National Pollutant Discharge Elimination System (NPDES)

Permit Requirements for Storm Water Discharges

Workshop sponsored by the
Hawaii Local Technical Assistance Program
in cooperation with the
Hawaii State Department of Transportation
University of Hawaii's Department of Civil Engineering
and the Federal Highway Administration

When:    March 6-7, 2000
Where:    University of Hawaii, East West Center, Asia Room
    1777 East West Road
Time:    8:00 a.m. - 4:30 p.m.
Cost:    FREE for HDOT and County, $125 for private industry personnel
Contact:  Hawaii LTAP at 956-9006, 956-8851 FAX or juli@wiliki.eng.hawaii.edu


DESCRIPTION:
Departments of Transportation face several unique challenges in complying with the National Storm Water program.

DOT CONSTRUCTION OPERATIONS
State DOTs are among the largest construction organizations operating in this country.  As such, many of their projects are subject to storm water discharge permit requirements during construction.  These requirements have recently been revised by the U.S. Environmental Protection Agency as a part of the development of Phase 2 of the National Pollutant Storm Water program.  New requirements that will allow certain projects to be undertaken without permit coverage at all have been instituted by the EPA.  Other requirements that reduce the acreage threshold from 5 acres to 1 acre have also been finalized for the Phase 2 program.  Different methods of complying with NPDES regulations for highway projects and several failed attempts at compliance will be discussed.

DOT INDUSTRIAL OPERATIONS
Many State DOTs have extensive vehicle maintenance facilities.  They may also operate other types of industrial facilities.  Under current storm water permit program requirements, these industrial activities are subject to their own individual permit obligations which may not be satisfied by construction or municipal storm water discharge permits.  The identification of an industrial transportation facility is among the most difficult determinations under the NPDES storm water program.  An industrial transportation facility is characterized not only by the type of material stored or used at the site, but also the extent of operations performed on vehicles there, the particular types of vehicles that are maintained at the facility, and other specific considerations.  State DOTs in particular tend to operate transportation maintenance facilities at locations in which other activities are also performed, such as storage of roadway signs and other safety equipment, storage of construction materials, and various types of other operations.  Under these circumstances, it can be difficult to determine whether a particular facility qualifies as an industrial transportation facility or not.

DOT MUNICIPAL OPERATIONS
State DOTs are also municipal entities which fall under the large municipality requirements of the Federal Water Quality Act Ammendments of 1987.  As such, they have an obligation to reduce pollutant discharge to the maximum extent practicable and to eliminate illicit discharges into the public drainage systems that they own and operate.  These include all gutters, inlets, catch basins, storm sewers, channels, and all other elements of the storm water drainage system at any scale.

TARGET AUDIENCE:
Personnel responsible for NPDES permits at State DOTs, county public works departments and similar organizations

INSTRUCTORS:
Roy D. Dodson, P.E., Dodson & Associates, Houston, Texas