M RIBS RE PORT
Survey of Construction/Demolition
Open Source Regulations
and Dust Control Plans
For U.S. Environmental Protection Agency
Industrial Studies Branch, ESD (MD-13)
EPA Contract 68-02-4395
Assignment No. 48
MRI Project No. 8987-K(48)
September 25,1990
MIDWEST RESEARCH INSTITUTE 425 Volker Boulevard, Kansas City, MO 64110-2299 • (816)753-7600
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MRI. REPORT
.
Survey of Construction/Demolition
Open Source Regulations
and Dust Control Plans
For U.S. Environmental Protection Agency
Industrial Studies Branch, ESD (MD-13)
Research Triangle Park, North Carolina 27711
Attn: Wm. Larry Elmore, P.E.
EPA Contract 68-02-4395
Assignment No. 48
MRI Project No. 8987-K(48)
September 25, 1990
-81
MIDWEST RESEARCH INSTITUTE 425 Volker Boulevard, Kansas City, MO 64110-2299 . (816) 753-7600
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PREFACE
This report was prepared for the U.S. Environmental Protection Agency,
under Work Assignment 48 of EPA Contract No. 68-02-4395. Mr. Wm. Larry
Elmore, P.E., of the EPAts Industrial Studies Branch served as technical
representative. The report was prepared by Dr. Gregory E. Muleski and
Ms. Deann K. Hecht who are members of the Air Qual ity Assessment Section in
the Institute's Engineering and Environmental Technology Department.
Approved for:
MIDWEST RESEARCH INSTITUTE
~~
~~ Charles F. Holt, Ph.D.
o v . Director
Engineering and Environmental
Technology Department
2
September 25, 1990
ii
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PREFACE
Pref ace. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
F; gures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Tables[[[
1.
2.
Introduction..................................................
Information..............................
Review of Available
2.1 Survey of existing construction/demolition
dust regulations...................................
Dust emission sources at construction and
2.2
2.3
demolition sites...................................
Control of open dust source emissions at
construction and demolition sites..................
3.
4.
Example Regulation...........................................
Example Dust Control Plans...................................
4.1 Scenario
4.2 Scenario
4.3 Scenario
4.4 Scenario
5.
1........................................ .
2........................................ .
3........................................ .
4.......................... ~..............
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Number
1
2
3
4
5
6
7
8
Number
1
2
3
4
5
6
7
8
FIGURES
Hypothetical construction site
Hypothetical construction site
in Scenario 1.................
in Scenario 2.................
Hypothetical construction site
Hypothetical construction site
in Scenario 3.................
in Scenario 4.................
Mean annual number of days with at least 0.01 in of
precipitation................................................
Annual evaporation data for the contiguous United States.....
Watering control effectiveness for unpaved travel surfaces...
Average PM control efficiency for chemical suppressants......
TABLES
Details
about Scenario 1.....................................
Details
about Scenario 2.....................................
Details about Scenario
3.................................... .
Details about Scenario
4.................................... .
Summary of existing construction/demolition regulations......
Control options for construction/demolition open sources
of PMIO[[[
Estimated methods for average efficiency values for paved
road .controls...............................................
Example regulation...........................................
iv
Page
3
5
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SECTION 1
INTRODUCTION
Open dust sources at construction and demol ition (CD) sites contribute
significantly to ambient PM10 (particulate matter less than or equal to
10 microns in aerodynamic diameter) concentrations in many areas of the United
States. Besides emissions associated with on-site activities--such as
materials handling and vehicular traffic--substantial amounts of dust may
result from the reentrainment of mud and dirt tracked out from the site and
deposited onto nearby public paved roads.
While the potential importance of particulate emissions from CD sites has
long been recognized by U.S. Environmental Protection Agency (EPA) and other
air pollution control agencies, relatively little has been done to regulate
dust from these sites. Although emissions may be broadly classified as
"nuisance dust," relatively few pollution control agencies have specifically
addressed this source category.
This report presents an example regulation for the control of dust
emissions at CD sites. The example is partially the result of a review of
. certain existing and draft regulations. The EPA intends that the example
serve as a format that state and local control agencies could use in
developing their own regulations.
Because the example regulation requires preparation of a formal dust
control plan, example plans are also presented in this report. Each plan is
presented in sufficient detail to instruct readers in the preparation of their
own plans.
1
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The example dust control plans presented in Section 4 make use of the
following four construction/demolition "scenarios:"
Scenario 1. This example considers the erection of a 20-story building
.in a busy downtown area (see Figure 1). The site is fenced off and only
one access point is used by vehicles entering or leaving the site. The
access road is scheduled to be paved near the end of the construction.
Table 1 summarizes additional details of the construction project.
(Note that throughout thi s report common Engl ish uni ts--such as mi 1 es,
feet, and tons--are used. This approach has been taken because persons
preparing dust control plans for CD sites will probably be more familiar
with this system of units than with the metric system.)
Scenario 2. In this example, suburban housing is being developed in two
phases (see Figure 2) on a 20-acre site. No material will be transported
off-site nor will any other "foreign" fill material be brought in during
a 40-working day site preparation period. Present plans call for
preparing the entire 20 acres. After site preparation, 20 homes will be
built over a 7-month period (150 working days) in the area west of
Suburban Drive; the remaining half of the prepared site will be left
alone. Another 20 homes will be constructed during a second period which
is scheduled to begin one year from now. Table 2 summarizes other
details of the project.
Scenario 3. The multiyear construction of a limited access roadway in an
urban area is the subject of this example (see Figure 3). Traffic enters
and leaves the site by the ramp shown in the figure. Table 3 presents
details of the construction project for the time period of interest for
this example. Note that, because of the long duration and 'changing
nature of roadway construction, a month-long period is considered in this
example rather than the entire project.
2
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100 ft Fence
\
"0 ......
s:::: "0
~
o s::::
~
.0 0
.s:::
+> .0
~ .s:::
o +>
s..
V) 0
>, z:
IU >,
3
I IU
<11 3
s:::: I
a Q)
s::::
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+> Q)
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w V) +>
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ANGELUS
AVENUE
Figure 1.
Hypothetical construction site in Scenario 1.
N
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TABLE 1.
DETAILS ABOUT SCENARIO 1
Total area disturbed:
1.2 acres
Duration of the excavation phase:
20 workdays, 30 calendar days
Volume of material excavated and hauled:
5,000 ton/workday
Haul truck net capacity:
15 ton
Average haul travel distance on site (round trip):
150 ft
Average haul truck speed on site:
15 mph
Number of wheels on haul truck:
10
Tare weight of haul truck:
20 ton
Duration of construction phase: 8 months, 160 workdays, 240 days
Total vehicles entering site:
40/workdaya
Traffic rate on 4th Street:
5,000 ADT (average daily traffic)
a After the excavation phase; includes cement mixers,
structural steel and other deliveries.
4
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250 ft
c.n
SUMMIT
DRIVE
N
Figure 2. Hypothetical construction site in ~cenar10 2.
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TABLE 2.
DETAILS ABOUT SCENARIO 2
Duration of site preparation:
40 workdays, 60 calendar daysa
Total area disturbed:
20 acres
Number of scrapers in use:
2
Hours each scraper used per workday:
8
Average travel speed of scraper:
Number of dozers in use: 3
5 mph
Hours each dozer used per workday:
8
Duration of construction (first 20 homes):
150 workdays, 7 months
Total area disturbed:
10 acres
Total vehicles entering site:
Traffic rate on Summit Drive:
40
6,000 ADT
a Time required to prepare entire 20-acre site.
6
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....,
At Existing Grade
;'
>,
ra
~
I
If-
o
I
....
.r:
tn
~
!
.--- Excavation Activities
Figure 3.
Being Brought to Desired Grade
DEACON
NOT TO SCALE
t~
!i "-
o
CI
c.
E
ra
~
'"
'~
Site Preparation
Hypothetical construction site in Scenario 3.
DRIVE
Existing Roadway
Paving Activities
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TABLE 3.
DETAILS ABOUT SCENARIO 3
Total area disturbed in base month:
15 acres
Workdays in base month: 21
Number of scrapers in use: 4
Hours each scraper used per workday:
9
Average travel speed of scraper:
5 mph
Number of dozers in use: 2
Hours each dozer used per workday:
9
Volume of material excavated and hauled off-site:
5,000 ton/workday
Haul truck net capacity: 20 ton
Average haul travel distance on-site (round trip):
1,700 feet
Average haul truck speed on-site:
15 mph
Number of wheels on haul truck:
18
Tare weight of haul truck: 20 ton
Daily traffic rate on Deacon Drive:
7,500 ADT
8
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Scenario 4. This example is concerned 'with the demolition of a lO-story
building at the site shown in Figure 4. Note that only emissions occur-
ring after dismemberment of the structure are of concern in this example.
Access to the site will entail use of an unpaved travel surface. Addi-
tional details are presented in Table 4.
9
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BAL TIMORE
BOULEVARD
(Two-Way Traffic)
-
"'0
C "'0
~ C
o ~
.0 0
.c .0
~ Fenced Demo 1 iti on Site .c
~ +J
0 \ s...
V') 0
z
>,
10 >,
3 10
I 3
Q) I N
C Q)
...... 0 C
o 0
"-"
100 ft ~ +J
Q) Q)
Q) Q)
s... s...
~ +J
V') V')
"'0 .c
s... ~
(V) <:;t
Figure 4.
Hypothetical demolition site in Scenario 4.
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TABLE 4. DETAILS ABOUT SCENARIO 4
Floorspace to be demolished:
50,000 sq ft
Duration:
1 week, 5 workdays
Haul truck capacity: 20 tons
Average haul travel distance on site (round trip):
250 ft
Average haul truck speed on site:
15 mph
Number of wheels on haul truck: 10
Tare weight of haul truck: 20 ton
11
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SECTION 2
REVIEW OF AVAILABLE INFORMATION
Th is sect ion prov i des an
processes as related to the
regulations used by various
emissions.
overview of construction and demol ition (CD)
generation of dust emissions and describes
state and local agencies to control those
2.1 SURVEY OF EXISTING CONSTRUCTION/DEMOLITION DUST REGULATIONS
Virtually all construction and demolition emission sources could be
considered as being regulated under existing nuisance or fugitive dust rules
which are common throughout the country. In this way, agencies could require
emission reductions from construction sites visited as a result of citizen
complaints. However, given the potential magnitude of CD emissions, it is
probable that agencies would find routine and systematic reductions in this
source category to be effective in achieving certain air quality goals.
Nevertheless, without regulations that directly address CD activities and
provide an oversight role for the local agency, systematic control of
emissions is unlikely.
Table 5 summarizes the major points of four recent regulations directed
to construction activities (note that the San Joaquin rule is not yet
final). In three, some type of plan to control dust becomes either a condi-
tion of an air regulatory permit (such as a permit to disturb topsoil) or an
attachment to a separate building permit issued by another government body.
12
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TABLE 5. SUMMARY OF EXISTING CONSTRUCTION/DEMOLITION REGULATIONS
Regulation II, Rule 200 and Regulation III, Rule 310--Maricopa County Department of Health Services,
Division of Public Health, Bureau of Air Pollution Control
(both regulations revised 7/13/88)
General Description:
Exceptions:
Other Points:
......
c..u
Rule 210 states that earthmoving for commercial purposes requires a permit from the
Control Officer. Rule 310 prohibits no construction and demolition IIwithout taking
reasonable precautions to effectively prevent fugitive dust from. becoming
airborne. II
None are explicitly stated. Noncommercial (such as homeowner or public agency)
activities do not require a permit. although reasonable precaution requirement in
Rule 310 would still apply.
Rule 310 defines reasonable precautions as including the IIdaily removal of earth or
other material that has been tracked or transported onto paved streets by trucking
or earthmoving equipment. II Note that this could be construed as not requiring
cleaning at employee parking lots. contractor villages. or other access points not
used by trucks. The lIeffectiveness of ... reasonable precautions" monitored by a
visible" opacity technique.
Section 17--District Board of Health of Clark County (Las Vegas, Nevada)
(revised 4/23/87)
General description:
Exceptions:
Permit system to disturb topsoil. including construction activities. addition or
removal of dirt or fill. (Note: clearing and grubbing included in same
provision.) Permit required for the IIdestruction. demolition or removalll of any
structure at least 1.000 sq ft in area.
Size limitation of 0.1 hectare (one-quarter acre). Requirements also not intended
to apply to agricultural operations or landscaping by a person at his/her
residence.
(continued)
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TABLE 5.
(continued)
Other points:
While a term such as "dust control plan" is not specifically used, Section 17.5.1.2
requires that applicant present and agree to implement "an acceptable method to
prevent particulate matter from becoming airborne." Written description of
operating practices not usually required. Air pollution control officer (APCO) may
require posting of a surety bond in an amount between $500 and $20,000. Applicant
is responsible for ensuring contractors and/or subcontractors abide by conditions
of permit. Application specifically mentions mud/dirt trackout. No explicit
definitions of terms given in the regulation itself.
Section 040.030 of Amendments to Regulations of the Washoe County (Nevada) District Board of Health (adopted
November 22, 1989)
General Description:
In general, any person engaged in dismantling or demolition or buildings or public
or private construction "shall take all reasonable precautions to prevent the
generation of dust." A dust control plan must be submitted to and approved "before
topsoil is disturbed on any project where more than one (1) acre of surface area is
to be altered or where the natural surface area is removed." (In practice, Board
of Health usually takes lead in preparation of the plan, based on information
submitted in response to a questionnaire.) Jurisdictions issuing building permits
refer contractors to Board of Health offices.
.....
~
In addition, "any vehicle operating on a paved roadway with a load of dirt, sand,
or gravel susceptible to being dropped, spilled, leaked or otherwise escaping
therefrom, must be covered to prevent spillage." Covering not required if six (6)
inches of freeboard is maintained or if the material contains "enough moisture to
control dust emissions. II
Exceptions:
Commercial agricultural operations are specifically excepted from the permit
requirement. Minimum project size of one (1) acre. Also, the regulation does not
prohibit a public maintenance vehicle from depositing sand to enhance traction or
sprinkling water to clean and maintain the surface.
(continued)
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TABLE 5.
(continued)
Other points:
APCO may require (a) submission of soils data; (b) specific control measures
(including phased land clearing or palliatives); (c) that paved entry aprons or
other means be used to control trackout. Terms used are not explicitly defined in
Section 040.030.
Regulation VIII--Unified San Joaquin Valley Air Basin Authority
(draft dated May 3, 1990)
General Description:
.....
c.n
Exemptions:
For anyone of a variety of regulated activities, a written "PMI0 (dust) Prevention
and Control Plan" sha 11 be submitted to the APCO withi n 1 or 2 years (depending on
the size of operation) of the initial adoption of Regulation VIII. Plans are to be
formally reviewed every three years. In addition, three years of records of
control applications must be maintained, submitted upon request and be open for
inspection during unscheduled audits.
Requirements specific to construction and demolition (Rule 801) include: (a) pre-
vention or removal (at least daily) of any visible accumulation at trackout points;
(b) an overall, average PMI0 reduction of 25%, automatically increasing 25% every
three years to a maximum of 75%; (c) stabilization of any disturbed surface within
3 days of the "cessation of surface disturbance;" and, (d) upon completion or an
interruption of greater than 30 days, the disturbed surface is to be controlled lito
the conditions existing prior to surface disturbance." Note the use of
quantitative control efficiency goals.
Activities exempted from provisions of the regulation are: (a) disturbed areas
(other than roads) of less than one (1) acre; (b) construction or demolition
activity with a floor plan of less than 10,000 sq ft; (c) any construction or
demolition activity that meets the following:
i. occurs entirely within an enclosed structure with no visible emissions
ii. modifications to residential dwellings
iii. movement of less than 250 cubic yards of dirt
(continued)
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TABLE 5.
(continued)
Other Points:
In addition to Rule 801 for construction and demolition, draft regulation contains
five other rules directed at bulk material handling, landfilling operations, open
or staging areas, paved and unpaved roads.
Regulation defines 30 terms used.
~
en
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While all three are written as requiring the appl icant to prepare some
type of dust control plan, there may be substantial differences in practice.
For example, Clark County generally requires only that the general type of
control (e.g., water truck, sprinklers, or chemical sealants) be described in
the permit application. No formal written plan is usually required, although
applicants with, relatively large projects may be asked (on a case-by-case
basis) to submit additional information.
Washoe County takes a much more active role in preparation of control
plans. Appl icants complete a "generic" questionnaire from which a Health
Department employee develops the control plan. The Health Department outlines
any "special conditions" in the transmittal letter for the permit. These
special conditions usually deal with how many pieces of equipment are required
rather than frequency of application or other operating practices.
On the qther hand, the draft San Joaquin regulation IS approach to control
plans is quite different. First, the draft defines the PMIO prevention and
control plan to be a written document identifying measures or strategies to
"prevent, reduce, or control II emissions. Plans are to include schedules as
well as provisions to monitor the performance of the controls. Furthermore,
the setting of quantitative goals for control efficiency is tantamount to
requiring controlled and uncontrolled emission inventories. Finally, the
regulation gives recordkeeping requirements and establishes the interval for
formal review for the plan.
It is impossible to know how provisions in the draft regulation will be
implemented in practice. Nevertheless, it is important to discern the trends
in rulemaking and to incorporate desirable features of both existing and draft
rules. The example given in Section 3.0 (a) requires a written control plan;
(b) establishes a schedule for formal periodic review of the plan; and
(c) specific recordkeeping requirements on the part of the permittee as
evidence of control application.
The three agencies requiring some form of control plan in Table 5 exempt
certain operations on the basis of a minimum area of interest. Exceptions are
also made for enclosed CD activities, small floor plans, and certain homeowner
17
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activities, such as landscaping or remodeling. Example exemptions are
in the rule format presented in Section 3.0. Also, for greater clarity,
of definitions are included in the example regulation.
given
a set
It is believed that decisions such as
.
Drafting a regulation specific to CD as opposed to incorporating
rules in an overall fugitive dust regulation
.
Having the air regulatory agency issue a permit versus attaching a
control plan to a building permit
.
Requiring the appl icant to prepare the control plan rather than
using agency personnel
are best left to the discretion of the local agency.
regulation has been written in general terms to
flexibility.
The Section 3.0 example
provide agencies that
Features not found in Table 5 have been incorporated into the example
regulation. For example, the use of agency-suppl ied forms is required for
recordkeeping; it is believed that this would simplify agency inspection
procedures. In addition, at least one on-site inspection conducted by the
APCO or his/her designee is required to encourage a more structured inspection
process than may be common in certain jurisdictions.
2.2 DUST EMISSION SOURCES AT CONSTRUCTION AND DEMOLITION SITES
Prior to discussing generic dust emitting activities, it is necessary to
identify the following three "phases" in the construction/demolition process:
Phase I. Demol ition Debris Removal, during which the debris of any
existing man-made structures or natural obstructions is removed from the
site~ Thus, this phase includes the removal of debris from implosion or
mechanical dismemberment of a building as well as from blasting of rock
formations.
18
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Phase II. Site Preparation, during which
is brought to final or near-final grade.
site cut and fill operations as well as
off-site ~nd the receipt of "foreign" fill
the ground surface at the site
Thus, this phase includes on-
the transport of cut material
materials.
Phase I II . Construct i on, wh i ch i nc 1 udes the
activities, such as flatwork, structural and
tions, interior finishing, and landscaping.
other major construction
reinforcing steel opera-
Three points should be noted. First, the division of the construction process
into three phases is certainly arbitrary in that arguments can be made to
include other phases or to move certain operations from one phase to
another. For example, one could easily argue that rock blasting is better
characterized as "site preparation" rather than "demol ition." Here, the
intention is to define a series of sequential phases, involving "unit opera-
tions" with similar equipment and, hence, relatively similar emission estima-
tion procedures. Second, all three phases need not occur at a single
construction site. Finally, only emissions due to debris removal operations,
rather than the actual demolition process, will be considered in the following
sections.
2.2.1 Dust-Generating Activities During the Demolition Phase
As mentioned above, only the emissions associated with the removal of
debri s during the demol ition phase were considered as part of the scope of
this report. Note that a recommendation is made in Section 3.0 that a special
permit or a variance be issued for dust emissions during the actual
demolition.
Two sources of dust emissions are associated with debris removal:
(a) handling of the debris, with eventual placement into trucks, and
(b) transport of the material from the site.
19
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Phase I, Unit Operation A (debris loadingl: Both AP-421
EPA guidance manua12 present the following equation by which
debris loading could be estimated:
and the recent
emissions from
E = 0.0011 (U/5)A1.3 / (M/2)A1.4
(2-1)
where:
E = PM10 emission factor expressed as pounds of emissions per ton of
debris handled (lb/ton),
U = mean wind speed (mph) at 4-meter height, and
M = moisture content (%) of the debris being loaded.
The following default values are suggested for use when
information is unavailable:
site-specific
Default wind speed (U) = 10 mph
Default debris moisture content (M) = 0.5 %
These values have been chosen to yield conservatively high emission estimates,
in the absence of site-specific data. Finally, the mass of debris resulting
from building demolition may be estimated by assuming that 1 sq ft of floor
space results in 0.046 ton of debris.
Phase I, Unit Operation B (Transport of Debris): The following equations may
be used to estimate emissions due to truck transport of debris:1'2
E = 2.1 (s/12) (5/30) (W/3)AO.7 (W/4)AO.5 (365-p)/365
(2-2)
where:
E = PM10'emission factor expressed as pounds of emissions per vehicle
mile traveled (lb/vmt);
s = surface silt content (%); portion of road surface material less
than 200 mesh;
20
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S = mean vehicle speed (mph);
W = mean vehicle weight (ton);
w = mean number of wheels per vehicle; and
p = mean number of days with at least 0.01 inch of precipitation
(see Figure 5).
for travel on an unpaved surface, and
E = 0.77 (sL/0.35)AO.3
(2-3)
where:
E = PM10 emission factor expressed as pounds of emissions per
vehicle mile traveled (lb/vrnt); and
sL = surface silt loading (oz/sq yd); mass of material less than
200 mesh per unit area of road surface
for travel on a paved surface.
truck transport of debris:
The following default values are suggested for
Default unpaved surface silt content = 12%
Default haul truck speed = 20 mph
Default haul truck weight = 1.5 x truck capacity (ton), or, tare weight
(ton) plus one-half of capacity (ton)
Default number of wheels per haul truck = 10
Default number of days with precipitation = 0 for short term projects,
or, value taken from Figure 5
Default paved surface silt loading = 0.35 oz/sq yd
21
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N
N
'--'20
Q
2'0
~
Q,
~
~;o
D
...
""-
ALASKA
o 100 zoo JOO 400
~
HAWAII
o 50 100
-...
'---.1" .-
...
Figure 5. Mean annual number of days with at least 0.01 in of precipitation. Patterns
are too. complex in Hawaii for inclusion on map. (Means for Hilo, Honolulu, and
Lihue are 148, 204, and 90 days per year, respectively). 3
-------
As before, these values have been chosen to yield relatively conservative
emission estimates in the absence of site- specific data.
2.2.2 Dust-Generating Activities During Site Preparation
Dust emissions can occur during the following portions of the site
preparation phase: (a) bulldozing of earth; (b) pan scraper operations, such
as topsoil removal and general earthmoving; (c) truck haulage of 'cut or fill
materials, and (d) material handling of cut or fill materials. The following
sections discuss applicable emission estimation procedures.
Phase II, Unit Operation A (bulldozing):
recommended for bulldozing emission estimates: 1'2
The following equation is
E = 0.74 (s)A1.5 / (M)Al.4
(2-4)
where:
E = PM10 emission factor expressed as pounds per hour of dozer
operation (lb/hr);
s = surface silt content (%); and
M =surface moisture content (%);
In the absence of site-specific data, the following default values are
suggested to yield conservative emission estimates:
Default surface silt content = 12%
Default surface moisture content = 5%
Phase II, Unit Operation B (pan scrapers): The following emission factor
is recommended for scraping operations:2
E = 4.2 lb/mlle
(2-5)
23
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where:
E = PM10 emission factor expressed as pounds per scraper mile
traveled (lb/mile).
Phase II, Unit Operation C (Truck Haulage): Equations (2-2) and (2-3) may
be used to estimate emissions due to truck transport of cut and fill material
on paved and unpaved roads, respectively. The following default values are
suggested for truck transport involving travel off-site (Le., hauling cut
material away from the site or "importing" fill material).
Default silt content = 12%
Default .haul truck speed = 20 mph
Default haul truck weight = 30 tons
Default number of wheels per haul truck = 10
Default surface silt loading = 0.35 oz/sq yd
For transport ent ire ly
Euclids or model 769
suggested:
on-site (i .e., using "off highway" trucks, such as
Caterpillars), the following default values are
Default silt content (U) = 12%
Default haul truck speed = 20 mph
Default haul truck weight = 45 tons
Default number of wheels per haul truck = 6
Default surface silt loading = 0.35 oz/sq yd
These values have been chosen to yield conservative emission estimates in the
absence of site specific data.
24
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Phase II, Unit Operation 0 (Cut/Fill Material Handling): Equation (2-1)
is the recommended means by which emissions from material handling is
estimated: 1'2
E = 0.0011 (U/5)Al.3 / (M/2)A1.4
where:
E = PM10 emission factor expressed as pounds of emissions per ton of
material handled (lb/ton);
U = mean wind speed (mph) at 4-meter height; and
M = moisture content (%) of the material being handled.
The following default values are suggested to yield conservative emission
estimates for earthmoving, in the absence of site-specific data:
Default wind speed (U) = 10 mph
Default moisture content (M) = 5%
2.2.3 Dust Emissions During Construction
The following emission factor has been recommended to estimate emissions
from remaining construction activities (Phase III):~
E = 3.6 lb/acre/work hour
(2-6)
where:
E = PM10 emission factor expressing mass of emissions per unit area
disturbed per working hour.
No default values are considered necessary because the size and duration of
construction project should be known at the time a permit is sought.
Note that no "unit operations" (such as material handling or travel on
unpaved surfaces) have been included in this discussion of construction phase
dust emissions. This is primarily due to the form of the available emission
factor (Equation [2-6]). The factor was developed from perimeter monitoring
of many sources, rather than near-field source testing of an individual "unit"
source.
25
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In many respects, however, thi s is not a 1 imitation. For example, the
two previous phases can be relatively accurately estimated and scheduled.
This phase usually involves the receipt of many deliveries (such as concrete,
structural steel, and other building materials as well as landscaping items
later in the process); many of these arrival times are difficult to accurately
forecast. Equation (2-6) thus provides a method to estimate construction
phase estimates in spite of this uncertainty. Should applicants believe that
they can accurately predict average daily traffic levels and route lengths
together with activity levels for other unit operations during Phase III, then
they may use Equations (2-2) and (2-3) as well as the other emission factors
presented above to estimate emissions.
2.2.4 Mud/Dirt Trackout
In addition to on-site activities discussed above, substantial emissions
are possible because of material tracked out from the site and deposited onto
adjacent paved streets. Because all traffic (and not just that related to
construction) on the paved road can suspend the deposited material, this
"secondary" source of emi ssions may be far more important than all the dust
sources located within the construction area. Furthermore, this secondary
source is present during all phases of construction.
If N represents the daily number of vehicles entering or leaving an
unpaved access point to a paved road, then the quantity E in the following2
0.012
E = {
0.029
for N < 25
for N > 25
(2-7)
represents the unit PMI0 increase in lb/vehicle due to trackout. If M
represents the daily traffic volume on the paved road, then E x M represents
the PMI0 emission rate (in pounds per day) for trackout.
26
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2.2.5 Wind Erosion
In addition to mechanically generated dust emissions,. emissions may occur
from cleared land and material stockpiles during high wind events. Sec-
tion 11.2.7 of the EPA document AP-42 presents an estimation methodology for
PMI0 wind erosion sources. In its simplest form, the estimation technique can
be written asl
E = pI + p2 + p3 + ... + pN
(2-8)
where:
E = annual PMI0 emission rate due to wind erosion;
N = number of disturbances in a year; and
pi = erosion potential (mass per unit area) corresponding to the
observed (or probable) fastest mile of wind for the i-th period
between disturbances.
The erosion potential for a dry surface is found by the expression
p = {
29(u* - u*t)A2 + 12(u* - u*t)
o
for u* > u*t
(2-9)
for u* < u*t
where:
p = PMI0 erosion potential (g/m2);
u* = wind friction velocity (m/s); and
u*t = threshold friction velocity (m/s).
Additional details on the method can be found in Section 11.2.7 of AP-42.
Because the method can prove to be cumbersome when long-term (i.e., seasonal,
annual) emission estimates are desired, the algorithm has been included in the
computer model package described in EPA-450/3-90-010.~ Readers are encouraged
to use this computer package when wind erosion estimates are needed.
It is important to recognize that wind erosion emissions are much less
"certain" than emissions from, say, material handling or vehicle travel. That
27
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is, while one can be reasonably confident that dust will be generated from the
mechanical activities, erosion only occurs when the windspeed exceeds a
threshold value. It is possible that the threshold may not be exceeded during
the sometimes short time periods of interest in construction and demolition.
The implications of this uncertainty on ~etermining control efficiency and
emission reductions are discussed in Section 2.3.6.
2.3 CONTROL OF OPEN DUST SOURCE EMISSIONS AT CONSTRUCTION AND DEMOLITION
SITES
The previous section described dust generating activities at CD sites;
this section discusses the control techniques applicable to those
activities. Table 6 presents a summary of recommended controls for CD
activities. In keeping with general EPA guidelines, the use of preventive
rather than mitigative controls is emphasized in the following discussion.
2.3.1 Control Methods for Material Handling Operations
There are two fundamental dust control measures for material handling
operations: (a) sheltering from the wind and (b) wet suppression. These
. opti ons act to ei ther reduce the numerator or increase the denomi nator in
Equation (2-1). In either case, the predictive equation may be used to
determine the control efficiency as
CE = 100 x (Eu - Ec)/Eu
(2-10)
where:
CE = average control efficiency in percent;
Eu = "uncontrolled" emission factor from Equation (2-1); and
Ec = "controlled" emission factor from Equation (2-1).
The wind speed near a material handling operation may be reduced by portable
screens, fences, or any other type of flow obstruction (either natural or man-
made). Because barriers could be easily built with labor and materials on
28
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TABLE 6. CONTROL OPTIONS FOR CONSTRUCTION/DEMOLITION OPEN SOURCES OF PM10
Phase/Unit
operationa Emission source
I/A Loading of Debris
I/B Transport of Debrisb
II/A Bulldozing
II/B Pan Scrapers
II/C Cut/Fill Haulage
N
\0 II/D Cut/Fi 11 Handling
III General Construction
All phases Mud/Dirt Trackout
All phases Wind Erosion
Recommended control methods
Windspeed reduction, wet suppression (Section 2.3.1)
Wet suppression, paving, chemical stabilizationc
(Section 2.3.2)
Wet suppressiond (~ect;on 2.3.3)
Wet suppression (Section 2.3.3)
Wet suppression, paving, chemical stabilization
(Section 2.3.2)
Wind speed reduction, wet suppression (Section 2.3.1)
Wind speed reduction, wet suppression, early paving of
permanent roads (Section 2.3.4)
Early paving of permanent roads, cleaning of aprons,
truck cleaning devices, covered loads (Section 2.3.5)
Chemical stabilization, vegetative cover, wind speed
reduction (Section 2.3.6)
a Operations and phases as described in Section 2.2 of this report.
b Loads should be covered to avoid loss of material in transport.
c Chemical stabilization usually cost-effective for relatively long-term or semipermanent unpaved
roads.
d Excavated materials may already be moist and not require additional wetting.
-------
site, it is clear that this control measure is feasible at virtually all sites
of interest in this report.
Similarly, wet suppression is a generally feasible control measure for CD
sites, because most sites have access to some source of water. For projects
that do not have an abundant source of water (such as road construction in
rural parts of the west), the feasibility of wet suppression must be
determined on a case-by-case basis.
For sites with water, a variety of mechanisms may be used to add to the
moisture content of materials being handled at construction sites. (While
additives such as surfactants might be added to plain water, the use of foam
is not recommended in most CD situations because materials are not repeatedly
transferred.) Water cannons are easily added to water trucks that may already
be used to control roadway dust at the site. Spray systems with varying
geometries could be readily fabricated, assuming that pressurized water is
available.
Finally, it is imperative that dust control' plans contain some
precautions to be taken against compounding effects of watering programs on
trackout problems. For example, loadout emissions can be virtually eliminated
by soaking the material being transferred. However, it is clear that overly
wet material may leak from endloaders or transfer trucks, thus providing yet
another means for trackout beyond the site boundary.
2.3.2 Control of Vehicle-Related Dust
Unpaved Surfaces: The often short time periods of interest for CD sites
may require that unpaved roadway dust control be viewed differently than in
other industries. In general, the most cost-effective means of reducing
unpaved road dust is either to pave or to chemically stabilize the road
surface. Clearly, the high costs for paving or chemical treatment would not
be warranted for temporary construction roads and travel surfaces. While
temporary travel areas could be improved with a material with a lower silt
content, it is possible that future landscaping plans would preclude that
option. In that instance, wet suppression (either by watering or applying
30
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materials such as hygroscopic salts) would represent the preferred control
option for temporary roads.
Once again, it is imperative that dust control plans contain provisions
to protect against enhanced trackout as an undesired consequence of a roadway
watering program.
When projects involve the construction of permanent roads (industrial
parks or subdivisions, for example), paving .at the earliest possible time
represents an effective means of controlling unpaved road dust. Early paving
also provides a buffer (which may be cleaned as needed) to control trackout
onto more heavily traveled public streets. In addition, this can be a very
economical control measure, as the permanent roads would be an already
budgeted item.
The control efficiency afforded by paving may be calculated using
CE = 100 x (Eu - Ec)/Eu
(2-11)
where:
CE = average control efficiency in percent;
Eu = "uncontrolled" emission factor for the unpaved road from
Equation (2-2); and
Ec = "controlled" emission factor for the paved road from
Equation (2-3)
It is recommended that the default silt loading (sL) value given earlier be
used to determine the "controlled" emission factor. Regulatory agencies may
choose to provide their own sL values for applicants to use.
Two methods are available to assess the
of unpaved road emissions. The first is an
described in EPA-450/3-88-08:
effectiveness of .wet suppression
empirical model for watering, as
31
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CE = 100 - (K)(P)(D)(T)/(I)
(2-12)
where:
CE = average control efficiency in percent;
K = constant equal to 0.00087 for annual conditions or equal to
0.0012 for worst-case (summer) conditions;
P = evaporation value (inches) taken from Figure 6;
D = average hourly daytime traffic rate (vehicles/h);
I =water application intensity (ga1/sq yd); and
T = time (h) between applications.
While this model should be used only for plain water (i.e., no additives), the
second estimation method may be used for any type of wet suppression. Fig-
ure 7 shows that, between average uncontro 11 ed moi sture content and a value
twice that, a small increase in moisture content results in a large increase
in the control efficiency. Beyond this, however, control efficiency increases
very slowly with additional moisture. Note that the ordinate in Figure 7 is
instantaneous rather than average control efficiency. This point, as well as
the general use of both methods, is illustrated in the example control plans.
In the event that a site involves semipermanent unpaved roads (as might
be the case for roadway construction), then chemical stabil ization .becomes
much more cost-effective. Figure 8 presents a method that may be used to
estimate the time-averaged control efficiency due to repeated applications of
chemical dust suppressants. Several points should be noted about this figure
and its use:
1.
The term "ground inventory" used as the ordinate for the figure is a
. measure of residual effects from earl ier app1 ications. Ground
inventory is found by adding together the total volume (per unit
area) of concentrate (not solution) applied since the start of the
control program.
32
-------
w
w
---
----
\
\
\-
Figure 6.
Annual evaporation data for the contiguous United States.3
-------
1 00%
95%
~
Co)
c
Q)
.- 75%
Co)
:;::
-
w
0
-
-
c
0
()
0 500/0
.,..
I
::
c.
tn
~
0
Q)
c
(U
-
c 25%
(U
-
tn
C
-
Figure 7.
0% -
. -1
:?
3
4
5
Ratio of Controlled to Uncontrolled
Surface Moisture Contents
Watering control effectiveness for unpaved travel surfaces.
34
-------
100
90
'C
Q) -
C')~
ca -
-
Q) c:
> ~
~o
~ 80
>-cn
(,)
c:'C
.~ 0
(,).~
:;:Q)
-0.
w
(1)
oS
-'-
-t- 70
C
o (1)
(..)~
-
0-
,...(1)
. >
:50
c.
Figure 8.
(j
0-
0:05
0:-1
0..15
0.2
0.25
Ground Inventory. (gaf/sq yd)
Average PM10 control efficiency for chemical suppressants.
35
0.3
-------
2.
No
credit
is
given
for
ground
inventory
values
less
than
0.05 gal/sq yd.
3.
The figure is based on an average of four suppressants considered in
an earlier field study. The basis of the methodology lies in a
similar model developed for petroleum resins only.
The use of this figure is illustrated in the roadway construction example
given in Section 4.3.
Paved Surfaces: Paved travel surfaces represent a more difficult dust
source to control than do unpaved surfaces. Because the emission fac~or
depends on silt loading, available control measures attempt to decrease the
amount of material present on the surface. It is very important to note that,
because the exponent in Equation (2-3) is less than unity, a reduction in silt
loading is not accompanied by as large a reduction in the emission factor.
That is, a control that is 90% effective in reducing, silt loadings a paved
surface is only 50% effective in reducing the PM10 emissions.
Paved road control s may be .viewed either as "preventive, II in that the
control seeks to prevent material from being deposited onto a surface, or as
"mitigative, II with the purpose of removing material that has already been
deposited. While the current EPA pol icy emphasizes prevention, because CD
sites are localized and intensive sources of road loading, both preventive and
.
mitigative measures are considered feasible. As discussed in EPA 450/3-88-
008, there are no generally available methods by which the efficiency of
preventive controls can be estimated. Methods to estimate the efficiency of
common mitigative measures are summarized in Table 7.
2.3.3 Control of Site Preparation (Phase II) Emissions
For two of the four dust-generating operations under Phase II--namely,
material handling and truck haulage--the control techniques described in
Sections 2.3.1 and 2.3.2 apply. The other two operations deal with the
36
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TABLE 7. ESTIMATED METHODS FOR AVERAGE EFFICIENCY VALUES
FOR PAVED ROAD CONTROLSa
Control
Average eff~ciency, C
(%)
Comments
Vacuum sweeping
C = (34, D ~ 2
68/D, D > 2
C = ( 69-0116 V, V ~ 299
10,300/V, V > 299
340 m3/min (12,000 cfm)
blower tested
Water flushing
Water applied at
2.2 L/m2 (0.48 gal/yd2)
Water flushing
followed by
broom sweeping
C = ( 96-0.132 V, V ~ 365
17,500/V, V > 365
Water applied at
2.2 L/m2 (0.48 gal/yd2)
a Based on PM15 field emission measurements as given in Reference 2.
PM10 efficiency may be assumed equal to that for PM15.
b In the expressions, D and V represent the number of days or vehicle
passes, respectively, since application.
37
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movement of recently disturbed earth, which may. have a relatively high
moisture content.
With the exception of watering particularly dusty materials, no
additional controls are recommended for bulldozers and pan scrapers. The
control efficiency of watering bulldozer operations may be estimated by
comparing emission factors resulting from different moisture contents in
Equation (2-4). For scraping operations, it is recommended that one of the
two (i.e., either Equation [2-121 or Figure 7) methods described for unpaved
road watering under Section 2.3.2 be used to estimate the control efficiency.
2.3.4 Control of Emissions During Construction (Phase III)
Recall from the earlier discussion of this phase that the generally
available emission factor does not make use of "unit operations" and that it
is usually not possi ble to accurately forecast dai ly operating conditions.
Consequently, it is generally not possible to prepare detailed control plans
for this phase. It is recommended, however, that at a minimum plans contain
provisions for the control of unpaved travel surfaces and staging areas as
well as for trackout (see below).
2.3.5 Control of Mud/Dirt Trackout
Because this dust source occurs outside the site perimeter, the choice of
control measures may be highly dependent upon the physical setting of the CD
site. For example, construction within a busy urban corridor may preclude not
only the use of paved "buffer zones" but also routine cleaning of public
streets adjacent to the site. In that situation, then, prevention of trackout
by early paving and subsequent routine cleaning of access areas may be the
only viable control option. For construction in other areas, on the other
hand, a mitigative approach may be more successfully used to clean up material
that has already reached the street. As a rule of thumb, it is recommended
that local and state agencies strongly encourage the use of preventive (i.e.,
controls applied on the construction site) techniques rather than mitigative
measures that remove material which has already left the site boundaries.
38
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As noted in EPA guideline documents, quantification of the control
efficiency for preventive measures is impossible using the standard
before/after approach. EPA-450/3-88-008 presents a method of estimating upper
bounds of emission reductions that is essentially identical to Equation (2-7)
and then suggests that regulatory agencies assign some effective level of
control. For example, dai ly manual cleaning of an access area could be
associated with, say, 25% control while the use of paved aprons or buffers
together with routine cleaning of those paved areas might be given an
efficiency of, say, 90%. It is recommended here that local agencies
(1) establish nominal efficiency values for preventive trackout controls and
(2) focus on visual measures of trackout control performance dur.ing site
inspections.
2.3.6 Control of Open Area Wind Erosion
Earlier it was noted that, compared to other emission sources,
(a) applicants will find wind erosion emissions sUbstantially more difficult
to estimate and (b) reductions in thi s source are far less IIcertain.1I For
these reasons, it is recommended that wind erosion emissions not be included
,in determining CD site emission reductions and overall average control
efficiency. However, it is strongly recommended that local agencies require
that di sturbed earthen surfaces be stabi 1 ized against air and water erosion
within a fixed period of time after the disturbance. This recommendation is
included in the example regulation of Section 3.
Suitable surface stabilization may be accomplished with water chemical
suppressants, by the addition of larger aggregate (llmomentum partitioningll),
or through the establishment of vegetative cover. Ground cover is usually
cost-effective at construction sites, and its general use is recommended.
39
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SECTION 3
EXAMPLE REGULATION
This section presents an example CD regulation that state and local air
regulatory agencies may use as a model. The example (as presented in Table 8)
is largely based on features found during the review of existing and draft
regulations (see Section 2.1).
Several points should be noted about the example:
1.
First, the example presents only a skeleton of a regulation which
must be "f1eshed out" for use. For example, agencies will need to
decide if dust control plans are to be attached to building permits
or if a separate air regulatory permit is to be issued.
Similarly, it is important that regulators have. legal counsel
rephrase the example for consistency with state and local laws.
Table 8, for example, only prohibits persons from la110wing" certain
s i tuat ions; many agenci es wi 11 need to supp 1 ement th is wi th verbs
such as "cause" or "permit." A1 so, no specific mention of fees or
penalties is made.
2.
The example regulation contains several blank lines for items such
as the minimum size of areas to be considered or time periods within
which control must be applied. Agencies need to determine an
appropriate value for each blank.
40
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TABLE 8.
EXAMPLE REGULATION
Section 100--Genera1
101 Purpose--To reasonably regulate construction and demolition activities
that release particulate matter emissions to the ambient atmosphere
102 App1icabi1ity--This regulation applies to all construction and demolition
activities within the IS jurisdiction unless specifically
exempted below.
Section 200--Definitions
For the purpose of this regulation, the following definitions apply
201 APCO (Air Pollution Control Officer)--The person heading the -1agency)
or any of his/her designees.
202 App1icant--The individual, pUblic and/or private corporation, or any
other legal entity preparing the dust control plan described in
Section 301. .
203 Chemical Stabi1ization/Suppression--A means of dust control implemented
by any person to mitigate PM10 emissions by applying petroleum resins,
asphaltic emulsion, acrylics, adhesives, or any other APCO-approved
materials.
204 Construction/Demolition Related Activities--Any on-site mechanical
activities preparatory to or related to the building, alteration,
rehabilitation, or demolition of an improvement on real property,
including but not limited to: grading, excavation, loading, crushing,
cutting, planing, shaping, or breaking.
205 Disturbed Surface Area--A portion of earth1s surface, or materials placed
thereon, which has been physically moved, uncovered, destabilized, or
otherwise modified, thereby increasing the potential for emission of
fugitive dust.
206 Dust Suppressants--Water, hygroscopic materials, chemical stabi1ization/
suppression materials (see definition 203), and other materials not
prohibited for use by the Environmental Protection Agency or any other
applicable law, rule, or regulation, as a treatment material to reduce
PM10 emissions.
207 Fugitive Dust--The particulate matter entrained in the ambient air which
is caused from man-made and natural activities such as, but not limited
to, movement of soil, vehicles, equipment, blasting, and wind. This
excludes particulate matter emitted directly in the exhaust of motor
vehicles, other fuel combustion devices, from portable brazing, solder-
ing, or welding equipment, and from pile drivers.
(continued)
41
-------
TABLE 8.
(continued)
208 Lot--A designated parcel, tract, or area of land established by plat,
subdivision, or as otherwise permitted by law, to be used, developed, or
built upon as a unit.
209 Open Area--An unsealed or unpaved motor vehicle parking area, truck stop,
vacant lot, or any other disturbed surface area located on public or
private property which is subject to wind erosion, and is a source of
PM10 emissions.
210 Paved Surface--An improved street, highway, alley, public way, easement,
or other area that is covered by concrete, asphaltic concrete, asphalt,
or other materials specified by the APCO.
211 PM10--Particu1ate matter with an aerodynamic diameter smaller than or
equal to a nominal 10 microns as measured by the applicable Federal
reference method.
(PM10 Dust Prevention and) Control P1an--A written document that
describes dust emission sources present at the site and identifies the
means and strategies used to reduce the emissions.
213 Site--The real property upon which construction/demolition activities
occur.
212
214 (Surface, Soil) Stabi1ization--The process used to mitigate PM10
emissions for an extended period of time by applying petroleum resins,
asphaltic emulsion, acrylics, adhesives, or any other APCO-approved
material or physical stabilization by vegetation or the addition of
aggregate material to the surface.
215 Traffic Volume (ADT)--The average daily traffic (ADT) is the number of
vehicle trips on a paved or unpaved surface during a 24-h period. The
ADT value for a publicly owned road shall be determined according to the
regulations of the pUblic agency responsible for that road.
216 Unpaved Surface--Any surface not defined as paved in definition 210
above.
Section 300--Prohibitions/Requirements
301 No person shall engage in any construction/demolition related activity
(as defined above) without having an APCO-approved PM10 dust prevention
and control plan, unless exempted below. This control plan will be in
writing and, at a minimum, will
(continued)
42
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TABLE 8.
(continued)
1.
briefly describe construction/demolition activities to be performed
at the site that will produce PM10 dust emissions. These dust-
generating activities shall include, but not be limited to
I.
Removal of Obstructions (Natural/Man-made)
a. Transfer of the debris into vehicles for haulage
b. Transportation of the debris on-site
c. Additional transfers of the debris (if on-site, as
material)
for fill
II.
Preparation of the Site
a. Bulldozing and scraping operations
b. Truck transportation of materials (such
on-site
c. Transfers of materials
as "imported" fill)
III. Construction Operations
a. Traffic on paved surfaces and staging areas
b. Traffic on unpaved surfaces and staging areas
2. present estimated uncontrolled PM10 emission rates for each activity
and summarize the total uncontrolled PM10 emissions expected.
3. describe the control measures (if any) to be applied to each activity
and estimate the corresponding controlled emission rate for each
activity
4. estimate the overall efficiency of the control plan by comparing the
total controlled emissions to total uncontrolled emissions. (Note
that the APCO may choose to prescribe a minimum target overall
efficiency for the control plan.)
The applicant is responsible for ensuring that each contractor or
subcontractor working at the site adhere to the provisions of the dust
control plan.
The APCO shall make available for inspection examples of approved dust
control plans at the offices of
301 Unless specifically exempted below, no person shall allow any visible
accumulation of mud, dirt, dust, or other material from the paved roads
including paved shoulders adjacent to the site where construction/
demolition activity occurs. The methods used to prevent accumulation as
well as the scheduled frequency must be addressed in the dust control
plan.
(continued)
43
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TABLE 8.
(continued)
302 Unless specifically exempted below, disturbed surfaces may not be allowed
to remain in an unstabilized state. Disturbed surfaces must be
stabilized against wind and water erosion within calendar days after
the disturbing activity ceases. In no event shalr-a disturbed area be
allowed to remain unstabilized for a period greater than --- calendar
days. The method(s} used to stabilize the surface shall be described in
the dust control plan.
303 As evidence of control application, the applicant shall keep dust control
records on agency-supplied forms. These forms will be included with the
APCO.s written approval of the applicant's dust control plan. Records
are to be kept current, be submitted upon the request of the APCO, and be
open for inspection during unscheduled inspections.
304 For construction projects with a duration of at least calendar days,
the APCO shall perform at least one on-site inspection:--Prior to this
scheduled inspection, the APCO may require the applicant to furnish
information or other records.
305 For construction projects with a duration of at least calendar days,
the APCO will formally review the dust control plan within calendar
days of the on-site inspection. ----
Section 400--Exemptions
The following are specifically exempted from the provisions of this
regulation:
401 Construction/demolition activity involving a floor plan of less
than ----- sq ft
402 Any construction/demolition meeting the following activity levels or
requirements:
1.
occurring entirely within an enclosed structure from which no visible
airborne particulate matter escapes;
2. modifications to residential dwellings by the owner/occupant that do
not require building permits;
3. movement of less than
cubic yards of dirt;
403 Disturbed surface areas of less than
acre.
(continued)
44
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TABLE 8.
(continued)
404 The implosion or mechanical dismemberment of any structure.
however, that this activity may be subject to regulation
requires a permit or variance to be granted.)
405 Blasting of rock or other earthen materials in conjunction with
construction/demolition activities. (Note, however, that this activity
may be subject to regulation , which requires a permit or
variance to be granted.)
(Note,
, which
45
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3.
As noted in the example, dust emissions resulting from mechanical
dismemberment or implosion of an existing structure or from blasting
of rock are not covered by the regu 1 at i on. However, it is recom-
mended that agencies provide additional phrasing referring to a
separate permit or variance to cover this type of emission source.
4.
Readers are reminded that the regulation given in Table 8 is meant
solely as an example and is intended only to provide a general
framework around which regulations may be developed. Agencies
should freely add or delete material as appropriate for their
jurisdictions.
46
...
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SECTION 4
EXAMPLE DUST CONTROL PLANS
This section presents example dust control plans based on the four
"scenarios" introduced in Section 1 of this report. Refer again to Tables 1
through 4 and Figures 1 through 4 for more details.
4.1 SCENARIO 1
This example deals with the construction of a 20-story building in a busy
downtown area. The site is fenced off and only one access point is used by
vehicles entering or leaving the site. The access road is scheduled to be
paved near the end of the construction.
4.1.1. Uncontrolled Emissions
Phase I, Debris Loadout. Five thousand (5,000) tons of excavated
material are removed each day. Geologic site investigations have estimated
the soil moisture to be 6%. That value, together with the default wind speed
for Equation (2-1), results in a daily PM10 estimate rate of
0.0011 (10/5)A1.3 / (6/2)A1.4 lb/ton x 5000 ton/work day = 2.9 lb/day
Phase I, Truck Transport. Because the trucks in Table 1 have a net
capacity of 15 tons, 330 (= 5000/15) truck loads will be required each day.
Using the values in Table 1 together with the defaults suggested for Equa-
tion (2-2), it follows that emissions associated with truck transport of
excavated material can be estimated as
47
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2.1 (12/12) (15/30) ([20 + 15/2]/3)A.7 (10/4)A.5 lb/VMT x
330 load/day x 150 ft (round trip)/load x 1 mile/5,280 ft
= 73 lb/work day
Phase I, Trackout. Because 330 truck loads are required per day, the
appropriate value from Equation (2-7) is 0.029 lb/vehicle. Over the 1-month
(30-day) excavation period, the 5,000 vehicle/day traffic on 4th Street
accounts for
0.029 lb/vehicle x 5000 vehicle/day
x 30 day = 4400 lb
The daily emission rate of 4400/30 = 140 lb/day occur on both working and
nonworking days.
Phase II, Site Preparation. Because this site had been previously
developed, no additional site preparation is required in this example.
Consequently, there are no emissions associated with site preparation.
Phase III, Construction. PM10 emissions associated with general
construction activities at the site may be estimated using Equation (2-6) and
the information given in Table 1. Assuming 8 working hours during each of the
160 work days, then the 1.2 acre site is estimated to emit
3.6 lb/work hour/acre x 1.2 acre x 8 work hour/workday = 34 lb/workday
Phase III, Trackout. Because more than 25 vehicles enter and leave the
site each work day, the appropriate value from Equation (2-7) is
0.029 lb/vehicle. Over the 8-month (240-day) construction period, then,
0.029 lb/vehicle x 5000 vehicle/day x 240 day = 35,000 lb
Again, this emission rate applies to both working and nonwork1.ng days.
Summary. Over the two phases (Phases I and III), the following PMlO
emissions are estimated to occur:
48
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Phase I - 20 work days at
4,400 1 b of trackout, for a
over 1 month
(2.9 + 73) lb/workday or 1,500 lb, plus
grand tota 1 of 5,900 1 b of PMlO emi ss ions
. Phase III - 160 workdays at 34 lb/workday or 5,400 lb, plus, 35,000 lb
from trackout, resulting in a total of 40,000 of estimated PMI0 emissions
over 8 months
Both phases -- 46,000 lb of PMI0 estimated over a 9-month period
4.1.2 Example Control Plan
Phase r, Debris Loadout. As indicated by the summary above, this
activity results in only a very small fraction of the emissions. For that
reason, no additional controls are contemplated for this source.
Phase I, Truck Transport. To reduce both truck transport and trackout
emissions, the first 25 ft of the entrance will be paved to provide a buffer
before exiting to 4th Street. This portion of the entrance was scheduled to
be paved 1 ater . but wi 11 be paved now as a control measure. The rem a i ni ng
50 ft of temporary roadway will be constructed of 6-in deep crushed stone,
with no more than 2% passing a 200-mesh screen (i.e., silt content less than
2%).
Using Equations (2-2) and (2-3) together with default values
necessary, controlled emissions are estimated as
as
2.1 (2/12) (15/30) ([20 + 15/2]/3)A.7 (10/4)A.5 lb/VMT
x 330 load/day x 100 ft (round trip)/load
x 1 mile/5,280 ft = 8.1 lb/day
for the unpaved portion of the road and as
0.77 (.35/.35)AO.3 lb/VMT x 330 load/day x 50 ft
x 1 mile/5,280 ft = 2.4 lb/day
for the paved portion. Total
control efficiency of 86% (i.e.,
daily emissions would be 10.5
10.5 compared to 73 lb/day).
49
lb/day for a
-------
Phase I, Trackout. Emissions of trackout will be controlled by manually
cleaning (using a hose and a push broom) the paved 25-ft portion of the road
twice a day (e.g., at noon and at quitting time) and the paved curb cut at
4th Street when the cut shows visible accumulation. In addition, loads will
be covered with tarps prior to leaving the site. Furthermore, all travel
operations in the area will cease in the event of a spill or large amount of
trackout until the access area has been cleaned. These control measures have
been estimated to result in approximately 75% control. The controlled
emissions from this phase are 36 lb/day compared to the uncontrolled emissions
of 145 lb/day or 1,080 lb for 30 days.
Phase III, Construction. PM10 emissions from general constructipn
activities include miscellaneous sources such as traffic from delivery (e.g.,
cement mixers, structural steel, and other materials) vehicles and forklift in
staging areas, or traffic from workers arriving and leaving the site. The
summary above showed that this is a minor source of PMlO emissions when
compared to trackout. Consequently, no specific additional controls are
planned. Note, however, that improved access road wi 11 resu 1 tin reduced
emissions during the construction phase.
Phase III, Trackout. Phase III will control trackout in much the same
manner as Phase I. The 25-ft paved road will be cleaned (using a hose and a
broom) at least once daily (e.g., at quitting time). The reduced cleaning
schedule (from twice per day during Phase I) is believed to be sufficient
because (a) fewer vehicles should enter/leave the site each day and (b) the
vehicles are not carrying loose material (as they did in Phase I). If this
schedule is found not to be sufficient, the Phase I schedule will be
reinstituted. Furthermore, should a spill occur, no vehicles will be allowed
to leave the site until the spill has been cleared. Again, the control
efficiency is approximately 75%; 36 lb/day over the 8-month construction
period is the estimated controlled PM10 emission rate.
In summary, the total controlled PM10 emissions are:
Phase 1--20 workdays at 13.4 lb/workday (2.9 + 10.5) or 268 lb, plus
1,080 lb of trackout, for a grand total of 1,350 lb of PM10 emissions
50
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over 1 month. Compared to the uncontrolled total, this represents an
overall control efficiency of 77%.
Phase 111--160 workdays at 34 lb/workday or 5,400 lb,
trackout, resulting in a total of 14,000 lb estimated
8 months. Thus, an overall efficiency of 65% is
phase.
plus, 8,600 lb from
PM10 emissions over
estimated for this
Both Phases--A tot a 1 of 15,000 1 b of contro 11 ed PM10 is est imated,
compared to an uncontrolled estimate of 55,000; thus, overall average
control efficiency is found to be 72%.
4.2 SCENARIO 2
In this example, site preparation was planned for the entire 20-acre
site, followed by construction of 20 homes on one-half of the site. A second
construction phase of 20 other homes is scheduled to begin one year from
now. In the following, only site preparation and construction of the first
20 houses are considered.
4.2.1 Uncontrolled Emissions
Phase II, Bulldozing.
values of 12% si lt and 5%
factor is estimated as
Employing Equation (2-4) along with the default
moisture contents, the uncontrolled PM10 emission
0.74 (12)~1.5/(5)~1.4 = 3.23 lb/hr
From Table 2, it is known that three bulldozers will each operate 8 h/workday,
resulting in 24 dozer hours per workday. In that case, the estimated emission
rate is 78 lb/workday.
Phase II, Pan Scrapers. Section 2.2 presented a PM10 emission of
4.2 lb/mile for scrapers. Because two scrapers will each operate 8 h/workday
at 5 mph (see Table 2), there will be 2 x 8 x 5 = 80 scraper miles traveled
51
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each. workday. Applying the emission factor of 4.2 lb/mile to that value
results in an estimated PM10 emission rate of 340 lb/workday.
Phase III, Construction. The dust emissions associated with the
construction of the first 20 homes is estimated using the 3.6 lb/work
hour/acre value given in Section 2.3. From Table 2, it is known that the
project wi 11 requ i re 150 workdays of 8 work hours each. I n that case, the
10-acre site is estimated to emit
3.6 lb/work hour/acre x 10 acres x 8 work hours/workday = 290 lb/workday
Phase III, Mud/Dirt Trackout. From Table 2, there are 40 vehicles
entering/leaving the work site during each workday. Using Equation (2-7) and
the 6,000 ADT value for Summit Drive, it is seen that
0.029 lb/vehicle x 6000 vehicles/day = 170 lb/day
are estimated to result from trackout. As before, this value applies to the
entire 7-month period (i.e., working and nonworking days).
In summary, the PM10 emissions would be:
Phase II--78 lb/workday for bulldozing and 340 lb/work day for scrapers
for a total of 420 lb/workday. Over the 40 workdays, this results in
17,000 lb of estimated PM10 emissions.
Phase 111--290 lb/workday due
mud/dirt trackout. This yields
over the 7-month period:
to construction and 170 lb/day from
an estimated 80,000 lb of PM10 emissions
150 workdays x 290 lb/workday + 7 months x 365 day/12 months
x 170 lb/day = 80,000 lb
In addition, during the first construction period, there are 10 acres to
the east of Suburban Drive are sUbject to wind erosion. In keeping with the
recommendations made in Section 2.2.5, no attempt to estimate erosion
52
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emissions has been made here. (In general, one could expect that wind erosion
will represent a very minor source compared to the 80,000 lb total estimated
above.) The following dust control plan does, however, include provisions for
this potential source of PM10.
4.2.2 Example Dust Control Plan
Because of the need to stabilize the area left undeveloped, the applicant
has decided that staggering site preparation (i .e., 10 acres this year and
10 acres next year) would be more cost-effective. This will not only
eliminate the potential 10-acre wind erosion source but also cut total
uncontrolled emissions during Phase II in half, from 17,000 lb to 8,500 lb.
Phase II, Bulldozing. This represents a relatively minor source when
compared to the total emissions during Phase II; consequently, no additional
controls are proposed. Recall, however, that only 20 workdays will be
required for the staggered site preparation.
Phase II, Scrapers. The scraper route will be watered at the start of
each 8-h workday to decrease emissions. Assuming
.
Because the site is located in Kansas
appropriate value for P is 60 (see Figure 6).
City,
Missouri,
the
.
The estimate is for annual rather than summer conditions (i.e., the
appropriate value for K is 0.00087).
.
0.25 gal /sq yd of water is app 1 i ed to the route at the start of
every 8-h work~ay.
.
Each of the two scrapers makes 12 complete loops per hour (thus,
24 scrapers pass a point every hour).
then Equation (2-12) results in a control efficiency estimate of
100 - (0.00087)(60)(24)(8)/(0.25) = 60%
53
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This corresponds' to a controlled emission estimate of
(1-0.60) x 4.2 x 80 scraper miles/workday = 130 lb/workday
The above rate occurs only 20 workdays because site preparation will be
divided between two years.
Phase III, Construction. Because a major portion of the emissions during
construction is due to traffic on unpaved Suburban Drive, the applicant
proposes to pave this road as soon as site preparation has been completed. By
comparing the leading terms of Equations (2-2) and (2-3), a control efficiency
of 63% is estimated:
(2.1 - 0.77)/2.1 x 100% = 63%
This efficiency results in an estimated controlled emission rate of (1-0.63) x
290 = 110 lb/workday.
Phase II I, Mud/Di rt Trackout. Pavi ng Suburban Dri ve wi 11 also help to
control the mud/dirt trackout onto Summit Drive. It is estimated tha~ this
will result in 80% control. Controlled mud/dirt trackout PMI0 emissions are
estimated as (1-0.80) x 170 = 34 lb/day. In addition, travel operations in
the area will cease in the event of a spill or large amount of trackout until
the access area has been cleaned.
In summary, controlled emissions for the completion of the first 20 homes
are as follows:
Phase II--Twenty workdays at 78 lb/workday
130 1 b/workday (scraper) , thus total i ng 4,200 1 b of
represents a
(bulldozer)
emissions.
plus
This
[(78+340) - (78+130)] / (78+340) = 0.50
54
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or, 50% reduction in emission rate and a
(17,000 - 4200) / (17,000) = 0.75
or, 75% reduction in the total emissions during the current year.
Phase III--Total controlled PM10 emissions for Phase III activities
associated with the first 20 homes are estimated as
150 workdays x 110 lb/workday +
7 months x 365 day/12 months x 34 lb/day = 24,000 lb
This represents a 70% decrease from the uncontrolled total of 80,000 lb.
Overall efficiency for this control plan is 71%.
4.3 SCENARIO 3
As shown in Figure 3, operations in all three 'phases are occurring
simultaneously at this road construction site:
Phase I .
with cut
off-site.
Excavation-- The roadway is being built below exi sting grade
material loaded into haul trucks for transport and disposal
Phase II. Site Preparation--A previously excavated area is being brought
to final grade with pan scrapers and bulldozers.
Phase III. Construction--Pavement operations are being performed at the
far righthand area in the figure.
For illustration purposes, assume that each active area occupies 5 acres
of the total 15-acre site.
55
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4.3.1 Uncontrolled Emissions
Phase I, Material Loading. From Table 3, 5,000 tons of material are
hauled off-site each workday. Using Equation (2-1) together with the
recommended default values of 10 mph and 0.5% moisture and the information in
Table 3, the estimated PM10 emissions can be found as
0.0011 (10/5)A1.3 / (0.5/2)A1.4 lb/ton x 5000 ton/day = 94 lb/workday
Phase I, Transport of Debris. Equation (2-2) may be used to estimate
emi ss ions due to truck transport of materi a lover unpaved roads. From the
information provided in Table 3, the truck capacity is 20 tons and 5,000 tons
of material is hauled per day, therefore 250 loads (round trips) will be
required to remove the material per workday (= 5000 tons per workday / 20 ton
per load). Assuming that the site is in Kansas City, Missouri, it follows
from Figure 5 that the mean annual number of days with precipitation is
100 days. Assume further that the default silt content of 12% is applicable;
in that case, daily PM10 emissions are estimated as
E = 2.1 (12/12) (15/30) [(1.5x20)/3)AO.7 (18/4)AO.5
x [(365-100)/365] lb/VMT
x 250 loads/workday x 1,700 ft x 1 mile/5,280 ft
= 640 lb/workday
for truck haulage.
Phase II, Bulldozing. Estimated uncontrolled PM10 emissions from
bulldozing activities are determined from Equation 2-4. Assuming the default
values of 12% silt and 5% moisture, this equation yields:
0.75 (12)A1.5 / (5)A1.4 = 3.3 lb/hr of dozer operation.
From Table 3, it is seen that there are 18 h of dozer operation every workday
(2 dozers x 9 h/workday); thus,
56
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E = 18 h/workday x 3.3 lb/h = 59 lb/workday
is the estimated emission rate.
Phase II, Pan Scrapers. The emission factor for pan scrapers is
4.2 lb/mile{Equation 2-5). From Table 3, an emission rate of
E = 4.2 lb/mile x 4 scrapers x 5 miles/h x 9 h/day = 760 lb/workday
can be determined.
Phase III, Construction. The particulate emissions from paving the
roadway is estimated using the construction phase emission factor of
3.6 lb/acre/work hour (Equation [2-6]) and the information in Table 3.
Therefore, the emission rate for these activities is 160 lb/workday , which is
equal to the product of the emission factor, the 5-acre site, and the 9 work
hours per workday.
Mud/Dirt Trackout.With 250 loads/day being hauled off-site from
excavation operations, more than 25 vehicles enter/leave the site per day and
the emission factor of 0.029 lb/vehicle (Equation [2-7]) is applicable. Total
traffic on Deacon Drive is 7,500 vehicles per day, giving a total emission
rate of 220 lb/day. Note that this includes working as well as nonworking
days.
In summary, total emissions from this project include:
.
Phase I Cut Operations--730 lb/workday (94 lb/workday loading and
640 lb/workday transport)
.
Phase II Site Preparation--820 lb/workday (59 lb/workday bulldozing
and 760 lb/workday pan scrapers)
.
. Paving--160 lb/workday for construction
.
Trackout--220 lb/day
57
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With 21 workdays during the 30 day base month, the total PM10 emissions for
the base month are estimated as
21 workdays x (730 +820 +160) lb/workday
+ 30 days x 220 lb/day = 42,000 lb = 21 tons
4.3.2 Example Control Plan
In the following example control plan, it is assumed that the APCO has
set an overall control of at least 65% control. This will require reducing the
21 tons of PM10 emissions to no more than 7.4 tons during the base month.
Phase I, Debris Loading. Because this is a relatively minor source, no
additional control measures are contemplated. Emissions are unchanged at
94 lb/workday.
Phase I, Transport of Debris. This source accounts for almost half of
the total emissions and needs to be well controlled. In addition, as this
site involves an unpaved ramp to Deacon Drive and a haul ,route that will be in
use for a fairly long period, chemical stabilization is cost-effective. The
main haul route and the entrance/exit ramp will be treated with 0.25 gal/sq yd
of a 1 part chemical to 5 part water solution on the first of each week.
Thus, the "ground inventory" increases by
1/(1+5) x 0.25 gal/sq yd = 0.042 gal/sq yd
each week.
obtained:
From Figure 8, the following control efficiency estimates are
Average
Ground control
inventory efficiency
Period Jgal/yd2) (%)
Week 1 0.042 0
Week 2 0.083 85
Week 3 0.12 89
Week 4 0.17 92
58
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The controlled emission rate for the base month may be estimated by applying
the mean average control efficiency of (0 + 85 + 89 + 92) /4 = 66% to the
uncontrolled emission rate of 640 lb/workday. Thus, controlled emissions are
estimated as (1-.66) x 640 = 210 lb/workday. (If this dust control program
continues, estimated emissions will be even lower in later months as the
ground inventory increases.)
Phase II, Bulldozing. This is also a relatively minor source. No
additional controls are planned and the emission rate is unchanged at
59 lb/workday.
Phase II, Scrapers. The control efficiency for watering the site can be
determined with Equation (2-12) together with a few assumptions. Assuming
that
.
Because the site is located in Kansas
appropriate value for P is 60 (see Figure 6)
City,
Missouri,
the
.
The estimate is for summer (worst-case)
appropriate value for K is 0.0012)
conditions (i.e., the
.
1.0 gal/sq yd of water is applied at the start of every 9-h workday
.
Each of the 4 scrapers makes 5 complete loops per hour (thus,
20 scrapers pass a point every hour)
then the control efficiency would be estimated as
[100 - (0.0012)(60)(20)(9)/(1.0)] = 87%
The estimated controlled emission rate is thus (1-.87) x 760 = 98.3 lb/
workday. Note that, because scrapers operate only on-site, this watering
program will not compound mUd/dirt trackout onto Deacon Drive.
Phase III, Construction. Unpaved travel surfaces and staging areas will
be kept at twice the uncontrolled surface moisture value. According. to
59
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Figure 7, this wi 11 result in approximately 75% instantaneous control for
travel emissions. Because instantaneous control efficiency is greater than
than average control efficiency; it is assumed that the 75% value applies to
the entire emission rate of 160lb/workday. Therefore, estimated controlled
PM10 emissions will be (1-.75) x 150 = 40 lb/workday.
Phase III, Mud/Dirt Trackout. To control mud/dirt trackout, the
temporary ramp used to enter and exit the site which is chemically treated to
control truck transport emissions will also control the mud trackout. Also,
.
the paved access point at Deacon Drive will be manually cleaned (using a hose
and push broom) of rock and dirt at least twice per workday (e.g., at noon and
at quitting time). Furthermore, the haul trucks carrying excavated material
will be covered with tarps prior to leaving the site. Finally, operations in
the area will cease in the event of a spill or large amount of trackout until
the area has been cleaned. This combination of controls is estimated to have
a control efficiency of approximately 70% which corresponds to an emission
rate of (1-0.7) x 220 = 66 lb/day.
In summary, then, controlled emissions during the 30-day period of
interest are estimated to be
21 workdays x (94 + 210 + 59 + 98 + 40) lb/workday
+ 30 days x 66 lb/day = 12,000 lb = 6.2 tons
This represents a 70% overall reduction from the uncontrolled total of 21
tons.
4.4 SCENARIO 4
This example deals with the demolition of a building within a busy
downtown area. Only emissions after the building is dismembered are
considered.
60
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4.4.1 Uncontrolled Emissions
Debris Loading. Based on information given in Table 4 and the default
values given in connection with Equation (2-1), it follows that the debris
loading PM10 emissions equal
0.0011 (10/5)A1.4 (0.5/2)A1.4 lb/ton x 50000 sq ft x 0.046 [ton/sq ft]
= 43 lb
Note that the 43 lb of emissions is spread over 5 days, so the emission rate
is 8.7 lb/day.
Truck Transport. Because the demolition results in 0.046 ton/sq ft. x
50,000 sq ft = 2,300 tons of debris and because the haul truck capacity is
20 tons, it is clear that 115 loads (round trips) will be required to remove
all the debris. Using the values in Table 4 together with the defaults
suggested for Equation (2-2), it follows that the truck transport emissions
are estimated as .
2.1 (12/12) (15/30) ([20 + 20/2]/3)A.7 (10/4)A.5 lb/VMT x 115 loads
x 250 ft (round trip)/load x 1 mile/5,280 ft = 45 lb
Th is 45 1 b is also spread over the 5-day peri od, resu 1 t i ng in a rate of
9.0 lb/day.
Trackout Emissions. Because the 115 trips required to remove the debris
result in a daily total of at least 46 vehicles entering and leaving the site,
the appropriate value for trackout emissions from Equation (2-7) is 0.029 lb/
vehicle. When applied to the traffic rate on 4th Street, it is seen that
trackout emissions equal 0.029 lb/vehicle x 5,000 vehicle/day = 140 lb/day.
Note that trackout emissions may continue to occur for a period after debris
removal.
In summary, the uncontrolled PM10 emission rate in this example is 8.7 +
9.0 + 140 = 160 lb/day over the removal period. Of this total, trackout
emissions account for approximately 90%.
61
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4.4.2 Example Control Plan
Suppose that each of the three sources described above are to be
controlled. The following presents a possible control plan.
Debris Loading. The demolition contractor proposes to build 10-ft high
sections of approximately 50% porous fence from wood lath or latticework
before any loadout is performed. Each section will be skid-mounted to allow
easy relocation. Prior to starting loadout each workday, the sections will be
aligned to reduce winds from a sector of approximately 180 degrees.
Assuming a 50% reduction in wind speed from the 10 mph default value used
above, then Equation (2-1) yields
0.0011 (5/5)A1.3 / (0.5/2)A1.4 lb/ton x 50000 sq ft x 0.046 ton/sq ft
= 18 lb
This represents (43-18)/43 x 100% = 58%
Recall that this total emission rate is
PM10 emission rate of 3.6 lb/workday.
control of debris loading emissions.
spread over 5 workdays, with a daily
Truck Transport. Rather than wateri ng the short stretch of unpaved
travel route involved in this example, the contractor prefers to construct a
temporary road of crushed stone, with no more than 2% passing a 200-mesh
screen (i.e., silt content less than 2%). The contractor also believes that
this control option will help in controlling trackout emissions.
This road will be 125 ft long by 15 ft wide and 6 in deep, thus requiring
roughly 40 cu yd of stone. This represents a (12-2)/12 x 100% = 83% reduction
in silt content used earlier in Equation (2-2); because the emission factor is
a linear function of silt content, this also corresponds to an 83% reduction
in the daily emission rate (i.e., from 9.0 lb/day to 1.5 lb/day).
Trackout Emissions. In order to reduce track out emissions, the demolition
contractor proposes the following preventive measures. First, traffic will be
restricted to the temporary crushed stone road; plastic pennants or streamers
will be used to mark the sides of the road to facilitate compliance. Second,
62
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the paved curb cut at 4th Street will be manually cleaned (using a hose and
push broom) of rock and dirt at least twice per work day (e.g., at noon and at
quitting time). Furthermore, operations will cease in the event of a spill or
large amount of trackout until access area has been cleaned. This combination
of controls is estimated as having an efficiency of 70% compared to uncon-
trolled trackout from an unimproved travel surface. Seventy percent effi-
ciency corresponds to a controlled emission rate of 44 lb/day.
In summary, the controlled PM10 emission rate for this example is 3.6 +
1.5 + 44 = 49 lb/day. When compared to the 160 lb/day uncontrolled value, it
is seen that the overall efficiency of the proposed control plan is estimated
to be 69%.
Finally, it should be noted that, because new construction activities
will take place at this site, no provisions to stabilize the exposed area have
been included in this dust control plan.
63
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SECTION 5
REFERENCES
1.
Environmental Protection Agency.
Factors (AP-42). Research
September 1988.
Compilation of Air Pollution Emission
Triangle Park, North Carolina.
2.
Cowherd, C., G. E. Muleski, and J. S. Kinsey. Control of Open Fugitive
Dust Sources. EPA-450/3-88-008, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. September 1988.
3.
Climatic Atlas of the United States.
Washington, D.C. June 1968.
U.S. Department of Commerce,
4.
Environmental Protection Agency. User's Manual for the PM-10 Open
Fugitive Dust Source Computer Model Package. EPA-450/3-90-010. Research
Triangle Park, North Carolina. April 1990.
64
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