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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 D ������ � JAi���-2016 o�U� --iH-�no�s �e�r�mni � uN�� -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