NATURALLY OCCURRING ASBESTOS DUST MITIGATION PLAN

NATURALLY OCCURRING ASBESTOS DUST MITIGATION PLAN HUNTERS VIEW REDEVELOPMENT PROJECT SAN FRANCISCO, CALIFORNIA Prepared for: Ms. Margaret Campbell Hu...
Author: Homer George
9 downloads 0 Views 6MB Size
NATURALLY OCCURRING ASBESTOS DUST MITIGATION PLAN HUNTERS VIEW REDEVELOPMENT PROJECT SAN FRANCISCO, CALIFORNIA

Prepared for: Ms. Margaret Campbell Hunters View Associates, LP 1388 Sutter Street, 11th Floor San Francisco, CA 94109 February 12, 2010 Revised February 17, 2010 Project No. 8364.000.003

GEOTECHNICAL ENVIRONMENTAL WATER RESOURCES CONSTRUCTION SERVICES

Project No. 8364.000.003 February 12, 2010 Revised February 17, 2010 Ms. Margaret Campbell Hunters View Associates, LP 1388 Sutter Street, 11th Floor San Francisco, CA 94109 Subject:

Hunters View Redevelopment Project San Francisco, California ASBESTOS DUST MITIGATION PLAN

Dear Ms. Campbell: With your authorization, we have prepared an Asbestos Dust Mitigation Plan (ADMP) for the Hunters View Redevelopment Project in San Francisco, California. The ADMP has been prepared pursuant to Title 17 of the California Code of Regulations (17 CCR) Section 93105, Asbestos Airborne Toxic Control Measure (ATCM) for Construction, Grading, Quarrying and Surface Mining Operations. This document was prepared by ENGEO Incorporated for the sole use of Hunters View Associates, LP. This report is based upon field and other conditions discovered at the time of preparation of ENGEO’s report. This document must not be subject to unauthorized reuse; that is, reusing without written authorization of ENGEO. Such authorization is essential because it requires ENGEO to evaluate the document’s applicability given new circumstances, not the least of which is passage of time. We are pleased to provide our services to you on this project and look forward to consulting further with you and your design team. Sincerely, ENGEO Incorporated

B.H. Bronson Johnson, PE, CEG

Brian Flaherty, PG

i 332 Pine Street, Suite 300  San Francisco, CA 94104  (415) 284-9900  Fax (888) 279-2698 www.engeo.com

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

TABLE OF CONTENTS Page Transmittal Letter……………………………………………………………………...………. i Site Contact Personnel………………………………………………………………………....iii Acronyms and Abbreviations………………………………………………………………….iv

1.0

INTRODUCTION ..................................................................................... 1-1

2.0

PROJECT INFORMATION .................................................................... 2-1

3.0

BACKGROUND ........................................................................................ 3-1 3.1 3.2 3.3 3.4 3.5

SITE LOCATION AND DESCRIPTION ....................................................... 3-1 SITE HISTORY................................................................................................. 3-1 PROPOSED DEVELOPMENT ....................................................................... 3-1 SCOPE OF CONSTRUCTION WORK.......................................................... 3-1 NO VISIBLE DUST GOAL.............................................................................. 3-2

4.0

LOCATIONS OF SERPENTINE SOILS WITHIN THE PROJECT AREA .......................................................................................................... 4-1

5.0

REGULATORY BACKGROUND........................................................... 5-1

6.0

LAND USE WITHIN 0.25 MILE OF PROJECT AREA ...................... 6-1

7.0

POTENTIAL SOURCES OF EMISSIONS ............................................ 7-1

8.0

DUST MITIGATION MEASURES......................................................... 8-1 8.1 8.2 8.3 8.4 8.5 8.6 8.7

9.0

TRACK-OUT PREVENTION AND CONTROL .......................................... 8-1 ACTIVE STORAGE PILES............................................................................. 8-1 INACTIVE DISTURBED SURFACE AREAS AND STORAGE PILES .... 8-2 ON-SITE TRAFFIC CONTROL ..................................................................... 8-2 EARTH-MOVING ACTIVITIES .................................................................... 8-4 CONTROL FOR OFF-SITE TRANSPORT................................................... 8-5 POST-CONSTRUCTION STABILIZATION OF DISTURBED AREAS... 8-6

AIR MONITORING PROGRAM ........................................................... 9-1 9.1 9.2

GENERAL.......................................................................................................... 9-1 AIR MONITORING TRIGGERED DUST MITIGATION MEASURES .. 9-1

APPENDICES A. Regulatory Documentation: Asbestos Dust Mitigation Plan Application B. Figures C. Ambient Air Sampling Protocols ii

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

SITE CONTACT PERSONNEL Project Sponsor: Hunters View Associates, LP 1388 Sutter Street, 11th Floor San Francisco, CA 94109 Contact Name: _________________________________________________________________ Contact Phone Number: __________________________________________________________

Construction Contractor: Company: _____________________________________________________________________ Address: ______________________________________________________________________ Contact Name: _________________________________________________________________ Contact Phone Number: __________________________________________________________

iii

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

ACRONYMS AND ABBREVIATIONS ADMP

Asbestos Dust Mitigation Plan

AHERA

Asbestos Hazard Emergency Response Act

APCO

Air Pollution Control Officer

ATCM

Asbestos Airborne Toxic Control Measure

BAAQMD

Bay Area Air Quality Management District

BMP

Best Management Practice

CCR

California Code of Regulations

DPH

San Francisco Department of Public Health

DTSC

Department of Toxic Substance Control

EIR

Final Environmental Impact Report

HEPA

High-Efficiency Particulate Air

mph

Mile Per Hour

NOA

Naturally Occurring Asbestos

RACM

Regulated Asbestos-Containing Material

RWQCB

Regional Water Quality Control Board

SWPPP

Storm Water Pollution Prevention Plan

TSP

Total Suspended Particulate

iv

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

1.0

8364.000.003 February 12, 2010 Revised February 17, 2010

INTRODUCTION

This plan is being prepared on behalf of Hunters View Associates, LP pursuant to Title 17 of the California Code of Regulations (17 CCR) Section 93105, Asbestos Airborne Toxic Control Measure (ATCM) for Construction, Grading, Quarrying and Surface Mining Operations. The purpose of this plan is to propose dust mitigation measures to limit airborne asbestos and identify air monitoring methods for implementation during the project’s grading, infrastructure development, and construction phases. Asbestos is a naturally occurring mineral that is commonly found in serpentine or ultramafic rock, which exists in abundance throughout the state of California. Serpentine is the official state rock of California. The ATCM requires that the project sponsor submit an Asbestos Dust Mitigation Plan (ADMP) to the BAAQMD for approval. The project sponsor shall not engage in any construction or grading operation on property containing naturally occurring asbestos, serpentine, or ultramafic rock where the area to be disturbed is greater than one acre unless an ADMP for the operation has been approved by the BAAQMD. The provisions contained within this ADMP will be implemented at the beginning, and maintained throughout the duration of construction activity and/or grading that may have the potential to disturb naturally occurring asbestos (NOA) at Hunters View (17 CCR 93105 (e)(2)(A)2). The location, property lines, and construction phasing of the Hunters View redevelopment project are shown in the Figure 2 of Appendix B. This plan will be submitted to Bay Area Air Quality Management District (BAAQMD). No grading activities will be initiated until BAAQMD approval is received (17 CCR 93105 (e)(2)(A)1).

1-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

2.0

8364.000.003 February 12, 2010 Revised February 17, 2010

PROJECT INFORMATION Project Sponsor Name and Address

Project Location/Schedule

Hunters View Associates, LP

Middle Point and West Point Roads

1388 Sutter Street, 11th Floor

San Francisco, CA 94124

San Francisco, CA 94109

Estimated Start Date: March 2010

Attention: Ms. Margaret Campbell

Estimated Phase I Completion Date: March 2012

Phone: (415) 345-4490

Estimated Project Completion Date: March 2016

.

2-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

3.0

BACKGROUND

3.1

SITE LOCATION AND DESCRIPTION

The 22-acre Hunters View public housing complex is located in the Bayview-Hunters Point neighborhood in the southeast section of San Francisco, as shown in Figure 1 of Appendix B. The site was developed across a relatively steep sloping hillside with the public housing units constructed on terraced building pads along Middle Point Road between Evans Avenue to the north and Innes Avenue to the south. From Middle Point Road the development extends to the west through West Point Road and to the east through Wills Street, West Point Road and Hare Street. Topographically, the project is situated above a north-to-northwest-facing slope that varies from an elevation of 30 feet at the bottom of the slope at Keith Street to an approximate elevation of 100 feet at the top of the slope (County and City of San Francisco Datum). The highest existing elevation of the proposed redevelopment is approximately 130 feet at the southern intersection of Middle Point Road and West Point Road. Existing slope gradients on the north-facing slope vary substantially but are generally very steep.

3.2

SITE HISTORY

This public housing project was constructed in 1956 on the foundations of World War II workforce housing. The housing complex currently consists of 55 buildings with about 267 units of housing in 50 of these barracks-style structures. The existing building structures are rectangular two- to three-story wood-frame residential apartments. A number of the structures are vacant or abandoned.

3.3

PROPOSED DEVELOPMENT

It is currently planned to revitalize the Hunters View neighborhood with up to 800 units of mixed-income housing. The 22-acre site will be redeveloped in three phases with the demolition of all structures within each phase prior to redevelopment. The current plans show a street realignment for site access with new roads and walkways and infrastructure improvements planned to maximize the site’s development capacity.

3.4

SCOPE OF CONSTRUCTION WORK

Construction will consist of development of horizontal infrastructure to support later development. The work will consist of demolition of existing structures, site grading, utility system upgrades and construction of building pads. Deconstruction of existing structures will be performed by a qualified contractor. The contractor will use proper handling and disposal techniques for any asbestos-containing material.

3-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

3.5

8364.000.003 February 12, 2010 Revised February 17, 2010

NO VISIBLE DUST GOAL

The dust control measures set forth in this plan are intended to achieve a goal of no visible dust emissions associated with soil disturbance or excavation, to the extent required by City Order 171,378 and BAAQMD Regulation 6, Rule 1.

3-2

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

4.0

8364.000.003 February 12, 2010 Revised February 17, 2010

LOCATIONS OF SERPENTINE SOILS WITHIN THE PROJECT AREA

Figure 3 of Appendix B shows a regional geologic map of the project area. The site geology generally consists of bedrock overlain in certain areas by shallow pockets of artificial fill and native soils, as indicated on Figure 4, Site Geologic Map. The bedrock is predominantly comprised of serpentine with more localized exposures of shale and sandstone in the southwestern portion of the site. The fill appears to have been derived from on-site bedrock and soil at the time the project was initially graded. The fill has been placed to construct the existing building pads and roadways. Based on the findings from previous subsurface explorations, the existing fills range in thickness from less than a couple of feet in the center of the site to greater than about 21.5 feet at the southeastern corner of the site. These existing fills generally include a mixture of native soil and bedrock-derived materials as well as imported base rock type material. Fills 10 feet or greater in thickness are indicated on the geologic map; shallower zones of fill can be found throughout the site. Both the soil and serpentine bedrock on the site have been found to contain naturally occurring asbestos.

4-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

5.0

8364.000.003 February 12, 2010 Revised February 17, 2010

REGULATORY BACKGROUND

The Final Environmental Impact Report (EIR) for the Hunters View Redevelopment Project includes mitigation measures requiring actions that will reduce or eliminate adverse environmental impacts during construction. These mitigation measures were adopted in a Mitigation Monitoring and Reporting Program and approved by the San Francisco Planning Department on June 12, 2008. Dust control is one of the specific mitigation measures applicable to construction-related activities, and this plan specifically identifies the steps that will be taken to reduce dust emissions as a result of soil disturbance or excavation associated with grading, utility work, and construction of site infrastructure. This plan also includes the monitoring and reporting requirements. This Asbestos Dust Mitigation Plan incorporates requirements of the following applicable regulations: •

California Code of Regulations (CCR) Title 17, Section 93105: The Asbestos Airborne Toxic Control Measure (ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations



BAAQMD Regulation 6, Rule 1: Particulate Matter and Visible Emissions



BAAQMD Regulation 11, Rule 14: Asbestos Containing Serpentine



City of San Francisco Health Code, Article 22.B: Construction Dust Control Requirements



Order No. 171,378 of the Department of Public Works



Mitigation Measure E-1.A: Construction Dust Control (PM10)



Mitigation Measure E-2: Naturally Occurring Asbestos Control

A site-specific dust control plan is required by Article 22.B of the City of San Francisco Health Code. Article 22.B applies to any site preparation or construction activities taking place within the City and County of San Francisco that has the potential to create dust or that will expose or disturb soil. Order No. 171,378 of the San Francisco Department of Public Works specifies a goal of no visible dust

emissions from the site and outlines housekeeping measures required to meet this goal. Mitigation Measure E-1.A similarly defines best management practices (BMPs) including wetting and seeding unpaved, inactive areas, minimizing activity during periods of high wind, sweeping paved areas, covering trucks, etc. Best management practices (BMPs) are required to be implemented throughout the duration of the project. Additionally, BAAQMD Regulation 6, which generally prohibits emission of visible dust beyond the property boundary, is also applicable. 5-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

Because the site is in an area with serpentine rock, CCR Title 17, Section 93105 (ATCM) applies. ATCM includes, among other things, the requirement for submission of this Asbestos Dust Mitigation Plan for BAAQMD approval prior to earth-moving activities, such as grading or excavation. The ATCM also includes very specific practices to be implemented during construction. Mitigation Measure E-2 also provides BMPs for handling serpentine material, and BAAQMD Regulation 11, Rule 14 prohibits the use or sale of asbestos-containing serpentine materials for road surfacing.

5-2

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

6.0

8364.000.003 February 12, 2010 Revised February 17, 2010

LAND USE WITHIN 0.25 MILE OF PROJECT AREA

Land use within 0.25 mile of the project site is generally light/heavy industrial, residential, parks and open space, public, and commercial. Within 0.25 mile of the project area, there are schools and playgrounds but no hospitals or nursing homes.

6-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

7.0

8364.000.003 February 12, 2010 Revised February 17, 2010

POTENTIAL SOURCES OF EMISSIONS

Planned site activities that have the potential to generate emissions in the form of fugitive dust include: •

Demolition Activities - Wrecking, moving or dismantling of a load-supporting structural member or portion of a building, related cutting, disjointing, stripping, removal of structural elements, removal of existing at-grade features such as pavement or foundations, and processing of concrete and asphalt for recycling/ reuse may produce construction emissions.



Construction Traffic - Movement of construction equipment around the construction area is capable of creating construction emissions in excavated or cleared areas. There is also the potential for vehicular traffic on paved or unpaved roads and parking lots to produce construction emissions.



Site Preparation and Mass Grading - Clearing, grubbing, excavation, processing of rock for reuse as fill, grading, construction of site retaining walls, and backfilling operations can produce both fugitive dust and vehicle emissions.



Trenching Activities - Excavation of trenches for the installation of underground utilities can cause construction emissions.



Offhaul - Removal of excess soil and rock from site during mass grading for disposal off site can produce both fugitive dust and vehicle emissions.



Material Stockpiles and Inactive Areas - Stockpiles of soil generated from excavation activities and exposed areas where soil has been disturbed may contribute to windborne dust emissions.



Cleanup and Pad Grading - Backfilling, pad grading and re-vegetating of the excavated areas may produce both fugitive dust and vehicle emissions.



Foundation Work - Excavation of footings and other foundations elements, construction of structural retaining walls, and backfilling operations can produce both fugitive dust and vehicle emissions.

Mitigation of these potential sources of fugitive dust is addressed in Section 8.0.

7-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8.0

8364.000.003 February 12, 2010 Revised February 17, 2010

DUST MITIGATION MEASURES

This section presents mitigation measures to control sources of fugitive dust generated by soil disturbance or excavation. The methods proposed meet the requirements of the ATCM and, in some cases, may actually be more stringent than the ATCM provisions. These mitigation measures are also presented in the project Dust Control Plan, which more generally addresses particulate matter emissions due to construction activities.

8.1

TRACK-OUT PREVENTION AND CONTROL

Asbestos airborne toxic control measure (17 CCR 93105(e)(4)(A)) requires prevention and removal of visible track-out from a paved road at any location where vehicles exit the work site. 1. Track-out of loose materials will be controlled using a stabilized construction entrance consisting of gravel pads with a tire washing/cleaning station installed at the access point from the project site to the paved public road to prevent tracking of mud onto public roadways. The stabilized construction entrance will be installed according to the specifications provided in the Erosion and Sediment Control Plan of the Storm Water Pollution Prevention Plan (SWPPP) for the site. 2. All vehicle tires will also be inspected and washed as necessary to prevent track-out (at gravel ramps of at least 50 feet long) prior to entering the paved roadways. 3. All paved roads within the construction site will be swept twice daily with a wet sweeper. 4. At least the first 500 feet of any public roadway exiting from the construction site will be swept twice daily using a wet sweeping vacuum device. The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden. 5. Any visible track-out on a paved public road at any location where vehicles exit the work site will be removed using a wet sweeping vacuum device at the end of the work day.

8.2

ACTIVE STORAGE PILES

Asbestos airborne toxic control measure (17 CCR 93105(e)(4)(B)) requires active storage piles be adequately wetted or covered with tarps. Fugitive dust emissions from active soil storage piles will be controlled using the following methods: 1. Provide adequate watering of all active storage areas containing waste materials or materials to be recycled from demolition activities to prevent dust from becoming airborne (without creating run-off) at least three times per shift per day, or as often as necessary in order to

8-1

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

prevent dust emissions from crossing the property line. Thoroughly wet down these areas prior to weekends or holidays and/or arrange for weekend watering as necessary to prevent airborne dust. 2. Install dust enclosures, curtains, dust collectors, plastic tarps, screens, windbreaks, misting systems, fencing, or plant tree windbreaks on the property line on windward and down windward sides of active stockpile areas, including abatement and demolition areas, as necessary in order to prevent dust emissions from crossing the property line.

8.3

INACTIVE DISTURBED SURFACE AREAS AND STORAGE PILES

The asbestos airborne toxic control measure (17 CCR 93105(e)(4)(C)) requires stabilization of inactive (no disturbance for more than seven days) disturbed surface areas and storage piles by means of wetting, covering, and/or application of chemicals. Fugitive dust emissions from inactive disturbed surface areas and storage piles will be controlled with the following mitigation measures: 1. Inactive stockpiles will be covered with a tarp consisting of a 10 mil (0.01 inch) polyethylene plastic or equivalent with bracing to hold it down. It may be preferable to cover large stockpiles with other equivalent soil stabilization techniques, such as hydroseeding or applying non-toxic soil stabilizers. 2. If grading will not take place within 7 days following demolition of existing foundations and pavement, the exposed surface soil will be stabilized with dust palliative and water to form a crust on the soil surface. 3. Graded roadway and building pad areas will be stabilized with chemical stabilizers within 7 days of grading completion. 4. Openspace areas where finished grading is complete will be hydroseeded within 7 days to minimize the amount of disturbed soil at the surface. For slopes that are not yet complete but will remain inactive for greater than 7 days, it may be preferable to apply hydroseed and maintain a grass cover. Refer to the construction SWPPP for stabilization details.

8.4

ON-SITE TRAFFIC CONTROL

The asbestos airborne toxic control measure (17 CCR 93105(e)(4)(D)) limits on-site traffic speeds to 15 miles per hour (mph) and requires stabilization of unpaved roads and parking areas by means of wetting, covering, and/or application of chemicals. Fugitive dust emissions from construction traffic traveling on unpaved surfaces will be controlled with the following mitigation measures: 1. All unpaved areas in the project construction site subject to vehicular traffic, including access roads, parking areas and staging areas, will be watered prior to the start of any personnel or equipment (other than water trucks that are actively spraying water to control dust) traveling 8-2

Hunters View Redevelopment Project Asbestos Dust Mitigation Plan

8364.000.003 February 12, 2010 Revised February 17, 2010

on the unpaved surfaces at the beginning of the work day. In addition, the unpaved surfaces will be watered every two hours or frequently enough to maintain adequate wetness, whichever is greater. The frequency of watering can be reduced or eliminated, as appropriate, during periods of precipitation. Watering frequency may be increased during above average ambient air temperatures or wind speeds. (Reclaimed water will be used if required by Article 21, Section 1100 et seq. of the San Francisco Public Works Code. If not required, reclaimed water should be used whenever possible.) 2. Visible speed limit signs will be posted at the construction site entrances. No construction vehicles will exceed 10 miles per hour (mph) (16 kilometers per hour [km/h]) within the construction site and 15 miles per hour (mph) offsite within 500 feet of the project. 3. On site parking areas for construction equipment and materials storage areas will be graveled to reduce fugitive dust emissions. 4. Gravel access pads will be constructed in the traveled areas of temporary stockpile locations. Four to six inches of appropriately-sized gravel will be spread evenly to construct the pads. Additional gravel will be added periodically to maintain effectiveness. 5. Pave roadways as early as practical or install a temporary rock surface to minimize the amount of disturbed soil at the surface. The following mitigation measures will be followed for fugitive dust emissions from construction traffic traveling on paved surfaces located on the site: 1. Construction areas adjacent to and above grade from any paved roadway will be treated with BMPs, as specified in the Construction SWPPP. 2. All paved roads within the construction site will be swept twice daily with a wet sweeper. 3. Limit on-site traffic to only those vehicles necessary to support construction activities. Construction employees will park personal vehicles on paved streets adjacent to the site. If any of the above mitigation measures fail to properly control fugitive dust emissions, one or more of the following reasonably available control measures, will be applied: 1. Physical or chemical stabilization, such as a dust palliative, will be applied to control dust on unpaved roads if necessary. 2. Gravel, recycled concrete, crushed rock, or other material of low silt content (

Suggest Documents