EPA-450/3-77-021d
    June 1977

A
W
      AN IMPLEMENTATION PLAN
                  FOR SUSPENDED
           PARTICIPATE MATTER
           IN THE PHOENIX AREA
            VOLUME IV - CONTROL
        STRATEGY FORMULATION
      U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Air and Waste Management
       Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711

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                                  EPA-450/3-77-021d
        AN IMPLEMENTATION PLAN
FOR SUSPENDED PARTICULATE MATTER
           IN THE PHOENIX AREA
    VOLUME IV - CONTROL STRATEGY
                FORMULATION
                        by

                      George Richard

              Environmental Engineering Division of TRW, Inc.
                      One Space Park
                   Redondo Beach, California
                    Contract No. 68-01-3152
                 EPA Project Officer: Dallas Safriet
                      Prepared for

               ENVIRONMENTAL PROTECTION AGENCY
                 Office of Air and Waste Management
               Office of Air Quality Planning and Standards
               Research Triangle Park, North Carolina 27711

                       June 1977

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This report is issued by the Environmental Protection Agency to report technical
data of interest to a limited number of readers.  Copies are available free
of charge to Federal employees,  current contractors and grantees, and nonprofit
organizations - in limited quantities - from the Library Services Office (MD-
35), Research Triangle Park,  North Carolina 27711; or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
This report was furnished to the Environmental Protection Agency by Environmental
Engineering Division of TRW, Inc. , One Space Park, Redondo Beach, California,
in fulfillment of Contract No. 68-01-3152.  Prior to final preparation, the report
underwent extensive review and editing by the Environmental Protection Agency.
The contents reflect current Agency thinking and are subject to clarification
and procedural changes.

The mention of trade names or commercial products does not constitute endorse-
ment or recommendation for use by the Environmental Protection Agency.
                        Publication No. EPA-450/3-77-021d

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                             TABLE OF CONTENTS

                                                                      Page

1.0    INTRODUCTION AND SUMMARY	     1-1

       1.1   RESULTS	     1-1

       1.2   CONCLUSIONS AND RECOMMENDATIONS   .  .	     1-0

2.0    CHARACTERIZATION OF ALTERNATIVE CONTROLS	     2-1

       2.1   CONTROL OF DUST EMISSION FROM UNPAVED  ROADS   	     2-3

       2.2   CONTROL OF ENTRAINED DUST OFF PAVED  STREETS	     2-13

       2.3   CONTROL OF DUST FROM CONSTRUCTION ACTIVITIES	     2-31

3.0    FORMULATION OF REASONABLE CONTROL STRATEGY  	     3-1

       3.1   FACTORS AFFECTING SELECTION OF REASONABLE  CONTROL
            MEASURES	     3-1

       3.2   SELECTION OF REASONABLE STRATEGY	     3-6

       3.3   IMPACT OF STRATEGY ON EMISSION LEVELS    	     3-13

            3.3.1   Unpaved Roads	     3-18

            3.3.2   Entrainment of Dust Off Paved Roads  	     3-21

            3.3.3   Construction Activities  	  	     3-26

       3.4   IMPACT ON AIR QUALITY	     3-26

       3.5   COST OF CONTROLS	     3-36

       3.6   IMPLEMENTATION PROBLEMS	     3-38

       3.7   DEMONSTRATION MODEL   	     3-42
                                    in

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                         1.0  INTRODUCTION AND SUMMARY

     This report is the fourth of four documents associated with a project
to develop an air pollution control  strategy for total suspended particulate
matter in the Phoenix area.  The previous documents include a review and
analysis of air quality data (Volume I), documentation of a particulate
emissions inventory (Volume II), and development of the relationship be-
tween emissions levels and air quality.  The present report (Volume IV)
characterizes alternative control measures and documents the synthesis of
these candidate measures into a control strategy.  The data base and
methodology developed in the project have been extended to provide a general
guideline document for application to areas with fugitive dust problems
similar to those in the Phoenix area.
     A principal goal of the project was to develop a control strategy based
on "reasonable and achievable controls" that would minimize TSP concentra-
tions in the study area to the extent practicable.  Such a plan has been
formulated and is described in this report.  The strategy deals solely
with fugitive dust sources, the main cause of high TSP levels in Phoenix
today.  Complete attainment of the standard is predicted with application of
reasonable and  available controls.
     The present section of this report introduces the study and summarizes
the major results and conclusions.  Section 2 characterizes various candi-
date dust control methods for major fugitive dust sources causing high
levels of TSP in the Phoenix area.  Section 3 discusses the factors in-
volved in reasonable control selection, and formulates a control strategy
based on these selection considerations.  The impact of the control
strategy on emissions levels and air quality is evaluated, and the cost
and implementation problems associated with each of the control measures'
are documented.
1.1  RESULTS
     A review of the emissions inventory developed earlier in the study^  '
showed that local fugitive dust sources are the most substantial contrib-
utor to TSP levels in the Phoenix area.  By 1985, after planned develop-
ment changes the distribution and magnitude of the various sources, it is fore-
casted that three fugitive  dust source categories will  alone contribute to
                                    1-1

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over 90% of the TSP levels  in  the  study  area.  These sources  are  unpaved
roads, street dust on paved roads, and construction activities.   Because
of the domination of TSP levels  by these sources,  the  investigation  of
alternative controls deals  exclusively with  their  treatment.
     Control  methods to reduce dust emissions  from unpaved  roads  consist
of:  1) paving, 2)  chemical stabilizers, 3) watering, 4) graveling,  and
5) traffic related controls.   Characterization of  these  controls  shows
that as a long term cost effective measure,  paving of  roads  is  the most
suitable control approach,  as  well as a  relatively effective one.  In
addition, road paving is compatible with planning  objectives  of local
agencies, and provides numerous  cost benefits  to many  sectors of  the
community.  The effectiveness  of chemical stabilizers  as a  road dust con-
trol has improved in recent years, but the high annualized  cost of this
measure for only partial reduction of road emissions is  a major drawback  to
its use»  The same shortcomings  afflict  watering   and  graveling controls.
Traffic controls such as speed restrictions  are effective as interim con-
trol approaches, reducing dust emission  rates  significantly at  very  low
cost, but causing substantial  inconvenience  in areas where  unpaved roads
serve as major travel routes.
     Dust entrained from paved streets may be  best controlled by  either
eliminating sources of street  dust, or by more frequent  and efficient
removal of street dust loadings.  Dust sources, consisting  primarily of
exposed soil  areas near the streets, are substantially reduced  when  unpaved
road shoulders are upgraded with curb and sidewalks.   Further elimination
of sources is attained by providing soil cover (e.g. vegetation or aggregate
materials) or stabilization of adjacent  soil areas.  These  measures  are
relatively cost effective,  and consistent with general improvement plans
in any community.  Frequent street sweeping  is an  equally cost  effective
measure, provided the suspendabl.e fines  are  removed  by a suitable
cleaning approach such as vacuum sweeping.
     Control  methods to reduce dust arising  from  construction activities
consist of:  1) watering unpaved areas  subject to  traffic,  2) stabilization
of cleared areas of exposed earth, and  3) sweeping nearby public  streets.
Enforcement of these measures, particularly  wetting  of unpaved  access routes,
                                    1-2

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provides significant reduction in dust emissions, and reduces  the tempo-
rarily  localized effects of construction activities on air quality.
     In establishing the reasonableness (technological  and economic
feasibility) of control  measures, several  area-specific factors must be
considered.  These factors  include:   1) the compatibility of the controls
with general planning of the area, 2) the  timetable for implementation,
3) the degree of control required, and 4)  the financing mechanisms  available
for implementation of the control.  Based  on the characterization of
available control methods and a consideration of the above selection factors,
most of the measures for control of fugitive dust appear to be both
technically and economically feasible (reasonable) in the Phoenix area.
Control selection, therefore, reduces to a determination of the most cost
effective and least disruptive measures which will provide attainment
of air quality standards.
     Table 1-1 summarizes the reasonable control strategy proposed  for the
Phoenix area.  The strategy has been formulated by evaluating  successive
trials of specific combinations of cost effective measures until attainment
of air quality standards was predicted at  each of the monitor sites.  The
strategy was designed to minimize "overkill" at any given monitor site, and
to provide special attention where needed  for attainment in "hot spot"
areas.  The strategy is aimed at attainment over a reasonably achievable
time frame, beginning in 1978 and reaching complete attainment at all monitor
sites by 1975.  Cost of the strategy is estimated at $4.4 million per year.
     The measures comprising the strategy  are consistent with  long  term
planning goals for the Phoenix region, and are also effective  as dust
controls.  The strategy is implementable in a technical and economic sense,
however, substantial social resistance'may likely develop against its
execution.  A special feature of the overall strategy is a demonstration
model to develop social acceptance for; the strategy approach.   This portion
of the strategy is discussed in Section 3.7.  Another special  proposal
concerns the extension of the current monitor network to establish  base-
line air quality in specific locations identified by the study as potential
non-attainment areas after strategy implementation.
     The reasonable control strategy formulated for the Phoenix area is
selective for the three major sources affecting TSP levels.  The control
                                    1-3

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                 TABLE  1-1.
                                SUMMARY  OF REASONABLE  CONTROL STRATEGY FOR PHOENIX  AREA
                                NOTE:  THE DEMONSTRATION STRATEGY IS  PREREQUISITE TO
                                        IMPLEMENTATION  OF THIS PROGRAMb
SOURCE CATEGORY
                     CONTROL MEASURE
EMISSIONS  REDUCTION FROM
   1985 BASELINE LEVEL
  tons/day    percent
           ANNUAL I ZED COST OF MEASURE
             (Millions of Dollars)
Entrained Dust
  Off Streets
Construction
Unpaved Roads    1.  Chip  Seal all section line roads
                    by  1995, and one half by 1985.

                 2.  Reduced speed limit to 20 mph
                    for all interior unpaved roads
                    (private and county) by 1985

                 1.  By  1985, sweep major city roads to attain
                    a 60% reduction in assumed street dust
                    loading in designated areas.b

                 1.  Effective 1980, wetting of site access
                    roads twice daily at .5 gal/yd2.

                 2.  By  1980, sweep roads to remove visible
                    dust  loads caused by construction
                    activities.  Sweeping shall be daily
                    if  necessary.

                 3.  By  1980, stabilization of exposed earth  at
                    construction sites when operations cease
                    on  this land for more than 2 months.

Other Sources       No  additional measures are recommended as
                    other sources are already controlled (either
                    by  direct pollution regulations or by other
                    restrictions which affect dust control)  or
                    have  insignificant impact on TSP levels.
     298


     256



      18



      77
19.2%


16.5%



 5.6%



 5.0%
2.5


0.2



 .36a



0.7


0.6
aBased on the required  sweeping program indicated by the existing data base.  This would consist  of  cleaning
 major roads three  times weekly, alternating from vacuum sweeping to broom sweeping as appropriate.
bThree field programs are proposed as prerequisites to  implementation of the control strategy.  First, a
 demonstration project  would involve application of the strategy measures within a limited selected  area, and
 promotional  aspects to shape public acceptance for the eventual overall strategy.  Second, a  field  measurement
 program to  determine street dust loads and effects of  various  sweeping alternatives should be conducted to
 reconcile current  sweeping controls indicated necessary by  the limited existing data base. Third,  the air
 quality monitor  network should be extended to establish baseline TSP levels at potential  non-attainment areas
 which may require  additional controls in 1985.

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measures for unpaved roads exert the greatest impact on overall  emission
levels.  These controls reduce total baseline particulate emissions in the
study area by 35% in 1985.  Figure 1-1 shows the impact of the control
strategy on emission levels.  Overall, the total change in emission levels
ini1985, due to the strategy and to anticipated development in the study
area, amounts to a 31.6% reduction from the 1975 level.  Emission reductions
attained by the year 1980 are less dramatic as only roughly two sevenths
of the strategy will be implemented by then.
     Equally important as the emission level magnitudes are the distribu-
tion of the reductions.  Emissions are reduced substantially in the areas
near the monitor sites.  Because the major portion of ambient TSP levels
are caused by local sources in the near vicinity of the receptor, the impact
of the control strategy in areas near the monitors is substantial.  Air
quality improvements at monitor sites in the specially designated control
area are dominated primarily by reductions in entrained street dust.  How-
ever, sites outside the metropolitan influence or bordering the city tend
to be more affected by control measures proposed for unpaved roads.
Figure 1-2 shows the effect of the strategy on air quality at several of
the monitoring sites. By 1980, significant improvements in air quality are
predicted at many of the sites.  However, these gains are minor compared
to the effect of the strategy by 1985, when baseline TSP levels are reduced
by about one third at most sites, and all' but two sites are forecasted
to attain (or very nearly attain) the primary air quality standards by 1985.
Air quality at the two exception sites was found to be unrepresentative
of the general area; hence, more stringent controls in the vicinity of these
monitors may be needed.  However, before extensive site-specific plans are
implemented, more detailed analysis of the sites in question with regard to
monitor location, etc., should be completed.  Additional air quality monitor-
ing data may also be necessary in order to further assess the problem and
evaluate the impact of the proposed strategy once it is implemented.  TSP
levels at the Sun City and Glendale sites are substantially lower than the
standards level, but this is due to a low baseline concentration of TSP and
unavoidable impact of the strategy throughout the remainder of the area,
rather than an overkill control plan at these sites.
                                    1-5

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o
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                      CENTRAL PHOENIX
                                                                   NORTH  PHOENIX
CO
 D.
 co
    209-'
    TOO
      o-
                         Baseline
Frlmary standard     S --~-._~

                  Crnnt-Y-nl Qt-i-a
                           Strategy
                                                           200
                                                      co
             75
                  80
             SOUTH PHOENIX
85
    200
    100
                                      —Baseline
                                Control Strategy
          Background
            75
                  80
85
                                                        o>
                                                        :  100
                                                  0--
                                                                                           Baseline
                                                                                      Control  Strategy
                                                                  Background
75             80             85
  N.  SCOTTSDALE/PARADISE VALLEY
                                                      co
                                             .E
                                             O)
                                                       CO
                                                200
                                                100
                                                                                          Baseline
                     Primary Standard      -


                             Control Strategy-
75
80
85
Figure 1-2.   Impact of Dust Control Strategy on Suspended Particulate  Levels at Monitor Sites in
             Phoenix Area.

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I
00
                                 CHANDLER
                                                                      GLENDALE
           200
       co
         . 100
        Q.
                                        Baseline
Primary Standard
                  Background
                                      Control  Strategy
                                                             co
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                                                                   o -
                   Baseline
                                                    Background
                                                                        Control  Strategy
                    75
                 80


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        Q.
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           200
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                                               Baseline
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                  Background
                                          Control  Strategy
                     75
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                                              100
                                                o -
   80


ST. JOHNS
85
                                                                                               -Baseline
                      Primary Standard
                                                                      -Control  Strategy
                                                                         Background
                                                                        0
                Figure 1-2. (Continued)  Impact of Dust Control Strategy on Suspended Partlculate
                                         levels At Monitor Sites in Phoenix Area

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                             SUN CITY
    200


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 en

  .  100
 Q.
          o-
                                          Baseline
           Primary Standard

           Background
           --o-

"Control Strategy
                •TT
                                           -85-
                                                                                      SCOTTDALE
                                                                     200
                                                                 CD
                                                                 ft
                                                                 -Baseline

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                                                                            Background
                                                                                                Control  Strategy
I
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                           ARIZONA STATE
    o>
        200- •
        100
                                          Baseline
              Control


              Primary Standard
              Background
                 75
                            80
            85
                              E

                              CD
                                                                 CL.
                                                                 CO
                                                                                    DOWNTOWN PHOENIX
                                                                  200- '
                                                                     100
                                                                                                         Baseline
                                                                         Control  Strategy



                                                                         Primary  Standard





                                                                         Background
                                                                        75             80
Figure 1-2 (Continued).  Impact of Dust Control Strategy on Suspended Particulate  Levels at
                         Monitor Site  in Phoenix Area
85

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1.2  CONCLUSIONS AND RECOMMENDATIONS

     •  A reasonable control  strategy  can  attain substantial  improvements
        in ambient air quality  in  Phoenix.  Measures which  are  technically
        and economically feasible  can  achieve the emission  reductions  re-
        quired for attainment of the primary air quality standards  for TSP.

     •  The cost of clean air in Phoenix appears economical.  Compared to
        cities experiencing  TSP non-attainment due to  conventional  emission
        sources (e.g. Los Angeles), the cost effectiveness  of lowering TSP
        from fugitive dust in Phoenix  is an order of magnitude  less.

     •  Successful implementation  of the control strategy may be  jeopardized
        by social resistance (about 70% of the strategy costs must  be
        financed by public funds).   A demonstration strategy should be
        instituted to promote social acceptability for the  strategy concept.

     •  A local demonstration strategy is  particularly appropriate  for areas
        experiencing widespread fugitive dust problems because  of the
        dominant local influence of these  sources.  A  substantial portion
        of the particle sizes from thse sources are greater than  15 microns,
        and are limited in travel  distance.  However,  because of  their
        widespread distribution throughout the Phoenix area,  these  sources
        play a major role in measured.TSP  levels at many sites.   The
        feasibility of improving air quality by eliminating such  local
        sources could be readily demonstrated by institution  of a modest
        local control program which is closely monitored.

     •  The uncertainties involved in  the  analysis of  dust  pollution sources
        makes justification of  extensive control strategies untenable.
        More precise demonstration is  needed to warrant implementation of
        the costly measures which  are  predicted to improve  air  quality.
        The short term local model strategy  is an appropriate vehicle  for
        this demonstration.

     •  A special feature of the fugitive  dust measures comprising  the
        strategy is their compatibility with overall planning objectives
        for the area.  Dust control for unpaved roads  and paved city streets
        are merely intensified  extensions  of current local  programs (e.g.
        paving of roads).

     t  The consistency between the major  elements of  the proposed  control
        strategy and planning objectives of  local governmental  agencies
        permits a workable approach  to implementation  of dust controls.
        The measures may be instituted and conducted as on-line operations
        of the various local agencies, as  opposed to the more conventional
        procedure employing regulatory actions.

     •  Because of uncertainties  in  the data  base available for assessing
        street dust loadings and  street equipment sweeping  efficiencies,
        it is not possible to specify  a definite street sweeping  program
        to accomplish the targeted emission  reductions.  A  field  measure-
        ment program should be  instituted  to establish baseline loadings

                                   1-10

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   for various streets  and to determine  by test  the  actual  sweeping
   programs needed to obtain the allowable dust  levels.

•  This study has identified nine potential  non-attainment  areas
   (Figure 3-10) which  may require additional  control  attention
   in 19850  It is recommended that monitor sites  be installed at
   the indicated locations to establish  baseline TSP levels for use
   in air quality simulation and  prediction of  future TSP  levels
   there.  The timetable for completing  the expanded monitor network
   should be immediate  to permit appropriate adjustment  of  the proposed
   control strategy (if necessary) before required deadlines.

0  To insure maximum effectiveness of the demonstration  strategy as
   a persuasive tool, implementation should include  a public relations
   program to promote awareness of the economic  and  air  quality
   benefits inherent in dust control plans.   Opinion surveys should
   be conducted to develop an understanding of the value forces which
   must be shaped.
                               1-11

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2.0  CHARACTERIZATION OF ALTERNATIVE CONTROLS

     In the Phoenix area, formidable reductions in fugitive dust emissions
must be achieved if air quality is to be upgraded to the National Ambient
Air Standards for suspended particulates.  Therefore, the success of the
air pollution control plan will depend greatly on the effectiveness of
controls proposed for the major fugitive dust sources.  Examination of the
1975 and 1985 emission inventories reveals the dominance of 5 major source
categories in the total emissions tabulation.  Table 2-1 shows a listing
of the major particulate emissions expected from these sources in 1985.
Five sources are responsible for all but 17% of the particulate emissions
in 1975, and by 1985 these sources are estimated to account for all but
7% of the total particulate emissions in the study area.  During the air
quality modeling task of this study [17], it was shown that three of the
major sources are almost entirely responsible for the high levels of sus-
pended particulates monitored throughout the study area.  These sources
are fugitive dust arising from unpaved roads, dust off paved streets, and
construction activities.
      The dominance of fugitive dust emissions in the particulate emissions
inventory (Table 2-1) is confirmed by microscopic analyses of the Hi-Vol
filters.  Approximately 70% of all mass deposited on the filters consists of
particles greater  than  20 micron diameters. ~[35]   In areas where conventional
sources are already controlled (such as Phoenix), particles greater than
10 micron diameter are generally of fugitive origin.  In the Phoenix study
area, one third of the fugitive dust emissions are  estimated to  be greater
than 20 micron diameter.  The  local impact of large  particles is substantial.
Gravitational settling of the  larger particles confines  them to short
range transport, and limits their dispersion significantly.  Controls which
treat these sources on a local basis may  imorove local air quality substantially.
However, because the sources are widespread throughout the study area, the
effective control  of these local sources must be area-wide to reduce the
local impact of particle deposition at many  separate  locations.

      This chapter provides a  general characterization of alternative control
methods which are  applicable for prevention  of fugitive dust emissions from
the three major source categories.
                                    2-1

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                       TABLE 2-1.   PARTICULATE EMISSIONS FROM  MAJOR SOURCES*  IN  THE PHOENIX  STUDY
                                    AREA, 1975 AND  1985.
EMISSIONS , TONS/DAY

EMISSIONS SOURCE CATEGORY
1 . Unpaved Roads
2. Resuspension off paved roads
3. Construction activities
4. Wind Erosion-undisturbed
Desert
5. Off road vehicles
6. All other categories
Sub-total for 5 categories
Total emissions
.Percentage of all emissions
generated by 5 fugitive dust
categories
0-10y
537
164
66
200
29
258
996
1254
79.4

10-20y
144
57
23
65
8
70
297
367
81 :0
1975
20-lOOu
600
27
11
29
23
49
690
739
93.5

TOTAL
1281
248
100
294
71
386
1974
2360
83.7
0-lOy
637
213
169
58
44
105
1121
1226
91.5
1985
10-20y
171
74
59
19
12
16
335
351
95.5

.20-100y
745
35
28
8
50
19
866
885
98.0

TOTAL
1553
322
256
85
106
140
2322
2462
94.3
PO
I
ro
     *  The five sources listed above are  the largest emitting sources of particulates projected to exist  in 1985.

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2.1  CONTROL OF DUST EMISSIONS FROM UNPAVED ROADS

     Control methods to reduce dust emissions from unpaved roads consist
of (1) paving roads, (2) application of chemical stabilizers, (3) watering,
and (4) traffic related controls.  Both the city of Phoenix and Maricopa
County have considered these alternatives as candidate measures in their
respective improvement program.

     In 1960, the City Transportation Department rejected use of measures
which are temporary or of short term nature and adopted an overall plan to
provide a high standard for roadways throughout the city.  The city progr.am,
forecasted for completion by 1985, will provide for paving of all unpaved
streets and general upgrading of the city link network.  The program has
already accounted for a decrease in unpaved road mileage in the city from
550 miles in 1960 to 191 in 1976.

     The County Roadway Program includes a modest street paving effort
amounting to approximately 50 miles per year (including those streets
paved by private development).  The County Highway Department is presently
engaged in a modest test program to evaluate highway alternative chemical
stabilizers as dust retardants and as preparation bases for asphaltic
composition road surfaces.  Cement stabilization, lime, enzymes, and tree
sap have been tried as dust palliatives, without success, and also appear
to show little promise as stabilizer bases for bituminous asphaltic surfaces.
The stabilizers wear quickly under the abrasive action of motor vehicle
travel and retain their effectiveness only briefly before repeated applica-
tion is necessary [1].  The cost of effective dust control using road soil
stabilizers varies with the average vehicle traffic.  An initial application
may cost from $2000 to $4000 per mile, depending on the type of stabilizer
and the surface preparation provided.

     The Arizona Department of Transportation has recently funded a study [13]
in which various chemical stabilizers were tested for dust control on unpaved
roads.  The stabilizers were applied to sections of an unpaved road with an
                                    2-3

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average daily traffic of 140 vehicles and a surface soil  silt content of
28%.  Some of the chemicals were applied by spray, while  others were mixed
to a three inch depth after ripping the roadbed surface.   Hi-Vol and dust
collector measurements were utilized to evaluate the dust suppressing
ability of the stabilizers with the road subject to normal traffic condi-
tions.  The performance of the stabilizer products is shown in Tables 2-2
and 2-3.  As a spray treatment, dust control  oil demonstrated the highest
degree of dust control on the road surface both after the 5 month and 14
month observation periods.  This palliative also was superior in terms of
least cost.  As a stabilizer which is mixed.into the roadbed, the Redicote
E52 Asphalt Stabilizer Emulsion provides superior dust control, especially
for the longer observation period.  The stabilizer exhibiting the best
performance for dust control also performed significantly better in  terms of
road surface preservation.  The dust palliatives tested are available com-
mercially and can be applied at costs ranging from $4,300 to $10,300 per
mile of 2 lane roadway.  Since these palliatives must generally be applied
once annually (for roads carrying 150 ADT), it is clear that the substantial
annual cost of this measure should be carefully evaluated against alterna-
tives before it is applied.

     The city of Phoenix is currently engaged in a modest program to treat
a limited number of unpaved roads where dust emissions have been particularly
offensive.  Dust control stabilizers are applied with the use of a boot
truck equipped with a spray bar.  The street surface is prepared prior to
application by surface blading or by ripping, depending on whether the
application is a surface treatment or a soil  penetration  mix.  After
application of the stabilizer, the street surface is compacted using a
roller.

     The city of Phoenix is currently using Dust Control  Oil (RD-1000) sup-
plied by Standard Oil as it has proven to be a satisfactory dust palliative
in the past.  The State Department of Transportation is also using the Dust
Control Oil in the Phoenix area to stabilize 400 acres of cleared right of
way for the future Maricopa Freeway.  This treatment was  applied in 1974,
yet the soil still exhibits a crust and has been observed to be stable
during heavy winds.  Because the oil application was very light (.1 to 25
      o
gal/yd ), the crust is easily disturbed by pedestrian or  vehicle traffic.
                                     2-4

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                      TABLE  2-2.   PERFORMANCE  RATING AND RQAD  CONDITIONS  FOR  SELECTED  ROAD  DUST  PALLIATIVE,
                                        SPRAY  ON APPLICATIONS  [13]
ro
i
en
Chenical
Dust Control Oil
fixture of petroleum
resin and light hydrocarbon
solvent. Applied at .6 gal/
yd. 2.
Curasol AE
A oolymer dispersion di-
luted in water by .6 to 1 .
Applied in 4 passes at .25
gal/yds2' each.
Aerospray 70
A polyvinyl Acetate
resin diluted 6 to 1 with
water. Applied using 4 passes
at .25 gal/yd each.
Dust Bond 100 + F-125
Mixture of lignin sulfate
and other chemicals. Applied
non diluted in first pass at
1 gas/ydz- then at 1 to 1 di-
lution plus 2.5'* formula 125 on
next pass. Surface compacted
intermittently for several
nours after application
Foramine 99-194
A urea-formaldehyde resin
in water solution. Diluted
1.6 .to 1 by w.ater appli-
cation at 1 gal/yd'-
Water



Cost of Chemical
& Application3-
S/mt.
5?80




8130




8080




8420








10300




400



After 5 Months
Percentage
Control0' Description of Road Condition
95.2 Black, very hard surface, some
potholes near shoulders, min-
imal loose material, extremely
light dust behind traffic.

86.9 Dark brown, medium hard surface,
rutted with few potholes, loose
coarse particles on surface,
moderate dust behind traffic.

82.6 Brown, medium hard surface,
medium wear and ruts, few pot-
holes, loose coarse particles
on surface, moderate dust be-
hind traffic.
88.0 Brown, medium hard surface, mod-
erate wear, few potholes, smooth
surface, slippery when wet, mod-
erate dust behind traffic.





46.6 Natural color, worn and rutted
surface, large amount of loose
particles, poor riding quality,
heavy dust behind traffic.

0 Natural color, soft when wet,
worn and rutted surface, large
amount of loose particles,
heavy dust cloud behind traffic.
After 14 Months and Several Bladlngs
"ercentaqe
Control1-- Description of Road Condition
54.3 Dark brown, hard surface, scattered
potholes, moderate loose material
but from outside the road, light
dust behind traffic.

9.4 Brown, several ruts and potholes,
large amount of loose particles,
very heavy dust behind traffic.


44.3 Lt. Brown several ruts and potholes,
large amount of loose particles,
heavy dust behind traffic.


17.6 Lt brown, few patches of treated
surface, several ruts, large a-
mount of loose particles, heavy
dust behind traffic.





8.9 Natural color, similar to untreated
(water) section.



0 Natural color, worn, numerous ruts
and potholes, large amount of loose
particles, heavy dust cloud behind
traffic.
Cost effectiveness6'
$/ton of dust
Emissions Prevented
9.3




23.8




18.0




22.4








52.2




—



          Based on State cost figures [13]  for chemical stabilizers, adjusted 15%  upward to  reflect current (1976 costs, and another 10% to  Include
          cost of surface preparation ano applications.  Correction for adjustment to current costs 1s based on personal communication with  a principal
          supplier [I4j.  Costs  include shipping expenses for supplier to Phoenix.

          Cost effectiveness Is  based on the ratio of the cost and the average emissions reduction attained for the period Indicated.  This  reduction  is
          estimated by applying  the control figures above to the uncontrolled dust emissions corresponding to an unpaved road with ADT of 140, soil silt
          content of 28%, and average vehicle speed of 35 mph (see reference [10]. The uncontrolled emissions are 254 tons per mile of road  for the 5
          month period, and 712  for the 14  month period.

          Control effectiveness  1s based on dustfall measurements conducted at various distances from road.

-------
                          TABLE  2-3.   PERFORMANCE  RATINGS  AND  ROAD CONDITIONS  FOR  SELECTED  ROAD  SOIL  STABILIZERS,
                                            MIXED  INTO  SOIL3-  [13]

Chemicals
Redlcote E52 Asphalt Emulsion
A cationic asphalt emulsion
(7.4^ In water) applied at
2.4 gal/yd2-
Dust Bond 100 + F-125
A misture of lignin sulfonatp
and other chemicals plus
formula 125. Applied at
1 gal/yd .
Dust Control Oil
Mixture of petroleum resin
and light hydrocarbon solvent.
Applied at .5 gal/yd2-
Water

Cost of Chemical.
and its application
$/mi
10810
8440
4370
600

Percent .
Control '
94.7
86.6
80.5
0
After 5 Months
Description of Road Condition
Black, very hard, asphalt like
surface, little wear, smooth
no loose material, no dust behind
traffic.
Brown, hard surface, smooth,
little wear, some loose material,
very light dust behind traffic.
k
Black, hard at,spots, few ruts
and potholes, loose course material
moderate dust behind traffic
Natural color, rutted, several pot-
holes substantial loose material,
heavy dust behind traffic.

"ercent
Control a-
84.4
44.7
11.5
0
After 14 Months
Description of Road Conditions
After Several Bladings 9/29/75
Black very hard, asphalt like surface,
little wear, good riding quality, some
loose coarse material, very little dust
behind traffic.
Brown, few hard spots, numerous ruts
and potholes, heavy dust concentration
behind traffic.
Dark brown, hard at few spots, numerous
ruts and potholes, heavy dust cloud
behind traffic.
Natural color, rutted, numerous potholes,
substantial loose material, heavy dust
cloud behind traffic.

Cost effectiveness
$/ton of dust emissions
Prevented
17.0
18.1
13.4

ro
cr>
       b.
Mixing of the chemical stabilizer  into the road bed is accomplished as follows:  1) the surface is first ripped to a  depth of 3 Inches; 2)- the surface
is sprayed with water; 3) the chemical is sprayed on the  surface; 4)  the chemical is mixed into the soil  surface with a series of successive bladings;
5) the road surface  is compacted by rolling.

Based on state cost  figures [13] for chemical stabilizers, adjusted 15* upward to reflect current (1976)  costs, and, adjusted another 10% to include
cost of surface preparation and chemical  application.Correction to current costs are based on communication with a principal supplier [14].  Costs
Include shipping expenses from supplier to Phoenix.   .


Cost effectiveness 1s based on the ratio  of the cost and  the average  emissions reduction attained for the period indicated.  This reduction 1s estimated
by applying the control figures above to  the uncontrolled dust emissions corresponding to an unpaved road with ADT of 140, soil silt content 28%, and
average vehicle speed of 35 mph (see reference [10].  Roadway dust emissions without control are 712 tons  for the 14  month period.
           Control effectiveness is based on dustfall  measurements conducted  at various  distances from road.

-------
This crust is, however, re-established after rainfall provided the soil is
not disturbed by frequent traffic.

     The tests by the State Department of Transportation show clearly that
chemical soil stabilizers may be used as an effective control for unpaved
road dust emissions.  In some cases the stabilizer also serves to preserve
the road surface, resulting in lower road maintenance cost.  Of the various
chemicals tested by the state, the Dust Control spray application is by far
the most cost effective in terms of dust control.  The most effective
performer was the mix-in application of Redicote Asphalt Emulsion, which
was controlling dust emissions by 85% after a 14 month period.  The main
drawback to use of the effective stabilizer is cost.  Repeated applications
of the chemicals, even at reduced rates, impose costs which approach or
exceed the annualized cost of a paved road.

     In addition to chemical road stabilizers, the county and city have
each considered low-cost paving alternatives.  The most widely used low
cost pavement is the bituminous asphaltic chip seal over a granular
base or a stabilized soil base.  Figure 2-1 shows a profile of this chip
seal construction.  A penetration stabilizer (liquid asphalt MC-250) is
applied to the 6 to 8 inch base, followed by a chip seal.
                          \  Er./jf/r.a  Bosc MafsriaJ_
   Figure 2-1.  Profile of Typical Section for Chip Seal Road Surface
                Construction.
                                    2-7

-------
                     TABLE 2-4.  COST  OF  CITY STREET MAINTENANCE IN PHOENIX,  1974-75 FISCAL  YEAR [2]

MAJOR:
Fully improved
Bituminous Surface Treatment
Oiled Roadway
No. Surface Treatment (graded)
Total
COLLECTOR
Fully improved
Bituminous Surface Treatment
Oiled Roadv.'ay
No Surface Treatment (graded)
Total
LOCAL:.
Fully improved
Bituminous Surface Treatment
Oiled Roadway
No Surface Treatment (graded)'
Total
GRAND TOTAL

Miles
397
13
5
5
TFO"

200
28
8
1
237

1,772
15
35
116
T7913"
.2,595

% of Total
City Miles
15.3 •>
0.5.
0.2
0.2
T672
"
7.7
1.1
0.3 "
-


68.3 - ..
0.6
1.3
. 4.5
74.7
: '100.0


City Cost
For Period
$1,296,027
42,743
13,531
	 19_,_69P.

$ 182,737
45,688
2,427
8,702
$ 239,554

$ 541,499 '
44,570
40,503
. 222,663
5 849,2.35
: .'$2,460,730


% of Total •
City Cost
52.7
1.7
0.5
0.8
. 5577'

7.4
1.9
0.1
0.4
9.8
. \ i
22.0
1.8
1.7
9.0
34. b'
::100.0


• Co3t Per nile
For Period
$3,265
3,223
2,705 '
3, '333
$1,267

$ 913
1,632
303
8^702
• 51,011

$, 306
2,971
1,157
1,920
$ ~'4jd
.'•$ 948


ro
i
oo
           Note:  Above  figures do not  include cost of  Preventive Maintenance by Contract,

-------
      The city has rejected the chip seal  approach on the basis of its high
annual maintenance costs and poor performance characteristics.   Table 2-4
shows the high maintenance costs incurred during 1974-1975 for the four major
types of road construction in the city of Phoenix.  However, the county is
experimenting with the bituminous chip seal  for roads with low vehicle traffic
counts (100 vehicles/day), and finding it satisfactory in applications
throughout the county.  Maintenance requirements depend on vehicle traffic
and locale, but generally include a second chip seal after one year, followed
by another seal in approximately 5 years.

     A study conducted by the city of Seattle Engineering Department has
shown the most cost effective method of dust control on roadways is a chip
seal when the average daily traffic is 150 vehicles.  This dust control option
is also economically beneficial, considering the estimated annual savings of
$2,665/yr/mi in maintenance costs resulting from the measure.  A Duwamish
Valley study [3] has shown annual maintenance costs of various types of
roadways diminishes appreciably with the quality of the road surface.
Table 2-5 shows the annual maintenance costs derived from this study.  The
study also includes a cost analysis of benefits gained by dust control for
Duwamish roadways.  These benefits were estimated to translate to over
$3.88 million/year to the community, and demonstrate clearly that paving
of roads is a good investment.
            TABLE 2-5.  ANNUAL MAINTENANCE COSTS FOR VARIOUS ROAD3
                        SURFACES [3] IN DUWAMISH VALLEY
 TYPE OF ROAD                                            COST IN $/MI

 Gravel Road                                                  2900
 Oiled Surface                                                1100
 Seal Coat                                                     245
 3 inch Asphalt                                                245
 6 inch Concrete and Curbs                                     100
a.  Costs are given for standard 2-1ane road

                                    2-9

-------
     While it is possible to show the high cost of roadway dust control
programs is economically beneficial, the most cost effective control  measures
are difficult to determine.   The Duwamish Valley Study estimated that
oiling of unpaved roads with an average daily traffic over 15 vehicles is
the least cost way to reduce dust levels.  As traffic increases, maintenance
costs required to sustain dust control throughout the year increases  until
the least cost dust control  consists of a chip seal surface at 150 ADT,  and
with still more vehicle traffic, an asphalt surface.  Typical cost estimates
for initial construction and maintenance of the different road types  in
Phoenix are shown in Table 2-6.  It is apparent that maintenance costs
contrast sharply with those  reported in Phoenix City (Table 2-4) and  the
Duwamish Valley .(Table 2-5).  This is due to the diversity of maintenance
practices and requirements from one region to another, and the differing
cost of resources.
             TABLE 2-6.  INITIAL COST AND MAINTENANCE COST OF ALTERNATIVE
                         ROAD SURFACES APPLIED BY MARICOPA COUNTY HIGHWAY
                         DEPARTMENT [1, 13]
TYPE OF ROAD
Gravel Koad
Oiled Surface (Low Cost
Application)
Oiled Surface Dust Control Oil
Chip Seal Coat
3" Asphalt
COST ($/MI)
16,000
2000-3000
5,300
35,000
55,000-100,000
ANNUAL MAINTENANCE
($/MI)
600
2000-3000
5,300
800
160
     Control efficiency estimates for the various dust measures are tabulated
by considering the effect of altering a road which is presently an unpaved
dirt surface having a silt content about twice that of a gravel road (re-
presentative of the Phoenix area).  Cost effectiveness is then estimated by
considering the annualized cost of the measure in the given study area and
the resulting emissions reduction.  Efficiencies and cost effectiveness

                                    2-10

-------
estimates are shown in Table 2-7.   The chip seal  surface appears  to be
somewhat more cost effective than  the other road  surfacing dust control
measures, and of those measures providing the best control, the chip seal
is significantly more cost effective.  These findings  are consistent with
the Duwamish Valley Study [3] where it was found  that  the least cost con-
trol was a chip seal surfacing when ADT is over 100.  However, for lower ADT,
lighter applications of the road dust palliatives may  be used to
attain a certain level of dust control and cost effectiveness of the
palliative in this instance becomes competitive with the chip seal  paving
approach.

      TABLE 2-7.  EFFECTIVENESS OF ALTERNATIVE ROAD SURFACES IN REDUCING
                  DUST EMISSIONS FROM AN UNPAVED  ROAD  IN MARICOPA COUNTY
EMISSION RATE
ROAD TYPE LB/VEHICLE MI.
Dirt Surface
Gravel
Oil Surface (Dust Control
Oil)
Oiled Surface (Low Cost
Application)
Chip Seal
Asphalt
22a
lla
5f

nb

oe
oe
ANNUAL
EFFICIENCY
—
50%
75%

50%

100%
100%
COST EFFECTIVENESS0
$/TON OF DUST
—
11.0
19.5

13.5

10. 8d
19. 6d
 '   Based on MRI emission factor [6], and road silt content of 24% and
    average vehicle speed of 35 mph.
 '   From reference [4].
c*   Computations based on assumption  of ADT of 100, maintenance costs of
    Table 2-6, and annualized cost of indefinite period at 10% interest.
 "   These figures do not incude the dust reductions attained by inducement
    of traffic off unpaved roads to the newly paved surface.
e>   This emission rate does not include entrainment of dust loadings off
    the pavement.  Entrained dust emissions are discussed in Section 2.2.
 '   Based on field test conducted by  Arizona Department of Transportation  [13],
                                    2-11

-------
    Traffic controls also offer potential for dust emissions reduction
from unpaved roads.  Dust emissions increase exponentially with vehicle
speed up to 30 mph [5,6].  Table 2-8 illustrates the dust emission rate at
different speeds for a vehicle traveling over a dirt road characteristic of
the Phoenix area.  Based on an average speed of 35 mph, the reduction
achieved by restricting vehicle speed to 20 mph would be 62%.

    Restriction of use of unpaved roads may also be employed to reduce
dust emissions.  Unpaved roads may be closed to travel when alternative
paved routes are available.  The potential of this dust control measure is
not encouraging since almost all roads provide needed access to at least
a limited segment of the population, and it is not plausible to restrict
traffic to only this limited sector.  It should be noted, however, that
traffic volume on the remaining interior unpaved roads will be diverted
significantly after addition of paved routes to the road network.  Such
traffic inducement should be considered in assessing the total effectiveness
of the road-surfacing measures.  For example, a plan to pave half the
section line roads in Maricopa County (Arizona) by 1985 would reduce expected
traffic on remaining interior unpaved roads by  15%.  This analysis is made
by considering the trip alternatives in a representative section of the
road network for the "before and after" paving control measure (Section 3.3).

      TABLE 2-8.  DUST EMISSION RATES AT DIFFERENT VEHICLE SPEEDS
SPEED OF
VEHICLE
35
30
25
20
EMISSION RATE3
LB/VEHICLE MI.
22
19
13
8.5
DEGREE OF EMISSIONS
REDUCTION
.
14%
41%
62%
1
     The emission rate is based on the MRI  emission factor [13]  for vehicle
     speeds of 30 mph and over.  For speeds from 0 to  30 mph the emission
     rate increases exponentially  with speed and is calculated  as  follows:
     e = .0211 S2, where e = emission rate  (Ib/vehicle mi.), and S  = vehicle
     speed (mph).  The baseline emission rate (35 mph) was calculated as-
     suming a typical dirt road silt level  of 24%.

                                     2-12

-------
2.2  CONTROL OF ENTRAINED DUST OFF PAVED STREETS

     The amount of   entrained dust entering the atmosphere from paved
streets is proportional to the traffic volume and the street surface dust
loading [20].  Both of these parameters vary substantially from region to
region, as well as within the region itself.  Figure 2-2 illustrates street
dust loadings measured [8] in various cities differing in age, size, locale,
meteorology, and land use patterns.  The average dust loadings of the cities
sampled was 1500 Ib/curb mile, and for Phoenix, 780 Ib/curb mile.

     The variation of dust loadings by different land use categories is
illustrated in Figure 2-3.  Streets in industrial areas tend to be most
heavily loaded, while commercial streets are least heavily loaded.  This
pattern is consistent with land use and street sweeping practices.  Com-
mercial areas are swept frequently while, industrial areas receive less
cleaning attention.  These patterns suggest the control of entrained dust
by two methods: 1) control of the street dust origins, and 2) modification
of street sweeping practices.

Control of the Dust Origins

      One obvious  means of reducing street dust loadings  is  by controll-
ing the dust sources.   Significant  origins consist of carryout of dust
from dirt surfaces by  motor vehicles,  atmospheric fallout of airborne
particulates,  and  transport from adjacent  exposed land areas.   In
Phoenix, the major sources of dust  originate from dust fallout of local
source emissions  and from transport of exposed  soil  areas near the
streets.  There are presently 470 miles of city  streets  with  unpaved
shoulders in the  cities of the study are*..   Over half of  these roads
are major streets  experiencing substantial  traffic volume.   Dust from
the exposed road  shoulders is transported  to the street surface by
air turbulence from passing vehicles,  wind erosion,  tracking by^ped-
estrians and vehicles, and water runoff.   In addition, there are
numerous exposed  vacant lots throughout Phoenix which contribute to dust
transport on nearby street surfaces.
                                    2-13

-------
f—

Z
Z
o
<
O
  ^
97
—i ~
0  e
0
       4000
                   -6000
       2000 	
       1000	
          0













•'<







•i

"




	 	
Si  > ° — rf «1
0 J « n <
          Figure 2-2.  Street Dust  Loadings for
              Various Cities in  U.S.  [8].
                      .2-"14

-------
              4000	
              3000
                       RESIDENTIAL
  >-
  h-
  t/»
  f1
  UJ

o 2

5 o

*_J *™


GO
               rooo —
INDUSTRIAL f'.-i
         £1
                                             COMMERCIAL
M
h
H
H
0.
_u
o
r



o
>
5
O
Fill ii

1 !j [| I
-1 1^3 i.n* L^
JS '^ — t •
171 "5 "i ~c<
•S J :E ^
••T ^ x

S' "° —
t> . o , o
< > -i-
-o f, '•>
o — E
( j
[1 F
Ml
Hi
11 li 0
e >- £
.- O "£
•g ? £
5? — u
E
o
c
'5.

_c


0
,
^f
T3


li
C
V*
o
_n

Figure  2-3.   Street Dust Loadings  for Various  Land-Use Categories,
              Summary  of Several Cities in U.S.  [8].
                                  2-15

-------
     Roadway improvements anticipated over the  next ten  years  will  result
in significant impacts on street dust loadings.   The mileages  of uncurbed
streets in the cities of the study area will  change as follows:

  ROAD TYPE                         MILES OF  UNCURBED CITY STREETS

Local
. Collectors and Majors
1975
142
329
1980
72
260
1985
0
191
     Source:  Support Document #2 [10].

     These improvements are important because dust loadings for streets
with uncurbed shoulders are estimated to be four times  greater than that
observed for curbed streets [9].   While  local roads play a minor role in
total dust resuspension (due to low VMT  on~those roads) the improvement of
road shoulders for collectors and major  streets is expected to decrease
the city-wide entrainment emission factor from 11.1 g/vehicle mile.
in 1975 to 8.7 g/vehicle miles in 1985,  [10],  Table 2-9 summarizes the
reduction in area-wide dust resuspension factors which  would occur with
an intensified city program to curb all  major roads and collectors by 1985.
While this emission factor applies only  to city traffic, the substantial
portion of vehicle miles traveled in the study area are concentrated within
the cities.  Hence, reductions in street dust loadings  in the cities would
have far greater impact on TSP levels than would similar reductions in the
county road network.

        TABLE 2-9.  EFFECT OF ROAD SHOULDER IMPROVEMENTS ON DUST
                    RESUSPENSION FACTORS FOR CITY STREETS
                                    TOTAL UNCURBED         WEIGHTED DUST
                                    MILES IN CITY          SUSPENSION RATE
                                                           gm/VEHICLE-MI.
Baseyear 1975
Baseline, 1985
After Program to Curb all Roads
(Major & Collector by 1985)
329
191
0
11.1
8.7
5.3
                                    2-16

-------
      Based on present city construction costs of $5/curb foot [11], the
additional cost of improving all  remaining unpaved road shoulders with
curbs in the city by 1985 would be approximately $5 million.  This compares
to the projected plan of the city of Phoenix to spend $57 million on
local street improvements and $167 million on major streets [11, 12]
by  1985.
      To increase the effectiveness of street curbings as a dust con-
trol measure, the adjacent soil should be stabilized or covered to
prevent wind erosion or tracking of this soil onto the street.  Clearly,
the most effective means of soil  protection at the curb is a sidewalk.
The current city policy is to include sidewalks whenever curbs are
constructed on major streets.  The cost of sidewalk construction is $6
per running foot of the standard 5 foot wide sidewalk.  Quantification
of the effectiveness of this measure is not possible but it is clear
that transfer of exposed soil to adjacent road surfaces will be decreased
significantly.

Street Sweeping

      There are three main types of machine street sweepers currently
in use.  Broom sweepers utilize a rotating gutter broom to sweep debri
from the gutter into the main pickup broom which rotates to carry the
debris into the truck hopper.  The broom sweeper is by far the most
commonly used class of sweeper.  A second type of sweeper, called the
air broom uses an air blast to direct debris into a collection hopper.
A third type of sweeper utilizes a broom and vacuum system to collect
debris.  Each of the sv/eepers employs a water spray to control dust
emissions during sweeping.  A number of operational and equipment
factors have an appreciable impact on street sweeping effectiveness.
                                   2-17

-------
These factors include operator performance, forward speed, type of
sweeper, and condition of broom.  The most important operational
factor in sweeping efficiency concerns level  of effort.  Level of effort
in cleaning the road   (expressed in terms of cleaning time per area)
is related to the weight of material collected by:

                      M = M* + (M  - M*) e"kE
                                         *
Where M  is the initial street loading, M  is the loading unremovable
by any amount of sweeping, k  is an empirical constant dependent on
sweeper characteristics, and E the amount of sweeping effort [8].

      The exponential effect of sweep effort on collection efficiency
for a broom sweeper is illustrated in Figure 2-4.  For the normal
street sweeping operation, a single sweep pass is performed, yielding
approximately a 50% collection efficiency (for typical operating speed).
Adding a seocnd pass to the cleaning operation, or doubling the effort,
improves efficiency to 75%.  For the vacuum sweeper, collection ef-
ficiency is relatively constant regardless of level of effort for
vehicle speeds 6 mph and less [18].
              100 	;	
          u
          c
           Ol
          U Q.
          o
          o
               75
                30
25
                Based*on;
                M = M  +
MQ = 10.0 g/ft
M* = 0.5 g/ft
                                             - M
                                              2
                  012345
                  Number of passes (P)
         FIGURE 2-4.  Effect of Level of Effort on Col.lection
                      Efficiency of Broom Sweeper [8].

-------
     Sweeper collection efficiency is also related to particle size of the
street load.  Table 2-10 shows the efficiency of a broom sweeper for different
particle size ranges.  It is clear that the broom sweeper is ineffective in
removing those particles which are most likely to become airborne (<100y)
by passing vehicles.  In fact, the broom sweeper tends to fracture aggregated
fines causing slight increases in the concentration of smaller particles
after sweeping.  In addition, the sweeper tends to redistribute the remaining
dust over the surface of the street, making it more susceptible to atmospheric
reentrainment by passing vehicles.  While limited studies of the vacuum type
sweepers have been conducted, these controlled experiments demonstrate a
dramatic difference in the performance of the vacuum broom sweeper for col-
lecting smaller particles.  Table 2-11 shows the vacuum sweeper will collect
roughly twice the small size material of the broom sweeper (when the broom
effort is equivalent to about a 2 pass operation).  The vacuum sweepers
are most effective under dry conditions for loose dust.

        TABLE 2-10.  EFFICIENCY OF BROOM SWEEPER FOR VARIOUS
                     PARTICLE SIZES [8]
PARTICLE SIZE
- (P)
>2,000
840 - 2,000
246 - 840
104 - 246
43 - 104
<43
IN SITU TEST
78.8
66.4
69.5
47.7
< 0
< 0
EQUATION
--
—
49.2
48.7
22.2
15.8
COMPOSITE
(estimate)
79
66
60
48
20
15
                                    2-19

-------
                       TABLE  2-11.   COMPARISON  OF  REMOVAL EFFECTIVENESS FOR MOTORIZED SWEEPING AND
                                    VACCUMIZED  SWEEPING  [9].
ro
i
ro
o
MACHINE
TYPE
Motorized
Vacuumi zed
Motorized
Vacummized
RELATIVE
EFFORT
2.17
2.88
4.32
5.83
20 g/ft2
177-300vt
""(I)
92.5
95.0
94.5
98.5
100 g/ft2
74-177V
(%)
58.0
94.5
-
-
600 g/ft2
74-1 77v
(%)
46.0
89.5
62.6
91.4
                       NOTE:  Tests  conducted  on  asphaltic concrete.   Results are for 1 pass
                              in 2nd gear  and  1 pass  in  3rd gear.

                              g/ft2  = Initial  mass  level.

                              vi      = Particle size range  of simulant.,
                                                                (M   -  M)
                              %      = Removal  effectiveness =  _2	  x TOO
                                                                   Mo
                             Relative
                             Effort = effort  (time spent  by  sweeper covering a given area)
                                      relative  to  the  minimum level  of effort  attainable
                                      by  the  sweeping  equipment.  For the  tests above, unit
                                      relative  equipment  effort  corresponds to a forward
                                      speed of  1200  ft/min.   Therefore, relative effort =
                                      1200/forward speed  (ft/min.).

-------
     The city presently operates: Z3 motorized broom  sweepers on a full
time all day basis.   The sweepers generally perform  a  single pass during
cleaning-.  Major streets and collectors receivimr heavy traffic are
generally swept  by night, and low-use major collectors, and local streets
are cleaned by day.   The locarl streets, are swept/monthly,, most- collectors
every 2. weeks , the major streets every 7 days;..  Some of the^. Mglfc-use
streets aret cleatredr 3 tfmesr per* weetei :an&- & tfmftedr number are? sweplr
darty,  The* eostr of- this, pcegapanr is &V J^ BirVH-eifc per1 year ^
     The effect  of  street cleaning frequency on street  dust loadings
is illustrated hypothetical ly below (Figure 2-5).  The  loading intensity
increases: rapidly approaching an equilibrium level after- sweeping.  The
              atcet;.  eat . teypiiiea.'V, cirt^p. Sstrpgts. ha.v.p^-hppti. ^^d^Ptfe. r^trpftt.liT^
      furtdln§ b^tfeerEkv-iniuiiiaPbl^^^                   E^K  Tyg^eai-
Tatiorr rates after a  complete- cleaning are shown  in  Figure 2-6.
              0)
             -a.
              w
              o

     Figure 2-5".  Accumulation of Particulates (Shown with Periodic
                  Sweeping)
                                     2-21

-------
rv>
i
ro
ro
                 01
                 =3

                 O
                I/)
                I/)
                Q
O



O
LU


£
                O
                O
                       MOO
                       l?00
       1000
                        eoo  -
                                ELAPSED TIME SINCE LAST CLEANING BY SWEEPING  OR RAIN (days)
                         Figure 2-6.   Street Dust Loading Versus  Time Since Last Sweeping [8]

-------
     Figure 2-7 shows the effect of frequent sweeping with a broom sweeper
on a street with typical dust loading levels.   The diagrams of Figure 2-7
have been formulated by applying a collection  efficiency of 50% to the accum-
ulation schedule in Figure 2-6.  When broom sweepers are used, a 48% total
dust loading reduction would occur by shifting from a 10 day cleaning cycle
to a 3 day cycle.  In combination with a double pass of the broom sweeper,
the increased cleaning frequency would reduce  average total street dust
loadings still more.  Figure 2-8 shows the effect of frequent sweeping with
vacuum sweepers on a street with typical dust  loading levels.  These curves
are based on collection efficiency data shown  in Table 2-11 and reported in
reference [18], and the average street accumulation rates shown in Figure 2-6.
A 58% total loading reduction would occur by shifting from the current
sweeping cycle to a 3 day cleaning cycle.

     The information from Figures 2-7 and 2-8  are presented in summary form
in Figure 2-9 to permit extrapolation of total street dust loadings associated
with any given street sweeping schedule.

     The reduction in street dust loadings affects entrainment of dust by
motor vehicles according to the relation developed by MRI [20].

                  E = KLS
           Where  E = suspended dust per vehicle mile
                  K = an empirical proportionality factor
                  L = street dust loading
                  S = silt content of dust (percentage of particles  less
                      than 75y).

Emissions of street dust decrease with total street dust loading reductions
accomplished by street cleaning programs.  However, intensification of street
sweeping will probably raise the average silt content of the street dust.
Immediately after sweeping, the remaining dust is comprised of a higher per-
centage of fines as most of the heavier larger particules are removed during
sweeping.  Tables 2-10 and 2-11 show that the  broom sweeper is far less ef-
fective at collecting smaller particles than the vacuum sweeper.  For a
single pass of the broom sweeper, only 20% of the particles smaller than
100 micron were expected to be removed, and during field tests [8], it
                                     2-23

-------
a
<
o
   12CC-*-
   1000- •
    SCO- •
    SCO- •
(Sl


a   400
          BASELINE  AVERAGE  STREET  LOADING = 360 L3/MILE

                                  (SINGLE  PASS)    '    -
                                  AVERAGE = 720 LB/MILE I
                         (DOUBLE PASS)
                                                        I
    20°"  SINGLE OR  DOUBLE  PASS  OF  SWEEPER  AND CLEANING  IACH 10 DAYS
                H	h
                                                        10
                              DAYS
                   .AVERAGE STREET LOADING = W5 L3/MILE
    2CC"  SINGLE  PASS  OF  SWEEPER AND CLEANING EACH 3 DAYS
           H	1	1	1-
                                     I     I
                                                       10
                             DAYS
<
o
    •iCC- •
                 AVERAGE STREET LOADING = 34G L3/MILE
         :CL3LE PASS OF SWEEPER AND CLEANING EACH  3  DAYS
   GOO  .



   400



   200  -
AVERAGE DUST/LOADING - 305 LB/CURB-MILE
          SINGLE PASS OF SWEEPER AND CLEANING EACH DAY

         	M	1	1	1	1	1	1	1	1	K
                  4         C
                    DAYS
                                                          10
  Figure 2-7.     Effect of  Intensification of Broom Sweeping
                   on Street  Dust  Loadings
                              2-24

-------
    BASELINE  AVERAGE DUST LOADING
                  (BROOM  SWEEPER)
                       360 L3/MILE
300 +
500-
400-1-
200+/
         X
                                                            X
AVERAGE DUST LOADING  = 615 LB/MILE
(VACUUM SWEEPER)
V
              2.    '     4         6          8         T°
      3IMGLE PASS OF SWEEPER AND  CLEANING EVERY 10 DAYS
                          AVERAGE DUST  LOADING = 360 L3/MILE
             2          4          63
               VACUUM CLEANING EACH THREE DAYS  .
   600

   400

   200
 AVERAGE DUST LOADING = 160 LB/CURB MILE
    Figure 2-8.
         VACUUI CLEANING EACH DAY
   Effect of Intensification of Vacuum Sweeping
   on Street Dust  Loadings
                            2-25

-------
t\5
                £800..



               ^600..
                           H	1	1	1-
I      I	1     I	1-
                     B
           8
10
                                   DAYS BETWEEN EACH SWEEPING
                       Figure 2-9.  Effect  of Sweeping Frequency on Average Total  Street Dust Loadings

-------
was found that  a  street cleaning by the broom  sweeper actually increased
loading concentrations of the particles smaller  than 100 micron.  This caused
substantial shifts  in  the silt content of the  street dust, as shown in
Table 2-12.  The  higher silt values, increasing  in  some instances immediately
after sweeping  by factors of 2 to 6, partially cancel!, at least temporarily,
the dust control  benefits achieved by broom sweeping cleaning operations.
As accumulation of  new materials occurs, equilibrium between deposition
rates and traffic related removal rates is once  again achieved, returning
the silt levels within the range of 10 to 15%.   However, with frequent
sweeping, the average  silt levels of street dust may be significantly higher
than for normal street sweeping.  It is not possible, using available
data, to assess the effective silt value occurring  with more frequent
street sweeping.   Studies now underway by the  Environmental Protection
Agency should reveal more information on this  subject.
     TABLE  2-12.   COLLECTION EFFICIENCY OF  BROOM SWEEPER FOR VARIOUS
                   PARTICLE SIZES [8].
ATLANTA
rASTICLE
SIZE RANGE
(micron)
>2,COO
890-2.000
246-090
101-246
13-104
<«3
Total (S)
Overall Eff; (!) .
>104
<104
I silt*
1MMAL
LOADING
<9>
175
103
375
231
66
43
993

884
109
11
RESIDUAL
LOADING
(9)
76
14
56
29
136
187
438
50
175
323
67
INITIAL
LOADING

-------
     Increased levels of silt content resulting from frequent  broom sweeping
operations can be reduced substantially by employing vacuumized  sweepers.
Table 2-13 shows the effect of vacuum sweeping for various  particle size
ranges.  The data is based on claims of Ecolotec,  Inc.,  manufacturer of
commercial vacuum sweepers. For a street loading similar to that found in
Phoenix (768 Ib/mi)  the vacuum sweeper collects approximately  80% of the
particles smaller than 45y.  Therefore, the vacuum sweeper would have only
minor effects on the average silt level of road dust, while at the same
time this sweeper would reduce total street dust loadings substantially.
Consequently, the street dust loading reductions attained by a vacuum
sweeper program (Figure 2-9) will translate directly into emission reductions,
     TABLE 2-13.  EFFECT OF VACUUM SWEEPER OPERATIONS ON STREET DUST
                  LOADINGS [18].
          OPERATING  CONDITIONS
DEBRIS REMAINING
Vehicle Speed
MPH
3
3
3
3
3
3
3
3
3
1
1
1
6
6
Air Velocity
MPH -
115
115
115
134
134
134
186
186
186
134
147
171
147
171
Dirt Loading
#/mi .
768
1536
3072
768
1536
3072
768
1536
3072
3072
3072
3072
3072
3072
Overall
%
7.3
6.4
5.5
8.9
5.0
2.1
6.1
4.0
2.4
3.2
2.4
2.8
2.5
7.0
>841y
%
4.8
3.2
1.5
6.4
3.4
1.1
5.4
3.7
1.5
3.4
•!•
™
^
™.
44-840y
%
8.4
7.8,
7.1
10.0
5.5
2.4
6.1
3.8
2.7
2.9
-
-
-
_
<43y
%
21.8
16.7
19.2
24.8
16.7
9.2
20.0
12.1
8.6
4.6
-
!

- •!
                                    2-28

-------
     Caution should be exercised in applying the evaluation procedures
developed here for entrained street dust emissions control.  The avail-
able data base for existing street dust loadings and sweeper efficiencies
are very limited.  While an average dust loading and silt level  was as-
sumed based on limited field data, it is known there is substantial
variation from street to street.  The information for sweeper efficiency
is unclear, particularly with respect to the impact of the sweeper types
on the temporal and average distribution of the particle sizes.   As more
information becomes available, it may be possible to develop software to
compile emissions estimates for each link of the transportation  network,
using traffic volume tapes,street-specific dust load levels, and sweeper
efficiency values as inputs to the procedure.  However, a field  approach
would be preferable to the complex analytical procedure.  For example,
the control objective  would be specified in terms of an allowable dust
load target, and street sweeping would be adjusted by reasonable trials
to obtain the objective.  Field measurements would provide the basis for
determining the amount of actual sweeping required, rather than  uncertain
analytical estimates.

     The control effectiveness of various schedules of vacuum and broom
sweeping outlined above can be used only as a useful guideline in specifying
tentative and potential street cleaning requirements associated  with an
allowable street dust emission rate.

     The cost of street sweeping varies widely from city to city.  Because
the full scale street vacuum sweeper has been marketed for a limited time
in the United States (beginning in 1971), nearly all cost data available
pertain to the conventional broom sweeper.  The American City Survey [26,27]
showed sweeping costs varying from $2.18 to $8.42 per curb mile  sweep.
This cost range is due to differences in maintenance practices,  operators
pay, and accounting reporting practices.  The average cost of sweeping
streets in the city of Phoenix (using broom sweepers) is $4.80 per curb
mile [15].

     Street maintenance departments of various municipalities  [30,31,32]
are presently reserved about the potential utility of the vacuum sweepers.
                                    2-29

-------
It is generally agreed the vacuum sweeper is not capable of collecting
heavy loads (e.g., high piles of leaves or debri) or loads which  adhere
to the street surface (e.g., mud or sticky substances).   Added reluctance
to purchase the vacuum sweepers  stems  from the higher initial  cost of the
sweeper, and the general  viewpoint that it reflects new  state-of-art
development.  However, it is also widely acknowledged that the broom sweeper
has its drawbacks:  1) it is inefficient as a collector  of dust and small
particulates, and 2) it is characterized by high maintenance costs, exces-
sive downtime, and short lifetime.

     Few cities have experimented with the vacuum sweepers, but there is
indication from those that have  that it may provide satisfactory  performance
at overall costs roughly equivalent to that of the broom sweeper  [28].
The initial cost of a broom sweeper suitable for city street maintenance
is about $32,000 to $40,000 depending  on the manufacturer and type of
engine.  Because many cities find the  diesel engine more attractive economi-
cally, the capital cost is often close to $40,000.  Initial cost  of the
vacuum sweepers varies from about $49,000 - $58,000, depending on manu-
facturer and engine type.  Maintenance costs for the broom sweeper are
acknowledged to be higher.  In one study performed by the city of Columbus
(Ohio), the vacuum sweeper was reported to be operating  at an average cost
of $6.60 per cubic yard of collected material versus $26.00 per cubic yard
reported for the broom sweepers  [28].   Since the vacuum  sweeper is new on
the market, it is not possible to factor in equipment lifetime values to
compute annualized costs.  Manufacturer claims indicate  the vacuum sweeper
may be extended to a 7 to 10 year life [29,33], while experience  has shown
the broom sweepers are usually scrapped after a 5 to 6 year term.  Based on
these claims, the manufacturers  are promoting the vacuum sweep as the
least cost street cleaning method.

     While the available cost data are unclear in the comparison  of vacuum
versus broom sweep technology, there appears to be little doubt these alterna-
tives are competitive.  For the  purposes of this study,  the annualized cost
of these two street cleaning approaches was considered equivalent-
                                    2-30

-------
     Table 2-14 summarizes cost estimates and emission reductions for various
scenario street sweeping measures applied throughout the city of Phoenix.
City-wide costs are shown here for illustrative purposes only, while any
actual control program would probably focus on specific areas where en-
trainment of dust must be controlled to attain air quality objectives.
The cost of intensifying street cleaning operations in the city of Phoenix
(Table 2-14) have been estimated based on a review of the existing budget
and performance, and a projection of that base data for more intensified
operations.
2.3   CONTROL OF DUST EMISSIONS FROM CONSTRUCTION ACTIVITIES.

      Construction activities are temporary and variable in nature.  Fugitive
dust is emitted both during the activities (e.g., excavation, vehicle opera-
tion, equipment operations)  and as a result of wind erosion over the exposed
earth surfaces.  Earth moving activities comprise the major source of con-
struction fugitive dust emissions, but traffic and general  disturbance of
the soil also generate significant dust emissions.

      Emissions of dust from construction activities are already controlled
by the Maricopa County Bureau of Air Pollution Control Rules and Regulations.
Rule 31a states:

      ...."No building or its appurtenances, a utility or open area may
      be used, constructed, repaired, altered, or demolished without
      taking all reasonable precautions to prevent particulate matter
      from becoming windborne or airborne.  Dust and other types of
      particulates shall be kept to a minimum by such measures as
      wetting down, covering, landscaping, paving, treating or by other
      effective means."

Similarly rule 31B requires that reasonable precautions also be taken to pre-
vent particulate emissions during roadway construction activities.
                                   2-31

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                      TABLE  2-14.   COST  EFFECTIVENESS OF  VARIOUS  CITY-WIDE STREET SWEEPING PLANS
Control Measurement
Annual
Cost of Entire Motorized
Sweeping Program in  Mil-
1 ions of dollars
Reduction of Average
Street Dust .Loading
Expected
Reduction of
Dust Emissions
Expected
Cost Effectiveness
$/ton of dust em-
missions prevented
1.   Existing Motorized Sweeping
        Program                            .87

2.   Intensified Broom Sweeping

     a.  Sweep all  Majors  &  Collectors
            each 3  days                  2.6

     b.  Double pass with  Sweeper  on
                               48%
                                               79


ro
i
c*>
ro


c.
existing cycle
2 and 3 above
1.7
5.1
16%
60%
16%
45%
67
95
3. Vacuum Sweeper Program
a.
' b.

Sweeps on existing schedule
Sweep each 3 days

.87b
2.6

29% '
58%

29%
58%

Od
39

a  Based on budget for 1975  [15].  Cost estimates of more intensified sweeping measures above are expanded proportionally from  this
   base.

   Based on assumption that  annualized cost of vacuum sweeper is approximately equivalent to that of broom sweeper.   This is  pre-
   dicated on the tradeoff between higher initial cost of a vacuum sweeper  ($50,000) versus 40,000 for broom sweeper)  and lower
   annual  maintenance and longer lifetime of  vacuum  sweeper.


c  Dust emission reductions  for  broom sweeping have been estimated based  on assumption that silt content(percentage  of particles <75v)
   of street loading  reaches  equilibrium level within one day of sweeping.   The  silt level varies from 10% to a level 4-1/2 times  greater
   (based  on Table 2-12)  immediately after sweeping.   The equilibrium silt  value is taken as 10% [20].

   This measure does  not  incur additional costs because the vacuum sweepers can  replace broom sweepers on a phase out program at no charge
   Emissions  preventions are based on 322 tons of resuspended dust originating  in  the cities of the study area each day.   204
   tons/day are estimated  to originate off the streets of the city of  Phoenix.

-------
      While the construction regulations do not specify a definite amount
of control which must be applied, construction contractors are currently
employing water trucks and appear to be complying with the intent of the
rule [11, 16].    The rule was tested in court following a challenge by a
contractor, who had been cited in violation of the rule.  The court upheld
the rule, deciding that the contractor had not taken reasonable precautions
(i.e., wetting down soil) to prevent the dust from becoming airborne.
However, despite the support given by the court, the rule is enforced
rather loosely,  especially on construction sites removed from populated
areas.

     Wetting the surfaces of unpaved access routes for construction vehicles
and trucks is an effective control for dust emissions provided the surface
is maintained wet.  In the arrid Southwest this generally requires appreci-
able water.  A study on the effect of watering on construction sites [4],
indicates that extensive wetting of the soil may reduce dust emissions at
up to 60 to 70%.  However, this result was far from consistent, as the
watering control caused no apparent effect on several occasions, resulting
in an average efficiency of only 30%.  PEDCO [4] suggests that wetting of
access roads twice a day with an application of .5 gal of water per square
yard will suppress dust emissions by 50%.  Another study [25] has shown
emissions from unpaved roadways are reduced by 30% when the surface was
maintained moist.

     It is not clear what degree of compliance is presently being exercised
with respect to dust control on construction sites.  Baseline calculations
for emissions from construction sites were based on emission factors derived
from a study of a construction site in the Phoenix area where some degree of
dust control measures were being employed.  The effect of more extensive
wetting practices on baseline estimated dust emissions is entirely specula-
tive, although such a practice would surely incur significant additional
prevention of dust emissions off the construction site.  For the purpose of
this study, it was conservatively assumed that dust emissions would generally
be reduced by 30% with strict enforcement and awareness of the construction
dust regulations, including the added provision that watering be conducted
twice a day at a rate of 1/2 gal/sq.yd.

                                     2-33.

-------
     A negative tradeoff associated with  watering  controls  at construction
sites concerns the carry-out of mud onto  adjacent  streets.   The carried out
dust is susceptible to suspension by passing vehicles.   If  the construction
site is frequented by appreciable traffic and watering  controls are amply
employed, mud carryout will  be significant and should be controlled.

     Presently, rather minimal control  is provided by loose enforcement of
Rule 31D (this rule requires materials  deposited on public  roads be removed
by the responsible party).  One means of  removing  the dust  carryout from
construction activities is street sweeping.  Street sweepers may be employed
daily to clean those paved public roads where visible dust  has accumulated
due to construction activities.  To reduce cleanup costs, good housekeeping
measures (cleaning construction vehicles  before leaving site) may be
employed as a cost effective alternative  to street sweeping.  It is not
possible to generalize an effectiveness for these  actions.

     An additional dust source at construction sites consists of exposed
earth which is susceptible to wind erosion, and to dust emissions from in-
frequent traffic disturbance.  While the  suspended dust from this source is
generally significant, there are brief periods (i.e., during wind gusts or
traffic bursts) when the resulting dust levels may create a nuisance to
nearby inhabitants.  Dust emissions from  these sources  may  be reduced by
combining two approaches.  First, a soil  stabilizer, such as a chemical
palliative or vegetation cover may be applied.  A  second approach would
involve a stipulation that cleared earth  be exposed for a limited period
before subsequent operations on this land begin.  This  would prevent the
frequent practice of clearance of vast plots of land where  subsequent
construction operations are not scheduled to begin for  several months.  Such
clearance may be allowed only if accompanied by soil stabilization measures
within two months of the clearning.  The  effectiveness  of these measures
in reducing dust emissions is unknown.

     The cost of the alternative dust control measures  for  construction site
dust emission is shown in Table 2-15.
                                     2-34

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                     TABLE 2-15.  COST OF ALTERNATIVE DUST CONTROL MEASURES FOR CONSTRUCTION EMISSIONS
            DESCRIPTION OF MEASURE
                                                   CONTROL EFFICIENCY
                                 COST
r\>
i
Co
en
Wetting of site access roads twice/day
at .5 gal/yd2, and strict enforcement
by Building Department and County Health
Department

Daily (if necessary) cleanup of public roads
to remove visible dust or mud deposits resulting
from construction activities.

Stabilization of all exposed earth on the
construction site wherever operations cease
on that land for more than 2 months.
                                                                    30%
                                                                  Unknown
Unknown
                                                                                                        a.
                               $6/acrea'/day
                               $25/sweeping/
                               siteb-
$200-300/acre(
         Based on 3 hours labor and equipment cost.  Unlimited water is provided from irrigation canals to
         contracting for a single annual  permit cost.


         Based on typical sweeping service rates ($25/hour) [34], and assumed sweeping effort of one hour.
         Sweeping requirements will vary  substantially depending on the magnitude and nature of construction
         activities.  Good housekeeping practices can keep sweeping requirments to minimum.
         Based on cost of Dust Control  Oil  application as reported by State [13] and supplier [14].

-------
3.0  FORMULATION OF REASONABLE CONTROL STRATEGY  ,
     This chapter discusses the selection and evaluation of a reasonable
control strategy for reducing suspended particulate levels in the Phoenix
area.  Since the objective of the strategy is attainment of primary air
quality standards for TSP, the strategy selection necessarily involves
an iterative process where the impact of trial strategies are evaluat-
ed successively until the desired result is obtained.

     Section 3.1 describes general factors affecting the selection of
reasonable control measures.  Based on the general characterization of
alternative controls described in Section 2.0, and the general considera-
tions of Section 3.1, specific reasonable measures are selected to formu-
late an overall strategy (section 3.2).  For each selected measure, the
reduction in emissions of fugitive dust is estimated (Section 3.3) and
the air quality impacts of these reductions are calculated (Section 3.4)
using the source-receptor model developed earlier in the study [17].
The cost and implementation problems associated with the strategy are
also evaluated  (Section 3.5 and 3.6).

     A special  feature of the control strategy includes a demonstration
model to promote social acceptance for the main strategy.  This concept
is appropriate because of the significant funding required for implementa-
tion of the strategy, and the probable social resistance to be encountered,
Section 3.7 describes the features of this demonstration strategy.

3.1  FACTORS AFFECTING SELECTION OF REASONABLE CONTROL MEASURES

     Reasonable control measures are defined as those which are techni-
cally and economically feasible to implement, and attain significant
benefits in air quality.  The technological and economic feasibility
of various controls will differ depending on several  factors indiginous
to the study area.  General factors affecting the reasonableness  of a
control measure in Phoenix include:

     •   The compatibility of the controls with general plans
         of the area
     •   The time-table for implementation
     •   The degree of control required
                                   .3-1

-------
     •   The financing mechanisms  available  for  implementation

     The extent to which proposed  control measures  are  compatible .with
planned development affects  the  cost  and  technological  feasibility  of
the measure.   For example, the paving of roads for dust control is en-
tirely compatible with  long term city development objectives to improve
the transportation network.  Similarly, the improvement of road shoulders
to reduce street dust loadings and .reentrainment of this dust to the
ambient air is completely consistent with city objectives to improve
the quality of life in  the city.  This compatibility lends to greater
general technical and economic feasibility for the dust control measures
because of the other desirable benefits they provide.

     A significant degree of fugitive dust control will occur in the
next several years due  to normal development and improvement patterns.
Table 3-1 shows the expected improvement in air quality due to antici-
pated development in the Phoenix study area.  This development will
change the distribution of emission sources, eliminate local sources near
the monitors,  and diminish the magnitude of  many sources.  Although
total dust emissions from unpaved roads are expected to increase slightly
from 1975 to 1985, the  distribution of these emissions changes sub-
stantially, such that they are more widely spread in the rural areas,
and greatly reduced in  the city area.  By 1985, wind erosion emissions
are estimated  to decrease greatly from 1975 baseyear estimates due to a
decrease in wind erosion sources (i.e., vacant property), and the probable
occurance of typical meteorology (based on historical  averages in 1985.
Contributions  to TSP from entrainment of street dust are expected to in-
crease slightly by 1985, especially at monitors located within the city
areas.  As a result of  the net changes in emission source magnitudes and  (
distribution, TSP levels will decrease significantly at 11 of the 13
monitoring sites under  consideration (Table 3-1).
     Another consideration in the determination of reasonable measures
involves the degree of  control which is sought.  The ultimate goal  of
the reasonable control  strategy would be achievement of the primary
air quality standards.  Generally, the annual mean for TSP provides the
most appropriate target for air quality attainment.  Table 3-2 summarizes
the extent to which air quality standards were violated in the Phoenix
                                   3-2

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TABLE 3-1.   IMPROVEMENT IN TSP LEVELS DUE TO ANTICIPATED DEVELOPMENT IN THE PHOENIX AREA
MONITOR SITE
C. Phoenix
S. Phoenix
Arizona St.
Glendale
N. Phoenix
N. Scott/Paradise
Scottsdale
Mesa
Downtown
St. Johns
Sun City
Paradise Valley
Chandler
TSP, pg/m3
Observed Forecast
1975 1980
112
144
169
101
121
149
115
117
200
145
88
184
119
104
139
157
84
111
111
105
114
186
151
81
152
139
Forecast
1985
87
101
132
65
83
101.
93
95
155
157
74
93
160
Percentage
Reduction in
TSP
1975 to 1985
22.3
29.8
21.9
35.6
30.4
32.2
19.1
18.8
22.5
-8.3
15.9
49.4
-34.5
Contribution to TSP, yg/m
Unpaved Roads Resuspension Construction
1975 ' 1985 1975 1985 1975 1985
25
75
35
30
26
24
27
32
42
93
15
42
64
8
32
12
9
8
32
10
13
15
116
6
14
91
31
20
59
17
' 28
8
33
35
70
2
12
14
"10
37
2fl.
68
20
32
9
42
45
82
0
17
17
12
4
2
7
7
7
14
6 .
8
8
2
3
17
7
5
9
9
2
7.
25
5
4
10

16
25
23
Percentage of TSP Contributed
by 3 major souKces and back-
ground (30ug/m )
1975 1985
80
88
78
83
75
51
83
90
75
66
68
56
93
92
94
90
94
93
9b
94
97
89
96
93
93
97

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     TABLE  3-2.  SUMMARY OF 1973-1975 AIR QUALITY VIOLATIONS  FOR
                  TSP  IN PHOENIX  AREA
Stations
Reporting
Central Phoenix
South Phoenix
Arizona State
Glendale
North Phoenix
N Scot/Paradise
Scottsdale
Mesa
Downtown
St. Johns
Sun City
Paradise Val ley
Chandler
Carefree
TSP Concentration ug/m
Annual
139
170
156
97
127
143
110
124
199
145
84
191
136
41
Expected Second
Highest 24-Hra
370
320
390
220
340
450
225
250
450
63,0
200
480
320
135
Percentage Emission Reductions
to meet primary Standards'3 based
on .linear rollback
Annual
58.7
67.8
64.1
32,8
53.6
60.1
43.7
52.1
73.3
60.8
16.6
72.0
57.5

24-Hour
32.3
20.6
36.1
--
25.8
45.2 •
'
—
45.2
61.6
--
48.8
20.6
"
aBased on statistically computed expected concentrations (from distributions
 derived  from historical data [23] assuming 60 measurements per year).

\                                *3
 Annual primary standard = 75 pg/m
 24-Hour  primary standard = 260 u
                                     3-4

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area in 1975.  Except for days of dust storms, the severity of 24 hour viola
tions were generally of lesser degree than those for the annual measurements.
Table 3-2 also shows that substantial improvements in ambient air quality
are needed before the standards may be met.   The higher the level of
control which is needed for attainment, the  greater are the technical
and economic demands associated with the attaining control  strategy.
     Another important consideration in determining what is reasonable
strategy involves the time schedule of implementation.  Typically,
strategies of previous air quality programs  have been predicted on meet-
ing objectives within a short term.  This requirement has often imposed
implementation problems which cannot be reasonably resolved.  First, the
technological problems associated with the vast resources (i.e., labor
and materials) often required for rapid implementation of a regionwide
control are generally insurmountable;  second, the economic hard-
ships inherent in short term financing and the increased cost associated
with intensified program development pose important economic problems  for
the short term strategy.  A reasonable strategy must, therefore, permit
execution of control measures over an extended period commensurate with
the technological and economic limitations characteristic of the study
area.
     The economic feasibility of any control alternative is greatly
affected by the extent and manner of funding available.   Budgets re-
quired for implementation of different controls should be compared and
expressed in terms of monetary impact on a per capita or consumer basis.
The source and ease of funding should be identified and evaluated.  Some
controls (such as street sweeping, road surfacing) will be funded by
taxes or other governmental money-raising mechanisms, while others
will be paid by commercial enterprises and then passed onto the private
consumer.  Either method of financing is reasonable, provided the re-
quired resources are available and judged to be within the reasonable
range of cost incurred by other existing and pollution controls of
similar effect.
     Generally, public acceptance of reasonable available controls is  impor-
tant for implementation.  It is clear that the lack of social acceptance
will impose significant obstacles to the implementation of a reasonable

                                   3-5

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control, and specific measures will  be necessary to overcome these obstacles.
A demonstration project may be used  to generate public support when necessary.
The elements of the demonstration project, and its implications for resolving
implementation difficulties, are considered in Section 3.7.

     There are no absolute guidelines for the selection of reasonable
available control technology.  A measure which is reasonable in one
area may be unreasonable in another.  However,  in general,  most of the
measures available for control of fugitive dust are reasonable.  Selection,
therefore, should be based on the most cost effective measures which will
provide air quality improvements needed for standards attainment.  For
example, it may be necessary to pave all roads to bring about attainment,
with any lesser.measure being inadequate for attainment.  Hence, while
other-measures may be more technically and economically feasible (i.e.,
more reasonable), they would not be selected when another reasonable al-
ternative capable of attaining the needed emission reductions is avail-
able.

     Once a list of reasonable candidate measures have been identified,
selection of a control strategy is an iterative process accomplished by
means of successive tests of alternatives using the source receptor model
[17] to predict resulting air quality levels.  As various trial alter-
native strategies are tested, it becomes clear which areas in the study
region may need special attention and which areas will require only
minimal controls.  The emissions density grid map (Figure 3-3)  may be
used as an aid in identifying specific problem areas and in formulating
preliminary control strategies for test by the source receptor model.
Eventually, through a series of iterative trial judgements,  a strategy
should be established which attains the air quality objective at each
of the monitor sites utilizing the most cost effective combination of
reasonable control measures  available.
                                     3-6

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3.2  SELECTION OF RESONABLE STRATEGY
     Based on consideration of the selection factors discussed above
(Section 3.1) and the control characterization presented previously
(Section 2.0), trial strategies are formulated and evaluated in an
iterative approach to attain the air quality objectives.  Table 3-3
presents the final reasonable control  strategy selected to meet the
objectives.
     The measures comprising the strategy reflect the most cost effective
measures, are compatible with the long term planning goals for the
region, and are also effective as substantial  dust controls.  The strategy
is reasonable in that it is implementable in a technical and economic
sense, and accomplishes significant improvements in air quality.  How-
ever, substantial social resistance is likely to develop against its
execution.  A special feature of the overall strategy is a demonstration
project to develop social acceptance for the areawide strategy approach.
This portion of the strategy is discussed in Section 3.7.
      The reasonable control strategy is selective for the three major
sources affecting air quality.  Table 3-2 illustrates the relative
effect of these three sources on anticipated baseline TSP levels and
demonstrates clearly the justification for focusing attention to these
sources.  In 1975, unpaved roads contributed the greatest portion of
TSP levels at most of the monitor sites.  By 1985, after anticipated
development,  TSP levels at the monitors are affected mostly by en-
trained dust off streets.  Unpaved road emissions are still a dominant
contribution of TSP levels at sites in or near rural environments
(e.g., St. Johns, South Phoenix, North Scottsdale/Paradise, and
Chandler).
      It is important to distinguish between the controls needed to
attain the standard throughout the region and that needed to attain the
standards only at the monitoring stations.  Because of the very localized
impact of fugitive dust sources, it is possible to attain localized attain-
ment by application of controls in limited areas,  (i.e., around

                                  " 3-7

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          TABLE 3-3.   REASONABLE CONTROL  STRATEGY  FOR PHOENIX  AREA*
SOURCE CATEGORY
                                            PROPOSED CONTROL MEASURES
1.   Unpaved Roads
    Entrained Dust off
    Paved City Streets
3.
Construction
Activities
4.  Other Sources
County  Roads

•  Chip seal all section line roads with emulsified asphalt
   by 1995, and one half of section line roads by 1985.   Sequence
   of road selection should be based on ADT volume.

•  Reduce  speed limit to 20 mph  for all  unpaved  roads
   gradually by 1985, or,  where  applicable,  permit  improve-
   ment districts  to implement equivalent dust control by
   surface treatments such as  graveling,  oiling,  or paving.
   Restriction sequence should be  based on  availability of
   alternative pave'd routes and  trip lengths.

Private Roads

•  By 1985, restrict speed to  20 mph or require  equivalent
   dust emissions  reductions by  surface treatments   such
   as o'ling,  watering, graveling,  or paving.

City Streets

t  By 1980, establish a field  measurement program to deter-
   mine street dust'loads  and  effects of various  street
   sweeping alternatives (using  broom sweepers and  vacuum
   sweepers) on street dust loads.

•  Based on results of field program, formulate  sweeping
   requirements and implement  by 1985 a program  to  attain
   a 60% reduction in the  current  assumed average street
   dust loading of 780 pound per mile [8] in the  designat-
   ed areas (Figure 3-1).

•  Effective wetting of site  access roads  twice  daily
   at .5 gal/yd .

•  By 1980, sweep  roads to remove  visible dust loads caused
   by construction activities.  Sweeping  shall be performed
   whenever dust loads are apparent, to maximum  frequency
   of once daily.

•  By 1980, require stabilization  of all  exposed  earth at
   construction site whenever  operations  cease on that land
   for over 2  months.

•  No additional measures  are  recommended for other sources.
   These sources are already controlled (either  by  direct
   pollution regulations or by other restrictions which af-
   fect dust control) or have  minor impact  on TSP levels.
 *  A  demonstration project is recommended as a prerequisite to
   implementation of.the overall control strategy.  This project
  'would  involve application of the strategy measures within a
   limited  selected area.  The project should be conducted prior
   to the deadline date for submittal of State Implementation
   Plans  -For  fugitive dust control in July, 1978.
                                           3-8

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monitor sites).  This approach should not be used to circumvent the
widespread TSP problem in the Phoenix area.  It is evident that TSP at
other locations may be equivalent or higher than that represented by
the monitor network.  However, an accurate prediction of the non-attain-
ment problem at these sites is unavailable.  Under the circumstances,
a plausible policy for control strategy formulation was taken as:
1)  apply an area-wide plan whichiattains standards at the monitors and
improves air quality elsewhere, and  2)  identify the various locations
where additional controls may be necessary, but cannot be justified un-
til air monitoring data are available to confirm high TSP levels there.
The latter task may be accomplished by inspection of the 1985 projected
emissions grid maps,  (see Section 3.3).
      Implementation of the overall strategy (Table 3-3) is proposed
after the demonstration project is completed.  The main element of the
overall strategy consists of an intensive road surfacing program in the
county for the next 20 years.  Road surfacing is to be conducted by
applying a chip seal to the section line roads.  This approach represents
the most cost effective of the alternative road surfacing measures (Table
2-5), and attains maximum source control where applied.  Priorities for
the paving program would be assigned in the order of those section roads
receiving greatest traffic volume, and the county of Maricopa Depart-
ment of Transportation would administer the program.
      In addition to the road surfacing measure, a control is also
proposed for existing or future unpaved roads.  A speed restriction for
unpaved roads is especially cost effective, and is considered reasonable
when phased in concurrently with the road surfacing measure.  Exceptions
to  the speed  limit would be permitted  in instances where '.accessibility
to alternative paved routes is unavailable (e.g., roads connecting
remote residence sites to county arterials).  Also, other techniques
of dust control (e.g., watering, graveling, oiling) would be permitted
in place of the speed restriction wherever private groups desire to
assume responsibility for improvements.
                                   3-9

-------
      The overall  strategy includes an intensive  street  cleaning  program
in designated areas where reduction of entrained  street  dust  emissions
is necessary to attain the air quality standards.   Figure  3-1  shows  the
two areas which receive attention under this  plan:   the  area  surrounding
downtown Phoenix and the area around downtown Scottsdale.   It is  proposed
major streets be swept more frequently, alternating from vacuum sweeping
to broom sweeping to attain an overall reduction  of 70%  in sus-
pendable street dust loadings.  The broom sweeper would  be used to dis-
lodge material adhering to the road and for collection of  larger  particles,
while the vacuum sweeper would be employed for the  efficient  and  cost
effective collection of dust particles of all sizes.  The  analysis of
Section 2.0 indicates that adjustment of typical  existing  street  sweep-
ing programs to obtain a 60% reduction in street  dust loadings is probably
feasible.
      Because of the limited data ba-se available  to characterize  street
dust loadings and sweeping efficiencies, it is not  possible to specify
a definite street sweeping program to accomplish  the targeted emission
reductions.  A field measurement program is proposed to  establish baseline
loadings for various streets and to determine by  test the  actual  sweeping
programs needed to obtain the required dust levels.  Based on the crude
data of baseline average dust loadings and street sweeping efficiencies
available (Section 2.0), it appears that an adjustment from the existing
sweeping frequency (once per week for most major  streets)  to  3 times
per week will produce the targeted emission reductions.
      The final element comprising the control strategy  entails enforce-
ment of more rigorous regulations for construction  activities.  The
measures are relatively cost effective in terms of  total emissions re-
ductions, and produce significant benefits in air quality  for those  areas
affected by construction emissions.  The regulations would require:
1)  sweeping of nearby roads to remove visible dust loads  caused  by
construction activities (e.g., vehicle carryout from the construction
site), 2)  wetting of site access roads (when used) twice  daily,  and
3)  stabilization measures for land exposed without construction  activity

                                   3-10

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                                                               PHOENIX
                                                              AND VICINITY
Figure 3-1.  Area Map showing Special Areas  (Downtown  Phoenix and Scottsdale)
             Designated for Intensified Street Sweeping  Programs
                                   3-11

-------
for more than two months.   These measures  would  be  incorporated as
regulations of the building codes and enforced by the local  Building
and Safety Department.
      Evaluation of the emissions reductions  and air  quality resulting
from the strategy is discussed in Section  3.3 and 3.4.   From this  analysis
nine potential nonattainment areas are identified (see Figure 3-10).  There
is a distinct likelihood that some of these areas may require special con-
trols (e.g., street sweeping in urban areas). To establish  the extent
of the TSP problem in these areas, and to  simulate  future air quality
levels there,  it is recommended that the  current monitoring network be
expanded to include representation of air  quality in  the potential non-
attaining areas.  The additional monitor sites could  be included as
part of the control strategy implementation,  however, it would be  pre-
ferable that the.new monitors be installed prior to state submittal of
fugitive dust implementation plans (July,  1978)  so  that any  additional
area-specific control measures which might be required'may be efficiently
integrated  into the overall control plan.
      The strategy proposed in Table 3-3 has  resulted from a series of
trials of different control alternatives applied in varying  degrees.
Road improvements have been emphasized in  the overall plan because of
compatibility of this control with the general planning objectives of
local agencies, because of the substantial impact of  unpaved roads on
air quality, and because dust control off unpaved roads is generally
more cost effective than other measures.  By accelerating this street
improvement program (a program which would eventually be implemented
on a slower timetable), the  intensive  street  sweeping measure  is needed only  in
isolated areas.  Minimizing additional street cleaning requirements is
appropriate considering the low priority of this function relative to
other programs now receiving  competing attention for the city of  Phoenix
Department of Transportation budget, and the  high cost of this measure
as a dust control.  Curbing for unpaved road  shoulders is an effective
measure  for reducing street dust  loads, but  was not  included  in the
final control strategy because most streets in the  designated vicinities
requiring attention are located in downtown areas,  and are either  presently
                                   3-12

-------
curbed or will be curbed after planned improvements are carried out through
the year 1985.  Dust controls for construction activities are not responsible
for major long-term gains in air quality but are included to alleviate tempo-
rary and localized high levels of TSP surrounding the construction sites.

3.3  IMPACT OF STRATEGY ON EMISSIONS LEVELS

     The effect of the proposed strategy on total emissions levels for the
entire study area is shown in Table 3-4.  The source most affected by the
control strategy is unpaved roads.  Dust emissions from unpaved roads are
reduced by about 36% from the anticipated levels in 1985, and 22% from the
baseyear (1975) levels.  The  reduction in this single category amounts to
about 22% of the total 1985 baseline emissions total, and the impact of
this reduction on air quality is expected to be substantial because of the
local concentration of this source near many of the air quality monitors.
Similarly, control of entrained dust emissions off paved roads in the down-
town Phoenix area and Scottsdale will incur emissions reductions in areas
near monitor sites in these locations.  However, total entrained dust emissions
in the study area are expected to be reduced only 5.6% from 1985 baseyear
emission forecasts.  Construction emissions will be reduced by 30% of the
1985 baseyear construction emissions totals, however, this reduction amounts
to only 3% of the total baseline emissions forecast in 1985.  Hence, con-
struction dust controls are expected, to alleviate localized short term TSP
levels, but exert only minor effect on monitor annual TSP levels.  Due to
planned development in the study area, remaining fugitive dust sources not
addressed by the strategy are reduced below 1975 levels by a greater degree than
those major source categories which are the object of the control strategy.
Overall, the total change in emission levels, due both to the control strategy
and to anticipated development in the study area, amounts to a reduction of 23%
from the 1975 to 1985 forecasted level.

     Equally important as the emission level reduction magnitudes are the
distribution of these reductions.  Figure  3-2 presents the level and spatial
distribution of emissions before and after strategy application.  It is clear
that with strategy, emissions are reduced substantially in the area near the
monitor sites, that is, primarily in and bordering the metropolitan Phoenix
                                   3-13

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                                    TABLE 3-4.   IMPACT OF CONTROL STRATEGY
                                                 ON TOTAL EMISSION LEVELS
Source Category
Unpaved Roads
Entrained Street Dust
Construction Activities
Wind Erosion-Undisturbed Desert
Off-Road Vehicles
Other Categories
Total Emissions

Baseyear
Emissions
(1975)
1281
246
100
294
71
366
2360

Baseline Pro-
jected Emissions
(1985)
1553
322
256
85
106
139
2462
TOTAL EMISSIONS IN STUDY
Emissions After Ap-
plication of Control
Strategy - 1985
999
304
179
85
106
. 139
1812
AREA, TONS/DAY
Percentage Reduction
from Baseyear (1975)
in 1985
22.0
22.6
-79.0
71;0
.-49.3
62.1
23.2

Percentage Reduction
from 1985 Baseline
35.7
5.6
30.0
0.0
0.0
0.0
26.4
GO
I

-------
                                                        BASELINE 1985
                                                AFTER STRATEGY,  1985
Tigure 3-2.  Total Partlculate Emissions For Phoenix Study Area 1n 1985.
             With and Without Control Strategy.

-------
GRID
CODE

 0
 1
 2
 3
 4
 5
 6
 7
 8
 9
EMISSIONS
TONS/DAY

0
0 to .01
.01 to .04
.04 to .13
.13 to .32
.32 to .67
.67 to 1.2
1.2 to 2.1
2.1 to 3.4
3.4 to 5.2
Figure 3-3.   Total  Particulate Emissions  in 1985
               After Application of  Control  Strategy.
                                  3-16

-------
GRID
CODE

 0
 1
 2
 3
 4
 5
 6
 7
EMISSIONS
TONS/DAY

0
0 to .01
.01 to .04
.04 to .13
.13 to .32
.32 to .67
.67 to 1.2
1.2 to 2.1
2.1 to 3.4
3.4 to 5.2
Figure 3-3.
(continued)
Particulate
 Baseline Total
Emissions in  1985.
                                        3-17

-------
region.  The location of these reductions  are consistent with the intent
of the control measures comprising the strategy.   Entrainment of street dust
is prevented by control programs within the designated cities, and roads are
paved by priority of vehicle count along section  lines closely surrounding
the metropolitan area.   Figure 3-3 provides a more detailed illustration of
the distribution of emission densities in  the study area:  emission levels for
each of the grid squares of the study area network are given for both the
baseline and strategy forecasts.  Because  the major portion of ambient TSP
levels are caused by the local sources in  the immediate vicinity of the
receptor, the emissions grid map of Figure 3-3 serves  as a general representa-
tion of the TSP distributions as well.  However,  caution should be employed in
this representation, since local effects within a grid square may also cause
unsuspected levels of TSP to occur when the receptor is near or in the plume
of a nearby source.  For example, sources  at St.  Johns may be very area-
specific with respect to TSP values measured there because of the concentration
of fugitive dust sources near the monitor.  The grid emissions map of Figure
3-3 would not indicate this potential local effect, and assigns, instead a
lower emissions density based on the distribution of the "hot spot" sources
over the entire grid square.

     The impact of the strategy on each of the major source categories and
the basis for these estimates is discussed in the following sections.

3.3.1  Unpaved Roads

     The selected control strategy for unpaved roads is consistent with the
County's long-range planning objectives.  Under the County's planned develop-
ment, the number of unpaved interior streets will decrease steadily as road
improvements are accomplished according to County priorities.  Priority for
paving of roads is presently determined mainly by ADT.  Table 3-5 shows the
projected ADT for various road types in the study area for 1985.  By 1985,
baseline traffic volumes of unpaved roads  is expected to increase by 50%.
At the same time, the total mileage of unpaved gravel  roads is expected to
decrease by 21% (Table 3-6).  Gravel roads are the principal target for
present planned improvements, since they receive the heaviest traffic activity.
Most of these roads are section line streets (1 mile apart) which serve as
                                   3-18

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TABLE 3-5.  TRAFFIC  ACTIVITY AND STATUS OF UNPAVED  ROADS IN STUDY
            AREA,  1975  AND 1985

Dirt Roads (Maintained)
Dirt Roads (Not Maintained)
Gravel Roads
AVERAGE DAILY TRAFFIC
Rural
1975 1985
40 60
11 16
60 90
Urban
1975 1985
75 112
15 22
100 150
     1.  Figures are based on data presented in Support Document #2.
TABLE 3-6.  UNPAVED  ROADS MILEAGES IN STUDY AREA,  1975 AND 1985

Portion of Maricopa
County
Cities in Maricopa
Portion of Pinal
County
TOTAL
1975
Gravel
720
71
163
954
Dirt-
Maintained
1100
106
307
1513
Dirt-Not
Maintained
570

598
1168
1985
Gravel
579
10
163
752
Dirt-
Maintained
886
15
307
1208
Dirt-Not
Maintained
453

598
1051
                                  3-19

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major traffic links throughout the country.   The  net results of the planned
improvements and the expected traffic volume increases  is  an overall increase
in unpaved road emissions from 1281  tons/day in 1975 to 1553 tons/day in
1985 (Table 3-4).
     With implementation of the proposed Control  Strategy, dust emissions
from unpaved roads are reduced substantially.  Due to road, surfacing of
one-half the unpaved section line roads, previously anticipated 1985 emissions
arising from one-half the unpaved gravel roads in Maricopa County are es-
sentially eliminated.  The road surfacing measure alone may account for a
reduction of nearly 50% of the estimated baseline emissions in this source
category, depending on the absorption of traffic  from the  remaining unpaved
roads to the newly improved alternates.  Transportation of traffic to newly
paved streets will be further hastened by the traffic speed control measure
of the unpaved roads strategy.  Vehicle speed on  unpaved roads will be
restricted to 20 mph, causing an estimated dust emissions  reduction of
approximately 40% (assuming vehicles will actually travel  at 25 mph) for
those vehicles still using these roads.  A significant portion of traffic
would be expected to switch to the newly paved roads.

     In order to predict the reduction in VMT unpaved county roads as a
result of paving the gravel section line roads, a representative one-mile
rural section of the traffic line network was constructed, and net travel
in the link was considered for the "before and after" road paving control.
The representative .section was constructed using  a street map.  The map
showed that roughly 65% of the section line roads in Maricopa County are
presently paved.  Travel on unpaved and paved lengths within the section to
alternative exit  points on the section boundary was estimated by assigning
a  through  trip  to  the vehicle  population expected  to reside  in  the  section.
the analysis showed that the paving control would reduce expected traffic on
remaining interior unpaved roads by 15% in 1985.

     Because the strategy includes the paving of all roads within the cities,
dust emissions from unpaved city roads are essentially eliminated.  For most
cities, this involves a modest street improvement program.  For the City
of Phoenix, no additional strategy is required since the present 10-year
program includes improvement of all existing unpaved streets.  (New unpaved
roads are not anticipated due to a county ordinance which requires paving
of all newly developed roads.)

-------
     The expected emissions reductions associated with the control  measures
are applied to the computerized baseline inventory on a grid square basis to
determine the emissions levels after controls are applied.  The computerized
inventory maintains a record of urban and rural  road types, mileages, and
dirt road silt values for each grid square of the study network.  Table
3-4 summarizes the effect of the dust control strategies on total  unpaved
road emissions for the study area.   Over the 10-year period from 1975 to
1985, total dust emissions from unpaved roads would diminish 22% from 1281
tons/day in 1975 to  999 -jn 1985.  The distribution of emissions,  both for
the baseline case and with strategy applied, is  shown in the graphics
plots and emission grid maps of Figures 3-4 and  3-5.  It is clear that emis-
sions from unpaved roads diminish appreciable from 1985 baseline levels in
the vicinity of .nearly  all the monitor sites.

3.3.2  Entrainment of Dust Off Paved Roads

     The selected dust control strategy for entrained street dust on city
roads is consistent with city planning goals to  maintain clean streets.  An
effective street cleaning program is needed to maintain acceptable aesthetic
standards, to reduce pollution to sewer waters and treatment requirements
at sewage plants, and to maintain the condition  of road surface.  Dust con-
trol is an additional benefit to be gained by road cleaning programs, and
generally requires more effort than normally expended in typical street
cleaning operations.  Accordingly,  the proposed  control strategy for street
dust consists of an intensification of the city  street cleaning progams in
two designated areas where entrained street dust must be controlled for
attainment of the standards.

     The dust control benefits that can be achieved with various street
sweeping operations was discussed in Section 2.2.  It was determined that
either broom sweepers or vacuum sweepers may be  employed to reduce total
street dust loadings significantly when the level of street cleaning
effort is increased greatly over the normal amount.  However, it was also
determined that broom sweepers were far less efficient than vacuum sweepers,
especially for removal of smaller particles in the suspendable size range.
In fact, broom sweepers tend not to remove the smaller particles,  but to
                                     3-21

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                                                       BASELINE,  1985
                                                   AFTER STRATEGY,  1985
Figure 3-4.   Total  Particulate  Emissions From Unpaved Roads, With and
             Without Strategy,  1985
                               3-22

-------
GRID
CODE

 0
 1
 2
 3
 4
 5
 6
 7
 8
 9
EMISSIONS
TONS/DAY

0 to 0
0 to 005
0 to .02
.02 to .07
.07 to .18
.18 to .37
.37 to .68
.68 to 1.2
1.2 to 1.9
1.9 to 2.8
Figure 3-5.   Total  Particulate Emissions  from Unpaved Roads
               in 1985 After  Application.of Control  Strategy.
                                           3-23

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GRID
CODE

 G
 1
 2
 3
 4
 5
 6
• 7
 8
 9
EMISSIONS
TONS/DAY

0 to 0
0 to 005
0 to .02
.02 to .07
.07 to .18
.18 to .37
.37 to .68
.68 to 1.2
1.2 to 1.9
1.9 to 2.8
Figure 3-5.  (continued)   Total  Particulate Emissions
              From  Unpaved Roads, Baseline  1985.
                                          3-24

-------
redistribute them instead.   Consequently,  the different  effect of each  of
the sweeper types on dust emission rates  off paved  roads is  appreciable
(see Table 2-12).

     While the vacuum sweeper attains  higher collection  efficiency for
loose dust loadings under dry conditions,  it is not as effective as the
broom sweeper for collection of heavy, wet loadings which typically occur
after rainstorms.  In addition, rainstorms  tend to distribute dust loadings
across the entire street surface (as opposed to the usual high density  of
dust found only near the curb), making the broom sweeper, with its wide sweep
span, a very appropriate dust collection  mechanism  under these conditions.
The City Maintenance Department has suggested that  optimal street cleaning
equipment might consist of a battery of both vacuum sweepers and broom
sweepers, to be used alternately depending on street loading conditions [11].
Because rains occur infrequently in the Phoenix area, it is  feasible that
the future expanded sweeper squadron should be comprised predominantly  of
vacuum sweeper types.  As one feasible street cleaning scenario, broom
sweepers would be employed at the  same frequency as in the baseyear, while
vacuum sweepers would be used for  street  cleaning twice  in the interim
period.  Based on Figure 2-9 and data presented in  Section 2.2, this
alternating sequence between broom sweepers and vacuum sweepers would attain
at least a 60% reduction in entrained street dust emissions  off city
streets.  This sweeping scenario is suggested as a  tentative estimate of
the sweeping program which may be  applied  to the designated  areas (Figure
3-1) which appears to require additional  sweeping effort.

     Because of the limited data base available to  characterize street  dust
loadings and the effect of different sweeping alternatives,  final selection
of the sweeping measures of the control strategy should  be deferred until
an area-specific field measurement program is conducted.  This program  would
establish baseline loadings for various streets and determine by test the
actual sweeping programs needed to reduce  entrained street dust emissions to
allowable levels.  The measurements would include an analysis of dust silt
levels resulting from use of the major sweeper types to  enable a fair assess-
ment of the efficiency of the sweepers in removing  not only total dust  loads,
but in particular the suspendable fines.

                                    3-25

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     If reconciled to field test data, the proposed street sweeping scenario
would reduce total street dust by about 60% in the designated areas targeted
for control.  This reduction estimate was applied to all  streets within the
designated control areas (Figure 3-1).  Total  entrained dust emissions were
calculated for each link and assigned to grid  squares of the study area grid
network by means of simulator software operating on a computer tape of 1975
transportation link data.  The variation in emissions density throughout the
study area, with and without the strategy in 1985, is illustrated by the
graphics of Figure 3-6 and the grid map of Figure 3-7.

3.3.3  Construction Activities

          The wetting of construction access roads twice daily is assumed to
account for a 30% reduction in construction emissions (see Section 2.3).
This reduction was applied throughout the study area to the 1985 baseline
projected construction emission inventory.  Additional measures, such as
nearby road sweeping and soil stabilization will further reduce construction
emissions by an undetermined amount.  "Figure 3-8 and 3-9 show the distribution
and magnitude of emissions expected from construction activities after the
control strategy is applied by 1985.

3.4  IMPACT ON AIR QUALITY

     The emission levels associated with the proposed reasonable control
strategy were translated into air quality forecasts using the source-receptor
model developed earlier in the study.  These forecasts are shown for each of
the monitoring locations in the study area in  Table 3-7.   Substantial improve-
ments in air quality occur at each monitoring  site.  Baseline TSP levels in
1985 are reduced by about one third at most sites, and some monitor sites
experience from 40 to 60% reductions in TSP levels.  In many cases, a signifi-
cant portion of the air quality gains over baseyear levels is due to baseline
development planned for the area (see Section  3.1).  Between the improvements
achieved by development and the strategy together, baseyear TSP levels are
reduced by 31 to 76% by 1985.
                                     3-26

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              BASELINE, 1985
            AFTER STRATEGY, 1985
          Paved Streets,  With  and
3-27

-------
GRID
CODE

0
1
2
3
4
5
6
7
8
9
EMISSIONS
TONS/DAY

0 to 0
C to .004
.004 to .02
.02 to .07
.07 to .18
.18 to .37
.37 to .69
.69 to 1.2
1.2 to 1.9
1.9 to 2.9
Figure 3-7.   Total  Dust Emissions  (Entrained from Unpaved Roads
               In 1985 After Application of Control Strategy.
                                          3-28

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GRID
CODE
EMISSIONS
TONS/DAY

0 to 0
0 to .004
.004 to .lit
.02 to .07
.07 to .18
.18 to .37
.37 to .69
.69 to 1.2
1.2 to 1.9
1.9 to 2.9
                      Figure 3-7.  (continued)  Total  Dust  Emissions  From Paved  Roads,
                                    Baseline  1985.
                                         3-29

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OJ
I
CO
o
                                            WITH STRATEGY, 1985
       Figure 3-8.  Total  Dust Emissions
From Construction Activities  in  1985  After Application of Control Strategy

-------
GRID
CODE

 0
 1
 2
 3
 4
 5
 6
 7
 8
 9
EMISSIONS
TONS/DAY

0 to 0
0 to .001
.001 to .007
.007 to .02
.02 to .06
.06 to .12
.12 to .22
.22 to .38
.38 to .61
.61 to .92
Figure 3-9.  Total  Dust Emissions  From  Construction Activities in  1985
              After  Application of  Control  Strategy.
                                           3-31

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                       TABLE  3-7.   IMPACT  OF  CONTROL OF MAJOR SOURCE CATEGORIES ON TSP LEVELS
CO
I
CO
ro

MONITOR SITE
1. Central Phoenix
2. S. Piioenix
3. Arizona State
4. Glendale
5. N. Phoenix
6. N.Scottsdale/
Paradise
7. Scottsdale
8. Mesa
9. Downtown Phoenix
id. Sun City
11. Paradise Valley
12. Chandler
13. -St. John
TOTAL SUSPENDED PARTICUL/VTES, ug/m3
BASELINE
1975 1980 1985
112 104 87
144 139 101
169 157 132
101 84 65
121 111 83
149 111 101
115 105 93
117 114 95
200 186 155
88 81 74
184 152 93
119 139 160
145 151 157
STRATEGY
1980 1985
99 77
12£ 73
138 73
80 56
104 73
105 78
99 73
105 74
163 85
79 64
138 73
113 68
130 85
REDUCTION OF:
1975 TSP DUE '
1985 BASELINE TO STRATEGY &
TSP DUE TO PROJECTED
STRATEGY DEVELOPMENT
11.4% 31.22;
27.7% 49.3%
44.6% 56.8%
13.8% 44.6%
12. IS 39.6%
22.8% 47.6%
21.5* 36.5%
22.1% 36.7%
45.1% 57.5%
32.4% 76.1%
21.5% 60.3%
57.5% 42.8%
45.8% 41.4%
CONTRIBUTION TO TOTAL SUSPENDED PARTICULATES , ug/m3
UNPAVED ROADS ENTRAINED ST. DUST CONSTRUCTION ACTIVITIES
1985 1985 1985 1985 1985 1985
BASELINE STRATEGY BASELINE STRATEGY BASELINE STRATEGY
8 1 37 35 55
32 7 24 23 96
12 2 68 24 96
9 1 20 20 21
8 1 32 32 75
32 16 99 25 18
10 2 42 33 54
13 3 45 45 43
15 2 82 29 10 7
6 1 17 17 16 11
14 2 17 16 25 17
91 5 12 12 23 16
116 45 2 2 22

BACKGROUND
LEVEL
30
30
30
30
30
30
30
30
30
30
30
30
30

-------
     With application of the control  strategy, air quality at all  thirteen
of the monitor sites is forecasted to attain,  or come very close  to attaining,
the primary air quality standard for  TSP (75 yg/m ).   Only the Downtown
                                                                         O
Phoenix and St. John sites are expected to experience TSP levels  (85 yg/m  )
significantly higher than the standard.  However, previous analysis has  shown
that air quality at each of these sites is probably not representative of
air quality in the general area.  Each of the two sites is located in a
hot spot of fugitive dust sources, and air quality measured there is site-
specific and biased towards higher levels than are 'representative  of the general
area.  Consequently, additional site-specific control measures may be needed.
However, before these measures are implemented, it may be advisable to further
examine  the existing air monitoring network in the areas in question and supple-
ment  the network as necessary to further refine the problem and evaluate the
impact of the proposed strategy once it is implemented.
      Control  strategy  air quality improvements are dominated  primarily by
reductions of dust  emissions from unpaved roads.   Because  controls  for unpaved
roads are targeted  for county areas,monitor sites outside the metropolitan
influence tend to be more affected by  the control measures  proposed  for un-
paved road emissions.  These measures  improve TSP levels at Chandler, St.
Johns, North  Scottsdale/Paradise Valley, and South Phoenix  in amounts ranging
from 25  to 71  yg/m  in 1985.  The effect of controls to  reduce entrained
street dust emissions  off paved roads  is evidenced most  noticeably at monitors
within the designated  areas of control  (Downtown Phoenix and Scottsdale).  The
downtown Phoenix monitor experiences the greatest improvement as TSP  levels
                       3
are reduced by 53 yg/m  due to the street dust strategy measures.  The effect
of construction controls is relatively minor at all monitors, ranging from a
                               o
resulting improvement of 8 yg/m  at Paradise Valley to no improvement at St.
Johns where construction activities are anticipated to be very limited.   As
discussed previously, other sources do not contribute significantly  to TSP
levels at the various monitor sites.

     As anticipated, the areawide emission reductions are significantly less
than the relative improvement in air quality.  A 36% emission reduction
(Table 3-4) occuring in 1985 from the strategy translated to TSP reductions
of 11 to 57%.  In view of the relatively high background contributions,
which is unaltered  by the strategy, the improvement leverage  provided by the
 emissions reductions is appreciable.  As discussed previously, this is  due to

                                     3-33

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the dominant influence of local  fugitive sources on TSP levels at any
given location.

     The impact of the control  strategy by 1980 is  also significant, but
because the control measures are about only two-sevenths complete by
this time, air quality at only  one of the monitor sites (Sun City) is fore-
casted to attain the primary standard.
                                                                            i
     As discussed earlier, it is useful to distinguish between the control
strategy needed to attain the standard throughout the region and that
needed to attain the standard at the monitoring stations.  Because of the
very localized influence of fugitive dust sources,  and the limitations
associated with current state-of-art air quality simulator techniques, the
proposed  control strategy cannot assure region-wide attainment.  TSP levels
at certain locations may be higher than those represented by the monitoring
network.  The analysis of air quality and emissions levels resulting from
the strategy may be combined to indicate potential  non-attainment areas
where monitor sites should be established and additional controls applied
if warranted.  Figure 3-10 shows nine potential non-attainment areas which
may require additional control  attention in 1985.  These areas were identified
by locating grid squares where  emissions densities  were greater than those
levels predicted at the attaining monitor sites (i.e., all grid squares with
grid codes greater than 7).  Inspection of the emissions grid maps (Section
3.3) suggests the relative influence of the major sources on air quality at
these sites.  Some of the potential hot spot grid squares are located within
the metropolitan area and are most affected by entrained street dust emissions.
Most of the potential problem sites are located in  more rural areas outside
the metropolitan influence, where unpaved road emissions and dust from con-
struction activities are the major sources of the emissions totals.

     Air quality monitors should be installed at the indicated sites to
establish baseline TSP levels for use in air quality simulation and prediction
of future TSP levels there.  The timetable for completing the expanded monitor
network should be immediate to permit appropriate adjustment of the proposed
control strategy.
                                    3-34

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                                            43533
GRID
CODE

 0
 1
 2
 3
 4
 5
 6
 7
 8
 9
EMISSIONS
TONS/DAY

0
0 to .01
.01 to .04
.04 to .13
.13 to .32
.32 to .67
.67 to 1.2
1.2 to 2.1
2.1 to 3.4
3.4 to 5.2
Figure  3-10.
Potential  Non-Attainment  Are*
in  1985 After Application o*
Proposed Control  Strategy.
                                     3-35

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3.5  COST OF CONTROLS

     The cost of implementing the control  measures of the proposed strategy
are shown in Table 3-8.  The estimates are based on cost data presented in
Section 2.  The cost effectiveness is expressed in terms of emissions re-
ductions and average air quality improvement.    With the exception of the
measures to restrict vehicle speed on unpaved  roads, there is relatively
minor  difference in the cost effectiveness of the various measures.  The
vehicle speed restriction is especially cost effective because of 1) the
substantial emission reduction attained, 2) the presumption that the
measure can be implemented inexpensively at an annualized cost of $200,000.
Costs of the measures vary from about $2 to $55 per ton of dust emissions
prevented, or from about $40,000 to $218,000 for each yg/m  of TSP con-
centration decrease.  These costs are significantly loWer than those
typically required to control particulate  emission sources in other regions
experiencing non attainment problems due mainly to conventional type
sources [21].

     The total cost of instituting the control strategy is consistent with
the concept of "reasonable" strategy defined earlier.  Annual cost of the
strategy is about $4.4 million, or approximately $3 per capita in Maricopa
County.  This compares to an appropriate 1976  total budget of $358 million
for the city of Phoenix.  Expressed as a tax on automobile gasoline in
Maricopa County, the control would cause an increase of 0.8 cents per gallon.

     An important aspect in assessing the  true cost of the controls concerns
cost benefits derived from the measures.  The  cost effects of air pollution
on water treatment, materials, aesthetics, property taxes, vegetation,
health, and economic development are significant.  It is recommended that
the demonstration model, proposed as an integral part of the overall control
strategy (see Section 3.7), include a cost benefit analysis for each of the
proposed measures.
                                    3-36

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                                            TABLE  3-8.   COST OF  IMPLEMENTING  CONTROL  STRATEGY
CO
 I
00
SOURCE CATEGORY
Unpaved Roads 1 .
2.
Entrained Dus.t 1 .
Construction
Activities 1 .
2.
3.
1
TOTAL, OVERALL STRATEGY
ANNUALI7.ED COST INCREASE
(MILLIONS OF DOLLARS)
CONTROL MEASURES
Chip seal all section line roads by 1995, and one- 2.5
half by 1985.
Reduce speed limit to 20 mph for all interior unpaved .2
roads (private and county) gradually by 1985.
/ e
By 1985, sweep major roads in designated areas to attain .36
a 60" reduction in the current assumed average street
dust loading. Based on the existing data base, the
sweeping program would consist of cleaning major roads
three days weekly, alternating from vacuum sweeping to
broom sweeping as appropriate.
Effective 1980, wetting of site access roads twice daily at
.5 gal/yard.2 .72a'
By 1980, sweeping of paved roads used by construction vehicles .60
to remove visible dust resulting from construction activities.
By 1980, stabilization of exposed earth at construction sites - c'
when operations cease.
4.4
COST EFFECTIVENESS
S/TONS OF EMISSION
PREVENTED
23.0d"
2.1d'
54.8
25.4
18.6
                    a.
                    b.
                    c.
                    d.
                    e.
                    f.
Based on assumption  that access roads comprise 10%  of all areas.involved in construction  activity (6590 active acres/month),  and
watering of these  roads is currently performed once daily at $3/acre.


Based on assumption  an average construction site is comprised of a 2 acre plot and there  are some 330 individual sites which  must
be attended on  any day in 1985.


It is anticipated  that construction practices  will  be modified to avoid this control  requirement by suitable scheduling of
activities.


Based on emissions reduction of 298 tons/day due to paving measure, and 256 tons/day  due  to speed limit restriction.


This estimate was  derived by multiplying the current average cost of street cleaning  in Phoenix ($4.80/curb mile [15]) by the
number of curb  miles of major roads to be swept 3 times weekly in the designated areas.   (Total of 474 curb miles based
on compilations from traffic volume maps).


Cost effectiveness in terms of incremental air quality improvement was computed by dividing the total annual cost of  the
measure by the  average incremental TSP improvement  for all monitor sites.  Accordingly, this figure reflects the particular
cost effectiveness associated with gains at the monitor sites only.

-------
3.6  IMPLEMENTATION PROBLEMS

     The difficulty in implementing the strategy depends on political,
legal, and socioeconomic obstacles associated with the various  control
measures.  The magnitude of these  obstacles  depends on the general  im-
plementation approach of the strategy, that is, whether it is to be  en-
forced as a series of air pollution control regulations, or as  in-line
actions to be taken by various agencies in the performance of related
projects.  As a direct regulatory approach, implementation of the strategy
will probably meet with substantial obstacles.  There is the legal question
of whether the county has the authority to regulate and impose  require-
ments on various agencies or private interests, and whether legislation
has actually delegated this specific authority to the county.  While local.
agencies are responsible for the establishment of air pollution regulations,
the justification for many local regulations has stemmed from state  and
federal pollution control requirements.  The county could exercise initiative
in assuming implied-authority, and adopt new regulations for implementing
the control strategy, but the risks involved in this approach (e.g., jeopardy
of the current control program) would make it an improbable action by the
county.

     In addition to legal obstacles, political and social acceptance of
the proposed measures may pose implementation problems especially if
controls are imposed by regulations.  Regulations assembled by the County
Health Department and justified on the basis of air quality improvements
may generate apprehension on the part of agencies and individuals per-
ceiving conflict with their own interests.  Productive interaction among
appropriate groups would alleviate this problem, but visible enforcement
of the measures by an air pollution control agency for questionable  health
benefits would place support for the strategy in constant jeopardy.

     The alternative to the regulatory approach for control measures is a
workable approach which provides for integration (when possible) of the
control measures into the on-line operations of various governmental agencies.
This approach generates greater political and social acceptance to the measures,
since the measures are visible not only as dust controls, but as planning  and

                                    3-38

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development improvements which will yield several tangible benefits of
more popular demand.  In view of the types of major fugitive dust emission
sources which are typically uncontrolled at present, the integral planning
approach is particularly appropriate.  Reasonably available controls for
unpaved road dust and entrained street dust emissions are entirely con-
sistent with objectives of the local transportation and street maintenance
departments.

     The major obstacle confronting implementation of a dust control strategy,
whether utilizing the integral planning approach or the direct regulatory
technique, concerns the socioeconomic acceptability of the proposed actions.
Appropriations by the respective local agencies  for implementing controls
requires  financial  support of  the  citizenry, whether by taxes, bonds,  or
assessment districts.  While the funding needed to support implementation
of the strategy is relatively miminal (amounting to 1.2% of the annual city
budget), there is little chance that the additional expenditures  associated,
with the strategy would be absorbed in the annual budgets without visible
justification.  Such justification may be facilitated by a persuasive
control demonstration project to validate the benefits of the proposed
strategy.

     While some of the major sources can be controlled with general plan-
ning programs within the relevant local  agencies, it is clear that all
sources cannot be controlled in this manner.  For example, commercial
point sources of fugitive dust are currently controlled by county regula-
tions under the reasonable control clause requirement, and although other
participating agencies (e.g., Building and Safety Department) may be in-
volved in implementation of the present rule, the motivation stems from
regulatory mandate rather than planning interest.  Such regulatory mandates
are subject to test by the courts.  In fact, the reasonable control clause,
as it applies to construction activities, has already been tested in Phoenix.
The state court ruled for the regulation in this case, deciding that a
contractor has not taken reasonable precaution to reduce dust emissions
during construction activities.  The proposed strategy of this study would
expand the control regulation for construction activities (requiring watering
twice daily and daily street sweeping) in more specific terms,and enlist

                                   3-39

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the participation of the Building and Safety Department in the issuing of
construction permit approvals (under their delegated authority)  contigent
on compliance with the control  measure.

     Table 3-9 provides a summary of the ranking of implementation dif-
ficulties anticipated for each  of the control  measures comprising the
strategy.  The rankings are based on the interdisciplinary implementation
approach, in which various  departments  of the local government are active
participants in carrying out the strategy.  The assessment is estimated
for two cases: with, and without the benefit of a demonstration model pre-
ceeding implementation of the area wide  proposed strategy.  The estimates
are necessarily somewhat speculative, but are consistent with the foregoing
control strategy analysis and interviews with appropriate administrators
and staff of pertinent local agencies in Phoneix.

     The summary of Table 3-9 shows the  relative difficulty of implementing
any of the measures is very similar.  Without the benefit of a demonstra-
tion model to provide general awarene*ss  and to support the suitability of
the proposed area wide strategy, each of the measures is likely to encounter
substantial socioeconomic resistance.  Additional annual funding of about
$4.4 million would be needed to support  the measures, most of which would'
be generated by increased taxes or direct assessment.  Socioeconomic
resistance is compounded by the uncertainties inherent in the control
strategy development, and the subsequent difficulty in justifying expenditures
with minimum risk of expected benefits.   None of the measures face diffi-
cult technical problems with the possible exception of the intensive street
cleaning proposal.
     The lower half of Table 3-9 presents estimates of implementation
difficulties  subsequent to conducting a demonstration model strategy
in a limited  area of the Phoenix study region.  Presuming the model is
conducted  successfully, yielding a public awareness of the various bene-
fits (including air quality improvements) to be gained from widespread
implementation of the model elements, and dismissing speculative uncertainties
                            3-40

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                            TABLE  3-9.  IMPLEMENTATION DIFFICULTY OF CONTROL STRATEGY
to
I
CONTROL
MEASURES
WITHOUT DEMONSTRATION MODEL:
1. Intensive Road Paving
2. Lower Speed Limit on Unpaved
Dirt Roads
3. Intensive Street Cleaning
'4. Wetting of Construction Site
Unpaved Access Roads
5. Sweeping Paved Access Roads Used
By Construction Vehicles
6. Stablize Cleared Areas of
Construction Sites
AFTER IMPLEMENTATION OF DEMONSTRATION
MODEL
1. Intensive Road Paving
2. Lower Speed Limit on Unpaved
Dirt Roads
3. Intensive Street Cleaning
4. Wetting of Construction Site
Unpaved Access Roads
5. Sweeping Paved Access Roads Used
by Construction Vehicles
6. Stabilized Cleared Areas of
Construction Sites
*
SEVERITY OF
TECHNICAL

1
1

2
1

1

1

1
1

2
1

1

1


IMPLEMENTATION
POLITICAL LEGAL

1
2

'2
2

2

2

1
1

1
1

1
1
1



1
1

1
1

1

2

1
1

1
1

1

2


DIFFICULTY
SOCIOECONOMIC

3
3

3
3

3

3

2
1

2
1

1

2


OVERALL
SEVERITY

6
7

8
7

7

8

5
4

6
6

4

6



-------
surrounding the appropriateness of the measures, the remaining obstacles
limiting the full scale institution of the strategy are expected to be
resolvable.  The ingredients of the demonstration model are discussed
.in the following section.

3.7  DEMONSTRATION MODEL

      The proposed  measures  of the control  strategy are reasonable  in  terms
 of their technical,  institutional, economic,  and legal  feasibility.   How-
 ever,  because  of substantial  socioeconomic resistance  associated with the
 measures,  it  is proposed that a  demonstration model  be formulated  and in->
 eluded as  a prerequisite to implementation of the overall  control  strategy.
 The model  strategy would be useful in a  number of ways.   First,  the model
 Would be instrumental  in generating the  public acceptance  needed  for
 eventual financial support  of the total  strategy.  Second, the demonstra-
 tion would promote committment from local agencies as participants
 in dust control objectives.  Finally, the demonstration program is essential
 as a tool  for  pollution control  analysis as it would yield useful  insights
 for appropriate adjustments of the region-wide strategy.

      There is  substantial indication the local control demonstration  would
 result in significant air quality improvement.  The evidence shows clearly
 that local sources are affecting the Hi-Vol monitor measurements  dramati-
 cally.  The cost of  controlling these sources may well be less than the
 cost of the air pollution consequencies, and the specific controls are
 compatible with other city  and county planning objectives.  Hence, the
 local  control  demonstration is a very appropriate vehicle for persuasion,
 with very little risk involved.                     '

      The demonstration model must be formulated carefully, and should
 consist of the following elements:
      •   Surveys to establish understanding of pertinent value forces
          operating among the various social sectors.
                                    3-42

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      •   A cooperative task  force  committee  comprised  of representatives
          from the major affected  local  departments  (i.e.,  Department of
          Transportation, County Highway Department,  Agricultural  Exten-
          sion Service, County Legal  Services,  Maricopa County  Health
          Department,  etc.).   The  committee would  be  responsible  for  the
          planning of  the model strategy.
      •   A field test to demonstrate the  effect of  the proposed  control
          measures in  a limited area. This test would  include  institution
          of all  controls proposed  for the area-wide  strategy.  A com-
          prehensive TSP field monitoring  program  would be  implemented.
      •   A detailed economic analysis to  evaluate the  economic consequences
          of particulate air  pollution in  Phoenix, and  the  cost benefits
          of the  proposed dust control strategy.
      •   A public relations  program to  promote awareness of the  benefits
          of the  proposed dust control and to generate  support  for funding
          measures needed to  implement the measures.

     The selection of  the specific area  for  the model demonstration would  be
dependent on several factors.  First, receptibility  of the various local
agencies to participate in the model test should be  assurred.  Discussions
with various departments of the City of  Phoenix and  Maricopa County have
indicated a positive disposition  to participate in both the funding and
implementation of a model demonstration  program [1,  15, 16, 11, 22].   The
position of additional affected agencies should be surveyed, and  the disposi-
tion of local agencies in unincorporated cities of the study area should be
investigated.  Second, the test area should  be representative of  air quality
and major emission sources causing high  levels of TSP throughout  the study
area.  Controls for the three major fugitive  emission sources can then be
tested and evaluated during the single demonstration program.  Third, it would
be preferable if the selected area included  a monitor of the existing air
                                     3-43

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sampling network.  This would facilitate the comparison between control  and
after control air quality, and would place the test program within the context
of the present study framework.  Fourth, since a key to the utility of the
test model  is its effect on social  acceptance, the area selection should
reflect a level of social acceptance typical of that characteristic of the
region targeted for control strategy application.    Another, but not necessari-
ly final consideration in test area selection is the scheduled planning  for
the area.  Desirability for selection of the area  is increased when scheduled
development is compatible with the specific controls comprising the demonstra-
tion model.

     Selection of a test area should be based on a prioritized ranking of
each of the above (and other) selection factors, and the specific charac-
terization  for the various candidate areas being considered.
                                    3-44

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                              REFERENCES

 1.    Maricopa County  Highway  Department, Personal communication, June 1976.

 2.    City of Phoenix  Department  of Transportation, street maintenance data
      compiled for internal  use by the  department, July  1975.

 3.    Roberts, J.W., and  H.  A. Matters,  "Cost  and Benefits of Road Dust
      Control in  Seattle's  Industrial Valley," Journal of the Air Pollution
      Control Association,  September  1975.

 4.    Jutze,  G.,  and K. Axetell,  PEDCO  Environmental Specialists, Inc.,
      "Investigation of Fugitive  Dust,  Volume  I  - Sources, Emissions, and
      Control," June 1974.

 5.    Roberts, J.W., A. T.  Rossano, P.T.  Bosserman, G.C. Hafer,  and H.A.
      Watters, "The Measurement,  Cost and Control of Traffic Dust and Gravel
      Roads in Seattle's  Duwamish Valley,"  Paper No. AP-72-5, presented at
      the Annual  Meeting  of the Pacific Northwest International  Section of
      the Air Pollution Control Association, November  1972.

 6.    Cowherd, Chatten; Axetell,  Kenneth; Midwest Research Institute,
      "Development of  Emission Factors  for  Fugitive Dust Sources," June 1974.

 7.    Sehmel, G.A., "Particle  Resuspension  from  an Asphalt Road  Caused by
      Vehicular Traffic," BNWL-1651 PT1.

 8.    Sartor, James, Gail Boyd,  "Water  Pollution Aspects of Street Surface
      Contaminants," Prepared  for U.S.  Environmental Protection  Agency,
      November, 1972.

 9.    American Public  Works Association,  "Water  Pollution Aspects of Urban
      Runoff," APWA, Chica  o,  1969.

10.    TRW Environmental Engineering Division,  "Development of an Implementation
      Plan for Suspended  Particulate  Matter in the Phoenix Area," Volume 2,
      Prepared for Environmental  Protection Agency, May  1976.

11.    City of Phoenix  Department  of Transportation, Personal communication,
      July 1975.

12.    City of Phoenix  Arizona, "1975  Accelerated Major Street Program,"
      July 1975.

13.    Sultan, Hassen A, Arizona Transportation and Traffic Institute,
      "Soil Erosion and Dust Control  of Arizona  Highways Part IV Final
      Report Field Testing Program,"  Prepared  for Arizona Department of
      Transportation,  November 1975.

14.    Hawkins Company, Phoenix, Arizona,  Personal communication, July 1970.

15.    Phoenix Department  of Transportation  and Road Maintenance, Personal
      communication, June 1976.

                                   R-l

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                            REFERENCES  (continued)

16.   Maricopa County Bureau of Air Pollution  Control,  Personal  communication,
      June 1976.

17.   TRW Environmental  Engineering Division,  "Development  of  an Implementa-
      tion Plan for Suspended Particulate  Matter  in  the Phoenix  Area," .
      Volume 3, Prepared for Environmental  Protection Agency,  August 1976.

18.   Horton, D., Ecolatec,  Inc.,  "Effectiveness  of  Vacuum  Sweepers,"
      American Public Works  Association Reporter, April 1976.

19.   Ecolotec, Inc., Personal  communication,  September 1976.

20.   Midwest Research Institute,  "Quantification of Dust Entrainment
      from Paved Roadways,"  Prepared for Environmental  Protection Agency,
      March 1976.

21.   Trijonis, J., TRW Environmental  Engineering Division, "An  Imple-
      mentation Plan for Suspended Parti.culate Matter in the Los Angeles
      Basin," March 1975.

22.   City of Phoenix Department of Transportation,  Personal communication
      with City.Tra.ffic Engineer,  May 1976.

23.   TRW Environmental  Engineering Division,  "Development  of  an Implementa-
      tion Plan for Suspended Particulate  Matter  in  the Phoenix  Area,"
      Volume 1, Prepared for Environmental  Protection Agency,  March  1976.

24.   Olsen, R.H., Boeing Technology Services, "The  Suspended  Particulate
      Problem in Seattle's Duwamish Basin," Presented at the Pacific
      Northwest International Section of the Air  Pollution  Control
      Association Annual Meeting.

25.   Roberts, J.W., A.  T. Rossano, P.  T.  Bosserman, C. G.  Hafer, and H. A.
      Watters, "The Measurement, Cost and  Control of Traffic Dust and Gravel
      Roads in Seattle's Duwamish  Valley," Paper  No. AP-72-5,  presented  at
      the Annual Meeting of the Pacific Northwest International  Section
      of Air Pollution Control  Association, November 1972.

26.   Scott, John B., Director of Research, "The  American City 1970  Survey
      of Street Sweeping Equipment," The American City  and  the Municipal
      Index, December 1970.

27.   Laird, Carlton W., Scott, John, "How Street Sweepers  Perform Today  ...
      in 152 selected cities across the nation,"  The American City,
      and the Municipal  Index, December 1970.

28.   Jackson, R.D., City of Columbus,  Ohio, Department of  Public Service,
      "Street Cleaning, the Best Way," presented  at the Governmental Refuse
      Collection and Disposal Association Seminar and  Equipment Show,
      Santa Cruz, California, November 1973.


                                    R-2

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29.    Elgin Leach Corporation,  Illinois,  Personal communication, October
      1976.

30.    Los Angeles Department of Street  Maintenance, Personal communication,
      October 1976.

31.    Long Beach Department of  Street Services, Personal communication,
      October 1976.

32.    City of Phoenix Department of  Street Services, Personal communication,
      October 1976.

33.    Central Engineering  Company, Inc.,  Milwaukee, Personal communication,
      October 1976.

34.    Super Vac Sweeping Service, Alhambra, California, Personal communi-
      cation, October 1976.
                                    R-3

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                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
      EPA-450/3-77-021d
                              2.
                                                            3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
      An  Implementation  Plan for Suspended Particulate
      Matter in the Phoenix Area, Volume  IV, Control
      Strategy Formulation
                                                      5. REPORT DATE
                                                           June  1977
                                                      6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
       George Richard
9. PERFORMING ORGANIZATION NAME AND ADDRESS

       TRW
       Environmental  Engineering Division
       One Space Park
       RpHnpHn Rparh   Tali form' a
                                                            10. PROGRAM ELEMENT NO.
                                                      11. CONTRACT/GRANT NO.
                                                          68-01-3152
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
U. S. Environmental Protection Agency
Office of  Air Quality Planning and Standards
Research Triangle Park,  N.C.   27711
                                                                 Final
                                                            14. SPONSORING AGENCY CODE
                                                                   200/04
15. SUPPLEMENTARY NOTES   Vol ume j f Air Quality Analysis  -  EPA 450/3-77-021a;  Volume  II
       Emission Inventory - EPA 450/3-77-021J>; Volume III, Model Simulation of Total
                 Partinilate Matter Levels - EPA 450/3-77-021c ; Volume IV. Control
16. ABSTRAC
             strategy' Formal atlon -  EPA 450/3-77-021;d
       This document  is  one volume of a  four volume  report presenting an implementation
       plan for control  of suspended  particulate matter in the Phoenix area.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                                                                    c. COS ATI Field/Group
       Particulate  Matter
       Total Suspended Particulate
       Emission Sources
       Control Methods
       Fugitive Dust
       Air Quality  Measurements
18. DISTRIBUTION STATEMENT
       Release Unlimited
                                        19. SECURITY CLASS (ThisReport)
                                            Unclassified
                                                                           21. NO. OF PAGES

                                                                              94
                                               20. SECURITY CLASS (This page)

                                                   Unclassified
                                                                           22. PRICE
EPA Form 2220-1 (9-73)
                                             R-4

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