HomeMy WebLinkAbout20140090 Ver 3_Winston-Salem Northern Beltway Eastern Section_20160121Transportation
January 15, 2016
Mrs. Amy Chapman
Transportation Permitting Unit Supervisor
NCDENR-DWR
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Notice of Deficiency, dated January 8, 2016
Winston-Salem Northern Beltway Eastern Section
U-2579B, Forsyth County -
DWR no. 2014-0990 v3
Dear Mrs. Chapman:
PAT McCRORY
Governor
NICHOLAS J. TENNYSON
Secretary
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JAi���-2016
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-y �1SPOR
We received the Notice of Deficiency (NOD) regarding a violation to the 401 Water Quality
Certification (WQC) No. 3987 issued to the North Carolina Department of Transportation
(NCDOT) dated January 8, 2016. The violation referenced condition no. 21 of the WQC 3987,
which requires NCDOT to use Best Management Practices to protect surface water standards.
Following the violation, NCDOT project personnel immediately shut down all work on the
project not related to erosion control. The project remained shut down until a mandatory
meeting was held on January 12, 2016 with NCDOT project personnel, Dragados-USA, Inc.
(prime contractor) and subcontractors including foremen, superintendents, and management.
NCDEQ-DEMI,R staff, Mr. Tim Latham, also attended the meeting.
Dragados-USA, Inc. was reminded during the meeting that this was the second notice of
deficiency (NOD) on this project. Dragados described measures that were put in place following
the first NOD that included but were not limited to posting signs not to enter permit areas
without approval. Erosion Superintendent, Mr. Roger McNeill, was to be informed of any
work/activity that took place in permitted areas. After Mr. McNeill denied a request to work in
permit site 2, another superintendent directed a foreman to complete the work anyway, without
approval and in violation of 401 Water Quality Certification 3987. This superintendent was
relieved of his duties by Dragados-USA, Inc. NCDOT advised upper management from
Dragados-USA, Inc. that another incident like this cannot be tolerated and that a future
occurrence will result in significant consequences for Dragados-USA, Inc..
DIVISION OF HIGHWAYS DIVISION NINE DIVISION OFFICE
375 SILAS CREEK PARKWAY, WINSTON-SALEM, NC 27127
PHONE (336) 747-7800 FAX (336) 703-6693
Mrs. Amy Chapman
Page 2
January 15, 2016
Dragados-USA Inc, along with Mr. Phil Suggs, NCDOT Roadside Environmental Field
Operations Engineer, is continuing to conduct training on NCDOT's Best Management Practices.
We have attached a copy of the commitments that the contractor made following the meeting to
alleviate the concerns associated with the NOD.
If you have any questions or require additional information, please contact myself or Amy Euliss
at 336-747-7800.
incerely,
.i •
S. P. Ivey, P.E.
Division Engineer
SPUscb
Enclosures: Response letter from Dragados-USA Inc. and supporting documentation
ec: Mike Holder, P.E. Chief Engineer
Don Lee, CPESC, State Roadside Environmental Engineer
Dave Wanucha, NCDWR .
Jose Ignacio Martin Alos
Tim Latham, NCDEMLR
Jeremy Guy, P.E., NCDOT Division 9 Resident Engineer
John Thomas, USACE
Phil Suggs, NCDOT Roadside Environmental
Amy Euliss, Division Environmental Offcer
nRa�Aoos usA
January 14, 2Q16
IUorth Caralina pepartment ofTransportation
Division 9
375 5ilas treek Pkury, Winston-Salem MC 27127
ATTENTIOIV: S.P.Ivey
Division Engineer
SUBJECT: LET'fER DUSA - C203484.003; Response to Natice o# Deficiency
Dear Mr. Ivey:
I am in receipt of the Notice of De�ciency issued to the Department by the IVorth Carolina D'ovision of
Water Resources (NCDWR). Dragados wants tn siart by extending our apologies to all the Department
and NCDWR. Since we received the first NOD i� August 2015 Dragados has been implementing the
committed corrective action plan to avoid occu�rence of any other vi4lation. The curr�e�t procedure
established fflr any and all employees working in our project includes:
• tnitial Erosion Control Orientation
• Certified Level II Erosion Control #oremans for all the crews.
• Continued Training frorn aur Erosion Control Supervisor, Mr. Roger McNeil
• Mr. McNeil has got authority to stop work at any given time for any Erosion Control related mal
praxis.
• Any and all crews and su6contraciors wanting to vuork on a permitted area need to fill in a
permit request which is revised, discussed and app�oved by Mr. McNeil before tt�e operations
start.
• Special signing has been installed in all the permitted sites to enforce the permitted areas.
• After rain events we pair up our faremans with the NCQOT Praject inspectars to expedite
inspection and be able to address any potential issues sooner. We believe this also helps the
foremans acquire even more awareness of what needs to be taken into account when
inspecting EC devices.
This Cflrrective Action Plan implemented since early September has been working thraugh the last
months in which we had a considerable amount of rain. This occurrence is due to a unilateral decision by
one of our employees who was directed not to remove or modify #he BMP's in place. This employee has
loeen removed fram the company.
5ince this occurrence we have already had meetings with all the staff and made them, once again, aware
of the aero tolerance policy for Erosion Control.
Dragados USA — Winston Salem Northern Beltway Project
775 Robbins Perch Trail, Kernersville NC 27284
� �RAGADO� USA
We believe that this action will help the rest of the project personnel to be aware of how seriously
Dragados takes Erasion Con4rol into consideration. We want to ensure that any employe� in the Project
haa got access to Erosion Control Specialists at any given time and if they have any question mr doubt
about how to proceed. Therefore, and hoping that this will help monitor and contral every individual
even more, we will implement the "Erosion C�ntrol Hotline Cards" which will be handled to every
employee on the project.
Basically, these cards will have the ph�ne number of the lead EC Superoisor, the NCDQT Head Inspector
and the NCDOT CEI Lead inspector for Erasion Cantrol. We will ensure that all the erraployees have
access to therr► if they have any queseion/concern about Erosion Control while we continue their training
to ensure EC awareness.
On top of this, Mr. Suggs will be cflordinati�g additional training for all the emplayees with Mr. Mc Neil
so that the continued education is implemented on site.
Dragados hopes that these additional reinforcement actians help ensure that no additional occurrences
take place.
Please feel free to contact me if you need any additional clarification.
Sini
Jose Martin Alds
Project Manager
Cc: Angel Crespo
Jordi And�es
Rafael de la Barreda
Michelle Bostick
Jeremy Guy
Dra�ados USA— Winston Salem Northern Beltway Project
775 Robbins Perch Trail, Kernersville NC 27284