A Debris Management Handbook for State and Local DOTs and Departments of Public Works (2014)

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75 Synopsis of Issue A major component of managing debris is the monitoring of debris. Monitoring ensures over- sight of health and safety concerns in the field, eligibility (i.e., general compliance with debris removal policies), tracking debris volumes, and successful overall debris operations (validating certifications, efficiencies, and documentation requirements). Effective monitoring helps mini- mize eligibility and reimbursement issues both during and after the debris removal operations. While PA eligibility may not be a priority, debris removal eligibility in compliance with the appropriate policies is paramount. All monitors should know and understand current policies for all removal operations, including all local, state, or federal regulations that govern the debris activities. Those responsible for debris management should understand the policies regarding the removal of the various types of debris likely to be encountered during operations: vegetative; C&D; hazardous waste; household hazardous waste; electronic waste; white goods; soil, mud, and sand; vehicles and vessels; putrescent debris; infectious waste; and chemical, biological, radiological, and nuclear (CBRN) contaminated debris. Target Audience • Debris removal monitors. • Debris managers. • Debris supervisors. • Solid waste personnel. • Debris removal personnel. • Debris removal contractors. What Is Debris Monitoring? Debris monitoring is a proactive means of observing the removal of event-generated debris in the field, ensuring that all debris is “eligible” according to current policies, and that operations are safe, efficient, and documented. Effective debris monitoring is necessary for normal supervision and oversight of the debris removal contractor’s activities, regardless of whether the work follows local, state, or federal regulations. Correct debris monitoring operations require comprehensive observation and documentation of work performed from the point of debris collection to final disposal, and involves constant oversight of crews to ensure that workers are performing debris removal in accordance with all applicable federal, state, and local regulations. Failure to prop- erly monitor debris removal operations may jeopardize a jurisdiction’s eligibility to claim federal C H A P T E R 1 0 Monitoring

76 A Debris Management Handbook for State and Local DOTs and Departments of Public Works reimbursement, if that option is available. Most importantly, debris operations that are sufficiently staffed with trained monitors generally have fewer issues with questionable debris operations. Types of Debris Monitors Debris monitors ensure that all applicable debris removal policies are followed by the removal contractors and other field personnel. Current debris management policies may be modified for each debris-generating event as deemed necessary by authorized individuals. Debris monitors are responsible for understanding current policies and regulations. Debris monitoring should be conducted at the loading, staging, and disposal sites of the oper- ations. While the same policies govern the work performed at all three locations, what the debris monitors accomplish at each is slightly different. Loading Site Monitors oversee removal operations at the debris loading site (i.e., right-of-way), ensuring that the debris is eligible according to current policies and that handled debris is not a health and safety concern for the carrying contractors. The loading site monitor’s primary responsibility is to ensure that only eligible debris is collected for processing. For a comprehensive list of field monitor duties, please see the job aids in the appendices of this handbook. At the loading site, monitors document each load of debris, usually using load tickets. The load ticket is one of the primary documentation items used during debris operations. It is essen- tial that these documents be filled out completely and accurately by the monitor and removal contractor. It is imperative to document both the amount of debris collected and the loading capacity of the vehicle hauling the debris (see Figure 10.1). Trucks carrying quantities below their full capacities will have their estimated haul volume adjusted down based on visual inspection by the debris monitor, who will verify the quantity and type of debris contained in the bed of the truck from an inspection tower. The most commonly used unit for measuring debris volume is CY, but occasionally, and in specific instances, measurements may be in tons. (When the mea- surement is in tons, a debris monitor is stationed at the scales used to weigh the loaded trucks.) Load tickets not only document the type and quantity of debris collected in each load, they also identify where the load site is located and where the debris was removed. An accurate record Figure 10.1. Trailer being measured by prime contractor and city monitor. (Source: FEMA)

Monitoring 77 of debris load locations is important because some eligibility restrictions are based on the loca- tion where the debris is originally collected. It is important to separate debris collection efforts from public property and private property, as some programs do not reimburse for any debris from private property deposited in the public right-of-way, and FEMA generally does not reim- burse contractors for removing debris on private property. The location of any staging area and final disposal site should also be documented. Perhaps one of the most critical pieces of information contained on the load ticket is the type of debris being hauled. Part of the debris monitor’s job is to help ensure that the various types of debris (e.g., vegetative, C&D, and hazardous waste) are not mixed, or hauled, in the same load. FEMA 327, Public Assistance Debris Monitoring Guide, contains an inclusive list of the types of debris likely to be handled, as previously discussed in Chapter 8. Staging and Disposal Site Debris monitors also participate in the estimating of debris quantities at the staging centers and final disposal centers. Staging centers are locations at which the debris is often segregated and stored temporarily until transport to the final disposal sites. Vegetative debris is often ground into mulch at the staging sites by the staging site contractor; however, debris segregation can occur at both locations. Debris monitors generally observe truck loads of debris from a “tower.” These towers are often makeshift towers consisting of a high-lift or constructed wooden structure, elevated in the air to view the contents of a truck bed (see Figures 10.2 through 10.6). Observing each load ensures that the trucks are accurately credited for the load hauled, and that the trucks are not artificially loaded (e.g., wetted or fluffed). Why Is Debris Monitoring Important? Debris monitoring is important for mainly two reasons: to prepare documentation on behalf of the debris monitor’s organization (load tickets), and to supervise the work of hired contrac- tors. The duties of a debris monitor are similar to construction inspecting, which ensures con- struction activities are done in accordance with contracts and plans. Figure 10.2. High-lift inspection tower. (Source: FEMA)

78 A Debris Management Handbook for State and Local DOTs and Departments of Public Works Figure 10.3. Wooden structure inspection tower. (Source: FEMA) Figure 10.4. Unsafe scissor lift inspection tower. (Source: FEMA) Figure 10.5. Acceptable tower monitoring station. Scissor lift with terrain tires. (Source: FEMA)

Monitoring 79 Accurate documentation of debris removal and disposal operations and eligible associ- ated costs is the outcome of a good debris monitoring program. This documentation serves as the basis for the grant applications that authorize reimbursements from federal agencies, if such reimbursement is being sought by the organization. The same documentation would be used to authorize payments to the debris contractors, even if reimbursement is not being sought. Failure to properly document eligible work and costs may jeopardize grant funding. Debris monitoring serves to document eligibility issues that may complicate the reimburse- ment phase. If the organization or jurisdiction has contracted for any component of the debris operation, debris monitoring is important to verify that the work completed is within the contract scope of work. Who Is Qualified to Be a Debris Monitor? Immediately after a disaster, monitoring activities are likely to be conducted by local agen- cies’ force account labor until monitoring contracts can be activated (if desired or necessary). If local resources are completely overwhelmed immediately after a disaster, the state may be able to provide some additional support on a short-term basis (e.g., state employees, National Guard) until other resources can be obtained. Supplemental resources might also be available through the Emergency Management Assistance Compact (EMAC). Personnel who serve as debris monitors need to be trained in the requirements of the vari- ous debris programs, as well as in how to measure and estimate debris volume. They should be familiar with the local debris management plan and have an understanding of the scopes of work for debris removal contractors. If contractors are used for long-term monitoring assignments, having pre-event debris monitoring contracts in place can expedite deployment to the field and ensure complete documentation of removal operations. Depending on the organization or jurisdiction’s needs and preferences for long-term monitoring, the debris management operation can be staffed using force account labor and/ or contracted labor. Contracting should follow applicable procurement requirements such as the Stafford Act, legislation that established guidelines for the government’s response to Figure 10.6. Inspection tower at landfill. Debris monitors on site, making capacity calls. (Source: FEMA)

80 A Debris Management Handbook for State and Local DOTs and Departments of Public Works disasters. The following key features can help the applicant choose which option is more beneficial to them: 1. Contracted Labor: • Contractor assumes all training requirements. • Employees serving in a force account labor capacity can resume normal daily functions. • Regular and overtime labor hours are reimbursable. 2. Force Account Labor: • Employees serving in a force account labor capacity are more familiar with neighboring conditions. • After the necessary training, force account labor will be better prepared for future events. • Trained construction inspectors are ideal for this assignment, making the process a bit smoother because of their experience in such work. • Force account labor hours spent performing disaster-related work should always be tracked separately from labor hours spent doing other work in case federal grant programs permit reimbursement for disaster-related work performed by force account labor. 3. Staff Augmentation/Local Hire: • Jurisdictions and other organizations need to have a just-in-time training program set up for training monitors. The program should include a handbook that each monitor can use as a reference. • A strong supervisor presence is required for this particular labor (supervisor needs to be a force account person). Regardless of the source of debris monitors, the importance of their task must be explained before their deployment. Procedures must be explained and understood, and the monitors should have a contact number to call for explanations, answers to questions, and to report issues. How Is Debris Monitoring Accomplished? Establishing a thoroughly researched and well-developed debris management plan builds the framework for organized, efficient debris monitoring operations. The debris management plan usually identifies debris operation zones, estimated quantities of debris to be generated by a design event, or events, and DMSs. This information can be used to evaluate the approximate number of monitors that are required for each zone during a prescribed event. Identifying the number of monitors that could be needed allows a jurisdiction to train its employees and/or contract for monitors in advance, so that when an event occurs, operations can begin immediately. After a debris-generating disaster occurs and debris estimates are developed or refined, the number of monitors that are required for each operational area and site can be determined. Based on the number of required personnel, the jurisdiction can determine if monitoring can be accomplished using in-house resources, contractor personnel, or a combination of both. Person- nel can be identified and assigned to roles and operational areas. Several different types of monitors are assigned to the debris operation, including load site monitors, roving monitors, tower monitors, and field supervisors. Load site monitors observe and document debris removal at the pickup points to ensure compliance with program and con- tract specifications. They may be assigned to monitor debris removal operations at more than one load point, depending on the provisions of the debris operations plan. Roving monitors can be used in addition to or in lieu of load site monitors, depending on the need. Roving monitors help with contract management by ensuring that the debris management plan, contract, and safety requirements are being met. If they observe non-compliant actions, they should report them to the appropriate manager, either the field manager or the debris manager, depending on

Monitoring 81 the provisions of the debris management plan. Tower monitors observe and record debris types and volumes as they enter debris management or disposal sites. They also observe unloading at the site to ensure that debris is deposited in the correct location(s) within the site. Field super- visors review and update the operational plan and coordinate scheduling of load site and tower monitors to ensure a sufficient number of personnel are monitoring the removal operations. They also coordinate with federal and state agency personnel, compile and submit daily reports on progress, and help resolve issues that arise in the field. Sometimes, debris removal contractors will set up a private agreement with homeowners to remove their debris. If this is the case, the debris monitor must ensure that this debris is not moved to the right-of-way or curbside for debris removal. The debris removed by the contrac- tor through a private agreement with the homeowner must be directly taken to the municipal landfill, and in most instances, the contractor should use trucks specifically for contract opera- tions, with the origin of the load clearly marked on the load ticket for the disposal site. In some instances, contractors have used separately marked trucks to haul debris for private homeown- ers. A debris management plan should incorporate a requirement that trucks hauling debris under a private agreement must have such vehicles clearly marked with appropriate signage. Example: After Hurricane Ivan, the debris removal contractors in Pensacola, FL, were allowed to enter private property to remove hazardous leaning trees and stumps. Debris monitors first accom- panied the local debris manager to obtain signed waivers from homeowners acknowledging their approval for contractors to remove stumps and hazardous trees from the homeowner’s property. The monitor and debris manager together identified, measured, and marked the eligible trees for contractors to remove. Recommended Tools for Debris Removal Operations FEMA 325, Debris Management Guide (25) suggests the use of all three of the following tools to document debris removal operations. While these tools historically have been paper copies with duplicates, electronic tools have been created and may be available to expedite data management. Sample debris monitoring tools can also be found in Appendix H. 1. Debris Monitor Reports As emphasized throughout this guide, documentation is the most important aspect of debris monitoring. Preparing a debris monitoring report will provide consistency to all records, regardless of who performs the work or from which grant program reimbursement is sought. Jurisdictions or organizations conducting debris removal operations are encouraged to develop, and have available, a debris monitoring report format that captures the required information when seeking reimbursement, including: • Location(s) of debris pickup and disposal, • Actual labor hours worked, • Actual equipment hours operated, and • Type and specification of equipment used. Reports that can be completed electronically in a spreadsheet or database format can be used to easily tabulate data for reimbursement requests. 2. Truck Certification List A truck certification list provides a standardized manner of identifying trucks in use and their hauling capacities. This information is important since debris, specifically vegetative debris, is often hauled and billed by volume. A comprehensive truck certification list should include: • Size of hauling bed in CY; • License plate number;

82 A Debris Management Handbook for State and Local DOTs and Departments of Public Works • Truck identification number assigned by the owner; • Short physical description of the truck; and • A number painted on each truck of a size easily read by debris monitors. This can be the same as the truck identification assigned by the owner; however, it must be painted on the truck. A computerized bar code system can be used to associate identifying information with a bar code assigned to each truck. The codes are scanned as the truck enters and leaves the DMS or landfill. 3. Load Ticket System A load ticket serves as the primary debris tracking document and is used to document the volume of debris in each truck and the hauling distance per trip. If the managing organiza- tion or jurisdiction uses a contract hauler, the load ticket is often used for billing purposes. Traditionally, load tickets have been carbon paper tickets with at least four identical copies generated for one load of debris. More advanced, electronic tracking tools for use with cell phones, tablets, and laptop computers have been developed and used in the field to reduce human error and facilitate data gathering and management. FEMA PA Publication 325 says the following about the preferred load ticket system: Historically, debris monitoring operations have used the four-part paper load ticket system. Depending on the size of the event, the manual process of filling out load tickets, transferring copies, and entering data for reporting and data compilation purposes can be very labor and time intensive, and can result in significant levels of human error. Recent advances in auto- mated debris management tracking systems have provided real-time and automated tracking and reporting. Electronic load tickets, computer tablets, and systems employing electronic contractor ID cards allow for instant data tracking, verification, and reporting. Some systems also incorporate truck tracking systems, GPS capability, and enhanced analytical capabilities of debris monitoring data. Other technologies are in development and testing to improve the accuracy of developing debris load estimates. Applicants should review the alternative procedures available, and make sure that all individuals involved in the debris operations are familiar with the process. In particu- lar, the monitors must be well-trained and knowledgeable to minimize any errors and downtime. Debris Monitor Job Aids Debris monitoring requires individuals who are trained in debris operations to observe and document the actions taken to remove disaster-generated debris from eligible areas. In general, there are three overarching functions or roles of debris monitors: field monitoring/roving monitors, site/tower monitoring, and field supervisor. The section below includes a job aid for the three types of monitors. Regardless of the monitor’s role, each individual should bring the following items with them into the field: • Hard hat, • Reflective vest, • Safety glasses, • Hearing protection, • Cell phone (fully charged), • Digital camera/video, • Protective shoes, • Long pants, • Hot, cold, and/or wet weather gear, and • Sunscreen and supply of bottled water.

Monitoring 83 Summary of Duties (FEMA 325) (25) Field Monitors/Roving Monitors: Monitor collecon acvies at load sites: Measure and cerfy (and recerfy) truck capacies, which include: • Valid driver’s license of truck operator. • Valid truck registraon and insurance. • Volumetric capacity of the inside of the loading container. • Calculated deducons of volumetric capacity for dog boxes, round container booms, and other volumetric capacity reducons. • Brief physical descripon of the truck. • Photographs of the truck, container, and driver. Ensure that debris is segregated at the curbside. Vegetave must be separate from C&D. Ensure that hazardous waste is not mixed in with other waste types. Ensure that only eligible debris (according to current policy) is being loaded into the truck; raise quesons/issues with a supervisor if it appears that debris outside the contract scope of work is being loaded. Ensure that trucks are not arficially loaded (e.g., weed or fluffed). Observe methods for loading trucks (e.g., mechanical vs. hand loading). Record equipment used for loading and mes of use. Check the area for safety consideraons (e.g., downed power lines, traffic control needs). Check areas in and around debris piles to idenfy buried items such as fire hydrants and mailboxes, and help prevent damage from loading equipment. Record and report any damages caused to streets, curbs, ulity meters, mailboxes, and other public property as a result of debris removal operaons. Validate hazardous trees, including leaners, hangers, and stumps. Reference current policy with regards to hanger and stump measurements. Record the following: • Date, • GPS locaon, • Physical address, and • Time that the work was performed. Issue field load ckets, documenng: • Debris classificaon, • Debris load call/volume esmaon, • Truck unloading me and date, and • Photographs of loads before and a“er unloading. Verify loads are properly contained before leaving the loading area (e.g., tailgates are secured, loads are covered if required). Ensure compliance with contract scope of work. Report to supervisor if work is not accomplished in accordance with local, state, and federal ordinances and regulaons. Ensure work area is clear of debris as specified in the contract before moving to a new loading area. Maintain a log of the number of load ckets issued during the shi“, the starng and ending load cket numbers, problems encountered, and locaons where debris was to be delivered. Ensure that any numbered load ckets that contained an error that was detected is clearly explained. (continued on next page)

84 A Debris Management Handbook for State and Local DOTs and Departments of Public Works Field Monitors/Roving Monitors: Monitor collecon acvies within debris zones: Ensure that only eligible debris is being picked up. Ensure that debris from private property has been moved to the curbside by the property owner and not a removal contractor. Obtain a wri
en consent form with a wet signature by the property owner before stepping onto private property and/or removing debris from private property. Support recorded observaons with digital photography. Make mulple visits to each load site daily. Report any malpracce to field supervisor IMMEDIATELY. Site/Tower Monitors: Complete load ckets at debris management and/or disposal sites. Esmate the volumes of debris that have been transported. Ensure that trucks are fully offloaded before leaving the debris management/disposal site. Maintain a log containing the truck numbers and volume of debris hauled, total amount of debris delivered during the shi†, and problems encountered. Field Supervisors: Manage the debris monitoring operaon. Schedule and deploy debris monitors to the necessary sites. Oversee daily acvies of debris monitors. Have thorough understanding of the reimbursement program. Resolve field eligibility and safety issues, and communicate these issues to the applicant. Collect daily logs from the debris monitors and tabulate truck load data for the daily report.