ADOT s Stormwater Program

Transcription

1 ADOT s Stormwater Program Wendy Terlizzi Arizona Department of Transportation Office of Environmental Services Water Quality Group Statewide Program Manager 60th Annual Arizona Conference on Roads & Streets April 21, 2011

2 History of ADOT s Stormwater Program In 1999, EPA determined ADOT to be a permittee and issued a permit for the Phoenix and Tucson metro areas Submitted reapplication (EPA) for Permit in February 2002 Expired in September 2002 and was administratively continued by ADEQ Submitted revised application to include new requirements in 2003

3 In 2004, ADOT received a consent order from ADEQ In 2005, as a condition of the consent order ADOT reapplied for an individual permit (tailored to ADOT s activities) Final Permit issued August 2008 Statewide (not limited to urbanized areas), but does not include Indian Country Includes Phase I and II requirements Includes municipal, construction, and industrial Expires 2013

4 Purpose of a Stormwater Audit Comprehensive evaluation of all components of a stormwater program to assess compliance with the permit and development and implementation of the stormwater management program.

5 Audit Overview EPA visited construction projects, maintenance yards, and industrial facilities in the Flagstaff, Phoenix, Prescott and Tucson Districts Four teams Total of 57 sites visited Saw a mixture of projects and facilities Certain program areas were focused on: Overall implementation of the stormwater program Consistency of implementation through Districts Housekeeping, inspections, enforcement for construction and maintenance

6 Best Management Practices (BMPs) BMPs means schedules of activities, prohibitions of practices, operation and maintenance procedures, and other management practices used to prevent or reduce pollution to waters of the U.S. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. Can be structural or non-structural. Non-structural Structural

7 AUDIT OBSERVATIONS

8 Employee Education and Training Not fully developed and deployed to appropriate staff (supposed to be completed in 1 st year)

9 Dry Weather Monitoring Procedures are developed on paper, but not fully implemented Storm drain system is not completely mapped

10 Storm Drains/Dry Wells Need to be marked Need to be maintained

11 Encroachment Permits Limited authority to enforce stormwater program Improperly installed/ maintained BMPs are nuisances for encroachment permits Permittees are supposed to comply with all applicable environmental regulations As an owner, we have a responsibility to make sure the permittee is not violating conditions of our permit

12 Construction Concerns Good housekeeping at yards Inconsistent use of liners in concrete washouts Improper selection, installation and maintenance of BMPs Lack of documentation of inspections and corrective action follow-up Incomplete delegation of authority

13 Contractor Oversight SWPPP template was created to assist the contractor Also ensures that all information ADOT requires is captured Section 9 provides a certification as well as a place for delegation of authority

14 Housekeeping Staking port-a-johns Spill kits on site

15 Track-out Control

16 Material Storage Ripped and uncovered bags of material Covered

17 Secondary Containment Gap in liner Tear in liner

18 Secondary Containment Laying on bare ground

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20 Oily residue on ground

21 Concrete Material barely or not contained

22 Not lined and unconsolidated material

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24 Improperly Installed BMPs

25 Poorly Maintained BMPs

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27 Maintenance Yard Concerns Good Housekeeping Lack of signatures on SWPPPs Inconsistent application of SWPPPs Inconsistent documentation of inspections and corrective action follow-up

28 Good Housekeeping Publicly display SWPPP Lock on secondary containment

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30 Bad Housekeeping Lids need to be closed when not in use Trash outside of dumpster Dumpsters always need plugs

31 Leaking truck over marked storm drain Oily Residue

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33 Overall Yard Issues Salt shed track-out Drainage off of the yards is an item of concern; most yards were designed prior to the Clean Water Act

34 Stockpile Management spillage

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36 Wash Racks Need to be permitted (by the state or the city)

37 Industrial Material sources No fencing (trespassing issues) Contributions from abutting properties Erosion stemming from adjacent (non- ADOT) roadway

38 Anticipated Audit Outcome ADOT is awaiting a report by EPA outlining their findings and recommendations A Compliance Order or similar action will be issued by EPA outlining an implementation plan and timeline Possible directives on things they want us to do immediately More stringent permit conditions in the future Similar order as that received by Caltrans No fines but remedial action required Short time frame to correct (Caltrans deadline 2-3 months post-abatement order; approx. 1 year post-audit total)

39 Solutions to Audit Observations Establish the governance policy, standards, directives Training focus on key emphasis areas Evaluation review and evaluate the effectiveness of the governance, and the reality of what is going on in the field Repeat Plan, Do, Check, Act philosophy

40 Future Actions? New Policies and Procedures Stormwater Policy Signatory authority Illicit Discharge, Detection and Elimination More enforcement capabilities, either by the District or HQ Coordination with other municipalities Leverage with contractors: Incentive/disincentive specs Training for staff and contractors Other?

41 Questions For More Information Wendy Terlizzi Water Quality Manager Office of Environmental Services