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OTIA III State Bridge Delivery Program. Environmental Stewardship Training US26: Rush Creek - Antone - Bundle A51. This training fulfils the requirements of Special Provision 00290.00.
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OTIA III State Bridge Delivery Program Environmental Stewardship Training US26: Rush Creek - Antone - Bundle A51
This training fulfils the requirements of Special Provision 00290.00. • Replacements of Contractor’s Project Manager, General Superintendent, superintendents, foreman and Erosion and Sediment Control Manager must receive this training within 10 Calendar Day of starting on the Project.
Agenda • Program creation / environmental framework • Programmatic Permits • Environmental Performance Standards • Environmental Documentation • Communication Protocols • Environmental Oversight Inspections • Contract Requirements • It’s not the way it’s always been…
Program Creation How did this new strategy come to be? • Bridge Options Report (BOR) identified bridges in need of repair or replacement • Environmental process identified as key hurdle to the successful project development and construction delivery of identified bridges • Web of regulations can be confusing • Coordination with approximately 15 regulations • Standard permitting can take 145 days to complete
New Environmental Framework • OTIA III Program is based on efficiency and cost-effectiveness: • Expedited permits and approvals – meet the delivery schedule • Permitting process takes 30 days • Permitting coordinated into “One Process” • Predictable • Reduce cost and time on redesign • Capture economies of scale
Environmental Performance Standards • Program administration • Species avoidance • Habitat avoidance • Water Quality • Site restoration • Compensatory mitigation • Access/Staging • Fluvial • Bat Habitat • Materials and Contamination
Environmental Documentation • The Pre-Construction Assessment (PCA) is the project specific environmental document for OTIA III • Developed by the Engineer during the design phase. • Documents if a performance standard is applicable and how compliance will be achieved. • Includes other relevant background documentation such as State Historic Preservation Office (SHPO) Concurrence, Wetland Determinations & Concurrence, Land Use Permits • PCAs are developed for all OTIA III bridges regardless of the scope of work (repair, replacement, in-water activities, etc.) • On non-OTIA III projects, Permits are developed only for projects which have environmental effects
Environmental Documentation • Environmental Action List or EAL • Included in the Permits binder • Provides a summary of standard and special provision contract requirements (environmental) • Special conditions of the permits will also be listed here • Set up based on Pre, During and Post construction activities • Submittals and Documentation requirements are highlighted
Other Permits • ODOT has a state wide Programmatic National Pollutant Discharge Elimination System (NPDES) 1200-CA permit. • Regulates discharge of contaminates from non-point sources such as construction sites • Includes requirements for Erosion and Sediment Control Plan contents, monitoring and maintenance, and documentation • Generally, compliance with this permit can be maintained by complying with the requirements of the Standard and Special Provision 00280.
Communication ProtocolsGeneral • Contacts with state and federal agencies regarding environmental issues will be coordinated through the Region Environmental Coordinator, TERESA BRASFIELD • This includes permit modifications during construction • The Region Environmental Coordinator needs to be included in all communication on environmental issues. • Notify the Region Environmental Coordinator of any state or federal agency site visits.
Communication ProtocolsViolations • Projects with an in-water work component have a much higher risk of violations than projects without in-water work although violations can occur on all projects • greater potential for water pollution • greater potential for fish and wildlife damage • people pay close attention to their waterways • Only activities specified in the environmental permits can be implemented in the field • very little ‘wiggle room’ for changes in design • field changes without permit review are frequently the cause of formal violations!
Communication Protocols Violations • If you observe a situation that potentially is a violation: • Safety is of the highest priority. Do not attempt to stop an activity if it cannot be stopped safely. • If you can, stop the activity from continuing • Snap a few quick photos for early documentation • Call the INSPECTOR assigned to the project and TERESA BRASFIELD 541.388.6041 (office) or 541.410.7683 (cell) • Stay onsite until you receive further direction
Communication Protocols Violations IF A VIOLATION OCCURS OR IS SUSPECTED BY REGION STAFF OR CONSTRUCTION PERSONNEL: Step 1: First notify the inspector then the Project Manager (PM). Ongoing construction activities suspected to be in violation should be suspended and necessary measures installed to protect affected resources from further Disturbance. If the PM’s office discovers an incident, the PM shall immediately contact the REC, HazMat, or other appropriate Region environmental specialist to obtain guidance. If they are unavailable, the PM should contact the Region Environmental Manager (REM), GeoHydro Manager (GHM), or other Region-based manager overseeing environmental/cultural specialists. Step 2: The REC/HazMat/other resource specialist shall then notify their respective supervisor of the situation. Step 3: The REM/GHM/other manager, in coordination with other Region staff, determines if the incident is reportable to Geo-Environmental (GE). If GE is notified, further notification and reporting procedures will be jointly determined according to guidelines in ODOT Environmental Compliance Incident Reporting and Response Procedures. *Timing/Sequencing: Depending on the significance of the incident, the PM can immediately notify the REM/GHM. Steps 1-3 should occur within 24 hours. NOTE: If notification of a regulatory agency is legally required, that notification shall occur as soon as possible and concurrent with ODOT’s internal notifications. IF A REGULATORY AGENCY IS ON-SITE AND DECLARES THAT A VIOLATION HAS OCCURRED: Step 1: Immediately notify the PM and direct the regulator to the appropriate Construction manager Step 2: The PM shall notify the REM/GHM of the regulatory agency presence and their notification of a violation. Step 3: The REM/GHM or their designee shall meet with the regulatory agency representative and other appropriate Region staff to develop immediate response. The REM/GHM should also solicit input from the appropriate GE Unit Manager to jointly determine the appropriate course of action for follow-up response to regulatory agencies according to the guidelines in ODOT Environmental Compliance Incident Reporting and Response Procedures. *Timing: Steps 1-3 should always occur within 24 hours. NOTE: Always respond in a courteous manner even if the regulatory agency representative is confrontational. Ask for the specific permit or clearance condition that is out of compliance. Ask for clarification if necessary. Be open and honest; do not speculate. When a regulatory agency requests stopping nonconforming work, comply. Make a written note of the situation and the people involved. If possible, take notes when meeting with regulatory agency staff and photograph the incident in question.
Environmental Oversight Inspections • The Region Environmental Coordinator will visit sites periodically to gauge level of compliance and assist with problems and will facilitate correction of the deficient item or non-compliance issue. • Items that may be reviewed: Project Documentation including monitoring forms, Erosion and Sediment Control, Pollution Control, general site conditions, in-water work, plantings, contractually required documentation such as vehicle inspections, etc. • Frequency of Environmental Oversight Inspections correlates directly to the number of non-compliance issues that arise on the project, and also on the contractor’s environmental compliance history • Environmental Oversight Inspection Reports document any issues observed during inspections • Environmental Oversight Inspection reports will be routed to the contractor through the Project Manager’s office
Environmental Compliance InspectionsDefinition of Observation Types • COMPLIANT: The item observed conforms to the requirements of the plan (Pollution Control Plan, Erosion and Sediment Control Plan, Environmental Compliance Plans, etc.), permit or Specifications (ODOT Standards, Specials and Design Build proposals) • DEFICIENT: The item observed requires maintenance, is inadequate for its required function, is unsatisfactory or is not installed / present as required or shown in the plans, permit or Specifications. • POTENTIAL VIOLATION / VIOLATION: The item observed is not in conformance with or there is an undocumented discrepancy between field conditions and the permit, plans or Specifications. Multiple instances of a deficient item or no Contractor response to or repair of the item in question may result in the item being elevated to Potential Violation, Violation and ultimately a Non-Conformance report.
Contract Requirements 00280 Erosion and Sediment Control • 280.63 Erosion Control Monitoring • Rain gauge at each bridge site • Stream color and clarity • Monitoring forms • Weekly on active sites • Every 2 weeks on inactive sites (this includes winter shut downs) • Daily during rainy season and after 5/8” of rain within 24 hrs
Contract Requirements 00290 Environmental Protection • 290.00: Contractor shall provide all documentation for new or proposed permits or modification to existing permits / environmental clearances. This includes disposal sites (Agency control lands and non-Agency controlled lands), staging areas, detour routes, work access areas, materials sources, areas outside of the defined Project limits. • Also includes In-water work period extension requests. • 290.20(e): Provide secondary containment for product storage areas • 290.20(e): Daily inspections of storage containers & staging areas • 290.20(i): Spill Response Agreement and identify company in PCP
Contract Requirements 00290 Environmental Protection • 290.30(a-1) - Regulated Work Area • Shown on Sheets 5 and 6 • Engineer to flag OHW • In-water work period is July 15 to August 31 • 290.30(a-1) • Contain drilling wastes • Limit turbidity to 10% above ground. Monitoring shall be at 4 hour intervals. • Do not use treated timbers
Contract Requirements 00290 Environmental Protection • 290.30(a-1) • Diapers on mobile equipment within 150 ft of RWA • Staging areas at least 300 ft from RWA • Fueling and storage at least 150 ft from RWA • Spill kits at each site • Water may not come from Bridge Creek. • Need an outside source. • 290.30(b) • PCP to address the OTIA III Materials and Contamination Performance Standards
Contract Requirements 00290 Environmental Protection • 290.30(c-1): Limit idling to 5 minutes except as indicated • 290.30(c-3): Burn restrictions • 290.31(a): Agency Biologist meeting prior to equipment mobilization • 290.31(c): Pump screening • 290.31(d): Prepare and submit a WORK AREA ISOLATION PLAN for work within RWA. • 290.30(e): Bubble curtain when pile driving within water
Contract Requirements 00290 Environmental Protection • 290.31(f): Treat construction water including concrete wash out water and drilling fluids prior to discharge. • 290.31(g) • Prevent nesting on bridges and vegetation • Nesting season is March 1 to September 30. • Inspect bridges and vegetation every 2nd working day • 290.31(h) • Develop and submit an Environmental Compliance Plan • 290.31(i): Contractor (NOT ODOT) is responsible for fish capture and release using a qualified fisheries biologist
Contract Requirements 00290 Environmental Protection • 290.32 • Develop and Submit a Work Containment Plan • Implement a Work Containment System (rigid) • 290.41(a): Agency Biologist meeting • 290.41(b): Fence off Wetland no work areas • 290.50: Fence off no work areas prior to beginning work near the sites
Contract Requirements 00320 Clearing and Grubbing • 320.40(b): Engineer to mark trees to save and Contractor to fence 00340 Watering • 340.10: No water from Bridge Creek 00330 Earthwork • 330.42(c-3): • Outer 12 inches of embankment constructed with material suitable to establish vegetation
Contract Requirements 01030 Seeding • New construction and disturbed ground shall be stabilized by seeding • 1030.42: Seeding window is October 1 thru February 1 • Permanent Seeding outside of these dates requires written permission from the Engineer • If outside of window, seeding is considered temporary. • 1030.44: No fertilizer within 50 ft of water • 1030.48(e): RWA seeding, mulch and biodegradable erosion control matting • 1030.60: 90% coverage of ground surface • 1030.61: Establishment periods ends once coverage is achieved • 1030.62: Establishment work • Recommend watering for achieving coverage sooner • Noxious weed management is required
Contract Requirements 01040 Planting • 1040.04(a): Submit Planting Work Plan within 90 days of award • 1040.04(b): Notify 24 hours in advance of required inspections • 1040.19(g): Contract growing agreement • 1040.42: Planting window is October 15 to November 30 • 1040.70: Plant establishment period begins immediately once the original planting is complete and accepted. Establishment period is one calendar year. • 1040.71: Maintain plantings in vigorous growing conditions • 1040.72: Periodic inspections – quarterly • 1040.73: Success criteria • 100% survival and vigorous growth trees larger than 1/2 inch • 95% survival and vigorous growth of all smaller trees and shrubs • 1040.75: Weed control according to PWP
Contract Requirements NEW DOCUMENTATION REQUIREMENTS • 290.20 – Training documentationmaintained ON-SITE • 290.20(c-1) – Fuel Usage Log maintained ON-SITE and submitted by the 10th of the month • 290.20(c-1) – Equipment with EPA emissions reduction • 290.20(d-2) – Landfill disposal receipts submitted within 7 days of receipt • 290.20(d-3) – Material and Waste Logs • 290.20(i) – Incident Logmaintained ON-SITE • 290.20(i) – Complaint Log maintained ON-SITE • 290.30(a-1) – Daily inspection of coffer damsmaintained ON-SITE • 290.30(a-1) – Turbidity monitoringmaintained ON-SITE • 290.30(a-1) – Daily “diaper” inspectionsmaintained ON-SITE • 290.30(a-1) – Documentation of equipment cleaning and inspection prior to mobilization maintained ON-SITE • 290.30(a-1) – Daily equipment inspections maintained ON-SITE • 290.30(b) – Pollution Control Plan training maintained ON-SITE • 290.31(g) – Bird Exclusion Monitoringmaintained ON-SITE
Contacts Teresa Brasfield Region Environmental Coordinator Oregon Department of Transportation Technical Services Branch 63034 OB Riley Road Bend, OR 97701 teresa.l.brasfield@odot.state.or.us 541.388.6041 / 541.410.7683(cell) Fax: 541.385.0476 Don Peterman Environmental Compliance Monitor Oregon Bridge Delivery Partners 1165 Union Street NE Salem, OR 97301 Don.Peterman@obdp.org 503.269.7213, Fax: 541.312.2321 Shannon Williams Environmental Construction Compliance Manger Oregon Bridge Delivery Partners 1165 Union Street NE Salem, OR 97301 Shannon.williams@obdp.org 503.269.4914, 503.587.3602 Fax: 503.587.2929