\    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASH.NGTON.DC. 20460              9Q5R771 16




                            1 ft  flllT 1Q77                    OFFICE OF
                            J. O  MUU I3/ /             AIR AND WASTE MANAGEMENT
                                                                                      .
                                                                                     *
SUBJECT:  Guidance on SIP Development and New Source
         Jfeyiew in Areas Imaa&ted by_Fugitive Dust
FROM:     Edwaf^F./flC^k^tawi^ssistant Administrator
            foj^i(^^wa^TexManagement

MEMO TO:  Regional Administrators

     Many of the July 1, 1976, calls for particulate matter SIP revisions
identified fugitive dust as a significant contributor to the particulate
matter problem within the urbanized areas throughout the nation.  Addition-
ally, recent studies have indicated that fugitive dust control  should be
considered as part of the overall control program for particulate matter            , (
if many urban areas are to attain and maintain the NAAQS.                           \j?

     The attached policy paper has undergone considerable review from
both within and outside the Agency.  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 fugitive 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, mining operations,  etc.) which
in themselves are presently causing violations of the NAAQS or are sources
of a known toxic or nazardous material (e.g., asbestos).  For the purposes          1
of implementing the fugitive dust policy, rural areas are primarily                 P
determined by the following criteria:  (1) the lack of major industrial             •'.^
development or absence of significant industrial particulate emissions,             |
and  (2) low urbanized population.                                                   i»

     In addition, new sources that wish to construct in rural fugitive
dust area's-should be allowed to do so without the need of an emission
offset, as long as they comply with the applicable emission regulation,
and  the impact of their emissions plus the emissions from other stationary
sources in the vicinity of the proposed location, along with normal back-
ground, is not projected to cause violations of the NAAQS.  Sources wishing
to locate in urban non-attainraent areas must obtain offsets and may do so
by controlling fugitive dust sources.
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     The control of fugitive dust sources reflecting the application of            f
reasonable available controls should be included with the SIP revisions            j
now under development.  It should be noted that since fugitive dust                k
control programs will be relatively new to many State and local agencies,
time will be required for coordination among various groups in order to
implement an effective program in urban areas.  Demonstration projects
and special implementation studies may be needed, and efforts to support
such programs are encouraged.

Enclosure

cc:  Director, Air and Hazardous Materials Division, Region I, III-X
     Director, Environmental Programs Division, Region II
   "  Assistant Adminstrator for Enforcement
•   .  Office of General Counsel
     Assistant Administrator for Planning and Management

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