1. January 28, 2008 ODOT Central Office – Room 1C
Post-Construction BMPs
Update Meeting

2. Post-Construction BMPs
Introductions
Bill Ujvari, P.E. – Production Administrator, Central Office Production
Mike Wawszkiewicz, P.E. – Hydraulic/Roadway Designer, Central Office Production
Please feel free to ask questions during the presentations.

3. L&D Manual, Volume 2 Revisions
Revisions published January 18, 2008
Today’s Topics
Implementation Plan – IOC (included in hand-outs)
Notable revisions to post-construction BMP Sections in the L&D Manual
Local-let and ODOT-let BMP
BMP Design Approach
BMP Submittals to Central Office
OEPA Notices of Violation
Training Needs
Start with summary
Details
End with Summary

4. Implementation Plan – Projects Scoped after January 18, 2008
Include post-construction BMP based on January 2008 L&D Manual, Vol. 2
Easiest to understand.
Should be no questions on which policy should be used for this scenario

5. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Follow these steps:
Step 1
Determine if post-construction BMP are needed based on January 2008 L&D Manual, Vol. 2
If post-construction BMP needed, continue to Step 2
If post-construction BMP are not needed, no further action needed
Determination made through use of Figure
Local-let LPA projects – no longer using BMP Project Scenario guidelines

6. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Please note: Less than one acre project EDA and Routine Maintenance Projects are only projects that do not require BMP.

7. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Step 2
Determine the answers to the following:
Has the project received Stage 1 plan approval prior to January 18, 2008?
If there was no Stage 1 submittal, has the project received Stage 3 plan approval prior to January 18, 2008?
Were the right-of-way tracings completed prior to January 18, 2008?
If “No” to all of the above, design BMPs according to the January 2008 L&D Volume 2
If “Yes” to any of the above, continue to Step 3
If, for some reason, your project does not fit into these categories and you feel that BMPs per the January 2008 manual may not be needed, contact C.O.
Don’t wont to proceed with design only to have issues during construction.

8. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Step 3
Is existing and/or proposed right-of-way available to incorporate post-construction BMPs meeting the January 2008 L&D Volume 2 BMP requirements for all or part of the project?
If “Yes”, incorporate BMPs according to the January 2008 L&D Volume 2 and continue to Step 4
If “No”, continue to Step 4
Best scenario: Able to incorporate as needed for compliance

9. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Step 4
Based on BMPs incorporated within available existing and/or proposed right-of-way in Step 3, is the project 100% compliant with the January 2008 L&D Vol. 2?
If “Yes”, no further action needed
If “No”, continue to Step 5
Not best-case: partial compliance and no compliance. Either way, we must coordinate with OEPA.

10. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Step 5
Document restrictions preventing full compliance with the January 2008 L&D Vol. 2.
Cost and Schedule Impacts
Percent of project treated with BMPs
Environmental and Right-of-way impacts
Other Impacts
Documentation does not require full design of what could be. General estimates for additional manufactured systems, length of VBF, additional right-of-way that would have been required, additional length of utility relocations, etc.
Need this information to build database of potential costs for BMP. Also, we need to be able to determine possible mitigation to satisfy OEPA requirements.
Not necessarily to be shared with OEPA. However, without some assessment, we are guessing and we could overestimate.

11. Implementation Plan – Projects Scoped Prior to Jan. 18, 2008
Step 5 cont.
Submit documentation to Central Office Production for coordination with Ohio EPA
Ohio EPA will consider each project with ODOT and determine possible options that will resolve non-compliant areas of a project
Global settlement
Mitigation within the same watershed
Experience will provide us a better understanding of how this will work. So far, the few projects coordinated through OEPA have been relatively successful (D-7, D-1, D-6 (Darby))

12. Notable changes in January 2008 edition of L&D Volume 2
Stream Protection –
Bankfull culvert design method
“Water quantity”/”Stream Protection”
Added additional cross-section through culvert section to allow better bankfull culvert comparison.
Stream Protection is “water quantity” protection in OEPA’s vocabulary. Section 1105 provides options for culverts provides exemptions for water quantity.

13. Notable changes in January 2008 edition of L&D Volume 2
Notice of Intent (NOI) – 1112
Projects with estimated contractor and Project Earth Disturbed Area (EDA) less than one acre do not require an NOI or post-construction BMP
Updated Figure (NOI Calculator)
OEPA has been receiving many NOI applications (each at 4.9 acres) which cost ODOT $500 each for projects that have less than one acre EDA. Saves administrative time that ODOT was spending filing NOI and NOT. In addition to $500 per application. OEPA does not require coverage for projects less than one acre. Therefore, changes have been made. Since it is not a huge blanket, there may be some initial missteps, but they should be small and few in number.

15. Notable changes in January 2008 edition of L&D Volume 2
Notice of Intent (NOI) – 1112 cont.
Example #1: Bridge replacement project with 0.5 acres of Project EDA and an estimated 0.2 acres of Contractor EDA
Add SS832 and Item 832 Erosion Control (each) to plans
SWPPP quantity is not needed
NOI is not needed
No coverage under Construction General Permit required. 404/401 still an issue if waterway involved.

16. Notable changes in January 2008 edition of L&D Volume 2
Notice of Intent (NOI) – 1112 cont.
Example #2: Bridge replacement project with 0.7 acres of Project EDA and an estimated 0.25 acres of Contractor EDA
Add SS832 and Item 832 Erosion Control (each) to plans
Based on site conditions, work type, etc., determine level of confidence with Contractor EDA estimate
If the Contractor EDA could reasonably exceed the estimate and result in the total EDA being greater than 1 acre
Provide a Project Site Plan, Item 832 SWPPP (Lump Sum), Item 832 Erosion Control (Each), and file the NOI
Need to use judgment. Is there a receiving water nearby. Are there wetlands or other sensitive environmental resources? If so, err on the side of caution. If not, and feel comfortable with the estimate, proceed without an NOI.

17. Notable changes in January 2008 edition of L&D Volume 2
Notice of Intent (NOI) – 1112 cont.
Example #2 Variation: Bridge replacement project with 0.7 acres of Project EDA and an estimated 0.25 acres of Contractor EDA
It is determined that 0.25 is a reasonable estimate for Contractor EDA
However, the Contractor uses more area and the resulting EDA is greater than one acre.
What happens now?
SS 832 is being updated. The update will require the Contractor to file the NOI and obtain the Permit, if he cannot constrain his operations to what is shown on the title sheet.
This is the scenario that could cause small problems. However, with small construction projects, the Contractor EDA will rarely be very large (not much earthwork) and therefore exceeding the estimated should not be common. Language in the new SS832 will encourage the Contractor to stay within estimated EDA.

18. Notable changes in January 2008 edition of L&D Volume 2
Notice of Intent (NOI) – 1112 cont.
Routine Maintenance Activity list provided
Multiple part and non-contiguous projects
Non-contiguous projects separated by at least ¼ mile can be considered separate
Non-contiguous multiple part projects can be considered with respect to each part

19. Notable changes in January 2008 edition of L&D Volume 2
Notice of Intent (NOI) – 1112 cont.
Watershed Specific Permits
Big Darby Creek and Olentangy River
Additional requirements
Groundwater
Riparian Setback
Temporary Sediment Basin Locations
Coordinate with Central Office Production
Different submittal procedure required. OEPA wants to review initial draft of SWPPP/Project Site Plan prior to approval of the NOI and granting coverage. ODOT has worked through this process on one project so far. While it has taken time, the results were favorable and future endeavors should be more efficient.

20. Notable changes in January 2008 edition of L&D Volume 2
Post-Construction BMP – 1115
Post-construction BMP requirements apply to ODOT and LPA projects
Redevelopment vs. New Development
Area within existing ODOT right-of-way is considered impervious for BMP calculations

21. Notable changes in January 2008 edition of L&D Volume 2
Post-Construction BMP – 1115 cont.
Options for locating BMP based on treating 100% water quality for 20% of the Project EDA (redevelopment)
Water quantity treatment not required when less than 1 acre of new impervious area created
Examples of 100% for 20% EDA to follow.
Exemptions in Section relate to Water Quantity only. Water quality BMPs are still required.

22. Notable changes in January 2008 edition of L&D Volume 2
BMP Selection and Submittals – 1116
Submittals to Central Office Production
Conceptual layout
Plan sheets with BMP located
Calculations/documentation
No treatment for areas with sheet flow off roadway and outside ODOT right-of-way

23. Notable changes in January 2008 edition of L&D Volume 2
BMP Toolbox – 1117
Exfiltration Trench
Updated Figure
Manufactured Systems
Not suitable for large trunk sewers
Depth limitations due to maintenance
Permit Reviews – Watch for use of manufactured systems on ODOT maintained roadways. Verify maintenance accessibility.
More information on manufactured systems on projects will follow. Be careful with design. Think about maintenance.

24. Notable changes in January 2008 edition of L&D Volume 2
BMP Toolbox – 1117 cont.
Vegetated Biofilter
No conveyance ditch
No energy protection area
Bottom width determination (ignore rounding)
Use the entire contributing drainage area (No incremental treatment)
Maximum ditch bottom width of 10 feet
Updated Anti-Seep collar design requirements

25. Local-let and ODOT-let LPA Projects
ODOT files the NOI
ODOT should ensure post-construction BMP provided meeting Ohio EPA expectations
LPA should be made aware of BMP requirements and maintenance responsibilities
We cannot ignore the requirements of the CGP. If we can meet the Permit and avoid placing the BMP within LPA R/W, this is fine. However, we must meet the permit.

26. Local-let and ODOT-let LPA Projects
Local-let LPA projects
Local agency files the NOI
The LPA is responsible for providing post-construction BMP that meet Ohio EPA expectations (may use L&D Volume 2 or other EPA approved guidance)
ODOT’s global settlement negotiations do not apply to local-let LPA projects that cannot meet BMP requirements
The LPA must coordinate with Ohio EPA when deficiencies are identified

27. Local-let and ODOT-let LPA Projects
BMP Project Scenarios Document
This document should no longer be used as a guideline
Post-construction BMP apply to the entire project with the exception of privately owned property (non-municipal)
Private owner – Drive relocations do not need exfiltration trenches or VBF. Not going to require private property owner to maintain a BMP.

28. BMP Design Approach Using Redevelopment/Treatment Percent reduction
New Construction Projects
Calculate treatment percent (T%)
Minimum T% is 20%
Redevelopment Projects
20%

29. BMP Design Approach BMP Design Options Redevelopment projects
Provide 100% treatment for an area equal to 20% of the Project EDA
Provide 20% treatment for the entire project.
New construction projects
Provide 100% treatment for an area equal to T% of Project EDA
Provide T% treatment for the entire project.

30. BMP Design Approach Vegetated Biofilters
The entire project does not require wider ditches
Water quality credit earned for drainage area within ODOT right-of-way
Once area credit equals or exceeds the 20% or T% requirement, no further treatment is needed

31. Vegetated Biofilter Example (Redevelopment)

32. BMP Design Approach Exfiltration Trenches (ExT)
Option #1 – Use 20% or T% of the required ExT length for the entire project
Requires all inlets, catch basins, etc. to provide an exfiltration trench or other BMP treatment

33. BMP Design Approach Exfiltration Trenches (ExT) cont.
Option #2 – Use 100% of the calculated ExT length based on Section and provide treatment for ODOT R/W area that equals or exceeds 20% or T% of the Project EDA.
Allows the locations of BMP to be chosen when there are restrictions preventing BMPs at all inlets.

34. Exfiltration Trench Example (Redevelopment)

35. BMP Design Approach Manufactured Systems
Option #1 – Calculate Water Quality Flow (WQf) and multiply the WQf by 20% or T%.
Entire contributing drainage area to the point in the storm sewer shall be used
Treat the entire project - Any project areas not tributary to this manufactured system must be drained to a BMP that will provide 20% or T% treatment

36. BMP Design Approach Manufactured Systems
Option #2 – Calculate Water Quality Flow (WQf)
Entire contributing drainage area to the point in the storm sewer shall be used
Treat drainage area with a minimum area equal to 20% or T%, with no reduction in the calculated WQf.
Water quality credit only applies to area within ODOT R/W, but BMP must be sized for entire contributing drainage area

37. Number of manholes in 100’ area. Depth of storm sewer
Number of manholes in 100’ area. Depth of storm sewer. Could we have moved to a more shallow location and provided more reasonable maintenance accessibility? Village did not have a vac truck to maintain. Likely will not be maintained. Try to avoid. Provide a BMP that can be maintained. Future audits by OEPA may result in fines for non-compliance.

38. Manufactured Systems

39. BMP Submittals Section 1116.2
Consideration of post-construction BMPs needs to happen early in the design process to allow for utilities and right-of-way issues to be addressed.
Early coordination with Ohio EPA will prevent fines, additional consultant costs, change orders and possible delays during construction.

40. BMP Submittals Major Projects
Conceptual layout with Step 6 (AFA) – Required review and comment through C.O. Production
BMP Design with Step 8 (Stage 1) – Required review and comment through C.O. Production
Refinements to Conceptual Layout may be submitted with Step 7 (PAVR)

41. BMP Submittals Minor Projects
Conceptual layout with Step 3 (PE) – Optional review and comment through C.O. Production
BMP Design with Step 4 (Stage 1) – Required review and comment through C.O. Production

42. BMP Submittals Contents of submittals at Stage 1 Estimated Project EDA
Pre and Post Runoff Coefficient
Pre and Post Impervious Area
BMPs selected
Calculations for BMPs
Plan sheets showing location of BMPs
Explanation for areas that were not treated

43. BMP Submittals Project Site Plan – Stage 3
Post-construction BMPs should be addressed on the Project Site Plan
Graphics
Tables
Cross-references to specific sheets or details
Narrative, if needed
Ohio EPA are not transportation/construction engineers. They are capable of reading plans, but they can do their jobs more efficiently if we provide a standardized location for BMP information.

44. BMP Submittals Projects that are not fully compliant
C.O. Production will discuss with the District and Consultant.
If necessary, a meeting with Ohio EPA will be held to determine whether additional mitigation is required.
Not wanting to obtain r/w for a project will not be acceptable to OEPA.

45. Issues during Construction
What happens when Ohio EPA issues a Notice of Violation (NOV) that cites a post-construction deficiency?
District should determine if post-construction BMPs were incorporated into the plans
If post-construction BMPs are shown in the plans, District shall obtain the calculations
District shall determine whether the BMPs shown in the plans were designed according to the Jan L&D Manual Vol. 2
If deemed compliant, forward calculations to Ohio EPA
If deemed non-compliant, forward to C.O. Production for coordination with Ohio EPA

46. Post-Construction BMP Training
Training for Post-Construction BMPs
Districts
Need to take the lead in communicating changes with BMPs for plans actively in design
Districts should coordinate with Central Office for assistance on unique situations
Consultants
Submittals, reviews, and experience should identify any potential training needs
Future training may be needed, but minimum benefit now
Districts will take lead in communicating changes in BMPs for plans actively in design.

47. Coming soon…. Renewal of Construction General Permit
Draft version available for public comment
Anticipated that the Permit will be effective in April 2008
Minor changes to post-construction
Draft Permit allows mitigation off-site (must be negotiated with Ohio EPA)
Covered by January 2008 L&D Vol. 2 updates

48. Coming soon…. SS832 revision
Addressing changes to Construction General Permit and January 2008 L&D Volume 2
Anticipated update in first half of 2008
NOI – Figure

49. Coming soon…. L&D Volume 3 Update
Addressing changes to January 2008 L&D Volume 2
Anticipated update in first half of 2008

50. Coming soon…. Olentangy Watershed Permit
Final version yet to be completed by Ohio EPA
Anticipated that the Permit will be effective later in 2008
Riparian Setback modifications
Temporary Sediment basins
Coordinate through Central Office Production

51. Summary Follow Implementation Plan for all projects
Provide BMPs for Local-let and ODOT-let LPA Projects
Revisions allow flexibility in locating Vegetated Biofilters, ExTs, etc.

52. Summary
No NOI or post-construction BMP for projects with less than one acre of total EDA
BMP Submittals to Central Office Production are required
Notice of Violation letters require prompt response

53. January 28, 2008 BMP Meeting Any Questions or Comments?
Questions/Suggestions regarding Post-Construction BMPs
Mike Wawszkiewicz
ODOT C.O. Production