1. Stormwater
Brian Smith FHWA—Resource Center
20152015 MIDMID--ATLANTIC WATERATLANTIC WATER QUALITYQUALITY
PEERPEER EXCHANGEEXCHANGE
FINALFINAL REPORTREPORT
2. 2
EXECUTIVE SUMMARY 3
WQPE14 AGENDA 6
PRESENTATION SUMMARIES 7
Program initiative/innovations 7
Vince Davis, DelDOT Delegation of Authority
Dana Havlik, MDSHA SWM Assets Program/Delegation of Authority
IDDE Screening 11
LaTonya Gilliam, DelDOT
John Olenik, VDOT
EPA Audits 12
Winne Okello, PennDOT
Ed Wallingford, VDOT
Permit Requirements and Issues 15
Winnie Okello, PennDOT
Meredith Upchurch, dDOT
Ryan Reali, NJDOT
Chesapeake Bay Regulator Perspectives 18
Crediting/Banking 20
John Olenik, VDOT
Vince Davis, DelDOT
Ryan Reali, NJDOT
TMDL Strategies and Impact on DOT 23
Karen Coffman, MDSHA
Karen Coffman, MDSHA, EMS for TMDL Implementation
Winnie Okello, PennDOT, TMDL and EMS
3. 3
Environmental Management System 27
Dana Havlik, MDSHA
Program Funding 29
Meredith Upchurch, dDOT
DelDOT Database, EM process and work management……………… ……….30
LaTonya Gilliam, DelDOT
BMP Design coordination 32
Vince Davis, DelDOT
Meredith Upchurch, DDOT
Inspections 34
Dana Havlik, MDSHA
Vince Davis, DelDOT
Sharing resources 38
Online resources 38
Contact information 39
Presentations 40
DelDOT Street Sweeping Science 71
DelDOT IDDE Screening 78
4. 4
Executive Summary
The Mid-Atlantic Water Quality Peer Exchange occurred September 21-23, 2015 in Dover,
DE. Participants collaborated to create an agenda that focused on issues and concerns
specific to Mid-Atlantic States. Six DOTs were represented.
Participants shared their recent innovations in work practices and tools, and approaches to
implementing their programs. Stormwater issues are highly visible in the Mid-Atlantic and
regulations are very rigorous requiring substantial DOT investment in project design, engi-
neering, maintenance, technology and technical guidance. Issues of concern to the prac-
titioners are reflected in the agenda. Communication with regulators and between the
various DOT disciplines is very important. For example, although new regulations emphasize
a preference for smaller low-impact BMPs they do not address the feasibility of these prac-
tices.
Peer Exchange participants and contributors:
Vince Davis, DelDOT Ed Wallingford, VDOT
LaTonya Gilliam, DelDOT Meredith Upchurch, DDOT
Winnie Okello, PennDOT Etayanesh (Ty) Asfaw, DDOT
Dana Havlik, MDSHA Ryan Reali, NJDOT
Karen Coffman, MDSHA Meeti Trivedi, NJDOT
John Olenik, VDOT
FHWA representatives included:
Brian Smith, FHWA Resource Center
Marcel Tchaou, FHWA Headquarters
5. 5
New regulations are pushing DOTs to install and maintain more BMPs per project and in-
vest in detailed site-specific evaluations to ensure proper conditions exist at sites. Poor sit-
ing will result in retrofit, corrective engineering, or higher long-term maintenance costs for
the DOT. Most DOTs are being required to add BMPs within the ROW to treat existing im-
pervious surfaces and anticipate that this trend will continue over a long-term. Improving
work flow and data management will be essential to continuous improvement and risk
management.
To manage increasing workload DOTs are employing the use of environmental manage-
ment systems (EMS), GIS technology and real-time data. Development of EMS for storm-
water management is still relatively new but benefits of EMS are clearly evident as storm-
water assets continue to increase. States have shared that an EMS approach is useful for
work flow management and documenting MS4 program requirements including asset
monitoring, tracking, inventory and reporting.
Stormwater touches multiple disciplines including planning, environmental, engineering,
design, construction, maintenance and administration and is linked to multiple strategic
areas such as project delivery, environmental stewardship, asset management, fiscal re-
sponsibility, communication, coordination, collaboration, and cooperation, workforce de-
velopment, mobility and safety. Executing the innovations and practices described here
involves breaking down borders and working across disciplines.
The Peer Exchange allowed participants to share their other successes and challenges as
well as new strategies and tools developed to support their programs and address man-
agement concerns.
The Peer Exchange consisted of two days of discussion including perspectives of local reg-
ulatory staff from the Delaware Department of Natural Resources and Environmental Con-
trol (DNREC). The presentations are included in the Appendix. Each presentation was in-
tended to spur discussion among participants. Topic discussions are summarized in the
body of this report.
6. 6
MID-Atlantic WATER QUALITY PEER EXCHANGE
September 21-23
Dover, DE
TENTATIVE AGENDA (updated 8-113-15)
Monday, September 21 2-5:30pm
Introductions
Program initiatives/innovations
EPA Audits
Permit Requirements/issues
Tuesday, September 22 8am-5:15pm
Chesapeake Bay Regulator perspectives 8-9:30 am
Crediting/Banking 10-11:45 am
TMDL Strategies and Impact on DOT 12:30 – 2:15 pm
TMDL clarity/ Planning for TMDL
Environmental Management Systems 2:30 – 4 pm
Programming funds 4 – 5:15 pm
Wednesday, September 23 8am-12:30pm
BMP Design coordination 8 – 9 am
Inspection 9:20 – 11 am
Products and resources 11:15 – 12:15 pm
Closing and Adjourn 12:15 – 12:30 pm
7. 7
Delegation of Authority
Vince Davis , Delaware Department of Transportation
The U.S. EPA has delegated its authority to administer the federal NPDES permit program in
Delaware to the State of Delaware, with the exception of pre-treatment and federal facil-
ities. Within the Delaware Department of Natural Resources and Environmental Control
(DNREC) Division of Water Resources, the Surface Water Discharges Section (SWDS) is re-
sponsible for administering the NPDES program and the Division of Watershed Stewardship
oversees construction activities.
DelDOT houses responsibilities for stormwater program areas in different sections of the
Maintenance and Operations Division (M & O) and the Division of Transportation Solutions
(DOTS). Roadside Environmental and NPDES Section are in the M & O Division and Envi-
ronmental and Stormwater Sections are in the DOTS.
DelDOT Roadside Environmental Section handles pesticide permits
DelDOT Environment Section handles
NEPA, 401, 404 permits, Section 10 Re-
ports
DelDOT NPDES Section handles MS4 pro-
gram (Phase I and Phase II), Stormwater
general permits under 7 Del C chapter
60 – Part I for Industrial stormwater per-
mits.
DelDOT Stormwater Section handles
Stormwater general permits under 7 Del
C chapter 60 – Part II for Construction
activities, Sediment and Stormwater law
7 Del C chapter 40 and stormwater
management and construction E&S.
The following agencies have delegation
of Sediment and Stormwater Program
elements consisting of plan review, con-
struction inspection, and maintenance inspection for their geographic boundaries:
DelDOT, Kent Conservation District (CD), Sussex CD, Town of Middlesex, City of Newark,
City of Wilmington, New Castle CD, New Castle County Department of Land use. Re-
delegation occurs every 3 years.
In most DOT’s, stormwater responsibilities are di-
vided between Design, Environment and Mainte-
nance. DOT organization that is based on storm-
water program areas (construction, industrial and
MS4 activities) may provide more consistent deliv-
ery of stormwater management responsibilities
than an organization structure based on jurisdic-
tional issues (e.g., state projects vs. local projects)
or project types (small projects vs. larger projects).
Success requires that good comprehension of
stormwater duties and responsibilities, well de-
fined staff roles and responsibilities, shared re-
sponsibility within the agency, informed and well
equipped staff, and good communication between
disciplines and program areas.
8. 8
Figure 1 illustrates the duties of the DelDOT Stormwater Section.
Figure 1. Duties of the DelDOT Stormwater Section.
DelDOT does not have a Hydraulics section. DelDOT designers have cradle-to-grave re-
sponsibility for projects. DelDOT manages 90% of all roads in DE and uses consultants under
DelDOT supervision to review subdivision entrances and street designs/plans. DelDOT has a
joint permit and an agreement with six other municipalities for sharing data, training, and
NDPES responsibilities (monitoring, outfall inventories). Municipalities collect data within their
geographic areas.
The process and requirements for DelDOT state delegation is spelled out in DE state laws
and state regulations. EPA NPDES delegation requires that DelDOT is audited by DNREC
and USEPA audits DNREC’s delegation.
MDOT SHA Office of Highway Development- SWM Assets Program/ Delegated Authority -
Dana Havlik
MDOT SHA restructured as a result of their recent delegation of authority.
TMDL, Quality Assurance, Stormwater Assets
Stormwater duties are housed in the Office of Environmental Design (OED) and Office of
Highway Development (OHD), MDOT SHA has assigned managers/coordinators to oversee
the following stormwater program areas.
IDDE – OED - Water Programs Division (WPD) and Environmental Compliance Division (ECD)
MS4 - OED - WPD
TMDL - OED - WPD
Construction activities – Office of Construction (OOC) and OED- Quality Assurance
9. 9
Stormwater Assets (post-construction) (OHD – Highway Hydraulics Division (HHD)
SWM Preventive Maintenance - District Maintenance shops
SWM/ ESC Approval- OHD Plan Review Division (PRD)
Highway Hydraulics Division (HHD) provides design, technical support and review for a
range of projects and functions including:
Major highway projects
HH modeling/drainage
Stormwater Management (SWM)
Stream restoration/stabilization
Erosion and Sediment Control (ECSC)
Projects Review
Environmental permits coordination – ESC/ SWM/NPDES
Drainage and SWM Assets Program ( inventory inspections and rating)
Figure 2. MDSHA Organizational Chart
11. 11
features intended to mimic “forest in good conditions” water quality functions and runoff
characteristics. Because ESDs are very small, many ESDs are required on a single project.
This greatly increases the number of stormwater assets that MDOT SHA must track, inspect,
rate, report and maintain statewide. For example, a project requiring removal of 10lb of
pollutant may require 140 ESDs. Several states mentioned approaches to ESDs (Low Impact
Design) are being encouraged by regulatory agencies.
Structural BMP cannot be used to meet project SWM regulatory requirements for new de-
velopment unless demonstrated ESD to Maximum Extent Practicable (MEP) is fully imple-
mented. Water quality credit from structural BMPs cannot be credited to the WQ Bank.
Structural BMPs can be used as a last resort and for redevelopment projects.
Peak flow management (typically 2yr , 10 yr storm, in few cases 100 yr storm depending on
the local jurisdiction /county requirements) requires structural BMP (Dry , wet or extended
detention ponds)
Water quality requirements are met by use of ESD to MEP.
IDDE screening – LaTonya Gilliam DelDOT and John Olenik VDOT
DelDOT is a joint permittee with six other municipalities in New Castle County and has
worked out an agreement for the municipalities to turn in their own data. DelDOT does pro-
vide assistance when needed such as
providing copies of the DelDOT BMP
inspection manual and invites to
DelDOT training. DelDOT owns 90% of
outfalls and have a large outfall moni-
toring program and municipalities will
piggyback on those contracts. Con-
tractors/consultants are familiar with
the work so this is a win for the munici-
palities. Municipalities obtain GIS work
from the University of Delaware and
student interns.
For IDDE where DelDOT and New Cas-
tle County overlap, DelDOT covers
closed drainage inspections and New
Castle County covers over open drain-
age inspection.
For IDDE inventory, DelDOT is required
to inventory 20% of their system every
IDDE monitoring is a lot of effort with little re-
turn. Many states such as VDOT rarely find
anything. DelDOT has proposed a desk top
screening approach based on industrial ar-
eas, septic areas and watershed size in its
new permit. Outfalls draining more than 50
acres and if no industrial uses are present -
no field screening is done. Where industrial
uses, auto shops, gas station, septic area
are present then field screening is done.
This approach has resulted in substantial
cost savings.
12. 12
year and now the entire system is invento-
ried. DelDOT uses GIS overlay to identify
blue line streams, buffer distance from out-
fall, etc. in its inventory. However, now they
are putting more f
focus on information identified in EPA elec-
tronic data requirements (e.g., proximity to
blue line stream, buffer distance, etc.).
VDOT IDDE inventory includes headwater areas. Looking forward to EPA electronic data
re-
porting requirements will help DOTs plan for future IDDE inventories.
VDOT has expressed concerned that its DEQ has requested that VDOT monitor permitted
discharges. New Castle County fought a similar permit requirement from DNREC and loss.
This added condition will add to VDOTs MS4 permit compliance cost.
EPA Audit
Winnie Okello, Pennsylvania Department of Transportation
PennDOT received a statewide request for information including:
Information from District Offices:
· Maintenance Stockpile Evaluation docs (external audits/evaluations)
· Internal Evaluations reports
· County Salt management plans ( Pub 23 Ch.4)
· Foreman's Quarterly Stockpile Checklist
· SEMP Checklist and record form
· Oil -water separator cleanout docs
· Corrective Action Reports (CARPARS)
DelDOT and VDOT refer IDDEs to the state regulatory agency and are re-
quired to follow-up. MDSHA reports IDDEs to the county that has en-
forcement authority. Responsibility to report violations to enforcement
agency is subject to interpretation. EPA interprets the regulations as re-
quiring permittees to report a track IDDEs. Reporting of IDDEs should be
documented for compliance purposes.
On October 22, 2015, EPA published
the final National Pollutant Dis-
charge Elimination System (NPDES)
Electronic Reporting Rule in the
Federal Register.
13. 13
· Latest CFRP-Combined facility response Plan
· SEMP Manual (Strategic Environmental Management Program)
· Schematic plans/ Drainage Patterns of facility drainage system
· Invoices of disposal of vac-truck and sweeper waste
Statewide information request for:
· Copies of recent MS4 permits (2010-Present)
· Construction activities Docs:
o NOI, Lat/Long, Statewide map of all permitted activities, Urbanized areas/rural,
projects NPDES permits, documentation of commencement of construction ac-
tivities, violations during construction, NOT
· All PENNDOT owned PCSM BMPs
o Type of structure, date of completion, maintenance agreements with CCD/
municipalities, lat/long, statewide map showing locations, documentation of
PCSMs, estimated pollution reduction or TMDL requirements (N/A)
· All PENNDOT Maintenance Facilities :
o Lat/long, salt pile inventories, UA/rural, Inspection Reports
· ISO 14001 Certification Compliance docs:
o All audits/reviews, Notices of nonconformance, SEMP manual (guidance on
SEMP/ISO standard operations)
· Annual cost for MS4 compliance:
o All aping efforts, training received/given, and inspection costs
PennDOT’s MS4 is under their Strategic Environmental Management Program (SEMP). This is
the 2nd statewide information request for information. The first statewide information request
was in 2013. In response Central Office SEMP Chief went out and did internal audits on
some districts (5 and 6). The SEMP Office found that SEMP inspection checklists were rou-
tinely being pencil-whipped (i.e., copied over from previous years) and important issues
were not being addressed. As a result, PennDOT is moving from ISO 14001 toward a compli-
ance based environmental management system (EMS).
PennDOT updated their maintenance manual and policies to be more proactive. For ex-
ample, updates will address:
14. 14
· Winter maintenance: Salt storage and applications - Transfer salt and other environ-
mentally sensitive materials to permanent storage buildings to will eliminate potential
pollution problems, keep the materials in a usable condition, and help in the general
cleanup and appearance of stocking areas.
· Storage facilities - Proper management of wastes associated with highway mainte-
nance operations, and basic waste management requirement to comply with feder-
al and state regulations.
· Vegetation & various roadside maintenance activities – herbicide and pesticide stor-
age and documentation
PennDOT also added an MS4 section to their records retention policy update to address
management of required MS4 documentation.
PennDOT is looking to get approval for more positions for inspectors.
EPA Audit
Ed Wallingford, Virginia Department of Transportation
VDOT, the 3rd largest DOT in the US, went through its first EPA audit in 2012. Although VDOT
was aware of the impending audit, VDOT officially received a 2 week notice of the audit
date in October 2012. VDOT prepared for the audit by doing housework in their mainte-
nance facilities. This was a good investment of time as some deficiencies were found prior
to EPA inspection. One of VDOT’s privately leased facilities required as much if not more
good housekeeping improvements as state-operated facilities. This last hour housekeeping
and preparing was not enough as VDOT was not familiar with the high level of expectation
that EPA brought with audit inspections.
The audit was conducted by two EPA teams that visited 13 construction sites and 9 mainte-
nance sites across the site. A debrief was conducted on the next day. VDOT staff and con-
sultants accompanied EPA inspectors with the intention of producing similar notes and pho-
tos generated by EPA inspectors. VDOT’s documentation was helpful and allowed VDOT to
take proactive steps while EPA generated its audit report. EPA completed their 5000 page
audit report in March 2014. Principally, EPA inquiries could only be satisfied with presenta-
tion of appropriate documentation. VDOT provided additional documentation at the re-
quest of EPA but that only seemed to generate more questions that required some level of
documented evidence.
EPA requested and VDOT agreed to prepared detailed response to the 5000 page audit by
July 2014. Following VDOT’s response to the audit report the agencies held an Enforce-
ment Partnership conference call in October
2014. In May 2015, VDOT agreed to terms of a
Consent Order and partnering activities.
Despite the timing, VDOT found that proactive
steps were very helpful. Taking notes and pho-
tos of the audit allowed VDOT to take proac-
tive steps during the 18 months that EPA pre-
There is concern that TMDLs for salt/
chloride could increase EPAs con-
cern, oversight and review of DOT
programs and increase fines and
penalties.
15. 15
pared its audit report. Top VDOT Administration sent notice about audit findings to VDOT
staff and increased visibility of the issue. At the time that EPA presented its audit report
VDOT was able to show that proactive steps had been taken in response to the audit in-
spections. Proactive measures taken by VDOT include increasing compliance reviews to
annually, revising several guides, and improving documentation. Infrequent inspections
and lack of documentation were key factors of non-compliance. As a result meetings and
negotiations with EPA were productive. VDOT was able to highlight the value of its research
program and negotiate a lower civil penalty by conducting environmental projects such as
nutrient credit purchases, a permeable pavement parking lot, installing two 25000 runoff
tanks to replace ponds, and conducting research on drop inlets. The experience has result-
ed in VDOT reorganizing and re-allocating staff to work in stormwater management pro-
gram areas. VDOT is increasing visibility and encouraging stormwater stewardship by man-
ning a stormwater awareness booth at the statewide rodeo.
Permit requirements and Issues
Winnie Okello, Pennsylvania Department of Transportation
PennDOT Office of Chief Counsel’s (OCC) guidance has been extremely helpful during the
permit renewal and negotiation process. This includes evaluation of a revised anti-
degradation policy within the Pollutant Reduction Plan. The revised anti-degradation policy
requires treatment of up to 10% of existing untreated impervious areas (UIA) in sediment im-
paired watersheds, where practicable. PennDOT wants cost to be a practicability factor
and clear definition of practicability for compliance documentation. With PennDOT OCC
assistance, cost aspects of practicability was defined as not exceeding more than 15% of
stormwater management cost including ROW cost but not annual maintenance cost. It is
essential to define practicability in order to document practicability at the completion of
the design phase. PennDOT OCC preferred to list practicable stormwater control measures
to avoid or minimize invention of “new” measures during the permit cycle. PennDOT is not
named in a TMDL and not a significant source of nutrient loading. So consideration of
“new” measures should not be the focus of the renewed permit. However, PennDOT has
developed a proactive plan that it will initiate if and when named in a TMDL.
For Chesapeake Bay TMDL, PENNDOT will address new discharge sources separately from
existing discharges in Urbanized Areas. New discharges (UA) will be addressed through
DEP’s NPDES Permitting program and for existing discharges (UA) PennDOT will develop and
implement an MS4 TMDL plan to demonstrate consistency with any applicable WLA.
PennDOT successfully negotiated through DEPs persistence to be proactively involved in
stewardship of TMDL waters including the Chesapeake Bay area. PennDOT is concerned
that they may be named in a future TMDL and has proactively developed a plan that is
reasonable and practicable for them (PennDOT) to implement if and when PennDOT in-
volvement is required. PennDOT’s new permit will provide clearer language to distinguish
between DOT-owned and municipal-owned MS4 Systems and applicable responsibilities.
16. 16
OCC has made a significant difference in developing workable permit conditions and re-
quirement.
PennDOT is concerned that DEP’s demand for system mapping will require a massive under-
taking and developing a new data management system. It is PennDOT OCC position that
only outfalls require mapping not the entire drainage system. PENNDOT currently has inlets
and outlets/outfalls mapped but the data is housed in different systems (BMS, RMS, mainte-
nance IQ/GIS). The issue of mapping the entire drainage system is still in negotiation.
PennDOT is also anticipating issues in non-urbanized areas related to illicit discharges and
stream erosion concerns.
Permit requirements and Issues
Meredith Upchurch, District Department of Transportation (dDOT)
DDOT does not have its own permit. They are a part of the MS4 permit issued to the city.
DDOT does not have the opportunity to participate in permit negotiations. DEC is the ad-
ministrator of the MS4 permit for DC. DC is in its 3rd permit cycle (issued 2011).
Two new requirements
1. Retrofit 1.5 million sf of row (18 million for DC)
2. New regs put in place to retain 1.2” of runoff to the MEP
Disturbance of 50sf triggers soil erosion and sediment control requirements and disturbance
of 5000sf triggers stormwater retention requirements. Pretty much every project has to re-
tain 1.2” except for resurfacing and utility trenching.
For existing ROW there is MEP language in permit and an evaluation process that acknowl-
edges conflicts in ROW due to space limitation. MEP evaluation process does not require
ROW purchase but requires looking at entire ROW to determine if stormwater measures can
be employed. MEP is considered at every phase of design (e.g., infiltration testing, 30% and
65% design) and any conflicts are noted. Agencies have agreed on certain practices and
BMPs such as bioretention, permeable pave, LID, green infrastructure approaches. Con-
flicts affecting travel lanes are not practicable. DDOT is not using underground storage or
proprietary devices.
This change that requires review for MEP is difficult to get adjusted to. It may require looking
at smaller sized BMPs and results in a larger number of BMPs. DDOT uses a spreadsheet to
calculate MEP (see attached or download at http://ddot.dc.gov/sites/default/files/dc/
sites/ddot/publication/attachments/DDOT%20MEP%20Worksheet%20042114.xlsx ). At the
end of the process, DDOT does not pay or mitigate if they cannot make 1.2” retention re-
quirement work. DDOT anticipates their retrofit requirement increasing in the future. DC just
completed a TMDL planning process that modeled the entire city and found that even with
city-wide retrofitting the TMDL is not likely to be met. So the trend of retrofitting and MEP
17. 17
evaluation will continue for DDOT over a long-term. DDOT achieves retrofits by treating un-
treated areas within their roadway projects.
Permit requirements and Issues
Ryan Reali, New Jersey Department of Transportation
In NJDOT, maintenance handles MS4 issues. NJDOT handles design and requirements for
New Jersey stormwater water management rules (NJAC 7:8). Stormwater management is
required when there is ¼ acre of new net impervious (quality, quantity, and recharge re-
quirements). Curbing roadway that was umbrella drainage counts as new impervious
(because the water is “collected”). One acre of ground disturbance triggers quantity and
recharge requirements. Roadway reconstruction only counts as disturbance if the entire
pavement box is removed down to the ground surface. If permits are needed from NJDEP
Land Use Regulation Program, NJDEP reviews stormwater plans. By agreement with NJDEP,
if no permits are needed from NJDEP LURP then NJDOT can self-certify stormwater manage-
ment. If Pinelands permit is needed, Pinelands Commission (PC) reviews stormwater man-
agement. Trigger for Pineland Commission review is 5,000 sf of disturbance outside limits of
existing infrastructure. Delaware & Raritan Canal Commission (DRCC) also can review
stormwater management and in some situations Counties or Municipalities can review
stormwater management.
The primary purpose and focus of the NJ stormwater law is municipal land use not linear
projects. Many approved BMPs cannot be applied to a linear project.
One of the goals of NJAC 7:8 is to maintain groundwater recharge. NJAC 7:8 contains the
following groundwater recharge requirements:
· Recharge same amount as pre development condition
· Recharge difference between pre and post development run off quantity for the 2
year storm
NJDEP developed the New Jersey Groundwater Recharge Spreadsheet (NJGRS) to calcu-
late the BMP size to provide treatment.
The NJGRS is available at http://www.state.nj.us/dep/stormwater/bmp_manual2.htm . Pro-
ject is exempt from the groundwater recharge requirement if:
o In PA-1 Area (i.e., Urban areas), provided there is no vegetation disturbance
o Contaminated Soils
o Clay Soils, numerous borings required to approve exemption may be cost pro-
hibitive
o High water table, depends on type of basin
Compliance with water quantity requirements must show that one of the following is true:
18. 18
· Post construction hydrographs for water leaving the site doesn’t exceed pre con-
struction hydrograph (2, 10, 100 year storms)
· No increase in peak runoff rates of stormwater leaving site between pre and post
construction hydrologic & hydraulic analysis (2,10,100 year storms)
· Post construction runoff rates for the 2, 10, and 100 year storm events are 50%, 75%,
and 80%, respectively of pre-construction runoff rates
· Projects in tidal areas are exempt.
NJAC 7:8 is focused on private development projects and not linear development projects
and there are several potential reviewers (NJDEP, PC, DRCC, counties and municipalities)
that do not have knowledge/experience with evaluating linear road projects. When there
is limited ROW cost of BMPs/Land can be an issue. The cost to repair infiltration basins can
be an issue as well. Adequate soil testing and appropriately located soil test borings are
necessary to ensure the appropriate BMP design and to identify subsurface conditions such
as unknown clay/restrictive layers. Utility conflicts occur within the ROW.
Common construction issues include:
· Swales built wrong depth/width
· Not using lightweight equipment in basins
· Compaction due to heavy equipment
· Inverts at wrong elevation
· Incorrect grading
The number of BMPs that DOTs are maintaining continues to grow. In the long term,
maintenance burden should be considered with MEP.
Perspectives from Delaware Natural Resources and Environmental Control (DNREC)
DNREC is working toward volume reduction credit for stream restoration projects. Since
most DelDOT projects are bridge projects this could provide an incentive for DelDOT to ex-
pand the scope of bridge project to include stream restoration to offset deficits that occur
in highly urbanized areas.
Several DOTs indicated that a more collaborative relationship has been es-
tablished with their state regulatory agency through dialogue. DDOT discuss-
es their challenges with DEC, and DEC has grown to appreciate DDOTs posi-
tion. DelDOT frequently discusses project plans and issues related to dele-
gated authority with DNREC. DelDOT and DNREC work together to maintain
compliance with USEPA.
19. 19
Some sites within the Chesapeake Bay watershed have limited capacity for meeting new
runoff reduction requirements. There is a fee in lieu offset option. Applicants must show run-
off reduction to the maximum extent practicable before taking the fee in lieu option.
DelDOT developed a banking agreement to compensate for its credit-deficit projects. An
advantage of the banking approach is generation of stormwater credits currently with im-
pacts.
So far, infiltration success and geotechnical evaluations have been inconsistent. Qualified
geotechs should be involved in evaluation of infiltration BMP sites. DelDOT found DNREC’s
desktop evaluation tool useful. Contractors need training to avoid compaction and con-
struction sedimentation of infiltration basin sites.
For their Chesapeake Bay Action Plan, VDOT provided a suite of BMPs and examples in the
action plan. Reviewers wanted more specific numbers and locations. VDOT, DelDOT, and
MDSHA indicated that it is not feasible for DOTs to develop specific numbers and locations
and to name specific projects in their action plans because missing specific targets would
require frequent modifications and adjustments to the plan. Running three different equa-
tions to evaluate nitrogen, phosphorus, and sediment reduction, reporting and tracking of
those numbers for permit compliance adds another level of complexity for DOT/Designers
to get accustomed to.
Farming issues in Chesapeake Bay watershed
DelDOT cooperates and communicates well with DNREC. DNREC met with us to share their
perspectives.
Agriculture is the largest land use in the Chesapeake Bay watershed. Agriculture (crops,
poultry farms, horses) is a source of nutrients and sediment. Farmer might give up marginal
land for conservation purposes. Farmers are not held to any water quality standards and
any cooperative efforts with DOTs would have to be highly incentivized. Taking land out of
production for a water quality benefit would cost money. DelDOT tries to berm their ROW
and divert farm runoff to cross road pipes rather than accept run on stormwater from farms.
DOT has to monitor their outfalls and accepting farm stormwater would require DOT to
meet water quality standards at those outfalls. It would be costly for DOT to treat farm
stormwater and there is no incentive for the farmer to cooperate in any way.
Share treatment could be burdensome by requiring DOTs to enter into agreements, MOUs,
monitoring the agreement/MOU conditions, misperceptions of fairness to individual farmers,
lawsuits, and demands from other interested parties (developers). These potential issues
would be compounded as the number of agreements/MOUs increased.
20. 20
Crediting and Banking
John Olenik , Virginia Department of Transportation
In 2012, VA general assembly changed regulations to allow post-construction stormwater to
be addressed off-site. For VDOT, potential cost savings to tax payers, on engineering and
design, storm management design, impacts to projects (schedule), ROW, BMP mainte-
nance, MS4 requirement s for reporting and inventory was their impetus for considering
credit banking. VRTC developed a white paper on the issue. Nine projects were analyzed
and found cost of $33,000 excluding ROW and $44,000 including ROW. With nutrient credit
banking, VDOT pays $15,000 per credit for 1 pound phosphorous. For your project to quali-
fy for a 100% offsite nutrient credit compliance purchase, the project cannot exceed 5
acres of disturbance OR 10lbs. of total phosphorous. If your project exceeds these thresh-
olds, 75% on-site treatment is required, 25% can be offsite nutrient credit purchases. More
than 25% off site can be purchased with the approval of the VA DEQ. The program and
VDOTs participation are working well. Most of the banks are agricultural land conversions.
Agriculture land is typically converted to forest or wetlands.
VDOT policy and procedures are attached and illustrated in
slides. DEQ has approved 42 private nutrient credit banks in Vir-
ginia. The banks service HUC 8 watersheds. VDOT procures
credits from private banker owners. For projects under the quali-
fication thresholds, the District Drainage Engineer or Project Manager submits form LD-453 to
the Central Office, Location and Design MS4 program coordinator to procure credit. VDOT
tracks all purchases they make in the state. Procuring credits is a one-time cost and 1-to-1
credit ratio. VDOT now has approved Nutrient Credit Banks throughout the entire Common-
wealth. VDOT has made Approximately $4 million dollars in purchase.
In the state of Maryland, DEP and Department of Ag have been working on a banking-
crediting-trading program and will be announcing their credit program in the near future.
Crediting and Banking
Vince Davis, Delaware Department of Transportation
DelDOT has had a banking agreement in place from 1996 to
2014. This is an agreement with DNREC for DelDOT projects. The
agreement was initially based on impervious area. Tracking was
based on 45 watersheds (within the 4 major basins). A new agreement is being drafted that
will use the DURMM (Delaware Urban Runoff Management Model) to give a cubic foot
number to based runoff volume and credits on. DURMM Model recognizes the affect that
the infiltration/interception has on multiple pollutants (TSS, N, Zn, P, etc.) including TMDL con-
stituents. For credit/debit, projects must prove that treatment cannot be done on-site. They
are still looking to quantify stream restoration credits. DelDOT can add credits within their
projects (by over-treating runoff). This only applies to water quality. There is no variance or
waiver to water quantity. However, many DelDOT projects can be approved with
“Standard plans”. Standard plan projects are small projects that do not change the runoff
The program and
VDOTs participation
are working well.
DelDOT can add
credits within their
projects (by over-
treating runoff).
21. 21
CN or drainage pattern and have minimal quality and quantity impact. For projects under
standard plan review DelDOT does not have to do water quality. DNREC reviews DelDOT
banking activities every quarter.
Crediting and Banking
Ryan Reali, New Jersey Department of Transportation
Stormwater banking would solve a lot of issues for NJDOT regarding ROW cost. NJDOT did
research into banking programs for quality, and quantity, and groundwater recharge
based on HUC-11 watershed service area. NJDEP was concerned with flooding and lack of
control at stream being affected. NJDOT had prepared a full banking program (see http://
www.nj.gov/transportation/refdata/research/reports/FHWA-NJ-2009-022.pdf) but NJDEP
rejected the program. New Jersey doesn’t have a program for stormwater credits.
NJDOT developed stormwater credit approach on one project, the Route 72 Manahawkin
Bridge Project over Barnegat Bay. The project added over ¼ acre impervious and 1 acre
disturbance. The stormwater quality requirement could not be met on site due to limited
land availability and the area around bridge was a developed beach community or envi-
ronmentally sensitive.
NJDOT made an agreement from NJDEP to improve the quality of runoff going to Barnegat
Bay, a C-1 waterway (high quality). Numerous DOT owned drainage systems were empty-
ing into Barnegat Bay. To meet quality NJDOT retro fitted several existing basins. The exist-
ing extended detention basins were retrofitted to gravel wetland basins. NJDOT enhanced
performance of the basins to increase TSS removal from 45% or 126,770 lbs/year to 90% or
246,587 lbs/year and increase total nitrogen removal from 11% or 390 lbs/year to 73% or
2,411 lbs/year.
22. 22
Figure 3. Gravel wetland schematic retrofitted from an extended detention basin
NJDEP approval of stormwater crediting for this one project was driven by site constraints on
the project site limited for constructing new BMPs and the NJ Governor’s initiate to clean-up
Barnegat Bay. To get an exemption for quantity the BMP must dump into tidal water.
DDOT requires retain 1.2” of runoff from disturbed area on a project. DEP requires 50% re-
tention on-site before going with off-site retention options and the applicant must prove the
requirement cannot be met. The off-site option gives more volume retained and more area
treated. DDOT also has an in-lieu fee payment option of $3.57/gallon per year. Stormwater
retention credit is defined as one gallon of storage per year. DEP did a cost analysis to
price the in-lieu fee option higher than off-site options. A voluntary site that is not regulated
can receive storage credit up to the 1.7” storm. A regulated site can receive storage credit
above the required 1.2” up to 1.7”. A voluntary site can apply to get credits after inspec-
tion, approval and certified. Every gallon gets tracked, and available credits are listed on
an open market database. Creditor and buyer negotiate and agree on a price. Pricing
the in-lieu option makes the off-site option more attractive and encourages the open mar-
ket exchange of credits. Certified credits are good for 3 years. Credits must be recertified
every 3 years. Creditor is not permanently tied to the project. Some condos have retrofit-
ted with green roofs to generate credits.
The Federal Highway Administration (FHWA) has been evaluating the feasibility of develop-
ing a stormwater-based crediting framework that can be used by DOTs to develop, or par-
ticipate in the development of, crediting programs that can be utilized to provide flexibility
in meeting stormwater management requirements. A study commissioned by FHWA should
be completed in 2017. Later in 2017 FHWA will bring together stakeholders to discuss, com-
pare and recommend a framework for DOT stormwater quality/banking/trading strategies.
23. 23
The concept of green infrastructure is larger than stormwater. It should include animal pas-
sage, green space, Eco-Logical concepts that contribute to water quality as well. Finding a
common language would improve understanding and development of solutions.
Impact of the Bay TMDL on DOTs
Karen Coffman, Maryland State Highway Administration
The Maryland State Highway Administration (MDSHA) has been working for several years to
address load reduction targets for nitrogen, phosphorus and sediment assigned to SHA by
the MD Department of the Environment (MDE) to meet Maryland’s waste load allocations
(WLAs) in the Chesapeake Bay TMDL; and to complete restoration projects to meet antici-
pated 20% impervious surface restoration condition in the draft Maryland NPDES MS4 Phase
I permit. Within the MDSHA organization, the NPDES program is well integrated, with many
offices performing work to comply with MS4 Phase I & II, industrial and construction activity
permits including recent delegated authority for SWM/ESC permitting by MDSHA. Of partic-
ular interest to this peer group are two divisions: the Office of Highway Development (OHD),
Highway Hydraulics Division under Dana Havlik, is responsible for stormwater and erosion
and sediment control design and review as well as the water quality bank; and the Office
of Environmental Design, Water Programs Division under Karen Coffman, is responsible for
MS4 compliance and reporting and restoration projects associated with TMDL and MS4 per-
mits. Under the NPDES delegation, the SHA Plan Review Division provides sediment control
and stormwater plan review and approval for all SHA projects.
Total Maximum daily load (TMDL) requirements for Chesapeake Bay restoration have been
given to SHA as part of the Maryland Phase I Watershed Implementation Plan (WIP I) in the
form of pollutant reduction targets and the SHA Phase I MS4 permit as a requirement to re-
store 20% of previously built impervious surfaces by providing stormwater runoff controls.
A cogent discussion occurred about the challenge of meeting regulatory water quality
targets. The rational of specific regulatory water quality targets is questioned due to
normal variation in stormwater runoff generating conditions. A combination of variables
including precipitation events, pre-storm flow, stormflow, water quality, runoff coeffi-
cients, highway site characteristics, receiving water basin characteristics, and mitiga-
tion measures (BMPs) causes variability in stormwater runoff quality. Water quality tar-
gets, models and compliance should account for this variability in stormwater runoff
quality.
24. 24
Preliminary estimates of restoration requirements for SHA amount to over 5,000 acres of exist-
ing impervious surfaces without runoff treatment, which has been determined to be over
$600 Million expenditure between 2015 and 2021. Strategies being employed include
changing land uses to reduce runoff loading including tree planting and removing impervi-
ous surfaces; building new and retrofitting traditional and environmental site design (ESD)
stormwater controls; and reducing loads at the source through stream restoration, inlet
cleaning and outfall stabilization.
SHA is utilizing both state employees as team leaders (3) and facilitators and consultant pro-
ject managers (over 30 and increasing) and design teams as an implementation workforce.
The team leaders cover different aspects of the implementation plan (stormwater manage-
ment, stream restoration and outfall stabilization, and tree projects). The program is working
within the SHA organization structure to design, permit, advertise and construct the restora-
tion projects by utilizing a non-disclosure agreement between SHA and key consultant pro-
ject managers that allows them to perform certain tasks typically reserved for state person-
nel. Consultants assist with geotechnical investigations, permitting, etc. An extensive GIS
and database system has been developed to facilitate tracking, mapping, etc. (see MD
SHA – EMS for TMDL Implementation below). GIS identifies/tracks areas constructed, under
construction or under design and potential sites for BMP implementation, and treated/
untreated impervious surface calculation.
Impervious surface calculation
SHA has developed a protocol using GIS effort to analyze whether existing channels meet
criteria for water quality swale. Field crews verify that swales identified by the GIS protocol
meet criteria for water quality swale. Applicable swales are added to the database as
stormwater management facilities.
MDSHA will have to continuously maintain the BMPs and credits. Under the Bay Program,
stream restoration credits will have a 10 year renewal cycle and stormwater management
will have a 5 year renewal cycle. BMPS will have a 3 year inspection and remediation cy-
cle.
It was mentioned that the Stochastic Empirical Loading and Dilution Model
(SELDM) recognizes the stochastic nature of stormflow variables and its ap-
proach should be considered by the regulatory community. The science
of water quality management must recognize and accommodate uncer-
tainty.
25. 25
MDSHA have developed a series of work flow charts to facilitate training, coordination and
management of consultant teamwork and products. The database facilitates task man-
agement, programming A&E contracts (and funding), summary reports (e.g., cost per acre
of credits).
Numerous modeling efforts going on for the Bay TMDL has impacted MDSHA reporting.
Modeling efforts are not coordinated and results do not always agree. The Maryland As-
sessment Scenario Tool (MAST) derived different loadings and resulted in changes in load-
ings requirements. As discussed earlier, it is difficult for DOTs to adjust projects, plans and
contracts on short notice in response to changing targets. Pollutant removal efficiencies
used in MAST are not equating to the pollutant removal efficiencies used in the NPDES ac-
counting guidance that MDE issued and not aligned with the Bay protocol efficiencies. So
for reporting, MDSHA developed a modeling tool that allows MDSHA to change the effi-
ciencies depending on who they are reporting to. TMDL targets remain a moving target.
Water quality monitoring data is typically wide ranging as data varies with site, storm and
traffic characteristics and pollutant removal efficiencies used.
MDSHA has encountered some lawsuits opposing Phase 1 MS4 permits. Tree planting re-
quirements present issues with roadway safety. MDSHA is working on a salt management
plan for watersheds that are chloride impaired. Other efforts include a trash program,
street sweep research study, bioretention monitoring. MDSHA is developing an outfall cred-
iting protocol for sediment retained at outfalls and investigating offset and trading opportu-
nities.
EMS for TMDL Implementation
Karen Coffman, Maryland State Highway Administration
MD SHA has integrated environmental stewardship and compliance into the organizational
thinking by implementing many environmental performance measures into our business
plan including pollutant reductions and impervious restoration for Chesapeake Bay TMDL
compliance (sediment, phosphorous, bacteria, PCBs, trash). Our MS4 restoration program
relies heavily on GIS, data development and management to develop watershed strate-
gies and take implementation projects from planning through construction. Also, develop-
ing the impervious surfaces and treatment requirements is a large GIS analysis of SHA road-
ways and stormwater management systems across 11 counties. The MS4 permit authority,
Maryland Department of the Environment (MDE) published an accounting guidance for de-
termining means for complying with impervious restoration and waste load allocations
(WLAs) and a standardized geodatabase design format for permit data development and
delivery. We have developed a geodatabase, side databases, Microsoft schedules and
field verification tools that support the program. A standardized modeling tool is under de-
velopment that will read many data sources as well as allow input of varying modeling pa-
rameters to assist SHA in developing the most effective BMP implementation strategy. eGIS
software is employed to share data throughout SHA at an enterprise level with a special
26. 26
widget developed to allow data editing within the eGIS environment. Our Chesapeake
Bay restoration BMPs and other reports and information are loaded to an external website
that allows the public to key in their address to see restoration projects in proximity to their
neighborhoods.
TMDL and Environmental Management System
Winnie Okello, Pennsylvania Department of Transportation
PENNDOT is NOT currently under any specific TMDL requirements
PennDOT is not named in a TMDL and not a significant source of nutrient loading. However,
PennDOT has developed a proactive plan that it will initiate if and when named in a TMDL.
It is PennDOT’s position that new discharges are addressed through DEP’s NPDES Permitting
program and PennDOT will develop and implement an MS4 TMDL plan, if and when named
in a TMDL that is consistent with any applicable WLA (based on proposed PRP plans). In
the future, PennDOT and DEP may establish a policy or agreement for credits and banking
of pollutant load reductions based on establishment of riparian forest buffers, stream resto-
ration/reclamation, and other identified best management practices.
Some changes are anticipated in maintenance practices, such as limiting application of
fertilizers to establish roadside vegetation and specifying application rates in PENNDOT' S
408 Specifications. Currently, roadside mowing has been reduced. PennDOT will include
in the MS4 permit reports the SCMs and stream restoration/enhancement activities con-
structed in areas tributary to locally impaired water bodies or watersheds with applicable
WLAs in approved TMDLs in designated urbanized areas.
DEP’s desire for PennDOT to address existing impervious areas in UA and include proactive
measures in the NPDES permit will increase operation and maintenance costs. Costs are
likely to increase for the design process, reporting requirements (e.g., system mapping, pol-
lution reduction). PennDOT has been holding roundtable talks to get perspective from the
design, construction and maintenance folks on the permit requirements so that PennDOT
can determine what is practicable and what is not and to identify areas where PennDOT is
meeting reduction goals. DEP has hinted to future regulatory requirements regarding salt.
Documentation has been a key focus area of PennDOT’s continuous process improvement.
PennDOT EMS
PennDOT has an ISO 14001 status and conducts 3rd Party compliance audits in addition to
the current ISO 14001 audits. These compliance audits have identified compliance defi-
ciencies in the system missed by ISO 14001 process audits. PennDOT is de-centralized with
Districts certified individually – each having its own EMS. ISO is a process-based system - not
compliance based and focuses on ensuring that processes are in place. ISO 14001 auditors
are not trained on PennDOT operations.
27. 27
PennDOT proposes to replace its ISO 14001 registrations with a new EMS that is a Statewide
system that will create more uniformity throughout the Engineering Districts. The newly pro-
posed EMS is compliance based (determined by regulatory compliance). A Strategic Envi-
ronmental Management Committee (SEMC) formed that is comprised of cross-section of
employees from Districts and Central Office. The SEMC provides SEMP management over-
sight and serves as management review. The SEMC created a Corrective and Preventive
Actions (CAR PAR) database that will inform all districts and facilitate proactive measures
within the Districts. The new database will include defined O&M plans and training, aware-
ness, and competence requirements for all activities (not just for MS4). The database will
include GIS data, data from Google maps, on-site inspections, notifications and will eventu-
ally incorporate an app to allow download information from the field. A single statewide
database will result in better and more consistent documentation. The CAR PAR will rate
severity of findings and allow Districts to share best management practices/lessons learned.
PennDOT is proposing internal and external controls. Internal Controls will include annual
compliance audit, quarterly stockpile environmental checklists, and monthly site-specific
tank inspection forms. External Controls will include Annual 3rd-party compliance audit (20%
of facilities per year) and annual 3rd-party quality assurance reviews (20% of facilities per
year). Audit results will be tied to employee performance reviews (for District Executives).
PennDOT has an eCMS (electronic Contract Management System) that manages PennDOT
processes from design to construction and eDMS (electronic Data Management System)
that manages project documents.
Environmental Management System
Dana Havlik, Maryland State Highway Administration
The objectives of the MDSHA Stormwater Management Program are 1) Sustain and en-
hance SWM Facilities Performance ( pollutants removal efficiency, safety and aesthetic ap-
pearance and comply with SWM approval); 2) Comply with NPDES permit requirements
(inventory and inspect all SWM facilities, perform routine maintenance annually, identify
and perform required repair work, and re-inspect each facility every 3 years); and 3) To
meet SHA Business Goal of 90% functional adequacy by the end of FY year 2010.
MDSHA has developed a manual for Field Inspection and Data Collection Procedure.
MDSHA uses a two tier rating system to evaluate their SWM facilities. SWM facility perfor-
mance rating is based on structural integrity and functionality. Structural Integrity ratings
ranging from 1 (Operating as Designed, No Issues Observed) to 5 (Non-Functional, Hazard-
ous Conditions) and Functioning rating ranging from A (Functioning as designed, no prob-
lem conditions) to E (Facility failed, hazardous conditions) determine MDSHA response or re-
mediation action for the facility. MDSHA action ratings are:
28. 28
I No Response Required – schedule for multi-year inspection
II Minor Maintenance – perform as necessary to sustain BMP performance. Upon reme-
dial action and re-inspection, can be candidate for multi-year inspection
III Major Maintenance or Repair – is needed to return the site to original functionality
within the existing footprint of the facility. Structural defects require repair and/or restoration
(requires heavy equipment mobilization; handled by contracts))
IV Retrofit Design – is required on-site or at another location, since BMP cannot be re-
turned to its original functionality within its existing footprint
V Immediate Response – is mandatory to address any public safety hazards regardless
of the functionality of the BMP
VI Abandonment – of the BMP when the facility is not maintainable and will not provide
sufficient benefits if retrofitted due to the lack of access for construction and maintenance,
limited space or minimum impervious area treated
Figure 4. MDSHA Stormwater management facilities Program and Process for BMP Mainte-
nance and Remediation
MDSHA has an extensive inventory of SWM BMPs to inspection and maintain to comply with
their NPDES permit.
29. 29
Programmatic Efforts undertaken to meet the demands of this aspect of the NPDES permit
include: innovative contracting for BMP maintenance and remediation, performing preven-
tive maintenance through SHA District Maintenance Offices, and continually improving da-
ta management tools for effective data tracking. Currently, MDSHA is developing a manu-
al for maintenance staff and working with maintenance staff to identify effective data
management tools for their preventive maintenance duties. Preventive maintenance is es-
sential minimizing capital cost and future projections show the number of SWM BMPs to
maintain substantially increasing while the maintenance are tight. The maintenance budg-
et gets impacted when there is a hard winter maintenance season and maintenance ac-
tivities can also be burdened by the cost of invasive species management.
MDSHA is implementing restoration projects in their MS4 coverage (11 urban counties) in an-
ticipation of their future MS4 permit and for the Bay TMDL compliance. The Bay Cabinet de-
termined that impervious surface restoration activities meet the TMDL load requirement.
The Bay TMDL load requirement is evaluated and tracked for each county individually and
the MS4 impervious surface treatment requirement is evaluated and tracked collectively for
all 11 counties. The impervious surface treatment requirement has less geographic re-
striction allowing MDSHA to identify eligible projects/activities. Meeting the Bay TMDL load
requirement involves working collaboratively with local municipalities. Double counting
(Bay credits and NPDES credits) is not allowed.
Program Funding
Meredith Upchurch, District Department of Transportation
Through Federal-aid projects, stormwater facilities are eligible to be built and funded by
Federal-aid funds. In DC, private developments that disturb the public ROW are required to
manage runoff from the ROW in perpetuity including establishment of covenants. Other
funding sources include a stormwater fee. Fees are collected from all properties. The resi-
dential property fee is based on residential units per household and commercial fees are
based on impervious area. In Lieu Fee is used for regulated parcels. A 5 cent grocery bag
fee goes toward stormwater. Stormwater activities are also supported some special interest
projects and funding. DC uses Federal funding sources from transportation (enhancement
funds), EPA clean water state revolving funds grants, and National Fish and Wildlife Founda-
tion grants. For maintenance, DDOT is inventorying sites in GIS and using the Cityworks work
order management system. Due to low funding, maintenance, inspection, and manage-
ment schedules are inconsistent.
Stormwater facilities may be constructed using enhancement funds but this is a competitive
funding source that is allocated based on state DOT interests (e.g., historic, recreation and
aesthetic interests) rather stormwater program needs. Enhancement funded projects are
more similar capital projects than maintenance activities. SAFETEA-LU does support inven-
torying assets and information management systems which may include stormwater facili-
30. 30
ties. These types of activities are more similar to transportation, community and system
preservation than maintenance.
Stormwater facilities are essential to overall surface transportation system and intersect long
-term with issues such as CWA permit requirements, Endangered Species Act requirements,
Invasive Species Executive Order, asset management, and safety. As long-term manage-
ment of stormwater facilities are more clearly tied to and become a prominent element of
highway project objectives such as green infrastructure, funding eligibilities may be revised
or become more flexible in support of stormwater management funding eligibility.
There are several programs that could be considered maintenance, but the language used
to describe the activity does not state that (e.g., Pavement Rehabilitation Program, Bridge
Painting Contracts, Line Striping Contracts). Let’s begin to champion and put forward cap-
ital improvement programs and projects titled as e.g., Drainage Improvement Program –
STP Program Funding, Flood Mitigation Program – NHPP Funding, Corridor Enhancement –
TAP Program Funding, Drainage Inspection and Evaluation – NHPP Funding (Asset Manage-
ment).
DelDOT Database, EM process and work management
LaTonya Gilliam, Delaware Department of Transportation
With each permit cycle, DelDOT has made improvements in the areas information and work
management. Initially starting with a modest access database with uploaded photos and
assets, the DelDOT database has been improved to incorporate GIS data and housing doc-
uments via Sharepoint. The most recent database version allows viewing and querying in-
formation. Map viewer and map viewer mobile app allows maintenance staff to locate
drainage system elements, stormwater BMPs, inspection reports and query and access work
orders (WOs). Tracking and inventory is done using Maximo Asset Management system.
Maintenance staff can query information off WOs. For example, a vac truck team can
query and retrieve WOs for inlets over 50% full and print a map or table of those WOs. Que-
rying may be done by type of maintenance. Work activities are coded by type of work/
maintenance. Inspectors enter customized WO codes into the system as they are creating
WOs. DelDOT customized Maximo codes to represent MS4/BMP inspection work and im-
Generally, stormwater maintenance activities are not eligible for Federal funding:
The Surface Transportation Program (STP) (23 U.S.C. 133) provides funds (as capital funding) for public
transportation capital improvements, ...
FAST Act provides a set-aside of Surface Transportation Block Grant (STBG) program fund-
ing for transportation alternatives (TA). These set-aside funds include all projects and ac-
tivities that were previously eligible under the MAP-21 Transportation Alternatives Pro-
gram (TAP) including environmental mitigation related to stormwater.
31. 31
prove work flow. A “tree view” feature pulls up all files associated with an asset (e.g., WOs,
as-built plans, inspection reports, consent orders, etc.). Maintenance staff assembles a
notebook containing all inspection reports and maps of all facilities that is used for their an-
nual work plan. All assets are geotagged and cross-reference in Maximo.
This improved data and information tool allows DelDOT to effectively maintain a preventa-
tive maintenance schedule for all of its BMPs. Neglected maintenance could lead to costly
reconstruction of a SWM facility such as removal of accumulated sediment, reconstructing
fore bay areas, removing tree roots from pipes. So in essence, the database improvements
will result in cost savings. Custom coded WOs for querying and geotagging assets for loca-
tion is a notable innovation.
Drainage is one of the 6 assets that DelDOT has selected to actively manage under MAP-21.
Database information is used to develop quantities for capital drainage improvement pro-
jects.
DelDOT is now developing modules for specific work flow and data management needs. A
module is being developed for the E&S team that will contain active construction plans,
certified construction review forms, CCR inspection forms, and weekly inspection forms. This
will facilitate document request during the next audit. DelDOT has about 550 active BMPS
and about 400 in design or construction.
Map output is color keyed to show current WOs (pink), completed WOs (green), outfalls
(yellow), NPDES outfalls (orange) discharging off DelDOT-system. DelDOT's renewed Phase 1
permit has two new elements, a PCB pollutant minimization plan and water quality improve-
ment plans (WQIP). For the WQIP, DelDOT will select two WQIPs to implement within 4 years.
For the WQIP requirement, DelDOT is able locate opportunities to retrofit NPDES outfalls dis-
charging < 50 acre off the DelDOT system. WQIPs are based on watersheds. DelDOT is re-
quired to reduce effective impervious surface by 3% within their MS4 area (New Castle
County).
DelDOT will eventually integrate all database work modules into a single module (E&S,
maintenance, IDDE, water quality reports/monitoring, stream restoration, etc.). The tool will
eventually meet the requirements for electronic reporting and be flexible enough to
change/modify for reporting purposes.
DelDOT links its annual reports and Storm Water Pollution Prevention and Management Pro-
gram (SWMP) at http://deldot.gov/stormwater/permit.shtml
The SWMP lists goals, methods, and provides an overview of each Permit element and mon-
itoring requirement. Goals are listed for Principal Permittees and Co-permittees.
DelDOT proposes to monitor IDDE as follows:
Annually 20% will receive comprehensive inspection by a desktop exercise, and screening,
which will occur in the field. The evaluations will be comprehensive irrespective of municipal
32. 32
boundaries and DelDOT will make information available to all Permittees. Approximately
20% of the system in New Castle County will be evaluated each year such that the entire
system is evaluated by the end of the Permit term. Outfalls to be targeted for subsequent
screening each year as well as criteria for selecting outfall sites to be monitored are de-
fined in the permit. Important criteria for outfall screening/monitoring include past reports/
complaints, outfalls with expected higher potential for illicit discharges or connections (e.g.,
age of development; density or aging septic systems; aging or failing sewer infrastructure;
and density and age of industrial activities), outfall draining at least 50acres, landscape
type, etc. See http://deldot.gov/stormwater/pdfs/SWPPMPFinal080114.pdf
Finally, DelDOT maintains an internal website for posting education, information and bulle-
tins for maintenance staff.
BMP Coordination
Vince Davis, Delaware Department of Transportation
DelDOT BMP design coordination is handled through E&S Section. DelDOT moved to a con-
currence approach as away from tradition terminology of preliminary design, semi-final de-
sign, draft final design and final design approach. Use of tradition terminology was confus-
ing (prelim, semi-final, pre-final, final, post-final, post-post final, approved plan). Concur-
rence meetings are agreement points that focus resolving on relevant design issues. For
example, the first concurrence meeting focuses on limits of disturbance, outfall locations,
and kinds of BMPs to consider. This allows designers to think about issues early. Unresolved
design issues can affect project costs, scheduling, change orders, and project manage-
ment. DelDOT utilizes Primavera Project Management software that allows their DEs to
monitor project progress. The water quality goal for stormwater management in Delaware
is to infiltrate 2.7” (1-year storm event). This is the resource protection volume (RPv). The
goal of stormwater quantity is to design for 10- and 100- year events (CE&FE , see DelDOT
chart for designers). Currently, there is no design standard to follow for TMDL compliance
but an approach is anticipated. Delaware state regulations all for the use of standardize
plans (“Standard plans”) for routine projects that result in minimal change to drainage, CN,
etc. The criteria and applicability of standard plan for projects is discussed during concur-
rence meeting one. Standard plans can be applied to most DelDOT projects. Most bridge
jobs meet standard plan criteria. Small bridge work usually includes removing old pipes,
scour protection which is a stream enhancement. DelDOT anticipates that they will be re-
quired to track TMDL compliance. Believing that “Standard Plan” projects are not substan-
tial contributors to TMDL issues, DelDOT will track standard plan projects to rebut claims of
DelDOT's contribution to TMDL issues.
The Delaware Sediment and Stormwater Regulations allow DNREC to develop criteria for
cases when a standardized Sediment and Stormwater Management Plan may satisfy the
33. 33
requirement in the place of a detailed plan. When a project meets the Standard Plan ap-
plicability criteria for the project type, that project has the option to comply with the con-
ditions of the Standard Plan for the project type, in lieu of developing a detailed Sediment
and Stormwater Management Plan.
Minor Linear Disturbances Applicability: 1. Disturbance will be linear, as in utility construc-
tion, having a maximum width of disturbance of 20 feet, and a maximum length of 2.0
miles. 2. No greater than 1.0 acre will be disturbed at any one time throughout the course
of construction. 3. Within the disturbed area, the pre-development land use is not classified
as “wooded” based on the 2007 Delaware Land Use/Land Cover data. 4. Land cover will
be restored to the pre-construction hydrologic condition. Preconstruction grading and sur-
face cover will remain after construction. No new impervious surfaces will be created as
part of the construction. Conditions: 1. Stabilization with seed and mulch or seed and stabi-
lization matting will occur daily so that no greater than one acre will be disturbed at any
one time. 2. Construction site stormwater management best management practices will
be used. 3. Construction through sensitive areas, including stream and wetland crossings,
will be accomplished through directional drilling, with land disturbance happening outside
of the sensitive area. 4. Construction projects exceeding 1.0 acre of total disturbance re-
quire submittal of a Notice of Intent (NOI) for Stormwater Discharges Associated with Con-
struction Activity. A plan fulfilling Stormwater Pollution Prevention Plan (SWPPP) require-
ments must be developed to obtain general permit coverage for Stormwater Discharges
Associated with Construction Activity.
http://www.dnrec.delaware.gov/swc/Drainage/Documents/Sediment%20and%
20Stormwater%20Program/Technical%20Document/Latest%20Version%20of%20all%
20Articles/3.01%20Project%20Types.pdf
Using DURMM will calculate adjusted CN for a project based on combinations of land cover
and soil type and BMPs used. For example, DURMM calculate higher runoff reduction with
bioswale than with vegetative channel.
Some BMPs approved by DNREC are not applicable to DelDOT projects. DelDOT commonly
uses infiltration basin and trench, bioswale (requires 9 minute residence time), bioretention
and anticipates increasing use of underground infiltration trench. Filter strip was eliminated
because the design requires 3” drop off which is a traffic safety problem. Generally,
DelDOT avoids using any high maintenance proprietary BMPs.
Some states are moving away from infiltration because of groundwater contamination.
BMP Coordination
Meredith Upchurch, District Department of Transportation
DC has made a huge effort toward green infrastructure including a 2014 publication of
Green Infrastructure Standards (Green Book, see http://ddot.dc.gov/sites/default/files/dc/
sites/ddot/publication/attachments/2014-Final%20DDOT%20Green%20Infrastructure%
34. 34
20Standards.pdf ). DDOT earned an FHWA Environmental Excellence Award for its green
infrastructure efforts.
Inspections
Dana Havlik, MDSHA
Inspection is a requirement of the NPDES permit. Re-inspect is required every 3 years to en-
sure that 90% of BMPs are functional. MDSHA has developed 8 chapters of standard proce-
dures. Chapter 3 provides details for inspecting BMPs for performance and inventory in-
spection rating. Chapter 7 describes SHA actions in response to ratings. The manual will in-
clude sections on data management to support continuous improvement of their data-
base and new technologies. Most as-builts, design reports are scanned and retrievable
electronically. Design report provides important information describing the objective/
functions of the structure/facility. This is valuable and useful for inspection as inspectors
may be misinformed by a non-functioning BMP (e.g., a failed infiltration basin may appear
as a stormwater pond). The BMP rating is based on 45 factors.
Major maintenance is requires on about 20% of MDSHA facilities. Example s of major
maintenance include stabilization of eroded areas, structural repairs, vegetation manage-
ment, grading and dredging, outfall repairs, debris removal , infiltration trench media re-
placement and well installation. Major maintenance typically requires an E&S plan and if
the facility occurs on jurisdictional waters a permit is required for the work. With delegation,
MDSHA has general approval for E&S.
Retrofit design is challenging and requires converting a failed bmp to a different functional
bmp. If the BMP is retrofitted or changed then the stormwater plan and reports must be up-
dated. Retrofits are considered new projects and required a new permit to build.
MDSHA uses on-call contractors paid by time and material or by bid items. The standard
procedures will be an important guide for preventive maintenance, data management
and tracking. MDSHA recently began collecting information on pipe invert for climate
change and to determine flow capacity.
35. 35
Figure 3. Failed infiltration basin
Figure 4. Failed infiltration basin retrofitted to a sand filter
36. 36
Inspections
Vince Davis, DelDOT
DelDOT uses 3rd party E&S inspectors (2 Consultants) for construction sites. They are paid for
under construction engineering funding set up at the time of the project. For minor pro-
jects, E&S may be assigned to the construction inspector and they are required to maintain
a write E&S notes in their construction diary. DelDOT has a rating form (similar to Mary-
land’s) that is used for all contracts where E&S inspectors are used. DelDOT did a study to
evaluate its previous rating form (recommended by DNREC) and determined that the form
should be revised using more informative criteria. With the new form, inspections result is a
number grade and contractors seem to be motivates contractors to keep scores above
average. The previous form only had three subjective rankings. DelDOT weighted its in-
spection form more heavily toward stabilization and prior deficiencies which were com-
mon issues indicated from EPA inspections (deficiencies were not corrected in a timely
manner and plans were not red-lined). The inspection form also ties into contract specifi-
cation and project deductions. The form is color coded for ease of use. Inspectors are
strongly encouraged to take photos to document each deficiency and the corrective
measures.
New specifications identify a list of actions that construction must take if a contractor re-
ceives a low inspection score. The list of actions includes automatic re-inspection in two
days; withhold money; shut down project; prohibit other work until E&S is corrected.
DelDOT is moving to new performance seeding specifications based on species density
and growth that is more enforceable as well.
DelDOT just developed an incentive spec that allows the contractor to receive extra mon-
ey monthly if rating is above a certain level. This seems to reduce combativeness with the
contractor. DelDOT's first incentive project inspection received a score of 100. Incentive
computation is available on request. It’s based on project type (e.g., bridge, scale of con-
struction, number of days).
DelDOT uses a Facility Construction Checklist that ultimately becomes part of the as-built
and project documentation. The Facility Construction Checklist was mandated by DNREC
and modified for DelDOT. In addition to pre-construction meeting, DelDOT holds a sepa-
rate E&S pre-construction meeting. Contractor, DelDOT and DelDOT E&S must be present
for inspections when filling out the rating form. Contractor is usually willing to fix deficien-
37. 37
cies immediately to get incentive dollars. Some are even hiring full-time crews to maintain
E&S.
DelDOT's BMP field inventory and inspection follows a manual similar MDSHA’s. DelDOT
found it very useful to provide informal training and guidance to all maintenance staff. The
training focused on following the manual, identifying BMP types and maintenance require-
ments for each/all BMPs. Some maintenance crews brought their equipment to the train-
ing sessions and worked on BMPs under the guidance of DelDOT MS4 staff. DelDOT MS4
staff met with all maintenance staff.
Generally, maintenance work follows a season cycle (snow/ice Dec- Apr; street sweeping/
mowing Apr-summer; drainage and MS4 inspection summer-Sept; BMP inspection/
maintenance Oct). WOs for MS4 inspection and BMP inspection/maintenance are incor-
porated into the maintenance work cycle. WOs tend to get loss or overlooked if sent out
too soon. So timing WOs assignments with the maintenance staff’s season work cycle is im-
portant. Maintenance staff now works comfortably with specification sheets and WO
codes. Completed WOs are uploaded into Maximo quarterly by IT staff.
DelDOT's MS4 goal is to get all BMPs up to 90% function. DelDOT can generate costs and
track the cost of planned and completed NPDES related work.
DelDOT Traffic Safety has developed cases of TTC (“temporary traffic control”) zones ac-
cording to duration, location, type of work, and highway type. DelDOT uses this infor-
mation to develop reasonable accurate contracts estimates where TTC is required. This is a
notable innovation as MS4 maintenance is a great concern for DOTs. Examples of DelDOT
TTC cases can be found at http://www.deldot.gov/information/pubs_forms/manuals/
de_mutcd/pdf/Part_6_August_2009_Final.pdf .
38. 38
Sharing Resources
What information can we share?
Training videos
IDDE evaluation process
Weblinks
MS4front.com
field guides
Where can we share it?
Drop Box
Google Drive
Online Resources
AASHTO Maintenance Stormwater Field Guide
http://www.environment.transportation.org/center/products_programs/reports/
field_guide_maintenance_stormwater.aspx
2014-Final DDOT Green Infrastructure Standards
http://ddot.dc.gov/sites/default/files/dc/sites/ddot/publication/attachments/2014-Final%
20DDOT%20Green%20Infrastructure%20Standards.pdf
39. 39
Winnie Okello PennDOT 717-214-8788 wokello@pa.gov
Dana Havlik MDSHA 410-545-8418 dhavlik@sha.state.md.us
Karen Coffman MDSHA (410) 545-8407 kcoffman@sha.state.md.us
John Olenik VDOT (804) 371-0366 John.Olenik@VDOT.Virginia.gov
Ed Wallingford VDOT 804.371.6824 E.Wallingford@VDOT.Virginia.go
v
Meredith Up-
church
DDOT 202-671-4663 meredith.upchurch@dc.gov
Etayanesh (Ty)
Asfaw
DDOT (202) etayenesh.asfaw@dc.gov
Meeti Trivedi NJDOT (609) 530-5652 Meeta.Trivedi@dot.nj.gov
Ryan Reali NJDOT 609-530-6500 Ryan.Reali@dot.nj.gov
Vince Davis DelDOT (302) 760-2180 Vince.Davis@state.de.us
LaTonya Gilliam DelDOT 302.760.2095 LaTonya.Gilliam@state.de.us
Brian Smith FHWA-
Resource
Center
708-283-3553 bsmith@dot.gov
Marcel Tchaou FHWA Pro-
ject Dev &
Envir Review
202-366-4196 Marcel.Tchaou@dot.gov
40. 11/7/2016
40
DelDOT Delegation
Authority
US EPA
NPDES
Stormwater
Program
DNREC
Division of Water
Surface Water
Discharges Section
DelDOT
Environmental Section
Wetlands / Waters Permit
Section also does:
NEPA, 401, 404 Permits
Section 10 Reports
Stormwater General
Permits
(7 Del C. Chapter 60)
Construction Activities
(Part 2)
DNREC
Division of Watershed
Stewardship
Sediment and Stormwater
(7 Del C. Chapter 40)
DelDOT
Stormwater Section
Stormwater Management
Construction E & S
Pesticides General
Permit
Individual Permits
Industrial Stormwater
Permits (Part 1)
MS4 Program
DelDOT
Roadside Environmental
Section
DelDOT
NPDES Section
Phase I and II Permits
DelDOT
NPDES Section
Maintenance Facilities
DNREC – DelDOT Environmental Associations
The following agencies have delegation of Sediment and Stormwater Program
elements consisting of plan review, construction inspection, and maintenance
inspection for their geographic boundaries. Re‐delegation occurs every 3 years.
DelDOT
Delegated Agencies Under DNREC
DelDOT ES2M Basic Job Duties
41. MD SHA Program Initiatives
Maryland State Highway Administration
Dana Havlik. PE, Division Chief
Office of Highway Development
Highway Hydraulics Division
Maryland SHA Programs
2
Office of Highway Development
Highway Hydraulics Division (HHD)
Design, Technical Support and Review
Drainage and Stormwater Assets
Management Program
Plan Review Division (PRD)
Permitting and Delegated Authority
3
Where Do We All Fit?
MDOT
State Highway
Administration
Administration Operations
Planning, Engineering,
Real Estate, and
Environment
Office of
Maintenance
OMT
OOTS
District Offices
(D1-D7)
Office of Real Estate
Office of Structures
Office of
Environmental Design
Environmental
Programs
Quality
Assurance
Landscape
Architecture
NPDES/TMDL
Landscape
Operations
Environmental
Compliance
Office of Highway
Development
Highway Design
Community Design
Highway Hydraulics
Innovative
Contracting
Plan Review
Design Technical
Services
Engineering
Resources
Access
Management
Plats and
Surveys
4
42. Highway Hydraulics Division
Design, Technical Support and Review
Major highway projects support
HH modeling/drainage design
Stormwater Management Design (SWM)
Stream restoration/stabilization design
Erosion and Sediment Control (ECSC)
Projects Review
Environmental permits coordination – ESC/
SWM/NPDES
5
Maryland Regulations
SWM /ESC Regulations (COMAR 26.17.01 _& 26.17.02)
ESC approval required for disturbance over 5000 Sq. Ft
SWM required for all new impervious areas ( new development
and redevelopment projects are treated differently
Impervious Area Requiring Treatment (IART) – Water Quality
treatment: 100% new and 50% reconstructed
ESD to MEP, Structural BMPs only when necessary
Water Quantity Management :
– Channel Protection
– Peak Flow Management 2 yr, 10 yr and 100yr in some
watersheds
– Downstream channel stability
NPDES Permit for CA ( LOD >1 Acre) 6
Water Quality (WQ) Bank
To streamline project permitting and assure timely delivery
Tracks amount of impervious
areas managed or treated for WQ
in acres.
Balances managed on a
watershed basis using the 6-digit
basin identification.
Projects with impervious area
treatment in excess of
requirements are added as
credits.
Projects that cannot meet
treatment requirements may be
debited.
7
Water Quality (WQ) Bank
Strategy and Tracking Tool
8
44. Changes in Plan Review and Processing
Delegated Authority applies to all new projects that have
not been submitted to MDE as of February 2015.
Highway Hydraulics Division continues its design
expertise function
All submissions go through HHD
3 Separate Approvals for SWM/ESC:
Approval stages coincide with Major Milestone Reviews
Concept Preliminary Investigation
Site Development Semi-Final Review
Final Approval Final Review/PSE
Each approval stage may require multiple submissions
13
Compliance
SHA QA Program will continue to provide ESC Compliance inspections
SWM Compliance inspections is a new responsibility for SHA QA program
Attention to Stormwater Construction as-built certification
Modification Approvals – Two Levels
– Level 1
Minor in scope
Review/Approval by QA Program
– Level 2
Major in scope
Review/Approval by HHD/PRD (new projects)
HHD/MDE (existing projects)
14
MDE Partnership
MDE to maintain enforcement authority and continue
to provide programmatic oversight
SHA to submit quarterly reports for the first year and
annual reports thereafter
MDE shall conduct review and construction audits
EPA may audit SHA processes
15
Going Forward
MD SHA partnering with MDE:
Finalizing Technical Procedures
Finalizing reconciliation of Water Quality Bank
Developing Standard Details
Worksheets and computational methods
General Approvals
Policies, Administrative Procedures, Guidelines, SOP’s and
Review Checklists-COMPLETE!!!!
16
46. 11/7/2016
46
MS4 Mid-Atlantic States Peer Exchange
Topic: EPA Audits
By: Winnie Okello
Sept 21, 2015
2015 EPA inspections
Berks
Bucks
Delaware
Montgomery
Philadelphia
Requested Documents from district offices
Maintenance Stockpile Evaluation docs (external audits/evaluations)
Internal Evaluations reports
County Salt management plans ( Pub 23 Ch.4)
Foreman's Quarterly Stockpile Checklist
SEMP Checklist and record form
Oil -water separator cleanout docs
Corrective Action Reports (CARPARS)
Latest CFRP-Combined facility response Plan
SEMP Manual
Schematic plans/ Drainage Patterns of facility drainage system
Invoices of disposal of vac-truck and sweeper waste
Statewide EPA Information Request
Copies of recent MS4 permits (2010-Present)
Construction activities Docs:
NOI, Lat/Long, Statewide map of all permitted activities, Urbanized areas/rural,
projects NPDES permits, documentation of commencement of construction activities,
violations during construction, NOT
All PENNDOT owned PCSM BMPs
Type of structure, date of completion, maintenance agreements with
CCD/municipalities, lat/long, statewide map showing locations, documentation of
PCSMs, estimated pollution reduction or TMDL requirements (N/A)
All PENNDOT Maintenance Facilities :
Lat/long, salt pile inventories, UA/rural, Inspection Reports
ISO 14001 Certification Compliance docs:
All audits/reviews, Notices of nonconformance, SEMP manual (guidance on SEMP/ISO
standard operations)
Annual cost for MS4 compliance:
All aping efforts, training received/given, and inspection costs
47. 11/7/2016
47
Internal audit/reviews During Post EPA
inspections: Distr. 5 and 6-01 offices
SEMP inspection checklists were routinely being pencil-whipped
Brine mixer units were full throughout the year, but lacked secondary containment
In permanent storage locations, oxygen cylinders were stored alongside acetylene or propane
tanks
Improper herbicides storage, e.g. without proper signage, security, or containment
Tack oil (E3 Oil) and other flammable ASTs were not electrically grounded
Salt sheds were filled beyond capacity, resulting in walls being pushed outward and salt
spilling onto unpaved surfaces
Waste drums were being stored beyond one year, due to problems with BOMO’s waste disposal
ITQ
Missing drum labelling and storage on secondary containment
MS4 permit-covered stormwater basin was overgrown and was not being maintained
MS4 permit-covered stockpile had stormwater from floor drains and yard drains piped directly
to surface water
In a stockpile, oil staining was found from an AST whose seepage had underflowed its
containment wall into the yard and a neighboring office. Worse, ISO 14001 internal audits,
SEMP Checklist inspections, and a BOMO QA inspection the month before had failed to note
this serious regulatory noncompliance.
Response Actions
ISO14001 EMS based compliance approach
PRP policy Updates: PENNDOT Pub 23-Maintenace manual
Storage facilities
Winter maintenance: Salt storage and applications
Vegetation & various roadside maintenance activities
Records retention requirements reminder to all District Executives
Documentation Documentation Documentation!
E-permitting tool-synchronous permitting between agencies
Maintenance IQ –Inspection requirements updates
GIS Database geotagging of facilities
Regional positions
MS4 specific Billing codes
Discussions
Winnie Okello
Sr. Civil Engineer Transportation
SEMP Section-SRP/MS4 Manager
Maintenance Technical Leadership Division
PA Department of Transportation
Bureau of Maintenance & Operations
400 North Street - 6th Floor | Harrisburg PA 17120
Phone: 717.214.8788 | Fax: 717.783.8012
wokello@pa.gov| www.dot.state.pa.us
Winter| Emergency & Incident Management|
Roadside, Environmental & Storm Water Management
48. 11/7/2016
48
MS4 Mid-Atlantic States Peer Exchange
Permit requirements and Issues
By: Winnie Okello
Sept 21, 2015
Permit Requirements
MCMs: See PDOT SW management Plan-clean draft
Public Education and Outreach on Stormwater Impacts
Public Involvement/Participation
Illicit Discharge Detection and Elimination (IDD&E)
Construction Site Stormwater Runoff control
PCSM in New and redevelopment Activities
Pollution Prevention/good Housekeeping for Municipal Operations
PRP: Pollutant Reduction Plan
Revise the anti-degradation policy; treatment of up to 10% of Existing Untreated impervious areas (UIA) in sediment impaired
watersheds, where practicable
Reduce UIA where practicable through new highway projects
Practicability will be documented via forms to be completed during design phase
Increased municipal coordination
TMDL: Chesapeake bay
New requirement for permit renewal
PENNDOT will address new discharge sources separately form existing discharges in Urbanized Areas
New Discharges (UA):addressed through DEP’s NPDES Permitting program
Existing Discharges (UA): DOT will develop and implement an MS4 TMDL plan to demonstrate consistency with any applicable WLA
Issues/Concerns
TMDL requirement:
DOT is not a significant source of nutrient loading to watershed!
‘System’ Mapping requirements:
PENNDOT currently has inlets and outlets/outfalls mapped, no connections specified due to data management
system setup
inlets/outlets and pipe sys are housed in diff systems. BMS, RMS, maintenance IQ/GIS.
OCC petitioned against this requirement only because of the massive undertaking that would be required if DOT
was to map ALL inlet, outlets, pipe connection and all downstream outfalls to waters of the commonwealth.
Emergency incident management is not a justification for extensive mapping request
DOT owned vs. municipality owned MS4 Systems: curb-to-curb policy
permitted facilities; BMPS/PCSMs, contributing areas...
Future Concerns:
Anticipating addressing non-urbanized areas with illicit discharges and stream erosion concerns
Salt contamination regulations in the horizon?!
Permitting terms Negotiations: Good Chief Counsel representation helps a lot!
Discussions
Winnie Okello
Sr. Civil Engineer Transportation
SEMP Section-SRP/MS4 Manager
Maintenance Technical Leadership Division
PA Department of Transportation
Bureau of Maintenance & Operations
400 North Street - 6th Floor | Harrisburg PA 17120
Phone: 717.214.8788 | Fax: 717.783.8012
wokello@pa.gov| www.dot.state.pa.us
Winter| Emergency & Incident Management|
Roadside, Environmental & Storm Water Management
49. 11/7/2016
49
Stormwater Management Triggers
• ¼ acre of new net impervious
• Triggers Quality, Quantity, Recharge
• Curbing roadway that was umbrella drainage counts as new
impervious
• 1 acre of ground disturbance
• Triggers Quantity and Recharge
• Roadway reconstruction only counts as disturbance if the entire pavement
box is removed
Who Reviews Stormwater Management
• If permits are needed from NJDEP Land Use Regulation Program,
NJDEP reviews stormwater
• If no permits are needed from NJDEP LURP then NJDOT can self
certify SWM
• If Pinelands permit is needed, Pinelands Commission reviews SWM
• Different triggers than NJDEP (5,000 sf disturbance outside limits of existing
infrastructure)
• Delaware & Raritan Canal Commission also can review SWM
• In some situations Counties or Municipalities can review SWM
Water Quality
• 80% Total Suspended Solids (TSS) removal for new impervious surface
• 50% TSS removal for reconstructed impervious surface
• 95% TSS removal for discharge to C‐1 water
• C‐1 specifies waterways of high environmental
quality/importance
• Usually associated with trout production/maintenance
• Can be averaged over entire site
• X(0.8) + y(0.5) = Required Treatment
• X= area of new impervious
• Y = area of reconstructed impervious
• A(%removal) + B(%removal) = Provided Treatment
• A = area going to BMP 1
• B= area going to BMP 2
BMP TSS Removal Rates
50. 11/7/2016
50
Groundwater Recharge
• Recharge same amount as pre development condition
• Recharge difference between pre and post development run off
quantity for the 2 year storm
• Calculate using NJGRS Spread Sheet
• Project is exempt if:
• In PA‐1 Area (Urban)
• Contaminated Soils
• Clay Soils
• High water table
Calculating Required Recharge
• NJGRS Spread Sheet Page 1
• Select municipality
• Enter area in acres
• Enter Land Cover
• Enter soil type
• Repeat for post development
Calc. Recharge Continued
• NGJRS page 2 calculates BMP
size to provide treatment
calculated on page 1
Water Quantity
• Must show that one of the following is true
• Post construction hydrographs for water leaving the site doesn’t exceed pre
construction hydrograph (2, 10, 100 year storms)
• No increase in peak runoff rates of stormwater leaving site between pre and
post construction hydrologic & hydraulic analysis (2,10,100 year storms)
• Post construction runoff rates for the 2, 10, and 100 year storm events are
50%, 75%, and 80%, respectively of pre construction runoff rates
• Project exempt if
• In tidal area
