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MDOT Illicit Discharge Elimination Program. “Together . . .Better Roads, Cleaner Streams”. Our Cleaner Streams Mascot. Today’s Goals . To Understand: Which discharges are illicit (and which are not) Where and when illicit discharges may be encountered

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Mdot illicit discharge elimination program l.jpg

MDOT Illicit Discharge Elimination Program

“Together . . .Better Roads, Cleaner Streams”

Our Cleaner Streams Mascot


Today s goals l.jpg
Today’s Goals

To Understand:

  • Which discharges are illicit (and which are not)

  • Where and when illicit discharges may be encountered

  • How to handle a reported illicit discharge

  • Who is responsible for various tasks

  • How to use the Reporting Database

  • Annual reporting responsibilities

  • Staff training


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Agenda

  • MDOT Phase II Storm Water Program Overview

  • Illicit Discharge Reporting

  • Training Module

  • IDEP Screening Update

  • Summary



Is water from a commercial car wash facility an illicit discharge l.jpg
Is water from a Commercial Car Wash facility an illicit discharge?

A. Yes, Always

B. Sometimes, only when polluted

C. No, never


Which one of the following best represents a municipal separate storm sewer system l.jpg
Which one of the following best represents a Municipal Separate Storm Sewer System?

A. A bridge scupper drain

B. A residential sump pump drain

C. A septic system cheater pipe


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Is MDOT required to conduct an IDEP program? Separate Storm Sewer System?

YES

NO


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What are the proper actions of notification of an illicit discharge?

A. Do nothing, someone else will take care of it

B. Send an email to “DOT the Drop”

C. Notify the MDEQ, the MDOT storm water coordinator, and other proper authority


Which one of these is considered a permittable point source discharge click on the correct photo l.jpg
Which one of these is considered a permittable “point source discharge”(click on the correct photo)


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GREAT JOB!! source discharge”


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Agenda source discharge”

  • MDOT Phase II Storm Water Program Overview

  • Illicit Discharge Reporting

  • Training Module

  • IDEP Screening Update

  • Summary


Mdot phase ii permit l.jpg
MDOT Phase II Permit source discharge”

  • Effective April 1, 2004 – April 1, 2009

  • Provides Statewide Coverage

  • Authorizes Storm Water Discharges from MDOT Facilities

  • Six Minimum Measures

  • Storm Water Management Plan (SWMP)

  • Annual Reporting


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Project source discharge”Approach

Program Components

PollutionPrevention/Good Housekeeping

PostConstruction


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MDOT Activities for IDEP Component source discharge”

Illicit Discharge

Elimination Program

  • Dry Weather Outfall Screening

  • Mapping

  • Outfall Labeling

  • Education and Training Activities

  • Illicit Discharge Reporting Program

  • Follow-up on Illicit Discharges

  • Legal Authority


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What is source discharge”IDEP?

I= Illicit – Wrong, illegal, needs correction

D= Discharge – Someone may swim in it

E= Elimination – Let’s get rid of it

P= Plan/Program/Project – Solutions


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Definition – Illicit Discharge source discharge”

Illicit Discharge: “The discharge of pollutants or non-storm water materials to storm water drainage systems via overland flow, or direct dumping of materials into a catch basin.”


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Definition – Illicit Connection source discharge”

Physical connection to the drainage system that:

  • Primarily conveys illicit discharges into the drainage system and/or

  • Is not authorized or permitted by MDOT (where MDOT requires such authorization or permit)

Source: MDEQ Permit No. MI0057364


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Definition - Point Source Discharge (PSD) source discharge”

“An outfall from a drainage system to waters of the state, or a point where a storm water drainage system discharges into a system operated by another public body.”


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Includes: source discharge”

The Great Lakes and their connecting waters

All inland lakes

Rivers

Streams

Impoundments

Open drains

Other surface bodies of water within the confines of the state

What are Waters of the State?

Does Not Include:

  • Drainage Ways and ponds used solely for wastewater conveyance, treatment, or control


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Rising groundwaters source discharge”

Uncontaminated groundwater infiltration (40 CFR 35.2005(20))

Pumped groundwaters (except for groundwater cleanups not specifically authorized by NPDES permits)

Acceptable Non-Storm Water Discharges

Source MDEQ Permit No. MI0057364


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continued source discharge”

Acceptable Non-Storm Water Discharges

  • Diverted stream flows

  • Flows from riparian habitats and wetlands

  • Springs

  • Emergency fire fighting activities (unless identified as significant sources of pollutants)

Source MDEQ Permit No. MI0057364


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continued source discharge”

Acceptable Non-Storm Water Discharges

  • Foundation drains

  • Water from crawl space pumps

  • Footing drains and basement sump pumps

  • Air conditioning condensates

  • Water line flushing

Source MDEQ Permit No. MI0057364


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continued source discharge”

Acceptable Non-Storm Water Discharges

  • Landscape irrigation runoff

  • Irrigation waters

  • Lawn watering runoff

  • Residual street wash waters

Source MDEQ Permit No. MI0057364


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continued source discharge”

Acceptable Non-Storm Water Discharges

  • Discharges from potable water sources

  • Waters from non-commercial car washing

  • Residential swimming pool waters and other permitted, dechlorinated swimming pool waters without untreated filter backwash

Source MDEQ Permit No. MI0057364


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Agenda source discharge”

  • MDOT Phase II Storm Water Program Overview

  • Illicit Discharge Reporting

  • Training Module

  • IDEP Screening Update

  • Summary


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MDOT Staff who find illicit discharges source discharge”

Maintenance

Construction

Survey

Tasks associated with finding illicit discharges

Ditch clean-out

Mowing

Pesticide

Survey

Construction

Accidental

IDEP Discoveries


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Legal Authority to Remove source discharge”

  • Permit Requirements

    • MDOT shall possess legal authority statewide to prohibit discharges into drainage system

  • Current Authority

    • Section 9.13 Construction Permit Manual

  • Methodology

    • Notice and Order to Remove Encroachment

    • Multiple notices of violation

Stay Tuned – Judy will be discussing after lunch


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Illicit Discharge Tracking Procedure source discharge”

Illicit Discharge Suspected

Record Information

Is it an emergency?

Call 911 or PEAS hotline: 1-800-292-4706

Notify Supervisor or Region IDEP Coordinator

No

Yes

STOP

No Further Action Necessary

Preliminary Verification

Notify Supervisor or Region IDEP Coordinator

No Problem

Problem

Suspected

Discussion

MDOT and Tetra Tech;

Notify MDEQ, Local Authority, and MDOT Storm Water Program Manager

MDOT

Tetra Tech

  • Legend

  • Responsible Parties

  • = Initial Reporter

  • = IDEP Region Coordinator

(Continued on next page)


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Illicit Connection Removal Process source discharge”

(Continued from Previous page)

Tetra Tech

MDOT

Field Investigation to Identify Source

STOP

No Further Action Necessary

NotifyMDEQ

No Problem Found

Illicit Discharge Confirmed

Off ROW?

Yes

No

Stay Tuned – Judy will be discussing after lunch

Refer to Local Authority or proceed with letter notification sequence as appropriate*

MDOT will correct problem

  • Legend

  • Responsible Parties

  • = IDEP Region Coordinator

  • * Refer to Figure 3-1 in MDOT’s Storm Water

  • Management Plan for letter sequence

Confirm that problem was removed


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MDEQ Notification Requirements source discharge”

  • Emergency Discharge:

    • Discharge that poses imminent danger to health or environment

      • Tanker accidents, pipeline breaks, and releases of hazardous substances, oil, salt, or other polluting materials (defined by the Critical Materials Register) under state law.

  • Verbal Notification to MDEQ within 24 hours

    • Make every attempt to notify a live person at the applicable MDEQ District Office including pressing “0” for the MDEQ operator

  • After Hours Call PEAS: 1-800-292-4706

  • Part I Section C.2.a


Mdeq notification requirements31 l.jpg

continued source discharge”

MDEQ Notification Requirements

  • Non-Emergency Discharge:

    • Discharge that does not pose imminent danger to health or environment

    • Verbal or Written documentation to MDEQ within 5 days of becoming aware of any reason or instance of non-compliance.

    • Part I Section C.2.c

  • All notification must include (if known):

    • Name of regulated discharger

    • Location of discharge and outfall

    • Nature of pollutants

    • Clean-up and recovery measures planned


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If untreated or partially treated sewage is discharged from drainage system...

Untreated Sewage Discharge Notification

  • Notify with 24 hours after discharge begins:

    • MDEQ

    • Local Health Dept.

    • One or more daily newspapers of general circulation

  • Compliance with Section 324.3112a of Michigan Act

  • Part I Section C.2.d


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admin drainage system...

admin

Complaint Tracking Database

  • Discharge tracking component

  • Microsoft Access Database

  • Housed on server at each MDOT Region Office

  • Mandatory use of Reporting Database


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  • Login Screen drainage system...

    • Administrators, Region IDEP Coordinators: To login for the first time, use the following format for your user name and password.

      • User Name: first.last

      • Password: first.last

    • Example: Judy Ruszkowski

      • User Name: judy.ruszkowski

      • Password: judy.ruszkowski

    • Then, go to User Management to create a specific account for you. You may do this same procedure to create an account for all users.

    • Users: To login for the first time, use the login user name and password assigned to you from an Administrator, (Region IDEP Coordinator). Only the Administrator can change your password.


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New Complaint drainage system...: If you are entering information for the first time about a new reported illicit discharge or connection, use New Complaint.

Existing Complaint: If you are referencing or editing an existing complaint, use Existing Complaint.

Report: If you are creating a report of existing illicit discharge issues in your region, Report will allow you to customize the information included in the report.

Logout: Use logout to exit the database.

User Management: To create a new user account, or to manage the functions each user can perform, User Management will allow you to add and edit user accounts. Only an administrator will see this button.

Administrator Only


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  • Initial Complaint drainage system...

  • This page is where you will enter the information received about an illicit discharge via telephone or field staff reporting. A paper form exists to fill out when not logged in to the database.

  • The sections with an *asterisk are required fields. The information entered into the top portion of the screen will be automatically copied into subsequent screens related to this complaint.

  • Once you select a Region, only the Counties contained in that region will be listed in the pull down menu.

  • Once a County is selected, only the Control Section Numbers in that County will be listed in the pull down menu.

  • Once a Control Section Number is identified, only the Routes contained in that Control Section will be listed in the pull down menu.

  • Be sure to save before exiting this page.

  • The buttons at the bottom of the screen will open additional forms to be filled out or edited in relation to this complaint.


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  • Existing Complaint drainage system...

  • This page is where you will select an existing complaint to reference or edit.

  • You may search for an existing record by:

    • Complaint Number

    • Region

    • County

    • Control Section

    • Route

    • Date

    • Or selecting from the Complaint List

  • Once you have highlighted a complaint number, select Go to Existing Complaint Menu

  • Return to Main Menu takes you back to the main option menu.


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Initial Complaint drainage system...: If you want to reference the initial complaint made, use Initial Complaint.

Initial Investigation: If you want to reference, or enter a new site investigation, use Initial Investigation.

Follow-up Investigation: If you want to reference, or enter a new follow-up investigation, Follow-up Investigation will allow you to view or enter the information.

Communication: If information has been exchanged, external or internal to MDOT regarding this complaint, use Communication.

Completion: Use this if the reported illicit discharge issue has been resolved.

Information can be edited and saved in all pages related to an existing complaint, with the exception of automated text that is linked to the Initial Complaint page. This automated information can only be changed in the Initial complaint page.

Administrator Only


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This area will fill in automatically from initial complaint data.

Communication Tracking

If information has been exchanged, external or internal to MDOT regarding this complaint, use Communication.

The sections with an *asterisk are required fields.

Files may also be attached to this complaint such as letters, or emails in any format. To attach a file, click Save this Communication and Attach Files. You will be prompted to browse and upload a file. To retrieve an uploaded file, use the scroll buttons and click Download. Then, indicate where you would like it to be saved.

Be sure to save the data before exiting.


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Investigation data.

This form needs to be filled out when a crew completes a site investigation of the reported illicit discharge. A paper form exists for the crew to fill out in the field.

This form applies to both an initial site investigation and a follow-up investigation.

The sections with an *asterisk are required fields.

Files may also be attached to this complaint such as letters, or emails in any format. To attach a file, click Save this Communication and Attach Files. You will be prompted to browse and upload a file. To retrieve an uploaded file, use the scroll buttons and click Download. Then, indicate where you would like it to be saved.

Be sure to save the data before exiting.

Investigation continues on next page.

This area will fill in automatically from initial complaint data.

This area will fill in automatically from initial complaint data.


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Investigation data. (continued from previous page)

This form needs to be filled out when a crew completes a site investigation of the reported illicit discharge. A paper form exists for the crew to fill out in the field.

This form applies to both an initial site investigation and a follow-up investigation.

The sections with an *asterisk are required fields.

Files may also be attached to this complaint such as letters, or emails in any format. To attach a file, click Save this Communication and Attach Files. You will be prompted to browse and upload a file. To retrieve an uploaded file, use the scroll buttons and click Download. Then, indicate where you would like it to be saved.

Be sure to save the data before exiting.

This area will fill in automatically from initial complaint data.


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This area will fill in automatically from initial complaint data.

Completion

This form needs to be filled out when an illicit connection or discharge issue has ceased or has been referred to another entity and MDOT is no longer responsible.

Do not complete this form until the illicit connection or discharge removal is confirmed by a site visit or follow up investigation.

Be sure to save the data before exiting.

This area will fill in automatically from initial complaint data.


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  • Report data.

  • This page will allow you to generate three different report types.

  • 1. Complaint Summary – list of complaints with brief description of each.

  • . Detailed Complaint Report – a detailed report of a single complaint.

  • . Progress Summary – A numerical tally of complaints by Region.

  • You may search for a complaint record by:

  • Date

  • Region

  • County

  • Control section

  • Route

  • By selecting a complaint number in the list

  • Complaint status

  • The reports will assist in obtaining the necessary information for the MDOT storm water permit annual report.


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The data.Complaint Summary lists each complaint and pertinent information, such as the location of the discharge, nature of the problem and the status.

This report page opens as a separate window in the database. You can close this window without closing the entire database by clicking the “X” in the top corner.


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This report page opens as a separate window in the database. You can close this window without closing the entire database by clicking the “X” in the top corner.

The Detailed Complaint Report gives a detailed report of a single complaint including information about the problem, and subsequent investigations.


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The You can close this window without closing the entire database by clicking the “X” in the top corner.Progress Summary Report is a numerical report which tallies the number of complaints per Region. It also indicates the percent of resolved issues.

This report page opens as a separate window in the database. You can close this window without closing the entire database by clicking the “X” in the top corner.


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Administrator Only You can close this window without closing the entire database by clicking the “X” in the top corner.

User Management

This page will allow you to create or edit user accounts.

You may edit user information by scrolling to the specific user, making changes and clicking

Save Record.

To add a new user, click Add Another User then fill in the correct information, and click Save Record.

To specify functions each user may have access to, click on the Yes box next to the desired function.

If the box contains a check mark, the user has access to that management function.

If the box does not contain a check mark, the user does not have access to that management function.


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Database upload. You can close this window without closing the entire database by clicking the “X” in the top corner.Scenario information is located in the tab labeled “Reporting Database”.


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Scenario 1: Reported oil sheen on river from MDOT outfall You can close this window without closing the entire database by clicking the “X” in the top corner.


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Information to Record You can close this window without closing the entire database by clicking the “X” in the top corner.

Be as specific as possible!

  • Where

    • Control Section # 70014, along north bound US-31, 1000 feet north of BR-196 and US-31 interchange (Holland)

  • What

    • Oil sheen (possibly gasoline or fuel oil), spread 10 ft. radius from outfall pipe

  • When – (Observation Info.)

    • February 15, 2006 at 10:00 am

  • Who (Complaint and source, if known)

    • Complaint is anonymous, source of discharge is unknown


Investigation l.jpg
Investigation You can close this window without closing the entire database by clicking the “X” in the top corner.

The reported problem is located within the MDOT Right-of-Way (along US-31 in Holland)

  • Action: MDOT sends a crew to investigate, confirm and take additional notes and photos.

  • Observations: Crew investigates oil sheen and finds an illicit discharge from an oil change facility. Source location is confirmed to be outside of MDOT ROW.


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Notification You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Notification:The MDEQ District Office is notified within 5 days of MDOT becoming aware of non-compliance.

  • Corrective Action:MDOT sends a letter to the oil change facility landowner to remove discharge from MDOT drainage system.

    • Landowner must provide documentation of corrective actions to remove discharge.

    • Use letters in Section 9.13 of Construction Permit Manual.

  • Completion: The connection was removed by the landowner on April 1, 2006. Field staff re-investigated to confirm removal on April 5, 2006.


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Example You can close this window without closing the entire database by clicking the “X” in the top corner.Sheens

www.riverkeeper.org


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Scenario 2: Spill discharging to MDOT drainage system You can close this window without closing the entire database by clicking the “X” in the top corner.


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Information to Record You can close this window without closing the entire database by clicking the “X” in the top corner.

Be as specific as possible!

  • Where

    • Catch basin along M-99, 100 feet south of I-496 bridge (Lansing)

  • What

    • Fluorescent green liquid

  • When – (Observation Info.)

    • March 15, 2006 at 5 pm

  • Who (Complaint and source, if known)

    • Complaint is Joe Smith, source of discharge is from restaurant


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Investigation You can close this window without closing the entire database by clicking the “X” in the top corner.

The reported problem is located within the MDOT Right-of-Way (along M-99 in Lansing)

  • Action: MDOT sends a crew to investigate, confirm and take additional notes and photos.

  • Observations: Crew investigates green liquid and finds an illicit discharge from a “Yummy Food” restaurant. The liquid is a biodegradable, non-toxic, cleaning agent. Source location is confirmed to be outside of MDOT ROW.


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Notification You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Notification:MDEQ is notified within 5 days of MDOT becoming aware of non-compliance.

  • Corrective Action:MDOT sends a letter to the “Yummy Food” restaurant to discontinue dumping cleaning agents down storm drains.

    • MDOT sends a reminder that cleaning agents are not acceptable discharges.

    • Use letters in Section 9.13 of Construction Permit Manual.

  • Completion:The landowner received the letter and will begin acceptable discharge compliance.


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Example Spills You can close this window without closing the entire database by clicking the “X” in the top corner.

USFWS.gov


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Scenario 3: Highly turbid water discharging from outfall You can close this window without closing the entire database by clicking the “X” in the top corner.


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What Information do I need? You can close this window without closing the entire database by clicking the “X” in the top corner.

Be as specific as possible!

  • Where

    • Discharging from Construction site along M-43 in Lansing, 1000 feet east of BR-96 and M-43 intersection.

  • What

    • Soil erosion from a construction site entrance

  • When – (Observation Info.)

    • April 1, 2006 at 10:00am

  • Who (Complaint and source, if known)

    • Complaint is anonymous, source is at an MDOT Construction site.


Investigation what actions l.jpg
Investigation – What actions? You can close this window without closing the entire database by clicking the “X” in the top corner.

The reported problem is located within the MDOT Right-of-Way (along M-43 in Lansing)

  • Action: MDOT sends a crew with a certified SESC operator to investigate, confirm, and take additional notes and photos.

  • Observations: Crew and SESC operator investigates soil erosion and finds an illicit discharge and no BMP’s in place on a construction site of 5-acres. Source location is confirmed to be located in MDOT ROW.


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Notification – Who was notified? You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Notification: The MDEQ District Office is notified within 5 days of MDOT becoming aware of non-compliance.

  • Corrective Action: MDOT begins correction at construction site, installing proper BMPs. An SESC operator will perform BMP monitoring to ensure BMP does not fail.

  • Completion: MDOT installs BMPs on April 14, 2006 and reports on progress to MDEQ according to permit.


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Scenario 4: Septic Cheater Pipe You can close this window without closing the entire database by clicking the “X” in the top corner.


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Information to Record You can close this window without closing the entire database by clicking the “X” in the top corner.

Be as specific as possible!

  • Where

    • Middle of woods along MDOT road ditch (Genesee County)

  • What

    • Dry Weather Flow with sewage debris

  • When – (Observation Info.)

    • May 9, 2005 at 12:30 pm

  • Who (Complaint and source, if known)

    • Complaint is John Doe, source of discharge unknown, no houses in near vicinity


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Investigation You can close this window without closing the entire database by clicking the “X” in the top corner.

The reported problem is located within the MDOT Right-of-Way (drainage ditch in Genesee County)

  • Action: MDOT sends a crew to investigate, confirm and take additional notes and photos.

  • Observations: Crew investigates raw sewage debris discharging from a 6” PVC pipe. Upstream land use is forest in range of sight. Further investigation confirms the pipe cuts through woods for 1000 feet and disappears at a residential property line. Source location is confirmed to be outside of MDOT ROW.


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Notification You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Notification:MDEQ, the Health Dept., and a newspaper are notified within 24 hours of MDOT becoming aware of non-compliance.

  • Corrective Action:MDOT sends a letter to the resident and corresponding municipality to remove septic cheater pipe from storm drainage ditch.

    • Use letters in Section 9.13 of Construction Permit Manual.

  • Completion: Resident removes pipe on June 30, 2005; municipality and MDOT field crew re-investigate to confirm removal on July 24, 2005.


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Reports You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Complaint Summary – list of complaints with brief description of each.

  • Detailed Complaint Report – a detailed report of a single complaint.

  • Progress Summary – A numerical tally of complaints by Region.


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Database User Management You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Accessible to database “Administrators”

    • Create New User

    • Assign User Functions


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Cheater Pipes You can close this window without closing the entire database by clicking the “X” in the top corner.

Floatables


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Suds You can close this window without closing the entire database by clicking the “X” in the top corner.


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SESC Issues You can close this window without closing the entire database by clicking the “X” in the top corner.


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Region IDEP Reporting You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Frequency of submittal (quarterly or annual)

  • Forward to Tetra Tech by the first week in January (January 5, 2007)


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Agenda You can close this window without closing the entire database by clicking the “X” in the top corner.

  • MDOT Phase II Storm Water Program Overview

  • Illicit Discharge Reporting

  • Training Module

  • IDEP Screening Update

  • Summary


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MDOT IDEP Training Module You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Illicit Discharge Elimination Program Module

  • Topics:

    • NPDES Storm Water Program Overview

    • Permit Requirements

    • Illicit Discharge Examples

    • IDEP Reporting Program

  • Training for MDOT staff


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Agenda You can close this window without closing the entire database by clicking the “X” in the top corner.

  • MDOT Phase II Storm Water Program Overview

  • Illicit Discharge Reporting

  • Training Module

  • IDEP Screening Update

  • Summary


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Dry Weather Screening Update You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Dry Weather Screening

    • 14 Urbanized Areas Investigated Statewide

    • Road Stream Crossings with Impaired Waterbodies

    • Nearly 90% Complete

    • Follow-up investigations require drainage maps

  • Remaining Work

    • Starting back up

    • May contact Region coordinator for assistance


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IDEP Outfall Mapping You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Locations investigated during IDEP


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Known You can close this window without closing the entire database by clicking the “X” in the top corner.Outfall Mapping

  • Permit Requirements

    • Mechanism for Mapping known outfalls statewide

    • Part I Section B.3.a

  • Approach

    • Phase I Field Data

    • Phase II Field Data

    • Design Survey Data


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Agenda You can close this window without closing the entire database by clicking the “X” in the top corner.

  • MDOT Phase II Storm Water Program Overview

  • Illicit Discharge Reporting

  • Training Module

  • IDEP Screening Update

  • Summary


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Here’s what you need to do You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Tracking Application

    • Install it

    • Decide who’s going to use it and how

    • USE IT

    • Provide feedback as requested by Judy and Tt

  • Follow up on reported problems (ask for help if you need it)

  • Training

    • Train maintenance, construction and survey

      staff by the end of the year

    • Provide feedback to Judy and Tt on who,

      what, when, where and how

  • Known Outfall Maps

    • Review and comments. No fieldwork necessary.


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When you have questions . . . You can close this window without closing the entire database by clicking the “X” in the top corner.

  • Call Judy when you have...

    • Problems with an illicit discharge (Judy will call Tt as needed)

    • General questions on the storm water program

  • Call Tetra Tech when you have...

    • Problems with the database

    • Results of reviewing the known outfall maps

    • Questions about the training module


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