1	DUST CONTROL AT CONSTRUCTION SITES IN CLARK COUNTY Environmental Management Solutions Inc By John Letkeman Select slides at left or use navigation controls below.
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3	Clark County & PM-10 Clark County Has Been Designated By the EPA as a Non-Attainment Area for PM-10 Dust is Measured as PM-10 PM-10: Particulates under 10 microns in size, Suspended in Air EPA Requires Strict Control of Dust Levels through “State Implementation Plan (SIP)” Clark County is Responsible for the SIP for PM-10
4	WHY SUCH STRICT DUST REGULATIONS? Failure to meet the National Ambient Air Quality Standards (NAAQS) for PM₁₀ could result in Federal sanctions. The EPA could impose a Federal Implementation Plan (FIP) for Clark County. Which could result in increased restrictions on all valley companies and residents. Clark County would lose local control over our Air Quality Regulations to the U.S. EPA.
5	PM 10 & Associated Health Risks Respiratory Impacts Acute-wheezing, coughing, sneezing Chronic-damage to alveoli, aggravates other health conditions such as respiratory disease, emphysema, & asthma Effects on Quality of Life Affects pets, causes more frequent cleaning of pools, windows, vehicles, homes; damages vegetation
6	Populations Most Sensitive To PM 10
7	PM-10 Non-Attainment Area
8	CLARK COUNTY DUST REGULATIONS FINES CAN BE UP TO $10,000 PER DAY, PER OCCURANCE ANY VISIBLE DUST CAN BE A VIOLATION CONSTRUCTION SITES OVER ¼ ACRE NEEDS A DUST PERMIT SITES OVER 10 ACRES NEED A FORMAL DUST MITIGATION PLAN SITES OVER 50 ACRES REQUIRE IN DEPTH SOIL ANALYSIS AND A FULL TIME DUST MONITOR
9	ENFORCEMENT DAQM has expanded TO 25 Enforcement Officers Cooperation with Enforcement Officers works best Officers will often give a verbal warning before issuing a CAO If problems are corrected, inspection will pass, or else a Field Corrective Action Order (CAO) is possible. CAO’s can be followed by fines
10	VIOLATION STRUCTURE Enforcement Officer Writes Field Corrective Action Order &/or Failure-to-Comply with CAO Recipients Need to Report Corrective Actions County Verifies Corrective Actions If not Corrected, Notice of Violation is Prepared Air Quality Hearing Officer Determines Fines Appeals are Possible at Any Stage in Process
11	Raising Dust is Easy
12	Interesting Facts & Statistics In 2003: Air Quality Compliance Officers conducted 7,029 visits to construction and vacant land sites within Clark County The County issued 3,045 dust control permits covering 30,092 acres at a cost to developers of over 3.5 mil. In 2004: Over 400 Notice of Violations (NOV’s) were issued with fines totaling $ 1 MILLION The County’s “Complaint Hotline” receives more than 100 calls per month
13	DAQEM DUST PERMITS ARE AGREEMENTS BETWEEN THE DEVELOPER AND THE DAQEM ON DUST CONTROL METHODS PERMIT IS USED BY THE DAQEM TO ENFORCE REGULATIONS Summary of Information included in permit: Site Contact Information Site Soil Types Project boundaries, Site maps, Other Relevant Spatial Information Site Specific Best Management Practices (BMP’s) Site Specific Supplemental Dust Mitigation Plan Supplemental & Various Location Permits (VLP’s)
14	Site Contact Information Must be up to date and relevant and should be accurately reflected on the Dust Control Sign Should Include: Business Hours Contact After Hours Contact Relevant Dust Card Information
15	Site Soil Types Soil types are classified into five categories ranging from “high to slight” according to their particulate emission potential (PEP) PEP is determined by measuring the soils silt content and optimum moisture levels Sites under 50 acres can determine soil type by using generalized soil maps provided by the DAQEM Sites over 50 acres must conduct silt and optimum moisture tests from actual samples collected from the site Soil type determines what BMP’s will be required during the projects construction activities
16	DUST CONTROL AND PEP “High” PEP soils need optimum moisture content for compaction and water is not readily absorbed by these soils so more water is needed to control dust. To improve moisture absorption the use of a surfactant is required when implementing dust control measures in high PEP soils. “Moderate High” soils need tackifier to help reduce emissions. A tackifier binds together small particles within the soil creating improved soil absorbing qualities
17	LV Valley Soil Types
18	SOILS ANALYSIS AND PEP CALC FLOW CHART
19	Project Boundaries The permit includes a parcel map issued by the Clark County Assessors Office showing project boundaries Activity outside the Permit Boundaries is the best way to get a FINE! Permits over 10 acres MUST include: Project Vicinity Map Map with Location of Site Construction Office Map of Overall Development.
20	Site BMP’s BMP’s are required by the DAQEM to control dust during all phases of a projects development and for all construction activities BMP’s will vary based on site conditions and the soils PEP BMP compliance is the best way to avoid fines
21	Dust Mitigation Plan
22	Supplemental Dust Mitigation Plan Is required for projects over 10 acres in size and provides details about the developers plan for following BMP’s and maintaining compliance at the site It will include specifics about: Site Personnel Site Dust Control Budget Project details
23	Supplemental Permits & VLP’s Supplemental Permits are required for Blasting, Implosion, & Demolition of a structure greater than 1000 ft² A Various Location Permit is required for power screening or crushing on-site. Dust Permit must include Supplemental Permits and VLPs
24	Maintaining BMP’s BMPs are Important Reasons for not complying with BMP’s can be due to: Ignorance of the permit and Regulations Refusing to comply with the Regulations
25	Common Non-Compliance Issues That Result in CAO’s Fugitive Dust from dry soil Trackout onto paved streets Working Outside of Permitted Boundaries Site Supervisors/Water Truck Drivers Working Without Dust Cards Failure to Maintain Required Dust Records/Permits On Site Poorly Maintained Soil Conditions Building Dirt Ramps over curbs Insufficient Cleanup
26	Fugitive Dust Emissions
27	Trackout
28	Working Outside of Permitted Boundaries
29	Site Inspection Form
30	Poorly Maintained Soils
31	Dirt Ramps Over Curbs Insert Pictures
32	Insufficient Cleanup
33	BMP’s for Construction Activities Clearing & Grubbing Cut and Fill Disturbed Soil/Land Crushing Screening Staging Areas Stockpiles Truck Loading Importing/Exporting Trackout Prevention & Cleanup Backfilling Trenching Clearing Forms Paving/Subgrade Prep Sawing/Cutting Material Traffic Landscaping
34	Clearing and Grubbing Pre-water and maintain soils where support equipment and vehicles will operate ( this includes the area where the earthmoving equipment will be parked) Apply water during clearing and grubbing, if high PEP soils are present a tackifier or surfactant may be necessary Water disturbed soils to form a crust after clearing and grubbing activities are over
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36	Cut and Fill Pre-water using surfactants and ploughs if necessary to ensure that soils are at optimum moisture content Control Speed to allow watering Do not overfill equipment
37	DUST-FREE CUT AND FILL
38	Disturbed Soils Stabilize and maintain the stability of disturbed soil throughout the site by using water to form a crust Prevent disturbance of the soil by limiting vehicle traffic using fencing, barriers, barricades and wind barriers
39	Disturbed Soil \| Barricade
40	Screening PREVENT DUST Power Screen VLP must be on-site while operating Pre-moisten materials prior to screening Drop material slowly and minimize drop height Dedicate a water truck or large hose to screening operation, apply water as needed
41	DUST-FREE SCREENING
42	Staging Areas Set aside staging areas: avoid staging materials on paved streets Maintain surface soil moisture within the staging area by treatment or soil cover Limit access routes and direct traffic over trackout control devices
43	TRAFFIC CONTROL
44	Stockpiles Stockpiles located within 100 yards of occupied buildings must be less than 8 feet high Stockpiles over 8 feet high must have a road to the top to allow water truck access or have a sprinkler system installed Maintain stockpiled materials with at least 70% optimum moisture content, use tackifiers and surfactants if necessary
45	STOCKPILES TOO CLOSE TO HOMES
46	Truck Loading All loads must be covered prior to leaving the site Empty the loader bucket slowly and minimize the drop height into the truck bed Maintain optimum moisture for material being loaded, use tackifiers and surfactants if necessary
47	DRY SOILS MAKE DUST
48	Importing/Exporting 15MPH Speed Limits on soil haul-roads Cover loads and keep soils moist Trackout Control Devices must be well-maintained to be effective – Rock Pads, Shaker Plates, Wheel Washers Even with Trackout Devices, Trackout Happens, so Sweepers etc. are needed.
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50	Trackout Prevention & Clean up Trackout must be less than 50 feet long on a paved surface and less than ¼ “ thick All other trackout must be cleaned immediately. Interior streets MUST be free of trackout at end of day Trackout control devices at all access points to paved roads
51	Trackout Prevention & Clean up (cont.) Install and maintain trackout control devices at all access points to paved roads Trackout control devices can consist of: 1” to 3” rock pads Wheel shakers Wheel washers
52	BAD BETTER
53	Backfilling Stabilize backfill material before, during and after backfilling operations Maintain optimum moisture to backfill material Water truck or hose should be available during backfilling operations
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55	Trenching Pre-water surface soils Pre-trench to 18” and soak soils when deep trenching Dedicate water truck or hose during trenching operations Use water to form crust on excavated windrow
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57	Clearing Forms Limit visible emissions to no more than an average of 20% opacity for any period aggregating 3 minutes in any 60 minute period Use single stage pours to minimize clearing Use water or industrial vacuum to clear forms
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59	Paving & Subgrade Preparation Pre-water subgrade surface until optimum moisture is maintained Maintain at least 70% optimum moisture content for Type II while aggregate is applied Place tack coat on Type II base immediately after application Stabilize adjacent disturbed soils following paving
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61	Sawing/Cutting Limit visible emissions to no more than an average of 20% opacity Use water to control dust, or Use a vacuum to collect dust
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63	Traffic Limit vehicle speeds to 15 mph on all unpaved routes Use water to stabilize and maintain all haul routes Use water to stabilize and maintain all parking areas
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65	Landscaping Stabilize soils, materials and slopes during handling and at the completion of activity Use tackifiers and surfactants if necessary
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67	SUMMARY 1. Maintain optimum soil moisture 2. Limit trackout on paved surfaces 3. Work within the permitted boundaries
68	MORE GUIDELINES REDUCE DUST: ANY VISIBLE DUST CAN BE A VIOLATION Do Not Move Dry Soil – Keep Water Hose or Truck Nearby Learn Required Dust Control Methods for Each Job No Soil Allowed on Sidewalks and Driveways Make Sure Soil Is Crusted At End Of Day PREVENT TRACKOUT All Trackout MUST be cleaned up at the end of the day Trackout MUST be LESS THAN 50 ft and LESS THAN ¼ inch Thick Work Crews need push-brooms and shovels to keep streets clean Always use Trackout Devices – DO NOT go around them No Parking on Pads, and DO NOT block streets