14.3 Good Housekeeping Part 2: Stockpiles, Dust Control, Wind Fence, Street Cleaning, Sanitary Waste, and Trash

1. Stockpiles (12.6.7)

Unprotected stockpiles of stripped topsoil, structural fill, bedding sand, crushed aggregate, or cold-mix asphalt are among the most concentrated sources of sediment and chemical runoff on a construction site because their steep, loose, unvegetated side slopes are highly vulnerable to both raindrop splash detachment and wind scouring.

Siting and Geometry Rules

• Minimum $50\text{-Foot}$ Setback: Locate all stockpiles on flat, well-drained upland ground at least $50\text{ feet}$ away from storm drain inlets, open drainage swales, ditches, wetlands, and surface waters, and completely outside the $50\text{-foot}$ natural riparian buffer and tree Critical Root Zones (CRZs).
• Prohibition on Paved Streets & Flow Paths: Never place a soil, sand, or aggregate stockpile on paved public or internal streets, across curb gutters, on sidewalks, or inside concentrated overland flow paths!
• Slope & Height Limits: Shape stockpiles with side slopes no steeper than $\le 2\text{H}:1\text{V}$ and limit pile height to prevent rotational slumping and reduce exposure to high-velocity wind shear.

Two Mandatory Lines of Stockpile Protection (EPA CGP Part 2.2.5 & 12.6.7)

Every construction stockpile must be protected by a two-part defense system:

1. Continuous Downgradient Perimeter Sediment Barrier: Install a sediment barrier—such as trenched silt fence, a heavy compost filter sock, a staked fiber roll (wattle), or a gravel-bag berm—around the entire downgradient base perimeter of every active or inactive stockpile. Leave an access opening only on the upslope side so front-end loaders can excavate or add material without crushing the perimeter barrier.
2. Surface Cover / Stabilization ($14\text{-Day}$ Inactivity Rule): Whenever a soil, topsoil, or fine-aggregate stockpile will remain inactive (unused) for $14\text{ calendar days}$ or more (or prior to forecasted rainstorms or high-wind events where required by state/local MS4 permits), stabilize the exposed surface of the pile using:
   • An anchored waterproof plastic tarp or geotextile cover weighted down continuously around the base and seams with gravel bags (never anchor a stockpile tarp by throwing loose dirt on top of the plastic!), OR
   • Temporary seeding and mulching, OR
   • A sprayed polymer tackifier, acrylic soil binder, or bonded fiber matrix.

Special Rule for Cold-Mix Asphalt & Contaminated Soil Stockpiles (12.6.7): Stockpiles of cold-mix asphalt (which contains leachable cutback petroleum solvents or emulsions) or petroleum/chemically contaminated soils must always be placed atop an impervious plastic sheeting liner ($\ge 10\text{ mil}$) and kept covered with an anchored waterproof tarp at all times when not actively being worked, surrounded by a continuous containment berm.

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2. Dust Control (12.6.2) and Wind Fence (12.6.10)

Dust Control (12.6.2)

Fugitive windblown dust—comprising $\text{PM}_{10}$ (coarse inhalable particulates $\le 10\text{ }\mu\text{m}$) and $\text{PM}_{2.5}$ (fine respirable particulates $\le 2.5\text{ }\mu\text{m}$)—degrades ambient air quality, violates Clean Air Act and local air-district opacity limits (typically $20\%$ maximum plume opacity at the property line), creates blinding highway visibility hazards for motorists, and deposits fine sediment and adsorbed phosphorus directly into nearby waterways.

• Water Truck Spraying (Crucial Exam Checkpoint): Spraying haul roads and active grading planes with a water truck is the most common real-time dust control method. Operators must apply water in frequent, light misting passes so the surface soil stays just damp enough for capillary tension to bind dust particles together without over-watering to the point of soil saturation, mud generation (which causes severe vehicle trackout), or erosive surface runoff!
• Chemical Dust Suppressants & Soil Binders: For semi-permanent haul roads and inactive graded pads, contractors can spray anionic polyacrylamide ($\text{PAM}$), acrylic copolymers, vinyl acetate emulsions, lignin sulfonate (a wood-pulp byproduct), non-toxic vegetable-oil or tall-oil resin emulsions, or hygroscopic deliquescent salts (magnesium chloride [$\text{MgCl}_2$] or calcium chloride [$\text{CaCl}_2$]) that draw moisture from the air to keep road surfaces damp. Environmental precaution: Avoid excessive application of chloride salts ($\text{MgCl}_2$ or $\text{CaCl}_2$) near salt-sensitive freshwater streams, wetlands, or roadside vegetation where chloride runoff causes osmotic toxicity.
• Operational & Mechanical Controls:
  • Enforce a strict maximum $15\text{ mph}$ vehicle speed limit on unpaved site haul roads (reducing truck speed from $30\text{ mph}$ to $15\text{ mph}$ cuts fugitive wheel-dust emissions by $50\%$ to $75\%$).
  • Stabilize primary haul roads with crushed gravel, recycled concrete aggregate, or wood chips.
  • Halt mass earthmoving and fine grading when wind gusts exceed $25\text{ mph}$.
  • Roughen or chisel-plow bare clay/silt soils perpendicular to prevailing winds, and require all highway dump trucks to cover their beds with tarps while maintaining at least $6\text{ inches}$ of vertical freeboard below the top of the truck bed sidewalls.

Wind Fence (12.6.10)

A wind fence is a vertical porous barrier ($3\text{ to }10\text{ feet}$ high) constructed of wooden-slat snow fencing or UV-stabilized high-density polyethylene (HDPE) knitted mesh fabric with $40\%$ to $50\%$ open porosity, tensioned on driven steel or timber posts oriented perpendicular ($90^\circ$) to the prevailing wind direction along the upwind edge of exposed grading areas, coastal dunes, or fine soil stockpiles.

• Aerodynamic Physics — Why $40\%$ to $50\%$ Porosity and the $7H\text{ to }10H$ Sheltered Zone: Why must a wind fence have $40\%$ to $50\%$ open porosity rather than being a $100\%$ solid wall? A solid, non-porous wall forces the entire wind stream abruptly upward over its crest, creating an intense low-pressure wake behind the wall that generates violent, turbulent downward eddy vortices on the leeward side—scouring soil even worse than having no barrier at all! By bleeding $40\%$ to $50\%$ of the airflow through its small openings, a porous wind fence breaks up large turbulent eddies, reduces near-ground wind shear velocity below the threshold friction velocity for soil detachment, and creates a calm leeward sheltered zone extending a horizontal distance of $7\text{ to }10\text{ times}$ the height of the fence ($7H\text{ to }10H$) downwind (for example, a $4\text{-foot}$-high wind fence protects a $28\text{- to }40\text{-foot}$-wide strip downwind, so parallel wind-fence rows across a large graded tract are spaced $7H\text{ to }10H$ apart). Accumulated windblown sand drifts must be excavated before they bury the fence.

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3. Street Cleaning (12.6.8)

Even when a stabilized construction exit (12.4.8) is properly maintained, heavy truck traffic during wet weather can carry residual mud clods onto adjacent public roadways.

• Daily Inspection & End-of-Shift / Pre-Storm Sweeping: Inspect paved public streets, highway shoulders, and internal paved subdivision roads adjacent to construction exits daily. Any tracked mud, dirt clods, or spilled aggregate must be cleaned up before the end of each work shift and prior to any forecasted rain event using dry mechanical rotary-broom sweepers, regenerative-air/vacuum street sweepers, flat-blade loader scrapers, or hand shovels and stiff brooms.
• Absolute Prohibition on Street Washing/Flushing: NEVER wash, flush, or hose tracked mud or sediment off a paved street into street gutters, roadside ditches, or storm drain inlets! Hosing down a muddy street transforms dry, easily sweepable soil clods into highly mobile turbid slurry that flows straight into catch basins and receiving streams. All collected street sweepings must be hauled back onto the construction site and deposited in a contained upland fill area or stockpile behind active perimeter sediment controls.

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4. Sanitary Waste Management (12.6.5)

Portable chemical toilets (Porta-Johns) on construction sites hold concentrated raw human sewage (fecal coliform and E. coli bacteria, enteric viruses, and high biochemical oxygen demand) mixed with concentrated blue deodorizing and disinfecting chemicals (containing formaldehyde, glutaraldehyde, quaternary ammonium biocides, or bronopol) that are acutely toxic to aquatic life.

Three Mandatory Siting, Anchoring, and Servicing Rules

1. Minimum $50\text{-Foot}$ Setback & Traffic Protection: Place portable toilets on flat, level, stable upland ground at least $50\text{ feet}$ away from storm drain inlets, open drainage ditches, curb gutters, wetlands, and surface waters. Set units well back from paved street curbs and active haul-truck turning lanes (or shield them with concrete jersey barriers/bollards) so a backing dump truck or loader cannot strike a unit and knock it over into the street gutter.
2. Mandatory Physical Ground Anchoring: Physically anchor every portable toilet to the ground—using driven rebar stakes or steel pins through the base skids, heavy gravel/sandbags across the base runners, guy wires, or a staked timber perimeter frame—so high thunderstorm wind gusts cannot blow the lightweight plastic enclosure over and spill raw sewage and blue biocide chemical across the site.
3. Licensed Vacuum-Truck Servicing & Secondary Containment Pans: Contract a licensed sanitary-waste vacuum-truck hauler to pump out, clean, and service portable toilets on a regular schedule so holding tanks never overflow (ensuring the pump truck parks on stable ground and uses hose drip containment during pumping), and place secondary containment pans/trays beneath portable toilets wherever required by state CGP or local MS4 permits.

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5. Trash Containment (12.6.9)

Construction and demolition operations generate large quantities of solid waste—cardboard packaging, scrap lumber, drywall offcuts, plastic shrink-wrap, empty caulk tubes, food wrappers, beverage cups, and expanded polystyrene (styrofoam) insulation beads.

• Covered, Leak-Proof Roll-Off Dumpsters: Provide sufficient leak-proof, covered roll-off dumpsters and lidded trash receptacles across the site, and police the jobsite daily to collect windblown litter before it reaches perimeter fences or drainage swales.
• Mandatory Sealed Drain-Plug & Closed-Lid Rules: Ensure that every roll-off dumpster has its bottom drain plug tightly sealed/capped and require crews to close dumpster lids or secure waterproof tarps over open-top dumpsters at the end of every work shift and prior to any forecasted rainstorm or high-wind event! An uncovered dumpster with an open bottom drain plug acts like a giant coffee filter during a rainstorm—percolating rainwater through trash to leach paint residue, drywall gypsum sulfate, and adhesives out the bottom drain hole directly onto pavement and into storm drains—while wind gusts lift buoyant styrofoam and plastic bags out of open bins into receiving streams.
• Waste Segregation & Disposal Prohibitions: Never mix liquid hazardous wastes, leftover solvents, liquid paint cans, petroleum containers, pesticides, or lead-acid batteries into general solid-waste dumpsters, and never burn or bury construction trash or demolition debris on site. Schedule regular dumpster haul-offs before bins reach rim capacity.

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Daily Good Housekeeping Inspection Workflow

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