905R77115
FUGITIVE DUST POLICY:
SIP's AND NEW SOURCE REVIEW
August 1 , 1977
Control Programs Development Division m
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Office of Air Quality Planning and Standards f
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Office of Air and Waste Management Ev
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Purpose
The purpose of this paper is .u identify and set forth the Agency's
position concerning fugitive dust relative to the control strategy and
new source review requirements of the State Implementation Plans (SIPs).
Policy Statement
Briefly, the policy recognizes the greater environmental impact due
to violations of the National Ambient Air Quality Standards (NAAQS) due to
fugitive dust in urban versus rural areas. Consequently, for control
strategy development, urban areas should receive the highest priority for
the development of a comprehensive and reasonable program to control fugi-
tive dust. Rural area control programs at this time should center on the
control of large existing man-made fugitive dust sources (i.e., tailing piles, f
mining operations, etc.) which in themselves are presently causing violations t
of the NAAQS or are sources of a known toxic or hazardous material (e.g.,
asbestos). For the purposes of implementing the fugitive dust policy, rural *"
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areas are primarily determined by the following criteria: (1) the lack of
major industrial development or absence of significant industrial particu-
late emissions and (2) low urbanized population.
In addition, new sources that wish to construct in rural fugitive dust L*$;
areas should be allowed to do so without the need of an emission offset, as PJBI
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long as they comply with the applicable emission regulation, and the impact MS*
of their emissions plus the emissions from other stationary sources in the »'t
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vicinity of the proposed location, along with normal background, is not i;;
projected to cause violations of the NAAQS. Sources wishing to locate in £&
urban non-attainment areas must obtain offsets and may do so by controlling £^y.
fugitive dust sources.
Summary
The particulate matter found in rural areas, without the impact of [
man-made sources, is typically native soil that for various reasons •
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becomes airborne. It is generally not exposed to potential contamination
by industrial pollutants which commonly occur in urban atmospheres.
In urban areas, the native soil is contaminated.to a measurable
degree by various components highly suspect in their health effects.
Urban fugitive dust characteristically contains a combination of industrial
pollutants from a variety of sources making it potentially more harmful.
Additionally, the problem is more pronounced within urbanized areas and
thus more conducive to the development of an implementable control program.
Therefore, the major emphasis for fugitive dust control should center
upon urban areas. Urbanized areas shall be required to adopt compre-
hensive but reasonable fugitive dust control plans.
Additionally, certain non-urban sources may have a significant air
quality impact or may contain known toxic materials (such as some mining
and large tailings operations) and should also be controlled through the
application of reasonably available control technology (RACT).
Since fugitive dust control programs will be relatively new
to many State and local agencies, time will be required for coordination
among various State and local agencies in order to develop and implement
an effective program. Demonstration projects and special studies may
be needed as part of the control strategy development process and adequate
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control plans reflecting the application of RACT should be submitted as ^
part of the SIP revisions now under development and provide for imple-
mentation of the program as expeditiously as practicable considering
that a demonstration project would or could be the first phase of the
implementation program which would require several years to fully and
completely implement.
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The emission offset policy states that if a new source wishes
to locate within an urbanized non-attainment area, the source must
insure that its emissions will be controlled to the greatest degree
possible, that more than equivalent offsetting emission reductions will
be obtained from existing sources, and that there will be progress
toward attainment of the NAAQS. Since fugitive dust is a significant
problem which must be controlled within the urban area, the source could
be permitted to minimize either the existing fugitive dust or stack particu-
late emissions in order to satisfy the offset requirements. It should be
pointed out that if a source wishes to offset /Its proposed particulate
stack emissions with fugitive dust emissions, it must provide a demonstra-
tion that this offset utilizing fugitive dust control represents an
equally effective offset as compared to an offset utilizing stack emission
control only. However, if a new source wishes to locate in a rural area
with violations of the NAAQS attributed to non-industrial sources, the
source will be allowed to construct without the need of offsets, as long
as it complies with the applicable emission regulations (NSPS, state
regulation, etc.) and the impact of Its emissions, plus the emissions
from other stationary sources 1n the vicinity of the proposed location,
along with normal background, is not projected to cause violations
of the NAAQS for particulate matter. If violations are predicted,
the source will be required to provide for further control and/or
offsets as necessary, as outlined in the current Emissions Offset
Policy (December 21, 1976).
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Prioritites for Control of Fugitive Dust
Briefly, efforts should begin to control fugitive dust from all
major sources in' urban areas, with little or no attention to natural
or non-industrial (i.e., unpaved roads, agricultural activities)
related fugitive dust sources in rural areas. Exclusion of rural areas
from control efforts at this time is based upon the belief that the
toxic fraction of fugitive dust in areas without the impact of man-made
pollutants is likely to be small. Fugitive dust sources in such areas
Include dust from deserts, arid lands, sparsely vegetated land, exposed
but vacant lots in rural communities, dust from sparsely traveled,
unpaved roads and unpaved residential driveways, and other such conditions
endemic to rural America. It is generally not exposed to potential
contamination by industrial fallout or subject to adsorption of gaseous
pollutants, which commonly occur in urban atmospheres. This analysis
is supported in a qualitative manner by an EPA statement to the U. S.
Senate Committee on Public Works:
"In rural areas relatively free from point emission sources,
such as in areas of the Southwest, the total suspended particulate
matter may be composed largely of non-toxic substances, such as
silicates; although certain organic material, such as fungi and
aeroallergens, may be present in specific areas. No epidemiological
studies have been conducted in sparsely populated areas where the
TSP concentration may be high due to 'fugitive dust.' In general,
the population is too small to provide a statistically significant
sample. Detailed information on the chemical composition of the »*,'•
TSP in these areas is not available; however, the toxic fraction is
likely to be small." F*1
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Fugitive dust in urban areas, on the other hand, is a relatively fc'y
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different phenomenon. While mineral matter is still the primary ingredient, &T--
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it can no longer be considered as native soil. In urban areas, it is con-
taminated to a measurable degree by various components whicn may adversely
affect health. Urban fugitive dust contains fallout from industrial and
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combustion related processes, lead from automotive exhaust, measurable
rubber tire particles, and other components associated with an advanced
technologically dependent community. " Further contamination may result
in urban areas from adsorption of harmful gases or adhesion of fine
particle matter on fugitive dust particles making fugitive dust particles
carriers of potentially more harmful and potent ingredients.
There are other reasons why efforts for fugitive dust control should
center in urban areas. From a resource point of view (i.e., control
agency manpower and control costs) and from a population at risk viewpoint,
control efforts concentrated in urban environments will be more effective
and beneficial. In urban centers, a larger base of support exists to
implement an expanded road-paving or other such fugitive dust control
program than would exist in a rural area because of the more uniform and
pronounced impact of the problem on the population in general. Within
the urban area, the feasibility and implementability of the control plan
is enhanced by the increased number of positive improvements in addition
to air quality which can be derived from a fugitive dust control program
(improved streets, less soil erosion, overall urban improvement and
enhancement). Therefore, urban areas should receive a higher priority
in the development and implementation of a comprehensive reasonable
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program to control fugitive dust.
Thus from either a scientific or priority basis, the need to control
fugitive dust should begin in urbanized areas where the impact and
feasibility of implementing a program are the greatest.
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Integration of Fugitive Dust Control Into the Particulate Hatter
Control Strategy and New Source Review Program
Urban Areas
"Urban" fugitive dust is a significant air pollution problem and
must be controlled. The criteria used to determine what constitutes an
urbanized area vs a "rural" area should be based upon a number of factors
(i.e., industrial emissions, population, or population density). For
the purposes of defining a "rural" fugitive dust area, the following
_criteria should be examined: (1) the lack of major industrial develop-
ment or absence of significant industrial particulate emissions and
(2) low urbanized population (i.e., eastern states <100,000-200,000 or
western states <25,000-50,000).
Once the "urban" area is defined, an analysis should be conducted
to identify all sources of particulate matter and to consider various
measures that might be used to reduce particulate emissions from both
conventional stationary sources and fugitive dust sources and determine >f
what impact such measures would have on ambient air quality. From this 'J"
evaluation, a comprehensive achievable control program should be developed.
Generally, the control of fugitive dust at construction activities
is reasonably available and should be required if needed to meet national
standards. Also, cleared land awaiting construction can be stabilized.
Additionally, the number of acres cleared at 6ne time should be minimized
to the greatest extent practicable. Similarly, it is generally reasonable
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in urban areas to control fugitive dust from demolition and similar
activities, commercial driveways and parking lots and truck parking
areas. In urban areas where there is enough rain or water available,
it may be reasonable to require owners of vacant lots to maintain some
type of vegetation cover to minimize the potential of soil loss by wind
erosion.
Additionally, fugitive dust measures such as street sweeping or
street cleaning, paving of existing unpaved roads, stabilizing road
shoulders and roadways, requiring that all new roads be paved and
constructing curbs along roadways, may be reasonable, depending upon local
conditions (technical, social, or economic). More specific discussions
of the control alternatives for fugitive dust, their effectiveness and cost
can be found in OAQPS Guideline Series 1.2-071, Guideline for Development
of Control Strategies in Areas with Fugitive Dust Problems.
A fugitive dust strategy should contain a series of air pollution
control regulations, which should be coordinated where possible with
existing on-line actions taken by various agencies in the performance
of related projects. The traditional regulatory enforcement approach
is certainly required for several of the source categories (i.e., construc-
tion, aggregate storage). This will be the only way to insure compliance.
However, in some cases this direct approach may pose some difficulties
and binding agreements on the part of certain departments (i.e., public
works, etc.) that they will participate in and be responsible for the
implementation of a certain portion of the strategy should be pursued.
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This approach provides for integration (where possible) of the '
control measures into the on-line operations of various governmental r
agencies. This approach generates greater acceptance in that these f
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measures are viewed not only as air pollution controls, but as overall »
planning and developmental improvements which will yield other tangible f
benefits in addition to air quality improvement. \
In some areas, demonstration projects may be planned as an integral ^
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part of the control strategy to generate support and coordinate efforts **
within various departments. Because fugitive dust control may be a new
program, a control demonstration project is particularly appropriate
to insure an achievable program in a timely manner. In many areas,
demonstration projects will not be necessary, however, and the program
to control fugitive dust can be immediately implemented. In other areas,
some control efforts have already begun, and more complete enforcement
of existing regulations, along with the implementation of some additional
control, will be effective.
It seems appropriate that wide latitude be given in the develop-
ment of a fugitive dust control program. Sufficient time should be
given to the States to develop a comprehensive program. Plans for the
eventual control of fugitive dust should be submitted as part of the
SIP revisions now under development. It is anticipated that the plans
submitted will include various interagency agreements or demonstration
programs to implement the strategy in various stages, if necessary.
This approach is based upon the fact that specific fugitive dust
control programs will be relatively new to many State and local agencies.
Time will be required for coordination among various State and local
agencies in order to develop and implement an effective program.
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For new source review in non-attainment urban areas, the program
which includes the emission offset concept remains unchanged. However,
since fugitive dust is recognized as a significant air pollution problem
in urban areas, it is appropriate to allow sources to minimize either
existing fugitive dust sources or particulate stack emissions in order
to satisfy their emission requirements. When proposing offsets, the
source must be required to consider the nature of the particulate matter
being offset and should provide a demonstration that the offset utlizing
fugitive dust control represents an equally effective offset when compared
to an offset utilizing stack emissions only. Such factors as exit
velocity, effective stack height, temperature and the particulate size
of the particulate matter should be specifically considered when a source
proposes to utilize fugitive dust control as an equivalent offset.
Rural Areas
While it is agreed that a comprehensive fugitive dust control
program may not be realistic within rural areas,* certain sources
which may have a significant impact upon air quality or which may
contain toxic materials, such as mining and large tailings operations,
can and should be controlled. Several areas have very effectively
controlled large isolated sources of fugitive dust. When the source is
determined to have a specific health or air quality impact, control
agencies have traditionally required the application of reasonable
precaution measures to minimize the source's impact upon health and
welfare. In rural areas, this is still an effective means of control
and should continue to be utilized.
See page 6 for criteria to identify rural areas.
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There has been considerable concern about the location of major new ;
stationary sources in rural areas where fugitive dust has been determined !
to be the major source. This awareness of a problem has been brought
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about in many cases by the results of special ambient air quality monitoring
studies being conducted in remote areas (where previously little or no long-
term sampling had been done) prior to the source applying for a new source
review permit. In many cases, these short-term sampling programs are
established to determine the background concentrations for the geographic
area under consideration for plant location. Quite often the long-term
averages for these particular sampling locations, if conducted over
more than a few months, are quite low, however, on rare occasions, i.e.,
2 or 3 times during the-sampling program, unusually high 24-hour concen-
trations in many cases violate the 24-hour NAAQS and provide some concern
when considering the location of a new source within this isolated rural
area essentially free from the impact of stationary sources. These
values should be closely reviewed prior to use. These short-term data
should be statistically analyzed via some statistical test (e.g., Dixon
Ratio Test) to evaluate the peak-to-mean ratio. Quite often the peak-
to-mean ratio is unusually high and the maximum 24-hour concentration
is highly suspect when compared to the measured norm. This analysis *
would suggest which short-term maximum concentrations may not be
representative in determining the concentration which best describes
the average air quality for the area in question. If through such a
statistical analysis the violations of the 24-hour concentration are *^*
"flagged"," it is recommended that these concentrations be investigated
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and where further analysis supports the non-representativeness of the
data it should be omitted for evaluating the impact of the new
stationary source.
Similarly, for control strategy development, when the impact of
natural sources can be determined, the Part 51 SIP regulations allow
such data to be discarded and not used in control strategy development.
Section 51 J2d states:
"For purposes of developing a control strategy, data derived
from measurements of existing ambient levels of a pollutant may
be adjusted to reflect the extent to which occasional natural or
accidental phenomena, e.g., dust storms, forest fires, industrial
accidents, demonstrably affected such ambient levels during the
measurement period."
New sources that wish to construct in rural areas with infrequent
short-term violations of the TSP standard should be allowed to construct
without the need of an emission offset, as long as they comply with the
appropriate emission regulation (NSPS, state regulation or BACT for PSD
source) and when considering their emissions, plus "non-urban" back-
ground and the emissions from other stationary sources in the vicinity
of the proposed location, they do not cause violations of the NAAQS
or appropriate PSD increments if applicable. Specific procedures to
conduct an air quality modeling analysis for new particulate matter
sources can be found in current EPA modeling guidance now under
development.
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Environment?!
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REFERENCES
1 . A Study of the Nature and Origir. of Airborne Particulate Matter
In Philadelphia, Scott Environmental Technology, Inc., January 1975.
2. Draftz, R. G., Types and Sources of Suspended Particles in Chicago,
ITTRI, May 1975.
3. National Assessment of the Urban Particulate Problem. Volume I:
Summary of National Assessment, U. S. Environmental Protection
Agency, Research Triangel Park, North Carolina. Publication
Number EPA-450/3-76-024, July 1976.
4. Water Pollution Aspects of Street Surface Contaminants, Sartor, 0. D.,
and Boyd, G.B., Contract No. 14-12-921, November 1972. EPA-R2-72-081 .
•5. Contributions of Urban Roadway Usage to Hater Pollution, Shaheen, D.G.,
Contract No. 68-01-0197, Task Order 005, April 1975.
6. Dixon, W. J., "Processing Data for Outliers," Biomedics, 9:75, 1953.
7. Guideline for Air Quality Models, Second Draft, OAQPS. May 1977.
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