HB-0001_NOV-2022-PC-0389_Wood Response.pdf

wood.
August 18, 2022
Three Oaks Engineering, Inc.
324 Blackwell Street
Suite 1200
Durham, North Carolina 27701
Attention: Mr. Craig Young, PE
Subject: Wood response to Notice of Violations
STIP No.: HB-0001
Tyrrell and Dare Counties
Wood E&IS Project Number: 6234-21-0242
References: NCDWR NOV-2022-PC-0389 Dated July 26, 2022
USACE NOV-SAW-2021-01091 Dated August 11, 2022
Dear Sir:
This letter is in response to the NC Division of Water Resources Notice of Violation (2022-PC-
0389) issued on July 26, 2022, due to failure to secure written 401 Water Quality Certification
(WQC) as well as 401 WQC condition violation; and the United States Army Corps of Engineers
Notice of Violation (SAW-2021-01091), issued on August 11, 2022, violation of General Condition
#11 of the Nationwide Permit #6 for NCDOT STIP HB-0001, Replacement of Bridge No. 7 on US
64 over the Alligator River in Tyrrell and Dare Counties.
As requested by the NCDOT and in support of the NCDOT response to the above Notice of
Violations (NOVs), a timeline of the work performed, activities that led to the NOVs, and planned
changes to future work processes are provided below.
Timeline of Site Activities:
5/23 to 5/26: The geotechnical drilling rig mounted to a Marsh Buggy ATV carrier and a
smaller Marsh Master personnel carrier mobilized to the Dare County side of the project
site and moved into the woods/marsh to begin the planned geotechnical roadway and
land -based bridge borings on this end of the project. The first boring was completed near
station -L- 234+00. While moving to the next boring location at -L- 232+00 the Marsh
Buggy became stuck in very soft ground. It was determined that a second Marsh Buggy
would need to be brought to the site to extract the stuck drill rig and continue the
geotechnical boring work.
5/31 to 613: Second Marsh Buggy rig arrives onsite 5/31 and work begins to extract the
stuck rig. A second entry path was made into the site to facilitate removal of stuck rig.
Correspondence:
Wood Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Tel [phone]
Fax [phone]
Woodplc.com

HB-0001 Wood Response to NOVs
Wood Project 6234-21-0242
August 18, 2022
Page 2
Some hand clearing was performed with a chain saw to create a second entry point into
site and facilitate removal of the stuck rig. The stuck Marsh Buggy was freed and removed
to the staging area for demobilization from site.
6/6 to 6/9: Boring work continued with the second Marsh Buggy and the team completed
the boring near -L- 232+00. While moving to the next boring location at -L- 230+00, the
marsh master support vehicle broke down (engine failure). The boring was drilled at -L-
230+00, then the Marsh Buggy was used to tow the marsh master out of woods/marsh
and a third entry path was made into site to facilitate removal of broken-down marsh
master. Some hand clearing with a chain saw was performed to create third entry point
and to facilitate the tow and removal of marsh master from site. The marsh master was
demobilized from site to get repaired.
6/13 to 6/17: Mobilized replacement marsh master support vehicle to site and continued
boring work. Borings at -L- 228+00 and -L- 226+00 were completed. Some hand clearing
with chain saw was required to access these locations in areas of thick brush and woods
(trees too closely spaced to move between them or too close together to push through).
The team encountered very dense areas of small trees with some larger trees while
moving to boring at -L- 224+00, and hand clearing with a chain saw was required to create
path for marsh buggy and marsh master to access boring location (unable to "push
through" with Marsh Buggy/marsh master). Hand clearing and chain saw use was limited
as much as possible to trees with diameters of 5" inches or less at chest height, though a
few trees of diameters up to 10" were cut due to the density of trees and to avoid the larger
trees at the site. On 6/15 we had a call from property owner regarding the multiple entry
points to the site and chainsaw clearing. We discussed issues of the rig getting stuck and
equipment breakdown and the unanticipated clearing required to get unstuck, remove the
broken-down equipment, and access the boring locations. Property owner requested we
limit access to site from third entry point for remainder of work and limit hand clearing/chain
saw use as much as possible. Work continued and completed borings at -L- 224+00 and
-L- 222+00, with hand clearing of trees as described above performed as needed to
access these locations. Extra effort by the field drilling crew was made to find the "path of
least resistance" while staying within the proposed right-of-way limits of the project and
limit the amount hand clearing required to continue accessing the site and proposed boring
locations.
6120 to 6/24: Work continued as above, with hand clearing as needed to access the
proposed bridge boring locations. Completed bridge boring EB-2.
6/27 to 711: Work continued as above, with hand clearing as needed to access boring
locations. Completed bridge boring B-133. During the HB-0001 monthly status meeting on
6/27 the above events were conveyed to the project team. We provided a timeline for the
completing the remaining geotechnical boring work to the team. NCDOT personnel visited
the site on 6/28 to evaluate the site conditions of the drilling operation. Due to the difficult
conditions experienced up to that point, it was considered unfeasible and would cause
additional damage to the site to create alternative access paths to access the remaining
deep borings for the proposed bridge.
7/5 to 7/8: Work continued as above, with hand clearing as needed to access boring
locations. Completed bridge boring B-131, returned to EB-2 location to collect Shelby tube

HB-0001 Wood Response to NOVs
Wood Project 6234-21-0242
August 18, 2022
Page 3
samples at offset boring location adjacent to EB-2, and started moving Marsh Buggy and
marsh master out of woods/marsh.
7/11: Marsh Buggy and marsh master equipment moved out of woods/marsh to staging
area and prepared for demobilization from site. GoToMeeting held with USACE, NCDWR,
and NCDOT to discuss the wetland impacts.
Activities Leading to the NOVs:
• The consequences of getting the initial Marsh Buggy drilling equipment stuck, breakdown
of the marsh master support vehicle, and the subsequent actions required to safely extract
and remove this equipment from the woods/marsh, along with the density of the woods
we encountered accessing much of the site resulted in the use of hand clearing with chain
saws to access many of the boring locations on this side of the of the project site.
The thickness or closely spaced nature of the immature woods along with groves of larger
trees was unanticipated, interspersed with areas of soft ground, marsh, and wetland
prevented the equipment from pushing through the brush and small trees as we had
anticipated and experienced on the west end of the project (Tyrrell County side).
At the request of the landowner, our access to the Dare County side of the project site
was limited to one path in and out of the site, which was utilized multiple times per day by
the marsh master support vehicle during drilling operations. The soft ground combined
with the repeated/overuse by the support vehicle resulted in rutting of the ground (areas
characterized as "mechanical clearing") in portions of the site, in the area where the Marsh
Buggy got stuck, where the broken marsh master had to be towed out of the woods/marsh,
and portions of the site that had surficial/standing water.
Planned Changes to Future Work Processes:
Future work processes will include a more thorough evaluation of site conditions during
the scoping phase of the project and will include more input from subcontractors to better
assess the capabilities of the drilling platforms to access the proposed sites and boring
locations. These evaluations will provide better understanding of the potential site
environmental impacts and will include consideration of worst -case scenarios or
unintended consequences from geotechnical boring operations.
On future projects, the NCDOT will be immediately notified if difficulties arise in the
performance of the scope of work that could lead to unpermitted impacts to jurisdictional
resources.
• Better collaboration with those involved in the environmental permitting for these types of
projects so that those involved with securing the permit and those performing the work
have a clear and mutual understanding of the conditions/limitations contained within the
permit, what the thresholds are for a changed condition, and to temper best -case or overly
optimistic evaluations of site conditions with operational experience.

HB-0001 Wood Response to NOVs
Wood Project 6234-21-0242
August 18, 2022
Page 4
If we can be of further assistance to the NCDOT in responding to these NOVs or if you would like
to discuss further, please do not hesitate to contact us.
Sincerely,
Wood Environment & Infrastructure Solutions, Inc.
Michael B. Lear, L.G.
Associate Geologist/Project Manager
Registered, North Carolina 1927
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