Environmental Requirements - Construction Phase

Environmental Health and Safety (EHS), Environmental Programs (EP) coordinates multiple programs to assist in maintaining compliance with the University’s storm water and wastewater permits as well as other environmental regulations. Several of these programs are applicable to construction projects, such as: sediment and erosion control, storm water pollution prevention plan review, dye testing, discharge requests and pre-treatment device approval.

Contractor Responsibilities

Contractors are solely responsible for cleaning up and properly disposing of all spilled pollutants brought to the site as part of the contractor's work, including oil, paint, fuels, antifreeze, solvents, etc. in accordance with applicable laws and regulations. Contractor must keep accurate records (such as receipts, copies of analytical results, etc.) indicating proper disposal of spilled materials in accordance with applicable laws and regulations. Furthermore, the Contractor is responsible for ensuring that all discharges from the site are in compliance with all applicable laws and regulations.

No substance may be dumped or leaked onto the ground or allowed to run-off of a construction site that might cause pollution. Be aware that the contractor is responsible for preventing pollutant contaminated run-off and proper disposal of all waste materials generated as a result of the contractor's activities.

All contractors should review and be familiar with the Construction Site Procedures (PDF).

Notification Requirements and Procedures

EHS should be notified immediately in the event of:

  • Any spill that threatens to enter a storm sewer or watercourse
  • Any potential asbestos containing material
  • All petroleum spills e.g. hydraulic fluid, transmission fluid, diesel, gasoline, etc.
  • Any hazardous or unknown material spill, e.g. cleaners, solvents, etc.
  • Any discharge from your site which you suspect may be in violation of city code and/or state or federal laws and regulations, e.g. discharges which are cloudy, foul smelling, colored, contain chemicals or heavy sediment loads

To report a spill or discharge, please call EHS at (512) 471-3511 during normal service hours, Monday-Friday from 8:00 a.m. to 5:00 p.m. Nights, weekends, and holidays please call 911.

Dye testing

Dye testing of sanitary sewer drains is required during all new building construction, building renovations, and any time a building plumbing fixture is connected to a drain line. The goal is to confirm that all sanitary sewer drains are properly plumbed and eliminate the chance of an inadvertent cross connection to the storm sewer system. Dye testing is conducted as part of the University’s Storm Water Management Program. For more information, please see the dye testing procedure (PDF).

The requirement is that all fixtures installed or renovated be tested with dye. In new construction, EHS and Utilities and Energy Management (UEM) personnel can visually inspect plumbing lines and verify proper connections to reduce the number of fixtures requiring testing.

To schedule a dye test, notify EHS and UEM at least seven to ten business days prior to the proposed testing date. Submit a dye test log (PDF) identifying all fixtures to be tested along with relevant drawings. Please send notification to EHS-EnvironmentalOps@austin.utexas.edu and contact UEM-Mechanical Distribution at (512) 471-3793.

Stormwater Pollution Prevention Plans (SWPPP)

All construction projects are required to manage stormwater runoff.  The total acres of planned disturbance correlates with the required controls and applicable permits. The University’s Phase I Municipal Separate Storm Sewer System (MS4) permit issued by the TCEQ requires all projects to limit the increase in erosion and discharge of pollutants in stormwater as the result of new development and redevelopment. If greater than an acre will be disturbed, then coverage under the TCEQ’s Construction General Permit (PDF) is also required. For more information on SWPPP requirements during design, please see Environmental Requirements - Design Phase.

The SWPPP is a living document, and must be updated frequently to represent site conditions. Remember to update the major grading and stabilization log, include all inspections, and revise the project erosion control drawing to reflect current site conditions.

Failure to comply with the permit requirements can result in project delays, civil penalties, notices of violation and in severe cases, could include criminal charges.

SWPPP Start-Up Meeting

Prior to any land disturbance on the project site, the UT Austin Project Manager (PM) must schedule a meeting involving a designated representative from the UT Austin project management, the contractor, and EHS. This meeting will consist of a site walk to verify all best management practices (BMPs) have been installed according to the site’s approved SWPPP, a review of expectations and inspection requirements, and form signing. All required forms are included in EHS’ SWPPP template (PDF).

Inspection Requirements

Sites < 1 Acre: As the TCEQ MS4 permit operator, EHS is the authority having jurisdiction. EHS staff will inspect sites <1 acre periodically to ensure all erosion and sediment (E&S) controls are being properly maintained and to look for any potential sources of pollution. Operators are responsible for maintaining all controls and adhering to the site-specific E&S plan.

Sites > 1 Acre: These projects are covered under the construction general permit, so all operators must conduct weekly site inspections. This includes both the contractor and the UT Austin project management. Inspections must be once every seven days, on the same day of the week for the duration of the project. If deficiencies are observed, operators are required to complete repairs within seven days or prior to the next rain event. All inspection reports must be filed in the onsite SWPPP binder. EHS will also conduct monthly inspections as the authority having jurisdiction.

Close-Out Requirements

The SWPPP can be closed out once the site achieves final stabilization. There can be no further soil disturbances planned and 70% of the site must have vegetative coverage. The UT Austin PM or Construction Inspector (CI) will notify EHS, who will confirm all BMPs have been removed. The contractor must initial and fill out the “date notice removed” on the construction site notice, and submit along with the completed SWPPP binder to EHS including copies of all inspections.


To request a training or submit feedback, please reach out to us by calling (512) 471-3511 or send an email to EHS-EnvironmentalOps@austin.utexas.edu. For additional training resources, please visit Environmental Programs Training.

Discharge Requests

Environmental Health and Safety (EHS) approval is needed for discharges to the sanitary sewer system other than domestic sewage. Approval is also needed for discharges to the storm sewer system other than rain water. Please allow at least seven to ten business days to process a discharge request. In some cases, sampling may be required. If the discharge request is not submitted with adequate processing time, the project management team will be responsible for containerizing the discharge contents until the discharge is approved by EHS.

EHS is required to document and review all discharges in order to maintain the University’s compliance with both our Texas Commission on Environmental Quality issued storm water permit and City of Austin issued wastewater permit. Common discharges include new or existing utility piping drain downs, pools, fountains, and fire system pressure tests.

In order to be compliant with the terms of the University’s Wastewater permit, illicit discharges to the sanitary sewer system are prohibited.

Examples of permissible discharges (with EHS testing and approval):

  • Discharge from  HVAC or utility piping systems (Condenser, condensate, chilled or hot heating water)
  • Non-toxic water-based discharge dependent upon pH. Contact EHS.
  • Water (potable or non-potable)

Examples of prohibited discharges:

  • Any discharge containing silt and sediment
  • Any hazardous waste, hydrocarbon, volatile organic or inorganic substance, or other flammable or explosive liquid, solid or gas  
  • Any substance containing glycols
  • Any substance containing grease, oil, or heavy metals (beyond allowed limits)
  • Any regulated toxic organic compound
  • Any substance with a temperature over 120 degrees F

Note: The above list only contains a few examples and is not exhaustive. Dilution is strictly prohibited when cleaning and passivating new utility piping. Pre-flush or post-flush water must not be used to dilute the proposed discharge in order to comply with prescribed effluent limits.

To submit a discharge request, you must be a UT representative possessing a current UT EID.

Submit Discharge Request

For additional information regarding waste and storm sewer discharges contact the EHS Department directly by calling (512) 471-3511.

For information on power washing and other exterior building washing activities, please refer to the Exterior Building Washing Standards UT-EHS (PDF).

Construction Site Oil Storage

For information on the appropriate methods of oil storage at construction sites please refer to our SPCC page

Pre-Treatment Devices

Pre-treatment devices such as grease traps, grit traps, oil-water separators, etc. must be inspected by EHS and UEM, upon installation but prior to backfilling. Inspections are also required for interior devices. Installation of any such device without prior EHS approval is prohibited.

A complete overview of the pre-treatment approval process can be found at Pre-treatment Device Compliance Procedure (PDF)

To schedule an inspection, notify EHS and UEM at least seven to ten business days prior to the proposed date. Please send notification to EHS-EnvironmentalOps@austin.utexas.edu, or call EHS at (512) 471-3511. Contact UEM-Mechanical Distribution at (512) 471-3793.