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NPDES Project Water Pollution Prevention and Compliance

NPDES Project Water Pollution Prevention and Compliance. The NPDES Project. NPDES Project origin DOH, DDC, WEC felt assistance and information would be more useful than penalties Everyone’s participation in this project affects DDC and WEC’s compliance with the enforcement action

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NPDES Project Water Pollution Prevention and Compliance

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  1. NPDES ProjectWater Pollution Prevention and Compliance

  2. The NPDES Project • NPDES Project origin DOH, DDC, WEC felt assistance and information would be more useful than penalties • Everyone’s participation in this project affects DDC and WEC’s compliance with the enforcement action • Project focuses on: • Personal assistance • Informational Sessions

  3. 3rd Party Inspection Assistance Brainstorming BMPs for your site NPDES Team: Here to help! DDC & Wastewater Project Required by DOH Enforcement Consists of: Skill Sessions Tools Personal Assistance Jenny, Codee, and Jamie 596-7790 NPDES@tlcghawaii.com Self-Inspections & Reports BMP Plan & SWPPP Reviews & Updates Presence @ Pre-Construction Meetings

  4. Untangling the Regulations The Players & What They Do

  5. Some Water Pollution Regulations Affecting Your Site Dewatering NPDES permits Stormwater Rules Relating to Water Quality & NPDES permits Hydrotesting NPDES permits

  6. The Feds (EPA) The County The State The Clean Water Act County Rules & Ordinances State Water Pollution Laws (HRS 342D) US Waters Are “Fishable & Swimmable” Hawaii’s Waters Are “Fishable & Swimmable” Activities in the CCH keep Hawaii’s waters fishable & swimmable National Pollutant Discharge Elimination System Hawaii’s National Pollutant Discharge Elimination System CCH MS4 Program Rules Relating to Water Quality

  7. Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! MS4 (storm drain systems) Program Construction Stormwater Program Construction Dewatering Program Permits (Individual and General) Permits (Individual and General) City’s MS4 Permit HIS000002 Requirements (like BMPs) Requirements (like BMPs) Requirements (like BMPs)

  8. Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! MS4 (storm drain systems) Program Construction Stormwater Program Construction Dewatering Program Permits (Individual and General) Permits (Individual and General) City’s MS4 Permit HIS000002 Requirements (like BMPs) Requirements (like BMPs) Requirements (like BMPs)

  9. The HAR 11-55 allows for penalties and criminal charges for “falsification” Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! Construction Stormwater Program General Permit (HAR 11-55, Appendix C) Individual Permits (HI######) Notice of General Permit Coverage HIR10E123 Permits (Individual and General) 1 acre or more of disturbance? or Notice of Start (7 days) SWPPPs Verbal & Written Non-Compliance Reports Requirements (like BMPs) General Contractor Info Weekly and/or 0.25” Rain Inspections Notice of Cessation Certifying Person/Rep

  10. Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! MS4 (storm drain systems) Program Construction Stormwater Program Construction Dewatering Program Permits (Individual and General) Permits (Individual and General) City’s MS4 Permit HIS000002 Requirements (like BMPs) Requirements (like BMPs) Requirements (like BMPs)

  11. The HAR 11-55 allows for penalties and criminal charges for “falsification” Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! Construction Dewatering Program General Permit (HAR 11-55, Appendix G) Individual Permits (HI######) Notice of General Permit Coverage 18GE123 Dewatering to a state water or storm drain? Permits (Individual and General) or Requirements (like BMPs) Verbal & Written Non-Compliance Reports Notice of Start (7 days) Dewatering Plan Sampling (weekly) General Contractor Info Notice of Cessation Certifying Person/Rep Monthly Reports

  12. Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! MS4 (storm drain systems) Program Construction Stormwater Program Construction Dewatering Program Permits (Individual and General) Permits (Individual and General) City’s MS4 Permit HIS000002 Requirements (like BMPs) Requirements (like BMPs) Requirements (like BMPs)

  13. * RRTWQ allows for penalties * MS4 program can be penalized by DOH Hawaii’s National Pollutant Discharge Elimination System When your site discharges to state waters! Annual “Inquisiq” training Annual conference @ Blaisdell Construction Runoff Control Program 3rd Party Inspections Minor/major/critical deficiencies BMP requirements Rules Relating to Water Quality BMP plan or ESCP approved by DPP ESCP Coordinator Inspections

  14. Construction Stormwater Program Construction Dewatering Program City’s Rules Relating to Water Quality City’s MS4 Program Notice of Start (7 days) Notice of Start (7 days) Notice of Start Deficiency Tracking (Minor, Major, Critical) General Contractor Info Sampling & Lab Testing DPP-approved ESCPs 3rd Party Inspections Monthly Discharge Monitoring Reports SWPPPs Inspections (how often is based on risk) Inspection Checklists Weekly and/or 0.25” Rain Inspections Verbal & Written Non-Compliance Reports ESCP Coordinator Training: Inquisiq/Ecatts & Annual Blaisdell Verbal & Written Non-Compliance Reports Notice of Cessation Notice of Cessation

  15. Activity! This Photo by Unknown Author is licensed under CC BY-SA-NC Add a footer

  16. Reporting Non-Compliances When to report, what to report

  17. When to report non-compliances The most important time to report to the authorities: Polluted Discharges (or evidence of them) • Muddy storm water • Illicit discharges • Dewatering effluent that exceeds permit limits Notify the regulators so they can decide if actions are needed to protect the public.

  18. Why should we report? • Being up-front builds trust with regulators • When there is trust, there is less need to enforce with severity • Minimize the enforcement associated with polluted discharges • There are penalties specifically for not reporting! • There are “discounts” specifically for being cooperative! • Protect the community • The only time you become personally liable is when you lie Add a footer

  19. Report to DOH or SWQ if it reaches a: Storm drain State water (stream, dry gulches, ocean, wetland, etc.) Muddy Storm Water Report to DOH-Clean Water Branch 808-586-4309 (business hours) 808-247-2191 (after hours) Report to DFM-SWQ 808-768-3245 Applies to all of your City construction projects It doesn’t matter if the site has an NPDES permits Utilize the Non-Compliance Report Form If your site discharges polluted storm water… Determine where it goes Estimate the rough volume Utilize your contingency plan Notify designated site personnel

  20. Potential Pollutants on Site Washouts: Concrete, Plaster, Paint Solvents Fertilizer Form Oil Curing Compound Illicit Discharges Report to DOH-Clean Water Branch 808-586-4309 (business hours) 808-247-2191 (after hours) Report to DFM-SWQ 808-768-3245 Applies to all of your City construction projects It doesn’t matter if the site has an NPDES permits Utilize the Non-Compliance Report Form Fuel Equipment fluids & greases Porta Potties Powdered materials (grout)

  21. Dewatering Discharges Report to DOH-Clean Water Branch 808-586-4309 (business hours) 808-247-2191 (after hours) Report to DFM-SWQ 808-768-3245 Applies to projects with dewatering Applies to projects with an NPDES dewatering permit Utilize the Non-Compliance Report Form If your site dewaters and… Dewatered effluent is discharged to a storm drain or state water without permit coverage Dewatered effluent has permit coverage, but exceeds permitted limits

  22. Potential Signs of a Sewage Spill Grayish-black color Toilet paper speck/residue Odor Ground has unexplained, persistent dampness Sewage Spills Report to DOH-Clean Water Branch 808-586-4309 (business hours) 808-247-2191 (after hours) Report to DFM-SWQ 808-768-3245 Applies to all of your City construction projects It doesn’t matter if the site has an NPDES permits Utilize the Non-Compliance Report Form https://www.hawaiitribune-herald.com/2018/08/25/hawaii-news/lane-triggers-sewage-spills-at-hilo-bay-puhi-bay/ https://www.al.com/news/index.ssf/2017/09/adem_rolls_out_email_notificat.html

  23. Information to Report • Date/Time of discharge • What the discharge contained (soil, concrete washout, etc.) • Estimated volume of discharge • What occurred to cause discharge • How future discharges will be prevented • Any other non-compliances that need to be reported • NPDES permit if applicable

  24. Reporting Guides • 2 Reporting Guides: Construction Stormwater & Dewatering • Copy included in your handouts • Also available for download: https://tlcghawaii.sharefile.com/d-s158d9ed836445c48 If your site has a discharge, TLCG is available to assist your through the reporting and correction process!

  25. Please offer us feedback through our survey! Hard copies available; or utilize this QR code to do the survey on-line! Questions? Contact us with any questions or requests for assistance with stormwater or dewatering compliance! Codee, Jenny, or Jamie @ 808-596-7790 or NPDES@tlcghawaii.com

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