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SWMP Annual Report

Small MS4 Annual Report for Year: 2021

Ohio EPA Facility Permit Number: 4GQ00000*CG

Name of MS4: Ohio Department of Transportation

Primary Contact: Becky Humphreys

Title: Stormwater Program Manager

Mailing Address: 1980 West Broad Street; Mail Stop 5220

City: Columbus

Zip Code: 43223

County: Franklin

Telephone Number: 614-387-1125

Email Address: Becky.Humphreys@dot.ohio.gov

 

Include or attach a Table of Organization. Indicate who (name and contact information) is responsible for overall management and implementation of your program, and if different, each minimum control measure of your program. Identify how development and implementation across multiple positions, agencies and departments

occur. Also, identify any Memorandum of Understandings (MOUs) or other such agreements that exist.

The Office of Hydraulic Engineering (OHE) is responsible for ODOT’s Stormwater Management (SWM) program oversight, management, and reporting. OHE coordinates with the other offices, divisions, and districts to implement and report on SWM program operations, effectiveness, and compliance. ODOT’s Table of Organization is included in Appendix A.

ODOT has twelve districts, and each district has an MS4 Liaison to assist OHE with implementing and reporting SWM program practices and activities. The MS4 Liaisons, along with representatives from other ODOT offices, report MS4 implementation activities to OHE and work with district staff to collect program information annually.

THE TABLE OF ORGANIZATION IS INCLUDED IN APPENDIX A.

The Office of Hydraulic Engineering (OHE) is responsible for ODOT's Stormwater Management (SWM) program oversight, management and reporting. OHE coordinates with the other offices, divisions and districts to implement and report on SWM program operations, effectiveness and compliance. ODOT's Table of Organization is included in Appendix A.

ODOT has twelve districts and each district has an MS4 Liaison to assist the OHE with implementing and reporting SWM program practices and activities. The MS4 Liaisons, along with representatives from other ODOT offices, report MS4 implementation activities to the OHE and work with district staff to collect program information annually.

MCM 1: Public Education and Outreach

ODOT implements a public education program to distribute educational materials to its employees, contractors, consultants, and facility users.

ODOT also conducts outreach activities associated with the impacts of stormwater discharges on water bodies and information that their employees, contractors, consultants, and facility users can take to help ODOT reduce pollutants in stormwater runoff.

Responsible Offices / Position

  • Hydraulic Engineering
  • Construction Administration
  • Maintenance Operations
  • Facilities Management
  • Alternative Delivery
  • Communications
  • Training

Performance Standards

ODOT’s stormwater public education and outreach program includes more than one mechanism and targets at least five  different stormwater and drainage themes or messages over the permit term through multiple manuals and guidance documents. ODOT, as a non- traditional MS4, is required to provide educational materials and outreach to employees, contractors, consultants, and facility users. ODOT shall reach at least 50% of the target audience over the 5-year permit term.

ODOT's Public

•    Employees
•    Contractors
•    Consultants
•    Facility Users
 

Decision Process

ODOT's public education and outreach decision process is centered on continuous revisions and updates to policies, manuals, specifications, procedures, website content, as well as internal and external training. This is ODOT’s primary means of communicating with their public.

ODOT’s public must keep current with changes and revisions as part of their expected duties and activities to perform planning, environmental studies, roadway design, construction, operations, or maintenance activities for ODOT’s assets.

Rationale Statement

ODOT’s public education and outreach practices will be used to reach ODOT’s targeted audiences through the publications identified in BMP 1.1.    ODOT will continue to update, revise, and provide training opportunities, as summarized in BMP 1.4, and collect information on attendance and participation. ODOT will also continue to implement mechanisms such as storm drain stamping (BMP 1.2). ODOT uses the website for additional information sharing (BMP 1.3) to continue to provide stormwater program updates and messaging to ODOT’s public.

BMPs for MCM 1

1.1    Publications
1.2    Storm Drain Stamping
1.3    Stormwater Management Program Website
1.4    Training and Presentations
 

BMP 1.1: Publications

BMP 1.1: Publications

MCM 1

Responsible Parties: Hydraulic Engineering, Construction Administration, Maintenance Operations, and Facilities Management

 

 

Measurable Goal(s):

Document publications that were revised during the reporting year.

Effective Yes, ODOT continually assesses and updates their publications. ODOT’s audiences are required to stay current with

these documents as part of doing business with ODOT.

Document feedback and information collected from ODOT’s target audiences.

Effective: Yes, ODOT annually collects program information and feedback from multiple offices and departments to support development of the Annual Report. In addition, ODOT employees

regularly contribute updates to ODOT’s Master List of Publications cited below.

Target Audience: ODOT employees, Consultants and Contractors

Permit Goal 50% of Target Audience Reached: Yes

Master List of Publications 

These publications are maintained for ODOT’s public:

  • Location and Design Manual Volumes 1, 2 and 3
  • ODOT Construction and Material Specifications
  • ODOT Supplemental Specifications (832)
  • ODOT Hydraulic Standard Construction Drawing
  • ODOT Construction Administration Manual of Procedures
  • ODOT Stormwater Best Management Practices - Inventory, Inspection, and Maintenance Guidelines 2.01
  • Ohio Maintenance Operations Manual
  • Roadway Infrastructure Maintenance Responsibility Manual
  • ODOT Highway Operations Environmental Manual
  • ODOT BMP Calculation Spreadsheet
  • ODOT Post-Construction BMP Presentations
  • ODOT Post-Construction BMP Design Examples
  • ODOT Post-Construction BMP Review Checklist
  • ODOT Stormwater Management Plan
  • ODOT Stormwater Management Program - Annual Report
  • ODOT MS4 Stormwater Outfall Inventory Manual

2021 Program Activities 

These publications were updated in the reporting year:

  • Location and Design Manual Volumes 1, 2 and 3 
  • ODOT Construction and Material Specifications
  • ODOT Supplemental Specifications (832)
  • ODOT Hydraulic Standard Construction Drawing
  • ODOT Construction Administration Manual of Procedures
  • ODOT BMP Calculation Spreadsheet
  • ODOT Post-Construction BMP Presentations
  • ODOT Post-Construction BMP Design Examples
  • ODOT Post-Construction BMP Review Checklist
  • ODOT Stormwater Management Plan
     

2022 Proposed Program Activities and Schedule 

The following publications have planned updates:

•    Location and Design Manual Volumes 1, 2 and 3
•    ODOT Construction and Material Specifications
•    ODOT Supplemental Specifications (832)
•    ODOT Hydraulic Standard Construction Drawing
•    ODOT Construction Administration Manual of Procedures
•    ODOT BMP Calculation Spreadsheet
•    ODOT Post-Construction BMP Presentations
•    ODOT Post-Construction BMP Design Examples
•    ODOT Post-Construction BMP Review Checklist
•    ODOT Stormwater Management Plan

Updates are planned, based on the following schedules:

  • Location and Design Manual Volumes 1, 2 and 3 are updated biannually (January and July).
  • ODOT Construction and Material Specifications are updated quarterly.

The remaining program publications are updated as needed to address policy, regulatory or procedural changes at ODOT or Ohio EPA. There is no formal schedule for updating or revising these program elements.

BMP 1.2: Storm Drain Stamping

BMP 1.2: Storm Drain Stamping

MCM 1

Responsible Parties: Hydraulic Engineering, Construction Administration, Maintenance Operations, and Facilities Management

 

Measurable Goal(s):

New and replacement stormwater grates and castings are to be pre-stamped.

Effective: Yes, ODOT has developed standard drawings incorporating storm drain message as part of the standard pay item for drainage

structures on construction projects statewide.

Standard hydraulic construction drawings provide stamped message requirements

Effective: Yes, ODOT continues to maintain and update the standards as needed.

Target Audience: ODOT Employees, Consultants and Contractors

Permit Goal: ODOT uses this practice to educate ODOTs audience and requires use of this storm grate for new and replacement stormwater grates.

2021 Program Activities 

Standard Construction Drawing (SCD)

ODOT projects continue to incorporate pre-stamped grates on all new and re-development roadway, maintenance and facility projects.

Standard Construction Drawing includes requirements for grate stamping “Drains to Waterway.” All new drainage structures are inspected for compliance with the SCD when they are constructed/installed.

2022 Proposed Program Activities and Schedule

  • ODOT will continue this program practice in 2022 and revise the SCD as needed.
  • The pre-stamped message will be included on all new and replacement stormwater grates.

Dump No Waste - Drains to River

BMP 1.3: Stormwater Management Program Website

BMP 1.3: Stormwater Management Program Website

MCM 1

Responsible Parties: Hydraulic Engineering and Communications

 

Measurable Goal(s):

Maintain all website links to other sources

Effective: Yes, Links on webpage need to be tested semi-annually to verify they are still active and updated as necessary.

MS4 program and additional ODOT stormwater information archived and updated annually

Effective: Yes, MS4 program and additional ODOT stormwater information updated throughout the year as needed.

Target Audience: ODOT Employees, Consultants and Contractors

Permit Goal: ODOT uses the SW website to keep their audience informed.

2021 Program Activities 

Website Updates - The following activities were completed:

  • Post-construction BMP inspection and maintenance training materials added to webpage
  • 2020 annual report uploaded to webpage
  • 2021 Stormwater Management Plan (SWMP) uploaded to webpage
  • A cross check of links on the website was conducted to verify they are active
  • Updated the District MS4 Liaison Contacts

2022 Proposed Program Activities and Schedule

  • ODOT website will be updated with Proposed Program Activities and Schedule

BMP 1.4: Training and Presentations

BMP 1.4: Training and Presentations

MCM 1

Responsible Parties: Hydraulic Engineering, Construction Administration, Maintenance Operations and Facilities Management

 

 

 

Measurable Goal(s):

Incorporate stormwater elements into appropriate ODOT training modules, sessions or workshops

Effective: Yes, ODOT has a robust training program and has incorporated stormwater and water quality information into new

and existing training modules as feasible.

Identify stormwater training needs annually

Effective: Yes, Central Office and the MS4 Liaisons identify stormwater training needs.

Document ODOT- led stormwater/water quality presentations to the public

Effective: Yes, ODOT will continue to conduct stormwater training for ODOT’s public through multiple outlets.

Name of training and number of employees

attending training

Effective: Yes, ODOT can effectively document attendance.

Target Audience: ODOT Employees, Consultants and Contractors

Permit Goal 50% of Target Audience Reached: Yes

2021 Program Activities

Employee Presentations - ODOT employees presented at national, statewide, and local conferences.

Name of Conference

Presentation Name

Year: 2020

Target Audience

Conaway Conference     Environmental and Hydraulics Update     03-01     Contractors, designers, internal staff

ODOT Employee Training - ODOT employees attended training.

Training Name

# of attendees

HT.105 Snow & Ice Control

208

HT.110 Basic Structures

76

HT.113 Regulated Waste Removals and HAZWOPER Awareness

180

HT.115 Highway Roadside

83

HT.202 Basic Highway Plan Reading

98

HT.405 Environmental Policy Overview

17

Winter Construction School D9

60

Winter Construction School D6

100

Winter Construction School D3

90

SWPPPTrack Training

70+

SWPPPTrack Training for MS4 Liaisons

15

ODOT Employee online training

 

Training Name

# of attendees

SWPPP training

1603

MS4 Liaison Training

5

Snow and Ice Operations

297

Herbicide Applicator Recertification

197

2022 Proposed Program Activities and Schedule

  • ODOT will conduct a similar training and presentation schedule.
  • ODOT will publish an on-line self-paced training on inspection and maintenance of post construction BMPs.

MCM 2: Public Involvement / Participation

ODOT’s public involvement/participation programs engages ODOT employees, contractors, consultants and academia through several programs and participation opportunities.

Responsible Office/Position

  • Division of Planning
  • Hydraulic Engineering
  • Construction Administration
  • Maintenance Operations
  • Districts
  • Planning and Research

Performance Standards

ODOT’s stormwater public involvement/participation program shall include, at a minimum five public involvement activities over the five-year permit term.

Decision Process

A significant portion of ODOT's public involvement/participation control measure is centered on the success of the Adopt-A-Highway (AAH) program, which is supported through public involvement of groups or individuals participating in roadside litter collection. In addition, ODOT also involves their public through funded research that engages academia and consultants.

Rationale Statement 

ODOT’s continued involvement with the AAH, Keep Ohio Beautiful (KOB), educational workshops and research helps increase awareness of litter being a ‘pollutant of concern’ associated with stormwater runoff. Memberships in local, statewide and national committees provides ODOT access to these organizations and allows ODOT to gain an understanding of their peers’ stormwater programs and resources.

ODOT has a robust research program in the Division of Planning. The program strives to anticipate and address a range of agency needs to provide effective and applied solutions. ODOT sponsors multiple research projects covering a wide range of departmental and district needs that have included stormwater and water quality projects/activities.

BMPs for MCM 2

2.1    Public Involvement Programs
2.2    Stormwater Research
 

BMP 2.1: Public Involvement

BMP 2.1: Public Involvement

MCM 2

Responsible Parties: Hydraulic Engineering, Maintenance Operations and District AAH Coordinator

 

 

 

 

Measurable Goal(s):

Attend Keep Ohio Beautiful (KOB) meetings.

Effective: Yes, ODOT, continues to be active with KOB and supports statewide activities annually.

Maintain the Memorandum of Agreement (MOA) with the Ohio Department of Rehabilitation and Corrections

(ODRC).

Effective: Yes, MOA in place with many institutions eligible to participate.

Facilitate AAH activities in every county throughout Ohio.

Effective: Yes, ODOT actively coordinates AAH cleanup efforts.

National committees with ODOT employee members [Transportation Research Board (TRB) and American Association of State Highway and Transportation

Officials (AASHTO)].

Effective: Yes, ODOT has members on the several committees. Continue to share committee information.

Target Audience: ODOT Employees and Facility Users

2021 Program Activities

AAH participants –AAH groups continued to participate in 2021, 12 of the 12 districts recorded active AAH groups.
ODRC – 2020 saw a decrease in the number of institutions participating in the program, 11 districts reported active ODRC trash pick-up.
 

Bags of trash removed

 

Committee involvement – ODOT is involved with national and statewide committees related to water quality.

Name of Committee

OSWA - Transportation Sub-Committee

AASHTO Committee on Environment and Sustainability

TRB AKD50 - Standing Committee on Hydrology, Hydraulics, and Stormwater

2022 Proposed Program Activities and Schedule 

  • ODOT will continue to operate and promote AAH program.
  • ODOT will continue to maintain the MOA with ODRC.
  • ODOT will continue involvement with KOB.
  • Participation in department-wide programs to reduce roadside litter will continue.

BMP 2.2: Stormwater Research

BMP 2.2: Stormwater Research

MCM 2

Responsible Parties: Division of Planning (Statewide Planning and Research), Maintenance Operations, Construction Administration, and Hydraulic Engineering

 

 

 

 

Measurable Goal(s):

Continue to identify and develop stormwater and water quality research needs and problem

statements to be reviewed and scored for possible funding.

Effective: Yes, ODOT uses research to provide applied solutions to staff identified needs.

Continue to implement completed stormwater research solutions to increase program

efficiencies and address permit requirements.

Effective: Yes, ODOT needs to continue to implement research findings into planning design, construction, operations, and

maintenance activities.

Continue to review completed research (in-state or national) for stormwater and water quality improvement opportunities, concepts to increase

efficiencies and innovative ideas to improve roadway stormwater runoff quality.

Effective: Yes, ODOT needs to continue to assess national research findings to ascertain elements that could be incorporated into design, construction, operations and maintenance practices, policies, programs or procedures.

Target Audience: ODOT Employees, Consultants and Contractors

2021 Program Activities 

ODOT’s research program provides decision makers and staff with the information and tools they require to ensure Ohio's transportation system meets the evolving needs of ODOT’s public. The program works to anticipate and address concerns to provide effective and applied solutions. ODOT sponsors multiple research projects covering a wide range of departmental and district needs that have included stormwater and water quality projects/activities/guidance manuals and equipment purchase. Ongoing research is vital for providing ODOT with state of the practice, practical and implementable solutions for identified operational, maintenance or system performance needs and to continue meeting the “State of Good Repair” objectives.

Active ODOT Sponsored Research Projects

Project Title

Assessment of Existing and Potential Volume Reduction for Post Construction Stormwater Management

Evaluate replacement of current post-construction groundcover with pollinator beneficial groundcover

Inlet Protection Comparison for Sediment Control on Roadway Construction

Engineering ROC Detention Basin Water Quality Outlet Redesign

Roadside Vegetation Aesthetics

Efficient and Effective Ways to Manage Water through ODOT’s Temporary Access Fills during Construction

Benefit Analysis of Barrier Inlet Screens

Fiscal Years 2022-2023 Proposed Program Activities and Schedule

Proposed or Research In Progress (RiP) Projects

ODOT has 2 options through which to conduct research. The first option is ODOT’s Strategic Research Plan Projects (SRPP) identified internally within ODOT. The second option is ODOT’s Ohio Research Initiative for Locals (ORIL). ODOT has set schedules for each of these research programs. The SRPP advertises for projects in January with proposals due in March. ORIL collected potential research ideas between April and November and advertises for proposals in March. The table below summarizes the current water quality or stormwater related research that is in progress or scheduled for the next reporting year.

 

 

Proposed projects for Fiscal 2021

RFP

Project Title

Technical Office

End Date

2022-06

Improving Traps/Basins on ODOT Construction Projects

Construction Administration and Hydraulic Engineering

Spring 2022

MCM 3: Illicit Discharge Detection and Elimination

ODOT implements and enforces a program to detect and eliminate illicit discharges. When a possible illicit discharge is discovered, ODOT will attempt to determine the source and nature of the discharge. ODOT will, as necessary, contact the local health department and/or the neighboring MS4 to assist with elimination of the source and provide follow up documentation that the removal is complete or has been addressed. ODOT’s Office of Chief Legal Counsel may provide assistance as part of ODOT’s illicit discharge elimination process.

Responsible Office / Position

  • Hydraulic Engineering
  • Technical Services
  • Construction Administration
  • Maintenance Operations
  • Facilities Management
  • Districts

Performance Standards

ODOT is continuing their current approach of long-term system-wide surveillance that includes investigations of sources detected during maintenance or construction operations associated with the outfalls and roadside ditches within the MS4 area. As reported by the districts or public, data collected each year is evaluated and priorities and goals shall be revised annually based on this evaluation.

Decision Process

MCM 3 requires mapping of the system. Traditional municipal (Urban Areas – Cities, Counties and Townships) based storm sewer system mapping is not practical for ODOT's non-traditional owner-operated MS4. ODOT maintains record plans for every roadway or bridge project constructed for ODOT statewide. The record plans are available to ODOT’s public through a records request. Connection points to the system are included on the roadway or bridge construction plans.

Rationale Statement

ODOT maintains databases of construction plans at each district office. These plans contain storm system and project drainage design details which make up ODOT’s comprehensive storm sewer system and outfall mapping. The location of existing household sewage treatment systems (HSTS) discharging to ODOT’s Rights of Way at the time of construction are also documented within these plans.
ODOT actively maintains a stormwater system asset inventory database, which includes the location of stormwater systems, post- construction BMPs, culverts, and outfalls. ODOT’s public assists with identification of illicit discharges during annual asset inventory, assets inspections, design, construction, or maintenance activities. ODOT’s stormwater outfalls have been identified and are available to the public through TIMS.

BMPs for MCM 3

3.1    Stormwater Outfall and System Mapping
3.2    Illicit Discharge Detection, Reporting, and Removal

BMP 3.1: Stormwater Outfall and System Mapping

BMP 3.1:  Stormwater Outfall and System Mapping

MCM 3

Responsible Parties: Hydraulic Engineering, Technical Services, District Hydraulic Engineer, District Public Relations Officer and MS4 Liaison

 

Measurable Goal(s):

Maintain record project plans.

Effective: Yes, ODOT maintains record plans of all construction projects. These record plans are readily available to ODOT’s public.

Maintain ODOT’s outfall locations map via TIMS.

Effective: Yes, ODOT updates TIMS throughout the year as projects

are constructed.

2021 Program Activities

Mapping Updates -
ODOT had 180 active construction projects in 2021. The construction project record plans serve as the basis for ODOT’s MS4 and outfall mapping. Culverts, bridges, storm sewers and outfalls are located as points in TIMS and the point locations are available through TIMS to the public. MS4 Liaisons review record plans and update TIMS, if necessary. MS4 Liaisons provided a total number of projects with outfall revisions for their district that are presented below.

 

TIMS Outfall Revisions by District

 

Number of Outfall Revisions

Total

6

2022 Proposed Program Activities and Schedule 

  • MS4 Liaisons will coordinate public requests for construction plans and identify and report on TIMS updates as needed.
  • MS4 Liaisons will continue to provide a total number of projects with outfall revisions for their district on an annual basis.

SWMP Revisions for new MS4 Permit
Revise factsheet to include Post Construction BMP information.
 

BMP 3.2: Illicit Discharge Detection, Reporting, and Removal

BMP 3.2: Illicit Discharge Detection, Reporting, and Removal

MCM 3

Responsible Parties: District MS4 Liaison, Hydraulic Engineering, Construction Administration, ODOT Personnel, and District Right of Way staff

 

 

 

 

Measurable Goal(s):

Dry weather flow investigations

Effective: Yes, ODOT will assess the procedures or protocols used to evaluate their dry weather flows to determine effectiveness and

make adjustments.

Document reported illicit discharge investigations.

Effective: Yes, ODOT will assess the procedures or protocols used to

evaluate their dry weather flows to determine effectiveness and make adjustments.

Document investigations that were sent to adjacent

interconnected MS4 and/or Local Health Department (LHD) as possible illicit discharges.

Effective: Yes, ODOT will assess the procedures or protocols used to

evaluate their dry weather flows to determine effectiveness and make adjustments.

Document illicit discharges removed by adjacent

interconnected MS4 and/or LHD.

Effective: Yes, ODOT will assess the procedures or protocols used to

evaluate their dry weather flows to determine effectiveness and make adjustments.

2021 Program Activities 

Illicit Discharges - ODOT established a process to investigate illicit discharges. Discharges discovered by ODOT personnel or reported through the website are investigated. ODOT attempts to determine the nature of the discharge. The local health department is informed, if the source of the discharge is undeterminable or from an HSTS. If the discharge is a possible illicit discharge from an adjacent interconnected MS4, then that MS4 entity will be notified.

Notified Discharge Investigations

 

 

 

 

Priority

 

 

Notified Discharges

 

Reported to Adjacent interconnected MS4

 

Reported to Local Health Department

 

 

Illicit Discharges Removed

Verified as not an outfall and

removed from inventory

Concern

0

0

0

0

0

Not a Concern

0

0

0

0

0

Total

0

0

0

0

0

Priority Outfalls - ODOT investigated a portion of the low priority dry weather outfall flows.

Dry Weather Flow Outfall Priority Investigations

 

 

Priority

 

 

Investigated

Illicit Discharges

Removed

Verified as not an outfall and removed

from inventory

Verified as having no dry weather

flow

Low

3

0

2

1

No flow

0

0

0

0

2022 Proposed Program Activities and Schedule

  • ODOT Central Office will continue to develop working relationships with the Local Health Departments.
  • MS4 Liaisons will investigate the remaining 7 low priority outfalls.

Remaining outfalls to be investigated

 

Dry weather screening

Priority

Outfalls

High

0

Medium

0

Low

4

Documentation Associated with Addressing Audit Commitment

Audit Commitment

Complete Date

Low priority dry weather flows to be field investigated and documented.

To be completed in 2021.

 

SWMP Revisions for new MS4 Permit

Revise factsheet to include new reporting requirements.

MCM 4: Construction Site Runoff Control

ODOT has a program to reduce or prevent pollutants associated with stormwater runoff originating from construction activities on ODOT projects. ODOT requires all projects greater than or equal to one acre to complete the following: obtain coverage under the Ohio EPA Construction General Permit (CGP); design, install, inspect, operate and maintain erosion controls, sediment controls; and control construction wastes/debris on ODOT projects statewide.

Responsible Office / Position

  • Hydraulic Engineering
  • Construction Administration
  • District Construction Personnel

Performance Standards

ODOT’s construction site stormwater control program shall include pre-construction stormwater pollution prevention plan (SWPPP) review for projects with construction activities greater than one acre in size. Applicable projects shall be inspected initially and weekly. The frequency of follow-up ODOT/SWPPP designer inspections shall be monthly, unless ODOT documents procedures for prioritizing inspections such as: waterways, disturbed area, site compliance, etc.

Decision Process

All projects requiring coverage under a CGP require a compliant SWPPP be developed/designed and the project construction site inspected by a Certified Professional in Erosion and Sediment Control (CPESC) or can be inspected by a CPESC or a Certified Erosion, Sediment, Stormwater Inspector (CESSWI). ODOT has incorporated these requirements as a Contract Item of Work as outlined in Supplemental Specification 832 (SS832). SS832 requires the SWPPPs to be prepared by an Ohio licensed Professional Engineer (P.E.) who maintains their CPESC credentials. These identified qualifications are intended to ensure that all SWPPPs are prepared by qualified, competent and experienced professionals.

Rationale Statement

ODOT’s construction stormwater program is led by the Office of Construction Administration. The majority of ODOT’s construction stormwater program is guided by ODOT SS832. As a contract mechanism SS832 allows ODOT to:

  • Require erosion and sediment controls be designed, installed and maintained on ODOT construction projects;
  • Include escalation clauses for enforcement; and
  • Combines SS832 with ODOT’s construction materials specification (CMS) Item 202 and Ohio EPA’s SWPPP checklist to address the construction site waste requirements.

BMPs for MCM 4
4.1    Preconstruction SWPPP Reviews
4.2    Inspection and Maintenance
4.3    Enforcement
 

BMP 4.1: Pre-Construction SWPPP Review

BMP 4.1: Pre-Construction SWPPP Review

MCM 4

Responsible Parties: Construction Administration, Hydraulic Engineering, District Construction personnel, and MS4 Liaison

 

 

Measurable Goal(s):

Number of qualifying projects requiring coverage under

a CGP in ODOT’s MS4 regulated area

Effective: Yes, ODOT obtained CGP coverage for qualifying

projects.

Number of SWPPPs reviewed by ODOT for qualifying

projects

Effective: Yes, ODOT reviewed SWPPPs for all qualifying

projects.

ODOT completes the qualifying projects via a project by

project review as to whether they are inside ODOTs Urbanized Area Boundary.

Effective: Yes, The information is captured and recorded in a

column via SWPPPTrack.

2021 Program Activities

SWPPP inspection software

ODOT uses an app based inspection software to track construction inspections. The software system enables ODOT to meet the intent of the permit language and manage compliance activities throughout the state.

SS832

ODOT requires a compliant SWPPP to be developed by the contractor around the selected means and methods of construction. ODOT identifies when a SWPPP is required as a contract item of work per SS832

NOIs and pre-construction SWPPP reviews

Pre-Construction SWPPP Review Activity

Number

Number of ODOT-let qualifying projects within MS4 area active in 2020 but began construction prior to 2021

44

Number of ODOT-let qualifying projects within MS4 area that began construction in 2021

49

Number of SWPPPs reviewed by ODOT within MS4 Area
*All projects that started during 2021 received an initial SWPPP review

61

20221 Proposed Program Activities and Schedule

MS4 Liaisons will use SWPPPTrack to verify SWPPP compliance beyond construction activities. In addition, ODOT will continue to use SWPPPTrack to verify and track project construction stormwater compliance.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
 

BMP 4.2: Inspections and Maintenance

BMP 4.2:  Inspections and Maintenance                                                                                  M

MCM 4

Responsible Parties: Construction Administration, Hydraulic Engineering, District Construction personnel, and MS4 Liaison

 

 

 

Measurable Goal(s):

Number of qualifying projects (within ODOT’s MS4 urbanized boundary area) receiving an initial

inspection

Effective: Yes, ODOT tracks these projects inspections through SWPPPTrack.

Number of qualifying projects (within ODOT’s MS4

urbanized boundary area) receiving required weekly and monthly inspections

Effective: Yes, ODOT tracks these project compliance

requirements through required SWPPPTrack information.

Number of qualifying projects (within ODOT’s MS4

urbanized boundary area) receiving ODOT technical process reviews

Effective: Yes, ODOT can track and document the project

receiving ODOT technical reviews through SWPPPTrack.

2021 Program Activities

SWPPP inspection software

To improve the site inspection reviews, ODOT has implemented a software inspection and tracking system. The software system will more efficiently enable ODOT to meet the intent of the permit language and manage compliance activities throughout the state.

SS832

Construction inspections are completed by qualified contractor personnel in accordance with SS832. The inspections are performed using an inspection software developed to ensure quality and consistency of reporting of each inspection. The P.E./CPESC who prepared the SWPPP reviews each inspection report and provides a monthly inspection update on the projects to ensure accurate SWPPP reporting.

Notice of Terminations

The districts reported submitting 90 NOTs to the Ohio EPA.

Central Office Quality Assurance Reviews (QARs)

ODOT Construction Administration provided 31 QARs of projects within the MS4 area.

Inspection and Maintenance Activities

Inspections Activity

Number

Number of qualifying projects within the MS4 Area that began construction in 2021

49

Number of qualifying projects within the MS4 Area that received an initial inspection
*All projects that began construction in 2021 received an initial inspection.

49

Number of weekly and monthly inspections completed on qualifying projects
*All projects under construction in 2021 received the required weekly/rain event and monthly inspections.

2,593

2022 Proposed Program Activities and Schedule

ODOT will continue to use an inspection app on construction projects statewide.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
 

BMP 4.3: Enforcement

BMP 4.3: Enforcement

MCM 4

Responsible Parties: Construction Administration, Hydraulic Engineering, District Construction personnel, and MS4 Liaison

 

Measurable Goal(s):

Number of Notice of Violations (NOVs) issued by regulatory agency

Effective: Yes, The NOVs were documented as received.

Number of written or e-mail notices issued by

ODOT

Effective: Yes, E-mail notifications issued by ODOT related to

enforcement of deficiencies were documented.

2021 Program Activities 

ODOT implements the contractor language in SS832 as the legal mechanism to enforce the construction permit-required erosion and sediment control practices. If ODOT or any government regulatory agency finds a non- compliant site condition, the contractor must correct and mitigate the conditions within 48 hours of notification.

Enforcement Actions

Enforcement

Number

Number of NOVs issued by regulatory agency

1

Number of written or e-mail notices issued by ODOT

147

 
2022 Proposed Program Activities and Schedule

  • ODOT will continue to implement SWPPPTrack on construction projects statewide.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
 

MCM 5: Post-Construction Stormwater Management

ODOT has implemented and enforced a program to address stormwater runoff from new development and redevelopment roadway projects that disturb greater than or equal to one acre on projects statewide.

Responsible Office / Position 

  • Hydraulic Engineering
  • Alternative Delivery
  • Construction Administration
  • Maintenance Operations
  • Facilities Management
  • District Hydraulic Engineer
  • Districts

Performance Standards

ODOT performs a pre-construction SWPPP review for projects that disturb greater than or equal to one acre. These projects shall be inspected to ensure that controls are installed per requirements. ODOT shall also ensure long-term operation and maintenance (O&M) of Post-Construction Best Management Practices (PCBMPs).

ODOT maintains compliance with these performance standards through specifications, manuals, training and policy updates.

Decision Process 

PCBMPs are reviewed by ODOT during the Stage 1 design plan review. ODOT inspects the PCBMPs during construction before they are accepted. ODOT locates these PCBMPs with Geographic Information Systems (GIS). ODOT inspects and maintains the PCBMPs.

Rationale Statement

ODOT incorporated PCBMP design requirements into its stormwater Location and Design Manual (L&D) Vol. 2. All projects designed using ODOT’s specifications shall incorporate the latest design criteria. The L&D Vol. 2 was incorporated into CGP for roadway construction projects by public entities.

BMPs for MCM 5
5.1    Design of PCBMPs
5.2    Operation and Maintenance of PCBMPs
 

BMP 5.1: Design of Post-Construction BMPs

BMP 5.1: Design of Post-Construction BMPs

MCM 5

Responsible Parties: Hydraulic Engineering, District Hydraulic Engineer, Construction Administration, Facilities Management, and MS4 Liaison

 

 

 

Measurable Goal(s):

Review post-construction BMPs for compliance with design standards within ODOT’s L&D vol. 2.

Effective: Yes, All ODOT projects are reviewed for compliance with the design standards.

Ensure all projects are designed with PCBMP as

required by the CGP or have properly

documented alternatives (i.e., in lieu-fee, regional controls or others as appropriate).

Effective: Yes, All ODOT projects are reviewed for compliance with

the design standards.

Inventory and track ODOT roadway and facility

PCBMPs.

Effective: Yes, All ODOT PCBMPs are inventoried in ODOT’s system.

PCBMP inspections and maintenance are tracked.

2021 Program Activities 

L&D-v2 Updates

Several sections of the L&D Vol. 2 were updated to provide clarification and/or consistency between sections.

PCBMP Asset Collector

After construction, each new PCBMP is added to the inventory using the Asset Collector application (app).

Mapping

The locations of the PCBMPs are available to ODOT’s public through records request or TIMS.

District Reviews

The Central Office reviewed projects for design requirements.

PCBMP Design Summary

 

Activity

Number

ODOT-let projects issued an NOI

34

ODOT-let projects designed with PCBMPs

82

ODOT-owned projects with PCBMPs input into BMP Database

57

Projects audited by Central Office, Office of

Hydraulic Engineering for PCBMPs

34

ODOT-owned projects with PCBMPs constructed

58

ODOT-owned PCBMPs constructed

211

New/redesigned ODOT facilities with PCBMPs

2

2022 Proposed Program Activities and Schedule

  • ODOT will continue to update the L&D Vol. 2 to optimize BMP implementation and address design, construction, and maintenance concerns.
  • ODOT will conduct various training classes to inform roadway designers of changes to PCBMP design requirements associated with the regulatory updates and associated updates to the L&D Vol. 2.
  • ODOT will continue to incorporate results from PCBMP inspection and maintenance reports and assess the need to adjust design requirements based on those results.
  • ODOT will incorporate results of various research projects associated with PCBMPs into L&D Vol. 2 BMP design criteria as appropriate.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
 

BMP 5.2: Operation and Maintenance of PCBMPs

BMP 5.2:  Operation and Maintenance of PCBMPs

MCM 5

Responsible Parties: Hydraulic Engineering, Construction Administration, Maintenance Operations, Facilities Management, and MS4 Liaison

 

 

 

 

Measurable Goal(s):

Continue updating PCBMP database throughout the year using the Collector application

Effective: Yes, All PCBMPs were included in the database, enabling efficient inspection.

Update the Post-Construction Stormwater BMP

Maintenance Guidelines as needed.

Effective: Yes, Manual was updated in February.

Document PCBMPs that were inspected per Post-

Construction Stormwater BMP Maintenance Guidelines.

Effective: Yes, 1944 PCBMPs were inspected and documented in the

collector App..

Document PCBMPs are maintained per Post-

Construction Stormwater BMP Maintenance Guidelines.

Effective: Yes, PCBMPs requiring maintenance were documented in

the collector App.

2021 Program Activities 

PCBMP Inventory/Inspection Manual

PCBMP inventory/inspection manual was finalized.

PCBMP Collector App

The PCBMP Collector app was used track inventory and inspections for each PCBMP. ODOT forces were used to conduct inspection and maintenance activities. Collector App updated in 2021 to better align with inspection/maintenance needs.

PCBMP Activity Summary

 

Activity

Number

PCBMPs inspected

1944

PCBMPs needing maintenance

333

PCBMPs maintained

87

PCBMPs constructed in 2020

270

2022 Proposed Program Activities and Schedule 

  • ODOT will inspect all PCBMPs annually.
  • ODOT will identify all PCBMPs needing maintenance and incorporate maintenance activities into county level work plans.
  • ODOT will refine maintenance practices for PCBMPs based on experience.
  • ODOT will update the PCBMP inspection and maintenance training to a self-paced on-line version.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
 

MCM 6: Pollution Prevention and Good Housekeeping

ODOT has developed and implemented a Facility SWPPP Inspection program that includes training and has a program goal of reducing or preventing pollutant-laden runoff from facility operations. This includes annual training for employees in Pollution Prevention and Good Housekeeping (PP/GH) practices associated with roadway and facility operations and maintenance best practices.

Responsible Office / Position

  • Hydraulic Engineering
  • Facility Management
  • Maintenance Operations

Performance Standards 

ODOT's PP/GH program includes annual employee stormwater pollution prevention and good housekeeping training. ODOT's Facility SWPPP includes program includes appropriate procedures, controls, maintenance schedules, and recordkeeping. The majority of ODOT’s training is collected, organized and reported as part of MCM1. The SWPPP trainings at the facilities are specific to PP/GH and include deicing material handling, storage and material cleanup and site-specific training.

Decision Process

ODOT has taken advantage of existing operations and maintenance practices to organize and develop their roadway and facility PP/GH program. These practices have been updated and incorporated into facility specific SWPPPs that are used by ODOT staff to reduce and prevent stormwater pollution from ODOT’s facilities. ODOT administers facility SWPPPs within the MS4 urbanized areas. All ODOT employees engaged in winter weather operations receive snow and ice training to improve the efficient use, handling and cleanup of deicing materials.

Rationale Statement

ODOT has developed SWPPPs for each of their facilities located within their MS4 urbanized areas. The plans include the following elements that comprise ODOT’s rationale statement:

  • Facility operations that require BMP implementation and reporting
  • Pollution Prevention Training
  • Practices for controlling runoff pollution at ODOT’s facilities
  • Responsible staff at each facility
  • Proper waste disposal

BMPs for MCM 6
6.1    Roadway Infrastructure
6.2    Deicing
6.3    Facilities
 

BMP 6.1: Roadway Infrastructure

BMP 6.1: Roadway Infrastructure

MCM 6

Responsible Parties:  Hydraulic Engineering, Maintenance Operations, Construction Administration, and Facilities Management

 

 

Measurable Goal(s):

Document the following pollution prevention/good housekeeping activities annually: storm sewer systems cleaned, catch basins cleaned, miles of roadway swept, bridge

deck cleaning and culverts maintained.

Effective: Yes, Using ODOT’s EIMS system, ODOT tracks work orders related to these PP/GH activities.

Document appropriate ODOT staff training

annually.

Effective: Yes, Staff received training. Refer to BMP 1.4

2021 Program Activities 

ODOT operates an Integrated Vegetation Management (IVM) program to properly manage impacts to the environment associated with vegetation management practices.

Number of flood control projects reviewed and approved: 0

Roadway debris removal

Removing sediment from the drainage structures, roadways via street sweeping and bridge deck cleaning prevents the material from discharging to the stormwater system.

Operations and Maintenance Activities

 

Activity

Units

Totals

Cleaning Drainage Structures:

catch basins, inserts, manholes and storm sewers

Each

118,835

Street Sweeping Performed

Miles

29,658

Bridge Deck Sweeping

Each

5,966

Bridge Cleaning

Each

1,229

2022 Proposed Program Activities and Schedule 

  • ODOT will emphasize both proper post-snow and ice operations and cleanup and proper material handling and storage during annual training.
  • ODOT will continue asset maintenance activities and document completed maintenance.
  • ODOT to begin revisions on the highway maintenance checklist program that incorporate the use of BMPs for limiting stormwater runoff from disturbed areas.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.

BMP 6.2: Deicing

BMP 6.2: Deicing

MCM 6

Responsible Parties:  Hydraulic Engineering, Maintenance Operations, MS4 Liaison and Facilities Management

 

 

Measurable Goal(s):

Maintain and continue to evaluate snow and ice practices and update current manual as necessary.

Effective: Yes, Optimizing the use of deicing material reduces stormwater run-off quality impacts.

Provide annual training to staff.

Effective: Yes, Employees involved with winter weather events

receive training annually.

Document facilities that modify salt storage

structures.

Effective: Yes, ODOT ensures that the annual training for each

facility incorporates the most appropriate controls.

2021 Program Activities 

Snow and Ice

Office of Maintenance Operations continues to develop deicing programs and conduct research for reducing product usage and optimizing deicing operations. Bollards or barriers were installed at facilities with liquid deicing storage tanks to provide protection to the tanks.

Water Quality

ODOT continues to assess application technologies, materials and delivery methods. As ODOT continues to look for more efficient materials and methods, which ancillary provide beneficial impacts to water quality.

Snow and Ice Training

ODOT conducts comprehensive employee training on the handling, storage and use of deicing materials. ODOT is committed to providing the traveling public with safe roadways as efficiently and effectively as possible.

Training Course

Employees Trained

HT.105 Snow & Ice Control

208

Snow and Ice Operations

297

2022 Proposed Program Activities and Schedule 

2021 Snow and Ice training will be completed prior to snow and ice season.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
Review and update ODOT's Ohio Maintenance Operations Manual, Volume II for deicing material permit requirements.
 

BMP 6.3: Facilities

BMP 6.3: Facilities

MCM 6

Responsible Parties:  Hydraulic Engineering, Maintenance Operations, MS4 Liaison and Facilities Management

 

Measurable Goal(s):

Maintain SWPPPs at facilities within ODOT’s MS4 Urbanized Area Boundary (MS4 area).

Effective: Yes, All applicable facilities within the MS4 area have active SWPPPs.

Respond to corrective actions found during the

quarterly or annual inspections.

Effective: No, ODOT is implementing a process to confirm

corrective actions are completed.

Provide annual training to staff.

Effective: Yes, SWPPP training was provided at all the facilities

within the MS4 area.

2021 Program Activities 

SWPPPs

All facilities within ODOT’s MS4 area are required to have an active SWPPP and annual training. There are 88 facilities located within the MS4 area. 14 of those locations are under construction, vacant or are used only for deicing material storage. The remaining 72 locations have active SWPPPs. All active SWPPPs were updated to comply with the NPDES Industrial Storm Water General Permit (OHR000006).

Training

Personnel at applicable facilities were assigned and received the on-line self-paced training.

Annual Inspection

Comprehensive annual inspections continue to be completed annually. The MS4 liaison shall begin to follow up with appropriate facility staff at a regular frequency via e-mail to document corrective actions have been completed.

SWPPP Training at facilities within MS4 Area

District

# Active SWPPPs

Employees Trained

Total

72

1603

Inspection Software and Corrective Actions
ODOT developed an application-based program for the monitoring required at the facilities. Corrective actions during the quarterly or annual inspections will be documented with the application

2022 Proposed Program Activities and Schedule

ODOT’s facilities within the MS4 area will continue to have a comprehensive inspection scheduled and completed annually.

ODOT will continue the use of an application-based program for the monitoring required at the facilities. Corrective actions during the quarterly or annual inspections will be documented with the application.

SWMP Revisions for new MS4 Permit
Revise factsheet to include new reporting requirements.
 

Appendix A

Table of Organization

TABLE OF ORGANIZATION -