Stormwater Program Support – Naval Support Activity Annapolis

Stormwater Program Support – Naval Support Activity Annapolis

Since 2016, Bluestone has been awarded multiple contracts to provide various stormwater related services to Naval Support Activity Annapolis. Activities completed under these contracts include the following:


BMP Inspections Forms and Tablet

Bluestone developed electronic BMP inspection checklist and procured a tablet computer for NSA Annapolis to use when inspecting BMPs. A separate checklist was developed for each of the 95 BMPs in accordance with MDE BMP guidelines. Following approval of the new checklists, Bluestone completed a full inspection of all 95 BMPs onsite utilizing the tablet and, during that inspection, trained NSA Annapolis Environmental Program staff on its use. Bluestone also prepared a guidance document to accompany the tablet to train NSAA employees on BMP inspections and how to complete the electronic checklists.

Illicit Discharge Survey

Bluestone performed multiple illicit discharge surveys of all stormwater outfalls at NSAA. Prior to arrival onsite, Bluestone reviewed all stormwater maps, field logs, and previous inspection report to familiarize themselves with the site and evaluate whether the recommend corrective actions were taken. Bluestone was also responsible for obtaining all equipment necessary to complete the sampling, preparing the chain of custody forms, and securing the analytical laboratory prior to the start of fieldwork.

While onsite, Bluestone observed and inspected 105 outfalls identified by the Government. For any outfall with flow during dry weather, the field team progressed upstream to each accessible inlet until the source of the flow could be identified. If the source was identified, Bluestone attempted to determine if it was an allowable non-stormwater discharge or an illicit discharge. For any discharge not conclusively identified as allowable, Bluestone performed dry weather field measurements and collected grab samples. Bluestone recorded all observations and field measurements on electronic checklists developed specifically for the NSAA illicit discharge task. Samples were catalogued and delivered to an accredited laboratory for analysis in accordance with the parameters outlined in the scope of work. For each mobilization, Bluestone and the NSAA Public Works Department on short notice due to the requirement that the survey be performed following a 72-hour period of no rainfall. Bluestone ensured that all staff available to work on the task had the proper security clearances and were familiar with the site and laboratory to minimize delays and streamline logistics.

Following completion of onsite inspections, Bluestone developed a report to include observations of all outfalls, completed inspection checklists, survey methods, laboratory results, recommendations, and conclusions. The report also included a summary table listing the date of observation, structures(s) observed, diameter or size of the structures, and if any discharge was noted. Bluestone also included a list of all corrective actions identified in the previous illicit discharge survey that were not corrected and an excerpt that NSAA can submit to MDE as part of their MS4 Annual Report to demonstrate compliance with the Illicit Discharge Detection and Elimination Procedures Minimum Control Measure.

Stormwater Outreach for Earth Day Activities

Bluestone created various public outreach materials in support of NSA Annapolis’s MS4 Program. Outreach materials include tablecloths, tabletop displays, retractable banners, 500 flipchart booklets containing information on various environmental topics applicable to NSA Bethesda, stormwater informational brochures, DVDs, and posters. Bluestone custom designed each outreach item to cover various environmental topics applicable to each Installation and per installation personnel request. Topics included natural and cultural resources, stormwater controls, illicit stormwater discharges, waste management, air pollution, drinking water management, and wastewater. Bluestone also designed custom logos for the installation for use on a variety of Earth Day and public outreach materials. In addition, Bluestone procured and installed 200 stormwater drain placards that state “No Dumping, Drains to Bay.” Bluestone coordinated storm drain locations and site access logistics with NSAA staff to minimize impact on the Naval Academy population.

Comprehensive Stormwater Compliance Inspections

NSAA stormwater discharge permits require comprehensive site compliance evaluations at least once a year to verify accurate descriptions of potential pollutant sources, facility drainage maps have been updated, and pollution prevention/reduction controls identified in the SWPPP are being implemented and are adequate. Bluestone provided qualified personnel who possess the knowledge and skill to assess conditions and activities that could impact stormwater quality and who can evaluate the effectiveness of all existing BMPs to complete all inspections. Bluestone evaluated the overall effectiveness of the SWPPP, existing control measures and stormwater best management practices (BMPs) in an effort to reduce potential pollutant discharges into the stormwater system. Bluestone performed an on-site compliance evaluation at areas with the greatest potential for pollutants to enter stormwater: YP Marina, MWR Carr Creek Marina, fire stations, wastewater treatment plant, water treatment plant, recycling center, commissary and exchange, golf storage area, brigade sports complex, and Perry Center.

In addition, Bluestone inspected material handling areas for evidence of, or the potential for, pollutants entering the drainage system. Bluestone’s complete evaluation also included reviewing NSAA’s current SWPPP and preparing lists of areas used for material handling and storage, or areas otherwise covered by the SWPPP; listing all equipment, containment or other pollution prevention controls in these areas; reviewing facility operations for the past year to determine if additional areas that have the potential to pollute stormwater runoff should be included in the SWPPP; identification of newly constructed areas to determine if they must be added to the SWPPP; inspecting stormwater drainage areas for evidence of pollutants entering the drainage system; determining if soil erosion protection is necessary; observing structural BMPs, permanent sediment controls, and other mechanical BMPs to ensure they are kept in proper operating condition and to evaluate maintenance requirements using checklists pre-loaded onto a tablet; evaluating non-structural BMP effectiveness in reducing pollutant loadings and determining whether additional measures are needed; inspecting areas that contain potential pollution sources (e.g., salt storage or kitchen waste containers); inspecting any equipment needed to implement the SWPPP, such as spill response equipment; and evaluating NPDES sampling results, ensuring remedial action was taken for any exceedances.

Following onsite evaluation, Bluestone developed a report to document and analyze deficiencies in the SWPPP. The report included a spreadsheet with comments, photos, and recommended corrective actions that will bring the facility into compliance with the SWPPP and any applicable permits.

SWPPP Update

Bluestone was tasked with updating Stormwater Pollution Prevention Plan (SWPPP) at NSAA. Bluestone collected data under a separate task to perform a comprehensive site evaluation. Bluestone then modified the existing plan to address deficiencies and observations noted during the evaluation, additional modifications provided by NSAA, and new permit requirements.

The plan addressed all “high-priority areas” on the FBI Quantico Complex, defined as those areas where the potential for pollutants to mobilize and enter stormwater are greatest. The SWPPP identified these areas onsite and described the good housekeeping and pollution prevention best management practices that personnel can implement to minimize pollutants in stormwater water. The SWPPP was designed to be a complimentary document to NSAA’s other stormwater management tools and provided specific guidance on onsite operating procedures that will help the site maintain compliance with the Good Housekeeping and Pollution Prevention Minimum Control Measure stipulated in the MS4 permit. Bluestone also interviewed NSAA personnel, reviewed available records and documents, and identified opportunities to meet or exceed stormwater management required by the permit, where applicable.