United States         Center for Environmental
             Environmental Protection     Research Information
             Agency           Cincinnati, OH 45268
            Technology Transfer       	EPA 762575-877022
xvEPA      User's Guide
            Emission Control
            Technologies and Emission
            Factors for Unpaved Road
            Fugitive Emissions

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                                         EPA/625/5-87/022
                                          September 1987
           User's  Guide

Emission Control  Technologies
   and Emission  Factors for
     Unpaved  Road  Fugitive
             Emissions
    Center for Environmental Research Information
       Office of Research and Development
       U.S. Environmental Protection Agency
            Cincinnati, OH  45268
   Air and Energy Engineering Research Laboratory
       Office of Research and Development
       U.S. Environmental Protection Agency
       Research Triangle Park, NO 27711

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                                    Notice

This document has been reviewed In accordance with the U.S. Environmental Protec-
tion Agency's peer and administrative review policies and approved for publication.
Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.

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                              Acknowledgments

This handbook is primarily a summary of the results of two independent studies, one
conducted by Midwest Research Institute (MRI),  Kansas City, Missouri, and the  other
by Southern Research Institute (SORI), Birmingham, Alabama. The MRI Report, Identi-
fication, Assessment and Control of Fugitive Paniculate Emissions was written by  Chat-
ten Cowherd Jr., John S.  Kinsey and Dennis Wallace; Dale Harmon of EPA's Air and
Energy Engineering Research Laboratory was project officer.  The SORI report,  Criti-
cal Review of Open Source Paniculate Measurement, Part II - Field Comparison, was
written by Bobby E. Pyle and Joseph McCain; Robert McCrillis of EPA's Air and Energy
Engineering Research Laboratory was project officer.

This handbook was adapted and produced by Marjorie Fitzpatrick, JACA Corporation,
Fort Washington. Pennsylvania. Norman Kulujian of EPA's Center for  Environmental
Research Information. Cincinnati,  Ohio,  was the EPA project officer for this publica-
tion.

If you wish to obtain the  more detailed  reports,  they are available from the National
Technical Information Service  (NTIS),  5285 Port  Royal Road,  Springfield,  Virginia
22161;  (703) 487-4650. The order numbers are:

                  MRI Report;  PB 86-230083; EPA-600/8-86-023
                  SORI Report; PB 86-239787; EPA-600/2-86-072
                                       IV

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                                              Contents


1 Introduction 	      1
  1.1 Background	      1
  1.2 Organization of Document	      1
  1.3 References	      2
2 Overview of Source Testing Methods	      3
  2.1 Mass  Emissions Measurements	      3
  2.2 Particle Sizing Methods  	      A
  2.3 References	      8
3 Uncontrolled Fugitive Road  Dust Emission Factors  	      9
  3.1 Published Emission Factors	      9
  3.2 Quality Rating  System for AP-42 Emission Factors	      9
  3.3 Other Types of Emission Factors	     12
  3.4 Recommendations  for Use of Emission Factors  	     13
  3.5 References	     13
4 Control Alternatives  	     15
  4.1 Wet Suppression  	     15
  4.2 Chemical Stabilization 	     15
  4.3 Physical Stabilization  	      16
  4.4 Other Unpaved Road Control Techniques  	     16
  4.5 Estimation of  Cost-Effectiveness of Control Options  	     16
  4.6 References	     18
5 Estimation of Control System Performance	     19
  5.1 Wet Suppression  	     i9
  5.2 Chemical Stabilization 	     20
  5.3 Paving	     21
  5.4 Other Control Alternatives	     21
  5.5 Calculation  of Controlled Emission Rate	     22
  5.6 Alternate Indicators of Control Performance 	     24
  5.7 References	     24
6 Fugitive Emissions Control Strategy Development  	        27
  6.1 Identifying/Classifying Fugitive Emission Sources 	     27
  6.2 Preparing an Emissions Inventory	      27
  6.3 Identifying Control Alternatives  	     29
  6.4 Estimating Control Efficiencies  	     29
  6.5 Calculating  Cost and  Cost-Effectiveness	     29
  6.6 References	     31
Appendices
  A   Glossary of Terms  	     33
  B   Abbreviations   	     35
  C   Modeling of Fugitive Emissions	     37
  D   Control Efficiency Decay Curves  	      39

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                                             Tables


3-1  Typical Silt Contents for Unpaved Road Surface Materials  	     11
4-1  Implementation Alternatives for Stabilization of an Unpaved Road 	     17
5-1  Field Data on Watering Control Efficiency	     20
5-2  Classification of Tested Chemical Road Dust Suppressants  	     21
5-3  Summary of Major Unpaved Road Dust  Suppressant Control Efficiency Tests  	     22
5-4  Summary of Major Unpaved Road Dust  Suppressant Control Efficiency Decay
      Function Tests 	     23
6-1  Uncontrolled  Emission Factors for Hypothetical Crushing Plant	     29
6-2  Plant and Process Data for Hypothetical Facility  	     30
6-3  Source Extents and Uncontrolled Emission Rates  for Hypothetical Crushing Plant  	     30
6-4  Cost Comparison for Two  Selected Implementation Scenarios	     31
                                                VI

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                                             Figures


2-1   Illustration of upwind/downwind sampling method  	      3
2-2   Illustration of exposure profiling sampling method	      4
2-3   Cyclone/impactor combination  	      5
2-4   Lundgren cascade impactor 	      6
2-5   Stacked filter profiler head	      6
3-1   Mean number of days with greater than or equal to 0.01  in.  of precipitation	     10
6-1   Process flow diagram of hypothetical rock crushing plant  	     28
D-1   Control efficiency decay for an initial application of Petro Tac®	     39
D-2   Control efficiency decay for an initial application of Coherex®	     40
D~3   Control efficiency decay for a  reapplication of Coherex®	     41
D-4   TSP control efficiency decay for light-duty traffic on unpaved roads  	     42
D-5   Control efficiency decay for LiquiDow® applied to haul roads	     43
D-6   Control efficiency decay for Soil Sement® and Biocat-Enzyme® applied
      to haul roads 	     44
D-7   Control efficiency decay for Flambinder® applied to haul roads 	     45
D-8   Control efficiency decay for Arco 2200®  applied to haul  roads  	     46
D-9   Control efficiency decay for reapplication of various chemical suppressants	     47
                                               VII

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                                           Chapter 1
                                          Introduction
1.1  Background
During the  past decade, research has shown that
participate  emissions  from open  sources  such as
unpaved roads contribute significantly to  ambient
particulate matter concentrations in many areas. (1]
The  current EPA emission trading policy, [2]  com-
monly called the  bubble policy,  allows excessive
emissions from one source to be offset by improved
control of another source within the same  plant.  In
implementing the  bubble policy,  some plants have
agreed to reduce fugitive  dust emissions in  lieu of
tighter controls on process emissions. [3]

This  document has been prepared to assist control
agency personnel in evaluating unpaved road fugi-
tive  emissions control plans and  to assist Industry
personnel in the development of effective control
strategies for  unpaved  roads. This document de-
scribes control techniques  for reducing  unpaved
road emissions, methods for quantifying or estimat-
ing emissions generation, and provides data for esti-
mating the  efficiency of  the performance of various
control  technologies.  Although fugitive particulate
emissions can be reduced by reducing the extent of
the source, this document focuses on the use of
"add-on" controls which do not affect the size or
throughput  of the  source.

Within this  document, fugitive  emissions  refer to
those air pollutants that  enter the  atmosphere with-
out passing through a stack or duct designed to di-
rect  or control their flow.  Terms and abbreviations
for specific types  and  sizes of  particulate matter
cited in this document Include:

TP    Total  airborne particulate matter.

TSP   Total  suspended particulate  matter, as repre-
      sented  approximately by particles equal to
      or  smaller than 30 ^m  in aerodynamic diame-
      ter. [4,5]

IP     Inhalable  particulate  matter   consisting of
      particles equal to or smaller than 15 )j,m in
      aerodynamic diameter. [4]

PMio  ParUculate matter consisting of particles equal
      to  or smaller than 10 p.m in aerodynamic di-
      ameter. [4]
RP    Respirable  particulate matter  consisting of
      particles  equal to  or  smaller than approxi-
      mately 3.5 nm in aerodynamic diameter. [4]

FP    Fine   particulate matter  consisting of parti-
      cles equal to or smaller than 2.5 ^m In aero-
      dynamic diameter. [4]

Other terms used In this document are defined In Ap-
pendix A.


1.2 Organization of Document
This document is organized as follows:

 Chapter 2  - Source Testing Methods: describes
     the mass and particle sizing methods used to
     measure unpaved road emissions.

 Chapter 3 - Uncontrolled Fugitive Road Dust Emis-
     sion  Factors:  discusses  published  (AP-42)
     emission factors,  emission factors developed
     for specific sources  using  linear regression
     techniques, and the emission factor rating  sys-
     tem for published emission factors.

 Chapter 4  - Control Alternatives: describes possi-
     ble techniques for reducing fugitive  road  dust
     emissions  and briefly discusses calculation of
     cost effectiveness.

 Chapter 5 - Estimation of Control System Perform-
     ance:   presents available  data for  estimating
     the effectiveness of control techniques.

 Chapter 6  - Fugitive Emissions  Control  Strategy:
     presents a  fully  worked  industrial  example
     (with emphasis on unpaved road emissions) Il-
     lustrating  the  procedural  steps  for  control
     strategy development, Including the  capital,
     operation and maintenance costs of represen-
     tative  controls.

 Appendix A - Glossary of Terms.

 Appendix B -  Abbreviations: lists and defines ab-
     breviations used In this report,

 Appendix C - Modeling of Fugitive Emissions:  pre-
     sents a general discussion of ambient air qua!
     Ity modeling.

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 Appendix D - Control Efficiency Decay Curves: fig-
     ures   depicting  control  efficiency  decay
     curves.
1.3 References
 1.  Cowherd, C.,  Jr. and R.W. Hendriks.  Fugitive
     Emissions  from  Integrated  Iron  and  Steel
     Plants,  Open Dust Sources.    Paper 77-6.2,
     presented  at  the 70th Annual Meeting of the
     APCA, Toronto, Canada,  June 1977.


 2.  Federal  Register.  Emissions  Trading Policy
     Statement, 51 FR 43813-43860, December 4,
     1986.
3.  Palmisano, J. and D. Martin. "The Use of Non-
   traditional Control  Strategies in the Iron and
   Steel Industry: Air Bubbles,  Water Bubbles,
   and Multimedia Based Control Strategies." Pa-
   per 84-39.1,  presented  at  the  77th  Annual
   Meeting of the APCA, San Francisco. Califor-
   nia, June  1984.

4.  Cowherd, C. Jr. and J.S. Kinsey. Identification,
   Assessment, and Control of Fugitive Particulate
   Emissions. EPA-600/8-86-023, U.S. Environ-
   mental Protection  Agency, Research Triangle
   Park, NC, August  1986.

5.  U.S. Environmental Protection Agency Compi-
   lation of Air Pollution Emission Factors. Volume
   1:  Stationary  Point and Area Sources  Fourth
   Edition, Supplement A,  AP-42. Office  of Air
   Quality Planning and Standards. Research Tri-
   angle Park. NC, October 1986.

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                                           Chapter 2
                            Overview of Source Testing Methods
Testing verifies the rates of uncontrolled emissions
from the most significant  sources and establishes
the relative importance of each of those sources. In
addition,  source testing provides valuable data on
the emission characteristics of each source, which
in turn aids considerably in selecting the most suit-
able control method for each source.  This chapter
presents an overview of the testing methods used to
sample emissions from unpaved roads.

Fugitive  paniculate emission  rates and particle size
distributions  are difficult to quantify because  of the
diffuse  and  variable  nature  of  fugitive  emission
sources  and  the  wide range of  particle sizes In-
volved  (including  particles which deposit  immedi-
ately adjacent to the source).  Standard source test-
ing methods, which are designed for  testing con-
fined flows under  steady-state,  forced-flow condi-
tions, are not  suitable for measurement of fugitive
emissions.
2.1 Mass Emissions Measurements
Field measurement of fugitive mass emissions from
unpaved roads is usually conducted using either the
upwind/downwind  method or the  exposure profiling
method. The former involves measurement of up-
wind and downwind particulate concentrations, utiliz-
ing ground-based samplers under known meteoro-
logical conditions, followed by calculation of source
strength (mass emission rate) with atmospheric dis-
persion  equations. The exposure profiling method
involves simultaneous, multi-point measurements of
particulate concentration and wind  speed over the
effective cross-section of the plume, followed by
calculation of net particulate mass flux through inte-
gration of the plume profiles.
2.1.1  The Upwind/Downwind Method
The  basic  procedure  of  the  upwind/downwind
method,  shown schematically  in Figure 2-1,  is to
measure  particulate concentrations both upwind and
downwind of the pollutant source using ground level
samplers. The required number of upwind sampling
instruments depends on how well the source opera-
tion can  be isolated (i.e.. the  absence of Interfer-
ences  from other sources upwind). At least five
downwind particulate  samplers must be operating
during a test; increasing the number of downwind in-
struments will improve the  reliability in determining
the emission rate by providing better plume defini-
tion. [1]


Figure 2-1.  Illustration of upwind/downwind
            sampling method.8
                           Upwind
                          Sampler
              Downwind k.
           J  Samplers /


                   }'
                 Plume
                Centerline
                           / Wind
                            Instrument
 A modified drawing from reference 2.
After the concentrations measured upwind are sub-
tracted from the downwind concentrations, the net
downwind concentrations  are input  to  dispersion
equations (normally of the  Gaussian type). The dis-
persion  equations  are used to back-calculate the
particulate emission rate required to generate the
pattern of downwind concentrations.  (See Appendix
C for a brief discussion of Gaussian air quality mod-
els and the parameters used in the models). A num-
ber of meteorological  parameters must be concur-
rently recorded for input to this dispersion equation.

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At a minimum, the wind direction and speed must be
recorded on-site.
 Figure 2-2.  Illustration of exposure profiling
            sampling method. [3]
2.1.2 The Exposure Profiling Method
This  method uses the profiling concept that Is the
basis for conventional (ducted) source testing. The
difference is that in  the case of exposure profiling,
the ambient wind directs the plume to the sampling
array. The passage  of airborne  paniculate matter
immediately downwind of the source Is measured di-
rectly by means of simultaneous multi-point  sam-
pling of  particulate concentration and  wind velocity
over the effective cross section of the  fugitive emis-
sions plume.  For measurement of fugitive emis-
sions, profiling sampling heads are distributed over a
vertical  network positioned just downwind  (usually
about 5 m) from the source. Particulate sampling
heads should  be symmetrically distributed over the
concentrated portion of the plume containing about
90%  of the total mass flux (exposure).  A vertical line
grid of at least three samplers is sufficient for meas-
uring  emissions from line or moving point sources.
At least  one upwind  sampler must be  operated  to
measure  background  concentration,  and  wind
speed must be measured concurrently on-site. Fig-
ure 2-2  Illustrates the exposure profiling method.

Unlike the, up wind /downwind method, exposure pro-
filing  uses a  mass-balance calculation  scheme
rather than requiring Indirect calculation through the
application of a generalized atmospheric dispersion
model.  The mass  of airborne  particulate matter
emitted  by the source is obtained by spatial integra-
tion of distributed measurements of particulate flux,
after subtracting the background contribution. The
exposure is the point value of the flux (concentra-
tion  of  airborne particulate accumulated over the
time  of  measurement).
2.1.3 Recommended Sampling Procedures
The  method of choice In measuring fugitive emis-
sions from unpaved roads is the exposure profiling
method. [4,5]. Measurement results  of a line source
(such as unpaved road)  obtained using the expo-
sure profiling method are more accurate than those
obtained by the upwind/downwind method. [5]  The
exposure/profiling  method Is source-specific,  and
its increased accuracy over the upwind/downwind
method is a result of the fact that emission factor
calculation is based on direct measurement of the
emission rate. [5]

Maximum exposure values from unpaved roads usu-
ally occur at a height of 1.5 to 2.0 meters above
ground  level.  However,  there  may be significant
       O Profiler Head (See below left)
       O Cyclone/lmpactor (See below right)
       "A Anemometer
       ^ Wind Vane                 O
       Profiler Head
       with Motor
       and Flow
       Controller
Cyclone
Preseparator
with 5 Stage
Cascade
Impactor,
dust exposures  at heights up to at least 9 meters.
The exposure profile  method provides better char-
acterization of the plume  generated by vehicular
traffic  on an unpaved road because emissions are
measured at multiple  heights in the dust  plume.

The Ideal exposure profiling system to characterize
unpaved road  mass  emissions would  have mass
samplers situated  at 1.5, 2.5,  4,0, 6.0,  7.5 and 10
.meters above the road surface. Each sampling head
would  contain a horizontally mounted high-volume
filter and an inlet nozzle below the filter. It is possible
to sample isokinetically at each mass sampler on the
profiler tower if each sampler is  equipped with a
servo  system and individual velocity  sensors. This
sampling set-up provides continuous  adjustment of
the flow rate based on wind velocity at each eleva-
tion on the profiler tower.


2.2 Particle Sizing Methods
Three  fundamentally  different  methods  are com-
monly used to perform  particle size measurements
on open dust emission  sources — cyclone/impac-
tors, stacked filters, and scanning electron micros-
copy.  These measurement  techniques  will  be  dis-
cussed in the following sections.  For particle size
analysis of fugitive road dust emissions,  sampling Is
generally done in  conjunction  with total  particulate

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sampling using the exposure  profiling method dis-
cussed in the previous section.

A fourth type of particle size  sampler,  the EPA di-
chotomous  sampler,  is  useful for quantifying fine
particulate mass concentrations.  This sampler was
designed with a  symmetrical size-selective  Inlet
(usually having a particle size outpoint  of 10 or 15
jxmA) which is insensitive to wind speed or direction.
However, this device operates at a low  flow rate (1
m3/hr), yielding only 0.024 mg of sample In 24 hours
for  each 10 (ig/m3 of TSP concentration. Thus, an
analytical balance of high precision is required to de-
termine mass concentrations below and above the
fine particulate (2.5 urn) outpoint (the  minimum in
the typical bimodal size distribution of atmospheric
particulate).
2.2.1 Cyclone/lmpactors
High-volume cascade impactors with glass fiber Im-
paction substrates,  which are commonly used to
measure mass size distribution of atmospheric par-
ticulate, may be adapted  for sizing fugitive particu-
late  emissions. A  cyclone preseparator  (or other
device) precedes the Impactor to remove  coarse
particles which otherwise would be subject to parti-
cle bounce within the impactor, causing fine particle
bias. The  set-up of  a cascade Impactor with a cy-
clone  preseparator  is shown  in Figure 2-3, The
analysis of the particulate matter collected  by this
device is by gravimetric methods.  Multiple sampling
devices are used to  obtain a representative sample
-  one upwind and  two  or more  downwind using
either the  upwind/downwind or profiling method dis-
cussed previously.  The sampling intake  should be
pointed into the wind and  the sampling velocity ad-
justed  to the mean  local wind  speed by fitting the
intake nozzle of appropriate size to obtain a sample
at or near isokinetic  conditions.

Figure  2-4 shows a second type of cascade  impac-
tor,  the Lundgren impactor. These impactors are
four stage (plus filter) inertial classifiers. [6,7,8] The
samples are taken quasi-isoklnetlcally with Inlet noz-
zle cross sections adjusted  in accordance with the
mean wind speed  at the start  of the test. Particle
collection  in this impactor takes place on  a moving
plastic film coated with an adhesive. The adhesive is
used to insure retention of the Impacted particles.
The particle size distribution is measured gravimetri-
cally. By collecting the particles on the moving film,
overlapping  of particles In the  collected sample Is
largely avoided, permitting individual particles col-
lected  on each stage to be  easily examined by mi-
croscope.
Figure 2-3. Cyclone /impactor combination.
      05
   Scale-Inches
                                  Cyclone
                                                                                    5 Stage Cascade
                                                                                    Impactor
Back-up Filter
Holder
2.2.2 Stacked  Filters
A schematic diagram of  a stacked filter sampler Is
shown in Figure 2-5, A stainless steel inlet screen
having ;a 30 \i.m pore size Is used to provide a nomi-
nal 30 |im fractionatlon point. The screen Is followed
by two  Nuclepore filters, the first of which has a
pore size (8 pm) selected to provide a 2.5 p.m aero-
dynamic diameter cutoff while the second,  which
has a pore size of 0.8 urn, serves as the final filter.

2.2.3 Microscopy
Another particle sizing technique gaining some re-
cent prominence Is microscopy. Microscopes used
in  particle  sizing  Include  optical or  light micro-
scopes, transmission electron microscopes (TEM),
and scanning electron microscopes (SEM). SEM is
the most widely used microscopy technique for de-
termining particle size distributions.
Using the SEM  technique, selected portions of the
filters from the collection devices are  removed,
placed  between  finely perforated stainless  steel
screens, and backwashed with acetone  or back-
blown with compressed air to remove the collected
particles. For samples collected using the  acetone
backwash procedure the acetone particle  suspen-
sion   is  then  agitated   and  the  particles  are
redeposlted by vacuum filtration onto 0.2 urn pore
size Nuclepore  filters. Air-suspended particles from
the compressed air backblown procedure are recol-
lected on similar Nuclepore filters for analysis. A thin
coating   of  carbon  is  evaporated  onto   the

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Figure 2-4.  Lundgren cascade Impactor.
                1st Stage Nozzle
                                            1st Stage Rotating Plastic Film (with Adhesive)
 Air Inlet
redeposited specimen after mounting on SEM sam-
ple stubs.
Of the many techniques available to size particles by
their physical dimensions as  observed through the
microscope, the most  common approach is  the
projected area technique. Particle volumes are esti-
mated by categorizing the particle shapes and esti-
mating overall dimensions  based on the measure-
ments and assigned shape  category. X-ray fluores-
cence  emissions are used  to assign a probable
composition class to each particle. A density Is then

Figure 2-5.  Stacked filter profiler head.
      assigned  to the particle.  After measuring approxi-
      mately  700 to 4,500  particles and assigning esti-
      mated volumes and densities, a physical diameter-
      weight  distribution  curve is constructed. Aerody-
      namic diameters are also estimated for each particle
      based on the  assigned category,  the measured di-
      mensions, and  aerodynamic shape factors.  The
      choice  of particle measuring technique  and the
      method for deciding that a sufficient number of parti-
      cles have been measured varies among firms per-
      forming the analysis.

                                              Bracket
                                              to Tower
                   Stainless Steel
                    Inlet Screen
Nuclepore Filters


1,0 In I.D.
Inlet
Orifice



400
Mesh
Screen



Front
Filter
Holder



Back
Filter
Holder



Adapter
Section


\


V,
Hivo1 '


T__
V
/ X
/ /\.
Electrical I / X
Line
V

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Because this work requires several tedious hours to
perform  manually,  automated  processes  have
arisen.  An example  is the use of automatic image
analysis for  optical  computer  controlled scanning
electron microscopy (CCSEM).
2.2.4 Comparison of Particle Sizing Methods
There are advantages and disadvantages with  each
of the particle sizing techniques described in the
previous section.
Particle sizing is performed at only two stages with
the stacked filter technique (2.5 and 30 urn), which
means that all other particle sizes (such as the com-
mon 10 p,m size) are inferred based  on the two siz-
ing points. Another problem with this method is that
the 30  pm  screen, the  first  sizing outpoint in the
sampler,  becomes effectively  smaller during sam-
pling due to impaction and interception of  smaller
particles on the screen.  This reduces  the effective
cutoff diameter of the screen to a value smaller than
30 jam,  which could cause systematically low results
for all particle sizes.
The  procedures used to prepare samples for SEM
analysis could cause bias among both the large and
small particles. The filter retention screens used in
transferring  the sample from the profiler filter (the
original collection medium) to the Nuclepore mate-
rial will themselves act as filters and bias the sample
taken from  the profiler  filter by  suppressing the
transfer of large particles.  At  the other end of the
size  spectrum, it is unlikely that the techniques  used
to remove particles from the profiler filters would be
effective in removing smaller particles. Thus the bulk
of the small particles removed would be in the  form
of agglomerates which would be counted as larger
particles.  In order to properly characterize the size
distribution,  measurements of about 4,500 particles
are needed to obtain a statistically valid sample; this
is generally larger than the number of particles cur-
rently counted for  SEM analysis. There are also in-
herent difficulties in estimating particle volumes and
assigning  aerodynamic diameters  to  the  irregular,
nonhomogeneous particles encountered in fugitive
road dust.
current 20 cfma flow rate. A second potential prob-
lem is errors resulting from the possible transfer of
material from the outlet of the cyclone tube to the
first stage of the impactor.

2.2.5 Recommended Particle Sizing Method
There are long recognized problems in reconstitut-
ing size  distributions  of airborne  particles  from
resuspenslons of bulk material. For fugitive emission
sampling  of unpaved roads the sizing  should take
place prior to collection (or concurrent with collec-
tion  as in cyclones and  Impactors).  The  recom-
mended procedure for measuring the  particle size
distribution is the cyclone/impactor technique. [4]

The ideal particle sizing sampling technique for fugi-
tive  road  dust  emissions is  composed of  profiler
towers (upwind and downwind), with  cyclone/im-
pactors placed at 1.5, 4.5,  and 7.0 meters above
the road surface on the tower. Sizing is conducted
using a cyclone for the  removal of large particles
followed  by a  high-volume cascade  Impactor  for
size distribution measurement. The size distribution
measurements are made separately from the expo-
sure measurement.

With  regard to  field operations, reduction in the
sampling flow rate from the commonly  used  20 cfm
to 15 cfm would help minimize errors from particle
bounce. Alternatively, adhesive coated substrates
could be used at'the current 20 cfm flow rate. Errors
resulting from the possible transfer  of material from
the outlet  tube of the cyclone to the first stage of
the impactor can be avoided by counting only the
material collected in the body of the cyclone as its
catch. The outlet  tube catch would then be com-
bined with that of the first impactor stage.

With respect to  particle  sizing  data analysis,  the
technique  commonly used in reducing impactor data
from  industrial sources is appropriate. [9,10,11] A
spline fit is made to the cyclone/impactor data in the
cumulative percentage form of the distribution. The
fit is made in a manner that requires continuity In the
slope of the curve, and the solution is forced to  be
asymptotic to 100% at a diameter equal to the maxi-
mum  diameter  present  in the sample.  The fitted
curve  is then used to interpolate or extrapolate  as
needed to obtain the mass fractions in  the selected
size intervals. This technique avoids the assumption
of a  functional form for the  distribution and makes
The cyclone/impactor method obtains data directly
on an aerodynamic basis at five to seven cutpoints.
One problem with the technique Is potential particle
bounce in the sampler. Particle bounce  can be
overcome by  sampling  at a reduced flow rate  (15
cfm) or by using adhesive coated substrates at the
' 20 cfm is a specific sampling flow rate used by Sierra high
 volume cascade impactors (Model No. 230)  designed  to
 sample fugitive road dust. Theoretically,  sampling  flow
 rates can vary by manufacturer, although  there are  no
 other known manufacturers of cascade impactors used in
 this application.

-------
use of the complete data set rather than just two of
the data points.


2.3 References
  1.  Cowherd, C.. Jr. and  J.S. Klnsey.  Identifica-
     tion, Assessment, and  Control of Fugitive Par-
     tlculate Emissions.  EPA-600/8-86-023, U.S.
     Environmental  Protection  Agency,  Research
     Triangle Park,  NC, August  1986.

  2.  Axetell, K., Jr. and C.  Cowherd,  Jr. Improved
     Emission Factors for  Fugitive Dust from West-
     ern  Surface Coal Mining Sources, Volumes  I
     and  II.   EPA-600/7-84-048   (NTIS   PB84
     -170802),  U.S.  Environmental  Protection
     Agency,  Research Triangle  Park. NC,  March
     1984.

  3.  Cowherd, C.,  Jr., et  al. Development of Emis-
     sions  Factors  for  Fugitive  Dust  Sources.
     EPA-450/3-74-037 (NTIS PB-238 262/0), U.S.
     Environmental   Protection Agency,  Research
     Triangle Park,  NC, June 1974.

  4.  Pyle, Bobby E.  and  J.D. McCain. Critical Re-
     view of   Open  Source  Partlculate Emission
     Measurements,  Part II - Field  Comparison.
     EPA-600/2-86-072,  U.S.  Environmental  Pro-
     tection Agency, Research Triangle, NC, 1986.

  5.  TRC Environmental Consultants,  Inc. Protocol
     for the Measurement of Inhalable  Particle Fugi-
     tive  Emissions   for   Stationary  Industrial
     Sources.  EPA Contract No. 68-02-3115, Task
     114,  U.S. Environmental  Protection Agency,
     Research Triangle Park, NC,  March 1980.
6.  Lundgren, D.A. "An Aerosol Sample for Deter-
   mination of Particle Concentration as a Func-
   tion of Size  and  Time," Journal  APCA,  17
    (4):225-259,  1967.

7.  Rao,  A.K.  Sampling and Analysis  of  Atmos-
   pheric Aerosols., Particle Technology Labora-
   tory Publication No. 269, University of Minne-
   sota. 1975.

8.  Wesolowskl, J.J., A.E. Alcocer, and B.R. Ap-
   pel. "The Validation of  the  Lundgren  Impac-
   tor,"  In: The Character and Origins of Smog
   Aerosols,  (9): 125-146,  1980.

9.  Johnson, J.W..  Q.I. Clinard, L.G.  Felix,  and
   J.D. McCain.  A Computer-Based Cascade Im-
   pactor     Data      Reduction     System.
   EPA-600/7-78-042  (NTIS PB-285 433), U.S.
   Environmental Protection  Agency, Research
   Triangle Park, NC,  1978.

10. Tatsch,  C.E.,  W.M.  Yeager.  and  G.L.
   Johnson. Interactive Particle Data Reduction
   for Fine Particle Testing. Paper presented at
   the Third Symposium  on Advances in Particle
   Sampling  and  Measurement,  U.S.  Environ-
   mental Protection Agency,  Research Triangle
   Park, NC.  1981.

11. TRS-80  Cascade  Impactor  Data  Reduction
   System. Denver Research Institute, P.O.  Box
   10127,  Denver, CO 80208.

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                                           Chapter 3
                     Uncontrolled Fugitive Road Dust  Emission Factors
The large number of individual sources and the di-
versity of source types make impractical  the field
measurement of emissions at each point of release.
In most cases the only feasible method for determin-
ing source-by-source emissions is to estimate the
typical emission rate for each type of source and to
adjust each estimate for the size or  activity of the
specific source  and the level  of control. Emission
rates  can be  estimated using  published emission
factors (AP-42) or emission factors developed dur-
ing in-house sampling. An emission factor Is an esti-
mate  of the quantity of emissions released to the
atmosphere relative to appropriate units  of weight,
volume,  distance or duration  of the activity  that
emits the pollutant. For unpaved roads, emission
factors are expressed in pounds per vehicle mile
traveled  (or kilograms per vehicle kilometer trav-
eled).


3.1 Published Emission Factors
The document  Compilation of Air Pollutant Emission
Factors (commonly called AP-42), published by the
EPA since 1972, is a compilation of emission factor
reports  for  the  most significant emission  source
categories. Data obtained from source tests, mate-
rial balance studies, and engineering  estimates are
used to calculate the emission factors in AP-42.

The predictive equation for unpaved road emissions
described in AP-42,  expressed in pounds of particu-
late per vehicle mile traveled (Ib/VMT) or kilograms
per vehicle kilometer  traveled (kg/VKT), Is as fol-
lows:a
          .12 A 30

   (for Ib/VMT)
 All abbreviations used in this report are defined in
 Appendix B as well as in the text where the abbre-
 viation first appears.
                           0.7
                                   0.5
   (for kg/VKT)
where

  E  =

  k  =

  s  =


  S  =

  W  =
emission factor, Ib/VMT  (kg/VKT)

particle size multiplier, dlmensionless

silt content of road surface material,  %
passing a 200 mesh (75 urn)  screen

mean vehicle speed, mph (km/hr)

mean vehicle weight, tons (Mg, metric
tons)
  w  =   mean number of wheels, dimensionless

  p  =   number of days with at least 0.01 In.
         (0.254 mm) of precipitation per year,
         dimensionless.

The particle size multiplier,  k, varies with the aero-
dynamic particle size range. The values for the parti-
cle size  multiplier  k, as listed In the AP-42 docu-
ment, are: 0.80 (<30 um), 0.50 (<15  urn),  0.36
(<10 jxm), 0.20 (<5 urn), and 0.095  (<2.5 (Jim).
The silt content of the road surface material, s, var-
ies on a site-by-site basis.  Silt content Is deter-
mined using the ASTM-C-136 method; however, the
Information on Table 3-1 can be  used to approxi-
mate the silt content for unpaved  roads.

Figure 3-1 shows the mean number of days with at
least 0.01 inches  (0.254 mm) of precipitation per
year, which is p in equations  3-1 a and b.


3.2 Quality Rating System for AP-42
     Emission Factors
Data used to calculate  AP-42 emission factors are
obtained from a variety  of sources, Including  pub-
lished technical papers  and  reports,  documented
emission testing results, and  personal communica-
tions.  Some data sources provide complete details

-------
Figure 3-1. Mean number of days with greater than or equal to 0.01 in. of precipitation. [1]
                                                                                                          ,150
                                                                      VJ  .-V-
                                                           'xvU4
                                                              LOUISIANA1,
                                                                    (
                                                                                             120
210
                                240
                                                                 0  100 200 300  400  500
                                                                 I  1  i  i  i  i  i  l  i  i  i

                                                                         Miles
                                                                                                            140

-------
about  their collection  and  analysis  procedures,
whereas others provide only sketchy information. A
rating system for AP-42 emission factors was devel-
oped by the U.S. EPA. Office of Air Quality Planning
and Standards to help users assess the reliability and
accuracy of emission factors. The system entails 1)
rating individual test data sets for accuracy and reli-
ability and  2)  calculating an overall rating for the
emission factor based on ratings assigned to individ-
ual data sets.

Several subjective schemes have been used to as-
sign  emission factor ratings. Because of the subjec-
tive nature  of the rating system, a rating should only
be considered an indicator of the accuracy and pre-
cision of a  given factor.

The  AP-42  rating system is briefly discussed in this
section because the system is used to rate test data
presented in Chapter 5. For a more detailed descrip-
tion of the AP-42 rating system  and how it relates to
unpaved road emission  factors,  other references
are available. [1.2,3]

The  rating  system for  an emission  factor test data
set,  as it relates to unpaved roads, is based on the
following data standards:

  •   A - Tests  performed by a sound methodology
     and reported in  enough  detail  for  adequate
     validation. These tests are not necessarily EPA
     reference method tests,  although such  refer-
     ence  methods  are  certainly  to be  used  as a
     guide.

  •   B - Tests  that  are performed by a generally
     sound methodology but lack enough detail for
     adequate validation.
 •   C - Tests that are based on an untested or new
     methodology or that lack a significant amount
     of background data.

 •   D - Tests that are based on a generally unac-
     ceptable  method but  may  provide  an or-
     der-of-magnltude value for the source.

In the  ideal situation,  a large  number of A-rated
source test data sets representing a cross section
of the industry are reduced to a single value for each
individual source by computing the arithmetic mean
of each test set.  The emission factor Is then com-
puted by calculating the arithmetic mean of the indi-
vidual  source  values.   Alternatively,  regression
analysis Is used to derive a predictive emission fac-
tor equation for the entire A-rated test set.  No B-,
C-, or D-rated test sets are used  in the calculation
of  the  emission  factor because the  number of
A-rated tests is sufficient. This Ideal  method of cal-
culating an emission  factor is not always possible
because of a lack of A-rated data.

If the number of A-rated tests Is so limited that inclu-
sion  of B-rated tests would  Improve the emission
factor, then B-rated  test data are Included  in the
compilation of the  arithmetic  mean.  No  C-  or
D-rated test data are averaged  with A- or B-rated
test data.  The rationale for inclusion  of any B-rated
test data Is in the background Information document.

If no A- or B-rated test series are  available, the
emission factor is the arithmetic mean of the C- and
D-rated test data. The C- and D-rated test data are
used  only as  a   last resort,  to  provide  an or-
der-of-magnitude value.

In AP-42,  the reliability of these  emission factors Is
indicated by an overall Emission Factor Rating rang-
ing from A (excellent)  to E  (poor).  These ratings
 Table 3-1.   Typical Silt Contents for Unpaved Road Surface Materials"
Industry
Copper smelting
Iron and steel production
Sand and gravel processing
Stone quarrying and processing
Taconite mining and processing

Western surface coal mining




Rural roads


Road Use or
Surface Material
Plant road
Plant road
Plant road
Plant road
Haul road
Service road
Access road
Haul road
Scraper road
Haul road (freshly
graded)
Gravel
Dirt
Crushed limestone
Plant
Sites
1
9
1
1
1
1
2
3
3

2
1
2
2
Test
Samples
3
20
3
5
12
8
2
21
10

5
1
5
8
Silt (%
Range
15.9- 19.1
4.0 - 16.0
4.1 -6.0
10.5-15.6
3.7 - 9.7
2.4-7.1
4.9 - 5.3
2.8 - 18.0
7.2 - 25.0

18.0 - 29.0
NA
5.8-68.0
7.7-13.0
)
Mean
17.0
8.0
4.8
14.1
5.8
4.3
5.1
8.4
17.0

24.0
5.0
28.5
9.6
 "Reference 1.
 ''Expressed on a weight per weight basis.
                                                                         11

-------
take into account the type and amount of data from
which the  factors were calculated, as follows:

 •   A - Excellent. Developed only from A-rated
     data  taken from many randomly chosen facili-
     ties  In the  industry  population. The  source
     category is  specific enough to minimize vari-
     ability within the source category population.

 •   B  -  Above average.  Developed  only  from
     A-rated data from a reasonable number of fa-
     cilities. Although no  specific bias  is evident,
     the facilities may not represent a random sam-
     ple of the  Industry.  As in the A  rating, the
     source category is specific enough to  mini-
     mize  variability within  the  source category
     population.

 •   C  -  Average. Developed only from A- and
     B-rated data from a reasonable number of fa-
     cilities. Although no  specific bias  is evident,
     the facilities tested may not represent a ran-
     dom  sample of the industry. As in the A rating,
     the source  category is  specific  enough  to
     minimize variability within the source category
     population.

 •   D - Below  average.  Developed only from A-
     and B-rated data from a small number of facili-
     ties,  and these facilities may not represent a
     random sample of the industry. There also may
     be evidence of variability within the source
     category population.  Limitations on the use of
     the emission factor should be footnoted.

 •   E -  Poor.  Developed  from C- and D-rated
     data,  and the facilities  tested may not repre-
     sent  a random sample of the  industry. There
     may   be  evidence  of  variability  within the
     source category population.  Limitations on the
     use of these factors  are always footnoted.

The equations listed in AP-42 (equations  3-1 a and b
discussed previously)  to calculate an emission fac-
tor  for unpaved roads have an Emission  Factor Rat-
ing  of A. The A rating for size-specific emission fac-
tors is based  on two criteria.  First, the test  data
were developed using well documented and sound
methodologies. Second, a total of at least six tests
were performed  at two or more plant sites. [3]

However,  the A Emission Factor Rating is only appli-
cable with  all the following conditions:

 •   Road surface  silt  content between 4.3 and
     20%

 •   Mean vehicle weight  between  3 and 157 tons
      (2.7-147 Mg)

 •   Mean vehicle speed between 13 and 40 mph
      (21-64 km/hr)
 •   Mean number of wheels between 4 and  13.

Also, the  A rating only applies if site specific data
(such as silt content)  is available. The rating is low-
ered to a B if assumptions are made for site-specific
data.

The rating system discussed in this section will be
used to rate test data  presented in Chapter 5 of this
report.
3.3  Other  Types of Emission Factors
The most reliable emission factors are based on field
tests of representative sources using a sound test
methodology reported in enough detail for adequate
validation. Usually  the emission  factor for  a  given
source operation,  as presented in a test report, is
derived simply as the arithmetic average of the indi-
vidual emission factors calculated from each test of
that source.  Frequently the range of individual  emis-
sion  factor values is also presented.

As an alternative to the presentation of an emission
factor as a single-value arithmetic mean, an  emis-
sion  factor may be presented in the form of a pre-
dictive equation derived by linear regression analy-
sis  of  test  data.  The predictive emission factor
equation   mathematically  relates   emissions   to
parameters  which  characterize source conditions.
An emission  factor equation is useful if it is success-
ful in explaining much of the observed variance in
emission factor values on the basis of correspond-
ing  variances in specific source parameters. This
enables more reliable estimates of source emissions
on a site-specific basis by allowing for correction of
the emission factor to specific source  conditions.

Examples of site-specific predictive emission factor
equations developed using linear regression  tech-
niques are as follows:
               E = k (W) (m)
                                           (3-2)
where

  E  =

  m  =

  W  =

  k.a.b
emission factor,  Ib/VMT (kg/VKT)

road surface moisture content,  %

mean vehicle weight,  tons  (Mg)

constants dependent  upon  the size
fraction of the particulate being con-
sidered
                     12

-------
and
                                          able predictor of unpaved road emissions currently
                                          available.
              0 139   -0 203   0 267    0 395
         = k(s)    (R)    (w)    (W)
where
  p  	

  R  =

  W  =

  w  =
                                          (3-3)
emission factor,  Ib/VMT (kg/VKT)

ambient relative  humididty, %

mean vehicle weight, tons (Mg)

mean number of wheels, dimensionless
  s   =   silt content of road surface material

  k   =   particle size multiplier, dimensionless

Equations 3-2 and 3-3 are provided only as samples
of equations developed using linear regression tech-
niques.  The equations  were derived from a set of
data from a specific site and the equations are, most
likely, only applicable for the specific site. Also note
that  the equations do not take into  account the
amount  of rainfall.


3.4 Recommendations for Use of  Emission
    Factors
The utility of an emission  factor predictive equation
is that of predicting the emissions from a particular
site in lieu of actual measurements. In order that the
equation be applicable  over a wide range of site lo-
cations  and conditions, it  should include as many of
the relevant parameters describing the site as pos-
sible.  This requires that the predictive equation be
developed  from  as large  a data base as possible.
The equation currently described in the AP-42 man-
ual was  developed from a fairly broad data base us-
ing multiple linear regression techniques.  The AP-42
emission factor equation  is probably the  most reli-
The high emission factor rating for the AP-42 equa-
tion for calculating emissions from unpaved roads is
only applicable within specific limits of road surface
silt  content and  mean  vehicle speed, weight, and
number of wheels (see Section 3.2). If actual plant
conditions stray outside the  limits of  the  AP-42
equation, it may be necessary to conduct mass or
particle  size testing to determine emission rates.

AP-42  emission  factors  are  useful for estimating
emissions from an  air  pollutant source. However,
the factors are averages obtained from a wide range
of data with varying degrees of accuracy. Emissions
calculated using AP-42  emission factors are likely to
be different  from a facility's actual  emissions. For
the most accurate estimate of emissions, site-spe-
cific data should  be obtained whenever possible.


3.5 References
  1.  U.S. Environmental Protection Agency. Compi-
     lation of Air  Pollution Emission Factors,  Volume
     1:  Stationary Point and Area Sources. Fourth
     Edition,  Supplement  A,  AP-42, Office of Air
     Quality Planning and  Standards, Research Tri-
     angle Park,  NC, October, 1986.

  2.  Cowherd, C., Jr. and B.  Peterman.  AP-42 Up-
     date,  Section  11.2, Fugitive  Dust Sources.
     EPA-450/4-83-010. U.S.  Environmental  Pro-
     tection  Agency, Research Triangle Park, NC.
     March 1983.

  3.  Cowherd, C., Jr. and P.J. Englehart. Size Spe-
     cific Particulate Emission Factors for Industrial
     and Rural Roads — Source Category Report.
     EPA-600/7-85-051. U.S.  Environmental  Pro-
     tection Agency, Research Triangle Park,  NC,
     October 1985.

-------

-------
                                            Chapter 4
                                       Control Alternatives
 There are several options for control of fugitive par-
 tlculate emissions from unpaved roads. Emission re-
 duction may be achieved  by reducing the  source
 extent (the level of the source activity) or by using
 measures  to prevent or reduce  emission  genera-
 tion.

 Although the reduction of source extent results in a
 highly predictable  reduction in  the  uncontrolled
 emission rate, such an  approach usually requires a
 change in the process operation. Frequently, reduc-
 tion in the extent of one source may necessitate the
 Increase in the extent of another, as in the shifting of
 vehicle traffic from  an unpaved  road to a paved
 road, The  option of  reducing source extent is be-
 yond the scope of this manual and will not be dis-
 cussed further.

 Wet suppression, chemical stabilization,  and physi-
 cal stabilization  are feasible control  techniques for
 unpaved road fugitive  particulate emissions.  This
 chapter describes the basic characteristics of each
 control technique and briefly discusses  cost effec-
 tiveness.

 In selecting or evaluating a control alternative, it is
 important to keep in  mind the overall environmental
 impact of  the control  alternative.  For example,  a
 chemical suppressant used to stabilize the road sur-
 face  could  cause ground  water  or  surface water
 problems If the  chemical is improperly applied.  In
 other words, to  reduce an air pollution  problem,  a
 water pollution problem was created.


 4.1  Wet Suppression
 Wet suppression systems for unpaved roads apply
 either water or a water solution of a chemical agent
 to the surface of the road.  Application of chemical
 agents in a water solution will be addressed in the
 next section of this chapter.  Wet suppression pre-
 vents or suppresses the fine particles contained in
 that material from leaving the surface and becoming
 airborne. The suppressant  agglomerates and binds
the fines to the aggregate surface, thus eliminating
or reducing its emissions potential.

Plain water has been used as a wet suppression sys-
tem for many years on  such sources as crushing,
 screening, and materials transfer operations as well
 as unpaved roads. Water Is generally applied to the
 surface of unpaved roads by a truck or some other
 vehicle using  either  a pressurized or a gravity  flow
 system.  Watering unpaved roads  is only a tempo-
 rary measure  and must be repeated at regular inter-
 vals.

 Wet suppression with plain water can cause freezing
 problems in the winter. In  the arid West,  wet sup-
 pression is not  always practical due  to inadequate
 water supplies.

 To improve the overall control efficiency of wet dust
 suppression systems, wetting agents  can be  added
 to the water to reduce the  surface tension. The ad-
 ditives allow particles to more easily  penetrate the
 water droplet  and increase the number of droplets,
 thus increasing the surface area and contact poten-
 tial.
4.2 Chemical Stabilization
Particulate release  from unpaved surfaces can be
reduced or prevented by stabilizing  those surfaces.
The use of chemical dust suppressants for stabiliza-
tion has received much  attention in the past several
years. Chemical suppressants can be classified into
six generic categories: salts (i.e.. CaCI2 and MgCI2).
lignin sulfonate, wetting agents, latexes,  plastics,
and petroleum  derivatives.

Salts, which are usually obtained from natural brine
deposits,  control dust  by  absorbing and  retaining
moisture  in the surface material.   Wetting  agents
lower the surface tension of water, thereby causing
more rapid  penetration into the surface  material.
The remaining dust suppressants, both natural and
synthetic, bind  the fines to  larger aggregates in the
surface material.

Chemical dust suppressants are generally applied to
the road surface  as a water solution of the agent.
The degree of  control achieved is a direct function
of the application Intensity, dilution  ratio,  and fre-
quency (number of applications/unit time)  of  the
chemical applied to the surface. Control depends or
the type and number of vehicles using the road.
                                                 15

-------
4.3  Physical Stabilization
Physical stabilization techniques  can also  be used
for the control of fugitive  emissions  from  unpaved
road surfaces.  Physical stabilization includes any
measure, such as compaction of fill material at con-
struction sites, which physically reduces the  emis-
sions potential of a source from either mechanical
disturbance or wind erosion.

The  most notable  form of physical stabilization  of
current interest involves the use of civil engineering
fabrics or "road carpet" for unpaved roads. In prac-
tice, the road carpet fabric Is laid on  top of a  prop-
erly prepared road base just below a layer of coarse
aggregate (ballast)   The fabric sets  up a  physical
barrier that prevents the fines (particles less than 75
urn  in  diameter)  from contaminating the ballast
layer. These  smaller  particles are now no longer
available for  resuspension and  saltation  resulting
from the separation of the fines from the ballast. The
fabric is  also effective in  distributing the  concen-
trated  stress from  heavy-wheeled  traffic  over a
wider area. Currently,  this application has limited ac-
tual use; therefore detailed information on the effec-
tiveness of this technique  is not yet available.


4.4  Other Unpaved Road Control
     Techniques
Other practices may be used to reduce fugitive par-
ticulate emissions from an  open dust source.  Work
practices focus on  transport equipment operation.
For an unpaved travel  surface, emissions can be re-
duced by decreasing  vehicle speed and weight.

Housekeeping practices generally refer to  the peri-
odic removal of exposed  dust-producing materials
to reduce the potential for dust generation through
wind or machinery  action.  Examples of housekeep-
ing measures that may be  used to reduce  unpaved
road emissions include clean-up of spillage  on  travel
surfaces or elimination of mud/dirt  carryout onto
roads at construction and demolition sites. Any such
housekeeping method can be employed depending
on the  source, its operation, and  the type  of  dust-
producing material involved.

A recent study indicates that paved  road  cleaning
techniques (such as flushing and vacuuming) may
be used to increase the control efficiency of chemi-
cally treated unpaved roads. [1]  This preliminary
conclusion was drawn based on one test series con-
ducted  on  an unpaved road in  an iron and steel
plant


4.5  Estimation of Cost-Effectiveness of
    Control Options
Development and evaluation of particulate fugitive
emissions control strategies require analysis of the
relative costs of alternative control options.  The pri-
mary goal of any cost analysis Is to provide a con-
sistent comparison of the real costs of alternative
control measures.
The general approach for cost analysis is to calcu-
late the cost-effectiveness for each proposed con-
trol alternative. Cost-effectiveness is the ratio of the
annualized  cost of the  emissions  control  to the
amount of emissions reduction achieved.
Calculation of cost-effectiveness for comparison of
control  measures  or strategies  can  be  accom-
plished in four steps.  First, the alternative  control/
cost scenarios  are selected.  Second,  the capital
costs of each scenario are calculated. Third, the an-
nualized costs for each of the alternatives are devel-
oped. Finally, the cost-effectiveness  is calculated
as a ratio, taking into consideration the level of emis-
sions reduction.
The first step in  the cost analysis is to select a set of
specific  control/cost  scenarios  from  the  general
techniques. The specific scenarios will  include defi-
nition  of  the major cost elements and identification
of specific implementation alternatives for  each  of
the major cost elements. For unpaved  road control
techniques these major cost elements include capi-
tal equipment elements and operation/ maintenance
elements. For example,  the major cost elements for
chemical stabilization of an unpaved road Include:  a)
chemical acquisition; b) chemical storage;  c) road
preparation; d)  mixing the chemical with water; and
e) application of the chemical solution.  The first step
in any cost analysis is definition of these major cost
elements.
For each major cost element,  several implementa-
tion alternatives can be chosen. Options within each
cost element include such choices as buying  or
renting equipment;  shipping chemicals by rallcar,
truck  tanker, or  in  drums  via  truck;  alternative
sources of power or other utilities; and use  of plant
personnel or contractors for construction and main-
tenance. The major  cost elements and the imple-
mentation alternatives for each of these elements
for  the  chemical  stabilization example described
above are outlined in Table 4-1.
The second step is  to  calculate capital costs for
each scenario.  The capital costs of  a fugitive emis-
sions  control system  are  those direct  and  indirect
expenses incurred up to the date when the control
system is placed in operation. These  capital costs
include actual purchase expenses for control equip-
ment, labor and utility costs associated with installa-
tion of the control  system, and system  startup and
shakedown costs.  In  general, direct capital costs
are the  costs of control equipment and the labor,
material,  and utilities  needed  to  install the equip-
ment. Indirect costs are overall costs to the facility
                     16

-------
Table 4-1.    Implementation Alternatives for Stabilization of
            an Unpaved Road
    Cost Elements
     Implementation Alternatives
Purchase and ship
  chemical
Store chemical
Prepare road
Mix chemical and water
  in application truck
Apply chemical solution
  via surface spraying
Sliip in railcar tanker (11,000-22,000
  gal/tanker)
Ship in truck tanker (4,000-6,000 gal/
  tanker)
Ship in drums via truck (55 gal/drum)

Store on plant property
— In new storage tank
-In existing storage tank
    Needs refurbishing
    Needs no refurbishing
— In railcar tanker
    Own railcar
    Pay demurrage
— In truck tanker
    Own truck
    Pay demurrage
— In drums
Store in contractor tanks

Use plant-owned grader to minimize ruts
  and low spots
Rent contractor grader
Perform no road preparation

Put chemical in spray truck
— Pump chemical from storage tank or
  drums into application truck
— Pour chemical from drums into appli-
  cation truck,  generally using forklift
Put water in application truck
— Pump from river or lake
— Take from city water line

Use plant-owned application truck
Rent contractor application truck	
Incurred by the system but not directly attributable
to specific equipment items.  Indirect costs include
engineering/design,   construction/field  expenses,
contractor's  fee,  shakedown/startup and contin-
gency   costs.

The third step in calculating cost-effectiveness is to
calculate annuallzed  costs for the control scenario.
The annualized cost  of a  fugitive  emission control
system includes operating costs such as labor, ma-
terials,  utilities, and  maintenance items  as well as
the annuallzed cost  of the capital  equipment. The
annualization of capital costs is a classical engineer-
ing economics problem, the solution of which takes
Into account  the  fact that money  has time value.
These annualized costs are dependent on the inter-
est rate paid  on borrowed money or collectable by
the plant as Interest (if available capital Is used), the
useful life of the equipment and depreciation rates of
the equipment.
                                   The annualized costs  of  control equipment  can be
                                   calculated from:
       Ca=CRF (Cp) + C0 + 0.5C0
(4-1;
                                                       where:
  Ca  =  annualized costs of control equipment
         ($/year)
  CRF =  Capital Recovery Factor
  0   =  installed capital costs ($)
  Co  =  direct operating costs  ($/year)
  0,5 =  plant overhead factor
The capital recovery factor (CRF) combines interest
on  borrowed funds  and depreciation  into a  single
factor.  It is a function of the interest  rate  and the
overall life of the capital equipment and can be esti-
mated by:
             CRF =•
                                                                              K1+D
                                                                           (1+D   -1
                                                                                                     (4-2)
where:
  I   =   Interest rate (annual % as a fraction)
  n  =   economic life of the control system
         (years)
The final step In calculating cost-effectiveness is to
calculate the actual cost-effectiveness ratio. This
ratio is defined as:
                                                    C*  =•
                                                          A R
                                                                                (4-3)
                                  where:
                                    C*  =   cost-effectiveness ($/mass of emissions
                                            reduced)
                                    C9  =   annualized cost of control equipment
                                            ($/year)

                                    AR =   annual reduction in particulate emissions
                                            (mass/year)
                                  The annual reduction in particulate emissions can be
                                  calculated from the following equation:
                                                     A R = MEc
                                                                                (4-4)
                                                                                 17

-------
where:

 M  =  annual source  extent  (i.e., measure of
        source size or level of activity — such as
        vehicle miles traveled per year)

 E  =  uncontrolled emission factor (i.e.,  mass of
        uncontrolled emissions per unit of source
        extent)

 c  =  average control efficiency expressed as a
        fraction

Collection of the data to conduct a cost analysis can
sometimes  be difficult. If a well defined  system Is
being costed, the best sources of accurate capital
costs are vendor estimates. However, if the system
is  not sufficiently  defined to develop  vendor esti-
mates, published cost data can be used. Published
sources of  cost data  for fugitive  emission control
systems are included in references 2 through 7. Ref-
erences 2  through 4 relate primarily to open dust
control systems while references  5 through  7 can
be used to estimate component costs for both open
dust and process  fugitive emissions  control sys-
tems.

Often, published cost estimates are based on differ-
ent time-valued dollars. These estimates must be
adjusted for inflation so that they reflect the most
probable capital investments for a current time and
can be consistently compared. Capital cost Indices
are the techniques used for updating costs. These
indices provide a general method for updating over-
all  costs without having to complete in-depth stud-
ies of individual cost elements.  Indices  typically
used  for updating control  system  costs  are  the
Chemical Engineering Plant Cost Index, the Bureau
of  Labor Statistics  Metal Fabrication Index,  and the
Commerce  Department Monthly Labor Review,
4.6 References
  1.  Muleskl, G.E.  and C. Cowherd, Jr.  Evaluation
     of  the  Effectiveness of Chemical  Dust  Sup-
     pressants  on  Unpaved Roads. U.S. Environ-
     mental  Protection Agency, Research Triangle
     Park, NC, Draft Final Report, May 1986.

  2.  Cusclno, T., Jr.  Cost Estimates for Selected
     Dust Controls Applied to Unpaved  and Paved
     Roads in Iron and Steel Plants.  EPA Contract
     No. 68-01-6314, Task 17, U.S. Environmental
     Protection  Agency, Region V, Chicago, IL, April
     1984.

  3.  Cuscino, T,, Jr., G. E. Muleski, and C. Cow-
     herd, Jr. Iron and Steel  Plant Open Source Fu-
     gitive  Emission   Control  Evaluation.   EPA-
     600/2-83-110, U.S. Environmental  Protection
     Agency, Research Triangle Park, NC, October
     1983.

  4.  Muleski, G. E., T. Cusclno, Jr., and C. Cow-
     herd, Jr. Extended Evaluation of Unpaved Road
     Dust Suppressants In the Iron and Steel Indus-
     try. EPA-600/2-84-027 (NTIS PB 84-110568),
     U.S. Environmental  Protection  Agency,  Re-
     search Triangle Park, NC, February  1984.

  5.  Neveril, R.V,  Capital and Operating Costs of
     Selected  Air   Pollution   Control   Systems.
     EPA-450/5-80-002   (NTIS  PB  84-154350).
     GARD,  Inc., December 1978.

  6.  Richardson Engineering Services,   Inc.  The
     Richardson Rapid Construction Cost Estimating
     System: Volume I - Process Plant Construction
     Estimating   Standards.  1983-84 Edition.

  7.  Robert Snow Means Company, Inc. Building
     Construction Cost Data. 1979.

-------
                                            Chapter  5
                          Estimation  Of Control System Performance
The  principal control  measures for unpaved  roads
are  wet suppression, chemical  stabilization,  and
paving. This chapter will discuss available perform-
ance data  and design considerations  for each of
these control measures. Other control approaches,
such as physical stabilization, will  be  discussed
briefly.  Work practices, such as speed control on
unpaved travel  surfaces,  will not be discussed.


Performance capabilities of unpaved road dust con-
trols can be affected by four  categories of vari-
ables:  a) control application parameters;  b) vehicle
characteristics; c) properties of the surface  to be
treated;  and d) climatic factors. Furthermore,  be-
cause  of site-to-site  differences  in most of  these
parameters,  the  performance  of  a given control
system can be expected  to vary significantly from
one  application to another. Therefore,  in using  the
control efficiency data presented in  this section,
care must  be taken to document the source  and
control parameters tied to each control efficiency
data set. The selection of a control technique in-
volves the  evaluation  of both performance charac-
teristics and cost  considerations. No Individual table
or figure can provide all the required information.


Most  of the control  techniques  involve periodic
rather than  continuous control application, for exam-
ple,  watering unpaved travel surfaces.  The control
efficiency is cyclic, peaking immediately after  appli-
cation, then eroding with time. Because of the finite
durability of these  control  techniques,  ranging from
hours to months,  it is essential to relate an average
efficiency value to a frequency of application.  For
measures of extended durability such as paving,  the
application  program required to sustain control ef-
fectiveness should be indicated. One common pitfall
to be avoided is using field data collected  soon after
control measure application to represent the  aver-
age control efficiency  over the lifetime of  the meas-
ure.
For a periodically applied control measure, the most
representative value of control efficiency is the time
average, given by:
          C(T) =
         1   r1
         T  0J
c(t) dt
                                           (5-11
where:
  cm

  c(t)
    average control efficiency during pe-
    riod of T days between application (%)

    instantaneous  control  efficiency at  t
    days  after  application  (%),   where
    t 
-------
  t   =   time between applications, hr

The data to support this empirically based mathe-
matical model are shown In Table 5-1 along with ad-
ditional results  from testing of unpaved  haul roads
with water control.  No significant  difference In the
average control efficiency of watering as a function
of particle size has been established to date. As with
all empirical models, equation 5-2 should not be ap-
plied beyond the ranges of independent variable val-
ues tested.
5.2  Chemical Stabilization

5.2.1 Design Considerations
The control application parameters affecting control
performance of chemical dust suppressants are: a)
application intensity;  b)  application  frequency; c)
dilution ratio;  and d) application procedure. Applica-
tion intensity is the volume of diluted solution applied
per  unit area  of  surface   (for example,  l/m2 or
gal/yd2). The higher the intensity, the higher the an-
ticipated control efficiency.  However,  this relation-
ship  applies only to a  point,  because too Intense an
application will begin to run  off the surface.

Application frequency is the number  of applications
per unit of time. The  dilution ratio is the volume of
chemical concentrate to the volume of  water (for
example,  a 1:7 dilution ratio = 1 part chemical to 7
parts water).

The decay in control  efficiency  of a chemical dust
suppressant occurs largely because vehicles travel-
ing over  the  road surface impart  energy to the
treated surface which breaks the  adhesive bonds
that keep fine particles on the surface from becom-
ing airborne.  An  increase  in  vehicle  weight and
speed  accelerates  the  decay  in efficiency  for
chemical treatment of unpaved roads.

Any action which  contributes to  the breaking of  a
surface crust will  adversely affect  the  control effi-
ciency. For example,  the structural characteristics
of an unpaved road  affect  the  performance of
chemical  controls. These characteristics are:  a)
combined subgrade  and base bearing strength, as
measured by the California Bearing Ratio (CBR); b)
amount of fine material (silt and clay) on the surface
of the road; and c) the friability of the road surface
material. Low bearing  strength causes the  road to
flex and rut  in  spots  with  the passage  of heavy
trucks;  this destroys the compacted surface en-
hanced by the chemical treatment.  A  minimum
amount of fine  material in the wearing surface  Is
needed to provide the  chemical binder with the par-
ticle surface  area  necessary for  effective interpar-
ticle bonding.  Finally, the larger particles of a friable
wearing surface material simply break up under the
weight of the vehicles and cover the  treated road
with layer of  untreated dust.

Adverse weather usually accelerates the  decay of
control performance. For example,  freeze-thaw cy-
cles break up the crust formed by chemical binding
agents; heavy precipitation washes  away water-sol-
uble chemical treatments like llgnln sulfonates; and
Intense solar radiation dries out watered  surfaces.
On the other  hand, light precipitation might improve
the efficiency of water extenders and hygroscopic
chemicals like calcium chloride.
Table 5-1.    Field Data on Watering Control Efficiency
Location
N. Dakota
New Mexico
Ohio
Missouri
Mine 1

Mine 1

Mine 1

Mine 2

Mine 2

Reference(s)
2-4
2-4
2-4
2-4
7

7

7

7

7

No. of
Tests
4
5
3
2
—

—

—

—

_

Month
October
July /Aug.
November
September
_

_

_

_

_

Application
Intensity
(L/m2)
0.2
0.2
0.6
1.9
—

_

_

_

_

Average Time
Between
Applications

-------
5.2.2 Performance Data
The  control of dust emissions from unpaved roads
has  received the  widest attention in the literature
(see Table 5-2).  Exposure profiling  and upwind/
downwind  sampling  have been used to measure
control efficiencies for watering and for a range of
chemicals  which bind the surface material  or In-
crease its  capacity  for moisture retention. Tables
5-3  and 5-4 summarize the  measured performance
data for chemical dust suppressants.


The  observed control efficiency decay functions for
several dust suppressants are shown In a series of
nine figures contained in Appendix D (Figures D-1
through D-9). Most  of the data on the figures are
expressed in terms of  vehicle passes rather than
time because vehicle traffic  Is the primary cause of
the loss  of control effectiveness.  The control effi-
ciency decay functions can be used to  derive the
critical relationships  between  average control effi-
ciency and application frequency. Assuming, as a
first  approximation,  that control efficiency decays
linearly from an Initial value of 100%, the average
control efficiency for a given frequency of applica-
tion is twice the value at the end of the decay  cycle.


The  quality rating of control  performance data for a
periodically applied control  measure  must address
the reliability of the average control  efficiency for
the  particular application frequency  tested.  Obvi-
ously, a spread In  the measured values of Instanta-
neous control efficiency is  expected as the  effi-
ciency decays. The quality rating must be based on
how well the Instantaneous values  fit a decay func-
tion. At the time of this writing, mathematically de-
rived decay functions were  available for  only a few
of the control measures. Therefore, no quality rat-
Ings were  assigned  to  the  control efficiency data
presented.
 Table 5-2.    Classification of Tested Chemical Road Dust
            Suppressants
Dust
Suppressant
Category
Petroleum-based




Lignosulfonates

Salts



Polymers
Surfactants
Mixtures

Trade Name
Petro Tac®
Coherex®
Arco 2200®
Arco 2400®
Generic 2 (QSI*
Lignosite
Trex®
Peladow®
LiquiDow®
Dustgard®
Oil Well Brine
Soil Sement®
Biocat®
Arcote 220® /
Flambinder*
Number of
Valid
Controlled
Tests"
13
130
20
91
8
73
3
1
34
11 (17)
4
32
3
4

Reference
Numbers
2-4,6
2-4,6,8-10
7
11
6
11
12
13
7
11
8
6,7
7
8

 "Numbers without parentheses represent total suspended particulate
  (TSP) and numbers in parentheses represent respirable particulate
  (RP).
 'This is a petroleum resin product developed at the Mellon Institute for
  the American Iron and Steel Institute.
5.3  Paving
The control efficiencies afforded by paving unpaved
road segments can be estimated by comparing the
AP-42 emission factors for the unpaved  and paved
road conditions. The emission factor for the paved
road condition requires an estimated silt  loading on
the paved surface.  An  urban street  dust  loading
model[14] can be used to estimate silt  loadings as a
function of traffic volume. The model Is  expressed
as follows:
In most of the extended tests of control perform-
ance, efficiency values were found to decay  with
vehicle passes (and time)  after application. In Fig-
ures D-1  through  D-3 and D-9.  the  best-fit linear
decay functions determined by least-squares analy-
sis are shown. In Figures D-4 through D~8, the data
points are connected by line segments.


Apparent Increases In control efficiency with vehicle
passes were observed in several test series from
Reference 7. This  behavior Is thought to be the re-
sult of moisture effects on the uncontrolled emission
rate, which was measured simultaneously with each
controlled  emission  rate.   In  other  words   the
efficiency values were not always referenced to a
dry uncontrolled emission rate.
               sL = 21,3  (ADT)"
                                           (5-3)
where:
  sL      =  silt loading,  oz/yd2 (g/m2)
  ADT    =  average daily traffic, vehicles/day
This  urban model  was developed from silt loading
measurements in five urban areas  (Baltimore;  Buf-
falo;  Granite City, IL; Kansas City; and St. Louis). All
of the streets were paved edge to edge  and had
curbs and gutters.  The calculated  control  efficien-
cies  for paving are usually on  the order of  90%.

5.4  Other Control Alternatives
A number of open source control techniques have
not yet been quantitatively evaluated for control effi-
                                                                           21

-------
Table 5-3.   Summary of Major Unpaved Road Dust Suppressant Control Efficiency Tests


Ref.
No.
2-4






9-10

11










12




Dust
Suppressant
Tested
Coherex®
Coherex®


Coherex®


Coherex®
Coherex®
Coherex®

Arco 2400®

Lignosite
(50% solids)
Dustgard®

Peladow®


Trex®
(ammonium
lignin
sulfonate)
No. of
Valid
Controlled
Tests
2
4


5


4
2
91

91

73

11 (17)*

1


3





Test
Site
Steel plant
Steel plant


Steel plant


Steel plant
Steel plant
Public road

Public road

Public road

Public road

Surface coal
mine

Taconite mine





Measurement
Method"
P
P


P


P
P
U/D

U/D

U/D

U/D

P


P




Days
After
Application
<7
1-2


1-2


Unknown
14-15
30-270

30-270

30-270

3-60

90


<7



Application
Intensity
(gal sol/
yd2)
Unknown
0.19


0.19


Unknown
Unknownd
l.S'/0.33f

3.5

0.125V0.25/

0.5

0.6


0.08



Dilution
Ratio
(gal chem:
gal H2O)
1:9
1:6


1:6


Unknown
1:4-1:7
\:5'/-[:9f

1:0

M'/l:!/

1:0*

1:2


1:4



Average
Vehicle
Weight
1ST)
3
50


3


4-19
26
4

4

4

4

3


110-127




Control
Efficiency*
(%)
91C
TP: 92-98
TSP: 91-96
FP: 90-97
TP: 94-100
TSP: 91-99
FP: 92-97
TP:81
TP:99
TSP: 53
RP: 64
TSP: 96
RP:57
TSP: 46
RP:42
TSP: 48
RP: 24
TSP: 95
RP:95
FP.-88
TSP: 88



"P = profiling; U/D = upwind/downwind.
*TP = total paniculate; TSP = total suspended paniculate; RP = respirable paniculate; FP = fine paniculate.
cParticles of less than 30^/m stokes diameter (47)jm aerodynamic diameter).
dFour applications; testing began 2 weeks after fourth application.
"Initial application.
^Repeat application.
6Eleven TSP tests and 17 RP tests conducted.
^Dilution as shipped unknown; no further dilution.
clency. These methods include physical stabilization
of unpaved surfaces, mud/dirt carryout control, and
vegetative stabilization. Vegetative stabilization can
be used only when the material to  be stabilized Is
inactive and will remain so for an extended time pe-
riod; therefore,  the technique has limited, if any, ap-
plication to controlling unpaved road emissions. Ref-
erences which  describe  these  control  alternative
methods in further detail are available  in the litera-
ture. [15-20]
5.5 Calculation  of Controlled Emission
     Rate
Calculation  of the  estimated emission rate for a
given source requires data on  source extent, un-
controlled emission  factor,  and  control efficiency.
The mathematical  expression for this calculation Is
as follows:
                   = ME  (1 -c)
                                             (5-4)
where:
  R  =   estimated controlled mass emission rate

  M  =   source extent

  E  =   uncontrolled emission factor, i.e., mass of
         uncontrolled emissions per unit of source
         extent

  c  =   fractional efficiency of control

The  source  extent is the appropriate measure  of
source size or level of activity which Is used to scale
the  uncontrolled  emission factor to  the particular
source In question. For unpaved roads, the source
extent Is reported In  vehicle miles traveled per year
(VMT/yr)  or vehicle  kilometers  traveled  per year
(VKT/yr). Source extent Is calculated by multiplying
the average daily traffic count  (ADT) by the length of
                      22

-------
Table 5-4.   Summary of Major Unpaved Road Dust Suppressant Control Efficiency Decay Function Tests

Dust
Ref. Suppressant
No. Tested
2-4 Petro Tac®
Coherex®
Coherex®
8 Coherex®
Oil well brine
Arcote
220® / Flam-
binder® Mixture
7 LiquiDow®


Soil Sement®

Biocat®
Flambinder®


Arco 2200®

6 Petro Tac»
Coherex®
Generic 2 (QS)
Soil Sement®
No. of
Valid
Controlled
Tests
8
8
4
5
5


5
8
18
8
12
12
3
4
16
8
16
4
5
6
8
8



Test Site
Steel plant
Steel plant
Steel plant
Steel plant
Steel plant


Steel plant
Surface coal mine 1
Surface coal mine 2
Surface coal mine 3
Surface coal mine 1
Surface coal mine 2
Surface coal mine 3
Surface coal mine 1
Surface coal mine 2
Surface coal mine 3
Surface coal mine 2
Surface coal mine 3
Steel plant
Steel Plant
Steel Plant
Steel Plant


Measurement
Method"
P
P
P
U/D
U/D


U/D
P
P
P
P
P
P
P
P
P
P
P
P
P
P
P

Days
After
Application
2-116
7-41
4-35
17-35
17-35


17-35
14-49
7-28
14-21
21-42
7-35
7-14
14
7-28
7-21
7-28
7
13-30*
13-30*
13-30*
13-30*
Application
Intensity
(gal sol/
yd2)
0.70
0.83C
1.0d'e
1.5
3.8


1.9
0.27-0.6
0.27-0.6
0.3-0.6
1.9-3.0
1.0
2.0
0.5-2.1
0.5-2.0
1.8
0.9-2.8
1.1-2.3
0.21*/0.35'
0.21*/0.36'
0. 14" / 0.46'
0. 16" / 0.44'
Dilution
Ratio
(gal chem:
gal H20)
1:4
1:4C
1:8d.e
1:4
Neat


1:4
1:1.6
1:1.6
1:1.9
1:8.3
1:6.4
1:20,000
1:4.6
1:4.6
1:4.6
1:7
1:6.1
5:1
5:1
5:1
5:1
Average
Vehicle
Weight
(ST)
23-34
27-50
31-56
3
3


3
28-66'
44-83'
70-276'
22-89/
38-82'
70-276'
16-65'
51-69/
70-276'
18-80'
70-276'
9.7-24
9.6-24
9.3-24
9.6-24
Efficiency
Decay
Function
Figure6
D-1
D-2
D-3
D-4
D-4


D-4
D-5
D-5
D-5
D-6
D-6
D-6
D-7
D-7
D-7
D-8
D-8
D-9
D-9
D-9
D-9
°P = profiling; U/D = upwind/downwind.
'Figures are contained in Appendix D.
'Initial application.
^Repeat application.
"Retreated 44 days after the initial application.
A/alues represent range of haul truck weights from empty to loaded vehicles.
 Haul truck has 10 wheels at mines 1 and 2 and six wheels at mine 3.
*Days after second application.
"First application.
'Second application, 40 days after first application.
the unpaved road. Each vehicle has a disturbance
width equal to  the width of a traffic lane.

The uncontrolled emission factor is calculated by us-
ing predictive equations  (see Chapter 3) or meas-
ured using either the upwind/downwind or exposure
profiling methods (see Chapter 2). Normally, the un-
controlled emission factor incorporates the effects
of natural mitigation  (such  as  rainfall),  although
emission factors developed as a result of testing un-
der specific conditions may or may not account for
natural mitigation.

Fractional  control  efficiency can  be  determined,
through a testing program (before and after testing
of the  application of  the  treatment  scheme)  or
through estimates available In the literature based on
tests  performed under similar conditions  (see Fig-
ures D-1 through D-9 in Appendix D and Tables 5-1
through 5-4).  There  is  also  a  simple model dis-
cussed in this chapter (see equation 5-2) which can
be used to estimate control efficiency for water sup-
pression.

The equation to estimate controlled mass emission
rate is a fairly simple mathematical expression.  The
emission rate is dependent on only three variables
— the source extent, the uncontrolled emission  fac-
tor,  and  the  fractional control  efficiency.  Care
should be  used in selection or estimation of these
three data variables. A high or low estimate of  any of
the variables could yield a misrepresentative value
for the estimated controlled mass emission rate. For
example,  an inflated  uncontrolled emission  factor
and an unusually  high  fractional  control efficiency
could show  a greater  Improvement  In ambient air
quality than  actually will be  realized. As  with  any
mathematical expression,  the final result is only as
good  as the  data  used in the equation.
                                                                             23

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5.6 Alternate Indicators of  Control
     Performance
Actual field measurement of controlled and uncon-
trolled emissions from unpaved  roads is expensive
and time consuming. Studies have been conducted
in  an  attempt  to  develop an alternate method  to
monitor  the effectiveness of dust control programs.
Early preliminary studies showed a strong correla-
tion between the  efficiency of a control technique
and the silt content of surface material. [2,6,21]
Later long-term studies indicated no significant cor-
relation   between   silt   content  and   control
performance. [3,6] The studies  completed to date
used various types of chemical dust suppressants to
control emissions.

Another  recent study indicates that the AP-42 emis-
sion factor equation for industrial paved road emis-
sions  can  be used  to conservatively overestimate
unpaved road emissions controlled  by chemical dust
suppressants. [6]  The paved  road emission  factor
equation tends to  overestimate emissions by  a fac-
tor of 1.5  to 2 when applied to situations of typical
chemical suppressant  application intensities  over
the first  30 days.  [6] The emission factor equation
for industrial paved roads is discussed in detail in ref-
erence 22.
5.7 References
  1.  Letter to  Laxmi Kesari,  U.S.  Environmental
     Protection Agency,  Washington, D.C., from
     Chatten  Cowherd, MR),  regarding control effi-
     ciency achievable by watering, October  21,
     1982.

  2.  Cuscino.  T.. Jr., G.E.  Muleski,  and C. Cow-
     herd, Jr. Iron and Steel  Plant Open Source Fu-
     gitive    Emission     Control     Evaluation.
     EPA-600/2-83--110.  U.S. Environmental Pro-
     tection Agency.  Research Triangle  Park. NC,
     October 1983.

  3.  Muleski.  G.E..  T. Cuscino,  Jr.,  and C. Cow-
     herd, Jr. Extended Evaluation of Unpaved Road
     Dust Suppressants in the Iron and Steel Indus-
     try.  EPA-600/2-84--027,  U.S.  Environmental
     Protection Agency,  Research  Triangle Park,
     NC, February 1984.

  4.  Cowherd. C., Jr., R. Bohn, and T. Cuscino, Jr.
     Iron  and Steel Plant  Open Source  Fugitive
     Emission Evaluation.  EPA-600/2-79-103 (NTIS
     PB-299  385),  U.S.  Environmental  Protection
     Agency,  Research  Triangle Park,  NC, May
     1979.
5.  U.S. Department of Commerce, Environmental
   Services Administration. Climatic  Atlas of the
   United States. June 1968, reprinted by the Na-
   tional Oceanic and Atmospheric Administration
   in 1983.

6.  Muleski, G.E. and  C.  Cowherd, Jr. Evaluation
   of the Effectiveness  of Chemical Dust  Sup-
   pressants on  Unpaved Roads. U.S.  Environ-
   mental Protection  Agency,  Research  Triangle
   Park, NC,  Draft Final Report, May  1986.

7.  Rosbury, K.  D., and R. A. Zimmer. Cost-Effec-
   tiveness  of  Dust Controls   Used  on Unpaved
   Haul Roads - Volume 1 of 2. Draft Final Report,
   U.S.  Bureau of Mines, Minneapolis, MN,  De-
   cember 1983.

8.  Russell, D.  and S.  C.  Caruso.  A Study of
   Cost-Effective  Chemical  Dust Suppressants
   for Use on Unpaved Roads in the Iron and Steel
   Industry,  American Iron and Steel Institute, De-
   cember 1982.

9.  Energy Impact  Associates.  An  Alternative
   Emission Reduction Option for Shenango Incor-
   porated Coke and  Iron Works,  January 1981.

10. Roffman, A., et al. A Study  of Controlling Fugi-
   tive  Dust Emissions for Nontraditional Sources
   at the United States Steel Corporation Facilities
   in Allegheny County, Pennsylvania. Report pre-
   pared for U.S. Steel  Corporation, Pittsburgh,
   PA. December 1981.

11. Schanche, G. W.,  M. J. Savoie, J. E. Davis, V.
   Scarpetta, and P. Weggel. Unpaved Road Dust
   Control Study (Ft.  Carson,  CO). Draft Final Re-
   port  for  U.S.  Army Construction Engineering
   Research Laboratory,  Champaign. IL, October
   1981.

12. Cuscino, T., Jr. Taconite Mining Fugitive Emis-
   sions  Study.  Minnesota  Pollution   Control
   Agency, Roseville, MN, June 1979.

13. Axetell. K.  J.  and C.  Cowherd,  Jr. Improved
   Emission Factors for Fugitive Dust from West-
   ern Surface Coal Mining Sources  - Volumes I
   and    II.    EPA-600/7-84-048    (NTIS   PB
   84-170802),  U.S. Environmental Protection
   Agency,  Cincinnati, OH, March 1984.

14. Cowherd, C., Jr.  and P.J.  Englehart. Paved
   Road  Paniculate  Emissions.  EPA-600/7-84
   -077 (NTISPB84-223734),  U.S. Environmental
   Protection  Agency,  Research Triangle  Park,
   NC,  July 1984.
                    24

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15. Kinsey, J.S., et al. A Review of Traditional and
   Nontraditional Techniques for the Control of Fu-
   gitive   Particulate  Emissions.  Paper   No.
   80-20.4, 73rd Annual Meeting of the Air Pollu-
   tion Control  Association.  Montreal, Quebec,
   June 22-27, 1980.

16. Chepil, N.S., and N.P. Woodruff.  "The Physics
   of Wind Erosion and Its Control." in  Advances
   in Agronomy.  Vol.  15, Academic Press.  NY,
   1963.
17. Bonn, R., et al.  Dust Control for Haul Roads.
   Contract No. J0285015, U.S. Bureau of Mines,
   Washington, D.C.. February  1981.

18. Albrecht, S.C.. and E.R. Thompson. Impact of
   Surface Mining on Soli Compaction  in the Mid-
   western U.S.A. Contract J0208016, U.S. Bu-
   reau  of Mines,   Minneapolis,  MN.  February
   1982.
19. Donovan,  R.P., et al. Vegetative Stabilization
   of Mineral  Waste Heaps.  EPA-600/2-76-087
   (NTIS PB-252 176), U.S.  Environmental Pro-
   tection  Agency,  Research Triangle Park,  NC,
   April 1976.
20. Englehart,  P.. and  J.  Kinsey. Study of Con-
    struction Related Mud/Dirt Carryout. EPA Con-
    tract No.  68-02-3177,  Work Assignment 21.
    U.S. Environmental  Protection Agency. Region
    V. Chicago, IL. July 1983.


21. Cuscino. T., Jr., G.E.  Muleski, and  C.  Cow-
    herd, Jr. Determination of the Decay in Control
    Efficiency of Chemical Dust Suppressants on
    Unpaved Roads. In: Proceedings of the  Sym-
    posium on Iron and Steel Pollution Abatement
    Technology, Pittsburgh. PA. November 16-18,
    1982. EPA-600/9-83-016, U.S. Environmental
    Protection  Agency,  Research Triangle  Park.
    NC,  April 1983.


22. U.S. Environmental Protection Agency. Compi-
    lation of Air Pollution Emission Factors, Volume
    1: Stationary Point  and Area  Sources. Fourth
    Edition, Supplement A, AP-42. Office of Air
    Quality Planning  and Standards, Research Tri-
    angle Park, NC,  October 1986.
                                                                      25

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                                            Chapter 6
                      Fugitive Emissions Control Strategy Development
Developing a fugitive emissions control strategy for
an Industrial facility can be accomplished through a
five step process:

    Step 1:  Identify and classify all fugitive sources.

    Step 2:  Prepare an emissions inventory.

    Step 3:  Identify control alternatives.

    Step 4:  Estimate control system performance.

    Step 5:  Estimate control costs and cost-effec-
            tiveness.

This section will illustrate these five steps for a hypo-
thetical rock crushing plant with a rated capacity of
300  ton/hr  and an actual  operating rate  of  150
ton/hr. As shown in Figure 6-1,  the facility Includes a
primary,  secondary,  and tertiary crusher;  associ-
ated materials  sizing,  handling, and  storage facili-
ties;  a paved road; and an unpaved haul road.  The
following subsections describe the control strategy
evaluation for  this facility.  Emphasis  will be placed
on  calculating emissions,  developing   a  control
scheme, and calculating control costs for unpaved
roads,  as this  is the primary thrust of this report.


6.1 Identifying/Classifying  Fugitive
    Emission Sources
The fugitive  paniculate emission sources for this fa-
cility, identified schematically in Figure 6-1, include:

 •   A primary crusher

 •   A secondary crusher

 •   A tertiary crusher

 •   Two screens

 •   A truck dump station

 •   Six  conveyor transfer points

 •   Vehicular traffic on unpaved haul road between
     the  quarry and the plant

 •   Windblown emissions from product storage

 •   A front-end  loader  for loadout of  customer
     trucks
  •  Vehicular traffic on a paved road between the
     loadout area and the property line.

6.2  Preparing an  Emissions Inventory
Calculation  of the estimated  emission  rate  for  a
given source requires  data  on source extent,  un-
controlled emission factor,  and control efficiency.
The  mathematical expression for this calculation Is
as follows:
               R-ME (1-c>
                                           (6-1;
where
  R  =   estimated mass emission rate

  M  =   source extent

  E  =   uncontrolled emission factor (I.e., mass of
         uncontrolled emissions per unit of source
         extent)

  c  =   fractional efficiency of control

For this plant we assume that the Initial control effi-
ciency for all sources Is 0%. The uncontrolled emis-
sion factors for the  five  open dust sources,  the 11
process sources, and the source extents are shown
in Table 6-1.

Plant and process data for the hypothetical crushing
plant  used to calculate  the  emission  factors are
shown in Table 6-2.

The uncontrolled emission factor for unpaved roads
as presented in Reference  1 Is:
where

 E   =

 k   =

 s   =

 S   =
                                 (6-2)


emission factor,  Ib/VMT

particle size multiplier (dlmenslonless)

silt content of road surface material (%)

mean vehicle speed  (mph)
                                                27

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Figure 6-1.  Process flow diagram of hypothetical rock crushing plant.
         Dump Truck
  KEY-.  \  Indicates fugitive emission point
                                                   Y/////////////////////////7/
 W  =  mean vehicle weight  (tons)

 w  =  mean number of wheels

 p  =  number of days with at least 0.01 In. of
        precipitation per year

Plant data required to calculate the  emission factor
are  silt content, vehicle speed,   mean  vehicle
weight,  and mean number  of  wheels.  These are
taken from  the hypothetical plant data presented in
Table 6-2.

Using the particle size multiplier for TSP and precipi-
tation frequency from Reference 1,  the  resultant
emission factor for the haul road is:
  - 8.86 Ib/VMT


where

 k   =  0.80 for particles < 30 pimA (see Refer
        ence  1)

 s   =  7.3%  (given in Table 6-2)

 S   =  20 mph  (given in Table 6-2)
 W  =  40 tons (given in Table 6-2)

 w  =  6 (given in Table 6-2)

 p  =  140 (see Reference 1, as applied to lower
        Great Lakes)

The information in Tables 6-1 and 6-2 can be used
to  calculate the source extent for the unpaved haul
road as follows:
           days       vehicles         miles
   M = 240 ——  X100-—:	  x  6.3—rr-r
            yr          day           vehicle
     = 151,200 VMT/yr

The data on source extent and emission factors can
be substituted into equation 6-1 to obtain the follow-
ing uncontrolled estimated mass  emission  rate for
the unpaved haul road:
    R= 151,200
                                ton
                 yr
                       VMT    2000 Ib
x (1-0)
      - 670 ton/yr
Table 6-3 summarizes source  extents and uncon-
trolled emission rates for the unpaved haul road as
well as the other particulate emitting sources for the
hypothetical crushing plant.
                    28

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 Table 6-1.    Uncontrolled Emission Factors for Hypothetical Crushing Plant

      Source                           Emission Factor Equation"'*
 Unpaved haul road
                                                          Emission Factor
     / s \  /S\ /WX07  /W\05 /365-p\
k(5-9) UJ  (lo) (T)    (-r)    bar)
                                         8.86lb/VMT
 Truck dump and
 Front end loader
 Storage pile erosion
        W00018)
        W0.0018) -
                  MY\
                 IT;  Uj

          17 f M  /365-p\  /f N
          1'7 U5J  iTarV  ClBV
                                         Dump - 0.00019 Ib/ton
                                         Loader-0.000529 Ib/ton
                                         3.2 Ib/acre/day
 Paved roads
(v)
                        -          )
                                                                                0.398 Ib/VMT
 Primary crushing
 Secondary crushing

 Tertiary crushing
 Screening

 Conveyor transfer
                                                    0.28 Ib/ton0
                                                    0.28 Ib/ ton"
                                                    1.85lb/ton"
                                                    0.16/ton/screen"
                                                    0.0034 Ib/ton/transfer point"
 "Reference 1.
 b Refer to Table 6-2 for description of variables used in equations.
6.3 Identifying  Control Alternatives
Based on the emissions inventory for the hypotheti-
cal facility,  the  primary focus  of  control should be
vehicular traffic  on the  unpaved haul road with sec-
ondary  emphasis  on  certain   process  fugitive
sources (primary, secondary, and tertiary crushing,
and screening operations).


Three methods  can be used to  control emissions
from  unpaved roads — wet suppression, chemical
stabilization, and physical  stabilization. For this hy-
pothetical facility,  chemical  stabilization was  se-
lected as the most feasible means. Wet suppression
was rejected  because of the difficulty  in maintaining
watering systems over relatively  long stretches of
roads  in rural areas. Chemical rather  than physical
stabilization was selected because of the temporary
nature of the  facility.


The two  principal means  of  controlling emissions
from  crushing and screening  operations are  wet
suppression and capture hoods with an associated
air  pollution control device. Wet  suppression  was
selected as the preferred  control because of diffi-
culties associated with the operation and mainte-
nance of  capture/collection  systems  on mobile
crushed  stone facilities.
                         6.4 Estimating  Control Efficiencies
                         A petroleum-based resin, Coherex®, was selected
                         for  chemical  dust  suppression  on  the unpaved
                         road.9  The data in Table 5-3 and Appendix D sug-
                         gest that an average control efficiency of 90% can
                         be achieved for up to about 5,000 vehicle passes.

                         Only limited test data are available on the effective-
                         ness of  wet  suppression systems  In  controlling
                         emissions from minerals processing  operations.

                         Based on these limited data, the control efficiency
                         estimates are: [2,3]

                               Primary crusher: 80%
                               Secondary crusher: 65%
                               Tertiary crusher: 50%
                               Screens: 50%

                         6.5 Calculating Cost and  Cost
                              Effectiveness
                         The procedure for calculating  the estimated cost
                         and the associated cost  effectiveness of controlling
                         vehicular emissions by chemical stabilization  of the
                           Mention of trade names or commercial products does not
                           constitute endorsement or recommendation for use.
                                                                           29

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 Table 6-2.    Plant and Process Data for Hypothetical Facility    Table 6-3.    Source Extents and Uncontrolled Emission Rates
                                                                     For Hypothetical Crushing Plant
 Process Operation
  Operating rate = 150ton/hr
  Operating hours =  1,920hr/yr
  No. of days with at least 0.01 in. rain (p) = 140°

 Haul Road
  Average daily traffic = 100 vehicles/day*
  Average vehicle weight (W) = 40 tonsc
  Average number of vehicle wheels (w)  = 6
  Average capacity =16 yd3
  Average vehicle speed (S) = 20 mph
  Roadway length =  6.3 miles
  Roadway width = 30 ft
  Roadway silt content (s) = 7.3%
  Particle size multipler (k) = 0.8 (for particles < 30ymA)"

 Truck Dump
  Material silt content (s) = 0.5%
  Mean wind speed (U) = 5 mph
  Drop height IH) =  10 ft
  Material moisture content (M) = 2%
  Average capacity (Y) = 16 yd3
  Particle size multiplier (k) = 0.73 (for particles  <30^mA)a

 Storage Piles
  Storage pile silt content (s) = 2.2%
  Storage pile size =  0.5 acre
  % time unobstructed wind speed > 12 mph (f) = 20%

 Front End Loader
  Aggregate silt content (s) = 1.6%
  Mean wind speed (U) = 5 mph
  Drop height (H) = 5 ft
  Aggregate moisture content (M) = 2%
  Loader dumping capacity (Y) = 3 yd3
  Particle size multiplier (k) = 0.73 (for particles  <30^mA)B

 Customer Traffic
  Road augmentation factor (I) = 1°
  No. of travel lanes (n) = 2
  Surface silt content (s) = 6%
  Surface dust loading (L) =  1,000 Ib/mile
  Average vehicle weight (W) = 30 tons'*
  Roadway length =  0.5 miles
  Average daily traffic = 120 vehicles/day'
  Particle size multiplier (k) = 0.86 (for particles < 30^mA)°
 "Reference 1.
 *50 round trips per day.
 'Tare +  load - 2 = 28 + 24/2 = 40 tons.
 dTare  +  load  + 2 = 20 + 20/2 = 30 tons.
 "60 round trips per day.
unpaved haul road at the hypothetical plant Is as fol-
lows:

Step  1 - Determine the Times Between Applications
      and the Application Intensity. The following ap-
      plication parameters are taken from Table 5-4
      and Figures D-2 and D-3 in Appendix D.
      Initial application intensity = 0.83  gal of 20%
      solution/yd2
Source
Unpaved haul road
Truck dump
Storage pile erosion
Front end loader
Paved roads
Primary crushing
Secondary crushing
Tertiary crushing
Screening
Conveyor transfer points

Source Extent
151,200 VMT/yr
288,000 ton/yr
182 acre day/yr
288,000 ton/yr
14,400 VMT/yr
288,000 ton/yr
288,000 ton/yr
288,000 ton/yr
288,000 ton/yr
288,000 ton/yr
Total
TSP Emissions
(ton /year)
670
0.027
0.29
0.076
2.87
40
40
266
46
3
1068.3
      Reapplication intensity = 1.0 gal of 12% solu-
      tion/yd2
      Application frequency = once every  44 days
Step  2  - Calculate the Required Number of Annual
      Applications and Number of  Treated Miles.

M            ,         .,          365 days/yr
No. of  annual  applications = 44 days/application

                            = 8.3 applications/yr
No.  of treated  _ R «    miles
miles per year  ~  '   application
x 8.3
applications
      yr
                 = 52  treated miles/yr
Step 3 - Select the Desired Program Implementation
      Plan.  The decision   is  made to  purchase
      rather than rent  equipment. The implementa-
      tion plan and associated costs are outlined In
      Table 6-4. Scenario 2.
Step 4  - Calculate Total Annual Cost.  To annualize
      the capital investment, the capital cost shown
      in  Table  6-4,  Scenario 2, is simply multiplied
      by a capital  recovery factor which is calcu-
      lated as follows:
                 CRF =
                        (1 +i)n-  1
where:
  i   =   annual interest  rate fraction
  n  =   number of payment years
                       30

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Assuming i = 0.15 and n = 10 years,

                          10
       CRF = —
               0.15 (1.15)
               (1.15)'" -1
= 0.199252
The  annual operation and maintenance costs (C0 )
are calculated as follows:
 C0 = S4,785/treated mile x 52 treated miles/yr +
       $630/actual mile x 6.3

     = $253,000/yr
 actual miles
      yr
The total annualized cost (Ca )  Is:
     Cn=  CRF  (Cp) + C0 +0.5(C0 )
        =  (0.199252) (105,000) +253,000
           + 0.5(253.000)
        = $400.000

Because the costs in Table 6-4 are based on a road
width of 40 ft, it is necessary to scale total cost by
actual road width  of 30 ft:

Actual total annualized cost = $400,000/yr x
                           = $300,000/yr
                                            40 ft
Step 5 - Calculate Cost-Effectiveness (C*). Cost-ef-
      fectiveness is defined as:
                  C* =  ^i
                        AR

where

  Ca =   total cost from Step 4

  AR =   reduction in TSP emissions, i.e.  the prod-
         uct of the uncontrolled emission rate  and
         the fractional efficiency of control
  C* -
          $300,000/yr
         770 ton/yr x 0.9

     = $433/ton of TSP emissions reduced
The above calculations to determine the cost-effec-
tiveness ratio for control scenario 2 show that It will
cost approximately $433  to reduce  emissions by
one ton  from this unpaved road. To determine the
most cost-effective emissions reduction plan for the
                         Table 6-4.   Cost Comparison for Two Selected
                                    Implementation Scenarios"

                                                           Cost
                           Alternative Approach
                       Capital
                     investment
                        <$)
                                                            Unit O&M cost*
                                                          $/Treated
                                                            mile
       $/Actual
         mile
SCENARIO 1 —Rent Where Possible to Minimize Capital Expenditure
Purchase chemical and
  ship in truck tanker                   4,650
Store in contractor tank                   140
Rent contractor grader to
  prepare road                                  1,200
Take water from city line                  20
Rent contractor truck"                    500
                                                                                       5,310
                                                                     1,200
                          SCENARIO 2-Buy Equipment Where Possible
                          Purchase chemical and
                           ship in truck tanker
                          Store in newly purchased
                           storage tank
                          Prepare road with plant
                           owned grader
                          Pump water from river or
                           lake
                          Apply chemical with plant
                           owned application
                           truckc
                       30,000



                        5,000


                       70,000
                       105,000
                                                                                       4,650
135
          630
                                                           4,785
          630
                          "1983 Dollars.
                          *Plant overhead costs are included.
                          'Includes labor to pump water and chemical and apply solution.
                                                      facility, a similar series of calculations must be per-
                                                      formed for each possible control scenario,
                          6.6 References
                           1.  U.S. Environmental Protection Agency. Compi-
                               lation of Air Pollution Emission Factors, Volume
                               1:  Stationary Point and Area Sources. Fourth
                               Edition, Supplement  A,  AP-42,  Office of Air
                               Quality Planning and  Standards,  Research Tri-
                               angle Park, NC, October  1986.

                           2.  Page,  S.J. Evaluation of  the Use of Foam for
                               Dust Control on  Face Drills and Crushers.  Rl
                               8595,  U.S.  Bureau  of  Mines,  Washington,
                               D.C., 1982.

                           3.  Elmutis, E.C., T.R. Blackwood, and  R. Wach-
                               ter. Particulate Emissions from Stone Crushing
                               Operations.  Monsanto Research Corporation,
                               Dayton, OH,  November 1979.

                           4.  Cusclno, T.,  Jr.  Cost Estimates for Selected
                               Fugitive Dust Controls Applied to Unpaved and
                               Paved Roads In Iron and Steel Plants,  Final Re-
                               port for Region V, U.S. Environmental Protec-
                               tion Agency,  Chicago, IL, April 1984.
                                                                            31

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                                           Appendix A
                                       Glossary Of Terms
Air Quality Model - An equation or series of equa-
tions which predict a source Impact on air quality.

Annualized Cost - The  control technique cost ($/yr)
calculated as annual cost over the useful life of the
equipment  (or application). The annualized cost Is a
sum of the annualized purchase and installation cost
(I.e., capital costs) and the annual maintenance and
operating costs.

Application Frequency  - Number of applications of a
control measure to a specific source per unit time;
equlvalently, the Inverse of time between  two appli-
cations.

Application Intensity -  Volume of water or chemical
solution applied per unit area of the treated surface.

Capital Recovery Factor - The factor which  is used
to annualize capital investment to  obtain the  annual-
ized capital cost. The  capital  recovery factor is a
function of  annual interest rate and the total number
of payment years.

Chemical Stabilization  - The use of chemical dust
suppressants for the control of fugitive partlculate
emissions from open dust  sources or material stor-
age piles.

Control Efficiency - Percent decrease in  controlled
emissions from the uncontrolled state,

Cost-Effectiveness - The cost of control per  unit
mass of reduced particulate emissions.

Dilution  Ratio  - Ratio  of  the  number  of parts of
chemical to the number of parts of solution,  ex-
pressed in percent (e.g., one part chemical to four
parts water corresponds to a 20% solution).

Dry Sieving - The sieving  of oven-dried aggregate
by  passing it through  a series of screens  of  de-
scending opening size.

Dust  Suppressant -  Water  or  chemical solution
which, when applied to  an aggregate material, binds
suspendable particulate to larger particles.

Emission Factor - An estimate of the mass of un-
controlled emissions released to the atmosphere
per unit of source extent (e.g.. Ib/VMT).
Emission Rate - Mass of emissions  generated per
unit time (e.g.,  Ib/hr).
Emissions Inventory - A listing and classification of
all sources of emissions, and  the quantity of emis-
sions generated for a specific geographic area or
facility.
Erosion Potential - Total quantity of erodible parti-
cles, in any size range, present on the surface (per
unit area) prior to the onset of erosion.
Exposed Area - Outdoor ground area subject to the
action of wind and protected by little or no vegeta-
tion.
Exposure Profiling Method - A method for quantify-
ing fugitive emissions which involves the isokinetic
measurement of  airborne  pollutant  immediately
downwind of  the source  by means of simultaneous
multipoint sampling over the effective plume cross
section.
Fine Particulate  (FP) - Particulate matter less than
or equal to 2.5 (im in aerodynamic diameter.

Fugitive Dust - Solid particles  generated by the ac-
tion of wind or machinery which are not emitted from
a stack, duct, or flue.
Fugitive Emissions - Emissions not originating from
a stack, duct, or flue.
Inhalable Particulate  (IP) -  Particulate  matter less
than or equal to  15 p,m aerodynamic diameter.
Materials Handling - The receiving and transport of
raw, intermediate and  waste  materials,  including
barge/railcar  unloading, conveyor transport and as-
sociated conveyor transfer and screening stations.
Moisture Content -  The  mass portion of an aggre-
gate sample consisting of unbound moisture as de-
termined from weight loss In oven drying.
Open Dust Sources - Sources of fugitive emissions
that entail generation of particulate  matter  by the
forces  of wind  or machinery  acting on exposed
(i.e., open)  materials where no physical or chemi-
cal change occurs to the particle-generating mate-
rial.
Particle Diameter, Aerodynamic - The diameter of a
hypothetical sphere of unit density  (1 p,g/cm3) hav-
                                                33

-------
ing the same terminal settling velocity as the particle
in question, regardless of its geometric size,  shape
and true density.

Physical Stabilization -  Any measure  which  physi-
cally reduces the emissions potential of a source re-
sulting from either mechanical disturbance or wind
erosion.

PMio  - Particulate matter less than or equal to 10
urn  in aerodynamic diameter.

Preventive Measures - Techniques for controlling
fugitive particulate  emissions which  prevent  the
creation and/or release  of  particulate  matter(e.g.,
wet suppression,  stabilization of unpaved surfaces,
cleaning of paved surfaces).

Process Sources -  Sources of  fugitive emissions
associated with industrial operations that alter the
chemical  or  physical  characteristics of  a  feed-
material.

Receptor-Oriented  Air  Quality  Model  (Receptor
Model) - An air quality model which uses chemical
analysis at receptors (i.e., ambient  monitors) to
statistically infer the separate contribution from each
of the sources of the emissions.

Respirable Particulate (RP)  - Particulate matter less
than or equal to about 3.5 prn aerodynamic diame-
ter,  as measured with  a 10-mm  Door-Oliver cy-
clone precollector.

Road, Paved - A roadway constructed of rigid  sur-
face materials such as asphalt, cement, concrete,
and brick.

Road, Unpaved -  A roadway constructed of nonrigid
surface materials  such  as dirt,  gravel  (crushed
stone or slag), and oil and  chip surfaces.

Road Surface Dust Loading - The mass of loose sur-
face dust  on a paved roadway, per length of road-
way,  as determined by dry vacuuming.

Road Surface Material - Loose material present on
the surface of an unpaved  road.
Silt Content -  The mass portion of an aggregate
sample  smaller than 75 p.m in  diameter as deter-
mined by dry sieving,

Source Extent - The measure of the level of source
activity. For roads,  the source  extent is in vehicle
miles traveled (VMT) per year.

Source-Oriented Air Quality Models  (Dispersion
Models) - An  air quality model which  predicts a
source's impact on air quality by using  a series of
predictive equations to model the dispersion of the
plume from the source.

Total Particulate (TP) -  Particulate matter  of  all
sizes as collected by isokinetic  sampling.

Total Suspended Particulate (TSP) -  Particulate
matter measured by a high volume sampler with an
inlet 50% cutoff 30-50 jam in aerodynamic diameter.

Upwind/Downwind Method - A  method of quantify-
ing fugitive emissions which involves the measure-
ment of air quality  upwind and downwind of  the
source under known meteorological conditions,  fol-
lowed  by "back-calculation" of  source emission
rates using atmospheric dispersion equations.

Vehicle, Heavy-Duty - A motor  vehicle with a gross
vehicle traveling weight exceeding 30 tons.

Vehicle, Light-Duty - A motor vehicle with  a  gross
vehicle  traveling weight of less than or equal to 3
tons.

Vehicles,  Medium-Duty  - A motor vehicle with a
gross vehicle traveling weight  of greater than 3
tons, but less than 30 tons.

VKT -  Vehicle kilometers traveled.

VMT - Vehicle  miles traveled.

Wet Suppression - The application of water to the
surface of the material producing emissions to  inhibit
the generation of particulate matter emissions.
                     34

-------
                                          Appendix  B
                                         Abbreviations
a - Constant in equation 3-2
ADT - Average daily traffic
AMS - American Meteorological Society
APCA  - Air Pollution Control Association
AP-42 -  The following publication:  U.S,  Environ-
    mental Protection  Agency. Compilation  of  Air
    Pollution Emission Factors,  Volume 1: Stationary
    Point and Area Sources. Fourth Edition, Supple-
    ment A, AP-42, Office of Air Quality Planning and
    Standards. Research Triangle Park, NC, October
    1986.
Avg -  Average
b - Constant In equation 3-2
c - Fractional control efficiency
C* - Cost-effectiveness
Ca  - Annuallzed costs  of control equipment
CaCI2 - 'Calcium chloride
CBR - California bearing ratio
CCSEM - Computer controlled scanning  electron
    microscopy
cfm -  Cubic feet per minute
Chem  - Chemical
C0 - Direct operating costs
CO - Colorado
Cp - Installed capital costs
CRF -  Capital recovery factor
c(t) -  Instantaneous control efficiency at t days  af-
   ter application of dust suppressant
C(T) - Average control efficiency during period of T
   days between application of dust suppressant
d - Average hourly daytime traffic rate
days/yr - Days per year
dt - Change in time
E - Emission  factor
EPA - U.S, Environmental Protection Agency
f  - Percent time unobstructed wind speed greater
   than 12 miles per hour
FP - Fine paniculate matter
ft - Feet
gal - Gallons
gal sol/yd2 - Gallons of solution per square yard
gal/yd2 - Gallons per square yard
g/m2 - Grams per square meter
g/m3 - Grams per cubic meter
g/s - Grams per second
H - Drop height  except as used in Appendix C
H -  Final plume  rise in  Gaussian equation in
     Appendix C
H2O -  Water
hc - Height of convectively mixed layer
hi-vol  -  High volume
hm - Height of mechanically mixed layer
hr- Hour
hr 1 - Per hour
nr/yr - Hours per year
I  - Interest rate except  as used in equation 5-2
i  - Application intensity In equation 5-2
I  - Road  augmentation factor
IL - Illinois
in - Inches
IP -  Inhalable partlculate
k - Particle  size  multiplier
kg - Kilogram
kg/VKT - Kilogram per vehicle kilometer traveled
km - Kilometer
km/hr  -  Kilometers per  hour
I - Liters
L - Surface  dust loading
l/m2 -  Liters per square meter
Ib - Pound
Ib/mlle - Pounds per mile

-------
Ib/VMT - Pounds per vehicle mile traveled
m - Meters except as used In equation 3-2
m - Road surface moisture content only as used In
    equation 3-2
M - Material moisture content as used on Tables 6-1
    and 6-2
M - Annual source extent except as used In Tables
    6-1 and 6-2
m2 - Square meters
m3 - Cubic meter
m3/hr - Cubic meters per hour
mg - Megagram
MgC!2 - Magnesium  chloride
mm - Millimeter
mm/hr -  Millimeters  per hour
MN - Minnesota
mph - Miles per hour
MRI - Midwest Research Institute
m/s - Meters per second
n - Number of travel  lanes as used in Tables 6-1 and
    6-2
n - Economic life of  control system except as used
    in Tables 6-1 and 6-2
NC - North Carolina
NCDC - National Climatic Data Center,  Ashevllle, NC
No. - Number
OH - Ohio
O&M - Operation and maintenance
oz/yd2 - Ounces per square yard
p - Number of days with at least 0.01 inches of pre-
    cipitation per year except as used In equation
    5-2
p  - Potential  average  hourly daytime evaporation
    rate in equation 5-2
P - Profiling, used in Table 5-4
PA - Pennsylvania
PMio - Particulate matter consisting of  particles less
    than or equal to  10  prn
Q  - Source strength
RP - Respirable particulate matter
s - Silt content  of road  surface material
S - Mean vehicle speed
SEM - Scanning electron microscope
sL - Silt loading
Sol - Solution
SORI - Southern Research Institute
ST - Short  tons
t - Time between applications In equation 5-2
TEM - Transmission electron microscope
ton/yr - Tons per year
TP - Total airborne particulate matter
TSP - Total suspended particulate matter
u - Wind speed as used In Appendix C
U - Mean wind speed except as used In Appendix C
U/D - Upwind/downwind, used In Table 5-4
UMAMAP - User's  Network for Applied Modeling of
    Air Pollution
Veh - Vehicle
VKT - Vehicle kilometer traveled
VMT - Vehicle mile traveled
VMT/yr - Vehicle miles traveled per year
w - Mean number of wheels
W - Mean vehicle weight
X - Pollutant concentrations
y - Lateral distance from plume centerllne In Gauss-
    Ian equation in  Appendix C
Y - Average capacity  (of  dumper or  front end
   loader)  except as used In Appendix C
yd2 - Square yard
yd3 - Cubic yards
yr - Year
AR - Annual reduction in particulate emissions
AT  - Temperature  difference
© - Wind direction
g/m3 - Mlcrogram per cubic  meter
urn - Micrometer
umA - Micrometer (aerodynamic basis)
ay - Lateral dispersion parameter
az - Vertical dispersion parameter
                    36

-------
                                           Appendix C
                                Modeling Of Fugitive Emissions
The  Identification and estimation  of air  quality Im-
pacts from fugitive dust sources typically require the
use of air quality models. Traditional regulatory ap-
proaches have  dictated that  source Impacts  be
Identified by dispersion (source) modeling. The fol-
lowing discussion is intended to provide a general
overview of source-oriented models; for more de-
tailed discussions, the user should consult recent
reviews  readily  available In  the  scientific  litera-
ture. [1,2]  Source-oriented models assume  that
mass transported from  a source to a  receptor is
transported with  conservation  of mass  by  atmos-
pheric dispersion of the  source  material. [3]  It
should also be recognized that  the selection of an
appropriate model (s) will depend upon the particular
program/study objectives and resource  constraints
(i.e.,  data, manpower,  computing facilities,  etc.),
as well as the user's knowledge of the model tech-
nology.

The Gaussian plume model Is more widely used than
any other source-oriented model. Stripped to its es-
sentials, the Gaussian model may be represented as
follows:
x =
                                          (C-1)
where the parameters are:

 X  (g/m3)   =  concentration of pollutant in air

 Q  (g/s)    =  continuous point source strength

 u  (m/s)    =  wind speed at height H

 ay  (m)    =  lateral dispersion parameter

 crz  (m)    =  vertical  dispersion  parameter

 y  (m)      =  lateral distance from plume center
               line

 z (m)      =  height above ground

 H  (m)      =  final plume rise of plume above
               ground
As the name implies, the model predicts concentra-
tions under the assumption that the plume disperses
in the horizontal and vertical according to a Gaussian
distribution.  Other major assumptions include:  a)
constant and continuous emission rates, b) no vari-
ations  in meteorology (wind speed, wind direction,
and atmospheric  stability) between source and re-
ceptor, and  c)  complete reflection of the plume
from the ground surface.

The Gaussian plume  concept is the basis for nearly
all models in  the  U.S. EPA system of UNAMAP (Us-
er's Network for Applied Modeling of Air Pollution)
models. The differences between models of the UN-
AMAP family are mostly due to variations in the treat-
ment of plume rise, pollutant half-life,  diffusion limi-
tations due to mixing heights, source configurations,
and dispersion coefficients  to  characterize plume
growth. Abstracts which summarize model capabili-
ties of most  of the current  generation of UNAMAP
models may  be  found  elsewhere. [4] Reasonably
complete technical descriptions for each model are
available In the various users'  manuals.

For all but  the crudest screening applications, the
use of  a dispersion model requires appropriate infor-
mation on source emission rates and study area me-
teorology. In the case of stationary sources, it is
usually a fairly straightforward procedure to develop
an adequate emissions inventory. For  fugitive (par-
ticularly open source) emissions, the measures  of
source extent (e.g.. unvegetated surface  area ex-
posed to the wind) are often  more difficult to define.
The reliability of open source  emissions estimates
are greatly increased if  site-specific information is
collected.

In similar fashion, to make the  best use of Gaussian
modeling,  site-specific  meteorological measure-
ments need to be made that  relate closely to pollut-
ant  dispersion. [5] These include, for  example,  a)
continuous measurements of wind speed (u) and di-
rection (@) at two heights; b)  ambient temperature
difference  (AT)   between 2  and  10  m:   and c)
heights of the convectively mixed layer (hc)  and the
mechanically mixed layer (hm). Very few programs
are designed  to acquire  such detailed  information.
                                               37

-------
Many routine modeling applications rely on data from
nearby locations such as airports, National Weather
Service stations, and military Installations to repre-
sent the atmospheric conditions  for the area of In-
terest. These observations are intended primarily for
aviation needs, and are not particularly well suited to
dispersion problems.  The  primary source for  sur-
face and upper  air  meteorological data is the Na-
tional  Climatic Data  Center  (NCDC, Asheville, NC).
For many  long-term or climatological applications,
the meteorological  conditions of a site are  repre-
sented by a stability array or "STAR" tabulation. The
STAR  tabulation  summarizes meteorological  condi-
tions in terms of  joint frequency distributions of wind
speed,  atmospheric  stability class, and wind direc-
tion. This information has been developed for many
locations in the  United States and is also available
from NCDC.

The principal advantage of source-oriented (disper-
sion) models lies in the fact  that they can be used to
directly predict the impact of either existing or  pro-
posed sources. [3] Another advantage of this class
of models is  that they do  not require ambient air
quality data, though, if available, air quality data  may
be  used to  assign  "background"  pollutant  levels.
Additional advantages are that the models are widely
available and  have been evaluated using many dif-
ferent data sets. [2]

The primary limitations of dispersion models relate
not only to deficiencies in  the quality  of the Input
data for a particular application, but also to the  abil-
ity of the Gaussian model  to reproduce the  impor-
tant  physical/chemical processes affecting trans-
port of  pollutants in the atmosphere. The Gaussian
model will perform best under the conditions used to
form the basis for the current models. These condi-
tions include:

  Source: Low-level, continuous, nonbuoyant emis-
     sions, in simple terrain.

  Meteorology:  Near neutral  stability, steady,  and
     relatively homogeneous wind field.

  Estimate: Local, short-term, concentrations of In-
     ert pollutants.

Under those relatively simple conditions, "factor of
two"  agreement between predicted and observed
concentrations is probably  realistic. [6]

Addition of complicating features to the simple dis-
persion case will substantially increase the  uncer-
tainties associated  with model  estimates.  Compli-
cating features  include:

  •  Aerodynamic  wake flows of all kinds
 •   Buoyant fluid flows and accidental releases of
     heavy toxic gases

 •   Flows over surfaces markedly  different from
     those represented In the  basic experiments,
     e.g., forests, cities, water, complex terrain

 •   Dispersion in extremely  stable and unstable
     conditions

 •   Dispersion at great downwind distances (>10
     to 20 km)

It is widely recognized that significant  improvements
In dispersion modeling will require more direct ob-
servational knowledge  under  these  conditions.
Model users should be aware that the capabilities of
the current UNAMAP series to represent these fea-
tures are based on a few special case studies. (7]


References
 1.  Turner, D.B.  Atmospheric Dispersion Modeling:
     A Critical Review.  Journal of  the  Air Pollution
     Control Association. 29 (5):502-519,  1979.

 2.  Hanna, S.R.  Handbook on Atmospheric Diffu-
     sion Models. ATDL-81/5, National Oceanic and
     Atmospheric  Administration.  Oak Ridge, TN,
     1981.

 3.  Cooper, J.A. Chemical Mass  Balance Source
     Apportionment Methods.  Paper presented at
     the  74th Annual Meeting  of the  Air Pollution
     Control Association, Philadelphia, PA, 1981.

 4.  Environmental Protection Agency.  Environ-
     mental Modeling  Catalogue: Abstracts of Envi-
     ronmental Models. U.S. EPA Information Clear-
     inghouse.   U.S.   Environmental   Protection
     Agency, Washington, DC,  August  1982.

 5.  American Meteorological Society. On-Site Me-
     teorological Requirements to Characterize Dif-
     fusion from Point Sources. Proceedings from a
     Workshop Held in Raleigh,  NC, January 15-17,
     1980. American  Meteorological Society, Bos-
     ton,  MA.  1980.

 6.  American Meteorological Society.  Accuracy of
     Dispersion Models: A Position Paper of the AMS
     Committee on  Atmospheric  Turbulence  and
     Diffusion. Bulletin of the American Meteorologi-
     cal Society,  59(8): 1025-26, 1978.

 7.  American  Meteorological  Society. Air Quality
     Modeling and the Clean Air Act:  Recommenda-
     tions to EPA on Dispersion Modeling for Regula-
     tory  Applications. American    Meteorological
     Society,  Boston,  MA, (NTIS PB 83-106237),
     1980.

-------
                                              Appendix D
                                 Control Efficiency Decay Curves
Figure D-1.  Control efficiency decay for an initial application of Petro Tac   [1-3].
                                               Petro-Tatr
o
g>
"o
it
in
 o
O
     100
      80
60
      40
      20
                  Rating A
                                Application Intensity    3.2 |im
                                Dilution Ratio          20%
                                Avg. Veh. Weight      27 Mg
                                Avg, No, of Wheels    9.2
                                Avg. ADTa            414
     100
               10
               Vehicle Passes after Application
                        (1000's)
                                                         Vehicle Passes after Application
                                                                  (1000's)
ADT = average daily traffic (vehicles/day)

-------
Figure D-2.  Control efficiency decay for an initial application of Coherex  [1-3]
                   Rating B
    c:
    o
   o
       100
        80 —
        60 —
        20
                                                 Coherex®
Application Intensity
Dilution Ratio
Avg. Veh. Weight
Avg. No. of Wheels
Avg, ADT
3 . 8 |1 m2
20%
34 Mg
6,2
95
                                        TP
                                                                                        IP
    o
    O
       100
        80 —
        60 —
    o   40
        20
                                        PM
                                           10
                                                                                        FP
                                                                                  J_
                   1234
                 Vehicle Passes after Application
                            (1000's)
  1234
Vehicle Passes after Application
            (1000's)
                    40

-------
                Control Efficiency (%)
                Control Efficiency (%)

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                                                                          a
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-------
Figure D-4.  TSP control efficiency decay for light-duty traffic on unpaved roads [4],
        120
        100  —
        80  —
    9
    o

    UJ

    o


    o
    o
    Q.
    w
    t-
60 —
        40 —
         20
                                                        Reapplicatlon of OWB (0.6 gal sol/yd  )


Application

Intensity (gal sol/yd 2 )
Dilution Ratio (gal chem:gal H2O
Avg Veh. Weight (tons)
Avg. No of Wheels
Rating
B C
Flambinder® Oil
& Arcote Well
220® Brine
• *
1.9 3.8
1:4 1:0
3 3
4 4
C
Coherex®
•
1.5
1:4
3
4
                                       12
                                             18
24
                                                                                 30
                                                                                       36
                                           Time after Application (days)
               42

-------
             FP Control Efficiency (%)
                                                       TSP Control Efficiency (%)
                                                                                                                             TI

                                                                                                                             IQ
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-------
Figure D-6.  Control efficiency decay for Soil Sement   and Biocat-Enzyme  applied to haul roads [5].
Soil Sement ®
Mine
Application Intensity (gal sol/yd2)
Dilution Ratio (gal chem:gal H2O
Avg. Veh. Weight (tons)
Avg, No. of Wheels
Rating
1
1.9-3.0
1:8,3
22-89
10
B
2
1.0
1:6.4
38-82
10
B
Biocat-Enz
3
2.0
1:20.000
70-276
6
D
   o
   c
   0)
   o
   o
   o

   CL
   V)
       100
        80
60
        40
        20
                                       Topical

                                     Application
                                                                                  Mixed

                                                                               Application
       100
   o
   c
   9!
   o


   UJ

   o

   c
   o
   o
40  ._
        20 -
                 5      10     15     20    25

                 Vehicle Passes after Application

                            (1000's)
                                           30
                                                                                         Mixed

                                                                                       Application
5      10    15     20    25

Vehicle Passes after Application

           (1000's)
                                                                                                  30
                    44

-------
Figure D-7.  Control efficiency decay for Flamblnder   applied to haul roads [5].
                                                Flambinder
   s
   o
   §
   o
   a.
   v>
       100
        80
60
        40
        20
Mine
Application Intensity (gal sol/yd2)
Dilution Ration (gal chenv. gal H2O
Avg. Veh. Weight (tons)
Avg. No. of Wheels
Rating
1
0.5-2.1
1:4.6
16-65
10
E
2
0.5-2.0
1:4.6
51-69
10
C
3
1.8
1:4.6
70-276
6
C
                                       Topical
                                      Application
                        Mine 1
                                                                       . Mine 1
                                                                                 Mixed
                                                                               Application
   >,
   o
   E
   ill
   §
   O

   fc
       100
        80
        60
        40
        20
                                       Topical
                                      Application
                         I
                             I
I
                 5      10     15     20     25
                 Vehicle Passes after Application
                            (1000's)
                                           30
                                                                                 Mixed
                                                                               Application
                     5      10    15     20    25
                     Vehicle Passes after Application
                               (1000's)
                                                                                                   30

-------
Figure D-8.  Control efficiency decay for Arco 2200® applied to haul roads [5].
                                                        Arco 2200 <
Mine
Application Intensity (gal sol/yd 2 )
Dilution Ratio (gal chem:gal H2O
Avg. Veh. Weight (tons)
Avg. No. of Wheels
Rating
2
0,9-2.8
1:7
18-80
10
C
3
1,1-2.3
1:6.1
70-276
6
E
        100
    8
    $
    g
    8
    o

    a
    w
    H
                                        Topical
                                       Application
Mine 3
                                                                    Mixed

                                                                 Application
                                                                      -Mine 3
         100
    o

    i
    o

    LU
    O

    Q.
    U.
                       Mine 3
                                         Topical

                                       Application
                   5     10     15     20     25

                   Vehicle Passes after Application
                             (1000's)
                             30
5      10    15     20    25

Vehicle Passes after Application
          (1000's)
                     46

-------
Figure D-9. Control efficiency decay for reapplication of various chemical suppressants [6].
Code Letter
Initial Application
Intensity (gal /yd2)
Second Application
Intensity (gal /yd2)
Dilution Ration (chem:
water)
Avg. Vehicle Weight (tons)
Avg. No. of Wheels
Petro Tac®
P
0.21
0,35
1:5
9.7 - 24
6
Soil Sement®
S
0.16
0.44
1:5
9.6 - 24
6
Cohered
C
0.21
0.36
1:5
9.6 - 24
6
Generic
G
0.14
0.46
1:5
9.3 - 24
6
                 100
             o
             0)
             o

             LU
            o
             5?
                 100
                 50
                        PM
                         I     I     I    I     I
                                                            IP
                             10        20        30      0         10       20


                                         Days after Second Application
                                                                                 47

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References
  1.  Cuscino,  T., Jr., G.E.  Muleski,  and C. Cow-
     herd, Jr.  Iron and Steel  Plant Open Source Fu-
     gitive     Emission     Control     Evaluation.
     EPA-600/2-83- 110,  U.S.  Environmental Pro-
     tection Agency, Research Triangle Park, NC,
     October 1983.
  2.  Muleski. G.E.,  T. Cuscino, Jr.,  and C. Cow-
     herd, Jr. Extended Evaluation of Unpaved Road
     Dust Suppressants in  the Iron and Steel Indus-
     try. EPA-600/2-84-027,  U.S.  Environmental
     Protection Agency,  Research  Triangle Park,
     NC. February 1984,
  3.  Cowherd, C., Jr.. R. Bohn, and T. Cuscino, Jr.
     Iron and  Steel Plant Open  Source  Fugitive
     Emission    Evaluation,    EPA-600/2-79-103,
     (NTIS  PB--299  385),  U.S.  Environmental Pro-
     tection Agency. Research Triangle Park. NC,
     May 1979.
4.  Russell,  D.  and  S.  C. Caruso.  A Study  of
   Cost-Effective  Chemical  Dust Suppressants
   for Use on Unpaved Roads in the Iron and Steel
   Industry. American Iron and Steel Institute, De-
   cember  1982.

5.  Rosbury, K.  D., and R. A. Zimmer. Cost-Effec-
   tiveness of  Dust  Controls  Used  on Unpaved
   Haul Roads - Volume 1  of 2. Draft Final Report,
   U.S.  Bureau of Mines,  Minneapolis, MN, De-
   cember  1983.

6.  Muleski,  G.E. and C. Cowherd, Jr. Evaluation
   of the Effectiveness  of Chemical Dust Sup-
   pressants on Unpaved  Roads. U.S.  Environ-
   mental Protection Agency. Research Triangle
   Park, NC, Draft Final Report, May  1986.
                                                                   U. b. GOVEBNMENT PRIMTISG OFFICE 1987/748-121/67021
                  48

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