PRHTA Compliance Response

8/19/2019 PRHTA Compliance Response

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ES I ADO 1.115R1 ASOCIADO DI.

PUERTO RICO

Atitoridad do Carreteras y Fransportacion

March 11, 2016

Mr. Jaime Lopez

Senior Enforcement Officer

Multimedia Permits and Com pliance Branch

Caribbean Environmental Protect ion Div is ion

U.S. Environmental Protection Agency

City View Plaza, Suite 7000

48 Rd.165 km. 1.2

Guaynabo, Puerto Rico 00968-8069

Com pl iance P lan For

Administrat ive Compl iance Order

Docket Num ber CW A-02 -2016 -3109

Construct ion of Dr i lled shaf t Retaining W al l at PR-25 K m 1.1

Add it ional Stabi l izations W ork S

Mun icipali ty of San Juan

AC-002533 /R000025033

Dear Mr. Lopez:

As required by item Num . 62 of the above referenced

Administrat ive Compliance Order (ACO),

issued on March 4,

2016, the

Puerto Rico Highways and Transportat ion Authori ty (PRHTA)

respectfully submits for USEPA revision

and approval, the

Com pl iance Plan (CP) prepared for the project. This CP

intends to comply w ith the requirements

detailed in the

A C O

and in the 2012 Construction General Permit

(2012 CG P) .

In addition we want to inform you that the

P R H T A

and

Del Va l le Group SP (DVG ),

Project General Contractor,

ceased all construction operations related to the project on March 1 2016, after DVG received the Order and in

compliance with paragraph No. 59 of the same. DVG confirmed receipt of the Order on March 1, 2016. PRHTA

received the Order on March 4, 2016 but started coordination with USEPA on March 1, 2016 as soon as the

contractor made PRH TA aw are of the Order received.

On the same date, DVG and PRHTA representatives contacted and coordinated a meeting with USEPA

representatives as required on paragraph 61 of ACO. After the meeting, held on March 2, 2016 DVG submitted an

email notification regarding the resuming of activities to continue with the installation and maintenance of erosion and

sedimentation control BMPs required by the PREQB and the SWP PP. USEP A via email acknowledged its receipt on

March 3, 2016.

The followin g is a description of the already performed and p roposed activities. Such activities are being executed in

compliance with the mandatory requirements of the

ACO.

The information will be presented in the same order as the

A C O .

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Mr. Jaime Lopez

March 11, 2016

Page 2

•

Respond ent 's contac t in fo rmat ion fo r those respons ib le fo r the deve lopm ent and im p lementa t ion o f

the Com pl iance Plan

Respondent contact information responsible for the development and implementation of the Compliance

Plan are:

Mr. Javier Arroyo Rosario, P.E., Deputy Executive Director for Infrastructure., Telephone

787-721-8787 X-1055;

Jarroyodtop.qov.pr

Mr. Noel Rosario Hem andez P.E. Construction Area Director. M r. Rosario was designated by

Mr. Arroyo to act on his behalf. Telephone 787- 721-8787 X-1101,

nrosario(@ Atop.qov.pr

•

Implementat ion dates ( in i t iat ion and complet ion) for each of the act ions to be taken, which shal l not

e x c e e d o n e h u n d r e d e i g h t y (1 8 0 ) c a le n d a r d a y s o f t h e r e c e i p t o f th i s o r d e r , u n l e s s o t h e r w i s e

speci f ied

As we have previously informed you the scope of the original project was substantially completed. The

additional construction phases have been agreed upon by the

P R H T A a n d D e l V a l le G r o u p S P ( G C ) ;

therefore, a new project schedule including dates for the commencement and completion of the described

actions has been d eveloped. Major tasks include:

Providing temporary stabilization to areas where clearing, grading, and excavation

activities has temporarily ceased;

Providing final stabilization to areas where clearing, grading and excav ation activities will

no longer be performed;

Implementing erosion and sediment controls, and

Best Managem ent Pract ices (BMP's )

at the site;

Providing Maintenance for the existing and future

BMP's

and

Installation and maintenance of sediment and erosion controls required by the

Puerto

Rico Envi ronm enta l Qual ity Board

(provided that a w ritten notification is submitted to

E P A

no later than five 5) calendar days before the commencement of such activity. The

notifications shall include a description and itinerary of implem entation of the activities to

be u ndertaken.

The implementation of the temporary erosion and sediment control measures will be accomplished within

the thirty (30) calendar-day period established in the Order. Despite some of the permanent stabilization

activities already begun, such as the installation of stone revetment (i.e. breakwater reshaping), the same

are intended for completion within a four (4) month period. The termination date will be on June 17, 2016. A

copy of the Project Stabilization Plans as included as

Attachment 1

of this report.

A copy o f the revised itinerary has been included in

Append ix A- Pro jec t Schedule

of the

S W P P P

and as

At tachment 2

of this letter. However, it shall be noted that installation of temporary as well as permanent

soil stabilization

BMP's

have already started in the project as authorized under the original NPDES Permit

P R R 1 2 A 8 2 5

granted on June 20, 2015. The permit was modified to include the additional stabilization

works and it was re-authorized on March 4, 2016.

•

Developmen t /Select ion, implem entat ion and maintenance of soi l s tabi lization BM P's


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Mr. Jaime Lopez

March 11, 2016

Page 3

The development/selection, implementation and maintenance of the soil stabilization practices for the

project has been taken based on the current conditions of the project, as required by

EPA. For the

stabilization practices have been divided in two (2) broad catego ries. They are:

Temporary M easures

Tem porary m easures selected for its use in the project include:

•

Installation of Silt fences

Reshaping of temporary stabilized entrance/exits

Installation of Erosion control w attles

Construction of temporary swales

Installation of Plastic liners to cover the unstable embankments

•

Installation of Temporary slope drain ( if deem necessary)

Maintenance of vegetation w here possible

The location for the mentioned measures can be observed in the

eros ion Contro l

Measures Drawings , (Temporary and Perm anent )

for the slope stabilization works as

they were incorporated in the Modified

SWP P P

and also attached to th is letter.

Per manent M easur es

Permanent measures for slope stabilization were designed in-house by PRHTA Design

Area personnel. Those m easures include:

•

Reshap ing and s t rengthen ing o f the b reakwater ( s tone reve tment

type V)

R e m o v a l o f u n s t a b l e m a t e r i a l a n d r e c o n s t r u c t io n o f s l o p e s

emb ankmen t with selected ma ter ia l

Placing of top soi l

•

Instal lat ion of erosion control Mat — 24 m onth of longevi ty

P l a n t in g o f V e t iv e r G r a s s ( C h r y s o p o n g o n z i z a n o i d e s ) s i e r ra

variety

•

Developm ent of s i te speci f ic inspect ion repo rt forms

Specific Inspection Forms for the additional works were developed using the forms developed for the

original SWP PP. Copies of the Form s have been included in the modified

SWPPP.

Inspection reports have

been duly completed and filed since construction resumed.

•

Performance of inspect ions by qual i f ied personne l

Inspections of the project for

SWP P P

purposes will be handled by qualified personnel as defined in the

C G P

requirements. The

P R H T A

has designated the following personnel for conducting the inspections:

Eng. Axel Carrasquillo cuevas

•

Eng. Eduardo F. Ruiz Velez,

P E


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Cord

Noe . Rosa o Hernandez

Director

Construction area

Mr. Jaime Lopez

March 11, 2016

Page 4

The reason to designate two 2) persons is to maintain a resource available in the event that one of them is

unavailable due to unforeseen conditions. Both engineers have experience in the construction of highway

projects; and although already having experience in site inspections, were also trained in the specific

requirements of compliance with the

2 0 1 2 C G P

conditions. They will interact with the Del Valle Group SP

designated inspector.

•

Preparat ion of inspect ions reports by qual i f ied personn el

The new forms will be used to document the project inspections and will be performed

s

reviously

indicated by qualified personnel from both the contractor and the

PRHTA.

•

Designat ion of author ized representat ives

The designated authorized representative of the

P R H TA

for the 2012 C G P

implementation of this project

will be Eng. Axe l Carrasquillo Cuevas. (Cell. phone: 787-487-1313).

•

C o s t e s t i m a t e s t o im p l e m e n t th e C o m p l ia n c e P l a n a n d e a c h e r o s i o n a n d s e d i m e n t c o n t ro l .

Stabi l izat ion pract ice an d p ol lut ion p revent ion act iv i ty

Detailed cost estimates of the erosion and sediment control stabilization practices and pollution prevention

activities have been prepared. They are included in

Attachment 3

of this report.

•

Mod i fied as needed and imp lement the SW PPP to com ply wi th the te rms and requ i rements o f 20112

C G P

The

P R H T A

has modified the

SWP P P

jointly developed with Del Valle Group SP

(GC)

for the Original

project. The

S W P P P

was revised by the

P R H T A

to incorporate erosion co ntrols, stabilizations practices and

pollution preventions measures, which can be identified in the slope stabilization plans, for the purpose of

improving the actual conditions of the project. Such m easures include:

Improved tem porary and final soil stabilization BMP s based on existing project conditions

Updated time schedule for the additional works based on actual project conditions

Measures to control run-on across the com pleted slopes

Revised inspections forms

As required by the

2 0 1 2 C G P ,

the revised

SWP P P

incorporates the PRHTA solutions to address the

deficiencies identified in your

Reconnaissance Inspect ion Report

of March 17, 2016

We look forward that the submitted information complies with the

A C O

requirements, however, if there is a need to

provide additional information don t hesitate to contact us, at (787) 721-8787 X -1105, 1158, 1167


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ATTACHMENTS


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Attachment

Cost of implementation of BMP on the Project

9


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Q T Y

320.00

1,200.00

2,732.00

100.00

1.00

100.00

1,700.00

ESTADO I.IRR I A SO( I A DO

PUERTO RI O

Avieridad de C arrot

ransportaeicrni

DRILED SHAFT RETAINING WALL, HIGHWAY P R-25R KM 1.1

MUNICIPALITY OF SAN JUAN

AC 002533 / R000025033

COST OF IMPLANTATION OF BMP

O N T H E P R O J E C T A R E A

P E R M A N E N T S T A B I LIZA T I O N A N D L A N D S C A P IN G

I T E M

U N I T

D E S C R I P T I O N

Q T Y

U N I T P R I C E

A M O U N T

5

CuM

Borrow Calss B

3,950.00

20.00

79,000.00

8

SqM

Double Net Erosion Control Blanket

1,818.00

5.00

9,090.00

1 4

CuM

Stone Revetment Type V

1,790.00

60.00

107,400.00

21 CuM

Polymeric Marine Mattress

165.74

400.00

66,296.00

2 2 CuM

Sand Filled Geocontainer

203.75

280.00

57,050.00

3 6

CuM

Non-Woven Geotextile

1,270.00

5.00

6,350.00

40 Each

Planting Vetiveria zizanioides (Vetiveria Grass)

6,200.00

8.00

49,600.00

T E M P O R A R Y E R O S I O N C O N T R O L

ITEM UNIT

E S C R I P T I O N

6

ach

traw Bales

7

nM

8

qM

3 5

S

Special and/or Additional Works (asphalt berm)

Plastic Liner

Double Net Erosion Control Blanket

Special and/or Additional Works

(Barrera para minizar turbidez en el mar)

Construction Exit

Silt Fence

U

N I T P R I C E

A M O U N T

12.00

3,840.00

8.00

9,600.00

5.00

13,660.00

62.24

6,224.00

2,500.00

2,500.00

25.00

2,500.00

8.00

13,600.00

T O T A L

4 2 6 , 7 1 0 . 0 0

4 1 ach

42

S

44

qM

VOCIODID Of tfiNbffetaf

rrww avdtatw


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Attachment 2

Project Schedule


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Estado Libre Asociado de Puerto Rico

CT-174

Departamento de Transportacion y Obras Publicas

Rev. 6/92)

AUTORIDAD DE CARRETERAS Y TRANSPORTACION

H O J A D E T R A M I T E

RECIBIDO

FECHA:

15 de marzo de 2016

A: 1er.

A: 2do.

A: 3ro.

A: 4to.

A: 5to.

Sr. Jaime Lopez-EPA

•

=

i

. c

7

r

C.,,

f

: 1:

DE:

ASUNTO:

Ana L. Torres Santana-Jefa, Oficina Gerencia de Construccion

•••C)

COMPLIANCE PLAN FOR ADMINISTRATIVE COMPLIANCE ORDER

DOCKET NUMBER CWA 02 2016 3109

AC 002533

Corres./De:

orres. Fechada:

Contestar para firma del Secretario

ometer recomendaciones

Contester para mi firma

nvestigar e Informal*

Contestar directamente

reparar opini6n

Acusar recibo

nterarse y enviar a archivo

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Accion pertinente

nterarse y devolver

Discutir conmigo

studiar y radicar la alegaciOn

MO

Para su informacion

orrespondiente

OBSERVACIONES:

e incluye asunto mencionado para su informacion y tr6mite que estime

pertinente.

6512/Iir

Anexo

PRHTA Compliance Response

Documents

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