Overcoming Industrial Stormwater Permit Challenges at a Large Naval Installation

Industrial activities at Department of Defense installations, such as those operated by the Navy, include hazardous material handling/storage and vehicle (truck/ship/airplane) maintenance. These activities are often conducted outdoors and exposed to rainfall. Because rainfall runoff can transport pollutants to nearby waterways either directly or via a storm drain system, federal regulations at 40 CFR 122.26(b)(14)(i)-(xi) require stormwater discharges associated with specific categories of industrial activity to be covered under a National Pollutant Discharge Elimination System (NPDES) permit. Although Phase 1 of the industrial NPDES stormwater permit has been in place since 1990, the regulated community would benefit significantly from sharing lessons learned on reducing regulatory burden and streamlining compliance activities. This paper and associated presentation address lessons learned while overcoming the challenges faced by Naval Station Norfolk (NSN) on complying with their industrial stormwater permit issued by the Virginia Department of Environmental Quality (VADEQ). Objectives of the paper and presentation include:
- Identifying the current challenges with Phase 1 stormwater permit compliance which have evolved over the past 30 years.
- 2) Identifying logistical challenges associated with the annual update of an industrial stormwater pollution prevention program (SWPPP) for NSN, which covers several industrial sectors, numerous standard industrial classification (SIC) codes, over 100 tenant commands, and a transient work force: and###- 3) Sharing lessons learned on the most problematic programmatic best management practices (BMPs) that reduce regulatory burden, while maintaining good stewardship of the environment and associated water resources.