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HomeMy WebLinkAbout2.21 Mid-Cont Road Dust Management Plan 2014_01_02 Mid-Continent Business Unit Performance Standards Effective Date: 1/2/2014 Fugitive Dust Mitigation – Piceance Operations Doc: A301.8 Rev: 02 HESTrainingProgramsStandard.doc Revised by MHB. 1 of 3 1. Program Scope This written standard addresses general operation and maintenance practices to manage fugitive dust from unpaved roadways and construction. Currently this program scope applies to the Rockies Cascade Creek operating area only. 2. Purpose To establish mitigation/control measures to manage fugitive particulate matter (dust) emissions that may occur during field operations to a level that is technologically feasible and economically reasonable and consistent with industrial health standards and regulatory requirements. 3. Roles & Responsibilities Management & Proponent Leads  Ensure that the operating area where responsibility exists, the asset will have minimum requirements established to mitigate fugitive dust.  Ensure that the asset will have adequate dust control measures in place, as required or otherwise appropriate.  For each of these requirements, ensure an adequate budget has been established to implemented critical aspects of the program in each operating area. HES and Regulatory Department  Identify state and federal regulatory requirements related to fugitive dust that may apply to operations and activities within each operating area.  Periodically measure vehicle traffic to determine if vehicle counts exceed 200 vehicles per day making Colorado Reg 3 III.D.a.(i).A. applicable. Current vehicle counts were significantly less than this for 2013.  Obtain air quality or other permits for fugitive dust sources, if necessary, as required by state and/or federal law.  Ensure compliance with state and federal regulatory limitations, work practices, and reporting obligations related to fugitive dust.  Ensure roads are maintained and operated in a manner consistent with safety and good air pollution control practices for minimizing road dust and prevention of off-site transport.  Identify routine and non-routine activities and operations that may result in fugitive dust emissions, including paved and unpaved roadways and construction operations.  Determine proper dust mitigation procedures and engineering controls for routine or project- specific activities based on the potential for fugitive dust emissions identified and risk of off-site migration.  Train field employees on fugitive dust mitigation practices.  Maintain training records.  Investigate and mitigate fugitive dust complaints from the public, private contractors, and agencies. Mid-Continent Business Unit Performance Standards Effective Date: 1/2/2014 Fugitive Dust Mitigation – Piceance Operations Doc: A301.8 Rev: 02 HESTrainingProgramsStandard.doc Revised by MHB. 2 of 3 All Field or Effected Employees  Complete all recommended awareness training according to the asset’s training program requirements.  Maintain and operate equipment to ensure compliance with regulatory limitations and requirements.  Follow equipment-specific requirements established in relevant permits and/or Oxy procedures established to minimize airborne dust; this includes unpaved road speed limits.  Report abnormal or excessive fugitive dust to an Oxy Supervisor or the HES Department. 4. Operating Area Programs Fugitive Dust Control Measures General Practice: Employ operating procedures and control measures as are necessary to minimize fugitive dust emissions into the atmosphere from any operation through the use of available practical methods which are technologically feasible and economically reasonable. Such practices shall include but are not limited to the use of  Speed restrictions  Regular road maintenance  Restriction of land disturbance construction activity during high-wind days. Additional management practices such as road surfacing, wind breaks and barriers, or automation of wells to reduce truck traffic is also recommended if technologically feasible and economically reasonable. The following control measures are applicable to unpaved roadways and construction activities within each operating area:  Designate an appropriate speed limit for vehicles on unpaved roadways and limit vehicle speed to designated limit. Post speed limit signs accordingly  Use water trucks to wet roadways, as needed, when natural moisture is insufficient to prevent airborne dust  When necessary, use chemical dust suppressants such as magnesium chloride to manage dust in high traffic areas or near sensitive receptors  Implement good housekeeping to prevent accumulation of material on roadways and vehicles that may become airborne  Implement an awareness training program for vehicle operators (employees and contractors) Recommended Awareness Training Integrate fugitive dust awareness training into existing employee and contractor health and safety training programs. Mid-Continent Business Unit Performance Standards Effective Date: 1/2/2014 Fugitive Dust Mitigation – Piceance Operations Doc: A301.8 Rev: 02 HESTrainingProgramsStandard.doc Revised by MHB. 3 of 3 Permits Fugitive dust permitting is likely not required for Oxy operations in the Piceance due to the small size of potential land disturbances. In Colorado, any land disturbance project over 1850 acres is subject to a Construction Permit and Public Notice proceedings. Oxy land disturbance work is not expected to exceed 1850 acres in size.  If 1850 acre disturbance size is to be exceeded, an application (APEN) should be prepared and submitted for land development activities; Oxy can opt for a General Permit (GP-03), which sets out basic limitations and control measures.