2013 Ag Burn Permit

Here’s the pdf of the HC&S Agricultural Burn Permit

2013 Permit 01

Page 1

Subject to Hawaii Revised Statutes (HRS), Chapter 342B; Hawaii Administrative Rules (HAR), Chapter 11-60.1; and all the following conditions unless modified or replaced by any attached special conditions:

1. Permittee shall notify the Maui Police Central Dispatch at (808) 244-6400 and the fire station nearest to your bum location at least one hour prior to each burn.

2. BURNING IS NOT allowed during a “no-burn” period declared by the Department of Health (DOH) under §11-60.1-55, HAR.

3. Permittee shall provide an adequate water source to the bum location which will prevent the Hre from spreading to areas adjacent to burn location.

4. An inspection shall be conducted on all accessible areas of each Field prior to burning. Any batteries, abandoned vehicles, wastes handled or processed by sugar factory operations, tires, petroleum wastes, appliances, furniture, logs greater than 4″ in diameter, hazardous wastes, 55 gallon drums and other similar items which may have been deposited in the burn area and identified by the inspection shall be removed prior to any bum. Burning of agricultural wastes that are not generated from the burn location is prohibited. In the pre-burn checklist document that the inspection was conducted prior to burning of the field.

5. Fire shall be attended or supervised by an adult in accordance with Exhibit 1 (HC&S Bum Procedures) which is attached hereto and incorporated herein.

6. The following fields, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with Exhibit 1 (HC&S Burn Procedures): 105, 107, 109, 112, 113, 116, 117, 118, 202, 204, 208, 209, 210, 211, 212, 213, 214, 300, 302, 305, 306, 307, 309, 314, 401, 402, 403, 404, 405, 408, 409, 410, 411, 412, 413, 414, 416, 418, 500, 501, 505, 506, 508, 509, 510, 511, 512, 602, 605, 609, 611, 700, 701, 702, 706, 707, 709, 710, 711, 712, 714, 715, 716, 717, 718, 719, 737, 741, 743, 745, 747, 749, 751, 753, 757, 761, 763, 765, 767, 802, 803, 806, 807, 808, 813, 815, 819, 821, 823, 902, 903, 904, 905, 906, 907, 908, 909, 910, 911, 912, 913, 914, 915, 918, 919, 921, and 922; which are attached hereto and incorporated herein.

7. The following fields, which are nearest to roadways and Kahului airport, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with Exhibit 2: 105, 107, 113, 204, 208, 210, 211, 212, 300, 306, 401, 404, 405, 413, 500, 501, 505, 506, 508, 509, 511, 602, 605, 609, 611, 700, 701, 702, 706, 707, 709, 710, 711, 712, 714, 715, 716, 717, 718, 719, 737, 741, 743, 745, 747, 749, 751, 753, 757, 761, 763, 765, 767, 902, 906, 908, 911, 912, 913, 914, 915, and 919; which are attached hereto and incorporated herein.

8. The following fields, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with Exhibit 3; 109, 112, 116, 117, 118, 202, 209, 213, 214, 302, 305, 307, 309, 314, 402, 403, 408, 409, 410, 411, 412, 414, 416, 418, 510, 512, 802, 803, 806, 807, 808, 813, 815, 819, 821, 823, 903, 904, 905, 907, 909, 910, 918, 921, and 922; which are attached hereto and incorporated herein.

9. The following fields, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with the schedule below:
Peak traffic hours are 7:00 a.m. — 8:30 a.m. and 3:30 p.m. — 5:00 p.m. All flames must be extinguished by the end of the burn period.


 

Page 2

a. The following Fields may be burned between the hours of 3:00 a.m. and 6:00 a.m.: 605, 609, 709, 710, 711, 712, 714, and 715.

b. The following field may be burned between the hours of 4:O0 a.m. and 6:00 a.m.: 413.

c. The following field may be burned in the summer months (June, and July) between the hours of 4:00 a.m. and 6:00 p.m., excluding peak traffic hours and in all the other months
between 4:00 a.m. and 6:00 a.m.: 204.

d. The following fields may be burned between the hours of4:00 a.m. and 6:00 p.m.: 813, 815, 819, 909, and 910.

e. The following Fields may be burned between the hours of4:00 a.m. and 6:00 p.m., excluding peak traffic hours: 105, 107, 208, 212, 300, 306, 401, 404, 405, 410, 500, 501, 505, 506, 508, 509, 511, 602, 611, 700, 701, 702, 706, 707, 716, 717, 718, 719, 737, 741, 743, 745, 747, 749, 751, 753, 757, 761, 763, 765, 767, 902, 908, 911, 912, 913, 914, 915, and 919.

f. The following Field may be burned under trade wind conditions between the hours of 4:00 a.m. and 10:00 a.m., excluding peak traffic hours and under Kona wind conditions between the hours of 8:30 a.m. and 3:30 p.m.: 906.

g. The following Fields may be burned between the hours of 6:00 a.m. and 6:00 p.m., excluding peak traffic hours: 210, 211.

h. The following field may be burned between the hours of 6:00 a.m. and 6:00 p.m., excluding peak traffic hours, except during Makawao Union Church services or Sundays: 113.

i. All other Fields, as indicated in the 2013 Harvesting Schedule, map submitted by the permittee, or listed in condition #6, shall be burned between 6:00 a.m. and 6:00 p.m.
10. Only controllable amounts shall be burned and under conditions that will minimize visible ground level smoke from entering any residence, business, or public area. With the exception of smoke impacts to roadways and/or the Kahului airport resulting from the burning of Fields listed under Condition 7 in accordance with Exhibit 2, ifa burn has begun and visible ground level smoke enters any residence, business, or public area, permittee shall not burn additional Fields that day which would affect such impacted areas until meteorological conditions improve. If a decision is made to conduct additional burning under this provision, permittee shall notify DOH by telephone prior to the day’s next burn and shall document the justification for conducting additional burns on a Burn Justification Log. This documentation shall include the location of the original burn and of residences, businesses, or public areas that were impacted by visible ground level smoke, the planned location of any subsequent burns that day, a description of any problems encountered during the original burn which may have contributed to visible ground level smoke in a residence, business, or public area and any corrective actions implemented to address them, any changes in meteorological or Field conditions since the initial burn, and identification of downwind areas most likely to be impacted by the next burn.

11. Visible ground level smoke entering any residence, business, or public areas, with the exception of smoke impacts to roadways and/or the Kahului airport resulting from the burning of fields listed under Condition 7 in accordance with Exhibit 2, or smoke impacts from fires not caused by the permittee (e.g., malicious fires, brush fires), shall not exceed a Public Impact Code of 3, as described in Exhibit 1. After completion of the burn, smoldering piles shall be promptly addressed in compliance with Exhibit 1.

12. Permittee shall submit a written report to DOH within five (5) working days after any deviation from the permit requirements, including the procedures specified in Exhibits 1, 2 and 3 and accompanying attachments. The report shall identify the probable cause of the deviation and any corrective actions or preventive measures taken.

13. Permittee shall monitor all burns and maintain a record of the meteorological conditions and plume behavior throughout each burn. To the extent practical, photos shall be taken of the plume behavior. A copy of each Pre—Burn Checklist, Exhibit 2/Exhibit 3 Checklist, Burn Monitor Log and the Daily Weather and Dispersion Forecast shall be submitted to the DOH, either in hard copy or electronically, within seven (7) days after Friday of each week or upon request.

14. All records, including support information, shall be true, accurate, and maintained in a permanent form suitable for inspection, retained for a minimum of three (3) years following the date of such records, and made available to the DOH or its representatives upon request.

15. Permittee shall keep a copy of this permit at the burn site during the burn and shall make it available for inspection upon request.

16. For the purpose of determining compliance with this permit, the DOH or its duly authorized representatives shall be granted access to the property at reasonable times, pursuant to HRS,

§342B—41, Inspection of Premises. The DOH shall not be denied access to burn sites.
The DOH reserves the right to terminate, suspend, reopen, or amend this permit, subject to HAR $11-60.1-57 (e). Violation of any condition of this permit, any section of Chapter
342b, HRS, or any section of Chapter 11-60.1 HAR, may result in fines no greater than $10,000.00 or each day of each violation, pursuant to §342b-47(b), HRS. In addition, a
violation may be reason for amendment, suspension, or revocation of this permit.


HC&S Fields via USDA
HC&S Fields via USDA (May be out of date)

 

Page 3

Hawaiian Commercial & Sugar Company
2013 Agricultural Burning Permit – Exhibit 1


This exhibit describes general procedures to be followed for pre—harvest burning of sugarcane in order to minimize public exposure to visible smoke impacts. Included are procedures to be followed prior to, during, and after each burn. The Harvesting Manager (or his designated alternate) shall ensure that all fields are burned in accordance with these procedures. Additional requirements are specified for individual fields in Exhibits 2 and 3 and these requirements shall also be followed.

A. Actions to be taken prior to burning:

(l) Assessment of field location and actions for sensitive downwind areas — Prior to burning any field, the Harvesting Manager shall review the location of the field with respect to certain sensitive areas to determine the types of public notifications necessary and any
restrictions on when the field can be burned.

(a) Public Notification Procedures
Public notifications specified for each burn are listed in the attached Cane Burn
Notification listing (Attachment la) and are described below.

• Written Notices: For those fields for which written notices are specified in Attachment
la, attempts will be made to deliver flyers to residential premises, schools, churches,
and other facilities. By law mailboxes cannot be used for this purpose, and some
residences may not be accessible (e. g., due to dogs, locked gates, etc.) or may have no
other provisions for receiving written notices; therefore, reasonable efforts will be made
to leave written notices where they are likely to be seen by occupants of the premises.
Where multiple dwellings may be present on a single residential property, the
notification attempt will be made to the dwelling most readily accessible from the
street. Where a particular residential area is specified in the “Written Notice” column
of Attachment la, HC&S shall make reasonable efforts to ensure that all residential
premises in the specified area receive written burn notifications. Where the words
“Adjacent Residents” appear in the “Written Notice” column, HC&S shall make
reasonable efforts to deliver notices only to those homes immediately adjacent to the
field. A sample flyer is included as Attachment lb.

• Telephone Notifications: Telephone notifications will be attempted at least two hours
prior to scheduled burns for those individuals who have specifically requested such
notifications. A call list is maintained for these individuals and is updated as new
requests are received. Reasonable attempts at phone notifications will be made;
notifications may be precluded when no one answers the phone, there is no answering
machine or voice mail, the number is out of service, or in similar circumstances.

• Road Signs and Guards: For fields adjacent to roads and highways, signs and/or traffic
guards shall be posted as indicated in the Cane Burn Notification listing to alert
approaching motorists.


 

Page 4

• Police and Fire: The Maui Police Department Central Dispatch and the nearest fire
station shall be notified prior to each burn as specified in the Agricultural Burning Permit. Notifications shall be made at least one hour prior to burning.

(b) Restrictions on Burning — Schools and Churches
Fields which are upwind of abutting schools shall not be burned while school is in
session. Burns will be scheduled so that they are completed at least one hour prior to
the start of school or else will be conducted after school hours. The Harvesting
Manager shall maintain and make available to the Department of Health a list of all
known schools located adjacent to HC&S fields (Attachment 1c) and their normal hours
of operation, including any summer school_and after school programs. If necessary,
permission will be requested from the Department of Health to burn such adjacent
fields after 1800 in order to prevent any smoke impacts. Fields upwind of adjacent
churches shall not be burned during scheduled services. As noted above, notification to
the person responsible for these facilities will be attempted two days prior to scheduled
burns.

(c) Restrictions on Burning — Public Roadways
The following public roadways may be impacted by smoke during burning and are
considered potentially hazardous roadways:
Hana Highway
Haleakala Highway
Mokulele Highway/Puunene Avenue
Pulehu Road
North Kihei Road
Haliimaile Road
Baldwin Avenue
Kuihelani Highway/Dairy Road
Honoapiilani Highway
Fields adjacent to these roadways shall not be burned during peak traffic periods (0700-
0830 and 1530-1700) unless otherwise authorized in the permit. In order to minimize
traffic impacts and potentially hazardous conditions, HC&S will request approval from
the Department of Health to burn most fields adjacent to these roadways between the
hours of 0400 to 0600. As noted above, signs will be posted and/or roadways may be
manned by traffic control guards (private security or off-duty police officers) for these
fields. The Police Department shall be notified prior to burns that may impact traffic on
roads and highways.

(d) Restrictions on Burning – Public Recreation Areas
There shall be no burning of fields directly upwind from adjacent public recreation
areas on Sundays. For the purposes of this exhibit, “adjacent” means adjoining the field
being burned. To the extent practicable when reasonable advance notification has been
provided, efforts shall be made to adjust the harvesting schedule in order to further
reduce the potential for smoke to impact planned and organized public activities (e. g.,


Page 5

fairs, carnivals, charity walks, athletic events, etc.) in downwind areas adjacent to fields
scheduled for burning.

(e) Restrictions on Burning – Airport
In order to minimize impacts on airport operations, HC&S will request approval from
the Department of Health to burn fields adjacent to the airport or located in the airport
approach path between the hours of 0300 to 0600. The airport control tower shall be
notified by telephone prior to burns in the vicinity of the airport as noted in the Cane
Burn Notification listing.

(f) Exhibit 2 and Exhibit 3 Burn Conditions
All burns shall be conducted in accordance with the conditions and limitations specified
in Exhibit 2 or Exhibit 3, as applicable.

(2) “No Burn” declarations — Upon issuing a “no burn” declaration, the Department of Health representative will notify the HC&S Harvesting Manager (or his designated alternate) via cellular telephone. Prior to burning, the Harvesting Supervisor in charge of the burn shall contact the Harvesting Manager (or his designated alternate) to determine whether the Department of Health has declared a “no burn” period. Burning shall not be conducted during any “no burn” period declared by the Department of Health.

(3) Red Flag Warnings – A Red Flag Warning is an advisory from the National Weather
Service intended to inform fire fighting and land management agencies when weather
conditions may pose an increased risk of wildfire ignition and propagation. A Red Flag
Warning is advisory in nature, not regulatory. However, local fire agencies may, at their
discretion, impose a ban on outdoor burning when warranted by local conditions. Upon
receipt of any notice from the Maui Fire Department (MFD) that a ban on outdoor burning
is in effect on Maui, the Harvesting Manager shall ensure that burning does not occur in the areas covered by the ban until MFD advises that the ban has been lifted.

(4) Assessment of meteorological conditions — Prior to burning, the Harvesting Manager shall review available meteorological data, including wind speed and direction, to determine likely smoke plume behavior and whether conditions are suitable for burning. Burning shall only be conducted under conditions that will minimize ground level visible smoke from entering residences, businesses, or other areas to which the public has unrestricted access. The following sources of data shall be considered:

• Western Weather Group (WWG) smoke management weather and dispersion
forecast (obtained daily through computer link)

• Existing weather conditions from HC&S weather stations, especially those
nearest to the burn location

• Wind data from field measurements at the burn site

• Rainfall data from the area of the field to be burned

• Records and experience from past burns indicating historical weather data and
corresponding smoke plume behavior

• National Weather Service forecast


Page 6

(5) Assessment of predicted dispersion in area of field being burned – The WWG daily weather and dispersion forecast shall include predicted conditions for smoke dispersion at the scheduled burn time and for later in the day in the area of each field planned to be burned on that day. When smoke dispersion for a particular field is predicted to be “poor” at the scheduled burn time, that field shall not be burned on the day covered by the forecast except that burning may be considered later in the day if the forecast predicts that dispersion for that field will improve to “fair” or better. Dispersion conditions predicted for a particular field shall only affect burn decisions made for that field, and will not
necessarily preclude burning in other fields.

(6) Assessment of temperature inversions – The WWG daily weather and dispersion forecast shall include the predicted likelihood of a morning temperature inversion in the area of each field planned to be burned on that day. When a “moderate” or “strong” morning inversion is predicted in the area of a particular field, that field shall not be burned until after the inversion is predicted to break (typically around mid-morning). Inversion conditions predicted for a particular field shall only affect burn decisions made for that field, and will not necessarily preclude burning in other fields elsewhere on the plantation.

(7) Assessment of rainfall – The WWG daily weather and dispersion forecast shall include
information regarding rainfall measured within the previous 24 hours at the weather station
nearest to each field scheduled to be burned. Additionally, manual rain gages may be sited in or near fields scheduled to be burned. When rainfall over the previous 24 hours recorded in or nearest to a field is 0.1 inches or more, that field shall not be burned until the vegetative mat in the field has been checked for moisture to confirm that the field is dry enough to burn.

(8) Assessment of vog – The WWG daily weather and dispersion forecast shall include
predictions for vog to impact air quality on Maui based on data from the University of
Hawaii Vog Measurement and Prediction Project (VMAPP) website. When the VMAPP
tables of model predicted values indicate that sulfur dioxide and/or sulfate aerosol
concentrations in Kihei will result in “moderate” (indicated by a rating of “yellow” on the
WWG forecast) or “unhealthy” (indicated by a rating of “red” on the WWG forecast) air
quality on the day covered by the forecast, burning shall not be conducted. A rating of
“green” on the WWG forecast indicates that air quality is predicted to remain in the “good”
range despite any potential vog impacts, and burning in compliance with other applicable
permit requirements is therefore permissible. If the VMAPP website is not functioning or
the table of model predicted values is not posted, has not been updated, or is clearly
erroneous at the time that the WWG daily forecast is prepared, then the forecaster shall
indicate “NA” (not available) for vog data. In that event, this assessment of vog shall not
be required for that day’s burns.
The VMAPP website is maintained by the University of Hawaii and HC&S has no control
over the continued availability of data on this site. In the event that maintenance of the
VMAPP website is discontinued, or the information available on the VMAPP website is


Page 7

significantly changed or the format modified such that compliance with this provision is not
feasible, then compliance with this provision of Exhibit 1 shall no longer be required as
part of the pre—burn assessment. HC&S shall retain the flexibility to evaluate whether a
new or modified vog forecasting tool is sufficiently reliable and suitable for incorporation
into its pre-burn assessment procedures.

(9) Assessment of existing air quality – Within one hour prior to each burn, the Harvesting
Manager shall check the current Air Quality Index (AQI) for the Department of Health’s
Kihei air monitoring station posted on the Department of Health’s Hawaii Ambient Air
Quality Data (HAAQD) website (go to http://emclweb.doh.hawaii.gov/air—guality/ and click on “Air Monitoring Sites” and then “Maps”).

• If the AQI at the Kihei air monitoring station is in the “good” range (indicating air
quality meets state and federal standards), burning may be conducted as normal in
compliance with all other applicable permit requirements.

• If the AQI at the Kihei air monitoring station is within the “moderate” range (indicating
air quality meets state and federal standards), then additional caution shall be exercised
to avoid burning under marginal conditions which could result in further degradation of
the AQI (i.e., into the “unhealthy” range). The Harvesting Manager shall evaluate
whether predicted conditions for dispersion and other meteorological conditions
warrant calling a voluntary “no burn”. Burning when the AQI is in the “moderate”
range shall be conducted in compliance with all other applicable permit requirements.

• If the AQI at the Kihei air monitoring station falls within any “unhealthy” range, no
burning shall be conducted until air quality improves and the AQI is again within the
“good” or “moderate” range.

• If the HAAQD website is not functioning, or the current AQI for the Kihei station is not
posted or is clearly erroneous at the time that the website is checked, then no
assessment of the AQI shall be required in order for the burn to proceed.
The HAAQD website and the Kihei air quality monitoring station are maintained by a
government agency and HC&S has no control over the continued availability of the data
they provide. In the event that operation of the HAAQD website or the Kihei air quality
monitoring station is discontinued, or the information available from these sources is
significantly changed or the format modified such that compliance with this provision is not
feasible, then compliance with this provision of Exhibit 1 shall no longer be required as
part of the pre-burn assessment. HC&S shall retain the flexibility to evaluate whether a
new or modified air quality forecasting tool is sufficiently reliable and suitable for
incorporation into its pre—burn assessment procedures.

(10) Inspection and removal of unauthorized materials – An inspection shall be conducted of all accessible areas of each field prior to burning. Any batteries, abandoned vehicles, factory wastes, tires, petroleum products, appliances, furniture, hazardous wastes, 55-gallon drums, or other similar items which may have been deposited in the burn area and which are identified during the inspection shall be removed from the burn area prior to any burn. Any logs greater than four inches in diameter which may have been deposited in the burn area and which are identified during the inspection, with the exception of those from any plants


Page 8

found growing in the field, shall be removed from the burn area prior to any burn.
Inspections will normally be conducted during cutting of firebreaks within one day of the
scheduled burn.

(11) Protection of irrigation system infrastructure – Drip irrigation systems are installed in each field, consisting of buried PVC irrigation mainlines and above-ground irrigation system risers in valve lines located along field edges, subsurface polyethylene drip tubing used to apply water to the crop, and polyethylene oval hose used to supply water from the risers to the drip tubing at the field edges. Permanently installed PVC piping is expensive and time-consuming to replace, so extensive efforts are made to protect these irrigation system components from damage during harvesting. Prior to each burn, action shall be taken as follows to minimize the potential for accidental damage or burning of irrigation
infrastructure:

• Except at field edges where it connects to the remainder of the irrigation system, the
majority of drip irrigation tubing is buried during installation and is thereby protected
from burning.

• Once irrigation of the field has been halted in preparation for harvest, oval tubing
located at the field edges shall be disconnected and pulled from the field prior to the
field being burned.

• During preparation for burning, sugarcane at the field edges shall be pushed into the
fields, away from the irrigation riser line, to create a “fire line” in order to prevent
damage to or destruction of the irrigation risers when the field is burned. “Fire line”
cane may also be hauled out of the field rather than pushed into the field, or the field
edge may be “notched” (i.e., cane pushed or hauled out only in the area around each
riser) to protect the irrigation risers. Alternate means of protecting the risers may be
developed and employed, provided that they are equally effective at preventing the
risers from burning.

B. Actions to be taken during the burn:
(1) Monitoring and recordkeeping – The Harvesting Manager shall designate an individual to monitor each burn and document meteorological conditions and plume behavior, including any visible smoke impacts on public areas. The Burn Monitor shall continue to monitor the burn and record observations for a minimum of one hour from the start of the burn and until all visible smoke has passed overhead beyond public areas or out to sea and any ground level visible smoke impacts to public areas have dissipated. If necessary, the Burn Monitor shall follow the smoke plume to determine the extent of any ground level visible smoke impacts in public areas. In addition to recording observations of the burn, the Burn Monitor shall take a photograph during each observation, when practicable (for example, photos shall not be required when precluded by darkness).

(a) Burn Monitor Log – The Burn Monitor shall record the following information on the
Burn Monitor Log (Attachment le) for each burn:

• The number of the field to be burned and the number of acres burned


Page 9

• The date and time the burn was started and the wind speed and direction at the
burn site at the start of the burn

• The smoke pattern exhibited by the plume throughout the burn; a listing of
smoke pattern codes is included as Attachment lf

• Any significant shifts in wind speed and direction which occur during the burn

• A description of any observed visible smoke impacts in public areas, including
a Public Impact Code from “0” (no evidence of smoke in the area) to “7” (very
heavy smoke); a listing of smoke pattern codes is included as Attachment lf

• The date and time the burn was completed (i.e., date and time when all flames
have been extinguished)

• The time that the photograph of each observation was taken (all photographs
shall be appended to the Burn Monitor Log).

(b) Maui Vortex – The WWG forecast includes a prediction of whether formation of a
characteristic circulating wind pattern near the southern edge of the plantation, called
the “Maui vortex”, is likely to occur. The Maui vortex can impact downwind
dispersion of smoke from the burn. When formation of the Maui vortex is predicted
and meteorological conditions during the burn include slow or stagnant winds,
reasonable efforts shall be made to monitor wind conditions in the vicinity of the vortex
after completion of the burn for indications of vortex formation. Monitoring of wind
conditions shall include observing wind data from the Kihei, Field 415, and Kula Ag
Park stations. The Burn Monitor shall resume monitoring for ground level smoke
impacts if such impacts are anticipated to result from vortex formation.

(c) Special Burn Monitoring — At its sole discretion, HC&S may choose to conduct special burn monitoring beyond what is specifically required by this Exhibit, using additional personnel besides the designated Burn Monitor, in order to better document conditions during and after the burn. Such monitoring will typically be conducted during burns upwind of especially sensitive areas or to attempt to substantiate complaints from a
particular area. When conducted, such special monitoring may be recorded at the end
of the Burn Monitor Log for the subject burn. Documentation of special burn
monitoring should include the location(s) of the special monitor(s), the period of time
during which the monitor was at each location, a description of any smoke impacts
observed by the monitor(s), and other relevant information.

(2) Suspension of burns due to smoke impacts – In the event that any ground level visible
smoke is observed entering any residence, business, or public area (conditions
corresponding to a public nuisance code of “2” or greater) during or after a burn, the Burn
Monitor shall immediately notify the Harvesting Manager or the Harvesting Supervisor in
charge of the burn. The Harvesting Manager or Supervisor shall ensure that no additional
burns are conducted that day which would impact the affected area until meteorological
conditions improve. (Note: This requirement shall not apply to fields burned in
accordance with Exhibit 2 where ground level smoke impacts are limited to public roads or the airport.)


Page 10

(3) Resumption of burning after visible smoke impacts – When visible smoke impacts to
public areas warrant that no additional burns should be conducted which would impact the
affected area until meteorological conditions improve (per Section B.(2) above), additional
burns may be conducted on the same day only after all of the following conditions have
been met:

(a) Smoke impacts to public areas from the earlier burn (other than smoke impacts to
public roads and/or the airport from burning an Exhibit 2 field) did not exceed a Public
Impact Code of three (3). [ note: Code 3 = “Visible smoke with some visual impairment Visibility greater than 500 feet“]

(b) The Harvesting Manager has determined that conditions under which any subsequent
burns would be conducted are unlikely to result in visible smoke impacts to the same
public area(s) affected by the earlier burn. (Note: This requirement shall not apply to
smoke impacts to public roads and/or the airport from burning an Exhibit 2 field.)

(c) The Harvesting Manager has documented the determination required under Section
B.(3)(b) above on a Burn Justification Log (Attachment lg). Documentation shall
include:

• The time and location of the original burn;

• Identification of any public areas that were impacted by ground level visible smoke
as a result of the burn and a description of the smoke impacts (e. g., duration, Public
Impact Code);

• The planned location of any subsequent burns to be conducted on the same day;

• A description of any problems encountered during the initial burn which may have
contributed to ground level smoke in public areas;

• Corrective actions or preventative measures implemented to address problems
identified during the initial burn;

• Any changes in meteorological or field conditions since the initial burn that are
expected to improve smoke dispersion; and

• Identification of downwind areas most likely to be impacted by the next burn.

(d) The Harvesting Manager or Harvesting Supervisor in charge of the burn has notified
the Department of Health by telephone of the intent to conduct additional burns.

(5) Attendance to fires and conduct of burns – The date, time, and acreage to be burned shall be determined by the Harvesting Manager. The Harvesting Supervisor at the burn site shall be responsible for controlling the burn and shall assign men and equipment to the burn as necessary depending upon wind conditions, field location, dryness of the surrounding area, and proximity to public areas. A supervisor shall remain at the burn site until all flames are extinguished and smoke emissions are minimized.

(a) Controlling fires – Fire breaks are used to isolate the specific area of cane to be
harvested and are cleared prior to burning. The size and location of firebreaks will be
determined by the Harvesting Supervisor depending upon field location and wind
conditions. Under normal conditions, a 15-foot wide firebreak will be cleared;
however, a firebreak up to 50 feet wide may be cleared to avoid a “jump fire” into
standing cane, rangeland, or nearby structures. In fields immediately adjacent to
residences, firebreaks shall be adequate to protect adjacent property and the area
surrounding the acreage to be burned shall be watered down prior to burning. In the

 


Page 11

event that the field is too close to residences or other structures to be safely burned, a portion of the field shall be harvested unburned. The Harvesting Supervisor at the burn site shall determine the speed and direction of burning by controlling firing of the field, utilizing backfire techniques, and remaining alert to changes in wind conditions. Water trucks and firebreak equipment shall be maintained at the burn site during the burn to help prevent uncontrolled fires. (b) Contingency Plans – Training in dealing with contingencies shall be a part of the Harvesting Department’s continuing training program. In the event of a ‘jump fire” or other unforeseen accident, the following steps shall be taken:

• Notify the Fire Department and Police Department

• Dispatch additional water trucks and rakes to the burn site

• Notify all harvesting crews to assist in dealing with the emergency

• Complete additional notifications and actions required under the plantation fire
protection manual as necessary.

(c) Variable Winds — Burning in the Pulehu area can be hazardous due to highly variable wind conditions during the day and the proximity to frequently dry rangelands. HC&S may request approval from the Department of Health to burn certain fields in this area during early morning hours (0400 to 0600) to take advantage of more consistent downslope drainage winds. However, such early morning burns shall only be conducted under meteorological conditions that will also minimize smoke impacts on public areas. If such conditions cannot be met during early morning hours, then normal daytime burns in these areas will be required.

(d) Minimizing Smoke Impacts – Only controllable amounts shall be burned and under conditions that will minimize ground level visible smoke from entering any nearby building, public road, highway, beach, or any area to which the public has unrestricted access. With the exception of smoke impacts to roadways and/or the Kahului airport resulting from the burning of fields listed in Exhibit 2 and smoke impacts from fires not caused by the permittee (e.g., malicious fires, brush fires), ground level visible smoke entering any residence, business, or public areas shall not exceed a Public Impact Code of three (3), as determined by the HC&S Burn Monitor or by DOH staff.

C. Actions to be taken at the completion of the burn:

(1) Extinguishing flames and minimizing smoke impacts – The following measures shall be implemented to minimize the potential for ground level smoke impacts to public areas due to smoldering.

(a) A supervisor shall remain at the burn site until all flames are extinguished and smoke emissions are minimized. After the fire has burned out (i.e., all flames have been extinguished), personnel and equipment shall remain in the field as necessary to minimize smoke emissions from smoldering piles.


Page 12

(b) Water wagons shall be used to extinguish smoldering piles and, if necessary, rakes and cranes shall be used to break up the smoldering piles. These “mop up” operations shall be completed within two hours after the end of the burn and repeated as needed thereafter for compliance with Section C.(l)(d) below.

(c) Once emissions following the burn have been reduced to the point where smoke is no longer visible passing beyond HC&S field boundaries and into public areas, equipment may leave the field.

(d) The Harvesting Supervisor responsible for the burn shall ensure that the field is checked periodically for flare-ups or excessive smoldering (i.e., smoldering which results in visible smoke passing beyond HC&S field boundaries and into public areas). Periodic checks shall be made at least once per hour during the first four hours following completion of the burn. After that, checks for smoldering shall be made at maximum intervals of four hours until harvesting of the field is completed (i.e., all cane to be harvested has been removed from the field). More frequent checks may be made in fields that are located close to public areas.

(e) In the event of a flare-up, water wagons and rakes, if necessary, shall be returned to the field to re-extinguish all flames and smoldering. Action shall be initiated to address flare-ups or excessive smoldering within one hour of discovery.

(f) Actions taken for compliance with these provisions relating to smoldering shall be documented in the Post-Burn Smoldering Log (Attachment lh)

(g) In order to reduce the potential for smoldering piles and resultant ground level smoke after the burn is completed, consideration shall be given during burn preparations to hauling out “fire line” cane (i.e., removing it from the field unburned instead of pushing into the field to be burned) and/or “notching” valve lines (risers) when practicable.

(2) Clearing of burned fields – To the extent possible, burned cane located closest to adjacent residences, roadways, and other public areas shall be cleared first in order to minimize smoke impacts. Fire line cane will also be hauled out of these areas when possible. Clearing of burned fields shall be done so that the cane is moved away from these sensitive areas whenever possible.

D. Recordkeeping and Reporting

(1) Recordkeeping – For each burn, records shall be maintained as described below. To help ensure legibility of scanned documents, all records required by this Exhibit l shall be completed in pen. All records, including supporting information, shall be maintained in a true, accurate, and permanent form suitable for inspection, retained for a minimum of three (3) years from the date of such records, and made available to the Department of Health or their representative(s) upon request.


Page 13

(a) Pre-Burn Checklist (Attachment ld) — For each burn, a Pre-Burn Checklist shall be completed. This checklist documents the completion of all pre-burn inspections, notifications, and other requirements that are mandatory for every field. The completed checklist for each burn shall be maintained in the harvesting records.

(b) Exhibit 2/Exhibit 3 Checklist- For each burn, either an Exhibit 2 Checklist (for fields where smoke impacts to certain public areas, such as roads and airports, cannot be avoided) or an Exhibit 3 Checklist (for all other fields) shall be completed. This checklist documents additional, field-specific requirements for each burn. The completed checklist for each burn shall be maintained in the harvesting records.

(c) Burn Monitor Log (Attachment le) — For each burn, the burn location, start and end times, wind speed and direction, and information on smoke plume behavior and smoke impacts throughout the burn shall be recorded on the Burn Monitor Log (see additional details under B.(l)). All photographs taken during burn monitoring shall be appended to and considered part of the Burn Monitor Log; photographs may be maintained in electronic format. The completed Burn Monitor Log for each burn shall be retained in the harvesting records.

(d) Burn Justification Log (Attachment lg) — When a burn has resulted in visible smoke impacts to a public area (other than smoke impacts to public roads and/or the airport from burning an Exhibit 2 field), the Harvesting Manager’s determination that a subsequent burn on the same day is not expected to impact the same public area shall be documented on the Burn Justification Log. The Burn Justification Log, when required, shall be retained with the records for the subsequent burn in the harvesting records.

(e) Post-Burn Smoldering Log (Attachment lh) — All post—burn field checks for smoldering and associated corrective actions shall be recorded on the Post-Burn Smoldering Log. The completed Post-Burn Smoldering Log shall be retained in the harvesting records.

(f) Daily Weather and Dispersion Forecast (Attachment lj), Weather Data — Copies of each daily smoke management weather and dispersion forecast shall be maintained in the harvesting records. A complete record of data output from HC&S weather stations is maintained in the weather computer memory.

(2) Reporting
(a) Weekly Report – Within seven (7) days after the end of each week, the Harvesting Manager or his designee shall submit to the Department of Health Clean Air Branch (Honolulu) a copy of each of the records listed in Section D.(l) above for each burn conducted during the week. Records may be submitted electronically or by hard copy. For the purposes of this reporting requirement, Friday shall be considered the end of the week.

(b) Reporting of Deviations — Within five (5) working days after any deviation from a permit requirement, including the procedures specified in Exhibits 1, 2, and 3 and


Page 14

accompanying attachments, HC&S shall submit a written report to the Department of Health, Clean Air Branch (Honolulu) identifying the deviation, the probable cause, and any corrective actions or preventive measures implemented as a result. The Permit Deviation Report Form (Attachment lk) shall be used for this purpose, and a copy of each report shall be retained in the harvesting records.

E. Weather station locations and operation

(l) Locations and data collected – HC&S operates both fixed and mobile weather stations for collecting weather data to be used in making burn determinations. Each station provides data on rainfall, wind speed and direction, temperature, and relative humidity. Fixed weather stations are listed in the attached table (Attachment li) and locations are shown on the harvest map.

(2) Mobile station, use of alternate stations — The mobile weather station will normally be located near sensitive downwind areas for each burn. In the event that any weather station specified for use in making burn determinations in Exhibit 2 or 3 is out of service, either the mobile station or the nearest alternate station will be used instead.

(3) Data readouts, station maintenance – Weather stations provide readouts to a central computer located at the HC&S Main Office. Weather station outputs are also provided directly to Western Weather Group for use in preparing the daily smoke dispersion forecast. Readouts from each weather station are checked daily during the harvest season and any station that provides readings which appear to be inconsistent or unreasonable is serviced as soon as is practicable to ensure proper operation. Each station’s sensors are cleaned regularly to ensure optimum performance. Each station is calibrated quarterly to ensure that all sensors operate properly.

Attachments to Exhibit 1
Attachment la — Cane Burn Notification Listing
Attachment lb — Sample Written Notice
Attachment lc — List of Schools Adjacent to HC&S Su garcane Fields
Attachment ld — Pre—Burn Checklist
Attachment le — Burn Monitor Log
Attachment lf- Smoke Pattern Codes and Public Impact Codes
Attachment lg — Burn Justification Log
Attachment lh — Post-Burn Smoldering Log
Attachment li — Listing of Weather Stations
Attachment lj — Sample WWG Daily Weather and Dispersion Forecast
Attachment lk — Permit Deviation Report Form


Page 15-18 are illegible


 

Page 20

Attachment lc
List of Schools Adjacent to HC&S Sugar Cane Fields
As required by Exhibit 1 to the agricultural burning permit, the following is a list of operating hours for schools located adjacent to HC&S sugar cane fields which could be impacted by smoke from agricultural burning. As required by the permit, burning of fields adjacent to these schools will not be conducted while school is in session or within one hour of the start of school.

School Hours
Doris Todd Memorial Christian Schools (Paia) 0750-1400 no after school or summer programs
Kaahumanu Hou School (Puunene Avenue) 0800-1500 no after school or summer programs
Paia School (Paia) 0750-1730 includes after school program; no
summer program
Anuenue Pre-School (Baldwin Avenue, Paia) 0700-1700 one month off in summer

Rev 3/2013


Be the first to comment

Leave a comment

Your email address will not be published.


*