United States
Environmental Protection
Agency
&EPA
Region V
Air Compliance Branch
230 South Dearborn Street
Chicago, Illinois 60604
EPA-905/2-84-001
February, 1984
Air Management Division
An Inspector's Guide
For Fugitive Dust
Emission Sources
Causes and Control
Techniques,
Recommendations and
Examples
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AN INSPECTOR'S GUIDE
FOR
FUGITIVE DUST EMISSION SOURCES
Causes and Control Techniques,
Recommendations and Examples
Prepared by tne
Air Compliance Branch
Air Management Division
U.S. EPA, Region V
Larry Kertcher, Chief
Lucien Torrez, Project Officer
Susan Nelson, Editor
February 29, 1984
Reprinted May 11, 1984
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FOREWORD
The United States Environmental Protection Agency (EPA) was created in 1970
in response to increasing public and governmental concern about the dangers
of pollution to the health and welfare of the American people.
Amemdments to the Clean Air Act that year required EPA to protect the public
health and welfare by establishing and enforcing national ambient air quality
standards for major, or priority, air pollutants. As a result, such standards
exist for sulfur dioxide, total suspended particulates (TSP), carbon monoxide,
ozone, nitrogen oxides, and lead.
The same legislation made States responsible for developing and implementing
specific plans to achieve those standards. These plans, called State imple-
mentation plans (SIPs), are reviewed by EPA and revised periodically.
In the case of TSP, throughout the 1970s and early 1980s, EPA and many States
concentrated on process-related emissions. Although dramatic decreases were
achieved in levels of TSP emitted from industrial point sources, overall levels
of particulates tended to remain high.
With the attention of EPA increasingly focused on nonprocess fugitive emissions,
a need became apparent in Region V to develop more uniformity in the conduct of
fugitive dust inspections and enforcement of the related regulations. Until
now, EPA Region V has had no inspection guide to assist Federal, State, and
local air pollution-control officials.
EPA Region V has developed this guide to assist inspectors who are responsible
for monitoring fugitive dust emission sources. It is our hope that the materials
assembled here can improve the overall task of fugitive dust emission source
evaluation and control by all officials charged with this responsibility.
EPA does not endorse any specific pollution-control products or processes,
regardless of their inclusion or mention herein.
Larry F. Kertcher, Chief
Air Compliance Branch
Air Management Division
U.S. EPA Region V
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CONTENTS
Introduct i on 1
Example Facilities Affected by FD Regulation 3
Heavy Industry FD Sources in Region V 3
Overview of Control Techniques 4
Enforcement Responsibi 1 ities 6
Applicable FD Rules, Region V States 8
Illinois 9
Indiana 11
Mi chi gan 20
Mi nnesota 28
Ohio 29
Wi sconsi n 32
Gathering Evidence for a Compliance Determination 34
Compliance Inspector's Checklists 35
Appendi x 38
Control Measures for a Source's Consideration 39
Power Readers on Controlling Coal-Pile Dust 40
FD Control Equi pment 42
Typical Control Plans: Coal-Fired Power Plant 43
Iron and Steel Plants 5b
Inner-City Sources 57
Strategies for Dust Control, Unpaved Roads 58
Quarry Dust Control 64
Asphalt Plant Dust Control 68
Descriptions/Specifications, FD Control Equipment 71
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INTRODUCTION
Process fugitive emissions, as tne word "fugitive" implies, include particulate
emissions from industrial operations that escape to the atmosphere without
passinq through a primary exhaust system such as a stack, flue, or control
system.
Fugitive dust, as distinguished from process fugitive emissions, includes
natural dust, agricultural dust, and particulate matter generated from other
nonindustrial activities. These are considered, then, nonprocess fugitive
emissions.
Federal air-quality regulations have always implicitly included control
measures for fugitive dust emissions, but until recently Federal enforcement
has been directed only at point-source emissions. Since 1980, nowever, tne
U.S. Environmental Protection Agency (U.S. EPA) has been concerned about
these nonprocess fugitive dust emissions. Two developments have spurred
U.S. EPA efforts in dealing with fugitive emissions: the nonattainment
of National Ambient Air Duality Standards (NAAQS) in many air quality-control
regions, and an accumulation of information that indicates fugitive emissions
and dust, specifically, may significantly contribute to mass and ambient
air quality.
Still, only loading operations associated with grain elevators subject to new
source performance standards (NSPS) are covered by Federal regulations. Any
other regulations for tne control of fugitive dust emissions (FDs) nave been
developed by the States and submitted as part of each State's implementation
plan (SIP) for total suspended particulates. With approval of that portion
of a SIP, the FD-specific regulation becomes a rule that is then enforceable
by either State or Federal air pollution-control officials.
This guidance package has been developed to supply inspectors with the infor-
mation they may be expected to need for conducting FD compliance inspections.
It is intended to explain both the change in U.S. EPA's focus and possible
methods for controlling fugitive dust emissions.
Information is based on field experience as well as on ideas of several
investigators whose writings appear in Chemical Engineering, Power, and other
technical journals. These periodicals are available in most technical libraries,
including U.S. EPA Region V's library.
Provided on the following pages are an overview of control techniques, updates
of applicable fugitive dust rules in Region V States, checklists that may be
used by compliance engineers as well as by inspectors, and explanations of
several recognized control measures that are available to sources that wish
to control their FDs.
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The sample FD control plan for a coal-fired utility plant was developed by
Commonwealth Edison Company. Witn few modifications it can be tailored to
most sources in Region V. The sample plan for iron and steel plants was
developed by ARMCO, Inc. for a specific "bubble" application. Tne voluntary
program developed by the Milwaukee Solvay Coke Company was targeted at an
inner-city source.
Tnese are not offered as model plans but only as examples of the types of
regulations and permit conditions now being commonly used by State agencies.
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EXAMPLE FACILITIES AFFECTED BY FUGITIVE DUST EMISSION REGULATION
Asphalt plants
Cement plants
Concrete ready-mix plants
Foundries
Grain elevators
Lime plants
Municipalities, road crews, etc.
Open-pit mines
Power plants
Quarries
Sand & aggregate screening plants
Slag processing plants
Steel mills
HEAVY INDUSTRY COMMONLY HAVING FUGITIVE DUST EMISSION SOURCES IN REGION V
Blast furnace slag handling
BOP & open hearth shops
Coal piles (storage & working)
Coal processing plants
Conveyor systems
Foundries
Grainhandling operations
Lime operations
Open pit mining
Quarries
Raw materials piles (storage & working)
Sand & aggregate screening & handling
Secondary metals operations
Slag processing plants
Storage piles (waste materials)
Transporting materials (vehicle)
Unloading & loading materials
Unpaved and paved roads
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OVERVIEW OF CONTROL TECHNIQUES
While measurements of fugitive dust emissions have proved difficult, the
need for control is clear. Approximations of the extent of these emissions
indicate two things: that such sources may constitute a significant portion
of nationwide emissions, and that localized sources with impact upon local
air quality are sufficiently widespread to be of national significance.
To date, as we have noted, only one category of FDs is covered by Federal
regulation: grain elevators that are subject to new source performance stan-
dards (NSPS) under Section 60.302, subpart DD, of the Clean Air Act. All
other FDs are addressed by all States in their State implementation plans (SIPs),
which are approved by U.S. EPA. Thus, approved State rules are enforceable by
either Federal or State actions.
Because fugitive dust is emitted from nondefinable points, it cannot easily be
measured by conventional techniques. This has caused the various States to
tailor compliance programs they develop to their specific problems. Specific
rules and control requirements of Region V's six States begin after page 8.
Usually the regulations developed by the States to control FDs specify that
no person/source shall cause or allow, from any activity, any emissions of
fugitive particulate matter that are visible to an observer who looks horizon-
tally along the source's property line.
Each State's regulations may contain certain exceptions that are pertinent
to that State's own industrial makeup. Normally, in the absence of specific
permit conditions, and discernible amount of dust emanating from these
activities that crosses over the source's property line is considered a
violation of the fugitive dust regulations.
However, some States allow an exemption when wind speeds exceed 25 mph. (Wind
speed is to be determined as a one-hour average or an hourly recorded value
at the nearest official station of the National Weather Service or by wind-
speed instruments that are operated on the site.)
Specific measures that are generally agreed to be effective in dealing with
FDs are summarized in the following paragraphs.
Physical stabilization methods can control fugitive dust from inactive waste
heaps, unpaved roads, and other sites. In such cases an exposed surface is
covered with a material that prevents the wind from disturbing the surface
particles. Common stabilizer materials include rock, soil, crushed or granu-
lated slag, bark, wood chips, and straw. These materials are then harrowed
into the top few inches of the exposed surface. Elastomeric films, asphalt,
wax, tar, oil, pitch, canvas, and other materials can also be used. For
dirt roads, paving is a common practice; however, this is expensive and
usually must be preceded by roadbed buildup and improvement.
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Wet suppression of dust, using either water or water plus a chemical wetting
agent, can be employed for temporary control of fugitive dust from transport
of raw materials or products, materials handling and beneficiation, stockpiles,
waste heaps, unpaved roads, and mining and construction activities. In cases
where there is continual activity at the source, the suppressive must be
repeatedly applied if it is to be effective. Wet-dust suppression cannot be
used if the product or the next stage of processing cannot tolerate a wet prod-
uct, as is the case, for example, with grain processing and certain benefi-
ciation processes. Also, in hot summer weather, water alone requires very
frequent application if it is to be an effective suppressant.
In recent years a wet-dust suppression system using foam has been introduced.
Foam svstems have been successfully applied both to hard-rock drilling opera-
tions and at transfer points of conveyors. These systems increase wetability
and thus require a smaller supply of wetting fluid.
Chemical stabilization uses materials that bind with surface particles to form
a protective crust upon drying. This methodology is often used in combination
with vegetative stabilization. Applications include agricultural fields, unpaved
roads, waste heaps, and excavation neaps.
Vegetation can effectively be used to stabilize a variety of exposed surfaces.
However, modifications must be made to the surface or to tne surrounding
terrain before stabilization can occur (for example, fertilization, pH modifi-
cation, and slope reduction). Also, vegetative stabilization is restricted
to inactive areas where the vegetation will not be mechanically disturbed
once it is started. Such areas include refuse piles, especially of coal and
other minerals, and road shoulders.
Numerous other control measures are available. Among the most effective are
these:
-Lowering/enforcing the vehicle speed limit on unpaved roads.
-Vacuuming paved roads and parking lots.
-Reducing fall distances at materials drop points.
-Enclosing a source of FDs.
-Sealing, hooding, and ducting, as appropriate (and possible).
-Stationary spraying systems for large materials piles.
-Use of buses to move personnel into and around plant property.
Specific control measures that sources may elect to implement are listed on
page 39, in the Appendix.
Finally, effective control of FDs is unquestionably linked to inspections,
both those of regulators and those of plant or facility supervisors in their
own controlled FD areas.
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ENFORCEMENT RESPONSIBILITIES
The regulations that have been developed by Region V States to control FDs
vary, as can be seen after a careful reading of the rules, which begin on
page 8.
Yet, all six States—and a good many of the States in other U.S. EPA Reyions--
have set similar standards for the most common sources of fugitive dust
emissions in this country.
All six States, for instance, regulate FDs from materials piles based upon
various measures, including the following:
1. Potential FDs of particulate matter in excess of specific tons
per year.
2. Volume of this material expressed as specific cubic meters.
3. Volumetric throughput of this material expressed as specific cubic
meters.
4. FDs known to emanate from similar piles of a specific volume.
Enforcement engineers may want to utilize the Compilation of Air Pollutant
Emission Factors, Third Edition, to aid in making applicability and compliance
determinations.
In addition, some States regulate materials piles according to limitations
specifying FD impact on the ambient air quality that are based on specific
micrograms per cubic meter, either annual or maximum 24-hour per cubic
meter. Compliance with this measure is typically determined by an ambient
air monitor located in the emissions area. Such monitoring may be done
by the source, if not by the State.
Further, all six States require that potential FD violating sources submit
control plans that are designed to reduce FDs from the following activities:
-Crushing, grinding, mixing, screening, and compacting operations.
-Construction/demolition sites.
-Conveying of materials.
-Transferring of materials.
-Transporting of materials.
-Loading/unloading operations, and material storage.
-Paved roads and lots.
-Unpaved roads and lots.
-Any other, localized activity that causes FDs.
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Because Federal regulations for NSPS grain elevators have existed since 1981,
all States follow tnese opacity limitations for determining compliance:
1. Truck unloading railcar loading stations—less than 5 percent
opacity.
2. Truck loading operations—lO percent or less.
3. Barge/shiploading stations--20 percent or less.
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APPLICABLE FUGITIVE DUST RULES
REGION V STATES
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JiiJNQIS
Fugitive Particulate Matter.
(1) No person shall cause or allow the emission of fugitive particulate matter from any process, including any
material handling Or-storage activity, that is visible by an observer looking generally toward the zenith at a
point beyond the property line of the emission source.'
(2) Except for those operations subject to Rule 203'dK8) (Grain-Handling and Grain-Drying Operations), Rule
203(f) (31 shall apply to all mining operations (SIC major groups 10 through 14), manufacturing operations (SIC
major groups 20 through 39). and electric generating operations (SIC group 491'). which are located in the areas
defined by the boundaries of the following townships, notwithstanding any political subdivisions contained
therein, as the township boundaries were defined on October 1. 1979, in the following counties.
Cook: All townships
Lake: Shields. Waukegan, Warren
DuPage: Addison, Winfield, York
Will: DuPage, Plainfield, Lockport, Channahon, Peotone. Florence, Joliet
Peoria: Richwoods, Limestone, Hoi 1 is, Peoria, City of Peoria
Tazewell Fondulac. Pekin, Cincinnati. Groveland, Washington
Macon: Decatur. Hickory Point
Rock
Island: Blackhawk. Coal Vallev Hampton, Moline, South Moline, Rock Island, South Rock Island
LaSalle: LaSalle, Utic*
Madison: Alton, Chouteau, Collinsville, Edwardsville, Fort Russell, Godfrey, Granite City, Nameoki, Venice,
Wood River
St. Clair: Canteen, Caseyville, Centerville, St; Clair, Stites, Stookey, Sugar Loaf. Millstadt.
(3) On and after December 31.1982. potential sources of fugitive particulate matter shall be maintained and oper-
ated as follows.
(A) All storage piles of materials with uncontrolled emissions of fugitive particulate matter in excess of 50
tons/year which are located within a facility whose potential particulate emissions from all sources
exceed 100 tons/year shall be protected by a cover or sprayed with a surfactant solution or water on a
regular basis, as needed, or treated by an equivalent method, in accordance with thi operating program
required by Rule 203(f)(3)(F).
Exception: Subparagraph (A) of this Rule 203(f) (3) shall not apply to a specific storage pile if the owner
or operator of that pile proves to the Agency that fugitive particulate emissions from that pile do not cross
the property line either by direct wind action or reentrainment.
. (B) All conveyor loading operations to storage piles specified in Rule 203(0 (3)(A) shall utilize spray systems.
telescopic chutes, stone ladders, or other equivalent methods in accordance with the operating program
required by Rule 203(f)(3)(F).
(C) AH pormal traffic pattern access areas surrounding storage piles specified in Rule 203
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(D) All unloading and transporting operations of materials collected by pollution control equipment shall be
enclosed or shall utilize spraying, pelletizing, screw conveying, or other equivalent methods.
(E) Crushers, grinding mills, screening operations, bucket elevators, conveyor transfer points, conveyors, bag-
ging operations, storage bins, and fine product truck and railcar loading operations shall be sprayed with
water or a surfactant solution, utilize choke-feeding, or be treated by an equivalent method in accordance
with an operating program.
Exception: Subparagraph (E) of this Rule 203 (f) (3) shall not apply to high-lines at steel mills.
(F) The sources described in paragraphs (f)(3)(A) through (f)(3)(E) shall be operated under the provisions of
an operating program prepared by the owner or operator and submitted to the Agency for its review by
December 31,1982. Such operating program shall be designed to significantly reduce fugitive particulate
emissions.
As a minimum the operating program shall include the following:
1. the name and address of the facility;
2. the name and address of the owner or operator responsible for execution of the operating program;
3. a map or diagram of the facility showing approximate locations of storage piles, conveyor loading
operations, normal traffic pattern access areas surrounding storage piles and all normal traffic pat-
terns within the facility;
4. location of unloading and transporting operations with pollution control equipment;
5. a detailed description of the best management practices utilized to achieve compliance with Rule
203(f), including an engineering specification of particulate collection equipment, application
systems for water, oil, chemicals, and dust suppressants utilized and equivalent methods utilized;
6. estimated frequency of application of dust suppressants by location of materials
7. and such other information as may be necessary to facilitate the Agency's review of the operating
program
The operating program shall be amended from time to time by the owner or operator so that the operating
program is current Such amendments shall be consistent with this Rule 203(0 and shall be submitted to
the Agency for it*, review
>4> If particulate collection equipment is operated pursuant to Rule 203(f)(3). emissions from such equipment shall
not exceed 0.03 gr/dscf (0.07 grams per cubic meteri
• 51 Rule 203(f )i 1 > shall not apply and spraying pursuant to Rule 203(f)(3t shall not be required when the wind speed
is greater than 25 miles per hour • 40.2 kilometers per hour). Determination of wind speed for the purposes of this
rule shall be by a one-hour average or hourly recorded value at the nearest official station of the U.S Weather
Bureau or by wind speed instruments operated on the site In cases where the duration of operations subject to
this rule is less than one hour, wind speed may be averaged over the duration of the operations on the basis of on
site wind speed instrument measurements.
(6) No person shall cause or allow the operation of a vehicle of the second division as denned by III. Rev. Stat., Ch. 95
1/2, § 1-217, as revised, or a semi-trailer as denned by III. Rev. Stat., Ch. 95 1/2, § 1-187, as revised, without a
covering sufficient to prevent the release of particulate matter into the atmosphere, provided that this paragraph
(fX6) shall not pertain to automotive exhaust emissions.
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Section 1
Section 2.
Air Pollution Control Board
of the State of Indiana
325 IAC 6-5
fugitive Particulate Matter Emissior
Limitations
Applicability. The requirements of this Hule slK.-ll £p?-iy to
the following:
(a)
(b)
Any source of fugitive particulate matter e.T.^s
located in nonattainment areas for participate ::
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Sectior. 3. Submittal of Control Plans.
(a) If a source is required by this Rule to suon.it a ccntrol
plan or a request for an exemption, the scarce shall be
so notified by the Board. If a SGI -:ct» fails to submit
a control plan or a request for an exemption within
6 months after nctificati-.n, the Board may adopt a
control plan meeting the requirements of this Rule for
such a source.
(b) A control plan or request for an exemption from ti.e
control plan shall be included in all permit applications
and submitted to the Board by those sources specified
in Subsection l(b).
(c) The control plans submitted by sources subject to this
Rule shall minimize visible ejnis.sio;is of fugitive
particulate matter.
Section <+. Control Measures. Fugitive particulate matter emission
resulting from the emission points specified in this Section
shall be controlled unless exempted pursuant to Subsection 7(d)
of this Rule. All control measures specified in this Section
shall be considered Reasonably Available Centrei Measures
(RCH). No control plan shall contain control measures vhich
violate the provisions of the Indiana Code or the rule^ of
any other state agency.
(a) Paved Roads, Unpaved Roads, and Parking Lots. Fugitive
particulate matter emissions resulting from paved
roads, unpaved roads, and parking lots shs-I be controlled
unless exempted pursuant to Subsection 7(d) of this
Rule. Sources nay use one or more of the following
measures:
(1) Paved roads and parking lots:
(A) Cleaning by vacuum sweeping.
(B) Flushing.
(C) An alternate measure.
(2) Unpaved roads and parking lots:
(A) Paving with a material such as asphalt or
concrete.
(B) Treating witn a suitable and effective oil or
chemical dust suppressant approved by the
Board. The frequency of application shall be
on an as needed basis.
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(C) Spraying vith water, the frequency of application
shall be on an as needed basis.
(D) Double chip and seal the road surface aiid
maintain on an as needed basis
(E) An alternate measure.
(b) Open Aggregate Piles:
(1) Measures to control fugitive particul.it e matter
emissions shall be required for open £j;gresate
piles consisting of material such as; but not
limited to, sand, gravel, stone, grain, and coal
and which material is finer than 2CO mssh size
equal to or greater than one percent by veight.
Open aggregate material ir-esh size shall oe determined
by the "American Association of State Highv.-cy and
Transportation Officials Test Method T27-74," or
other procedures acceptable to the Hoarci.
(2) Fugitive particulate matter emissions result:.ig
from open aggregate piles consisting of surh
material as, but not limited to, sand, gravel,
stone, grain, and coal shall be controlled unless
exempted pursuant to Subsection 7(o) of thiE Rule.
Sources may use one or more of the following
measures:
(A) Cleaning the area around the perimeter of tLe
aggregate piles,
(B) Application of a suitable and effective oil
or other dust suppressant on an as neeaeo
basis,
(Cj An alternate measure.
(c) Conveying fugitive particulate matcer emissions resulting
from outdoor conveying of aggregate material such as,
but not limited to, sand, gravel, stone, grain, aii«:
coal, by equipment such as belt conveyors a.-jc bucket
elevators shall be controlled unless exempted pursuant
to Subsection 7(d) of this Rule. Sources may use one
or more or the following measures:
(1) Enclosing the conveyor belt totally on the top and
sides as needed to isiniciize visible emissions.
Also, if needed, exhausting emissions to particulate
control equipment during operation of conveyor.
(2) Applying water or suitable and effective chemical
dust suppressant at the feed and/or intermediate
points as needed to minimize • isible et
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(3) An alternate measure.
(d) Transferring. Fugitive particulate matter emissions
resulting from the transferring of aggregate material
shall be controlled unless exempted pursuant tc
Subsection 7(d) of this Rule. Sources may use one or
more of the following measures:
(1) Minimizing the vehicular distance between the
transfer points.
(2) Enclosing the transfer points and if nreded
exhausting emissions to particulate control
equipment during the operation of thu transferring
system.
(3) Application of water or suitable and effective
chemical dust suppressant as needed to minimize
visible emissions.
(A) An alternate measure.
(e) Transportation of Aggregate Material by Moter Vehicles.
Fugitive particulate matter emissions resulting from
transportation of aggregate material by truck, frc;:i_
end loaders, or similar vehicles bhall bs ccr.trolleu
unless exempted pursuant to Subsection "Ctl) of tlv ?
Rule. Sources may use one or more of the £c.i lowing
Measures:
(1) Use of completely enclosed vehicles.
(2) Tarping the vehicle,
(3) Maintaining the vehicle body in such a condition
that prevents any leaks of aggregate material.
(4) Spraying the materials in the vehicle vith a
suitable and effective dust suppressant.
(5) An alternate measure.
(d) Loading end Unloading. Fugitive particulate matter
emissions resulting from the loading and unloading
operations of the material from bins, hoppers, anc
silos, etc., onto or out of vehicles, shall be controlled
unless exempted pursuant to Subsection ~(d) of this
Rule. Sources nay use one or mora of the following
measures:
(1) Enclosure of the loading/unloading material area.
(2) Total or partial enclosure of the facility vith
exhaustion of emissions to particulnte collection
equipment. Such equipment shall be approved by
the Board.
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(3) Spraying wiz.h water or suitable and effective
chemical dust suppressant as needed tc minimize
visible emissions.
(4) Reduction of free fall distance.
(5) An alternate measure.
(g) Waste Disposal Sites. Fugitive particulate matter
emission resulting from activities involving waste
disposal shall be controlled unless exempted pursuant
to Subsection 7(d) of this Rule. Sources may use one
or more of the following measures:
(1) Hauling
(A) Wet suppression of the material being transported.
(B) Hauling the material enclosed or covered.
(C) Minimizing the free fall distance when unloading
from the particulate collection equipment
and/or process equipment onto the. hauling
vehicle.
(D) An alternate measure.
(2) Dumping
(A) Applying water cr suitable and eft active
chemical dust suppressant, on an as needed
basis to minimize visible emissions.
(B) Minimizing the free fall distance of the
material.
(C) An alternate measure.
(h) Material Handling Operations. Fugitive particular
matter emissions resulting fron material handling
operations such as crushing, grinding, screening, and
mixing, etc., shall be controlled unless exempted by
subsection 7(d) of this Rule. Sources may use one or
more of the following measures:
(1) Wet suppression.
(2) Enclosure of emission source with venting of
emissions to a fabric filter.
(3) An alternate measure.
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(i) Building Openings. Provisions of this Section are
applicable in preventing particulate matter from escaping
through building openings such as doors, windows,
powered or unpowered ventilators, rocf monitors, other
than a stack as defined in 325 IAC 1.1-1, Section 77
from sources subject to this rule. However, grain
elevators subject to the provisions of this Section
shall provide for good housekeeping and good maintenance
procedures as set forth in Rule 325 IAC 6-l-2(d)(2).
(1) Fugitive particulate matter emissions escaping
through building openings set fortn above shall be
controlled unless exempted by Subsection 7(d) of
this Rule. Sources may use one or more of the
following measures:
(A) Installing a removable filter over appropriate
building openings.
(B) Capturing emissions within the building by a
proper hood system and conveying through n
duct to particulate collection system approved
by the Board.
(C) An in-house operating and procedure nicl: cnance
program consisting of:
(i) Proper maintenance of the process equipment
and particulate collection system approved
by the Beard.
(ii) Substitution of the process equipir^JiL,
material, and/or operating procedure
that will minimize visible tnissionE.
(D) An alternate measure.
Section 5. Requirements of_ Fugitive Particulate .Matter £r..isLJon
Control Plans.
(a) The fugitive particulate matter emission control plan
shall be in writing and shall include, at a minimum the
following information:
(1) Name and address of the source;
(2) Name and address of the owner or operator responsible
for the execution of the control plan;
(3) Identification of all processes, operations, and
areas which have the potential to emit fugitive
particulate matter in accordance with Section 4 of
this Rule;
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(4) A map of the source showing aggregate pile areas,
access areas around the aggregate pile, unpaved
roads, paved roads, parking lots and location of
conveyor and transfer points, etc.;
(5) The number and mix of vehicular activity occurring
on paved roads, unpaved roads, and parking lots;
(6) Type and quantity of material handled;
(7) Equipment used to maintain aggregate piles;
(8) A description of the measures to he implemented to
control fugitive particulate ir.atter emission?
resulting from each emission print pursuant to
Item 3 of this Section;
(9) A specification of the dust r.uppressar.t ;uteri:.i,
such as oil or chemical including the cstirateu
frequency of application rates and concentrations;
(10) A specification of the particulr.te matter collection
equipment used as a fugitive particulate matter
emission control measure;
(II) A schedule to comply with the prevision? oi the
control plan. Such schedule shall specify the
amount of time the source reciuircs to award or.y
necessary contracts, commence and cor.pletc ccr&Vruccicn,
installation, or modification of the fjjcitive
particulate matter emission control measures; and
(12) Other relevant data taat may be requested by the
Board or its Staff, to evaluate tha effectiveness
of the control plan.
(b) Records shall be kept and naintained which d.icunic-ni. all
control measures and activities to be implemented ir.
accordance with the approved control plan. Said rcco.-Js
shall be available upon the request of the Board or its
Staff, and shall be retained for thr.ee (3) years.
Section 6. Compliance. All sources subject to this Rule shall have an
approved control plan and shall implement said plan as of:
(a) December 31, 1982, or as otherwise specified in the
approved plan, by sources located in prin-ary nonattainirent
areas for total suspended particulate matter. However,
a source is not required to implement a control plan
until such plan has been approved by the Board.
(b) As expeditiously as possible, but no Ister a^n December 31,
1985, or as otherwise specified in the approved pla:i by
sources located in secondary nonattaintr.cnt areas for
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total suspended particulate matter. However, a source
is not required to implement a control plan until such
a plan has been approved by the Board.
( (c) The date operation commences for new sources..
Section 7. Approval of Plans.
(a) Within three (3) months of receiving a control plan,
the Board shall notify the source of:
(1) The approval of the control plan or request for an
exemption;
(2) Improvements that the Board deems necessary to the
control plan, or
(3) Disapproval of the control plan or request for an
exemption.
(b) If the Board finds a control plan or request for an
exemption from the control plan to be incomplete, the
applicant shall provide the board the required additional
information.
(c) The Board shall approve control plans whicn contain any
RCM specified in Section 4 of this Rule. In determining
if (i) an alternate control measure represents a RCM,
or (ii) exemptions from control plans are acceptable,
/ the Board shall consider and the source shall submit
' information pertaining to factors, including, but not.
limited to the following:
(1) The impact on the environment in terms of any
increase in water, air, or solid waste pollution
emissions;
(2) The impact of these costs on firm;
(3) The energy requirements of the selected control
measure; :
(4) The capital expenditure, impact on production, and.•
operating costs to implement the selected control
measure; and
(5) Any adverse worker or product safety implications
of the selected control measure.
(d) Sources that demonstrate to the satisfaction of the
Board either that their fugitive emissions are not
significantly impacting the air quality outside their
property line or that the cost of controlling their
fugitive emissions is not commensurate with the degree
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of air quality improvement to be achieved by implementing
control measures pursuant to this Rule shall be exempted
from implementing such controls.
(e) If a control plan or request for an exemption from the
plan is disapproved by the Board, the applicant shall
have up to fifteen (15) days from the date of receipt
of the disapproval letter to request, in writing, 2
hearing on the matter. In the event a hearing is
requested, it shall be held in accordance '*ith the
requirements set forth in 1C 4-22-1 and the burden of
proof shall lie with the applicant to demonstrate why
the control plan or request for an exemption from the
plan is appropriate.
(f) The control plan approved by the Board shall become
part of the source's operation permit.
Section 8. Revision of Control Plans. The control plan shall be updated
at the tirr.e of reapplication for the source's operation
permit or as required in 325 IAC Article 2.
Section 9. Board Discretion. Any discretionary action taken by the
Board in accordance with this Rule shall be established as a
revision to the Indiana State Implementation Plan.
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HICHIGAM
DEPARTMENT OF NATURAL RESOURCES
AIR POLLUTION CONTROL COMMISSION
, GENERAL RULES
Filed with the Secretary of State on February 2, 1981.
These rules take effect 15 days after filing with the Secretary of State (February 17, 1981)
(By authority conferred on the air pollution control commission by sections 5, 7, and
14a of Act No. 348 of the Public Acts of 1965, as amended, being § § 336.15, 336.17,
and 336.24a of the Michigan Compiled Laws)
R 336.1106 of the Michigan Administrative Code, appearing on page 50 of Quarterly
Supplement No. 1 to the 1979 Michigan Administrative Code, is amended, and R
336.1370 to R 336.1372 are added, to read as follows:
PART 1. GENERAL PROVISIONS
R 336.1106 Definitions; F.
Rule 106. As used in these rules:
(a) "Federal land manager" means, with respect to any lands in the United States,
the secretary of the department with authority over such lands.
(b) "Fossil fuel-fired steam generator" means a furnace or boiler used in the process
of burning fossil fuel for the primary purpose of producing steam by heat transfer.
(c) "Fuel-burning equipment" means a device, contrivance, or equipment used
principally, but not exclusively, for the burning of fuel, and all appurtenances thereto,
including ducts, breechings, control equipment, fuel-.feeding equipment, ash removal
equipment, combustion controls, and stacks and chimneys, which equipment is used for
indirect heating in which the material being heated is not contacted by, and c'ccs not
add substance to, the products of combustion. This equipment typically includes that
used for heating water to boiling; raising steam or superheating steam.; heating air as
in a warm-air furnace; furnishing process heat, that is conducted through vessel walls;
and furnishing process heat indirectly through its transfer by fluids.
(d) "Fuel gas system" means any system in which gas is generated by a petroleum
refinery process unit and is combusted, including any gaseous mixture of natural gas
with such gas, and is not commercially sold.
(c) "Fugitive dust" means particulate matter which is generated from indoor
processes, activities, or operations and which is emitted into the outer air through
building openings and general exhaust ventilation, except stacks. The term also means
particulate matter which is emitted into the outer air from outdoor processes,
activities, or operations due to the forces of the wind or man's activity.
PART 3. EMISSION LIMITATIONS AND PROHIBITIONS-PARTICULATE MATTER
R 336.1370 Collected air contaminants.
Rule 370. (1) Collected air contaminants shall be removed as necessary to maintain
the equipment at the required operating efficiency. The collection and disposal of air
contaminants shall be performed in a manner so as to minimize the introduction of
contaminants to the outer air.
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(2) At a minimum, in priority I and II areas listed in tables 33 and 34, the use of 1 or
more of the following material handling methods is required for the transport of
collected air contaminants:
(a) Enclosed trucking or transporting vehicles.
(b) Enclosed, pneumatic, or screw conveying transporting equipment.
(c) Water or dust suppressant sprays.
(d) An acceptable method which is equivalent to the methods listed in subdivisions
(a), (b), and (c) of this subrule.
R 336.1371 Fugitive dust control programs.
Rule 371. (1) Upon notification by- the commission, the person who is responsible
for the operation of a facility which processes, uses, stores, transports, or conveys bulk
materials, such as, but not limited to, coal, coke, metal ores, limestone, cement, sand,
gravel, and material from air pollution control devices or a facility which has
activities specifically identified in R 336.1372 and which is located in a priority I or
priority II area shall submit a fugitive dust control program, hereinafter referred to as
"control program", to the commission. The commission's notification shall specify
which parts of R 336.1372 are applicable to the facility and the reasons for the
notification. Except as provided in subrule ^ of this rule, the control program shall be
submitted to the commission not later than 6 months after notification.
(2) Based on ambient air quality measurements or substantive complaints, the
commission may request that the person who is responsible for the operation of any
facility which is not included in subrule (1) of this rule, but which is located in this
state, submit a fugitive dust control program. The commission shall notify the person
who is responsible for the operation of the facility of the parts of R 336.1372 which
apply to the facility and the reasons for the commission's notification. Except as
provided in subrule 4 of this rule, the control program shall be submitted 10 the
commission not later than 6 months after notification.
(3) A fugitive dust control program which is required by subrules (1) or (2) ol this
rule shall be in writing and shall provide for all of the following:
(a) Using 1 or more combinations of available technologies, operating practices, or
methods listed in R 336.1372 as are reasonably necessary to control fugitive dust
emissions.
(b) Consideration of the quantity, moisture content, specific gravity, and the
particle size distribution of the bulk materials. The more friable, drier, lighter, and
finer the bulk material is, the more effective the fugitive dust control methods
• incorporated into the control program shall be.
(c) The keeping and maintenance of records consistent with the various activities to
be implemented under the control program.
(d) Identification of the control technologies, methods, or control equipment, If any,
to be implemented or installed and the schedule, including increments of progress, for
implementation or installation. The schedule shall provide for final control program
implementation in priority I and priority II areas by December 31, 1982.
(4) Within 3 months following notification by the commission that a fugitive dust
control program is required, the person who is responsible for operating the facility has
the opportunity to demonstrate, to the satisfaction of the commission, that any part of
the facility is not subject to the provisions of subrules (1) or (2) of this rule.
(5) If a control program is not submitted within 6 months after notification by the
commission, the commission may proceed, pursuant to the act, toward the entry of a
final order which contains a control program that meets the requirements of subrulc
(3) of this rule.
(6) The control program is subject to review and approval by the commission. The
commission shall approve a control program only upon the entry of a legally
enforceable order or as part of an approved permit to install or operate. If, in the
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opinion of the commission, the program does not adequately meet the requirements set
forth in subrule (3) of this rule, the commission may disapprove the program, state its
reasons /or disapproval, and require the preparation and submittal of an amended
program within a specified time period.. If, within the specified time period, an
amended program is cither not submitted or is submitted but, in the opinion of the
commission, fails to meet the requirements of subrule (3) of this rule, the commission
may proceed, pursuant to the act, toward the entry of a final order which contains a
control program that meets these requirements.
(7) After approval by the commission, the person who is responsible for the
preparation of the control program shall begin implementation of the program pursuant
to the schedule contained in the control program.
' (8) Either the person who is responsible for a facility or the commission may request
a revision to a commission-approved control program to meet changing conditions.
The commission shall review the revision following the requirements of subrule (6) of
this rule.
H
R 336.1372 Fugitive dust control program; required activities; typical control
methods.
Rule 372. (1) A fugitive dust control program which is required by R 336.1371 and
which deals with 1 or more of the fugitive dust sources listed in this rule may include
any of the typical control methods listed in this rule xor that'source.
(2) The following provisions apply to the loading or unloading of open storage piles
of bulk materials as a source of fugitive dust:
(a) Open storage piles of bulk materials, hereinafter referred to as "piles", which
meet any of the following 3 conditions need not be included in a fugitive dust control
program:
(i) All piies of the same material at a manufacturing or commercial location, v! rich
have a total volume of less than 100 cubic meters (131 yards ).
(ii) Any piles at a manufacturing or commercial location if the total annual
volumetric throughput of all the stored material at the site is less than 10,000 cubic
meters (13,100 yards ).
(iii) Any single pile at a manufacturing or commercial location that has a volume of
less than 'f2 cubic meters (55 yards ).
(b) Typical control methods for controlling fugitive emissions resulting from the
loading or unloading of piles may include, but are not limited to, the following:
. (i) Completely enclosing the pile within a building furnished with commission-.
approved air pollution control equipment.
(ii) Using pneumatic conveying or telescopic chutes.
(iii) Spraying the working surface of the'pile with water or dust-suppressant
compound.
(iv) Directing engine exhaust gases that are generated by the machine used on the
piles for loading or unloading upwards.
(v) Minimizing the drop distance from which the material is discharged into the pile.
The drop distance shall be specified in the control program.
(vi) Periodic removal of spilled material in areas within 100 meters (328 feet) from
the pile. The frequency of removal shall be specified in the control program.
(3) The following provisions apply to the transporting of bulk' materials as a source
of fugitive dust:
(a) Trucks with less than a 2-ton capacity that are used to transport sand, gravel,
stones, pect, and topscil arc exempt from the provisions of this subrule.
(b) Typical control methods for controlling fugitive emissions resulting from ihe
transporting of bulk materials by truclc may include, but are not limited to, the
following:
(i) Completely covering open-bodied trucks.
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(ii) Cleaning the wheels and the body of each truck to remove spilled materials
after the truck has been loa'dcd.
(iii) Use of completely enclosed trucks.
(iv) Tarping the truck when operating empty if residue has not been completely
removed after emptying.
(v) Cleaning the residue from the inside of the truck after emptying.
(vi) Loading trucks so that no part of the load making contact with any sideboard,
side panel, or rear part of the load enclosure comes within 6 inches of the top part of
the enclosure.
(vii) Maintaining tight truck'bodies so that leakages within the body will be
eliminated and future leakages prevented. »
(viii) Spraying the material being transported in a vehicle with a dust suppressant.
The frequency of spraying shall be specified in the control program.
(ix) Restricting the speed of the vehicle which transports the material. The speed
of the vehicle shall be specified in the control program.
(4) The following provision applies to outdoor conveying as a source of fugitive dust:
Typical control methods for controlling fugitive emissions resulting from conveying
bulk materials may include, but are not limited to, the following:
(a) Completely enclosing all conveyor belts and equipping them with belt wipers and
hoppers of proper size to prevent excessive spills.
. (b) Enclosing transfer points and, if necessary, exhausting them to a baghouse or
similar control device at all times when the conveyors are in operation.
(c) Equipping the conveyor belt with not less than 210-degree enclosures.
(d) Restricting the speed of conveyor belts. The belt speed shall be specified in the
control program.
(e) Periodically cleaning the conveyor belt to remove the residual material. The
frequency of cleaning shall be specified in the control program.
(f) Minimizing the distance between transfer points. The distance between transfer
points shall be specified in the control program.
(g) Removing the spilled material from the ground under conveyors. The frequency
of removal shall be specified in the control program.
(5) The following provisions apply to roads and lots as sources of fugitive dust:
(a) Roads and lots which are located within industrial, commercial, and government-
owned facilities and which meet the following 2 conditions are not subject to the
requirement of submitting a fugitive dust control program:
(i) The traffic volume is less than 10 vehicles per day on a monthly average.
(ii) The lots are less than 500 square meters (5,382 feet ) in area.
(b) Typical control methods for controlling fugitive emissions resulting from roads
and lots located within industrial, commercial, and government-owned facilities may
include, but arc not limited to, the following:
(i) Paving roads and parking lots with a hard material, such as concrete, asphalt, or
an equivalent which is approved by the commission.
(ii) Mechanically cleaning paved surfaces by vacuum sweeping, wet sweeping, or
flushing. The frequency of cleaning shall be specified in the control program.
(iii) Washing the wheels of every truck leaving the plant premises.
(iv) Treating the roads and lots with oil or a dust-suppressant compound which is
approved by the commission. The frequency of application shall be specified in tlie
control program.
(v) Periodically maintaining off-road surfaces with gravel where trucks have
frequent access. The frequency of maintenance shall be specified in the control
program.
(6) The following provisions apply to inactive, storage piles as sources of fugitive
dust:
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(a) - Inactive storage piles that are less than or equal to 500 cubic meters (G
yards ) in volume arc not subject to the requirement of submitting a fugitivr dust
control program.
(b) Typical control methods for controlling fugitive emissions resulting from
inactive storage piles-may include, but are not limited to, the following:
(i) Completely covering the pile with tarpaulin or other material approved by the
commission.
(ii) Completely enclosing the pile within a building.
(iii) Enclosing the pile with not less than 3 walls so that no portion of the stored
material is higher than the walls. '
(iv) Periodically spraying the piles with water or other dust-suppressant compound
approved by the commission. The frequency of application shall be specified in the
control program.
(v) Growing vegetation on and around the pile.
(7) The following provisions apply to building ventilation as a source of fugitive
dust:
(a) This subrule is applicable to all of the following:
(i) Ferrous and nonferrous foundries.
(ii) Electric arc furnaces, blast furnace casihouses, sinter plants., and basic oxygen
processes at iron and steel production facilities.
(iii) Metal heat treating.
(iv) Metal forging.
(v) Bulk material handling, storage, drying, screening, .and crushing.
(vi) Metal fabricating and welding.
(vii) Briquetting. sintering, and palletizing operations.
(viii) Machining and pressing of metal.
(ix) Stone, clay, and glass production.
(x) Lime, cement, and gypsum production.
(xi) Chemical and allied product production.
(xii) Asphalt and concrete mixing operations.
(b) Typical control methods for controlling fugitive emissions resulting from
building openings, such as roof monitors, powered and unpowered ventilators, doors,
windows, and holes in the building structure integrity, may include, but are not limited
to, the following:
(i) Exhausting the entire building to a dust collection system which i.s acceptable to
the commission.
(ii) Using local hoods connected to a dust collection system to capture emissions
within the building.
(iii) Establishing and maintaining operating procedures and internal housekeeping
practices (specify details).
(iv) Installing removable filter media across the vent opening's.
(8) The following provisions apply to fugitive dust emissions from construction,
renovation, or demolition activities located in priority I areas:
(a) This subrule is applicable to the ov/ner or prime contractor, except for those
owners or prime contractors who construct, renovate, or demolish less than 12 single-
family dwelling units per year.
(b) Typical control methods for controlling fugitive dust emissions from construc-
tion, renovation, or demolition activities may include, but are not limited to, the
following:
(i) Spraying of all work areas with water or other dust-suppressant compound which
is approved by the commission.
(ii) Completely covering the debris, excavated earth, or other airborne materials
with turpaulin or any other material which is approved by the commission.
(iii) Any other method acceptable to the commission.
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County
Calhoun
Genesee
Saginaw
Wayne
TABLE 33
Priority I areas
Area
T2S, R4W, Section 3*.
Starting at intersection of Stewart Avenue and north Saginav/ .Street,
then east along Stewart Avenue to Dort Highway to Franklir. Avenue
to Hamilton Avenue to Saginaw Street to Stewart Avenue.
T12N, R5E, Sections 7, 8, 17, and IS.
Area included within the following (counter clockwise): Lrke St.
Clair to Moross Road to Seven Mile Road to Yar.Dyke Road ts Eight
Mile Road to Wyoming Road to Seven Mile Road to Schaeffer !'!.oad to
Fenkell Road to Greenfield Avenue to Joy Road to So i;hfield
Expressway to Ford Road to Telegraph Road to Cherry Hill '-load to
Beech-Daly Road (extended) to Michigan Aver us to Inkster T'ond to
Carlysle Street to Middle Belt Road to Vanborn Road to V/ayr- Road
to Pennsylvania Road to Middle Celt Road to Sibley Ro?.c! to
Telegraph Road tc King Road to Grange Road to Sibley Road to
Jefferson Avenue to Bridge Street (Grosse He) extended to Detroit
River.
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TABLE 34
Priority II areas
County
Bay
Berricn
Pelta
Emmet
Genesee
Area
Ingham
Kent
Maccmb
Manistee
Marquette
Mason
Midland
Monroe
Muskeg on
Oakland
Saginnw
St. CJoir
T14N, R5E, Sections 14-16 and 21-23.
T4S, R18W, Sections 7, 8, 17-20, 29, and 30.
T4S, R19\V, Sections 12-14 and 23-27.
T39N, R22\V, Sections 19, 30, south one-half of 17, and south one-half
of 18.
T34N, R6W, Sections 1-3 and 9-12.
Starting at intersection of Carpenter Road and DuPcnt Street, then
east on Carpenter Road to Center Road, then sot'th to M-21, then
west to 1-475 to Bristol Road, then west to 1-75, then north to
Corunna Road (M-56), then east to Flint city limits, then north to
Pasadena Avenue, then east to DuPont Street to Carpenter Road.
T4N, R2W, Sections 2-11 and 14-23. •
T7N, Rll\V, Sections 19, 30, and 31;
T7N, R12\V, Sections 22-27 and 34-36.
T4N, R14E, Sections 27, 2S, 33, and 34;
Macomb County south of the T2N north township line.
T21N, R16W, Sections 7,1S, and 19;
T21N, R17W, Sections 12 and 13.
T48N, R25W, Sections 1 and 2.
T18N, R18W, Sections 13, 14, 23, and 24.
T14N, R2E, Sections 14-16, 21-23, 26-28, and 33-35.
Exeter, Ash, Berlin, Raisinville, Monroe, and^Frenchtown Townships,
incorporated cities and towns inclusive.
T9N, R16W, Sections 5 and 6;
T10N, R16W, Sections 21, 22, and 27-34.
T3N, R10E, Sections 15, 16, 21, 22, 27, and 28;
Area included within Coolidge Road, Ten tMile Road, Campbell Road,
fourteen Mile Road, Dequindre Rpad, and Eight Mile Road.
T12N, R4E, Sections 1, 12-15, 22-27, and 34-36;
T12N, R5E, Sections 4-6, 9, 16, 19-21, and 28-33.
T6N, R17!:, Sections 2-4, 9-11, 14-16, 21, 22, and 28.
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County
Washtcnaw
t
Wayne
TABLE 34
(continued)
Priority II areas
Area
Area within Cross Street, Huron Street, Harris Road, and 1-9^ near
Ypsilanti.
The area included within the following (counter clockwise):
Lake St. Clair to Eight Mile Road to Schaeffer Road to McN'ichoIs
Road to Greenfield Avenue to Schoolcraf t Avenue to Evergreen Road
to 3oy Ro'ad to Telegraph Road to Ford Road to Beech-Daly Toad to
Cherry Hill Road to Inkster Road to Carlysle. Street to Mic'r'.c Belt
Road to VanBorn Road to Wayne Road to Ecorse Road to H:..;~.erty
Highway to Tyler Road to Belleville Road to 1-9'; to Rawsonvii:- Read
to Oakville Waltz Road to Will Carleton Road to the Huron Rl ,'c-r to
Lake Erie, except subarea listed in table 33.
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niffESOTA
ACEKCY RULES APC «
CHAPTER SIX: APC 6
AFC 6 Preventing Particulate Matter from Becoming Air-Borne
(a) No person shall cause or permit the handling, use, transporting, or
storage of any material in a manner which may allow avoidable amounts
of paniculate matter to become air-borne.
(b) No person shall cause or permit a buflding or its appurtenances or
a road, or a driveway, or an open area to be constructed, used, repaired or
demolished without applying ail such reasonable measures as may be re-
quired to prevent particulars natter froia becomins air-borne. The Director
dust-free surfaces; application of water, and the planting and maintenance
of vegetative ground cover.
[July 7,19693
27
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OHIO
3745-17-08 Restriction of emission of fugitive dust.
(A) Applicability: '
0) EXCEPT AS OTHERWISE INDICATED IN PARAGRAPH (A) (4) OF THIS RULEA
?he THE requirements of paragraph (B) of this rule shall apply
to any fugitive dust source which is located within the areas
Identified in Appendix A of this rule-j
Except as additional time for achieving compliance is provided
1n paragraph (C) of rule 3745-17-04 of the Administrative Code,
any such source shall comply with the requirements of paragraph
(B) of this rule upon the effective date of this rule.
(2) NOTWITHSTANDING THE EXEMPTIONS IN PARAGRAPH (A) (4) OF THIS
RULEj_ ?he THE requirements of paragraph (B) of this rule shall
apply to any fugitive dust source regardless of location if, in
the director's judgment, probable cause exists to believe that
such source is causing or contributing to a nuisance in violation
of rule 3745-V5-07 of the Administrative Code. In such cases,
the director may require the owner or operator of the fugitive
dust source to apply for and obtain a permit to operate for the
source in accordance with rule 3745-35-02 of the Administrative
Code, and/or require the ov/ner or operator to submit and implement
a control program which will bring the fugitive dust source
Into compliance with the requirements of paragraph (B) of this
rule as expeditiously as practicable.
(3) If deemed appropriate by the director, compliance with the
requirements of paragraph (B) of this rule may be determined on
a facilitywide basis.
.(4) THE REQUIREMENTS OF PARAGRAPH (B) OF THIS RULE SHALL NOT APPLY
TO:
' {a) ANY FUGITIVE DUST SOURCE WHICH IS LOCATED AT A GRAIN
ELEVATOR HAVING A PERMANENT STORAGE CAPACITY OF LESS THAN
2.5 MILLION BUSHELS; AND
FUGITIVE DUST GENERATED BY THE FOLLOWING SOURCES AT THE
"ARMCO INC.. MIDDLETOWN WORKS^ (OEPA PREMISE .NUMBER 1809010006),
LOCATED ON CRAWFORD STREET, WODLETOWN, OHIO:
(1) NUMBER 3 BLAST FURNACE (OEPA SOURCE NUMBER P02S);
(11) NUMBER 15 BASIC OXYGEN FURNACE SHOP (OEPA SOURCE NUMBER
P026); AND
(111) NUMBER 16 BASIC OXYGEN FURNACE SHOP (OEPA SOURCE NUMBER
£027). '
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(B) No person shall cause or permit any air contaminant source to be
operated; or any materials to be handled, transported, or stored; or a
building or its appurtenances or a road to be use, constructed,
altered, repaired, or demolished without taking or installing reasonably
available control measures to prevent fugitive dust from becoming
airborne. Such reasonably available control measures shall include,
but not be limited to, one or more of the following which are appropriate
to prevent fugitive dust from becoming airborne: .
(1) The use of water or other suitable dust suppression chemicals for
the control of fugitive dust from the demolition of existing
buildings or structures, construction operations, the grading of
roads or the clearing of land;
- (2) The periodic application of asphalt, oil, water, or other suitable
dust suppression chemicals on dirt or gravel roads.-and parking
lots, and other surfaces which can create airborne dusts;
(3) The installation and use of hood's, fans, and other equipment to
adequately enclose, contain, capture, vent and control fugitive
dust from an air contaminant source. Such equipment shall be
deemed adequate by the director if:
(a) The collection efficiency is sufficient to minimize or eliminate
visible emissions of fugitive dust at the point(s) of capture
to the extent possible with good engineering design; and
(b) The equipment achieves an outlet grain loading of .030
grains per dry standard cubic foot of exhaust gases or there
are no visible emissions from the exhaust stack(s), whichever
Is less stringent;
.(4) For ship loading operations at grain terminals:
(a) Except during topping-off periods or during the loading of
tween-deckers or tankers, the covering of the hatches and
loading spouts with tarpaulin covers, to the extent practicable,
and evacuation of the hatches to control equipment which is
designed to achieve an outlet grain loading of .030 grains
per dry standard cubic foot of exhaust gases; or
(b) The installation and use of control measures such as deadbox
or bullet-type loading spouts which are equivalent to or
better than the overall control efficiency of the measures
described in paragraph (B)(4)(a) of this rule:
(5) The use of adequate containment methods during sandblasting or
other similar operations;
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(6) The periodic application of water or other suitable dust suppression
M chemicals, the Installation of storage silos, bins or other
*>' enclosed structures, or the use of canvas or other suitable
'coverings, for all materials stockpiles and stockpiling operations,
except temporary stockpiles and stockpiling operations for grain
.- and grain products, to minimize or eliminate visible emissions of
airborne dust;
(7) The covering, at all times, of open bodied vehicles when transporting
materials likely to become airborne;
(8) The paving of roadways and the maintaining of roadways in a clean
condition; and
(9) The prompt removal, in such a manner as to minimize or prevent
resuspension, of earth or other material from paved streets onto
which earth or other material has been deposited by trucking or
earth moving equipment or erosion by water or other means.
(C) Any owner or operator of a facility which contains a fugitive dust
source and which is located within any area identified in Appendix A of
this rules shall submit a certification and/or application for a permit
to operate in accordance with paragraphs (B) and (C) of rule 3745-17-04
of the Administrative Code'.
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WISCONSIN ADMINISTRATIVE CODE
NKIM
NR 154.11 Control of paniculate emissions. I ]) GENERAL LIMITATIONS.
No person shall cause, allow, or permit participate matter to be emitted
into the ambient air which substantially contributes to exceeding of an
air standard, or creates air pollution.
(2) FUGITIVE OUST. No person shall cause, allow, or permit any materi-
als to be handled, transported, or stored without taking precautions to
prevent particulate matter from becoming airborne. Nor shall a person
allow a structure, a parking lot, or a road to be used, constructed, al-
tered, repaired, sand blasted or demolished without taking such precau-
tions.
*
(a) Such precautions shall include, but not be limited to:
1. Use, where possible, of water or chemicals for control of dust in the
demolition of existing buildings or structures, or construction opera-
tions.
2. Application of asphalt, oil, water, suitable chemicals, or plastic cov-
ering on dirt roads, material stockpiles, and other surfaces which can
create airborne dust, provided such application does not create a hydro-
carbon, odor, or water pollution problem.
3. Installation and use of hoods, fans, and air cleaning devices to en-
close and vent the arts* where dusty materials are handled.
4. Covering or securing of materials likely to become airborne while
being moved on public roads, railroads, or navigable waters.
5. Conduct of agricultural practices such as tilling of land or applica-
tion of fertilizers in such manner as not to create air pollution.
6. The paving or maintenance of roadways or parking lots so as not to
create air pollution.
(b) In addition to meeting the requirements of par. (a), any direct or
portable source located in a nonattainment area identified under s. NR
154.03 (1) for suspended particulate matter; and any director portable
source located near such areas whose aggregate fugitive dust emissions
may cause an impact on the ambient air quality in such areas equal to or
greater than one microgram per cubic meter (annual concentration) or 5
micrograms per cubic meter (maximum 24-hour concentration), as de-
termined by the analysis under s. NR 154.03 shall meet the following
RACT requirements:
1. Storage piles having a material transfer greater than 100 tons in any
year: a. Storage piles of material having a silt content of 5e"o to20'V. shall
be treated with water, surfactants, stabilizers or chemicals; draped; or
enclosed on a minimum of 3 sides. Access areas surrounding storage
piles shall be watered, cleaned or treated with stabilizers as needed to
prevent fugitive dust from vehicle traffic.
b. Storage piles of materials having a silt content of 20% or more shall
be completely enclosed or draped except any part being worked, loaded
or unloaded. Access areas surrounding storage piles shall be watered,
cleaned or treated with stabilizers as needed to prevent fugitive dust
from vehicle traffic.
2. Materials handling operations: a. Materials handling operations, in-
cluding but not limited to crushing, grinding, mixing, screening, com-
pacting, conveying, handling of waste material with more than 5% silt,
and loading and unloading of railcar, truck, ship or barge shall have fugi-
tive emissions controlled to 20% opacity when wind speeds are less than
25 miles per hour except for 3 minutes in any hour when fugitive emis-
sions may equal 50% opacity.
b. Any device used to control fugitive emissions from materials hand-
ling operations which has a discharge to the ambient air shall be con-
trolled equal to or less than 0.20 pounds of particulate matter per 1000
pounds of exhaust gas.
3. Process fugitive emissions: a. Any device used to control fugitive*
particulate emisiions from processes which has a discharge to the ambi-
ent air shall be controlled to an exhaust gas concentration equal to or
less than 0.20 pounds of particulate matter p"er 1000 pounds of exhaust
gas.
b. Emission;; from any building or structure egress other than a stack
shall be controlled such that visible emissions shall not exceed 20''i
RrflmUt, October. !'J«A No 322
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opacity except for 3 minutes in any hour when fugitive emissions may
equal 50ru opacity.
(c) In addition to meeting the requirements of par. (a), private indus-
trial or commercial trafficable areas, roads and driveways which are lo-
cated in or within one mile of a nonattainment area identified under s.
NR 154.03 (1) for suspended paniculate matter, are 20,000 square feet
or more in total area, are on contiguous property under common owner-
ship or control, and are subject on 3 separate days during any 14 consec-
utive day period to motor vehicle traffic at any point within the roads,
driveways or trafficable areas at a rate equal to or greater than 10 motor
vehicles per 60 minute period, shall meet the following RACT emission
limitations:
1. Be paved with asphalt, concrete or other material approved by the
department, or use other methods of dust control which the department
approves as representing RACT for the particular road, driveway or
trafficable area. Such other methods of dust control which may be ap-
proved by the department include but are not limited (o periodic appli-
cation of water, oil or suitable chemicals. In reviewing and acting upon
plans required by par. (d) for compliance with this paragraph, the de-
partment shall consider the effects of the use of paving or other methods
of dust control upon the rate aixl volume of surface water runoff and
water quality.
2. If paved, lie kept reasonably free of material likely to become air-
borne, through a program of periodic cleaning.
(d) When a direct or portable source is subject to the emission limita-
tions of par. (b), (c) or (el the owner or operator may not exceed the
following increments of progress in achieving compliance commencing
with the nonattainment determination under s. NR 154.03 (1):
1. Submit plans for compliance within 8 months.
2. Award any necessary contracts within 15 months.
3. Commence construction, installation or modification of emission
control techniques required under pars, (b) 1. and 2.a., (c) and (e)
within 18 months.
4. Commence construction, installation or modification of emission
control techniques required under par. (b) 2.b. and 3. within 24 months.
5. Complete construction, installation or modification of emission
control techniques required under pars, (b) 1. and 2.a., (c) and (e),
achieve compliance, and so certify to the department within 21 months.
6. Complete construction, installation or modification of emission
control techniques required under par. (b) 2.b. and 3. within 30 months
and achieve final compliance and so certify to the department within 33
months.
(e) In addition to meeting the requirements of par. (a), any roadway
or public trafficable area which is located in or within one mile of a
nonattainment area identified under s. NR 154.03 (1) for suspended
particulate matter and which is subject on 3 separate days during any 14
consecutive day period to motor vehicle traffic at any point within the
roadway or public trafficable area at a rate equal to or greater than 10
motor vehicles per GO minute period shall meet the RACT emission limi-
tations of this paragraph. For purposes of this paragraph, ownership or
control of different portions of a roadway or public trafficable area by
different municipalities, interstate agencies, state agencies or federal
agencies may not be considered in determining the contiguous area of
the roadway or public trafficable area.
1. If paved, roadways and public trafficable areas covered by this par-
agraph shall be kept, through a program of periodic cleaning, reasonably
free of material likely to become airborne. This subdivision does not ap-
ply to a public traffic able area of less than 20.000 contiguous square feet
in area unless the public trafficable area is also a roadway.
2. If unpaved, roadways and public trafficable areas covered by this
paragraph shall be paved with asphalt, concrete or other material ap-
proved by the department, or use other methods of dust control which
the department approves as representing RACT for the particular road-
way or public trafficable area. Such other methods of dust control which
may be approved by the department include but are not limited to peri-
odic application of water, oil or suitable chemicals. In reviewing and act-
ing upon plans required by par (d) for compliance with this paragraph.
the department shall consider the effects of the use of paving or other
methods of dust control upon the rate and volume of surface water run-
off and water quality. This subdivision does not apply to roadways or to
public trafficahle areas which have less than 20,000 contiguous square
feet of unpaved surface area.
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GATHERING EVIDENCE FOR A COMPLIANCE DETERMINATION
The compliance inspector will generally be asked to make an inspection of a
given source by an enforcement investigator, such as an Air Compliance Branch
engineer. From that point, the responsibilities of the inspector may be
summarized as follows:
1. To research the source to determine any FU sources involved and
the applicable regulation(s).
2. If emissions can be seen from off the property of the source, to take
VE readings and/or photographs—from outside the property line if possible,
as appropriate.
3. Then, equipped with appropriate safety gear, a camera, and notebook,
to visit the source and communicate the intention of the visit to the
responsible official, typically the plant or facility manager/
supervisor or the environmental officer. (Should access be denied,
to leave the premises and contact an Agency attorney, who can secure
either access or formal denial of access, in which case legal action
may be pursued.)
4. Once access is secured, to continue the investigation within the plant
and with the plant personnel assigned for the duration of the inspection
visit. (In order to maximize time and to minimize the chance of forgetting
an important step, consult the Inspector's Checklists beginning on the
next page.)
5. Upon concluding inspection, to prepare for and submit to the request-
ing enforcement investigator a report that covers each point on the
checklists, answers any specific questions the requestor may have
asked, and notes any unusual findings.
The inspector's findings can then be compared to the pertinent State regula-
tion or State permit, approved by U.S EPA as part of the SIP, and to the aims
of any FD control program expected to be in operation. Compliance or a
violation can be determined from these comparisons.
If a violation is determined, an NUV can then be issued to the source.
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COMPLIANCE INSPECTOR'S CHECKLISTS
An inspection to determine compliance with FD rules is actually composed of
several separate inspections:
- a visual inspection of tne facility in order to observe emission
sources and any controls,
- examination of tne source's control equipment,
- observations of any spraying operations undertaken by the source
during tne inspector's visit, and
- an examination of tne source's records.
Wnen emissions are visible, the inspector can also expect to take photographs,
which may document both the extent of the emissions and any movement of
tnose emissions across property lines, and VE readings, in order to determine
opacity, where possible.
Tne following cnecklists are offered as a reminder of key information to be
obtained by the inspector. They can be further refined according to specific
needs; they also can be arranged in traditional checklist or chart format.
In all cases, prior to inspection it is necessary to contact State/local authorities
for permit requirements and to review any regulations for FDs.
INFORMATION TO BE OBTAINED DURING VISUAL INSPECTION
1. FD points. Are all points listed in State permit/
control plan still existent? Are there
additional points tnat are not noted in
the files?
2. For each control measure, note and evaluate equipment being used.
a. Enclosures, hooding Is there a fan and control device as-
sociated with the enclosure?
b. Distance at materials drop points Are telescoping spouts used? Is the
system capable of varying the height?
c. Vegetation What type(s)? Where planted?
d. Spraying What suppressant is used? Frequency?
Is a surfactant used? If so, what kind
and in what dilution?
e. Stationary spraying systems Are they located as indicated in files?
Are they in use? Are nozzles plugged?
f. Vacuuming of paved roads, lots What frequency? What type equipment?
Describe, including model number.
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g. Paving of roads, lots
h. Any other measures?
Is paving work finished?
Are paved surfaces vacuumed or flushed?
Describe.
EXAMINATION OF CONTROL EQUIPMENT
1. Types of equipment.
Does equipment match the
information from control plan
files? List each. Does it
appear to be well-maintained
and recently used? Is there
evidence that the source can and
does make repairs to FD con-
trol equipment? Specify.
Determine dilution rates of any
chemical suppressants used,
either at this stage or
during spraying operations.
INFORMATION TO BE OBTAINED DURING SPRAYING OPERATIONS
1. Observe areas to be sprayed.
2. Inquire about O&M procedures.
3. Examine reports re: spraying.
4. Examine any chemical suppressants.
5. Inspect stationary spraying towers.
Do this at least twice, several
hours apart, during the visit.
Photographs may be appropriate;
so may be VE readings. Determine
if spray nozzles are plugged.
Ask to see source's checklist and
schedule.
How frequent are the applica-
tions? What amounts of water
or chemical suppressants are
used? Do these meet manufac-
turer' s specific at i o n s ?
If requested, take a sample of each
for follow-up laboratory analysis.
Identify and cross-check with
manufacturer's instructions
for use.
Do they appear to be regularly
operated?
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INFORMATION TO BE OBTAINED FROM SOURCE'S FILES
1. Copy of State permit to operate.
2. Copy of source's control plan.
3. Resource program and assignments.
4. Equipment purchases.
5. Recordkeeping program.
6. Self-monitoring procedures.
7. Maps of FD points.
8. Stationary spraying systems using
water or cnemical suppressant.
9. Ambient air monitoring stations.
Check for any conditions that
pertain to source's operations.
Ask if source is aware of exist-
ing rules. Note any FD controls
needed.
Does control plan address each
needed control noted in State
permit and thus comply with the
permit?
Has staff been assigned to
implement the control plan?
Does a budget exist?
Are there order forms and invoices
tnat quantify equipment to be
used in support of control plan?
Note specific equipment, which
can be expected to be seen out-
side the office. Include chemi-
cal suppressants as equipment, as
well as fencing, ducting, vegeta-
tation, etc.
Are records being kept? Do
they cover the duration of
the control plan? Is there
a current O&M scnedule for
implementing the control plan?
Note frequency of controls. Are
there records of VE readings?
Of surprise inspections by con-
trol plan supervisor?
Do they exist? Do they locate
any air monitoring stations?
Do they correspond to FO points
as mapped? Do they spray the
proper liquid?
Are they located appropriately
to control FDs from large piles?
Are the piles mapped?
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APPENDIX
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CONTROL MEASURES
FOR A
SOURCE'S CONSIDERATION
Wnen a source decides to control its fugitive dust emissions, it generally must
do so without benefit of guidance from those who may later measure the effec-
tiveness of those controls.
What follow here are several basic control techniques and programs that a source
may choose to consider. The order in which these steps are taken will vary
according to the circumstances of each source. Bringing about and/or main-
taining compliance is the goal.
-Identify fugitive dust regulation requirements.
-Increase management's awareness of any FD problems.
-Develop maps that locate FD points.
-Develop an FD control plan to assure compliance with regulations,
including a schedule for spraying.
-Assign resources to execute control plan.
-Design and install stationary spraying systems amenable to wet sup-
pression for large storage piles.
-Install air monitoring stations if size of storage area warrants.
-Identify and purchase essential equipment.
-Develop operating and maintenance (O&M) procedures.
-Train personnel to implement O&M procedures and control plan.
-Design simple recordkeeping procedures.
-Design inspection procedures to ensure compliance, including the
taking of VE readings.
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THIS MONTH'S PROBLEM
Paul Baur
Is there a better way to eliminate coal-pile dust?
Our plant has been increasing its stockpiling of coal during
the past three years. We had not had extensive land area
for this, but by taking over part of an outside storage yard,
we obtained a long strip about 100 ft wide and 1000 ft long.
We have built up a pile about 80 ft wide and the full length
of the area, using a small bulldozer, which compacts the
pile and reclaims the coal to the conveyor when needed.
We probably have about 30,000 tons in the pile now.
Our main trouble Is with dust from the pile blowing out
Into local yards and houses. Prevailing winds are across the
pile and can often exceed 20 mph for many hours. We have
tried chemicals on the pile but they were only marginally
effective and were expensive. We try to use coal from all
along the pile, to prevent any'of it from standing and
weathering too long, and chemical loss is therefore proba-
bly more than for some other plants. Planting of trees or
building of a screen has also been suggested.
What experience have POWER readers had with measures,
such as water spray, to suppress dust loss from coal piles?
Does the shape of the pile affect the loss? Would a
rubber-tired vehicle make for fewer fines than our present
bulldozer does?—JO, October POWER
Solutions
Manage live- and dead-storage areas
There are no surefire solutions to keeping fugitive-dust
emissions in check, particularly in high winds. Many
factors help to create a fugitive-dust problem, includ-
ing:
• Coal properties: chemical makeup, friability, size
distribution, moisture content.
• Weather conditions: rainfall, humidity, windspeed.
• Stacking/reclaiming methods: truck, conveyor
chute, bulldozer.
Our experience with coal-fired powerplants in India
indicates that occasional water spraying is the only
feasible method of suppressing coal dust in outdoor piles.
Permanently mounted water sprinklers located in trou-
blesome areas such as unloading chutes have been suc-
cessful in some applications. We found that water addi-
tives to help in fines agglomeration work marginally at
best.
Dust control is best achieved by adopting well-coordi-
nated inventory measures for material, and by selectively
segregating live- and dead-storage zones. Dead storage
should have suitable permanent or semipermanent sur-
face protection such as grass growth, coal tar, or pitch,
and should be used only in an emergency. Reclamation
should be restricted to a relatively small portion of the
total pile, with constant attention paid to dust control by
water dousing.
We do not think that screens provide a sound engi-
neering solution to controlling fugitive dust. We also
reject the belief that rubber-tired vehicles create less
fines than bull dozers. B K MITRA, Philadelphia, Pa
Water and compact it, or bury It
Our plant maintains a 2.1-million-ton coal pile with
prevailing winds ranging up to 60 mph for several days
at a time. We have found that chemicals are not a very
effective dust suppressant. We use water instead, mainly
to assist in obtaining optimum compaction of the coal.
The best way to limit fugitive-dust emissions is to
make part of the pile a dead-storage area. We water this
section, compact it with a vibratory roller, and leave it
alone. Of course, this approach assumes that oxidation is
not a significant problem. We have determined through
fuel analysis that when our pile is compacted to an
average of 70-80 Ib/cu ft, heat content of the coal won't
seriously degrade until after five years of storage. After
this period, we know that it's time to start rolling over
the area. Regarding dead-storage areas: Count on having
high coal-dust blowoff after initial buildup and a fast
decrease in emissions thereafter. Also, if you are in a
high freeze/thaw area, you should expect to see a slight
increase in emissions after each freeze and thaw-out
period.
Another solution is to put the coal pile in a subsurface
storage area—if the water table permits—so that the top
of the pile is below grade and out of harm's way.
128
Power, January 1983
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Conveyor belt
-Dead storage
rrr
f Wind direction
t * t t
Consider also creating a large dead-storage area and a
small active or live-storage area to provide maximum
shielding of live areas from the elements (figure). This
will reduce, but not eliminate, your fugitive-dust prob-
lem. Only protective covering will contain emissions
completely.
In our experience, there appears to be no difference in
fines production between rubber-tired and track-type
bulldozers. G LEARY, P.E., Page. Ariz
The downside of spraying with water
If you spray stored coal with water, it may crumble and
become more susceptible to spontaneous combustion,
particularly if the pyrites content is high. When properly
compacted, a rectangular pile with sloped sides and a
crowned top to aid in drainage will deter wind losses.
If outdoor storage won't be used for relatively long
periods, consider covering the pile with an airtight
asphalt or road-tar seal. Surfaces exposed directly to
prevailing winds may require greater thickness. Care
must be taken to prevent rupture of the seal by moving
vehicles, picks, and shovels. Some type of provision for
thermal expansion and contraction of the pile should also
be considered.
In some cases, construction of a concrete enclosure for
a pile may be justified. H B WAYNE, Jamaica, NY
Don't discount chemicals completely
JD said that he had tried chemicals without notable
success, but he may not have realized that there are
several types of chemicals available. The newer ones are
reportedly more effective in fugitive-dust control.
According to reports from the manufacturer, these poly-
mers form a relatively long-lasting bond layer on the
surface of the pile. The surface is permeable, so there is
no alteration in water-runoff characteristics. The bound
layer also reportedly resists breakage when the pile
settles. If these claims are true, then maybe JD should
give chemicals another try.
W F FLOWERS, Oak Brook, III
Use chemicals more effectively
Surface-treatment techniques may be the only hope for
low-grade coals—such as low-rank subbituminous—
which contain an excessive amount of fines and degrade
under the effects of weathering. Several organic poly-
mers and a petroleum resin/water emulsion are the most
commonly used sprays. Most are designed to be compat-
ible with the environment, resist degradation from bacte-
ria, oxidation, and sunlight, and will not interfere with
the quality or subsequent use of the coal. __^^_ _
The success of chemical crusting as dust controller,
however, depends on several factors, including:
• Pile preparation. The pile should be compacted to
ensure a competent base for the crust. Sides should have
at least a 2:1 slope both to allow for thorough and
convenient compaction and to keep the crust from crack-
ing and separating. Piles should be shaped to remove
sharp edges or ridges that would be prone to wind
erosion, and to avoid partial vacuums or eddy currents
that would lift the crust.
• Application method. The only equipment needed
here is a tank truck with a pump that can develop
enough pressure to spray all portions of the stockpile.
Some plants also use crusting agents to obtain benefits
other than dust control. By using a latex polymer
compound, for example, we've been able to seal off the
pile from the effects of weather. With this type of
treatment, the pile actually loses moisture. Reason: A
greenhouse effect is created by the covering, which
reduces the chance of spontaneous combustion and
weathering. S B K.IERNAN, Providence, Rl
Keep down coal dust
without soaking it
Water sprays are effective for cutting
down on coal dust, but the added mois-
ture hurts boiler effectiveness. To get
around this problem at its first full-scale
coal-preparation installation in Charles-
ton, SC, Westvaco Corp is installing a
dry-fog dust-suppression system.
The system, supplied by Sonic Devel-
opment Corp, Mahwah, NJ, uses water
to suppress the dust, but in the form of a
fine spray instead of a shower that wets
the coal. Spray bars at inlets and outlets
of the coal crusher and transfer tower
are equipped with special spray nozzles
(sketch), which create a mist of fine
droplets within the shrouds. The droplets
collide with airborne coal particles which
agglomerate and fall on their own. The
system has now been successfully operat-
ing for over 18 months.
An alternative dust-suppression sys-
tem using fabric filters was rejected
because of the widely dispersed dust-
generation points. Duct runs of ISO to
200 ft would have been needed, adding
to the cost and the time needed for
installation. Wet sprays also can cause
freezeup problems in winter.
DONALD R GRENNAN, Edison, NJ
•Resonator
chamber
Liquid
energy-core
130
PMMT. Jmwy 1M3
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FD CONTROL EQUIPMENT
The products and/or companies listed beginning on page 71 nave been reported
by a sampling of Region V sources to be effective in various FD control
operations. Tneir listing nere or mention earlier in tnis guidance package
does not in any way constitute endorsement or recommendation for use by the
United States Environmental Protection Agency.
DUST-SUPPRESSANT CHEMICALS
Johnson-Marcn Corp.
Nalco Chemical Company
Neyra Industries, Inc.
Zenex Corporation
Philadelphia, PA (Compound MR)
Oak Brook, IL (NALCO 8820)
Cincinnati, OH (Resinex)
Chicago, IL (Dustgard)
DUST-SUPPRESSANT SPRAY TRUCKS
Syntech Products Corp. -
Toledo, OH
HIGH-PRESSURE SPRAY TRUCKS
Peabody Myers Corp.
Streator, IL
VACUUM STREET SWEEPERS
Central Engineering Co.,
Vac-All Division
Elgin Sweeper Company
Peabody Myers Corp.
Tennant Company
Milwaukee, WI
Elgin, IL
Streator, IL
Minneapolis, MN
FIXED WIND FENCES
AeroVironment, Inc.
Pasadena, CA
Concentrations of chemical dust suppressants and frequency of use are best
developed by experience, since eacn source affected by FDs may present a
different set of problems. In-house engineering is generally considered
tne best bet for developing stationary spraying systems.
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TYPICAL FD CONTROL PLAN
FOR
COAL-FIRED POWER PLANTS
(Commonwealtn Edison Company)
[Commonwealth Edison Company developed the guidance materials that follow
as a generic control plan for coal-fired utility stations. Individual
Commonwealth Edison stations then tailored these materials to their own
needs and specifications.]
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Fugitive Particulate Matter
Operating and Maintenance Procedure
Facility Naiae;
Facility Address:
Responsible Person
for Execution of
Operating Program: Station Superintendent
I. Purpose
To control sources of fugitive dust on Station property
within regulatory limits through a documented dust-suppression program which
includes treatment of storage piles, treatment of roads and grounds and
control measures applied to coal*handling and ash-handling facilities.
II. References
A. Illinois Pollution Control Board Rule 203(f) of
Chapter 2: Air Pollution dated October 4, 1979.
B. Drawing of Generating
Station property showing the locations of:
1. storage piles .
2. conveyor loading operations
3. roads surrounding the storage piles
4. roads within station property
5. location of unloading and transporting opera-
tions with emission control equipment.
C. Attachment 1: Specifications for particulate
collection equipment, water and chemical spray
equipment, and chemical solutions.
III. Regulatory Limits
A. No person shall cause or allow the emissions of
fugitive particulate matter from any process in-
cluding any material handling or storage activity,
that is visible by an observer looking generally
toward the zenith at a point beyond the station
property line.
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B. Paragraph A. shall not apply when the wind speed is
greater than 25 miles per hour. In addition,
spraying of fugitive dust emission sources with
water and/or duet suppressant solutions shall not
be required when the wind speed is greater than 25
miles per hour. Determination of wind speed for
the purposes of this procedure shall be by a one-
hour average value from the National Weather Ser-
vice Station at O'Hare Airport. One-hour-average
wind speed values from O'Hare Airport may be ob-
tained by dialing the National Weather Service
recorded message at 312/976-1212.
IV. Procedure
A. Coal Pile Management
1. Coal Stacker Telescopic Chute
The coal stacker will be equipped with a
telescopic chute which will allow for minimum
free-fall distance of conveyed coal onto the
pile. In the event that the telescopic chute
malfunctions, repairs will be made as soon as
possible to restore the chute ts service.
Coal conveying operations will continue dur-
ing malfunctions.
2. Treatment of the Coal Pile
a. Active and Inactive Areas
The treatment of the coal pile will vary
according to whether the area of the
pile is active or inactive. An active
pile area is one which is frequently
being worked or disturbed by the action
of coal pile vehicles and equipment. An
inactive pile area is one which remains
relatively undisturbed for more than
several days. For example, the coal
pile slopes are inactive areas of the
pile.
Inactive areas of the pile will be
marked to show coal handling personnel
which areas to leave undisturbed. All
other areas will be considered active.
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b. Treatment of the Active Arear •
The active areas of the coal pile will
be treated with water sprays from a "•
mobile water wagon.
The coal pile will be treated prior to
and subsequent to the operation of coal-
handling vehicles on the pile. On days
when coal handling vehicles are opera-
tional or anticipated to-ba operational>
the pile will be sprayed with water as
needed to control fugitive dust emis-
sions but no less frequently than once
per day. On days when coal handling
vehicles are not operational or not
anticipated to be operational, the pile
will be sprayed only as necessary to
control fugitive dust emissions.
Water spray treatments will be suspended
for up to 24 hours subsequent to a pre-
cipitation event of 0.1 inch or
greater. Precipitation data will be
obtained from a precipitation gauge
located at Station. A log will
be kept of all precipitation totals
gre'ster than 0.1 inches.
Water spray treatments will be suspended
during the period December 1 through the
end of February and during any other
periods of temperatures less than
32°F. Cessation of spraying treat-
ments during these periods will preclude
damage to equipment from freezing.
Water spray treatments will be suspended
when malfunctions of the water wagon
and/or the fill facilities occur such
that normal spray treatments cannot be
conducted. Repairs will be made as soon
as possible after the occurrence of a
malfunction.
c. Treatment of the inactive areas
The inactive areas of the coal pile will
be treated with a chemical binding agent.
-------
-47-
Th e chemical binding agent will be ap-
plied as needed or at the manufac-
turer's recommended frequency. Re-ap-
plications of the chemical binding agent
will be made as soon as possible after
the inactive areas of the pile are dis-
turbed. In instances when there are
delays in retreating inactive pile areas
with chemical binding agents, the areas
will be treated as active. Vater spray
treatments on the inactive pile areas
will be suspended under the same condi-
tions as apply to water spray treatments
on the active pile areas.
Treatment of the inactive areas of the
coal pile with chemical binding agents
will be suspended under the same condi-
tions as apply to suspension of water
spray treatments.
A log (Figure 1) will be maintained by
the operator of all applications of
chemical binding agents made to the coal
pile.
B. Coal Handling Management
1. Barge unloading coal dust suppression
Barge unloading coal dust suppression will be
accomplished by the oiling of coal at the
mine. Documentation of coal oiling
applications will be available from
Commonwealth Edison's Environmental Affairs
Department upon request.
2. Rotoclone bag filters
Rotoclones on the coal handling system will
be supplemented by bag filters at the crusher
house, at the dock junction house, at the
reclaim hopper, and at the Unit 7 and Unit 8
bunkers. The performance level of this
equipment is determined by observations of
emissions 'and the physical condition of the
equipment.
Routine observations of rotocloae/bagfilter
performance and preventive maintenance
inspections of this equipment will follow the
-------
-48-
procedures specified in the "Particulate
Emissions Compliance Procedures" for
Station, Section—.Daily, weekly, and
quarterly inspection and maintenance forms
(Figures 2, 3, and A) will be completed by the
operator and maintained in the Shift
Engineer's office for inspection.
C. Fly Ash Handling Management
1. Fly Ash Telescopic Chutes
The fly ash silo will be unloaded to tank
trucks through two telescopic chutes. The
flyash unloading control operator will manage
unloading activities so as to minimize spills
and effect clean-up actions in the case of
spills. Flyash spills will be swept up as
soon as possible after they occur.
In the event of a malfunction of the tele-
scopic chutes and appurtenances, repairs will
be made as soon as possible.
2. Ash Silo Bag Filters
The ash silo will vent through a new baghouse
and use the existing baghouse for back-up.
The performance level of this equipment is
determined by observations of emissions and
the physical condition of the equipment.
Routine observations of the performance of
the ash silo bagfilters and preven^tive
maintenance inspections of this equipment
will follow the procedures specified in the
"Particulate Emissions Compliance Procedures"
for Station, Section. Daily, weekly,
and quarterly inspection and mainten^ance
forms (Figures 2, 3( and 4) will be completed
by the operator and maintained in the Shift
Engineer's office.
D. Treatment of Bottom Ash Piles
• Bottom ash storage piles will be treated as needed
with water sprays or chemical binding agents to
control fugitive dust emissions. Spray treat-
ments will be suspended under the same conditions
-------
-49-
as apply to suspension of water spray treatments
on the coal pile.
E. Roads and Grounds
1. Treatment of Paved Areas
Roads within station property have been
paved, as shown on Drawing , to minimize
fugitive dust emissions. Paved •reas will be
swept as needed to minimize fugitive dust
emissions but no less frequently than once
per week.
Sweeping will be suspended when malfunctions
of sweeping equipment occur. Repairs will be
made as soon as possible after the occurrence
of a malfunction.
Sweeping will be suspended when paved areas
are snow and/or ice covered and for up to 24
hours subsequent to precipitation events of
0.1 inches or greater.
Dust and debris collected during street
sweeping activities will be stored in an
onsite dumpster. The dumpster is enclosed on
three sides by a cyclone fence with a wind-
screen^and on the fourth side there is a ramp
leading from local grade level to the top of
the dumpster.
2. Treatment of Unpaved Areas
All normally travelled unpaved roads and
unpaved parking areas will be treated with
water sprays or chemical dust suppressants.
Chemical dust suppressants will be applied as
needed or at the manufacturer's recommended
frequency. Dust suppressant treatments will
be suspended during the period December 1
through the end of February, during any other
periods of temperatures lees than 32°F, and
for up to 24 hours subsequent to precipi-
tation events of 0.1 inch or greater.
In lieu of treatments with chemical dust
auppressantSjunpaved areas will be sprayed
with water as needed to minimire fugitive
-------
-50-
dust emissions. Water spray treatments will
be suspended during the period December 1
through the end of February and during any
other periods of temperatures less than
32°F. Spray treatments will be suspended
for up to 24 hours subsequent to precipi-
tation events of 0.1 inch or greater.
-------
-51-
Figure 1
Record of Coal File
Chemical Binding Agent Treatments
Month, Year
Manufacturer's Name:
Chemical Name:
Minimum Recocmended
Frequency of Treatment;
Date
Areas Treated
Reasons Treatment
Suspended/Not Performed
-------
FORWARD TO SHIFT ENGINEER
-52-
Figure 2
STATION
Coal Handling and Ash Handling
Daily Inspection Report
Procedure
Once daily, while the coal handling and ash handling systems are
in operation, observe emissions at each location noted belcw *nd record the
conditions as found. Show condition at each location as one of the
following:
clear - slight - heavy - dark - off
If the dust control equipment is off, record the reason it is
off. If the reading is heavy or dark, call the Coal Handling Foreman
immediately. Also record pressure differentials as noted below. Return the
completed sheet to the Coal Handling Supervisor.
Conveyors #4 Junction House
Rotoclone
Crusher House Rotoclone/
Bagfilter
Dock Junction House Rotoclone/
Bagfilter
Bunker 7 Rotoclone/Bagfilter
Bunker 8 Rotoclone/Bagfilter
Reclaim Area Rotoclone/
Bagfilter
Ash Silo Bag Filter
Emission
Observations
Bagfilter
Pressure
Differential
N.A.
Work
Request
Number
Date:
Operator:
ShifC Engineer:
-------
-53-
FORWARD TO SHIFT ENGINEER
FIGURE 3
STATION
COAL HANDLING AND ASH HANDLING
WEEKLY INSPECTION REPORT
Procedure
Once per week, while the coal handling and ash handling systems are in
operation, record operating conditions noted below. Return completed form
to the Coal Handling Foreman.
ROTOCLONES/DYNACLONES
BAG FILTERS
Reclaim Area
Crusher House
Dock Junction House
Unit 7 Bunker •
Unit 8 Bunker
Coal Sampler
Bag Filter Blower
Conveyors :#4
Junction House
Dust Silo
Bag Filter
Dust Silo Traveller
Dust Silo
Dynaclone Blower
Bearing
Cond.
Dust
Leaks
Vibration/
Noise
V-Belts
Cond.
Press. Diff.
j
I
I
0082E
Date:
Operator:
Shift Engineer:
-------
FORWARD TO DESIGNATED OPERATING ENGINEER
Figure 4
Bag Filter Quarterly Inspection Report
Coal Handling and Ash Handling System
Inspect bags (torn,
blinded, etc.) W.R. No.
Inspect compartment and
seals for leaks and wear
W.R. No.
Inspect Venturi nozzles
for wear W.R. No.
Check pulse air pres-
sure range and frequency
W.R. No.
Check traveller wear,
wheels and blower
piping W.R. No.
Inspected By
Date
Reclaim
Area
NA
Crusher
House
NA
.
Dock
Junction
House
NA
Unit 7
Bunker
NA
Unit 8
Bunker
NA
Coal
Sampler
NA
Ash
Silo
NA
Ash Silo
Dynaclone
I
in
0082E
RHL:ds
-------
-55-
TYPICAL FD CONTROL PLAN
FOR
IRON & STEEL PLANTS
(ARMCO, INC.)
In the spring of 1979, ARMCO, Inc. implemented a comprehensive fugitive dust-
control plan at its Middletown (Onio) Works. Tne plan was developed as a
result of tne "bubble" concept and is an ongoing program consisting of tnese
seven elements:
1. Reduction of plant vehicular traffic by installing plant perimeter
parking and locker room facilities and establishing a busing program
for employees and contractors.
?.. Paving of unpaved roads, parking lots, and staging areas, and installation
of new paved roads to improve traffic flow, where appropriate.
3. Cleaning of paved areas with daily use of mobile, vacuum-type street
sweepers and water spray trucks.
4. Treatment of unpaved surfaces with water and dust-suppressant solutions.
5. Reduction of bare areas exposed to wind by planting of vegetation.
6. Surface treatment of storage piles with fixed or mobile spray equipment
to minimize windblown emissions.
7. Installation of an ambient air monitoring network to gauge progress and
effects of the program.
The monitoring system was made operational in August of 1979. A total of
16 monitoring sites, six of them ARMCO-operated, were collecting data for all
or part of the year preceding the complete implementation of the fugitive
dust-control program. This network provided an important data base that
allowed comparison of data before and after control and that also could be
used for calibration purposes for subsequent air modeling.
Operation of the Program
The daily operation of the facilities and equipment to implement the fugitive
dust-control program at the Middletown Works is under the direction of a general
foreman in the general services department. He in turn has a day foreman with
sole responsibility for managing a 10-person force that operates the street
sweepers and mobile spray equipment. The esprit de corps of this group is
considered a key factor in the Middletown success.
Two road sweepers are normally operated seven days per week, 12 hours per day,
in order to provide thorough and frequent coverage of the plant's 30 miles of
paved roads. The spray and flushing equipment (three separate vehicles) is
operated five days per week, eight hours per day.
-------
-56-
The application of chemical dust suppressants to unpaved surfaces varies greatly
with the surface in question. Some undisturbed areas require treatment only
twice yearly, whereas other, more active areas require twice-monthly treatment.
Normal application is a 1:7 solution of a commercially available, petroleum-based,
resinous binding agent at a rate of about 0.1 gallon/square yard of surface,
but tnis also varies. The annual cost of chemicals for this plant is approxi-
mately $200,000.
Operation of tne fixed-spray system for tne coal pile can be automatically or
manually activated. Normally it is programmed to operate at a specified time
eacn day. However, it can be bypassed on wet or cold days or it can be operated
more frequently in hot, dry weather. Because the spray system is designed only
to provide moisture to the pile surface in order to prevent windblown emissions,
no operating problems have been created by excessively wet coal. The coal-pile
system is operated and maintained by coke plant personnel.
Maintenance problems to date have been frequent, as with most mechanical and
mobile equipment, but they have not been so excessive as to cause serious
operating difficulties. When one sweeper is out of service, the other must be
operated more hours to cover the required road surfaces. However, the spray
trucks are sufficient in number and flexible enough to provide adequate coverage
when a unit is out of service.
The air monitoring network is serviced by the plant's engineering personnel. This
includes minor repairs, normal filter replacement, calibration, and data compila-
tion. Analytical, quality assurance, audit, and troubleshooting support are supplied
by the plant and corporate research laboratories. Corporate environmental engineer-
ing provided assistance for site selection and equipment acquisition and assists in
the ongoing management and interpretation of air data.
Summary and Conclusions
ARMCO, Inc.'s efforts to demonstrate tne benefits of the bubble concept as applied to
iron and steel plant fugitive dust sources have spanned several years, including
that period of U.S. EPA's development of policy on the concept. The prototype
program at ARMCO Inc.'s Middletown Works has shown that significant improvements in
ambient air quality are possible with a comprehensive fugitive dust control program.
The improvements can be obtained with lower capital and operating costs, with less
energy, and in less time than witn process fugitive emission controls. Moreover,
improvements are not limited solely to total suspended particulates but also include
reductions at smaller particulate-size fractions.
-------
-57-
TYPICAL FD CONTROL PLAN
FOR
INNER-CITY SOURCES
(Milwaukee Solvay Coke Company)
The fugitive dust-control plan at Milwaukee Solvay Coke Company was developed
several years ago in response to public concern about fugitive dust emissions
from a source in the middle of a major city. The program consists of three
main parts as explained in the following program summary:
1. Pave all regularly traveled roadways.
2. When loading stock from stockyard during nonfreezing weatner,
use water mist sprays on the feed hopper, which receives the coke from
front-end loaders, and on the screen. These do a good job of suppressing
the dust from the rescreening and loading operation.
3. Probably most significant, control fugitive dust from the coal
storage area with appropriate chemical suppressants, as described below.
Milwaukee Solvay has a 500-foot radial bridge for stocking and reclaiming coal,
which is received in 13,000-ton, self-unloading coal boats. The company instal-
led a system of sprays along the entire length of the bridge. The sprays are
sized to give uniform distribution of the sealing material to the area under
the coal bridge as the bridge travels. This system allows the flexibility of
using specific sprays over a special area. These sprays are located about 50
feet above the grade of the coal storage field.
It is the company's practice to spray all piles of coal within a few days after
arrival. Weather and wind are the main factors in determining when to spray.
In addition to spraying individual piles, Milwaukee Solvay sprays the entire
storage area periodically. Frequency here, too, is determined mainly by weather
conditions: During not, dry spells, the frequency is increased. On the average,
it is necessary to spray the entire area once every three to four weeks during
spring, summer, and fall.
The amount of spraying required to form tne desirable crust on the coal surface
has to be determined by trial and error because of the variables involved in
each system of application.
Several companies offer similar sealing materials. Milwaukee Solvay is using
NALCO #8820, which it mixes with water in a feed tank at the base of its coal
bridge and then pumps up to the spray header on the bridge. [A product bulletin
on NALCO #8820 appears at the end of the Appendix.]
In short, Milwaukee Solvay Coke finds tnat its system does a very good job
of controlling fugitive emissions from its coal storage area.
-------
-58-
Strategies for the Optimal Control of Dust Emissions from
Unpaved Roads
John S. Evans, Douglas W. Cooper and Joseph J. Harrington
Harvard School of Public Health
Boston, Massachusetts
Travel on unpaved public roads Is the single largest anthropogenic
source of emissions of airborne particles in the U.S. The average
impact of this source on average annual mean total suspended par-
ticulate (TSP) concentrations varies from 0.05 ng/m3 (Alaska) to
11 ng/m3 (Pennsylvania). When compared by contributions to the
variance in state to state TSP levels, their Impact is as great as the
impact of emissions from all conventional sources. Common emission
control methods include paving, oiling, speed reduction, watering,
and application of calcium chloride. Total annual emissions are, In
most cases, most economically reduced by either speed control or
paving, with expected average control costs of less than $0.50/lb of
emissions reductions. For most roads with average daily traffic flows
above 100 vehicles per day, paving Is shown to control emissions at
average costs of less than $0.05/lb. In some situations, the costs of
paving are more than offset by reductions in maintenance costs. Thus
it would appear that, even accounting for the order of magnitude lower
Impact on statewide average concentration per ton of particles
emitted from open sources, control of dust emissions from unpaved
roads offers an economical means for reducing ambient TSP
levels.
There are almost 2 million miles of unpaved public roads in
the U.S. Of the iVg trillion vehicle-miles travelled each year,
approximately 4% (58 billion vehicle-miles) are travelled on
these unpaved public roads.1 Both wind erosion of the road
surface and mechanical and aerodynamic disturbances of the
surface due to vehicular travel result in emissions of particles.
The annual emissions rate for the year 1976 was slightly under
275 million tons/yr, making unpaved roads that year the
largest source of particulate emissions in the U.S.2 As a point
of comparison, all other open sources (those sources too great
in extent to control through enclosure or ducting) emitted
approximately 305 million tons in 1976, and total conventional
source emissions for that year were estimated by the EPA to
be about 15 million tons/yr.3
Of the 10 major open source categories explored, only un-
paved roads appear to contribute significantly to measured
Dr. Evans is a Research Associate and Dr. Cooper is Asso-
ciate Professor of Environmental Physics, Harvard School of
Public Health. Dr. Harrington is Professor of Environmental
Health Engineering, Harvard School of Public Health, and
Gordon McKay Professor of Environmental Engineering,
Harvard University, Boston, MA 02115. This paper was sub-
mitted for editorial review on May 18,1981; the revised man-
uscript was received on January 12,1983.
statewide-averaged TSP levels.4 The analyses indicate that
a ton of emissions from unpaved roads typically has only one
ninth the impact on variations in measured statewide-aver-
aged TSP levels that a ton of conventional source emissions
has.4 However, even with this relatively small marginal im-
pact, on the average the total impact of emissions from un-
paved roads on statewide-averaged annual mean TSP levels
is 1.2 times as great as the impact of emissions from all con-
ventional sources.4 Estimates of the contributions of unpaved
road emissions to statewide-averaged annual mean TSP levels
(1976) vary from 0.05 /ig/m3 (AK) to 10.73 Mg/m3 (PA). Others
have demonstrated that dust emissions from unpaved roads
have even more significant impacts on both short-term and
long-term TSP concentrations in the immediate vicinity of
the roads.5'6
Airborne particles decrease visibility, increase rates of
soiling of materials and structures, contribute to vegetation
damage, and are thought to impair health and decrease life
expectancy. The decision to control emissions from unpaved
roads, and the selection of a strategy for control affect society
in two ways: the amount, type and location of damage due to
airborne particles is altered; resources are diverted from other
potentially beneficial uses.
A thorough analysis of the problem would help answer
several policy questions: Should particulate emissions from
unpaved roads be controlled? If so, which methods (and what
degree) of control should be used? Finally, if society elects to
control emissions from some unpaved roads, which roads
should be given priority? Theoretically, a benefit-cost analysis
(with adequate attention to equity) could answer all of these
questions.
To perform a benefit-cost analysis it would be necessary to
relate unpaved road emissions quantitatively to each physical
outcome—i.e., decreased life expectancy, increased soiling,
decreased visibility—and to assign economic values to changes
in the levels of these physical outcomes. Scientific under-
standing of these phenomena is imperfect.7-8 In addition, al-
though economists agree in some cases as to the theoretically
proper measures of social value, empirical estimates of these
measures are lacking.9 Although analytical methods (e.g.
statistical decision analysis)10'11 are capable of addressing
these uncertainties, it would seem that no single policy is likely
to emerge as sharply optimal, regardless of choices among
plausible alternatives for value of life, dose-response rela-
tionships, etc.
Methodology
To avoid explicit benefit estimation, a cost-effectiveness
analysis may be performed. In taking this step, efforts to an-
swer questions that require knowing the value to society of
Copyright 1983-Air Pollution Control Association
312
Journal of the Air Pollution Control Association
-------
reducing TSP levels are abandoned. Instead, the following,
more limited questions are addressed: If a sum of money is
allocated by society to reduce TSP levels, what portion, if any,
should be used for the control of dust emissions from unpaved
roads? If it is determined that funds should be used for road
dust control, on which control options and where should the
money be spent? Finally, if it is spent, what reduction in
emissions or TSP levels can be achieved?
In a cost-effectiveness analysis, an alternative criterion of
effectiveness is substituted for the elusive social benefit term.
In this application, several alternative criteria might be con-
sidered. These include minimization of:
(1) emissions from unpaved roads,
(2) the contributions of unpaved road emissions to ambient
TSP levels or to population-weighted TSP levels,
(3) the life shortening or the number of deaths attributable
to emissions of particles from unpaved roads.
In the selection of a criterion of effectiveness, three factors are
balanced: the degree to which the criterion is believed to be
correlated with social benefit, the amount of data gathering
and computational effort required to evaluate control policies
under various criteria, and the sensitivity of policy choice to
the choice of criterion. Often, complex problems are best an-
alyzed sequentially. Accordingly, the analysis was phased so
that in the early stages aspects of the problems deserving more
careful consideration might be identified. There were three
goals for this first stage of analysis.
(1) Outline a method appropriate for the analysis of cost-
effectiveness of control of dust emitted by unpaved
roads.
(2) Identify control methods which may be economically at-
tractive.
(3) Identify conditions under which the economics of control
may be favorable.
For these purposes, the simple criterion of minimization of
the mass of particles emitted seemed appropriate.
Estimated emission factors have varied from 0.04 to 55.9
lb/veh-mi.12 The emissions factor used in the analyses is in-
dicated below.13
-59-
0.016 Srij
- Pijk)
(1)
where:
,F,jk = emissions factor (lb/veh-mi) for region i, road unit
j, day k.
STl) = road surface silt content (% of mass < 75 ^m in
diameter) for road i, j.
Vjjk = average vehicle velocity (mi/hr) for road i, j, day
k.
P;,k = precipitation indicator variable for road i, j, day k
(=1 if rain or snow, =0 otherwise).
To obtain an average emission factor applicable to a segment
of roadway, the term Pyj, is replaced by p, the fraction of days
with appreciable rain or snow, and the average vehicle velocity
is substituted for Vyi,.
The total annual emissions for any region may be found by
summing the total annual emissions for each mile of road in
the region. The emissions from each mile may be given as the
product of the emissions factor, F (lb/veh-mi), and a road use
factor, N (veh/day).
To specify the cost of efficiently minimizing emissions, one
must first be able to identify the least cost method of reducing
to any desired level the emissions from any segment of road-
way in the region of interest. Such an analysis requires a
computational definition of cost to use to make comparisons
of control methods with widely varying effective lifetimes, e.g.,
watering vs. paving. A widely used approach is that of an-
nualized cost. To calculate the total annualized cost (TAG),
the average annual operating and maintenance cost (AOM)
is added to the product of the capital recovery factor (CRF)
and the initial capital investment /.14 (The CRF is the fraction
of the initial investment which one would pay yearly on a loan,
at an annual interest rate p, for the life of the loan T, assumed
to be the economic life of the capital item.) The relevant
equations are:
TAG = AOM + (CRF)I
(2)
(3)
Several factors complicate the analysis. There may be large
uncertainties in the components of total annualized costs.
There may be unforeseen or unrecognized trends in the costs
of various control techniques. There is no agreement as to the
proper interest rate to use in discounting. The approach taken
here was to assume that mid-ranges or expected values may
be used. However, the conclusions of an analysis such as this
may be very sensitive to the particular values assumed for
various parameters. Therefore, sensitivity analyses are likely
to be quite informative, and should aid the analyst in deciding
on the confidence to place in the cost-effectiveness rankings
and unit control cost estimates.
Basic Results of Cost-Effectiveness Analysis
The annual emissions from any segment of unpaved road-
way may be reduced by reducing the number of vehicles using
the roadway, or by reducing the average emissions factor Fy,
applicable to the given segment. The latter may be achieved
by altering the road surface silt content Sr, the average vehicle
speed V, or the surface moisture, or by restructuring patterns
of road use so that periods of relatively intense use occur when
emission factors are low. Some of the more common control
techniques are: paving, oiling, speed control, application of
calcium chloride, and watering. Although other control ma-
terials (e.g., stabilizers such as lignin sulfonate, salt brine, and
emulsifiers) have been suggested, not enough data were found
to permit an evaluation of their cost-effectiveness.15 Wind
breaks could be used to limit the emissions due to wind erosion
of the road surface; however, in most situations they would
have only a limited impact on total dust emissions, which are
most often dominated by the contributions of vehicular
travel.
The average cost AC ($/lb), of reducing emissions was cal-
culated for each of the control methods, using the following
formula:
AC =
TAG
(Fu -
-A
(4)
where TAG is the expected total annualized cost ($/yr/mi),
Fu is the emissions factor without control (lb/veh-mi), Fc is
the emissions factor with control, A is the change in the cost
of aggregate replacement ($/lb), and N is the roadway use
factor (veh/day). Average control costs depend strongly upon
the level of use of the road and upon the uncontrolled emission
factor, which itself is a function of average vehicle speed, silt
content, and precipitation frequency.
Table I summarizes the basic results of this cost-effective-
ness study. For each of the five control techniques, TAG, Fc,
and AC are given as functions of Fu, N, Vc and p.
The data in Table I indicate that oiling is more cost-effec-
tive than application of calcium chloride, and that in most
circumstances (i.e., for precipitation probability p < 0.73)
oiling is more cost-effective than watering. However, the most
significant feature of Table I is the apparent economy of
paving as a method of emissions control. For almost any road
(i.e., Fu > 0.8) paving appears to be more economical than
oiling. Table II, which gives average control costs available
through paving, oiling, and speed control for typical soil and
gravel roads, reinforces these observations.
It should be noted that these conclusions pertain only to the
cost-effectiveness of the various control strategies for long-
April 1983 Volume 33, No. 4
313
-------
-60-
Table I. Cost and efficiency of dust control techniques."
Techniqueb
Expected
total
annualized
cost
($/yr)
Controlled
emission
factor
(Ib/veh-mi)
Average
control cost
($/lb)
Paving
Oiling
Speed
control
Calcium
chloride
2600
5720
3100/V
9000
0.50
0.17FU
(FU-0.5)/V
-0.008
Vu-Vc
VUVC
8'5°
-0.008
0.40FU
41.1
-0.008
Watering 25,650(1 - p)
70.0(1 - p)
FaN
-0.008
a All costs have been adjusted to the price levels which prevailed on
January 1,1980.
b Paving: / = $20,000/mi; T = 10 yr; Fc = 0.5 Ib/veh-mi; p = 5%/yr
Oiling: / = $6,500/mi; T = 1.2 yr; e = 83%; p = 5%/yr
Speed control: lost time = $8.50/veh-hr; emissions proportional to
speed13
Calcium chloride: / = $3,000/mi; T = 0.3 yr; e = 60%
Watering: / = $70/mi; T = 1 day
Gravel losses: aggregate = $10/ton;.-. A = $0.008/lb
term control of emissions. Watering or calcium chloride
treatments may be useful for short-term or intermittent dust
control. By equating the paving and watering average cost
equations, it may be demonstrated that whenever more than
d' days of rain are expected each year, watering provides a
cheaper means of reducing total annual emissions than
paving:
d' > 365 - 37.1
?« ~ 0.5)
(5)
solving for Fu = 1.0, d' >. 291. Speed controls may also be ap-
plied on an intermittent basis, during periods of high traffic
use or higher than average emissions.
Figure 1 gives the expected average control costs for paving
as a function of the uncontrolled emission factor Fu and the
intensity of use N. These data indicate that over a wide range
of intensity of road use and uncontrolled emissions factors,
emissions from travel on unpaved roads can be controlled at
average costs less than $0.50Ab. In fact, there is a large region
of the figure in which the average cost of emissions control is
Table II. Typical average control costs for soil and gravel roads.
Average cost estimate, AC ($/lb)a
Dry region Wet region
(p = 0.1) (p = 0.5)
Technique
Low speed High speed Low speed High speed
V = 25 V = 45 V = 25 V = 45
A. Soil Roads (Sr = 30%)
Speed 20% 0.031
reduc- 40% 0.044
tion
Paving 0.692/N
Oiling 1.75/JV
B. Gravel Roads (S, = 15%)
Speed 20% 0.071
reduc- 40% 0.097
tion
Paving 1.45/W
Oiling 3.49/N
0.004
0.008
0.063
0.086
0.377/N 1.30/N
0.972/N 3.14/N
0.016
0.024
0.134
0.181
0.773/W 2.85/W
1.94/JV 6.29/JV
0.014
0.021
0.692/JV
1.75/JV
0.036
0.050
1.45/JV
3.49/N
a Each of these cost estimates should be reduced by $0.008/lb to reflect
the savings due to reductions in aggregate losses.
negative! In this region (above and to the right of the line AC
= 0) paving would appear to be justified on the basis of eco-
nomic considerations alone, without regard to the potential
emissions reductions.
These paving control cost estimates are subject to both
variability and uncertainty. Depending upon the initial cost
of paving ($10,000-$30,000/mi), the life of the pavement (5-15
yr), the discounting rate (3-7% yr"1), and the emission factor
with control (0.005-0.80 Ib/veh-mi), these unit costs could vary
by a factor of almost 10 in either direction.
The one emission control technique which may have even
lower average control costs than paving in certain circum-
stances is speed control. By equating the average control costs
of the two methods, one may solve for the control velocity Vc',
at which the average control costs of the two methods are
equal. This yields:
V> 1.19--
(6)
Thus for a road with ^u = 5, speed control would have lower
average control costs than paving as long as Vc' > 1.17 N. At
an intensity of road use of N > 47, this would require the
control velocity to be >55 mph, the legal speed limit in the
1000
r
•^200
•100
UJ --
-------
There are uncertainties in the estimates of cost and effi-
ciency applicable to speed control. Foremost among them are
the assumption that emissions factors are proportional to
vehicle speed and that the costs of speed control are ade-
quately represented by the costs of increased travel time,
valued at $8.50/vehicle hour. Thus, the average unit control
costs may easily vary by a factor of approximately 3 in either
direction.
-61-
0.5
1.0 2.0 5.0 10.0 200
UNCONTROLLED EMISSION FACTOR, Fu
(Ib/veh-mi)
50.0
Figure 2. Contours of equal average speed control costs (AC, $/lb) plotted
tor uncontrolled emission factors between 0.5 and 50 Ib/veh-mi and control
velocities between 0 and 60 mph.
It is often true that a single control method is not dominant
(i.e., least cost) over the entire range of control efficiencies.
Screening curves, such as those shown in Figure 3, summarize
information on control costs as a function of the level of con-
trol for several competing techniques. For the situation de-
picted, speed control is the most economical technique up to
control efficiencies of 50%. Between 50% and 90%, paving is
most economical. To achieve control efficiencies above 90%,
watering becomes necessary. In the evaluation of cost and
effectiveness for any specific segment of roadway, local data
on materials and labor cost, pavement surface life, intensity
of road use, and emissions should be used. Paving cost esti-
mates should be based upon an engineered design of an ap-
propriate combination of roadbed and surface for local con-
ditions. Speed control cost estimates should reflect the local
value of increased travel time.
Screening curves serve two purposes. It is obvious that an
air quality planner interested in achieving a specified reduc-
tion in the emissions from a particular segment of roadway
may use the curve to determine directly the most cost-effective
control technique. More significant perhaps is the potential
use of data from screening curves as input to mathematical
programming algorithms. Once a screening curve were de-
veloped for each segment of roadway in a region, using tech-
niques such as integer programming, air quality planners in-
terested in minimizing regional emissions from unpaved roads
at least cost could use data from screening curves to identify
the regional minimum control cost function.16 Such a function
gives the minimum cost at which any desired level of regional
emissions reduction may be achieved and specifies the set of
control techniques which must be applied to the roads in the
region to obtain this least cost solution. Judicious choice of
what is defined as a "segment" requires balancing accuracy
of the predictions against the cost of obtaining the data and
performing the calculations.
Although a national optimization might never be under-
taken, the procedure might well be applied by individual
states in an effort to optimize their control efforts.
Discussion
Accepting for the moment the appropriateness of the goal
of minimization of TSP emissions at least cost, there are still
many sources of uncertainty in the analysis. The uncertainty
surrounding the estimates of cost and effectiveness could be
reduced substantially by further research. For example, it
would be helpful to have better estimates of emissions rates
applicable to paved rural roads, an improved understanding
of the relationship between control efficiency and time since
application of dust control oil, and more precise knowledge
of the relationship between vehicle speed and emissions.
However, until the necessary research is complete, decisions
must be based upon the best currently available information.
When decisions must be made in an uncertain environment,
it is advisable to perform sensitivity and uncertainty analyses
in conjunction with any optimization procedure. Here, for
example, it might be useful to know to which assumptions the
choice of control technique would be most sensitive. The
Appendix briefly outlines methods for sensitivity and un-
certainty analyses and examines the factors which determine
the choice between paving and oiling.
Where uncertainties are large and the costs of making in-
correct decisions are substantial, one possible action is to delay
the implementation of control methods until key uncertainties
are resolved. However, an air quality planner must balance
the costs of delaying the improvements in air quality against
the benefits of potentially more efficient control strategies.
Further, considerations other than simple cost-effectiveness
(based on reduction of mass emission rates) must enter the
decision making process. For example, in the selection of re-
gions for control, factors such as: (1) proximity to population
centers and population sub-groups, (2) characteristic dis-
persion conditions (i.e., mixing height, wind speed and di-
rection, atmospheric stability), (3) NAAQS compliance status,
3.0 4.0 5.0 6.0
(50%) (100%)
EMISSION REDUCTION (10' Ib/yr)
Figure 3. Control technique screening curve for a gravel road
(S, = 15%) in a moist climate (p = 0.5) with high uncontrolled
vehicle speed (Vu = 45 mph) and low use (N = 30 veh/day).
and (4) typical concentrations of particles and other air pol-
lutants, would be relevant. In the calculation of costs, exter-
nalities need attention. Does paving, with the associated
emissions of airborne hydrocarbons and particles, make sense
as a method of reducing road dust? Are any damages associ-
ated with water pollution reflected in the costs of applying oil
as a road dust palliative?
In the choice of control methods, strategic considerations
are essential.17 Will the decision to pave limit the development
of technological alternatives which might prove to be superior?
April 1983 Volume 33, No. 4
315
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-62-
Is this the time to act, in the face of uncertainty as to the va-
lidity of TSP as an indicator of the potential for adverse
health/welfare impacts? If so, should a capital-intensive,
long-lived control technique, such as paving be chosen? Or
should decision makers hedge, selecting a method with slightly
higher average costs (e.g., oiling) which will provide more
long-range flexibility?
The available evidence does not permit sharp conclusions
on these issues. However, the analysis does indicate that
control of total annual emissions from unpaved roads may be
achieved most economically by paving, oiling, or speed control
at costs which are low in comparison with the costs of control
of conventional sources. A recent analysis for the EPA indi-
cated that control of conventional primary particulate emis-
sions could be achieved in 14 industries at costs between
$0.001 and $68/lb depending upon size of plant, operation, and
degree of control required.18 For example, in the iron and steel
industry, average control costs are between $0.008 and $68/lb.
It is clear that, given the choice of reducing dust emissions
from unpaved roads or reducing their conventional emissions,
it will be highly profitable for some industries to control road
dust emissions. However, from the point of view of those at
risk from airborne particles, these conventional source control
costs are not strictly comparable with the road dust control
costs generated in our analysis. Unpaved road emissions have,
per ton, approximately one tenth the impact of conventional
emissions on measured TSP levels.4 Therefore, it would seem
that if the road dust control costs were multiplied by 10, they
would be roughly comparable to conventional control costs
in a cost-effectiveness analysis. Even after such adjustment,
in many situations the average control costs would be lower
than the costs of conventional source emission reductions from
many industries. Therefore, it would seem that air quality
planners should pay added attention to dust emissions from
unpaved roads.
It could be argued that society should not allocate valuable
resources to control ambient TSP levels. Here one issue is
imbedded within another. First is the question of selection of
a proper measure (metric) for airborne particles. Perhaps
national air quality standards (and therefore criteria of cost-
effectiveness) should be written in terms of fine particle (FP)
concentrations, inhalable particulate (IP) concentrations, or
sulfate concentrations. However, this issue is potentially much
easier to analyze than the question of whether (and if so, by
how much) society should divert resources to the control of
concentrations of airborne particles at all. Analytical resolu-
tion of this second, broader issue is contingent upon: (1) ad-
vances in the development of quantitative models relating
concentrations of particles (or doses) to physical and biological
effects, and (2) movement toward some consensus as to the
proper methods for valuing increments in health and life ex-
pectancy. These uncertainties are much greater than the im-
precision in estimates of unit control costs applicable to re-
duction of dust emissions from unpaved roads.
The results of this analysis should be viewed as preliminary
and somewhat tentative, to be repeated as more data become
available and in light of any new evidence on the validity of
TSP as an exposure metric.
Conclusions
Situations have been identified for which control of un-
paved road emissions would be very much less expensive than
conventional source control, and methods for choosing among
unpaved road control options have been outlined. Even after
accounting for the relatively low incremental impact of un-
paved road emissions on measured TSP levels, control eco-
nomics appear favorable. In most situations, speed control or
paving offer control at lower unit costs.
Those responsible for reducing particulate emissions (or
TSP levels) should consider the economics of open source
controls using methods similar to those outlined here. Air
quality planners should give priority for these more detailed
analyses to: (1) states where reductions in unpaved road
emissions could lower statewide average annual mean TSP
levels to less than 75 /j.m/m3, (2) states where unpaved road
emissions constitute the large fractions of total particulate
emissions, and (3) states in which the marginal impacts of
emissions reduction on population-weighted TSP exposures
would be significant.4 Regional or metropolitan air quality
planners may find it advantageous to apply the cost estimates
developed in this work in conjunction with standard Gaussian
air quality models to assess control alternatives available to
them. Where these analyses indicate that economics of un-
paved road controls are favorable, more detailed cost studies
or field trials should be implemented.
Acknowledgments
We are indebted to our colleagues at Harvard, Professors
D. Harrison, Jr., R. A. Leone, and D. W. Moeller, for their
comments on preliminary drafts of this work. The work was
funded in part by the U.S. Environmental Protection Agency
Special Air Pollution Fellowship #4911179-01 and Grant
R5805294 and by U.S. Public Health Service Grant 5D04 AH
01475, but neither agency is responsible for the results.
APPENDIX
Sensitivity and Error Analyses
Given a function of several variables, such as f(x,y), one
often wants to know the effect on / of changes in x or y or
perhaps the contribution to errors (variance) in / of errors
(variance) in x or y. The answers to these questions can be
determined by sensitivity analysis and error analysis respec-
tively.19 In some cases, sensitivity and propagation of error
can be determined analytically by manipulations performed
on the relationship f(x,y). But in many cases, the functional
relationships are of sufficient complexity that this is not fea-
sible. In these more complex cases, numerical simulations may
be necessary.
The sensitivity of f(x,y) to small changes in x and y is just
the partial derivative of / with respect to x or y. Evaluating
such a derivative means choosing some value of x and of y
around which to vary x and y. The choice is not trivial and a
different choice may produce substantially different partial
derivatives. If f(x,y) has substantial curvature, the sensitivity
coefficient will apply only over a very limited segment of the
range of x and y, and its application outside of this range may
be very misleading.
The random error (variance) in / caused by random errors
(variance) in x and y can be estimated by multiplying the
variance of x by the square of the partial derivative of / with
respect to x and multiplying the variance of y by the square
of the partial derivative of/ with respect to y, for small vari-
ances and no correlation between the variances:
var(/) *> (df/dx)2 var(*) + (df/Sy)2 var(y) + H.O.T. (Al)
in which H.O.T. stands for higher-order terms. Once again,
the sensitivity coefficients play an important role in the error
analysis. In addition to giving an estimate of the total error
in /, the error analysis indicates how much each term con-
tributes to the total.
In the process of estimating the average cost of control
AC($/lb) for each of the control techniques many assumptions
were necessary. When uncertainties were involved, mid-range
or expected values were used. It would be important to know
316
Journal of the Air Pollution Control Association
-------
-63-
how sensitive the average control cost estimates are to the
values assigned to various parameters. A sensitivity analysis
might be expected to provide useful information.
For example, the average control cost for paving may be
expressed as:
ACD
• - A (A2)
365AT(0.016 SrV(l - p) - FCplve)
As a foundation for either sensitivity or error analysis, the
sensitivity coefficients must be determined. Those applicable
to paving are summarized in Table A-I. The partial derivatives
were evaluated at the nominal values of all of the other pa-
rameters. Further, the numerical values given are appropriate
for the road conditions used as the basis for Figure 3, i.e., Sr
= 15%, V = 45, N = 30, p = 0.5.
Table A-I. Sensitivity coefficients for average cost of control for
paving.
Parameter
•* pave
T
i pave
p
A
r
rCp.,e
Sensitivity
coefficient
+2.41 X ID"6
-3.81 X 10-3
+2.35 X 10-3
-1.00
+9.85 X 1C-3
Units
$/lb per $/mi
$/lb per yr
$/lb per % yr~J
$/lb per $/lb
$/lb per Ib/veh-mi
Nominal Parameter Values
/pave = 20,000 $/mi Tpave = 10 yr p = 0.05 yr-1
A = 0.008 $/lb FCpave = 0.5 lb/ ACpave = 0.0403 $/lb
veh-mi
Assumed Road Conditions
Sr = 15% V = 45 mph N = 30 veh/day p = 0.5
Using the sensitivity coefficients from Table A-I it can be
estimated that to increase the average cost of paving by 10%
(from its nominal value of $0.04/lb of emissions reduction) it
would be necessary to either: increase the capital cost of paving
by $1700/mi, decrease the life of the paved surface by 1 yr,
increase the discounting rate by 1.7% yr"1, decrease the cost
of aggregate by $0.004/lb, or increase the emissions factor after
control by 0.4 Ib/veh-mi.
Although we have not carried the analysis through, it would
be relatively straightforward to conduct an error analysis using
the squares of these sensitivity coefficients in conjunction with
estimates of the errors (variances) inherent in each of the
nominal parameter values.
It is also interesting to consider how much any single pa-
rameter estimate would have to be in error in order for an error
Table A-II. Sensitivity of cost-effectiveness of paving relative to
oiling for a road with Sr = 15%, V = 45 mph, p = 0.5 and N = 30
veh/day.
Parameter
£01]
/on'
P
F
r Cpuve
T
* pave
Jpave
Critical value"
>200%
2.3 yr
<2800$/mi
>0.42yr-!
>3.4 Ib/veh-mi
<3.6 yr
>48,000 $/mi
Nominal value
83%
1.2 yr
6500 $/mi
0.05 yr-'
0.5 Ib/veh-mi
10 yr
20,000 $/mi
8 Beyond this value the average control costs applicable to oiling are
lower than the costs of paving.
to be made in the choice of control technique. For example,
in Figure 3 it appears that paving dominates oiling; that is,
paving has both a higher estimated control efficiency and a
lower estimated control cost than oiling. However, with the
many assumptions which were necessary to reach this con-
clusion, it would seem entirely possible that oiling might in
fact be more cost-effective than paving.
Some indication of the amount by which a single parameter
would have to be in error to yield an incorrect control choice
may be obtained by simply setting the average cost of paving
equal to the average cost of oiling and solving for the critical
parameter value. The results of such an analysis are presented
in Table A-II. Notice, for example, that the conclusion that
paving is more cost-effective than oiling is quite insensitive
to estimates of the errors in the efficiency of control of oiling,
the emissions factor applicable to paved roads, and the dis-
count rate. An error of a factor of between 2 and 3 would be
necessary in any of the other parameter values to lead to an
incorrect conclusion.
The analyses described above are simply illustrative. Before
large financial commitments are made, comprehensive sen-
sitivity and error analyses should be conducted in an attempt
to verify the robustness of any proposed control strategy.
References
1. "1976 National Highway Inventory and Performance Study," U.S.
Department of Transportation, Federal Highway Administration,
Washington, DC, 1977.
2. J. S. Evans, D. W. Cooper, "An inventory of particulate emissions
from open sources," JAPCA 30:1298 (1980).
3. "National Air Quality and Emissions Trends Report, 1976,"
EPA-450/1-77-002, U.S. Environmental Protection Agency,
Monitoring and Data Analysis Division, Research Triangle Park,
NC, December 1977.
4. J. S. Evans, D. W. Cooper, "The contributions of open sources
to ambient TSP levels," JAPCA 31: 549 (1981).
5. T. G. Pace, "An Empirical Approach for Relating Particulate
Microinventory Emissions Data, Monitor Siting Characteristics
and Annual TSP Concentration," U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Jan. 1979
(draft).
6. R. Handy, et at., "Unpaved roads as sources for fugitive dust,"
Transportation Research News (1975).
7. A. M. Freeman, III, The Benefits of Environmental Improve-
ment—Theory and Practice, Johns Hopkins University Press,
Baltimore, 1979.
8. L. B. Lave, E. P. Seskin, "Epidemiology, causality, and public
policy," Am. Scientist, 67:178 (1979).
9. E. J. Mishan, Cost-Benefit Analysis, Praeger Publishers, New
York, 1976.
10. M. G. Morgan, et al, "A probabilistic methodology for estimating
air pollution health effects from coal-fired power plants," Energy
Systems and Policy 2: 287 (1978).
11. H. Raiffa, Decision Analysis, Addison-Wesley, Reading, MA,
1968.
12. R. Heinsohn, et al., "Fugitive Dust from Vehicles Using Unpaved
Roads," presented at the Third National Conference on Energy
and the Environment, Oxford, OH, Sept. 1979.
13. C. Cowherd, et al., "Development of Emissions Factors for Fu-
gitive Dust Sources," EPA-450/3-74-037, U.S. Environmental
Protection Agency, Office of Air and Waste Management, Re-
search Triangle Park, NC, June 1974.
14. R. deNeufville, J. H. Stafford, Systems Analysis for Engineers
and Managers, McGraw-Hill, New York, 1971.
15. J. S. Evans, "Systems Analysis of Open Sources of Atmospheric
Particles," Sc.D Dissertation, Harvard University, Department
of Environmental Health Sciences, 1980.
16. D. M. Simmons, Nonlinear Programming for Operations Re-
search, Prentice-Hall, Englewood Cliffs, N.J., 1975.
17. R. A. Leone, et al., "Regulation and Technological Innovation
in the Automobile Industry," report for Office of Technology
Assessment, Contract No. 933-3800.0, June 1980.
18. D. M. Jenkins, et al., "Incremental Cost Effectiveness for Air-
borne Pollution Abatement," report to U.S. Environmental
Protection Agency, Battelle Columbus Laboratories, Columbus,
OH, 1979.
19. P. R. Bevington, Data Reduction and Error Analysis for the
Physical Sciences, McGraw-Hill, N.Y., 1969.
April 1983 Volume 33, No. 4
317
-------
-64-
QUARRY
DUST
CONTROL
Reprinted for
JOHNSON-MARCH CORP.
3018 Market Street
Philadelphia, Pa., 19104
From
PIT AND QUARRY
December, 1969
-------
-65-
State Aggregates, Inc.,
takes a tough line
on dust pollution
at sandstone quarry
Pennsylvania quarry before dust suppression system had been placed in operation.
Same quarry after dust suppression system had been installed.
• Over the last decade, the prob-
lems created by heavy dust have
been demanding more and more
special attention from the opera-
tors of rock quarrying and crush-
ing firms. Production suffers be-
cause dust blowing off the crush-
ers obscures the operator's view of
his equipment, and the abrasive
particles, working their way into
operating machinery and increas-
ing wear, boost maintenance and
replacement costs. A nearby com-
munity may object to dust thrown
into the atmosphere by a rock
crushing company and create a
public relations problem for man-
agement. And the firm, if it vio-
lates a local or state air pollution
law, risks being slapped with a
heavy fine.
The foregoing are some obvious
reasons why many companies
have come to grips with the dust
problem in recent years and
equipped their plants with an ef-
fective suppression system. How-
ever, at the State Aggregates, Inc..
crushing and processing plant in
Montrose, Pa., two altogether dif-
ferent additional factors prompted
the firm to install dust control
equipment early in 1968.
First, the stone processed at the
Montrose site, having a high silica
content (33% free silica), gives
off an abrasive dust, which can
cause eye and lung damage over
long periods of exposure. Second,
Montrose and its neighboring
towns are in the upstate Pennsyl-
vania Pocono Mountains, a scenic
resort area with little heavy indus-
try. As a result, State Aggregates
wanted to eliminate the potential
threat to the health of its em-
ployees and preserve the pictur-
esque beauty of its rural locale.
At the Montrose operation.
about 1,000 tons of stone are quar-
ried and processed every day. The
rock is loaded onto dump trucks
and hauled to the plant a quarter
of a mile away. The rock is
dropped into a hopper, onto a vi-
brating feeder, screened, then fed
into the primary crusher. An op-
erator standing on a platform just
above the crusher controls the rate
of feed.
After the stone passes through
the primary crusher, it is fed into
the secondary crusher and re-
cycled through it a second time
to crush the stone missed in the
first cycle.
The conveyor belt carries the
stone to a tertiary crusher, and
it is screened and discharged into
-------
-66-
State Aggregates
bins and then stockpiled by dump
trucks.
Searching for an effective way
to combat the heavy dust created
in this process, State Aggregates
called upon Johnson-March Corp.
to analyze its Montrose operation.
Dust control engineers from John-
son-March examined the crushing
equipment and installed a Chem-
Jet dust suppression system. Chem-
Jet is a low-cost, easy-to-maintain
system that applies a solution of
water and a wetting compound
onto the stone as it goes through
the processing operations. By sup-
pressing the dust right at its
source before it can become air-
borne, it is less complicated, trou-
blesome and expensive than sys-
tems that collect the dust and
carry it off for disposal.
Wetting with plain water is in-
effective because normal surface
tension causes the fine particles
of dry dust to rest on the surface
of the water. Untreated water
sprayed onto a pile of dust forms
globules and rolls off, leaving the
dust free to rise into the air.
The Chem-Jet system, however,
adds a small amount of Com-
pound M-R, a chemical which
breaks down the surface tension
of water, makes it spread further,
penetrate deeper and diffuse more
widely than untreated water.
The chemical solution—1,000
parts of water to 1 part of Com-
pound M-R is mixed automatically
in a small pump house a few feet
away from the Montrose plant's
fine crusher.
The flow of water into the mix-
ing tank is held constant, and a
special liquid flow proportioner
automatically controls the amount
of compound added. The propor-
tioner is equipped with a positive
displacement pump that uses a
spring bellows to meter the two
liquids at the ratio necessary for
the Montrose processing operation
—with an accuracy of 1%.
Spray jets usually are set up
wherever dry material changes its
direction of travel at conveyor
transfer points, where new sur-
faces are created, or is subjected
to strong wind. For the State Ag-
gregates quarry, the critical ap-
plications of the solution are at
the mouth and discharge of the
crushers, where most of the dust
is produced.
Two spray jets open up above
the mouth of the primary and
secondary crushers and the ter-
Primary crushing phase before treatment of stone.
tiary, and one opens up below the
discharge of each. The water-
chemical solution blankets all
nine areas, causing the dust par-
ticles to agglomerate and pre-
venting them from rising into the
air.
The nine sprays may be turned
on or off collectively at the pump
shack; or an operator, standing at
the primary crusher, may open
or close the valves individually by
pushbutton control.
In either case, the sprays—
hooked up free of the conveyor
system—may be turned off while
the crushing operation goes on.
In addition to effective dust
control at crushers, screens and
transfer points, the Chem-Jet sys-
tem provides an additional bene-
fit. The carry-over effect of the
application of Compound M-R so-
lution so conditions the stone that
the loading onto the stockpiles
and into trucks is rendered dust
free.
Studies made by the Pennsyl-
vania Health Department's Divi-
sion of Occupational Health indi-
cate how effectively the Chem-
Jet system has suppressed the dust
at the Montrose quarry.
To protect the health of employ-
Another view of same phase aner treatment of stone.
-------
-67-
ees working at high-silica quarries,
the state requires that dust con-
centration have no more than 6
million particles per cubic foot of
air. Two separate tests show that,
on the operator's platform at the
primary crusher, there were 1.86
million and 2.3 million particles
of dust per cubic foot of air; in
the bins, 490,000 and 1.02 million
particles; and on the maintenance
man's platform, 1.8 million and
1.42 million particles.
At all three spots, dust content
was far below the state require-
ment.
The main operating cost of this
system at Slate Aggregate's plant
is the wetting compound, which
averages out to an expense of one
mill for every ton of stone proc-
essed and treated.
The system, in operation for
nearly a year and a half, failed
only once when, last winter, the
proportioner pump was not
drained at the end of the day and
froze during the night. It was re-
placed by a new pump which
holds anti-freeze and operates
throughout the cold months with-
out the danger of freezing and
cracking.
Although this was the only re-
pair job done on the Chem-Jet at
Montrose in nearly 18 months,
the system is checked by a John-
son-March engineer periodically—
from two, to tour times a year—
to insure proper operation.
The money spent on this dust
suppression system has paid off
for State Aggregates in several
ways. Some tangible rewards are
faster, more efficient production
as well as lower equipment and
maintenance costs.
More important, however, are
the intangible ones. By keeping
the atmosphere clean and creating
a safer, more healthful working
environment, the company has
averted what later could have be-
come serious public—and employ-
ee—relations problems. • • •
-------
-68-
A REPRINT FROM
JULY, 1972
Asphalt plant salves dust problem,
makes valuable by-product
Initial operation of the asphalt plant
of Hills Materials Company, Rapid
City, South Dakota, demonstrated
quickly that its cyclone dust col-
lector was inadequate for operation
in a residential area. This led to an
investment of more than $40,000 in
a bag collector which eventual lyre-
suited in reclaiming valuable min-
eral filler as well as an improve-
ment in community relations.
Analysis of the situation indicated
that collection of the fines for sale
was essential, not simply disposal.
This ruled out dust suppression de-
vices or a scrubber. For if the
scrubber were arranged to trans-
form an air pollution problem into
a water pollution problem, it would
have required a settling pond and
frequent removal of the sludge.
Further, the scrubber and settling
pond combination would not recov-
er the valuable fines easily since
the cost of drying and processing
the fines would be prohibitive.
Preliminary evaluation indicated
that the $80,000 cost of a bag col-
lector and accompanying ductwork
for dust collection would be nearly
$2 per cfm. Handling about 45,000
cfm at 225 deg F, this seemed to
be a large amount of money even
with the expectation of profitable
resale of the fines.
These studies also indicated the
possibility that, with detailed re-
finements, the bag col lector, neces-
sary ductwork, and collecting and
handling of the fines, could be in-
stalled at a cost well below the tar-
get cost of $2 per cfm. In addition,
there are a number of local condi-
tions at this plant that collectively
add up to significant savings.
First important detail was instal-
lation of a firing cut-off control
regulated by a thermostat in the
stack to maintain stack temperature
at a maximum of 225 deg F. Ob-
viously, vapor going out the stack
at a temperature over 212 deg F
represents an unnecessary loss of
heat and is wasteful. continued
Fines from the cyclone primary dust collector at Hi'ls Materials are returned to the dryer where they are used as
mineral filler. Alternatively, excess fines can be hauled away as agricultural limestone.
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-69-
Bag collector, center, solved severe dust problem for Hills Materials by removing
fines that cyclone dust collector couldn't catch. A screw conveyor in the hopper
bottom takes collected fines to an elevator and storage bin in the background.
With proper lifting flights in the
rotary dryer, sufficient exposure of
the stone surfaces to the heat is
obtained and stack temperature can
be maintained at or below 225 deg
F without loss of drying capacity.
Should temperatures exceed this
level the thermostat cuts off or re-
duces the firing rate. These inter-
locked controls and low exhaust
temperatures permit the use of Or-
ion acrylic fiber bags instead of
the Nomex nylon fabric units that
are standard in most asphalt plant
bag collectors.
But, frequently, Nomex bags will
prove to be more economical if fir-
ing control mechanisms and the
personnel running them are not ac-
customed to the necessary critical
temperature control. Then the dan-
ger to bags other than Nomex is
too great. However, for Hills Ma-
terials the use of Orion bags rep-
resented a practical and justifiable
reduction in cost.
An additional saving was realized
by the use of an existing hot gas
fan which had the motor horse-
power of 100 hp and blade capacity
to produce a forced draft through
the collector in spite of its natural
resistance of 4 in. wg.
Collected dust: The plant's orig-
inal cyclone collector was left in
place to return the coarser dust par-
ticles to the mix and the new bag
collector follows the cyclone. The
hopper under the bag collector dis-
charges to a screw conveyor which
moves the collected fines to a
bucket elevator that lifts them to a
storage silo where they can be
loaded into a closed body truck
for transport.
The approximately 15 tons per
day collected by the unit are fines
that otherwise would have been lost
as dust over the neighborhood.
These fines, which meet specs of
Nebraska and Montana for mineral
filler, have a net resale value of
about $6 per ton, a satisfactory re-
turn even without the advantages
of being a good neighbor.
Collector operation: Air is cir-
culated up through the bags and
out the top of the bag collector
while dust adheres to the inside of
the bags. A common duct installed
at the top of the collector dis-
charges clean exhaust air into a
short stack. If it is ever considered
necessary, an induced draft fan can
be added to supplement the exist-
ing forced draft fan.
The total cloth area of 17,500 sq
ft provides an air-to-cloth ratio of
2.57 to 1. The dust collector oper-
ates at about 4 in. wg and the col-
lector bag system is designed to
withstand a maximum of 10 in. of
static pressure. The steel shell of
the collector is of modular con-
struction with 10 compartments
each 5 ft long, 10 ft high and 10 ft
wide.
A sequence timer shakes the
bags in each section automatically.
A total shake time of 16 seconds
is currently being used although
shake time can be varied between 5
and 20 seconds at the option of the
operator to fit individual conditions.
Dampers closed before shakedown
All motor controls for the entire asphalt plant are centralized on this one panel,
including fans, conveyors, pumps, burners and elevators.
Table I
Gradation:
% Retained on #50 sieve
% Retained on #200 sieve
Plastic Index
"S" Factor: Value
Actual
. 0,0
5.0
0.0
0.20
Limit
5.0
20.0
3.0
0.25
do not reopen until 5 seconds after
shaking is complete.
This is all done automatically
and each section of the unit is re-
peatedly shut off and shaken in se-
quence. Thus, the pressure drop
-------
-70-
across the bags is minimized and
maximum collection assured.
There are 140 Orion acrylic fiber
bags in each compartment each
bag is 5 in. diam and 9 ft 3 in.
long. Each bag is provided with an
air nozzle to direct the flow of the
dusty air into the bag without ex-
cess abrasion on the bag.
Should the temperature in the
duct entering the bag collector from
the cyclone exceed 240 deg F, a
damper on the fan suction side is
opened allowing cold air to be
drawn in to dilute the hot air. If
this is not sufficient and the temper-
ature should exceed 250 deg F, the
dryer burners are automatically cut
off. The bag collector system has
more than met expectations of the
management of Hills Materials.
More than 99 percent of the fines
are being collected and either re-
turned to the system or sold at an
advantageous price.
The dust problem has been com-
pletely eliminated. Because of the
typical low humidity in South Da-
kota even the condensate plume
has been largely eliminated. Only
on very cold damp days when the
stone fed through the dryers is ex-
tremely wet has the plume become
evident. But even then the plume
dissipates quickly after leaving the
stack so that, even to near neigh-
bors, it is evident that no dust is
being discharged.
On the basis of resale of the col-
lected fines it is anticipated that
the installation will pay for itself in
about three years. Few problems
have been experienced except ini-
tially from an occasional conden-
sation within the collector when dry-
ing wet stone in very cold weath-
er. This problem was solved with
the addition of insulation on the
north wall of the collector.
A sample of crushed limestone
dust was submitted to an inde-
pendent laboratory for testing to
determine compliance with the re-
quirements of Section 214 of the
State of Nebraska 1965 Standard
Specifications for Highway Con-
struction. These results (Table I)
show that this material meets the
requirements for Mineral Filler of
these specifications. D
-------
-71-
• Sea/* the surface of ore stockpiles to prevent wind erosion.
• Penetrates surface of mineral to form a thick, water insoluble crust
• Eliminates dust problems caused by windblown panicles.
• Flexible bind resists breakup on settling of bulk materials.
•• o
ft
c
:l °
•" O
. a.
. c
•
J^ALCOe
8820
CHEMICAL
BINDING AGENT
PRINCIPAL USES
NALCO 8820 is a chemical binding agent designed to pre-
vent material loss, air pollution, and dusting problems in
the stockpiling and shipping of bulk materials. It contains a
surface-active agent that permits the product to penetrate
the mineral surface. Upon drying, a water insoluble crust is
formed which goes on protecting against erosion for several
months. NALCO 8820 is a very versatile product, finding
application in the following areas:
Coal shipping and stockpiling.
Coke and other carbon products.
Granulated fertilizers.
Limestone.
Sand and gravel.
Soda ash and potash.
Bulk minerals.
Soil stabilization.
Fly ash dust suppression.
APPLICATION
NALCO 8820 should be diluted to a 10% solution with
water prior to application. The product is applied to the
material surface with a spray apparatus. Normal dosage is
1.2-3.6 gallons of solution per 100 square feet of area
treated. Generally, the finer the particle size, the more
chemical required. Approximately 12 hours should be
allowed to achieve complete drying and crust formation.
After drying is complete, the resulting film is resistant to
sunlight, rain, and wind deterioration.
It is not necessary to use high pressure, specialized spray
equipment to apply the NALCO 8820; any type of spray
apparatus is suitable. Agricultural rigs capable of 50-200
pounds pressure work well.
Independently constructed gasoline driven engines with
high speed centrifugal pumps work well. Spray nozzles
allowing for coverage of the required distance are necessary.
Ask your Nalco Representative for additional information
regarding application instructions.
GENERAL DESCRIPTION
NALCO 8820 is an organic-based product in liquid
form. It requires only dilution with water to ready it
for application.
Density 8.77 Ib/gal
Color White
Odor" Sweet
Viscosity (Neat @ 75°F) 15 cp
pH (5% Solution! 5.8
Pour Point 29°F
Flash Point > 200°F
Freeze/Thaw Recovery Complete
HANDLINQ AND BHIPPINQ
NALCO 8820 is available either in bulk shipments or in
55-gallon non-returnable lined steel drums. Approximate
drum weight is 450 pounds net. Due to the film forming
tendency of 8820 upon drying, it is necessary to keep the
drums tightly closed when not in use. Avoid prolonged con-
tact with skin; wash any affected area with plenty of water.
NALCO CHEMICAL COMPANY
iMOUSTMIAk DIVISION WATB« TMSATMBMT CMSMICALS
89O1 euTTERPlELO PIOAO ., OAK U^OClK. !ULirJOI3 60331
SUBSIDIARIES IN AUSTRIA. BRAZIL. CANADA. COLOMBIA. FRANCE.
ITALY. MEXICO. SPAIN. SWEDEN. SWITZERLAND. VENEZUELA AND
WEST QERMAhiV AFFILIATES IN AUSTRALIA. CANADA, HOLLAND.
SOUTl-i AFRICA UNITED KINGDOM AND THE UNITED STATES.
*«fifUr** TrtOmiru of Ntico ClM*ic*l Ce»w»
i* U 1«. I M
r"^
NALCO
-------
CHEMICAL PRODUCTS
COMPOUND MR
Increased Wetting Power For Dust Control
Reduces airborne dust
Increases wettability of extremely fine
particulate materials
Non-reactive
• Biodegradable
• Easy to handle
• Proven safe and effective
Crushtng tower at North Carolna stooe quwry
... 30 seconds after dust control system was turned off.
tone faofty with t» Johnson-March Ctwm-Jet dust control
system in operation.
Improved dust prevention
Fugitive dust—generated by han-
dling of bulk materials or wind ac-
tion on stockpiles, has an adverse
effect on both working and living
environments.
Wet suppression has proved the
most practical means for reducing
fugitive dust emissions.
Johnson-March Compound MR is
a safe, economical, and convenient
additive that significantly increases
the effectiveness of wet suppression.
Here's how (and why) it
works
Compound MR offers superior wet-
ting and penetration characteristics.
Essentially, it reduces water's surface
tension so that it wets, spreads
through, and penetrates highly hy-
drophobic materials.
This saturation agglomerates small
dust particles into heavier particles,
eliminating dust that would otherwise
occur during materials handling. This
creates a surface highly resistant to
the effects of momentum changes,
abrupt directional changes, wind ac-
tion, and other dust generating
forces. The end result is decreased
ambient dust.
MR formulated for top
performance
Johnson-March has drawn on forty
years of experience in solving the
dust control problems of materials
handlers to develop this blend of sur-
face active materials, couplers and
stabilizers. The results? Excellent
surface active qualities, combined
with controlled viscosity, broad stabil-
ity and solubility characteristics. In
short, an outstanding performer that
is especially tailored to the dust con-
trol needs of the Johnson-March
Chem-Jet Wet Suppression System.
-------
Proven by
independent experts
to be environmen-
tally safe
The following information is an ex-
cerpt of a report prepared by inde-
pendently commissioned consultants
for the Michigan Department of
Natural Resources concerning the
environmental consequences of
continued use of Compound MR
(complete information available
on request):
Air quality—"Compound MR, in
view of its overall non-volatility and
absence of heavy metals, presents
no hazard to air quality due to evap-
oration ... or from incineration."
Water quality—"... low toxicity for
mammals indicates no damage from
ingestion. The high levels necessary
to produce toxic effects in fish are
much greater than those which would
be expected from a potential major
accidental spill."
Metal leaching—"The leaching
ability of Compound MR is quite
poor and no augmentation to the dis-
solving of a variety of metals ... is
to be expected."
Biodegradability— The rapid
degradation of (MR)... will not build
up to levels toxic to mammals or fish
... no toxic degradation products are
to be expected."
Conclusion—"It does not appear
that any acute toxological effects
could occur under the use of
this surfactant."
SPECIFICATIONS:
Appearance
Odor
ph (1%)
Specific Gravity (at 77T)
Freezing Point
Boiling Point
Flash Point (TCC.)
Fire Point
Cloud Point
Temperature Stability
Solubility
Dilution Rate
Freeze-Thaw Stability
Compatibility in Hard Water
Type of Container
Clear fluid
Mild, pleasant
6.0-7.0
1.007 ±.002
22°F
212°F
None to boiling point
None to boiling point
No upper or lower cloud point
Stable at all temperatures
Between 22°F-212°F
Soluble in water, alcohol
1:1000
Stable—6 cycles (minimum)
Good
New lith/lined 55 gallon steel drum
r» _ _f ..„_...,,„. „,_-
Technical Considerations
VtettaWlttyaixl Penetrability: .
Compound MR reduces water sur-
face tension from 75 dynes to toss
than 25 dynes/cm. TNs increases '
ling, wetting, and pene-
powers. The tower tie surface
tension in dynes, the greater the
spreadability of the solution. No other
competitive product has been found
that can match cor
ting tests.
Flash Prtnt: Compound MR has no
flash point up to the boiling point.
Some competitors make Iheir prod- :
udwtrh inexpensive, low flash point
ak»hol as a stabilizer, andthis could
risks of fire and exptoskxi.,
Fre«ze-Thaw and Heat StabMfty
Because it can withstand the effects
of heat and oc4d wttrxxrt separating
into layers, compound MR doesn't
require continuous mixing. Heat
staDity prevents the risk of system
there te no
'
DieperslbHtty: Compound MR
concentrate goes into sorutkjn im-
mediately when proportkjned into
X uniformly
tiBatedsolutiOTwrHchprovkJesexcel-
tent wetting consistentty.
Vtecosity IbmperBturB Cur
Special provisions have been made
that assure mirin^ change in com- -
pound MR viscosity ever the ambient
temperature range. ThU provides
Johnson-March Corporation
555 City Line Ave.
BalaCynwyd, PA 19004
(215)668-2800
Export Dept., 1201 Chestnut St., 14th Floor, Philadelphia, PA 19107
The clear choice In dust control.
Johnson-March designs, engineers
and manufactures Fabric Filters
and Chemical Wet Suppression Sys-
tems for dust control for almost
any application regard/ess of size
and complexity.
BuM* No. 150AN-2.5M-1062
-------
Product Description
Dustgard is a natural hygroscopic compound in
concentrated liquid form. It draws moisture from the
atmosphere and holds it in surface soils, acting as an
extremely effective dust control agent.
Source
The natural, concentrated brines of the Great Salt
Lake in Utah are pumped into shallow ponds, where
through a process of solar evaporation and carefully
controlled phase chemistry, they are formulated into
Dustgard.
Typical Chemical Composition
Major
Constituents
Maximum-
Minimum
Typical
Analysis
SO,
K
Na
Ca
Minor Elements
Li
B
Br
Fe
Ni
Cu
Zn
As
General Additives
33.0-27.4
3.5-0
0.5-0
0.5-0
0.1-0
1% by Weight)
32.0 .
2.5
0.3
0.3
0.05
Typical Concentration (PPM)
600
500
900
< 5
<
<
<
<500*
'Specific information available upon request
Specific Gravity 1.31 to 1.36
End Uses
*•
Dust suppression, surface stabilization, roadbase
compaction, erosion control of unpaved roads.
Packaging/Shipping
Available in bulk: rail car, tank truck or drums.
Call our customer service department for handling
and transportation requirements
Product Stewardship
GSL is pleased to-provide assistance from technical
personnel in judging the suitability of any GSL
product to your processes. We suggest you become
thoroughly familiar with the application and prop-
erties of this product in reference to health, safe
handling and environmental quality. GSL cannot
accept any responsibility for the improper use or
application of this product.
Additional Information
For Additional information
please call Zenex Chemical
at (312) 549-0600
Procedure
Roadbed Preparation: No specialized equipment is
necessary. Where necessary, prepare the road surface
to eliminate any potholes or washboarding. Normally.
-------
only blading is required. The surface should contain"7^"
an adequate mix of aggregates and fines and be
crowned to allow for good drainage. Compaction
prior to Dustgard application is recommended, to
eliminate any void spaces.
Watering: Prior to the application of Dustgard, the
road should be watered to break any surface tension
and to allow optimum penetration of the product
At the time of Dustgard application, the road should
ideally be moist to a depth of two to four inches.
Dustgard Application: A pressurized spreader
bar is recommended. Apply Dustgard at a pressure of
three to four PSI. This recommendation may vary,
depending on roadbase type, condition and location.
Gravity feed units may also be used if necessary.
Dustgard should be applied in two 1/4 gallon/
square yard passes for a recommended \/2 gallon/
square yard treatment.
Compaction: After Dustgard application, a steel or
rubber-wheeled roller is used to provide good
compaction and a firm, finished surface.
Application Volumes
Width of Gallons/mile at rate of
spread 1/2 gallon per square
(feet) yard
4 1.173
8 2.346
16 4.693
24 7,040
30 8.800
Miles per
truckload
(4,550 gallons)
3.87
1.93
.97
.65
.52
General Services Administration
Federal Supply Service
Authorized Federaf Supply
Schedule Pricelist (Catalog)
Schedule Title: New Item Introductory Schedule
FSC Class(es): 6810
Contract Number: GS-OOS-40069
Untreated
Fines escape as dust or through water and wind erosion.
Aggregates are loosened, surface becomes unstable, rough.
susceptible to further damage.
Dustgard Treated
Fines and aggregates are bound together with moisture.
Good compaction and smooth, durable surface are achieved.
Months After Dustgard Treatment
Dusrgard's hygroscopic action continues to attract and hold
atmospheric moisture, preserving compaction and surface
smoothness.
ZENEX CORPORATION '
2940 N. Halsted Si.'
Chicago, Illinois 60657
312/549-0600 Telex: 25-4587
-------
-76-
SPECIFICATION FOR OUSTGARD
SCCPi
1.1 A cr32t.T.ent for ooen surface gravel and crusned rock roads whera
either native soils or imported graded soils are involved, and
zhat soils when treatad will arrast fugitive airborne dust, stab-
ilize the soil indepth, and reduce frost coil action.
1.2 This :reai^ent of soils to apply to ai'her a sur-aca application as
a dust suppressant or road beds treated in depth for stabilization.
CRITERIA
~~~~~~^~~' i
2.1 A material that can be used in clays, silt and sands, or varying
ratios of same. •
2.2 Only slightly more corrosive to equipment than water. • ,
2.3 Non Toxic
2.4 flon Flammable
2.5 Non-Hazardous to handle . •
2.5 Will not freeze to approximately 50 degrees J>elow zero
2.7 Requires no special equipment for application
2.3 Easy clean up of equipment
2.9 Met harmful to animal and plant life
*
2.10 Economical to use
3. TYPE
3.1 The material shall be magnesium chloride based in liquid form,
water clear and ready to use.
(
4. CHEMICAL COMPOSITION
4.1 Major Constituents . MIN MAX
Mg . . 7.0* 9.0**
C12 20.4 24.0
S0
-------
-77-
Soecification for Oustgard
APPLICATION - Genaral Parameters Oustgard
C^r experience'has shown that bast results are obtained as follows:
Read bed should be pretreated with water.
5.2 Scarification may be necessary to remove potholes and.washboarding
etc.
5.3 Grading is desirable to shape the road and bring it to a crown for
water drainage.
5.4 Application of Oustgard at the rate of .5 gallons per square yard
has given the best results. Lesser application rates have also
been successful and may be. adequate for your desired performance.
5.5 If you can compact the road surface with either a rubber wheeled
roller or-a steel roller, you get a smoother, more desirable surface,
Don't compact until the road material will not stick to the roller.
6. SAMPLING, TESTING AND REJECTION
6.1 If the material fails to meet Section 4.1 chemicaT composition, the
material can be rejected.
6.2 Testing, sampling and analysis will be by standard accepted practice.
7. PACKAGING
7.1 Material can be delivered in either bulk form via rail or truck.
Drummed material is also available upon request.
-------
The standard—for automatic drive, one pass street sweeping.
Sweepers are our only business
-------
We set the standard—constant broom speed; superior operator control forward, reverse, stop; outstanding
fuel economy, low maintenance costs.
Brakes:
Service:
Type—Full power, fully enclosed, internal expanding
Protection—Enclosed double dust shield
Actuation—Hydraulic by foot pedal
Surface—256 square inches (1651 cm2)
Parking:
Type—Positive mechanical ondrive sprocket
Actuation—Hand lever
Operational Holding:
Type—Mico accumulock
Cab:
Type — Full, 14-gauge steel
Doors — Rat safety glass
Opening — From rear
Latches — Automotive
Dust Protection — Rubber gasket sealed
Windows — Safety glass
Visibility — 3,686 square Inch (2.38 m2) glass area
Rear — Slide opening type
Windshield wipers — Dual electric
Mirrors—Inside (1)
Lights (interior) — Instrument panel
Seat(s) — Deluxe foam cushion with seat belt(s)
Sound suppression — Tunnel cover and firewall sound insulation
Chassis-Body:
Type— Unitized, fabricated and welded heavy steel plate
Tow Hooks—Two front, two rear
Capacity—30 quarts, (28.4 L) 50%antMreeze, 50% water
Core Area—21 y«"x22"(537mmx559mm)
Type—6 blade pusherwith shroud enclosure
Conveyor System:
Type — Multiple ply reinforced fabric rubber belt
Cleats — Nine, integrally molded, full width
Splice — Full width steel
Drive — Independent hydraulic gerotor motor, chain and sprocket drive
Protection — Relief valve
Speeds — Forward/Reverse, independent of brooms
Dimensions:
Wheel Base 127.4"(3236mm)
Drive Wheel Tread 7"7"(2311mm)
Overall Length 15/10"(4826mm)
Height with Cab 9TJ"(2743mm>
Width OutsideTires 8"6" (2590 mm)
Turning Radius Sweeping 15V(4572inm)
Sweeping Path — One Side Broom 8*0" (2438mm)
Two Side Brooms 10V(3048mm)
Weight —With Cab One Side Broom 13.800 IDS. (6260 kg)
With Cab Two Side Brooms 14,400 Ibs. (6530 kg)
Travel Speed Upto24mph(38.6km/h)
Electrical System:
Alternator/Regulator — Unitized, 60 ampere
Battery —12 volt, 90 ampere hour
Lights (exterior) — Sealed multiple beam headlights. Combination stop and
tail lights. Adjustable side broom spotlights, Directional signals with
hazard switch, electric backup alarm.
Engine:
Type — V-8. H.D. Industrial (IHC 345)
Fuel — Gasoline
Cylinders — 8
Displacement — 344.958 cubic inches (5654 cm3)
Horsepower —145 (147 HP metric) at 2800 RPM
Torque — 281 ft. Ibs. (39 kg. m.) @ 2100 RPM
Air Cleaner — Dual safety element dry type
Engine Mounting — Rubber
Oil Filter — Full flow with replaceable element
Fuel System:
Tank capacity — 35 gallons (132.5 L)
Location — Outside operator's compartment
Tank Construction — Steel
Pump — Diaphragm type
Governor — Mechanical
Capacity—3cubic yards (2.3m3)
Dumping Method—Hydraulically elevated and pivoted
Dumping Height— Up to 9'6"(2895 mm)
Clearance height required when dumping at max height—16' (4.87 m)
LGIFNJ
Elgin Sweeper Company
f=»O Box S3T 13OO West Bsrttett Road
Elein. Illinois 6O12O
Telephone: 3l2/-7fcM-S3VO
Telex T2-2413 • Cable: El_GS\A/F=>
Printed in U S A
Max. reach—33" (838 mm)
Max. extension of hopper—Tl W (2.17 m)
Hopper width—5' (1524 mm)
Lifting Capacity—9000 Ibs. (4080kg) net load
Instruments:
Panel — Full vision, illuminated
Gauges — Clock type speedometer. Odometer, Tachometer, Engine heat
gauge, Oil pressure gauge. Ammeter gauge. Fuel gauge, Kay type ignition
switch, choke and hand throttle
Hydrostatic Drive:
Hydrostatic transmission consisting of back-to-baek variable-displacement
pump and fixed displacement motor equipped with- pressure override
relief valve, single foot pedal for forwa»d/reverse control without clutch
and shifting, dynamic braking, broom speeds. Independent of vehicle
speed/direction, oil temperature gauge, cab insulation, 2-speed differen-
tial axle, oil clutch broom engagement, with automatically actuated brake.
Main (Pick-up) Broom:
Type— Prefab Polypropylene, disposable
Size—36" dia. 68" long (914 mm Dia. x 1727 mm Lg.)
Core—Steel, reversible
Speeds—Variable
Controls— Raising, lowering, nydraulically by operator in cab
Paint:
Color—Hi-Way Yellow or Standard White
Side Broom:
Type—vertical digger
Diameter—36 inches (914 mm)
Location—Center of sweeper behind drive wheels
Speeds—Variable
Protection—In/Out (adjustable recoN spring). Up/Down, Forward/Rearward
Suspension — Positive hydraulic positioning with spring, cushion float over
street surface
Controls—Raising lowering and positioning hydraulically by operator with
single lever in cab
Segments—Four, quickly detachable; cast aluminum
Filler—Tempered steel wire
Steering:
Type— Full power hydrostatic
Wheel—18 inches diameter (457 mm Dia.)
Tires:
Front=—(2) 10:0ffx20 F(12P.R.)
Rear—(2) 7:50x 15 E(10P.B.)
Water Sprsy System:
Tank:
Capacity—180 gallons(680L.)Addi«onal capacity available
Protection—Coro-gard anti-rust lining
Access Door—Top, forward of cab
PumpType—Gear, 40 PSI with relief valve
Rusher—Integral cascade hopper/conveyor wash
Spray nozzles—Adjacent to each broom, atomizing
Controls—On-Off, variable flow in cab
Filter Location—Exterior left side
Fill Hose—12.5' (3800 mm) with coupling, permanently mounted w/storage
basket
Wheels:
Front—Steel disc type, mounted on alloy steel axle
Rear—Dual steel disc type, mounted on aHoy steel axle
Protection—Skid plate supports and fenders over drive wheels
Options:
Dual Controls.— Equipped with right and left side brooms, seats, and oper-
ator controls, providing, operation from either side of operator's
compartment for sweeping in direction of traffic.
Hydraulic Main Broom — Spring-suspended, and snubbed with positive
power hydraulic positioning. Position Indicators show position and ores*
sure of main and side brooms located adjacent to operator's seat Adjust-
ment for pressure and fiber wear adjacent to operator's seat
Diesel Engine (John Deere 4276T) — 4 Cylinder
Piston Displacement — Cubic Inches 276 (4523.64 cm*)
Horsepower 95 (96.3 HP metric) @ 2200 RPM
Torque 265 (36.» kgfrn) @ 1500 RPM
Air Cleaner Dual Safety Element Dry Type
Oil Filter , Full Row
Stroke 1 5.00" (127 mm)
Bore 4.19" (106.43 mm)
Compression Ratio 16.5 to 1
NOTE: Elgin Sweeper Company reserves the right to change the above specifi-
cations when, in its opinion, improvements will result from so doing or
when Government material regulations make change-necessary.
^Copyright, 1982, Elgin Sweeper Company
Form No. ES82PHS
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The Leader. Power vacuum cleaning with power sweeping and diesel economy and efficiency.
Sweepers are our only business
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Mr System: '
Compressor Capacity — Truck 7.2S CFM (205 Umin)
Compressor Capacity — Sweeper 12.0 CFM (340 Umin)
Electro-Pneumatic Valves Actuated from operator's position
Air Cylinders — Position vacuum nozzle, extension and side brooms
and gate valve.
Axles:
Front 9.000 ib. (4082 kg) with 12,000 Ib. (5443 kg) springs
Rear Two speed 19,000 Ib. (861» kg)
with 19,000 Ib. (8818 kg) single stage
vari-rate springs and 4,000 Ib. (181+kg) auxJSary springs.
Ratio .;. .. .....&50 high—8.87 tow
Blower: . '
Drive - .':, Direct 5-Groove Power Sett
Speed—RPWi.,,. ,,.....-... „..„„.. 3486
Blower Rating iaOOOCFM(283,2(»Umirt>airvolume
Diameter—Inches .. 3TV*(794mm) Width—Inches.... 8(203mm)
- No.of Blades.,.,,»j,„»',»;*'•.;;•;,,,.».„.,,_.......«.»,..^.».^^ft^i".^;.81
Vacuum RatingatSucth-inNozil*: 51"(.129t«g/cm») Negative VWMer Pressure
Body; • ' *
Construction ....:..< .... Weld8d-Steel plate
Vacuum Chamber—Voided 7.4CubJcYards(5.6m3)
Dumping—Hoistedhydraulicallyto50°angtebypropulaionengjn*
Door — Opened, rrydraulically by propulsion engine — mechanicalty
latchable
Hopper floor angle degrees........ '..,•*•
Full Hopper Indicator—Weight actuated switch with warning light in cab
Safety Prop , StBetbarunderbody
Brakes: - •,,-•. - - . - - :'- .. : ,
Service Brakes — FuU air S-carw type with 7.25 CFM (205 Umin) Air Com>
Front......... ,i .«,,_„. .V.J. ..,:.„„ 1« x 4" (380mm it 102mm)
Rear .>.....™.,,», t6.S*7"(^*wm*ir»mw)f
Plying/Emergency Brake*—Piggyback typai spring applied, air released
Side Broom
Segments—2aluminum,quickdetachabte,temperedwirefilled
Diameter—Inches — 28 (711mm)
Wear Edge Steel discforcurbcontact
Speed Constant—Non Reversible
Flexibility — Rubber shock mounted and free floating to follow street
contour
Drive Hydraulic motor with relief valve
Adjustment For tilt, pressure and wear
Lift Control Pneumatic—from operator's position
Pressure Control Pneumatic—from operator's position
Location Centerof sweeper—forward of vacuum nozzle, retractable
Extension Broom
Type Poryprcpyleneprefab-dlsposabte-reverslble
Diameter—Inches ., 16 (406mm)
Length—Inches , 80(1524mm)
Speed Constant—Non Reversible
Lift Control — Pneumatic—from operator's position
Drive —.... Hydraulic motor with relief valve
Chassis:
Type „ „.. CO-ISSOBwitfitiltcaboverengbw
Frame Inverted"L" Reinforcement
Section Modulus Combined 1170
Resistance to Bending Moment, 493,200
Dimensions:
Wheel Base 149" (3785 mm)
Drive Wheel Tread 6U7" (2050 mm)
Overall Length 21V (6604 mm)
Overall Width at)" (2438 mm)
Overall Height 97" (2921 mm)
Cornering Radius 11B" (3505 mm)
Outside TUming Radius 24"9" (7544 mm)
Sweeping Path:
Vacuum Nozzle Only 2W" (762 mm)
Vacuum Nozzle S Side Broom 4-0" (1219 mm)
Vacuum Nozzle S Extension Broom 6«" (1981 mm)
Vacuum Nozzle Side Broom & Extension Broom 8' (2438 mm)
Traveling Speed Legal highway speeds
Clearance Height Required When Dumping 17<6" (5334 mm)
Electrical System:
Alternators 81 amperes each-
Batteries 2-12 volt 104 amp 206-ampere hours total
Lights — Sealed multiple beam headlights with floor mounted dimmer
switch, two combination stop S tail, back-up, dome, clearance, identifi-
cation, side broom, instrument, license plate, and directional signals
with hazard switch, electric backup alarm.
Engine — Propulsion:
Engine (Cat 3208) V-6
Piston Displacement 636 cu. in. (10424 cm1)
Torque Ft. Lb 400 (55.3 kg/m) @ 1400 RPM)
ELGIIXI
Elgin Sweeper Company
F»0 Box 037 1300 West Qartlett Road
Elgin. Illinois S0120
Telephone: 312/7-*1-B37O
Telex 72-2413 • Cable: EUGSWF=
Printed in U S A
Horsepower .......................... 175 (177 HP" metric) @ 2800 RPW
Air Cleaner.. ...... . . .............................. TVuro Stage Dry Type
Oil Filter . . .................................................. Full Flow
Stroke ................................................. 5.0" (127 mm)
Bore .............. ..... .............................. 4.5" (114.3 mm)
Compression Ratio ........................................... 16.5 to 1
Transmission — AT54S — automatic, forward ratios of 3.45 — 2.25 —
1.41 — 1.00. reverse ratio 5.02
Engine (John Deem 4Z76T}.. ...... . ......... ......... ........ 4 Cylinder
Piston Displacement .. ......... . ........ ..... 276 cu. in. (4523.64 crrv>) «
Horsepower. ...,...,:..... ........ ... 95 (96.3 HP metric) @ 2200 RPM
Torqiw .,,,„, ..... „.„,.. ................ 268 (36i6 kg/m* @ 1500 RPM
Air Cleaner ____ ........ . ..... . ........... Dual Safety Element Dry Type
OM=t«ar ..... .......... , ..... .,: ............ ,..„ ..... ........ Full Flow
Strotei ...w.i. ..... „...„ ....... ....... ............. ...... SJOir (127 mm)
'ioret ...... *, ..... ,,»tem-.
Trade
Piwipeap»etty.-QP»* ....................... 1.7tft43L4@1000RPM
Purpose— Hydraulic power to raise body and open hopper door
' Sweeper
. PunvCapac%«-QPMf.. ........ „.-. ......... . 7.0(26.5L.)@2100RPM
; Type . ------- .. ..... .... ................... .. ................ Tandem
>,'-,' Purpose— Poworohydmutto motors onside broom and axienatonbroom
Controls— Hydraulterrmtorsactrvatewm^ lowering and ralsir^ of brooms
PropulsionEngine — Speedomotnr, tachometeiv odometer, fae» gauge, am-
BnperatUfe gauge; oH pressure gauge, dual air pressure
gauges
* Sweeper Engine—Tachometer, water temperature gauge; oil pressure
gauge, air pnffisura-gaagja, engine hour meter
X* "
Cab Hydraulic Tilt—Att weather steel with roll-down windows, flat floor, and
naugahyde foam operator's seat
Ground Point VisibHUy—Forward —Inches Approx. 75 (1905 mm)
Single operator controls right hand side, full power hydraulic
Steering Wheel Diameter , 2B-tecrr(508mm)
Vacuum Hose: « :
Type ....l,;ft|C. ......FtoxiWe, Steel Reinforced
Dlamat«r^-lliehe»6-««-..i.*., .^,.».. 11 (279mm)
. .Pneumatically RateatfLowered From Cab
.......... Opona nncf cloieir antomatteal^
t»MPH(2B1l«miEhr)
Area— Square Inches . .
Controls, ..... ____ „....
Shutter Q0er>,, ....^ . „:.„ .
AirVekwity ..,„,. ..„.,»
WaterSyatem:
WaterTank— Cap«e»y— Gallons ............... ..;.. ...... 280(1060t_)
Location ........ ---- ....... Subfloorofvacuumchamberoverrearaxle
Rltered Spray Water — f4ozzles in vacuum nozzle and at brooms
Pump— Centrifugal type with bronze Impeller
Controls — Off-On Switches located on operator^ control panel , , . ..
'
f
Empty Weight .,...*,„ ......... ...;.. .......... ... 17,700 Iba; (8028 ho)
Front Axte.. „.....» ...... ...,.^. ......... ....; 8,700 ibB. (3948 kg)
RearAxte ...... 4..,».. ...... . ......... ..... 9,tK»lbs. (4082kg)
Gross Vehicle W»lght .............. , ........ .... 28^X10 Ito. (12,70t kg)
Whe^&Tlres: . -. . . , .„.••.. 5* ,:
Wheels— Typ», ....... ....... ...... ,^ ........ .... Dtec,taterehangeabte
Rim Size ____ . ...... :it. _____ .%.«,.,,. ..... ,..A ____ •,.. ....... ... . 7'SO¥»
Tlres(si)i)
Hot Water Heater
Dual Def rosters
Two-Speed Electric
Windshield Wipera
Windshield Washers
DualWestCoastMfrrors
Fronts Hear Bumpers
Fronts Rear License
' Rate Brackets ... ,; - .w ': '
Reflectors '-.'" '
Hydrant Fill Hcw(12V7(3800 mm)
with Coupling ,
WasrrftownHos«C25T(7620mro)
wimttozzta • ,; .„ ,~ "
Painted: SlandardWIWe f "\* ~"f
Option*: , ..
Dual Controls— Left-hand vacuum nozzle andhoseasaembtyt left-hand side
broom and water system, pivoting extension broom, dual steering and
operator controls In C3&
Wandering Hdsw-~12.foott.366e firor) tang; frinch (20Smm) diameter boom
supported hoswwfth fou» foor collection nozzle. Power assisted up and
down, mounted and secured to rear of tank, water dust control system.
Notes: Specifications are subject to change without notice. For California
Engine and Transmission Specifications, Consult Factory.
1 Copyright. 1982. Elgin Sweeper Company
Form No. ES82WW2D
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-82-
AeroVironment Inc.
Particulate Matter — Measurement,
Impact Assessment, and Control Strategies
Fugitive Emissions. Pollutant emissions that directly enter the
atmosphere without passing through a stack, chimney, vent or other
equivalent opening. Examples: emissions through doors and windows of
an industrial plant: from open storage/hand/ing of coal, sand, rock, or from
unpaved roads and open fires.
Fugitive Emissions... Possible Health Hazard. Research shows that
inhalable particles less than 10-15 n in aerodynamic diameter —
especially those smaller than 2-3 pm — can be a human health hazard,
contribute to the formation of acid rain, and degrade atmospheric visibility.
Particulate matter in the atmosphere contains a variety of substances.
Some of these — fluorides, beryllium, lead, asbestos — are known to be
toxic There are others whose toxic effects have not yet been identified.
Fugitive Emissions... Not Only a Local Problem. Fugitive emissions
occurring within property lines are not only a local problem, but also can
contribute to ambient paniculate matter levels over long distances
Particulate pollutants from open sources, such as unpaved roads or open
fires, can impact areas of hundreds of square kilometers. The particles
can float in the air for seconds to days, or longer, depending on their size.
EPA TO PROPOSE A STANDARD
The EPA is expected to propose a standard for airborne participate
concentrations which will focus, for health reasons, on the smaller-than-
10 /tm aerodynamic diameter.
Key Industries Affected:
D Utilities D Mining
D Industrial processing D Cement
D Oil D Material handling
AEROVIRONMENTS EXPERIENCE
AeroVironment has conducted studies involving measurement, modeling,
and control of fugitive emissions.
Some clients:
California Portland Cement
Company
AV studied techniques for reducing
material emissions from open storage
buildings at a cement plant. An open
system of strategically placed wind
fences with a porosity of more than
50% was recommended.
Getty Oil Company
Monitoring of paniculate and
hydrocarbon emissions from diatomite
oil recovery pilot plants included an
intensive, short-term field study
focused on loading and processing
operations. Emission factors will
support client's permit application to
build a production plant.
Granite Construction Company
Intensive field study developed fugitive
particulate emission factors to support
client's permit application to the local
• Air Pollution Control District.
Oregon Department of
Environmental Quality
We used data gathered by an air quality
monitoring network to assess the
impact of field and slash burning on
Total Suspended Particulate Matter
(TSP) in the Willamette Valley of
Oregon and nearby National
Wilderness areas.
Southern California Edison
Company
AV assessed fugitive coal particle
emissions from dry coal storage piles
at a generating station. Porous wind
fences were recommended as control
devices.
U.S. Environmental Protection
Agency
A prototype Charged Fog Generator
was developed and successfully tested
to control inhalable particles using
electrically charged water droplets.
Fine particles control efficiencies of
over 90% were achieved.
AEROVIRONMENTS R&D IN
MEASUREMENT AND CONTROL
The Challenge:
A standard for inhalable particulate
matter presents two technological
challenges
D Measuring ambient
concentrations of particles in
smaller-than 10-^m size range
requires new samplers that
comply with Federal
performance specifications
D Controlling such small particles
requires new approaches,
especially for fugitive dust
AV's measurement and control
devices are described below and on
Pages 3 and 5.
When required, AV scientists and en-
gineers design and build special
measurement instrumentation and
control devices for fugitive emission
programs.
AeroVironment's Wind Fences
(featuring advanced aerodynamic
design) were developed to control
wind-blown dust and other particles
from exposed areas in mines,
quarries, construction sites, coal-fired
generating stations, and processing
facilities Portable, porous panels are
easily assembled into modular fences
Key elements are panels with 50%
porosity and strategic placement.
Smaller versions reduce fugitive, wind-
blown particles from open bed trucks.
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