Sandia Corporation

U.S. Department of Energy

English

University of New Mexico

University of New Mexico
UNM Digital Repository
Municipal Separate Storm Sewer System (MS4)
Permit Sandia National Labs/NM Technical Reports
9-9-2016
U.S. Doe MS4 Annual Report
U.S. Department of Energy
Sandia Corporation
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Recommended Citation
U.S. Department of Energy and Sandia Corporation. "U.S. Doe MS4 Annual Report." (2016). https://digitalrepository.unm.edu/
snl_ms4/3






Addendum 
2016 MS4 Annual Report 
 
Note:  DOE and Sandia have included this addendum to provide additional information and 
clarify responses to some of the questions on the Annual Report as per Question 10. 
Section 1-  MS4 Information 
NPDES number:  This box will not allow for alphabetic text to be entered; only numerical.  
DOE’s NOI tracking number is NMR04A011.  Sandia’s tracking number is NMR04A012. 
Section 2- Water Quality Priorities 
2.A:  The SNL MS4 does not discharge directly to an impaired water; it discharges to a tributary 
(Tijeras Arroyo), and to adjacent MS4s that discharge to the Rio Grande.  Approximately 90% of 
the SNL MS4 discharges to the Tijeras Arroyo, which discharges into the Isleta Pueblo to 
Alameda Bridge reach of the Rio Grande (Assessment Unit NM-2105_50).  The other 10% of the 
SNL MS4 discharges to the Kirtland Air Force Base MS4, which discharges into the Alameda 
Bridge to HWY 550 reach of the Rio Grande (Assessment Unit NM-2105.1_00). 
 
2.B:  For the reaches of the Rio Grande that receive stormwater discharges from the SNL MS4, 
E. coli is the only impairment for which a total maximum daily load (TMDL) is assigned.  The 
TMDL does not assign a waste load allocation (WLA) to SNL specifically, but it does assign a WLA 
for all the MS4s in the Albuquerque Urbanized Area.  Section 2.4 of the SWMP Plan describes 
the portion of the WLA assigned to the SNL MS4 calculated according to the Percent Jurisdiction 
Approach, in accordance with the guidance and requirements provided in Appendix B of the 
MS4 Permit. 
Section 3- Public Education and Public Participation 
3.C:  Specific successful outcomes attributable to our public education program during the 
reporting period include increased awareness of minimizing pesticide, fertilizer, road salt 
among MS4 personnel and contractors responsible for their use and storage.  We have also 
increased awareness and implementation of proper stormwater controls at small construction 
sites < 1 acre. 
 
Requirements of the MS4 have been incorporated into corporate procedures and training 
materials, increasing the number of employees educated on MS4 stormwater quality issues and 
procedures.  Key benefits include: 
• increased awareness of minimizing pesticide, fertilizer, road salt among MS4 personnel 
and contractors responsible for their use and storage, 
• increased awareness and implementation of proper stormwater controls at small 
construction sites < 1 acre, with emphasis on controlling the discharge of 
uncontaminated natural sediments, 
• Increased awareness that stormwater discharges from SNL may flow to natural 
waterways, including the Rio Grande. 
 
3.D:  The SNL MS4 does not have a formal advisory committee; however, DOE and Sandia are in 
regular attendance at monthly meetings of the Technical Advisory Group which includes 
permittees from the Albuquerque MS4 Permit.  DOE and Sandia also participate in the 
DOE/DoD Semi-Annual Public Meetings where public stakeholders can openly provide 
comment, ask questions and/or express concerns. 
Section 4- Construction 
4.C:  Two construction projects within the SNL MS4 (planned and began construction after the 
effective date of the MS4 Permit) were required to obtain coverage under the CGP.  A SWPPP 
for each of these projects was developed by the Stormwater Program.  Information pertinent to 
the MS4 Permit for these two construction projects is included in Appendix G-1 of the SWMP 
Plan.  These sites are: 
• Building 905 (new building construction) 
• Building 756 (new building construction) 
 
4.G: The following language from Section 1.6 of the SWMP Plan is provided for clarity as to the 
possible types of enforcement actions available to DOE and Sandia: 
• DOE can enforce compliance with the requirements of the MS4 Permit on Sandia 
through contract DE-AC04-94AL85000, by application of the following clauses, e.g., 
Clause I-72, DEAR 970.5204-2 Laws, Regulations, and DOE Directives (DEC 2000); Clause 
I-75 DEAR 970.5215-3 Conditional Payment of Fee, Profits, and Other Incentives-Facility 
Management Contracts (AUG 2009) (Deviation); and Clause I-78 Integration of 
Environment, Safety, and Health Into Work Planning and Execution (DEC 2000).  These 
clauses require Sandia to comply with all applicable Federal, State, and local laws and 
regulations, including DOE regulations; impose requirements on subcontractors at any 
tier to the extent necessary to ensure Sandia’s compliance with the requirements of the 
MS4 Permit; and cooperate with Federal and non-Federal agencies having jurisdiction 
over environment, safety, and health matters under the contract. 
 
• Sandia Corporate Procedure ESH100.2.ENV.10, Manage Surface and Stormwater 
Discharges (and applicable procedures discussed in this SWMP Plan), affords Sandia the 
ability to “enforce” compliance with stormwater requirements.  The procedures include 
the following statement regarding disciplinary actions for knowingly causing or allowing 
an illicit discharge: “Granting or permitting exceptions or violations of policy, process, or 
procedure without authority, regardless of position or title, may be cause for 
disciplinary action up to and including termination of employment.  Violating a policy, 
process, or procedure may be cause for disciplinary action up to and including 
termination of employment.”  Sandia also has the ability to take legal action in response 
to a contractor’s breach of contract. 
 
When corrective conditions are observed during site inspections, a corrective action request is 
submitted to the construction manager.  After the corrective action has been implemented by 
the construction contractor and documented by Stormwater Program personnel, the inspection 
and corrective action forms are certified by all permit operators (those holding CGP NOIs).  To 
date, DOE and Sandia have not been issued a Notice of Violation from a regulatory agency for 
non-compliance with the CGP or MS4.  
 
4.I:  To date, DOE and Sandia have not been issued a Notice of Violation from a regulatory 
agency for non-compliance with the CGP or MS4.  Several corrective conditions were identified 
during inspection and prompt actions were taken to address the issues.   
 
4.J:  Stormwater Pollution Prevention Training (SW100) reviews the concepts of stormwater 
pollution prevention; summarizes the CGP and MS4 regulatory requirements at SNL/NM; and 
provides guidance on spill prevention/response and best management practices.  Members of 
the workforce of DOE and Sandia whose job duties include any of the following responsibilities 
are required to take SW100 annually: 
• Design, install, maintain, or repair stormwater controls, conduct inspections, or 
implement corrective actions at construction sites. 
• Plan, review, permit or approve construction site plans, inspections and corrective 
actions. 
• Hold a role as a construction site operator, contractor or provide support. 
• Operate or maintain SNL/NM grounds or landscaping, fleet, buildings (outside), roads, 
stormwater inlets or drainage system, or work on projects with any ground disturbance. 
• Design projects that control the effects to water quality from stormwater runoff. 
• Plan or review projects with regard to stormwater quality standards and pollution 
prevention controls. 
Stormwater Discharges from Industrial Sites Training (SW200) exists for activities/sites 
related to stormwater runoff from industrial sites/activities regulated by the MSGP.  SW200 
is required for members of the workforce of DOE and Sandia who work in one or more of the 
industrial MSGP-permitted areas, or whose job duties include the responsibility for 
implementing stormwater pollution prevention controls/activities in those areas. Section 5- 
Illicit Discharge Elimination 
 
5.C:  There are four outfalls from the MS4, which are coincident with the following monitoring 
locations: 
• SWSP-05 
• SWSP-24 
• SWSP-35 
• SWSP-36 
 
A description of MS4 outfalls is provided in SWMP Plan Section 12.2.1.  Maps of MS4 outfall 
locations and their drainage areas are provided in Appendix B of the SWMP Plan.   
 
5.G:  Outfalls screening is conducted at least twice per week per outfall.  Auto-samplers are 
operational year-round to collect potential non-stormwater samples, which would allow for 
water quality assessments to help identify the source.  Informal scans are conducted as 
frequently as daily by field personnel and other environmental staff trained to monitor for 
leaks, spills, and other discharges.  Formal screening will be conducted and documented at least 
once every five years which will include the inspection of all known outfalls and MS4 
conveyance structures for the presence of non-stormwater discharges.  Illicit discharges that 
are discovered will be sampled (as appropriate), tracked to a source, and corrected through 
administrative or engineered control measures.  A database will be maintained for the duration 
of the Permit term to document non-stormwater and illicit discharges. 
5.J:  Only 1 Illicit discharge was detected during the reporting period.  A stuck valve caused a 
cooling tower on the south side of Building 810 to overflow; approximately 1,000 gallons of 
water was released to the stormdrain system.  This incident was reported to EPA and NMED by 
DOE.  Corrective action has been implemented, including replacement of the valve. 
 
5.L:  See Addendum 4.J. 
Section 6- Stormwater Management for Municipal Operations 
6.C:  DOE and Sandia conduct construction stormwater inspections as per the 2012 CGP.  
Specific details and metrics are provided in Section 5.6 of the SWMP Plan. 
• During the wet season (July 1 through October 31): 
o Active or unstabilized construction areas at SNL/NM that discharge to the Rio 
Grande via adjacent MS4s are inspected every 7 days and within 24 hours of a 
storm event of 0.25 inches or greater. 
o Active or unstabilized construction areas at SNL/NM that discharge to Tijeras 
Arroyo are inspected every 14 days and within 24 hours of a storm event of 0.25 
inches or greater. 
• During the dry season (November 1 through June 30): 
o Active or unstabilized construction areas at SNL/NM are inspected once per 
month and within 24 hours of a storm event of 0.25 inches or greater. 
• Construction areas where stabilization has been completed (and permit termination has 
not yet been filed) are inspected monthly. 
 
DOE and Sandia conduct industrial stormwater inspections per the 2015 MSGP at each 
permitted site once every quarter of the calendar year.  One quarterly inspection is conducted 
during a time when a stormwater discharge is occurring (or has the potential to occur).  
Inspections are conducted more frequently than quarterly if there are significant findings 
identified during routine inspections and where sector-specific requirements require more 
frequent inspections. 
 
The inspections required by the MS4 Permit in addition to those required by the CGP and MSGP 
that also satisfy the requirements of the MS4 Permit, are discussed in Addendum 7.I. 
 
6.D:  The following is a list of operating procedures and management specific to stormwater 
that have been developed.  For additional details see SWMP Plan section 7. 
• Sediment control plan 
• collection of used motor vehicle fluidsand toxics (including paint, solvents, fertilizers, 
pesticides, herbicides 
• Cleaning and disposal of trash and/or sediment form stormwater basins 
• Street cleaning 
• Fertilizer use 
• Pesticide use 
• Solid waste collection and management 
 
6.G:  See Addendum 4.J. 
 
6.H:  Stormwater Pollution Prevention Training (SW100) and Stormwater Discharges from 
Industrial Sites Training (SW200) are reviewed annually and updated as necessary. 
Section 7- Long Term (Post-Construction) Stormwater Measures 
7.B:  SNL is a Federal facility and currently complies with the Energy Independence and Security 
Act (EISA), Section 438 of the Clean Water Act (CWA).  The purpose of Section 438 is to 
preserve or restore predevelopment hydrology for all development and redevelopment 
projects with a footprint that exceeds 5,000 gross square feet (GSF).  Compliance with EISA 
required SNL facilities to manage post-construction runoff by detaining stormwater on-site via: 
1) detention of the runoff from a 95th percentile storm or 2) calculating the pre-development 
and post-development runoff, and detaining the volume difference. 
 
New buildings, major renovations and alterations of buildings greater than 5,000 GSF at SNL 
must comply with the Guiding Principles for Federal Leadership in High Performance 
Sustainable Building.  Where the work exceeds a footprint of 5,000 sq.-ft. and $5 million, 
buildings must achieve the U.S. Green Building Council’s certification of Leadership in Energy 
and Environmental Design (LEED) Gold for New Construction.  A design charrette occurs in the 
construction planning stages of each project to demonstrate compliance with 
GI/LID/Sustainable Practices through compliance with LEED standards. 
 
7.F:  Sandia’s Facilities Management and Operations Center (FMOC) Design Standards Manual 
includes the Section 438 requirements and provides guidance on its use, based on EPA’s 
“Technical Guidance on Implementing the Stormwater Runoff Requirements for Federal 
Projects under Section 438 of the Energy Independence and Security Act”, dated December 4, 
2009.  The publically-accessible link for Section 438, and associated guidance and fact sheets is: 
https://www.epa.gov/polluted-runoff-nonpoint-source-pollution/stormwater-management-
federal-facilities-under-section-438. 
 
 
7.G:  There were 2 development and redevelopment plans reviewed during the reporting 
period to assess impacts to water quality and receiving stream protection.  These two projects 
are: 
• 9920 to 9956 Fiber Line 
• Eubank Contractor Gate 
 
7.I:  MS4 Part I.D.5b.(ii)(c) requires permittees to perform inspections of stormwater 
management structures during construction and post-construction to verify BMPs are built and 
operating as designed.  Since permit inception there have been no stormwater BMPs installed.  
As they are completed, stormwater BMPs installed since the MS4 Permit became effective will 
be included for annual inspections.   
 
7.K:  In the event controls need to be replaced/repaired/maintained; and 1) the repair or 
replacement is not significant; and 2) it can be corrected through routine maintenance, the 
work is required to be initiated immediately1 and completed by the close of the next work day.   
Action(s) to minimize or prevent the discharge of pollutants will be immediately initiated and 
maintained until a permanent solution is installed and made operational.  This includes cleaning 
up any contaminated surfaces so that the material will not discharge in subsequent storm 
events.  In the event that a required stormwater control was never installed, was installed 
incorrectly, or was not installed in accordance with permit requirements, the control is required 
to be installed, repaired and/or made operational within 7 calendar days from the date of 
discovery. 
 
7.L:  Enforcement authority is limited in scope as discussed in Addendum 4.G. 
 
7.O:  All Stormwater Program personnel have access to the electronic tool (e.g., GIS, database, 
spreadsheet) used to track post-construction, BMPs, inspections and maintenance. 
 
7.P:  See Addendum 4.J. 
Section 8- Program Resources 
8.A, B and C: Per Part III.B.4 of the MS4 Permit, this question is only applicable to Class A 
permittees.  DOE and Sandia are Class C permittees. 
 
8.D:  The 5.0 estimated FTEs required to implement the stormwater program include field staff, 
professional staff, and management. Approximately 4.5 FTEs are provided by Sandia and 0.5 
FTE are provided by DOE.  None of the staff or management that contribute to the 5.0 FTE work 
exclusively on the stormwater program.    
 
                                                     
1 “Immediately” means corrective actions will be initiated on the same day as discovery to minimize or prevent the 
discharge of pollutants until a permanent solution is installed and made operational.  However, if the problem is 
identified at a time in the work day when it is too late to initiate corrective action, corrective action is required to 
begin on the following work day. 
8.E:  DOE (as owner of SNL) and Sandia (as operator of SNL) share responsibility for the SNL 
MS4.  DOE and Sandia together will comply with all of the requirements of the MS4 Permit, but 
will do so independently of participation in a cooperative group.  DOE and Sandia may share 
monitoring data with other MS4s when the sharing of such data is useful to DOE and Sandia, or 
to the other entity.  The sharing of data shall not be construed as evidence of the existence of a 
cooperative program or a shared responsibility for meeting Permit requirements. 
Section 9- Evaluating/Measuring Progress 
9.A:  This answer is limited to non-stormwater discharges for this reporting period.  Additional 
tracking measures are expected when stormwater data is collected in future years. 
Section 10- Additional Information 
Information required in Parts I.C, I.D, and III.B is provided in the Updated SWMP Plan submitted 
in conjunction with this Annual Report. 


U.S. Doe MS4 Annual Report

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U.S. Doe MS4 Annual Report

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