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From page 34... ...
Colorado Department of Transportation Colorado DOT has a unique approach to construction stormwater program management. A statewide municipal separate storm sewer system (MS4)
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From page 35... ...
Of the seven MS4 programs, the Construction Sites MS4 Permit program focuses on construction stormwater management. The MS4 Construction Program Manual (Colorado DOT, 2023)
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From page 36... ...
In addition, Colorado DOT has revised its regulatory authority to be practice-based so that the contractors are more proactive in complying with the SCP require ments. The regulatory mechanism approach has pushed the contractors who work with Colorado DOT to be more proactive in their construction stormwater management.
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From page 37... ...
The QA/QC teams perform inspections along with the project and MS4 inspections. Colorado DOT is also considering a program to qualify consultants as project compliance administrators so that, in addition to Colorado DOT personnel, consultants can oversee more aspects of construction stormwater management.
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From page 38... ...
In addition, the plan addresses the following factors when applicable to a highway construction project: • Unstable stream reaches and flood mark • Watershed areas • Stream crossings • Access routes for construction • Access for maintenance of temporary and permanent erosion controls • Borrow and waste disposal areas • Critical natural and constructed slopes, soil types, eroding areas, rock outcroppings, and seep age zones • Requirements imposed by adjacent landowners and stewards • Construction dewatering methods and locations • Detours • Concrete washout methods and locations • Fuel storage areas • Methods of limiting off-site soil tracking All projects that include 1 acre or more of soil disturbances require a site-specific storm water management plan. The Colorado DOT requires plan designers to obtain and maintain Table 4. Information needed for Colorado DOT's SWMP (Colorado DOT, 2023)
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From page 39... ...
Generally, the Colorado DOT water quality specifications state the control measures that can be used across the state for highway construction. Specifications 208 and 216 define the control measures that can be used, which include the following: • Erosion bales • Silt fence (used regularly)
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From page 40... ...
Training Colorado DOT requires that the contractor employ a trained and certified Stormwater Management Plan Administrator. This administrator must possess working knowledge of and experience in construction stormwater management and hold a current Transportation Erosion Control Supervisor (TECS)
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From page 41... ...
Experiences and Findings Sharing the experiences of Colorado DOT staff involved with construction stormwater program management helps other DOTs with their construction stormwater management program and associated processes and procedures for managing, tracking, monitoring, and reporting compliance with permit requirements. The findings from Colorado DOT include the following: • Proactive specifications for stormwater management: Colorado DOT's Specifications 107.25, 208, 213, and 216 provide that, if contractors perform work according to the contract, they are in compliance with the contract.
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From page 42... ...
The overall purpose of the Manual is to build a level of consistency in technical expertise and professional conduct to ensure the desired benefits of the construction stormwater management program are achieved. Beyond the Manual and guides available, each of the districts within Florida DOT has its own processes for monitoring and tracking construction stormwater management.
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From page 43... ...
Clearly stating roles and responsibilities helps improve consistency in the Florida DOT construction stormwater management program. Inspections of installed BMPs and control measures on construction projects occur every 7 days according to the NPDES CGP or within 24 hours of a storm event.
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From page 44... ...
Florida DOT provides the estimated quantities of BMPs to install and maintain on any highway construction project so that all contractors bid on the same items for stormwater management during procurement. Best Management Practices The Manual includes a variety of erosion control methods, sediment containment systems, and temporary construction site BMPs.
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From page 45... ...
MS4 audits tend to be more focused but are not conducted often; therefore, Florida DOT does not spend much time preparing for them other than using internal audits to check and improve processes. Experiences and Findings Sharing the experiences of Florida DOT staff involved with construction stormwater program management helps other DOTs with their construction stormwater management program and
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From page 46... ...
Figure 22. Staked turbidity barrier installation at Florida DOT.
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From page 47... ...
Each of the 13 Resident Engineer Offices across the six districts of Iowa DOT administers the construction stormwater management program and compliance during construction. The resident construction engineer manages the permit requirements with assistance from project inspectors who perform the inspections and audits of the practices and control measures used during construction to determine compliance with permit requirements.
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From page 48... ...
This order resulted from multiple inspections and audits of various Iowa DOT highway construction projects over several years. The outcome of the order was a penalty assessed to Iowa DOT, which therefore had to implement changes to its construction stormwater management program.
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From page 49... ...
Figure 23. Iowa DOT weekly construction stormwater site inspection form.
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From page 50... ...
Figure 24. Iowa DOT non-compliance notice form.
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From page 51... ...
One of the challenges mentioned by Iowa DOT personnel was the lack of staff available for planning, designing, developing, overseeing, and inspecting its construction stormwater management program. Iowa DOT has lost experienced staff over the years and is replacing them with less experienced individuals or not replacing them at all.
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From page 52... ...
Chapter 10 of the Iowa DOT Design Manual -- Roadside Development and Erosion Control -- includes three sections: 10A) topsoil; 10B)
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From page 53... ...
Training is important for improving compliance, infusing consistency into processes, and implementing construction stormwater management successfully. Therefore, Iowa DOT has an Erosion and Sediment Control Training and Certification Program.
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From page 54... ...
Each has improved stormwater permit compliance. New York State Department of Transportation New York State DOT has a construction stormwater program as part of project management for highway projects.
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From page 55... ...
As mentioned by New York State DOT personnel, deficiencies are addressed quickly. They are typically not a major issue for highway construction projects at New York State DOT.
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From page 56... ...
56 Construction Stormwater Program Management, Tracking, Reporting, and Compliance Figure 26. SPDES permit certification form.
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From page 57... ...
New York State DOT has the authority to use flocculants for stormwater management; however, these are rarely used due to the maintenance needed to check and refill the chemicals and change filters at BMP locations. In most cases, flocculants are considered a last-resort BMP for New York State DOT construction stormwater management.
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From page 58... ...
58 Construction Stormwater Program Management, Tracking, Reporting, and Compliance Figure 27. New York State DOT SWPPP construction revision form.
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From page 59... ...
New York State DOT and New York State DEC perform the inspection audits to determine what can be improved. Experiences and Findings Sharing the experiences of New York State DOT staff involved with construction stormwater program management helps other DOTs with their construction stormwater management program and associated processes and procedures for managing, tracking, monitoring, and reporting compliance with permit requirements.
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From page 60... ...
Information is updated every 3 months. In relation to the consent agreement from the EPA, PennDOT staff mentioned that they have revised the construction stormwater management program based on EPA requirements, which
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From page 61... ...
The VSIR application is used in the field to track and monitor construction stormwater management and associated control measures. PennDOT developed a VSIR user's manual in 2021 for correct use of the application.
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From page 62... ...
Construction stormwater management is a more formal process for PennDOT;
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From page 63... ...
To overcome the challenges of involving various personnel, agencies, and districts in construction stormwater management for a highway project, PennDOT mentioned that consistent processes and definitions are vital so that stakeholders understand the approach and are on board with how stormwater will be managed during construction. Stormwater Pollution Prevention Plan In Pennsylvania, in lieu of an SWPPP, two stormwater management plans are normally required for highway construction projects.
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From page 64... ...
measures design, construction stormwater inspection, and PCSM design. Based on the consent agreement with the EPA and the establishment of the CMP, PennDOT developed its mandatory construction stormwater inspection training program for in-house and consultant inspectors.
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From page 65... ...
The Environmental Resource Management–Operations Compliance Section of the Environmental Affairs Division at the central office is a dedicated section within Texas DOT and has four full-time employees who dedicate their time to oversight, management, and compliance of construction stormwater, MS4, and facilities management programs. The 25 districts and the associated construction offices across the state manage stormwater and E&SC of a project during construction.
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From page 66... ...
By requiring the use of a new template, Texas DOT expects more consis tency in the information provided in the SWPPP, since it is organized similarly for all highway construction projects across all districts. One of the major tools Texas DOT uses for stormwater management is Form 2118–Construction SWPPP Field Inspection and Maintenance Report, provided in Appendix K
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From page 67... ...
Benefits and Challenges Benefits mentioned by Texas DOT personnel include fewer CGP and MS4 violations and deficiencies, along with cleaner water protected from sediment, chemicals, and other pollutants found at construction sites that can harm surrounding receiving waters, habitats, and wetlands. Proper construction stormwater management provides better flood control and less liability for the traveling public.
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From page 68... ...
The SWPPP for highway construction projects outlines erosion control, sediment control, and BMPs that can be used to control those pollutants during construction. The SWPPP at Texas DOT is prepared at the district level.
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From page 69... ...
EPIC are typically used during construction when required by the NEPA process rather than for stormwater management. EPIC BMPs used on Texas DOT construction projects include the following: • Amphibian and reptile exclusion fence • Preservation of existing vegetation • Tree protection • Vegetation filter strips and buffers • Dewatering controls Texas DOT has no policy for using flocculants as a BMP for E&SC.
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From page 70... ...
Experiences and Findings Sharing the experiences of Texas DOT staff involved with construction stormwater program management helps other DOTs with their construction stormwater management program and
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From page 71... ...
Summary of Case Examples The six case examples provided in-depth information about the state of the practice related to state DOT construction stormwater management programs. Each of the state DOTs was asked to discuss the approaches and processes used for construction stormwater management, including the following: • Obtaining required permits and ensuring compliance with permit requirements • Benefits and challenges experienced by state DOTs when managing construction stormwater runoff • Preparing and managing SWPPPs, BMPs, and control measures • Training for construction stormwater management including BMP installation and inspection training • Internal and regulator audits • Experiences and findings helping state DOTs with their construction stormwater manage ment program Table 5 outlines similarities and differences found in the six state DOTs related to their approach to permitting, E&SC, site plan, and the state regulatory agency that administers the permit and provides regulatory audits of construction sites.
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From page 72... ...
Table 6. Construction stormwater management training programs of state DOTs in case examples. DOT Training Program • Transportation Erosion Control Supervisor (TECS)
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From page 73... ...
• Having enough resources helps for full execution of the construction stormwater management program. Iowa • The Erosion and Sediment Control Training and Certification Program helps reduce deficiencies and improve consistency.
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