EPA-450/3-74-036-b
June 1974
INVESTIGATION
OF FUGITIVE DUST
VOLUME II - CONTROL STRATEGY
AND REGULATORY APPROACH
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/3-74-036-b
INVESTIGATION
OF FUGITIVE DUST
VOLUME II - CONTROL STRATEGY
AND REGULATORY APPROACH
by
Georae Jutze and Kenneth Axetell
PEDCo Environmental Snecialists, Inc.
Suite 13 Atkinson Square
Cincinnati, Ohio 45246
Contract No. 68-02-0044
Task Order 9
Program Element No. 412953BDD1
EPA Project Officer: David R. Dunbar
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planninq and Standards
Research Triangle Park, N. C. 27711
June 1974
-------
'rtvs >"epori is issued by the Environmental Protection Agency to
reoort technical data of 4nterest to a limited number of readers.
Copies are available free of charge to Federal emoloyees, current
contractors and grantees, and nonnrofit organizations - as sunolies
permit - f"~cn the Air Pollution Technical Information Center, Environ-
mental Protection Agency, Research Triangle Park, North Carolina
277"1, or from the National Technical Information Service, 5285 Port
Royal Road, Soringfield, Virginia 22151.
his report was furnished to the Environmental Protection Agencv by
PEDCo Environmental Specialists, Inc., Cincinnati, Ohio 45246, in
fulfillment of Contract No, 68-02-0044. The contents of this renort
are reproduced herein as received from PEDCo Environmental Soecialists
Inc. The opinions, findings, and conclusions exoressed are those of
the author and not necessarily those of the Environmental Protection
Agency. Mention of company or product names is not to be considered
as an endorsement by the Environmental Protection Agencv.
Publication No. EPA-450/3-74-036-b
11
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ACKNOWLEDGMENT
Many individuals and organizations have been helpful
in developing this report; for these contributions the project
management extends its sincere gratitude.
The contributions of Messrs, Bruce Scott of the Arizona
Division of Air Pollution Control; Donald Arkell and Janette
Smith of the Clark County Health Department,' Norm Covell and
Dan Dobrinen of the Fresno County Air Pollution Control
District; Robert Taylor and Grant Johnson of the Maricopa
County Health Department; Richard "SeF"d"o"2'~S"f"the""Nevada Bureau""
of Environmental Health; David Duran of the New Mexico
Environmental Improvement Agency; John Ensdorff and William
Griffith of the Pima County Air Pollution Control District?
Harry Davidson of the Albuquerque Department of Environmental
Health; David Howekamp of EPA's Region IX; Gary Bernath of
EPA's Region VI; Edward Lillis of /EPA's Control Programs
Development Division and a dedicated group of technical
specialists in EPA, OAQPS were of particular significance,
Mr. David Dunbar, Environmental Protection Agency, served
as project officer, and Mr. George A, Jutze, PEDCo-Environmental
Specialists, Inc., the project manager, assisted by Messrs.
Kenneth Axetell, who directed the investigative program and
William Parker,, who implemented the field effort.
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Pacre Number
2-1
2.1 General Testina Rationale 2-1
2.2 Control Strategies to be Tested ... 2-3
2.3 Results 2-7
3.0 PROPOSED REGULATORY APPROACHES ......... 3-1
3.1 Regulation for the Control of
Particulate Matter: Unpaved Roads. 3-1
3.2 Regulation for the Control of
Particulate Matter: Agriculture .. 3-2
3.3 Regulation for the Control of
Particulate Matter: Material
Storage 3-3
3.4 Regulation for the Control of
Particulate Matter: Tailings Ponds 3-3
3.5 Regulation for the Control of
Particulate Matter: Feedlots ..... 3-3
3.6 Regulations for the Control of
Particulate Matter: Construction . 3-3
3.7 Regulatory Considerations 3-4
4.0 SUMMARY AND CONCLUSIONS 4-1
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1.0 111 'PRODUCT IOiM
Implementation plans for five Air Quality Control Regions
in the States of New Mexico, Nevada, Arizona, and California
failed to demonstrate achievement of primary or secondary
suspended particulate air quality standards. In addition, the
Albuquerque - Mid Rio Grande AQCR was included in the investiga-
tion since emissions from unpaved roads were identified in the
SIP. A preliminary investigation by EPA indicated that all six
of these AQCR's were arid areas with widespread fugitive dust
problems, and that this fugitive dust either had not been con-
sidered in the implementation plans or was poorly quantified in
particulate control strategy evaluations.
PEDCo-Environmental was asked to determine the fugitive dust
sources having a major impact on particulate levels and to in-
vestigate control techniques and regulatory approaches which
would result in attainment of the air quality standards. The
resulting project was divided into three phases, which could be
characterized as design, data collection, and strategy develop-
ment and testing.
In Phase I, significant fugitive dust sources in the
four-state study area were identified and sampling studies
were designed to better quantify their relative contributions.
This information was submitted for EPA review in the Phase I
report on July 14. In brief summary, three fugitive dust
sources were found to have regional impacts -- unpaved roads,
agriculture, and construction activities — and several others
were found to create significant localized sources of particulate,
Only the three major sources were investigated in the sampling
studies. A total of seven field sites in the four states were
proposed in the Phase I report, with three specifically for
unpaved roads, two for agriculture, and two for construction.
1-1
-------
Phase II was composed of three distinct areas of data
collection performed concurrently:
1, conduct of field sampling at the seven sites to
generate source impact data;
2. survey of the six AQCR's to determine the number
and extent of their fugitive dust sources, from
which to estimate emissions; and
3. investigation of feasible control techniques for
fugitive dust, including the approximate efficiencies
of the controls.
The description and presentation of results for each of
these data collection efforts comprises a companion report
to EPA titled, "Investigation of Fugitive Dust - Sources,
Emission and Control," May, 1973.
Phase III involved the combining of selected control
techniques for different fugitive dust sources into comprehensive
control strategies, and the testing of alternate strategies in
attempting to demonstrate achievement of air quality standards
in each AQCR. Predicted reductions in emissions from use of
control techniques were compared with reductions in ambient
particulate concentrations necessary to reach the standards.
The procedures and results of this control strategy testing
are presented in this report. In addition, a series of example
regulations for the control of various fugitive dust sources
are included.
1-2
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2.0 CONTROL STRATEGY TESTS
2.1 'izdli?ral Testing Raniona_l e_
The implementation plans submitted by the states for
the AQCR's under investigation did not show attainment of
primary and secondary particulate air quality standards. By
considering fugitive dust emissions and their control in the
simulated strategy analyses, the work presented in this section
has attempted to demonstrate that they can be achieved. The
same air quality data and key receptor sites which were used
in the implementation plans have been used in the present
analyses. These data are shown in Table 2-1. For further
uniformity, a 1970 base year has been used wherever possible
in the collection of fugitive dust emission data.
Emission reductions were predicted by applying the
percentage controls found in the control techniques investigation
to the emission data compiled for each region. Particulate
emissions, both existing and predicted following control, from
conventional sources were taken directly from the implementation
plans for use in these control strategy tests.
Two different methods were employed in testing the
strategies -- IPP diffusion modeling and proportional reduction
(rollback). Selection of the more appropriate method was made
after checking (a) availability of adequate point and area
source distribution data for diffusion modeling, (b) topography
of the area, and (c) that emission density was high enough
to be significantly different than background if the area was
to be modeled.
In the Albuquerque-Mid Rio Grande AQCR and the Phoenix
and Tucson metropolitan areas, all of the above conditions for
modeling ware met. Because of the large areas involved, only
2-1
-------
TABLE 2-1
AIR QUALITY DATA USED FOR
CONTROL STRATEGY TESTING
AQCR
County
Sampling Station
1970 Annual
Geometric Mean,
San Joaquin
Phoenix -Tucs on
Kern
Tulare
Fresno
Kings
Stanislaus
San Joaquin
Maricopa
Pima
Final
Bakersfield
Visalia
Fresno
Hanf ord
Modesto
Stockton
South Phoenix
North Tucson
Florence
169
167
97
98
94
77
265
156
149
Albuquerque -
Mid Rio Grande
El Paso-Las Cruces-
Alamogordo
Nevada Intrastate
Bernalillo
Dona Ana
White Pine
Nye
Churchill
Albuquerque
Dona Ana
McGill
Gabbs
Fallen
121
145
(108)*
(97)
(82)
Northwest Nevada
Lyon
Washoe
Douglas
Lyon
Fernley
Reno - Sparks
Stateline
Yeringtor.
(75)
(99)
(71)
(71)
1972 data in parentheses
2-2
-------
portions of these regions were included in the modeling area.
The standard IP? program was used, with the model for each
of the areas being satisfactorily validated with 1970 emission
and air quality data.
In the San Joaquin AQCR, detailed information could not
be obtained for point and area sources in "hot spots" around
Bakersfield, Visalia, and Fresno, Since the majority of
emissions in this AQCR were from agriculture, it was decided
that distribution was not critical to reduction patterns and
that rollback would be an equally accurate evaluation technique
For the other three AQCR's, there were very few emissions from
point and area particulate sources, and fugitive dust emission
density was also relatively low. Therefore, the possibility
of modeling was eliminated and rollback was used. Emission
reductions in the four regions utilizing rollback calculations
were done either by county or for a smaller area immediately
surrounding the sampling site.
2.2 Control Strategies to be__Tested
Strategies were devised by project personnel by fitting
the most appropriate available control to each source category.
The degree of control imposed was also influenced by the
relative contribution of a source category to total particulate
emissions. uniform control methods were generally applied
throughout an AQCR, although more strenuous controls were
possibly required in the areas with highest measured concen-
trations .
Three strategies were tested for each AQCR -- the first
(control strategy A) with moderate control, the second (B)
with what was judged to be the best available technology, and
a third of comparable stringency but uniform for all AQCR's (C)
These are summarized in Tables 2-2, 2-3, and 2-4.
2-3
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TABLE 2-2
SUMMARY OF CONTROL STRATLGY A
Source
Control
Unoaved Roads
Agriculture
Construction
Tailings Piles
Aggregate Storage
Feedlots
Chemical stabilization of 10 percent of
roads., paving of 5% of roads.
Speed limit of 25 raph.
Continuous cropping or limited irrigation
(where agriculture is a significant source)
Watering
Chemical or vegetative stabilization
Chemical spray
Watering by truck or sprinkling system
2-4
-------
Source
Control
I,nDaved Roads
Agriculture
Construction
Tailings Piles
Aggregate Storage
Taedlots
Pave roads with more than 150 vehicles/day
in Albuquerque, Pnoenix-Tucson, El Paso,
San Joaquin AQCR'S; pave roads carrying 15%
of venicle milc.s in Nevada Intrastate and
Northwest Nevada
Speed limit of 20 moh.
Continuous cropping or limited irrigation
(where agriculture is a significant source)
Watering and Chemical soil stabilization of
completed cuts and fills
Combined chemical - vegetation stabilization
Chemical spray
Watering by truck or sprinkling system
2-5
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TABLE 2-4
SUMMARY OF CONTROL STRATEGY C
Source
Control
Unpaved Roads
Agriculture
Construction
Tailings Piles
Aggregate Storage
Feedlots
Pave 10% of roads
Speed limit 20 mph. in city limits, 25 mph.
in rural areas
Continuous cropping or limited irrigation
Watering and chemical soil stabilization
of completed cuts and fills
Combined chemical - vegetative stabilization
Chemical spray
Watering by truck or sprinkling system
2-6
-------
For areas wnich did not achieve at least the primary
standard «ith one of taese strategies, one additional control
tecanique was applied; tne use of cnemical soil stabilizers
on actively tilled agricultural lands.
2.3 Results
Albuquerque-Mid Rio Grande was the first region tested
Dy modeling, Tne area modeled included all of Bernalillo
County (location of metropolitan Albuquerque) and adjacent
strips of the other two counties in the AQCR, Valencia and
Sandoval. Tne initial attempt at validation gave a correlation
of 0.75 with 8 receptor sites. Two of the data points were
badly out of line with the line of best fit. These two sites
were the only ones outside the Rio Grande River valley. After
modifying the model to account for differences in elevation between
the river valley and mesa zones, correlation increased to 0.90. The
ratio between calculated and observed values {slope of the line of
3
oest fit) was 1.57 and the y-intercept was 9 yg/in after
subtracting background. This was thought to be an excellent
model of such a highly variable system as fugitive dust emissions.
Utilizing these data, an isopleth map was constructed (Figure 2-1)
depicting the suspended particulate levels in Albuquerque prior
to fugitive dust control. When the three control strategies
were applied to the fugitive dust emissions, the maximum
indicated particulate concentrations in the area modeled were
64, 61, and 61 pg/m geometric mean for strategies A, B, and C,
respectively. An isopleth map of predicted regional air quality
with strategy B is shown in Figure 2-2.
The Pnoenix-Tucson AQCR was modeled in two separate parts,
for the two major metropolitan areas in which achievement of
2-7
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VALENCIA COUNTY
•gure 2-1 Predicted ParHculate Concentrations in Albuquerque Area Prior
to fugitive Dust Control »
-------
SANDOVAi. COUNTY
BERNA^LLO COUNTS
40 Wm3 30
VALENCIA COUNTY
f T/DRlANvE COUNTY
Figure 2-2 Predicted Particulate Concentrations in Albuquerque Area with
Control Strategy B.
2-9
-------
standards could not be demonstrated. This dual approach was
required because of the distinct topographical difference
between tj;e two urban areas. Also, the sensitivity of the
mathematical diffusion model is enhanced by reducing the size
of the investigated region. In the validation runs, correlation
with observed values was relatively low in one case, i.e. ,
0.45 for Phoenix, while an acceptable value of 0.70 was found
for Tucson. Elimination of one of the outlying data points on
the plot of calculated vs. observed values for Phoenix increased
the correlation of 0.79 and changed the slope of the line of best
fit to 0.64. The sampling site associated with the eliminated data
point did not appear to be representative of the area in which
it was located because it was situated on a small mountain. With
this change, both of the models were thought to be acceptable
(see Figures 2-3 and 2-5 for Pre-controlled Conditions), so
emission reductions from the three control strategies were applied.
In the Tucson area, resultant maximum concentrations were 77, 63,
and 63 ug/m (annual geometric mean) for the three strategies.
The area exceeding 60 ug/m under strategy B was limited to a
few square miles and was caused by a point source rather than
fugitive dust emissions. A 94 percent control on this remote
mining operation instead of the presently required 90 percent
would achieve the 60 ug/m level in this "hot spot" indicated by
the model. The isopleth map for control B is shown in Figure 2-4.
In the Phoenix area, however, the same three strategies
caused maximum particulate levels to decrease only to 114, 94, and
3
95 yg/m geometric mean. The results of strategy B are shown in
Figure 2-6. Large parts of Maricopa County were shown to exceed
the primary standards for any of the three strategies. A
review of the sources contributing to receptor sites above
the standards revealed that the major sources in every case
were agricultural emissions. Available control techniques
clearly did not have a high enough percentage reduction in
agricultural emissions to achieve the standards in the Phoenix
area. A 65 percent control of agricultural emissions was
2-10
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90 jjm3
80 jug/m
DO wg/ m
N
50 ug/m3
P;M- BOUNTY
SANTAORUZ v^.
z
D
o
t,,»
?
<^
x
<
Qi
10
Z
:D
O
!u
i4J
LO
E
u
O
Igure 2-3 Predicted Particulate Concentrations in Tucson Area
Pnor to Fugitive Dust Control ,
2-11
-------
O
o
c
I
6
L.
LU
\ ~-
i;
6
N
0 10 miles
^4~
SCALE
P'MA COUNTY
COUNTY
Figure 2-4 Predicted Particulate Concentrations in Tucson Area with
Control Strategy B .
2-12
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MARJCPfA CQUN J YJ
"PIN AI COUNTY"
N
0 • 10 miles
SCALE
Figure 2-5 Predicted ParHculafe Concentrafions in Phoenix Area
Prior to Fugitive Dust Control»
2-13
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MARiCOPA COUNTY
0 10 miles
. ats
SCALE
Figure 2-6 Predicted Particulafe Concentrations in Phoenix Area with
Control Strategy B.
2-14
-------
applied in a follow-up run of the model for Phoenix in addition
to tne other controls for strategy B. This value was obtained
as the combined effect of chemical stabilization of newly
planted cropland (a costly technique not yet proven in full-
scale field testing) plus continuous cropping and/or limited
irrigation of fallow land to reduce emissions in seasons other
than the prime farming season. This control strategy predicted
a maximum concentration of 72 ug/m geometric mean, (see
Figure 2-7). Control strategy tests were not undertaken for
the other three counties of the region, since their existing
particulate measurements are lower than in Maricopa and Pima
Counties. Region-wide adoption of strategy B controls should
also achieve standards in these three counties.
In the remainder of the regions, control strategy
evaluations were by the proportional reduction method, Roll-
back calculations in the San Joaquin AQCR were made for each
of the six counties in which there was an air quality
sampling site reading above the primary standard. Emission
reduction calculations for control strategy B are shown in
Table 2-5. These are compared with the percent reductions
necessary to achieve primary and secondary standards in the
same table. The secondary standard is reached in only one
of the six counties, and the primary standard is still exceeded
in Kern and Tulare Counties. Corresponding calculations for
strategy A gave unacceptable reductions in all but San
Joaquin County; C and B were indistinguishable strategies
for this AQCR. A review of the emission contributions and
the reductions obtained by source category in Table 2-5
indicated that, as in Maricopa County in the Phoenix-Tucson AQCR,
agricultural emissions were primarily responsible for
the predicted high particulate concentrations after control
of fugitive dust. Application of the 65 percent control from
use of chemical stabilizers, etc., brought down the maximum
predicted concentrations in Tulare County to 75 i-g/m and
in Kern County to 77 yg/m . Therefore, achievement of the
2-15
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/
SUN GTYjl
MARK: OP A COUNTY
N
F:Igure 2-7 Predicted Particulafe Concentrations in Phoenix Area with Control
Strateay B plus 65% Control of Agricultural Emissions.
2-16
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TABLE 2-5
CONTROL STRATEGY CALCULATIONS FOR SAN JOAQUIM
County
Pollutant Reductions
Max. ann . geom. mean, yg/m"
Background,
Kern Tulare Fresno Kings
Stan is 1 aur>
% Reduction necessary to
achieve primary standard
% Reduction necessary to
achieve secondary standard
Emi s s i on Redu ct i on s
Emissions - Existing
Unpaved Roads
Agriculture
Aggregate Storage
Feedlots
Construction
Point Sources
Area Suurces
Emissions - Controlled
unpaved Roads
Agriculture
Aggregate Storage
Feedlots
Construction
Point Sources
Area Sources
Optional Strategy Emissions
% Reduction Obtained
Estimated Max. Air
Duality Levels in 1975
* Strategy B+, includes 65% control of agriculture
169
25
65%
75%
3300
288290
900
1320
4870
17849
767
317296
1650
224000
90
260
1720
8942
730
237392
114553*
25%
64%
133
77*
167
25
65%
75%
3530
185000
-
240
-
7556
621
196947
1480
143000
-
50
-
4380
621
149531
68001*
24%
* 65%
131
75*
97
25
31%
51%
70040
117300
1620
410
16200
17995
1752
225317
29400
90500
160
80
5680
10512
1460
137792
39%
*
69
98
25
31
51
36900
133000
-
360
-
5439
913
176612
15500
96000
-
70
-
5000
219
116789
34
73
28<
49%
540
23600
230
560
2100
3285
730
33045
230
18300
20
110
730
767
_JL!!L
20887
33%
7!
an Joaquin
77
4%
33 S
8840
211000
860
83'U;
814u
1168
3720
22500
90
_
30992
48
-------
primary standards can be demonstrated throughout the region,
however this would require the use of untested teehnicmes for
fugitive dust control. Achievement of the secondary standards
appear to be most unlikely regardless of the application of
identified control techniques.
For the second AQCR in New Mexico (El Paso-Las Cruces-
Alamogordo), most of the air quality measurements were already
well below the secondary standard. The one high reading
of 145 yg/m in Dona Ana County was in a predominantly agri-
cultural area in the Rio Grande River valley. A county-wide
reduction in emissions according to strategy B resulted in a
37 percent reduction in emissions, as shown in Table 2-6. The
percent reductions in ambient levels needed to reach the
primary and secondary standards were calculated to be 58 and
71 percent, respectively. Therefore, these calculations also
confirmed that the only areas in which fugitive dust emissions
cannot be controlled to the extent necessary to at least achieve
the primary standards are those with highly concentrated farmlands.
Rollback calcuj.at.ions in the two AQCR's in Nevada were
performed on emissions occurring within a three mile radius
of sampling stations exceeding the secondary standard. This
smaller area was specified instead of counties because the
air quality readings at the stations with the exception of
the Reno-Sparks station, were considered to be more representative
of air quality in the immediate vicinity than county-wide
air quality. Four of the seven sites in the state exceeding
tne standard (see Table 2-1) are greatly influenced by nearby
large particulate point sources , and all seven are located in
commercial or residential areas of a town.
Detailed on-site surveys of these seven sites were made
to inventory all significant particulate emission sources
within the three mile radius. In order that the air quality
data would correspond with the time period of these emission
2-18
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Table 2-6
CONTROL STRATEGY CALCULATIONS FOR
EL PASO-LAS CRUCES-ALAMOGORDO AQCR
DONA ANA COUNTY
Poll u t a n t_ R e d u c t i o n s _
Max. ann. geom. mean, ug/m 145
Background, yg/m 25
% Reduction necessary to achieve
primary 58%
i Reduction necessary to achieve
secondary 71%
Enaission Reductions
Emissions - Existing
Unpaved Roads 23,700
Agriculture 48,000
Aggregrate Storage 430
Tailings/Feedlots
Construction 2,350
Point Source 115
Area Source 567
75,162
Emissions - Controlled
Unpaved Roads 10,000
Agriculture 37,200
Aggregrate Storage 43
Tailings/Feedlots
Construction 822
Point Sources 76
Area Sources 567
48,708
Optional Strategy 28,308*
% Reduction Obtained 35%
62%*
Estimated Max. Air 103
Quality Level in 1975 71*
* Strategy B+, includes 65% control of agriculture
2-19
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surveys, 1972 air quality data were used in the rollback
calculation?. The 1972 annual geometric means for the stations
i.re generally lower tna.n 1970 levels because of emission re-
ductions already achieved on some sources impacting on the
sites. Rollback calculations for the three areas in the Nevada
Intrastate AQCR and four areas in the Northwest Nevada AQCR are
shown in Tables 2-7 and 2-8, respectively.
In the Nevada Intrastate AQCR, control of non-fugitive
sources above is shown to achieve necessary emission reductions
to reach the primary standard throughout the region. Control of
conventional sources is shown to achieve the secondary standard
in the vicinity of Gabbs, while control of conventional sources
plus fugitive dust from tailings will provide air quality levels
consistent with the secondary standard at McGill. However, attain-
ment of the secondary standard at Fallen cannot be demonstrated
by the rollback calculations, largely due to a lack of large
sources within the three mile radius of the station.
In Northwest Nevada, a combination of conventional source
control measures and fugitive dust control results in attainment
of the primary standard throughout the region and the
secondary standard at all but the Fernley location. Paving
of streets in Fernley would be required to meet the secondary
standard there. Paving of roads carrying 15 percent of the
vehicle miles would also be necessary in Washoe County as part
of the control strategy.
In summary, stringent fugitive dust control strategies are
required in all six regions. Even these strategies do not
attain the primary standard in certain intense agricultural
areas in three of the AQCR's, although it is able to reach
the primary or secondary standards in other parts of these
regions. In the other three AQCR's, the evaluations indicate
that the secondary standard will probably be achieved through-
out the regions.
2-20
-------
I
K)
TABLE 2-7
CONTROL STRATEGY CALCULATIONS
County
Sampling Station
Pollutant Reductions _,
Annual geometric .-.me an, ug/ni
Background, \ig/m
% Reduction necessary to achieve primary
standard
% Reduction necessary to achieve secondary
standard
Emission Reductions
Emissions - Existing*
Unpaved Streets
Agriculture
Tailings
Point Sources
Emissions - Controlled*
Unpaved Streets
Agriculture
Tailings
Point Sources
% Reduction Obtained
FOR NEVADA INTRASTATE AQCR
White Pine
McGill
108
25
40%
57%
170
4360
4810
9340
;ivo
508
3166
3844
58%
Nye
Gabbs
97
25
31%
51%
38
(included w/
pt -.- sources) ,'
30801
30839
38
(included w/
pt. sources)
1232
1260
96%
Churchill
Fallon
82
25
12%
39%
7
16
39
62
7
16
25
48
23%
Estimated max. air quality level in 1975
ug/m
<60
<60
69
* Emissions within a 3-mile radius of the sampling station
-------
KJ
CONTROL STRATEGY CALCULATIONS FOR NORTHWEST NEVADA AQCR
County Lyon Lyon Was hoe Douglas
Sampling Station Fernley Yerington Reno-Sparks Statsline
Pjjjllutajit: Reductions .,
Annual geome t ri c _me an , pg/in , 75 71 99 71
Background, ug/m . 25 25 25 25
% Reduction necessary to achieve primary standard 0 0 32% 0
% Reduction necessary to achieve secondary standard 30% 24% 53% 24%
Emission Reductions
Emissions - Existing *
Unpaved Roads 45 20 77,700
Aggregate storage 12 - 143
Tailings " - 312
Construction - - - 50
Point Sources 727 379 3,156
Area Sources ............................... - ........... ^ _ - 1 , 268 ___IL_
784 711 82,267 50
Emissions - Controlled*
Unpaved Roads 45 20 38,850
Aggregate Storage 12-14 -
Tailings (already controlled) - 312 -
Construction - - - 0
Point Sources 536 200 553
Area Sources - - Ir268 -
593 532 40,685 0
% Reduction Obtained 25% 25% . 51% 100%
Estimated max. air quality level in 1975, pg/m 63' <60 '61 <60
* Emissions within a 3-mile radius of the sampling station, except county-wide emissions
for Washoe County.
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The cost of implementing the strategies has not been
estimated in this report. However, the cost data presented
in the Phase I/II document reveals that paving will be the
most costly control excluding, of course, the application of
chemical stabilization to vast agricultural areas. In regions
where the secondary standard will be achieved, a scheduled
paving program which reduces ambient levels to the primary
standard by 1975 and to the secondary by 1977 or thereafter
may be more feasible economically.
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3.0 PROPOSED REGULATORY APPROACHES
Representative regulations covering control techniques
found to be necessary have been drafted and are presented
below. These will require in-depth review-by involved legal
staff and insertion of appropriate terms to make them specific
to individual jurisdictions. Also, conditional exclusions
may be necessary/ particularly for watering regulations. For
example, watering could be omitted when temperatures are below
50°F or when a rainfall of more than 0,1 inch has been recordec
(peither of these numbers is backed by data). However,
exclusion clauses have not been included in the example
regulations for fear of creating opportunities for circumventit
3.1 Regulation for the Control of Particulate Matter;
Unpaved Roads . ."
0 The political subdivisions responsible for the constructic
and maintenance of unpaved roads within the _=j_u
_____ sha^ll be required to pave all unpaved roac
with an average daily traffic (ADT) volume of more than
150 vehicles with a quality of paving equal to or better
than a 3" bituminous surface or be otherwise treated by a
method approved by _^ _„___ to provide at least
equivalent protection to that of -a 3" bituminous surface,
against the emissions of particulate matter into the
atmosphere resulting from vehicle travel on the road. Sue
equivalent protection may include the rerouting of traffic
and or closing of unpaved roads.
0 The political subdivisions responsible for the constructic
and maintenance of unpaved roads within the
shall establish and enforce:
(i) A maximum speed limit of 20 miles per hour within the
City of .
(ii) A maximum speed limit of 25 miles per hour in all
other areas of the region.
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0 No person shall construct any new public road, alley or
narking lot within the without
causing the surface over which the vehicles will travel to
bo paved with a 3" bituminous surface and cause the shoulders
of such roads to be constructed or treated in a manner which
will prevent particulate matter from becoming airborne.
0 No person within the shall
construct any new private parking lot which may be used for
more than 15 vehicle movements per day without causing the
surface over which the vehicles will travel to be paved
with a 3" bituminous surface.
3,2 Regulation for Control of Particulate Matter: Agriculture
0 Any person who owns or is in charge of any actively tilled
agricultural land within the shall
manage and use such land in a manner so as to prevent
particulate matter from becoming airborne, to the maximum
extent practical.
0 Any person who owns or is in charge of any actively tilled
land of more than 500 acres within the
shall submit to
for approval a detailed soil management plan for compliance
with the requirements of (d)(1). If the
disapproves, the reasons for such will be furnished to the
owner or operator submitting the plan. Approvals may be for
such period as the may specify. Such soil
management plans may be revised upon application to the
for revision.
A detailed soil management plan may include, but is not
limited to, one or more of the following measures;
(i) Maintaining a crop cover at all times
(ii) Planting of vegetative ground covers
(iii) Maintaining a ground cover of crop residue
(iv) Periodic irrigation
(v) Application of chemical soil stabilizers
(vi) Strip cropping
(vii) Inter-row plantings
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'viii) Use of windbreaks
(ix) Mulching
(x) Planting of crops that do not result in wind
erosion of soil.
3.3 Regulation for the Control of Particulate Matter:
Material Storage
D No person within the ^ shall cause or
permit any material to be handled, transported or stored
unless the particulate matter emissions are controlled by
such measures as enclosures, covers, spraying with an
approved dust suppressant or other methods approved by
3.4 Regulation for the Control of ParticulateMatter:
Tailings Ponds
0 No person with the shall cause
or permit the storage or disposal of materials from the
mining, quarrying or processing of ores or minerals unless
the particulate matter emissions are controlled by such
measures as chemical stabilization, vegetative growth,
cover with a non-erodible material such as smelter slag or
other equivalent methods as approved by .
3 • 5 Regulation for the Control of Particulate Matter: Feed^lots
0 No person within the shall cause or
permit the operation of an animal feedlot of greater than
one acre without controlling emissions of particulate
matter by daily watering of the feedlot with an application
rate of at least .5 gallon per square yard or by other
methods approved by . Such applications
of water need not be made when rainfall provides an
equivalent application of water. Precautions shall be
taken to prevent water run off from creating a water
pollution problem.
3.6 Regulations for the Control ofParticulate Matter:
C onstruction
0 No person within the shall engage
in the clearing or Ieve1ing of land, earthmoving, excavation,
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demolition, or the movement of trucks or construction equip-
ment over cleared land or temporary access or haul roads
without watering all such access or haul roads at the
construction site for dust suppression at least twice daily
with a minimum watering rate for each application of ,5
gallons per square yard, or by other equivalent methods
approved by the . Such applications of water
need not be made when rainfall provides an equivalent
application of water.
The owner or operator of land areas which have been
cleared or excavated within the
shall take measures to prevent particulate matter from
becoming airborne. Such measures may include, but are
not limited to (1) planting vegetative cover, (2) providing
mulch cover, (3) treating such areas with a chemical soil
stabilizer or any equivalent method approved by
at the completion of the clearing, or excavating activity
or during temporary periods of inactivity to prevent exposed
soil from becoming airborne as particulate matter. These
areas shall be retreated or replanted as required.
3.7 Regula tory Con s i dera t i ons
The implications of imposing regulations whose eventual
impact on air quality levels is not substantially defined,
and, whose health and welfare ramifications could be extensive,
require evaluation of many factors.
In the case of fugitive dust, control of emissions from
agricultural operations by the application of chemical soil
stabilizers must certainly be carefully considered. Factors
which mitigate against a requirement for this control technology
include:
0 A herbicide must be co-applied with the chemical
stabilizer in order to retard weed growth which would
force the farmer to disturb the induced soil crust,
thus defeating the purpose of the application,
Preliminary research indicates that the herbicides
do not retard crop seedling growth but, possible
uptake in the plant as well as inhalation during
spraying operations may produce injurious human
health effects which will far outweigh those gained
by reducing airborne soil levels.
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0 The permanency of these spray-on adhesives on
receptor crop lands has not been established. It is
possible that for some soil classifications this
technique is either ineffective or will require
development of new chemical products.
0 Since most of the compounds suggested for this
application are either water soluble or form
agglomerates which can be washed-out by rain or
irrigation, their possible effect on water quality
must be determined.
0 The economic impact of this technology is substantial.
Best cost estimates for purchase and spray application
of currently available soil adhesives range from
$40 to $60 per acre. And, the process must be re-
peated each time a new crop is started. In the
San Joaquin Valley,, for example, use of this approach
would require approximately fifty (50) million dollars,
per each crop cycle.
Another possible approach"to "tTfe control of fugitive
dust from farming is to prohibit the use of a certain amount
of acreage by employing a system similar to the "Soil-Bank".
However, this concept would only lead to a substantial loss
in farm employment with the resultant decline in community
health levels which always accompanies a depressed economic
situation. Even more serious, in this case, would be the loss
in agricultural production from the,, San Joaquin area. Removing
approximately half of its productive effort would severely
jeopardize the food supply of the entire West Coast.
In consideration of the above factors, an appropriate
course may be to 'promulgate the proposed regulations,
recognizing that in some areas the Primary Standard may
not be achieved by 1975. However, during the intervening
period of the next two-three years a viable program must
be initiated to include:
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Education of farmers in good operational practices
aimed at reducing airborne particulates.
Increased emphasis on land use planning.
Determination of the health effects of particulate
emissions generated from agricultural operations.
Development of alternate control technologies for
the prevention of fugitive dust emissions.
While the improvement in air quality resulting from
these programs is difficult to quantify, their implementation
can only serve to improve the ambient levels of suspended
particulate while enhancing soil management practices.
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4.0 SUMMARY AI\D CONCLUSIONS
It was demonstrated in the Phase I/II Report that
Fugitive dust emissions are much greater than particulate
emissions from conventional point and area sources in each
of the six Air Quality Control Regions inventoried. Further,
the relative importance of specific fugitive dust source
categories varies considerably from one region to anotner.
While agricultural emissions overshadow all other sources
in two of the regions and are a large contributor in a third,
it must be noted that these regions contain some of the
most intensively farmed land in the U.S. In the other four
AQCR's, fugitive dust from unpaved roads and construction are
prominent sources of suspended particulates.
Most of the fugitive dust controls investigated are
applications of one of three basic techniques -- watering,
chemical stabilization, or reduction of surface wind speed
across exposed sources. For exposed roads, tracks, and
lots, control techniques include paving and traffic control
for unpaved roads. Feasible control methods and their
approximate efficiencies for each fugitive dust source
are summarized in Table 4-2 of the Phase I/II report.
The same general set of control methods must be employed
in each AQCR, even though the relative contributions from
specific source categories vary within each region. The
effective strategy contains provisions for:
4-1
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0 paving of highly traveled unpaved roads,
0 speed limits on remaining unpaved roads,
0 no construction of new unpaved roads,
0 maintenance of tilled agricultural land continuously
in either cash crops or cover crops,
0 frequent irrigation during brief fallow periods or
when crops are in the seedling stage,
° watering of construction sites ,
0 chemical stabilization of completed cuts and fills,
0 chemical, physical, or vegetative stabilization of
tailings piles ,
0 covering, enclosure, or spraying with a dust
suppressant chemical for aggregate storage piles, and
0 daily watering of cattle feedlots.
Implementation of these control measures would attain the
primary standard of 75 yg/m in all parts of the six AQCR's
except areas of intensive agricultural activity. These are
Dona Ana Counties in the El Paso-Las Cruces-Alamogordo region,
Maricopa County in the Phoenix-Tucson region, and Kern and
Tulare counties in the San Joaquin AQCR. The only additional
controls which might be employed in these areas are the spraying
of chemical soil stabilizers on newly planted fields or remov-
ing part of the land from active tilling.
In several other counties, the primary standard is achieved
by the strategy, but not the secondary standard of 60 yg/m .
Possibly, the time extension available for development of a
plan to attain the secondary standards can be utilized in the
El Paso, Phoenix-Tucson, and San Joaquin AQCR's. Regardless, most
of the southern half of the San Joaquin region will have
difficulty in reaching the secondary standards because of the
high density of farming activity and arid climate throughout
this area.
Much work is currently underway to better define the con-
ditions causing fugitive dust emissions and methods for their
4-2
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control. However, of all the fugitive dust sources, the
least attention from an air pollution control standpoint
is being given to agriculture. The present study indicates
that agriculture is the most difficult source to control
with existing technology. Specific investigations which
would advance understanding of agricultural emission
mechanisms and define control techniques are:
0 determination of the portion of wind erosion losses
that are measured as suspended particulate;
0 impact that an ambient air quality standard for the
respirable particle sizes would have on problems
in agricultural areas;
0 extensive field testing of chemical stabilization
of newly planted fields; and
0 study of educational methods and economic incentives
for extending soil conservation programs to include
particulate air pollution control as a major objective,
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TECHNICAL REPORT DATA
(Please read laslructiom on the rcrvrsc before completing)
1 REPORT
PORT NO
EPA-450/3-74-036b
4 TITLE ANDSUBTITLE
Investigation of Fugitive Dust: Volume II - Control
Strategy and Regulatory Approach
3 RECIPIENT'S ACCESSIOWNO,
5 REPORT DATE
June 1974
I
6 PERFORMING ORGANIZATION CODE
-•OP1
George Jutze, Kenneth Axetell
9 PERFORMING OB "ANIZATION NAME AND ADDRESS
PEDCO Environmental Specialists, Inc.
Suite 13, Atkinson Square
Cincinnati, Ohio 45246
8 PERFOHMING ORGANIZATION REPORT NC
10 PROGRAM ELEMENT NO
412953BDD1
11 CONTRACT/GRANT NO
12 SPONSORIMG AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
68-02-0044, Task No. 9.
13. TYPE OF REPORT AND PERIOD COVERED
Final
14, SPONSORING AGENCY CODE
15 SUPPLEMENTARY NOTES
16, ABSTRACT
A study of alternative control strategies for controlling fugitive dust
emissions in six (6) air quality control regions. The study was initiated
to determine if, by using available technology, fugitive dust emissions
be controlled in AQCR's where fugitive dust emissions prevent t
of the national ambient air quality standards for particulate. Fugitive
dust emissions from the following sources were studied: (!) unpaved roads,
(2) agriculture, (3) construction, (4) tailing piles, (5) aggregate storage,
(6) feedlots. The strategies were tested by IPP and/or proportional modeline
for each AQCR within the study area.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Fugitive dust
b. IDENTIFIERS/OPEN ENDED TERMS
COSATI I idd/Croup
13b
19 SECURITY CLASS 'T'i" Report!
unclassified
21 NO OF PAGES
41
Release unlimited
20 SECURITY CLASS (Tins page)
unclassified
22 PRICE
EPA Fo » 2220-1 (9-73)
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