Under EPA’s National Pollution Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) the MBTA was required to obtain coverage for stormwater discharges from industrial activities at nine bus maintenance facilities in the Boston metropolitan area. With this was the responsibility to develop comprehensive stormwater pollution prevention plans (SWPP Plans) and associated documents to comply with EPA’s 2013 NPDES MSGP, Sector P – Land Transportation and Warehousing.
CDW reviewed existing reports and files for all nine facilities to become familiar with the operations at each facility that require the implementation of the SWPP Plan under the 2013 NPDES MSGP. We also reviewed the existing Stormwater Pollution Prevention (SWPP) Plans, and evaluated current Best Management Practices (BMPs) described in those plans. CDW performed an initial screening to determine the eligibility for coverage under the Endangered Species Act (ESA), considering the effects of stormwater discharges on federally-listed species and designated critical habitats. We also performed a screening to determine the eligibility of coverage with the Historic Properties Preservation Section 106.
CDW performed a comprehensive inspection of each facility, and reviewed current operations and measures in place to reduce or prevent stormwater pollution, including the types and effectiveness of Best Management Practices. We also reviewed the history of releases of petroleum (if any) and mitigation conducted. Our team performed the baseline outfall inspections at the facilities and documented site conditions and effectiveness of BMPs in preventing stormwater pollution.
For each facility, CDW developed the general location map and site specific map indicating the locations of various industrial activities, site drainage, storm water control measures, receiving waters, etc. We performed site surveys, as needed, to supplement site drawings provided by MBTA. The site plans were used to show the material storage areas, areas vulnerable to releases (i.e., drains) and location of spill response equipment.
CDW prepared new SWPP Plans for these 9 MBTA Facilities in accordance with the new 2013 MSGP requirements, announced in the spring of 2015. We provided recommendations for appropriate control measures and/or corrective actions to comply with the NPDES MSGP. The NOI filings were completed in time to meet an aggressive EPA deadline.