HomeMy WebLinkAbout4.9.6 Mid-Cont Road Dust Management Plan 2014_01_02COX Y
Mid -Continent Business Unit
Performance Standards
Effective Date:
1/2/2014
Fugitive Dust Mitigation — Piceance Operations
Doc: A301.8
Rev: 02
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.
HESTrainingProgramsStandard.doc
Revised by MHB.
1 of 3
UX Y
Mid -Continent Business Unit
Performance Standards
Effective Date:
1/2/2014
Fugitive Dust Mitigation — Piceance Operations
Doc: A301.8
Rev: 02
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.
HESTrainingProgramsStandard.doc
Revised by MHB.
2 of 3
COX Y
Mid -Continent Business Unit
Performance Standards
Effective Date:
1/2/2014
Fugitive Dust Mitigation — Piceance Operations
Doc: A301.8
Rev: 02
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.
HESTrainingProgramsStandard.doc
Revised by MHB.
3 of 3