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Post-Construction BMPs Update Meeting. January 28, 2008 ODOT Central Office – Room 1C. Post-Construction BMPs. Introductions. Bill Ujvari, P.E. – Production Administrator, Central Office Production Mike Wawszkiewicz, P.E. – Hydraulic/Roadway Designer, Central Office Production.
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Post-Construction BMPs • Update Meeting January 28, 2008 ODOT Central Office – Room 1C
Post-Construction BMPs • Introductions • Bill Ujvari, P.E. – Production Administrator, Central Office Production • Mike Wawszkiewicz, P.E. – Hydraulic/Roadway Designer, Central Office Production Please feel free to ask questions during the presentations.
L&D Manual, Volume 2 Revisions • Revisions published January 18, 2008 • Today’s Topics • Implementation Plan – IOC (included in hand-outs) • Notable revisions to post-construction BMP Sections in the L&D Manual • Local-let and ODOT-let BMP • BMP Design Approach • BMP Submittals to Central Office • OEPA Notices of Violation • Training Needs
Implementation Plan –Projects Scoped after January 18, 2008 • Include post-construction BMP based on January 2008 L&D Manual, Vol. 2
Implementation Plan –Projects Scoped Prior to Jan. 18, 2008 Follow these steps: • Step 1 • Determine if post-construction BMP are needed based on January 2008 L&D Manual, Vol. 2 • If post-construction BMP needed, continue to Step 2 • If post-construction BMP are not needed, no further action needed
Implementation Plan –Projects Scoped Prior to Jan. 18, 2008 • Step 2 • Determine the answers to the following: • Has the project received Stage 1 plan approval prior to January 18, 2008? • If there was no Stage 1 submittal, has the project received Stage 3 plan approval prior to January 18, 2008? • Were the right-of-way tracings completed prior to January 18, 2008? • If “No” to all of the above, design BMPs according to the January 2008 L&D Volume 2 • If “Yes” to any of the above, continue to Step 3
Implementation Plan –Projects Scoped Prior to Jan. 18, 2008 • Step 3 • Is existing and/or proposed right-of-way available to incorporate post-construction BMPs meeting the January 2008 L&D Volume 2 BMP requirements for all or part of the project? • If “Yes”, incorporate BMPs according to the January 2008 L&D Volume 2 and continue to Step 4 • If “No”, continue to Step 4
Implementation Plan –Projects Scoped Prior to Jan. 18, 2008 • Step 4 • Based on BMPs incorporated within available existing and/or proposed right-of-way in Step 3, is the project 100% compliant with the January 2008 L&D Vol. 2? • If “Yes”, no further action needed • If “No”, continue to Step 5
Implementation Plan –Projects Scoped Prior to Jan. 18, 2008 • Step 5 • Document restrictions preventing full compliance with the January 2008 L&D Vol. 2. • Cost and Schedule Impacts • Percent of project treated with BMPs • Environmental and Right-of-way impacts • Other Impacts
Implementation Plan –Projects Scoped Prior to Jan. 18, 2008 • Step 5 cont. • Submit documentation to Central Office Production for coordination with Ohio EPA • Ohio EPA will consider each project with ODOT and determine possible options that will resolve non-compliant areas of a project • Global settlement • Mitigation within the same watershed
Notable changes in January 2008 edition of L&D Volume 2 • Stream Protection – 1105.2 • Bankfull culvert design method • “Water quantity”/”Stream Protection”
Notable changes in January 2008 edition of L&D Volume 2 • Notice of Intent (NOI) – 1112 • Projects with estimated contractor and Project Earth Disturbed Area (EDA) less than one acre do not require an NOI or post-construction BMP • Updated Figure 1112-1 (NOI Calculator)
Notable changes in January 2008 edition of L&D Volume 2 • Notice of Intent (NOI) – 1112 cont. • Example #1: Bridge replacement project with 0.5 acres of Project EDA and an estimated 0.2 acres of Contractor EDA • Add SS832 and Item 832 Erosion Control (each) to plans • SWPPP quantity is not needed • NOI is not needed
Notable changes in January 2008 edition of L&D Volume 2 • Notice of Intent (NOI) – 1112 cont. • Example #2: Bridge replacement project with 0.7 acres of Project EDA and an estimated 0.25 acres of Contractor EDA • Add SS832 and Item 832 Erosion Control (each) to plans • Based on site conditions, work type, etc., determine level of confidence with Contractor EDA estimate • If the Contractor EDA could reasonably exceed the estimate and result in the total EDA being greater than 1 acre • Provide a Project Site Plan, Item 832 SWPPP (Lump Sum), Item 832 Erosion Control (Each), and file the NOI
Notable changes in January 2008 edition of L&D Volume 2 • Notice of Intent (NOI) – 1112 cont. • Example #2 Variation: Bridge replacement projectwith 0.7 acres of Project EDA and an estimated 0.25 acres of Contractor EDA • It is determined that 0.25 is a reasonable estimate for Contractor EDA • However, the Contractor uses more area and the resulting EDA is greater than one acre. • What happens now? • SS 832 is being updated. The update will require the Contractor to file the NOI and obtain the Permit, if he cannot constrain his operations to what is shown on the title sheet.
Notable changes in January 2008 edition of L&D Volume 2 • Notice of Intent (NOI) – 1112 cont. • Routine Maintenance Activity list provided • Multiple part and non-contiguous projects • Non-contiguous projects separated by at least ¼ mile can be considered separate • Non-contiguous multiple part projects can be considered with respect to each part
Notable changes in January 2008 edition of L&D Volume 2 • Notice of Intent (NOI) – 1112 cont. • Watershed Specific Permits • Big Darby Creek and Olentangy River • Additional requirements • Groundwater • Riparian Setback • Temporary Sediment Basin Locations • Coordinate with Central Office Production
Notable changes in January 2008 edition of L&D Volume 2 • Post-Construction BMP – 1115 • Post-construction BMP requirements apply to ODOT and LPA projects • Redevelopment vs. New Development • Area within existing ODOT right-of-way is considered impervious for BMP calculations
Notable changes in January 2008 edition of L&D Volume 2 • Post-Construction BMP – 1115 cont. • Options for locating BMP based on treating 100% water quality for 20% of the Project EDA (redevelopment) • Water quantity treatment not required when less than 1 acre of new impervious area created
Notable changes in January 2008 edition of L&D Volume 2 • BMP Selection and Submittals – 1116 • Submittals to Central Office Production • Conceptual layout • Plan sheets with BMP located • Calculations/documentation • No treatment for areas with sheet flow off roadway and outside ODOT right-of-way
Notable changes in January 2008 edition of L&D Volume 2 • BMP Toolbox – 1117 • Exfiltration Trench • Updated Figure 1117-1 • Manufactured Systems • Not suitable for large trunk sewers • Depth limitations due to maintenance • Permit Reviews – Watch for use of manufactured systems on ODOT maintained roadways. Verify maintenance accessibility.
Notable changes in January 2008 edition of L&D Volume 2 • BMP Toolbox – 1117 cont. • Vegetated Biofilter • No conveyance ditch • No energy protection area • Bottom width determination (ignore rounding) • Use the entire contributing drainage area (No incremental treatment) • Maximum ditch bottom width of 10 feet • Updated Anti-Seep collar design requirements
Local-let and ODOT-let LPA Projects • ODOT-let LPA projects • ODOT files the NOI • ODOT should ensure post-construction BMP provided meeting Ohio EPA expectations • LPA should be made aware of BMP requirements and maintenance responsibilities
Local-let and ODOT-let LPA Projects • Local-let LPA projects • Local agency files the NOI • The LPA is responsible for providing post-construction BMP that meet Ohio EPA expectations (may use L&D Volume 2 or other EPA approved guidance) • ODOT’s global settlement negotiations do not apply to local-let LPA projects that cannot meet BMP requirements • The LPA must coordinate with Ohio EPA when deficiencies are identified
Local-let and ODOT-let LPA Projects • BMP Project Scenarios Document • This document should no longer be used as a guideline • Post-construction BMP apply to the entire project with the exception of privately owned property (non-municipal)
BMP Design Approach • Using Redevelopment/Treatment Percent reduction • New Construction Projects • Calculate treatment percent (T%) • Minimum T% is 20% • Redevelopment Projects • 20%
BMP Design Approach • BMP Design Options • Redevelopment projects • Provide 100% treatment for an area equal to 20% of the Project EDA • Provide 20% treatment for the entire project. • New construction projects • Provide 100% treatment for an area equal to T% of Project EDA • Provide T% treatment for the entire project.
BMP Design Approach • Vegetated Biofilters • The entire project does not require wider ditches • Water quality credit earned for drainage area within ODOT right-of-way • Once area credit equals or exceeds the 20% or T% requirement, no further treatment is needed
BMP Design Approach • Exfiltration Trenches (ExT) • Option #1 – Use 20% or T% of the required ExT length for the entire project • Requires all inlets, catch basins, etc. to provide an exfiltration trench or other BMP treatment
BMP Design Approach • Exfiltration Trenches (ExT) cont. • Option #2 – Use 100% of the calculated ExT length based on Section 1117.1 and provide treatment for ODOT R/W area that equals or exceeds 20% or T% of the Project EDA. • Allows the locations of BMP to be chosen when there are restrictions preventing BMPs at all inlets.
BMP Design Approach • Manufactured Systems • Option #1 – Calculate Water Quality Flow (WQf) and multiply the WQf by 20% or T%. • Entire contributing drainage area to the point in the storm sewer shall be used • Treat the entire project - Any project areas not tributary to this manufactured system must be drained to a BMP that will provide 20% or T% treatment
BMP Design Approach • Manufactured Systems • Option #2 – Calculate Water Quality Flow (WQf) • Entire contributing drainage area to the point in the storm sewer shall be used • Treat drainage area with a minimum area equal to 20% or T%, with no reduction in the calculated WQf. • Water quality credit only applies to area within ODOT R/W, but BMP must be sized for entire contributing drainage area
BMP Submittals • Section 1116.2 • Consideration of post-construction BMPs needs to happen early in the design process to allow for utilities and right-of-way issues to be addressed. • Early coordination with Ohio EPA will prevent fines, additional consultant costs, change orders and possible delays during construction.
BMP Submittals • Major Projects • Conceptual layout with Step 6 (AFA) – Required review and comment through C.O. Production • BMP Design with Step 8 (Stage 1) – Required review and comment through C.O. Production
BMP Submittals • Minor Projects • Conceptual layout with Step 3 (PE) – Optional review and comment through C.O. Production • BMP Design with Step 4 (Stage 1) – Required review and comment through C.O. Production
BMP Submittals • Contents of submittals at Stage 1 • Estimated Project EDA • Pre and Post Runoff Coefficient • Pre and Post Impervious Area • BMPs selected • Calculations for BMPs • Plan sheets showing location of BMPs • Explanation for areas that were not treated
BMP Submittals • Project Site Plan – Stage 3 • Post-construction BMPs should be addressed on the Project Site Plan • Graphics • Tables • Cross-references to specific sheets or details • Narrative, if needed
BMP Submittals • Projects that are not fully compliant • C.O. Production will discuss with the District and Consultant. • If necessary, a meeting with Ohio EPA will be held to determine whether additional mitigation is required.
Issues during Construction • What happens when Ohio EPA issues a Notice of Violation (NOV) that cites a post-construction deficiency? • District should determine if post-construction BMPs were incorporated into the plans • If post-construction BMPs are shown in the plans, District shall obtain the calculations • District shall determine whether the BMPs shown in the plans were designed according to the Jan. 2008 L&D Manual Vol. 2 • If deemed compliant, forward calculations to Ohio EPA • If deemed non-compliant, forward to C.O. Production for coordination with Ohio EPA
Post-Construction BMP Training • Training for Post-Construction BMPs • Districts • Need to take the lead in communicating changes with BMPs for plans actively in design • Districts should coordinate with Central Office for assistance on unique situations • Consultants • Submittals, reviews, and experience should identify any potential training needs • Future training may be needed, but minimum benefit now
Coming soon…. • Renewal of Construction General Permit • Draft version available for public comment • Anticipated that the Permit will be effective in April 2008 • Minor changes to post-construction • Draft Permit allows mitigation off-site (must be negotiated with Ohio EPA) • Covered by January 2008 L&D Vol. 2 updates
Coming soon…. • SS832 revision • Addressing changes to Construction General Permit and January 2008 L&D Volume 2 • Anticipated update in first half of 2008
Coming soon…. • L&D Volume 3 Update • Addressing changes to January 2008 L&D Volume 2 • Anticipated update in first half of 2008
Coming soon…. • Olentangy Watershed Permit • Final version yet to be completed by Ohio EPA • Anticipated that the Permit will be effective later in 2008 • Riparian Setback modifications • Temporary Sediment basins • Coordinate through Central Office Production