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.