URS

 

May 16, 2001

 

Arizona Department of Emergency and Military Affairs

Army National Guard, FMO Environmental Office

5636 East McDowell Road, Building M5330

Phoenix, Arizona85008-3495

 

Attn:Ms. Whitney Kirk

Compliance Project Manager

 

Re:Post-Implementation Evaluation Report

D&M Job No. 29679-006-058

 

Dear Ms. Kirk:

URS Corporation, formerly Dames & Moore, is pleased to submit one copy of this Post-Implementation Evaluation Report to summarize field observations performed on Saturday March 4, 2000, for the implementation of Dust Control Measures at the Arizona Army National Guard (AZ ARNG) Florence Military Reservation (FMR).

Should you have any questions regarding the information or conclusions presented in this report, please feel free to contact me at (602) 371-1100.

 

Sincerely,

URS Corporation

Kevin R. Somerville

Project Manager

 

KRS/cd

 

 

1.0 INTRODUCTION

URS Corporation (formerly Dames & Moore) is providing this Post-Implementation Evaluation Report as the first installment of three evaluation reports for the Implementation of Fugitive Dust Control Measures Project, at the Florence Military Reservation (FMR). This report was prepared for the Arizona Department of Emergency and Military Affairs (ADEMA) Project No. AZ08099008-2 in accordance with the scopes of work presented in our proposal dated August 30, 1999.The two additional evaluation report installments will include a 6-month evaluation report and a 12-month evaluation report. The 6-month effectiveness evaluation was scheduled to take place on Saturday July 15, 2000 but was rescheduled and completed on Saturday September 9, 2000. The 12-month evaluation will be scheduled at a future date to coincide with training maneuvers at the Florence Military Reservation (FMR).

 

2.0 PURPOSE OF EVALUATION

The purpose of the site visit was to evaluate the effectiveness of two soil stabilization dust palliatives that were previously applied at two locations within the FMR as follows:

• Mesa Staging Area (MSA)
• Main Supply Route (MSR)

The primary objectives of the evaluation and reporting that were identified in the task assignment offer (TAO) request and described in the URS (formerly Dames & Moore) proposal are as follows:

• Perform evaluations at three intervals over a period of one year to assess the effectiveness of the respective palliative at two locations on the FMR. The three intervals identified are as follows:
  • Within two weeks following implementation
  • Approximately 6 months following implementation
  • Approximately 12 months following implementation
    
    
• Assess effectiveness of the evaluations quantifiably in accordance with Pinal County Air Pollution Control Regulation 2-8-300 and the ADEMA Scope of Work, which limits the opacity of air pollutant emissions to 20 percent at the fence line or property line.It also states that opacity from any site within the property should not exceed 25 percent.
• Assess the effectiveness of the evaluations by the general observations of dust plumes that may migrate westwardly toward the Florence Gardens Community and become a nuisant issue for residents of that community.
• Use the information gathered and conclusions drawn from each evaluation to prepare a final report and Operations and Maintenance Plan to assist the Arizona Army National Guard (AZ ARNG) with projecting maintenance and re-application activities and making recommendations for future projects.

The primary method of evaluation was by opacity observations of the fugitive dust generated from vehicle traffic during training activities at the FMR. The observations were performed in general accordance with the U.S. Environmental Protection Agency (EPA) Reference Method 9 as codified in 40 Code of Federal Regulations (CFR) Part 60, Appendix A.

Reference Method 9 as presented in 40CFR60 Appendix A applies to point stationary sources generating a plume of particulate emissions. The method outlines the observation techniques, training and certification testing for qualified observers.T he method also covers data reduction methods for presenting the visual opacity measurements. The method states that a minimum of twenty-four 15-second observations be recorded on an observational record sheet and that the average of the 24 observations is the reduced number to be used when reporting opacity. The 15-second opacity observation is an average for that period. The 24 observations taken every 15 seconds equates to sixminutes so the data reduction method of averaging every 6 minutes is also known as the 6-minute rolling average method. Although the 6-minute data reduction method is called for in EPA Method 9, 1 3-minute rolling average was used for data reduction during this study. A 3-minute rolling average was utilized for data reduction because limited observation data could be collected during the study period. The limited data was due to the intermittent nature of the vehicle traffic on the study areas during the observation periods. This 3-minute rolling average, a more conservative data reduction, was agreed to by all involved in the evaluation efforts before the observations were performed.

 

3.0 SCOPE OF EVALUATION

URS performed this post-implementation evaluation for the following two palliative products that were previously applied at the FMR:

 

• EnviroKleen® - a synthetic hydrocarbon emulsion (clear oil) dust palliative
• Soil-Sement® - an acrylic polymer type dust palliative.

The first product, EnviroKleen®; was applied at the MSA (on top of a layer of crushed aggregate material) beginning January 11, 2000. The second product, Soil-Sement®; was applied to the MSA Helipad on January 12, 2000. EnviroKleen® was then applied to the MSR beginning February 7, 2000. A subsequent application of EnviroKleen® was applied to the MSA on February 10, 2000.Soil-Sement® was applied to the MSR beginning February 7, 2000 at locations where the road crossed small natural desert washes, ranging from 55 feet to 428 feet in length.

 

On the morning of Saturday March 4, 2000, Mr. Taran Doty P.E., a URS air quality specialist, set up the meteorological monitoring station, performed visual opacity observations at the MSA, traveled the highway ahead of the convoy to get into position at predetermined locations of the MSR, and performed three of the visual opacity observations. Ms. Whitney Kirk, Compliance Project Manager with the AZ ARNG, performed two of the visual opacity observations. The locations selected, also shown on Figure 1, and observes were as follows:

• MSATaran Doty
• Wash Crossing #9 of MSRTaran Doty
• Gate #5 of MSRTaran Doty
• Between Wash Crossing #2 & #3Whitney Kirk

The visual opacity observation location at the southeast corner of the MSA was selected to optimize the convoy traffic that could be seen leaving the MSA from both the southern ramp and the northern exit. General observations also were made as the vehicles drove along Track Road from the MSA to the MSR.

The area between Wash Crossing #2 and #3 was selected because it was adjacent to the Florence Garden Community and because it was in the middle of a straight segment of the MSR where the military convoy vehicles would approach speeds of 25 miles per hour (mph) or more.

The Wash Crossing #9 was selected because it coincides with an interface of application of both palliative products. This location allowed the observer to evaluate the effectiveness of both palliative products at their interface of application by allowing opacity observations of adjacent areas of the MSR (one treated with EnviroKleen®, one treated with Soil-Sement®) with one observer.

The Gate #5 location was selected at the termination of the EnviroKleen® application along the MSR and allowed the observer to evaluate the effectiveness of the palliative product compared to an untreated section of the MSR.

The Battalion 180 military convoy on March 4, 2000 was counted and consisted of the following vehicles:

• M109 Howitzer Artillery GunTrack12
• Ammunition HaulersTrack9
• Communication VehiclesTrack11
• FISTVsTrack6
• Humvees4-Wheel13
• ·.5 Ton Truck6-Wheel11
• Tow Trailers (behind 2.5T Truck)2-Wheel6
• Flatbed Transport18-Wheel3
• Fuel Tanker (Hemets)18-Wheel2
• Personnel Jeep4-Wheel7

Total 80 Vehicles

However, the military vehicles were mobilized form the MSA in individual units; therefore, each convoy size ranged from one to eight vehicles, spaced as much as a mile (or 10 minutes) apart from one unit to the next.

Visual opacity observations were made by Taran L. Doty P.E., a registered professional engineer and certified Expert Visible Emissions Evaluator. Ms. Whitney Kirk of the AZ ARNG Florence Military Operations (FMO) Environmental Office is familiar with the palliative products, the application at this site, and also is an Expert Visible Emissions Evaluator. Mr. Doty and Ms. Kirk both conducted visual opacity observations for this post-implementation evaluation.

Mr. Kevin R. Somerville, the URS project manager for this project, also was onsite to coordinate field activities, document general observations, take photographs of the convoy, and video tape the convoy. The complete set of photographs and a copy of the video tape was forwarded to the AZ ARNG, previously, under separate cover.

 

4.0 METEOROLOGICAL STATION

 

URS and other AZ ARNG field personnel arrived onsite early to set up a portable meteorological monitoring station in the southeast corner of the MSA. This portable station was assembled to measure and record the following weather data:

• Wind speed
• Wind direction
• Ambient temperature
• Relative humidity
• Barometric pressure

The station was assembled, set up to collect 15-minute average data, and operated at one location for the duration of the day’s observations, or about four hours. For the purposes of this evaluation, only wind speed, direction, and ambient temperature were reported herein. The relevant meteorological monitoring station data are included as Table 1.

Climatological data obtained from the National Weather Service Gauge Station located in Coolidge, Arizona indicated that 0.24 inch of precipitation had occurred on February 21, 2000, 10 days following the application. However, no other precipitation had occurred before February 21, 2000, since January 1, 2000, indicating the soil moisture for the area most likely is relatively low. The precipitation data from the Coolidge, Arizona, National Weather Service Gauge Station are included as Table 2.

On March 4, 2000, the wind speed at the FMR from 10:00 a.m. to 1:00 p.m. ranged between 5 and 6 mph. The average wind speed for this time period was 5.9 mph. The wind direction varied from 87 to 251 degrees from north. The temperature increased from 67.8 degrees Fahrenheit at 10:00 a.m. to 78.9 degrees Fahrenheit at 1:00 p.m. The average temperature was calculated to be 74.7 degrees Fahrenheit.

 

1.0 Observations

In accordance with EPA Reference Method 9, opacity observations were made at 15-second intervals. These data were collected and the resultant data set used to calculate running 3-minute average values (for intermittent sources). At the speed and spacing at which the convoy vehicles traveled along the MSR, the 15-second interval corresponded to a maximum of one reading after every vehicle. Generally, when no vehicles were passing, then no fugitive emissions were observed.Because of the very intermittent nature of the convoy travel along the MSR during this exercise, it was difficult to obtain enough opacity observations to calculate 3-minute average values. As shown in the attached calculation tables, there was difficulty in obtaining a sufficient quantity of observations to perform the requisite 3-minute average calculations. Therefore, zeros have been added to extrapolate a 3-minute rolling average.

The data shown in the attached tables can be used to draw some useful conclusions regarding the relative performance of the two palliative products. Primarily, vehicle travel at this section of the MSR treated with either product resulted in only small quantities of fugitive dust with low opacity readings (15 percent or less). Combining these short emission “events” with the much larger periods of time in which no emissions were observed, average values far below regulatory thresholds result.

 

1.1 MESA STAGING AREA

The first opacity observations began at 10:39 a.m. as the convoy left the MSA in approximately four equally sized groups. The vehicles were mobilizing from a parallel position to the MSR at speeds less then 10 mph.As mentioned previously, the majority of the MSA had been covered with approximately 4 inches of crushed aggregate and then treated with the EnviroKleen® palliative at an application rate of 25 square feet per gallon.This combination of treatment provided excellent control of fugitive dust emissions as the vehicles (tracked and rubber-tired) drove across the surface. Virtually no particulate emissions were generated. Only slight dust plumes were generated as some of thetracked vehicles performed hard turning maneuvers and scraped the aggregate and layer of treated material away to expose the untreated soils beneath. Visual opacity observations were attempted, but as shown in Table 3, the emissions were of insufficient magnitude and duration to yield direct opacity observation values greater then zero.The data was used to calculate a 3-minute rolling average of zero.

 

1.2 MAIN SUPPLY ROUTE – WASH CROSSING #9

 

After observing vehicular activity at the MSA, Mr. Taran Doty relocated to the MSR at Wash Crossing #9.At this location, opacity observations were performed for both palliative products.

The Soil-Sement® product appeared to perform more favorably than the EnviroKleen® in reducing the generation of fugitive dust. In fact, while some amount of dust was observed to be generated on the EnviroKleen®-treated soil at Wash Crossing #9, no additional dust was observed once the vehicles traveled across the portion of the road treated with Soil-Sement®. Visual opacity observations for the EnviroKleen®-treated MSR ranged from zero to fifteen percent. Visual opacity observations for the Soil-Sement® treated Wash Crossing #9 were all zero percent. The maximum 3-minute rolling averages of the EnviroKleen® and Soil-Sement® opacity data was 5.0 and 0.8 percent, respectively. The results of the visual opacity observations are summarized in Tables 4 through 5.

It should be noted that the small quantities of dust that were generated from soil treated with the EnviroKleen® “carried” only a short distance from the road before quickly settling from the atmosphere.

All wash crossings stabilized with Soil-Sement® were observed after the convoy had passed. Carry-over of soil particles from MSR treated with EnviroKleen® (loose soil matrix) onto the portion of the MSR stabilized with Soil-Sement®.

After a group of vehicles had passed, Wash Crossing #9 was visually inspected. While the portion of the MSR treated with EnviroKleen® showed some disturbance in the surface (i.e.; tire or track imprints), the hard crust that was formed on the Soil-Sement® wash crossing showed very little disturbance. The crust formed by the application of the Soil-Sement® product appeared to remain intact.

 

1.3MAIN SUPPLY ROUTE – GATE #5

After observing vehicular activity at Wash Crossing #9, Mr. Taran Doty relocated further north on the MSR to Gate #5. At this location, opacity observations were performed for the EnviroKleen® palliative product and an untreated section of the MSR. By the time the observers arrived at Gate #5, the majority if the convoy vehicles had already passed and proceeded to their destination. Opacity observations were performedfor the remaining straggling vehicles, but the intermittent and wide spacing again presented a difficulty in obtaining a sufficient quality of observations to perform the 3-minute average calculations. Therefore, zeros have been added to extrapolate a 3-minute rolling average.

As shown in the data collected at Gate #5, the application of the EnviroKleen® palliative provided a significant reduction in the generation of fugitive dust as vehicles traveled along the MSR. The rubber tired vehicles were observed generating more dust than the tracked vehicles. Visual opacity observations for the treated section ranged from 5 to 30 percent while those for the untreated section were as high as 100 percent. The maximum 3-minute rolling average for the EnviroKleenÒ -treated MSR was 5.8 percent while the maximum 3-minute rolling average for the untreated MSR was 21.7 percent. The results of the visual opacity observations are summarized in Tables 6 through 9.

Mr. Kevin Somerville performed general observations and videotaping at Gate #5 simultaneously to Mr. Doty performing opacity evaluations. Mr. Somerville observed dust plumes over 30 feet high along the untreated MSR looking north – as much as one half mile away. The dust plume appeared to linger in the atmosphere for several minutes. This was likely a cumulative affect from multiple vehicles traveling along the untreated MSR. However, it is URS’s understanding that the MSR north of Gage #5 is not improved with engineered road base material, but, rather, it consists of natural soils.

 

1.4 MAIN SUPPLY ROUTE – BETWEEN WASH CROSSING #2 AND #3

After observing vehicular traffic at the MSA, Ms. Whitney Kirk relocated the MSR between wash crossings #2 and #3. At this location, opacity evaluations were performed with EnviroKleen®-treated oil. The rubber-tired vehicles were observed to generate more dust than the tracked vehicles. The small amount of dust kicked up by all vehicles did not appear to travel very far except to fall rapidly back to the ground.Visual opacity observations for the treated section ranged from 0 to 10 percent and the maximum 3-minute rolling average was 3.8 percent. The results of the visual opacity observations are summarized in Tables 10 through 12.

 

2.0 WASH CROSSING OBSERVATIONS

URS and the AZ ARNG identified 15 wash crossings that possibly would require soil stabilization to protect from both stormwater erosion and dust from vehicles. Figure 1 shows these crossings at their corresponding reference numbers.A small sign was placed at the southeast corner of each wash crossing along the MSR to indicate the crossing number (1 through 15). Of these, 12 were treated with Soil-SementÒ blended with Aggregate Base material (AB). The remaining three wash crossings will be observed to assess if soil stabilization is necessary in the future to keep the dust control measures intact. Table 13 indicates the general observations for each crossing after the convoy had traveled along the MSR.The wash crossing observations were intended to evaluate the presence of the following:

• Raveling
• Cracking
• Rutting
• Erosion rills
• Abrasions
• Carry over

 

The type or degree of erosion or diminished dust control is dependent upon the soil matrix adjacent to the Soil-Sement® -treated section, the size and frequency of rock content, steepness of grade, and exposure to direct runoff.

 

7.0 PALLIATIVE PENETRATION MEASUREMENTS

The depth of penetration of EnviroKleen® was measured in the field approximately three weeks after the palliative was applied to allow time for the miniscule downward migration to take place. The depth was measured at three locations at the MSA and three locations along the MSR. A hand trowel was used to excavate a small hole approximately 6 inches in diameter and 3 inches deep. The palliative coated the soil particles such that they became darker in color and distiguishable from untreated soil.The depth of penetration was easily discernable given the color contrast.A hand tape was used to measure from a straight edge held across the open hole to the horizontal plane of the treated soil. The results of the palliative penetration tests are summarized in Table 14.

The depth of Soil-Semen® was observed and measured during mixing and placement based on the thickness of dry AB material spread across the MSR at each crossing and the relative thickness after compaction. The loose lift thickness of soil was approximately 6 inches. After compaction by the 9-wheel pneumatic compactor, the thickness was estimated to be 4.5 inches. No depth measurements were taken after the Soil-Sement® had cured to a very hard solid matrix.

 

8.0 CONCLUSIONS

The following conclusions were drawn form the post-implementation observations and opacity measurements performed at the FMR:

1. The opacity of the dust plumes, generated by the convoys, on both the EnviroKleen® and the Soil-Sement® treated areas were all lower than the 20 percent as required at the property line according to Pinal County Air Pollution Control Regulation 2-8-300.The more conservative 3-minute rolling average data reduction method was used to calculate the maximum opacities for each area observed.
2. The EnviroKleen® dust palliative appeared to greatly reduce the generation of fugitive dust emissions at the site as evidenced at Gate #5 and the opacity observations performed for both treated and untreated sections of the MSR. Although dust was generated immediately behind the vehicle at a height of approximately six feet, the dust quickly settled and no plume was generated.
3. The combined application of coarse rock material and Envirokleen® dust palliative appear to provide excellent control of fugitive dust generation.
4. Opacity observations at Wash Crossing #9 suggest that the Soil-Sement® dust palliative provided a greater degree of dust control than the EnviroKleen® product for the soil conditions of the MSR.
5. Both the EnviroKleen® and Soil-Sement® palliatives appear to exhibit a tolerance to the type of vehicular traffic of the MSR (generally heavy vehicles with both rubber tires and tracks).The EnviroKleen®-treated MSR showed more surface disturbance after use than the Soil-Sement®. This does not constitute a decrease in performance because vehicle traffic (tracked and rubber tire) actually forces the blending of EnviroKleen® and soil and therefore increases performance. According to the vendor literature on the Palliatives, the EnviroKleenÒ penetrates the soil surface, adds weight, and acts to bond the small soil particles into larger masses that are less likely to become airborne and that settle out of the air faster than fine dust particulates.The Soil-Sement® product, on the other hand, is an acrylic polymer that acts to bond the treated soil virtually eliminate dust and to form an impenetrable surface that resists erosion and wear.At least for this evaluation, the Soil-Sement® appeared to maintain its general integrity at the surface after receiving heavy, abrasive traffic, particularly tracked vehicles.
6. The rubber-tired military vehicles appeared to develop appreciably more fugitive dust than the tracked vehicles. The 18-wheel variety of military vehicles created the most sustaining dust plume, presumably because of their multiple tires in contact with the road, and also because of their capabilities of traveling faster than the tracked vehicles.
7. These observations of fugitive dust generation and treated surface degradation should not be considered complete evidence of the long-term performance of either product, or its one-time application.
8. The penetration of EnviroKleen® at the MSA ranged from 5/8 inches to 1-1/4 inches, which was not as deep (3 inches) as observed during the Test Section conducted in September 1999.

 

9.0 RECOMMENDATIONS

The following summarizes our recommendations based on the post-implementation observations and opacity measurements performed at the FMR:

 

1. The MSA should be lightly graded after each use to redistribute the aggregate in areas where it is significantly disturbed by vehicle traffic (i.e.; tracked vehicles performing hard turning maneuvers). Ideally, a chain bar or gannon box, dragged behind a vehicle, is used to level the rock without severe displacement.
2. This type of evaluation should be continued at the 6-month and 12-month intervals to evaluate the performance of the products after repeated use and long-term exposure to the elements in order to reasonably assess the need (or schedule) for maintenance re-applications of one or both palliatives.
3. In future projects where coarse rock is proposed to assist in armoring the sub-grade and reducing fugitive dust, the material should be crushed, angular aggregate, which can be purchased from most commercial suppliers that produce concrete materials (i.e.;#57 rock).
4. In future projects where coarse rock is proposed, the EnviroKleen® palliative should be applied, first, prior to the spreading of rock material to achieve the maximum palliative penetration.
5. Consideration should be given to schedule the 6-month evaluation for both a Saturday and Sunday during the AZ ARNG training weekend.Visual opacity observations should continue on Saturday to compare to the baseline results and conclusions presented herein. We recommend that the military vehicle convoy travelling on Sunday morning from the firing boxes, along the MSR, and back to the MSA be observed. Based on conversations with FMR Training Site personnel, the convoy will be grouped with greater consistency on Sunday. Observing the convoy at this time would provide a “worst-case” scenario for generation of fugitive dust and would likely yield the largest dust plume, if any.

The training site personnel should cease the historical procedure to apply water, using a water truck, as a supplemental dust control measure.

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