UPDATE ON ODOT’S L&D MANUAL FOR UPDATE ON ODOT’S L&D MANUAL FOR POST-CONSTRUCTION CONTROL BMP’SPOST-CONSTRUCTION CONTROL BMP’S

Mike Wawszkiewicz, P.E.◦Hydraulic/BMP Specialist, Central

Office Production

IntroductionIntroductionTopics

◦ Linear Transportation Post-Construction BMPs Differences from standard residential/commercial

development

◦ Design Requirements Amount of Treatment

◦ ODOT Experiences Design, Construction, Maintenance Issues

◦ Maintenance and Permitting Responsibilities

◦ What’s next?

IntroductionIntroductionMagnitude of Permitting

◦Per OEPA database of Construction General Permit Permittees: ODOT has ~660 permits

◦To ensure a consistent application regarding post-construction BMPs for roadway projects, ODOT needed to have design guidelines

ODOT/Storm Water ODOT/Storm Water AcronymsAcronyms BMP – Best Management Practice CGP – Construction General Permit EBW – Enhanced Bankfull Width EDA – Earth Disturbed Area ExT – Exfiltration Trench L&D Manual – ODOT Location and Design Manual LPA – Local Public Agency NOI – Notice of Intent NPDES – National Pollutant Discharge Elimination System OEPA – Ohio Environmental Protection Agency SWPPP or SWP3 – Storm Water Pollution Prevention Plan T% - Treatment Percent TSEC – Temporary Sediment and Erosion Control VBF – Vegetated Biofilter WQf – Water Quality Flow WQv – Water Quality Volume

Linear Transportation Linear Transportation BMPsBMPs Linear

Transportation Projects vs. Standard Land Development◦ Difficulty

implementing BMPs listed in the Construction General Permit R/W limitations

(Eminent Domain) Safety of the

traveling public Linear nature results

in crossing multiple watersheds (centralized BMP impossible)

Dangers of Ponded Water

Multiple Watersheds Crossed

Linear Transportation Linear Transportation BMPsBMPs

◦Difficulty implementing BMPs listed in the Construction General Permit (cont.) Roadway improvements offer little ability to

change alignment to allow easier BMP implementation. Not an option to relocate existing bridges and roads in most cases.

Urban environments – Highly developed areas with little room for storm water facilities

Henderson Road Bridge

Linear Transportation Linear Transportation BMPsBMPsRural

Construction◦ Options are

limited Vegetated Biofilter Small Dry Detention

Areas

Urban Construction◦ Options are very

limited Manufactured

Systems Exfiltration Trench Underground

Storage

Linear Transportation Linear Transportation BMPsBMPsOhio EPA Construction General Permit

for Storm Water Discharge (OHC000003)◦Part III.G.2.e – Post-Construction Storm

Water Management Requirements Transportation Projects – ODOT L&D Volume 2 “The construction of new roads and

roadway improvement projects by public entities (i.e., the state, counties, townships, cities, or villages) may implement post-construction BMPs in compliance with the current version (as of the effective date of this permit) of the Ohio Department of Transportation’s “Location and Design Manual, Volume Two Drainage Design” that has been accepted by Ohio EPA as an alternative to the conditions of this permit. “

Linear Transportation Linear Transportation BMPsBMPsODOT and OEPA agreed that the

following alternative BMPs can be used for linear transportation projects:◦Manufactured System◦Vegetated Biofilter◦Exfiltration Trench

Linear Transportation Linear Transportation BMPsBMPsManufactured

Systems – Item 895◦ Filtering devices

that allow for treatment of a portion of the flow in a storm sewer

Note off-line configuration

Linear Transportation Linear Transportation BMPsBMPs

Exfiltration Trench – Item 835◦ Pervious concrete

layer at top allowing water to enter a 12 inch layer of filter material

◦ Standard Construction Drawing: WQ-1.3

Design RequirementsDesign RequirementsODOT Location & Design, Volume 2

◦Project Thresholds Earth Disturbed Area (EDA > 1 acre)

◦Routine Maintenance Projects are exempt Projects that do not change original line,

grade and hydraulic capacity of the facility (i.e. resurfacing)

EDA < 5 acres List of maintenance activities in L&D Vol. 2,

Section 1200

Design RequirementsDesign RequirementsODOT Location & Design, Volume

2

◦Project Classifications for Post-Construction Storm Water BMP Design Redevelopment vs. New Construction

Redevelopment - 20% treatment required New Construction – Treatment % (T%) required

Design RequirementsDesign RequirementsNew Construction

◦ New Construction does not necessarily mean a brand new highway alignment. Any project where pavement is added outside the existing R/W resulting in a change in the runoff coefficient.

◦ The area within existing ODOT R/W is considered impervious area for the purpose of post-construction BMP calculations

Calculate Weighted Average of New Impervious vs. Existing Impervious to determine amount of

treatment

Design RequirementsDesign Requirements

New Construction◦ New construction

projects allow for a reduction of treatment based on the weighted average of existing vs. new impervious area in a drainage area or for a project (Treatment Percent)

A brand new alignment project would require 100% treatment

Design RequirementsDesign RequirementsWhat does New Construction mean for

the amount of treatment required?◦ Localized Treatment: 100% treatment for a

specific area of the project (Area must be equal to T% x Project Earth Disturbed Area)or

◦ Project Wide Treatment: Provide reduced treatment for the entire project based on T%

◦ Allowable treatment reductions for specific BMPs (i.e. exfiltration trench), see L&D Vol. 2, Section 1115.6.1 and 1115.6.2

Design RequirementsDesign RequirementsRedevelopment: No increase to

runoff coefficient◦The area within existing ODOT R/W is

considered impervious area for the purpose of post-construction BMP calculations

Design RequirementsDesign RequirementsRedevelopment

◦Projects that do not add impervious area outside the existing R/W are considered redevelopment Includes most ultra-urban projects and

divided highways that widen toward the median

Widening toward the median would be considered redevelopment for this divided

highway

Design RequirementsDesign RequirementsWhat does Redevelopment mean for

the amount of treatment required?◦ Localized Treatment: Provide 100%

treatment for an area equal to 20% of the Project EDAor

◦ Project Wide Treatment: Provide 20% treatment for the entire project

◦ Allowable treatment reductions for specific BMPs (i.e. exfiltration trench), see L&D Vol. 2, Section 1115.6.1

Design RequirementsDesign RequirementsWhen storm water treatment is being

applied using a “Localized Treatment”:◦ Credit toward meeting the treatment goal (%

of EDA) is only applied to the portion of the contributing drainage area to the BMP within the roadway right-of-way (on-site).

◦ Any offsite contributing drainage area must be included in the BMP calculations for sizing purposes (i.e. width of ditch, length of ExT, etc.). The offsite area will not be included in the reduction of the required amount of project EDA that requires treatment.

Redevelopment – Vegetated Redevelopment – Vegetated BiofilterBiofilter

Redevelopment – Vegetated Redevelopment – Vegetated BiofilterBiofilterDesign Examples for vegetated

biofilters and exfiltration trenches can be found at the following website:◦http://www.dot.state.oh.us/

Divisions/ProdMgt/Production/bmp/Pages/PostConstructionBMP.aspx

Design RequirementsDesign Requirements

Water Quantity/Water Quality Differences◦Most linear BMPs treat water quality

only◦Water quantity post-construction

BMPs are typically detention facilities (difficult to fit in the linear transportation footprint)

Design RequirementsDesign RequirementsWater Quantity (stream

protection/stability) treatment not needed when: ◦One or less acre of new impervious

area is created in new permanent right-of -way area being acquired for the project

◦Discharging to 4th order stream◦Ultra-urban areas

Design RequirementsDesign RequirementsWater Quantity alternative options:

◦ Stream Protection based on culvert/bridge design Grade Controls for bridges and culverts L&D Volume 2, Section 1115.2 provides additional

information for culvert design options that provide water quantity credit (i.e. concrete aprons, bankfull design)

OEPA considers cutoff walls at culverts as a grade

control

Design RequirementsDesign RequirementsNothing fits my project – What now?

◦ ODOT-Let Projects – Contact ODOT Central Office Production (Mike Wawszkiewicz)

◦ Local-Let Projects Contact Ohio EPA – District Contact http://www.epa.state.oh.us/dsw/storm/

contacts_storm.html

◦ Possible Options at increased ratio (1.5:1 – WQv) Offsite Mitigation Conservation Easements Offsite mitigation and conservation easements

should be coordinated through Ohio EPA prior to NOI submittal

ODOT ExperiencesODOT ExperiencesConsider the impacts of BMPs during

plan development!◦ Right-of-way Issues need to be identified

early◦ Take advantage of the treatment reductions

allowed through the CGP and L&D Volume 2.◦ Take the time to calculate the T%. ◦ Do not provide post-construction BMPs on

Routine Maintenance ProjectsWhy?

◦ Construction Cost◦ R/W Cost and Acquisition Time

Especially Vegetated Biofilters◦ Maintenance Costs and Time to Maintain!!!!

ODOT ExperiencesODOT Experiences

Design Considerations◦ Depth of BMP (manufactured system)◦ Location of BMP for access. Vacuum

trucks needed for manufactured systems.◦ Confined Space issues◦ Can one manufactured system replace

long runs of Exfiltration Trench? The initial cost may be higher. However, for maintenance purposes, it may be more beneficial to use a single manufactured system.

ODOT ExperiencesODOT Experiences

Design Considerations (cont.)◦Detention Facilities: Consider the

effects of ponding water on the upstream drainage system. Culvert tailwater effects Ditch flow depths Storm sewer capacity

ODOT ExperiencesODOT ExperiencesConstructability

Issues◦ Utility Conflicts◦ Maintaining BMPs

free of construction debris (sequencing of construction activities)

◦ Condition of BMP at point of hand-off from construction to maintenance

ODOT ExperiencesODOT ExperiencesMaintenance Issues

◦ Understand the materials/equipment/training needed for maintenance are available for the specified BMPs

◦ Disposal of BMP wastes…Hazardous?

Maintenance Maintenance ResponsibilitiesResponsibilities

Part IV.B.1 of CGP requires that a maintenance agreement is in place when filing the NOT◦ODOT will maintain BMPs on ODOT

maintained roadways and facilities

Maintenance Maintenance ResponsibilitiesResponsibilitiesMaintenance Issues

◦Where are the BMPs? ODOT is developing an inventory of post-construction BMPs on ODOT roadways

◦Training of ODOT staff (County Managers) on maintenance procedures

◦OEPA can audit MS4’s.

Maintenance Maintenance ResponsibilitiesResponsibilitiesMaintenance Issues

◦Frequency for clean out of some linear BMPs is still unknown (i.e. Exfiltration Trench)

◦Level of effort for some BMPs may be high based on frequency

Maintenance Maintenance ResponsibilitiesResponsibilitiesODOT projects that extend onto

Local Public Agency roadways◦Similar to other roadway features,

ODOT will NOT maintain post-construction BMPs outside of ODOT right-of-way

◦Local is responsible for maintenance◦Coordination during Preliminary

Legislation development

Maintenance Maintenance ResponsibilitiesResponsibilitiesODOT Projects extending onto

LPA roadways◦Local may request a specific BMP

type based on maintenance concerns ODOT may require Local to pay the

difference in cost

Permitting ResponsibilitiesPermitting ResponsibilitiesLocal-let LPA projects

filed through ODOT◦ 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)

The LPA, not ODOT, must coordinate with Ohio EPA if deficiencies are identified.

What’s next?What’s next?Watershed Specific Permits

◦ Big Darby◦ Portions of the Olentangy

ODOT Research◦ Exfiltration Trench - Performance,

Durability and Maintenance◦ Vegetated Biofilter - Performance

Refinements to existing BMPs and continued monitoring…

Watershed Specific Watershed Specific PermitsPermits Big Darby

◦ Counties affected: Logan, Champaign, Clark, Union, Madison, Franklin, Pickaway

◦ Effective Date: October 27, 2006

◦ Riparian Setback and Groundwater Mitigation

◦ Sediment Pond size: 134 CY/Ac of drainage

◦ Total Suspended Solids testing 45 mg/l TSS

performance required

Watershed Specific Watershed Specific PermitsPermits Olentangy

◦ Counties affected: Morrow, Marion, Delaware, Franklin

◦ Issued: January 23, 2009

◦ Effective Date: April 8, 2009

◦ Riparian Setback Mitigation

◦ Sediment Pond size: Same as Standard CGP

Watershed Specific Watershed Specific PermitsPermitsOhio EPA Requirements

◦Submittal of SWPPP with NOI application ODOT submits temporary sediment

basin locations, post-construction BMP locations, and mitigation calculations. Contractor completes remainder of SWPPP when project is awarded.

◦45-day review period (standard CGP is 21 day review)

Watershed Specific Watershed Specific PermitsPermits“Mitigation for mitigation”

◦Overlapping Mitigation resulting from State or Federal environmental regulations (i.e. 404/401) may be adjusted in recognition of these requirements.

Watershed Specific Watershed Specific PermitsPermitsRedevelopment Projects

covered by Watershed Specific Permits◦Projects located within the

delineated setback boundary are exempt from Riparian Setback Mitigation provided the proposed project does not further intrude the delineated setback boundary.

Watershed Specific Watershed Specific PermitsPermitsBig Darby and Olentangy were

generated by TMDL recommendations

More TMDL watersheds have potential to become Watershed Specific Permits.

Manufactured System

Vegetated Biofilter

Exfiltration Trench

Detention Basin

Questions?Questions?

Mike Wawszkiewicz, P.E.◦Phone: 614-728-4585◦Email:

michael.wawszkiewicz@dot.state.oh.us

◦ODOT Post-Construction BMP Website:http://www.dot.state.oh.us/Divisions/ProdMgt/Production/bmp/Pages/PostConstructionBMP.aspx