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MDOT Illicit Discharge Elimination Program

• Together . . .Better Roads, Cleaner Streams

Our Cleaner Streams Mascot
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Todays Goals

• To Understand
• Which discharges are illicit (and which are not)
• Where and when illicit discharges may be
  encountered
• How to handle a reported illicit discharge
• Who is responsible for various tasks
• How to use the Reporting Database
• Annual reporting responsibilities
• Staff training

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Agenda

• MDOT Phase II Storm Water Program Overview
• Illicit Discharge Reporting
• Training Module
• IDEP Screening Update
• Summary

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ICE BREAKER!
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Is water from a Commercial Car Wash facility an
illicit discharge?

• A. Yes, Always
• B. Sometimes, only when polluted
• C. No, never

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Which one of the following best represents a
Municipal Separate Storm Sewer System?

• A. A bridge scupper drain
• B. A residential sump pump drain
• C. A septic system cheater pipe

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Is MDOT required to conduct an IDEP program?

• YES
• NO

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

• A. Do nothing, someone else will take care of
  it
• B. Send an email to DOT the Drop
• C. Notify the MDEQ, the MDOT storm water
  coordinator, and other proper authority

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Which one of these is considered a permittable
point source discharge(click on the correct
photo)
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GREAT JOB!!
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Agenda

• MDOT Phase II Storm Water Program Overview
• Illicit Discharge Reporting
• Training Module
• IDEP Screening Update
• Summary

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MDOT Phase II Permit

• Effective April 1, 2004 April 1, 2009
• Provides Statewide Coverage
• Authorizes Storm Water Discharges from MDOT
  Facilities
• Six Minimum Measures
• Storm Water Management Plan (SWMP)
• Annual Reporting

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Program Components
ProjectApproach
PollutionPrevention/Good Housekeeping
PostConstruction
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MDOT Activities for IDEP Component
Illicit Discharge Elimination Program

• Dry Weather Outfall Screening
• Mapping
• Outfall Labeling
• Education and Training Activities
• Illicit Discharge Reporting Program
• Follow-up on Illicit Discharges
• Legal Authority

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What is IDEP?

• I Illicit Wrong, illegal, needs correction
• D Discharge Someone may swim in it
• E Elimination Lets get rid of it
• P Plan/Program/Project Solutions

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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.

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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
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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.

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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

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Acceptable Non-Storm Water Discharges

• 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
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Acceptable Non-Storm Water Discharges
continued

• Diverted stream flows
• Flows from riparian habitats and wetlands
• Springs
• Emergency fire fighting activities (unless
  identified as significant sources of pollutants)

Source MDEQ Permit No. MI0057364
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Acceptable Non-Storm Water Discharges
continued

• Foundation drains
• Water from crawl space pumps
• Footing drains and basement sump pumps
• Air conditioning condensates
• Water line flushing

Source MDEQ Permit No. MI0057364
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Acceptable Non-Storm Water Discharges
continued

• Landscape irrigation runoff
• Irrigation waters
• Lawn watering runoff
• Residual street wash waters

Source MDEQ Permit No. MI0057364
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Acceptable Non-Storm Water Discharges
continued

• Discharges from potable water sources
• Waters from non-commercial car washing
• Residential swimming pool waters and other
  permitted, dechlorinated swimming pool waters
  without untreated filter backwash

Source MDEQ Permit No. MI0057364
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Agenda

• MDOT Phase II Storm Water Program Overview
• Illicit Discharge Reporting
• Training Module
• IDEP Screening Update
• Summary

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IDEP Discoveries
Accidental

• MDOT Staff who find illicit discharges
• Maintenance
• Construction
• Survey

• Tasks associated with finding illicit discharges
• Ditch clean-out
• Mowing
• Pesticide
• Survey
• Construction

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Legal Authority to Remove

• Permit Requirements
• MDOT shall possess legal authority statewide to
  prohibit discharges into drainage system
• Current Authority
• Section 9.13 Construction Permit Manual
• Methodology
• Notice and Order to Remove Encroachment
• Multiple notices of violation

Stay Tuned Judy will be discussing after lunch
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Illicit Discharge Tracking Procedure
Illicit Discharge Suspected Record Information
Is it an emergency?
Call 911 or PEAS hotline [phone]
Notify Supervisor or Region IDEP Coordinator
No
Yes
STOP No Further Action Necessary
Preliminary Verification
Notify Supervisor or Region IDEP Coordinator
No Problem
Problem Suspected
Discussion MDOT and Tetra Tech
Notify MDEQ, Local Authority, and MDOT Storm
Water Program Manager
MDOT
Tetra Tech
Legend Responsible Parties
Initial Reporter IDEP Region
Coordinator
(Continued on next page)
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Illicit Connection Removal Process
(Continued from Previous page)
Tetra Tech
MDOT
Field Investigation to Identify Source
STOP No Further Action Necessary
Notify MDEQ
No Problem Found
Illicit Discharge Confirmed
Off ROW?
Yes
No
Stay Tuned Judy will be discussing after lunch
Refer to Local Authority or proceed with letter
notification sequence as appropriate
MDOT will correct problem
Legend Responsible Parties
IDEP Region Coordinator Refer to Figure 3-1 in
MDOTs Storm Water Management Plan for letter
sequence
Confirm that problem was removed
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MDEQ Notification Requirements

• Emergency Discharge
• Discharge that poses imminent danger to health or
  environment
• Tanker accidents, pipeline breaks, and releases
  of hazardous substances, oil, salt, or other
  polluting materials (defined by the Critical
  Materials Register) under state law.
• Verbal Notification to MDEQ within 24 hours
• Make every attempt to notify a live person at the
  applicable MDEQ District Office including
  pressing 0 for the MDEQ operator
• After Hours Call PEAS 1-800-292-4706
• Part I Section C.2.a

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MDEQ Notification Requirements
continued

• Non-Emergency Discharge
• Discharge that does not pose imminent danger to
  health or environment
• Verbal or Written documentation to MDEQ within 5
  days of becoming aware of any reason or instance
  of non-compliance.
• Part I Section C.2.c
• All notification must include (if known)
• Name of regulated discharger
• Location of discharge and outfall
• Nature of pollutants
• Clean-up and recovery measures planned

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Untreated Sewage Discharge Notification

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

• Notify with 24 hours after discharge begins
• MDEQ
• Local Health Dept.
• One or more daily newspapers of general
  circulation
• Compliance with Section 324.3112a of Michigan Act
• Part I Section C.2.d

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Complaint Tracking Database

• Discharge tracking component
• Microsoft Access Database
• Housed on server at each MDOT Region Office
• Mandatory use of Reporting Database

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• Login Screen
• Administrators, Region IDEP Coordinators To
  login for the first time, use the following
  format for your user name and password.
• User Name first.last
• Password first.last
• Example Judy Ruszkowski
• User Name judy.ruszkowski
• Password judy.ruszkowski
• Then, go to User Management to create a specific
  account for you. You may do this same procedure
  to create an account for all users.
• Users To login for the first time, use the login
  user name and password assigned to you from an
  Administrator, (Region IDEP Coordinator). Only
  the Administrator can change your password.

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New Complaint If you are entering information
for the first time about a new reported illicit
discharge or connection, use New
Complaint. Existing Complaint If you are
referencing or editing an existing complaint, use
Existing Complaint. Report If you are creating
a report of existing illicit discharge issues in
your region, Report will allow you to customize
the information included in the report.
Logout Use logout to exit the database. User
Management To create a new user account, or to
manage the functions each user can perform, User
Management will allow you to add and edit user
accounts. Only an administrator will see this
button.
Administrator Only
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Initial Complaint This page is where you will
enter the information received about an illicit
discharge via telephone or field staff reporting.
A paper form exists to fill out when not logged
in to the database. The sections with an
asterisk are required fields. The information
entered into the top portion of the screen will
be automatically copied into subsequent screens
related to this complaint. Once you select a
Region, only the Counties contained in that
region will be listed in the pull down menu.
Once a County is selected, only the Control
Section Numbers in that County will be listed in
the pull down menu. Once a Control Section
Number is identified, only the Routes contained
in that Control Section will be listed in the
pull down menu. Be sure to save before exiting
this page. The buttons at the bottom of the
screen will open additional forms to be filled
out or edited in relation to this complaint.
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• Existing Complaint
• This page is where you will select an existing
  complaint to reference or edit.
• You may search for an existing record by
• Complaint Number
• Region
• County
• Control Section
• Route
• Date
• Or selecting from the Complaint List
• Once you have highlighted a complaint number,
  select Go to Existing Complaint Menu
• Return to Main Menu takes you back to the main
  option menu.

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Initial Complaint If you want to reference the
initial complaint made, use Initial
Complaint. Initial Investigation If you want to
reference, or enter a new site investigation, use
Initial Investigation. Follow-up Investigation
If you want to reference, or enter a new
follow-up investigation, Follow-up Investigation
will allow you to view or enter the
information. Communication If information has
been exchanged, external or internal to MDOT
regarding this complaint, use Communication. Comp
letion Use this if the reported illicit
discharge issue has been resolved. Information
can be edited and saved in all pages related to
an existing complaint, with the exception of
automated text that is linked to the Initial
Complaint page. This automated information can
only be changed in the Initial complaint page.
Administrator Only
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This area will fill in automatically from initial
complaint data.
Communication Tracking If information has been
exchanged, external or internal to MDOT regarding
this complaint, use Communication. The sections
with an asterisk are required fields. Files may
also be attached to this complaint such as
letters, or emails in any format. To attach a
file, click Save this Communication and Attach
Files. You will be prompted to browse and upload
a file. To retrieve an uploaded file, use the
scroll buttons and click Download. Then,
indicate where you would like it to be saved.
Be sure to save the data before exiting.
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Investigation This form needs to be filled out
when a crew completes a site investigation of the
reported illicit discharge. A paper form exists
for the crew to fill out in the field. This form
applies to both an initial site investigation and
a follow-up investigation. The sections with
an asterisk are required fields. Files may also
be attached to this complaint such as letters, or
emails in any format. To attach a file, click
Save this Communication and Attach Files. You
will be prompted to browse and upload a file. To
retrieve an uploaded file, use the scroll buttons
and click Download. Then, indicate where you
would like it to be saved. Be sure to save
the data before exiting. Investigation continues
on next page.
This area will fill in automatically from initial
complaint data.
This area will fill in automatically from initial
complaint data.
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Investigation (continued from previous page) This
form needs to be filled out when a crew completes
a site investigation of the reported illicit
discharge. A paper form exists for the crew to
fill out in the field. This form applies to both
an initial site investigation and a follow-up
investigation. The sections with an asterisk
are required fields. Files may also be attached
to this complaint such as letters, or emails in
any format. To attach a file, click Save this
Communication and Attach Files. You will be
prompted to browse and upload a file. To
retrieve an uploaded file, use the scroll buttons
and click Download. Then, indicate where you
would like it to be saved. Be sure to save
the data before exiting.
This area will fill in automatically from initial
complaint data.
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This area will fill in automatically from initial
complaint data.
Completion This form needs to be filled out when
an illicit connection or discharge issue has
ceased or has been referred to another entity and
MDOT is no longer responsible. Do not complete
this form until the illicit connection or
discharge removal is confirmed by a site visit or
follow up investigation. Be sure to save the
data before exiting.
This area will fill in automatically from initial
complaint data.
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• Report
• This page will allow you to generate three
  different report types.
• 1. Complaint Summary list of complaints with
  brief description of each.
• . Detailed Complaint Report a detailed report
  of a single complaint.
• . Progress Summary A numerical tally of
  complaints by Region.
• You may search for a complaint record by
• Date
• Region
• County
• Control section
• Route
• By selecting a complaint number in the list
• Complaint status
• The reports will assist in obtaining the
  necessary information for the MDOT storm water
  permit annual report.

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The Complaint Summary lists each complaint and
pertinent information, such as the location of
the discharge, nature of the problem and the
status.
This report page opens as a separate window in
the database. You can close this window without
closing the entire database by clicking the X
in the top corner.
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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.
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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.
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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.
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Database upload. Scenario information is
located in the tab labeled Reporting Database.
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Scenario 1 Reported oil sheen on river from MDOT
outfall
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Information to Record

• Be as specific as possible!
• Where
• Control Section 70014, along north bound US-31,
  1000 feet north of BR-196 and US-31 interchange
  (Holland)
• What
• Oil sheen (possibly gasoline or fuel oil), spread
  10 ft. radius from outfall pipe
• When (Observation Info.)
• February 15, 2006 at 1000 am
• Who (Complaint and source, if known)
• Complaint is anonymous, source of discharge is
  unknown

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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.

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Notification

• Notification The MDEQ District Office is
  notified within 5 days of MDOT becoming aware of
  non-compliance.
• Corrective Action MDOT sends a letter to the oil
  change facility landowner to remove discharge
  from MDOT drainage system.
• Landowner must provide documentation of
  corrective actions to remove discharge.
• Use letters in Section 9.13 of Construction
  Permit Manual.
• Completion The connection was removed by the
  landowner on April 1, 2006. Field staff
  re-investigated to confirm removal on April 5,
  2006.

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Example Sheens
www.riverkeeper.org
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Scenario 2 Spill discharging to MDOT drainage
system
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Information to Record

• Be as specific as possible!
• Where
• Catch basin along M-99, 100 feet south of I-496
  bridge (Lansing)
• What
• Fluorescent green liquid
• When (Observation Info.)
• March 15, 2006 at 5 pm
• Who (Complaint and source, if known)
• Complaint is Joe Smith, source of discharge is
  from restaurant

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Investigation

• The reported problem is located within the MDOT
  Right-of-Way (along M-99 in Lansing)
• Action MDOT sends a crew to investigate, confirm
  and take additional notes and photos.
• Observations Crew investigates green liquid and
  finds an illicit discharge from a Yummy Food
  restaurant. The liquid is a biodegradable,
  non-toxic, cleaning agent. Source location is
  confirmed to be outside of MDOT ROW.

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Notification

• Notification MDEQ is notified within 5 days of
  MDOT becoming aware of non-compliance.
• Corrective Action MDOT sends a letter to the
  Yummy Food restaurant to discontinue dumping
  cleaning agents down storm drains.
• MDOT sends a reminder that cleaning agents are
  not acceptable discharges.
• Use letters in Section 9.13 of Construction
  Permit Manual.
• Completion The landowner received the letter and
  will begin acceptable discharge compliance.

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Example Spills
USFWS.gov
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Scenario 3 Highly turbid water discharging from
outfall
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What Information do I need?

• Be as specific as possible!
• Where
• Discharging from Construction site along M-43 in
  Lansing, 1000 feet east of BR-96 and M-43
  intersection.
• What
• Soil erosion from a construction site entrance
• When (Observation Info.)
• April 1, 2006 at 1000am
• Who (Complaint and source, if known)
• Complaint is anonymous, source is at an MDOT
  Construction site.

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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 BMPs in place on a construction site of
  5-acres. Source location is confirmed to be
  located in MDOT ROW.

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Notification Who was notified?

• Notification The MDEQ District Office is
  notified within 5 days of MDOT becoming aware of
  non-compliance.
• Corrective Action MDOT begins correction at
  construction site, installing proper BMPs. An
  SESC operator will perform BMP monitoring to
  ensure BMP does not fail.
• Completion MDOT installs BMPs on April 14, 2006
  and reports on progress to MDEQ according to
  permit.

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Scenario 4 Septic Cheater Pipe
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Information to Record

• Be as specific as possible!
• Where
• Middle of woods along MDOT road ditch (Genesee
  County)
• What
• Dry Weather Flow with sewage debris
• When (Observation Info.)
• May 9, 2005 at 1230 pm
• Who (Complaint and source, if known)
• Complaint is John Doe, source of discharge
  unknown, no houses in near vicinity

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Investigation

• The reported problem is located within the MDOT
  Right-of-Way (drainage ditch in Genesee County)
• Action MDOT sends a crew to investigate, confirm
  and take additional notes and photos.
• Observations Crew investigates raw sewage debris
  discharging from a 6 PVC pipe. Upstream land
  use is forest in range of sight. Further
  investigation confirms the pipe cuts through
  woods for 1000 feet and disappears at a
  residential property line. Source location is
  confirmed to be outside of MDOT ROW.

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Notification

• Notification MDEQ, the Health Dept., and a
  newspaper are notified within 24 hours of MDOT
  becoming aware of non-compliance.
• Corrective Action MDOT sends a letter to the
  resident and corresponding municipality to remove
  septic cheater pipe from storm drainage ditch.
• Use letters in Section 9.13 of Construction
  Permit Manual.
• Completion Resident removes pipe on June 30,
  2005 municipality and MDOT field crew
  re-investigate to confirm removal on July 24,
  2005.

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Reports

• Complaint Summary list of complaints with brief
  description of each.
• Detailed Complaint Report a detailed report of
  a single complaint.
• Progress Summary A numerical tally of
  complaints by Region.

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Database User Management

• Accessible to database Administrators
• Create New User
• Assign User Functions

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Cheater Pipes
Floatables
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Suds
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SESC Issues
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Region IDEP Reporting

• Frequency of submittal (quarterly or annual)
• Forward to Tetra Tech by the first week in
  January (January 5, 2007)

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Agenda

• MDOT Phase II Storm Water Program Overview
• Illicit Discharge Reporting
• Training Module
• IDEP Screening Update
• Summary

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MDOT IDEP Training Module

• Illicit Discharge Elimination Program Module
• Topics
• NPDES Storm Water Program Overview
• Permit Requirements
• Illicit Discharge Examples
• IDEP Reporting Program
• Training for MDOT staff

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Agenda

• MDOT Phase II Storm Water Program Overview
• Illicit Discharge Reporting
• Training Module
• IDEP Screening Update
• Summary

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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

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IDEP Outfall Mapping

• Locations investigated during IDEP

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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

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Agenda

• MDOT Phase II Storm Water Program Overview
• Illicit Discharge Reporting
• Training Module
• IDEP Screening Update
• Summary

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Heres what you need to do

• Tracking Application
• Install it
• Decide whos going to use it and how
• USE IT
• Provide feedback as requested by Judy and Tt
• Follow up on reported problems (ask for help if
  you need it)
• Training
• Train maintenance, construction and survey
• staff by the end of the year
• Provide feedback to Judy and Tt on who,
• what, when, where and how
• Known Outfall Maps
• Review and comments. No fieldwork necessary.

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When you have questions . . .

• Call Judy when you have...
• Problems with an illicit discharge (Judy will
  call Tt as needed)
• General questions on the storm water program
• Call Tetra Tech when you have...
• Problems with the database
• Results of reviewing the known outfall maps
• Questions about the training module

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Thank you for your participation!