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8/19/2019 PRHTA Compliance Response
1/10
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 .
4
8/19/2019 PRHTA Compliance Response
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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
8/19/2019 PRHTA Compliance Response
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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
8/19/2019 PRHTA Compliance Response
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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
8/19/2019 PRHTA Compliance Response
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ATTACHMENTS
8/19/2019 PRHTA Compliance Response
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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
8/19/2019 PRHTA Compliance Response
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Attachment 2
Project Schedule
8/19/2019 PRHTA Compliance Response
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8/19/2019 PRHTA Compliance Response
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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
N e c m i
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