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TRANSCRIPT
NAVFAC HAWAII
Guam Unique Challenges &
ePermitting System
Scot UradaNAVFAC Pacific
December 1, 2010
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PRESENTATION OUTLINE
* Guam & CNMI Military Relocation
* Finegayan & Unique Challenges
* Laws & Regulations
* Compliance Approach
*ePermitting System
*SWDA Submittal Requirements
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Guam & CNMI Military Relocation
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Guam & CNMI Military Relocation
• USMC: Okinawa to Guam• Apra Harbor wharf construction to support aircraft carrier• Relocating US Army Air & Missile Defense Task Force to Guam• $6B construction funds from Japan
• Approx. 8,600 Marines & 9,000 dependents• “transient” Navy personnel • Approx. 600 Army personnel & 900 dependents• Nearly 2,600 acres total land area• Develop over 1,100 acres• Construct: admin building, housing, training facilities, support
facilities, new or relocated utilities, and new or relocated roadways
• ….LOTS OF PROJECTS!
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Finegayan development area
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Land Uses in Finegayan
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Finegayan & unique challenges
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Finegayan & Unique Challenges
Existing conditions• Sole Source Aquifer• Karst geology & sinkholes
Protecting the drinking water• Federal Laws & Regulations• Local Laws & Regulations• Compliance to laws & regulations
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Limestone – Karst Conditions
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Karst geology with lots of sinkholes
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Aquifer
*Sole source aquifer
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Groundwater Management Protection Zone
Groundwater Protection Zone
Finegayan (Navy) Base Property Zone
Andersen (AF) Base Property
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Wellhead Protection Areas (1,000’ circles)
We need to protect Guam’s drinking water source by complying with regulations designed for this purpose.
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Laws and RegulationsCompliance Approach
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Laws, Regulations, andCompliance Documents
Laws and Regulations• Guam Administrative Rules, Title 22, Chapter 7• Guam Administrative Rules, Title 22, Chapter 6-Section 53106 of the Guam Safe Drinking Water Act-Section 6141.5 of Guam Primary & Secondary SDW Regs.• Section 438 of the Energy Independence and Security Act
DoD Compliance Documents• Unified Facilities Criteria (UFC) 3-210-10 & 3-210-10N• Dept. of Navy LID Policy for Storm Water Management
Other Standards and Guidance• CNMI and Guam Stormwater Management Manual
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Laws and Regulations
Guam Administrative Rules, Title 22, Chapter 7, Section 7130“…no person shall construct, utilize, operate, occupy or cause, allow or let, permit or suffer or to be constructed, utilized, operated or occupied any land use served or to be served by septic tank and leached field, sanitary sewer, storm water disposal method, or liquid waste storage, disposal or treatment method, and which is within the GWMPZ and within any 1,000 feet radius of any public utility potable water supply well, until the person has obtained prior written approval of the Administrator…”
Section 438 of the EISA“The sponsor of any development or redevelopment project involving a Federal facility with a footprint that exceeds 5,000 square feet shall use site planning, design, construction, and maintenance strategies for the property to maintain or restore, to the maximum extent technically feasible, the predevelopment hydrology of the property with regard to the temperature, rate, volume, and duration of flow.”
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DoD Compliance Documents
UFC 3-210-10, Low Impact Development• This UFC provides guidelines for LID planning, design, construction, and O&M• “…reduce the hydrologic impact of the development and to incorporate techniques
that maintain or restore the site’s hydrologic and hydraulic functions…”
UFC 3-210-10N, Low Impact Development• Provides technical criteria, requirements and references for the planning & design
to comply with stormwater requirements under EISA
• Maintain or restore predevelopment hydrology to the maximum extent technically feasible
• State and local standards for LID Integrated Management Practices (IMP) design shall be used if available.
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CNMI and Guam Stormwater Management Manual
• Provides minimum criteria for BMPs that are acceptable for meeting construction & post-construction stormwater criteria and water quality treatment goals
• Specifies that infiltration of stormwater runoff from “hotspots” is not allowed without prior water quality treatment, and that a Stormwater Pollution Prevention Plan (SWPPP) must be prepared and implemented for “hotspots” to reduce the generation of pollutants and prevent contact of rainfall with the pollutants.
• The Navy has made a commitment with GEPA to comply with this document in anticipation of the adoption of Guam’s updated Erosion Control and Stormwater Management Regulations into Guam’s new regulations.
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What does all this mean?
• Need to protect Guam’s water resources• Need Guam EPA’s approval for water systems (siting approvals
and design approvals)• Need Guam EPA’s approval for sewer system (design approvals)• Need Guam EPA’s approval for wellhead protection• Need to pay special attention to projects inside the 1,000’ circles*especially for “high risk” land uses/activities
• Follow standards and guidelines in the 2006 CNMI & Guam SWMM
• Follow DoD Low Impact Development policies
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Overall Stormwater Management & Compliance Strategy
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Planning
Design
Operations/ Maintenance
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Planning Phase
Mitigation Strategies
• Relocate certain types of activities (entire or pollutant-generating part) outside of WHPA
• Convey and infiltrate runoff outside WHPA
• Consider relocating certain wellhead(s) (possible example: low producing well with high chlorides) or consider shutdown of certain wellheads or designating them for non-potable use
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Planning: Categories of proposed“High Risk” Activities that encroach into WHPAs
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A. Vehicle fueling stations
B. Vehicle service and maintenance facilities
C. Vehicle and equipment cleaning facilities
D. Outdoor loading/unloading facilities
E. Facilities that generate or store hazardous materials and/or liquid or solid waste
F. Stormwater disposal facilities
G. Dining facilities / food preparation
H. Engineering Training Pit
*Also we need to pay special attention to parking lots
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Design Phase – LID Site Design
LID Site Design strategies reduce the hydrologic impact of development and incorporate techniques that maintain or restore the site’s hydrologic and hydraulic functions to pre-project conditions. Strategies include:
• Reduce amount of impervious areas
• Disconnect impervious areas
• Direct runoff into or across vegetated areas
• Preserve, or design into the infrastructure, naturally vegetated areas that are in close proximity to parking areas, buildings, and other impervious expanses in order to slow runoff, filter out pollutants, and facilitate infiltration
**Taking care of water “at the source” instead of the traditional “end of pipe” approach using small scale approaches or Integrated Management Practices (IMPs)**
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Design Phase – BMP/IMP &Treatment Trains
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Pollutants of concern:• TSS• Nutrients (TN and TP)• Metals• Bacteria• Hydrocarbons
BMP/IMP Treatment Trains are multiple treatment devices operatingin series designed to remove specific pollutants of concern.
* Finegayan Main Cantonment Area Comprehensive Drainage and Low ImpactDevelopment Implementation Study Final Report (April 2010)
Applicable BMPs/IMPs*:• Proprietary oil/grit separator; Filter Strip, Dry Swale, Bioretention
Basin, TSS filter Chamber, Inlet Protector, Rain Barrel / Cistern
Treatment Trains developed for*:• Roof Runoff• Impervious paved areas w/insignificant oil or suspended metals• Impervious paved areas w/significant oil or suspended metals• Impervious paved roadways with insignificant oil or suspended
metals• Landscaping, grass and recreational areas• Site-Optional porous pavement (non-vehicle)
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Design Phase – Source Control BMPs
Source Control BMPs are low-technology practices designed to prevent pollutants from contacting runoff or to prevent discharge of contaminated runoff to the storm drainage system, such as:
• Include an overhanging roof structure or canopy over fuel dispensing areas, vehicle wash areas, and outdoor work areas
• Pave fuel dispensing areas, repair/maintenance floor areas, hazardous material or waste storage areas, and loading/unloading areas with Portland cement concrete instead of asphalt concrete
• Slope/grade/berm fuel dispensing areas, vehicle wash areas, outdoor repair bays, and material storage areas to prevent ponding and run-on
• Prevent spilled materials and wash-down waters from repair bays from entering the storm drain system.
• Install sumps to collect wash water from cleaning facilities or loading/unloading areas
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Operations and Maintenance Phase
Industrial SWPPP
• Be in compliance with NPDES regulations
• Identify potential stormwater pollution sources
• Implement & maintain stormwater control measures
• Procedures to follow to comply with MSGP or state general industrial stormwater permit
Components of Industrial SWPPP
• Stormwater pollution prevention team
• Site description
• Summary of potential pollutant sources
• Description of control measures
• Schedules and procedures
• Documentation to support eligibility considerations under other federal laws
• Certification of the SWPPP
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Operations and Maintenance Phase (cont.)
General Guidelines for O&M• Prevent pollution
• Minimize exposure
• Combine controls
• Examine site pollutant sources
• Maximize infiltration
• Use existing vegetated areas
• Buffer on-site or adjacent waterbodies or drainage systems
• Use structural practices (as applicable)
• Implement good procedures and practices
• Worker awareness & education12/1/2010
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Overall Stormwater Management Strategy
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Planning
Design
Operations/ Maintenance
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ePermitting System
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ePermitting
Challenges• Lots of projects coming• Limited number of Guam EPA Staff• Unable to hire or fund additional bodies• Increased workload is not permanent• Guam EPA approval required by local regulations• Timely reviews & approvals needed to meet 2014 goal
ePermitting system solution• A means to make the design reviews and approval more efficient• A more transparent process to track reviews & approvals• Web access 24/7
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ePermitting (cont’d)
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Launched late summer 2010 and continually being enhanced!
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ePermitting (cont’d)
How to use ePermits:• You must be a registered user to:
– Enter or upload data into the system, – modify data and – receive notifications from the system
• To request access, click on the “New User? Register here” link on the ePermitting System home page
– Be sure to notify your Navy contracting officer (design or construction)
– ePermits administrator will seek the Navy’s contracting officer’s approval of your access request
ePermits URL:http://jrm-epermit.dzsp21.com/Structure/Home.aspx
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ePermitting (cont’d)
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ePermitting (cont’d)
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ePermitting (cont’d)
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ePermitting (cont’d)
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ePermitting (cont’d)
ePermits training:• Training currently being held on Guam at DZSP21 corporate
office, Bank of Hawaii Building, 3rd floor- Dec. 8th & 15th (8:30 AM)
• Or webcasts offered- Dec. 10th (9:00 AM)
• To sign up, email: [email protected] or call 671-479-3999In the email subject line, put “e-Permitting Training Reservation”
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SDWA Submittal Requirements
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Submittal Requirements
• Permits or design reviews that require Guam EPA’s action will be processed on ePermits
• SDWA Design approval submittals:- Water Systems- Sewer Systems- Wellhead Protection
• Other typical permits (construction or operating) processed during construction:
- Test Boring permit- Well Drilling Permit- Air Emissions Permit: Standby Generator- Underground Injection Control (UIC) Well Permit (note – Navy’s preference is to
avoid UICs)- Well Operating Permit
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Required Submittals – Water Systems
All projects with:•more than 200 LF of new waterlines, or•waterlines more than 6 inches in diameter, or•Serving more than 10 residential units, or•new materials or new processes•New water source, booster pump, storage tank or transmission line requires a SITING approval as well as DESIGN approval.
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When submittals are required:•30% design (basis of design or 1391
and may include SITING information)
•90% design (pre-final package)•Final design (final package)
Submittal Components:•SITING approval- Project purpose, description, population
served, Location map, NEPA documentation
•30% design- basis of design, calculations, one-line
diagram with key nodes, project description, pre-final RFP/1391
•90% design•Final design
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Required Submittals – Water Systems
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Submittal Components:•SITING approval- Project purpose, description, population served, location map, NEPA documentation•30% design- basis of design, calculations, one-line diagram with key nodes, project description- optional meeting with Guam EPA recommended- For D-B projects, pre-final RFP. For D-B-B projects, 1391 documents•90% design- Full sized hard copy of plans showing water system & details ONLY, detail showing all
hydrants protected by bollards, specifications, boring logs, one-line diagram showing hydraulic analysis (for large projects – hydraulic analysis from source to project showing key pressure points. For small projects like a single facility – hydraulic analysis from point of connection), summary of how Guam EPA’s 30% comments were addressed
•Final design- set final drinking water design plans (electronic), summary of how Guam EPA’s 90%
comments were addressed•Post Construction - As-built drawings within 60 days from project completion
***A Guam Environmental Protection Agency Approval Checklist – Safe Drinking Water Actis available from the Navy ***
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Required Submittals – Sewer Systems
All projects with:• more than 600 LF of new gravity sewerlines that are greater than
8 inches in diameter, or• more than 2 sewer manholes, or• New or modified pump station, or• Sewer force mains, or• new materials or new processes (example: treatment systems)
When submittals are required:• 30% design (Guam EPA will indicate if 90% submittal is needed)
• 90% design
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Required Submittals – Sewer Systems
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Submittal Components:•30% design- project location map, basis of sewer design, calculations (if available), project description & purpose
- pre-final RFP for D-B projects or 1391 for D-B-B projects- Guam EPA will review and advise Navy if 90% design submittal is required•90% design- full sized hard copy of plans showing sewer system & details- electronic copy of plans- hydraulic analysis (showing modeling runs clearly showing adequate capacity
for proposed project. For large projects – show downstream analysis to receiving pump station or wastewater treatment plan. For small projects –hydraulic analysis to POC to existing system and showing adequate capacity in receiving gravity sewer or pump station)
***A Guam EPA Sewer Design Plan Plan Review Requirements checklist is available from the Navy ***
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Required Submittals – Wellhead protection
• Applicability and submittal requirements currently being discussed with Guam EPA
• Guam EPA contemplating on developing a flowchart (as of 10/2010)
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Stay Tuned !
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ePermitting : Process for D-B-B SDWA Design Submittals
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A-E prepares GEPA design approval submittal package
Navy’s Design Manager reviews submittal package
Navy’s Environmental Office reviews submittal package A-E finalizes
submittal package based on Navy’s comments
Navy’s Environmental Office uploads to ePermits
Guam EPA review & enters comments into ePermits
Design Mgr reviews draft responses, forwards to Environ. Office
A-E prepares draft responses, additional info or revised submittal material as required
Design Manager and Eviron. Office reviews Guam EPA’s comments
Environ. Office reviews draft responses & uploads finalized documents to ePermits
Design Submittal approved by Guam EPA
GEPA review within 30 days for 30% or 90% submittals; 15 days for SITING or FINAL submittals ----
Note: If submittal is deemed to be incomplete, review period starts over
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ePermitting : Process for D-B SDWA Design Submittals
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D-B prepares GEPA design approval submittal package
Navy’s Construction Manager (CM) forwards to design & environ. office review/support
Navy’s construction, design & environ. offices reviews submittal Navy CM transmits
comments to D-B
D-B revises submittal package, furnish addit. info as req’d & resubmits to Navy
Navy reviews & approves revised submittal package
D-B contractor reviews & prepares responses to Guam EPA’s comments.
Guam EPA reviews design submittal & enters comments into ePermits
Navy CM uploads submittal documents into ePermits
Navy CM reviews D-B’s responses and revised submittal documents and obtains design & environ. support as req’d Design Submittal
approved by Guam EPA
D-B revises documents as necessary and obtains Navy’s approval
Navy’s CM uploads responses and other revised documents to ePermits for Guam EPA’s review
GEPA review within 30 days for 30% or 90% submittals; 15 days for SITING or FINAL submittals
Note: If submittal is deemed to be incomplete, review period starts over
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Submittal Process for Construction or Operating Permits by Contractors
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ePermitting - Construction or Operating Permit Process
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Contractor prepares construction or operating permit application
Navy’s CM and Environmental Office reviews permit application
Navy provides comments to Contractor Contractor finalizes
permit application
Contractor submits permit application via ePermits
Guam EPA review & enters comments into ePermits
Navy CM reviews revised permit application Contractor addresses
Guam EPA’s comments, drafts response
Contractor reviews Guam EPA’s comments
Contractor submits revised permit application or addit. info via ePermits
Permit approved by Guam EPA
