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 Compliance Branch

Caribbean Environmental Protection Division

U.S. Environmental Protection Agency
City View Plaza, Suite 7000
48 Rd.165 km. 1.2
Guaynabo, Puerto Rico 00968-8069
Compliance Plan For
Administrative Compliance Order
Docket Number CWA-02-2016-3109
Construction of Drilled shaft Retaining Wall at PR-25 Km 1.1
Additional Stabilizations Work S
Municipality of San Juan
AC-002533/R000025033
Dear Mr. Lopez:
As required by item Num. 62 of the above referenced Administrative Compliance Order (ACO), issued on March 4,
2016, the Puerto Rico Highways and Transportation Authority (PRHTA) respectfully submits for USEPA revision
and approval, the Compliance Plan (CP) prepared for the project. This CP intends to comply with the requirements
detailed in the ACO and in the 2012 Construction General Permit (2012 CGP).
In addition we want to inform you that the PRHTA and Del Valle 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 PRHTA aware 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 SWPPP. USEPA via email acknowledged its receipt on
March 3, 2016.
The following is a description of the already performed and proposed 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

ACO.

Mr. Jaime Lopez

March 11, 2016
Page 2

Respondent's contact information for those responsible for the development and implementation of
the Compliance 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 Hemandez P.E. Construction Area Director. Mr. Rosario was designated by
Mr. Arroyo to act on his behalf. Telephone 787- 721-8787 X-1101, nrosario(@Atop.qov.pr

Implementation dates (initiation and completion) for each of the actions to be taken, which shall not
exceed one hundred eighty (180) calendar days of the receipt of this order, unless otherwise
specified
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 PRHTA and Del Valle Group SP (GC);
therefore, a new project schedule including dates for the commencement and completion of the described
actions has been developed. 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 excavation activities will
no longer be performed;
Implementing erosion and sediment controls, and Best Management Practices (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 Environmental Quality Board (provided that a written notification is submitted to
EPA no later than five (5) calendar days before the commencement of such activity. The
notifications shall include a description and itinerary of implementation of the activities to
be undertaken.
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 of the revised itinerary has been included in Appendix A- Project Schedule of the SWPPP and as
Attachment #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
PRR12A825 granted on June 20, 2015. The permit was modified to include the additional stabilization
works and it was re-authorized on March 4, 2016.

Development/Selection, implementation and maintenance of soil stabilization BMP's

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 categories. They are:

Temporary Measures
Temporary measures selected for its use in the project include:

Installation of Silt fences

Reshaping of temporary stabilized entrance/exits
Installation of Erosion control wattles
Construction of temporary swales
Installation of Plastic liners to cover the unstable embankments
Installation of Temporary slope drain ( if deem necessary)
Maintenance of vegetation where possible

The location for the mentioned measures can be observed in the erosion Control
Measures Drawings, (Temporary and Permanent) for the slope stabilization works as
they were incorporated in the Modified SWPPP and also attached to this letter.

Permanent Measures
Permanent measures for slope stabilization were designed in-house by PRHTA Design
Area personnel. Those measures include:

Reshaping and strengthening of the breakwater ( stone revetment

type V)
Removal of unstable material and reconstruction of slopes
embankment with selected material
Placing of top soil
Installation of erosion control Mat 24 month of longevity
Planting of Vetiver Grass (Chrysopongon zizanoides) sierra
variety

Development of site specific inspection report forms

Specific Inspection Forms for the additional works were developed using the forms developed for the
original SWPPP. Copies of the Forms have been included in the modified SWPPP. Inspection reports have
been duly completed and filed since construction resumed.

Performance of inspections by qualified personnel

Inspections of the project for SWPPP purposes will be handled by qualified personnel as defined in the CGP
requirements. The PRHTA has designated the following personnel for conducting the inspections:
Eng. Axel Carrasquillo cuevas
Eng. Eduardo F. Ruiz Velez, P.E.

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 2012 CGP conditions. They will interact with the Del Valle Group SP
designated inspector.

Preparation of inspections reports by qualified personnel

The new forms will be used to document the project inspections and will be performed
indicated by qualified personnel from both the contractor and the PRHTA.

as

previously

Designation of authorized representatives

The designated authorized representative of the PRHTA for the 2012 CGP implementation of this project
will be Eng. Axel Carrasquillo Cuevas. (Cell. phone: 787-487-1313).

Cost estimates to implement the Compliance Plan and each erosion and sediment control.
Stabilization practice and pollution prevention activity
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.

Modified as needed and implement the SWPPP to comply with the terms and requirements of 20112
CGP
The PRHTA has modified the SWPPP jointly developed with Del Valle Group SP (GC) for the Original
project. The SWPPP was revised by the PRHTA to incorporate erosion controls, 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 measures include:
Improved temporary 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 completed slopes
Revised inspections forms
As required by the 2012 CGP, the revised SWPPP incorporates the PRHTA solutions to address the
deficiencies identified in your Reconnaissance Inspection Report of March 17, 2016

We look forward that the submitted information complies with the ACO 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
Cord'

Noe . Rosa o Hernandez

Director
Construction area

ATTACHMENTS

Attachment 1
Cost of implementation of BMP on the Project

ESTADO I.IRR I A SO(' I A DO

PUERTO RICO
Avieridad de Carrot

Transportaeicrni

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

MUNICIPALITY OF SAN JUAN
AC-002533 / R000025033

COST OF IMPLANTATION OF BMP ON THE PROJECT AREA

PERMANENT STABILIZATION AND LANDSCAPING

ITEM

UNIT

DESCRIPTION

QTY

UNIT PRICE

AMOUNT

CuM

Borrow Calss B

3,950.00

$20.00

$79,000.00

SqM

Double Net Erosion Control Blanket

1,818.00

$5.00

$9,090.00

14

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

22

CuM

Sand Filled Geocontainer

203.75

$280.00

$57,050.00

36

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

TEMPORARY EROSION CONTROL

ITEM UNIT

DESCRIPTION

QTY

U NIT PRICE

AMOUNT

Each

Straw Bales

320.00

$12.00

$3,840.00

LnM

Silt Fence

1,200.00

$8.00

$9,600.00

SqM

Double Net Erosion Control Blanket

2,732.00

$5.00

$13,660.00

35

LS

100.00

$62.24

$6,224.00

41

Each

Special and/or Additional Works

(Barrera para minizar turbidez en el mar)
Construction Exit

1.00

$2,500.00

$2,500.00

42

LS

Special and/or Additional Works (asphalt berm)

100.00

$25.00

$2,500.00

44

SqM

Plastic Liner

1,700.00

$8.00

$13,600.00

TOTAL

$426,710.00

AVOCIODID Of tfiNbffetaf

rrwwPavdtatw

Attachment 2
Project Schedule

0,

zasTIVM

F in al Clean ing

Vetiver G rass

E rosion Net Control Bl a nk et

Fin al Backlit!

U ncl . E xca vation

Backfill

Stone R evetmen t

tst allation Fitter Fabric Geotextile

Exca vation(Stone Revetm en t Area)

Const ruction D iversion D ike

I nstallatio n

Const ruction E nt rance, Silt Fence, S t r aw B ale

g
04.Elihitkiri-

30

30

INIV13V JAMS 111V0

Approval EWO Doc ument

General Activities

M obilization

Constructio n Activities

GC-000

anteu 30 NOIDDMI

Ew

CA-99-999
P11-070
PII-070
PII-070
PD-070
PII-070

PII-070

PII-070

.,

.1,

ii1

'"

ACT-174
(Rev. 6/92)

Estado Libre Asociado de Puerto Rico

Departamento de Transportacion y Obras Publicas
AUTORIDAD DE CARRETERAS Y TRANSPORTACION

HOJA DE TRAMITE
RECIBIDO
FECHA:

15 de marzo de 2016

A: 1er.

Sr. Jaime Lopez-EPA

A: 2do.

A: 3ro.

= ri ..,,,c

A: 4to.

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70

A: 5to.

C.,,
C)

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

DE:
ASUNTO:

COMPLIANCE PLAN FOR ADMINISTRATIVE COMPLIANCE ORDER

DOCKET NUMBER CWA-02-2016-3109
AC-002533

Corres. Fechada:

Corres./De:

Necmi
MO

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