Appendix D. Valley Fever Considerations (Memorandum)

Transcription

1 Appendix D Valley Fever Considerations (Memorandum)

2 Denise Duffy & Associates, Inc. PLANNING AND ENVIRONMENTAL CONSULTING MEMORANDUM TO: CC: Delinda Robinson, Senior Planner, RMA Planning Department John Ford, Planning Services Manager, RMA Planning Department Patrick Treffry, Environmental Health Bureau Nisha Been, Senior Planner, Rincon Consultants, Inc. David Lazerwitz, Project Counsel, Farella Braun + Martel LLP Shawn Zovod, Project Counsel, Ebbin Moser + Skaggs LLP Marc Ebbin, Project Counsel, Ebbin Moser + Skaggs LLP John Gaglioti, Senior Project Manager, Project Developer Engineer, First Solar, Inc. Scott Dawson, Manager of Siting and Permitting, First Solar, Inc. (for California Flats Solar, LLC) Denise Duffy, Principal, DD&A, Inc. FROM: Tyler Potter, AICP, Project Manager, DD&A, Inc. DATE: July 25, 2013; Amended April 25, 2014 SUBJECT: California Flats Solar Project (PLN120294) Valley Fever Considerations INTRODUCTION This memorandum provides additional information to the County of Monterey regarding potential public health hazards related to Valley Fever. This memorandum is in response to public comments received on the Notice of Preparation (NOP), as well as on going discussions with the Monterey County Environmental Health Bureau (see NOP comment letter from Jane Wooster dated May 8, 2013). This memorandum presents relevant background information regarding Valley Fever, describes potential impacts associated with the project that could result in the exposure of sensitive receptors (i.e., construction personnel, residences, etc.) to potential health hazards, and identifies appropriate mitigation measures. BACKGROUND Valley Fever is an illness caused by the fungus Coccidioides, which grows in soils in areas, such as the project site, that have low rainfall, high summer temperatures, and moderate winter temperatures. It is found most often in the southwestern United States (especially Arizona and California) and parts of Mexico, Central America, and South America, and been reported locally, in Monterey, San Luis Obispo, Kern and Fresno counties. Valley Fever infection rates are the highest from June to November, when soils are typically very dry. 1

3 Valley Fever is not known to spread from person to person or between people and animals. Exposure typically occurs in connection with ground disturbing activities that release fungal spores which are then inhaled. Construction personnel, agriculture workers and archaeologist typically have an increased risk of exposure to the Coccidioides fungus since those professions can be exposed to disturbed soils that harbor the fungal spores. Construction personnel at two solar sites in San Luis Obispo County recently reported contracting Valley Fever. 1 Most people who are exposed to the fungus do not develop symptoms, or have relatively mild flu like symptoms. Others, however, can experience more severe symptoms, particularly individuals with a weakened immune system, who are of African American or Filipino descent, or who are pregnant. The elderly may also be prone to more severe cases. Common symptoms include fever, cough, headache, rash, muscle aches, and joint pain. Symptoms of advanced coccidioidomycosis may include skin lesions, chronic pneumonia, meningitis, bone or joint infection. Symptoms may appear between one (1) and three (3) weeks after exposure. Some patients have reported having symptoms for six months or longer, especially if the infection is not diagnosed early. POTENTIAL IMPACTS & MITIGATION Construction activities, including grading and construction vehicle traffic, could generate dust and expose sensitive receptors (i.e., residences, construction personnel, etc.), particularly during periods of high wind, to potential health hazards associated with the Coccidioides fungus. Extended periods of high heat or unusually windy conditions could increase fugitive dust, and the resulting potential for exposure to the Coccidioides fungus. As a result, sensitive receptors could be exposed to potential health hazards during project construction. Standard construction Best Management Practices (BMPs) to minimize fugitive dust emissions, as well as standard erosion control measures, are adequate for the purposes of minimizing potential hazards associated with the release of fungal spores and are consistent with the recommendations of the California Department of Public Health. The project would implement dust suppression measures throughout project construction in accordance with a dust control plan to minimize fugitive dust and potential erosion related impacts and thereby potential Valley Fever hazards (see California Flats Solar Project, Project Description, DD&A, April 2013). In addition, the Air Quality/Greenhouse Gas Assessment (DD&A, March 2013) also identified mitigation to reduce particulate matter (PM 10 ) emissions during construction. The implementation of Mitigation Measure AQ 1 would also further minimize potential health hazards associated with Valley Fever. Mitigation Measure AQ 1 requires that the project minimize ground disturbance, revegetate disturbed areas immediately following construction, apply soil stabilizers to disturbed areas (where appropriate), conduct construction watering, and similar measures to minimize 1 Cases of Valley Fever have recently been reported by construction personnel working at two solar energy facilities in the Carrizo Valley, San Luis Obispo County. A total of 28 cases were reported in San Luis Obispo County in The California Valley Solar Ranch project reported 25 cases of Valley Fever and 3 cases have been reported at the Topaz Solar project. However, the majority of these cases were determined to be non occupational. 2

4 fugitive dust emissions (See Attachment 1). These measures would minimize the likelihood or extent of fugitive dust, thereby reducing the potential for exposure to the Coccidioides fungus. In addition to the measures described above, California Flats Solar, LLC has identified other measures to further minimize potential health hazards during construction. These measures include additional dust suppression during periods of extended high heat or excessive wind (greater than 15 mph) to minimize the release of fugitive dust and fungal spores (Mitigation Measure Haz 1). Haz 1 would minimize potential hazards to sensitive receptors (i.e., construction personnel, residences, etc.) by reducing the potential for increased fugitive dust and the release of fungal spores. Furthermore, the implementation of worker training and additional BMPs (Mitigation Measure Haz 2) would minimize the risk of exposure for construction personnel. Workforce training is an essential element to ensure that construction personnel are aware of potential hazards and methods to minimize potential risks due to exposure. These measures are consistent with best practices to minimize potential hazards and would ensure that potential impacts would be less than significant. Mitigation Measures Haz 1: Between June 1 and November 30, when Valley Fever rates of infection are the highest, additional dust suppression measures (such as additional water or the application of additional soil stabilizer) will be implemented prior to and immediately following ground disturbing activities if wind speeds exceed 15 miles per hour (mph) or temperatures exceed 95 degrees Fahrenheit for three consecutive days. The additional dust suppression will continue until winds are 10 mph or lower and outdoor air temperatures are below 90 degrees for at least two consecutive days. The additional dust suppression measures will be incorporated into the Final Construction Management Plan. The Final Construction Management Plan will be submitted to the County of Monterey for review and approval prior to the issuance of any grading permit. Haz 2: Prior to any project grading activity, the primary project construction contractor will prepare and implement a worker training program that describes potential health hazards associated with Valley Fever, common symptoms, proper safety procedures to minimize health hazards, and notification procedures if suspected work related symptoms are identified during construction. The worker training program will identify safety measures to be implemented by construction contractors during construction. Safety measures will include: Providing HEPA filtered air conditioned enclosed cabs on heavy equipment. Train workers on proper use of cabs, such as turning on air conditioning prior to using the equipment. Providing communication methods, such as two way radios, for use by workers in enclosed cabs. Providing personal protective equipment (PPE), such as half mask and/or full mask respirators equipped with particulate filtration, to workers active in dusty work areas. 3

5 Providing separate, clean eating areas with hand washing facilities for construction workers. Cleaning equipment, vehicles, and other items before they are moved offsite to other work locations. Providing training for construction workers so they can recognize the symptoms of Valley Fever and promptly report suspected symptoms of work related Valley Fever to a supervisor. Directing workers that exhibit Valley Fever symptoms to immediately seek a medical evaluation. Prior to initiating any grading, the project applicant will provide the County of Monterey Environmental Health Bureau with copies of all educational training material. CONCLUSION The project is located in an area where the Coccidioides fungus may be present. As a result, ground disturbing activities could result in the exposure of sensitive receptors to potential health hazards. Mitigation contained in the Air Quality/Greenhouse Gas Assessment (DD&A, 2013), as well as standard construction BMPs, including erosion control measures, in addition to the project dust management plan would minimize the extent of potential health hazards associated with Valley Fever. California Flats Solar, LLC has identified additional measures deemed appropriate to protect human health and safety as described above. These measures are consistent with best practices to address potential Valley Fever hazards. The implementation of these measures, in addition to the existing measures already proposed as part of the project, would minimize impacts to a less than significant level. 4

6 RESOURCES: California Department of Public Health. Date Unknown. Valley Fever. Online: Accessed May 18, California Department of Public Health Coccidioidomycosis (Valley Fever). Online: Accessed May 18, Centers for Disease Control and Prevention (CDC) Coccidioidomycosis (Valley Fever). Online: Accessed May 22, Updated May 6, Centers for Disease Control and Prevention (CDC) Fungal pneumonia: a silent epidemic Coccidioidomycosis (valley fever). Online: fact sheetcalifornia final 508c.pdf. Accessed May 22, Centers for Disease Control and Prevention (CDC) CDC Features, Valley Fever: Awareness is Key. Online: Accessed May 21, Updated May 15, 2013 County of San Luis Obispo California Valley Solar Ranch Final Environmental Impact Report. Online: Accessed May 20, County of San Luis Obispo Topaz Solar Farm Final Environmental Impact Report. Online: Accessed May 20, County of San Luis Obispo Coccidioidomycosis (Valley Fever) in San Luis Obispo County. Online: Accessed May 19, County of San Luis Obispo, Public Health Department What is Valley Fever. Online: +High+Plains+Solar+Ranch/valley_fever.pdf Accessed May 19, Das et al 2012, Occupational Coiccidiodomycosis in California, Journal of Occupational and Environmental Medicine, Volume 54(2), pp

7 Mitigation Measure AQ 1 Attachment 1 California Flats Solar Project, Air Quality/Greenhouse Gas Assessment (DD&A, March 2013) AQ 1: The Project Applicant and/or Contractor shall be responsible for implementing the following mitigation measures throughout the duration of construction. Prior to the issuance of any grading permit, the Project Applicant and/or Contractor shall submit construction drawings to the County of Monterey that include the following measures on all plans and specifications: Reduce the amount of the disturbed area where possible; Use of water trucks or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site. Increased watering frequency would be required whenever wind speeds exceed 15 mph. Reclaimed (non potable) water should be used whenever possible; All dirt stock pile areas should be sprayed daily as needed; Permanent dust control measures identified in the approved project revegetation and landscape plans should be implemented as soon as possible following completion of any soil disturbing activities; Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading should be sown with a fast germinating, non invasive grass seed and watered until vegetation is established; All disturbed soil areas not subject to revegetation should be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the MBUAPCD and SLO County APCD; All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used; All trucks hauling dirt, sand, soil, or other loose materials are to be covered or should maintain at least two feet of freeboard (minimum vertical distance between top of load and top of trailer) in accordance with CVC Section 23114; Install wheel washers where vehicles enter and exit unpaved roads onto streets, or wash off trucks and equipment leaving the site; Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers with reclaimed water should be used where feasible; 6

8 All of these fugitive dust mitigation measures shall be shown on grading and building plans; and The contractor or builder shall designate a person or persons to monitor the fugitive dust emissions and enhance the implementation of the measures as necessary to minimize dust complaints, reduce visible emissions below 20% opacity, and to prevent transport of dust offsite. Their duties shall include holidays and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the APCD Compliance Division prior to the start of any grading, earthwork or demolition. 7