Experiences from the FieldExperiences from the Field

Project had a CAP requirement that called Project had a CAP requirement that called for protection of sensitive watersfor protection of sensitive waters

Managed a project against the odds to Managed a project against the odds to protect “the Blind Cave Shrimp” an protect “the Blind Cave Shrimp” an endangered speciesendangered species

District 3 - KY 259 Edmonson CountyDistrict 3 - KY 259 Edmonson County

Challenges …Challenges …

• 30 + inches of rain30 + inches of rain

• Highly erodeable Highly erodeable SoilsSoils

KPDES BMP Plan Template

1. Implement the requirements of Permit KYR10 for all projects that disturb One or more acre of ground.

2. Items marked (1) are to be completed by project manager/design engineer

3. After letting, District and Contractor complete items marked (2) and (3) and NOI

Page 3 - Items marked (1)

7. a general statement about the existing soil cover and erodability of the soils.

The place in the BMP Plan to enumerate the soil conditions in relation to erosion and sediment controls.

Page 3 - Items marked (1)

9. and 10. TMDL review – look for ORW streams or 303(d) listed streams

Project managers are expected to see that streams that require extra protection are identified.

Page 3 - Items marked (1)

9. and 10. TMDL review – look for ORW streams or 303(d) listed streams

Extra provisions for erosion and sediment control

Environmental GIS Viewer

http://kytcgis.ky.gov/enviro/viewer.htmhttp://kytcgis.ky.gov/enviro/viewer.htm

Results ……….

Sensitive Water

Reasonable quantities of each probable erosion and/or silt control feature, methods or practice for bid purposes.

The reason for developing an ECPis to provide information and/orSite Specific Solutions which theContractor and the Resident Engineer can use to develop and maintain a BMP Plan which will comply with the KPDES permit.

2008 Standard Specifications

Apply to all contracts awarded after Jan 1, 2008 Topsoil – unless it is addressed in the contract, it

probably won’t be saved or used. Consider temporary easements to stockpile

topsoil. 3 seed mixtures are applied based on region of

the state and mow vs. no-mow zones. Plan Quantities for payment are used unless

there is a 10 % deviation from reality

2008 Standard Specifications

Require contractor to have a KEPSC qualified inspector

Protecting streams BMPs in place before opening new areas

Inspection Notebook

Developed after our EPA 309 Letter Moved the Five Day letter into the

inspection process Example from KY 259 These notebooks start with the Design

Engineer Residents and Contractors document using

references to the plan documents through DWRs and pay estimates

Trends in EPSC Management

KYTC is increasingly engaging the contractor in taking responsibility for KPDES compliance

Design Build contractor holds the permit KEPSC inspectors are being required The national trend is to increasingly place

the responsibility for NPDES compliance on the contractor

Standard specifications apply including the ability to charge liquidated damages

WWW.KEPSC.ORGWWW.KEPSC.ORG

KPDES Permit, Where are we ?

KYR10 permit is expired. Sept 15, 2008 - there is a chance the

permits to replace KYR10 will be public noticed.

KYTC will manage construction that it controls under the KYG50 permit.

Permits managed under the KYG50 will not have to be filed with the Division of Water to obtain coverage.

KYTC will send DOW reports on permit activity

KYG50 Permit - Expired

Covers highway maintenance lots

Primarily for: De-icing material

management Suspended solids Oil and grease

Employs BMP Plans for facilities

Environmental Handbook

KYG50 Permit

This permit will be modified to include highway construction

Earth disturbing highway maintenance will be covered by Fact Sheets

Project specific permit coverage will not be required for maintenance activities

USEPA Perspectives - Stormwater Discharges during Construction

EPA is developing Effluent Limitations Guidelines as a regulation

Watch www.epa.gov/waterscience http://cfpub.epa.gov/npdes/stormwater/cgp.cfm

USEPA Perspectives - Stormwater Discharges during Construction

Seven days notice US Fish & Wildlife Service Review NOI Preparer information Education of employees and subcontractors Maintenance - 50 % then clean out BMPs Increased emphasis on stabilization and

documenting progress of construction

USEPA Perspectives - Stormwater Discharges during Construction

Clarified documentation regarding Endangered Species Act compliance

Added documentation requirements when discharges enter TMDL streams.

Inspection options added to be either weekly or every two weeks + after ½ inch storms

The time of rest in grading has been reduced to 14 days. (KYR10 had 21 days)

USEPA Perspectives - Stormwater Discharges during Construction

Areas with 10 or more disturbed acreage, design to store the runoff volume from a 2 yr, 24 hr storm or use 3,600 cu ft storage volume per acre disturbed.

When one large basin can not be provided, smaller devices with equivalent volume is to be employed.

USEPA Perspectives - Stormwater Discharges during Construction

“Inspections must be performed by qualified personnel; either the operators own personnel or consultants hired to perform the inspections. The inspectors must be knowledgeable and possess the skills to assess conditions at the construction site that could impact stormwater quality and assess the effectiveness of sedimentation and erosion control measure chosen to control the quality of sites stormwater discharges.”

USEPA Perspectives - Stormwater Discharges during Construction

NOT is to be filed within 30 days of stabilization.

Records retention is three years after NOT is filed.

What to watch for ….

KYG50 permit re-issuance “Plan of Common Development” Lexington MS4 permit KYR10 permit re-issuance

Will apply to any work that KYTC does not “control”

Public Notice e-mail ann.workman@ky.gov

Aunt EPheliA

Now, Just what

have they been

doing in Kentucky

???

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