Dust_Control_and_Air_Quality_Monitoring_Plan_Lassen_Volcanic_Park_Fire_Cleanup_12-12-2022_(1).pdf

PDF 422 KB Posted May 6, 2024

Attached to: Removal of Hazardous Ash and Debris, Lassen VNP
Solicitation number: 140P8424Q0057
Issued by: Department of the Interior National Park Service Pacific West Region

About this file

Written by GovTribe AI · May 6, 2024

This document is a Dust Control and Air Quality Monitoring Plan for the Lassen Volcanic Park Dixie Fire Cleanup project. It outlines the dust control measures, worker exposure monitoring, and worksite air quality monitoring that will be implemented during the debris removal operations.

The plan references the Statement of Work for the Hazard Assessment and Soil Remediation project and the Debris Removal Operation Plan. It provides details on the specific sites to be cleaned up, including the Drakesbad Water Treatment Plant, Kelley Cabin, and various boardwalks. The plan addresses the monitoring and control of potential hazards such as crystalline silica, lead, asbestos, and other metals. It specifies the monitoring methods, sampling procedures, and exposure limits to be followed. The plan is supplementary to the overall Debris Removal Operation Plan for the Lassen Volcanic Park Dixie Fire Cleanup.

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http://www.xrfresearchinc.com;		info@xrfresearch.com	Page 1 of 11
9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

Dust Control and Air Quality Monitoring Plan

Lassen Volcanic Park Dixie Fire Cleanup

Address: 38050 Highway 36 E, Mineral, CA 96061 (NPS Headquarter)

Prepared by: XRF Research Inc.

Prepared for: FedVet Construction, Inc

Date of Report December 12, 2022

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

December 12, 2022

Edgar DeLeon, President, Fedvet Construction

Re: Air Quality Monitoring Plan, Lassen Volcanic Park Fire Cleanup

Dear Mr. DeLeon,

The

following

dust

control

and

air

monitoring

work

plan

based

specifications

the

document

entitled

“140P8422Q0158

Attachment

01-

Statement

Work,

Hazard

Assessment

and

Soil

Remediation”

(“SOW”

“Statement

Work”).

This

Dixie

fire

debris

cleanup

operations

the

Lassen

Volcanic

National

Park

(LAVO),

expected

take

place

2023.

Some	of	the	proposed	airborne	exposure	assessments	are	based	on	findings
from	the	site	characterization	carried	out	in	October	2022	and	summarized	in
the	document	entitled	Fire	Cleanup	Project,	Lassen	Volcanic	Park,	Phase	I	Site
Visit	Report	dated	November	30,	2022	(“Site	Visit	Report”).

The	work	plan	below	is	supplementary	to	the	DROP,	the	document	entitled
Debris	Removal	Operation	Plan	for	Lassen	Volcanic	Park,	Dixie	Fire	Cleanup,
dated	December	11,	2022.

you

have

any

questions

regarding

these

findings,

please

feel

free

contact

858-243-5415.

Regards,

Javier	Gonzalez,	Ph.D.,		Ashley	A.	Allison
Senior	Industrial	Hygienist	CAC	#10-680

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

TABLE OF CONTENTS

I. Project Overview 4

II. Dust Control Measures 5

III. Worker Exposure Monitoring 7

IV. Worksite Air Quality Monitoring 11

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

I. Project Overview

The

following

document

operations

plan

for

dust

control

and

air

monitoring

done

during

the

expected

cleanup

fire

ash

and

debris

from

the

Dixie

fire

(July

2021)

that

damaged

number

properties

the

Lassen

Volcanic

National

Park

(LAVO),

operated

the

National

Park

Service.

Per

the

SOW

document

reference

above,

the

recommended

work

practices

are

based,

part,

the

document

entitled

Plumas

County

Fire

Debris

Removal,

Alternative

(Private)

Debris

Removal

Program;

Beckwourth

Complex

and

Dixie

Fires,

September

24,

2021.

The

burn

sites

are

all

rural

areas.

Most

consist

boardwalks

constructed

pressure

treated

wood

watershed

marshy

areas,

some

accessible

only

foot.

Three

the

sites,

the

Drakesbad

Water

Treatment

Plant,

Kelley

Cabin

Juniper

Lake,

and

Mt.

Harkness

Lookout

and

pit

toilet,

were

developed

sites

with

previously

existing

structures.

pre-work

trip

was

conducted

October

2022

survey

the

burn

sites

and

collect

ash

and

soil

for

composition

analysis.

The

results

were

summarized

trip

report

that

has

been

previously

submitted

and

referenced

the

cover

letter

above.

Specifications

for

the

work

can

found

the

DROP

document

above,

subject

the

Health

Safety

plan,

also

submitted

separately

Section II below has general specifications for dust control for the project.

Section

III

has

site-specific

plan

for

exposure

monitoring

workers.

This

based

findings

from

the

site

characterization

that

are

both

from

visual

observations

and

from

the

waste

characterization

findings

summarized

the

trip

report.

Section	IV	has	specifications	for	worksite	area	monitoring	for	airborne	dust
and	contaminants.

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

II. Dust Control Measures

Dust

must

controlled

all

times

during

all

fire

debris

cleanup

operations.

The

specifications

here

are

referenced

the

main

work

plan

for

the

removal

work

(“DROP”).

Nuisance dust control measures include:

• Control

Water

the

form

mist

spray

must

used

during

the

cleanup

work

prevent

dust

emissions.

Each

area

where

ash

and

debris

are

removed

will

pre-watered

with

fine

spray

nozzle

advance

initiating

debris

removal

and

needed

during

the

removal.

o Note:

The

water

must

applied

manner

that

does

not

generate

runoff.

When

necessary,

engineering

controls

for

storm

water

discharges

such

the

use

barriers

must

place

prior

dust

control

operations.

• Control

All

loads

shall

covered

with

tarp;

this

includes

metal

and

concrete

debris.

Ash

and

debris

loads

shall

also

fully

encapsulated

with

Mil

polyethylene

plastic

(“burrito

wrap”

method).

o In

the

case

loads

that

are

classified

hazardous

waste,

the

waste

containers

must

lined

with

the

plastic

sheeting,

then

top

the

load

should

also

enclosed

with

the

same

plastic,

with

the

tarp

acting

secondary

barrier.

• Control

All

waste

material

that

not

removed

the

end

each

workday

will

consolidated,

sufficiently

wetted,

and/or

covered

prevent

the

offsite

migration

contaminants.

• Control

All

soil

surfaces

the

worksite

that

appear

visibly

dry

should

moistened

with

water

minimize

the

formation

fugitive

dust

emissions

during

the

work.

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

o Note:	the	water	should	be	delivered	by	misting	with	a	sprayer	and
should	be	limited	to	avoid	pooling	or	runoff	(“erosion”).

o Note:	Upon	completion	of	the	cleanup	operations	(including	the
confirmatory	soil	sampling),	the	freshly-scraped	(disturbed)	soil
surface	should	be	moistened	with	a	sprayer	before	it	is	covered
with	mulch	per	the	DROP.

• Control	5	–	When	traveling	on	unpaved	(“dirt”)	roads,	the	speed	should
be	limited	to	15	mph	(miles	per	hour).

o Note:	Maintaining	a	proper	distance	(e.g.,	50	feet)	in	between
vehicles	helps	minimize	exposure	to	dust	to	the	occupants	of
vehicles	that	are	following.

• Control

–

Soil

and/or

ash

must

contained

the

worksite

and

during

transport

they

not

contaminate

roadways

neighboring

parcels,

this

could

create

airborne

health

hazard.

o The	use	of	blower	devices,	dry	rotary	brushes,	or	brooms	for
removal	of	carryout	and	track	out	on	public	roads	is	strictly

prohibited.

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

III. Worker Exposure Monitoring

This	section	pertains	to	the	worker	exposure	monitoring.	For	the	area
monitoring,	see	§IV.	Worksite	Air	Quality	Monitoring,	below.

Personal

Breathing

Zone

Monitoring

performed

for

workers

and

supervisors

who

are

engaged

the

fire

debris

cleanup

work.

This

done

ensure

compliance

with

OSHA/CAL

OSHA

regulations

and

for

health

and

safety

reasons.

The

hazardous

substances

that

are

monitored

for

each

worksite

depend,

part,

what

was

observed

during

the

initial

site

investigation

and

the

analytical

results.

See

Table

III-1,

below.

Specific

pollutants

concern

are

discussed

below.

Crystalline

Silica

and

Dust.

Crystalline

silica

common

building

materials

such

sand

stone,

rock,

concrete,

brick

and

mortar

and

released

into

the

air

from

operations

used

construction.

Exposure

airborne

crystalline

silica

small

particle

size

causes

silicosis,

lung

cancer,

COPD

and

kidney

disease

and

regulated

OSHA.

The

relevant

CAL

OSHA

regulations

are

CCR

Title

§1532.3,

Occupational

Exposures

Respirable

Crystalline

Silica

and

the

Federal

regulations

are

CFR

1910.1053,

Respirable

Crystalline

Silica.

• The	permissible	exposure	limit	(PEL)	for	respirable	crystalline	silica	is
50	µg/m³	based	on	an	8-hour	TWA	(time	weighted	average)	and	the
action	level	is	25	µg/m³	based	on	an	8-hour	TWA.

• OSHA	and	CAL	OSHA	regulations	require	that	employers	carry	out
exposure	assessments	for	employees	who	may	be	exposed	to	respirable
crystalline	silica	at	or	above	the	action	level.

• Nuisance

dust

classified

OSHA

“Particulates,

not

otherwise

Regulated

(PNOR)”.

The

PEL

for

respirable

dust

mg/m³

based

8-hour

TWA.

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

Table III-1. Exposure Monitoring for the various Lassen burn sites

Site

Structure Silica/Dust* Lead¶ Asbestos† Other¶

A Fire Lookout – Mt.

Harkness √ √ √ Copper

B§ Pit Toilet – Mt.

Harkness§

Kelley	Cabin
Juniper	Lake

Drakesbad	Water
Treatment	Plant

√ √ √ Antimony

E Drakesbad Boardwalks

√ - - Arsenic, Copper

Boardwalks	–
Grassy	Swale

√ - - Arsenic, Copper

G Hot Springs Creek

Bridge √ - - Copper

Devil’s	Kitchen
Boardwalks	&

Bridge √ - - Copper

I Boardwalks –

Drake’s	Lake	Trail
√	-	-	Arsenic,

Copper

Boardwalks	-
Summit	Lake

√ - - Arsenic, Copper

§The	pit	toilet	is	in	close	proximity	to	the	fire	lookout	structure
(approximately	90	feet	Southeast	of	the	lookout	structure).

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

*Method	NIOSH	7500	(Silica	by	XRD;	EMSL	also	reports	respirable	dust);	SKC
cassette	225-803	(PVC	filters,	GLA-5000,	5.0	µm,	37mm)

¶Method

NIOSH

7082

(Lead),

NIOSH

7300

(metals);

SKC

cassette

225-3-01

(MCE

Filters

preloaded

cassettes,

0.8

µm,

mm).

Use

method

NIOSH

7300

when

metals

other

than

lead

multiple

metals

are

involved.

†NIOSH

7402

(Asbestos

TEM;

Variation

involving

using

NIOSH

7400

–

fibers

PCM,

with

positive

trigger

for

TEM;

use

standard

PCM

cassette,

mm,

0.8

µm)

Asbestos.

not

known

asbestos

present

the

worksites,

but

suspect

materials

were

observed

three

the

worksites

(Table

III-1,

and

D),

exposure

monitoring

would

carried

out

precaution

comply

with

CCR

Title

Subchapter

Article

§1529

(CAL

OSHA

Asbestos

Construction

standard).

• The

permissible

exposure

level

(PEL)

0.1

fibers/cc

air

8-h

time-weighted

average

(TWA).

• The Excursion Limit is 1.0 fibers/cc of air averaged over 30 minutes.

Lead

and

Metals.

One

metals

were

observed

all

sites

hazardous

waste

levels

(Table

III-1,

above).

Lead	regulations	affecting	exposure	relevant	to	the	project	area	found	in	CCR
Title	8,	§1532.1	(CAL	OSHA	Lead	in	Construction	Standard)

• The

permissible

exposure

level

(PEL)

for

lead

µg/m3

air

time-weighted

average

(TWA).

o The

action

level

for

lead

µg/m3

air

8-h

time-

weighted

average

(TWA).

• The	PEL	for	Arsenic	is	10	µg/m3	of	air	(8hTWA)*
• The	PEL	for	Antimony	is	500	µg/m3	of	air	(8hTWA)*
• The	PEL	for	Copper	is	1000	µg/m3	of	air	(8hTWA)*

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

*The

PELs

for

metals

are

from

Table

AC-1,

CCR

Title

§5155

(Airborne

Contaminants

Subchapter

General

Industry

Safety

Orders;

Group

16.

Control

Hazardous

Substances,

Article

107,

Dust,

Fumes,

Mists,

Vapors

and

Gases)

Field Procedures for personal exposure monitoring.

• Setup	with	the	appropriate	cartridges	and	calibration	of	pumps	is	to	be
done	by	the	field	industrial	hygienist	project	monitor	(IH).		Note
crystalline	silica	requires	a	constant	flow	pump	like	the	Gilaire-5.

• The	workers	being	monitored	should	be	the	ones	most	likely	to	be
exposed	to	a	particular	contaminant,	to	be	determined	by	the	IH
immediately	before	placing	the	pumps	and	cartridges	per	discussion
with	the	supervisor.

o For	example,	in	the	case	of	removal	of	a	fire-damaged	lead	acid
battery,	the	worker	doing	the	actual	removal	should	be	monitored
for	lead	(or	lead	and	other	metals,	as	appropriate);	the	worker
operating	the	sprayer	or	collecting	debris	could	be	monitored	for
other	airborne	pollutants	such	as	asbestos	or	crystalline

silica/dust.

• Typically	a	single	pump/cartridge	would	be	used	for	each	worker	per
shift	and	data	collection	may	be	representative.

• Pumps

should

calibrated

before

and

after

collection

with

the

media

attached.

This

especially

important

for

non-constant

flow

pumps

such

the

Gillian

BDX,

the

flow

can

change

the

porosity

the

filter

reduced

with

increased

• The	samples	should	be	collected	by	the	IH	and	labeled	carefully	with
data	required	for	the	chain	of	custody	such	sample	IDs,	names,	dates,
flow	rates	and	times,	etc.	and	submitted	to	the	lab	under	chain-of-
custody	procedures	as	soon	as	it	is	practical.

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9921	Carmel	Mountain	Rd.	#326	San	Diego,	CA	92129	858-442-3230

IV. Worksite Air Quality Monitoring

This	section	pertains	to	the	work	area	perimeter	monitoring.		For	personal
monitoring,	see	§III.	Worker	Exposure	Monitoring,	above.		Additional
information	relevant	to	the	hazardous	airborne	substances	can	be	found	in
the	personal	monitoring	section.

A. Dust and particulates

DustTrak™

particulate

monitors

(e.g.,

Model

8535),

similar

instrumentation

mounted

surveyor’s

tripods

height

feet

from

the

ground

should

used

measure

ambient

dust

levels

all

the

worksites.

This

should

also

include

monitoring

and

recording

PM10

and

PM2.5

particle

levels.

These

monitoring

stations

should

place

proximity

the

operations,

e.g.,

near

the

boundary

the

work

zone.

Depending

the

size

and

configuration

the

worksite,

there

may

than

one

monitor

set

up,

for

example,

one

upwind

and

one

downwind

from

the

operations.

These

monitors

produce

real-time

data

that

should

observed

the

project

monitor

(IH).

The

PEL

for

respirable

dust

mg/m³

based

8-hour

TWA.

the

PEL

level

exceeded

any

time

during

operations,

the

work

should

stopped

and

dust

control

measures

implemented.

This

would

include,

e.g.,

misting

with

sprayer

and,

appropriate,

modification

work

practices

(vide

supra).

B. Crystalline silica, Asbestos and Lead/Metals – Area Monitoring

The

worksite

would

monitored

using

the

same

methods

described

above

for

workers,

except

the

placement

would

involve

tripods.

Sampling

would

done

the

perimeter

the

work

area

outside

the

actual

regulated

area

(ash

footprint).

File details come from the government source that posted it. Updated May 6, 2024.