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HomeMy WebLinkAbout20001432_Site Inspection_20110901Beverly Eaves Perdue Governor ��� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director September 1, 2011 MEMORANDUM To: John Olinger, Division Construction Engineer, NCDOT Division 8 From Subject Mason Herndon, NCDWQ, Fayetteville Regional Office Site Visit Follow-up TIP No. R-2417AA Lee County This memo is a follow-up to our site visit of the Sanford Bypass project (R-2417AA) in Lee County on August 24, 2011 to inspect non compliance items that were noted in our letter dated August 18, 2011. Ronnie Smith with the U.S. Army Corps of Engineers was also present at this visit. I appreciate the time your staff spent with us to review this project. The following comments are provided to help document our joint site visit and to provide technical guidance and assistance to DOT staff to ensure that this project is constructed in compliance with the permits issued to this project. NPDES Record Review The following items need to be addressed and corrected on all future inspections and reporting: • SDO's were identified by ID # only on reporting form. DWQ suggest including station number of device on the form to clearly identify its location and/or have plan sheets with the report identifying the device location and the assigned ID number. • When multiple inspections are required in a week, each inspection should be entered on a separate line. Multiple inspections were noted on a single line. • All SDO's must be inspected within 24 hrs of a 0.5" rain event. During our review of the reports, we noted several incidences where some devices where not reviewed within the required time period. • Qualitative monitoring of discharges is not being documented on report. Dee Freeman Secretary Ramp B Repairs to Structures 197 and 198 have been completed and excessive turbidity at Site 2, noted during previous inspection appears to have been resolved. In addition, the area surrounding these structures has been temporary seeded and mulched by DOT. Outlet protection has been installed out the outlet of these two structures. DOT needs to continue to monitor this area after each rain event to make sure the problem has been corrected. Site 2a Sta. 33+00/33+65 Contractor ceased using the silt basin for dewatering the jack and bore pit for the 54" culvert at this location on Monday per DOT after finding that the addition of flocculants and other improvements to the basin were ineffective. DOT and their contractor have yet to develop an alternative plan to dewater this pit. High turbidity was noted downstream of Patterson Creek below the confluence of this tributary. It is anticipated that the turbidity is a result of the ineffectiveness of the basin treating the effluent from the bore during its previous use. DOT needs to develop a better plan for dewatering the bore site that will not create a turbid discharge into Patterson Creek. 225 Green St., Suite 714, Fayetteville, NC 28301-5043 Phone:910-433-33001FAX:910-486-0707 Internet: www.ncwaterqualitv.orq MEqualOppotlunirylAffirma�ivePdionEmployu-50% Rayded110% Pos�ConsumerPaper NorthCarolina �aturallr� R-2417AA September 1, 2011 Site 1 Station 23+32(RT) Bore and jack of 24" pipe complete. The stream bank is undisturbed and stable at outlet into Patterson Creek. DOT asked if rip rap bank stabilization required. DWQ and USACE agree that rip rap bank stabilization is not necessary. Site 3 Station 35+20/36+30(RT) Mechanical clearing complete, no fill has been placed in wetland. No issues noted. Site 4 Station 52+08(LT/RT) No issues noted. Good stand of vegetation has been established on the east slope. Permitted site at Station 63+00(RT) was not reviewed. Site 5 Station 87+90(LT/RT) 54" RCP has been installed. Nylon net matting has been placed in the stream bed; this material is unsuitable for this application and needs to be removed. This matting has a long life and aquatic species are prone to getting tangled up in this material. Permanent impacts to the stream extended beyond their permitted limits and extend all the way to the right of way. The areas permitted for temporary impacts have been permanently impacted due to changes in the stream dimension and profile throughout this reach. The outlet of the pipe is perched approximately 2.5 ft above the natural stream bed at the permitted limits per elevations take by Mr. Johnson with your staff. This is not in compliance with the conditions of the 401 WQC issued to this project. The permit requires that the pipe be buried one foot below the natural stream bed. DWQ request that DOT reviewthe permit drawings and provide an explanation to why the stream was permanently impacted beyond the permanent impact limits and how the improper installation of the 54" culvert occurred. Furthermore, the Department needs to submit plans on how they propose to rectify these non compliance issues. Based upon DOT's proposal, additional mitigation may be required for these impacts. This information must be submitted to DWQ in writing within 30 days of receipt of this letter. Failure to comply with this request within 30 days will result in a Notice of Violation. Site 6 Station 120+20(LT) and 120+57(LT/RT) 8' x 6' RCBC has been constructed; flow is still going through diversion channel because channel work has not been completed. Based on the non compliance issues pertaining to the channel work completed at Site 5, DWQ strongly suggest that DOT schedules a preconstruction site meeting with the DOT Hydraulic and Natural Environmental Units to ensure that everyone is clear on the proposed scope of work and permitted limits at this site. If stream impacts occur beyond their permitted limits a NOV will be issued. Earthen plugs for temporary access roads have placed in the stream channel within the temporary impact area on both the inlet and outlet end of the culverts. These structures were not included in the permit application and therefore are not considered approved. Per the permit drawings the only activities proposed in these areas include channel improvements, bank stabilization and dewatering BMP's. Furthermore, if these structures had been authorized they were not constructed in accordance with the NCDOT BMP Manual for Construction and Maintenance Activities. Filter fabric would be required in the stream bed so the natural stream profile would not be disturbed during removal of the temporary fill. DWQ request that DOT provide DWQ with revised permit drawings depicting all temporary stream crossing required for the construction of this project and a detail of how they will be constructed. This information must be submitted to DWQ in writing within 30 days of receipt of this letter. Failure to comply with this request within 30 days will result in a Notice of Violation. Site 9 Station 178+g2(RT) Construction of (2) 9' x 7' RCBC is in progress. Rip rap and stone access road has been installed on outlet of culvert. DWQ's comments for this activity are the same as those stated above for Site 6. Proposed channel work has not been completed at this time. As state above in the comments for Site 6, DWQ strongly suggest that DOT schedules a preconstruction site meeting with the DOT Hydraulic and Natural Environmental Units to ensure that everyone is clear on the proposed scope of work and permitted limits at this site. R-2417AA September 1, 2011 Summary: DWQ is very concerned with the consistent non compliance issues that have been occurring on this project. Future non compliance issues on this project will be unacceptable and will likely result in the issuances of a NOV. To assist the Department with this project, DWQ suggests that the Department coordinate a regularly scheduled monthly field inspection (ie. second Thursday of every month) with DOT staff, the contractor, DWQ and the USACE, so we can work together in getting this project in compliance. Please let me know what day each month will work for your staff and the USACE as soon as possible so I can reserve it on my calendar. If you have any questions on the items described above or need a clarification of the information that has been requested, please do not hesitate to give me a call at (910) 308-4021 or contact me via e-mail. Cc: Marty Tillman, PE, Division 8 Resident Engineer, Lee County Sarah Lentine, PE, Division 8 Assistant Resident Engineer Art King, Division 8 Environmental Officer Belinda Henson, SWPS, Fayetteville Regional Office Ronnie Smith, US Army Corps of Engineers, Wilmington District Office Barry Harrington, NCDOT Roadside Environmental, Div. 7& 8 Brian Wrenn, DWQ Wetlands/401 Transportation Group File Copy