Willow Grove, Pennsylvania


HRP was responsible for developing a Storm Water Preparedness, Prevention & Contingency Plan (PPC Plan) to comply with requirements of NPDES stormwater permitting in the State of Pennsylvania.  HRP identified 17 of the client's workcenters that qualified as “industrial activity” under the applicable regulations. The PPC included two components – a base-wide plan for overall administrative activities, and a set of 17 individual work-center modules.  The work-center modules were designed to decentralize and delegate site-specific pollution prevention actions to personnel most familiar with and most able to control day-to-day activities.

Initially, fourteen (14) catchment areas and their storm water outfalls were identified on Base property. Each work-center and it’s associated potential pollutants were identified and listed under the relevant outfall.  A base-wide Pollution Prevention Team of key Base personnel including the Fire Department, Public Works and Training was established under the authority of the Base Environmental Officer. Points-of-Contact at each work-center were also assigned to the Team.

Each work-center module contained an activity description, drainage analysis, pollutant sources, monitoring and training.  An evaluation of deicing and anti-icing activities on the airfield was performed.  The use of propylene glycol (deicing) and Urea (anti-icing) were identified.  Discharge of these chemicals in storm water runoff is minimized through the use of indoor and outdoor application areas where excess liquid is directed to oil/water separators and to the sanitary sewer. Recommendations for center-specific Best Management Practices (BMPs) were included in the final PPC and, where applicable, an implementation schedule was established.