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DOT Airports Construction and Post-Construction Program
MALAMA I KE KAI - PROTECT OUR
WATERS
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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/
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Storm Water Management Program Plans
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SWMP Plan Definitions
• Construction = Land Disturbance. – Exempted projects:
Interior Renovations
Post Installation
Utility Repair
Minor Pavement Repair Maintenance
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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
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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)
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Notification Form for Sites <1 Acre
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Design Review Checklist
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Permit to Discharge
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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.
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Permanent BMP Selection Process
Identify Pollutants of
Concern
Identify Candidate BMPs
Determine BMP Size / Capacity
Incorporate Operations
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
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Permanent BMP Selection Process
Identify Pollutants of
Concern
Identify Candidate BMPs
Determine BMP Size / Capacity
Incorporate Operations
Maintenance Plan
BMP Nutri
ents
Sedi
men
t
Tras
h
Bact
eria
Pest
icide
s
Oil &
Gre
ase
Meta
ls
Orga
nic
Com
poun
ds
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
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Permanent BMP Selection Process
• 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.
Ord
er o
f P
refe
ren
ce
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Permanent BMP Selection Process
• 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.
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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.
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Low Impact Development (LID)
• Treatment Techniques: – Green Roof – Rain Gardens – Cisterns – Bioretention – Bioswales – Infiltration Basins – Vegetative Buffers
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Preferred Permanent BMPs
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Ideal Implementation: •Along streets, taxiways, runways, and parking lots.
Preferred Permanent BMPs
• Bioswales: – Vegetated, mulched, or xeriscaped channels that
provide treatment and retention. – Refer to SWMPP Section D, PC13.
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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.
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Preferred Permanent BMPs
• 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.
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Preferred Permanent BMPs
• 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.
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Preferred Permanent BMPs
• 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.
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Preferred Permanent BMPs
• 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).
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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?
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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
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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.
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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
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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.
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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
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Conducting Construction Site BMP Inspections
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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
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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.
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Airports BMP Inspections
• 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.
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Airports 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.
– 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.
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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).
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Airports BMP Inspections
• 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
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Airports BMP Inspections
• 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
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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.
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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.
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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.
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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/