Debris Managment Site (DMS) and Temporary Debris Managment Sites (TDMS) and Operations
During the pre-event planning Ameri-Green, appropriate DMS/TDSR sites should have been identified for use in the event of activation. It is recommended that, at a minimum, the following actions be taken prior to the site being placed in service.
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A photographic and/or video record of the condition of the site prior to activation should be made and maintained.
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Basic features such as buildings, fences, culverts and landscaping should be documented and noted.
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Random soil samples should be taken throughout the site with the area from which the sample was taken documented and retained.
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Random ground water samples should be recorded and retained in the same way.
The site plan and fire action plan should be developed and presented once the TDSR site has been identified. The plan will be submitted to the Client for approval and will include, at a minimum the following data:
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An overall site plan;
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Identification of ingress and egress routes;
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Traffic plan both inside and outside the site;
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Inspection tower(s);
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Storage;
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Debris reduction area;
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Safety and exclusion zones;
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The site activation date and project hours of operation;
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Site management team with 24-hour contact information.
In some circumstances, it may be possible to encounter hazardous, toxic and/or radiological waste. If in fact such materials are encountered, AMERI-GREEN will construct a containment area, lined with impermeable material and constructed with a berm to prevent contamination of the surrounding area. The containment area will be approximately 25 feet on all sides with hay bales, staked in place, serving as an additional safety berm. The entire area will be lined with heavy gauged plastic to provide a waterproof barrier. Because runoff entering the containment area could compromise its integrity, site grading will be conducted to eliminate the threat. Finally, additional heavy gauge plastic, sufficient to cover the entire area, will be provided to prevent rain from entering the containment. As the debris is collected and stored, a locally licensed HTRW contractor, license in conformity with all applicable state, federal and local regulations will remove the material.
HTRW is often confused with household hazardous waste in that the Comprehensive Environmental Response, Compensation, and Liability Act (CERCELA) and the Resource Conservation and Recovery Act (RCRA) often refer to listed materials as hazardous substances. Household hazardous waste includes, but is not limited to waste oil, waste fuel, paints, chemicals, antifreeze, pesticides, spray cans, unidentified liquids, common household cleaning sup plies, motor oil, lubricants, transmission and brake fluids, propane tanks, gasoline, diesel fuel, batteries and oxygen bottles. Most if not all of these items do not fall under CERCELA or RCRA. However, there is some cross over. For example, industrial waste, naturally recurring radioactive materials, products and waste of the oil and gas industry, herbicides and pesticides will fall under that guidance. AMERI-GREEN is careful to err on the side of caution and seek the assistance of a local HTRW contractor. In this instance, however, HHW is to be left at the curb.
Immediately following is a general outline and diagram of a typical TDSR site provided for your review and consideration. While FEMA 325 (PAPPG) recommends a 100-acre site, practice and experience has shown that sites of seven (7) acres or more will suffice in most situations. Of course, the exact nature of the storm will dictate not only site size but space allocations as well. How the debris will be reduced will also impact the layout. F or example, grinding generally requires 300 feet from any residential or commercial structure and public right of way. Contrariwise, open burning requires approximately one quarter of a mile from residential area. These requirements will vary by state. However, safety also plays a significant role in the decision-making process.
Tower construction begins during the initial phases at the pre-determined site locations. AMERI-GREEN follows the USACE specifications as follows: The platform floor elevation will be ten (10) feet above existing ground elevation. The 8’ by 8’ floor area will be constructed using 2” by 8” joints, 16” OC with ¾ inch plywood. The Platform will be supported by a minimum of four 6” by 6” posts. The platform will contain a 4’ high wall constructed of 2” by 4” studs covered with ½ “plywood to protect the interior. The area of the floor will be covered with a roof with a minimum of 6’ 6” of headroom below the ceiling/roof support joists. Steps, with a handrail, will be provided for access to the tower. All towers will be firmly anchored to the ground. Restroom facilities will be placed at all TDSR Sites conveniently located for use by site personnel. A representative depiction follows:
Environmental Plan
As discussed in the Pre-Event Planning section earlier in brief, AMERI-GREEN is extremely aware of its obligations regarding environmental considerations. These issues typically arise because of catastrophic events such as flooding, tornadoes, large scale fires and major hurricanes. The destruction enhances the possibility that medical waste, dead animals, hazardous waste, and household hazardous waste will enter the debris stream. Proper curb side segregation techniques, as required by FEMA 325 (Debris Management Guide) (PAPPG), will not always guarantee the inadvertent entry of such debris into the DMS/TDSRS. There are, however, various steps that can be taken to mitigate the effects of such occurrences:
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As discussed previously in brief, soil and water samples should be taken prior to and post closure of all DMS/TDSRS locations;
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The training of supervisors and crews for proper segregation techniques to severely limit the inadvertent introduction of the debris into the DMS;
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Establishing a lined containment area within the DMS/TDSRS such as illustrated below:
4. Compliance with all applicable EPA and DEQ guidelines as well as State and Federal statutory requirements such as the following:
a. Clean Air Act
b. Clean Water Act
c. National Environmental Policy Act
d. Resource Conservation and Recovery Act
e. Endangered Species Act
f. Wild and Scenic Rivers Act
g. Historic Preservation Act
h. Fish and Wildlife Coordination Act of 1956
i. Coastal Barrier Resources Act
j. Coastal Zone Management Act
k. Rivers and Harbors Act
Please refer to FEMA’s NEPA Desk Reference for more details and procedures.
AMERI-GREEN always has and always will comply with all state and federal guidelines. In fact, AMERI-GREEN processed and recycled millions of cubic yards of vegetative debris.
Typical Site Specific Health and Safety Plan
AMERI-GREEN maintains a comprehensive safety plan and program modeled after the USACE FMFM-385-1 series. The document itself comprises over 300 pages and is therefore far too long to include. However, a complete copy is available upon request.
Personal Protective Equipment (PPE) is required of all personnel entering the site perimeter without exception. PPE includes hard hats, safety shoes/boots, safety vests, protective eyewear, and hearing protection. Tower personnel will be provided air horns to be sounded should anyone enter the site without proper PPE. Upon sounding of the horn, all work must cease until an all clear is sounded.
The above reflects a typical layout of a TDSR Site illustrating the ingress and egress routes and general traffic flow. Both the C & D and Vegetative drop off points are wide enough to accommodate multiple deliveries of material simultaneously. Vehicles are stopped at the tower (T) and the loads are judged. They then proceed to the designated area for unloading. A second tower is sometimes placed at the exit for quality control purposes.
Site Development Design, Operational and Safety Features
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Portable toilets are conveniently located to serve to site and tower personnel;
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When required, silt and/or other fencing to control erosion and access;
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Separate Ingress and Egress gates which can be secured to provide security in addition to even traffic flow throughout the site;
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Water and fire suppression/safety equipment located within the site to control dust and to provide immediate fire safety/rescue and recovery;
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A minimum of 200 feet (300 feet optimum) safety zone around all debris processing/grinding operations;
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When air curtain incineration or open burning is required, the processing site will be located a minimum of one quarter mile (1320 Feet) from any residential or business structure and a minimum of 300 feet from any debris stockpiles;
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Aggregate, mulch or any combination thereof will be used to maintain road surfaces in and around the selected sites to allow safe off-loading of debris;
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Parking areas and, when required, office areas will be established inside the fenced perimeter, site permitting, or outside;
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Establishing a lined containment area should HTRW and/or household hazardous waste inadvertently makes its way into the debris stream;
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Daily processed debris removal to minimize fire potential and expedite site close out;
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Minimum of one tower if a common gate is used. Two towers for separate gates, and;
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When requested, a separate area will be established to allow for citizen drop off of debris. The site will be monitored and emptied regularly
