MODOT LAND DISTURBANCE TRAINING 2013

Nate MuenksMoDOT Design

Environmental & Historic Preservation Section

Moving in the Right Direction - A Team Effort!

AGC/MEC, MDC & MoDOT collaborated on the renewal of the general permits for land disturbance

Seeing more emphasis placed on E&SC on all fronts, including regulators

Better timing & phasing of grading/finishing in conjunction with seed & mulch application

More awareness of where runoff is leaving the project & what BMPs are in place to control it

E&SC plans are improving in the design phase

Construction/Contractors doing a better job of keeping E&SC plans up to date with project changes

Moving in the Right Direction - A Team Effort!Continued……

Moving in the Right DirectionSediment Basins, Traps, Energy Dissipation

Moving in the Right DirectionConcrete Washout

Still Working Toward the GoalErosion Control Blanket or Equivalent

Some things to consider though, esp. soil fertility

Still Working Toward the GoalDitch Check Installation

Still Working Toward the GoalDitch Check Installation

Still Working Toward the GoalTemporary BMP Removal

If the temporary BMPs are non-biodegradable, they must be removed once the job achieves final stabilization. Be sure to note this on your semi-final.

Becoming More PopularMulch

New Products TriedFiber Matrices

Be sure to apply the proper rate to sufficiently cover the ground – should look “dimpled” when done correctly, with no soil showing.

Lessons Learned…..Dewatering

Have a plan before you turn on the pump or dig the ditch

What path will the water take & where will it end up?

Lessons Learned…..Wattles

If installed as type II ditch check must have fabric beneath May have to reduce their use more in SWPPP??...especially

for inlets

Inlet Protection (Potential Revision)Curb Inlet Protection:

Sand Bags/Rock Socks Wattles/Silt Socks/Silt Logs, etc. Various Filter Inserts Wood, Steel or Other Barricades

Drop or Pipe/Box Inlet Protection: Rock Tri-Dikes Sand Bags Various Filter Inserts or Covers Wood, Steel or Other Barricades

Lessons Learned…..In-Stream BMPs (Jurisdictional Streams) MDNR does not completely approve Only during construction of in-stream boxes or

pipes – Then remove ASAP Must be used in conjunction with BMPs in the

ditches or along the banks, catching sediment BEFORE it enters the stream

Lessons Learned…..Geese

Geese, Canada geese in particular, do not like construction inspectors

Innovation

Has led to us knowing that more innovation is needed. Below ground storage????

District Question 1Q1. Are we going to start requiring that all Erosion &

Sediment Control Plans be developed to match each construction phase?

A1. Our permit states: “Disturbed Areas: Slopes for disturbed areas must be defined in the SWPPP. A site map or maps defining the sloped areas for all phases of the project must be included in the SWPPP.”

One could argue that our plan, profile and X-section sheets address this for the most part, but one phase that I feel is important and overlooked is BMPs for the initial clearing and grubbing stages at our outfalls and at the base of sloped areas. This is something we need to produce.

District Question 2Q2. How are we handling the 2' shoulder jobs where

erosion/sediment control may or may not be required? Do they fall under the “linear” or “ribbon work” exemption?

A2. I requested from MDNR that this type of narrow/strip land disturbance be exempted from our permit and was told “No”. Therefore we treat this like any other land disturbance, but we must be logical in how we go about setting up erosion and sediment control on these jobs. If on-site veg is enough to control sediment from sheet flow, then we really only need to protect outlets with devices. The only exemptions you have are if you don’t actually have any dirt work or if you can stay under the 1 acre threshold. (Note: Even if under the threshold, we still can’t cause pollution, so BMPs may still be needed.)

District Question 3Q3. Clarify what erosion control information is required in contract plans.

On minor projects, such as adding shoulders, these jobs often disturb an acre or more to require a SWPPP, but we don't have any survey data or even plan sheets showing streams, ditch slopes, etc.

The EPG requires the following items, most of which we do not have on a resurfacing/shoulder project:

MoDOT site maps (erosion and sediment control plans) are to include: Direction(s) of stormwater flow and approximate slopes anticipated after grading

activities (DE-Show SW flow direction, slopes are shown as slope limits and then X-section sheets) Areas of soil disturbance and areas that will not be disturbed (Slope limits and any

“Do Not Disturb” areas) Location of major structural and non-structural BMPs (DE-All anticipated BMPs

on plans, CM may have to amend) Locations where stabilization practices are expected to occur (Slope limits and

BMPs shown on plans) Locations of on and/or off-site material, waste, borrow or equipment storage areas

(DE if known, CM will likely need to amend) Locations of all waters of the U.S. (DE-Label all named bodies of water) Locations where stormwater discharges to a surface water (DE-Label outfalls) Areas where final stabilization has been accomplished and no further construction-

phase permit requirements apply. (CM)

District Question 3A3. EPG 806.8.2 - These items are a direct list from our new 2012

permit requirements. You are correct that these requirements aren’t going to be appropriate for all scenarios, but we do the best we can to achieve compliance with them, and what it comes down to is documentation and in the case of a shoulder job, perhaps developing a “typical” E&SC plan for typical situations expected on the job (i.e., all outfalls protected with rock sediment traps contained within the existing ditch).

District Question 4Q4. Has there been discussion on setting up specific

erosion control measures for urban area projects. With limited drainage areas to maintain the runoff, it would be beneficial to have design include more erosion control mats, filter socks, and sod ditch checks.

A4. No. I was not aware this was an issue. It is difficult to break out all the BMPs and say, “These BMPs are for urban and these are for rural”. The fact is many will work for both. Even in urban areas, all jobs are different and stormwater acts differently as well. The objective is to give a suite of BMPs to allow for choice and flexibility in finding the best fit for every situation. With that said, I am looking at splitting out inlet protection into drop inlet vs. curb inlet.

District Question 5Q5. On our small ITS (intelligent transportation system)

jobs, we have had trenches, conduit, or drilled shaft foundations in proximity to ditches, but no erosion control items were included in the job. Are there any changes on the horizon?

A5. These types of jobs are typically below the 1 acre threshold and often BMPs are overlooked on them. Regardless of whether jobs meet the 1 acre threshold or not, if there is any land disturbance that has the potential to pollute, there should be BMPs installed to “treat” any stormwater runoff.

District Question 6Q6. In the future will it be up to the district design to

provide the topography map or is this falling back to the project office to provide the map based on the job specifics?

A6. From what I understand, in most districts, DE is supplying the maps along with other supporting documents for the job for CM to use. The intent was that this is something DE would absorb and provide.

District Question 7Q7. Can you please summarize changes that have been

made to the standard drawings for E&SC?

A7. Working with the SW District, we submitted a note to be added to the standard plan for sediment basins: “Sediment basins are to be included in the BMP system when the geometry of ROW allows. Where included, sediment basins are to be designed and constructed to provide storage volume for the local 2-year, 24-hour storm for disturbed acreage draining to them. If the design storm volume has not been calculated, basins are to be designed and constructed to provide a storage volume of at least 3,600 cubic feet per disturbed acre draining to the basin(s).”

District Question 8Q8. Are we making a move to be more specific on the type

of Type II's we specify (e.g., rock vs. tri-dike) or are you just leaving this up to the Districts? What are other Districts doing if this is the case?

A8. At this time, we are not specifying statewide one approved product over another. We have to give some degree of flexibility. Most of the decision is coming from either the preference of the RE office or the contractor. There are several REs who will allow nothing but rock for ditch checks. I can tell you that the main problem we have with any ditch check is correct installation and maintenance.

District Question 9Q9. It seems like DNR does not recognize the naming

conventions we use for our devices or products. We were discussing Type II devices and they didn't seem to know what these were. Since they are the agency that issues violations, why don't we match with them on our product descriptions?

A9. For the most part, we do use the same names as MDNR. However, when it comes to ditch checks, we break them down into subcategories to allow the use of various products. I’ve heard our “ditch checks” also referred to as check dams, silt checks and silt dikes depending on the state you are in. These are all the same thing. Then, when you start to go through the different products and the conditions under which they can perform properly, all the state DOTs have them split out by various nomenclature. Our system is not complicated, with only 2 types (categories) based on height and ability to withstand flow.

District Question 10Q10. Where has the discussion gone with changing the negative

perception we place on having DNR visit our project's and submit a report to us with what they saw? This was considered a LOW which does not accurately reflect a spirit of collaboration between our agencies.

A10. This is called compliance assistance. Typically I do not encourage inviting MDNR, the EPA, or any other entity onto our active projects. I understand this is how some may choose to operate, but you must be cautious in doing so! If MDNR does come on site and gives you a “letter of inspection”, this is not considered a LOW. To be tracked as a LOW or NOV, it must state one of those in the subject of the letter. There was confusion by those who track this, but this has been sorted out. If you are going to get MDNR involved, the best time to do so is during design or at the pre-con, not while you’re turning dirt on a job.

District Question 11Q11. Are we hearing anything further from MDNR or

EPA on regulation of effluent levels (i.e., turbidity)?

A11. No, this topic has been shelved by the EPA for the time being until more data on the matter can be gathered. This is a good thing for us and anyone in the construction industry. When the day comes that we have to comply with a turbidity standard, I expectproject cost to significantly increase.

District Question 12Q12. On permit jobs, the contractors are allowed to use our

MDNR permit for work on R/W. Is this a new practice or is this the way it’s always been done (as opposed to the contractor getting their own permit)? Typically their work involves work both on and off of R/W.

A12. They can use our permit and SWPPP if the work is being done on MoDOT RW. It has always been that way. They cannot use our permit or SWPPP for any work being performed off MoDOT RW. If their job involves work both on and off RW, it’s probably just best if they get their own permit and develop their own SWPPP for the job. Also, please see “Section 14” of these permits regarding land disturbance.

District Question 13Q13. How much rain is needed before a post-runoff

inspection is required.....½ inch? ¼ inch?

A13. Any amount that causes runoff to occur on your job site will require a post-runoff inspection. This will vary based on your soils, topography, compaction, etc. Even snow and ice melt can cause runoff and transport sediment.

District Question 14Q14. Are hard copies of the inspection reports still required

physically on the jobsite if they are all available via the V: online or a sharepoint site?

A14. The short answer is no, the only things required to be kept on site are the permit and SWPPP. On page 9, our permit states the inspection reports can be kept “at an easily accessible location so that it can be made available at the time of an on-site inspection or at the request of the Department.” I’ve typically encouraged folks to keep a few of the most recent inspection reports with them on site as a quick reference for recent site activity in case of an inspection.

District Question 15(Several Similar Questions were Asked)

Q15. QM projects: Why is the contractor not responsible for maintaining the inspection reports, summary, permit, SWPPP maps, etc., and MoDOT just doing a follow up visual records check?

A15. The fact is that it is difficult to turn the reins over on this particular topic. This has been discussed at length, and the consensus from most at MoDOT and the contracting community is that until both parties can feel comfortable with turning this over to the contractor, it is not likely to happen statewide. Our permit says the person doing the inspection must “knowledgeable” in these practices, and many contractors don’t have the training to fit that description. Remember, this is our permit and our name is on it, as well as any NOVs we get. There have been discussions with AGC on how to get the contracting community trained to take this over. Still working on it, but we will likely offer them a class at this year’s AGC/MoDOT CO-OP.

District Question 16Q16. What has the experience been on project closeout due to

the 70% vegetative cover requirement? How do we need to handle as a department?

A16. The spec was modified to be compliant with our LD permit; however, this 70% is nothing new. Our permit has always read this way, for some reason our spec just was never written to match that. Since we can’t close out our permit on a job until we achieve the 70%, we need to ensure that is what the contractor delivers. I hope this is how it is being handled across the state. We are working on seeding and fertilizer specs to perhaps give the contractor some flexibility in how they choose to deliver this end result. REMEMBER TO INSPECT AND MAINTAIN BMPs UNTIL FINAL STABILIZATION, i.e., 70% GRASS GROWTH OVER THE AREA! You should not pull BMPs until you reach the 70% grass growth.

District Question 17Q17. Is someone putting together a performance-based

specification for seed to allow the contractor to determine the seed mix they want to guarantee to grow?

A17. We are currently working on something like this. One idea we are looking at is possibly splitting the state up based on 4 ecological regions and having an approved list of seed for that region. Then, from that list, the contractor could choose a percentage of warm season, cool season and cover crop for use in a mix. Fertilizer and lime application would be broken down by region as well.

District Question 18Q18. How do we get past the issue with seasonal grasses

establishing growth and then it dying out and having no further growth the following season?

A18. Personally, I think we need to start looking at soil amendments. The problem is we are trying to grow grass on subsoils that lack nutrients and biotics that are necessary to establishing a stand of grass. We throw out some lime and fertilizer with some seed and mulch and expect growth. The cover species use up quite a bit of the nutrients from the lime and fertilizer and then what’s left may start the perennial species, but can’t sustain them. We may need to start thinking about adding compost on cut and fill areas where there is no topsoil. Texas has had success doing this and we can base a spec off of their already developed spec. Of course, there are parts of the state, where this would not be needed, but for areas like the Ozarks, it is a needed option.

District Question 19Q19. What do we do to reseed areas that have no growth or

die out where we have the erosion control blanket installed?

A19. I’ve been researching this topic due to some problems experienced last year. Unfortunately, there’s not much out there on it. What I did find is support for pulling the fabric, reseeding and starting over. Some say we can seed over ECB, but then we’ll need to re-mulch as well. I think soil fertility is our biggest obstacle with this and perhaps we need to ensure we’ll have a good growth medium before we put down blanket in the future.

District Question 20Q20. Has anyone considered issuing a Job Order Contract for

Erosion Corrections and Seeding and Mulching. This would allow us to issue final acceptance at specified time and then still allow for a way to come back to a newly constructed project that may have been accepted but then experienced a drought season which destroyed the vegetative growth.

A20. This is a great suggestion and has been talked about a little in the past. Perhaps this is something we should look at again, especially given the drought we are in. I assume the original job contract would be required to meet the 70% growth requirement, b/c one of the fears of course is that some jobs may just abandon their efforts to establish grass on the original contract and “leave it for someone else to deal with”. This would just be for those scenarios where it did meet, but then died back for one reason or another?

Take Away/Ponder Become Familiar with Your Permit & SWPPP

Know Your Job Site & E&SC Sheets

Stormwater – Spread Out, Slow Down, Impound, Detain (Keep on Us as Long as Possible)

Install, Monitor, Maintain, Replace and Remove BMPs to Keep Sediment on the Job

Continue Progressing in the Right Direction & Don’t be Afraid to Discuss/Try Innovative Solutions

MORE QUESTIONS?

Designer Getting Creative with JSPs?  On‐site RE Executive Office?  Inspector’s Lounge?Nate’s Hotel Room for Night?