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Report Teanaway Solar Reserve Fugitive Dust Control Plan Kittitas County, Washington Prepared for Teanaway Solar Reserve, LLC February 2010 Prepared by

Teanaway Solar Reserve Fugitive Dust Control Plan Kittitas ......The following Fugitive Dust Control Plan is for the proposed Teanaway Solar Reserve in Kittitas County, Washington

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  • Re p or t

    Teanaway Solar Reserve Fugitive Dust Control Plan

    Kittitas County, Washington

    Prepared for

    Teanaway Solar Reserve, LLC

    February 2010

    Prepared by

  • ES021010193130PDX III

    Contents

    1.0 Introduction ...................................................................................................................... 1

    2.0 Project Contacts................................................................................................................ 1

    3.0 Project Description .......................................................................................................... 1 3.1 Projection Location ................................................................................................. 1 3.2 Soil Conditions ........................................................................................................ 2 3.3 Prevailing Wind Direction ..................................................................................... 2

    4.0 Potential Dust Sources ................................................................................................... 2

    5.0 Best Management Practices: Fugitive Dust Control Methods ................................ 3

    6.0 Best Management Practices: Contingency Measures ................................................ 4

    7.0 Self-Inspection Checklist ............................................................................................... 4

    8.0 References ......................................................................................................................... 4

    Appendices

    A Figures B AGC Guide to Handling Fugitive Dust from Construction Projects C Eastern Washington Stormwater Management Manual, BMP C140 and BMP C126 D WSDOT Chemical Dust E Self-Inspection Checklists Tables

    1 Project Contact List .................................................................................................................... 1 2 Dust Activities and Applicable Dust Control Measures ...................................................... 3

    Figures (Provided in Appendix A)

    1 Vicinity Map 2 Proposed Site Layout

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN

    ES021010193130PDX 1

    1.0 Introduction The following Fugitive Dust Control Plan is for the proposed Teanaway Solar Reserve in Kittitas County, Washington. Teanaway Solar Reserve, LLC proposes to construct and operate the Teanaway Solar Reserve (project), a solar farm capable of generating up to 75 direct current megawatts (MWdc) of photovoltaic (PV) solar energy. This plan has been prepared in response to public and agency comments and for additional information as part of the addendum to the SEPA Expanded Checklist, originally submitted in August 2009.

    2.0 Project Contacts Table 1 provides the current project contacts for the project site during business hours, after hours, and weekend control when necessary.

    TABLE 1 Project Contact List

    Description Name Address Work Phone Other Phone

    Project Owner Howard Trott 218 E. First Street, Suite B Cle Elum, WA 98922

    (206) 972-3800

    General Contractor or Builder

    TBD

    Site Developer or Excavator

    TBD

    24-Hour Contact Person

    TBD

    3.0 Project Description 3.1 Projection Location The proposed project site is located approximately 4 miles northeast of Cle Elum, Washington, in Township 20N, Range 16E, within Sections 22, 23, and 27 (see Figure 1 in Appendix A for site location). The site is located on the eastern slopes of the Cascade Mountains on Cle Elum Ridge, which runs generally from east to west at elevations ranging from approximately 2,200 to 2,600 feet. The Teanaway River is approximately 1 mile to the northeast of Cle Elum Ridge. The site is accessed from Highway 970 by way of county roads such as Red Bridge Road, private roads such as Loping Lane, and Wiehl Road, which is a dedicated public road that is maintained privately and not by the County.

    The proposed project area consists of 982 acres. Based on site surveys, the project will utilize approximately 477 acres within the proposed project area. Solar arrays will be placed on approximately 399 acres. The undeveloped acres will remain as open space and be

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN

    2 ES012210002547PDX

    preserved as part of the Wildlife Mitigation Plan (see Attachment H). An open corridor will be maintained to allow for wildlife migration through the site.

    3.2 Soil Conditions Soils on the proposed project site include the Teanaway Loam, 3 to 10 percent slopes, and the Teanaway Loam, 25 to 50 percent slopes (NRCS, 2008). These soils are formed in loess that overlies glacial till or outwash, with an influence of volcanic ash at the surface. These soils are described as moderately well-drained, moderately low to moderately high permeability, high available water capacity, and no flooding or ponding frequency. The Teanaway Loam is assigned to wind erodibility group (WEG) 5. The WEG consists of soils that have similar properties affecting their susceptibility to wind erosion in cultivated areas. The soils assigned to WEG 1 are the most susceptible to wind erosion, and those assigned to WEG 8 are the least susceptible. Therefore, the wind erosion potential of the soils onsite is considered low to moderate.

    Based on observations at the site made during the geologic field reconnaissance (November 2009), the site soils consist primarily of silty to silty sand loess with volcanic ash, with numerous rounded cobbles and boulders scattered across the surface. Site slopes are typically less than 20 percent in steepness, with a few areas of slopes up to 30 percent. The slopes on the site are relatively planar or exhibit a drainage pattern typical of fluvial processes (i.e. surficial runoff) rather than mass movement.

    No major areas of surficial soil erosion or gullying were observed during the geologic field reconnaissance. The erosional features present at the project site are typical of precipitation runoff.

    3.3 Prevailing Wind Direction A wind rose plot for Yakima, Washington, approximately and hour away from the project site, was used to estimate the prevailing wind direction for the project site. According to the Office of the Washington State Climatologist, the prevailing wind direction near the project site is to the east. Winds typically blow to the east at average speed of 6.51 knots (OWSC, 2010).

    4.0 Potential Dust Sources The following potential dust sources will exist at the project area. These dust sources are shown on Figure 2 (see Appendix A).

    • Construction of a 6-acre electrical substation and associated facilities • Construction of a 345-kilovolt (kV) transmission line and associated 300-foot corridor

    (TSR has delineated a 300-foot area within which the BPA transmission line could be sited. Of this 300-foot area, a maximum of 200 feet will be cleared for the placement of the BPA transmission line. Final design and placement will be determined by BPA.)

    • Access and maintenance roads • Installation of solar arrays • Clearing and grading the site

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN

    ES012210002547PDX 3

    5.0 Best Management Practices: Fugitive Dust Control Methods The best management practices (BMPs) for this project were selected from two regional guidance documents (1) the Associated General Contractors (AGC) of Washington in the publication, Guide to Handling Fugitive Dust From Construction Projects (see Appendix B), and (2) the Eastern Washington Stormwater Management Manual. The following is a list of BMPs compiled by the AGC for control of fugitive dust. Copies of this publication can also be requested from WSDOT and Puget Sound Clean Air Agency. The Eastern Washington Stormwater Management Manual provides additional guidance for dust control: BMP C140 and BMP C126 (see Appendix C). The following is a list of commonly employed fugitive dust management practices for various construction related dust sources. • Covering – Fabric/Other for Erosion Control • Road Dust Suppressants • Erosion Controls • Flocculating Agent • Minimize Disrupted Surface Area • Schedule Work: Reschedule work around especially windy days • Speed Reduction

    Table 2 shows the selected methods to be used to control dust at the project sources. The Fugitive Dust Control Plan should be considered in conjunction with the overall construction Stormwater Pollution Prevention Plan (SWPPP), which is required as part of the National Pollutant Discharge Elimination System (NPDES) Permit, administered by the Washington State Department of Ecology.

    TABLE 2 Dust Activities and Applicable Dust Control Measures

    Activity Applicable Dust Control Measures

    Unpaved Roads and Lots Applying dust suppressants Graveling Reducing vehicle speed Minimizing disrupted surface areas Erosion control

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN

    4 ES012210002547PDX

    TABLE 2 Dust Activities and Applicable Dust Control Measures

    Activity Applicable Dust Control Measures

    Construction and Landscaping

    Graveling areas early Applying road dust suppressants Reducing vehicle speed Minimizing disrupted surface areas Restricting dust-causing activities during high wind periods Limiting vehicle traffic Using chutes and covered dumpsters Revegetating disturbed areas in accordance with the Revegetation Plan as soon as practical

    Material Storage, Handling, and Transportation

    Applying road dust suppressants Using wind impervious covers Minimizing truck load size Stabilized rock construction entrance

    6.0 Best Management Practices: Contingency Measures Although water can be one of the main control agents for dust, it is important to plan ahead for water shortages and consider the use of other measures. When water will not be available, exposed soils will be sprayed with a dust palliative. Chemical dust suppressant application will follow guidelines outlined in BMP C126 in Appendix C. Kittitas County staff have also recommended the use of chemical dust suppressants. Additional consideration will be given to alternative chemical dust suppressants listed in the Washington State Department of Transportation Environmental Procedures Manual (see Appendix D).

    7.0 Self-Inspection Checklist A self-inspection checklist will be used for each source of fugitive dust emissions to help incorporate routine tasks of fugitive dust control into daily schedule. The checklist will serve as a job reminder on a daily basis and as a record of efforts to keep dust problems to a minimum. Additionally, a separate checklist will be used to document weather conditions. These checklists are anticipated to be modified once the construction begins and as needed throughout the construction process. Self-inspection checklists are in Appendix E. These checklists will be incorporated into the weekly storm water inspections sheets required as part of SWPPP. Inspections will be conducted by personnel trained in all parts of the Fugitive Dust Control Plan as well as the SWPPP.

    8.0 References Associated General Contractors of Washington (AGC). 1998. Guide to Handling Fugitive

    Dust From Construction Projects.

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN

    ES012210002547PDX 5

    Office of the Washington State Climatologist (OWSC). 2009. Wind Rose Plot for Yakima, Washington. http://www.climate.washington.edu/climate.html.

    Washington Department of Ecology (WDE). September 2004. Stormwater Management Manual for Eastern Washington. http://www.ecy.wa.gov/biblio/0410076.html.

    Washington State Department of Transportation (WSDOT). 2009. Environmental Procedures Manual. http://www.wsdot.wa.gov/Publications/Manuals/M31-11.htm.

    http://www.climate.washington.edu/climate.html�http://www.ecy.wa.gov/biblio/0410076.html�

  • APPENDIX A

    Figures

  • FIGURE 1Vicinity MapFugitive Dust Control PlanTeanaway Solar ReserveKittitas County, Washington

    \\ROSA\PROJ\AFLC\391226\GIS\MAPFILES\DRAFT\SEPA_SUPPLEMENT\DUSTPLAN\DP_VICINITYMAP.MXD AROBERT6 1/18/2010 14:24:07

    VICINITY MAP

    Note:1. USGS 100K Quadrangle: Wenatchee.

    90

    97

    970

    970

    10

    TEANAWAY RD.

    Proposed Project Area

    Cle Elum

    SouthCle Elum

    0 21

    Miles

    LEGENDProposed Project AreaCity BoundaryInterstateHighwayMajor Road Teanaway

    Solar Reserve

    Washington

    Idaho

    Oregon La GrandePortland

    Salem

    Olympia

    Seattle Spokane

    Yakima

  • FIGURE 2Proposed Site LayoutFugitive Dust Control PlanTeanaway Solar ReserveKittitas County, Washington

    \\ROSA\PROJ\AFLC\391226\GIS\MAPFILES\DRAFT\SEPA_SUPPLEMENT\DUSTPLAN\DP_PROPOSEDSITELAYOUT.MXD AROBERT6 2/16/2010 14:47:48

    Wieh

    l Roa

    d

    Loping Lane

    Red B

    ridge Road

    LEGENDProposed Project Features

    Proposed Project Area (982 Acres)Proposed Project Site (477 acres)

    Proposed PV Array BlockProposed Field Inverterand Field TransformerProposed Substation/O&M Facility

    Proposed Transmission LineProposed Transmission Structure

    Proposed Maintenance RoadProposed Improved Maintenance RoadExisting Maintenance Road(Planned Decommissioning)Proposed Improved County Access RoadProposed Improved Private Access Road

    Existing Features

    Existing BPA Transmission Line and ROWExisting Road

    StreamStream Buffer

    WetlandWetland Buffer

    VICINITY MAP

    TeanawaySolar Reserve

    Washington

    Idaho

    Oregon La GrandePortland

    Salem

    Olympia

    Seattle Spokane

    Yakima

    0 1,000

    Feet

    1 inch = 1,000 feet

    Prevailing Wind Direction to the East

  • APPENDIX B

    AGC Guide to Handling Fugitive Dust from Construction Projects

  • AGC OF WASHINGTONEDUCATION FOUNDATION AND

    FUGITIVE DUST TASK FORCE

    GUIDETO HANDLING

    FUGITIVE DUSTFROM CONSTRUCTION

    PROJECTS

  • We would like to gratefully acknowledge theFugitive Dust Task Force that provideddirection, technical advice and editing:

    • Michael Bernbaum, Teamsters - Local 174• Camilla Bishop, AGC Education Foundation• Mark Davies, CSR Associated• Roland Dewhurst, AGC - Southern Dist.• Richard Dickson, Wm. B. Dickson Co.• Peter Downey, Dept. of Transportation• John Hennessy, Nuprecon, Inc.• Rick Hess, PSAPCA• Ed Lizak, Nuprecon, Inc.• Rebecca Murray, Nuprecon, Inc.• Gerry Pade, PSAPCA• Mark Sandy, Operating Engine.ers• Frank Scarsella, Scarsella Bros., Inc.• Mike Schultz, PSAPCA• Mike Tollkuehn, Woodworth & Co.

    We would also like to acknowledge the technicalassistance provided by:

    • Mabel Caine, SCAPCA• Bob Gilmore, Garry Struthers Associates, Inc.• David Lauer, BCCAA• Doug Nelson, Active Construction• Scott Parker, Argus Pacific• Craig Weckesser, OAPCA

    Some illustrations are courtesy of the CalforniaEnvironmental Protection Agency, Air ResourcesBoard, Compliance Division.

    Chapter 90.48 RCW - Water PollutionControl: Section .080 prohibits thedischarge of any material into surface orground waters that could cause pollution asdefined in WAC 173-200-020(22). If yoursite is near surface or ground water, usedust control measures that have zero orminimal aquatic impact. If you decide to usea chemical dust suppressant, select aproduct with no aquatic toxicity.

    Chapter 70.105 RCW - Hazardous WasteManagement: This statute prohibits thedisposal to the ground of any dangerous(hazardous) waste. If you are planning touse a chemical dust suppressant, makesure it does not contain any dangerouswaste ingredients.

    Chapter 70.1050 RCW - Hazardous WasteCleanup - Model Toxics Control Act(MTCA): This law requires the identificationand cleanup of hazardous sites, TheDepartment of Ecology can investigatereports of releases or the presence ofhazardous substances. If a hazardousproduct is used as a dust suppressant andEcology later receives a complaint ofcontamination, a site assessment may beconducted,

    Chapter 90.03 RCW - Surface Water Codeand Chapter 90.44 RCW Regulations ofPublic Ground Water (wells): Thisregulation requires a water right permit forall surface water withdrawal and for anywater from a well that will exceed 5,000gallons per day. If you plan to use water,and have questions about it, call theDepartment of Ecology's Water ResourcesProgram.

    17

  • GUIDE TO HANDLINGFUGITIVE DUST FROM

    CONSTRUCTION PROJECTS

    WASHINGTON STATE DEPT. OF ECOLOGYS. LOCAL AIR POLLUTION CONTROL AGENCIES

    CONTENTS

    INTRODUCTION 1

    ADEPARTMENT OF ECOLOGY - EAST REGIONNorth 4601 Monroe, Suite 202Spokane, WA 99205-1295(509) 456-2926

    B OLYMPIC AIR POLLUTION CONTROL AUTHORITY909 Sleater-Kinney Rd. SE, #1Lacey, WA 98503(360) 438-8768 or 1-800-422-5623

    CSPOKANE CO. AIR POLLUTION CONTROL AUTHORITY1101 West College Avenue, Suite 403Spokane, WA 99201(509) 477-4727

    DNORTHWEST AIR POLLUTION AUTHORITY1600 S. Second SI.Mount Vernon, WA 98273(360) 428-1617 or 1-800-622-4627

    EPUGET SOUND CLEAN AIR AGENCY110 Union 51.. Suite 500Seattle, WA 98101(206) 343-8800 or 1-800-552-3565

    FBENTON COUNTY CLEAN AIR AUTHORITY650 George Washington WayRichland, WA 99352(509) 943-3396

    GSOUTHWEST AIR POLLUTION CONTROL AUTHORITY1308 N.E. 1341h S1ree1Vancouver, WA 98685(360) 574-3058 or 1-800-633-0709

    HDEPARTMENT OF ECOLOGY N.W REGION3190 -1601h Ave. SEBellevue, WA 98008-5452(425) 649-7000

    I YAKIMA COUNTY CLEAN AIR AUTHORITY6 South 2nd St.,Room 1016Yakima, WA 98901(509) 574-1410 or 1-800-540-6950

    J DEPARTMENT OF ECOLOGY - CENTRAL REGION15 W. Yakima Ave.. Suile 200Yakima, WA 98902(509)575-2490

    WHY FUGITIVE OUST IS A PROBLEM 2

    PRE-CONSTRUCTION PLANNING 3

    SITE-SPECIFIC DESIGNCONSIDERATIONS 5

    COMMON FUGITIVE OUSTMANAGEMENT PRACTICES 7

    DESCRIPTIONS OF BESTMANAGEMENT PRACTICES 9

    APPLICABLE WASHINGTONREGULATIONS 16

    LOCAL AIR POLLUTION CONTROLAUTHORITIES 18

  • APPLICABLE WASHINGTONREGULATIONS

    It is important to make sure that yourFugitive Dust control practices complywith federal, state and local laws. Thefollowing is a list of some of theregulations that apply; however contactyour local Air Pollution Control Agency,County Health Department and/or PublicWorks Department to find out the specificrequirements for the area in which yourproject is located.

    Local Air Pollution Control AgencyRegulations: Contact your local airpollution control agency for the specificregulations appropriate to the location ofyour project. These agencies and theirphone numbers are listed on the lastpage of this brochure.

    Chapter 70.94 RCW - WashingtonClean Air Act and Chapter 173-400WAC: These statutes require ownersand operators of Fugitive Dust sources toprevent Fugitive Dust from becomingairborne and to maintain and operatesources to minimize emissions.

    Chapter 70.951 RCW - Used OilRecycling: This law prohibits the use ofused oil as a dust suppressant. Used oilincludes any oil that has been refinedfrom crude oil, used, and as a result ofsuch use, is contaminated by physical orchemical impurities. If you plan to use achemical suppressant, verify that it doesnot contain any used oil as aningredient. Also, be certain that if theproduct contains fuel oil ingredients thatthe fuel oil does not contain used oil.

    Chapter 46.61.655 RCW - DroppingLoad, Other Materials - Covering: Thisregulation prohibits the discharge ofdebris from vehicles and prescribesminimum loading standards in lieu ofcovering truck beds.

    16

    INTRODUCTION

    Fugitive Dust is particulate matter that issuspended in the air by wind or humanactivities and does not come out of a stack.

    Air quality regulations require the use ofcontrol techniques to minimize Fugitive Dustemissions. The goal is to eliminate visibleairborne Fugitive Dust. Therefore, state andlocal regulatory agencies expect that asmany of these control techniques beemployed as necessary to achieve this goal.

    Reasons for Fugitive Dust ControlFugitive Dust from construction projects isregulated by the Washington State airquality laws for several reasons:

    1. Fugitive Dust can become a nuisance toneighbors by depositing on theirproperty;

    2. Inhaling Fugitive Dust particles cancause respiratory diseases;

    3. Fugitive Dust can be a direct safetyhazard.

    Purpose of BrochureThis brochure is designed as a guide toprovide practical examples of suggestedbest management practices necessary tocomply with air quality regulations involvedin the construction process.

    While Fugitive Dust can be created from avariety of activities, such as agriculturalactivities, this brochure will focus on FugitiveDust that is created by constructionactivities. Air pollution from debris burning,plant operations, rock crushing and abrasiveblasting, sometimes associated withconstruction activities, are dealt with in otherregulations and publications. For additionalinformation on the subject, the numbers oflocal air quality agencies are listed in theback of this brochure.

    1

  • comparison to other methods. Heavywatering can also create mud, run-off, andenvironmental problems.

    \

    '--I

    I~-------

    PLAN VIEW

    -- --

    WHEEL WASH: A wheel wash is amethod to remove mud and dirt fromwheels by driving through a shallowtrench filled with water or onto an areawhere the wheel wells and undercarriagecan be hosed down. Care should betaken to keep the trench deep enoughthat it is effective, but not so deep that itinterferes with the mechanical operationsof the vehicles. The trench may be linedwith asphalt to ease maintenance inrem'wing collected silt. A wheel wash canbe used in conjunction with brooms orhoses to remove dirt from other areas ofvehicles. Wheel washes must have acontainment area to take care of the run-off.

    VEHICLE SCRAPE: This is an alternativeto a wheel wash when water disposal, orother environmental constraints, arepresent. Establishing a specific areawhere compact dirt or mud is removedfrom ledges of dump trucks, wheel wells,hitches, tires, and other confined areas,will reduce track out.

    NuisanceIt is unlawful in the state of Washington tocause or allow air contaminant emissions insufficient quantities and of suchcharacteristics and duration that itunreasonably interferes with enjoyment oflife and property.

    SafetyFugitive Dust from construction can reducevisibility on roadways and highways,resulting in traffic accidents.

    WHY FUGITIVE DUST IS A PROBLEM

    HealthFugitive Dust can also have significanthealth effects if it is inhaled in largeamounts, or if dust contains crystalline silica,asbestos fibers, heavy metals or diseasespores. Very small particles can be inhaleddeep into lungs and are a particular healththreat for the young, the old, and those withchronic respiratory problems.

    Fugitive Dust can be created directly fromthe activities involved in construction, suchas moving soils or demolishing structures.Fugitive Dust can also be generated bydisturbing residual soils or materials thathave been left behind by constructionactivities. For example, vehicles cangenerate Fugitive Dust from dirt onroadways that was tracked out as mud fromconstruction sites.

    2 15

  • STREET SWEEPERS: Street sweepersare often used in conjunction with water.Some sweepers have a spray as well asbrushes. However, sweepers can spreadmud when there is a lot of wetness.Some sweepers, for parking lots andsmaller jobs, actually have vacuumsystems to trap Fugitive Dust. Drysweeping is discouraged, especially invery dry climate conditions, because itcauses dust particles to become airborne.

    VEHICLE SPILLAGE: Covers for haultrucks help to prevent soils and othermaterials from being dropped on roads.However, covering loads is not requiredby state law if six inches of freeboard ismaintained within the bed of the truck.

    Vehicles driving over dirt and other debristracked onto roads can cause significantFugitive Dust emissions. Reducing thedrop height for loading equipment, wetsuppression, and wind guards areeffective ways of minimizing the FugitiveDust created during loading operations.

    WATER SPRAY: Water spray, whether itis through a simple hose for smallprojects, or a water truck for largeprojects, is an effective way to keepFugitive Dust under control. Mistingsystems and sprinklers are mechanismsthat can be employed to delivercontinuous wetness. However, there areseveral constraints in using water. Watercan be very costly for larger projects in

    14

    PRE-CONSTRUCTION PLANNING

    Fugitive Dust control planning is apartnership between the owner, generalcontractor, subcontractors and any otherparty whose activities during the projectmay lead to the generation of FugitiveDust. This partnership extends to legalresponsibilities as well in that all partiescan be held liable for non-compliance andsubsequent regulatory actions, includingmonetary penalties.

    Incorporating Fugitive Dust controlmeasures in the plans and specificationsof the project can help ensure that theparticipants in the constructionpartnership avoid violations of FugitiveDust regulations. Early planning can alsohelp owners and project designers to"level the playing field" in the competitivebid process and avoid change orders.

    A Fugitive Dust control plan mightinclude:

    o Identification of all Fugitive Dustsources.

    o A description of the Fugitive Dustcontrol method(s) to be used for eachsource.

    o A schedule, rate of application,calculations or some other means ofidentifying how often, how much andwhen the control method is to beused.

    o Provisions for monitoring and record-keeping.

    o A backup plan in case the first controlplan does not work or is inadequate.

    o The name and phone number of theperson responsible for making surethe plan is implemented and who canbe contacted in the event of a FugitiveDust complaint.

    o Back-up or company phone number.o Map or drawing of the site.

    3

  • o Source and availability of materialssuch as water.

    Weather, equipment and site conditionswill require that field personnel make onthe spot, common sense changes inorder to address the intent of theregulations.

    Incorporating a simple inspectionchecklist during the daily report processhelps make the tasks of Fugitive Dustcontrol more routine. A checklist systemreduces paperwork, acts as a jobreminder, and serves as a record ofefforts to minimize Fugitive Dustproblems. Categories that might beincluded in the checklist are:

    o Dateo Timeo Preventative measureso Frequency of control measures

    applicationo Weather conditionso Comments

    REMEMBER: Fugitive Dust controls areonly effective when they are monitoredand managed through frequentinspections and maintenance of controlmeasures.

    4

    SCHEDULE WORK: Rescheduling workaround especially windy days canpotentially be one of the least expensiveand easiest Fugitive Dust controlmeasures. This can also be a totallyimpractical option if work crews are idleand/or this is a project with significanttime constraints. It is also unreasonableto expect to discontinue work ingeographical areas that are prone to highand continueous winds. However, limiteduse of rescheduling in extreme weatherconditions, might be appropriate.

    The high profile aspects of certainprojects and population exposed shouldbe taken into consideration whenscheduling especially Fugitive Dustproducing work. Evenings and weekendsare possible alternatives for schedulingwork in business and school locations;while mid-day may be more appropriatefor residential areas because people aremore likely to be away from home.

    SPEED REDUCTION: High vehiclespeeds increase the amount of FugitiveDust created from unpaved roads andlots. Reducing the speed of a vehiclefrom 45 to 35 miles per hour can reduceemissions by up to 22 percent accordingto a Washington State Department ofEcology study. However, no more than 5to 15 miles per hour is recommended formost conditions. Speed bumps are acommonly used method to ensure speedreduction. In cases where speedreduction cannot effectively reduceFugitive Dust, it may be necessary todivert traffic.

    13

  • Disturbing natural soil crusts in somegeographical areas, such as Central andEastern Washington, may unnecessarilycreate Fugitive Dust situations. Limitingvehicle access points to, and routeswithin, a project help to reduce thesedisruptions.

    PAVING: This is a more permanentsolution to Fugitive Dust control, suitablefor longer duration projects or situations.High cost is the major drawback topaving. Paving may be an appropriatesolution for access roads to largedevelopment projects, where the roadcan eventually be incorporated in theoverall plan for the area. Anotherappropriate use of paving might be"maintenance" projects such as parkinglots and staging areas, where gravelcover is not adequate for Fugitive Dustcontrol or erosion.

    QUARRY SPALLS: These are bufferareas that minimize the amount ofmaterial tracked on to a trafficked roadsurface, sometimes called "rockentrances". These buffer areas consist ofvery large aggregate,usually 4" to 8"crushed quarry rock, which jars particlesfree from wheels and undercarriage, asvehicles travel over the spall. Thisaggregate is sometimes laid over a fabricroad carpet to increase effectiveness. Aspall with typical dimensions is illustratedbelow.

    ------- ,!il;--R=lS' MIN.

    I

    '::3~INQ~l': ) ')'PROVIDE FULL WIDTH OF ./.INGRESSJEGRESS AREA

    12

    SITE-SPECIFIC DESIGNCONSIDERATIONS

    The specifics and level of complexity ofeach Fugitive Dust control plan willdepend on a number of factors that arespecific to each project. Consider thefollowing:

    Cost of Alternatives: Several factorsmust be taken into consideration whenweighing various alternatives. Costconsiderations include unit cost, totalproject cost, acquisition cost, mainten-ance cost, cost of non-compliance,capital cost, and the cost of time waitingfor product or application. While onemethod may not be cost effective forlarge projects because the unit cost ishigh, it may be cost effective for smallprojects because the acquisition cost islow.

    Environmental Constraints: Waterapplication is one of the best short termmethods for controlling Fugitive Dust.However, water run off containing mudand silt can cause damage to streamsand other resources. A Fugitive Dust planshould be considered in conjunction withthe overall Temporary Erosion andSediment Control (TESC) plan. TheDepartment of Ecology can be contactedfor even more specific information.

    Location: The proximity of the project topopulated areas may dictate morecontrols, due to anticipated impacts, thana project in a remote location. Wildlifehabitats and wetlands may also beaffected by Fugitive Dust.

    project Size and Duration: The marketplace will not practically allow for thesame rigors of control to be applied on allprojects. For example, a land clearingproject involving several acres or a majorexcavation project may call for truckwheel washing facilities, while this maynot be practical for clearing a residential

    5

  • using this type of control must bedetermined on a case-by-case method.

    FILTER FABRIC AROUND CATCHBASIN:Filter fabric around a catch basin is usedto collect sediment from muddy waterrun-off. Sediment, when left to dry, cancause Fugitive Dust emissions.Sediment collected in filtering systemsmust be dealt with on a regular basis.Treating mud with floculants, or "muckingout" catch basins, are two methods todeal with the residual debris.

    MINIMIZE DISRUPTED SURFACEAREA: A conscious effort, especiallyduring sitework and/or demolition, todisrupt only those areas that absolutelyneed to be cleared in order to accomplisha project can provide a variety of benefits.Vegetation left in place during siteworkreduces the area subject to wind erosion.In addition, minimizing the disruptedsurface area can also reduce the size ofthe project, potentially reducing the typesand cost of Fugitive Dust control.

    ~,N

    WR( rA8RIC M (()JAl2 • 2 • 14 c.... v.£lOCD

    fILTER FABRIC WAl(R1Al 60' 'MOE RQJ.SUSE STAPlES Cfi 'MRE RINGS TOAITATQt fABRIC TO 'MR(

    PROVlQ[ 3/4"-1.5"WA~EDCRAV[l BAO

  • DUST SUPPRESSANTS - CHEMICAL:There are many types and brands ofChemical Dust Suppressants which workby binding lighter particles. ChemicalSuppressants may be applied as asurface treatment to "seal" the top of anarea, or may be applied using an admixmethod that blends the product with thetop few inches of the surface material.

    Examples of these products include, butare not limited to, hydrolyzed starchderivatives, calcium chloride, magnesiumchloride, lignin derivatives, tree resinemulsions, and synthetic polymeremulsions. Other products, andproperties of products, can be found inthe Department of Ecology's "Techniquesfor Dust Prevention and Suppression", aswell as from many vendors.USED OIL CAUTION: It is important tonote that used oil may NOT be used as adust suppressant. RCW 70.951specifically prohibits the use of used oilas dust suppressant, and is referenced inthe "Applicable Washington Regulations"section of this brochure.

    EROSION CONTROLS: Plants, bushes,trees, earthen banks and rock wallsprovide natural, and more permanent,windbreaks. Other erosion controlmeasures, such as wood or porousfences can be installed for temporarymeasures. Because enclosures and windscreens can be costly the feasibility of

    10

    COMMON FUGITIVE DUSTMANAGEMENT PRACTICES

    The following is a list of commonlyemployed Fugitive Oust managementpractices for various dust sources.The best management practices for aparticular project should be selectedbased upon site-specificconsiderations.

    GRADERS AND SCRAPERS:• Use water truck or sprinklers to

    moisten soils before grading• Minimize areas of clearing and

    grubbing to a manageable size• Minimize timeframes between Fugitive

    Oust-creating activities and finalsolutions (ex., roadway excavation andpaving)

    • Avoid activity during high winds

    FRONT-END LOADERS AND BACK-HOES:• Use water truck to keep soils moist• Use water sprays (e.g. garden hose)

    when dumping soils into haul trucks• Minimize drop height• Avoid activity during high winds

    HAUL TRUCKS:• Wet loads with garden hose• Ensure adequate freeboard• Cover loads• Reduce speed on unpaved haul roads

    to less than 15 mph• Use water truck to keep haul roads

    moist• Surface haul roads with gravel

    7

  • • Pave haul roads• Pave exit aprons• Surface exit aprons with quarry spalis

    (aka "rip rap")• Brush off mud from wheels, wheel

    wells, running boards and tail gates• Wash wheels and inner fender wells

    immediately prior to exiting (note: thiscontrol may require installation of asedimentation basin)

    • Use street sweeper to removetrackout from paved roadways (note:sweepers should be periodicallychecked to insure that the waterstorage tank is full and spray nozzlesare in good working order)

    • Flush streets with water (note: thiscontrol may require the installation ofa sedimentation basin)

    DEMOLITIONS:• Use water sprays (e.g., fire hoses)

    before, during and after use ofwrecking ball or bulldozer

    • Avoid activity during high winds

    RENOVATIONS:• Use chutes and covered dumpsters

    for lowering dusty materials (e.g.,sheetrock) from multi-story buildings

    • Avoid activity during high winds

    STORAGE PILES:• Use sprinklers to keep piles moist• Use tarps to cover piles• Use soil stabilizers

    8

    DESCRIPTIONS OF BESTMANAGEMENT PRACTICES

    Fugitive Dust emissions can beprevented and reduced in four basicways:

    o Limiting the creation or presence ofdust-sized particles.

    o Reducing wind speed at ground level.o Binding dust particles together.o Capturing and removing Fugitive Dust

    from its sources.

    These Fugitive Dust control measuresare not mutually exclusive. Mostsituations require the use of two or moreof these methods in combination for anyparticular situation, and several methodswill be employed to handle the variety ofsituations that make up a particular job.

    COVERINGS - FABRIC/OTHER, FOREROSION CONTROL: Fabrics andplastics for covering piles of soils anddebris can be an effective means toreduce Fugitive Dust. However, thesematerials can be costly and are subject todegradation from the sun, weather, andhuman contact. Straw and hay can alsobe used to cover exposed soil areas,although they can be disturbed by windand track through.

    9

  • • Pave haul roads• Pave exit aprons• Surface exit aprons with quarry spalis

    (aka "rip rap")• Brush off mud from wheels, wheel

    wells, running boards and tail gates• Wash wheels and inner fender wells

    immediately prior to exiting (note: thiscontrol may require installation of asedimentation basin)

    • Use street sweeper to removetrackout from paved roadways (note:sweepers should be periodicallychecked to insure that the waterstorage tank is full and spray nozzlesare in good working order)

    • Flush streets with water (note: thiscontrol may require the installation ofa sedimentation basin)

    DEMOLITIONS:• Use water sprays (e.g., fire hoses)

    before, during and after use ofwrecking ball or bulldozer

    • Avoid activity during high winds

    RENOVATIONS:• Use chutes and covered dumpsters

    for lowering dusty materials (e.g.,sheetrock) from multi-story buildings

    • Avoid activity during high winds

    STORAGE PILES:• Use sprinklers to keep piles moist• Use tarps to cover piles• Use soil stabilizers

    8

    DESCRIPTIONS OF BESTMANAGEMENT PRACTICES

    Fugitive Dust emissions can beprevented and reduced in four basicways:

    o Limiting the creation or presence ofdust-sized particles.

    o Reducing wind speed at ground level.o Binding dust particles together.o Capturing and removing Fugitive Dust

    from its sources.

    These Fugitive Dust control measuresare not mutually exclusive. Mostsituations require the use of two or moreof these methods in combination for anyparticular situation, and several methodswill be employed to handle the variety ofsituations that make up a particular job.

    COVERINGS - FABRIC/OTHER, FOREROSION CONTROL: Fabrics andplastics for covering piles of soils anddebris can be an effective means toreduce Fugitive Dust. However, thesematerials can be costly and are subject todegradation from the sun, weather, andhuman contact. Straw and hay can alsobe used to cover exposed soil areas,although they can be disturbed by windand track through.

    9

  • DUST SUPPRESSANTS - CHEMICAL:There are many types and brands ofChemical Dust Suppressants which workby binding lighter particles. ChemicalSuppressants may be applied as asurface treatment to "seal" the top of anarea, or may be applied using an admixmethod that blends the product with thetop few inches of the surface material.

    Examples of these products include, butare not limited to, hydrolyzed starchderivatives, calcium chloride, magnesiumchloride, lignin derivatives, tree resinemulsions, and synthetic polymeremulsions. Other products, andproperties of products, can be found inthe Department of Ecology's "Techniquesfor Dust Prevention and Suppression", aswell as from many vendors.USED OIL CAUTION: It is important tonote that used oil may NOT be used as adust suppressant. RCW 70.951specifically prohibits the use of used oilas dust suppressant, and is referenced inthe "Applicable Washington Regulations"section of this brochure.

    EROSION CONTROLS: Plants, bushes,trees, earthen banks and rock wallsprovide natural, and more permanent,windbreaks. Other erosion controlmeasures, such as wood or porousfences can be installed for temporarymeasures. Because enclosures and windscreens can be costly the feasibility of

    10

    COMMON FUGITIVE DUSTMANAGEMENT PRACTICES

    The following is a list of commonlyemployed Fugitive Oust managementpractices for various dust sources.The best management practices for aparticular project should be selectedbased upon site-specificconsiderations.

    GRADERS AND SCRAPERS:• Use water truck or sprinklers to

    moisten soils before grading• Minimize areas of clearing and

    grubbing to a manageable size• Minimize timeframes between Fugitive

    Oust-creating activities and finalsolutions (ex., roadway excavation andpaving)

    • Avoid activity during high winds

    FRONT-END LOADERS AND BACK-HOES:• Use water truck to keep soils moist• Use water sprays (e.g. garden hose)

    when dumping soils into haul trucks• Minimize drop height• Avoid activity during high winds

    HAUL TRUCKS:• Wet loads with garden hose• Ensure adequate freeboard• Cover loads• Reduce speed on unpaved haul roads

    to less than 15 mph• Use water truck to keep haul roads

    moist• Surface haul roads with gravel

    7

  • using this type of control must bedetermined on a case-by-case method.

    FILTER FABRIC AROUND CATCHBASIN:Filter fabric around a catch basin is usedto collect sediment from muddy waterrun-off. Sediment, when left to dry, cancause Fugitive Dust emissions.Sediment collected in filtering systemsmust be dealt with on a regular basis.Treating mud with floculants, or "muckingout" catch basins, are two methods todeal with the residual debris.

    MINIMIZE DISRUPTED SURFACEAREA: A conscious effort, especiallyduring sitework and/or demolition, todisrupt only those areas that absolutelyneed to be cleared in order to accomplisha project can provide a variety of benefits.Vegetation left in place during siteworkreduces the area subject to wind erosion.In addition, minimizing the disruptedsurface area can also reduce the size ofthe project, potentially reducing the typesand cost of Fugitive Dust control.

    ~,N

    WR( rA8RIC M (()JAl2 • 2 • 14 c.... v.£lOCD

    fILTER FABRIC WAl(R1Al 60' 'MOE RQJ.SUSE STAPlES Cfi 'MRE RINGS TOAITATQt fABRIC TO 'MR(

    PROVlQ[ 3/4"-1.5"WA~EDCRAV[l BAO

  • Disturbing natural soil crusts in somegeographical areas, such as Central andEastern Washington, may unnecessarilycreate Fugitive Dust situations. Limitingvehicle access points to, and routeswithin, a project help to reduce thesedisruptions.

    PAVING: This is a more permanentsolution to Fugitive Dust control, suitablefor longer duration projects or situations.High cost is the major drawback topaving. Paving may be an appropriatesolution for access roads to largedevelopment projects, where the roadcan eventually be incorporated in theoverall plan for the area. Anotherappropriate use of paving might be"maintenance" projects such as parkinglots and staging areas, where gravelcover is not adequate for Fugitive Dustcontrol or erosion.

    QUARRY SPALLS: These are bufferareas that minimize the amount ofmaterial tracked on to a trafficked roadsurface, sometimes called "rockentrances". These buffer areas consist ofvery large aggregate,usually 4" to 8"crushed quarry rock, which jars particlesfree from wheels and undercarriage, asvehicles travel over the spall. Thisaggregate is sometimes laid over a fabricroad carpet to increase effectiveness. Aspall with typical dimensions is illustratedbelow.

    ------- ,!il;--R=lS' MIN.

    I

    '::3~INQ~l': ) ')'PROVIDE FULL WIDTH OF ./.INGRESSJEGRESS AREA

    12

    SITE-SPECIFIC DESIGNCONSIDERATIONS

    The specifics and level of complexity ofeach Fugitive Dust control plan willdepend on a number of factors that arespecific to each project. Consider thefollowing:

    Cost of Alternatives: Several factorsmust be taken into consideration whenweighing various alternatives. Costconsiderations include unit cost, totalproject cost, acquisition cost, mainten-ance cost, cost of non-compliance,capital cost, and the cost of time waitingfor product or application. While onemethod may not be cost effective forlarge projects because the unit cost ishigh, it may be cost effective for smallprojects because the acquisition cost islow.

    Environmental Constraints: Waterapplication is one of the best short termmethods for controlling Fugitive Dust.However, water run off containing mudand silt can cause damage to streamsand other resources. A Fugitive Dust planshould be considered in conjunction withthe overall Temporary Erosion andSediment Control (TESC) plan. TheDepartment of Ecology can be contactedfor even more specific information.

    Location: The proximity of the project topopulated areas may dictate morecontrols, due to anticipated impacts, thana project in a remote location. Wildlifehabitats and wetlands may also beaffected by Fugitive Dust.

    project Size and Duration: The marketplace will not practically allow for thesame rigors of control to be applied on allprojects. For example, a land clearingproject involving several acres or a majorexcavation project may call for truckwheel washing facilities, while this maynot be practical for clearing a residential

    5

  • o Source and availability of materialssuch as water.

    Weather, equipment and site conditionswill require that field personnel make onthe spot, common sense changes inorder to address the intent of theregulations.

    Incorporating a simple inspectionchecklist during the daily report processhelps make the tasks of Fugitive Dustcontrol more routine. A checklist systemreduces paperwork, acts as a jobreminder, and serves as a record ofefforts to minimize Fugitive Dustproblems. Categories that might beincluded in the checklist are:

    o Dateo Timeo Preventative measureso Frequency of control measures

    applicationo Weather conditionso Comments

    REMEMBER: Fugitive Dust controls areonly effective when they are monitoredand managed through frequentinspections and maintenance of controlmeasures.

    4

    SCHEDULE WORK: Rescheduling workaround especially windy days canpotentially be one of the least expensiveand easiest Fugitive Dust controlmeasures. This can also be a totallyimpractical option if work crews are idleand/or this is a project with significanttime constraints. It is also unreasonableto expect to discontinue work ingeographical areas that are prone to highand continueous winds. However, limiteduse of rescheduling in extreme weatherconditions, might be appropriate.

    The high profile aspects of certainprojects and population exposed shouldbe taken into consideration whenscheduling especially Fugitive Dustproducing work. Evenings and weekendsare possible alternatives for schedulingwork in business and school locations;while mid-day may be more appropriatefor residential areas because people aremore likely to be away from home.

    SPEED REDUCTION: High vehiclespeeds increase the amount of FugitiveDust created from unpaved roads andlots. Reducing the speed of a vehiclefrom 45 to 35 miles per hour can reduceemissions by up to 22 percent accordingto a Washington State Department ofEcology study. However, no more than 5to 15 miles per hour is recommended formost conditions. Speed bumps are acommonly used method to ensure speedreduction. In cases where speedreduction cannot effectively reduceFugitive Dust, it may be necessary todivert traffic.

    13

  • STREET SWEEPERS: Street sweepersare often used in conjunction with water.Some sweepers have a spray as well asbrushes. However, sweepers can spreadmud when there is a lot of wetness.Some sweepers, for parking lots andsmaller jobs, actually have vacuumsystems to trap Fugitive Dust. Drysweeping is discouraged, especially invery dry climate conditions, because itcauses dust particles to become airborne.

    VEHICLE SPILLAGE: Covers for haultrucks help to prevent soils and othermaterials from being dropped on roads.However, covering loads is not requiredby state law if six inches of freeboard ismaintained within the bed of the truck.

    Vehicles driving over dirt and other debristracked onto roads can cause significantFugitive Dust emissions. Reducing thedrop height for loading equipment, wetsuppression, and wind guards areeffective ways of minimizing the FugitiveDust created during loading operations.

    WATER SPRAY: Water spray, whether itis through a simple hose for smallprojects, or a water truck for largeprojects, is an effective way to keepFugitive Dust under control. Mistingsystems and sprinklers are mechanismsthat can be employed to delivercontinuous wetness. However, there areseveral constraints in using water. Watercan be very costly for larger projects in

    14

    PRE-CONSTRUCTION PLANNING

    Fugitive Dust control planning is apartnership between the owner, generalcontractor, subcontractors and any otherparty whose activities during the projectmay lead to the generation of FugitiveDust. This partnership extends to legalresponsibilities as well in that all partiescan be held liable for non-compliance andsubsequent regulatory actions, includingmonetary penalties.

    Incorporating Fugitive Dust controlmeasures in the plans and specificationsof the project can help ensure that theparticipants in the constructionpartnership avoid violations of FugitiveDust regulations. Early planning can alsohelp owners and project designers to"level the playing field" in the competitivebid process and avoid change orders.

    A Fugitive Dust control plan mightinclude:

    o Identification of all Fugitive Dustsources.

    o A description of the Fugitive Dustcontrol method(s) to be used for eachsource.

    o A schedule, rate of application,calculations or some other means ofidentifying how often, how much andwhen the control method is to beused.

    o Provisions for monitoring and record-keeping.

    o A backup plan in case the first controlplan does not work or is inadequate.

    o The name and phone number of theperson responsible for making surethe plan is implemented and who canbe contacted in the event of a FugitiveDust complaint.

    o Back-up or company phone number.o Map or drawing of the site.

    3

  • comparison to other methods. Heavywatering can also create mud, run-off, andenvironmental problems.

    \

    '--I

    I~-------

    PLAN VIEW

    -- --

    WHEEL WASH: A wheel wash is amethod to remove mud and dirt fromwheels by driving through a shallowtrench filled with water or onto an areawhere the wheel wells and undercarriagecan be hosed down. Care should betaken to keep the trench deep enoughthat it is effective, but not so deep that itinterferes with the mechanical operationsof the vehicles. The trench may be linedwith asphalt to ease maintenance inrem'wing collected silt. A wheel wash canbe used in conjunction with brooms orhoses to remove dirt from other areas ofvehicles. Wheel washes must have acontainment area to take care of the run-off.

    VEHICLE SCRAPE: This is an alternativeto a wheel wash when water disposal, orother environmental constraints, arepresent. Establishing a specific areawhere compact dirt or mud is removedfrom ledges of dump trucks, wheel wells,hitches, tires, and other confined areas,will reduce track out.

    NuisanceIt is unlawful in the state of Washington tocause or allow air contaminant emissions insufficient quantities and of suchcharacteristics and duration that itunreasonably interferes with enjoyment oflife and property.

    SafetyFugitive Dust from construction can reducevisibility on roadways and highways,resulting in traffic accidents.

    WHY FUGITIVE DUST IS A PROBLEM

    HealthFugitive Dust can also have significanthealth effects if it is inhaled in largeamounts, or if dust contains crystalline silica,asbestos fibers, heavy metals or diseasespores. Very small particles can be inhaleddeep into lungs and are a particular healththreat for the young, the old, and those withchronic respiratory problems.

    Fugitive Dust can be created directly fromthe activities involved in construction, suchas moving soils or demolishing structures.Fugitive Dust can also be generated bydisturbing residual soils or materials thathave been left behind by constructionactivities. For example, vehicles cangenerate Fugitive Dust from dirt onroadways that was tracked out as mud fromconstruction sites.

    2 15

  • APPLICABLE WASHINGTONREGULATIONS

    It is important to make sure that yourFugitive Dust control practices complywith federal, state and local laws. Thefollowing is a list of some of theregulations that apply; however contactyour local Air Pollution Control Agency,County Health Department and/or PublicWorks Department to find out the specificrequirements for the area in which yourproject is located.

    Local Air Pollution Control AgencyRegulations: Contact your local airpollution control agency for the specificregulations appropriate to the location ofyour project. These agencies and theirphone numbers are listed on the lastpage of this brochure.

    Chapter 70.94 RCW - WashingtonClean Air Act and Chapter 173-400WAC: These statutes require ownersand operators of Fugitive Dust sources toprevent Fugitive Dust from becomingairborne and to maintain and operatesources to minimize emissions.

    Chapter 70.951 RCW - Used OilRecycling: This law prohibits the use ofused oil as a dust suppressant. Used oilincludes any oil that has been refinedfrom crude oil, used, and as a result ofsuch use, is contaminated by physical orchemical impurities. If you plan to use achemical suppressant, verify that it doesnot contain any used oil as aningredient. Also, be certain that if theproduct contains fuel oil ingredients thatthe fuel oil does not contain used oil.

    Chapter 46.61.655 RCW - DroppingLoad, Other Materials - Covering: Thisregulation prohibits the discharge ofdebris from vehicles and prescribesminimum loading standards in lieu ofcovering truck beds.

    16

    INTRODUCTION

    Fugitive Dust is particulate matter that issuspended in the air by wind or humanactivities and does not come out of a stack.

    Air quality regulations require the use ofcontrol techniques to minimize Fugitive Dustemissions. The goal is to eliminate visibleairborne Fugitive Dust. Therefore, state andlocal regulatory agencies expect that asmany of these control techniques beemployed as necessary to achieve this goal.

    Reasons for Fugitive Dust ControlFugitive Dust from construction projects isregulated by the Washington State airquality laws for several reasons:

    1. Fugitive Dust can become a nuisance toneighbors by depositing on theirproperty;

    2. Inhaling Fugitive Dust particles cancause respiratory diseases;

    3. Fugitive Dust can be a direct safetyhazard.

    Purpose of BrochureThis brochure is designed as a guide toprovide practical examples of suggestedbest management practices necessary tocomply with air quality regulations involvedin the construction process.

    While Fugitive Dust can be created from avariety of activities, such as agriculturalactivities, this brochure will focus on FugitiveDust that is created by constructionactivities. Air pollution from debris burning,plant operations, rock crushing and abrasiveblasting, sometimes associated withconstruction activities, are dealt with in otherregulations and publications. For additionalinformation on the subject, the numbers oflocal air quality agencies are listed in theback of this brochure.

    1

  • We would like to gratefully acknowledge theFugitive Dust Task Force that provideddirection, technical advice and editing:

    • Michael Bernbaum, Teamsters - Local 174• Camilla Bishop, AGC Education Foundation• Mark Davies, CSR Associated• Roland Dewhurst, AGC - Southern Dist.• Richard Dickson, Wm. B. Dickson Co.• Peter Downey, Dept. of Transportation• John Hennessy, Nuprecon, Inc.• Rick Hess, PSAPCA• Ed Lizak, Nuprecon, Inc.• Rebecca Murray, Nuprecon, Inc.• Gerry Pade, PSAPCA• Mark Sandy, Operating Engine.ers• Frank Scarsella, Scarsella Bros., Inc.• Mike Schultz, PSAPCA• Mike Tollkuehn, Woodworth & Co.

    We would also like to acknowledge the technicalassistance provided by:

    • Mabel Caine, SCAPCA• Bob Gilmore, Garry Struthers Associates, Inc.• David Lauer, BCCAA• Doug Nelson, Active Construction• Scott Parker, Argus Pacific• Craig Weckesser, OAPCA

    Some illustrations are courtesy of the CalforniaEnvironmental Protection Agency, Air ResourcesBoard, Compliance Division.

    Chapter 90.48 RCW - Water PollutionControl: Section .080 prohibits thedischarge of any material into surface orground waters that could cause pollution asdefined in WAC 173-200-020(22). If yoursite is near surface or ground water, usedust control measures that have zero orminimal aquatic impact. If you decide to usea chemical dust suppressant, select aproduct with no aquatic toxicity.

    Chapter 70.105 RCW - Hazardous WasteManagement: This statute prohibits thedisposal to the ground of any dangerous(hazardous) waste. If you are planning touse a chemical dust suppressant, makesure it does not contain any dangerouswaste ingredients.

    Chapter 70.1050 RCW - Hazardous WasteCleanup - Model Toxics Control Act(MTCA): This law requires the identificationand cleanup of hazardous sites, TheDepartment of Ecology can investigatereports of releases or the presence ofhazardous substances. If a hazardousproduct is used as a dust suppressant andEcology later receives a complaint ofcontamination, a site assessment may beconducted,

    Chapter 90.03 RCW - Surface Water Codeand Chapter 90.44 RCW Regulations ofPublic Ground Water (wells): Thisregulation requires a water right permit forall surface water withdrawal and for anywater from a well that will exceed 5,000gallons per day. If you plan to use water,and have questions about it, call theDepartment of Ecology's Water ResourcesProgram.

    17

  • GUIDE TO HANDLINGFUGITIVE DUST FROM

    CONSTRUCTION PROJECTS

    WASHINGTON STATE DEPT. OF ECOLOGYS. LOCAL AIR POLLUTION CONTROL AGENCIES

    CONTENTS

    INTRODUCTION 1

    ADEPARTMENT OF ECOLOGY - EAST REGIONNorth 4601 Monroe, Suite 202Spokane, WA 99205-1295(509) 456-2926

    B OLYMPIC AIR POLLUTION CONTROL AUTHORITY909 Sleater-Kinney Rd. SE, #1Lacey, WA 98503(360) 438-8768 or 1-800-422-5623

    CSPOKANE CO. AIR POLLUTION CONTROL AUTHORITY1101 West College Avenue, Suite 403Spokane, WA 99201(509) 477-4727

    DNORTHWEST AIR POLLUTION AUTHORITY1600 S. Second SI.Mount Vernon, WA 98273(360) 428-1617 or 1-800-622-4627

    EPUGET SOUND CLEAN AIR AGENCY110 Union 51.. Suite 500Seattle, WA 98101(206) 343-8800 or 1-800-552-3565

    FBENTON COUNTY CLEAN AIR AUTHORITY650 George Washington WayRichland, WA 99352(509) 943-3396

    GSOUTHWEST AIR POLLUTION CONTROL AUTHORITY1308 N.E. 1341h S1ree1Vancouver, WA 98685(360) 574-3058 or 1-800-633-0709

    HDEPARTMENT OF ECOLOGY N.W REGION3190 -1601h Ave. SEBellevue, WA 98008-5452(425) 649-7000

    I YAKIMA COUNTY CLEAN AIR AUTHORITY6 South 2nd St.,Room 1016Yakima, WA 98901(509) 574-1410 or 1-800-540-6950

    J DEPARTMENT OF ECOLOGY - CENTRAL REGION15 W. Yakima Ave.. Suile 200Yakima, WA 98902(509)575-2490

    WHY FUGITIVE OUST IS A PROBLEM 2

    PRE-CONSTRUCTION PLANNING 3

    SITE-SPECIFIC DESIGNCONSIDERATIONS 5

    COMMON FUGITIVE OUSTMANAGEMENT PRACTICES 7

    DESCRIPTIONS OF BESTMANAGEMENT PRACTICES 9

    APPLICABLE WASHINGTONREGULATIONS 16

    LOCAL AIR POLLUTION CONTROLAUTHORITIES 18

  • PARTICIPATING ASSOCIATIONS

    fie----~fie----~

    INLAND

    AGcQ

    •lJJil/d.~ •••ge;

    Asphalt Paving Associationof Washington, Inc.1200 Westlake Ave. N., Suite 604Seattle, WA 98109(206) 284-8780

    Associated Builder & Contractorsof Western Washington1756-114"Ave. S.E., Suite 120Bellevue, WA 98004-6931(425) 646-8000

    Associated Builder & ContractorsInland Pacific ChapterP.O. Box 3787Spokane, WA 99220(509) 534-0826

    Associated General ContractorsInland Northwest ChapterP.O. Box 3266Spokane, WA 99220(509) 535-0391

    Associated General ContractorsOf Washington1200 Westlake Ave. N., Suite 301Seattle, WA 98109-3528(206) 284-0061

    Building Industry Association ofWashingtonP.O. Box 1909Olympia, WA 98507(800) 228-4229

    Building Industry Association ofWhatcom County3323 Northwest Ave.Bellingham, WA 98225(360) 671-4247

    Central Washington HomeBuilders Association1018 S. 33" Ave.Yakima, WA 98902(509) 454-4006

    Master Builders2155-112" Ave. N.E., Suite 100Bellevue, WA 98004(425) 451-7920

    Tn-City Construction CouncilP.O. Box 602520 E. Kennewick Ave.Kennewick, WA 99336(509) 582-7424

    19

  • APPENDIX C

    Eastern Washington Stormwater Management Manual,

    BMP C140 and BMP C126

  • BMP C126:

    Polyacrylamide

    for Soil Erosion

    Protection

    Purpose: Polyacrylamide (PAM) is used on construction sites to prevent soil

    erosion.

    Applying PAM to bare soil in advance of a rain event significantly reduces

    erosion and controls sediment in two ways. First, PAM increases the soil’s

    available pore volume, thus increasing infiltration through flocculation and

    reducing the quantity of stormwater runoff. Second, it increases flocculation of

    suspended particles and aids in their deposition, thus reducing stormwater runoff

    turbidity and improving water quality.

    Conditions of Use Conditions of Use: PAM shall not be directly applied to water or allowed to

    enter a water body. In areas that drain to a sediment pond, PAM can be applied

    to bare soil under the following conditions:

    During rough grading operations.

    Staging areas.

    Balanced cut and fill earthwork.

    Haul roads prior to placement of crushed rock surfacing.

    Compacted soil roadbase.

    Stockpiles.

    After final grade and before paving or final seeding and planting.

    Pit sites.

    Sites having a winter shut down. In the case of winter shut down, or where soil

    will remain unworked for several months, PAM should be used together with

    mulch.

    Design and Installation Specifications: PAM may be applied in dissolved form

    with water, or it may be applied in dry, granular or powdered form. The

    preferred application method is the dissolved form.

    PAM is to be applied at a maximum rate of ½ pound PAM per 1000 gallons

    water per 1 acre of bare soil. Table 7.3.8 and Figure 7.3.6 can be used to

    determine the PAM and water application rate for a disturbed soil area. Higher

    concentrations of PAM do not provide any additional effectiveness.

    September 2004 Chapter 7 - Construction Stormwater Pollution Prevention 7-67

  • Table 7.3.8 PAM and Water Application Rates

    Disturbed Area (ac) PAM (lbs) Water (gal)

    0.50 0.25 500

    1.00 0.50 1,000

    1.50 0.75 1,500

    2.00 1.00 2,000

    2.50 1.25 2,500

    3.00 1.50 3,000

    3.50 1.75 3,500

    4.00 2.00 4,000

    4.50 2.25 4,500

    5.00 2.50 5,000

    0.00

    0.50

    1.00

    1.50

    2.00

    2.50

    0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0

    Disturbed Area (ac)

    PAM (lbs)

    0

    500

    1000

    1500

    2000

    2500

    3000

    3500

    4000

    4500

    5000

    Water (gal)

    Figure 7.3.6 - PAM and Water Application

    Chapter 7 - Construction Stormwater Pollution Prevention September 20047-68

  • The Preferred Method:

    Pre-measure the area where PAM is to be applied and calculate the amount

    of product and water necessary to provide coverage at the specified

    application rate (1/2 pound PAM/1000 gallons/acre).

    PAM has infinite solubility in water, but dissolves very slowly. Dissolve

    pre-measured dry granular PAM with a known quantity of clean water in a

    bucket several hours or overnight. Mechanical mixing will help dissolve the

    PAM. Always add PAM to water - not water to PAM.

    Pre-fill the water truck about 1/8 full with water. The water does not have to

    be potable, but it must have relatively low turbidity – in the range of 20 NTU

    or less.

    Add PAM /Water mixture to the truck

    Completely fill the water truck to specified volume.

    Spray PAM/Water mixture onto dry soil until the soil surface is uniformly

    and completely wetted.

    An Alternate Method:

    PAM may also be applied as a powder at the rate of 5 lbs. per acre. This must be

    applied on a day that is dry. For areas less than 5-10 acres, a hand-held “organ

    grinder” fertilizer spreader set to the smallest setting will work. Tractor-

    mounted spreaders will work for larger areas.

    The following shall be used for application of PAM:

    PAM shall be used in conjunction with other BMPs and not in place of other

    BMPs.

    Do not use PAM on a slope that flows directly into a stream or wetland. The

    stormwater runoff shall pass through a sediment control BMP prior to

    discharging to surface waters.

    Do not add PAM to water discharging from site.

    When the total drainage area is greater than or equal to 5 acres, PAM treated

    areas shall drain to a sediment pond.

    Areas less than 5 acres shall drain to sediment control BMPs, such as a

    minimum of 3 check dams per acre. The total number of check dams used

    shall be maximized to achieve the greatest amount of settlement of sediment

    prior to discharging from the site. Each check dam shall be spaced evenly in

    the drainage channel through which stormwater flows are discharged off-site.

    On all sites, the use of silt fence shall be maximized to limit the discharges of

    sediment from the site.

    September 2004 Chapter 7 - Construction Stormwater Pollution Prevention 7-69

  • All areas not being actively worked shall be covered and protected from

    rainfall. PAM shall not be the only cover BMP used.

    PAM can be applied to wet soil, but dry soil is preferred due to less sediment

    loss.

    PAM will work when applied to saturated soil but is not as effective as

    applications to dry or damp soil.

    Keep the granular PAM supply out of the sun. Granular PAM loses its

    effectiveness in three months after exposure to sunlight and air.

    Proper application and re-application plans are necessary to ensure total

    effectiveness of PAM usage.

    PAM, combined with water, is very slippery and can be a safety hazard.

    Care must be taken to prevent spills of PAM powder onto paved surfaces.

    During an application of PAM, prevent over-spray from reaching pavement

    as pavement will become slippery. If PAM powder gets on skin or clothing,

    wipe it off with a rough towel rather than washing with water-this only

    makes cleanup messier and take longer.

    Some PAMs are more toxic and carcinogenic than others. Only the most

    environmentally safe PAM products should be used.

    The specific PAM copolymer formulation must be anionic. Cationic PAM shall

    not be used in any application because of known aquatic toxicity problems.

    Only the highest drinking water grade PAM, certified for compliance with

    ANSI/NSF Standard 60 for drinking water treatment, will be used for soil

    applications. Recent media attention and high interest in PAM has resulted in

    some entrepreneurial exploitation of the term “polymer.” All PAM are

    polymers, but not all polymers are PAM, and not all PAM products comply with

    ANSI/NSF Standard 60. PAM use shall be reviewed and approved by the

    jurisdiction. The Washington State Department of Transportation (WSDOT) has

    listed approved PAM products on their web page.

    PAM designated for these uses should be “water soluble” or “linear” or

    “non-crosslinked”. Cross-linked or water absorbent PAM, polymerized in

    highly acidic (pH20%

    hydrolysis) PAM.

    PAM tackifiers are available and being used in place of guar and alpha

    plantago. Typically, PAM tackifiers should be used at a rate of no more than

    0.5-1 lb. per 1000 gallons of water in a hydromulch machine. Some tackifier

    product instructions say to use at a rate of 3 –5 lbs. per acre, which can be

    too much. In addition, pump problems can occur at higher rates due to

    increased viscosity.

    Chapter 7 - Construction Stormwater Pollution Prevention September 20047-70

  • Maintenance Standards: PAM may be reapplied on actively worked areas after

    a 48-hour period.

    Reapplication is not required unless PAM treated soil is disturbed or unless

    turbidity levels show the need for an additional application. If PAM treated

    soil is left undisturbed a reapplication may be necessary after two months.

    More PAM applications may be required for steep slopes, silty and clayey

    soils (USDA Classification Type “C” and “D” soils), long grades, and high

    precipitation areas. When PAM is applied first to bare soil and then covered

    with straw, a reapplication may not be necessary for several months.

    Loss of sediment and PAM may be a basis for penalties per RCW 90.48.080.

    September 2004 Chapter 7 - Construction Stormwater Pollution Prevention 7-71

  • BMP C140: Dust

    Control

    Purpose: Dust control prevents wind transport of dust from disturbed soil

    surfaces onto roadways, drainage ways, and surface waters. Wind erosion is a

    significant cause of soil movement from construction sites in Eastern

    Washington. Although wind erosion can contribute to water quality impacts,

    dust control is regulated in some areas of Eastern Washington primarily through

    local air quality authorities. Where such an entity exists, contact the local air

    quality authority for appropriate and required BMPs for dust control to

    implement at your project site.

    Conditions for Use: In areas (including roadways) subject to surface and air

    movement of dust where on-site and off-site impacts to roadways, drainage

    ways, or surface waters are likely.

    Design and Installation Specifications:

    Contact your local Air Pollution Control Authority for guidance and training

    on other dust control measures. Compliance with the local Air Pollution

    Control Authority constitutes compliance with this BMP.

    Water applied to construction sites for dust control must not leave the site as

    surface runoff.

    See also “Techniques for Dust Prevention and Suppression,” Ecology

    Publication Number 96-433, revised April 2002.

    Techniques that can be used for construction projects include:

    Vegetate or mulch areas that will not receive vehicle traffic. In areas where

    planting, mulching, or paving is impractical, apply gravel or landscaping

    rock.

    Limit dust generation by clearing only those areas where immediate activity

    will take place, leaving the remaining area(s) in the original condition, if

    stable. Maintain the original ground cover as long as practical.

    Construct natural or artificial windbreaks or windscreens. These may be

    designed as enclosures for small dust sources.

    Sprinkle the site with water until surface is wet. Repeat as needed. To

    prevent carryout of mud onto street, refer to Stabilized Construction Entrance

    (BMP C105).

    Irrigation water can be used for dust control. Irrigation systems should be

    installed as a first step on sites where dust control is a concern.

    Spray exposed soil areas with a dust palliative, following the manufacturer’s

    instructions and cautions regarding handling and application. Used oil is

    prohibited from use as a dust suppressant. Local governments may approve

    other dust palliatives such as calcium chloride or PAM.

    PAM (BMP C126) added to water at a rate of 0.5 lbs. per 1,000 gallons of

    water per acre and applied from a water truck is more effective than water

    September 2004 Chapter 7 - Construction Stormwater Pollution Prevention 7-77

  • alone. This is due to the increased infiltration of water into the soil and

    reduced evaporation. In addition, small soil particles are bonded together

    and are not as easily transported by wind. Adding PAM may actually reduce

    the quantity of water needed for dust control, especially in eastern

    Washington. Since the wholesale cost of PAM is about $ 4.00 per pound,

    this is an extremely cost-effective dust control method.

    Techniques that can be used for unpaved roads and lots include:

    Lower speed limits. High vehicle speed increases the amount of dust stirred

    up from unpaved roads and lots.

    Upgrade the road surface strength by improving particle size, shape, and

    mineral types that make up the surface and base materials.

    Add surface gravel to reduce the source of dust emission. Limit the amount

    of fine particles (those smaller than .075 mm) to 10 to 20 percent.

    Use geotextile fabrics to increase the strength of new roads or roads

    undergoing reconstruction.

    Encourage the use of alternate, paved routes, if available.

    Restrict use by tracked vehicles and heavy trucks to prevent damage to road

    surface and base.

    Apply chemical dust suppressants using the admix method, blending the

    product with the top few inches of surface material. Suppressants may also

    be applied as surface treatments.

    Pave unpaved permanent roads and other trafficked areas.

    Use vacuum street sweepers.

    Remove mud and other dirt promptly so it does not dry and then turn into

    dust.

    Limit dust-causing work on windy days.

    Maintenance Standards:

    Respray area as necessary to keep dust to a minimum. Water applied to

    construction sites for dust control must not leave the site as surface runoff.

    Chapter 7 - Construction Stormwater Pollution Prevention September 20047-78

  • APPENDIX D

    WSDOT Chemical Dust Suppressant List

  • APPENDIX E

    Self-Inspection Checklists

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN

    APPENDIX E

    ES012210002547PDX 1

    Self-Inspection Checklist: Fugitive Dust Control Method Log Fugitive Dust Source: ______________________________________

    Date Time Control Method Comments

  • TEANAWAY SOLAR RESERVE, KITTITAS COUNTY, WASHINGTON FUGITIVE DUST CONTROL PLAN APPENDIX E

    2 ES012210002547PDX

    Self-Inspection Checklist: Weather Log

    Date Temperature Wind Speed/Direction

    Amount of Rainfall

    Comments

    Teanaway Solar Reserve Fugitive Dust Control Plan Kittitas County, WashingtonContents1.0 Introduction2.0 Project Contacts3.0 Project Description3.1 Projection Location3.2 Soil Conditions3.3 Prevailing Wind Direction

    4.0 Potential Dust Sources5.0 Best Management Practices: Fugitive Dust Control Methods6.0 Best Management Practices: Contingency Measures7.0 Self-Inspection Checklist8.0 ReferencesAppendicesA FiguresB AGC Guide to Handling Fugitive Dust from Construction ProjectsC Eastern Washington Stormwater Management Manual, BMP C140 and BMP C126D WSDOT Chemical Dust Suppressant ListE Self-Inspection Checklists