HomeMy WebLinkAbout1.24 Fugitive Dust PlanFugitive Dust Control Plan
PDC Energy
Piceance Centralized Soil Treatment Facility
OLSSON
ASSOCIATES
OA Project No. 011 -2627
760 Horizon Drive, Suite 102 1 Grand Junction, CO 81506 1 TEL 970.263.7800 1 FAX 970.263.7456
Fugitive Dust Control Plan
Garfield County, Colorado
May 2012
PDC Energy
Colorado, USA
Scope: The scope of these guidelines is to outline some basic principles to minimize
and control fugitive dust emissions during land development.
Requirements: PDC Energy (PDC) places the highest priority on the health and safety of our
workforce and protection of our assets and the environment.
Applicable Documents: Department of Public Health and Environment Air Quality Control
Commission Regulation 1 5CCR 1001 -3
Quality: These guidelines will be reviewed periodically and will be shared with
employees and contractors to ensure that they have adequate knowledge to
minimize fugitive dust emissions.
1.0 INTRODUCTION
Land development activities, including clearing, excavating, and grading, release fugitive dust, a
pollutant regulated by the Air Pollution Control Division (Division) at the Colorado Department of Public
Health and Environment. However, small land development activities that are less than 25 contiguous
acres and less than 6 month in duration do not need to report air emissions to the Division, but must
use appropriate control measures to minimize the release of fugitive dust from the site.
This Fugitive Dust Control Plan addresses how dust will be kept to a minimum on roads and pad sites.
This plan focuses action on:
1. Identifying specific individual sources of fugitive dust.
2. Control options for unpaved roadways.
3. Control options for disturbed areas.
4. Control options for transport, storage and handling of bulk materials.
5. Contingency Plan for alternative action in the event that control strategies are not adequate,
effective, or practical.
2.0 SPECIFIC SOURCES
Specific types of fugitive dust sources may appear to have negligible dust emissions, but when
combined with other specific sources underway at the same time can create dust plumes that are
visible beyond that which is appropriate for designated speeds and designs and may exceed nuisance
emission limitation guidelines. It is important to consider all activities on the site together in determining
compliance with federal, state, and local air quality regulations.
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Task:
Provide field personnel and contractors with the information required to limit fugitive particulate
matter (fugitive dust) from all specific sources to include:
• Unpaved roadways and traffic areas.
• Construction activities including earth moving and excavation.
• Bulk material (i.e. gravel and soils).
• Storage and handling of materials
3.0 CONTROL OPTIONS FOR UNPAVED ROADWAYS
Any owner or operator responsible for construction or maintenance of any (existing or new) unpaved
roadway is required to use all available, practical methods to minimize dust emissions:
Task:
Provide guidelines for minimizing fugitive dust emissions from all specific sources on unpaved
roadways and traffic areas:
• Require that all passenger vehicles, construction equipment, and truck traffic obey the posted
speed limits on all unpaved County roads to and from the project site.
• Ensure that vehicle speeds on new and existing access roads on the project site do not exceed
15 miles per hour by posting speed limits along these roads.
• Restrict vehicle traffic to existing roads by posting signs and /or providing the locations of
allowable access routes to all field personnel and visitors.
• Encourage carpooling to and from the project site to limit traffic on existing County roads.
• Roads and well locations will be surfaced with compacted gravel to protect against wind
erosion, to reduce the amount of fugitive dust generated by traffic and other activities, and to
reduce carryout/trackout.
• Use dust inhibitors (surfacing materials, water, or non - saline dust suppressants) on all unpaved
collector, local, and resource roads to prevent fugitive dust problems (ensure that any dust
suppressants used are appropriate for road conditions and will not compromise the safety of
workers on the project site).
• Restrict vehicular access during periods of inactivity using gates, fencing, and /or onsite security
personnel.
4.0 CONTROL OPTIONS FOR DISTURBED AREAS
Disturbed areas include new roads, well pads, parking and staging areas, and material storage areas
that have been cleared of vegetation, leveled, or excavated. These areas are susceptible to wind
erosion and are a major source of fugitive dust emissions that require the appropriate controls and dust
mitigation methods. Note that specific sources are subject to change as project conditions change, and
will require an evaluation of current control options to ensure effectiveness and practicality.
Task:
Limit the adverse impacts of fugitive dust emissions through control measures and operational
procedures designed so that no off - property transport emissions occur at the project site.
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• Ensure that land clearing, grading, earthmoving, and excavation activities are suspended when
wind speeds exceed a sustained velocity of 20 miles per hour.
• Surface all bare ground with gravel as soon as practicable after clearing, leveling, and grading.
• Use dust inhibitors (surfacing materials, water, or non - saline dust suppressants) on all disturbed
areas as necessary to prevent fugitive dust problems.
• Identify the water source to be used for dust suppression, and ensure that contract water
haulers are available when needed.
• Reduce the amount of time between initially disturbing the soil and revegetating or other surface
stabilization.
• Apply seeding, vegetative or synthetic cover to topsoil and spoil piles as soon as practicable
following stockpiling to prevent wind erosion and fugitive dust emissions.
• Compact the soil on disturbed areas that will not be surfaced with gravel or revegetated
immediately following construction.
• Minimize surface disturbance to only that necessary for safe and efficient construction and
operations.
• Use vegetative mulch, reseeding, or other methods of surface stabilization on all areas adjoining
development to include shoulders, borrow ditches, and berms if practical.
• Restrict vehicular access during periods of inactivity using gates, fencing, and /or onsite security
personnel.
• Entrance roads prior to construction will be treated with Garfield County Roads and Bridges
approved Mag chloride treatment to abate access egress traffic generation of fugitive dust.
• River water shall be available when stripping and stockpiling the topsoil horizons A,B,C.
• During construction gravel will be brought to location to mitigate dust impacts and prepare
surface for equipment installation.
• Identify any new sources of fugitive dust emissions and evaluate and implement the appropriate
control methods for that source.
• Buried water lines will be utilized to minimize fugitive dust emissions from truck traffic
• Limit vehicle speeds accessing facilities to reduce dust emissions.
• Perform road sweeping to reduce fugitive dust and mud tracking onto roadways where
practicable.
• Incorporate fugitive dust controls in all lands projects.
5.0 CONTROL OPTIONS FOR TRANSPORT, STORAGE AND HANDLING OF BULK MATERIALS
Transporting bulk materials, such as gravel and fill material, can result in off - property dust emissions
and other impacts (i.e. broken windshields) over some distance if the appropriate control measures are
not implemented. Storage and handling of bulk materials once they arrive at the project site also
requires that controls are in place to ensure that these materials do not exceed regulated nuisance dust
emissions.
Task:
Use control measures and operational procedures designed so that no off - property transport
emissions occur along public roadways to and from the project site:
• Enclose, cover, water, or otherwise treat loaded haul trucks to minimize the Toss of material to
wind and spillage.
• Require that all contract haul vehicles obey the posted speed limits on all public roadways to
and from the project site.
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• Ensure that haul truck speed on new and existing access roads on the project site do not
exceed 15 miles per hour by posting speed limits along these roads.
• Restrict haul trucks to existing roads and pad locations.
• Do not attempt to load- unload haul trucks when wind speeds exceed a sustained velocity of 20
miles per hour.
• Promptly remove dust - forming material from haul trucks to minimize entrainment of fugitive
particulate matter.
• Avoid storage and handling of bulk material any more than necessary to complete construction.
• Use covers, enclosures, wind breaks, or watering to prevent fugitive dust emissions from
material storage piles.
• Restrict access to construction areas and storage piles during periods of inactivity using gates,
fencing, and /or onsite security personnel.
6.0 CONTINGENCY PLANNING
Alternative control measures may become necessary in the event that the current dust control strategy
is not adequate or effective for conditions. An alternative plan may require additional planning,
permitting, or other regulatory compliance requirements to implement. In this case, the current
activities at the project site would necessarily be suspended until such time as the alternate dust control
methods could be put into place.
Task:
Implement alternative action to fugitive dust control plan and to each specific source if deemed
necessary to comply with federal, state, and local air quality regulations:
• Provide field personnel and contractors with contact information for responsible individuals in
cases where control measures need to be escalated in response to weather conditions (i.e.
increased windiness).
• Use an appropriate alternative dust inhibitor if water does not prove to be effective under normal
circumstances, and obtain all regulatory permissions for the use of chemical suppressants on
the project site.
• Use vegetative blankets or other methods for cover of topsoil, spoil, and bulk material storage
piles if immediate cover becomes necessary.
• Attempt to locate alternative sources of bulk material closer to the project site if fugitive dust
emissions or other impacts from contract haul trucks on state or federal highways become an
issue with public safety or regulatory compliance.
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