First Environment was retained by the Montrose and Castle Point, New York campuses of the VA Hudson Valley Health Care Network to prepare the following for each campus:
- Non-traditional (i.e., public complex) municipal separate storm sewer system (MS4) permit applications
- Site stormwater management plans (SWMP)
- Spill Prevention, Control, and Countermeasure (SPCC) Plans
The Castle Point site is a campus-style extended care complex located on approximately 113 acres located along the banks of the Hudson River. There are 110 buildings and structures on campus including several office buildings, residences, dormitory halls, gymnasium, maintenance garages, emergency generators, and a boiler plant. The Montrose medical campus, also located on the banks of the river, is comprised of 180 acres with 59 buildings and structures.
First Environment executed the scope of work in accordance with an expedited period of performance to allow for New York State site improvement authorizations that were in abeyance due to deficiencies with site MS4 permitting actions. To address stormwater management deficiencies, First Environment expedited site assessment activities at each campus to identify stormwater flow patterns, regulated site operations and activities, stormwater conveyance systems, and outfall locations; we also identified practical minimum control measures (MCM) that VA personnel can implement over a three-year permitting period. The MCMs related to the following areas:
- Public Education and Outreach
- Public Participation and Involvement
- Illicit Discharge Detection and Elimination
- Construction Site Runoff Control
- Post-Construction Storm Water Management
- Pollution Prevention and Good Housekeeping
First Environment also evaluated existing structural best management practices (BMPs) designed to improve the campus’ stormwater quality and quantity goals and identified appropriate maintenance and inspection activities for these structures for incorporation into the management plans.
To ensure that the campus’ stormwater discharges were permittable under New York’s general permit program, First Environment confirmed that the discharges did not directly or indirectly jeopardize listed endangered or threatened species, adversely modify critical habitat, or adversely affect properties listed or eligible for listing in the National Register for Historic Places. We made these confirmations via on-site observations, referencing New York State cultural and biological written resources, and contacting local officials.
All of the aforementioned site assessment and review activities were undertaken to satisfy NYSDEC’s SPDES permit obligations for stormwater discharges presented under general permit number GP-0-10-002. Following the VA’s approval of the plans, First Environment submitted the required permitting (e.g., Notice of Intent) notifications to the New York State Department of Conservation (NYSDEC) to secure individual SPDES permits for each campus.
First Environment also revised SPCC plans for both campuses to address previously identified deficiencies and regulatory non-compliances, as well as to clarify administrative roles pertaining to emergency response and the incident command structures. Plan revisions included the incorporation of portable containers (e.g., 55-gallon drums) and associated secondary containment and spill control measures; recently installed aboveground storage tanks (ASTs) and associated secondary containment and inspection protocols; revised facility diagrams that reflect current bulk petroleum storage activities (stationary and portable) for ASTs and underground storage tanks (USTs); updated roles, responsibilities, and notification procedures for facility personnel during and subsequent to spill events; procedures and delivery instructions for bulk unloading of petroleum products; and the inclusion of revised tank integrity testing requirements that reflect standards put forth by the American Petroleum Institute (API).
Once the SWMP and SPCC documents were approved by the VA, First Environment provided technical training to facility personnel of both campuses to ensure that personnel were informed of new operating requirements and legal commitments.
First Environment’s overall project management activities included site visit coordination, the development of matrices to identify regulatory requirements applying to the product deliverables, communications with state and local officials, and the expedited review of work products.