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DOT Harbors Construction and Post-Construction Program
MALAMA I KE KAI - PROTECT OUR
HARBOR WATERS
Harbors Program
• Harbors has NPDES permits for MS4s at: – Honolulu Harbor. – Kalaeloa Barbers Point Harbor. – Kahului Harbor.*
• Consent Decree. • SWMP details plan for compliance with
the permits. − http://hidot.hawaii.gov/harbors/library/storm-water-
management/
SWMP Definitions
• Construction = Land Disturbance. – Exempted projects:
Minor Land Disturbance Post Installation
Utility Repair
Minor Pavement Repair Maintenance
Harbor’s Construction Process Project Scoped (Determine Environmental Requirements)
Pre-Design Meeting*
Permits, Construction, PSMP, and Post-Construction Checklists
Project Review
Contractor Self Inspections
Initial Inspection
Regular Inspections
Final Inspection
Permanent BMPs
Long Term BMP O&M
Enforcement Actions
Design Review • Required Documentation by Project Type:
– Forms available in SWMP Section C and D. DOT Project Tenant Improvement Project
< 1 Acre 1 Acre + < 1 Acre 1 Acre +
• Harbors Notification Form
• Harbors Design Review Checklist
• NPDES Permit • SWPPP /
Construction Plans
• Harbors Post-Construction Checklist
• PSMP
• Harbors Notification Form
• Discharge or Connection Permit
• Harbors Design Review Checklist
• NPDES Permit • SWPPP /
Construction Plans
• Harbors Post-Construction Checklist
• PSMP • Discharge or
Connection Permit
Design Review Checklist
Permanent Post-Construction Design Checklist
Post-Construction Stormwater Mitigation Plan (PSMP)
Drainage Study and Conditions
of Concern
Identify potential
pollutants
Identify post-construction
BMPs
Complete PSMP
• Applicable to anticipated activities on the site AFTER construction is completed.
• Contents: • Narrative of project. • Site map. • Description of potential pollutants. • Drainage study and conditions of concern. • Post-Construction BMPs. • Maintenance requirements.
PSMP – Potential Pollutants
P = potential pollutant. Refer to Section 3.1 of Post-Construction Stormwater Management Manual.
PSMP – BMP Selection
• Select from these categories: – Low Impact Development (LID).
• Goal = Keep the stormwater on-site and treat it as a resource instead of a waste.
• Example = Conserve vegetated areas. – Source Control.
• Goal = Keep potential pollutants from coming into contact with stormwater runoff.
• Example = Covering a maintenance area. – Treatment Control.
• Goal = Remove pollutants from stormwater runoff. • Example = Hydrodynamic separators.
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PSMP – BMP Selection • Refer to City and County of Honolulu
resources. – BMP Manual for Construction.
(http://cleanwaterhonolulu.com/storm/learning_center/BMP_manual_2011-11.pdf)
– BMP Guide. (http://www.cleanwaterhonolulu.com/storm/notices/2012_sds_draft_rules/DPP_Storm_Water_BMP_Guide_(07-11-2012).pdf)
– Rules Relating to Storm Drainage Standards. (http://www.cleanwaterhonolulu.com/storm/notices/2013_sds/index.html)
• Required capacities: – Volume based BMPs must capture 1 inch of
stormwater. – Flow based BMPs must capture/treat rainfall
intensity of 0.4 inches per hour.
Plan Review
• Plan reviewers will look for: – Location and size. – Direction of storm water flow.
• Waterways (e.g. coastline, canals) and storm drains.
• Topography. • Ground cover and soil type.
– Locations of potential pollutants. • Land disturbance activities. • Staging areas. • Non-storm water.
Plan Review
• Plan reviewers will look for: – Scheduling / phasing.
• Is the main land disturbance activity planned for the dry season? (Apr – Sep)
• Have there been efforts to minimize the disturbed area?
– Responsible parties. • Does the Stormwater Pollution Prevention Plan
include the names or titles of parties responsible for: – Inspections? – Maintenance? – Recordkeeping? – Rain gauge monitoring? – Incident reporting?
Plan Review
• Plan reviewers will look for: – Temporary BMPs to address all potential
pollutants. – Plan for final stabilization. – Permanent BMPs, where required.
• LID considered first. • Ongoing maintenance plans.
– Applicable permit applications included.
Consent Decree Requirements
• Use the City and County of Honolulu Stormwater BMP Manual – Construction.
• Specific BMPs within the Consent Decree for: – Sites Disturbing 1 acres or more. – Roadway paving or repair. – Examples:
• Install inlet protection on all storm drains. • Restrict paving when raining. • Cover stockpiles.
Conducting Construction Site BMP Inspections
Construction Review • Project review after contract award:
– Contractor completes Stormwater Pollution Prevention Plan and provides to the Construction Manager (CM).
– CM will submit to Environmental Section (EE). – EE will send their comments to the CM through
memorandum. – Harbors Division will issue Notice to Proceed to
the contractor, specifying: • First work order is the installation of BMPs. • BMPs must be inspected prior to the start of any land
disturbance. – EE maintains an inventory of construction sites.
Construction Training Requirements
• Classroom Training for Inspectors: – General Program Management. – Construction Site BMP Inspections.
• Conduct at least 3 construction site inspections.
– Annual Refresher.
• Information Exchanges: – Pre-Bid Meeting. – Pre-Construction Meeting. – Video training.
Harbors BMP Inspections
• Initial Inspection: – BMPs are installed appropriately. – Deficiencies must be corrected prior to the start
of other construction work. • Regular Inspection:
– October to March: Every two weeks. – April to September: Every two months. – Deficiencies must be corrected or enforcement
will commence. – Inspector will provide the contractor with report
in five (5) calendar days.
Harbors BMP Inspections
• Final Inspection: – When all the following conditions are met:
• Construction is completed. • Exposed soil has been stabilized. • Remaining activities have minimal impact on
stormwater runoff.
– Ensure that permanent BMPs are properly installed, if applicable.
– Deficiencies must be corrected prior to issuance of final payment.
Harbors BMP Inspections
• 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.
• Signed by duly authorized representative.
– Ensure contractor has completed or has a plan for completion of maintenance and repair of BMPs.
– Any changes to BMPs must be documented.
BMP Inspection Checklist
• All inspections must be documented on the Construction Site BMP Inspection Checklist. – Included in the Construction Site Runoff
Control Manual, Att 4. – Environmental Section keeps original for
recordkeeping. – Copy provided to Contractor.
Construction Inspection Checklist
Construction Inspection Checklist
Harbors BMP Inspections
• Pre-Inspection Briefing. – Introductions. – Information exchange. – Review paperwork:
• Permits. • Training records. • Contractor Self-inspections. • Corrective action reports. • Monthly compliance reports. • Updated SWPPP.
Pre-Inspection
Briefing Site Walk
Post-Inspection
Briefing Follow-up
Harbors BMP Inspections
• Site Walk includes review of: – All BMPs. – Site perimeter. – All drains, canals, and receiving waters for
discharges.
• Post-Inspection Briefing – Identifies all areas for improvement
• Follow-up: Correction of deficiencies.
Pre-Inspection
Briefing Site Walk
Post-Inspection
Briefing Follow-up
Recent Inspection Findings
• Biosock without 6” overlap.
Recent Inspection Findings
• Solution: Mark 6” on the berm.
Recent Inspection Findings
• Biosock not “side-lapped.” Acceptable in this instance.
Recent Inspection Findings
• Silt fence must be installed properly.
Recent Inspection Findings
• Inlet Protection required on all drains.
Recent Inspection Findings
• Stabilized construction entrance must be installed per CCH BMP.
Recent Inspection Findings
• Dust fence needed.
Recent Inspection Findings
• Housekeeping – Sweep aggregate.
• Secondary containment for 55-gallon drums.
SWMP Enforcement Process • Upon discovery, contractor will immediately
correct deficiency. • Escalating enforcement, as required:
– Verbal warnings – CM. – Written warnings.
• Inspection report – CM. • Formal letter – CM. • Notice of Apparent Violation (NAV) – CM / HAR-EE.
– Notification provided to Department of Health. – Stop work orders - CM.
• Withholding of contractor payment. – Summons or citations – AG. – Referral to DOH / EPA.
Take Aways • All projects must be reviewed prior to start. • Projects over 1 acre must include post-construction
BMPs. • 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 City and County of Honolulu BMP manual, Harbor’s SWMP programs, Consent Decree, and construction documents.
Questions
MALAMA I KE KAI - PROTECT OUR HARBOR WATERS
• Harbors’ Website:
http://hidot.hawaii.gov/harbors/library/storm-water-management/.
• Harbor’s Contacts: – Reporting Hotline (Harbors Traffic Control): 587-2076. – Randal Leong, P.E.: 587-1962, randal.leong@hawaii.gov. – Joy Zhang, P.E.: 587-1960, ying.j.zhang@hawaii.gov. – Spencer Yim, P.E., 587-1963 Spencer.K.Yim@hawaii.gov. – Michele Freitas: 587-1976, michele.gn.freitas@hawaii.gov.
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