“Together...Better Roads, Cleaner Streams” MDOT Illicit Discharge Elimination Program Our...

“Together . . .Better Roads, Cleaner Streams”

MDOT Illicit Discharge Elimination Program

Our Cleaner Streams Mascot

Today’s Goals

To Understand: Which discharges are illicit (and

which are not) Where and when illicit discharges

may be encountered How to handle a reported illicit

discharge Who is responsible for various

tasks How to use the Reporting Database Annual reporting responsibilities Staff training

Agenda

MDOT Phase II Storm Water Program Overview

Illicit Discharge Reporting Training Module IDEP Screening Update Summary

ICE BREAKER!

Is water from a Commercial Car Wash facility an illicit discharge?

A. Yes, Always

B. Sometimes, only when polluted

C. No, never

Which one of the following best represents a Municipal Separate

Storm Sewer System?

A. A bridge scupper drain

B. A residential sump pump drain

C. A septic system cheater pipe

Is MDOT required to conduct an IDEP program?

YES

NO

What are the proper actions of notification of an illicit discharge?

A. Do nothing, someone else will take care of it

B. Send an email to “DOT the Drop”

C. Notify the MDEQ, the MDOT storm water coordinator, and other proper authority

Which one of these is considered a permittable “point source discharge”

(click on the correct photo)

GREAT JOB!!

Agenda



MDOT Phase II Permit

Effective April 1, 2004 – April 1, 2009 Provides Statewide Coverage Authorizes Storm Water Discharges from MDOT

Facilities Six Minimum Measures Storm Water Management Plan (SWMP) Annual Reporting

Program Components ProjectApproach

PostConstruction

PollutionPrevention/

Good Housekeeping

PublicInvolvement

Public Education

Illicit DischargeElimination

Program

Construction(SESC)

Assessment and Reporting

MDOT Activities for IDEP Component

Dry Weather Outfall Screening Mapping Outfall Labeling Education and Training Activities Illicit Discharge Reporting Program Follow-up on Illicit Discharges Legal Authority

Illicit DischargeElimination Program

What is IDEP?

I = Illicit – Wrong, illegal, needs correction

D = Discharge – Someone may swim in it

E = Elimination – Let’s get rid of it

P = Plan/Program/Project – Solutions

Illicit Discharge: “The discharge of pollutants or non-storm water materials to storm water drainage systems via overland flow, or direct dumping of materials into a catch basin.”

Definition – Illicit Discharge

Definition – Illicit Connection

Physical connection to the drainage system that: Primarily conveys illicit discharges

into the drainage system and/or Is not authorized or permitted by

MDOT (where MDOT requires such authorization or permit)

Source: MDEQ Permit No. MI0057364

Definition - Point Source Discharge (PSD)

“An outfall from a drainage system to waters of the state, or a point where a storm water drainage system discharges into a system operated by another public body.”

Includes: The Great Lakes and

their connecting waters All inland lakes Rivers Streams Impoundments Open drains Other surface bodies of

water within the confines of the state

What are Waters of the State?

Does Not Include: Drainage Ways and

ponds used solely for wastewater conveyance, treatment, or control

Acceptable Non-Storm Water Discharges

Rising groundwaters Uncontaminated groundwater infiltration

(40 CFR 35.2005(20)) Pumped groundwaters (except for

groundwater cleanups not specifically authorized by NPDES permits)

Source MDEQ Permit No. MI0057364

Diverted stream flows Flows from riparian habitats and wetlands Springs Emergency fire fighting activities (unless

identified as significant sources of pollutants)



continued


Foundation drains Water from crawl space

pumps Footing drains and basement

sump pumps Air conditioning condensates Water line flushing

continued


Landscape irrigation runoff Irrigation waters Lawn watering runoff Residual street wash waters


continued



Discharges from potable water sources Waters from non-commercial car

washing Residential swimming pool waters and

other permitted, dechlorinated swimming pool waters without untreated filter backwash

continued


Agenda



IDEP Discoveries

MDOT Staff who find illicit discharges Maintenance

Construction

Survey

Tasks associated with finding illicit discharges Ditch clean-out

Mowing

Pesticide

Survey

Construction

Legal Authority to Remove Permit Requirements

MDOT shall possess legal authority statewide to prohibit discharges into drainage system

Current Authority Section 9.13 Construction Permit Manual

Methodology Notice and Order to Remove Encroachment Multiple notices of violation

Stay Tuned – Judy will be discussing after lunch

Illicit Discharge Tracking Procedure

Is it an emergenc

y?

No

Notify MDEQ, Local Authority, and

MDOT Storm Water Program Manager

Call 911 or PEAS hotline: 1-800-292-4706

Notify Supervisor or Region IDEP Coordinator

Notify Supervisor or Region IDEP Coordinator

DiscussionMDOT and Tetra Tech;

MDOT

Tetra Tech

Illicit Discharge Suspected

Record Information

Yes

Preliminary

Verification

STOPNo

Further Action

Necessary

No Problem

ProblemSuspected

LegendResponsible Parties

= Initial Reporter = IDEP Region Coordinator

(Continued on next page)

Illicit Connection Removal Process

MDOT will correct

problem

YesNo

Notify MDEQ

Off ROW

?

Refer to Local Authority or proceed with letter notification

sequence as appropriate*

Confirm that problem was removed

Field Investigation to Identify

Source

STOPNo Further

Action Necessary

No Problem Found

Illicit Discharge Confirmed

LegendResponsible Parties

= IDEP Region Coordinator

* Refer to Figure 3-1 in MDOT’s Storm Water Management Plan for letter sequence

(Continued from Previous page)

MDOTTetra Tech

Stay Tuned – Judy will be discussing after lunch

MDEQ Notification Requirements Emergency Discharge:

Discharge that poses imminent danger to health or environment

– Tanker accidents, pipeline breaks, and releases of hazardous substances, oil, salt, or other polluting materials (defined by the Critical Materials Register) under state law.

Verbal Notification to MDEQ within 24 hours Make every attempt to notify a live person at the applicable

MDEQ District Office including pressing “0” for the MDEQ operator

After Hours Call PEAS: 1-800-292-4706 Part I Section C.2.a

MDEQ Notification Requirements

Non-Emergency Discharge: Discharge that does not pose imminent danger to health or

environment Verbal or Written documentation to MDEQ within 5 days of

becoming aware of any reason or instance of non-compliance.

Part I Section C.2.c

All notification must include (if known): Name of regulated discharger Location of discharge and outfall Nature of pollutants Clean-up and recovery measures planned

continued

Untreated Sewage Discharge Notification

If untreated or partially treated sewage is discharged from drainage system...

Notify with 24 hours after discharge begins: MDEQ Local Health Dept. One or more daily

newspapers of general circulation

Compliance with Section 324.3112a of Michigan Act

Part I Section C.2.d

Complaint Tracking Database

Discharge tracking component Microsoft Access Database Housed on server at each MDOT Region Office Mandatory use of Reporting Database

admin

admin

Login ScreenAdministrators, Region IDEP Coordinators: To login for the first time, use the following format for your user name and password.

oUser Name: first.lastoPassword: first.last

Example: Judy RuszkowskioUser Name: judy.ruszkowskioPassword: judy.ruszkowski

Then, go to User Management to create a specific account for you. You may do this same procedure to create an account for all users.

Users: To login for the first time, use the login user name and password assigned to you from an Administrator, (Region IDEP Coordinator). Only the Administrator can change your password.

New Complaint: If you are entering information for the first time about a new reported illicit discharge or connection, use New Complaint.

Existing Complaint: If you are referencing or editing an existing complaint, use Existing Complaint.

Report: If you are creating a report of existing illicit discharge issues in your region, Report will allow you to customize the information included in the report.

Logout: Use logout to exit the database.

User Management: To create a new user account, or to manage the functions each user can perform, User Management will allow you to add and edit user accounts. Only an administrator will see this button.

Administrator Only

Initial ComplaintThis page is where you will enter the information received about an illicit discharge via telephone or field staff reporting. A paper form exists to fill out when not logged in to the database.

The sections with an *asterisk are required fields. The information entered into the top portion of the screen will be automatically copied into subsequent screens related to this complaint.

Once you select a Region, only the Counties contained in that region will be listed in the pull down menu.

Once a County is selected, only the Control Section Numbers in that County will be listed in the pull down menu. Once a Control Section Number is identified, only the Routes contained in that Control Section will be listed in the pull down menu.

Be sure to save before exiting this page.

The buttons at the bottom of the screen will open additional forms to be filled out or edited in relation to this complaint.

Existing ComplaintThis page is where you will select an existing complaint to reference or edit.

You may search for an existing record by:

Complaint Number Region County Control Section Route Date Or selecting from the Complaint List

Once you have highlighted a complaint number, select Go to Existing Complaint Menu

Return to Main Menu takes you back to the main option menu.

Initial Complaint: If you want to reference the initial complaint made, use Initial Complaint.

Initial Investigation: If you want to reference, or enter a new site investigation, use Initial Investigation.

Follow-up Investigation: If you want to reference, or enter a new follow-up investigation, Follow-up Investigation will allow you to view or enter the information.

Communication: If information has been exchanged, external or internal to MDOT regarding this complaint, use Communication.

Completion: Use this if the reported illicit discharge issue has been resolved.

Information can be edited and saved in all pages related to an existing complaint, with the exception of automated text that is linked to the Initial Complaint page. This automated information can only be changed in the Initial complaint page.

Administrator Only

Communication TrackingIf information has been exchanged, external or internal to MDOT regarding this complaint, use Communication.

The sections with an *asterisk are required fields.

Files may also be attached to this complaint such as letters, or emails in any format. To attach a file, click Save this Communication and Attach Files. You will be prompted to browse and upload a file. To retrieve an uploaded file, use the scroll buttons and click Download. Then, indicate where you would like it to be saved.

Be sure to save the data before exiting.

This area will fill in automatically from initial complaint data.

InvestigationThis form needs to be filled out when a crew completes a site investigation of the reported illicit discharge. A paper form exists for the crew to fill out in the field.

This form applies to both an initial site investigation and a follow-up investigation.




Investigation continues on next page.



Investigation (continued from previous page)This form needs to be filled out when a crew completes a site investigation of the reported illicit discharge. A paper form exists for the crew to fill out in the field.

This form applies to both an initial site investigation and a follow-up investigation.





CompletionThis form needs to be filled out when an illicit connection or discharge issue has ceased or has been referred to another entity and MDOT is no longer responsible.

Do not complete this form until the illicit connection or discharge removal is confirmed by a site visit or follow up investigation.




ReportThis page will allow you to generate three different report types. 1. Complaint Summary – list of complaints with brief description of each.2. Detailed Complaint Report – a detailed report of a single complaint.3. Progress Summary – A numerical tally of complaints by Region.

You may search for a complaint record by: Date Region County Control section Route By selecting a complaint number in the list Complaint status

The reports will assist in obtaining the necessary information for the MDOT storm water permit annual report.

The Complaint Summary lists each complaint and pertinent information, such as the location of the discharge, nature of the problem and the status.

This report page opens as a separate window in the database. You can close this window without closing the entire database by clicking the “X” in the top corner.

The Detailed Complaint Report gives a detailed report of a single complaint including information about the problem, and subsequent investigations.


The Progress Summary Report is a numerical report which tallies the number of complaints per Region. It also indicates the percent of resolved issues.


User ManagementThis page will allow you to create or edit user accounts.

You may edit user information by scrolling to the specific user, making changes and clicking Save Record.

To add a new user, click Add Another User then fill in the correct information, and click Save Record.

To specify functions each user may have access to, click on the Yes box next to the desired function.

If the box contains a check mark, the user has access to that management function.

If the box does not contain a check mark, the user does not have access to that management function.

Administrator Only

Database upload.

Scenario information is located in the tab labeled “Reporting

Database”.

Scenario 1: Reported oil sheen on river from MDOT outfall

Information to Record

Be as specific as possible! Where

Control Section # 70014, along north bound US-31, 1000 feet north of BR-196 and US-31 interchange (Holland)

What Oil sheen (possibly gasoline or fuel oil), spread 10 ft.

radius from outfall pipe When – (Observation Info.)

February 15, 2006 at 10:00 am Who (Complaint and source, if known)

Complaint is anonymous, source of discharge is unknown

Investigation

The reported problem is located within the MDOT Right-of-Way (along US-31 in Holland)

Action: MDOT sends a crew to investigate, confirm and take additional notes and photos.

Observations: Crew investigates oil sheen and finds an illicit discharge from an oil change facility. Source location is confirmed to be outside of MDOT ROW.

Notification

Notification: The MDEQ District Office is notified within 5 days of MDOT becoming aware of non-compliance.

Corrective Action: MDOT sends a letter to the oil change facility landowner to remove discharge from MDOT drainage system. Landowner must provide documentation of corrective

actions to remove discharge. Use letters in Section 9.13 of Construction Permit

Manual. Completion: The connection was removed by the

landowner on April 1, 2006. Field staff re-investigated to confirm removal on April 5, 2006.

Example Sheens

www.riverkeeper.org

Scenario 2: Spill discharging to MDOT drainage system



Catch basin along M-99, 100 feet south of I-496 bridge (Lansing)

What Fluorescent green liquid

When – (Observation Info.) March 15, 2006 at 5 pm

Who (Complaint and source, if known) Complaint is Joe Smith, source of discharge is

from restaurant

Investigation

The reported problem is located within the MDOT Right-of-Way (along M-99 in Lansing)


Observations: Crew investigates green liquid and finds an illicit discharge from a “Yummy Food” restaurant. The liquid is a biodegradable, non-toxic, cleaning agent. Source location is confirmed to be outside of MDOT ROW.

Notification

Notification: MDEQ is notified within 5 days of MDOT becoming aware of non-compliance.

Corrective Action: MDOT sends a letter to the “Yummy Food” restaurant to discontinue dumping cleaning agents down storm drains. MDOT sends a reminder that cleaning agents are not

acceptable discharges. Use letters in Section 9.13 of Construction Permit

Manual.

Completion: The landowner received the letter and will begin acceptable discharge compliance.

Example Spills

USFWS.gov

Scenario 3: Highly

turbid water discharging from outfall

What Information do I need?


Discharging from Construction site along M-43 in Lansing, 1000 feet east of BR-96 and M-43 intersection.

What Soil erosion from a construction site entrance

When – (Observation Info.) April 1, 2006 at 10:00am

Who (Complaint and source, if known) Complaint is anonymous, source is at an MDOT

Construction site.

Investigation – What actions?

The reported problem is located within the MDOT Right-of-Way (along M-43 in Lansing)

Action: MDOT sends a crew with a certified SESC operator to investigate, confirm, and take additional notes and photos.

Observations: Crew and SESC operator investigates soil erosion and finds an illicit discharge and no BMP’s in place on a construction site of 5-acres. Source location is confirmed to be located in MDOT ROW.

Notification – Who was notified?

Notification: The MDEQ District Office is notified within 5 days of MDOT becoming aware of non-compliance.

Corrective Action: MDOT begins correction at construction site, installing proper BMPs. An SESC operator will perform BMP monitoring to ensure BMP does not fail.

Completion: MDOT installs BMPs on April 14, 2006 and reports on progress to MDEQ according to permit.

Scenario 4: Septic

Cheater Pipe



Middle of woods along MDOT road ditch (Genesee County)

What Dry Weather Flow with sewage debris

When – (Observation Info.) May 9, 2005 at 12:30 pm

Who (Complaint and source, if known) Complaint is John Doe, source of discharge

unknown, no houses in near vicinity

Investigation

The reported problem is located within the MDOT Right-of-Way (drainage ditch in Genesee County)


Observations: Crew investigates raw sewage debris discharging from a 6” PVC pipe. Upstream land use is forest in range of sight. Further investigation confirms the pipe cuts through woods for 1000 feet and disappears at a residential property line. Source location is confirmed to be outside of MDOT ROW.

Notification

Notification: MDEQ, the Health Dept., and a newspaper are notified within 24 hours of MDOT becoming aware of non-compliance.

Corrective Action: MDOT sends a letter to the resident and corresponding municipality to remove septic cheater pipe from storm drainage ditch. Use letters in Section 9.13 of Construction Permit

Manual.

Completion: Resident removes pipe on June 30, 2005; municipality and MDOT field crew re-investigate to confirm removal on July 24, 2005.

Reports1. Complaint Summary – list of complaints with brief

description of each.

2. Detailed Complaint Report – a detailed report of a single complaint.

3. Progress Summary – A numerical tally of complaints by Region.

Database User Management

Accessible to database “Administrators” Create New User Assign User Functions

Cheater Pipes

Floatables

SESC Issues

Region IDEP Reporting

Frequency of submittal (quarterly or annual)

Forward to Tetra Tech by the first week in January (January 5, 2007)

Agenda



MDOT IDEP Training Module

Illicit Discharge Elimination Program Module Topics:

NPDES Storm Water Program Overview Permit Requirements Illicit Discharge Examples IDEP Reporting Program

Training for MDOT staff

Agenda



Dry Weather Screening Update

Dry Weather Screening 14 Urbanized Areas Investigated Statewide Road Stream Crossings with Impaired

Waterbodies Nearly 90% Complete Follow-up investigations require drainage maps

Remaining Work Starting back up May contact Region coordinator for assistance

IDEP Outfall Mapping Locations investigated during IDEP

Known Outfall Mapping

Permit Requirements Mechanism for

Mapping known outfalls statewide

Part I Section B.3.a Approach

Phase I Field Data Phase II Field Data Design Survey Data

Agenda



Here’s what you need to do Tracking Application

Install it Decide who’s going to use it and how USE IT Provide feedback as requested by Judy and Tt

Follow up on reported problems (ask for help if you need it)

Training Train maintenance, construction and survey

staff by the end of the year Provide feedback to Judy and Tt on who,

what, when, where and how Known Outfall Maps

Review and comments. No fieldwork necessary.

When you have questions . . .

Call Judy when you have... Problems with an illicit discharge (Judy will call Tt

as needed) General questions on the storm water program

Call Tetra Tech when you have... Problems with the database Results of reviewing the known outfall maps Questions about the training module

Thank you for your participation!

“Together...Better Roads, Cleaner Streams” MDOT Illicit Discharge Elimination Program Our...

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Transcript of “Together...Better Roads, Cleaner Streams” MDOT Illicit Discharge Elimination Program Our...