2.3 First Environments Early Learning Center
So What s in Our SWPPP? 5. Potential Pollutant Sources 5.1 Industrial Activity and Associated Pollutant 5.1.1 Hazardous Waste Management 5.1.2 Pesticides & Fertilizers 5.1.3 Highbay Building 5.1.4 Loading / Unloading Deliveries 5.1.5 Outdoor Storage Area / Old Jenkins Road 5.1.6 Petroleum Storage Tanks 5.2 Spills and Leaks 5.2.1 Maintenance of Spill Response and Containment Materials 5.2.2 EPA-RTP Spill Response 5.2.3 EPA-RTP Spill History
So What s in Our SWPPP? 5. Potential Pollutant Sources (continued) 5.3 Non-Stormwater Discharges 5.3.1 Authorized Non-Stormwater Discharges 5.3.2 Unauthorized Non-Stormwater Discharges 6. Best Management Practices 6.1 Stormwater Management Systems 6.2 Good Housekeeping
So What s in Our SWPPP? 6. Best management practices (continued) 6.3 Inspection & Maintenance 6.3.1 Stormwater Drains Parking Decks, Areaways, and the Plaza 6.3.2 Stormwater Drains Highbay Fuel Farm 6.3.3 Stormwater drains Loading/Unloading Trench drains 6.3.4 Roof Drains 6.3.5 Wet Retention Basins & Bioretention Cells 6.3.6 FEELC Rain Cisterns 6.4 Erosion and Sediment Controls 6.5 Staff Training
So What s in Our SWPPP? 7. Stormwater Management Deficiencies & Corrective Action Plan 8. Construction & Land Disturbance 9. Certification / Annual Review
Challenges (= Must Do s) Reliance on our grounds and maintenance contracts SOWs new work requirements need to be added Incomplete facility as-builts for site developments 4 Separate development phases over 13 years, each with their own sets of dwgs never before merged Improving underperforming devices (only 7 of 11 Bioretention Areas) Daily housekeeping Not my job Too many organizational stovepipes No one person in charge Not in my SOW/budget New requirements key is training and oversight
Challenges (= Must Do s) Improve oversight & training for permit triggers Land disturbing activities greater than 1 acre Discharge of HTHW to surface waters Inprove O&M and PM Hydraulic bollard leaks Monitor ice treatment Control resident geese
Questions?
Further Information Need a copy of: Our SWPPP? Our IPM Plan? This presentation? Any other way we can assist? Take my business card Email me at: schubert.peter@epa.gov Call me at: 919-541-7526 Come visit our campus!