Evolution of MnDOT Metro’s MS4 Erosion/Sediment Construction Oversight Program

1. Evolution of MnDOT Metro’s MS4 Erosion/Sediment Construction Oversight Program Barb Loida, Carolyn Adamson, Dave Bauer MECA 2014

2. MS4 = Municipal Separate Storm Sewer System ?

3. Means • Permit with MPCA to discharge stormwater from our R/W • “Our R/W”: lanes, shoulders, medians, vegetated areas, truck stations, building sites (Waters Edge), construction sites, storage yards • Have to comply with all the requirements in the permit which is updated every 5 years • We have a SWPPP for “our R/W”

5. 6 Minimum Control Measures MCM 1 – Public Education MCM 2 – Public Participation MCM 3 – Illicit Discharge Detection Elimination MCM 4 – Construction MCM 5 – Post Construction MCM 6 – Good Housekeeping

6. 2006

7. 2006 MS4 Permit MCM 4 Required • Ordinance or Other Regulatory Mechanism. • Construction site operators to implement BMPs • Control of construction site materials/waste that could impact water quality. • Procedures site plan review water quality impacts • Procedure to receive and consider non-compliance reports by public. • Procedures site inspection and enforcement of BMPs.

8. What we developed: • Oversight inspections by MnDOT Central Office staff. • Started annual training for each Metro Construction Office. • Developed database for tracking projects had a SWPPP or drainage work. • Also tracking NOTs and requesting as-builts. • Each year asked construction # public complaints on erosion/sediment control.

9. Wasn’t Enough • Recognition that we needed to hire someone within the Metro District to focus on oversight inspections due to # projects within District.

10. 2009

11. What we developed: • Joint inspections with MnDOT Central Office staff. • Developed and tried inspection checklist. • Expanded annual training to focus on erosion/sediment control and illicit discharge training. • Developed standard SWPPP template.

12. 2010 – EPA Audit

13. This was a Big Deal • Focused both on our Maintenance and Construction activities. • 1st DOT in EPA Region V to get audited. • Here 3 days. • Full access to personnel and sites. • Asked for a lot (mean a lot) of information.

14. Evolved:

15. What changed: • Formal policy for Metro oversight inspections. • Starting more training on erosion/sediment controls with Maintenance and Permit staff. • Another version of construction training. • Began feedback loop to improve constructability of projects. • Developed inspection report forms.

17. Still not enough: • Recognition we needed more human resources focused on erosion/sediment oversight inspections.

18. 2012

19. What Changed: • Moved to electronic documentation using iPAD. • Metro WRE is lead oversight inspector on most Metro District projects. • Tracking projects that have a SWPPP, drainage work, or need more looking after. • Inspecting State Aid projects not just MnDOT Metro projects • Better site analysis for infiltration areas.

21. Improved site investigation (gold) and construction (red) of infiltration.

22. Improved Site Investigation Look for signs of seasonally high water table Note compacted soils Explain context of infiltration investigation so that interpretations can be made in the field.

23. Improved Construction Prevent sediment from reaching infiltration Areas Keeping equipment off infiltration areas Explain context of infiltration areas

24. Where we are at today • Have mature program • Revised specifications • Policies for MS4 needs

25. Most Importantly – w/Metro Construction Staff “Please come out and help me”

26. w/Outside Parties • More trust with outside agencies that on our construction projects we are doing the right thing. • Consistent contacts for outside parties. • Reduction in enforcement actions.

27. Questions Hampton Infiltration Basins September June