United States Air And Radiation EPA 340/1-89-007
Environmental Protection (EN-341) October 1989
Agency
&EPA Inspection Manual For PM-10
Emissions From Paved/
Unpaved Roads And
Storage Piles
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Inspection Manual for
PM-10 Emissions From Paved/
Unpaved Roads and Storage Piles
Final Report
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Stationary Source Compliance Division (EN-341)
401 M Street, SW
Washington, D.C. 20460
Attn: Mr. Robert Marshall, Jr.
EPA Contract No. 68-02-4463
Work Assignment No. 17
MRI Project No. 8911-1(17)
October 27,1989
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PREFACE
This report was prepared for the U.S. Environmental Protection Agency's
Stationary Source Compliance Division under Contract No. 68-02-4463, Work
Assignment No. 17. Mr. Robert Marshall, Jr. was the EPA Work Assignment
Manager. The work was performed in Midwest Research Institute's Environmental
Systems Department (Dr. Chatten Cowherd, Director). The report was prepared
by Mr. John Kinsey (Task Leader), Ms. Deann Hecht, and Mr. Frank Pendleton.
Approved for:
MIDWEST RESEARCH INSTITUTE
Chatten Cowherd, Director
Environmental Systems Department
October 27, 1989
ii
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CONTENTS
Page
Preface i i
Fi gures i v
Tabl es vi i
1. Introduction 1-1
1.1 General overview 1-1
1.2 Scope and objectives of inspection manual 1-2
2. Inspection Overview 2-1
2.1 Introduction 2-1
2.2 Baseline inspections 2-6
2.3 Typical permit conditions 2-9
2.4 Record keeping 2-14
2.5 Sampling and analysis techniques 2-15
2.6 Equipment preparation 2-16
2.7 Safety considerations 2-17
2.8 References for Section 2 2-22
3. Paved Roads 3-1
3.1 Public paved roads 3-8
3.2 Industrial paved roads 3-13
3.3 Regulatory formats and associated inspection
procedures 3-17
3.4 References for Section 3 3-26
4. Unpaved Roads 4-1
4.1 Emissions estimation 4-1
4.2 Emission control methods 4-7
4.3 Regulatory formats and associated inspection
procedures 4-9
4.4 References for Section 4 4-35
5. Storage Piles 5-1
5.1 Estimation of emissions 5-1
5.2 Emissions control methods 5-9
5.3 Regulatory formats and associated inspection
procedures 5-14
5.4 References for Section 5 5-26
Appendices
A. SIP requirements for the control of PM10 A-2
B. Overview of clean air act authority for inspectors B-l
C. Inspectors responsibilities, safety procedures, and
preparati on C-1
D. Summary of state methods for determining visible emissions
from open dust sources D-l
E. EPA Reference Method 22 for visual determination of
fugitive emissions E-l
F. Material sampling and analysis procedures F-l
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FIGURES
Number Page
3-1 Example facility map with roads divided into road segments 3-3
3-2 Sampling data form for paved roads 3-5
3-3 Example pneumatic traffic count log 3-6
3-4 Example manual traffic count log 3-7
3-5 Photo of a vacuum street sweeper 3-16
3-6 Example inspection form 3-18
3-7 Possible use of "action levels" to trigger paved road
control s 3-20
3-8 Meteorological data log for example facility X 3-24
3-9 Operator's log for example facility X 3-25
4-1 Example facility map with roads divided into road segments 4-2
4-2 Example pneumatic traffic count log 4-5
4-3 Manual traffic count log 4-6
4-4 Mean annual number of days with at least 0.01 in of
precipittion 4-8
4-5 Water truck treating a mine haul road 4-10
4-6 Example inspection form 4-13
4-7 Procedures for obtaining manual traffic mix and material
samples 4-14
4-8 Annual evaporation data for the contiguous United States 4-17
4-9 Watering control effectiveness for unpaved travel surfaces 4-18
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FIGURES (continued)
Number Page
4-10 Example water application log 4-20
4-11 Meteorological data log for example facility X 4-22
4-12 Operator's log for example facility X 4-23
4-13 Watering control effectiveness for unpaved road D in example
problem 4-26
4-14 Average PM10 control efficiency for chemical suppressants 4-28
4-15 Typical form for recording delivery of chemical dust
suppressants 4-30
4-16 Typical form for recording chemical dust suppressant control
parameters 4-31
4-17 Example chemical suppressant application log 4-32
4-18 Example completed log 4-33
5-1 Map of example facility X 5-3
5-2 Map of storage piles located within facility X 5-4
5-3 Typical storage pile emission sources 5-5
5-4 Mean wi nd speed 5-6
5-5 Fastest mile of wi nd 5-8
5-6 Sample inspection form . 5-15
5-7 Operator's log for example facility X 5-18
5-8 Meteorological data for example facility X 5-20
5-9 Operator's log for example facility X 5-25
F-l Location of incremental sampling sites on an unpaved road F-2
F-2 Data form for unpaved road sampling F-4
F-3 Unpaved road sampling F-5
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FIGURES (continued)
Number Page
F-4 Location of Incremental sampling sites on a paved road F-6
F-5 Data form for paved road sampling F-7
F-6 Paved road sampling procedures F-8
F-7 Data form for storage pile sampling F-10
F-8 Sample dividers (riffles) F-12
F-9 Coning and quartering F-13
F-10 Example moisture analysis form F-17
F-ll Example silt analysis form F-18
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TABLES
Number Page
2-1 Generic categories of open dust sources 2-2
2-2 Correction parameters for AP-42 emission factor models 2-3
2-3 Fugitive dust reference documents 2-8
2-4 General checklist for conducting an inspection of fugitive
sources 2-10
2-5 Recommended inspection and safety equipment 2-16
3-1 Selection of paved road emission factor 3-2
3-2 Summary of silt loadings (sL) for paved urban roadways 3-9
3-3 Paved urban roadway classification 3-9
3-4 Measured efficiency values for paved road controls 3-10
3-5 Estimated PM10 emission control efficiencies 3-10
3-6 Nonindustrial paved road dust sources and preventive
control s 3-12
3-7 Industrial paved road silt loadings 3-14
4-1 Typical silt content values of surface material on industrial
and rural unpaved roads 4-4
4-2 Control techniques for unpaved travel surfaces 4-7
4-3 Chemical stabilizers 4-11
5-1 Typical silt and moisture content values of materials at
various industries 5-10
5-2 Threshold friction velocities—Arizona sites 5-11
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TABLES (continued
Number Page
5-3 Threshold friction velocities—industriaT aggregates 5-12
5-4 Control techniques for emissions from storage piles 5-12
D-l Summary of TVEE Ml requirements D-3
D-2 Summary of Ohio Draft Rule 3745-17-(03)(B) D-6
F-l Moisture analysis procedure F-15
F-2 Silt analysis procedures F-16
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SECTION 1
INTRODUCTION
1.1 GENERAL OVERVIEW
The Clean Air Act (CAA) of 1970 (and amended in 1977). was passed "to
protect and enhance the quality of the Nation's air resource so as to promote
the "public health and welfare and the productive capacity of its popula-
tion." More specifically, the CAA provides the U.S. Environmental Protection
Agency (EPA) with the broad responsibility and authority to implement a
federal program to achieve these goals.
The interstate nature of air pollution caused Congress to charge the EPA
with the responsibility of establishing uniform national ambient air quality
standards (NAAQS) to assure consistency in protecting public health and
welfare. These standards were set for those pollutants which the adminis-
trator identified as widespread (emitted by numerous or diverse mobile and
stationary sources) and endangering public health and welfare. These so-
called "criteria" pollutants come from the fact that the CAA (Section 108)
requires the EPA to issue Air Quality Criteria Documents for each pollutant
having an ambient air quality standard.
Through July of 1987 the EPA has identified seven criteria pollutants and
promulgated national ambient air quality standards for: particulate matter,
sulfur oxides, nitrogen oxides, carbon monoxide, hydrocarbons (revoked in
January 1983), ozone, and lead. Of interest in this document is the NAAQS for
PM10 promulgated on July 1, 1987. The NAAQS for PM10 specifies a 24 h primary
and secondary standard of 150 yg/m3 and an annual primary and secondary
standard of 50 vg/m* (calculated as an annual arithmetic mean).
To attain and subsequently maintain the NAAQS for PM10, each state is
required to adopt and submit to EPA a plan providing for the implementation,
maintenance, and enforcement of the standards over the entire state. Each SIP
includes a major portion devoted to emission limitations and other regulations
and programs to prohibit stationary sources from "emitting any air pollutant
in amounts which will prevent attainment with the NAAQS or interfere with mea-
sures to prevent significant deterioration of air quality" (see Part C of
Title 1 of CAA). Thus, each state directs its control regulations towards its
unique set of sources and circumstances as long as the end result will be
attainment of the NAAQS in the required time frame. An overview of SIP
requirements for the control of PM10 is contained in Appendix A.
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Collection of compliance-related information is used to determine
compliance of sources with applicable regulations, to identify sources which
may be in violation, and to provide evidence to support enforcement actions.
The primary method of compliance monitoring is the on-site inspection. Under
the CAA, authority has been granted to inspectors for the determination of
compliance with applicable standards and regulations. This authority, under
Section 114 of the CAA, is described briefly in Appendix B.
1.2 SCOPE AND OBJECTIVES OF INSPECTION MANUAL
This manual outlines the basic procedures necessary to complete an
informative and accurate air compliance inspection for sources of fugitive
PM10. In addition, it addresses other topics relevant to the on-site
inspection and compliance monitoring including the selection of sources for
inspection, record keeping and reporting reviews, inspection safety, and
technical inspection procedures. The role of opacity measurements is also
briefly addressed. However, record keeping is primarily emphasized. An
overview of the inspector's general responsibilities, safety, and preparations
is provided in Appendix C with more detailed information on specific sources
contained in subsequent sections.
The information in this inspection guide is based, in part, on a previous
EPA document, "Control of Open Fugitive Dust Sources," EPA 450/3-88-008.
Information useful to the inspector may also be found in that document. It
provides examples for computing both controlled and uncontrolled PM10
emissions, potential regulatory formats, and additional information on various
control techniques.
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SECTION 2
INSPECTION OVERVIEW
2.1 INTRODUCTION
This section provides an overview of the key elements that together
constitute a set of inspection procedures for fugitive sources. First, an
introduction to fugitive dust sources, emissions, and controls is presented.
The section then discusses baseline inspections, typical permit conditions for
roads and storage piles, applicable record-keeping procedures, and sampling
and analysis methods for aggregate materials. Finally, field equipment and
on-site health and safety considerations are addressed.
2.1.1 Fugitive Dust Sources
Sources of fugitive particulate emissions may be separated into two broad
categories—process sources and open dust sources. Process sources of
fugitive emissions are those associated with industrial operations that alter
the chemical or physical characteristics of a feed material. Open dust
sources are those that entail generation of fugitive emissions of solid
particles by the forces of wind or machinery acting on exposed materials.
Only open dust sources are discussed in this document.
The partially enclosed storage and transfer of materials to or from a
process operation do not fit well into either of the two categories of fugi-
tive particulate emissions defined above. Examples are partially enclosed
conveyor transfer stations and front-end loaders operating within buildings.
Nonetheless, partially enclosed materials handling operations will be classi-
fied in this manual as open sources.
Open dust sources include both industrial sources of particulate
emissions associated with the transport, storage, and transfer of raw,
intermediate, and waste aggregate materials, as well as nonindustrial sources
such as unpaved roads and parking lots, paved streets and highways, heavy
construction activities, building demolition, and agricultural tilling.
Generic categories of open dust sources are listed in Table 2-1.
There is a wide variety of industrial facilities that contain fugitive
PM10 sources. Examples of industrial operations which could be evaluated by
an inspector include asphalt plants, cement plants, mines and processing
facilities, concrete ready-mix plants, power plants, quarries and rock
products plants, slag processing plants, steel mills, transfer terminals,
building demolition, and landfills.
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TABLE 2-1. GENERIC CATEGORIES OF OPEN DUST SOURCES
1. Unpaved Travel Surfaces
• Roads
• Parking lots and staging areas
• Storage piles
2. Paved Travel Surfaces
• Streets and highways
• Parking lots and staging areas
3. Exposed Areas (wind erosion)
• Storage piles
• Bare ground areas
4. Materials Handling and Storage
•Batch drop (dumping)
• Continuous drop (conveyor transfer, stacking)
• Pushing (dozing, grading, scraping)
5. Building Demolition
6. Transfer Terminals
• Ship loading and unloading
• Rail facilities
Although the types of sources found in industrial and urban settings are
generally similar (e.g., an unpaved road found in sand and gravel plant and an
unpaved city street), the quantity of emissions generated and the type(s) of
control applied may be quite different. Therefore, the inspector is cautioned
to evaluate each source on an individual basis.
2.1.2 Particulate Emission Factor Models
In developing particulate control strategies for "traditional" pollutant
concerns (i.e., to meet National Ambient Air Quality Standards [NAAQS]),
particulate emissions from open sources are estimated using the predictive
emission factors presented in Section 11.2 of EPA's "Compilation of Air
Pollutant Emissions Factors" (AP-42).i Further details on these emission
factors can be found in the EPA document entitled, "Control of Open Fugitive
Dust Sources," EPA 450/3-88-008. These factors cover the generic source
categories:
Unpaved travel surfaces
Paved travel surfaces
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Exposed areas (wind erosion)
Materials handling
These emission factors share many common features. For example, the
models are formulated as empirical expressions that relate variations in
emission factor (e) to differences in the physical properties (p) of the
material being disturbed and the mechanical energy (m) responsible for the
generation of particulate according to the general form:
= Kpamb
(2-1)
As empirical models, open dust source factors have adjustable coefficients
(K,a,b) that reflect relationships determined from actual open dust source
testing. Table 2-2 provides the correction parameters used in the emission
factor models published in AP-42 for the above open dust sources.
TABLE 2-2. CORRECTION PARAMETERS FOR AP-42 EMISSION FACTOR MODELS*
Source category
Model parameter
Units of measure
Unpaved roads
Paved roads
Exposed areas
Materials handling
Silt content of a surface material
Mean vehicle speed
Mean vehicle weight
Mean No. of wheels
No. of wet days per year
Silt content of a surface material
Total surface dust loading
No. of disturbances per year
Erosion potential
Mean wind speed
Material moisture content
Weight %
km/h (mph)
Mg or 106 g
(tons)
Dimensionless
Dimensionless
Weight %
kg/km 2 (Ib/mi*)
Dimensionless
m/s (mph)
Weight %
a From Reference 1.
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2.1.3 Preventive and Mitiqatlve Control Options
Typically, there are several options for control of fugitive participate
emissions from any given source. This is clear from the mathematical equation
used to calculate the emissions rate:
R = A e (1 - c) (2-2)
where: R = estimated mass emission rate
A = source extent (i.e., surface area for most open dust sources)
e = uncontrolled emission factor, i.e., mass of uncontrolled
emissions per unit of source extent
c = fractional efficiency of control
To begin with, because the uncontrolled emission rate is the product of the
source extent and uncontrolled emission factor, a reduction in either of these
two variables produces a proportional reduction in the uncontrolled emission
rate.
Although the reduction of source extent results in a highly predictable
reduction in the uncontrolled emission rate, such an approach in effect
usually requires a change in the process operation. Frequently, reduction in
the extent of one source may necessitate the increase in the extent of
another, as in the shifting of vehicle traffic from an unpaved road to a paved
road.
In the case of open sources, the reduction in the uncontrolled emission
factor may be achieved by adjusted work practices. The degree of the possible
reduction of the uncontrolled emission factor can be estimated from the known
dependence of the factor on source conditions that are subject to alteration.
For open sources, this information is embodied in the predictive emission
factor equations for fugitive dust sources as presented in Section 11.2 of
EPA's "Compilation of Air Pollutant Emission Factors" (AP-42).1
Control techniques can be divided into two broad categories—preventive
and mitigative. Although differences between the two are not always clear, in
general, preventive measures involve techniques that reduce source extent or
improve mechanical source operations relative to the generation of particulate
emissions. By contrast, mitigative techniques typically focus on altering the
surface/material conditions that constitute the source of particulate
emissions.
The reduction of source extent and adjusted work practices which reduce
the amount of exposed dust-producing material are preventive techniques for
control of fugitive dust emissions. This would include, for example, the
elimination of mud/dirt carryout onto paved roads at construction and demoli-
tion sites.
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On the other hand, mitigative measures involve the periodic removal of
dust-producing material. Examples of mitigative measures include cleanup of
spillage on travel surfaces (paved and unpaved) and cleanup of material
spillage at conveyor transfer points.
Most of the mitigative control measures for open sources involve periodic
rather than continuous control application. Familiar examples are the water-
ing of unpaved travel surfaces and the cleaning of paved travel surfaces. The
resultant control efficiency follows a cyclic pattern, decaying in time from
the highest value immediately after application. Because of the finite
durability of these control techniques, ranging from hours to months, it is
essential to relate an average efficiency value to a frequency of
application. It must be emphasized that the rate of control efficiency decay
is heavily dependent upon the source and control variables discussed in
Sections 3, 4 and 5.
2.1.4 Compliance Determination
There are three general compliance formats that are potentially suited to
open dust sources. These are:
a. opacity (visible emissions) readings;
b. evaluation of control program records—record keeping; and
c. "indirect" determination(s) of control performance.
These formats are described briefly below.
As a compliance tool, the determination of visible emissions (VE) has a
long history of application to stationary sources. VE readings appear
appealing as a compliance tool for open dust sources; in fact, two states
(Tennessee and Ohio) as well as EPA have promulgated VE methods for open dust
sources. A summary of the state methods is presented in Appendix D with EPA
Reference Method 22 provided in Appendix E.
Record keeping offers another, easily used compliance tool for fugitive
PM10 controls. As the name implies, record keeping involves the routine
collection and recording of appropriate control application parameters
(especially for periodically applied measures) by the source operator for the
permitted sources at the facility. These application parameters are generally
specified as part of a formal dust control plan and are critical to achieving
a certain level of control performance. The level of detail needed for record
keeping purposes varies with the control option employed. Record keeping,
together with on-site inspections, as required, will allow the regulator to
estimate performance of a dust control program.
While record keeping affords a convenient method of assessing long-term
control performance, it is important that regulatory personnel have "spot-
check" compliance tools at their disposal. For example, permit conditions
could be written specifying a minimum surface moisture content (thus, cor-
responding to a minimum control efficiency) to be maintained on an unpaved
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surface which is watered or treated with surfactants or salts. Inspection
personnel would then collect grab samples for moisture analysis to determine
compliance following the procedures discussed later in this section. This
technique is referred to as an "indirect" performance standard which is
enforced in lieu of actual source testing.
2.2 BASELINE INSPECTIONS
The purpose of this section is to describe the Baseline Inspection Tech-
nique and illustrate how it should be applied to the common types of fugitive
dust sources. The Baseline Technique is an approach which inspectors can use
to obtain relevant data in an organized fashion. These procedures are
organized into four categories that roughly correspond to increasing levels of
effort. The inspection procedures have been developed to ensure that the data
obtained are as accurate and complete as possible. The procedures outlined
should be used by field personnel unless technical or safety considerations at
a specific site demand modified approaches. In such a case the reasons for
the deviation from the standard procedures should be briefly described in the
inspection report.
2.2.1 Inspection Categories
It would be desirable to conduct detailed engineering-oriented inspec-
tions at all sources, however, this is obviously impractical due to the large
number of sources inspected regularly by EPA, state, and local regulatory
personnel. Therefore, inspection categories have been incorporated into the
overall inspection program to give agencies the opportunity to properly allo-
cate limited resources. The most complete and time-consuming evaluations are
performed only when preliminary information indicates the potential for a
significant emission problem.
Inspection categories are designated as Levels 1 through 4 with the
intensity of the evaluation increasing from one to another. The types of
activities normally associated with each level and the experience necessary to
conduct the different types of inspections vary substantially. The four
categories are:
Level 1 inspection is a field surveillance tool intended to provide
relatively frequent, but very incomplete indications of source per-
formance. No entry to the plant grounds is usually necessary, and
the inspection is never announced in advance. The inspector makes
observations on all sources which are visible from the plant bound-
ary and which can be properly observed, given prevailing meteoro-
logical conditions. To the extent possible, general plant
operations are observed to determine whether they correspond to
permit requirements.
Level 2 inspection is a limited "walk-through" evaluation of the
source and its control(s). Entry to the facility is necessary.
Therefore, appropriate administrative inspection procedures
(Appendix C) should be followed. The inspection can be performed
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either in a concurrent (i.e., with the process flow) or counter-
current fashion depending on the anticipated types of problems. In
either case the inspection data gathered is limited to that which
can be provided by readily available existing information.
Level 3 inspection includes a detailed evaluation of individual
emission sources, types of control techniques employed, source oper-
ation, and identification of potential problem areas. Source mate-
rial analyses may be reviewed and samples obtained for later evalua-
tion. Control techniques and application parameters would also be
identified for further engineering analysis. Sufficient data and
documentation is also obtained on-site to ascertain if control
procedures are being followed as specified by permit or regulatory
requirements.
• Level 4 inspection involves the observation of a source test(s) or
evaluation of an on-site air quality monitoring program specifically
intended to measure control performance. This is a very specialized
inspection and should be conducted with full knowledge of the
source/control specifications being evaluated. This type of
inspection is performed explicitly for the purpose of determining
compliance with permit conditions, regulations, and/or site-specific
dust control plans.
An important part of the level 3 inspection is the preparation of general
material flow charts and site plans. It is recommended that these be prepared
in accordance with the guidelines presented in Reference 2. As a starting
point, the inspector should request a map of those portions of the plant of
interest. Specific flow charts should be prepared so that all of the
important information concerning material flow streams, traffic flow and
volumes, and locations of all stationary equipment and material storage areas
are clearly shown. These charts then are used to perform the on-site
inspection.
2.2.2 Assembling Background Information
The inspector's knowledge of the source(s) and the associated controls at
a facility plays an important part in the success of an inspection, particu-
larly in the diagnosis of control problems. It is, therefore, highly recom-
mended that the inspector build his or her own and/or an agency technical
library of books, reports, guideline documents, and other publications related
to the inspection process. This should include materials addressing specific
dust-emitting sources, operation and maintenance of all types of controls, and
specific inspection procedures for various types of controls and dust sources.
To assist in assembling background information, Table 2-3 provides a list
of useful references involving the control of fugitive dust and PM10.
Although this list is not all-encompassing, these documents should definitely
be available to regulatory personnel prior to making an inspection of an
unfamiliar facility or source.
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TABLE 2-3. FUGITIVE DUST REFERENCE DOCUMENTS
U.S. Environmental Protection Agency. 1988. Compilation of Air Pollutant
Emission Factors, AP-42. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina.
Grelinger, M. A. 1988. Gap Filling PM10 Emission Factors for Selected Open
Area Dust Sources. EPA-450/4-88-003, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina.
Cowherd, C., G. E. Muleski, and J. S. Kinsey. 1988. Control of Open Fugitive
Dust Sources. EPA-450/3-88-008. U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. September.
Cowherd, C., Jr., and J. S. Kinsey. 1986. Identification, Assessment and
Control of Fugitive Particulate Emissions. EPA-600/8-86-023, U.S. Environ-
mental Protection Agency, Research Triangle Park, North Carolina.
U.S. Environmental Protection Agency. 1982. Control Techniques for Particu-
late Emissions From Stationary Sources—Volumes 1 and 2. EPA-450/3-81-005a
and b, Emission Standards and Engineering Division, Research Triangle Park,
North Carolina. September.
Ohio Environmental Protection Agency. 1980. Reasonably Available Control
Measures for Fugitive Dust Sources. Columbus, Ohio. September.
Guidelines for Development of Control Strategies in Areas With Fugitive Dust
Problems. 1977. OAQPS No. 1.2-071. U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. October.
Climatic Atlas of the United States. 1968. U.S. Department of Commerce,
Washington, D.C. June.
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2.2.3 General Inspection Procedures
Although fugitive dust control measures are generally implicit in federal
air quality regulations, the regulations generally do not explicitly include
readily enforceable standards of performance. However, a number of states
have (as part of their State Implementation Plans [SIPs] for PM10) developed
and adopted rules to control fugitive dust emissions. These rules are
enforceable by either state, local, or federal air pollution control
officials. Clearly, a portion of a general air compliance inspection should
be devoted to identifying potential sources of fugitive dust emissions and the
collection of data indicative of a source's compliance status with regard to
applicable permit conditions and regulations.
As is the case for other types of emission sources, the inspector should
be familiar with potential sources of fugitive PM10 at the plant and
applicable state/local/federal regulations and permit requirements. Preentry
evaluation from outside the plant (i.e., level 1 inspection) is particularly
important in regard to fugitive sources. During this evaluation, the inspec-
tor should identify and note any visible fugitive emissions at or near plant
boundaries and their source(s); conditions around feed, product, and/or waste
storage piles; and any other obvious sources of fugitive emissions. Notations
of any visible emissions and photographs should be taken at this time, as
appropriate.
The portion of the fugitive emissions inspection which is conducted
within the plant boundaries (level 2, 3, and 4 inspections) generally consist
of four phases:
1. Visual inspection of the facility in order to observe fugitive
sources and controls (including photographs to document).
2. Examination of the source's control equipment.
3. Observations of any spraying or other dust control operations under-
taken by source during the inspector's visit.
4. Examination of the source's records relating to the controls used.
A general checklist similar to that shown in Table 2-4 should be used as
a reminder of key information to be collected by the inspector during a
level 2 evaluation. This list should be refined according to the specific
goals of the inspection during subsequent visits and can be arranged in chart
formats, if desired. Also, the compliance formats described below should be
incorporated into the inspection, as applicable.
2.3 TYPICAL PERMIT CONDITIONS
Specific conditions placed on an air permit for open dust sources depend
to a large extent on the type of source being permitted as well as the statute
and regulations under which the permit is issued. Also, permit conditions
will depend on whether the permit is included in revisions to a State Imple-
mentation Plan, which are subsequently enforceable by EPA personnel.
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TABLE 2-4. GENERAL CHECKLIST FOR CONDUCTING AN INSPECTION OF
FUGITIVE SOURCES
Name of facility:
Address:
Type of facility or SIC code:
VISUAL INSPECTION
1. Are all points listed in current permit/control plan still existent?
2. Are there additional points that are not noted in the files? If so,
please note each new point.
3. For each source, note the type of control being applied (reference to map
or plot plan and/or process diagram).
Source ID:
Type of material processed:
Type of control:
Source ID:
Type of material processed:
Type of control:
Source ID:
Type of material processed:
Type of control:
(continued)
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TABLE 2-4 (continued)
Source ID:
Type of material processed:
Type of control:
Source ID:
Type of material processed:
Type of control:
4. Does control equipment and/or control measure(s) match the information in
the current permit file? If not, specify.
5. Does control equipment appear to be well maintained? If not, note that
equipment which does not.
6. Is there evidence that the source can and does make repairs to control
equipment? Specify.
INFORMATION FROM SOURCE FILES
1. Does the source have the current permit (and emissions control plan, if
applicable) on file and available for inspection?
2. Is source operator aware of applicable regulations, permit conditions,
and/or control plan specifications under which operation is per-
mitted?
(continued)
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TABLE 2-4 (continued)
3. Has a regular staff member been assigned to implementation of the control
plan?
4. Does a budget exist for implementation of the control plan?
5. Are permanent facility records being kept in accordance with permit or
control plan? If not, what are the deficiencies?
6. Is ambient air monitoring being conducted near the facility?
How is the monitoring equipment cited relative to fugitive sources?
7. The person to contact regarding fugitive emissions control at facility
is: Telephone No.:
INSPECTOR'S NAME: DATE OF INSPECTION:
TIME OF INSPECTION: REINSPECTION DATE:
2-12
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Because of the wide diversity in permit systems, it is difficult to
present "typical permit conditions which apply to all types of generic open
dust sources. Therefore, in this section, example conditions will be
presented as a guide to the inspector as they may appear on an air permit for
a fugitive dust source.
In general, permits for open sources are issued either in response to
ambient air quality violations (e.g., sources in nonattainment areas) or,
where air quality meets applicable standards, are directed to aesthetic,
nuisance, or similar considerations. Where ambient air violations are
present, the dust control strategy implemented by the source operator must be
very specific. Control application parameters must be rigorously adhered to
in order to achieve overall reductions in PM10 emissions and thus expected
improvements in ambient air quality in the area where the plant is located. A
formal schedule and methods of application must be established for each source
and control method applied; this is especially true for periodically applied
controls used on sources such as paved and unpaved roads.
As mentioned in Section 2.1.4, compliance with a permit condition can be
determined either by record keeping or some type of indirect performance
standard based on sampling and analysis of the sources material. An example
permit condition for sources in areas with air quality problems using record
keeping as a measure of compliance might be:
"Within 90 days of issuance of this permit, the plant operator
will submit to the Department a fugitive dust control plan for the
following sources .... This plan shall include sufficient
information to determine the control technique to be used for each
emission source, the application parameters for these controls,
and the expected level of reduction achieved. Within thirty days
after plan submittal, the Director will notify the permittee of
plan acceptance of, if found unacceptable, any deficiencies to be
corrected. Revisions to the dust control plan shall then be
submitted to the Department within 30 days following plan rejec-
tion. Appropriate plant records will be kept and submitted to the
Department on a monthly basis to verify compliance with the dust
control plan."
For sources where indirect measures are used to determine compliance, a permit
condition similar to the following might be appropriate:
"Within 90 days of issuance of this permit, the plant operator
will submit to the Department a dust control plan for the fol-
lowing sources .... This plan shall include sufficient infor-
mation to determine the type of control used for each source, the
applicable control application parameters, and specific perfor-
mance goals for each source/control combination. Control perfor-
mance goals shall be specified in the plan in terms of key source
material characteristics (e.g., moisture content) which can be
verified by on-site sampling and subsequent laboratory
analysis . . . ."
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For permits issued for aesthetic, nuisance, or similar considerations
where air quality is not a problem, a dust control plan should also be
submitted by the source operator. However, in this particular case, some
amount of discretion is usually allowed to maintain the dust emissions leaving
the site to within some allowable limit. This type of permit is much harder
for the inspector to enforce but, if properly handled, can result in adequate
dust control. Again, periodically applied controls should be formalized to
the extent possible.
For areas where air quality is not an immediate concern, the following
could appear on an operating permit for an open dust source:
"Within 90 days of issuance of this permit, the plant operator
will submit the to Department a dust control plan for the follow-
ing sources .... The control measures included in this plan
shall be sufficient to preclude dust emissions from leaving the
site as determined visually by Department personnel. If, upon
inspection, the dust control plan is determined to be inadequate,
a revised control plan will be submitted to the Department within
30 days of the inspection . . . ."
Many variations of the above are also possible depending on the statute and
regulations in force at the time the permit is issued.
2.4 RECORD KEEPING
As stated previously, record keeping is one alternative method to
determine compliance in lieu of an actual performance standard. To implement
this technique, records of site activity and control should be submitted to
the regulatory agency on a monthly basis. These records must be certified by
a responsible party as to their accuracy and completeness. All site records
should be maintained by the agency on a permanent basis.
To enforce the permit conditions and/or dust control plan, field audits
of key control parameters should be made by inspection personnel.. The results
of these audits would then be compared to site records submitted to the agency
for that period to determine compliance. If differences are found between
application of the control(s) observed on-site and those recorded by facility
operating personnel, this would constitute a violation and would be grounds
for enforcement action. To illustrate this process, an abbreviated example
will be given as applied to a typical building demolition project.
Assume a large demolition project consisting of the demolishing of a
block of buildings is to be conducted in a large metropolitan area. The site
dust control plan calls for watering of all truck routes to and from the
active demolition every 2 h as well as cleanup of mud/dirt carryout from the
access point on a twice-daily basis. Also, watering of debris during demoli-
tion and loadout to haul trucks is to be conducted on days without measurable
rainfall. An agency inspector observes the site activity from the public
street (Level 1 inspection) for a period of 3 h. During this period no water
truck is observed to be in operation, and debris are not watered prior to
loading into trucks.
2-14
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At the end of the month the inspector checks the submlttal from the site
operators and finds start and stop times for the water truck operator which
indicates operation during the observation period. The inspector also notes
that the water cannon used for debris control was broken down and was in a
repair shop. It is clear from this analysis that the operator is in violation
of the dust control plan for watering of unpaved surfaces. Because the truck
operator did not follow required dust suppression measures (and/or failed to
keep accurate records) an enforcement action could be taken against the site
operator.
As noted by the above example, no quantitative data are required for
enforcement of the dust control plan. This reduces the need for a set per-
formance standard (e.g., opacity limits) against which the site operator is
evaluated. This approach is, however, predicated on the fact that strict
implementation of the dust control plan will achieve certain reductions in
PM10 emissions associated with site operation.
In order to implement record keeping of site control activity, general
guidelines are provided in Sections 3, 4, and 5 for paved roads, unpaved
roads, and storage piles, respectively. These guidelines include only basic
information and should be modified, as necessary, according to the source
being monitored. Other information pertaining to control performance deter-
mination as related to record keeping is provided in Reference 3.
2.5 SAMPLING AND ANALYSIS TECHNIQUES
Sampling and analysis of source material (i.e., road surface and aggre-
gate materials) can be useful for a number of purposes. First, material
charactsristies are generally required to calculate uncontrolled PM10 emis-
sions for most open dust sources and, in some cases, are used to estimate or
verify control effectiveness. For the inspector, material sampling can be
used as an indirect measure of control performance as explained previously in
Section 2.1.4.
In general sampling of road surface material involves the collection of a
composite sample from each road segment being analyzed. For paved roads, this
entails collection of samples across the width of the travel lane using a
portable, stick-type vacuum cleaner equipped with tared collection bags. In
the case of unpaved roads, a whisk broom and dust pan is used in a similar
fashion. Details of these techniques are discussed in Appendix F.
For the sampling of aggregate materials, incremental samples are col-
lected from the top, middle, and bottom of storage piles or from the process
flow itself. A relatively large gross sample is collected in this manner
which is subsequently reduced to laboratory sample which is analyzed. This
technique is further described in Appendix F.
Finally, moisture content is determined in the laboratory by drying each
sample in a laboratory oven with the silt content determined by dry sieving to
obtain the fraction passing a 200 mesh (70 ymP) screen. Details of both
techniques as well as special preparation procedures for paved road samples
are provided in Appendix F.
2-15
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2.6 EQUIPMENT PREPARATION
Part of the preinspection preparation involves obtaining and preparing
inspection and safety equipment. The type of equipment may vary according to
the inspection objectives; the level of inspection; and the process, control
equipment, and safety requirements at the facility itself. A general list of
recommended equipment is provided in Table 2-5.
All equipment should be checked, calibrated, and tested before use. The
inspector is responsible for seeing that all equipment necessary to conduct an
inspection is brought to the inspection site.
Safety equipment required for a facility is based on plant health and
safety requirements. Safety requirements must be met, not only for safety
reasons, but to ensure that the inspector is not denied entry to the facility
or parts of it.
TABLE 2-5. RECOMMENDED INSPECTION AND SAFETY EQUIPMENT
Equipment necessary for
most inspections
Equipment required for
certain inspections
Hard hat
Safety glasses or goggles
Gloves
Coveralls
Safety shoes
Ear protectors
Tape measure
Flashlight
Stopwatch
Duct tape
"NIOSH/OSHA Pocket Guide to
Chemical Hazards"
Rain gear
Respirator with appropriate
cartridge(s)
Air velocity meter
Shovel or scoop
Broom-type vacuum sweeper
Tared vacuum bags and premarked
envelopes
Dustpan and broom
Riffle
Bucket
Sample containers (polyethylene trash
bags and/or screw-top jars)
Self-contained breathing equipment
Rope
As previously stated, Table 2-5 shows a listing of standard inspection
and safety equipment for air compliance inspections. It is recommended that
those items necessary for the majority of inspections (level 2) be carried in
a portable case or tool belt pouch from emission point to emission point. The
appropriate items from the list of "Equipment Required for Certain Inspec-
tions" (levels 3 and 4 and certain safety equipment not normally required)
should be added to the equipment carried or placed in a central location at
the plant or in the inspector's car to be retrieved if needed.
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Before or after equipment preparation, the inspector must also consider
what written materials, forms, documents, etc., he/she will require during the
inspection. These should also be gathered and organized before the inspec-
tion. These materials may include any or all of the following:
Maps
Flow charts
Plant layout
Applicable regulations
Inspection checklists
Field notebook
Field observation data recording forms (e.g., Method 22 data sheets)
Reference materials
Inspection plan or agenda
Credentials
Facility information
Baseline data
Information requested by facility
2.7 SAFETY CONSIDERATIONS
The performance of any field inspection always involves a certain degree
of risk. It is the objective of this section to describe means of minimizing
this risk through adherence to safety procedures. Procedures are presented
for most common health and safety problems encountered during the evaluation
of fugitive sources and controls. The official EPA Health and Safety Policy
can be found in Reference 2.
2.7.1 General Considerations
The inspection of any plant, industrial facility, mine, etc., inherently
involves a large number of potential health and safety problems which occur
frequently. Therefore, the inspector must be constantly alert so as to avoid
potentially hazardous situations.
Inhalation hazards are often created by leaks of pollutant laden gases
out of worn expansion joints, cracked welds, and corroded shells of process
equipment. The sudden downdraft from nearby stacks and vents can also lead to
acute exposures. The partially confined areas can allow high concentrations
of toxic material to accumulate even when the leak rates are comparatively
small. Most of the high pollutant concentrations occur by accident and
without the knowledge of plant personnel. The highly variable conditions make
any exposure monitoring data highly questionable. These problems complicate
the selection of the proper respirator for these conditions.
The elevated and isolated locations of many types of process equipment
also increases the safety risk. It may be necessary to climb permanent or
portable ladders to reach the equipment. In some cases, the equipment can
only be reached by crossing roofs or elevated walkways. Since these portions
of the plant are not regular work areas, even the plant personnel may not be
aware of some of the potential problems involved with the ladders and roof
areas. Frequently cables, hoses, and debris are found along the elevated
2-17
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platforms and roofs since plant maintenance personnel do not remove this
material. Injuries which occur in these portions of the plant can be very
serious. Rescue of injured personnel is difficult and time consuming due
again to the isolated and elevated locations of control equipment.
Due to the numerous potential hazards, it is very important that each
inspector adhere to established safety policies and procedures. _ It is also
necessary that the inspector recognize unusual and extreme conditions which
warrant additional or extreme safety precautions.
To minimize the risk of potential hazards, each inspector should follow
the general rules summarized below:
1. The work should be halted immediately when the inspector suffers any
nonspecific symptoms of exposure. The area should be approached again only
after the proper personal protective equipment has been obtained.
2. The work should be conducted at a controlled pace.
3. If the work cannot be accomplished safely, it should be postponed
until the appropriate steps are taken to permit safe inspection.
4. Nothing should be done which risks the health and safety of the
inspector, plant personnel, or which risks the conditions of plant
equipment.
5. All agency and plant safety requirements must be satisfied at all
times.
2.7.2 Specific Safety and Health Procedures
2.7.2.1 General Safety Procedures—
The following general procedures should be adhered to while conducting an
inspection:
1. Personal Protective Equipment—Inspectors should bring personal
protective equipment necessary to conduct the inspection of the facility. All
personal protective equipment should be in good working order and the inspec-
tor using it should be trained in its use and limitations.
2. Unaccompanied Inspections—The inspector should request that a
responsible plant representative accompany him at all times. The plant
representative can identify areas known to be unsafe and can warn the inspec-
tor about intermittent plant operations which can result in health and safety
risks.
3. Warning Codes and Sirens—The inspector should learn the warning
codes and sirens used at the plant to indicate blasting or emergencies such as
plant fires, etc. The inspector and plant representative should move to a
safe location as rapidly as possible after hearing the warning sirens and
report in to the appropriate authorities so >that no attempt is made to
"rescue" them from the affected area.
2-18
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4. Personnel Rescue—If an inspector observes another individual who
has suffered an accident, help must be summoned immediately. Attempting to
rescue the person can jeopardize the rescuer unless the proper procedures are
used. Rescue should be attempted only if the proper equipment is available to
ensure the safety of the rescuer.
5. Inclement Weather Conditions—Except in the case of public health
emergencies, field activities should be interrupted or postponed whenever
severe weather conditions present a significant safety risk to the inspector.
The specific criteria for interrupting or postponing the field activities
should be determined by each office. As a general guideline, work should be
delayed whenever: the ambient temperature is less than -20°F (wind chill);
the ambient temperature is greater than 100°F; the wind speed is greater than
25 mph; and/or whenever there are sleet and freezing rain conditions.
2.7.2.2 Walking and Climbing Hazards-
Inspectors should wear hard hats at all facilities being inspected.
These hats provide protection against collision with overhead beams and pro-
truding obstacles and also provide limited protection against falling objects.
Inspectors should also wear safety shoes approved for the specific type of
facility being inspected and gloves whenever the inspection will involve
climbing of ladders or handling of hot surfaces.
Portions of the facility with potentially slippery surfaces should be
avoided to the extent possible. Inspectors should not use temporary "walk-
ways" such as planks and horizontal ladders. Also, before walking on elevated
catwalks, the inspector should confirm, to the extent possible, that the sup-
ports are intact and have not corroded or rotted.
Accumulations of solids and snow can easily exceed the rated load bearing
capacity of roofs. Also, portions of the roof can be made of materials with
only a limited load bearing capability. For the above reasons, all roofs and
other elevated, horizontal surfaces should be approached cautiously. It is
recommended that inspectors follow plant personnel in such areas and that they
remain on defined walkways.
In climbing any ladder, the foot rungs should be grasped while climbing
even when the rungs are wet or muddy. Under no circumstances should an
inspector attempt to climb a ladder covered with ice or snow. Both hands must
always be free for climbing ladders.
Portable and fixed ladders in good physical condition should be used.
Portable ladders should be inclined on an angle to minimize the chances of
slippage or toppling and must extent above the surface being reached by a
minimum of 3 ft. The cage (if present) must have an opening ranging from
18 to 24 in at the top. The cage should not be severely distorted since this
would prevent easy movement inside. The ladder must have at least 9-in
clearance between it and where it is attached to allow secure placement of the
feet on the rungs and should extent at least 3 ft above the platform or sur-
face being reached. Finally, guard rails should never be used for climbing.
2-19
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While walking through the plant, inspectors must be alert for protruding
obstacles. Often these are difficult to spot in dimly lit portions of plants.
Loose clothing should not be worn when conducting an inspection since this can
result in entrapment in rotating equipment. Inspectors must be cautious when
in the vicinity of all rotating equipment since it is often impossible to see
the components moving at high speed. Equipment which operates intermittently,
such as hoists, should never be touched since this equipment often starts
automatically and without warning.
Inspectors should stay at least 75 ft from stationary rail cars at
sidings since these are sometimes coupled to remote-controlled engines run by
an operator without a complete view of the siding areas. Inspectors should
also not stand on coal piles and other material stockpiles since it is pos-
sible to become entrapped in the conveying equipment which is often underneath
these piles.
2.7.2.3 Eye and Hearing Protection—
Because of the possibility of hazardous chemicals or gases, contact
lenses should not be used during the inspection. Instead, inspection person-
nel should use prescription safety glasses with side shields while performing
field activities. Splash goggles should be used in addition to the safety
glasses whenever there is potential exposure to acid mist and/or liquid
chemicals.
Inspectors should use hearing protection whenever required by plant
policies and whenever it is difficult to hear another person talking in a
normal tone of voice at a distance of 2 ft. To the extent possible, time
spent in areas of the plant with high noise levels should be minimized.
2.7.2.4 Electrical Hazards—
The inspector should not use line powered equipment or instrumentation
not served by an approved ground fault interrupter. Prior to inspecting any
facility, the inspector must ask responsible plant personnel to identify any
high voltage cables in the area to be inspected. It is important to find any
lines which could be inadvertently touched while walking through the plant.
2.7.2.5 Explosions--
Inspectors should never take battery-powered, portable equipment such as
nonexplosion-proof flashlights, etc., into portions of the plant where there
are potentially explosive dusts and/or vapors. The equipment can be a source
of ignition. Also, smoking materials, including but not limited to matches
and lighters, should never be taken into any facility. Many areas of plants
visited by inspectors can have explosive dusts and vapors. Finally, the
inspection should be terminated immediately whenever a severely vibrating fan
is encountered. When a fan disintegrates, shrapnel can be sent over a large
area resulting in very serious injuries. Plant personnel should be notified
immediately if this problem is detected.
2.7.2.6 Burns—
The areas immediately around hot ducts should be avoided to the extent
possible. Also, uninsulated hot roofs should be avoided to the extent
possible. In cases where such is required, the proper foot wear must be
2-20
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worn. When climbing up to potentially hot roofs, gloves should be worn and
the roof should not be touched.
2.7.2.7 Inhalation Hazards--
To the extent possible, inspectors should avoid areas which allow the
accumulation of airborne pollutants. The appropriate respirators should be
selected in accordance with the procedures discussed during safety training
provided by the regulatory agency. Furthermore, the respirator must not be
worn whenever any condition would prevent a good seal. The most common reason
for an improperly fitted respirator is facial hair. The protection factor
limits of each respirator must be understood and used only for the specific
contaminants listed and only for the concentration range listed. Since
monitoring data is rarely available, the inspector must exercise some judgment
when selecting the appropriate respirator. Selection of the type of
respirator should never be done by smell or taste perception since some of the
most toxic pollutants cannot be detected at high concentrations.
Inspectors should use only a self-contained breathing apparatus or an air
line respirator when entering areas believed to be oxygen deficient. Each
individual using respirator protection must be trained in its proper fitting,
use, maintenance, and storage.
The respirator must be inspected before and after each use (disposable
respirators excluded). Equipment used only for emergencies will be inspected
at least monthly. A record should be kept by date with the results of all
inspections. All respirators must be cleaned and disinfected after each
use. All filters and cartridges must be replaced whenever necessary.
Replacement of other than disposable parts and any repair should be done only
by personnel with adequate training and test equipment to ensure the equipment
will function properly after the work is accomplished. Only certified parts
supplied by the manufacturer for the product being repaired shall be used.
The respirators should be stored in atmospheres that will protect them from
dust, sunlight, extreme heat or cold, and damaging chemicals.
Individualized eyeglasses mounted to the face piece of full face mask
respirators should be used whenever such respirators are necessary for the
field duties assigned. Also, contact lenses should not be worn while wearing
respirators. Inspectors with perforated ear drums or who have not demon-
strated, by means of regular physical examination, that they are capable of
withstanding the additional physical stress imposed by respirators, should not
wear respirators. Since respirators are necessary for field activities, such
individuals should not perform field duties. Finally, inspectors should not
chew gum or tobacco while wearing a respirator.
2.7.2.8 Heat Stress--
Each inspector working in moderate and hot climates should drink copious
amounts of water and carry drinking water in the vehicle used. The inspection
should be interrupted immediately whenever an inspector experiences the symp-
toms of heat exhaustion including but not limited to fatigue, nausea, vomit-
ing, headache, dizziness, clammy skin, and rapid pulse. The affected individ-
ual should rest in a cool place which is not less than 75°F and seek medical
care as soon as possible. Continuing the field activities during the onset of
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heat exhaustion can lead to heat stroke, a very serious condition requiring
immediate medical help. Also, the inspection should be interrupted immedi-
ately whenever an inspector experiences heat cramps. The affected individual
should find a cool place to rest and drink water containing 0.1% by weight
salt (1 teaspoon per 5 quarts of water).
2.7.2.9 Cold Stress--
Field inspectors should avoid portions of the plant exposed to high wind
conditions or wet areas when the ambient temperature is low. Clothing for
inspections conducted during cold weather must be selected to provide the
appropriate degree of protection and to reduce the chances of excessive
perspiration accumulation. Clothing should generally be layered to trap heat
and to provide the flexibility to adjust to both outside and inside conditions
while conducting the inspection. Steel-tipped shoes should not be worn when-
ever the ambient temperature is low. All shoes worn must be watertight.
2.7.2.10 Skin Absorbable Chemicals-
Inspection personnel should consult published reference materials con-
cerning the selection and use of protective clothing (including gloves)
whenever working with or near chemicals which are readily adsorbed by the
skin. A partial list of such chemicals is provided in the OSHA Pocket Guide
to Occupational Hazards. Inspectors should also exercise extreme caution when
sampling liquids containing skin absorbable chemicals. Under no circumstances
should the employee allow direct contact between such liquids and the skin
(e.g., hands and arms) while acquiring a sample.
2.8 REFERENCES FOR SECTION 2
1. U.S. Environmental Protection Agency. Compilation of Air Pollutant
Emission Factors, AP-42, U.S. Environmental Protection Agency, Research
Triangle Park, NC. 1988.
2. Segal 1, R. R., et al. Air Compliance Inspection Manual. EPA-340/1-85-
020. U.S. Environmental Protection Agency, Research Triangle Park, NC.
September 1985.
3. 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, NC. September 1988.
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SECTION 3
PAVED ROADS
Particulate emissions occur whenever a vehicle travels over a paved sur-
face, such as public and industrial roads and parking lots. These emissions
may originate from material previously deposited on the travel surface, or
resuspension of material from tires and undercarriages. In general, emissions
arise primarily from the surface material loading (measured as mass of mate-
rial per unit area), and that loading is in turn replenished by other sources
(e.g., pavement wear, deposition of material from vehicles, deposition from
other nearby sources, carryout from surrounding unpaved areas, and litter).
EPA's Compilation of Air Pollutant Emission Factors (AP-42) indicates that the
PM10 emission factors for paved roads may be written in the general form:
e = A ft ° (3-1)
where A, B, and C are constants and
e = PM10 emission factor, mass/vehicle/length
s = fractional surface silt content, dimensionless
L = total surface loading, mass/area
The product sL represents the mass of material less than 200 mesh per unit
area of the road travel surface and is usually termed the "silt loading."
Selection of the appropriate emission factor model (i.e., the constants
A, B, and C) for a given road depends upon:
The value of the silt loading (sL)
• The average weight of the vehicles traveling on the road
Table 3-1 describes the selection process for paved road emission factors.
Note that, for purposes of preparing an emissions inventory, this equation
would be applied to each road segment in a facility. A road segment is the
distance between two intersections. Figure 3-1 shows an example facility with
each road divided into road segments and assigned an arbitrary
identification.
3-1
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TABLE 3-1. SELECTION OF PAVED ROAD EMISSION FACTOR
Silt loading (sL)
g/m2
sL < 2
sL < 2
sL > 2d
2 < sL < 15
sL > 15d
oz/yd2
< 0.06
< 0.06
> 0.06
0.06 < sL < 0.44
> 0.44
Range weight
(W)
Mg
W > 4
W < 4
W > 6
W < 6
W < 6
Ton
> 4.4
< 4.4
> 6.6
< 6.6
< 6.6
Applicable F"M... emission
factor
g/VKTa
220 (sL/12)0'3
n flc
2.28 (sL/0.5)u'°
220 (sL/12)0'3
b
220 (sL/12)0'3
93
1 b/VMTa
0.78 (sL/0.35)0'3
n nc
0.0081 (sL/0.015)u'B
0.78 (sL/0.35)0'3
b
0.78 (sL/0.35)0'3
0.33
aVKT - Vehicle kilometers traveled, VMT = vehicle miles traveled.
Commonly referred to as the "industrial" paved road model.
cCommonly referred to as the "urban" paved road model.
For heavily loaded surfaces [i.e., sL > ~ 300 to 400 g/m2 (9 to 12 oz/yd2)], it is
recommended that the resulting estimate be compared to that from the unpaved road models
(Section 4.1.1 of this manual), and the smaller of the two values used.
3-2
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CO
CO
Scale ^
House
= 500tt.
Office
Maintenance
Building
Paved Road
__ Unpaved Road
Figure 3-1. Example facility map with roads divided into road segments.
-------
The emission rate is determined by multiplying the emission factor of
each road segment by the total vehicle mileage on the segment over the averag-
ing time of interest. Totaling the individual emission rates for each road
segment will provide an uncontrolled emission rate for all unpaved roads in
the facility.
Surface silt content (s) is the fraction of material smaller than 75 ym
in diameter. L is the total dust loading and the product sL represents the
mass of silt-size dust particles per unit area of the road surface. As is the
case for all predictive models in AP-42, the use of site-specific values of sL
is strongly recommended. The silt loading should be determined using the
sampling techniques and laboratory analysis procedures described in
Appendix F. Figure 3-2 is an example of a sampling data form for paved roads.
Vehicle-related parameters should be obtained using a combination of
counting devices, manual or automated records, and information from plant
personnel. Pneumatic tube axle counters can be used to obtain traffic volume
data. Figure 3-3 shows an example pneumatic traffic log. However, because
these counters only record the number of passing axles, it would also be
necessary to obtain traffic mix information (e.g., number of axles per
vehicle) to convert axle counts to the number of vehicle passes. Vehicle
mixes may be observed either visually or by the use of videotape or time-lapse
motion pictures. Figure 3-4 shows an example of a manual vehicle log. Com-
parison of the observed vehicle mix to the pneumatic counter totals allows the
accuracy of the axle counter to be assessed.
Paved road emissions can only be controlled in two ways: (a) by reducing
the silt loading in Eq. 3-1 and, therefore, reducing the emission factor, and
(b) the emission rate may be reduced by limiting the number of vehicles
traveling on each road segment. A combination of both techniques could be
used. Because it is often impractical to reduce vehicular traffic on a road,
most available control techniques either attempt to prevent material from
being deposited on the surface or to remove (from the travel lanes) any
material that has been deposited.
While the mechanisms of particle deposition and resuspension are largely
the same for public and industrial roads, there can be major differences in
surface loading characteristics, emission levels, traffic characteristics, and
viable control options. For the purpose of estimating particulate emissions
and determining control programs, the distinction between public and
industrial roads is not a question of ownership but rather a question of
surface loading and traffic characteristics.
Although public roads tend to have lower surface loadings than industrial
roads, the fact that these roads have far greater traffic volumes may result
in a substantial contribution to the measured air quality in certain areas.
In addition, many public roads in industrial areas often are heavily loaded
and traveled by heavy vehicles. In that instance, better emission estimates
would be obtained by treating these roads as industrial roads. In an extreme
case, a road or parking lot may have such a high surface loading that the
paved surface is essentially covered and is easily mistaken for an unpaved
road.
3-4
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PAVED ROAD SURFACE SAMPLING
Date Bv
Site of Sampli
No. of Traffic Li
Surface Condit
Sample No.
na:
ines: Type of Pavement: Asphalt/Concrete
ion:
Vac. Bag
No.
Time
Location*
Sample Area
Broom
Swept?
(y/n)
Use code given on plant map for segment identification and indicate sample location on map.
Figure 3-2. Sampling data form for paved roads.
3-5
-------
Pneumatic Traffic Count Log
Facility: Recorded bv:
Road
Segment
ID
Counter
ID No.
Site Location
Start Count
Date/Time
Stop Count
Date/Time
Axles/Vehicle
Mix Observation*
Total No.
of Vehicle
Passes
Obtained from the manual traffic log
Figure 3-3. Example pneumatic traffic count log,
3-6
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VEHICLE LOG
Date Recorded by
Road Location:.
Road Type:
Sampling Start Time: Stop Time:
Vehicle Type Axles/Wheels 123 45678 910 Total
Figure 3-4. Example manual traffic count log.
3-7
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In that event, use of a paved road emission factor may actually result in a
higher estimate than that obtained from the unpaved factor, and the road is
better characterized as unpaved in nature rather than paved.2
3.1 PUBLIC PAVED ROADS
As discussed above, the term "public" is used in this manual to denote
not only ownership of the road but also its surface and traffic character-
istics. Roads in this class generally are fairly lightly loaded, are used
primarily by light-duty vehicles, and usually have curbs and gutters. Exam-
ples are streets in residential and commercial areas and major thoroughfares
(including freeways and arterials).
3.1.1 Estimation of Emissions
The emission factor for public paved roads is determined by the decision
rule discussed above. Tables 3-2 and 3-3 present a summary of silt loadings
as a function of roadway classification and the scheme used to classify road-
ways, respectively.
In general, roads with a higher traffic volume tend to have lower surface
silt loadings. This relationship is expressed in the empirical model pre-
sented in Reference 3:
sL = 21.3/(Vo.*i) (3-2)
where: sL = surface silt loading (g/m2)
V = average daily traffic volume (vehicles/d)
3.1.2 Demonstrated Control Techniques for Public Paved Roads
Available control methods for public roads are largely designed either to
prevent deposition of material on the roadway surface or to remove material
which has been deposited in the driving lanes. Measurement-based efficiency
values for control methods are presented in Table 3-4. Note that all values
in this table are for mitigative measures applied to industrial paved roads.
In terms of public paved road dust control, only very limited field mea-
surement data are available. One reference was found that could be used to
indirectly quantify emission reductions and this, too, is for mitigative
measures. Estimated PM10 control efficiencies (Table 3-5) were developed by
applying Eq. 3-1 to measurements before and after road cleaning.•» Note that
these estimates should be considered upper bounds on efficiencies obtained in
practice because no redeposition after cleaning is considered. Note also that
these estimated emission control efficiencies for urban roads compare fairly
well with measurements at industrial roads. No airborne mass emission mea-
surements quantifying control efficiency were found.
3-8
-------
TABLE 3-2. SUMMARY OF SILT LOADINGS (sL) FOR PAVED URBAN ROADWAYS3
City
Baltimore
Buffalo
Granite
City, 111.
Kansas City
St. Louis
All
Local Collector
streets streets
Xg (g/m2) n Xg (g/m2) n
1.42 2 0.72 4
1.41 5 0.29 2
—
2.11 4
—
1.41 7 0.92 10
Major
streets/
highways
xn (g/m2) n
y
0.39 3
0.24 4
0.82 3
0.41 13
0.16 3
0.36 26
Freeways/
expressways
Xg (g/m2) n
— —
—
—
—
0.022 1
0.022 1
a Reference 1. X~ = geometric mean based on corresponding n sample size.
Dash = not available. To convert g/m2 to grains/ft2 multiply g/m2 by
1.4337.
TABLE 3-3. PAVED URBAN ROADWAY CLASSIFICATION3
Roadway category
Freeways/expressways
Major streets/highways
Collector streets
Local streets
Average
daily
traffic
(vehicles)
> 50,000
> 10,000
500-10,000
< 500
Lanes
> 4
> 4
2b
2c
a Reference 1.
b Road width > 32 ft.
c Road width < 32 ft.
3-9
-------
TABLE 3-4. MEASURED EFFICIENCY VALUES FOR PAVED ROAD CONTROLS3
Cited
Method efficiency Comments
Vacuum sweeping 0-58% Field emission measurement (PM-15)
12,000-cfm blower0
46% Reference 5, based on field measurement
of 30 ym particulate emissions
Water flushing 69-0.231 Vc'd Field measurement of PM-15 emissions0
Water flushing 96-0.263 Vc»d Field measurement of PM-15 emissions0
followed by
sweeping
a Reference 6, except as noted. All results based on measurements of air
emissions from industrial paved roads.
PM10 control efficiency can be assumed to be the same as that tested.
c Water applied at 0.48 gal/yd2.
" Equation yields efficiency in percent, V = number of vehicle passes
since application.
TABLE 3-5. ESTIMATED PM10 EMISSION CONTROL EFFICIENCIES3
Estimated PM10
Method efficiency, %
Vacuum sweeping 34
Improved vacuum sweeping 37
a Reference 4. Estimate based on measured initial and
residual < 63 ;im loadings on urban paved roads and
Eq. 3-1. Value reported represents the mean of
13 tests for each method.
3-10
-------
In general terms, one would expect that demonstrated control techniques
applied to industrial paved roads could also be applied to public roads. One
important point to note, however, is that it is generally recognized that
mitigative measures decrease in effectiveness as the surface loadings
decrease. Because mitigative measures are less effective for public paved
roads, the use of preventive measures should be stressed, especially in
instances where no dominant or localized source of road loading can be identi-
fied. Example sources would include: (1) unpaved areas adjacent to the road;
(2) erosion due to storm water runoff; and (3) spillage from passing trucks.
Corresponding examples of preventive measures include: (1) installing curbs,
paving shoulders, or painting lines near the edge of the pavement; (2) con-
trolling storm water or using vegetation to stabilize surrounding areas; and
(3) requiring trucks to be covered and to maintain freeboard (i.e., distance
between top of the load and top of truck bed sides). In instances where the
source of loading can be easily identified (e.g., salt or sand spread during
snow or ice storms) or the effects are localized (e.g., near the entrance to
construction sites or unpaved parking lots), either preventive or mitigative
measures could be prescribed. Table 3-6 summarizes nonindustrial paved road
preventive controls.
There are few efficiency values for any of the preventive measures pre-
sented in Table 3-6. Because these materials are designed to prevent deposi-
tion of additional material onto the paved surface, quantitative measurements
before and after the control are generally not possible and interpretation of
results are complicated. For example, based on ambient TSP monitoring results
over a 3-month period, immediate and continuous manual cleaning of the access
area to a construction site was estimated to result in ~ 30% control.7 It is
unclear, however, what effect seasonal variation in the monitoring data has on
the estimate of 30%. Also, because this estimate is based on ambient air
concentrations, use of the value may be inconsistent with the other efficiency
estimates given in this chapter.
Inspection Procedures^for Public Paved Roads. In many respects, public
paved roads cannot be considered subject to "field inspections" in the tradi-
tional regulatory sense. Silt loadings on these roads are at least partially
due to a wide range of ubiquitous sources (such as deposition of ambient dust,
application of snow/ice controls, pavement wear, spills, tire/brake wear,
litter). It is obvious that those types of sources of silt loadings cannot be
routinely inspected. In addition, EPA policy emphasizes preventive rather
than mitigative controls for public paved roads. In this way, general reduc-
tions in silt loadings in an area would be expected. However, the determina-
tion of the effective silt reduction due to a particular preventive control is
complicated because of the spatial and temporal separation of the cause and
the effect.
Thus, with the exception of "localized" preventive controls employed at
industrial and construction sites (such as covering haul trucks or cleaning
plant entrance areas), control measures taken to reduce silt loadings on
public paved roads cannot be generally inspected.
3-11
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TABLE 3-6. NONINDUSTRIAL PAVED ROAD DUST SOURCES AND PREVENTIVE CONTROLS
Source of deposit on road
Recommended controls
— Sanding/salt
— Spills from haul trucks
Construction carryout and
entrainment
Vehicle entrainment from
unpaved adjacent areas
Erosion from storm water washing
onto streets
Wind erosion from adjacent
areas
— Other
— Make more effective use of
abrasives through planning,
limited, and uniform spreading,
etc.
— Improve the abrasive material
through specifications limiting
the amount of fines and material
hardness, etc.
— Rapid cleanup after streets become
clear and dry
-- Require trucks to be covered
— Require freeboard between load and
top of hopper
-- Wet material being hauled
— Clean vehicles before entering road
-- Pave access road near site exit
-- Semicontinuous cleanup of exit
-- Pave/stabilize portion of unpaved
areas nearest to paved road
— Storm water control
— Vegetative stabilization
— Rapid cleanup after event
— Wind breaks
— Vegetative stabilization or
chemical sealing of ground
-- Pave/treat parking areas, drive-
ways, shoulders
— Limit traffic or other use that
disturbs soil surface
-- Case-by-case determination
3-12
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Implementation and enforcement of "area-wide" (i.e., not "localized" in
the sense described above) preventive measures—such as changes in snow/ice
control materials and practices or city ordinances requiring homeowners to
remove biological debris from streets in their neighborhoods—will generally
require a strong working relationship between the air regulatory agency and
other administrative bodies. This relationship is often expressed in a Joint
Memorandum of Understanding. Once again, competing demands (e.g., the impor-
tance of maintaining traffic safety during ice and snow storms) make "inspec-
tion" in the usual sense largely impossible.
Consequently, the inspection procedures for public paved roads will be
restricted to the localized preventive controls. These procedures are dis-
cussed in connection with industrial road inspections in Section 3.2 of this
manual.
3.2 INDUSTRIAL PAVED ROADS
As noted earlier, emission estimation for paved roads depends less upon
its ownership and more upon its surface material and traffic characteristics.
In this manual, the term "industrial" paved road is used to denote those roads
with higher surface loadings and/or are traveled by heavier vehicles. Conse-
quently, some publicly owned roads are better characterized as industrial in
terms of emissions. Examples would include city streets in heavily
industrialized areas or areas of construction as well as paved roads in
industrial complexes.
3.2.1 Estimation of Emissions
Whan estimating emissions from industrial paved roads, Eq. 3-1 and
Table 3-1 should be used. Table 3-7 provides measured silt loading values for
a few industries.
3.2.2 Demonstrated Control Techniques for Industrial Paved Roads
As noted in Section 3.1.2, the vast majority of measured control effi-
ciency values for paved roads are based on data from industrial roads. Conse-
quently, the information presented earlier in Table 3-4 is more applicable to
this class of road.
Mitigative measures may be more practical for industrial plant roads
because (1) the responsible party is known; (2) the roads may be subject to
considerable spillage and carryout from unpaved roads; and (3) all affected
roads are in relatively close proximity, thus allowing a more efficient use of
cleaning equipment. Preventive measures, of course, can be used in conjunc-
tion with plant cleaning programs and prevention is probably the preferred
approach for city streets in industrialized areas with many potential sources
of paved road dust.
3-13
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TABLE 3-7. INDUSTRIAL PAVED ROAD SILT LOADINGS*
CO
Industry
Copper smelting
Iron and steel
production
Asphalt batching
Concrete batching
Sand and gravel
processing
No. of
sites
1
6
1
1
1
No. of
samples
3
20
3
3
3
Silt, percent
Range
[15.4-21.7] |
1.1-35.7
[2.6-4.6]
[5.2-6.0]
[6.4-7.9]
w/w
Mean
[19.0]
12.5
[3.3]
[5.5]
[7.1]
No. of
travel
lanes
2
2
1
2
1
Silt loading,
g/m2
Range
[188-400]
0.09-79
[79-193]
[11-12]
[53-95]
Mean
[292]
12
[120]
[12]
[70]
a Reference 1. Brackets indicate values based on only one plant vist.
-------
Preventive Measures. These types of control measures prevent the
deposition of additional materials on a paved surface area. As a result, it
is difficult to estimate their control effectiveness. For mitigative con-
trols, before and after measurement (of surface loadings or of particulate
emissions) is possible; clearly, this is not the case for preventive mea-
sures. Table 3-6 contains a list of preventive measures along with
recommended controls.
Inspection Procedures for Preventive Measures. As mentioned in Sec-
tion 3.3.1, it is difficult to estimate control effectiveness for preventive
measures. Therefore, inspections for this type of control would require a
visual inspection. For example, the control plan/operating permit or
construction permit (hereafter referred to as plan/permit) may specify that
all haul trucks be covered to prevent spills, and all vehicles be cleaned
before entering a public paved road to limit carryout. In this instance, the
inspector would determine compliance by visually inspecting the haul trucks
and the rinsing of vehicles. The inspector should be familiar with all
preventive measures specified in the plan/ permit to determine if facility is
in compliance.
Mitigative Measures. While preventive measures are to be preferred under
the EPA urban dust policy, some sources of road dust loadings may not be
easily controlled by prevention. Consequently, some mitigative measures may
be necessary to achieve desired goals. This section discusses demonstrated
mitigative measures.
Broom Sweeping of Roads. Mechanical street cleaners employ rotary brooms
to remove surface materials from roads and parking lots. Much of their effect
is cosmetic, in the sense that, while the roadway appears much cleaner, a
substantial fraction of the original loading is emitted during the process.
Thus, there is some credence to claims that mechanical cleaning is as much a
source as a control of particulate emissions.
Measurement-based control efficiency of broom sweeping for industrial
roads and estimated efficiencies for urban roads both indicate a maximum
(initial) instantaneous control of roughly 25 to 30%. Efficiency, of course,
can be expected to decrease after cleanup.
Vacuum Sweeping of Roads. Vacuum sweepers remove material from paved
surfaces by entraining particles in a moving air stream. A hopper is used to
contain collected material and air exhausts through a filter system in an open
loop. A regenerative sweeper functions in much the same way, although the air
is continuously recycled. In addition to the vacuum pickup heads, a sweeper
may also be equipped with gutter and other brooms to enhance collection.
Figure 3-5 shows a vacuum sweeper truck in operation.
Instantaneous control efficiency values were given earlier in Table 3-4.
Available data show considerable scatter, ranging from a field measurement
showing no effectiveness (over baseline uncontrolled emissions) to another
field measurement of 58%. An average of the field measurements would indicate
an efficiency of 34%. In addition, the estimated upper limits for PM10
control of urban roads (Table 3-5) compare fairly well with that average.
3-15
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Figure 3-5. Photo of a vacuum street sweeper.
3-16
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Water Flushing of Roads. Street flushers remove surface materials from
roads and parking lots using high pressure water sprays. Some systems sup-
plement the cleaning with broom sweeping after flushing. Note that the
purpose of the program is to remove material from the road surface; in some
industries, water is regularly applied to roads to directly control emissions
(i.e., as in unpaved roads). Unlike the two sweeping methods, flushing faces
some obvious drawbacks in terms of water usage, potential water pollution, and
the frequent need to return to the water source. However, flushing generally
tends to be more effective in controlling particulate emissions.
Equations to estimate instantaneous control efficiency values are given
in Table 3-4. Note that water flushing and flushing followed by broom
sweeping represent the two most effective control methods (on the basis of
field emission measurements) given in that table.
3.3 REGULATORY FORMATS AND ASSOCIATED INSPECTION PROCEDURES
Once a PM10 control strategy has been developed and implemented, it
becomes necessary for the control agency to ensure that (a) the plan is being
carried out as specified, and (b) the plan is achieving the desired level of
control. This section discusses methods for determining compliance, along
with inspection procedures for paved roads.
3.3.1 "In-piant" Inspection Procedures
Figure 3-6 is an example inspection form which may be completed at the
start of the Level II and III inspections by interviewing plant personnel.
After determining any changes from the last inspection, a more thorough plant
inspection should be performed. "In-plant" inspections for paved roads may
consist of one or more of the following items:
1. Observation of control equipment in use.
2. "Spot" checks of pertinent traffic patterns.
3. Surface material sampling.
Each of these items is discussed in more detail below.
The plant inspection of paved road control equipment should focus on the
following items:
• Ensuring that operation of the equipment has not changed markedly
since the time of the last inspection.
Examining that the "on-board" pollution control devices (e.g., bags
on vacuum street cleaners, water sprays on flushing devices) are
performing in an adequate matter. (This evaluation will usually be
made on the basis of visible emissions from vents, brooms, etc.)
Verifying that maintenance items (e.g., replacement nozzles) shown
in the facility's records have actually been installed on the
control equipment.
3-17
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Business License Name of Corporation, Company, or Individual Owner or Governmental Agency:
Mai I ing Address:
Plant Address:
Name and Title of Company Representative:
Telephone Number:
Name of Official Conducting Inspection:
CO
i
oo
General Questions for Plant Personnel
1. Have any roads been eliminated or blocked off
since last inspection?
2. Have any roads been paved since last inspection?
3. Any new roads?
4. Have traffic volumes or vehicle character-
istics on roads changed because of process
changes, shutdown, etc.?
Controls
~TIHave any changes been made in control program
since last inspection?
6. Any new equipment?
7. Any equipment downtime since last inspection?
Yes*
No
N/A
Comments
* If any answer is yes, complete comment section.
Figure 3-6. Example inspection form.
-------
• Noting the qualitative performance of the device in removing
material from lightly to heavily loaded portions of the roadway.
Recording the vehicle's odometer (or elapsed usage clock) reading
for comparison against last reading and facility records.
In addition to the above items, in-plant inspections of the paved road control
equipment may also entail field measurements of silt loadings before and after
control. This is discussed in greater detail below.
If the facility personnel indicate marked changes in traffic patterns,
traffic volume, etc., or if the control plan calls for vehicle volume reduc-
tion (see Section 4.2), the inspector may wish to spot-check traffic param-
eters at selected roads in the facility. This is accomplished by taking
manual traffic mix data. General procedures for manual mix observations are
outlined below.
Procedures for Obtaining Manual Traffic Mix Data
Required equipment. Stopwatch, traffic count log (see Figure 3-3)
Procedure:
Select unobstructed observation point.
1.
2.
3.
4.
Determine distance between two easily defined points (A,B) on the
road segment in question.
Indicate mix start time.
For each passing vehicle, record vehicle type (if known), the number
of axles/wheels, and the time in seconds required to travel between
points A and B. Alternately, an accumulating stopwatch may be used
to determine the average time required to travel between A and B.
5. Record mix stop time.
Finally, the inspector can spot check paved roads by taking material grab
samples and comparing either "before and after" silt loadings or comparing the
silt loading against some "action level." The latter is useful in assessing
prevention of material carryout into public paved roads. As an example, if
the silt loading on a public road (with an average traffic volume of
2,000 vehicles per day) adjacent to an industrial or construction site ever
exceeds 2.9 g/m2 (the "action level"), the regulatory agency may require the
responsible party to reduce the silt loading to a level less than the action
level. The action level is an agency-supplied multiple (3 in this example) of
either baseline measurements or the surface silt loading predicted by Eq. 3-1
and should correspond to a minimally acceptable level of control. Figure 3-7
presents a possible format for use with public paved road sources.
3-19
-------
CO
I
rv>
O
O
5
o
_i
H
_J
CO
LU
O
DC
ID
CO
Note: At higher
traffic levels cleaning
becomes Impractical
because of safety concerns.
1,000 10,000
DAILY TRAFFIC VOLUME (VEH/DAY)
100,000
Figure 3-7. Possible use of "action levels" to trigger paved road controls.
-------
The sampling method used to determine silt loading for compliance
inspection should conform to the technique used to develop the AP-42 urban
paved road equation. That technique is specified in Appendix F and briefly
described below.
Procedures for Obtaining Surface Material Samples
Required equipment. Stick-type vacuum, hand broom, dust pan (Figure 3-2)
Procedure (See Appendix F):
1. Arrangements must be made to account for spatial variation of sur-
face silt loading. Possible suggestions include (a) visually deter-
mining the heaviest loading on the road and selecting that spot for
sampling, (b) sampling the midpoint of the road length segment of
interest, and (c) sampling preselected (possibly on the basis of
safety considerations) strips on the road surface (note that the
samples may be aggregated).
2. After sampling site has been selected, hand sweep with a hand broom
and dust pan if there are any large particles in the sampling
area. Place sample in jar and label.
3. Vacuum the test site, using preweighed bags. Remove vacuum bag,
check for leaks, and label.
4. Analyze for silt content as described in Appendix F.
3.3.2 Plant Record Keeping Requirements
Records must be kept to document the frequency a paved road is vacuumed,
flushed, or swept. Pertinent parameters that should be specified in a control
plan and regularly recorded include:
General Information to be Specified in the Plan
1. All road segments and parking locations referenced on a map avail-
able to both the responsible party and the regulatory agency.
2. Length of each road and area of each parking lot.
3. Type of control applied to each road/area and planned frequency of
application
4. Provisions for weather (e.g., program suspended for periods of
freezing temperatures; for broom and vacuum sweeping, a predetermined amount
of rainfall will be substituted for one treatment).
3-21
-------
Specific Records for Each Road Segment/Parking Area Treatment
1. Date of treatment
2. Operator's initials (note that the operator may keep a separate log
whose information is transferred to the environmental staff's data sheets)
3. Start and stop times on a particular segment/parking lot, average
speed, number of passes
4. Start and stop times for refilling tanks (for water flushing only)
5. Qualitative description of loading before and after treatment
6. Any areas of unusually high loadings, from spills, pavement
deterioration, etc.
General Records to be Kept
1. Equipment maintenance records
2. Meteorological log (to the extent that weather influences the
control program)
3. Any equipment malfunctions or downtime
Example Compliance Determination—Record Keeping for Flushing of Paved
Roads. This example considers the hypothetical facility X with paved roads
shown in Figure 3-1. Facility X is located in a PM10 nonattainment area and
has an approved dust control plan that specifies the following control
strategy for paved roads:
1. Flushing at intensities > 0.50 gal/yd2 (2.3 L/m2)
2. To achieve an average control of 34% by water flushing, no more than
300 vehicle passes can occur between treatments (c.f. Table 3-4).
Therefore, the frequency of flushing was determined by traffic vol-
ume in the control plan. Because roads A, B, and C have 50, 10, and
40 vehicle passes per working hour, respectively, the roads should
be flushed every 6, 30, and 7.5 h of operation. For practical con-
siderations, the permit requires that road B be flushed daily and
road C be flushed every 6 h with road A. In addition, paved parking
areas should be flushed at the close of each business day.
3. Flushing is to be performed from April 1 through October 31.
4. Each 1/2 in of rainfall (in the previous 24 h) will be substituted
for one treatment, and the program will be suspended for days where
the morning temperature (8 a.m.) does not exceed 32°F.
3-22
-------
Note that the permit also specifies flushing between 11:00 a.m. and 3:00 p.m.
when the ambient temperature at 11:00 a.m. 1s > 40°F for the period from
November 1 to March 31.
The source extent parameters for paved surfaces at facility X are given
below:
Vehicle
passes
Segment/area per hour Length (ft) Width (ft) Approx. area (yd2)
A
B
C
Parking
50
10
40
650
350
200
300
32
32
32
80
2,300
1,250
700
2,700
(Note that the vehicle passes are those used in the equation for determining
uncontrolled emissions.) The facility operates a 5,000-gal water truck
equipped with auxiliary spray "shoes" for flushing paved surfaces.
Example records kept by facility X to document its flushing program are
shown in Figure 3-8 (meteorological data log) and in Figure 3-9 (operator's
log). Because the control plan specifies the time interval between each
application, the use of the operator's log is the best way to determine
compliance. The operator's log should show at least one treatment for every
6 h for roads A and C and one treatment a day for road B. If it does not, the
facility should be required to submit a written explanation for the apparent
discrepancy. Note that this evaluation may require accumulating scale records
over more than one business day, and that it should consider periods of
minimal rainfall so as not to confound the check.
3-23
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Facility X Meteorological Data Log
Month/Year: Ot/2^ Observer ^
Obs. Precipitation Temperature
Day Time (in) (°F) Comments
01 g.'QS - 6»H
02 5?: 05 ~ 6.4
03
04
07 2:10 - 75
08 g-.|Q 0.08 7O.
09 g:|Q - 77
10
11
14 g:os - -7
15 RiQS - 7H
16 g:05 - 77
17
18
1 Q *?' AC. x*\ / / s t I
1-7 Q »UQ Q. Co <*o Ct>i
20 8: ftS - 70
21
22
23 g:Qf
24
25
26
27
28 %:Q5 - 76.
29 g:65 - 7%
30 K:6S - 2S_
31
05 9'. 16 o. 10 7^ Ro:x^e\
06 2-.1Q - _
12 8:65 3. IX 5C. K^a Flu^sW
13
Figure 3-8. Meteorological data log for example facility X.
3-24
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Facility X Flushing Program—Operator's log
Date Segment I.D./Time Treated
A"BCParking
6/1 7.'5Q 7.IC1Q 7:H5
6/1 1:30 - / : HO 5i3Q
6/a 7'3Q 7
— 10 O FLUSHING -
7.^0 7:50 7:55
6/n --K\0 FLUSHING
6/ao 7.50
i:30 - MHO 5:30
G//3 / - HO - j: 5^ 5: 3O
6Uo /.'30 ~ I'.HO Si 50
Figure 3-9. Operator's log for example facility X.
3-25
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3.4 REFERENCES FOR SECTION 3
1. U.S. Environmental Protection Agency. 1985. Compilation of Air
Pollution Emission Factors, AP-42. U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina.
2. Muleski, 6. E. 1987. Update of Fugitive Dust Emission Factors in AP-42
Section 11.2. Final Report, U.S. Environmental Protection Agency,
Contract No. 68-02-3891, Work Assignment No. 19.
3. Cowherd, C., Jr., and P. J. Englehart. 1984. Paved Road Particulate
Emissions. EPA-600/7-84-077. U.S. Environmental Protection Agency,
Washington, D.C.
4. Duncan, M., et al. 1984. Performance Evaluation of an Improved Street
Sweeper. EPA Contract No. 68-09-3902.
5. Eckle, T. F., and D. L. Trozzo. 1984. Verification of the Efficiency of
a Road-Dust Emission-Reduction Program by Exposure Profile Measurement.
Presented at an EPA/AISI Symposium on Iron and Steel Pollution Abatement,
Cleveland, Ohio. October 1984.
6. Cowherd, C., Jr., and J. S. Kinsey. 1986. Identification, Assessment
and Control of Fugitive Particulate Emissions. EPA-600/8-86-023, U.S.
Environmental Protection Agency, Research Triangle Park, North Carolina.
7. Axetell, K., and J. Zeller. 1977. Control of Reentrained Dust from
Paved Streets. U.S. Environmental Protection Agency. EPA-907/9-77-007.
3-26
-------
SECTION 4
UNPAVED ROADS
As is the case for paved roads, participate emissions occur whenever a
vehicle travels over an unpaved surface. Unlike paved roads, however, the
road itself is the source of the emissions rather than any "surface load-
ing." Within the various categories of open dust sources (i.e., paved roads,
storage piles, and wind erosion), unpaved travel surfaces have historically
accounted for the greatest share of particulate emissions in industrial
settings.
Unpaved travel surfaces are found in rural regions throughout the country
and in industrial settings. Rural roads may be unpaved because they experi-
ence only sporadic traffic and involve considerable road length, making paving
generally impractical. Some industrial roads are, by their nature, not suit-
able for paving. These roads may be used by very heavy vehicles or may be
subject to considerable spillage from haul trucks. Other roads may have
poorly constructed bases which make paving impractical. Because of the addi-
tional maintenance costs associated with a paved road under these service
environments, emissions from these roads are usually controlled by regular
applications of water and/or chemical dust suppressants.
In addition to roadways, many industries often contain important unpaved
travel areas. These areas include travel around stockpiles, staging and
reclaim activities. These areas may often account for a substantial fraction
of traffic-generated emissions from individual facilities. In addition, these
areas tend to be much more difficult to control than stretches of roadway.
4.1 EMISSIONS ESTIMATION
4.1.1 Emission Factor Equation
When considering emissions and their control from unpaved roads, each
road must first be divided into road segments. A road segment is the distance
between two intersections. Figure 4-1 is a map of an example facility with
each road divided into road segments and assigned an arbitrary identifica-
tion. After identifying each road segment, an emission factor may be deter-
mined by applying the following AP-421 equation to each road segment:
(if) (if)
if) (l§)
4-1
-------
I
ro
Paved Road
Unpaved Road
Figure 4-1. Example facility map with roads divided into road segments.
-------
where: E = PM10 emission factor in units stated
s = silt content of road surface material, %
S = mean vehicle speed, km/h (mi/h)
W = mean vehicle weight, Mg (ton)
w = mean number of wheels (dimensionless)
p = number of days with > 0.254 mm (0.01 in) of precipitation
per year
The emission rate is determined by multiplying the emission factor by the
length of the road segment and the vehicle passes per day. Adding the emis-
sion rate from each segment will provide a total unpaved road emission rate
for the facility.
Note that the above emission factor equation represents uncontrolled
conditions. (Roads that are controlled will be discussed later in
Section 4.3.) Emissions may be controlled by either "add-on" methods (such as
watering, etc.) or by reducing the values of parameters in Equation 4-1 (e.g.,
halving the vehicle speed halves the emission rate). In addition, some com-
pliance tools also make use of the parameters in this equation. Consequently,
each parameter in the equation is discussed in more detail below.
4.1.2 Parameters Affecting Emissions
Silt content is the percent of mass which passes a 200 mesh screen
(< 75 ymP). Table 4-1 gives a range of measured silt values for unpaved roads
in certain industries. As for all AP-42 emission factors, the use of site-
specific data is strongly encouraged. The silt content of the road surface
material should be determined using the sampling techniques and laboratory
analysis procedures described in Appendix F.
Vehicle-related parameters should be obtained using a combination of
counting devices, manual or automated records, and information from plant per-
sonnel. Pneumatic tube axle counters can be used to obtain traffic volume
data. (Note that traffic volume is also necessary to obtain emission rates
from Equation 4-1.) Figure 4-2 shows an example pneumatic traffic log.
However, because these counters only record the number of passing axles, it
would also be necessary to obtain traffic mix information (e.g., number of
axles per vehicle) to convert axle counts to the number of vehicle passes.
Vehicle mixes may be observed either visually or by the use of videotape or
time-lapse motion pictures. Figure 4-3 shows an example of a manual vehicle
log.
Additional information obtained from traffic mix observations include
fractions of different vehicle types, vehicle speed, and number of wheels per
vehicle. A posted plant speed limit may also be used to represent average
speed. Finally, comparison of the observed vehicle mix to the pneumatic
counter totals allows the accuracy of the axle counter to be assessed.
4-3
-------
TABLE 4-1. TYPICAL SILT CONTENT VALUES OF SURFACE MATERIAL ON INDUSTRIAL
AND RURAL UNPAVED ROADSa
Industry
Copper smelting
Iron and steel production
Sand and gravel processing
Stone quarrying and processing
Taconite mining and processing
Western surface coal mining
Rural roads
Road use or
surface material
Plant road
Plant road
Plant road
Plant road
Haul road
Service road
Access road
Haul road
Scraper road
Haul road
(freshly graded)
Gravel
Dirt
Crushed limestone
Plant
sites
1
9
1
1
1
1
2
3
3
2
1
2
2
Test
samples
3
20
3
5
12
8
2
21
10
5
1
5
8
Silt, weight
Range
15.9-19.1
4.0-16.0
4.1-6.0
10.5-15.6
3.7-9.7
2.4-7.1
4.9-5.3
2.8-18
7.2-25
18-29
NA
5.8-68
7.7-13
percent
Mean
17.0
8.0
4.8
14.1
5.8
4.3
5.1
8.4
17
24
5.0
28.5
9.6
Note: NA - Not applicable.
a Reference 1 (AP-42).
-------
Facilit
Road
Segment
ID
Pneumatic 1
/:
Counter
ID No.
Site Location
Start Count
fraffic Count 1
Recorded
Date/Time
Stop Count
-og
by:
Date/Time
Axles/Vehicle
Mix Observation*
Total No.
ot Vehicle
Passes
' Obtained from the manual traffic log
Figure 4-2. Example pneumatic traffic count log.
4-5
-------
VEHICLE LOG
Date Recorded by
Road Location:.
Road Type:
Sampling Start Time: Stop Time:
Vehicle Type Axles/Wheels 1 23456789 10
Total
Figure 4-3. Manual traffic count log,
4-6
-------
The number of wet days (i.e., precipitation > 0.01 in) per year (p) for
the geographical area of interest should be determined from local climatic
data. Figure 4-4 gives the geographical distribution of the mean annual
number of wet days per year in the United States. Maps giving similar data on
a monthly basis are available from the U.S. Department of Commerce.2
4.2 EMISSION CONTROL METHODS
As shown in Table 4-2, there are a variety of control options for unpaved
travel surfaces. Note that the controls fall into three general categories
of: source extent reductions; surface improvements; and surface treatments.
Each of these is discussed in greater detail below.
TABLE 4-2. CONTROL TECHNIQUES FOR UNPAVED TRAVEL SURFACES
Source extent reductions: Speed reduction
Traffic reduction
Source improvements: Paving
Gravel surface
Surface treatments: Watering
Chemical stabilization
- Asphalt emulsions
- Petroleum resins
- Acrylic cements
- Other
4.2.1 Source Extent Reductions
These controls either limit the amount of traffic on a road to reduce the
PM10 emission rate, or lower speeds to reduce the emission factor value given
by Equation 4-1. Examples could include industrial plant bussing programs for
employees, restriction of roads to only certain vehicle types, or strict
enforcement of speed limits. In any instance, the control afforded by these
measures is readily obtained by the application of the emission factor
equation.
4.2.2 Surface Improvements
These controls alter the road surface. Unlike the surface treatments
(discussed below), these improvements do not require periodic reapplication.
The most obvious surface improvement is, of course, paving an unpaved
road. This option is expensive and is probably most applicable to high volume
(i.e., more than a few hundred passes per day) public roads and industrial
plant roads that are not subject to very heavy vehicles (e.g., slag pot
carriers, haul trucks, etc.) or spillage of material in transport.
4-7
-------
oo
.J?P-.._ 100 110 120
•~™~"-~
cpv^..^ _ r- \
Figure 4-4. Mean annual number of days with at least 0.01 in of precipitation.
As noted in Reference 2, patterns are too complex in Hawaii for
inclusion on this map. (Means for Hilo, Honolulu, and Lihue are
148,204S and 90 days/yr, respectively.)
-------
Other Improvement methods cover the road surface material with another
material of lower silt content (e.g., covering a dirt road with gravel or
slag, or using a "road carpet" under ballast).5 Because Equation 4-1 shows a
linear relationship between the emission factor and the silt content of the
road surface, any reduction in the silt value is accompanied by an equivalent
reduction in emissions. This type of improvement is initially much less
expensive than paving; however, maintenance (such as grading and spot reappli-
cation of the cover material) may be required.
4.2.3 Surface Treatment
Surface treatment refers to those control techniques which require
periodic reapplications. Treatments fall into the two main categories of:
(1) wet suppression (i.e., watering, possibly with surfactants or other addi-
tives), which keeps the surface wet to control emissions; and (2) chemical
stabilization, which attempts to change the physical (and, hence, the emis-
sions) characteristics of the roadway. Necessary reapplication frequencies
may range from several minutes for plain water under hot, summer time condi-
tions to several weeks (or months) for chemicals.
Water is usually applied to unpaved roads using a truck with a gravity or
pressure feed system. This is only a temporary measure, and periodic reappli-
cations are necessary to achieve any substantial level of control effi-
ciency. Some increase in overall control efficiency is afforded by wetting
agents which reduce surface tension. Figure 4-5 shows a typical water truck
used to treat unpaved haul roads in a mining operation.
Chemical dust suppressants (Table 4-3). on the other hand, have much less
frequent reapplication requirements. These suppressants are designed to alter
the roadway surface, such as cementing loose material into a fairly impervious
surface (thus simulating a paved surface) or forming a surface which attracts
and retains moisture (thus simulating wet suppression).
Chemical dust suppressants are generally applied to the road surface as a
water solution of the agent. The degree of control achieved is a direct func-
tion of the application intensity (volume of solution per unit area), dilution
ratio, and frequency (number of applications per unit time) of the chemical
applied to the surface and also depends on the type and number of vehicles
using the road.5 Chemical suppressants have also been proven to be effective
as crusting agents for inactive storage piles and for the stabilization of
exposed open areas and agricultural fields.5
4.3 REGULATORY FORMATS AND ASSOCIATED INSPECTION PROCEDURES
Once a specific PM10 control strategy has been developed and implemented,
it becomes necessary for the control agency to assure that it is being carried
out as specified and is achieving the desired level of control. The control
efficiency actually attained by a particular technique depends on the appli-
cation parameters involved in its implementation. This section will discuss
methods for determining compliance, along with inspection procedures, for
various surface treatments of unpaved roads.
4-9
-------
Figure 4-5. Water truck treating a mine haul road,
4-10
-------
TABLE 4-3. CHEMICAL STABILIZERS3
A. Type: Bitumens
Product
AMS 2200, 2300
Coherex
Docal 1002
Peneprime
Petro Tac P
Resinex
Retain
B. Type: Salts
Product
Calcium chloride
Oowflake, Liquid Dow
DP-10
Dust Ban 8806
Dustgard
Sodium silicate
C. Product
Acrylic DLR-MS
Bio Cat 300-1
CPB-12
Curasol AK
DCL-40A, 1801, 1803
DC-859, 875
Dust Ban
Flambinder
Lignosite
Norlig A, 12
Orzan Series
Soil Gard
Manufacturer
Arco Mine Sciences
Witco Chemical
Douglas Oil Company
Utah Emulsions
Syntech Products Corporation
Neyra Industries, Inc.
Dubois Chemical Company
Manufacturer
Allied Chemical Corporation
Dow Chemical
Wen-Don Corporation
Nalco Chemical Company
G.S.L. Minerals and Chemicals Corporation
The PQ Corporation
Manufacturer
Rohm and Haas Company
Applied Natural Systems, Inc.
Wen-Don Corporation
American Hoechst Corporation
Calgon Corporation
Betz Laboratories, Inc.
Nalco Chemical Company
Flambeau Paper Company
Georgia Pacific Corporation
Reed Lignin, Inc.
Crown Zellerbach Corporation
Walsh Chemical
Reference 3, as cited by Reference 4.
4-11
-------
4.3.1 General Inspection Procedures and Compliance Information
4.3.1.1 General Inspection Procedures-
Figure 4-6 is an example inspection form which may be completed at the
start of the Level II or III inspection by interviewing plant personnel.
After determining any changes from the last inspection, a more thorough plant
inspection should be performed. "In-plant" inspections for a watering/
chemical suppression program may consist of one or more of the following
items:
1. Qualitative assessment of the water/chemical truck spray pattern.
2. "Spot" checks of pertinent traffic patterns.
3. Surface material sampling.
Each of these items is discussed in more detail below.
The qualitative evaluation of the water/chemical truck spray pattern
should verify that:
1. The spray pattern is roughly uniform over the treated area.
2. The observed application pattern (i.e., one or more passes by the
truck), effectively treats the entire travel surface.
If the spray pattern is not uniform, it often produces "ponding" of water/
chemical in small areas with little or no water/chemical over other areas of
the surface. The practical result is that although the average application
intensity (e.g., gal/yd2) based on calculations appears to provide acceptable
levels of control, an erratic spray pattern in reality results in lower con-
trol efficiencies. Also, the inspector may want to record the vehicles'
odometer reading to compare against the last reading and facility records.
If the facility personnel indicate marked changes in traffic patterns,
traffic volume, etc., or if the control plan calls for vehicle volume reduc-
tion (see Section 4.2), the inspector may wish to spot-check traffic param-
eters at selected roads in the facility. This is accomplished by taking
manual traffic mix data. General procedures for manual mix observations are
outlined in Figure 4-7.
Finally, the inspector can spot-check controlled roads by taking material
grab samples and comparing the moisture or silt content with a minimum accept-
able value specified in the control plan/operating permit, as applicable.
This represents an "indirect" measure of compliance determination as discussed
in Section 2. An illustration of this technique to spot-check control
efficiency of water and chemical suppressants is presented later in
Sections 4.3.2.3 and 4.3.3.3, respectively. Figure 4-7 describes briefly the
procedures for collecting material samples. A more complete description can
be found in Appendix F.
4-12
-------
Business License Name of Corporation, Company, or Individual Owner or Governmental Agency:
Mai I ing Address:
Plant Address:
Name and Title of Company Representative:
Telephone Number:
Name of Official Conducting Inspection:
General Questions for Plant PersonneI
1. Have any roads been eliminated/blocked off
since last inspection?
2. Have any roads been paved since last inspection?
3. Any new roads?
4. Have traffic volumes or vehicle character-
istics on roads changed because of process
changes, shutdown, etc.?
Controls
~~5~!Have any changes been made in control program
since last inspection?
Water ing
6.Any new equipment?
7. Any equipment downtime since last inspection?
Chemicals
"ITAny receipts since last inspection?
9. Any new equipment?
10. Any equipment downtime?
11. Have any treated roads been repaired (e.g.,
bladed, fiI led in, etc.)?
12. Any supplemental cleaning (e.g., flushing)
since last inspection?
Yes*
No
N/A
Comments
* If any answer is yes, complete comment section.
Figure 4-6. Example inspection form.
-------
Procedures for Obtaining Manual Traffic Mix Data
Required equipment: Stopwatch, traffic count log (see Figure 4-3)
Procedure;
1. Select unobstructed observation point.
2. Determine distance between two easily defined points (A,B) on the
road segment in question.
3. Indicate mix start time.
4. For each passing vehicle, record vehicle type (if known), the number
of axles/wheels, and the time in seconds required to travel between
points A and B. Alternately, an accumulating stopwatch may be used
to determine the average time required to travel between A and B.
5. Record mix stop time.
Procedures for Obtaining Surface Material Samples
Required equipment; Hand (whisk) broom, dustpan
Procedure;
1. Measure the width of the traveled portion of the roadway.
2. Remove the loose surface material from the hard road base with the
hand broom and dustpan. The sample should be taken across the
entire traveled portion of the road using an 8-in wide sample strip.
3. Place sample in a container and analyze for moisture or silt content
as described in Appendix F.
Figure 4-7. Procedures for obtaining manual traffic mix and material samples.
4-14
-------
4.3.1.2 Plant Record Keeping Requirements-
Records must be kept that document the date, time, and amount of water/
chemical applied to unpaved surfaces. Pertinent parameters that should be
specified in a control plan include:
All road segments and parking locations referenced on a map avail-
able to both the responsible party and the regulatory agency (see
Figure 4-1 for an example).
• Length of each road and area of each parking lot.
Watering
Amount of water applied to each road/area and planned frequency of
application. (Alternatively, a minimum moisture level could be
specified. This is discussed in greater detail later in this
section.)
• Any provisions for weather (e.g., 1/4 in of rainfall will be sub-
stituted for one treatment; program suspended during freezing
periods; watering frequency as a function of temperature, cloud
cover, etc.).
Source of water and tank capacity.
Chemical treatment
• Type of chemical applied to each road/area, dilution ratio,
application intensity, and frequency of application.
Any provisions for weather (e.g., application of chemical dust
suppressants during cooler periods of the year may be inadvisable
for traffic safety reasons).
4.3.2 Watering
4.3.2.1 Control Efficiency Determination—
The control efficiency of unpaved road watering depends upon: (a) the
amount of water applied per unit area of road surface; (b) the time between
reapplications; (c) traffic volume during that period; and (d) prevailing
meteorological conditions during the period. While several investigations
have estimated or studied watering efficiencies, few have specified all the
factors listed above.
An empirical model for the performance of watering as a control technique
has been developed.5 The supporting data base consists of 14 tests performed
in four states during five different summer and fall months. The model is:
C , 100 - °'8 P d t (4-2)
4-15
-------
where C = average control efficiency, %
p = potential average hourly daytime evaporation rate, mrn/h
d = average hourly daytime traffic rate, h"1
i = application intensity, L/m2
t = time between applications, h
Estimates of the potential average hourly daytime evaporation rate may be
obtained from:
0.0049 x (value in Figure 4-8) for annual conditions
p 0.0065 x (value in Figure 4-8) for summer conditions
Note that Figure 4-8 does not present data for Alaska and Hawaii. Readers
responsible for those portions of the country should consult local
meteorological data from local weather stations, state universities, etc.
An alternative approach is presented as Figure 4-9 which shows that
between the average uncontrolled moisture content and a value of twice that, a
small increase in moisture content results in a large increase in control
efficiency. Beyond this point, control efficiency grows slowly with increased
moisture content according to the relationship:
r 75(M-1) 1 < M < 2
62 + 6.7M 2 < M < 5
where C = instantaneous control efficiency, %
M = ratio of controlled to uncontrolled surface moisture contents
An example using this procedure is illustrated in Section 4.3.2.3.
4.3.2.2 Record Keeping Review-
To determine compliance using record keeping, the facility must maintain
records for each road segment/parking area including:
1. Date of treatment.
2. Operator's initials (note that the operator may keep a separate log
from which information is transferred to the environmental staff's
data sheets).
3. Start and stop times on a particular segment/parking lot, average
speed, number of passes.
4. Start and stop times for tank filling.
4-16
-------
I I 1
MEAN ANNUAL CLASS A PAN EVAPORATION
(In Inches)
Figure 4-8. Annual evaporation data for the contiguous United States (as
diagrammed in the "Climate Atlas of the United States,"
June 1968).
-------
100%
S 75% -
o
o
o
UJ
|
•a:
C/l
50% -
25% -*
95%
RATIO OF CONTROLLED TO
UNCONTROLLED SURFACE
MOISTURE CONTENTS
Figure 4-9. Watering control effectiveness for
unpaved travel surfaces.
4-18
-------
Figure 4-10 is an example form which plant personnel can complete when
applying water to unpaved roads. In addition, plant-wide records must be kept
including:
1. Equipment maintenance records.
2. Meteorological log (to the extent that weather influences the con-
trol program).
3. Any equipment malfunctions or downtime.
The procedures described above allow an inspector to review historical
data to determine compliance. A procedure is described below which provides
an independent assessment of dust control while the inspector is on-site.
Example Compliance Determination—Record Keeping for a Watering
Program. This example considers the hypothetical facility X with unpaved
roads and staging areas shown in Figure 4-1. Facility X is located in a PM10
nonattainment area and has an approved dust control plan that specifies the
following conditions:
1. Application intensity > 0.20 gal/yd2 (0.91 L/m*).
2. Application frequency of twice/10-h workday.
3. Watering according to the application parameters is to be performed
from April 1 through October 31.
4. Each % in of rainfall (in the previous 24 h) will be substituted for
one treatment, and the program will be suspended for days where the
morning temperature (8 a.m.) does not exceed 32°F.
Note that the permit also specifies watering between 11:00 a.m. and 3:00 p.m.
when the ambient temperature at 11:00 a.m. is > 40°F for the period from
November 1 to March 31.
The source extent parameters for unpaved surfaces at facility X are given
below:
Segment/area
D
E
F
G
H (staging area)
I (staging area)
Length
(ft)
800
500
1,000
1,200
-
-
Width
IfiL
40
25
40
40
—
—
Approx.
area
(yd 2)
3,600
1,400
4,500
5,300
10,000
17,000
Vehicle
passes
per hour
40
1
40
40
40
40
Vehicle
speed
(mph)
10
5
10
10
5
5
4-19
-------
WATER APPLICATION LOG
Climatic parameters
Application Amb. temp. Date/amt. of Equipment Operator
Date Time intensity (gal/yd ) Area(s) treated (°F) last rainfall used initials Comments
-^
o
Figure 4-10. Example water application log.
-------
The facility operates a 5,000-gal water truck equipped with a 10-ft spray
bar. Visual observation indicates that two water truck passes (i.e., one in
each direction) effectively treats the travel surface of the unpaved roads.
Five to six passes are required to cover the travel portions of the staging
areas (H and I).
Example records kept by facility X to document its watering program are
shown in Figure 4-11 (meteorological data log), and in Figure 4-12 (operator's
log). The inspector responsible for the facility would, in practice, compare
these two records for compliance with permit conditions. The check is
intended to verify that all the unpaved roads and staging areas have been
treated twice daily (except after significant rainfall or under freezing
conditions). Note in Figure 4-12 that only one treatment is logged for 6/22
as 0.27 in of rainfall was recorded for the previous 24-h period.
If it is suspected that the documentation is inaccurate, for example,
treatments are logged for periods where no water was applied, the operator's
log can be cross-checked against any facility records kept for maintenance/
service of the water truck. These records are typically more complete than
those for the watering program. If the two sets of records do not match, the
facility should be required to submit a written explanation for the apparent
discrepancy.
Information compiled in the operator's log represents critical data
against which operations observed during Level II and III inspections should
be evaluated. For example, Figure 4-12 provides a basis for estimating the
typical length of time for a typical "cycle"--the time required to complete a
single application to all facility unpaved surfaces. For facility X, this
cycle length is on the order of 2 h. In practice, if cycles observed during
an inspection deviated considerably from those indicated in the operator's
log, the inspector should require the facility to explain the reasons for the
deviation.
In a similar fashion, while the operator's log does not allow the inspec-
tor to directly determine application intensity—the amount of water applied
per unit surface area--a check of filling times during inspection does provide
a qualitative indicator of whether or not the facility is, in fact, complying
with its permit requirements. In the case of facility X, a typical filling
time is on the order of 10 to 15 min. In practice, if the inspector can
approximate the filling rate (from a knowledge of pump specifications), it is
fairly easy to determine whether application intensities suggested by the log
information meet permit requirements.
This procedure can be illustrated for facility X as follows:
1. The pattern of applications indicated in the operator's log—
E (1 pass)/F (2 passes)/and complete application to staging area I--
corresponds to 22,200 yd2.
4-21
-------
Facility X Meteorological Data Log
Precipitation
(in)
£05
—
Sr-jo
O-IO
$•. 10
2110
g:|0
-
o.os
—
8 OS
3.1^.
S 65
IDS
8: :05
—
—
—
g;05 O.UU
Si 05
—
—
0.07
g:O5 -
2:03
8:65
8; 05
-r
—
—
—
—
-p =- Trcvc_e_
Temperature
6,4
78
7Z
71
5Cp
4.7
71
74
77
70
74
78
75
Observer
Comments
ov\
.a^ ^
Figure 4-11. Meteorological data log for example facility X.
4-22
-------
Facility X Water Control Program—Operator's Log
Tank Fill Time Road Segments/Areas Treated Op.
Date Start Stop Start Stop Comments Initials
llOQ E(\
CO
g:30 £rdL)/FCz.Vx
y/QO ns l'2o
6»/o| y:&S /.'2Q 1:20 0^/6 ^.a) / Mfoa^teV^ lE'tl} c2.'OQ
3:oo
'HcompVeWEtO ^:QQ
i
DC7-V6 Lt&^te&li} S'.QQ
Figure 4-12. Operator's log for example facility X.
-------
2. Thus the minimum application intensity of 0.20 gal/yd2 requires
4,440 gal (22,200 yd* x 0.20 gal/yd2 = 4,440 gal).
3. Given a 10-min filling time, this corresponds to a fill rate of
about 400 gal/min.
During an inspection, the inspector for facility X would verify the length of
time required to completely fill the tank from an initial near-empty state.
Because the application cycle cited above (one-half or the total cycle)
requires nearly the entire tank capacity, it follows that if the tank is not
at least 90% full after a typical fill time, then it is likely that facility X
is not watering at the required application intensities.
4.3.2.3 "In-Plant" Inspection Procedures
An "in-plant" inspection to determine compliance with fugitive dust rules
or permit conditions for unpaved roads involves focusing on several items
including:
A visual inspection of the facility in order to observe that all
unpaved roads listed in the state permit/control plan still exist
and whether additional roads have been developed.
An examination of the source's records (as described above) docu-
menting frequency of water application, amount applied, area(s)
watered, etc.
Observations of any spraying operations undertaken by the source
during the inspector's visit.
After becoming familiar with the plant facilities and the control plan,
the inspector should request that plant personnel provide the information that
will allow the inspector to complete the example work sheet shown in
Figure 4-6. The inspector would conduct a full inspection of the facility in
order to obtain and verify actual operating conditions.
The inspector should spot-check the controlled roads by taking either
traffic counts or material grab samples from the road(s). The moisture or
silt content of the traveled portion of the roadway may be compared against a
minimum acceptable value specified in the control plan/operating permit to
determine compliance. This is considered to be an indirect method of compli-
ance determination as discussed in Section 2. For example, the control plan/
operating permit may specify that the control efficiency can never be below
75% or the average instantaneous control efficiency must not be below 85%. If
the latter is specified, more samples would be required because the instanta-
neous efficiency must be tracked over time.
To illustrate, assume that a facility waters unpaved road D (Figure 4-1)
every 3 h to control fugitive emissions. A field estimate of the control
efficiency can be determined by the following steps:
4-24
-------
1. Determine the uncontrolled moisture content by sampling prior to the
first control of the day and having the facility not water a small
portion of the road. Then collect a sample and determine moisture
content using the procedures found in Appendix F. The uncontrolled
moisture content needs only to be collected once. In this example,
the uncontrolled moisture 1s assumed equal to 1.5%.
2. Assume the facility waters road D (Figure 4-1) at noon and again at
3 p.m. A moisture sample should be taken right after water was
applied, at 1 p.m., 2 p.m., and again right before reapplication at
3 p.m.
3. Each sample should be analyzed for moisture content as quickly as
practical, again following the procedures found in Appendix F.
4. Next, the control efficiency can be determined by calculating the
controlled to uncontrolled ratio and using Figure 4-9. Assume the
following moistures from the four samples were:
Sample no. Time Moisture content (%)
ID Noon 6.75
2D 1 p.m. 6.00
3D 2 p.m. 5.25
4D 3 p.m. 3.75
Therefore, the moisture content ratios and associated control
efficiency values are:
Sample No. Ratio Control (%)
ID 6.75/1.5=4.5 92
2D 4.0 89
3D 3.5 85
4D 2.5 79
Average 86
The instantaneous control efficiencies for this example are shown on
Figure 4-13. Note that for this example, this facility would be in compliance
with both a minimum of the 75% instantaneous or 85% average control limits.
4.3.3 Chemical Treatments
4.3.3.1 Determination of Control Efficiency—
As noted in Section 4.2, some chemicals (most notably salts) simulate wet
suppression by attracting and retaining moisture on the road surface. These
methods are often supplemented by some watering. In these cases it is
4-25
-------
100%
o
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95%
RATIO OF CONTROLLED TO
UNCONTROLLED SURFACE
MOISTURE CONTENTS
Figure 4-13.
Watering control effectiveness for unpaved
road D in example problem.
4-26
-------
recommended that control efficiency estimates be obtained using Figure 4-9 and
enforcement be based on the grab sample moisture content technique described
above in Section 4.3.2.3.
The more commonly used chemical dust suppressants form a hard cemented
surface. It is this type of suppressant that is considered below.
Besides water, petroleum resins (such as Coherex) have historically been
the products most widely used and evaluated. However, considerable interest
has been shown in alternative chemical dust suppressants. These have included
asphalt emulsions, acrylics, and adhesives. In addition, "generic" petroleum
resin formulations (designed to be produced on-site) have gained considerable
attention. On-site production of this type of suppressant in quantities
commonly used at iron and steel plants has been estimated to reduce chemical
costs by approximately 50%.«
In an earlier test report, average performance curves were generated for
four chemical dust suppressants commonly used in the iron and steel indus-
try: (a) a commercially available petroleum resin; (b) a generic petroleum
resin for on-site production at an industrial facility; (c) an acrylic cement;
and (d) an asphalt emulsion.7 The results of this program were combined with
other test results to develop a model to estimate time-averaged PM10 control
performance. This model is illustrated as Figure 4-14. Several items are to
be noted:
• The term "ground inventory" is a measure of residual effects from
previous applications. Ground inventory is found by adding together
the total volume (per unit area) of concentrate (not solution) since
the start of the dust control season. An example is provided below.
• Note that no credit for control is assigned until the ground
inventory exceeds 0.05 gal/yd2.
• Because suppressants must be periodically reapplied to unpaved
roads, use of the time-averaged values given in the figure are
appropriate. Recommended minimum reapplication frequencies (as well
as alternatives) are discussed later in this section.
• Figure 4-14 represents an average of the four suppressants given
above. The basis of the methodology lies in a similar model for
petroleum resins only.7 However, agreement between the control
efficiency estimates given by Figure 4-14 and available field mea-
surements is reasonably good.
4.3.3.2 Record Keeping Review-
After becoming familiar with the plant facilities and the control plan,
the inspector should request that plant personnel provide the information that
will allow the inspector to complete the example inspection form shown in
Figure 4-6. The inspector would conduct a full inspection of the facility in
order to obtain and verify actual operating conditions. Specific records for
each road segment/parking area should include:
4-27
-------
0.25
(Iiters/m2)
0.5 0.75
1.25
a
UJ
CD
1 1 1
I-H Q
00
U_ LU
LU Q.
OS
Qi 1—1
O
CJ
(gal/yd2)
GROUND INVENTORY
Figure 4-14. Average PM10 control efficiency for chemical suppressants.
4-28
-------
1. Date of treatment.
2. Operator's initials (note that the operator may keep a separate log
of whose information is transferred to the environmental staff's
data sheets).
3. Start and stop times on a particular segment/parking lot, average
speed, number of passes, amount of solution applied, and dilution.
Figure 4-15 is a typical form which plant personnel can complete
when applying chemical dust suppressants to unpaved roads.
4. Qualitative description of road surface condition.
In addition, plant-wide records must be kept including:
1. Equipment maintenance records.
2. Suppressant delivery record. Figure 4-16 is an example.
3. Meteorological log (to the extent that weather influences the con-
trol program).
4. Any equipment malfunctions or downtime.
These plant-wide records provide the inspector with the information necessary
to cross-check the records kept for individual road segments. For example,
the start/stop inventories and suppressant delivery record should be compared
to the final ground inventory values over all roads at the facility. Also,
application records should be checked against the meteorological and equipment
maintenance/downtime records. The inspector should request plant personnel to
explain any discrepancies.
Another form which can be used as part of record keeping review of chemi-
cal control programs is presented in Figure 4-17. A completed form containing
typical data is shown in Figure 4-18. The following is an example using the
information in Figure 4-16 as applied to the determination of monthly average
control efficiency using Figure 4-14 above.
Suppose that Equation 4-1 has been used to estimate a PM10 emission
factor of 2.0 kg/VKT. Further, suppose that starting on May 1, the road is
treated with 0.25 gal/yd2 of a (1 part chemical to 5 parts water) solution on
the first of sach month until October. In this instance, the following
average controlled emission factors are found:
4-29
-------
Date Time delivered delivered agent Facility destination3 Comments
CO
o
a Denote whether suppressant will be applied immediately upon receipt or placed in storage.
Figure 4-15. Typical form for recording delivery of chemical dust suppressants.
-------
Applicat I on
Type of Dilution intensity. Equipment Operator
Date Time chemical ratio gal/ydz Area(s) treated used initials Comments
-P.
i
CO
Figure 4-16. Typical form for recording chemical dust suppressant control parameters.
-------
i
CO
ro
Site Desc
Treatment
No.
CHEMICAL SUPPRESSANT APPLICATION LOG AND WORKSHEET
t
\
ription
Date
Application
Intensity
(gal/yd2)
Dillution
Ratio
(watenchem)
Ground
Inventory
(gal/yd 2)
Period
(days)
Average
PM-10
Control (%)
Figure 4-17. Example chemical suppressant application log.
-------
CO
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Site Desc
Treatment
No.
1
2
3
H
5
CHEMICAL SUPPRESSANT APPLICATION LOG AND WORKSHEET
riotion
Date
S/l
4/1
7/1
8/1
I/I
Application
Intensity
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o.zs
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O.ZS
0.25
0.25
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(waterchem)
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5: i
5:1
5:1
5:1
Ground
Inventory
(gal/yd 2)
Period
(days)
vX\/NX\x^/\/^x\x\XN^^/^X^^N^N^N^^^N^\^N^N^^^N^N
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-------
Average
Average controlled
Ground control emission
inventory efficiency factor
Period (gal/yd 2) (%)a (kq/VKT)
May 0.042b 0 2.0
June 0.083 68 0.64
July 0.12 75 0.50
August 0.17 82 0.36
September 0.21 88 0.24
a From Figure 4-14; zero efficiency assigned if ground
inventory is less than 0.05 gal/yd2.
b 0.25 gal/yd2 x 1/6 = 0.042.
Additional topics must also be considered when inspecting roads con-
trolled by chemical dust suppressants. These are briefly discussed below.
* Use of paved road controls on chemically treated unpaved roads.
Repeated use of certain chemical dust suppressants tend, over time, to form
fairly impervious surfaces on unpaved roads. The resulting surface may allow
the use of paved road cleaning techniques (such as flushing, sweeping, etc.)
to reduce aggregate loading due to spillage and track-on. A field program
conducted tests on surfaces that had been flushed and vacuumed 3 d earlier.7
(The surfaces themselves had last been chemically treated 70 d before.) Con-
trol efficiency values of 90% or more (based on the uncontrolled emission
factor of the unpaved roads) were found for each particulate size fraction
considered.
The use of paved road techniques for "housekeeping" purposes would appear
to have the benefits of both high control (referenced to an uncontrolled
unpaved road) and potentially relatively low cost (compared to follow-up
chemical applications). Generally, it is recommended that these methods not
be employed until the ground inventory exceeds approximately 0.2 gal/yd2
(0.9 L/m2) and the paved controls be tested on a small portion of the
chemically treated road prior to full-scale implementation.
* Minimum reapplication frequency. Because unpaved roads in industry
are often used for the movement of materials and are often surrounded by addi-
tional unpaved travel areas, spillage and carryout onto the chemically treated
road require periodic "housekeeping" activities. In addition, gradual abra-
sion of the treated surface by traffic will result in loose material on the
surface which should be controlled.
It is recommended that at least dilute reapplications be employed every
month to control loose surface material unless paved road control techniques
are used (as described above). More frequent reapplications would be required
if spillage and track-on pose particular problems for a road.
4-34
-------
* Weather considerations. Roads generally have higher moisture contents
during cooler periods due to decreased evaporation. Small increases in sur-
face moisture may result in large increases in control efficiency (as refer-
enced to the dry summertime conditions inherent in the AP-42 unpaved road
predictive equation).a In addition, application of chemical dust suppressants
during cooler periods of the year may be inadvisable for traffic safety
reasons.
4.3.3.3 "In-Plant" Inspection Procedures for Chemical Treatment-
While record keeping affords a convenient method of assessing long-term
control performance, it is important that regulatory personnel have "spot-
check" compliance tools at their disposal (i.e., a hand broom and dustpan).
The inspector should broom sweep a portion of the road and determine silt
loading as described in Appendix F. The industrial paved road equation
(Equation 3-1) will conservatively overestimate controlled emissions:
Control efficiency (%) >
[Result from Equation 4-1 for p=0]
[Result from Equation 3-1]
Result from Equation 4-1 for p=0
x 100%
Note that this compliance tool (unlike others in this section) requires the
inspector to obtain the all-information necessary to estimate the two emission
factors (i.e., Equations 3-1 and 4-1).
4.4 REFERENCES FOR SECTION 4
1.
2.
3.
4.
5.
Environmental Protection Agency. Compilation of Air Pollution Emission
Factors (AP-42). Research Triangle Park, North Carolina. September
1985.
Climatic Atlas of the United States. U.S. Department of Commerce,
Washington, D.C. June 1968.
Rosbury, K. D. 1984. Fugitive Dust Control Techniques at Hazardous
Waste Sites. Interim Technical Report No. 1— Proposed Field Sampling
Plan, Contract No. 68-02-3512, WA 61, U.S. Environmental Protection
Agency, Municipal Environmental Research Laboratory, Cincinnati, Ohio.
March 1984.
Turner, J. H., et al. 1984. Fugitive Particulate Emissions From
Hazardous Waste Sites. Prepared for the U.S. Environmental Protection
Agency, Cincinnati, Ohio. September 1984.
Cowherd, C., Jr., and J. S. Kinsey. 1986. Identification, Assessment
and Control of Fugitive Particulate Emissions. EPA-600/8-86-023, U.S.
Environmental Protection Agency, Research Triangle Park, North Carolina.
4-35
-------
6. Russell, D., and S. C. Caruso. 1984. The Relative Effectiveness of a
Dust Suppressant for Use on Unpaved Roads Within the Iron and Steel
Industry. Presented at EPA/AISI Symposium on Iron and Steel Pollution
Abatement, Cleveland, Ohio. October 1984.
7. Muleski, 6. E., and C. Cowherd, Jr. Evaluation of the Effectiveness of
Chemical Dust Suppressants on Unpaved Roads. EPA-600/2-87-102, U.S.
Environmental Protection Agency, Research Triangle Park, North
Carolina. November 1987.
8. Muleski, G. E., T. Cuscino, Jr., and C. Cowherd, Jr. 1984. Extended
Evaluation of Unpaved Road Dust Suppressants in the Iron and Steel
Industry. EPA-600/2-84-027, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. February 1984.1
4-36
-------
SECTION 5
STORAGE PILES
Participate emissions from aggregate storage piles occur whenever the
material is disturbed, relocated, or subjected to wind speeds above the
material-specific erosion threshold value. The quantity of emissions released
from storage pile activity is dependent on the amount of material involved,
its moisture content, silt content, and friability. Emissions are also
affected by the material load-in, load-out, and maintenance techniques and by
the characteristics of vehicles traveling on and around the storage pile area.
Storage piles are found in most operations that use minerals in aggregate
form. Materials can be transferred to and from storage piles by a variety of
techniques which can include fixed stacker-reclaimer systems, front end-
loaders, scrapers, and other types of mobile equipment. Storage piles are
usually left exposed to the ambient winds because of the costs associated with
enclosing them and because of the impediment that enclosures cause to the
usual requirement for frequent material transfer.
There are two generally recognized mechanisms responsible for the direct
generation of dust emissions from storage pile operations. They include:
Materials handling operations, and
• Wind erosion.
In addition, if vehicular traffic is required for stockpiling activities,
vehicles can often be the predominant source of PM10 emissions from the
area. The traffic-related sources can be assessed, controlled and inspected
as discussed in detail in Section 4.
Particulate emissions from the two direct storage pile sources (i.e.,
materials handling and wind erosion) can be controlled by one of three general
methods. These include: containments to physically shelter the pile from
ambient winds; surface treatments to agglomerate exposed particulate; and
source extent control to reduce the amount of material handled and to enhance
natural crusting.
5.1 ESTIMATION OF EMISSIONS
Sections 5.1.1 and 5.1.2 provide methods that can be used for predicting
the emissions from materials handling and wind erosion sources associated with
storage piles. The quantity of emissions estimated by these techniques are
dependent on the physical characteristics of the stockpiled material, on the
amount of material handled, and on the local meteorology.
5-1
-------
If a fairly complete inventory of the area is needed, then the first step
toward the determination of storage pile emissions for a given facility is to
identify and map each pile within that facility. Figure 5-1 and Figure 5-2
are sample maps of an example facility X and of storage piles located within
that facility, respectively. Once the piles have been identified, estimates
can be obtained for the material throughput, the frequency with which the pile
surface is disturbed, pile perimeter dimensions, average pile height, and
vehicle specifications for any mobile equipment used on or around the storage
piles. In addition, climatological data from the nearest recording weather
station should be obtained.
Finally, any vehicular traffic related to the area must be identified and
emissions estimated using the information presented in Section 4. Figure 5-3
shows typical storage pile emissions for vehicular traffic and materials
handling operations.
5.1.1 Estimation of Emissions from Materials Handling Stockpiled Material
Adding aggregate material to a storage pile or removing it usually
involves the dropping of material onto a receiving surface or receptacle.
This can be performed by one of two methods: by continuous feed as exempli-
fied by conventional fixed stacker reclaimers, or by batch operations such as
would be performed by mobile equipment (i.e., front-end loader, truck, or pan
scraper) .
In order to estimate the emissions from the loading of material in and
out of storage piles, one must first obtain a sample of the stockpiled
material and a record of historical wind data at that location (Summaries of
Local Climatological Data).1 From the Local Climatological Data (LCD), the
mean wind speed can be obtained for the nearest recording weather station (as
illustrated by Figure 5-4). This wind speed can be adjusted from the
recording anemometer height to represent the wind speed at the average storage
pile height by using the procedure described in Section 11.2.7 of EPA's
Compilation of Emission Factors (AP-42).2 Aggregate sampling and subsequent
moisture analysis should then be performed on the sample(s) ,as described in
Appendix F.
Once the mean wind speed and the material moisture content have been
determined, the following equation can be used to estimate emissions from the
transfer operations (batch or continuous drop):
(JL) 1-3
E = k (0.0016) 1.* (kg/Mg) (5.!)
where: E = emission factor
k = particulate size multiplier (dimensionless) = 0.35 for PM10
U = mean approach wind speed (m/s), at height of transfer operation
M = material moisture content (percent)
5-2
-------
CJ1
I
co
Maintenance
Building
Figure 5-1. Map of example facility X.
-------
c
tn
Storage
Piles
-Slaging
Areas
F
H-Slaging Arca(s)
Figure 5-2. Map of storage piles located within facility X.
-------
(a) Storage pile vehicular traffic.
(b) Storage pile load-in with boom stacker.
Figure 5-3. Typical storage pile emission sources.
5-5
-------
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This equation shows that, for the handling of aggregate materials,
emissions increase with the ambient wind speed and are reduced as the material
moisture content increases.
5.1.2 Estimation of Emissions from Hind Erosion of Stockpiled Material
Field testing of various stockpiled surfaces using a portable wind tunnel
has demonstrated that;
a. Threshold wind speeds exceed 5 m/s (11 mph) at 15 cm above the pile
surface which is equivalent to 10 m/s (22 mph) at 7 m above the pile
surface.
b. Particulate emission rates tend to decay rapidly (half life of a few
minutes) during an erosion event.
c. Precipitation events cause natural crusting of surface material by
binding the erodible material, thereby reducing the erosion
potential.
Although in some instances wind erosion can be substantial, wind erosion is
usually considered the least significant of the mechanisms responsible for
dust emissions from storage piles. In most industrial settings, fugitive
emissions from vehicular traffic and materials handling overwhelm emissions
from wind erosion. If vehicular traffic is present in and around the storage
pile area, those emissions are generally far greater than that due to
materials handling.
If it is necessary to estimate the particulate emissions from the wind
erosion of storage piles, one must first obtain an aggregate sample of the
stockpiled material and a record of historical wind data for the nearest
recording meteorological station. From the Local ClimatologicaT Data (LCD)
the fastest mile of wind can be obtained for the nearest recording weather
station (as illustrated by Figure 5-5). The fastest mile of wind should then
be adjusted to represent the wind speed that impacts the storage pile surface
and an equivalent friction velocity determined as described in Section 11.2.7
of AP-42.2 Aggregate sampling and determination of the threshold friction
velocity should also be performed according to the procedures described in
Appendix F and AP-42, respectively.2
Once the friction velocity and the threshold friction velocity have been
determined, the erosion potential (P) can be calculated as:
P = 58 (u* - u*t)2 + 25 (u* - u\) (5-2)
where: u* = friction velocity (m/s)
ut = threshold friction velocity (m/s)
5-7
-------
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13
1 1
10
10
9
10
9
£ ¥
01 Q
Q. ^
-------
The emission factor, as a summation over periods between material
disturbances, can now be calculated as:
N
Emission factor = k ]T P. (5_3\
1=1 1
where: k = particle size multiplier = 0.5 for PM10
n = number of disturbances per year
P.J = erosion potential corresponding to the observed (or probable)
fastest mile of wind for the i^ period between disturbances
(g/m*)
In summary, emissions from wind erosion increase with the speed of wind
gusts and with the number of times that the material is disturbed. These
emissions can be controlled by reducing wind speeds and the number of dis-
turbances or by increasing the threshold friction velocity (which is a
function of the exposed surface particle size distribution).
5.1.3 Material Parameters Affecting Emissions
The two material properties that affect the quantity of emissions from
material handling and wind erosion are the materials threshold friction
velocity and its unbound moisture content. The threshold friction velocity is
a quantitative description of the condition under which the surface material
will begin to erode. It is a function of the material aggregate size dis-
tribution, density, and moisture content. The threshold friction velocity
can be estimated by performing the sieving procedure outlined in Sec-
tion 11.2.7 of AP-42. The moisture content of a given material simply
describes the amount of water retained on the surface of the aggregate
material (see Appendix F).
Typical silt values, and unbound moisture content values for some
industrial aggregate materials are summarized in Table 5-1. Threshold fric-
tion velocities and the associated wind speeds (as measured at 10 m) are
presented in Tables 5-2 and 5-3 for typical aggregate materials and soils,
respectively. Estimates for emissions are considered more accurate if site
specific data are used.
5.2 EMISSION CONTROL METHODS
As described in Table 5-4, there are a variety of options for the control
of particulate emissions from storage piles. Note that these controls fall
into one of four general categories. Each of these is discussed in greater
detail below.
5-9
-------
TABLE 5-1. TYPICAL SILT AND MOISTURE CONTENT VALUES OF MATERIALS AT VARIOUS INDUSTRIES
1 ndustry
Iron and steel production3
Stone quarrying and processing
Taconite mining and processing0
Western surface coal mining
^References 2 through 5. NA = not
Reference 1.
^Reference 6.
Reference 7.
Material
Pel let ore
Lump ore
Coal
Slag
Flue dust
Coke breeze
Blended ore
Sinter
L imestone
Crushed 1 imestone
Pel lets
Tai 1 ings
Coal
Overburden
Exposed ground
appl icable.
No. of
test
samples
10
9
7
3
2
1
1
1
1
2
9
2
15
15
3
Silt, percent
Range
1.4-13
2.8-19
2-7.7
3-7.3
14-23
1.3-1.9
2.2-5.4
NA
3.4-16
3.8-15
5.1-21
Mean
4.9
9.5
5
5.3
18.0
5.4
15.0
0.7
0.4
1.6
3.4
11.0
6.2
7.5
15.0
No. of
test
samples
8
6
6
3
0
1
1
0
0
2
7
1
7
0
3
Moisture, percent
Range
0.64-3.5
1.6-8.1
2.8-11
0.25-2.2
NA
NA
NA
0.3-1.1
0.05-2.3
2.8-20
NA
0.8-6.4
Mean
2.1
5.4
4.8
0.92
NA
6.4
6.6
NA
NA
0.7
0.96
0.35
6.9
NA
3.4
-------
TABLE 5-2. THRESHOLD FRICTION VELOCITIES—ARIZONA SITES
Location
Mesa - Agricultural site
Glendale - Construction site
Maricopa - Agricultural site
Yuma - Disturbed desert
Yuma - Agricultural site
Algodones - Dune flats
Yuma - Scrub desert
Santa Cruz River, Tucson
Tucson - Construction site
A jo - Mine tailings
Hayden - Mine tailings
Salt River, Mesa
Casa Grande - Abandoned
agricultural land
Threshold
friction
velocity,
m/sec
0.57
0.53
0.58
0.32
0.58
0.62
0.39
0.18
0.25
0.23
0.17
0.22
0.25
Roughness
height,
(cm)
0.0331
0.0301
0.1255
0.0731
0.0224
0.0166
0.0163
0.0204
0.0181
0.0176
0.0141
0.0100
0.0067
Threshold
wind velocity
at 10 m,
m/sec
16
15
14
8
17
18
11
5
7
7
5
7
8
5-11
-------
TABLE 5-3. THRESHOLD FRICTION VELOCITIES—INDUSTRIAL AGGREGATES
Threshold wind
Material
Overburden3
Scoria (roadbed
Threshold
friction
velocity,
m/s
1.02
1.33
velocity at
Roughness
height,
cm
0.3
0.3
10 m
actual
21
27
(m/s)
0?5 cm
19
25
Ref.
7
7
material)3
Ground coal3
(surrounding coal
pile)
0.55
0.01
16
10
Uncrusted coal pile
Scraper tracks on
coal pile3'0
Fine coal dust on
concrete padc
1.12
0.62
0.54
0.3
0.06
0.2
23
15
11
21
12
10
7
7
12
3Western surface coal mine.
Lightly crusted.
GEastern power plant.
TABLE 5-4. CONTROL TECHNIQUES FOR EMISSIONS FROM STORAGE PILES
Containment
Surface Treatments
Source Extent
Natural Events
Buildings\Si1os
Wind fences
Selective siting
Watering
Chemical stabilization
- Petroleum resins
- Acrylic cements
- Other
Reduced transfer operations
Reduced disturbance area
Reduced vehicular traffic
Previous erosion of fines
Crusting by precipitation
5-12
-------
5.2.1 Emissions Control by Containment
Storage piles are usually left exposed to the ambient winds because of
the costs associated with enclosures and the impediment that enclosures can
cause to the frequent material transfer often necessary. Containment of these
piles can be described as the physical separation of the storage pile from the
ambient air and its associated winds. Typically used containment strategies
include shielding by topography, wind fences, neighboring buildings, or other
storage piles; or partial or complete enclosure of the storage pile with a
dedicated structure.
Containment by selective siting is often an inexpensive method of
removing a storage pile from the winds that could generate emissions. It can
include the placement of an active storage pile within several more dormant
piles, within a natural depression, or among buildings.
The erection of a dedicated structure for containment of storage piles is
also practiced within industry. These structures often consist of wind
fences, three sided bunkers, silos, or completely enclosed buildings or
bins. Although potentially expensive and somewhat restrictive, this is a very
effective method of controlling particulate emissions. Often this method is
used to protect materials which deteriorate in weather, for the conservation
of expensive minerals, or to control emissions from small storage piles of
fine, highly erodible material.
5.2.2 Emissions Control by Surface Treatments
Surface treatments are used to wet or agglomerate exposed fine mate-
rial. Commonly used surface treatments include water (alone, with surfac-
tants, or with salts), petroleum binders, and latex binders. These methods
can be very effective until the time when the treated surface is disturbed or
covered. Water with or without wetting agents such as salts, surfactants, and
foams are commonly used to control emissions from active storage piles. This
technique affects material to a much greater depth then can be reached by
binding agents and produces a substantially greater control efficiency for
emissions from materials handling. Surface treatments accomplish wind erosion
control by increasing the threshold friction velocity of an exposed material.
5.2.3 Emissions Controlled by Source Extent Reduction
Source extent control refers to limiting the amount of aggregate material
put through storage (materials handling) or the surface area disturbed (wind
erosion). This can include reducing the number of material transfer opera-
tions necessary in a process, restricting the area disturbed by transfer and
pile maintenance operations, or restricting the amount of vehicular traffic
permitted on or around stockpiled material.
5.2.4 Emissions Control by Natural Methods
Finally, simply allowing the pile to crust naturally is an effective
control technique for wind erosion control of most stockpiled materials. Wind
erosion events remove the exposed surface fine particulate, leaving behind the
5-13
-------
coarse nonerodible aggregate. In addition, naturally occurring precipitation
tends to agglomerate most aggregate material. Inactivity can provide a
natural crust comparable to those achieved by surface treatments
5.3 REGULATORY FORMATS AND ASSOCIATED INSPECTION PROCEDURES
Once a specific PM10 control strategy has been conceived, approved, and
implemented, it becomes necessary for the control agency to assure that it is
being complied with and is achieving the desired level of control. This
section will discuss methods for determining compliance, along with inspection
procedures for various storage pile control strategies.
5.3.1 General Inspection Procedures and Compliance Information
5.3.1.1 General Inspection Procedures-
Figure 5-6 is an example inspection form which may be completed by
interviewing plant personnel at the beginning of a Level II or Level III
inspection. After discussing any changes in sources since the last inspection
with plant personnel, a more through field inspection should be performed.
Field inspections of control programs for dust from storage piles could
include the following steps:
1. Verification of sources located within the facility.
2. Qualitative inspection of surface material moisture or crusting.
3. Spot checks on the control application.
4. Spot checks on storage pile source extent.
5. Surface material sampling so that emissions can be estimated.
Each of these is discussed in more detail below.
The first step in any field inspection is a simple drive or walk through
the facility to verify the continued existence of previous sources, the
absence of new sources, and any changes identified by plant personnel.
To determine the effectiveness of strategies that depend on containment
techniques for dust control, a qualitative inspection should be adequate.
This inspection would simply require a verification of the existence and
integrity of the specified enclosure to determine compliance.
To determine compliance for a watering program, it is often adequate
simply to pick up handfuls of the storage pile surface material and examine
for wetness or to observe material transfer operations for emissions. Porta-
ble moisture instruments may also be useful to estimate the overall moisture
content of the pile material. If visible emissions are observed, an aggregate
sample may be collected for moisture analysis, as described in Appendix F to
determine compliance as appropriate.
5-14
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Business License Name of Corporation, Company, or Individual Owner or Governmental Agency:
Mai I ing Address:
Plant Address:
Name and Title of Company Representative:
Telephone Number:
Name of Official Conducting Inspection:
General Questions for Plant Personnel
1. Any new storage piles since last inspection?
2. Have any storage piles been deleted since last inspection?
3. Have any storage piles been left dormant since last
inspection?
4. Has any of the source extent associated with storage piles
^ changed since last inspection (i.e., reduced transfer
i operations, material drops heights, material thruput, and
— ' vehicular traffic on or around piles) ?
Controls
5. Have any changes been made in control program since last
inspection?
Waterincr
6. Any new equipment?
7. Any equipment downtime since last inspection?
Chemicals
8. Any receipts since last inspection?
9 . Any new equipment?
10. Any equipment downtime since last inspection?
11. Any supplemental control since last inspection?
Yes*
No
N/A
Comments
Figure 5-6. Sample inspection form.
-------
A qualitative inspection of surface treatment controls on undisturbed
portions of storage piles should verify that a control has been applied, and
also that it has been applied in a somewhat uniform manner over the entire
exposed surface. This is important because the uneven application of a
surface treatment can severely compromise the net control efficiency, regard-
less of the amount applied. Visual inspection is usually adequate to
determine where binders have been applied to aggregate material.
If large areas of inspected storage piles are found to be dry or
uncrusted (for water and chemically treatments, respectively), then these
deficiencies should be noted. If possible, it is recommended that the
inspector observe at least one application of any surface control to verify
application intensity and the uniformity of the application. This can be done
by placing preweighed pans on the stockpile surface during the control appli-
cation, reweighing them after the application, and dividing the mass collected
by the area of the pan.
In addition, note should be made of the source extent of materials
handled, of the amount of vehicle traffic on and around the stockpiles, and of
any visible emissions from these sources. Visible emissions can indicate
inadequacy in the control plan or its implementation.
For storage piles that are controlled simply by their dormant nature,
compliance can usually be determined by visual observation that the surface
(and any crust) has not been disturbed.
5.3.1.2 Plant Record Keeping Requirements—
Determination of storage pile control compliance by the review of plant
records can be performed for surface treatment controls and for reduced source
extent strategies. For surface treatments, plant records must be kept to
document the date, time, amount, and dilution (if applicable) of water/
chemical suppressant applied, and a description of where that control was
applied. For strategies based on reductions in source extent, records must be
kept of the amount of material transferred, the dates and times of equipment
usage for this transfer, or of vehicular usage on and around the storage
piles.
Record keeping for a storage pile dust control plan should include the
following elements:
Watering
The amount of water applied to each stock piled material and the
proposed frequency of application.
Any provisions for the reduction or suspension of the control
application during periods of inactivity or during specified weather
events (e.g., 1/4 in of rainfall to substitute for one treatment;
program suspended during freezing periods or during production
shutdowns; watering frequency as a function of temperature, cloud
cover, etc.).
5-16
-------
• Source of water and a description of any additives for performance
enhancement (i.e., salts, surfactants, etc.).
Chemical Treatments
Type of chemical to be applied to each storage pile, the dilution
ratio, application intensity, and the frequency of application.
Any provisions for the reduction or suspension of the control
application during periods of material inactivity or during speci-
fied weather events (e.g., 1/4 in of rainfall to substitute for one
treatment; program suspended during freezing periods; watering
frequency as a function of temperature, cloud cover, etc.).
Source Extent Reductions
• The time and identification of any mobile equipment used in the
storage pile area before and after implementation of the control
plan.
The times when any fixed stacker-reclaimer equipment would be used,
and an estimate of how much material was moved before and after
implementation of the control plan.
5.3.2 Watering
5.3.2.1 Record Keeping Review
To determine compliance from plant records, the facility must have
records that include:
1. Date of treatment.
2. Operators identification as a signature or initials (note that the
operator may keep a separate log from which information is trans-
ferred to the environmental staff's data sheets).
3. Start and stop times of the treatment on each storage pile,
approximate amount of water used, and the approximate area treated.
4. Description of any additive used (i.e., salts, surfactants, etc.).
Figure 5-7 is an example form which the equipment operator can complete
when applying water to storage piles. In addition, plant-wide records must be
kept which include:
1. Equipment maintenance records.
2. Meteorological log (to document the influence of weather on the
control program).
3. Documentation of any equipment malfunctions or downtime.
5-17
-------
Facility X Water Control Program—Operator's Log
Trink Fill T line
Date Start Stop Start
Road Segments/Areas Trent eel
S|-op
Comments
1 n i f i ..i 1 •
en
CO
£, 7.--.:-o 7:/o
7:25
3 ' 5
• e *~ 1
'Jo
3
9:3 o
J /
/-
Figure 5-7. Operator's log for example facility X.
-------
Documentation which contains these elements will allow an inspector to
determine compliance by reviewing the historical data. Below, a procedure is
described which allows the inspector to perform an on-site, independent
assessment of the control.
5.3.2.2 Example Compliance Determination—Record Keeping for a Watering
Program—
This example considers the hypothetical facility X which is shown in
Figure 5-1 with the storage piles shown in greater detail in Figure 5-2.
Facility X is located in a PM10 nonattainment area and has an approved dust
control plan that specifies the following conditions:
1. Application intensity > 0.15 gal/yd2-
2. Application frequency of once/10 h workday.
3. Watering according to the application parameters is to be performed
from April 1 through October 31.
4. Each 1/4 in of rainfall (in the previous 24 h) will be substituted
for one treatment, and the program will be suspended for days where
the morning temperature (8 a.m.) does not exceed 32°F.
Note that the permit also specifies watering between 11:00 a.m. and 3:00 p.m.
when the ambient temperature at 11:00 a.m. is > 40°F for the period from
November 1 to March 31.
An example of how records could be used to determine compliance for
facility X is given below. Facility X maintains the following three storage
piles:
Storage Pile Height Approx. Area Throughput
(ft) (sq. ft) (tons/yr)
1 20 5,000 10,000
2 15 1,500 500
3 15 2,500 4,000
The facility leases one 5,000-gal water truck and operator from a contractor
on an as needed basis. This equipment has a water cannon capable of spraying
water 50 ft. No additives to the water are used at this facility.
Example records kept by facility X to document its program of watering
storage piles are shown in Figure 5-8 (meteorological data log), and
Figure 5-7 (operator's log). The inspector responsible for the facility
would, in practice, compare these two records with the permit conditions to
determine compliance. This check should verify that all storage piles have
been treated daily (except after significant rainfall or under freezing
conditions).
5-19
-------
Facility X Meteorological Data Log
Montf
Day
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
i/Year:
Obs.
Time
8: 05
ms
81/0
2'IQ
^
2:05
2: 05
2:65
2:05
s;as
8:C6
8:05
g:05
Precipitation Temperature
(in) (°F)
O. |Q
0.08
5.10.
64
"78
73-
71
71
74
71
70
74
"70,
78
75
Observer
Comments
OV\
Figure 5-8. Meteorological data for example facility X.
5-20
-------
If it is suspected that the documentation is inaccurate (i.e., treatments
are logged for periods where no water was applied), then the operator's log
can be cross-checked against other records. For example, cross-checking would
be performed against facility records for maintenance/service of the water
truck, or against contractor invoices if the equipment is leased, as in the
above example. Both of these sources typically contain more complete records
then those kept for an emissions control program. If these records do not
match the operator's log, then the facility should be required to submit a
written explanation for the apparent discrepancy.
Information compiled in the operator's log represents critical data
against which operations observed during Level II and Level III inspections
should be evaluated. For example, Figure 5-7 provides a basis for estimating
the typical length of time and number of trucks full of water were required to
wet all of the storage piles within a facility. These values can be checked
against an application observed during the inspection. If the during the
inspection, the observed time for an application or required number of trucks
full of water required to treat a group of storage piles varies significantly
from what is indicated in the operator's log, then the inspector should
require the facility to explain the apparent discrepancy. As stated above,
this inspection should also verify that the water is being applied somewhat
uniformly to the storage piles surface area.
An example that applies this procedure to facility X is demonstrated
below:
1. On June 1, the operator's log indicates that the first two trucks
full of water were used to wet storage pile Nos. 1 and 2 and a third
truck full of water was used to wet storage pile No. 3.
2. About 10 min was required to fill each of the first two trucks, and
only 5 min to fill the third truck.
3. The log also indicates that the treatment of storage pile No. 1
required 25 min to empty the first truck of water, and 15 min to
complete the pile with the second truck of water. Treatment of
storage pile No. 2 took 6 min, and treatment of storage pile No. 3
took 16 min.
4. During the inspection it is noted that 10 min is required to fill
the truck and 12.5 min of actual spraying time to empty it.
From these data it can be assumed that approximately 8,000 gal of water was
probably applied to storage pile No. 1 (0.18 gal/yd2) from the first two
trucks; about 2,000 gal was probably applied to storage pile No. 2
(0.1 gal/yd2) with what was left in the second truck; and finally if
0.15 gal/yd2 was applied to piles 1 and 2 then truck 2 came back empty, and
only about 2,500 gal (5 min to fill the third truck) was available for pile
No. 3 (0.1 gal/yd2). These estimates indicate a potential violation of the
minimum application intensity of 0.15 gal/yd2 specified in the dust control
plan.
5-21
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5.3.2.3 "In-Plant" Inspection Procedures
An "in-plant" inspection to determine compliance with fugitive dust rules
or permit conditions for storage piles involves focusing on several items.
They include:
A visual inspection of the facility to verify that all of the
existing storage piles are listed in the permit/control plan.
An examination of the source's records (as described above)
documenting frequency of water application, amount applied, storage
piles watered, meteorology affecting watering, etc.
• Observation of any spraying operations undertaken during the
inspectors visit.
After becoming familiar with the plant facilities and the control plan, the
inspector should request that the plant personnel provide the information
necessary to complete the example work sheet shown in Figure 5-6. The
inspector should then conduct a full inspection of the facility in order to
obtain and verify the actual control conditions. If water is being applied on
the day of the inspection, then this should be observed as described above.
If there is a minimum moisture content criteria specified in the control
plan/operating permit, then the inspector could spot-check the moisture
content of stockpiled material by using the procedure described in
Appendix F. If there is a question as to whether the current control strategy
is adequate, an aggregate sample should be taken so that emissions can be
estimated as described in Section 5.1. Finally, the inspector should review
the plant records to verify that the controls have been applied appropriately
since the last inspection.
5.3.3 Chemical Treatments
5.3.3.1 Example Compliance Determination—Record Keeping for a Chemical
Control Program—
This example considers the hypothetical facility X shown in Figure 5-1
with the storage piles shown in greater detail in Figure 5-2. Facility X is
located in a PM10 nonattainment area and has an approved dust control plan
that specifies the following conditions:
1. Application of an emulsified petroleum dust suppressant.
2. Application intensity >0.1 gal/yd2.
3. Dilution of 1 part suppressant to 10 parts water.
4. Application frequency of twice/work week if material has been
disturbed since the last application. Once/2 weeks for dormant
material.
5. Chemical suppression according to the application parameters is to
be performed from April 1 through October 31.
5-22
-------
6. Each 1/4 in of rainfall (in the previous 24 h) will be substituted
for one treatment, and the program will be suspended for days where
the morning temperature (8 a.m.) does not exceed 32°F.
Note that the permit also specifies chemical suppression between 11:00 a.m.
and 3:00 p.m. when the ambient temperature at 11:00 a.m. is > 40°F for the
period from November 1 to March 31.
An example of how records could be used to determine compliance for
facility X is given below. Facility X maintains the following three storage
piles:
Height Approx. area Throughput
Storage pile (ft) (sq ft) (tons/yr)
1 20 5,000 10,000
2 15 1,500 500
3 15 2,500 4,000
The facility leases one 5,000-gal water truck and operator from a contractor
on an as-needed basis. This equipment has a water cannon capable of spraying
the suppressant 50 ft. The facility has a receipt for a 5,000 gal order of
Coherex® that was delivered in late March. By multiplying the total storage
pile area, 1,000 yd2 by the required 0.1 gal of Coherex required per yd2 per
application, it can be estimated that about 100 gal of Coherex are used per
application day. Example records kept by facility X to document days for
which the treatment of storage piles was not necessary, are shown in
Figure 5-8 (meteorological data log). Plant personnel indicated that other
than rain days, there were no days when treatments were not applied. The
inspector responsible for the facility would, in practice, compare the amount
of Coherex used from the storage tank with what the records and invoices
indicate should have been used.
If there are claims that treatments have been reduced because the mate-
rial has been dormant, then records kept by the storage yard foreman can often
be checked for verification. These checks should verify when storage piles
have been treated.
If it is suspected that the documentation is inaccurate (i.e., treatments
are logged for periods where no suppressant was applied), then the operator's
log can be cross-checked against other records. For example, cross-checking
would be performed against facility records for maintenance/service of the
water truck or, against contractor invoices if the equipment is leased, as in
the above example. Both of these sources typically contain more complete
records then those kept for a control program. If the two sets of records do
not match, then the facility should be required to submit a written
explanation for the apparent discrepancy.
Information compiled in the operator's log also represents critical data
against which operations observed during Level II and Level III inspections
5-23
-------
should be evaluated. For example, Figure 5-9 provides a basis for estimating
the typical length of time and number of trucks full of suppressant required
to treat all of the storage piles within a facility. These values can be
checked against an application observed during the inspection as described for
watering in 5.3.2.
If during the inspection the observed time for an application or required
number of trucks full of suppressant necessary to treat a given group of
storage piles varies significantly from what is indicated in the operator's
log, then the inspector should require that the facility explain the apparent
differences. As stated above, this inspection should also verify that the
suppressant is being applied somewhat uniformly to the storage piles surface
area. This can be performed by placing preweighed pans on the stockpile
surface during the control application, reweighing them after the application,
and dividing the mass collected by the pans area.
5.3.3.2 "In-Plant" Inspection Procedures—
An "in-plant" inspection to determine compliance with fugitive dust rules
or permit conditions for storage piles involves focusing on several items.
They include:
• A visual inspection of the facility to verify that all of the
existing storage piles are listed in the state permit/control plan.
• An examination of the source's records (as described above)
documenting frequency of suppressant application, amount applied,
storage piles treated, meteorology and plant activity affecting
treatment requirements, etc.
• Observation of any spraying operations undertaken during the
inspectors visit.
After becoming familiar with the plant facilities and the control plan,
the inspector should request that the plant personnel provide the information
necessary to complete the example work sheet shown in Figure 5-6. The
inspector should then conduct a full inspection of the facility in order to
obtain and verify the actual operating conditions. If suppressant is being
applied on the day of the inspection, then this should be observed as
described above.
If there is a maximum silt content criteria specified in the control
plan/operating permit, then the inspector could spot-check the silt content of
stockpiled material by using the procedure described in Appendix F. If there
is a question as to whether the current control strategy is adequate, an
aggregate sample should be taken so that emissions can be estimated as
described in Section 11.2.7 of EPA's AP-42. Finally, the inspector should
review the plant records to verify that the controls have been applied
appropriately since the last inspection.
5-24
-------
Facility X Water Control Progriim—Operator's Log
Tank Fill Time
Aroar, Trofilctl
IJ.ito Stiirt Slon Slart
STop
Comment
Op.
I n i f i .1 1 •
7.70 i^
£,.'!&>
7/;*o 7/30
ro
en
8: 30
4/23- ^^
VQ
l^i /»
Figure 5-9. Operator's log for example facility X.
-------
5.4 REFERENCES FOR SECTION 5
1. Local Climatological Data, Annual Summaries for 1988, Department of
Commerce, National Oceanic and Atmospheric Administration, National
Environmental Satellite, Data and Information Service, National Climatic
Data Center, Federal Building, Asheville, NC 28801.
2. Compilation of Air Pollutant Emission Factors, Volume 1, Stationary Point and
Area Sources, U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC 27711.
5-26
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APPENDIX A
SIP REQUIREMENTS FOR THE CONTROL OF PM10
A-l
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APPENDIX A
SIP REQUIREMENTS FOR THE CONTROL OF PM10
The following pages contain excerpts from the July 1, 1987, Federal
Register pertaining to the revision of State Implementation Plans to include
PM10.
A-2
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24712 Federal Register / Vol. 52, No. 126 / Wednesday, July 1, 1987 / Rules and Regulations
PART 51—REQUIREMENTS FOR
PREPARATION, ADOPTION, AND
SUBMITTAL Of IMPLEMENTATION
PLANS
For the reasons set forth in the
preamble, EPA amends Part 51 of
Chapter I of Title 40 of the Code of
Federal Regulations as follows:
1. The authority citation for Part 51 is
revised to read as follows:
Authority: This rulemaking is promulgated
under authority of sections 101(b)(l), 110,
160-169.171-178. and 301(a) of the Clean Air
Act 42 U.S.C. 7401(b)(l), 7410, 7470-7479,
7501-7508, and 7§01(a).
2. In § 51.100, paragraphs (oo), (pp),
(qq), (IT) and (ss) are added to read as
follows:
§51.100 Definitions.
*****
(oo) "Particulate matter" means any
airborne finely divided solid or liquid
material with an aerodynamic diameter
smaller than 100 micrometers.
(pp) "Particulate matter emissions"
means all finely divided sofid or liquid
material, other than uncombined water,
emitted to the ambient air as measured
by applicable reference methods, or an
equivalent or alternative method.
specified in this chapter, or by a test
method specified in aa approved State
implementation plan.
(qq) "PMio" meaas particnlale matter
with an aerodynamic diameter less than
or equal to a nominal 10 micrometers as
measured by a reference method based
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Federal Register / Vol. 52. No. 126 / Wednesday. July 1, 1987 / Rules and Regulations 24713
on Appendix J of Part 50 of this chapter
and designated in accordance with Part
53 of this chapter or by an equivalent
method designated in accordance with
Part 53 of this chapter.
(rr) "PMio emissions" means finely
divided solid or liquid material, with an
aerodynamic diameter less than or equal
to a nominal 10 micrometers emitted to
the ambient air as measured by an
applicable reference method, or an
equivalent or alternative method,
specified in this chapter or by a test
method specified in an approved State
implementation plan.
(ss) "Total suspended particulate"
means particulate matter as measured
by the method described in Appendix B
of Part 50 of this chapter.
3. In § 51.151, the third unnumbered
subdivision beginning "sulfur dioxide
and particulate matter combined" is
removed and the second unnumbered
subdivision beginning "particulate
matter" is revised to read as follows:
§51.151 Significant harm levels.
*****
PMio—600 micrograms/cubic meter 24-
hour average.
4. In § 51.165, the fourth entry in the
list in paragraph (a)(l)(x) is removed
and paragraph (b) is revised to read as
follows:
§ 51.151 Permit requirements.
*****
(b)(l) Each plan shall include a
preconstmction review permit program
or its equivalent to satisfy the
requirements of section 110(a)(2)(D)(i) of
the Act for any new major stationary
source or major modification as defined
in paragraphs (a)(l) (iv) and (v) of this
section. Such a program shall apply to
any such source or modification that
would locate in any area designated as
attainment or unclassifiable for any
national ambient air quality standard
pursuant to section 107 of the Act, when
it would cause or contribute to a
violation of any national ambient air
quality standard.
(2) A major source or major
modification will be considered to cause
or contribute to a violation of a national
ambient air quality standard when such
source or modification would, at a
minimum, exceed the following
significance levels at any locality that
does not or would not meet the
applicable national standard:
Pollutant
SOi
PM,0
NO,
CO .
Annual
1.0 ^gyrrt3
Averaging time (hours)
24
5 Nfl'"?3
8
3
25 mj/m1-
1
2 mg/m3
(3) Such a program may include a
provision which allows a proposed
major source or major modification
subject to paragraph (b) of this section
to reduce the impact of its emissions
upon air quality by obtaining sufficient
emission reductions to, at a minimum,
compensate for its adverse ambient
impact where the major source or major
modification would otherwise cause or
contribute to a violation of any national
ambient air quality standard. The plan
shall require that, in the absence of such
emission reductions, the State or local
agency shall deny the proposed
construction.
(4) The requirements of paragraph (b)
of this section shall not apply to a major
stationary source or major modification
with respect to a particular pollutant if
the owner or operator demonstrates
that, as to that pollutant, the source or
modification is located in an area
designated as nonattainment pursuant
to section 107 of tne Act.
5. In § 51.166, paragraph (a)(6)(i) is
revised, the fourth entry in the list in
paragraph (b](23)(i) is revised, the
entries under the headings "Particulate
matter" in the tables in paragraphs (c)
and (p)(4) are revised, paragraphs
(i)(8)(i) (c), (/), (h), and (/) are revised.
and new paragraph (i)(10) is added to
read as follows:
§ 51.166 Prevention of significant
deterioration of air quality.
(6) * * *
(i) Any State required to revise its
implementation plan by reason of an
amendment to this section, including
any amendment adopted simultaneously
with this paragraph, shall adopt and
submit such plan revision to the
Administrator for approval within 9
months after the effective date of the
new amendments.
*****
(b) * * *
(23)(i) * * *
Particulate mailer: 25 tpy of particulale
matter emissions. 15 tpy of PM,0 emissions.
* * * * .
(o) * ' *
Pollutant
Maximum
allowable
increases
(mtcrograms
per cubic
meler)
Class I
Particulate matter
TSP. annual geometric mean
TSP. 24-hr maximum
Class II
Particulata matter
TSP, annual geometric mean
TSP. 24-hf maximum
Class III
Particulate matter
TSP. annual geometric mean .
TSP. 24-hr maximum. —
5
10
19
37
37
75
*****
/•;•» * * *
(8) * ' *
(i) * * *
(c) Particulate matter—10 jig/m3 TSP,
24-hour average.—10 fig/m3 PMio, 24-
hour average.
(/) Lead—0.1 fig/m3, 3-month average.
[h] Beryllium—0.001 fig/m3, 24-hour
average:
(/) Hydrogen sulfide—0.2 ^g/m3.1-
hour average:
* * *
(10) If EPA approves a plan revision
under § 51.166 as in effect before "July 31,
1987 , any subsequent revision which
meets the requirements of this section
may contain transition provisions which
parallel .the transition provisions of
§52.21 (i)(ll)(i)(iii). and (m)(l) (vii) and
(viii) of this chapter as in effect on that
date, these provisions being related to
monitoring requirements for particulate
matter. Any such subsequent revision
may not contain any transition provision
which in the context of the revision
would operate any less stringently than
would its counterpart in §52.21 of this
chapter.
*****
(P) * * '
Pollutant
Maximum
allowable
Increases
(micro-
grams per
cubic
meter)
Particulate mailer
TSP. annual geometric mean..
TSP. 24-hr maximum
19
37
A-4
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24714 Federal Register / Vol. 52. No. 126 / Wednesday. July 1, 1987 / Rules and Regulation*
allowable
Pollute*
(micro-
grams per
cube
meter)
6. In 8 51.322. paragraphs (a)(l) and
(b)(l) are revised to read as follows:
{ 51.322 Sources subject to emissions
reporting.
(a) * • *
(1) For participate matter. PMio, sulfur
oxides, VOC and nitrogen oxides, any
facility that actually emits a total of 90.7
metric tons (100 tons) per year or more
of any one pollutant. For participate
matter emissions, the reporting
requirement ends with the reporting of
calendar year 1987 emissions. For PMio
emissions, the reporting requirement
begins with the reporting of calendar
year 1988 emissions.
• * • * *
(b) * ' *
(1) For participate matter, PMio, sulfur
oxides, VOC and nitrogen oxides. 22.7
metric tons (25 tons) per year or more.
For participate matter, the reporting
requirement ends with the reporting of
calendar year 1987 emissions. For PM,0,
the reporting requirement begins with
the reporting of calendar year 1988
emissions.
• * * • •
7. In 5 51.323, paragraphs (a)(l) and
(a)(2) are revised and paragraph (a)(3) is
added to read as follows:
S 51.323 Reportabto emissions data and
Information.
(a)' * *
(1) Emissions of participate matter,
sulfur oxides, carbon monoxide,
nitrogen oxides, and VOC as specified
by AEROS Users Manual. Vol. II (EPA
450/2-76-029, OAQPS No. 1.2-039) to be
coded into the National Emissions Data
System point source coding form,
. (2) Emissions of lead or lead
compounds measured as elemental lead
as specified by AEROS Users Manual.
Vol. II (EPA 45/2-76-029. OAQPS No.
1.2-039) to be coded into the Hazardous
and Trace Emissions System points
source coding forms, and
(3) Emissions of PMio as will be
specified in a future guideline.
*****
8. In Appendix L, paragraphs 1.1 (b),
(c), and (d) are amended by removing
the unnumbered subdivisions beginning
"SOj and particulate combined" and by
revising the unnumbered subdivisions
beginning "Particulate" to read as
follows:
Appendix L—[Amended]
APPENDIX L—EXAMPLE
REGULATIONS FOR PREVENTION OF
AIR POLLUTION EMERGENCY
EPISODES
1.1 •*•
(b)' * '
PMio—350 ng/ms, 24-hour average.
(c) ' ' *
PMio—420 pg/m1, 24-hour average.
(d)« ' '
PMio—500 fig/m3, 24-hour average.
Appendix S—[Amended]
9. In Appendix S, the fourth line
beginning "Particulate matter" in the list
in section llJV.10(k) is amended by
adding the words "of particulate matter
emissions" after the words "25 tpy."
PART 52—APPROVAL AND
PROMULGATION OF
IMPLEMENTATION PLANS
For the reasons set out in the
preamble, Part 52 of Chapter I of Title 40
of the Code of Federal Regulations is
amended as follows:
1. The authority citation for Part 52
continues to read as follows:
Authority: 42 U.S.C. 7401-7642.
2. In S 52.21. the fourth item in the
table in paragraph (b)(23)(i) is revised;
the entries under the heading
"Particulate matter" in the tables in
paragraphs (c) and (p)(5) are revised;
paragraphs (i)(4) (ix) and (x) are added;
the third, sixth, eighth, and twelfth items
in the list in paragraph (i)(B)(i) are
revised; paragraph (i)(ll), and
paragraphs {m)(l)(vii) and (viii) are
added; and paragraph (w)(2) is revised
as follows:
S 52.J1 Prevention of significant
deterioration of *tr quality.
*****
(b) Definitions. * * *
(23)(i) * * '
Particulate matter 25 tpy of particulate
matter emissions; 15 tpy of PMio emissions.
* * <« • •
(0'' *
Maximum
allowable
(mtcrograme
'per cubic
meter)
CUial
PoDutanl
Maximum
(mcrogrorne
per cubic
meter)
Particulate matter
TSP. annual geometric mean —
TSP, 244v maximum
« _.„...]
19
37
daw Ml
Particulate miner
TSP. annual geometric mean _
TSP. 24-hr maximum— —
37
7S
Paniculate matter
TSP. annual geometric mean..
TSP, 24-hr maximum.
s
10
(i) * * *
(4) * • *
(ix) The source or modification was
not subject to S 52.21, with respect to
particulate matter, as in effect before
July 31,1987, and the owner or operator:
(a) Obtained all final Federal, State,
and local preconstruction approvals or
permits necessary under the applicable
State implementation plan before July
31,1987.
(b) Commenced construction within 18
months after July 31,1987, or any earlier
time required under the Stale
implementation plan: and
[c] Did not discontinue construction
for a period of 18 months or more and
completed construction within a
reasonable period of time;
(x) The source or modification was
subject to 40 CFR 52.21, with respect to
particulate matter, as in effect before
July 31,1987 and the owner or operator
submitted an application for a permit
under this section before that date, and
the Administrator subsequently
determines that the application as
submitted was complete with respect to
the particulate matter requirements then
in effect in (his section. Instead, the
requirements of paragraphs (j) through
(r) of this section that were in effect
before July 31,1987 shall apply to such
source or modification.
*****
(8) * * *
(i) ' • •
Particulate matter
10 pg/m9 of TSP, 24-hour average.
10 ftg/ra* of PMio. 24-hour average;
*****
Lead—0.1 fig/m*, 3-month average;
*****
Beryllium—0.001 jigVm3, 24-hour
average.
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Federal Register / Vol. 52. No. 126 / Wednesday. July 1. 1987 / Rules and Regulations
24715
Hydrogen sulfide— 0.2 fig/m», 1-hour
average;
*****
(ll)(i) At the discretion of the
Administrator, the requirements for air
quality monitoring of PMio in paragraphs
(m)(l)(i)-(iv) of this section may not
apply to a particular source or
modification when the owner or
operator of the source or modification
submits an application for a permit
under this section on or before June 1,
1988 and the Administrator
subsequently determines that the
application as submitted before that
date was complete, except with respect
to the requirements for monitoring
particulate matter in paragraphs
(ii) The requirements for ail quality
monitoring of PMio in paragraphs (m)(lj
(iii) and (iv) and (m](3J of this section
shall apply to a particular source or
modification if the owner or operator of
the source or modification submits an
application for a permit under this
section after June 1, 1988 and no later
than December 1, 1988. The data shall
have been gathered over at least the
period from February 1, 1988 to the date
the application becomes otherwise
complete in accordance with the
provisions set forth under paragraph
(m)(l)(viii) of this section, except that if
the Administrator determines that a
complete and adequate analysis can be
accomplished with monitoring data over
a shorter period [not to be less than 4
months), the data that paragraph
(m](l)(iii) requires shall have been
gathered over that shorter period.
*****
(m) Air quality analysis.
(!)••*
(vii) For any application that becomes
complete, except as to the requirements
of paragraph (m)(l) (iii) and (iv)
pertaining to PMio. after December 1,
1988 and no later than August 1.1988 the
data that paragraph (m)(l)(iii) requires
shall nave been gathered over at least
the period from August 1.1988 to the
date the application becomes otherwise
complete, except that if the
Administrator determines that a
complete and adequate analysis can be
accomplished with monitoring data over
a shorter period (not to be less than 4
months), the data that paragraph
(m)(l)(iii) requires shall have been
gathered over that shorter period.
(viii) With respect to any
requirements for air quality monitoring
of PMio under paragraphs (i)(ll) (i) and
(ii) of this section, the owner or operator
of the source or modification shall use a
monitoring method approved by the
Administrator and shall estimate the
ambient concentrations of PMio using
the data collected by such approved
monitoring method in accordance with
estimating procedures approved by the
Administrator.
*****
(P) ' * *
(5) ' ' *
Pollutant
Mumum
alVnv
no*
gramt pe>
cubic
meter)
Pwttautati m«er
TSP. annueJ geomeWc rnean-
TSP 2*4» maximum
19
37
(w) Permit rescission. * ' '
(2) Any owner or operator of a
stationary source or modification who
holds a permit for the source or
modification which was issued under
§ 52.21 as in effect on July 30,1987, or
any earlier version of this section, may
request that the Administrator rescind
the permit or a particular portion of the
permit.
§52.24 [Amended]
3. In $ 52.24. paragraph (f)(10) is
amended by removing the fourth entry,
beginning "Particulate matter," from the
list of significant emission rates.
(FR Doc. 87-13709 Tiled 6-30-87; 8:45 am]
BILLING COOE tt«0-M-M
A-6
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APPENDIX B
OVERVIEW OF CLEAN AIR ACT AUTHORITY FOR INSPECTORS
B-l
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APPENDIX B
OVERVIEW OF CLEAN AIR ACT AUTHORITY FOR INSPECTORS
The Clean Air Act (CAA) authorizes plant entry for the purposes of
inspection. In specific, Section 114 of the Act states:1
" the Administrator or his authorized representative,
upon presentation of his credentials shall have a right of
entry to, upon or through any premises of such person or in
which any records required to be maintained are
located, and may at reasonable times have access to and copy
any records, inspect any monitoring equipment or
methods , and sample any emissions which such person is
required to sample "
Inspections conducted under Section 114 extend to all items relating to
compliance with the requirements of the CAA which are within the premises
being inspected. These may include: records filed, processes, monitoring
equipment, controls, sampling methods, and emissions.
Much of the compliance monitoring, including on-site inspections, is
accomplished at the state level. Section 114 of the Act provides for the
extension of federal authority to the states to carry out that Section. Where
a state has been delegated Section 114 authority from EPA, the same authority
EPA has to monitor, sample, inspect or copy records, and any other authority
under Section 114 can, in like manner, be exercised by the state. No
representative of EPA need accompany the state officials.
EPA does not always have the resources available to conduct all of the
compliance monitoring functions on its own. To accomplish these functions,
EPA frequently hires private contractors to provide technical support for on-
site inspections and sampling. EPA maintains that such contractors, upon
proper designation, are "authorized representatives" of the administrator
within the meaning of Section 114. However, the courts have not unanimously
upheld EPA's position. For this reason, EPA has adopted a policy that duly-
authorized contractors are only used to conduct on-site inspections in those
Circuits where Court of Appeals decisions have not been against the use of
contractors as authorized representatives.
1 U. S. Environmental Protection Agency. The Clean Air Act, Compliance/
Enforcement Guidance Manual. Office of Enforcement and Compliance
Monitoring. Washington, DC. 1987.
B-2
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EPA's current policy on the use of contractors to conduct on-site
inspections is as follows:2
First. Second, Third, Fourth, Fifth, Seventh, Eighth. Eleventh, and
District of Columbia Circuits. Authorized contractors may be
designated to provide technical support for inspections of facili-
ties owned by anyone other than Stauffer Chemical Company.
• Ninth Circuit. Authorized contractors may be designated to provide
technical support for any inspections.
• Sixth and Tenth Circuits. Absent express permission from
Headquarters, authorized contractors should not be designated to
provide technical support for any inspections.
EPA also has the authority to conduct unannounced, off-the-premises
inspections, such as visible emission observations.
U.S. Environmental Protection Agency. Air Compliance Inspection Manual.
EPA-340/1-86-200. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. September 1985.
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APPENDIX C
INSPECTORS RESPONSIBILITIES. SAFETY PROCEDURES. AND PREPARATION
C-l
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APPENDIX C
INSPECTORS RESPONSIBILITIES, SAFETY PROCEDURES, AND PREPARATION
C.I INSPECTOR RESPONSIBILITIES
The primary role of the inspector is to gather information needed in the
determination of compliance with applicable regulations and other enforcement
activities. Closely coupled with these functions are certain responsibilities
which include: (1) knowing and abiding by the legal requirements of the
inspection; (2) using proper procedures for effective inspection and evidence
collection; (3) practicing accepted safety procedures; (4) observing the
professional and ethical responsibilities; and (5) maintaining certain quality
assurance standards. Each is briefly outlined below.
C.I.I Legal Responsibilities
It is essential that all inspection activities be conducted within the
legal framework established by the Clean Air Act (CAA) or other applicable
statutes. In particular, this includes:
Proper handling of confidential business information.
Presentation of proper credentials and plant entry at reasonable
times.
• Protection of the legal rights of the company and its personnel
under the U.S. Constitution.
Knowledge of
conditions.
all applicable statutes, regulations, and permit
• Use of notice(s) and receipts, if appropriate.
For federal employees (or their representatives) conducting inspections under
the CAA, the guidance provided in Reference 1 should be followed. In the case
of state and local inspectors, the appropriate office responsible for legal
matters should be consulted regarding the above issues.
U.S. Environmental Protection Agency. The Clean Air Act, Compliance/
Enforcement Guidance Manual. Office of Enforcement and Compliance
Monitoring. Washington, DC. 1987.
C-2
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C.I.2 Procedural Responsibilities
The inspector must be familiar with and adhere to, when possible, all
general inspection procedures and evidence gathering techniques. This will
ensure accurate inspections and avoid the possibility of endangering a legal
proceeding on procedural grounds.
• Inspection procedures—Inspectors should observe standard procedures
for conducting each portion of the inspection as established by the
regulatory agency, when possible. All deviations should be clearly
documented.
• Evidence collection—Inspectors must be familiar with general
evidence gathering techniques. Because the agency's case in a civil
or criminal prosecution depends on the evidence gathered by the
inspector, it is imperative that the inspector keep detailed records
of each inspection. These records will serve as an aid in preparing
the inspection report, in determining the appropriate enforcement
response, and in giving testimony in an enforcement case, as
required. Specifically, inspectors must:
Know how to substantiate facts with items of evidence,
including samples, photographs, document copies, statements
from persons, and personal observations.
Know how to detect lack of good faith during interviews with
company personnel.
Be familiar with all applicable regulations and permit
conditions and know what type of information is required to
determine compliance with each.
Be able to evaluate what documentation is necessary (routine
inspection).
Collect evidence in a manner that will be incontestable in
legal proceedings.
Be able to write clear, informative inspection reports.
Know how to testify in court and at administrative hearings.
C.I.3 Safety Responsibilities
The inspection of industrial facilities generally involves potential
exposure to numerous hazards. The inspector must at all times avoid putting
anyone at unnecessary risk. To accomplish this, it is the inspector's
responsibility to:
C-3
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Know and observe all plant safety requirements, warning signals, and
emergency procedures.
Know and observe all agency safety requirements, procedures, and
policies.
Remain current in safety practices and procedures by regular
participation in safety training.
Use any safety equipment required by the facility being inspected in
addition to that required by the regulatory agency.
Use safety equipment in accordance with agency guidance and labeling
instructions.
Maintain safety equipment in good condition and proper working
order.
Dress appropriately for each inspection activity, including
protective clothing, if appropriate.
Section 2.7 of this manual (and listed references) address inspection
safety procedures in more detail.
C.I.4 Professional and Ethical Responsibilities
As professionals, inspectors are expected to perform their duties with
the highest degree of honesty and professionalism. Procedures and require-
ments ensuring ethical actions have been worked out through many years of
governmental inspection activities. These procedures and standards of conduct
have evolved for the protection of the individual, the regulatory agency, and
industry. The inspector is constantly in a position to set an example for
private industry and to encourage concern for the health and safety in
environment and compliance with the laws that protect them.
Specifically, the EPA inspector should always consider and observe the
following responsibilities:
U.S. Constitution--A11 investigations are to be conducted within the
framework of the United States Constitution and with due regard for
individual rights regardless of race, sex, creed, or national
origin.
EPA employee conduct—Inspectors are to conduct themselves at all
times in accordance with the regulations prescribing EPA Employee
Responsibilities and Conduct, codified in 40 CFR Part 60, Part 3.
Objectivity—The facts of an investigation are to be developed and
reported completely, accurately, and objectively. In the course of
an investigation, any act or failure to act motivated by reason of
private gain is illegal. Actions which could be construed as such
should be scrupulously avoided.
C-4
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Knowledge—A continuing effort to improve professional knowledge and
technical skill in the investigative field should be made. The
inspector should keep abreast of changes in the field of air pollu-
tion, including current regulations, EPA and other agency policies,
control technology, methodology, and safety considerations.
Professional attitude—The inspector is a representative of EPA and
is often the initial or only contact between the agency and indus-
try. In dealing with facility representatives and employees,
inspectors must be dignified, tactful, courteous, and diplomatic.
They should be especially careful not to infringe on union/company
agreements. A firm but responsive attitude will help to establish
an atmosphere of cooperation and should foster good working rela-
tions. He should always strive to obtain the respect of, inspire
confidence in, and maintain good will with industry and the public.
Attire—Inspectors should dress appropriately, including wearing
protective clothing or equipment, for the activity in which they are
engaged.
Industry, public, and consumer relations—All information acquired
in the course of an inspector's duties is for official use only.
Inspectors should not speak of any product, manufacturer, or person
in a derogatory manner.
Gifts, favors, luncheons--Inspectors should not accept favors or
benefits under circumstances that might be construed as influencing
the performance of governmental duties. EPA regulations provide an
exemption whereby an inspector could accept food and refreshment of
nominal value on infrequent occasions in the ordinary course of a
luncheon or dinner meeting or other meeting, or during an inspection
tour. Inspectors should use this exemption only when absolutely
necessary.
• Requests for information—EPA has an "open door" policy on releasing
information to the public. This policy aims at making information
about EPA and its work freely and equally available to all inter-
ested individuals, groups, and organizations. In fact, EPA employ-
ees have both a legal and traditional responsibility for making
useful educational and safety information available to the public.
This policy, however, does not extend to information relating to the
suspicion of a violation, evidence of possible misconduct, or
confidential business information.
C.I.5 Quality Assurance Responsibilities
The inspector assumes primary responsibility for ensuring the quality of
data generated as a result of the inspection. Thus quality assurance proce-
dures appropriate to the type of data being generated should be adhered to.
In general, quality assurance procedures are developed towards the following
elements: valid data collection; approved, standard methods; control of
service, equipment, supplies; quality analytical techniques; and standard data
C-5
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handling and reporting. Reference 2 should be consulted for general guidance
in this regard.
C.2 PREINSPECTION PREPARATION
Preinspection preparation is always necessary to ensure effective use of
the inspector's and facility's time, and to ensure that the inspection is
properly focused on collecting relevant data and information. This prepara-
tion involves: review of facility background; development of an inspection
plan; notifications; and equipment preparation. Each is discussed briefly
below.
C.2.1 Review of Facility Background
A review of the available background information on the facility to be
inspected is essential to the overall success of the inspection. The review
should enable the inspector to: become familiar with the facility's process
and emission characteristics; conduct the inspection in a timely manner;
minimize inconvenience to the facility by not requesting unnecessary data such
as that previously provided to the EPA or another agency; conduct an effi-
cient, but thorough, inspection; clarify technical and legal issues before
entry; and prepare a useful inspection report. The following types of
information should be reviewed:
* Basic facility information—Names, titles, and phone numbers of
facility representatives; maps showing facility location and
geographic relationship to residences, etc., potentially impacted by
emissions; process and production information; plot plans or maps
identifying sources, control equipment and methods, monitors, and
other points of interest; and safety equipment requirements.
* Sources and control equipment data—Sources and extent of fugitive
emissions; description and operational data for control equipment;
and previous inspection checklists (and reports).
* Regulations, requirements, and limitations—Most recent permits for
facility sources; applicable federal, state, and local regulations
and requirements; special exemptions and waivers, if any; and
permitted operating conditions.
* Facility compliance and enforcement history—Previous inspection
reports; complaint history including reports, follow-up, findings,
remedial action; past conditions of noncompliance; previous enforce-
ment actions; pending enforcement actions, compliance schedules
and/or variances; and control performance data and reports.
U.S. Environmental Protection Agency. Air Compliance Inspection Manual.
EPA-340/1-85-020. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. September 1985.
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The following sources are recommended for obtaining this background
information for EPA inspectors:
Inspectors "working" file—The inspector's own concise file for a
facility containing basic plant and process information, maps, dust
control plan, chronology of enforcement related actions, recent
permits, and safety requirements.
Regional office files and data bases—These files should include
much of the information needed including inspection reports, permits
and permit applications, compliance and enforcement history,
exemption or waiver information, and control performance monitoring
data.
• State/local files and contacts—These should be used to supplement
and update the information available in the regional office files.
Laws and regulations—The Clean Air Act and related regulations
establish emission standards, controls, procedures, and other
requirements applicable to a facility. State and local laws and
regulations should also be considered.
Technical reports, documents, and guidelines—These can often be
valuable in providing information and/or guidance concerning
specific processes, control techniques, performance advantages and
limitations of particular types of controls, and specific inspection
procedures. Table 2-3 lists some of the reference documents
available for fugitive sources.
C.2.2 Inspection Plan Development
Based on the review of the facility background information and the
intended purpose of the inspection, the EPA inspector should develop an
inspection plan. This plan should address the following items:
Inspection objectives—Identify the precise purpose of the
inspection in terms of what it will accomplish.
Tasks—Decide on specific tasks to accomplish the inspection
objectives including the exact information which must be collected.
Procedures—Determine the procedures to be used in completing the
tasks, particularly special or unfamiliar procedures.
Resources—Determi ne what equipment and personnel will be required.
Schedule—Estimate the time requirements for the inspection;
determine a reasonable time for the inspection (when plant is
operating at representative conditions).
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C.2.3 Facility Notification
EPA regional offices vary in their exact policies concerning giving a
facility advance notification of an inspection. In an EPA policy memo
entitled "Final Guidance on Use of Unannounced Inspections," the Stationary
Source Compliance Division recommends that all regional inspection programs
incorporate unannounced inspections as part of their overall inspection
approach.2 The advantages of the unannounced inspection are: (1) the
opportunity to observe the source under normal operating conditions (since the
source does not have time to prepare for the inspection); (2) detection of
visible emissions and O&M-type problems and violations; (3) creation of an
increased level of attention by a source to its compliance status; and
(4) projection of a serious attitude toward surveillance by the agency.
The potential negative aspects of performing unannounced inspections
are: (1) the source may not be operating or key plant personnel may not be
available; and (2) there could be an adverse impact on EPA/state or EPA/source
relations. However, it has been demonstrated by the regional offices who
already use the unannounced inspections that, in the majority of cases, these
drawbacks can be overcome.2
When using the unannounced inspection, an alternative to arriving at the
source totally unannounced is to contact the source shortly before the
scheduled inspection time. This is left to the discretion of the regional
office and/or the inspector and must be done so as not to alter the repre-
sentativeness of the source operation. The amount of advanced notice given
should be noted in the inspection report.
Announced inspections are performed by EPA (and its authorized
representatives) when some specific purpose is served by providing such
notice. Situations where announced inspections are appropriate are:
• When specific information is being sought which must be prepared by
the source, or where the source must make significant accommodations
for the inspector to gather the information.
• When the assistance of specific plant personnel is necessary for the
successful performance of the inspections (i.e., the information
they provide cannot be obtained from other on-duty plant personnel
or by a follow-up information request).
When inspecting the government facilities or sources operating under
government contract where entry is restricted due to classified
operations.
• When inspecting unmanned or extremely remote sources.
When the inspection is announced in advance, a lead time of five working
days is generally appropriate. Notification may be by telephone or letter and
it may or may not include the exact date and time of the inspection.
Instances where written notification (instead or oral) is appropriate are:
C-8
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When requested by the state/local agency or by the source.
When extensive or specific records are being sought.
When the inspection is to be performed solely by an EPA contractor.
• When inspecting government facilities with classified operations or
otherwise restricted entry.
Special-purpose inspections (e.g., to establish conditions for a
source-specific SIP revision).
A "114 Letter" (Appendix A) is sometimes used for notification if there
is a need to request facility information prior to the inspection. The
facility representative notified should have the authority to release data and
samples and to arrange for access. In addition, when notifying a facility on
an inspection, information should be requested in regard to on-site safety
regulations. This will avoid problems concerning safety equipment at the time
of the inspection.
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APPENDIX D
SUMMARY OF STATE METHODS FOR DETERMINING VISIBLE EMISSIONS
FROM OPEN DUST SOURCES
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APPENDIX D
SUMMARY OF STATE METHODS FOR DETERMINING VISIBLE EMISSIONS
FROM OPEN DUST SOURCES
Visible emission methods have been adopted by a number of states as a
tool for compliance. Although opacity observations at the property line have
commonly been employed in earlier fugitive dust control regulations, recent
court decisions in Colorado and Alabama have found that rules of that type are
unconstitutional (failing to provide equal protection). It is strongly
recommended that property-line opacity observations serve only as an indicator
of a potential problem, thus "triggering" further investigation. Source-
specific opacity determinations, on the other hand, have long been a court-
tested approach to regulation. The following sections describes two states'
approach to fugitive dust regulation using visible emission methods.
D.I TENNESSEE VISIBLE EMISSION METHOD
The State of Tennessee has developed a method (TVEE Method 1) for
evaluating visible emissions (VE) from roads and parking lots. The following
discussion focuses on TVEE Method 1 (Ml) in the technical areas: (1) reader
position/techniques, and (2) data reduction/evaluation procedures. Table D-l
summarizes the relevant features of TVEE Ml.
D.I.I Reader Position/Techniques
As indicated in Table D-l, TVEE Ml specifies an observer location of
15 ft from the source. In most cases, this distance should allow an
unobstructed view, and at the same time meet observer safety requirements.
Ml also specifies that the plume be read at - 4 ft directly above the
emitting surface. This specification presumably results from field experi-
ments conducted to support the method. It is probably intended to represent
the point (i.e., location) of maximum opacity. While there is no quantitative
supporting evidence, it seems likely that the height and location of maximum
opacity relative to a passing vehicle will vary depending upon ambient factors
(wind speed and direction) as well as vehicle type and speed.
Implied in the Ml specification that the plume be read ~ 4 ft above the
emitting surface, is the fact that observations will be made against a ter-
restrial (vegetation) background. The results of one study using a conven-
tional smoke generator modified to emit horizontal plumes, indicated that
under these conditions observers are likely to underestimate opacity levels.
More specifically, the study found that as opacity levels increased, opacity
D-2
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TABLE D-l. SUMMARY OF TVEE Ml REQUIREMENTS
Reader position/techniques
• Sun in 140 degree sector behind the reader
• Observer position - 15 ft from source
• Observer line of sight should be as perpendicular as possible to
both plume and wind direction
• Only one plume thickness read
• Plume read at ~ 4 ft directly above emitting surface
• Individual opacity readings taken each 15 s, recorded to nearest 5%
opacity
• Readings terminated if vehicle obstructs line of sight
• Readings terminated if vehicles passing in opposite direction
create intermixed plume
Data reduction
• 2-min time-averages consisting of eight consecutive 15 s readings
Certification
• Per Tennessee requirements
D-3
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readings showed an increasing negative bias. For example, at 15% opacity, the
observers underestimated opacity by about 5%, and at 40% opacity, observations
averaged about 11% low.1 Black plumes were underestimated at all opacity
levels.
Ml specifies that only one plume thickness be read. It includes
qualifying provisions that: (1) readings terminate if vehicles passing in
opposite directions create an intermixed plume; but (2) readings continue if
intermixing occurs as a result of vehicles moving in the same direction.
Unlike (1), the latter condition is considered representative of the
surface. The intent here is probably to minimize the influence of increasing
plume density which results from "overlaying" multiple plumes.
D.I.2 Data Reduction/Evaluation Procedures
There are two basic approaches that can be used to reduce opacity
readings for comparison with VE regulations. One approach involves the
time-averaging of consecutive 15-s observations over a specified time period
to produce an average opacity value.
In the development of Ml, the State of Tennessee concluded that a short
averaging period--2 min (i.e., eight consecutive 15-s readings) was appropri-
ate for roads and parking lots, as these sources typically produce brief,
intermittent opacity peaks.
Although not specified in Ml, VE from open sources could be evaluated
using time-aggregating techniques. For example, the discrete 15-s readings
could be employed in the time-aggregating framework. In this case, the
individual observations are complied into a histogram from which the number of
observations (or equivalent percent of observation time) in excess of the
desired opacity may then be ascertained. The principal advantage of using the
time-aggregate technique as a method to reduce VE readings is that the
resultant indicator of opacity conditions is then compatible with regulations
that include a time exemption clause. Under time exemption standards, a
source is permitted opacity in excess of the standard for a specified fraction
of the time (e.g., 3 min/h). The concept of time exemption was originally
developed to accommodate stationary source combustion processes.
Without more detailed supporting information, it is difficult to
determine which of the two approaches is most appropriate for evaluating VE
from open sources. With respect to time-averaging, statistics of observer
bias in reading plumes from a smoke generator do indicate at least a slight
decrease in the "accuracy" of the mean observed opacity value as averaging
time decreases. In Ml (2-min average), this is reflected in the inclusion of
an 8.8% buffer for observational error. This buffer is taken into account
before issuing a Notice of Violation.2
1 Rose, T. H. Evaluation of Trained Visible Emission Observers for Fugitive
Opacity Measurement. EPA-60/3-84-093, U.S. Environmental Protection
Agency, Research Triangle Park, NC. October 1984.
2 Telecon. Englehart, P., Midwest Research Institute, with J. Walton,
Tennessee Division of Air Pollution Control. Nashville, Tennessee.
September 1984.
D-4
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One potential problem with applying time-averaging to opacity from roads
and parking lots, is that the resulting average will be sensitive to vari-
ations in source activity. For example, interpreting one conclusion offered
in support of Ml, 1t is likely that under moderate wind conditions a single
vehicle pass will produce only two opacity readings > 5%.2 Averaging these
with six zero (0) readings yields a 2-min value below any reasonable opacity
standard. Yet, under the same conditions with two or more vehicle passes, the
average value will suggest elevated opacity levels. While there is no infor-
mation available on the use of time aggregation for open source opacity, it
appears that this approach would more easily accommodate variations in level
of source activity. For this reason alone, it may be the evaluation approach
better suited to roads and parking lots.
D.2 OHIO DRAFT RULE 3745-17-(03)(B)
The State of Ohio submitted a fugitive dust visible emission measurement
technique which the EPA proposed to approve in the Federal Register on
January 2, 1987. Unlike the Tennessee method, the Ohio draft rule contains
provisions for sources other than roads and parking lots. Average opacity
values are based on 12 consecutive readings. Table D-2 summarizes the Ohio
method; as can be seen from the table, many features of the Ohio draft rule
are similar to TVEE Ml. Consequently, the remarks made earlier in this
section are equally applicable here.
D-5
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TABLE D-2. SUMMARY OF OHIO DRAFT RULE 3745-17-(03)(B)
Reader position/techniques
• Roadways and parking lots:
* Line of vision approximately perpendicular to plume direction
* Plume read at ~ 4 ft above surface
* Readings suspended if vehicle obstructs line of sight;
subsequent readings considered consecutive to that taken before
the obstruction
* Readings suspended if vehicles passing in opposite direction
create an intermixed plume; subsequent readings considered
consecutive to that taken before intermixing
* If unusual condition (e.g., spill) occurs, another set of
readings must be conducted
• All other sources:
* Sun behind observer
* Minimum of 15 ft from source
* Line of sight approximately perpendicular to flow of fugitive
dust and to longer axis of the emissions
* Opacity observed for point of highest opacity
D-6
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APPENDIX E
EPA REFERENCE METHOD 22 FOR VISUAL DETERMINATION
OF FUGITIVE EMISSIONS
E-l
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APPENDIX E
EPA REFERENCE METHOD 22 FOR VISUAL DETERMINATION
OF FUGITIVE EMISSIONS
The following pages outline EPA Reference Test Method 22 for the visual
determination of fugitive emissions from material sources and smoke emissions
from flares.
E-2
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METHOD 22—VISUAL DETERMINATION OP FU-
GITIVE EMISSIONS FROM MATERIAL
SOURCES AND SMOKE EMISSIONS FROM
FLARES
1. Introduction
This method involves the visual determi-
nation of fugitive emissions, i.e., emissions
not emitted directly from a process stack or
duct. Fugitive emissions include emissions
that (1) escape capture by process equip-
ment exhaust hoods; (2) are emitted during
material transfer; (3) are emitted from
buildings housing material processing or
handling equipment; and (4) are emitted di-
rectly from process equipment. This method
is used also to determine visible smoke emis-
sions from flares used for combustion of
waste process materials.
This method determines the amount of
time that any visible emissions occur during
the observation period, i.e., the accumulated
emission time. This method does not require
that the opacity of emissions be determined.
Since this procedure requires only the de-
termination of whether a visible emission
occurs and does not require the determina-
tion of opacity levels, observer certification
according to the procedures of Method 9 are
not required. However, it is necessary that
the observer is educated on the general pro-
cedures for determining the presence of visi-
ble emissions. As a minimum, the observer
must be trained and knowledgeable regard-
ing the effects on the visibility of emissions
caused by background contrast, ambient
lighting, observer position relative to light-
ing, wind, and the presence of uncombined
water (condensing water vapor). This train-
ing is to be obtained from written materials
found in References 7.1 and 7.2 or from the
lecture portion of the Method 9 certifica-
tion course.
2. Applicability and Principle
2.1 Applicability. This method applies to
the determination of the frequency of fugi-
tive emissions from stationary sources (lo-
cated indoors or outdoors) when specified as
the test method for determining compliance
with new source performance standards.
This method also is applicable for the de-
termination of the frequency of visible
smoke emissions from flares.
2.2 Principle. Fugitive emissions pro-
duced during material processing, handling,
and transfer operations or smoke emissions
from flares are visually determined by an
observer without the aid of instruments.
3. Definitions
3.1 Emission Frequency. Percentage of
time that emissions are visible during the
observation period.
3.2 Emission Time. Accumulated amount
of time that emissions are visible during the
observation period.
3.3 Fugitive Emissions. Pollutant gener-
ated by an affected facility which is not col-
lected by a capture system and is released to
the atmosphere.
3.4 Smoke Emissions. Pollutant generat-
ed by combustion in a flare and occurring
immediately downstream of the flame.
Smoke occurring within the flame, but not
downstream of the flame, is not considered
a smoke emission.
3.5 Observation Period. Accumulated
time period during which observations are
conducted, not to be less than the period
specified in the applicable regulation.
4. Equipment
4.1 Stopwatches. Accumulative type with
unit divisions of at least 0.5 seconds: two re-
quired.
4.2 Light Meter. Light meter capable of
measuring illuminance in the 50- to 200-lux
range; required for indoor observations
only.
5. Procedure
5.1 Position. Survey the affected facility
or building or structure housing the process
to be observed and determine the locations
of potential emissions. If the affected facili-
ty is located inside a building, determine an
observation location that is consistent with
the requirements of the applicable regula-
tion (i.e., outside observation of emissions
escaping the building/structure or inside ob-
servation of emissions directly emitted from
the affected facility process unit). Then
select a position that enables a clear view of
the potential emission point(s) of the affect-
ed facility or of the building or structure
housing the affected facility, as appropriate
for the applicable subpart. A position at
least 15 feet, but not more than 0.55 miles,
from the emission source is recommended.
For outdoor locations, select a position
where the sun is not directly in the observ-
er's eyes.
5.2 Field Records.
5.2.1 Outdoor Location. Record the fol-
lowing information on the field data sheet
(Figure 22-1): company name, industry,
process unit, observer's name, observer's af-
filiation, and date. Record also the estimat-
ed wind speed, wind direction, and sky con-
dition. Sketch the process unit being ob-
served and note the observer location rela-
tive to the source and the sun. Indicate the
potential and actual emission points on th-3
sketch.
5.2.2 Indoor Location. Record the follow-
ing information on the field data sheet
(Figure 22-2): company name, industry,
process unit, observer's name, observer's af-
E-3
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filiation, and date. Record as appropriate
the type, location, and intensity of lighting
on the data sheet. Sketch the process unit
being observed and note observer location
relative to the source. Indicate the potential
and actual fugitive emission points on the
sketch.
5.3 Indoor Lighting Requirements. For
indoor locations, use a light meter to meas-
ure the level of illumination at a location as
close to the emission source(s) as is feasible.
An illumination of greater than 100 lux (10
foot candles) is considered necessary for
proper application of this method.
5.4 Observations. Record the clock time
when observations begin. Use one stopwatch
to monitor the duration of the observation
period; start this stopwatch when the obser-
vation period begins. If the observation
period is divided into two or more segments
by process shutdowns or observer rest
breaks, stop the stopwatch when a break
begins and restart it without resetting when
the break ends. Stop the stopwatch at the
end of the observation period. The accumu-
lated time indicated by this stopwatch is the
duration of the observation period. When
the observation period is completed, record
the clock time.
During the observation period, continous-
ly watch the emission source. Upon observ-
ing an emission (condensed water vapor is
not considered an emission), start the
second accumulative stopwatch; stop the
watch when the emission stops. Continue
this procedure for the entire observation
period. The accumulated elapsed time on
this stopwatch is the total time emissions
were visible during the observation period,
i.e., the emission time.
5.4.1 Observation Period. Choose an ob-
servation period of sufficient length to meet
the requirements for determining compli-
ance with the emission regulation in the ap-
plicable subpart. When the length of the ob-
servation period is specifically stated in the
applicable subpart, it may not be necessary
to observe the source for this entire period
if the emission time required to indicate
noncompliance (based on the specified ob-
servation period) is observed in a shorter
time period. In other words, if the regula-
tion prohibits emissions for more than 6
minutes In any hour, then observations may
(optional) be stopped after an emission time
of 6 minutes is exceeded. Similarly, when
the regulation is expressed as an emission
frequency and the regulation prohibits
emissions for greater than 10 percent of the
time in any hour, then observations may
(optional) be terminated after 6 minutes of
emissions are observed since 6 minutes is 10
percent of an hour. In any case, the observa-
tion period shall not be less than 6 minutes
in duration. In some cases, the process oper-
ation may be intermittent or cyclic. In such
cases, it may be convenient for the observa-
tion period to coincide with the length of
the process cycle.
5.4.2 Observer Rest Breaks. Do not ob-
serve emissions continuously for a period of
more than 15 to 20 minutes without taking
a rest break. For sources requiring observa-
tion periods of greater than 20 minutes, the
observer shall take a break of not less than
5 minutes and not more than 10 minutes
after every 15 to 20 minutes of observation.
If continuous observations are desired for
extended time periods, two observers can al-
ternate between making observations and
taking breaks.
5.4.3 Visual Interference. Occasionally,
fugitive emissions from sources other than
the affected facility (e.g., road dust) may
prevent a clear view of the affected facility.
This may particularly be a problem during
periods of high wind. If the view of the po-
tential emission points is obscured to such a
degree that the observer questions the va-
lidity of continuing observations, then the
observations are terminated, and the observ-
er clearly notes this fact on the data form.
5.5 Recording Observations. Record the
accumulated time of the observation period
on the data sheet as the observation period
duration. Record the accumulated time
emissions were observed on the data sheet
as the emission time. Record the clock time
the observation period began and ended, as
well as the clock time any observer breaks
began and ended.
6. Calculations
If the applicable subpart requires that the
emission rate be expressed as an emission
frequency (in percent), determine this value
as follows: Divide the accumulated emission
time (in seconds) by the duration of the ob-
servation period (in seconds) or by any mini-
mum observation period required in the ap-
plicable subpart, if the acutal observation
period is less than the required period and
multiply this quotient by 100.
7. References.
7.1 Missan, Robert and Arnold Stein.
Guidelines for Evaluation of Visible Emis-
sions Certification, Field Procedures, Legal
Aspects, and Background Material. EPA
Publication No. EPA-340/1-75-007. April
1975
7.2 Wohlschlegel, P. and D. E. Wagoner.
Guideline for Development of a Quality As-
surance Program: Volume IX—Visual Deter-
mination of Opacity Emissions From Sta-
tionary Sources. EPA Publication No. EPA-
650/4-74-005-i. November 1975.
E-4
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FUGITIVE OR SMOKE EMISSION INSPECTION
OUTDOOR LOCATION
Company _______
Location
Company representative
Observer .
Affiliation
Data
Sky Conditions
Pracipnation _.
Wind direction
Wind spaad
Industry
Procass unit
Sketch procaar unit: indicata obaarvar position ralativa to sourca and sun; indfcata potantial
emission points and/or actual emission points.
OBSERVATIONS
Bagin Observation
Clock
time
Observation
period
duration.
minrsec
Accumulated
emission
time.
min:sac
End observation
Figure 22-1
E-5
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Fugitive Mission Inspection Indoor Location Table
FUGITIVE EMISSION INSPECTION
INDOOR LOCATION
Company Observer
Location Affiliation
Company Representative Date
Industry Process unit
Light type (fluorescent, incandescent, natural
Light location (overhead, behind observer, etc.)
Illuminance (lux or footcandles) _
Sketch process unit; indicate observer position relative to source; indicate potential
emission points and/or actual emission points.
OBSERVATIONS Observation Accumulated
period emission.
Clock duration, time,
time raintsec rain:sec
Beginning observation
End observation
Figure 22-2
E-6
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APPENDIX F
MATERIAL SAMPLING AND ANALYSIS PROCEDURES
F-l
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APPENDIX F
MATERIAL SAMPLING AND ANALYSIS PROCEDURES
F.I SAMPLING TECHNIQUES
The following are recommended procedures for collection of appropriate
road surface and aggregate material samples. Where practical, the recommended
procedure is structured identically to the standard method published by the
American Society of Testing and Materials (ASTM).
F.I.I Unpaved Roads
The main objective in sampling the surface material from an unpaved road
is to collect a minimum gross sample of 23 kg (50 Ib) for every 4.8 km (3 mi)
of unpaved road. However, for unpaved road segments significantly < 4.8 km
(3 mi) found in industrial facilities, a traverse strip ~ 20 to 60 cm wide
across the travel lanes every 0.8 km (1/2 mi) is usually adequate. For
unpaved roads treated with a chemical dust suppressant, the sampling strips
will typically be wider (~ 45 to 125 cm) in order to collect adequate sample
mass. Where possible, incremental samples taken from unpaved roads should
ideally be distributed over the road segment, as shown in Figure F-l. In
these cases at least four incremental samples should be collected and
composited to form the gross sample.
L = 4.Okm (3 ML) ,
o
n
-Sample Slrip 20cm (0 in.) Wide
|4
L= !.6km (1 Mi.)
Figure F-l. Location of incremental sampling sites on an unpaved road.
F-2
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To collect each sample, loose surface material is removed from the hard
road base with a whisk broom and dustpan. The material should be swept care-
fully so that the fine dust is not injected into the atmosphere. The hard
road base below the loose surface material should not be abraded so as to
generate more fine material than exists on the road in its normal state.
Figure F-2 presents a data form to be used for the sampling of unpaved
roads. Figure F-3 shows the use of a dust pan and broom for unpaved road
sampling as well as a sample strip across the road.
F.I.2 Paved Roads
Ideally, for a given paved road, one gross sample per every 8 km (5 mi)
of paved roads should be collected. For industrial roads, one gross sample
should be obtained for each road segment in the plant. The gross sample
should consist of at least two separate increments per travel lane or each
0.8-km (0.5-mi) of road length should have a separate sample.
Figure F-4 presents a diagram showing the location of incremental samples
for a four-lane road. Each incremental sample should consist of a lateral
strip 0.3 to 3 m (1 to 10 ft) in width across a travel lane. The exact width
is dependent on the amount of loose surface material on the paved roadway.
For a visually dirty road, a width of 0.3 m (1 ft) is sufficient; but for a
visually clean road, a width of 3 m (10 ft) is needed to obtain an adequate
sample.
The above sampling procedure may be considered as the preferred method of
collecting surface dust from paved roadways. In many instances, however, the
collection of eight sample increments may not be feasible because of manpower,
equipment, and traffic/hazard limitations. As an alternative method, samples
can be obtained from a single strip across all travel lanes. When it is
necessary to resort to this sampling strategy, care must be taken to select
sites that have dust loading and traffic characteristics typical of the entire
roadway segment of interest. In this situation, sampling from a strip 3 to
9 m (10 to 30 ft) in width is suggested, where possible. From this width,
sufficient sample can be collected and a step toward representativeness in
sample acquisition will be accomplished.
Samples are removed from the road surface by vacuuming, preceded by broom
sweeping if large aggregate is present. The samples should be taken from the
traveled portion of the lane with the area measured and recorded on the appro-
priate data form. With a whisk broom and a dust pan, the larger particles are
collected from the sampling area and placed in a clean, labeled sample con-
tainer (plastic jar or bag). The remaining smaller particles are then swept
from the road with an electric broom-type vacuum sweeper. The sweeper must be
equipped with a preweighed, prelabeled, disposable vacuum bag. Care must be
taken when installing the bags in the sweeper to avoid torn bags which can
result in sample loss. After the sample has been collected, the bag should be
removed from the sweeper, checked for leaks and stored in a prelabeled, gummed
envelope, and sealed for transport. Figure F-5 presents a data form to be
used for the sampling of paved roads and Figure F-6 provides photos of sam-
pling procedures for industrial roads and city streets.
F-3
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Date Sample Collected
Sampling Data for
Unpaved Roads
Recorded by_
Type of Material Sampled:.
Site of Sampling*:
SAMPLING METHOD
1. Sampling device: whisk broom and dust pan
2. Sampling depth: loose surface material (do not abrade road base)
3. Sample container: metal or plastic bucket with sealed poly liner
4. Gross sample specifications:
(a) 1 sample of 23kg (50 Ib) minimum for every 3.8 km (3 mi) sampled
(b) composite of 4 increments: lateral strips of 6" width extending over traveled
portion of roadway
Indicate deiviations from above methods and general meteorology:
SAMPLING DATA
Sample
No.
Time
Location*
Surface
Area
Depth
Quantity
of Sample
* Use code given on plant or road map for segment identification and indicate sample
on map.
DIAGRAM
Figure F-2. Data form for unpaved road sampling.
F-4
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(a) Wisk broom and pan for surface sampling.
(b) Sample strip across road width.
Figure F-3. Unpaved road sampling.
F-5
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-Qkin (5 Mi.) of similar road type
Increment
Figure F-4. Location of incremental sampling sites on a paved road.
-------
Figure F-5. Data form for paved road sampling.
Paved Road Loading
Date Sample Collected
Recorded by.
Type of Material Sampled:
Sampling Location*:
No. of Traffic Lanes:
Surface Condition-
* Use code given on plant or road map for segment identification and indicate sample on map.
SAMPLING METHOD
1. Sampling device: Portable vacuum cleaner (broom sweep first if loading is heavy)
2. Sampling depth: Loose surface material
3. Sample container: Tared and numbered vacuum cleaner bags
4. Gross sample specifications:
(a) 1 sample every 8 kg (5 mi) of road length
(b) Composite two segments per travel lane (each 0.5 mi or 0.8 km should have
separate sample): lateral strips of 0.3 m minimum width extending from curb to curb
(c) Do not sample curb areas
Indicate deiviations from above method:
SAMPLING DATA
Sample
No.
Vac
Bag
Time
Surface
Area
Broom
Swept?
Sample
No.
Vac
Bag
Time
Surface
Area
Broom
Swept?
DIAGRAM (mark each segment with vacuum bag number)
F-7
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(a) Sampling of industrial paved roads.
(b) Sampling of city street.
Figure F-6. Paved road sampling procedures.
F-8
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F.I.3 Storage Piles
In sampling the surface of a pile to determine representative properties
for use in the wind erosion (or materials handling) equation, a gross sample
made up of top, middle, and bottom incremental samples should ideally be
obtained since the wind disturbs the entire surface of the pile. However, it
is impractical to climb to the top or even middle of most industrial storage
piles because of the large size.
The most practical approach in sampling from large piles is to minimize
the bias by sampling as near to the middle of the pile as practical and by
selecting sampling locations in a random fashion. Incremental samples should
be obtained along the entire perimeter of the pile. The spacing between the
samples should be such that the entire pile perimeter is traversed with
approximately equidistant incremental samples. If small piles are sampled,
incremental samples should be collected from the top, middle, and bottom.
An incremental sample (e.g., one shovelful) is collected by skimming the
surface of the pile in a direction upward along the face. Every effort must
be made by the person obtaining the sample not to purposely avoid sampling
larger pieces of raw material. Figure F-7 presents a data form to be used for
the sampling of storage piles.
In obtaining a gross sample for the purpose of characterizing a load-in
or load-out process, incremental samples should be taken from the portion of
the storage pile surface (1) which has been formed by the addition of aggre-
gate material or (2) from which aggregate material is being reclaimed.
F.2 LABORATORY ANALYSIS
F.2.1 Sources Other Than Paved Roads
F.2.1.1 Sample Preparation—
Once the gross sample is brought to the laboratory, it must be prepared
for silt analysis. This entails dividing the sample to a workable size.
A 23-kg (50-lb) gross sample can be divided by using: (1) mechanical
devices; (2) alternative shovel method; (3) riffle; or (4) coning and quarter-
ing method. Mechanical division devices are not discussed in this section
since they are not found in many laboratories. The alternative shovel method
is actually only necessary for samples weighing hundreds of pounds. There-
fore, this section discusses only the use of the riffle and the coning and
quartering method.
F-9
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Date Sample Collected
Sampling Data for
Storage Piles
Recorded by_
Type of Material Sampled:
Site of Sampling:
SAMPLING METHOD
1. Sampling device: pointed shovel
2. Sampling depth: 4-6 inches (10-15 crn)
3. Sample container: metal or plastic bucket with sealed poly liner
4. Gross sample specifications:
(a) 1 sample of 23kg (50 Ib) minimum for every pile sampled
(b) composite of 10 increments
5. Minimum portion of stored material (at one site) to be sampled: 25%
Indicate deviations from above method:
SAMPLING DATA
Sample
No.
Time
Location (Refer to map)
Surface
Area
Depth
Quantity
of Sample
Figure F-7. Data form for storage pile sampling.
F-10
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ASTM standards describe the selection of the correct riffle size and the
correct use of the riffle. Riffle slot widths should be at least three times
the size of the largest aggregate in the material being divided. The follow-
ing quote describes the use of the riffle.1
"Divide the gross sample by using a riffle. Riffles properly
used will reduce sample variability but cannot eliminate it. Rif-
fles are shown in Figure F-8(a) and (b). Pass the material
through the riffle from a feed scoop, feed bucket, or riffle pan
having a lip or opening the full length of the riffle. When using
any of the above containers to feed the riffle, spread the mate-
rial evenly in the container, raise the container, and hold it
with its front edge resting on top of the feed chute, then slowly
tilt it so that the material flows in a uniform stream through the
hopper straight down over the center of the riffle into all the
slots, thence into the riffle pans, one-half of the sample being
collected in a pan. Under no circumstances shovel the sample into
the riffle, or dribble into the riffle from a small-mouthed con-
tainer. Do not allow the material to build up in or above the
riffle slots. If it does not flow freely through the slots, shake
or vibrate the riffle to facilitate even flow."
The procedure for coning and quartering is best illustrated in
Figure F-9. The following is a description of the procedure: (1) mix the
material and shovel it into a neat cone; (2) flatten the cone by pressing the
top without further mixing; (3) divide the flat, circular pile into equal
quarters by cutting or scraping out two diameters at right angles; (4) discard
two opposite quarters; (5) thoroughly mix the two remaining quarters, shovel
them into a cone, and repeat the quartering and discarding procedures until
the sample has been reduced to 0.9 to 1.8 kg (2 to 4 Ib). Samples likely to
be affected by moisture or drying must be handled rapidly, preferably in an
area with a controlled atmosphere, and sealed in a container -to prevent
further changes during transportation and storage. Care must be taken that
the material is not contaminated by anything on the floor or that a portion is
not lost through cracks or holes. Preferably, the coning and quartering oper-
ation should be conducted on a floor covered with clean paper or plastic.
The size of the laboratory sample is important—too little sample will
not be representative and too much sample will be unwieldy. Ideally, one
would like to analyze the entire gross sample in batches, but this is not
practical. While all ASTM standards acknowledge this impracticality, they
disagree on the exact size, as indicated by the range of recommended samples,
extending from 0.05 to 27 kg (0.1 to 60 Ib).
D2013-72. Standard Method of Preparing Coal Samples for Analysis. Annual
Book of ASTM Standards, 1977.
F-ll
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Feed Cnufe
Riffle Scmoler
Riffle Sucker end
Separate Feed Chufe Sfcnd
(b)
Figure F-8. Sample dividers (riffles),
F-12
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Figure F-9. Coning and quartering.
F-13
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The main principle in sizing the laboratory sample is to have sufficient
coarse and fine portions to be representative of the material and to allow
sufficient mass on each sieve so that the weighing is accurate. A recommended
rule of thumb is to have twice as much coarse sample as fine sample. A labo-
ratory sample of 800 to 1,600 g is recommended since that is the largest
quantity that can be handled by the scales normally available (1,600-g
capacity). Also, more sample than this can produce screen blinding for the
8-in-diameter screens normally available.
F.2.1.2 Laboratory Analysis of Samples for Silt Content--
The basic recommended procedure for silt analysis is mechanical dry siev-
ing after moisture analysis. A step-by-step procedure is given in Tables F-l
and F-2. The sample should be oven-dried for 24 h at 230°F (110°C) before
sieving. The sieving time is variable; sieving should be continued until the
net sample weight collected in the pan increases by less than 3.0% of the
previous net sample weight collected in the pan. A minor variation of 3.0% is
allowed since some sample grinding due to interparticle abrasion will occur,
and consequently, the weight will continue to increase. When the change
reduces to 3.0%, it is thought that the natural silt has been passed through
the No. 200 sieve screen (75 ymP) and that any additional increase is due to
grinding. Both the sample preparation operations and the sieving results can
be recorded on Figures F-10 and F-ll.
F.2.2 Samples From Paved Roads
F.2.2.1 Sample Preparation and Analysis for Total Loading—
The gross sample of paved road dust will arrive at the laboratory in two
types of containers: (1) the broom-swept dust will be in plastic bags; and
(2) the vacuum-swept dust will be in vacuum bags.
Both the broom-swept dust and the vacuum-swept dust are weighed on a beam
balance. The broom-swept dust is weighed in a tared container. The vacuum-
swept dust is weighed in the vacuum bag which was tared and equilibrated in
the laboratory before going to the field. The vacuum bag and its contents
should be equilibrated again in the laboratory before weighing.
The total surface dust loading on the traveled lanes of the paved road is
then calculated in units of kilograms of dust on the traveled lanes per kilom-
eter of road. When only one strip is taken across the traveled lanes, the
total dust loading on the traveled lanes is calculated as follows:
m, -i- m
L = JL-.v (F-l)
where: L = surface dust loading (kg/km)
m^ = mass of the broom-swept dust (kg)
my = mass of the vacuum-swept dust (kg)
t = length of strip as measured along the centerline of the road
(km)
F-14
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TABLE F-l. MOISTURE ANALYSIS PROCEDURE
1. Preheat the oven to approximately 110°C (230°F). Record oven
temperature.
2. Tare the laboratory sample containers which will be placed in the
oven. Tare the containers with the lids on if they have lids. Record
the tare weight(s). Check zero before weighing.
3. Record the make, capacity, smallest division, and accuracy of the
scale.
4. Weigh the laboratory sample in the container(s). Record the combined
weight(s). Check zero before weighing.
5. Place sample in oven and dry overnight.*
6. Remove sample container from oven and (a) weigh immediately if
uncovered, being careful of the hot container; or (b) place tight-
fitting lid on the container and let cool before weighing. Record the
combined sample and container weight(s). Check zero before weighing.
7. Calculate the moisture as the initial weight of the sample and
container minus the oven-dried weight of the sample and container
divided by the initial weight of the sample alone. Record the value.
8. Calculate the sample weight to be used in the silt analysis as the
oven-dried weight of the sample and container minus the weight of the
container. Record the value.
aOry materials composed of hydrated minerals or organic materials like
coal and certain soils for only 1-1/2 h. Because of this short drying
time, material dried for only 1-1/2 h must not be more than 2.5 cm
(1 in.) deep in the container.
F-15
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TABLE F-2. SILT ANALYSIS PROCEDURES
1. Select the appropriate 8-in. diameter, 2-in. deep sieve sizes. Recom-
mended U.S. Standard Series sizes are: 3/8 in., No. 4, No. 20,
No. 40, No. 100, No. 140, No. 200, and a pan. Comparable Tyler Series
sizes can also be utilized. The No. 20 and the No. 200 are mandatory.
The others can be varied if the recommended sieves are not available
or if buildup on one particulate sieve during sieving indicates that
an intermediate sieve should be inserted.
2. Obtain a mechanical sieving device such as vibratory shaker or a Roto-
Tap.
3. Clean the sieves with compressed air and/or a soft brush. Material
lodged in the sieve openings or adhering to the sides of the sieve
should be removed (if possible) without handling the screen roughly.
4. Obtain a scale (capacity of at least 1,600 g) and record make,
capacity, smallest division, date of last calibration, and accuracy
(if available).
5. Tare sieves and pan. Check the zero before every weighing. Record
weights.
6. After nesting the sieves in decreasing order with pan at the bottom,
dump dried laboratory sample (probably immediately after moisture
analysis) into the top sieve. Brush fine material adhering to the
sides of the container into the top sieve and cover the top sieve with
a special lid normally purchased with the pan.
7. Place nested sieves into the mechanical device and sieve for 20 min.
Remove pan containing minus No. 200 and weigh. Replace pan beneath
the sieves and sieve for another 10 min. Remove pan and weigh. When
the differences between two successive pan sample weighings (where the
tare of the pan has been subtracted) is less than 3.0 percent, the
sieving is complete.
8. Weigh each sieve and its contents and record the weight. Check the
zero before every weighing.
9. Collect the laboratory sample and place the sample in a separate
container if further analysis is expected.
F-16
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Sample No:
Material:
Split Sample Balance:
Make
Capacity
Smallest Division
Total Sample Weight:
(Excl. Container)
Number of Splits:
Split Sample Weight (before drying)
Pan •*• Sample:
Pan:
Wet Sample:^
Oven Temperature:
Dare In Dots Out
Time In Time Out
Drying Time
Materiel Weignr
Pan - Material:
Pan:
after drying)
Dry Sample:
MOISTURE CONTENT:
(A) Wet Sample Wt._
(B) Dry Sample Wt._
(C) Difference Wt.
C X 100
Moisture
Figure F-10. Example moisture analysis form.
F-17
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Sample No:
Mai'erial:
Split Sample Balance:
Make
Capacity
Smallest Division
Material Weight (offer drying)
Pan T Material:
Pan:
Dry Sample:
Final Weight:
% Silt =
Toral Nef Weignr
SIEVING
Time: S^ar^:
Initial (Tare):
20 min:
30 min:
40 min:
Weight (Pan Only)
SIZE DISTRIBUTION
Screen
3/8 in.
4 mesh
10 mesh
20 mesh
40 mesh
100 mesh
140 mesh
200 mesh
Pan
Tare Weight
(Screen)
Final Weight
(Screen + Sample)
Net Weight (Sample)
|
%
Figure F-ll. Example silt analysis form.
F-18
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When several Incremental samples are collected on alternate roadway
halves as shown 1n Figure F-4, the total surface dust loading is calculated as
follows:
i"wi "*" ro..i + m. c + m..c
L = bl vl b5 v5 + (F-2)
mb2 + "v2 + mb6 * Bv6 ,
"b3 * t"v3 + "W + V
mb4 * mv4 + mb8 + mv8 ,
where: L = surface dust loading (kg/km)
m^j. = mass of broom sweepings for increment 1 (kg)
mv. = mass of vacuum sweepings for increment i (kg)
i = length of increment i is measured along the road center line
(km)
F .2.2.2 Sample Preparation and Analyses for Road Dust Silt Content-
After weighing the sample to calculate total surface dust loading on the
traveled lanes, the broom-swept and vacuum-swept dust is composited. The com-
posited sample is usually small and requires no sample splitting in prepara-
tion for sieving. If splitting is necessary to prepare a laboratory sample of
800 to 1,600 g, the techniques discussed in Section F.2.1.1 can be used. The
laboratory sample is then sieved using the techniques described in Section
F.2.1.2.
F-19
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