Rules and the Erosion Control Plan

I was talking to a friend recently over lunch-- he's an urban planning consultant, so I always value his insights.

I explained to him how this blog tends to focus on the outcome of erosion control--whether or not mud is getting into the lake.  After a bit of hesitation, he said he really didn't agree with that approach--that erosion control practices have to be based on rules and regulations.

His critique forced me to think more about the rules.   Yes, I believe in the rule of law.  And yes, workers on a complex construction site need simple but definite directions to guide them.  We have plenty of rules now, yet despite the rules, too much mud goes into the lake after every storm.  Why is that?

The question about why the present system isn't working, and how we can make it better, is really the central mission of this blog.

So far, I've identified 30 kinds of failure.  Each one alone isn't so bad.  But when you add many together, the system fails to protect the lakes. 

Obviously, you want to look for the flawed procedure that has the biggest contribution, or is the easiest to fix.  I have a few candidates:

The Erosion Control Plan (EC Plan)

I've looked at some of these now, in detail, and find them very, very inadequate.  They are done as a trivial afterthought to the painstaking design of a project.  They neglect the most basic considerations, such as the amount of runoff entering the site from above it.

Weather is the cause of erosion.  Big weather is the cause of big erosion.  So effective EC plans must accommodate big storms.  Yet some EC plans produced by the City of Madison do not seek to accommodate even moderate storms.   Yes, I agree there's the possible 1000 year storm that no plan can accommodate.  But let's set the bar a lot higher than it is now.

The Best Management Practice (BMP)

Together, a number of BMPs approved by the DNR and published in a manual make up the "toolkit" of the EC plan designer.

Unfortunately, a number of these BMPs are very dull tools indeed. 

Let's take the example of the filter used at stormwater inlets.  It's made of filter fabric stretched across the opening, or hanging inside like a bag.  This is probably the most common tool, almost universal.  That's because they are cheap, easy to install, and easy to forget.

But observation of them in the rain indicates marginal effectiveness.

• Frequently filters are clogged, or flaps of excess fabric have blown over the entrance.  So a large percentage of water headed for them just goes on past, to the next stormwater inlet (which is probably unprotected).
• Sometimes the filters are ripped on installed incorrectly, so unfiltered water gets past them into the opening.
• The filters can only trap the larger particles--tiny particles of mud go right through.  Since the great majority of pollution is attached to the small particles, inlet filters can stop only a small fraction of the pollution leaving a construction site.

Stormwater inlet with filter, 7/7.  This is one of the few filters for a large project by Findorff.  Left: You can see it is clogged, and passing sediment downstream to the right.  Right: Enlarged, you can see the same filter has been clogged for so long that weeds are growing. Click to enlarge.

Another BMP is the gravel tracking pad.  The purpose is to prevent muddy tracks from leaving the site.  These are supposed to be 50 feet long, but almost never are that long.  At many sites, they have sunk into the mud, so they are no longer working.

Washing of tires (of vehicles leaving a site) is another BMP designed to address the same problem as gravel tracking pads.  But tires washing isn't practiced in Madison.  If I mention "tire washing," contractors and EC inspectors fall silent, as if I had done something very rude.  It's their worst fear.  Yet there it is, an approved and effective tool that no one uses.

My conclusion--our rule-based erosion control depends on the Erosion Control Plan, which consists of BMPs.  If both are fundamentally flawed, then the system of rules simply can't work.  That's why I have been forced to look at mud that's flowing out of a contractor's site.  But I do feel an obligation to help get the rules back on track.

So I'm going to be more "constructive" in the future by offering some analyses of current construction sites, and offering some "tips" on erosion control practices.  The "Miss Manners" of mud. 

More effective BMPs

We have to adopt more effective filters.  The only really effective filter is a large, natural one that includes vegetation--a settling pond or basin, a rain garden, or vegetated swale.  These will be far more effective than an artificial one because they will trap all sizes of particles, and return the water to the ground; meanwhile their biological activity will help to neutralize pollutants.

Granted, these will be difficult to achieve on cramped sites.  But it should be relatively easy to export dirty runoff to the natural filters we build within a block or two.  Construction of these natural filters should planned as an integral part of the main project--and then put in place before the main project begins.

More effective EC plans

• Put a lot more effort into them.
• Creative, based on the unique features of the site
• Able to handle major storms
• Rely on natural filters rather than on ineffective fabric filters
• Integrated EC--Erosion control design is part of the main project design (more on this later)
• Contractor should be selected in part for their ability to carry out a good EC plan.(In the Hillcrest-Upland Greenway, S&L Underground & Trucking bid $500 on a very complex "Stormwater Control" line item.  Clearly they haven't thought this out.

Years of debate

For decades, government committees and citizens have debated the problem of construction site erosion.  Periodically, they issue reports that say "Crack down on construction site erosion."  "Enforce the rules at construction sites."  But there hasn't been enough improvement.  I do acknowledge that controlling erosion on construction sites isn't an easy job.  If it were, the problem would have been solved by now.

This means that construction sites are one of the last industries that are still casting their garbage into the public commons.... our lakes and streams.   Cracking down isn't enough (though it would help).  An overhaul is needed.

Erosion control plan for Greenway--unable to handle big storm

The Hillcrest-Upland Greenway has been a controversial project from its start, because residents were afraid they would lose the natural values of this lovely, wooded ravine.  More.

Below, I'll present the Erosion Control plan for the project, my critique of it, and Engineer Lisa Coleman's response to my critique.  You can come to your own conclusions if you want to read the entire article.  But I'll summarize my conclusions first, for those in a hurry.

Since the ravine drains a basin above it, there is much more potential for erosion during a big storm, compared to the Edgewood Av construction site pictured below.  The issue of planning for a big storm is the main subject of the details below.

I find that the plan is workable for light rain events, but completely inadequate for a large rainstorm (say over 1.75 inches).  When I made this point, Lisa Coleman chose to ignore it.  Based on this lack of reply, plus statements from Engineering staff, I believe the city has a policy of not designing for large storms, so as to keep costs to contractors (and hence the City) lower.

The City and contractors would rather pay for the additional gravel or soil to fill in the gullies--after a big storm happens--than pay for more robust erosion control measures.

Since most of the damage to the lakes occurs during large storms, I believe this policy can't be defended--given that surveys show citizens are unhappy with the City's care for the lakes.

L. Mendota after large storm, late 1960s, by UW Engineering Dept.

Out of one side of their mouth, Engineering staff (and the Board of Public Works) say to people concerned about the lakes that they are trying like crazy to meet the 2013 mandated reduction of 40% in sediment to the lakes. 

But out of the other side of the mouth, they are saying to contractors: "It's OK to dump truckloads of sediment into the lakes when your erosion controls fail in a big storm.  It just slips down the drain while people hunker down indoors.  No one will notice."

This approach is so consistent that it must be policy.  Who set this policy?  Who will support it, once brought out of the closet?

It does seem a little wasteful to build elaborate erosion control measures, which just have to be dismantled when the construction is over.  That's why I have advocated settling basins, rain gardens, and other watershed improvements, to be installed before a construction project begins.  These erosion control measures will remain after construction is finished, to beautify the city and moderate future flooding. 

 Decide for yourself if the plan can handle large storms

Erosion control plan for the Greenway

The two main elements of erosion control during construction (other than timing of construction) are the sediment trap, and a temporary dam in the ravine called a "ditch check."

The sediment trap receives runoff from the entire greenway, plus the gutters from two streets.  The trap consists of a silt sock (a long fabric sausage, a foot in diameter, filled with mulch).  The sock is located in the parking lane of Midvale Blvd and is held in place by a barrier of those large concrete "dominoes" you see at every highway construction site.  The basin the sock creates is nestled in a little hollow at the corner of Hillcrest and Midvale, where there are two stormwater inlets that will have filters on them.

Location of the sediment trap, corner of Midvale & Hillcrest.

Runoff from the Greenway goes into the sediment trap via a concrete flume (used for overflow).  The normal route of the stormwater into a big pipe under Midvale will be blocked, so the water can instead go to the trap.

This sediment trap arrangement will trap a pool of water no more than a foot deep, as it receives runoff from a half mile long basin, plus two streets.  From the trap, the water is supposed to exit into two stormwater inlets (which will be partly blocked due to the filters on them).  Is this realistic--stormwater from a half-mile basin, all draining into two half-blocked stormwater inlets?

Access to the Greenway will be from the top, but construction will start at the bottom.  Hence, the entire greenway will be disturbed when sewer emplacement begins at the bottom.  This is the time when construction is most vulnerable to storms.  As the bottom segment of sewer is finished, it will be covered with riprap, and the next segment higher up will be worked on. 

The entire disturbed area (from riprap on up) will be protected at its lower end by the "ditch check" dam.  There is only one ditch check planned, so runoff will rush down the bare portions of the ravine, until it encounters this dam.  The ditch check will be rather porous, so it will not pool much water.  Rather, it will slow the floods, catch larger sediment particles, and allow muddy water to pass through it and on to the sediment trap on the street.
 

Ditch checks haven't been that effective on Edgewood Av.

Additional notes on the EC plan and notes from the project specifications:

1. Types of inlet protections are listed--we omit the details.
2. All disturbed areas outside of riprap channel will be restored with 4” topsoil and seed, polymer, and erosion matting.
3. Construction entrance shall be installed as directed by the construction engineer.
4. Polymer stabilization, beyond seeded areas, shall be included as directed by the Construction Engineer.
5. Sweeping off-site shall be completed as directed by the Construction Engineer.
6. Dust suppression water/polymer blend shall be utilized as needed and directed by the Construction Engineer.
7. A temporary ditch check [a rock and gravel dam] shall be installed downstream of the area being worked on. The ditch check shall be moved as installation of riprap channel proceeds.
8. Temporary haul routes within the channel area shall be surfaced with clear stone as directed by the Construction Engineer.
9. The project site shall be inspected for erosion control compliance by a City inspector weekly, and within 24 hours of a rainfall greater than 0.5 in.

Storm Control  …Shall include all work, material, equipment, and incidentals required to control wet weather flow in the channel where the work is to be completed. The contractor should not expect flow in the channel during dry weather, however the channel can be expected to fill rapidly during rain events. The Contractor shall take all necessary steps to protect the new structures, piping, and channel from damage during construction and to accommodate the existing flows during construction. This item includes all storm control necessary for all aspects of the Construction. This item is not for control of groundwater.  The low bidder budgeted $500 for Storm Control.

My note: The Storm Control specs say nothing about erosion to soil or dirty water leaving the site.

Erosion control--sediment trap  ….This item shall also include minor field modification of the sediment trap as directed by Construction Engineer to fine-tune or improve effectiveness, as well as cleaning out of and maintenance of the sediment trap as needed and as directed by the Construction Engineer. The sediment trap shall not be removed until placement of riprap stabilization on the channel is complete, or until directed to remove by the Construction Engineer.

My critique of the erosion control plan

To: Engineering Division, Lisa Coleman

Hello Lisa,

I’ve had a chance to consider the erosion control (EC) plan for the Greenway.

First, two questions:

• What size (diameter) silt socks are planned?
• Are any cloth fences planned ? I saw them in the legend for the Erosion plan, but didn’t find any on the drawing.

While the ER plan can probably handle light precipitation, I believe the plan cannot handle a torrential rain. And, I believe it should be able to handle a torrential rain, because erosion control is one of the two main justifications of this project. One big storm could send tons of sediment from this project to the lake. I know October is a bit dryer, but hoping for no big storms is not an Erosion Control plan.

Here are my reasons:

Because it’s located in a ravine, this project has more potential for erosion during a big storm unless special precautions are taken.

Silt socks (the dense ones) are good filters of sediment. But this means sediment passes through them only slowly. So any volume of flow will surely do an end run around the planned sediment trap (consisting of Jersey barriers with silt sock).

Diversion of stormwater entering from outside the project is a basic method of erosion control--but that isn’t part of this EC plan. There are numerous sources that could be diverted before they reach the greenway. But the most obvious and easy to implement is storm water from Falles Ct, which enters the Greenway from a pipe near the Newby’s house. This tributary meets the greenway only 246 ft from Midvale Blvd. It could easily be diverted to the far side of Midvale with a temporary plastic hose. This tributary is a problem because it can both increase the erosion to the project, plus contribute clear water that can overwhelm your sediment trap on Midvale.

Likewise, the sediment trap on Midvale will be overwhelmed with clear water coming down the east gutter of Midvale, and the south gutter of Hillcrest. These clear water inputs should be diverted to the opposite sides of their streets.

Silt socks are only about 1 foot high. Once overtopped (or if water goes around), they cease to function. The capacity of your sediment trap could be increased if the silt socks were used to anchor a cloth sediment fence.

Likewise, water in a big storm will do an end run around the sediment trap, with some of it probably flowing to the west side of Midvale. Hence, much muddy water will flow down the west side of Midvale. What provision has been made for handling this muddy water? At the very minimum, you need inlet filters on the west side.

Since it’s likely muddy water will exit the area of the sediment trap on either side of Midvale, this suggests that additional sediment traps of the same design should be installed further down Midvale.

The EC plan doesn’t mention cleaning of the silt socks. They are likely to work well during small rain events, collecting sediment. If this sediment isn’t regularly cleaned out, then surely it will be washed downstream if there’s a big storm, when the sediment trap is overwhelmed.

Since the low bidder’s (S&L) line item for “storm control” is by far the lowest $ amount, I wonder if they have adequately considered the difficulties presented by this ravine.

My comments above are a critique of the layout of the EC plan‘s sediment trap. It will not work as designed, because it will be so easily overwhelmed. If you are going to use this kind of trap, then it has to be expanded and the layout (with respect to inputs and overflows) better designed.

However, I feel this kind of sediment trap can never function very well, no matter how well you design the layout. There is always going to be muddy water leaking through it--not to mention the problem of dealing with the trapped sediment. For example, what happens if the sock is removed, but there’s a storm before the contractor cleans up the trapped sediment?

I believe even muddy water containing only microscopic particles can significantly harm the lake. Nineteen percent of Mendota’s phosphorus comes from construction sites. Phosphorus isn’t very soluble, but is strongly sorbed* to soil particles. More phosphorus will be sorbed to tiny particles, because collectively they have far more surface area. Therefore, nearly all of the phosphorus will be transported to the lake via just muddy water, not on the large particles that are easy to trap.

If you instead trap the muddy water in vegetated basins, they will trap all sizes of particles, and there’s no issue of cleanup. While they do present the issue of construction and maintenance, they will continue to function and improve the watershed for years after.

Obviously, these basins have to be located a ways downhill from the construction site. But street gutters can be used to export runoff from the Greenway to the basin. Since the street gutters are going to be flooded anyway when your sediment trap is overwhelmed, why not use them for a better plan?

I don’t expect to convince you to use the “rain gardens” now, but I do feel that the sediment trap, as presently designed, will be nearly useless for a big storm. You need additional traps, and diversions of water entering from street gutters above. 

That's the end of my letter to Lisa, to which she responds below.  But after sending that letter, I had some additional comments I didn't send:

The idea of starting work at the lower end, and working upward, is dictated by the fact that--once you lay the riprap--you can't drive equipment over it. But this does mean that the entire ravine will be disturbed, before much riprap is laid.  The ditch check dam is at the bottom, moving upward as sewer is buried and riprap is laid.

So if a big storm strikes at this early stage, most of the ravine will not be protected by anything (except perhaps the gravel access road built along the ravine).  At this stage, the damage will be much worse than what happened on June 21 on Edgwood Av.  A great deal of muddy water and sediment will be washed onto Midvale Blvd, and the sediment trap will be unable to stop it.

Response to our critique

David, Thank you for your comments. To answer your questions…

• · Silt sock will be a minimum of 12 inches in diameter. Per our standard specifications, accumulated sediment should be removed when it has reached a height equal to half of the sock height. As with any construction project, watching the weather will be an important part of planning for erosion control - Removal/cleanout of the silt socks would be expected to occur during drier weather.
• · We do plan to use silt fence on an as-needed basis in the field, as directed by the Construction Engineer. Locations where it would be appropriate include on the downhill side of stockpiles, or adjacent to areas where sanitary laterals are being installed.

We recognize that erosion control from this site will require diligence. We expect that the plan may need some adjustment in the field, and expect to have our erosion control inspector on site frequently to ensure that the contractor is taking practical steps to minimize erosion from the site.

  Regards,  Lisa Coleman

#     #     #

The short ditch checks at Edgewood Av, placed on either side in the gutters, weren't effective.  The Greenway erosion plan calls for a more robust ditch check.  But mud can flow through, or around them.

* Means "clinging to."

The dog ate my erosion control plan...honest!

I've received a few polite responses to recent "busts" on Contractor Report.  I'm not going to reprint them because I don't want to embarrass people over their communications with me--and the excuses are embarrassing.  

(I do want to embarrass specific individuals for allowing mud to leave their sites.  So except for some general comments below on responses, I'll stay focused on the mud.)

Here are some of the sad things I see in response to a bad report:

• Excuses.  "The dog ate my EC plan...  but we were 'proactive' by placing it up on the table, so the dog had to stand up before he could eat it."  Isn't erosion control by nature supposed to be "proactive?"
• Denials of things you can clearly see in my photos.
• Semantic quibbles. For example, about whether or not something is a construction entrance.  If I see muddy tracks coming out, then it's an entrance.  If it walks like a duck, and quacks like a duck....
• Blaming the weather for problems with erosion control.  That's like blaming gravity when you fall and break your arm.
• "We followed everything in the EC plan, and more."  Yes, but it clearly wasn't working.  Following a lame, incomplete ER plan isn't much of a defense, if the goal is to protect the lakes.
• The most important violation is not responded to, but is buried under highly detailed explanations of minor issues.
• The responsible higher-ups, to whom I send my reports, send me back the unedited excuses of their subordinates.  This means the bosses are refusing to take leadership or responsibility.  Either they believe those excuses themselves, or they hope I will.  Either way, they don't bother to look into the problem.

This response will make you laugh (until you cry)

Before I start this story, I need to explain that I track statistics about visitors to my blogs.  It's possible to deduce a lot about your readers, though not the identity of individuals.

I published a bad report about a firm that likes to advertise it's environmental awareness.  A day or so later, I noticed that the public relations firm for the contractor had spent over three hours on Contractor Report.  They looked at every page.  That's probably more attention than I've ever had before.

But before I could congratulate myself too much, I had to admit that the PR people probably left their computer connected to my blog, while they went out for lunch. 

Then a few days later I got a call from the supervisor of the project, saying he would clean up his act if I'd delete the bad report.  Things did improve, so I deleted it.  But now there's mud leaving the site again.

The solution for this site was simple.  It wouldn't have taken much work.  Instead of complete cleanup, the company probably spent more for their PR firm to read my blog, than the contractor spent on erosion control.

Falsified self-inspections at Henry Mall?

For the Findorff project at Henry Mall on campus, the fox is inspecting the chicken house.  The Fox appears to be Findorff Construction Company.

Consider the evidence.  On July 7 after a moderate rain, I spotted some of the worst violations I've seen in Madison at this site.  The site was inspected just a day earlier by Jeremy White (wwhite@findorff.com).

For each item I could see and photograph from outside, I'll compare Mr. White's self-inspection report from 7/6 with my photo from 7/7:

Construction entrance sweeping/cleaning

Inspector says on 7/6: Inspected: "Yes" Comment:"Daily." Condition: "correct" (means OK).

Photo taken 7/7 afternoon shows very dirty surface of Henry Mall.

Perimeter control: Silt fence (the black fabric)

Inspector says on 7/6: Inspected:"Yes." Condition: "Correct."

Photo taken 7/7 shows silt fence along University Av has been down for a long time. Sediment has spread beyond its former location.

Stormwater inlet protection

Inspector says on 7/6: Inspected: "Yes." Condition:"Correct." Comment: "All inlets look very clean and in good condition."

Photos on 7/7 all look like this one--filters are clogged and unmaintained.  More photos

You can quibble about whether the stormwater inlet filters got completely clogged in one day. 

You can debate about whether Henry Mall got that dirty just one day after sweeping. 

But Findorff can't deny the perimeter fence facing University Ave has been down for days, yet was reported to be OK.  And their site was a mess on 7/7.

Moreover, there have been no inspections of this site since 7/6, even though there have been rain events on 7/7 and 7/11 that require inspections within 24 hours. 

The responsibilities here are truly Byzantine  source

• The City of Madison is the supervising Permit Authority (Tim Troester)
• But City says "Inspections not required/enforceable as site is located in UW area of authority."
• Troester has apparently delegated that inspection authority to Findorff (Bob Dillis is listed)
• But Jeremy White is really doing the inspections for Findorff.
• The WI Div. of State Facilities, Russ Van Gilder, is the Permit Holder (violator), but
• Gary Brown at the UW says he wants to be notified first of problems and he will pass the word down.  I notified him four days ago, but there haven't been any inspections posted.

No wonder it didn't get done right. 

The bottom line: Everyone passes the inspection buck, someone fibs, and there's more mud in the lakes.

Does this sound like the Gulf of Mexico?

"There goes my summer fun." Mud in the lakes again.  Lake Street, 7/7.

Hillcrest-Upland greenway project--hoping for good luck with the weather

Two contractors work on their "stormwater control" bid.

Click to enlarge.

S and L Underground and Trucking was the low bidder for the Hillcrest-Upland sanitary sewer project on Madison's near west side.  Construction is scheduled to begin Oct. 4.

Many of the residents surrounding this project are upset about losing the 65 trees this project plans to eliminate.  They have been active in opposition to the initial plans, which have since been modified.

So it's ironic that the low bidder for this project was the one that caused the uproar over damge to trees on Spaight Street last year.

In addition, "erosion control" has always been one of the objectives for this plan, so some neighbors want to ensure adequate plans are in place to protect Lake Mendota from muddy runoff.

Concerns about S & L Underground and Trucking

David Newby, one of the residents bordering the project, recently wrote to City Engineering:

There are concerns here about the low-bid contractor for the Greenway project.

Given the history of this contractor's behavior, is there evidence that he can do this complicated and delicate job? Can he fulfill the detailed specifications of what is to be done here, within the constraints as laid out in the bid (e.g. width of the work path, treatment of trees that are to be saved which are now close to the work path, type of stone to be used in the storm water channel)? And can he do it at the price he bid?

Engineering obviously worked hard here to give us a good plan for the Greenway and its problems. Does this contractor have the flexibility, the temperament, and the attention to detail to give us what we were promised here, and what the very detailed plans specify?

What we fear, of course, is that "mistakes will be made" (as just happened with Jon Nelson's hedges) - and once made (for example, the killing of mature trees, filling the ravine with the wrong rock, failing to effectively stem the erosion), the "mistakes" will be irreversible.

Erosion control--a challenge at this site

Ravine flow during the June 21st storm that dumped 1.75" of rain.  Storms of 7-10" are possible.  Photo by T. Kessenich.

This ravine drains a basin upstream that's about half a mile long.  It's the sole exit for all that stormwater.  The force of rushing water will be concentrated in a narrow ravine. 

If there's a major storm during construction, erosion will be difficult to control.  There would be damage to the project (for which the contractor is liable), as well as damage to our lakes.

Of the four bidders, S&L was the lowest when it came to the line item of "stormwater control."

S&L Underground & Trucking     $500
Speedway Sand & Gravel         $2,000
Joe Daniels Construction          $3,000
R.G. Huston & Co.                   $4,121

Note that Speedway, with all their bungling of erosion control at the Edgewood project, was the second lowest bidder on this item.

Given the difficulty of stormwater control for this project, we wonder--did S&L give stormwater control any serious consideration at all?  The round numbers for three of the contractors suggest wild guesses.

This project bears watching

Contractor Report is going to follow this project as closely as we did Speedway at the Edgewood Av site.  Neighbors will be mobilized to photograph work near trees, so S&L can be held accountable for damages, if trees outside the construction area die.

And if muddy water leaves the site, Contractor Report will consider this "mission failure," even if the City allows it.

S&L Underground and Trucking may wish they had left this difficult spot alone.

Rocket science and erosion control

Erosion control is more of an art than a science.  It's an art because water seems unpredictable.  Like a living thing, water finds its way around whatever obstacles we throw in its path.

Many engineers and contractors would rather forget about it and concentrate on the things they can control.  But by going out in the rain and inspecting your site, you can learn a lot.  Erosion does have its own rules, and you can become familiar with them.

Keeping the mission in mind

Erosion control does have one thing in common with rocket science--and that's the importance of keeping the goal in mind.

The Space Shuttle has always been a source of pride for America.  Tens of thousands of people turn out to watch shuttle launches.  A disaster for the program is a disaster for America.  Every contractor and sub-contractor is working to make each mission a success.

A few broken or missing tiles of the heat shield caused one space shuttle to disintegrate upon reentry.  Imagine the effect on the program if all the subcontractors were doing the minimum to get by. 

If contractors just said: "A rivet is a rivet--who cares where it's going..."  that would be a recipe for failure.  In fact, it was that attitude which contributed to the first space shuttle disaster, caused by faulty O-rings.

The "mission" of erosion control

Lake Mendota has always been a great source of pride and a boost to our economy.  The mission is to protect that resource--to keep our lakes and watersheds healthy.

Local studies show that 19% of phosphorus getting into Madison's lakes come from construction site erosion.  Phosphorus acts as a fertilizer that leads to toxic algae, smelly lakesides, and a lower quality of life for all.

Muddy water leaving your site in gutters (or on vehicle tires) is a pollutant.  Phosphorus hitchhikes to the lakes attached to the microscopic particles in muddy water.

When a plume of muddy water goes into the lake near your site, that's mission failure, no matter how well you followed the plan.  That's mission failure, even if City inspectors passed you, the afternoon before it rained.

"Mission failure" by Speedway Sand & Gravel at Lake Wingra, 7/7/10.

Since construction sites make a big contribution to water pollution, and are under the control of relatively few people, they are places where your actions can have a big impact.

So that erosion control plan is important.  If it's inadequate or not working, it's up to you to make sure it does work--that no muddy water leaves your site.

Expensive mistakes

Neglecting erosion control can be an expensive mistake.  That's what Speedway Sand and Gravel discovered after the evening storm of June 21, at their Edgewood Av construction site.

The storm dumped 1.75" of rain--peanuts compared to the 7-10" storms that have occurred in the area.

While this site does have a substantial slope, there is no basin above the site feeding stormwaters onto it.  So only water that falls on the site (plus water from one driveway) can erode it.

See for yourself what happened:

Edgewood Av during the storm, by Jamie Saul.  Click to enlarge.

Edgewood Av after the storm, by Jon Standridge.

This gully was predictable--because this driveway was the only place where runoff from off-site could enter the site.  So runoff got an extra "bite" here.  Once the gullty formed, other runoff fed into it.

If doing the job twice isn't motivation enough for good erosion control, think of the fines for violations if you're sued by citizens: $37,500 per violation per day.

Don't be the low bidder because you short-changed erosion control.

Stevens Construction, Scott Lewis and CMI violate erosion control permit--a dirty mess for neighborhood

Baldwin Corners, a development by Scott Lewis and CMI, is violating three parts of its erosion control plan:

Mr. Lewis is not maintaining the stormwater inlet filters as required.

Mr. Lewis is using an unauthorized entrance to the construction site--one without a gravel tracking pad.

The purpose of the gravel pad is to prevent mud from being tracked off the site.  So using an unauthorized entrance results in scattering mud about the neighborhood--eventually the mud ends up in the lakes.

Mr. Lewis is tracking much dirt off-site, without cleaning up at the end of the day, as required.

Neighbors say this has been continuing throughout construction.

Go here to find out why muddy tracks are a serious problem for the lakes.

In addition, we think the existing gravel pad is inadequate, although it has passed inspection by the City. (It's supposed to be 50' long.)

The muddy tracks leading from this pad prove that it's inadequate and prove that City inspectors routinely pass inadequate pads.

If this is how the construction is managed, it's fair to ask--how will the apartments be managed?

See all the photos here.

Contractor, on site, allowing mud to escape:
Stevens Construction ...  "THE BEST IN ALL WE DO"
Clayton Nelson, Project Manager  cnelson@stevensconstruction.com
Kirk Halvorsen, Jobsite Superintendent

Responsible City personnel:

Jeff Benedict

City-County Bldg., Rm. 115, Madison WI 53703-3342

(608) 267-1198

jbenedict@cityofmadison.com

Permit holder (and violator):

Baldwin Corners, LLC

Scott Lewis

106 E. Doty St, Madison WI 53703

608-256-4200

scott@cmimanagement.net

Problems at Miron Construction on Linden Drive

Continuing problems with muddy runoff from the Miron site for the Cancer Treatment Center. Allowing mud in the gutter, plus failing to deflect runoff entering the site, is resulting in muddy runoff getting into Lake Mendota.

Any dirt in the gutter goes straight to the lake. Just a man with a broom could solve this prolem.

This site and this problem are relatively small as things go, but this gutter would be easy to clean, and you can see the mud goes straight to the lake. Why is it so hard to get this right?

Muddy water headed from Miron (rear) towards Willow Creek.

Muddy  plume from Miron site entering Willow Creek, right.

See all the photos here.

Time to start thinking about sediment control at Edgewater Reconstruction

What's the use of a great view, if you're looking at mud?*

Located next to Lake Mendota, this project will dump tons of sediment into the lake, if Madison proceeds--business as usual.

• It's time to consider the records of contractors.  Which ones are sensitive to the environment?
• 
  
  It's time for the city to begin planning to minimize erosion from this project.

I've been watching the Miron construction site next to the Memorial Union.  They are using special, heroic measures to filter muddy water pumped from their hole.  We applaud these measures, but note they aren't working all that well.  Sediment basins--giant rain gardens--would function much better.  It's time for Madison to build some near the Edgewater site, where runoff can be pumped for infiltration into the ground.  After construction, these gardens would serve to improve the watershed, and beautify the inner city.

Mud into the Lake Mendota at Lake Street, July 7, after a brief but heavy rain.

*  Rendering of Edgewater project from Hammes Co, with our "artistic" interpretation added.

Numerous violations at Findorff construction site for Biochemistry II

Henry Mall

Numerous violations were observed on the afternoon of 7/7/10 after a brief but intense storm. Violations included

• cloth fences unmaintained and down
• lack of gravel pads at construction entrances
• unmaintained, clogged filters on stormsewer inlets

Especially noteworthy was the extremely dirty surface of the streets of Henry Mall. These inclined streets provide a straight shot for sediment to leave the site. The clogged inlet filters at the bottom of these streets, plus the mud on University Av, all attested to the dismal failure of erosion control at this site.

Henry Mall is covered with debris--will wash straight to the Lake.

Cloth dams facing Univ. Av are completely neglected.
Update 7/28: The black fabric is not a cloth dam.  Erosion control here was provided by a silt sock, which is buried by the fence under vegetation and sediment.  While we were wrong about the fence, the silt sock was breached in several places, so the end result is the same.  Since then, Findorff has added a second silt sock.

Filters on stormwater inlets are clogged, not maintained as required.

 See all the 7/7 photos here.

Enforcer of this permit (Permit Authority): City of Madison, Tim Troester, ttroester@cityofmadison.com
Permittee (the violator):  Wisconsin Division of State Facililties
Russ Van Gilder
russ.vangilder@wisconsin.gov

The DNR South Central Region stormwater program supervisor is James (Andy) Morton.
Laura Madsen is the DNR stormwater specialist who handles inspection of construction sites with stormwater permit coverage in Dane County.

Update: 7/27: The surface of Henry Mall was cleaner today that previously (photo below).

Continuing problems with Speedway Sand & Gravel at Edgewood Av

On July 7, during a brief but intense storm, the Edgwood Av construction site experienced problems:

• Silt socks failed to make contact with uneven ground before the storm
• Streets leaving area were dirty before rain began
• Cloth dam at bottom of Edgewood Av (west side) continued to be ineffective
• Torrents of muddy water made an end run down Jefferson and Lincoln streets (see below)

Muddy water leaving the site: corner of Lincoln & Jefferson.

See all the photos here

We've seen gradually improving methods at this site.  But because of constantly recurring problems, a group of citizens have filed a 60-day notice to sue for numerous violations of erosion control regulations.  Fines are $37,500 per violation per day.

Nevertheless, we were pleased to see a man out in the rain, trying to fix problems with the silt socks.

The bottom line: a muddy plume in Lake Wingra yet again.

Silt socks--an effective tool for sediment control

Dirty street gutters

These are one of the common problems I seen at construction sites, especially street construction locations.

When it rains, any dirt in the gutters goes directly to the lakes.  Leaving dirt in the gutter is like just dumping it into the lakes.  You can count on it!

Filters on stormwater inlets are the common solution to prevent debris from getting into storm sewers.  But the filters don't work that well, and they require maintenance (which is usually not done).

An easy method to control sediment in gutters

• Keep gutters squeaky clean.  Good housekeeping!  A man with a broom is very effective.
• Use short segments of silt sock in the gutter where water leaves your site, to filter sediment.
• Use short segments of silt sock in the gutter above your site, to deflect incoming water away from your gutter.

Dams in gutters, like silt socks or gravel, cannot handle large volumes--if there's a lot of flow, the water will just go around or over the silt sock.  So they can't be used everywhere.

That's why you use a silt sock upstream of your site.  By deflecting incoming water (to the other side of the street, for example), you reduce the volume of water hitting the silt sock at the lower end of your site.

Silt sock used to deflect water to left

Perimeter control

Where the ground is relatively level and runoff isn't concentrated into channels, silt socks can be very effective in preventing any sediment from leaving your site.  I've watched how they work at Sequoia Commons--Phase II.

Effective 8" silt socks at Sequoia Commons.
The only mud leaking out is coming from the entrance to the left.