RIDOT

Municipal Separate Storm Sewer System – MS4

RIDOT DRAINAGE CREW AT DEVIL’S FOOT ROAD & POST ROAD, NORTH KINGSTOWN, RI

Annual Compliance Report No. 2 January 1 – December 31, 2016

P Cotter RIDOT

8/22/2016

P a g e | ii INTRODUCTION ............................................................................................................................................... 1

RIDOT RESOURCES ....................................................................................................................................... 2

COMPLIANCE REPORTING ........................................................................................................................... 3

§ 60.a. Identification Of All Plans, Reports And Other Submissions .................................................... 3

§ 60.b. Description of Proposed Changes ................................................................................................ 4

TMDL & IMPAIRED WATERS REMEDIAL MEASURES............................................................................ 5

§ 60.c. Actions to Address Impaired Water Body Segments................................................................. 5

§ 60.d. SCP Structural Control Status ........................................................................................................ 5

§ 60.e. Structural Control Construction Report ........................................................................................ 5

§ 60.f. Revised O&M Plans for Constructed Structural Controls .......................................................... 5

§ 60.g. Status of Design and Implementation of Storm water Control Projects .................................. 5

§ 60.h. Updated List of Storm Water Control Plans ................................................................................. 5

§ 60.i. O&M Activities Performed on Structural Storm Water Controls ................................................ 6

§ 60.j. Discharges to Newly Listed Impaired Water Body Segments ................................................... 6

ILLICIT DISCHARGE REMEDIAL MEASURES ........................................................................................... 7

§ 60.k. Wet and Dry Weather Screening of Discharge Points .............................................................. 7

§ 60.l. Other RIDOT Roadways where SCPs are not Required ........................................................... 7

§ 60.m. Results of RIDOT IDDE and Discharge Point Screenings ...................................................... 7

§ 60.n. Description of IDDE Investigations ............................................................................................... 7

§ 60.o. Appendix 9 Interconnections ......................................................................................................... 7

§ 60.p. List of IDDEs Investigations exceeding 180 Days ..................................................................... 8

§ 60.q. IDDE Complaints ............................................................................................................................. 8

§ 60.r. IDDE Verified .................................................................................................................................... 8

GOOD HOUSEKEEPING REMEDIAL MEASURES.................................................................................... 9

§ 60.s. Street Sweeping............................................................................................................................... 9

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§ 60.t. Catch Basin and Manhole Inspections........................................................................................ 10

§ 60.u. Outfall Inspections......................................................................................................................... 11

§ 60.v. CatchBasin/Manhole Cleaning – Reporting Year + 2 Year Outlook ..................................... 11

§ 60.w. CatchBasin/Manhole Repairs - Reporting Year + 2 Year Outlook ...................................... 12

§ 60.x. Closed Drainage System Component Cleaning and Repairs ................................................ 13

MISCELLANEOUS CONSENT DECREE.................................................................................................... 14

§ 60.y. Supplemental Environmental Projects Update ....................................................................... 14

§ 60.z. Identification of all Consent Decree Noncompliance ............................................................. 14

APPENDICES .................................................................................................................................................. 15

Rhode Island National Pollutant Discharge Elimination System

Municipal Separate Storm Sewer Systems

Annual Compliance Report No. 2 January 1 – December 31, 2016

INTRODUCTION The Rhode Island Department of Transportation (RIDOT) submits this Annual Compliance Report as required by the United States of America vs Rhode Island Department of Transportation Civil Action (No. CV-15-433) Consent Decree. This report focuses on the work performed by RIDOT between January 1, 2016 and December 31, 2016. The Consent Decree became effective on December 22, 2015, and details remedial measures in relation to the National Pollutant Discharge Elimination System (NPDES) Storm Water discharge from Small Municipal Separate Storm Sewer Systems and Industrial Activity at Eligible facilities Operated by Regulated Small MS4’s permit. The Consent Decree establishes Remedial Measures and schedules for three broad areas: 1.) TMDL and Impaired Waters, 2.) Illicit Discharge Detection and Elimination (IDDE), and 3.) Good Housekeeping. The Consent Decree also establishes the reporting requirements for the annual report, which will document the compliance efforts of the RIDOT each calendar year.

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RIDOT RESOURCES CY2016 Activities: In 2016, RIDOT created the Office of Stormwater Management and hired Brian Moore, PE as the Administrator. Over the course of six months, the staff of the Stormwater Office has grown to include a staff of 9 professionals. Two additional staff positions are anticipated to be filled early in 2017.

Administrator: Brian Moore, PE Managing Engineer: John Preiss, PE Deputy Chief Engineer: Frank Corrao, PE Project Manager: Joe Baker, PE Principal Environmental Scientist: Allison Hamel Senior Civil Engineer: Mike DeRotto, PE Senior Environmental Scientist: Heather Hamilton Engineering Technician I: Frank Perri Administrative Assistant: Faye McCray

The Stormwater Office also released two RFPs (request for proposals) to hire qualified consulting and engineering firms to assist RIDOT with compliance efforts towards the Consent Decree and for Drainage Infrastructure improvement projects. Eight firms are available for the on-call compliance contract; four firms for the on-call drainage contract. The Stormwater Offices has also established new policies and procedures for compliance efforts, and works with the Planning Division and the Program Management Division. The RIDOT Division of Highway and Bridge Maintenance created a new Drainage Crew in 2016 for compliance with the Consent Decree and in accordance with the RIDOT Compliance Plan. The Drainage Crew is staffed by a Superintendent, two foremen, and between 6 – 8 highway maintenance operators. This group is directly responsible for compliance efforts with the Consent Decree regarding the in-house drainage system cleaning and repairs. New equipment has been purchased and the group has been trained in Consent Decree awareness and IDDE identification.

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COMPLIANCE REPORTING The Consent Decree establishes the prescribed reporting requirements expected of RIDOT. This report will detail RIDOT's accomplishments during the reporting period, and where required, provide goals for the next reporting period. Each of the prescribed reporting requirements from the Consent Decree paragraph 60 are outlined below: § 60.A. IDENTIFICATION OF ALL PLANS, REPORTS AND OTHER SUBMISSIONS SUBMISSION # DATE CD

PARAGRAPH ITEM REQUIRES APPROVAL STATUS

1a 9/30/2015 VI.D.38. a. RIDOT road and parking lot inventory No Complete

1b 9/30/2015 VI.C.20.b. a list of all non-bituminous ditch outfalls with DWD No Complete

2 10/30/2015 VI.C.25.b schedule for initiating IDDE investigations for Appendix 8 Outfalls

YES EPA Conditional Approval 8/12/16

Complete

3 11/30/2015 VI.D.44.a.i

Complete design of the catch basin, manhole, outfall, and STU inspection and maintenance management system.

No Complete

4 12/30/2015 VI.C.29. revised IDDE Plan

YES EPA Conditional Approval 8/12/16

Received comments 4/15/16 Resubmitted 6/30/2016 Complete

5 1/5/2016 XIII.92 RIDOT Stormwater Management Website No Complete

6 1/6/2016 V.7, 8 Civil Penalty No Complete

7 3/10/2016 VIII Annual Compliance Report #1

No

Complete No Comments Received

8 3/30/2016 VI.D.20.b Desktop Analysis of non-bituminous ditch outfalls No Complete

9 3/31/2016 VI.D.37.a.i. RIDOT Street Sweeping Implementation No Complete

10 3/31/2016 VI.D.43.a. RIDOT Drainage Inventory No

No Comments Received

11 4/29/2016 VI.D.44.a.ii. RIDOT Catchbasin Implementation No

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SUBMISSION # DATE CD

PARAGRAPH ITEM REQUIRES APPROVAL STATUS

12 5/4/2016 Appendix 12 Land preservation proposed deeds and exhibits

YES EPA APPROVED 6/29/2016

Resubmitted 6/17/2016 Re-Resubmitted 6/27/2016 Complete

13 6/17/16 VI.E.50. Compliance Plan NO

No Comments Received

14 6/30/2016 VI.D.45 STU Inspection/Maintenance Schedule

NO

No Comments Received

15 6/30/2016 IV.C.22 & 23. Lower Woonasquatucket SCP IDDE Exemption Request

YES EPA Approved 8/12/16

Complete

16 8/1/2016 VIII.61 six-month IDDE Compliance Update

No

No Comments Received

17 8/19/2016 § VII & Appendix 12

RIDOT SEP Completion Reports

Yes EPA Approved 10/5/2016

Complete

18 9/29/2016 § XIV Update to XIV. FORM OF NOTICE - As to RIDOT No Complete

19 9/30/2016 § VI.C.25.c. Results of Appendix 9 Interconnection Review No Complete

20 11/30/2016 § VI.C.25.c Appendix 9 Schedule YES Awaiting approval

21 11/30/2016 § VI.C.20.a. Appendix 6 Dry Weather Sampling Results

No

22 a-e 12/30/2016 IV.B.18.c. SCP Plan #1 Lower Woonasquatucket YES Awaiting

Comments

§ 60.B. DESCRIPTION OF PROPOSED CHANGES RIDOT proposes to update Appendix 5 – Groupings of Impaired Water Body Segments of the Consent Decree to include 2015 listed impaired waterbodies (as described in § 60.j. of 2015 Annual Report) and to include Group Names and Waterbody Names. ATTACHMENT A – Updated_Appendix_5.xls

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TMDL & IMPAIRED WATERS REMEDIAL MEASURES

§ 60.C. ACTIONS TO ADDRESS IMPAIRED WATER BODY SEGMENTS CY 2016 Activities: RIDOT procured consultant services and completed the Lower Woonasquatucket (Group 4050210) Storm Water Control Plan per Consent Decree § VI.B.18.c. RIDOT solicited consultant services to begin the next set of Storm Water Control Plans per Consent Decree § VI.B.18.d. - Upper Woonasquatucket (Group 4050200), Roger Williams Park Ponds (Group 4060900A), and Warwick Ponds (Group 4090200). § 60.D. SCP STRUCTURAL CONTROL STATUS CY 2016 Activities: There are no approved SCPs at this time to report in accordance with the Consent Decree § 60.D. § 60.E. STRUCTURAL CONTROL CONSTRUCTION REPORT CY 2016 Activities: As part of RIDOT’s general program, RIDOT finalized 34 construction projects throughout the State in 2016. No new STUs came online in 2016. RIDOT did not complete any Retrofit projects in 2016. § 60.F. REVISED O&M PLANS FOR CONSTRUCTED STRUCTURAL CONTROLS CY 2016 Activities: No new structural treatment units became operational in 2016, therefore no new O&M Plans have been created. RIDOT, RIDEM, and URI NEMO agreed to focus 2017 NEMO efforts on development of O&M Template as part of the URI/DEM/DOT Stormwater Phase II Agreement. § 60.G. STATUS OF DESIGN AND IMPLEMENTATION OF STORM WATER CONTROL PROJECTS CY 2016 Activities: In 2015, RIDOT received a Narragansett Bay and Watershed Restoration Fund (BWRF) grant from RIDEM to install two structural controls in the Roger Williams Park area of Providence, RI that provides water quality treatment for an identified RIDEM Priority Outfall in the Eutrophic Ponds TMDL (2007). In 2016, RIDOT procured consultant services to begin the design and permitting of the two STUs. Design and permitting has started; construction may occur in 2017. § 60.H. UPDATED LIST OF STORM WATER CONTROL PLANS

Report #

Submission DATE

CD PARAGRAPH ITEM

Appendix 5 Group #

Status

1 12/30/2016 VI.D.38. c. Lower Woonasquatucket River Stormwater Control Plan 4050201 Awaiting EPA

Comment

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§ 60.I. O&M ACTIVITIES PERFORMED ON STRUCTURAL STORM WATER CONTROLS CY 2016 Activities: RIDOT completed an inventory and inspection of documented structural stormwater controls. The inventory continues to be updated. ATTACHMENT B – STU_Inspections_2016.xls § 60.J. DISCHARGES TO NEWLY LISTED IMPAIRED WATER BODY SEGMENTS

CY 2016 Activities: No activities to report; newly listed segments are part of SCP Groups that have not been developed yet (falling under § 60.j.i.)

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ILLICIT DISCHARGE REMEDIAL MEASURES

§ 60.K. WET AND DRY WEATHER SCREENING OF DISCHARGE POINTS CY 2016 Activities: RIDOT has conducted Wet & Dry Weather Screenings of discharge points (catch basins, manholes, outfalls) as part of the Inventory and Inspection contract documented in § 60.t. Catch Basin and Manhole Inspections. RIDOT is still analyzing data from the 2016 inventory and inspections, and will provide full documentation in the August IDDE report. RIDOT continues to adapt VueWorks for accurate documentation and easier reporting; a module and summary reports are under development. RIDOT Maintenance has conducted screenings as part of their cleaning and inspection work documented in § 60.V. Catchbasin/manhole cleaning. RIDOT is still analyzing data from the 2016 cleaning/inspections, and will provide full documentation in the August IDDE report. RIDOT also conducted Wet & Dry weather Screenings as part of the Lower Woonasquatucket SCP plan and as part of the High Priority Appendix 6 and Appendix 8 work. RIDOT has initiated detailed plan and field analysis of drainage systems and will provide full documentation in August IDDE report. § 60.L. OTHER RIDOT ROADWAYS WHERE SCPS ARE NOT REQUIRED CY 2016 Activities: RIDOT does not have any ‘other’ RIDOT roadways to report for CY 2016. § 60.M. RESULTS OF RIDOT IDDE AND DISCHARGE POINT SCREENINGS CY 2016 Activities: ATTACHMENT C - IDDE_SummaryResults.xls. § 60.N. DESCRIPTION OF IDDE INVESTIGATIONS RIDOT has completed detailed drainage plan review and conducted detailed field review for drainage systems where “Investigation Needed” memos were initiated by IDDE screenings. Starting March 13, 2017, RIDOT will finalize reviews and conduct field sampling as needed and will report full investigation details in the August IDDE report. RIDOT continues to adapt VueWorks for accurate documentation and easier reporting; a module and summary reports are under development. § 60.O. APPENDIX 9 INTERCONNECTIONS CY 2016 Activities: RIDOT completed plan review and field visits for the Appendix 9 interconnections in 2016. RIDOT submitted an Appendix 9 Interconnection Review on September 9, 2016 and an Appendix 9 Schedule on November 30, 2016 to EPA for their review and approval. RIDOT is also conducting interconnection and IDDE screening as part of the required Drainage System Inventory and Inspection that is to be completed by December 2017 (per § VI.D.47.a.).

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Specific to Appendix 9, each identified outfall / area has an SCP planned within the next 10 years (most of them within the next 3 years). During SCP development, further interconnection and IDDE screening will occur; dry/wet weather sampling will occur as appropriate. For those outfall / areas that have an SCP planned within the next 3 years, interconnection & IDDE screening will occur as part of SCP development. For those outfalls / areas outside of the 3-year SCP timeline, RIDOT will investigate the area for interconnections and IDDE Screening in 2017. § 60.P. LIST OF IDDES INVESTIGATIONS EXCEEDING 180 DAYS CY 2016 Activities: All IDDE Investigations started in accordance with the Consent Decree are still within 180 days from start date. § 60.Q. IDDE COMPLAINTS CY 2016 Activities: RIDEM SB02 (Scarborough Beach) – RIDOT has completed detailed plan review and field review of Scarborough beach drainage areas specified in the EPA Approval with Conditions of the RIDOT IDDE Plan on August 8, 2016. Field Sampling and Analysis is anticipated to be completed within the 180 day requirement. § 60.R. IDDE VERIFIED CY 2016 Activities: RIDOT did not discover any unauthorized connections that were deemed illicit discharges in CY 2016. Field Investigations are still underway for High Priority & Priority outfalls.

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GOOD HOUSEKEEPING REMEDIAL MEASURES § 60.S. STREET SWEEPING CY 2016 Activities: RIDOT collected 1.4 million GPS tracking points in 2016, yielding approximately 2,800 distinct sweeping tracks (truck#-Facility-Date). ATTACHMENT D - RIDOT Street Sweeping.xls Statewide Street Sweeping

Rhode Island Roadways 6900 miles

RIDOT Maintained Roadways 1500 miles 22% of all roadways

RIDOT Maintained Roadways in CD Area 1175 miles 78% of all RIDOT Roadways

RIDOT Maintained roadways with NO sweeping tracks (neither PTO On nor Off) 35 miles 2.3% of all RIDOT Roadways

RIDOT Maintained roadways with NO sweeping tracks in CD area (neither PTO On nor Off)

25 miles 2.1% of all RIDOT Roadways in CD area

RIDOT Maintained roadways with NO sweeping tracks with PTO ON (traveled road with PTO OFF)

70 miles 4.7% of all RIDOT Roadways

RIDOT Maintained roadways with NO sweeping tracks with PTO ON in CD area (traveled road with PTO OFF)

46 miles 3.9% of all RIDOT Roadways in CD area

*all values approximate

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RIDOT completed increased sweeping in the Appendix 11 Sweeping Areas. Appendix 11 – Increased Frequency Street Sweeping Areas

2016 Sweeping JAN

FEB

MAR

APR

MAY

JUN

JULY

AUG

SEP

OCT

NOV

DEC

Woonasquatucket River AOI X X X X X X X

Mashapaug Pond X X X X X X Indian Run Brook X X

Eut

roph

ic P

onds

Roger Williams Park Ponds X X X X X X Spectacle Pond X X X X X X Gorton Pond X X X Sand Pond X X X Warwick Pond X X X X X Almy Pond NO RIDOT ROADWAYS Brickyard Pond X X Upper Dam Pond X X

New

port

Wat

er S

uppl

y R

eser

voirs

Bailey's Brook X X X X X X Lawton Valley Reservoir X X Maidford River X X Nonquit Pond X X X X North Easton Pond X X X X Paradise Brook Saint Mary's Pond X X Sisson Pond NO RIDOT ROADWAYS Watson Reservoir X X X

§ 60.T. CATCH BASIN AND MANHOLE INSPECTIONS CY 2016 Activities: RIDOT used catch basins inspection numbers as a surrogate of total drainage system numbers for ease of tracking compliance as the total number of drainage assets was still unknown. Using (then) current data, RIDOT estimated 16,000 catch basins in the Consent Decree area. RIDOT prepared for the inspection of 8,000 catch basins and associated drainage structures (manholes, pipes, outfalls) to be completed by December 2016, as required by the Consent Decree VI.D.47.a. RIDOT completed this task with RIDOT Maintenance staff and with consultant services. The Drainage Crew completed inspections during field operations. Drainage Crew inspections include the operational condition, environmental condition, and proposed repair/maintenance needs for catch basins. The cleaning and inspection of catch basins was prioritized based on the Stormwater Control Plan areas (Lower Woonasquatucket, Roger Williams Park Ponds, Warwick Ponds, Upper Woonasquatucket) and Limited Access Roadways.

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RIDOT developed an ON-CALL TRANSPORTATION ENGINEERING SERVICES TASK ORDER WORK PROGRAM. This program includes two components for Stormwater Management:

• SWTR 001 Stormwater Management Services ‐ MS4 & EPA Consent Decree Compliance Support Services

• SWTR 002 Stormwater Management Services – Statewide Drainage Design Support Services. ATTACHMENT E - 7550214 OnCallTASKPGM2016 RIDOT hired consultants using the On-Call program to perform inventory and inspections of the RIDOT drainage system on non-limited access roadways. Consultant inspections include the collection of the attribute information, operational condition, environmental condition, and proposed repair/maintenance needs for each drainage asset (catch basins, pipes, manholes, conveyances, outfalls). Consultants also identified and added assets not yet in the inventory, which was significantly more than anticipated. All condition inspections have been documented in VUEWorks. VueWorks continues to be adapted for more accurate reporting as needs are realized. VueWorks also continues to be updated with new assets. RIDOT VueWorks documents 7,278 catch basins were inspected in 2016, which is shy of the 50% of the 16,000 estimate. RIDOT continues to work on data accuracy issues. It is now apparent that the 16,000 estimate was not accurate. One consultant inspected 4,400 catch basins; 1,900 of which were not identified in the asset database (43%). VueWorks now has approximately 25,000 catch basin assets in the system. RIDOT continues to assess the drainage asset inventory and inspection program, and will work towards completion by December 2017 using both consultant services and in-house staff. RIDOT has budgeted $2.2M for this task. § 60.U. OUTFALL INSPECTIONS CY 2016 Activities: RIDOT completed outfall inspections as part of the RIDOT Inventory and Inspection Consultant Contract. See § 60.T. § 60.V. CATCHBASIN/MANHOLE CLEANING – REPORTING YEAR + 2 YEAR OUTLOOK CY 2016 Activities – Maintenance Division: According to our Maintenance Division, RIDOT cleaned a total of 3,866 catch basins in 2016. Inspections have been documented VUEWorks, however, the accuracy still requires improvement, which is anticipated with better field equipment (issuance of iPad tablets for the Drainage Crew - deployed March 2017). CY 2016 Activities – Construction Division: During the reporting period, 34 Bridge, Pavement, and Traffic projects were finalized. Applicable projects included items to clean & flush catch basins, manholes, pipes and outfalls. ATTACHMENT F - 2016 Final Inspections.xls

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Structures cleaned in Construction: STRUCTURE CLEAN AND FLUSH: 943 units OUTFALL CLEAN: 28 SY DITCH CLEAN: 8,400 SY

Detailed information will be available in future reports via implementation of the VUEWorks system. RIDOT will continue to clean catch basins and manholes within the scope of the projects completed during the 2017 reporting period and as part of our Maintenance Division activities during that same period. 2 Year Outlook: With the implementation of a dedicated Drainage Crew in RIDOT Division of Highway and Bridge Maintenance, it is anticipated that meeting the Consent Decree requirements for cleaning structures on non-interstate and interstate roadways will be achieved. RIDOT will continue to document efforts in VueWorks and will work on improving accuracy to provide better analysis in 2017. RIDOT’s Office of Stormwater Management provides guidance to RIDOT’s Office of Project Management for Consent Decree requirements. A memo was delivered on October 31, 2016 for the inclusion of cleaning and inspection of drainage structures in infrastructure development program projects per § VI.D.46. ATTACHMENT G - 10312016_MemoToPM RIDOT has a list of 2017 Program Projects. Bridge, Traffic, and Maintenance Projects include clean and inspect drainage structures as applicable; all Pavement Projects include clean and inspect drainage structures as part of the project. ATTACHMENT H - 2017 Program.pdf § 60.W. CATCHBASIN/MANHOLE REPAIRS - REPORTING YEAR + 2 YEAR OUTLOOK CY 2016 Activities – Maintenance Division: Detailed information will be available in future reports via configuration of the VUEWorks system. CY 2016 Activities: Construction Division: During the reporting period, 34 Bridge, Pavement, and Traffic projects were finalized. Applicable projects included items to clean & flush catch basins, manholes, pipes and outfalls. Structures repaired in Construction

STRUCTURE RECONTSTRUCTION OR REPAIR: 215 STRUCTURE ADJUSTMENT: 1322

2 Year Outlook: See above § 60.v

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§ 60.X. CLOSED DRAINAGE SYSTEM COMPONENT CLEANING AND REPAIRS CY 2016 Activities – Maintenance Division: Detailed information will be available in future reports via configuration of the VUEWorks system. CY 2016 Activities: Construction Division: During the reporting period, 34 Bridge, Pavement, and Traffic projects were finalized. Applicable projects included items to clean & flush catch basins, manholes, pipes and outfalls. Pipes cleaned in Construction:

PIPE CLEAN AND FLUSH: 50,475 LF 2 Year Outlook: See above § 60.v.

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MISCELLANEOUS CONSENT DECREE

§ 60.Y. SUPPLEMENTAL ENVIRONMENTAL PROJECTS UPDATE CY 2016 Activities: RIDOT completed the two land transfers in accordance with Consent Decree § VII. Supplemental Environmental Projects and Appendix 12. EPA approved the SEPs on October 4, 2016 with no conditions. There are no further actions or reporting requirements for this section. § 60.Z. IDENTIFICATION OF ALL CONSENT DECREE NONCOMPLIANCE CY 2016 Activities: RIDOT has no non-compliance issues to identify at this time.

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APPENDICES Appendix A: Updated Appendix 5 Appendix B: STU Inspections Appendix C: IDDE Summary Appendix D: Road Sweeping Appendix E: On-Call Task Appendix F. 2016 Final Inspections Appendix G. Memo to Project Management Appendix H. 2017 Program List