MDOT Illicit Discharge Elimination Program “Together . . .Better Roads, Cleaner Streams”

MDOT Illicit Discharge
Elimination Program
“Together . . .Better Roads, Cleaner Streams”
Our Cleaner Streams Mascot
Today’s Goals
To Understand:
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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
Agenda
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MDOT Phase II Storm Water
Program Overview
Illicit Discharge Reporting
Training Module
IDEP Screening Update
Summary
ICE BREAKER!
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?
A.
A bridge scupper drain
B.
A residential sump pump
drain
C.
A septic system cheater pipe
Is MDOT required to conduct an
IDEP program?
YES
NO
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)
GREAT JOB!!
Agenda
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MDOT Phase II Storm Water
Program Overview
Illicit Discharge Reporting
Training Module
IDEP Screening Update
Summary
MDOT Phase II Permit
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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
Project
Approach
Program Components
Pollution
Prevention/
Good
Housekeeping
Construction
(SESC)
Public
Education
Assessment
and Reporting
Post
Construction
Public
Involvement
Illicit Discharge
Elimination
Program
MDOT Activities for IDEP Component
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Dry Weather Outfall Screening
Illicit Discharge
Elimination Program
Mapping
Outfall Labeling
Education and Training Activities
Illicit Discharge Reporting Program
Follow-up on Illicit Discharges
Legal Authority
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
What is IDEP?
Definition –
Illicit 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.”
Definition – Illicit Connection
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
Definition - Point Source Discharge
(PSD)
“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.”
What are Waters of the State?
Includes:
 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
Does Not Include:
 Drainage Ways and
ponds used solely for
wastewater conveyance,
treatment, or control
Acceptable
Non-Storm Water Discharges
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Rising groundwaters
Uncontaminated groundwater infiltration
(40 CFR 35.2005(20))
Pumped groundwaters (except for
groundwater cleanups not specifically
authorized by NPDES permits)
Source MDEQ Permit No. MI0057364
continued
Acceptable
Non-Storm Water Discharges
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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
continued
Acceptable
Non-Storm Water Discharges
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Foundation drains
Water from crawl space pumps
Footing drains and basement
sump pumps
Air conditioning condensates
Water line flushing
Source MDEQ Permit No. MI0057364
continued
Acceptable
Non-Storm Water Discharges
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Landscape irrigation runoff
Irrigation waters
Lawn watering runoff
Residual street wash waters
Source MDEQ Permit No. MI0057364
continued
Acceptable
Non-Storm Water Discharges
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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
Agenda
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MDOT Phase II Storm Water
Program Overview
Illicit Discharge Reporting
Training Module
IDEP Screening Update
Summary
IDEP
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MDOT Staff who find
illicit discharges
Discoveries
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Tasks associated
with finding illicit
discharges
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Maintenance
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Construction
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Ditch clean-out
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Survey
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Mowing
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Pesticide
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Survey
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Construction
Legal Authority to Remove
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Permit Requirements
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Current Authority
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MDOT shall possess legal authority statewide to
prohibit discharges into drainage system
Section 9.13 Construction Permit Manual
Methodology
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Notice and Order to Remove Encroachment
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Multiple notices of violation
Stay Tuned – Judy will be discussing after lunch
Illicit Discharge Tracking Procedure
Illicit Discharge Suspected
Record Information
Call 911 or
PEAS hotline:
1-800-292-4706
Yes
Is it an
emergenc
y?
Notify
Supervisor or
Region IDEP
Coordinator
No
Notify Supervisor or
Region IDEP
Coordinator
STOP
No
Further
Action
Necessary
No
Problem
Prelimina
ry
Verificati
on Problem
Suspected
Notify MDEQ, Local
Authority, and
MDOT Storm Water
Program Manager
Discussion
MDOT and
Tetra Tech;
Tetra
Tech
MDOT
Legend
Responsible Parties
(Continued on
next page)
= Initial Reporter
= IDEP Region Coordinator
Illicit Connection Removal Process
(Continued from
Previous page)
Tetra
Tech
Notify MDEQ
Illicit
Discharge
Confirmed
Yes
Refer to Local
Authority or proceed
with letter notification
sequence as
appropriate*
Off
ROW
?
MDOT
Field
Investigatio
n to Identify
Source
No
Problem
Found
STOP
No Further
Action
Necessary
No
MDOT will
correct
problem
Stay Tuned – Judy will be
discussing after lunch
Legend
Responsible Parties
Confirm that problem was
removed
= IDEP Region Coordinator
* Refer to Figure 3-1 in MDOT’s Storm Water
Management Plan for letter sequence
MDEQ Notification Requirements
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Emergency Discharge:
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Discharge that poses imminent danger to health or
environment
–
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Verbal Notification to MDEQ within 24 hours
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Tanker accidents, pipeline breaks, and releases of
hazardous substances, oil, salt, or other polluting
materials (defined by the Critical Materials
Register) under state law.
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
continued
MDEQ Notification Requirements
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Non-Emergency Discharge:
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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 noncompliance.
Part I Section C.2.c
All notification must include (if known):
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Name of regulated discharger
Location of discharge and outfall
Nature of pollutants
Clean-up and recovery measures planned
Untreated
Sewage Discharge Notification
If untreated or
partially treated
sewage is
discharged from
drainage system...
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Notify with 24 hours
after discharge begins:
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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
Complaint Tracking Database
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Discharge tracking component
Microsoft Access Database
Housed on server at each MDOT Region Office
Mandatory use of Reporting Database
admin
admin
Login Screen
Administrators, Region IDEP
Coordinators: To login for the first time,
use the following format for your user
name and password.
oUser Name: first.last
oPassword: first.last
Example: Judy Ruszkowski
oUser Name: judy.ruszkowski
oPassword: 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.
New Complaint: 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.
Administrator Only
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.
Initial Complaint
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.
Existing Complaint
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.
Initial Complaint: 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.
Administrator Only
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.
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.
This area will fill
in automatically
from initial
complaint data.
Investigation
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.
This area will fill
in automatically
from initial
complaint data.
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.
Investigation (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 area will fill in
automatically from
initial complaint
data.
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.
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.
This area will fill in
automatically from
initial complaint
data.
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.
Report
This page will allow you to
generate three different
report types.
1. Complaint Summary – list
of complaints with brief
description of each.
2. Detailed Complaint
Report – a detailed report of
a single complaint.
3. 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.
The 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.
The Detailed Complaint
Report gives a detailed
report of a single complaint
including information about
the problem, and
subsequent investigations.
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 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.
Administrator Only
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.
Database upload.
Scenario information
is located in the tab
labeled “Reporting
Database”.
Scenario 1: Reported oil sheen on
river from MDOT outfall
Information to Record
Be as specific as possible!
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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
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.
Notification

Notification: The MDEQ District Office is notified

within 5 days of MDOT becoming aware of noncompliance.
Corrective Action: MDOT sends a letter to the oil
change facility landowner to remove discharge from
MDOT drainage system.
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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.
Example
Sheens
www.riverkeeper.org
Scenario 2: Spill discharging to
MDOT drainage system
Information to Record
Be as specific as possible!
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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
Investigation
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.
Notification

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.

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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.
Example
Spills
USFWS.gov
Scenario 3:
Highly
turbid water
discharging
from outfall
What Information do I need?
Be as specific as possible!

Where


What
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Soil erosion from a construction site entrance
When – (Observation Info.)
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
Discharging from Construction site along M-43 in
Lansing, 1000 feet east of BR-96 and M-43
intersection.
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?
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.
Notification – Who was notified?



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.
Scenario 4:
Septic
Cheater Pipe
Information to Record
Be as specific as possible!
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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
Investigation
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.
Notification

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 reinvestigate to confirm removal on July 24, 2005.
Reports
1. Complaint Summary – list of complaints with brief
description of each.
2. Detailed Complaint Report – a detailed report of a
single complaint.
3. Progress Summary – A numerical tally of
complaints by Region.
Database User Management

Accessible to database “Administrators”
 Create New User
 Assign User Functions
Cheater
Pipes
Floatables
Suds
SESC Issues
Region IDEP Reporting

Frequency of submittal (quarterly or annual)

Forward to Tetra Tech by the first week in
January (January 5, 2007)
Agenda

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
MDOT Phase II Storm Water
Program Overview
Illicit Discharge Reporting
Training Module
IDEP Screening Update
Summary
MDOT IDEP Training Module


Illicit Discharge Elimination Program Module
Topics:

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NPDES Storm Water Program Overview
Permit Requirements
Illicit Discharge Examples
IDEP Reporting Program
Training for MDOT staff
Agenda
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
MDOT Phase II Storm Water
Program Overview
Illicit Discharge Reporting
Training Module
IDEP Screening Update
Summary
Dry Weather Screening Update

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
IDEP Outfall Mapping

Locations investigated during IDEP
Known
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
Agenda


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
MDOT Phase II Storm Water
Program Overview
Illicit Discharge Reporting
Training Module
IDEP Screening Update
Summary
Here’s what you need to do

Tracking Application






Follow up on reported problems
(ask for help if you need it)
Training



Install it
Decide who’s going to use it and how
USE IT
Provide feedback as requested by Judy and Tt
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.
When you have questions . . .

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
Thank you
for your participation!