Construction Inspector Training - Storm Water HawaiiStorm ......– Location of near by drainage systems, streams, canals, wetlands, ponds, State water bodies. – Scheduling and Construction

DOT Airports Construction and Post-Construction Program

MALAMA I KE KAI - PROTECT OUR

WATERS

AIRPORTS Program • Airports has NPDES permits for MS4s at:

– Honolulu International Airport – Kahului Airport

• Storm Water Management Program Plan

details plan for compliance. • Section C: Construction Site Run-off Control

Program • Section D: Permanent BMPs Program − http://hidot.hawaii.gov/airports/doing-

business/engineering/environmental/construction-site-runoff-control-program/

Storm Water Management Program Plans

SWMP Plan Definitions

• Construction = Land Disturbance. – Exempted projects:

Interior Renovations

Post Installation

Utility Repair

Minor Pavement Repair Maintenance

Airports Construction Process Project Scoped (Determine Environmental Requirements)

Design Meeting / Design Charrette*

Permits, Construction Plans/Specs, PBMPs, and Design Review Checklists

Project Review

Contractor Self Inspections

Initial Inspection

Regular Inspections

Final Inspection

Permanent BMPs

Long Term PBMP O&M

Enforcement Actions

Design Review • Required Documentation by Project Type:

– Forms available in SWMP Section C and D. DOT Project Tenant Improvement Project Offsite Projects

Discharging to Airports MS4 < 1 Acre 1 Acre + < 1 Acre 1 Acre +

• Notification Form

• NPDES Permit for Hydrotesting Dewatering activities (if applicable)

• Design Review Checklist

• NPDES Permit

• SWPPP / SSBMP Plan

• Notification Form

• Permit to Discharge

• Connection Permit (if necessary)

• Design Review Checklist

• NPDES Permit

• SWPPP / SSBMP Plan

• Permit to Discharge

• Connection Permit (if necessary)

• Notification Form (< 1 acre)

• Discharge or Connection Permit

• NPDES Permit (if applicable)

Notification Form for Sites <1 Acre

Design Review Checklist

Permit to Discharge

Permanent BMP Selection Process

Identify Pollutants of

Concern

Identify Candidate BMPs

Determine BMP Size / Capacity

Incorporate Operations

Maintenance Plan

• Projects Requiring Permanent BMPs: • Site disturbing one acre or more • Site less than one acre that install one of the following:

• Steep earth embankments • Parking Lots/Buildings creating additional impervious area

> 10,000 SF and are within 50’ of a surface water body. • Uncontained aircraft, vehicle, or equipment washing area • Fueling or petroleum storage areas that exceed regulatory

threshold for SPCC plans in 40 CFR 112. • Modification, replacement, installation of new drainage

structures.



Concern




Maintenance Plan

• Projects Exempt from Permanent BMPs: • Trenching and resurfacing associated with utility work. • Resurfacing or replacement of damaged pavement. • Discontinuous or interior renovation sites. • Storm water runoff does not discharge to a receiving

waters. • Projects returning site to pre-development conditions • Sites where permanent BMPs may be prohibited due to

aircraft operational constraints • Emergency



Concern




Maintenance Plan

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Infiltration Basin H H H H H H H H Infiltration Trench H H H H H H H H Subsurface Infiltration H H H H H H H H Dry Well H H H H H H H H Bioretention Basin H H H H H H H H Permeable Pavement H H L H H H H H Green Roof M H H M M H M M Vegetated Bio‐Filter M H H M U H H H Enhanced Swale M H H U U M M U Downspout Disconnection L M M M U M M U Vegetated Swale L M L L U M M U Vegetated Buffer Strip L M M L U M M M Harvesting / Reuse H H L H H H H H Detention Basin L M H L U M L/M U Manufactured Treatment Device L M/H H L L M/H L L Sand Filter L/M H H M U H M/H M/H Note: H= High, M = Medium, L = Low, U = Unknown *Reference from City and County of Honolulu, Storm Water BMP Guide


• Select from these categories: – Low Impact Development (LID).

• Goal = Keep storm water on-site and treat it as a resource instead of a waste by means reusing, infiltrating, storing, detaining, evapotranspiring, and/or biotreating runoff .

– Source Control. • Goal = Keep potential pollutants from coming

into contact with storm water runoff. – Treatment Control.

• Goal = Remove pollutants from storm water runoff.

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• Resources for PBMPs: – Airports SWMP Section D PBMP Manual – HWY Storm Water PBMP Manual. – CCH Storm Water BMP Guide. – CCH Rules Relating to Storm Drainage Standards.

• Sizing capacities: – Volume based BMPs must capture 1 inch of

storm water off. – Flow based BMPs must capture/treat rainfall

intensity of 0.4 inches per hour.

Low Impact Development (LID)

• LID is a strategy seeking to control storm water quality at its source, incorporating such elements as infiltration, retention, and biofiltration.

• Primary goal: Mimic the site’s pre-development runoff characteristics.

• Promotes natural infiltration to occur as close as possible to the source.

• Storm water is treated as a resource rather than a waste product.

Low Impact Development (LID)

• Treatment Techniques: – Green Roof – Rain Gardens – Cisterns – Bioretention – Bioswales – Infiltration Basins – Vegetative Buffers

Preferred Permanent BMPs

Ideal Implementation: •Along streets, taxiways, runways, and parking lots.


• Bioswales: – Vegetated, mulched, or xeriscaped channels that

provide treatment and retention. – Refer to SWMPP Section D, PC13.

Preferred Permanent BMPs • Pervious Pavement

– Paved surfaces that infiltrate, treat, and/or store rainwater where it falls.

– Refer to SWMPP Section D PC18 or “porous asphalt pavement.”

Ideal Implementation: •Areas where land values are high. •Areas where flooding is a problem.


• Underground Detention System. – Capture flow and retain then infiltrates into the soil

or release it slowly over time, thereby decreasing peak flows and associated flooding problems.

– Refer to EPAs September 2001 Storm Water Technology Fact Sheet on “Site Underground Retention/Detention” (832-F-01-005).

Ideal Implementation: •Areas with available land and low costs •Parking lots •Large buildings.


• Hydrodynamic Separators. – Flow through structures with a settling or separation

unit to remove sediments and other pollutants. – Refer to SWMPP Section D, PC22.

Ideal Implementation: •Areas where materials to be removed from runoff are heavy particulates – which can be settled – or floatables –which can be captured, rather than solids with poor settle abilities or dissolved pollutants.


• Oil Water Separators – Separates oil from oily water before discharge. – Refer to SWMPP Section D, PC21.

Ideal Implementation: •Areas where vehicle repairs or washing take place.


• Storm Drain Inserts – Typically installed in a grate or curb inlet sump to

capture sediment, debris and pollutants. – Consult with district maintenance prior to selecting

a specific type or brand.

Ideal Implementation: •Where other BMPs are not sufficient. •Where excessive solid waste is expected (e.g. landscaping).

Storm Water Plan Review

• Plan reviewers will look for: – General location and project size. – Direction of storm water flow.

• Waterways (e.g. coastline, canals) and storm drains. • General Topography • Soil erodibility. • Existing and proposed ground cover.

– Potential non-storm water discharges. – Phasing

• Is the main land disturbance activity size limited or minimized during dry periods.

• Have there been efforts to minimize the disturbed area by appropriate project phasing?

Storm Water Plan Review • Plan reviewers will look for:

– Applicable regulatory and permit General Notes. – Activities that result in land disturbance and construction

support activities. • Clearing & Grubbing • Graded / Stabilized Areas • Excavating & Trenching • Ingress / Egress • Potential sediment tracking on public roadway • Material storage area • Inlet protection • Concrete Washout • Prime coat, form oil, curing compound, paints, • Hazardous Waste • Litter, Foreign Object Debris (FOD) control

Storm Water Plan Review

• Plan reviewers will look for: – Temporary construction BMPs to address all

potential pollutants. – Final stabilization. – Permanent BMPs, where required.

• LID considered first. • Understand the maintenance complexity of the

Permanent BMP

– Applicable permit applications.

SSBMP Plan / SWPPP Review

• SSBMP Plan or SWPPP must identify the activities and measures to be used to eliminate, minimize, or mitigate pollutants that are reasonably expected to be present during course of a project.

• Reviewers will check if the following are applicable: – NPDES Form C, Form F, Form G, Individual Permit – Section 401 Water Quality Certification – Section 404 DA Permit, NWP, Section 10 – Coastal Zone Management Permit – Special Management Permit

SSBMP Plan / SWPPP Review • Reviewers will check if the following are applicable:

– Existing and Proposed Features – Location of near by drainage systems, streams, canals,

wetlands, ponds, State water bodies. – Scheduling and Construction Phasing – Schedule for installation of BMPs, inspections, and

maintenance. – Implementation of soil stabilization, sediment control,

pollution control, non-storm water management. – Location of BMPs, preservation of existing vegetation. – Employee training, equipment refueling BMPs, spill kits.

• Recommend SWPPP mimic requirements in HAR 11-55 Appendix C.

Construction Training Requirements

• Classroom Training for Personnel: – General Storm Water Program Management. – Construction Site BMP Inspections.

• Information Exchanges:

– Pre-Bid Meeting. – Pre-Construction Meeting. – Video training.

– Annual Construction BMP Training Video

Conducting Construction Site BMP Inspections

Airports Construction Process Project Scoped (Determine Environmental Requirements)

Design Meeting / Design Charrette*

Permits, Construction Plans/Specs, PBMPs, and Design Review Checklists

Project Review

Contractor Self Inspections

Initial Inspection

Regular Inspections

Final Inspection

Permanent BMPs

Long Term PBMP O&M

Enforcement Actions

Airports BMP Inspections

• Initial Inspection: – BMPs are installed appropriately. – Deficiencies must be corrected prior to the

start of other construction work.

• Regular Inspection: – Deficiencies must be corrected or

enforcement will commence. – Inspector will provide the contractor with

report in 24 hours.


• Final Inspection: – When all the following conditions are met:

• Construction is completed. • Exposed soil has been stabilized.

– Ensure that permanent BMPs are properly installed, if applicable.

– Deficiencies must be corrected prior to issuance of satisfactory acceptance.


• Review completed Contractor Self Inspections: – For sites with NPDES permit:

• Contractor’s self inspections weekly AND within 24 hours of a 0.25 inch rainfall.

– Ensure contractor has completed or has a plan for completion of maintenance and repair of BMPs.

– Any changes to BMPs or site conditions must be documented.

BMP Inspection Checklist

• All inspections should be documented on the Construction Site BMP Inspection Checklist. – Section C: Construction Site Runoff Control

Program Plan, Att. C.6. – Attach photos of deficiencies. – AIR-EE shall keep records in database. – Forward copy to SPM, CM, Contractor, (AIR-

EE).


• Pre-Inspection Briefing. – Introductions. – Information exchange. – Review Contractor’s Field Documents:

• Permits. • Training records. • Contractor Self-inspections. • Corrective action reports. • Monthly compliance reports. • Updated SWPPP.

Pre-Inspection

Briefing Site Walk

Post-Inspection

Briefing Follow-up


• Site Walk includes review of: – All BMPs – Site perimeter – Potential non-storm water discharges – All drains, canals, and receiving waters for discharges

• Post-Inspection Briefing – Identifies deficient areas (minor, major, critical

Deficiencies)

• Follow-up: Correction of deficiencies.

Pre-Inspection

Briefing Site Walk

Post-Inspection

Briefing Follow-up

Common Inspection Findings BMP Plan was not available/updated.

• The BMP Plan is a living document. – The plan should be continually updated to reflect

current site conditions. – Changes should be signed by certifying person

or duly authorized representative. – The plan should be readily available to inspectors

and workers on site.

SWMP Enforcement Process

• Upon discovery, contractor will promptly respond and correct deficiency.

• Escalating enforcement, as required: – Verbal warnings – Written warnings

• Inspection report • Formal letter • Notice of Apparent Violation (NAV)

– Notification provided to Department of Health.

– Stop work orders • Withholding of contractor payment.

– Referral to DOH / EPA.

Take Aways • All projects must be reviewed prior to start. • Projects over 1 acre must include PBMPs. • Inspections are required by Consent Decree and

NPDES permits. – Inspections are an important tool to catch problems

before they result in regulatory enforcement. • Main goal is to ensure that pollutants are not

contaminating receiving waters or MS4. – Best if potential pollutants can be kept on-site!

• It is cheaper to implement BMPs than pay the regulatory fine including stipulated penalties.

• Be familiar with Airports SWMP Plans, City and County of Honolulu BMP manual, Consent Decree, and other resources.

Questions

MALAMA I KE KAI - PROTECT OUR HARBOR WATERS

• Airports’ Website:

http://hidot.hawaii.gov/airports/doing-business/engineering/environmental/construction-site-runoff-control-program/