OTIA III State Bridge Delivery ProgramOTIA III State Bridge Delivery Program

Environmental Stewardship TrainingUS26: Rush Creek - Antone - Bundle A51

Environmental Stewardship TrainingUS26: 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

Programmatic Permits

Environmental

Performance Standards

Pre-Construction Assessment

(PCA) &

Project Permits

Joint Batched-

Programmatic Biological Opinion for

OTIA III bridges

Project Specification

s &

Contract Drawings

Programmatic Permits

Environmental

Performance Standards

Pre-Construction Assessment

(PCA) &

Project Permits

Joint Batched-

Programmatic Biological Opinion for

OTIA III bridges

Project Specification

s &

Contract Drawings

Programmatic Permits

Environmental

Performance Standards

Pre-Construction Assessment

(PCA) &

Project Permits

Joint Batched-

Programmatic Biological Opinion for

OTIA III bridges

Project Specification

s &

Contract Drawings

Programmatic Permits

Environmental

Performance Standards

Pre-Construction Assessment

(PCA) &

Project Permits

Joint Batched-

Programmatic Biological Opinion for

OTIA III bridges

Project Specification

s &

Contract Drawings

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.

1. If you can, stop the activity from continuing2. Snap a few quick photos for early documentation3. Call the INSPECTOR assigned to the project and TERESA

BRASFIELD 541.388.6041 (office) or 541.410.7683 (cell)4. 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 managerStep 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 documentation maintained 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 Log maintained ON-SITE 290.20(i) – Complaint Log maintained ON-SITE 290.30(a-1) – Daily inspection of coffer dams maintained ON-SITE 290.30(a-1) – Turbidity monitoring maintained ON-SITE 290.30(a-1) – Daily “diaper” inspections maintained 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 Monitoring maintained ON-SITE

ContactsTeresa BrasfieldRegion Environmental CoordinatorOregon Department of TransportationTechnical Services Branch63034 OB Riley RoadBend, OR 97701teresa.l.brasfield@odot.state.or.us541.388.6041 / 541.410.7683(cell)Fax: 541.385.0476

Don PetermanEnvironmental Compliance MonitorOregon Bridge Delivery Partners1165 Union Street NESalem, OR 97301Don.Peterman@obdp.org503.269.7213, Fax: 541.312.2321

Shannon Williams Environmental Construction

Compliance MangerOregon Bridge Delivery Partners1165 Union Street NESalem, OR 97301Shannon.williams@obdp.org503.269.4914, 503.587.3602Fax: 503.587.2929