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Home My WebLink AboutD_NCS000250_HSP DEQ Follow-up Meeting Presentation 20191107NORTH CAROLINA Department of Transportation A R Q L 7r!) � DEQ Follow-up Meeting November 7, 2019 Construction Program Manual (2003) needs to be updated (Clarification: DEQ referring to BMP Construction Manual &not E&SC Manual) • NCDOT's BIVIP Construction manual is currently being updated; however, there is no deadline requirement. The existing manual is still used by contractors. The update is part of periodic internal document reviews/ updates. We anticipate completing the update in early 2020. 2 Construction Program Some inconsistencies across state, will try to better quantify those before finalizing the audit (training, "enforcement') • Need further clarification from DEQ Construction Program Standard documentation &tracking for reporting incidents to DEQ (chain of custody, how issues escalate if repeat offenders) • Incidents are reported per NCG01 Part III, Sec. C, page 14. Incidents per NCG01 get documented on DOT's Self Inspection Form for each project. DEQ (DEMLR & DWR) are notified orally or electronically within 24 hours of discovery. • The project inspector will notify Division personnel & REU of any incidents. It will then be reported to DEQ. - cont - 4 Construction Program • An ICA may be issued for non-compliance or for repeat offenses or if no progress to correct an incident is being made. The attached memo discusses the escalation policy of the ICA if non-compliance continues. All ICA reports get sent to DEQ. DEQ could issue an NOV if incidents are not corrected. Construction Program ESC/Construction under contracts/report a problem (recommend stormwater phone #, construction phone #, etc., or general phone number with a trained responder) • NCDOT has a Contact Us page that individuals can call or email with questions or concerns. These inquiries get sent to the appropriate Units or Divisions. • The Division of Highways also has a Contact Us page with REU phone number or report a problem message. https://www.ncdot.gov/divisions/highways/Pages/contact.aspx A I&M Program Training documentation (recurring issue), prove what was done &who received it (to what extent) webinar training. (Who did training, what was taught, who was taught; records need to be kept for permit documentation) • NCDOT tracks all AM training, including agenda, attendance, material covered, etc. Samples were provided to DEQ in data request. NCDOT will evaluate if any additional documentation is needed for training performed at the Division level as part of overall HSP training documentation reviews. rA Vegetative Management Program Relying on NCDA for documentation • By Law, NCDA&CS is required to maintain pesticide license records incl. date license is issued, recertification credits obtained, & dates of such training. Records of training are maintained in a separate database. As a result, training records for each person would have to be pulled separately. The attached table shows which NCDOT employees have license, sub - endorsements on their license, and when their license expires. All course history and certifications on that person's records are maintained by NCDA&CS. - cont - Vegetative Management Program • NCDOT is satisfied with this arrangement and feels that additional record keeping would be redundant. However, if DEQ requests additional verification, NCDOT would download the subject excel table once per year, prior to June 30, query the data by Hwy Divisions and have each DREE verify that their employees have a hard -copy of their license and that the employee is still a member of the RE Dept's staff. • Details related to sub -endorsements: A= Aquatic; E = Core; G = Forestry; H = Rights of Way; L = Ornamental and Turf; N = Demonstration and Research. 9 Vegetative Management Program Confirming "equivalent training" for contractors • During the contracting phase of Roadside projects, bidders are required to submit the names of staff possessing NCDA&CS Pesticide License and sub- classification endorsements. In addition, they must provide a copy of each staff member's current active license. Companies not providing that data are not be eligible to bid on projects where the application of pesticides is a component of the contract. - cont - 10 Vegetative Management Program • NCDA&CS also maintains a list of pesticide recertification credits obtained by each of the contractor's licensed staff. Without a current active license, contractors (like DOT employees) are subject to substantial fines and possible jail time, depending upon the severity of the infraction. • See example contract language 11 Vegetative Management Program Document training extent &content (e.g. staff certification) • Staff certification is stored in the same database as training through NCDA&CS. • In order to be eligible for recertification credits, all training must be submitted to and preapproved by NCDA&CS before training event. The person requesting the credits (usually D. Smith for DOT) is responsible for obtaining a list of attendees, including their NCDA&CS Pesticide License # &submitting that information into NCDA&CS. NCDA&CS will then review this submission and record that training in NCDA&CS database for each attendee. 12 Industrial Activities Program No analytical monitoring when a problem outfall is identified; not required but it will be discussed at permit renewal • SPPP Template Section 1.4.6 Non- Stormwater Discharges does provide guidance on methods typically employed to investigate whether any non-stormwater discharges are present at a facility, which includes analytical monitoring. 13 Industrial Activities Program Documentation -specific #'s should be readily available for training, facilities, plans (SPPP & SPCC) • Site -specific training documentation is maintained at each facility. Training of SPPP Team Leaders is maintained at facility and also centrally (includes agenda, rosters, and content, etc.) 14 Industrial Activities Program Escalating "enforcement" & ID of non -implementation (how we deal with people that don't follow SPPP) • BMP recommendations are given to Facility Team Leaders as well as Division POC (typ. Division Maintenance Engineer); if they are not followed Division Mgmt. handles. NCDOT will evaluate if additional enforcement tracking is needed. 15 Internal Education Program General SW awareness training for contractors, maint. workers • NCDOT has Stormwater Pollution Prevention and Spill Prevention & Response video modules for maintenance staff (which includes stormwater awareness level training); NCDOT will evaluate potential improvements to tracking IE training program, in particular, for contractors. 16 r�rvrrrrrrrrrri�IrYIII+II�/ External Education Program Documentation • Hard copies of information given out are tracked through orders & printing (including Litter Management and HSIP). NCDOT will evaluate if additional documentation of training is needed. 17 External Education Program Hotline 4 "contact us" on webpage, #'s • We will evaluate "Contact Us" to see if we can provide additional "clarification" information to general public to make sure needs are met. Contact Us links: Highway Divisions https://www.ncdot.gov/divisions/highways/Pages/contact.aspx NCDOT.GOV https://www.ncdot.gov/contact/Pages/default.aspx HSP Connect https://connect.ncdot.gov/resources/hydro/Pag eq s/Highway-Stormwater- Program.aspx NCDOT Stormwater Management/ IDDEP https://www. ncdot. gov/i n itiatives- olicies/environmental/stormwater/Pa es/default.as x 18