Maintaining Compliance at Petroleum Storage Terminal Complex
Four petroleum terminals jointly own and operate a massive stormwater retention basin. The stormwater system has a seven-million-gallon design storage capacity, mechanical spillway capacity for a 25-year storm, and emergency spillway capacity for a 100-year storm. The basin ultimately discharges into an unnamed tributary and operates under a five-year Virginia Pollutant Discharge Elimination System (VPDES) permit. Routine discharge monitoring reports are submitted to the Virginia Department of Environmental Quality.
GES assumed responsibility for the stormwater management program after regulatory concerns arose from the inability of two previous consultants to effectively manage the permit compliance monitoring. To assess the compliance issues, GES completed a thorough review of the previous permit, discharge monitoring reports, and on-site recordkeeping, and opened a dialogue with regulating authorities and the four oil company owners of the facility. GES devised a plan to ensure compliance with regulatory requirements and generated a system to ensure monthly updates to the on-site record log.
Ongoing responsibilities include sampling, monitoring, and regulatory reporting; completion of an annual comprehensive site compliance evaluation; annual updating of the stormwater pollution prevention plan; and five-year permit renewal.
Open, consistent, and professional dialogue with regulators has ensured cooperation and resolution of any sampling concerns, thus enabling the system to maintain ongoing compliance. This proactive collaboration has resulted in no exceedances or regulatory concerns since GES assumed responsibility for the stormwater permitting and compliance management activities. GES also works with each of the four member facilities as an important component of the quality assurance process.