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| 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 | is | based | on | |
| specifications | in | the | document | entitled | “140P8422Q0158 | Attachment | 01- | | | | | |
| Statement | of | Work, | Hazard | Assessment | and | Soil | Remediation” | (“SOW” | or | | | |
| “Statement | of | Work”). | | This | is | related | to | Dixie | fire | debris | cleanup | operations |
| in | the | Lassen | Volcanic | National | Park | (LAVO), | expected | to | take | place | in | 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. | | | | | | | | |
| If | you | have | any | questions | regarding | these | findings, | please | feel | free | to | contact |
| me | at | 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 | is | an | operations | plan | for | dust | control | and | air | | |
| monitoring | to | be | done | during | the | expected | cleanup | of | fire | ash | and | debris | from |
| the | Dixie | fire | (July | 2021) | that | damaged | a | number | of | properties | in | the | Lassen |
| Volcanic | National | Park | (LAVO), | operated | by | the | US | National | Park | Service. | | Per | |
| the | SOW | document | reference | above, | the | recommended | work | practices | are | | | | |
| based, | in | part, | on | 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 | in | rural | areas. | | Most | consist | of | boardwalks | constructed |
| of | pressure | treated | wood | in | watershed | or | marshy | areas, | some | accessible | only | | |
| on | foot. | | Three | of | the | sites, | the | Drakesbad | Water | Treatment | Plant, | Kelley | |
| Cabin | at | Juniper | Lake, | and | Mt. | Harkness | Lookout | and | pit | toilet, | were | | |
| developed | sites | with | previously | existing | structures. | | | | | | | | |
| A | pre-work | trip | was | conducted | on | October | 2022 | to | survey | the | burn | sites | and |
| collect | ash | and | soil | for | composition | analysis. | | The | results | were | summarized | in | |
| a | trip | report | that | has | been | previously | submitted | and | referenced | in | the | cover | |
| letter | above. | | Specifications | for | the | work | can | be | found | in | the | DROP | document |
| above, | subject | to | the | Health | & | Safety | plan, | also | submitted | separately | | | |
Section II below has general specifications for dust control for the project.
| Section | III | has | a | site-specific | plan | for | exposure | monitoring | of | workers. | | This | is |
| based | on | findings | from | the | site | characterization | that | are | both | from | visual | | |
| observations | and | from | the | waste | characterization | findings | summarized | in | 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 | be | controlled | at | all | times | during | all | fire | debris | cleanup | operations. |
| The | specifications | here | are | referenced | in | the | main | work | plan | for | the | removal |
| work | (“DROP”). | | | | | | | | | | | |
Nuisance dust control measures include:
| • Control | 1- | Water | in | the | form | or | a | mist | or | spray | must | be | used | during | the |
| cleanup | work | to | prevent | dust | emissions. | Each | area | where | ash | and | | | | | |
| debris | are | to | be | removed | will | be | pre-watered | with | a | fine | spray | nozzle | in | | |
| advance | of | initiating | debris | removal | and | as | needed | during | the | removal. | | | | | |
| o Note: | The | water | must | be | applied | in | a | manner | that | does | not | |
| generate | runoff. | | When | necessary, | engineering | controls | for | storm | | | | |
| water | discharges | such | as | the | use | of | barriers | must | be | in | place | prior |
| to | dust | control | operations. | | | | | | | | | |
| • Control | 2 | - | All | loads | shall | be | covered | with | a | tarp; | this | includes | metal |
| and | concrete | debris. | | Ash | and | debris | loads | shall | also | be | fully | | |
| encapsulated | with | 6 | to | 10 | Mil | polyethylene | plastic | (“burrito | wrap” | | | | |
method).
| o In | the | case | of | loads | that | are | classified | as | hazardous | waste, | the | |
| waste | containers | must | be | lined | with | the | plastic | sheeting, | then | top | | |
| of | the | load | should | also | be | enclosed | with | the | same | plastic, | with | the |
| tarp | acting | as | a | secondary | barrier. | | | | | | | |
| • Control | 3- | All | waste | material | that | is | not | removed | at | the | end | of | each |
| workday | will | be | consolidated, | sufficiently | wetted, | and/or | covered | to | | | | | |
| prevent | the | offsite | migration | of | contaminants. | | | | | | | | |
| • Control | 4 | - | All | soil | surfaces | in | the | worksite | that | appear | to | be | visibly | dry |
| should | be | moistened | with | water | to | minimize | the | formation | of | 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 | 6 | – | Soil | and/or | ash | must | be | contained | at | the | worksite | and |
| during | transport | so | they | do | not | contaminate | roadways | or | neighboring | | | |
| parcels, | as | this | could | create | an | 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 | is | to | be | performed | for | workers | and | | | | |
| supervisors | who | are | engaged | in | the | fire | debris | cleanup | work. | | This | is | done | to |
| ensure | compliance | with | OSHA/CAL | OSHA | regulations | and | for | health | and | | | | | |
| safety | reasons. | | | | | | | | | | | | | |
| The | hazardous | substances | that | are | monitored | for | each | worksite | depend, | in | | |
| part, | on | what | was | observed | during | the | initial | site | investigation | and | the | |
| analytical | results. | | See | Table | III-1, | below. | | Specific | pollutants | of | concern | are |
| discussed | below. | | | | | | | | | | | |
| 1. | Crystalline | Silica | and | Dust. | Crystalline | silica | is | common | in | building | | |
| materials | such | as | sand | stone, | rock, | concrete, | brick | and | mortar | and | is | released |
| into | the | air | from | operations | used | in | construction. | | Exposure | to | airborne | |
| crystalline | silica | of | small | particle | size | causes | silicosis, | lung | cancer, | COPD | and | |
| kidney | disease | and | is | regulated | by | OSHA. | | The | relevant | CAL | OSHA | regulations |
| are | CCR | Title | 8, | §1532.3, | Occupational | Exposures | to | 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 | is | classified | by | OSHA | as | “Particulates, | not | otherwise | | | |
| Regulated | (PNOR)”. | The | PEL | for | respirable | dust | is | 5 | mg/m³ | based | on | an |
| 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
ID
Structure Silica/Dust* Lead¶ Asbestos† Other¶
A Fire Lookout – Mt.
Harkness √ √ √ Copper
B§ Pit Toilet – Mt.
Harkness§
C
D
| Drakesbad | Water |
| Treatment | Plant |
√ √ √ Antimony
E Drakesbad Boardwalks
√ - - Arsenic, Copper
F
√ - - Arsenic, Copper
G Hot Springs Creek
Bridge √ - - Copper
H
| Devil’s | Kitchen |
| Boardwalks | & |
Bridge √ - - Copper
I Boardwalks –
| Drake’s | Lake | Trail | |
| √ | - | - | Arsenic, |
Copper
J
√ - - 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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| *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), | or | NIOSH | 7300 | (metals); | | SKC | cassette | 225-3-01 | |
| (MCE | Filters | preloaded | in | cassettes, | 0.8 | µm, | 37 | mm). | Use | method | NIOSH | 7300 |
| when | metals | other | than | lead | or | multiple | metals | are | involved. | | | |
| †NIOSH | 7402 | (Asbestos | by | TEM; | Variation | involving | using | of | NIOSH | 7400 | – | | |
| fibers | by | PCM, | with | a | positive | trigger | for | TEM; | use | of | standard | PCM | cassette, |
| 25 | mm, | 0.8 | µm) | | | | | | | | | | |
| 2. | Asbestos. | | It | is | not | known | if | asbestos | is | present | at | the | worksites, | but |
| suspect | materials | were | observed | in | three | of | the | worksites | (Table | III-1, | A, | C | | |
| and | D), | so | exposure | monitoring | would | be | carried | out | as | a | precaution | to | | |
| comply | with | CCR | Title | 8, | Subchapter | 4, | Article | 4, | §1529 | (CAL | OSHA | Asbestos | | |
| in | Construction | standard). | | | | | | | | | | | | |
| • The | permissible | exposure | level | (PEL) | is | 0.1 | fibers/cc | of | air | as | an | 8-h |
| time-weighted | average | (TWA). | | | | | | | | | | |
• The Excursion Limit is 1.0 fibers/cc of air averaged over 30 minutes.
| 3. | Lead | and | Metals. | | One | or | more | metals | were | observed | in | all | sites | at |
| 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 | is | 50 | µg/m3 | of | air | as | an | 8- |
| h | time-weighted | average | (TWA). | | | | | | | | | | | |
| o The | action | level | for | lead | is | 30 | µg/m3 | of | air | as | an | 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 | 8 | §5155 | (Airborne |
| Contaminants | - | Subchapter | 7, | General | Industry | Safety | Orders; | Group | 16. | | | |
| Control | of | 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 | be | calibrated | before | and | after | collection | with | the | media | | | | |
| attached. | | This | is | especially | important | for | non-constant | flow | pumps | | | | | |
| such | as | the | Gillian | BDX, | as | the | flow | can | change | if | the | porosity | of | the |
| filter | is | reduced | with | increased | loading. | | | | | | | | | |
| • 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™ | II | particulate | monitors | (e.g., | Model | 8535), | or | similar | | | | |
| instrumentation | mounted | on | surveyor’s | tripods | at | a | height | of | ~5 | feet | from | the |
| ground | should | be | used | to | measure | ambient | dust | levels | at | all | the | worksites. |
| This | should | also | include | monitoring | and | recording | of | PM10 | and | PM2.5 | | |
| particle | levels. | | | | | | | | | | | |
| These | monitoring | stations | should | be | place | in | close | proximity | to | the | operations, | | |
| e.g., | near | the | boundary | of | the | work | zone. | | Depending | on | the | size | and |
| configuration | of | the | worksite, | there | may | be | more | than | one | monitor | set | up, | for |
| example, | one | upwind | and | one | downwind | from | the | operations. | | | | | |
| These | monitors | produce | real-time | data | that | should | be | observed | by | the | project | | | |
| monitor | (IH). | | The | PEL | for | respirable | dust | is | 5 | mg/m³ | based | on | an | 8-hour |
| TWA. | | If | the | PEL | level | is | exceeded | at | any | time | during | operations, | the | work |
| should | be | stopped | and | dust | control | measures | implemented. | | This | would | | | | |
| include, | e.g., | misting | with | a | sprayer | and, | if | appropriate, | modification | of | work | | | |
| practices | (vide | supra). | | | | | | | | | | | | |
B. Crystalline silica, Asbestos and Lead/Metals – Area Monitoring
| The | worksite | would | be | monitored | using | the | same | methods | described | above | | | |
| for | workers, | except | the | placement | would | involve | tripods. | | Sampling | would | be | | |
| done | in | the | perimeter | of | the | work | area | outside | the | actual | regulated | area | (ash |
footprint).