United States
Environmental Protection
Agency
Office of Air
P'annin^and Standards
Research Triangle ."ark NC 27711
EPM-45C/3-&8-308
September 1988
Air
CONTROL OF
OPEN  FUGITIVE
DUST  SOURCES
                            7

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                                           EPA-450/3-38-008
    CONTROL  OF  OPEN  FUGITIVE  DUST SOURCES
                FINAL REPORT
                     by

 C. Cowherd, G.  E. Muleski,  and  J.  S.  Kinsey
        Midwest Research  Institute
            425 Volker Boulevard
        Kansas City, Missouri  64110
        EPA Contract No. 68-02-4395
             Work Assignment 14
            MRI  Project 8985-14
     William L.  Elmore,  Project Officer
        Emission Standards Division

Office of  Air Quality Planning and Standards
   U. S. Environmental Protection Agency
   Research Triangle Park,  North Carolina
               September 1988

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This report has been reviewed by the Emission Standards Division of the Office of Air Quality Planning and
Standards,  EPA,  and  approved for publication. Mention of trade names or commercial products is not
intended to constitute endorsement or recommendation for use. Copies of this report are available through
the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park NC
27711, or from National Technical Information Services, 5285 Port Royal, Springfield VA 221 61.

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                              ACKNOWLEDGMENTS


     We wish to acknowledge the significant contributions of a number of

individuals to the success of this project.  Much of the information

contained in this report was developed at a cooperative working session

attended by U. S. Environmental Protection Agency (EPA), State, local

program, and contractor personnel.  Without their cooperation in sharing

data, discussing control strategies, and reviewing document drafts, this

study would not have been possible.  The individuals who made significant

contributions and their organizational affiliations are listed below.
Frances Beyer, MRI
Chat Cowherd, MRI
Francis Daniel, APCD, Va.
Jim Dewey, Region V
Ken Durkee, ESD
Larry Elmore, ESD
Chuck Fryxell, San Bernardino County APCD, Calif.
Lynn Kaufman, MRI
Susan Kulstad, Region I
Ed McCarley, TSO
Greg Muleski, MRI
Duane Ono, Region IX
Tom Pace, AQMD
Butch Smith, MRI
Ken Woodard, AQMD
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                             TABLE OF CONTENTS

                                                                      Page

SECTION 1.0  INTRODUCTION	     1-1

             1.1  CONTROL OPTIONS	     1-1

             1.2  SCOPE OF THE DOCUMENT	     1-3

SECTION 2.0  PAVED ROADS	     2-1

             2.1  PUBLIC PAVED ROADS	     2-3
                  2.1.1  Estimation of Emissions	     2-4
                  2.1.2  Demonstrated Control Techniques for
                           Public Paved Roads	     2-6

             2.2  INDUSTRIAL PAVED ROADS	   2-10
                  2.2.1  Estimation of Emissions	   2-10
                  2.2.2  Demonstrated Control Techniques for
                           Industrial Paved Roads	   2-11

             2.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES	   2-11
                  2.3.1  Preventive Measures	   2-11
                         2.3.1.1  Salting/Sanding for Snow and Ice    2-14.
                         2.3.1.2  Carryout from Unpaved Areas and
                                    Construction Sites	-..   2-16
                         2.3.1.3  Other Preventive Control  Measures   2-17
                  2.3.2  Mitigative Measures'	   2^17
                         2.3.2.1  Broom Sweeping of Roads	   2-18
                         2.3.2.2  Vacuum Sweeping of Roads	   2-22
                         2.3.2.3  Water Flushing of Roads	   2-25

             2.4  EXAMPLE DUST CONTROL PLAN	   2-28

             2.5  POTENTIAL REGULATORY FORMATS	   2-29
                  2.5.1  General Guidelines	   2-29
                  2.5.2  Example SIP Language for Reduction of
                           Public Paved Road Surface Contaminants..   2-32

             2.6  REFERENCES FOR SECTION 2	   2-35

SECTION 3.0  UNPAVED ROADS	    3-1

             3.1  ESTIMATION OF EMISSIONS  FROM UNPAVED ROADS	   3-2

             3.2  DEMONSTRATED CONTROL TECHNIQUES  FOR UNPAVED  ROADS    3-6

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                      TABLE OF CONTENTS  (continued)
             3.3  EVALUATION  OF  ALTERNATIVE CONTROL MEASURES	   3-10
                  3.3.1   Source  Extent Reductions	   3-10
                  3.3.2   Surface Improvements	   3-10
                         3.3.2.1  Paving	   3-10
                         3.3.2.2  Gravel/Slag Improvements	   3-11
                         3.3.2.3  Vegetative Cover	  -3-11
                  3.3.3   Surface Treatments	   3-12
                         3.3.3.1  Watering	   3-12
                         3.3.3.2  Chemical  Treatments	   3-16

             3.4  EXAMPLE DUST CONTROL PLAN	   3-23
                  3.4.1   Example Water Program	   3-23
                  3.4.2   Example Chemical  Dust Suppressant Program    3-23

             3.5  POTENTIAL REGULATORY FORMATS	   3-24

             3.6  REFERENCES  FOR SECTION  3	   3-29

SECTION 4.0  STORAGE PILES	    4-1

             4.1  ESTIMATION  OF  EMISSIONS	    4-1
                  4.1.1   Materials Handling	    4-3
                  4.1.2   Wind Erosion.....	    4-4
                         4.1.2.1  Emissions and Correction
                                    Parameters-.	    4-4
                         4.1.2.2  Predictive Emission Factor
                                    Equation	    4-5
                  4.1.3   Wind Emissions From Continuously Active
                           Piles		   4-17

             4.2  DEMONSTRATED CONTROL TECHNIQUES	   4-18

             4.3  EVALUATION  OF  ALTERNATIVE CONTROL MEASURES	   4-20
                  4.3.1   Chemical  Stabilization	   4-20
                  4.3.2   Enclosures	   4-21
                  4.3.3   Wet  Suppression  Systems	   4-24

             4.4  EXAMPLE DUST CONTROL PLAN—WATERING OF  COAL
                    STORAGE PILE	   4-24

             4.5  POTENTIAL REGULATORY FORMATS	   4-24

             4.6  REFERENCES  FOR SECTION  4	   4-24

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                       TABLE  OF CONTENTS (continued)

                                                                      Page

SECTION 5.0  CONSTRUCTION AND DEMOLITION ACTIVITIES	    5-1

             5.1  ESTIMATION OF EMISSIONS	    5-2
                  5.1.1  Construction Emissions	    5-2
                  5.1.2  Demolition Emissions	    5-3
                         5.1.2.1  Dismemberment	    5-3
                         5.1.2.3  Debris Loading	  .  5-4
                         5.1.2.4  Onsite Truck Traffic	    5-4
                         5.1.2.5  Pushing Operations	    5-4
                  5.1.3  Mud/Dirt Carryout Emissions	    5-5

             5.2  DEMONSTRATED CONTROL TECHNIQUES	    5-5
                  5.2.1  Work Practice Controls	    5-7
                  5.2.2  Traditional Control Technology	    5-8

             5.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES	    5-9
                  5.3.1  Watering of Unpaved Surfaces	    5-9
                         5.3.1.1  Control Efficiency	    5-9
                         5.3.1.2  Control Costs....	   5-13
                         5.3.1.3  Enforcement Issues	   5-13
                  5.3.2  Wet Suppression for Materials Storage
                           and Handling	..	   5-14
                         5.3.2.1  Control Efficiency	   5-14
                         5.3.2.2  Control Costs.....	   5-19
                         5.3.2.3  Enforcement Issues—	...   5-19
                  5.3.3  Portable Wind Screens or Fences		   5-20
                         5.3.3.1  Control Efficiency	   5-20
                         5.3.3.2  Control Costs	   5-22
                         5.3.3.3  Enforcement Issues..	   5-23
                  5.3.4  Drilling Control Technology	   5-23
                         5.3.4.1  Control Efficiency	   5-23
                         5.3.4.2  Control Costs	   5-24
                         5.3.4.3  Enforcement Issues	   5-25
                  5.3.5  Control of Mud/Dirt Carryout		   5-25
                         5.3.5.1  Control Efficiency	   5-25
                         5.3.5.2  Control Costs	   5-27
                         5.3.5.3  Enforcement Issues	   5-27

             5.4  EXAMPLE DUST CONTROL PLAN	   5-28

             5.5  POTENTIAL REGULATORY FORMATS	   5-28
                  5.5.1  Permit System	   5-32
                  5.5.2  Opacity Standards	   5-35
                  5.5.3  Other Indirect Measures  of Control
                           Performance	   5-35

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                      TABLE OF CONTENTS  (continued)
                  5.5.4  Example Rule	   5-36
                         5.5.4.1  Conditions for Construction	   5-36
                         5.5.4.2  Control  Mud/Dirt Carryout	   5-38
                         5.5.4.3  Control  of Haul  Road Emissions...   5-38
                         5.5.4.4  Stabilize Soils  at Work Sites	   5-38
                         5.5.4.5  Record  Control Application	   5-38
                         5.5.4.6  Modification of  Permit
                                    Provi s i ons	   5-38

             5.6  REFERENCES  FOR SECTION  5	   5-41

SECTION 6.0  OPEN  AREA WIND EROSION	    6-1

             6.1  ESTIMATION  OF  EMISSIONS	    6-7
                  6.1.1  "Limited" Erosion Potential	    6-7
                  6.1.2  "Unlimited"  Erosion Potential	   6-16

             6.2  DEMONSTRATED CONTROL  TECHNIQUES	   6-17

             6.3  EVALUATION  OF  ALTERNATIVE CONTROL MEASURES	   6-18
                  6.3.1  Chemical  Stabilization	   6-18
                  6.3.2  Wind Fences/Barriers	   6-18
                  6.3.3  Vegetative  Cover	   6-21
                  6.3.4  Limited Irrigation of Barren Field	   6-23

             6.4  EXAMPLE DUST CONTROL  PLAN—COVERING UNPAVED
                    PARKING LOT  WITH  LESS  ERODIBILE SURFACE
                    MATERIAL....		   6-23

             6.5  POTENTIAL REGULATORY  FORMATS....	   6-25

             6.6  REFERENCES  FOR SECTION 6	   6-29

SECTION 7.0  AGRICULTURE	'.	    7-1

             7.1  ESTIMATION  OF  EMISSIONS	    7-1
                  7.1.1  Tilling	    7-1
                  7.1.2  Wind Erosion	    7-2
                         7.1.2.1  Simplified Version of  Wind
                                    Erosion Equation	    7-2
                         7.1.2.2  New Wind Erosion  Prediction
                                    Technology	   7-19

             7.2  DEMONSTRATED CONTROL  TECHNIQUES	   7-20
                  7.2.1  Tilling	   7-20
                  7.2.2  Wind Erosion	   7-23
                                   VI 1 1

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                       TABLE OF CONTENTS (continued)
                                                                       Page
             7.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES	   7-24
                  7.3.1  Tilling	   7-24
                  7.3.2  Wind Erosion	   7-24
                         7.3.2.1  Vegetative Cover	   7-24
                         7.3.2.2  Tillage Practices	   7-25
                         7.3.2.3  Windbreaks and Wind Barriers	   7-27
                         7.3.2.4  Strip-Cropping	   7-28
                         7.3.2.5  Limited Irrigation of Fallow
                                    Field	   7-28

             7.4  POSSIBLE REGULATORY FORMATS	   7-29

             7.5  REFERENCES FOR SECTION 7	   7-30

APPENDIX A   OPEN DUST SOURCE CONTROL EFFICIENCY TERMINOLOGY	    A-l

APPENDIX B   ESTIMATION OF CONTROL COSTS AND COST EFFECTIVENESS	    B-l

APPENDIX C   METHODS OF COMPLIANCE DETERMINATION FOR OPEN SOURCES..    C-l

APPENDIX D   PROCEDURES FOR SAMPLING SURFACE/BULK MATERIALS	    D-l

APPENDIX E   PROCEDURES FOR LABORATORY ANALYSIS OF SURFACE/BULK
               SAMPLES	..,,....	    E-l

APPENDIX F   FUGITIVE EMISSIONS PUBLICATIONS CURRENTLY ON FILE.....    F-l

APPENDIX G   EXAMPLE REGULATIONS	    G-l

APPENDIX H   FOOD SECURITIES ACT	    H-l

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                             1.0  INTRODUCTION

     Fugitive participate emissions are emitted by a wide variety of
sources both in the industrial and in the nonindustrial sectors.  Fugitive
emissions refer to those air pollutants that enter the atmosphere without
first passing through a stack or duct designed to direct or control their
flow.
     Sources of fugitive particulate emissions may be separated into two
broad categories:  process sources and open dust sources.  Process sources
of fugitive emissions are those associated with industrial operations that
alter the chemical or physical characteristics of a feed material.  Open
dust sources are those that entail generation of fugitive emissions of
solid particles by the forces of wind or machinery acting on exposed
materials.
     Open dust sources include industrial sources of particulate emissions
associated with the open transport, storage, and transfer of raw,
intermediate, and waste aggregate materials and nonindustrial  sources such
as unpaved roads and parking lots, paved streets and highways, heavy
construction activities, and agricultural tilling.  Generic categories of
open dust sources are listed in Table 1-1.  In some instances, the term
fugitive dust may be further restricted to include only nonindustrial
sources.
1.1  CONTROL OPTIONS
     Typically, there are several options for control  of fugitive
particulate emissions from any given source.  This is  clear from the
mathematical equation used to calculate the emission rate:

                              R  = M e  (1  -  c)

where:  R = estimated mass emission rate
        M = source extent (i.e., surface area for most  open dust sources)
        e = uncontrolled emission factor, i.e.,  mass of  uncontrolled
            emissions per unit of source extent
        c = fractional efficiency of control
                                  1-1

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      TABLE 1-1.   GENERIC CATEGORIES OF OPEN DUST SOURCES
1.  Unpaved Travel Surfaces
    •  Roads
    •  Parking lots and staging areas
    •  Storage piles
2.  Paved Travel Surfaces
    "  Streets and highways
    •  Parking lots and staging areas
3.  Exposed Areas (wind erosion)
    •  Storage piles
    •  Bare ground areas
4.  Materials Handling
    •  Batch drop (dumping)
    •  Continuous drop (conveyor transfer, stacking)
    •  Pushing (dozing, grading, scraping)
    -  Tilling
                             1-2

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To begin with, because the uncontrolled emission  rate  is  the  product  of
the source extent and uncontrolled emission factor, a  reduction  in  either
of these two variables produces a proportional reduction  in the
uncontrolled emission rate.
     Although the reduction of source extent results in a highly
predictable reduction in the uncontrolled emission rate,  such an approach
in effect usually requires a change in the process operation.  Frequently,
reduction in the extent of one source may necessitate  the increase  in the
extent of another, as in the shifting of vehicle  traffic  from an unpaved
road to a paved road.  The option of reducing source extent is beyond the
scope of this manual and will not be discussed further.
     The reduction in the uncontrolled emission factor may be achieved by
process modifications (in the case of process sources) or by adjusted work
practices (in the case of open sources).  The degree of the possible
reduction of the uncontrolled emission factor can be estimated from the
known dependence of the factor on source conditions that  are subject to
alteration.  For open dust sources, this information is embodied in the
predictive emission factor equations for fugitive dust sources as
presented in Section 11.2 of EPA's "Compilation of Air Pollutant Emission
Factors" (AP-42).
     The reduction of source extent and the incorporation of process
modifications or adjusted work practices which reduce the amount of
exposed dust-producing material are preventive techniques for control  of
fugitive dust emissions.  This would include,  for example, the elimination
of mud/dirt carryout onto paved roads at construction and demolition
sites.
     On the other hand, mitigative measures involve the periodic removal
of dust-producing material.  Examples of mitigative measures include:
cleanup of spillage on travel surfaces (paved  and unpaved) and cleanup of
material spillage at conveyor transfer points.
1.2  SCOPE OF THE DOCUMENT
     Prior to the use of this manual,  the  reader  should have a general
idea of what sources within the specified  jurisdictional  boundary may
require additional control  programs to achieve  desired  air quality  goals.
This determination may be based on a prior total  suspended particulate
                                  1-3

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(TSP) inventory of the area,  discussions with field inspection personnel,
or any other information source.   Because the cost of many open dust
source controls is directly related to the area of the source (e.g.,
surface area of a storage pile to be chemically stabilized, roadway area
to be swept or flushed, etc.), the user may employ the ratio:
                        Uncontrolled emission rate
                           Source  surface  area
to prioritize sources for control.   Regulatory personnel  may wish to also
combine this ratio with some  measure of the affected  population (e.g.,
zoning areas or population density within a certain distance of the
source).  This would be in keeping with guidance provided in a recent EPA
draft urban dust policy.
     The purpose of this document is to provide  regulatory personnel with
sufficient information to develop control  plans  for open  dust sources of
PM10 (i.e., particulate matter emissions no greater than  10 microns (ym)
in aerodynamic diameter).  Each section deals with a  different source
category:
    Section 2.0~Paved Roadways
        a.  Public
        b.  Industrial
    Section 3.0~Unpaved Roadways
        a.  Public
        b.  Industrial
    Section 4.0—Storage Piles
    Section 5.0—Construction/Demolition Activities
    Section 6.0—Open Area Wind Erosion
    Section 7.0—Agriculture
     Each section begins with  an  overview of  the  source category,
describing emission characteristics  and  mechanisms.   Following this,
available emission factors are presented to provide a basis  for analyzing
the operative nature of control measures.   Next,  demonstrated  control
techniques are discussed in terms of estimating efficiency  and determining
costs of implementation.  Suggested  regulatory formats explain the
"philosophy" used in implementing the  preceding technical discussions  in
                                 1-4

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viable regulations and compliance actions.  Example regulations for each
source category are presented in an appendix.  These examples are
predicated on a permit and penalty system as outlined in Table 1-2.
Control agencies may issue construction, operation, and use permits to
owners of many sources of fugitive PM10 emissions.  These permits can be
used to specify the conditions or activities that must be provided or
undertaken by the source to ensure attainment of the PM10 emission
reduction goals of the Agency's control plan.  A permit system also may
specify permit fees and compliance penalties which can be used to offset
the costs of administering an inspection and enforcement program.
Specific sources that may be appropriate for inclusion in a permit system
include the following sources.
     •  Industrial roads                  •  Feed lots
     •  Storage piles                     •  Staging areas
     •  Construction/demolition sites     •  Off-road recreational areas
     •  Vacant lots                       •  Land disposal  sites
     •  Parking lots                      •  Landfills
     In addition, a series of other appendices are also  included which
discuss terminology used in this manual, a general  costing  procedure  used
for open dust source controls and general  recordkeeping/inspection
procedures.
                                  1-5

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                  TABLE 1-2.  PERMIT AND PENALTY SYSTEM
Permits

     1.  Any Control Agency may establish, by regulation, a permit that
requires, except as provided below, that before any person engages in any
activity which will cause the issuance of fugitive PM10 emissions, such
person obtain a permit to do so from the control officer of the agency.

     2.  A permit system shall:

     a.  Ensure that the activity for which the permit was issued shall
not prevent or interfere with the attainment or maintenance of the Federal
PM10 standard.  Attainment can be demonstrated through dispersion modeling
of ambient concentrations resulting from source emissions.

     b.  Prohibit the issuance of a permit unless the control officer is
satisfied, on the basis adopted by the Control Agency, that the activity
will comply with all applicable orders, rules, and regulations of the
agency.

     3.  The control, officer may impose conditions on the permit to ensure
that the provisions of 2(a) and (b) are met.  The control officer, at any
time, may require from an applicant, or the holder of a permit, such
information, analyses, plans, or specifications which will disclose the
nature, extent, quantity, or degree of fugitive PM10  emissions which are,
or may be, discharged by the source for which a permit was issued or
applied.                 •                         .  .

     4.  The Control Agency may adopt a schedule of fees for the
evaluation, issuance, and renewal  of permits to cover the cost of the
agency programs related to the permitted sources.

     5.  Exemptions:

     a.  Size;
     b.  Duration; and
     c.  Location

Penalties

     la.  Any person who violates  any PMIO  fugitive dust order,  permit,
rule, or regulation of the Control  Agency  is guilty of a misdemeaner  and
is subject to a fine of not more than one  thousand dollars ($1,000),  or
imprisonment in the county jail  for not more than 6 months,  or both.

     Ib.  Each infraction on each  day during any portion of  which  a
violation of paragraph l(a) occurs  is a separate offense.

                                                               (continued)
                                   1-6

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                         TABLE  1-2.   (continued)
Penalties (continued)

     2a.  Any person who negligently emits an air contaminant in violation
of any PM10 fugitive dust order, permit, rule, or regulation of the
Control Agency pertaining to emission regulations or limitations is guilty
of a misdemeanor and is subject to a fine of not more than ten thousand
dollars ($10,000), or imprisonment in the county jail for not more than
9 months, or both.

     2b.  Each infraction on each day during any portion of which a
violation occurs is a separate offense.

     3a.  Any person who emits PM10 fugitive dust in violation of any
order, permit, rule, or regulation of the Control Agency pertaining to
emission regulations or limitations, who knew of the emission and failed
to take corrective action within a reasonable time under the circum-
stances, is guilty of a misdemeanor and is subject to a fine of not more
than twenty five thousand dollars ($25,000), or imprisonment in the county
jail for not more than 1 year, or both.

     For the purposes of this paragraph, "corrective action" means the
termination of the emission violation or the grant of a variance from the
applicable order, permit, rule, or regulation.

     3b.  Any person who, knowingly and with intent to deceive,  falsifies
any document required to be kept pursuant to any order,  permit,  rule,  or
regulation of the Control Agency is guilty of a misdemeanor and  is  punish-
able as provided in paragraph 3(a).

     3c.  Each infraction on each day during any portion of which  a
violation occurs constitutes a separate offense.
                                    1-7

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                              2.0  PAVED ROADS

     Particulate emissions  occur whenever  a  vehicle  travels  over a paved
surface, such as public and industrial  roads and  parking lots.   These
emissions may originate from material previously  deposited on the travel
surface, or resuspension of material from  tires and  undercarriages.   In
general, emissions arise primarily from the  surface  material  loading
(measured as mass of material per unit  area),  and that  loading  is in  turn
replenished by other sources (e.g., pavement wear, deposition of material
from vehicles, deposition from other nearby  sources, carryout from
surrounding unpaved areas,  and litter).  Because of  the  importance of the
surface loading, available  control techniques  either attempt  to  prevent
material from being deposited on the surface or to remove (from  the travel
lanes) any material that has been deposited.   Table  2-1  presents  estimated
deposition rates for paved  roads.  Note  that these estimates  date  from a
1977 report and may not accurately reflect current trends.1
     The following sections present a discussion of the  various  types  of
paved sources, available emission factors, viable control measures, and
.methods of determining controlled emission levels.
     While the mechanisms of particle deposition and resuspension  are
largely the same for public and  industrial roads, there  can be major
differences in surface loading characteristics, emission levels, traffic
characteristics, and viable control options.   For the purpose of
estimating particulate emissions and determining control programs, the
distinction between public  and industrial roads is not a question of
ownership but rather a question  of surface loading and traffic
characteristics.
     Although public roads  generally tend to have lower  surface loadings
than industrial roads, the  fact  that these roads have far greater traffic
volumes may result in a substantial contribution to the measured air
quality in certain areas. In addition,  many public roads in industrial
areas often are heavily loaded and traveled by heavy vehicles.  In that
instance, better emission estimates would be obtained by treating these
roads as industrial roads.   In an extreme case, a road or parking lot  may
have such a high surface loading that the paved surface is essentially
                                  2-1

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           TABLE 2-1.  ESTIMATED DEPOSITION RATESa
                                                 Typical rate,
Deposition process                               Ib/curb-mi/day
Mud and dirt carryout                                 100
Litter                                                40
Biological debris                                     20
Ice control compounds                                 10
Dustfall                                              10
Pavement wear and decomposition                       10
Vehicle-related (including tire wear)                  17
Spills                                                <2
Erosion from adjacent areas                           20
aSource:  EPA-907/9-77-007.1   As noted in the text, these
 estimates date from 1977  and  may not  accurately reflect
 current conditions or deposition at a specific location.
                             2-2

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covered and is easily mistaken for an unpaved  road.   In that  event,  use of
a paved road emission factor may actually result  in  a higher  estimate than
that obtained from the unpaved factor, and the road  is better
characterized as unpaved in nature rather than paved.2
     As noted in the introduction, the reader, prior to using this manual,
should have a general idea of what paved roads in  his/her  jurisdiction
require additional controls.  Furthermore, he/she  should also have a
general idea of what sources are contributing  significantly to increased
surface loadings on the roads requiring control.   For example,  heavy
trucks may spill part of their load onto public roads in industrial  areas,
or large amounts of salt and sand may be applied during winter months.
Prior to use of the information in this section, the  reader should
formulate preliminary answers to the following questions:
     1.  What paved roads are heavily loaded and thus  likely  to contribute
a disproportionate share of emissions?
     2.  What sources are likely to contribute to  these  elevated surface
loadings?
     3.  Who is the responsible party for each source  identified in
2 above?                                              .
     4.  Can the carryout/deposition from each identified source be
prevented or must the affected roadway be cleaned afterward?
     5.  Should any responsible party be granted an exclusion and on what
basis?
2.1  PUBLIC PAVED ROADS
     As discussed above, the term "public"  is used in this  manual  to
denote not only ownership of the road but also its surface  and' traffic
characteristics.  Roads in this class generally are fairly  li'ghtly loaded,
are used primarily by light-duty vehicles,  and usually have curbs  and
gutters.  Examples are streets in residential and commercial  areas and
major thoroughfares (including freeways  and  arterials).
                                  2-3

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2.1.1  Estimation of Emissions
     The current AP-42 PM10 emission factor for urban paved roads  is: 3

                       e = 2.28 (sL/0.5)o.s (g/VKT)
                                                                      (2-1)
                      e  =  0.0081  (sL/0.7)o.s  (Ib/VMT)

where:    e = PM10 emission factor,  in units shown above
          s = surface silt content,  fraction of material smaller than
              75 ym in diameter
          L = total surface dust  loading,  g/m2  (grains/ft2)
        VKT = vehicle kilometers  traveled
        VMT = vehicle miles traveled
The above equation is not  rated in AP-42 (see Appendix A).
     The product sL represents the mass of silt-size dust particles per
unit area of the road surface  and  is usually termed the "silt loading."
As is the case for all predictive models in AP-42,  the use  of site^-
specific (i.e., measured—using the  methodology presented in Appendices D
and E—for the sources under consideration)  values  of  si is strongly
recommended.  However, because measurement is not always feasible,  AP-42
presents default values  for use.  Tables 2-2  and 2-3 present a summary of
silt loadings as a function of roadway classification  and the scheme used
to classify roadways, respectively.   In general, roads with a higher
traffic volume tend to have lower surface  silt  loadings.  This
relationship is expressed  in the empirical  model presented  in Reference 4:

                            sL = 21.3/(Vo.M)      '                  (2-2)

where:  sL = surface silt  loading (g/m2)
         V = average daily traffic volume  (vehicles/d)
     Several items should  be noted about Table  2-2  and  Equation  (2-2).
First, samples are restricted  to the eastern and midwestern  portions of
the country.  While these  can  be considered representative  of  most  large
urban areas of the United  States, it is  generally believed  that  surface
silt loadings in the Southwest  can be  quite higher.  Available data,
                                 2-4

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   TABLE 2-2.  SUMMARY OF SILT LOADINGS (sL) FOR PAVED URBAN ROADWAYSa
Roadway category
City
Baltimore
Buffalo
Granite
City, 111.
Kansas City
St. Louis
All
Local
streets
Xg (g/m2)
1.42
1.41
—
—
—
1.41
Collector
streets
n Xg (g/m2) n
2 0.72 4
5 0.29 2
—
2.11 4
—
7 0.92 10
Major
streets/ Freeways/
highways expressways
Xg (g/m2) n Xg (g/m2) n
0.39 3
0.24 4
0.82 3
0.41 13
0.16 3 0.022 1
0.36 26 0.022 1
Reference 3.   X_  =  geometric mean based  on  corresponding n sample size.
 Dash = not available.   To convert g/m2 to grains/ft2  multiply g/m2 by
 1.4337.
             TABLE 2-3.   PAVED URBAN ROADWAY CLASSIFICATIONa
Roadway category
Freeways/expressways
Major streets/highways
Collector streets
Local streets
Average
daily
traffic
(vehicles)
>50,000
> 10, 000
500-10,000
<500
Lanes
>4
>4
2b
2c
      ^Reference  3.
      DRoad width >  32  ft.
      cRoad width <  32  ft.
                                   2-5

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however, do not necessarily support this suspicion; the following  compares
surface silt loadings from Table 2-2 and two counties in Arizona:
Street classification
Arterial /major
Collector

Table 2-2
0.36
0.92
Geometric mean sL (g/m2)
Maricopa Co.5
0.057
0.10

Pima Co.5
0.067
0.13
These differences may be partially the result of different measurement
techniques and/or of lower measured silt fractions of materials on the
Arizona roads.  Once again, the  use of site-specific data is stressed.
2.1.2  Demonstrated Control Techniques for Public Paved Roads
     As mentioned in the introduction to this section, available control
methods are largely designed either to prevent deposition of material on
the roadway surface or to remove material  which has been deposited in the
driving lanes.  Measurement-based efficiency values for control methods
are presented in Table 2-4.  Note that all  values in this table are for
mitigative measures applied to industrial  paved roads.
     In terms of public paved road dust control,  only very limited field
measurement data are available.   One reference was found that could be
used to indirectly quantify emission reductions and this, too,  is for
mitigative measures.  Estimated  PM10 control  efficiencies (Table 2-5) were
developed by applying Equation (2-1)  to measurements before  and after road
cleaning.6  Note that these estimates should  be considered upper bounds on
efficiencies obtained in practice because  no  redeposition after cleaning
is considered.  Note also that these estimated emission control
efficiencies for urban roads compare fairly well  with measurements at
industrial roads.  No airborne mass  emission  measurements quantifying
control efficiency were found.
     In general  terms, one would  expect that  demonstrated, control
techniques applied to industrial  paved  roads  could  also  be applied to
public roads.  One important point  to note, however,  is  that  it is
generally recognized that mitigative  measures  decrease  in effectiveness  as
                                 2-6

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     TABLE 2-4.  MEASURED EFFICIENCY VALUES FOR PAVED ROAD  CONTROLS3
    Method
  Cited
efficiency
              Comments
Vacuum sweeping   0-58 percent
Water flushing

Water flushing
  followed by
  sweeping
46 percent


69-0.231 Vc'd

96-0.263 Vc'd
Field emission measurement (PM-15)
12,000-cfm blower0

Reference 7, based on field measurement
of 30 ym particulate emissions

Field measurement of PM-15 emissions

Field measurement of PM-15 emissions
Reference 8, except as noted.   All  results based on measurements of air
 emissions from industrial paved roads.   Broom sweeping measurements
.presented in Section 2.3.2.1.
 PM10 control efficiency can be assumed  to be the same as that tested.
^Water applied at 0.48 gal/yd*.
 Equation yields efficiency in  percent,  V = number of vehicle passes since
 application.
        TABLE 2-5.  ESTIMATED PM10 EMISSION CONTROL EFFICIENCIES3

                                                            Estimated PM10

         Method                                             efficiency,  %
Vacuum sweeping
                                                34
Improved vacuum sweeping1
                                                37
Reference 6.  Estimated  based  on  measured  initial  and  residual  <63  urn
 loadings on urban paved  roads  and Equation  (2-1).  Value  reported
 represents the mean of 13  tests for  each method.   Broom sweeping mean
 (18 tests) given in Section  2.3.2.1.
 Sweeping improvements described in Reference  6.
                                   2-7

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the surface loadings decrease.   Because mitigative measures are  less
effective for public paved roads, a recent EPA draft urban dust  policy
stresses the importance of preventive measures, especially in instances
where no dominant or localized  source of road loading can be identified.
Example sources would include:   (1) unpaved areas adjacent to the road;
(2) erosion due to storm water  runoff; and (3) spillage, from passing
trucks.  Corresponding examples of preventive measures include:
(1) installing curbs, paving shoulders, or painting lines near the edge of
the pavement; (2) controlling storm water or using vegetation to stabilize
surrounding areas; and (3) requiring trucks to be covered and to maintain
freeboard (i.e., distance between top of the load and top of truck bed
sides).  In instances where the source of loading can be easily identified
(e.g., salt or sand spread during snow or ice storms) or the effects are
localized (e.g., near the entrance to construction sites or unpaved
parking lots), either preventive or mitigative measures could be
prescribed.  Table 2-6 summarizes Agency guidance on nonindustrial paved
road preventive controls.
     There are few efficiency values for any of the preventive measures
presented in Table 2-6..  Because these measures are designed to prevent
deposition of additional  material  onto the paved  surface,  quantitative
measurements before and after the control  are generally not possible and
interpretation of results are complicated.   For example,  based  on ambient
TSP monitoring results over a 3-month period, immediate and continuous
manual cleaning of the access area to a construction site  was  estimated to
result in -30 percent control.1   It is unclear, however, what  effect
seasonal variation in the monitoring data  has on  the estimate  of
30 percent.  Also, because this  estimate is  based  on ambient  air
concentrations, use of the value may be inconsistent with  the other  effi-
ciency estimates given in this  chapter.  Consequently,  one very  important
further development deals with  efficiency  estimates  for preventive
measures.
     A recent update of AP-42 Chapter 11.2  (Fugitive Dust  Sources)--
compared measured controlled  emissions  with  estimates based on the reduced
loading values, using the industrial  paved road model presented in the
next section.2  Despite the fact that  the  reduced  surface  loadings were
                                 2-8

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 TABLE  2-6.   NONINDUSTRIAL  PAVED  ROAD  DUST SOURCES  AND PREVENTIVE CONTROLS
    Source of deposit on road
         Recommended  controls
— Sanding/salt
— Spills from haul  trucks
   Construction carryout  and
     entrainment
   Vehicle entrainment from
     unpaved adjacent areas

   Erosion from stormwater washing
    -onto streets
   Wind erosion from  adjacent
     areas
-- Other
— Make more effective use  of
     abrasives through planning,
     uniform spreading, etc.
— Improve the abrasive material
     through specifications  limiting
     the amount of fines and material
     hardness, etc.
~ Rapid cleanup after streets become
     clear and dry

~ Require trucks to be covered
~ Require freeboard between load and
     top of hopper
— Wet material being hauled

— Clean vehicles before entering road
— Pave access road near site exit
— Semicontinuous cleanup of exit

-- Pave/stabilize portion of unpaved
     areas nearest to paved road

— Storm water control
~ Vegetative stabilization
— Rapid cleanup after event

~ Wind breaks
— Vegetative stabilization or
     chemical  sealing of ground
~ Pave/treat parking areas, drive-
     ways, shoulders
~ Limit traffic or other use that
     disturbs soil  surface

— Case-by-case determination
                                   2-9

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often outside the range of the underlying data base, predictive accuracy
was found to be quite good, both for vacuum sweeping and water flushing.
For those two controls, the available data suggest that adequate estimates
of controlled emission can be obtained from the predictive models.  For
flushing combined with broom sweeping, however, the estimates
substantially overpredicted (by approximately a factor of 5) controlled
emissions versus the measured values.
2.2  INDUSTRIAL PAVED ROADS
     As noted earlier, emission estimation for paved roads depends less
upon its ownership and more upon its surface material and traffic
characteristics.  In this manual, the term "industrial" paved road is used
to denote those roads with higher surface loadings and/or are traveled by
heavier vehicles.  Consequently, some publicly owned roads are better
characterized as industrial in terms of emissions.  Examples would include
city streets in heavily industrialized areas or areas of construction as
well as paved roads in industrial complexes.
2.2.1  Estimation of Emissions
     The current AP-42 PM10 emission factor for industrial  paved  roads
                        e = 220 (sl_/12)o.3 (g/VKT)
                                                                     (2-3)
                      e = 0.77 (sL/0.35)°.3 (Ib/VMT)

where:   e = emission  factor,  in  units given  above
        sL = surface silt loading, g/m2  (oz/yd2)
The above equation is  rated "A"  in AP-42  (see Appendix A).
     Alternatively,  AP-42 presents a single-valued emission  factor  for use
in lieu of Equation  (2-3) for  PM10 emissions  from light-duty vehicles  on
heavily loaded industrial roads:

                              e = 93 (g/VKT)
                                                                     (2-4)
                            e = 0.33 (Ib/VMT)
                                 2-10

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where e is as defined above.  These  single-valued  emission factors are
rated "C" (see Appendix A).  Although no  hard  and  fast  rules can be
provided, Table 2-7 summarizes  a  recommended decision process for
selecting industrial paved road emission  factors.
     Table 2-8 presents a summary of silt loading  values  for industrial
paved roads associated with a variety of  industries.  As  is  the  case with
all AP-42 Chapter 11.2 emission models, the use of site-specific data  is
strongly recommended.
2.2.2  Demonstrated Control Techniques for Industrial Paved  Roads
     As noted in Section 2.1.2, the vast  majority  of measured  control
efficiency values for paved roads are based on data from  industrial
roads.  Consequently, the information presented earlier in Table 2-4 is
more applicable to this class of  road.
     Mitigative measures may be more practical for industrial  plant roads
because (1) the responsible party is known; (2) .the roads may  be subject
to considerable spillage and carryout from unpaved areas; and  (3) all
affected roads are in relatively  close proximity,  thus allowing  a more
efficient use of cleaning equipment.  Preventive measures, of  course, can
be used in conjunction with plant cleaning programs and prevention is
probably the preferred approach for city  streets in industrialized areas
with many potential  sources of paved road dust.  As before, the  lack of
efficiency values for preventive measures remains an important data gap
and requires further investigation.
2.3  EVALUATION OF ALTERNATIVE CONTRutTMEASURES
2.3.1  Preventive Measures
     These types of control measures prevent the deposition of additional
material's on a paved surface area.  As  a result, it is difficult to
estimate their control effectiveness.  For mitigative controls, before  and
after measurement (of surface loadings  or of particulate emissions)  is
possible; clearly, this is not the case  for preventive measures.   Limited
field data suggest that a 12-month construction project  (without preven-
tion programs) could result in an additional  18 tons/yr  of TSP emissions
from an adjacent paved road with 1,000  vehicle  passes  per  day.9  In  this
instance, one would  expect that PM10 emissions  would  increase by approxi-
mately 10 tons/yr.  As noted before, however,  field data available to
                                 2-11

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 TABLE 2-7.  DECISION RULE FOR PAVED ROAD EMISSION ESTIMATES

Silt loading              Average vehicle
(sL), g/m2                weight (W),  Mg          Use model
SL <2
SL <2
sL>2d
2 15a
W
W
W
W
W
> 4
< 4
> 6
< 6
< 6
Equation (2-3)
Equation (2-1)
Equation (2-3)
Equation (2-3)
Equation (2-4)
aFor heavily loaded surfaces  (i.e.,  sL > -300 to 400 g/m2, it
 is recommended that the resulting  estimate be compared to
 that from the unpaved  road models  (Section 3.0 of this
 manual), and the smaller of  the  two values used.
                             2-12

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                          TABLE  2-8.   INDUSTRIAL PAVED ROAD SILT LOADINGS*
Industry
Copper smelting
Iron and steel
production
Asphalt batching
Concrete batching
Sand and gravel
processing
No. of
sites
1
6
1
1
1
No. of
samples
3
20
3
3
3
Silt, percent
Range
[15.4-21.71
1.1-35.7
(2.6-4.61
(5.2-6.0)
(6.4-7.91
w/w
Mean
(19.01
12.5
(3.31
(5.51
(7.11
No. of
travel
lanes
2
2
1
2
1
Silt loading^
Range
[188-4001
0.09-79
[76-1931
[11-121
[53-951
g/m2
Mean
[2921
12
(120J
(121
[70]
Reference 3.  Brackets indicate values based on only one plant visit.

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estimate the effectiveness of preventive programs are extremely  limited
and often difficult to interpret.  This data gap requires further
development.
     Instead of assigning control effectiveness values for preventive
measures, regulatory personnel  may choose to require all responsible
parties (e.g., general contractors, street departments spreading salt  and
sand, businesses/homeowners with unpaved parking lots and driveways) to
either submit control plans or  agree to agency-supplied programs.  Note
that frequent watering of access areas should be discouraged  (if possible)
because that practice may compound carryout problems.
     As early as 1971, EPA recommended reasonable mud/dirt carryout
precautions including:
     •  Watering or use of suppressants at construction/demolition, road
grading, and 1'and clearing sites.
     •  Prompt removal of materials deposited upon paved roadways.
     •  Covering of open trucks transporting material likely to become
airborne.
While most states have adapted  many of EPA's recommendations to their own
regulations, the vast number-and spatial-distribution of potential
mud/dirt carryout points, as well as the large number of potentially
responsible parties, make enforcement very difficult to  plan and
administer.  Consequently, smaller jurisdictive areas (such  as cities and
counties) should be used in monitoring carryout enforcement.
     Note that these local agencies include several  other than those
involved in air pollution per se.  For example, building permits may be
used to require carryout controls with building inspectors enforcing the
regulations.  Finally, it is clear that some agreement with  the local
public works department would be necessary to implement  modifications  in
street sal ting.and sanding procedures or to ensure prompt cleanup (see
Appendix G).
     2.3.1.1  Salting/Sanding for Snow and Ice.  After winter snow  and  ice
control programs, the heavy springtime street loadings found- in certain
areas of the country are known  to adversely affect ambient PM10
concentrations.   For example, data collected in Montana  indicates that
road sanding may produce early  spring silt loadings  5 to 6 times  higher
                                 2-14

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than the mean loadings in Table 2-2.3   Because that  increase corresponds
to roughly a fourfold increase in the emission level,  it  is  clear that
residual surface loadings represent  an  important source potentially
requiring control.  As indicated in  Table 2-6, appropriate controls may
include:  (a) clean-up as soon as practical, (b) the use  of  improved
materials, and (c) improvements in planning or application methods.   Note
that option (a) uses mitigative controls which are discussed in
Section 2.3.2.  The preventive options  are discussed below.
     Some municipalities have experimented by supplementing  or replacing
their usual snow/ice control materials  with other harder  and/or coarser
materials.  Because the choice of usual materials is based upon local
availability (salt, sand, cinders) and  price, it is clear that changes  in
materials applied will generally result in higher costs.  However,  the  use
of antiskid materials with either a  lower initial silt content or greater
resistance to forming silt-size particles will  result in  lower road
surface silt loadings.  Only limited field measurements comparing
resultant silt contents and no measurements of silt loading  values have
been identified; consequently, it is not possible at this time to
accurately estimate the control efficiency.afforded by .use of improved
materials.  Local agencies should design small-scale sampling programs
(using the paved road sampling method presented in Appendix D) to estimate
the differences in resulting silt loadings and  then apply Equation (2-1)
to determine a control efficiency value appropriate for their situation.
     Improvements in planning and application techniques limit the amount
of antiskid material applied to roads in an area.  As was  the case with
improved materials, no field data are known to  exist.   However,  an
adequate estimate of area wide control  efficiency can be obtained  by
(a) comparing the amounts of material applied,  (b)  assuming  that  both
applications are equally subject  to formation of  fines,  removal,  etc.,
(c) assuming that both resultant  silt loadings  are  substantially greater
than the "baseline" (i.e.,  prewinter) value,  and  (d)  using
Equation (2-1).   For example, if  a community, through  better  planning,
uses 30% less antiskid material,  than the  resultant  silt  loadings  may be
expected to be 30% lower.  Use of Equation (2-1)  would  then  indicate an
effective PM10 control  efficiency of  24.8%.   Note that  if  assumption (c)
                                 2-15

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above does not hold, the estimated control efficiency should  be  viewed
only as an upper bound.
     2.3.1.2  Carryout from Unpaved Areas and Construction Sites.   Mud  and
dirt carryout from unpaved areas such as parking lots, construction sites,
etc., often accounts for a substantial  fraction of paved road silt
loadings in many areas.  The elimination of this carryout can
significantly reduce paved road emissions.
     As noted earlier, quantification of control efficiencies for
preventive measures is essentially impossible using the standard
before/after measurement approach.  The methodology described below
results in upper bounds of emission reductions.  That is, the control
afforded cannot be easily described in  terms of percent but rather  is
discussed in terms of mass emissions prevented.
     Furthermore, tracking of material  onto a paved road results in
substantial spatial variation in loading about the access point.  This
variation may complicate the modeling of emission reductions as well as
their estimation, although these difficulties become less important as the
number of unpaved areas in an area and  their access points become larger.
     For an individual access point from an unpaved area to a paved road,
let N represent the daily number of vehicles entering or leaving the
area.  Let E be given by:

                          5.5 g/vehicle for N < 25
                     E = {
                          13 g/vehicle  for N > 25

where E is the unit PM10 emission  increase in g/vehicle  (see
Section 5.1).  Finally, if M represents the  daily number of  vehicle passes
on the paved road,  then the net  daily emission reduction (g/d)  is given  by
E x M, assuming complete prevention.
     The emission reduction calculated  above assumes  that  essentially all
carryout from the unpaved area is  controlled and,  as  such,  is  viewed as  an
upper limit.  In use,  a regulating  agency  may  choose  to  assign an
effective level of  carryout control  by  using some  fraction of  the E  values
given above to calculate an emission  reduction.   Also, the regulatory
                                 2-16

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agency could choose a percent control efficiency and  substantiate
compliance with testing data.
     The methods used to control carryout consist of  either mitigative
measures on the paved road or preventive measures at  the unpaved area or
construction site.  Discussion of these measures are  presented  in
Sections 2.3.2, 3.3, and 5.3.
     Finally, field measurements of the increased paved silt loadings
around unpaved areas may also be used to gauge the effectiveness of
control programs.  A discussion of this is found in Section 2.5.
     2.3.1.3  Other Preventive Control Measures.  As  shown in Table 2-6,
numerous other preventive controls have been proposed for certain sources
of paved road silt loadings.  These controls range from wind fences in
desert regions to keep sand off highways and other roads to measures
designed to prevent losses of materials transported in trucks.  No data
are known to exist that quantify the PM10 emission reductions attributable
to these controls.  It is recommended that, if the use of one or more of
these controls is contemplated in an area, the local control  agency design
small-scale field tests of the surface loadings (as.described in
Appendix D) before and after implementation to determine a reasonable
estimate of the efficiency.  Note that, in the design of any  program of
that type, particular attention must be paid to spatial  variations  in both
sources and controls applied.  For example,  while a program for wind
fences in desert areas would present few complications in assessing
control, a program to assess the impact of,  say,  storm water  control  or
haul truck restrictions,  must include provisions  for the localized  (and
possibly, random) nature  of the source and its effects on surrounding
roads.
2.3.2  Mitiqative Measures
     While preventive measures are to be preferred  under the  EPA urban
dust policy, some sources of road dust loadings may  not  be  easily
controlled by prevention.   Consequently, some  mitigative measures may be
necessary to achieve desired goals.   This  section discusses demonstrated
mitigative measures.                                             -
                                 2-17

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     2.3.2.1  Broom Sweeping of Roads.  Mechanical street cleaners  employ
rotary brooms to remove surface materials from roads and parking  lots.
Much of their effect is cosmetic, in the sense that, while the roadway
appears much cleaner, a substantial fraction of the original loading  is
emitted during the process.  Thus, there is some credence to claims that
mechanical cleaning is as much a source as a control of particulate
emissions.  Note, however, that mechanical sweeping may be the only viable
option for rapid cleanup of antiskid materials throughout the snow  season.
     Measurement-based control efficiency for industrial roads (Table 2-4)
and estimated efficiencies for urban roads (Table 2-5) both indicate a
maximum (initial) instantaneous control of roughly 25 to 30%.  Efficiency,
of course, can be expected to decrease after cleanup.
     Cost elements involved with broom sweeping include the following
capital and operating/maintenance (O&M) expenses:
     Capital:  Purchase of truck or other device
     O&M:  Fuel, replacement brushes, truck maintenance, operator labor
     Cost data presented in Reference 10 provides the following estimates
for a broom sweeping program:
     Initial capital expense:  6,580 to 19,700 $/truck
     Annual O&M expense:  27,600 $/truck
     All costs are based on April 1985 dollars.   Determination  of the
number of trucks can be based on an assumption that 3 to. 5  mi of  road can
be cleaned per unit per shift.11  Additional  cost data for  a broom
sweeping program is provided in Table 2-9. ^
     Enforcement of a broom sweeping dust control  program would  ideally
consist of two complementary approaches.  The first facet would require
the owner to maintain adequate records that would  document  to agency
personnel's satisfaction that a regular cleaning  program is  in  place.
(See Appendix C for a suggested recordkeeping format.)   The  second
approach would involve agency spot checks of  controlled  roads by  taking a
material sample from the road.   The latter  approach is discussed  in
Section 2.5.  The sampling method should be essentially  the  same  as  that
used in the development of the current AP-42  predictive  equations.   As
noted earlier, an estimate of the controlled  PM10  emission  level  could
then be obtained.2
                                 2-18

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       TABLE 2-9.  MISCELLANEOUS OPERATION/DESIGNaAND COST DATA FOR
                       BROOM SWEEPING PAVED ROADS


Purchase price:                                    $18,000 (1978)
                                                   $20,000 (1980)

Estimated life expectancy:                          5 yr

Approximate annual  operating cost during 1981:     $65,100—No. 1
                                                   $57,000—No. 2

Fuel consumption:                                  3 mi/gal

Cleaning capacity:                                  69,700 ftVh at 3 mph

Vehicle weight:                                    5,000 Ib

Width of area cleaned per pass:.                    7.5 ft

Normal sweeping speed:                              3 to  5 mile/h

Reference 11.  Purchase  cost is  actual  cost in year purchased; other
  costs in 1981 dollars.
                                   2-19

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     Records must be kept that document the frequency of  broom sweeping
applied to paved surfaces.  Pertinent parameters to be specified in a
control plan and to be regularly recorded include:
     General Information to be Specified in the Plan
     1.  All road segments and parking locations referenced on a map
available to both the responsible party and the regulatory agency
     2.  Length of each road and area of each parking lot
     3.  Type of control applied to each road/area and planned frequency
of application
     4.  Any provisions for weather (e.g., % in of rainfall will  be
substituted for one treatment)
     Specific Records for Each Road Segment/Parking Area Treatment
     1.  Date of treatment
     2.  Operator's initials (note that the operator may keep  a  separate
log whose information is transferred to the environmental staff's data
sheets)
     3.  Start and stop times on a particular segment/parking  lot,  average
speed, number of passes
     4. ' Qualitative description of loading before and after treatment
     5.  Any areas of unusually high loadings,  from spills, pavement
deterioration
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological log (to the extent that weather  influences the
control program—see above)
     3.  Any equipment malfunctions or downtime.
     In addition to those items related to control  applications, some of
the regulatory formats suggested in Section  2.5 require  that  additional
records be kept.  These records may include  surface material  samples or
traffic counts.   A suggested format for recording  paved  surface samples
(following the sampling/analysis procedures  given  in Appendices D and E)
is presented as  Figure 2-1.   Traffic counts  may be  recorded either
manually or using automatic devices (low frequency,  I/season,  1/yr).
                                 2-20

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Type of Materiel Sampled: ___^_^_
Site of Samplir.c: _	,	
Tvoe of ?aveme~-.r:  Asohoir/Concrefe
 No. cr Trcrfic  Lanes
.Surface Condition 	
i
Sample No. j Vac. Sag




• I
i




I
i
i
. ! .
i

Time















^occficn*








•


•



• 3 room
; Sweot?
Sample Area (y/n)










'• i
. ; i
i
; j
; i
   *'Jse  code  :iven on plant map for segment icer.fification  and  indicate sample
     iocatior.  cr, mao.
                Figure 2-1.   Example  paved  road  sample  log.
                                        2-21

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     2.3.2.2  Vacuum Sweeping of Roads.   Vacuum sweepers remove material
from paved surfaces by entraining particles in a moving air stream. A
hopper is used to contain collected  material and air exhausts through  a
filter system in a open loop. A regenerative sweeper functions in much the
same way, although the air is continuously recycled.  In addition to the
vacuum pickup heads, a sweeper may also  be equipped with gutter and other
brooms to enhance collection.
     Instantaneous control efficiency (cf. Appendix A) values were given
earlier in Table 2-4.  Available data show considerable scatter, ranging
from a field measurement showing no  effectiveness (over baseline
uncontrolled emissions) to another field measurement of 58 percent.  An
average of the field measurements would  indicate a efficiency of
34 percent.  In addition, the estimated  upper limits for PM10 control  of
urban roads (Table 2-5) compare fairly well  with that average.  Recall
that very adequate controlled emission estimates were obtained using the
industrial paved road model  given as  Equation (2-3).  It is recommended
that material loading samples be employed, if possible,  in conjunction
with the model to obtain a better estimate of control  effectiveness.
     Cost elements involved  with vacuum  sweeping include the following
capital and operating/maintenance (O&M)  expenses:
     Capital:  Purchase of truck or other device
     O&M:  Fuel, replacement parts, truck maintenance,  operator  labor cost
data presented in Reference  10  provides  the  following  estimates  for a
vacuum sweeping program
     Initial capital expense:   36,800  $/truck
     Annual O&M expense:   34,200 $/truck
     All costs are based  on  April  1985 dollars.   Determination of  the
number of trucks necessary can  be  made by assuming  that  6 mi  can be  swept
per unit per 12 h.11  Additional  cost  data for a  broom  sweeping program is
provided in Table 2-10.
     Enforcement of  a vacuum sweeping  dust control  program would ideally
consist of two complementary approaches.   The first  facet would require
the owner to maintain adequate  records that would document to  agency
personnel's satisfaction  that a  regular cleaning program is  in place.
(See Appendix C for  a suggested  recordkeeping format.)  The  second
                                 2-22

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       TABLE  2-10.   MISCELLANEOUS OPERATION/DESIGNaAND COST DATA FOR
                       VACUUM SWEEPING PAVED ROADS
Purchase price:                                    $72,000 (1980)
Estimated life expectancy:                         5 yr
Approximate annual  operating cost during 1981:     $214,000
Fuel consumption:                                   4 mi/gal
Hopper capacity:                                   10 yd3
Vacuum blower capacity:                            12,000 ft3/min
Vehicle weight:                                    32,000 Ib
Width of area cleaned per pass:b                   5 ft
Normal sweeping speed:                             5 mi/h
Velocity at suction head:                          N/A
Type of dust control system (i.e., wet or dry):     Wet
Reference 11.  Purchase cost is actual cost in  year purchased;  other
 costs in 1981 dollars.    _
Multiple passes required.
                                   2-23

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approach would involve agency spot checks of controlled roads by  taking a
material sample from the road. As before, the second approach is  discussed
in greater detail in Section 2.5.  Note that some sample collection may be
necessary to estimate control performance.
     Records must be kept that document the frequency of vacuum sweeping
paved surfaces.  Pertinent parameters to be specified in a control plan
and to be regularly recorded include:
     General Information to be Specified in the Plan
     1.  All road segments and parking locations referenced on a map
available to both the responsible party and the regulatory agency
     2.  Length of each road and area of each parking lot
     3.  Type of control applied to each road/area and planned frequency
of application
     4.  Any provisions for weather (e.g., ^ in of rainfall will be
substituted for one treatment; no sprays during freezing periods, etc.)
     Specific Records for Each Road Segment/Parking Area Treatment
     1.  Date of treatment
     2.  Operator's initials (note that the operator may keep a separate
log whose information is transferred to the environmental  staff's data
sheets)
     3.  Start and stop times on a particular segment/parking lot, average
speed, number of passes
     4.  Qualitative description of loading before and  after treatment
     5.  Any areas of unusually high loadings,  from spills, pavement
deterioration, etc.
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological log (to the extent that weather  influences the
control program—see above)
     3.  Any equipment malfunctions or downtime
     In addition to those items related to control  applications,  some  of
the regulatory formats suggested in Section 2.5 require  that  additional
records be kept.  These records may include surface material  samples or
traffic counts.  A suggested format for recording  paved  surface  samples
(following the sampling/analysis procedures  given  in Appendices  D  and  E)
                                 2-24

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was presented  in Figure 2-1.  Traffic counts may  be  recorded  either
manually or using automatic devices.
     2.3.2.3   Water Flushing of Roads.  Street  flushers  remove  surface
materials from roads and parking lots using high  pressure water sprays.
Some systems supplement the cleaning with  broom sweeping after  flushing.
Note that the  purpose of the program is to remove material  from the road
surface; in some industries, water is regularly applied to  roads to
directly control emissions (i.e., as in unpaved roads).  Unlike the two
sweeping methods, flushing faces some obvious drawbacks in  terms of water
usage, potential water pollution, and the  frequent need to  return to the
water source.  However, flushing generally  tends to be more  effective in
controlling particulate emissions.
     Equations to estimate instantaneous control efficiency values  are
given in Table 2-3.  Note that water flushing and flushing  followed  by
broom sweeping represent the two most effective control methods  (on  the
basis of field emission measurements) given in  that table.
     Cost elements involved with broom sweeping include the following
capital and operating/maintenance (O&M) expenses:
     Capital:  Purchase of truck or other device
     O&M:  Fuel, replacement parts (possibly including brushes), truck
maintenance, operator labor, water
     Cost data presented in Reference 10 provides  the following  estimates
for a flushing program;
     Initial capital  expense:   18,400 $/truck
     Annual O&M expense:  27,600 $/truck
All costs are  based on April  1985 dol'lars.   Determination of the number of
trucks required can be based on the assumption  that 3 to  5 mi  can be
flushed or flushed and broom swept per unit per 8-h shift,
respectively.11  Additional  cost/design data are provided as Table 2-11.
     Enforcement of a road flushing (possibly supplemented  by  broom
sweeping) program could consist of two approaches, as before.  The first
facet would require the owner  to maintain  adequate records  that  would
document to agency personnel's  satisfaction that a regular  cleaning
program is in place.   (See Appendix C for  a suggested recordkeeping
format.)  The second  approach would involve agency spot checks of
                                 2-25

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       TABLE  2-11.   MISCELLANEOUS  OPERATION/DESIGN AND COST DATA FOR
                          FLUSHING PAVED ROADS
Purchase price:
Estimated life expectancy:
Approximate annual operating cost during 1981:
Vehicle weight (dry):
Water tank capacity:
Normal vehicle speed:
Water pressure at nozzles:
Vehicle weight (wet):
Fuel consumption:
Water flow at nozzles:
Hopper capacity:
Daily water consumption:
Degree of water treatment:
$68,000  (1976)
10 yr
$57,000
N/A Ib
8,000 gal
4 mi/h
50 psig
N/A Ib
7 mi/gal
188 gal/min
40 yd3
30,000 gal
1,800 gal/mi,
Reference 11.  Purchase cost  is  actual  cost  in  year purchased; other
 costs in 1981 dollars.
                                   2-26

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controlled roads by taking a material sample from the  road.   Recall  that,
while resulting estimates of controlled emissions should  be  adequate for a
flushing program, the estimates are probably substantially overestimated
in a flushing/broom sweeping program.
     Records must be kept that document the frequency  of  broom sweeping
applied to paved surfaces.  Pertinent parameters to be specified  in  a
control plan and to be regularly recorded include:
     General Information to be Specified in the Plan
     1.  All road segments and parking locations referenced  on a  map
available to both the responsible party and the regulatory agency
     2.  Length of each road and area of each parking  lot
     3.  Type of control applied to each road/area and planned frequency
of application
     4.  Provisions for weather (e.g., program*suspended for periods  of
freezing temperatures)
     Specific Records for Each Road Segment/Parking Area Treatment
     1.  Date of treatment
     2.  Operator's initials (note that the operator may keep  a separate
log whose information is transferred to the environmental staff's data
sheets)                                             .
     3.  Start and stop times on a particular segment/parking  lot, average
speed, number of passes
     4.  Start and stop times for refilling tanks
     5.  Qualitative description of loading before and  after treatment
     6.  Any areas of unusually high loadings,  from  spills,  pavement
deterioration, etc.
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological  log (to the extent  that  weather influences the
control program—see above)
     3.  Any equipment malfunctions or downtime
     In addition to those items related  to  control applications, some of
the regulatory formats suggested in Section  2.5  require that  additional
records be kept.  These  records may include  surface  material  samples  or
traffic counts.  A suggested  format for  recording  paved surface samples
                                 2-27

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(following the sampling/analysis procedures given in Appendices D  and  E)
was presented in Figure 2-1.   Traffic counts may be recorded either
manually or using automatic devices.
2.4  EXAMPLE DUST CONTROL PLAN
     To illustrate the use of material in this chapter, this section
presents an example control plan.   Unlike the other open dust sources
considered in this manual, preventive control of paved roads (and
especially public paved roads) requires that control be applied to a wide
variety of contributing loading sources.   Furthermore, the contribution of
any individual loading source to the  total  silt loading on any roadway is,
at present, impossible to determine.   Consequently, the approach taken in
this example will employ area wide silt loading reductions and will also
use limited field sampling to gauge the effectiveness of the program.
     Suppose a control agency determines  that a 10% decrease in urban
paved road emissions is necessary  to  meet some goal.  Equation (2-1) shows
that a 10 prcent decrease in  the PM10 emission factor requires (a) a
10 percent reduction in traffic volume, (b)  a 12% decrease in silt
loading, or (c) some combination of traffic  and silt loading reductions.
Suppose that traffic reductions are not considered .feasible and. suppose
further that the agency desires a  uniform 12 percent decrease in area wide
silt loadings rather than staggering  loading decreases as  a function of
road lengths and traffic volumes.
     The types of controls that could be  applied to loading sources
include:  use of improved antiskid materials,  rapid cleaning of snow/ice
control methods, haul truck ordinances (e.g.,  covering,  freeboard, etc.),
and paving unpaved access points.   Selection of sources  to be controlled
depend on a variety of factors,  such  as the  perceived  relative
contribution of a source to an area's silt  loading values,  responsibility
for enforcement of any new ordinances,  etc.
     In general, unless there is good reason to suspect  that one  source
category is responsible for a substantial fraction of  the  paved  road
loading in an area, it is probable that a series  of  controls will  be
employed (see Section 2.5.2).   Assessment of the  (combined)  effectiveness
of the controls implemented will generally be  based  on the  field  sampling
measurements discussed in Appendices  D  and E.
                                 2-28

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2.5  POTENTIAL REGULATORY FORMATS
2.5.1  General Guidelines
     Clear and specific enforceable plan provisions are needed to gain
credit for claimed emission reductions in State implementation plans
(SIP's), which for paved road dust sources will likely rely on record-
keeping, reporting, and surrogate factors rather than short-term mass
emissions or opacity limits.  Surrogate factors will include control
program regulations, permits, or intergovernmental agreements to institute
programs such as vacuum sweeping, mud/dirt carryout precautions, spill
cleanup, erosion control, and/or measures to prevent or mitigate
entrainment from unpaved adjacent areas.  Record review of control
programs (e.g., vacuum sweeping, road sand/salt application, etc.) and
field checks (i.e., road silt loading sampling) will provide the likely
means of compliance determination for these sources.  Because paved road
emissions are directly related to the surface silt loading, the most
reliable regulatory formats are based on loading.   Formats viable for
other open dust sources—including opacity measurements, visible emissions
at the property line—are generally not applicable for paved roads because
of the lower unit emission.levels involved (e.g.,  there are usually no
visible plumes from a vehicle pass).
     Many States currently have regulations related to the control  of
paved roads.  Colorado, for example,  may require a control plan from any
party that repeatedly deposits materials which might create fugitive
emissions from a public or private roadway.  Note, however, that  no
quantitative determination of loading levels is specified.
     An alternative format is presented below to suggest how a
quantitative method could be incorporated in a regulation.  Figure  2-2
presents a possible format for use with public paved road  sources.   In
this example, if the silt loading on  a road with an average traffic  volume
of 2,000 vehicles per day ever exceeds 2.9 g/m2 (the "action level"),  the
regulatory agency may require the responsible party (e.g., a construction
site with mud/dirt carryout) or the owner of the road  to reduce the  silt
loading to a level less than the action level.   The action level  is  an
agency-supplied multiple of  either baseline measurements or the surface
silt loading predicted by Equation (2-2)  and should correspond  to
                                 2-29

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INi
I
00
O
00
 E

 CD


 CD
 z
 I—I
 Q

 O
 _l

 I—
 _l
 t—4
 I/O

 UJ
 CJ

 u.
 o:

                                                                                        At higher
                                                                                        traffic levels,
                                                                                        cleaning becomes
                                                                                        impractical because
                                                                                        of safety.
                                                                       10,000

                                           DAILY TRAFFIC  VOLUME  (veh/day)
                                                                                                              100,000
                       Figure 2-2.  Possible use of  "action levels" to trigger paved  road  controls.

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minimum percent control efficiency level.  The means of  reduction  will  be
left to the discretion of the responsible party  and could  consist  of
either preventive or mitigative controls.  The maximum allowed  silt
loading requirement could be made part of a construction permit  (as
discussed in Section 5 of this manual) or an enforceable intergovernmental
agreement.  Note that additional traffic due to  the construction activity
should be included in the daily traffic volume used to determine the
action level for the affected roadways.  In addition, a request for permit
should be accompanied with a description of the  control technique(s) that
will be employed.  Similarly, intergovernmental  agreements should  clearly
and specifically describe control techniques and associated recordkeeping
and reporting requirements.
     The field measurement of silt loading could either be made a
requirement of the responsible party or be assigned to agency inspection
personnel, or a combination of the two could be used.  In either event,
certain features of the measurement technique must be specified:
     1.  The sampling method used to determine silt loading for compliance
inspection should conform to the technique used to develop the AP-42 urban
paved road equation.  That technique is specified in Appendix 0 and should
be made part of an SOP for regulatory personnel or part of the
construction permit.
     2.  Arrangements must be made to account for spatial variation of
surface silt loading.  Possible suggestions include (a)  visually
determining the heaviest loading on the road and selecting that spot for
sampling, (b) sampling the midpoint of the road length  segment of
interest, and (c) sampling preselected (possibly on the basis of safety
considerations) strips on the road surface (note that the samples may  be
aggregated).
     3.  Provision should be made to grant a "grace period" following  a
spill or other accidental increase in loading.   An 8-h  period is suggested
to allow time for the responsible party to clean the affected area. This
allowance should be made part of a construction or other  permit.
     For industrial paved roads, an approach  similar to that  described
above could be applied as well,  using agency-supplied action  levels.   Note
that these levels could be specific to individual roads,  apply to  all
                                 2-31

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 roads  in  a  plant,  or  be  based on  plant  traffic  levels.   Because most
 plants will  contain many roads, the  regulatory  agency may choose to set
 plant-wide  goals  (such as vacuum  sweeping  each  road  twice per week) rather
 than source-specific  programs.
     The  control  efficiency equations presented in Table 2-4 provide
 another potential  regulatory format  for industrial paved road sources.
 This approach  involves inspection of both  plant road cleaning records and
 traffic counts.   By combining the two sets of information,  regulatory
 personnel would be able  to determine average efficiency  values for the
 plant's controlled paved roads.   Provision must be made  to  collect traffic
 information.   The  traffic data may require more frequent inspection visits
 than surface loading  samples; however,  analysis is more  easily
 accomplished.  Surface loading sampling provides an  additional means for
 checking  the success  of  achieving the estimated control  efficiency.
 2.5.2  Example SIP Language for Reduction  of Public  Paved Road Surface
       Contaminants
     Public paved  roads  are important PM10 sources in areas  across the
 country.  Unlike  the  industrial sources described in this manual,  control
 of municipal  paved roads generally requires a close  working  agreement
 between various government bodies and the  general public.
     A number  of  States  have developed  enforceable regulations,  permit
 conditions,  or provisions  in intergovernmental  agreements (between State
 agencies, and  with municipalities) that attempt to address sources
 contributing to the silt loading  of  paved  roads.  The following  example
 regulations are drawn from existing  State  regulations and
'intergovernmental  agreement provisions.
     Material  Transport
     -- No  person  shall  cause or  permit  the handling or  transporting  of
        any material  in  a  manner  which  allows or may allow controllable
        particulate matter to become airborne.  Visible dust emissions
        from the transportation of materials must be eliminated  by
        covering stock loads in open-bodied trucks or other equivalently
        effective  controls.
     — Earth  or other material  that is deposited by trucking  and
        earth-moving equipment on paved streets  shall be reported  to  the
                                  2-32

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    (local Department of Sanitation  at 	)  and removed
    immediately subject to  safety considerations  by the party or
    person responsible for  such deposits.
Motor Vehicle Parking Areas
—  Effective 	, no person shall  cause, permit,  suffer,  or
    allow the operation, use, or maintenance  of an  unsealed  or unpaved
    motor vehicle parking area.
        Low use parking area exemption:  Motor vehicle parking area
    requirements shall not  apply to  any parking area from which less
    than 	 (e.g., 10) vehicles exit on each day.   Any person seeking
  .  such an exemption shall:  (1) submit a petition to  the Control
    Officer in writing identifying the location, ownership,  and
    person(s) responsible for control of the parking area, and
    indicating the nature and extent of daily vehicle use; and
    (2) receive written approval from the regulating agency  that a low
    use exemption has been  granted.
Erosion and Entrainment From Nearby Areas
—  The City of 	•     will revegetate, pave,  or treat by  using
   water, calcium chloride, or acceptable equivalent materials the
   following:   paved road  shoulders and approach aprons for unpaved
   roads and parking areas that connect to paved roads, which  are
   within the City's right-of-ways  or under the City's control and
   within X feet (e.g.,  25) of roadways [specify location or entire
   roads by name],  in amounts and  frequencies as is necessary to
   effectively control  PM10 emissions to a level  of x percent control
   efficiency (e.g.,  paving~90 percent;  vegetation per specified
   requirements—50 percent;  chemical  treatment per specified
   requirements—70 percent).   [Include  list  of roads in memorandum
   of understanding and  specify whether  those areas will be
   revegetated,  paved,  or treated.]
—  If loose sand,  dust,  or dust particles  are found to  contribute to
   excessive silt loadings on  nearby paved  roads,  the Control  Officer
   shall  notify the owner,  lessee,  occupant,  operator,  or user of
   said land that said  situation is  to  be  corrected within a
   specified period of  time, dependent upon the scope and extent  of
                            2-33

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   the problem, but in no case may such a period of time exceed x
   (e.g., 2) days.
        The Control Officer,  or a designated agent, after due notice,
   may enter upon the subject land where said sand or dust problem
   exists, and take such remedial and corrective action as may be
   deemed appropriate to relieve, reduce, or remedy the existent dust
   condition, where the owner, occupant, operator, or any tenant,
   lessee, or holder of any possessory interest or right in the
   subject land, fails to do  so.
        Any cost incurred in  connection with any such remedial or
   corrective action by the Control Officer shall  be assessed against
   the owner of the involved  property, and failure to pay the full
   amount of such costs shall result in a lien against said real
   property, which lien shall remain in full force and effect until
   any and all such costs shall  have been fully paid, which shall
   include, but not be limited to, costs of collection and reasonable
   attorney's fee therefore.
Road Sanding/Salting and Traffic  Reduction
-- The City of 	\	 will, beginning with the (year) winter
   season, restrict the use of sand used for anti  skid operations  to
   a material with greater than x percent (e.g., 95) grit retained by
   a number 100 mesh sieve screen and a degradation factor of x.
— The City of 	 will provide alternative traffic flow
   patterns—such as a by-pass plan to reduce vehicular traffic
   (especially truck traffic) in  the central  business district to
   reduce the effects of vehicular reentrainment.
-T. The City of 	  will  conduct its vacuum street sweeping
   throughout the year with wintertime sweeping  done whenever shaded
   pavement temperatures—as  determined by  the  use of infrared
   thermometer—allow for the application of  water  spray  from the
   vacuum sweeper without jeopardizing the safety of pedestrian  and
   vehicular traffic on the swept areas.   The street vacuuming
   program shall be designed  to provide for maximum sweeping  efforts
   throughout the winter and  spring months  and shall  provide  for
   adequate personnel  and equipment to ensure thorough cleanup when
                            2-34

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        possible within temperature and safety constraints.  As  soon  as

        temperature conditions permit (melt periods), the City will begin

        vacuuming the road sand/salt loadings from streets per the

        following priority schedule:  [include schedule in memo  of
        understanding],  (Quality control provisions for recordkeeping/

        reporting requirements are presented in Section 2.3.2.2  and

        Appendix C.2.1. of this report.)

2.6  REFERENCES FOR SECTION 2

 1.  Axetell, K., and J. Zeller.  1977.   Control of Reentrained  Dust  from
     Paved Streets.  U.S. Environmental  Protection Agency,
     EPA-907/9-77-007.

 2.  Muleski, G. E.  1987.  Update of Fugitive Dust Emission Factors  in
     AP-42 Section 11.2.  Final Report,  U.S. Environmental Protection
     Agency, Contract No. 68-02-3891, Work Assignment No.  19.

 3.  U.S. Environmental Protection Agency.  1985.  Compilation of Air
     Pollution. Emission Factors, AP-42.   U.S.  Environmental  Protection
     Agency, Research Triangle Park, North Carolina.

 4.  Cowherd, C., Jr., and P. J. Englehart.   1984.  Paved  Road Particulate
     Emissions.  EPA-600/7-84-077.  U.S. Environmental  Protection Agency,
     Washington, D.C.

 5,  Engineering-Science.  1987.  PM-10  Emissions Inventory  Data for the
     Maricopa and Pima Plannings Areas.   EPA Contract No.  68-02-3888,  Work
     Assignment No. 35.

 6.  Duncan, M., et al.  1984.  Performance  Evaluation  of  an Improved
     Street Sweeper.   EPA Contract No. 68-09-3902.

 7.  Eckle, T. F.,  and D. L.  Trozzo.  1984.  Verification  of the
     Efficiency of  a  Road-Oust Emission-Reduction Program  by Exposure
     Profile Measurement.  Presented at  an EPA/AISI Symposium on  Iron  and
     Steel Pollution  Abatement, Cleveland, Ohio.   October  1984.

 8.  Cowherd, C., Jr., and J. S.  Kinsey.  1986.   Identification,
     Assessment and Control of Fugitive  Particulate Emissions.
     EPA-600/8-86-023, U.S. Environmental  Protection  Agency,  Research
     Triangle Park, North Carolina.

 9.  Englehart, P.  J., and J. S.  Kinsey.  1983.   Study of  Construction
     Related Mud/Dirt Carryout.  EPA Contract No.  68-02-3177,  Work
     Assignment No. 21.  July 1983.

10.  Kinsey, J. S., et al.  1985.   Control Technology for  Sources of
     PM1(?.  Draft Final Report, EPA Contract No.  68-02-3891,  Work
     Assignment No. 4.  September  1985.
                                 2-35

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11.   Cuscino,  T.,  Jr.,  et al.   1983.   Iron  and  Steel  Plant Open Source
     Fugitive  Emission  Control  Evaluation,  EPA-600/2-83-110, U.S.
     Environmental  Protection Agency,  Research  Triangle Park, North
     Carolina.   October 1983.
                                2-36

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                            3.0   UNPAVED  ROADS

     As is the case for paved roads, participate emissions occur whenever
a vehicle travels over an unpaved surface.  Unlike paved roads, however,
the road itself is the source of the emissions rather than any "surface
loading."  Within the various categories of open dust sources in
industrial settings, unpaved travel surfaces have historically accounted
for the greatest share of particulate emissions in industrial settings.
For example, unpaved sources were estimated to account for roughly
70 percent of open dust sources in the iron and steel industry during the
1970's.  Recognition of the importance of unpaved roads led naturally to
an interest in their control.  As a result of these control programs, the
portion of total open source dust emissions due to unpaved travel surfaces
has decreased dramatically over the past 5 to 10 years.  Nevertheless, the
need for continued control of these sources is apparent.
     This section presents a discussion of the various types of unpaved
sources, available emission factors, viable control measures, and methods
to determine compliance of controlled sources.
     Travel surfaces may be unpaved for a variety of reasons.  Possibly
the most common type of unpaved road is that found in rural regions
throughout the country; these roads may experience only sporadic traffic
which, taken with the often considerable road length involved, makes
paving impractical.
     Other important travel surfaces are found in industrial  settings.
During the 1980's, industry has paved many previously unpaved roads as
part of emissions control programs.  Some industrial  roads  are,  by  their
nature, not suitable for paving.   These roads may be used  by very heavy
vehicles or may be subject to considerable spillage from haul  trucks.
Other roads may have poorly constructed bases wh:ich make paving
impractical.  Because of the additional maintenance costs  associated with
a paved road under these service  environments, emissions from these roads
are usually controlled by regular applications of water or  chemical  dust
suppressants.
     In addition to roadways,  many industries often contain important
unpaved travel areas.  Examples include scraper traffic patterns  related
                                  3-1

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to stockpile/reclaim activities in coal yards, compactor traffic  in  areas
proximate to lifts at landfills, and travel related to open storage  of
finished products (such as coil at steel plants).  These areas may often
account for a substantial fraction of traffic-generated emissions from
individual plants.  In addition, these areas tend to be much more
difficult to control than stretches of roadway (e.g., changing traffic
patterns make semipermanent controls impractical, increased shear forces
from cornering vehicles rapidly deteriorate chemically controlled
surfaces, chemical suppressants may damage raw materials or finished
products, etc.).
3.1  ESTIMATION OF EMISSIONS FROM UNPAVED ROADS
     As was the case for paved roads, unpaved roads may be divided into
the two classes of public and industrial.  However, for the purpose of
estimating emissions, there is no need to distinguish between the two,
because the AP-42 emission factor equation takes  source characteristics
(such as average vehicle weight and road surface  texture)  into
consideration:1

          F - n fil / Vf S^ r W 1  "  A     (365-p)
          t = 0.61 (^-) (— ; ( - )     (-)     _
                    12   48  .2.7      4  .     365
                                                                     (3-1)
          F   9 1  t  *\ f S\ A°*7     °"5
          E = 2.1 (— ) (— ) (-)
                                          _
                   12   30   3       4        365
where:  E = PM10 emission factor in units  stated
        s = silt content of road surface material,  percent
        S = mean vehicle speed,  km/h (mil/h)
        W = mean vehicle weight, Mg (ton)
        w = mean number of wheels (dimensionless)
        p = number of days with  >0.254:mm  (0.01 in.) of  precipitation
            per year
Using the scheme given in Appendix  A,  the  above equation is  rated  "A" in
AP-42.  Measured silt values  are given in  Table 3-1.  As is  the  case  with
all AP-42 emission factors, the  use of site-specific data is  strongly
encouraged.
                                 3-2

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                       TABLE 3-1.  TYPICAL SILT CONTENT VALUES OF SURFACE MATERIAL ON INDUSTRIAL
                                               AND RURAL UNPAVED ROADS3
I
CO
Industry
Copper smelting
Iron and steel production
Sand and gravel processing
Stone quarrying and processing
Taconite mining and processing

Western surface coal mining




Rural roads


Road use or
surface material
Plant road
Plant road •
Plant road
Plant road
Haul road
Service road
Access road
Haul road
Scraper road
Haul road
(freshly graded)
Gravel
Dirt
Crushed limestone
Plant
sites
1
9
1
1
1
1
2
3
3
2

1
2
2
Test
samples
3
20
3
5
12
8
2
21
10
5

1
5
8
Silt, weight
Range
15.9-19.1
4.0-16.0
4.1-6.0
10.5-15.6
3.7-9.7
2.4-7.1
4.9-5.3
2.8-18
7.2-25
18-29

NA
5.8-68
7.7-13
percent
Mean
17.0
8.0
4.8
14.1
5.8
4.3
5.1
8.4
17
24

5.0
28.5
9.6
        Note:   NA  -  Not  applicable
        Reference 1  (AP-42).

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     The number of wet days per year, p, for the geographical area of
interest should be determined from local climatic data.  Figure 3-1 gives
the geographical distribution of the mean annual number of wet days per
year in the United States.  Maps giving similar data on a monthly basis
are available from the U.S. Department of Commerce.2
     It is important to note that for the purpose of estimating annual or
seasonal controlled emissions from unpaved roads, average control
efficiency values based on worst case (i.e., dry, p = 0 in Equation (3-1))
uncontrolled emission levels are required.  This is true simply because
the AP-42 predictive emission factor equation for unpaved roads, which is
routinely used for inventorying purposes, is based on source tests
conducted under dry conditions.1  Extrapolation to annual average
uncontrolled (including natural mitigation)  emissions estimates is
accomplished by assuming that emissions are  occurring at the estimated
rate on days without measurable precipitation,  and conversely are absent
on days with measurable precipitation.  This assumption has never been
verified in a rigorous manner; however, MRI's experience with hundreds of
field tests indicate that it is a reasonable assumption if the source
operates on a fairly "continuous" basis.
     The uncontrolled emission factor for a  specific unpaved road will
increase substantially after a precipitation event as the surface dries.
However, in the absence of data sufficient to describe this growth as a
function of traffic parameters, amount of precipitation,  time of day,
season, cloud cover, and other variables, uncontrolled emissions are
estimated using the simple assumption given  above.   Prior MRI testing has
suggested that for unpaved travel areas, surface moisture levels
approximately twice that for dry conditions  afford  control  of roughly 75
to 90 percent.3  Between the dry, uncontrolled  moisture level (typically
<2 percent) and approximately 3 to 4 percent, a small  increase  in  moisture
content may result in a large increase in control  efficiency.  Beyond  this
point, control efficiency grows slowly with  increased  moisture  content.
These relationships are discussed in greater detail  in  the  following
section.
                                  3-4

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CO
I
cn
                                                                          0 SO 100 200  300 400  100
                                                                                                    110
                                                                                 MIUS
                    Figure 3-1.  Mean  annual number of days  with at least 0.01  in of precipitation.-'

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3.2  DEMONSTRATED CONTROL TECHNIQUES FOR UNPAVED ROADS
     There are numerous control options for unpaved travel  surfaces,  as
shown in Table 3-2.  Note that the controls fall into the three  general
categories of source extent reductions, surface improvements,  and  surface
treatment.  Each of these is discussed in greater detail in the  following
sections.
     Source extent reductions.  These controls either limit the  amount  of
traffic on a road to reduce the PM10 emission rate or lower speeds to
reduce the emission factor value given by Equation (3-1).  Examples could
include industrial plant bussing programs for employees, restriction of
roads to only certain vehicle types, or strict enforcement of  speed
limits.  In any instance, the control afforded by these measures is
readily obtained by the application of the equation.
     Surface improvements.  These controls alter the  road surface.  Unlike
surface treatments (discussed below), these improvements are largely "one-
shot" control methods; that is, periodic retreatments  are not normally
required.
     The most obvious surface improvement is,  of course, paving an unpaved
road.  This option is expensive and is probably most applicable to high
volume (more than a few hundred passes per day)  public roads and
industrial plant roads that are not subject to very heavy vehicles (e.g.,
slag pot carriers, haul trucks, etc.) or spillage of material  in
transport.  Clearly,  control  efficiency estimates can  be obtained by
applying the information of Section 2.0 of  this  manual;  this is discussed
in greater detail  in  Section  3.3.
     Other improvement methods cover the  road  surface  material  with
another material  of lower silt content  (e.g.,  covering a dirt  road  with
gravel  or slag,  or using a "road  carpet"  under ballast).  Because
Equation (3-1)  shows  a linear relationship  between  the emission factor  and
the silt content of the road  surface,  any reduction in the silt value  is
accompanied by  an  equivalent  reduction  in emissions.   This type of
improvement is  initially much  less  expensive than paving; however,  the
reader is cautioned that maintenance  (such  as  grading  and spot
reapplication of the  cover material)  may be required.
                                 3-6

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  TABLE 3-2.   CONTROL TECHNIQUES  FOR  UNPAVED  TRAVEL  SURFACESa
Source extent reduction:       Speed reduction
                              Traffic reduction

Source improvement:           Paving
                              Gravel surface

Surface treatment:            Watering
                              Chemical stabilization".
                                - Asphalt emulsions
                                - Petroleum resins
                                - Acrylic cements
                                - Other

aTable entries reflect EPA draft guidance on urban fugitive
.dust control.
DSee Table 3-3.
                           3-7

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     Finally, vegetative cover has been proposed as a surface  improvement
for low traffic volume roads.  Note, however, that because vehicle related
emissions would be quite low, this method is probably intended to control
wind erosion of the road surface.  As such, this technique is discussed  in
Section 5.0 of this manual.
     Surface treatments.  Surface treatment refers to those control
techniques which require periodic reapplications.  Treatments fall into
the two main categories of (1) wet suppression (i.e., watering, possibly
with surfactants or other additives), which keeps the surface wet to
control emissions, and (2) chemical stabilization, which attempts to
change the physical (and, hence, the emissions)  characteristics of the
roadway.  Necessary reapplication frequencies may range from several
minutes for plain water under hot, summertime conditions to several weeks
(or months) for chemicals.
     Water is usually applied to unpaved roads using a truck with a
gravity or pressure feed.  This is only a temporary measure, and periodic
reapplications are necessary to achieve any substantial  level  of control
efficiency.  Some increase in overall control efficiency is afforded by
wetting agents which reduce surface tension.
     Chemical dust suppressants (Table 3-3), on  the other hand, have much
less frequent reapplication requirements.  These suppressants  are designed
to alter the roadway, such as cementing loose material  into a  fairly
impervious surface (thus simulating a paved surface)  or  forming a surface
which attracts and retains moisture (thus simulating  wet suppression).
     Chemical dust suppressants are generally applied to the road surface
as a water solution of the agent.   The degree of control  achieved is  a
direct function of the application intensity (volume  of  solution per
area), dilution ratio, and frequency (number of  applications per unit
time) of the chemical applied to the surface and also depends  on the  type
and number of vehicles using the road.  Chemical  agents  have also been
proven to be effective as crusting agents for inactive storage piles  and
for the stabilization of exposed open areas and  agricultural fields.   In
both cases, the chemical  acts as a binder to reduce the  wind erosion
potential of the aggregate surface.   The use of  chemical  agents  to  control
these sources is discussed in other chapters of  this  manual.
                                 3-8

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                    TABLE 3-3.  CHEMICAL STABILIZERS3
C.
Type:  Bitumens

Product

AMS 2200, 2300®
Coherex®
Docal 1002®
Peneprime®
Petro Tac P®
Resinex®
Retain®

Type:  Salts

Product

Calcium chloride
Dowflake, Liquid Dow4
DP-10®
Dust Ban 8806®
Dustgard®
Sodium silicate

Type:  Adhesives

Product
            DLR-MS®
            300-1®
Acrylic
Bio Cat
CPB-12®
Curasol AK®
DCL-40A, 1801
DC-859, 875®
Dust Ban®
Flambinder®
Lignosite®
Norlig A, 12®
Orzan Series®
Soil Card®
                   1803®
                                Manufacturer

                                Arco Mine Sciences
                                Witco Chemical
                                Douglas Oil Company
                                Utah Emulsions
                                Syntech Products Corporation
                                Neyra Industries, Inc.
                                Dubois Chemical Company
                                Manufacturer

                                Allied Chemical  Corporation
                                Dow Chemical
                                Wen-Don Corporation
                                Nalco Chemical  Company
                                G.S.L. Minerals  and Chemicals Corporation
                                The PQ Corporation
Manufacturer

Rohm and Haas Company
Applied Natural Systems, Inc.
Wen-Don Corporation
American Hoechst Corporation
Calgon Corporation
Betz Laboratories, Inc.
Nalco Chemical Company
Flambeau Paper Company
Georgia Pacific Corporation
Reed Lignin, Inc.
Crown Zellerbach Corporation
Walsh Chemical
aSource:  Reference 4, as cited by Reference 5.
                                  3-9

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     Finally, note that some chemical dust suppressants may  contain a
considerable fraction of hydrocarbons.  While these mixtures  are  generally
not very volatile, regulators in areas with ozone problems should balance
the benefits of dust control with the cost of a potential VOC emission
increase.
3.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES.
3.3.1  Source Extent Reductions
     These control methods act to reduce the emission rate due to traffic
on a road.  As noted in Section 3.2, control efficiency values are  easily
obtained by use of Equation (3-1).
     The reduction may be obtained by banning certain vehicles (such  as
employees' cars) or strictly enforcing speed limits.  Some of these
methods (e.g., employee bussing) will require capital  and operating and
maintenance (O&M) expenditures, while others (e.g.,  speed reductions)  may
only require indirect costs associated with increased  travel  times.
Consequently, identification of cost elements and estimation of costs  are
highly dependent upon the option(s)  selected to reduce source extent,  and
no attempt is made here to generalize costs.
3.3.2  Surface Improvements
     3.3.2.1  Paving.  Control  efficiency estimates  for paving previously
unpaved roads may be based on the material  presented in Section 2.0 of
this manual.  Inherent in this  process is estimating the silt loading on
the paved surface; it is recommended that the reader use Table 2-2 or 2-7
for public and industrial  roads, respectively.   Alternatively, for public
roads, the reader may wish to employ Equation (2-2)  to estimate  silt
loading as a function of the daily traffic  volume.   Note,  however, that
use of the equation implies that curbs will  be  installed after paving.
     Cost elements identified for paving  are  as  follows:
     Capital:  Operating equipment (graders,  paving  equipment),  paving
material  (asphalt, concrete),  and base material
     O&M:  Patching materials,  labor for  patching, and equipment
maintenance
     Reference 6 provides  the following cost  estimates (April  1985
dollars)  for asphaltic  paving:
     Initial capital  expense:   $44,700-$80,200/mile
                                 3-10

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     Annual O&M costs:  $6,600-$ll,900/mile
These estimates are based on resurfacing every  5 years  and  "15  percent
opportunity costs."  Reference 7 estimates a cost  of  $140,000/mile  (1983
dollars) to paved industrial unpaved roads.  Because  of the  variety of
cost estimates, it is strongly recommended that the reader obtain quotes
from local paving contractors.
     3.3.2.2  Gravel/Slag Improvements.  As noted  earlier, these types of
improvements replace the present road surface material  with  a lower silt
content material.  Note that this method may increase road maintenance
costs as the new aggregate fractures.  This cost may  be  avoided by
installing a "road carpet."  Because Equation (3-1) indicates a linear
relationship between silt content and emission  levels,  control efficiency
can be estimated.by determining the reduction in silt content.  For
example, if a road with a 12 percent silt content  is recovered with  a
gravel (with an equilibrium silt content of 5 percent;  see Table 3-1),
then a 58 percent control  efficiency would be expected.
     Identified cost elements for these improvements follow:
     Capital:  Material (including "road carpet,"  if applicable),
application equipment, and labor
     O&M:  Periodic grading including equipment and labor
No cost estimates were found in the reference documents used as the basis
for this document.  Because of the differences in  local  availability of
cover materials (and civil engineering fabrics)  and the amount of surface
preparation, compaction, and maintenance required for various road  types,
it is recommended that the reader obtain quotes from local  contractors.
     3.3.2.3  Vegetative Cover.  As noted by  Turner et al.,
"... vegetative covers are obviously impractical  for roads  and
facilities with construction activity .  . .  vegetative covering  may  be a
practical control option for many inactive  sites,  but  it is  likely  to be
impractical for areas of continuing activity  and areas that will  not
support a relatively dense vegetative cover."5
     Consequently, vegetation is  probably a  viable  control option only for
inactive area wind erosion and is discussed elsewhere  in this manual.
                                 3-11

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3.3.3  Surface Treatments
     3.3.3.1  Watering.  The control efficiency of unpaved road watering
depends upon (a)  the amount of water applied per unit area of road
surface, (b) the  time between reapplications, (c) traffic volume during
that period, and  (d) prevailing meteorological  conditions during the
period.  While several  investigations have estimated or studied watering
efficiencies, few have  specified all the factors listed above.
     An empirical model for the performance of  watering as a control
technique has been developed.a  The supporting  data base consists of
14 tests performed in four states during five different summer and fall
months.  The model is:

                           C - 100 - °'8 ? d t                         (3-2)

where:  C = average control efficiency,  percent
        P = potential average hourly daytime evaporation rate, mrn/h
        d = average hourly daytime traffic rate, (h-i)
        i = application intensity, L/m2
        t = time  between applications, h
Estimates of the  potential average hourly daytime evaporation rate may be
obtained from
             0.0049 x (value in Figure 3-2)  for annual  conditions
        p =  0.0065 x (value in Figure 3-2)  for summer  conditions
     An alternative approach (which is potentially  suitable  for  a
regulatory format) is shown as Figure 3-3.   This figure is  adapted  from
11 field tests conducted at a-coal-fired power  plant.   Measured  control
efficiencies did  not correlate well  with either time or vehicle  passes
after application.  However, this  is believed due to reduced  evening
evaporation (logistics  delayed the start of  testing until 3  p.m. and
testing continued through the early evening).   Surface  moisture  grab
samples were taken throughout the  testing  period, and not surprisingly,
these show a strong correlation with control efficiency.
     Figure 3-3 shows that between the average  uncontrolled moisture
content and a value of  twice that,  a small  increase in  moisture  content
results in a large increase in control efficiency.  Beyond this  point,
control efficiency grows slowly with increased  moisture  content.  Although

                                 3-12

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MEAN ANNUAL CLASS A PAN  EVAPORATION
             (In Inches)
             °'*|7*   _|Based_on  period 1946-55
  Figure  3-2.  Annual evaporation data.-'

-------
     100%
 %   75%
 o
 O
 o
 r-H
  I

 QL.
      50%  L
      25%  r
                                                             95%
                         RATIO  OF CONTROLLED TO
                          UNCONTROLLED SURFACE
                           MOISTURE CONTENTS
Figure 3-3.  Watering control  effectiveness for unpaved travel  surfaces,
                                3-14

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it is possible to fit hyperbolas to the data,  the  relatively  simple
bilinear relationship shown  in the figure provides  an  adequate  descrip-
tion.  Furthermore, this relationship is applicable to all  particle size
ranges considered:
                      _ 75 (M-l)     1 < M < 2                        ,3 .,,
                    c " 62+6.7M      2 < M < 5                        ^~J;
where:  c = instantaneous control efficiency, percent
        M = ratio of controlled to uncontrolled surface moisture  contents
     Costs for watering programs include the following elements:
     Capital:  Purchase of truck or other device
     O&M:  Fuel, water, truck maintenance, operator labor
Reference 6 estimates the following costs (1985 dollars):
     Capital:  $17,100/truck
     O&M:  $32,900/truck
     The number of trucks required may be estimated  by assuming that a
single truck, applying water at 1 L/m2, can treat roughly one mile  of road
every hour.
     Enforcement of a watering program would ideally consist of two
complementary approaches.  The first facet would require the owner  to
maintain adequate records that would document to agency personnel's
satisfaction that a regular program is in place.  (See Appendix C for a
suggested recordkeeping format.)  The second approach would involve agency
spot checks of controlled roads by taking either traffic counts or
material grab samples (Appendices D and E)  from the road.   For example,
the moisture or silt content of the traveled portion of the roadway could
be measured and compared against a minimum acceptable value.  As noted
earlier, estimates of the PMlo control  efficiency could then be obtained
from Equations (3-2) and (3-3), respectively.
     Records must be kept that document the frequency of water applied to
unpaved surfaces.  Pertinent parameters to  be  specified in a control plan
and to be regularly recorded include:
     General Information to be Specified  in the Plan
     1.  All road segments and parking locations referenced on a map
available to both the responsible party and the regulatory agency
                                 3-15

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     2.  Length of each road and area of each parking  lot
     3.  Amount of water applied to each road/area and planned  frequency
of application (alternatively, a minimum moisture level could be
specified)
     4.  Any provisions for weather (e.g., % in of rainfall will  be
substituted for one treatment; program suspended during freezing  periods;
watering frequency as a function of temperature, cloud cover, etc.)
     5.  Source of water and tank capacity.
     Specific Records for Each Road Segment/Parking Area Treatment
     1.  Date of treatment
     2.  Operator's initials (note that the operator may keep a separate
log whose information is transferred to the environmental staff's data
sheets)
     3.  Start and stop times on a particular segment/parking lot, average
speed, number of passes
     4.  Start and stop times for tank filling.
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological log (to the extent that  weather influences the
control program, see above)
     3.  Any equipment malfunctions or downtime.
     In addition to those items related to control  applications, some of
the regulatory formats suggested in Section 3.4  require that additional
records be kept.  These records may include surface  material samples
(following the sampling/analysis procedures given  in Appendices  0 and E)
or traffic counts.  Traffic counts  may be  recorded either manually or
using automatic devices.
     3.3.3.2  Chemical Treatments.   As noted in  Section 3.2, some
chemicals (most notably salts)  simulate wet suppression by attracting and
retaining moisture on the road  surface.  These methods  are often
supplemented by some watering.   It  is  recommended that  control efficiency
estimates be obtained using Figure  3-3 and  enforcement  be  based  on grab
sample moisture contents (see Appendices D  and E).
     The more common chemical dust  suppressants form  a  hard  cemented
surface.  It is this type of  suppressant that is considered  below.
                                 3-16

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     Besides water, petroleum resins  (such as Coherex®)  have  historically
been the products most widely used in the iron and  steel  industry.
However, considerable interest has been shown at both  the plant  and
corporate level in alternative chemical dust suppressants.  As a result  of
this continued interest, several new dust suppressants have been
introduced recently.  These have included asphalt emulsions,  acrylics, and
adhesives.  In addition, the generic petroleum resin formulations
developed at the Mellon Institute with funding from the American Iron and
Steel Institute (AISI) have gained considerable attention.  These generic
suppressants were designed to be produced onsite at iron  and  steel
plants.9  Onsite production of this type of suppressant in quantities
commonly used at iron and steel plants has been estimated to  reduce
chemical costs by approximately 50 percent.9
     In an earlier test report, average performance curves were  generated
for four chemical dust suppressants:  (a) a commercially  available
petroleum resin, (b) a generic petroleum resin for onsite production at  an
industrial facility, (c) an acrylic cement, and (d) an asphalt
emulsion.10  (Note that at the time of the testing program, these
suppressant types accounted for roughly 85 percent of the market share in
the iron and steel industry.)  The results of this program were combined
with other test results to develop a model to estimate time-averaged PM10
control performance.  This model  is illustrated as Figure 3-4.  Several
items are to be noted:
     •  The term "ground inventory" is a measure of residual  effects from
previous applications.  Ground inventory is found by adding together the
total(volume (per unit area) of concentrate (not solution) since the start
of the dust control season.  An example is provided below.
     •  Note that no credit for control  is assigned until the  ground
inventory exceeds 0.05 gal/yd2.
     •  Because suppressants must be periodically reapplied to unpaved
roads, use of the time-averaged values given in the figure are
appropriate.  Recommended minimum reapplication frequencies (as well  as
alternatives) are discussed later in this section.
     •  Figure 3-4 represents an  average of the four suppressants given
above.  The basis of the methodology lies in a  similar  model for  petroleum
                                 3-17

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                      0.25
    (liters/m2)

0.5         0.75
1.25
a
LU
CD
•=c z

>- o
O Z
Z 
-------
resins only.10  However, agreement between the control  efficiency
estimates given by Figure 3-4 and available field measurements  is
reasonably good.
     As an example of the use of Figure 3-4, suppose that  Equation  (3-1)
has been used to estimate a PM10 emission factor of 2.0  kg/VKT.   Further,
suppose that starting on May 1, the road is treated with 0.25.gal/yd2  of  a
(1 part chemical to 5 parts water) solution on the first of  each  month
until October.  In this instance, the following average  controlled
emission factors are found:
     Period
     May
     June
     July
     August
     September


Ground
inventory,
gal/yd2
0.042
0.083
0.12
0.17
0.21

Average
control
efficiency,
percent3
0
68
75
82
88
Average
controlled
emission
factor,
kq/VKT
2.0
0.64
0.50
0.36
0.24
aFrom Figure 3-3; zero efficiency assigned if ground inventory is less
 than 0.05 gal/yd2.
A form which could be used as part of a recordkeeping format is presented
in Section 3.4.
     In formulating dust control plans for chemical dust suppressants,
additional topics must be considered.  These are briefly discussed
below.
     Use of paved road controls on chemically treated unpaved roads.
Repeated use of chemical dust suppressants tend, over time, to form fairly
impervious surfaces on unpaved roads.  The resulting surface may admit the
use of paved road cleaning techniques (such as flushing, sweeping, etc.)
to reduce aggregate loading due to spillage and track-on.   A field program
conducted tests on surfaces that had been flushed and vacuumed 3 days
earlier.10  (The surfaces themselves had last been chemically treated
70 days before.)  Control efficiency values of 90 percent  or more (based
on the uncontrolled emission factor of the unpaved roads)  were found for
each particulate size fraction considered.
                                 3-19

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     The use of paved road techniques for "housekeeping" purposes would
appear to have the benefits of both high control (referenced to an
uncontrolled unpaved road) and potentially relatively low cost (compared
to followup chemical applications).  Generally, it is recommended that
these methods not be employed until the ground inventory exceeds
approximately 0.2 gal/yd2 (0.9 L/m2).  Plant personnel should, of course,
first examine the use of paved road techniques on chemically treated
surfaces in limited areas prior to implementing a full-scale program.
     Minimum reapplication frequency.  Because unpaved roads in industry
are often used for the movement of materials and are often surrounded by
additional unpaved travel areas, spillage and carryout onto the chemically
treated road require periodic "housekeeping" activities.  In addition,
gradual abrasion of the treated surface by traffic will  result in loose
material on the surface which should be controlled.
     It is recommended that at least dilute reapplications be employed
every month to control loose surface material unless paved road control
techniques are used (as described above).  More frequent reapplications
would be required if spillage and track-on pose particular problems for a
road.
     Weather considerations.  Roads generally have higher moisture
contents during cooler periods due to decreased evaporation.   Small
increases in surface moisture may result in large increases in control
efficiency (as referenced to the dry summertime conditions inherent in the
AP-42 unpaved road predictive equation).n  In addition,  application of
chemical dust suppressants during cooler periods of the  year  may  be
inadvisable for traffic safety reasons.
     Weather-related application schedules should be considered prior .to
implementing any control  program.   Responsible parties and  regulatory
agency personnel should work closely in  making this joint determination.
     Compared to the other open dust sources discussed in this  manual,
there is a wealth of cost information available  for chemical  dust
suppressants on unpaved roads.   Note that many salt products  are delivered
and applied by the same truck.   For those products,  costs are easily
obtained by contacting a local  distributor.
                                 3-20

-------
     For other chemicals, identified cost  elements  include:
     Capital:  Distributor truck, tanks, pumps, piping
     O&M:  Chemical suppressants, water, fuel, replacement parts,  labor
Many plants contract out application and thus have  minimal capital
expenditures.
     Because each plant faces a unique set of needs, no attempt has been
made here to include all possible costs involved in a dust control
program.  For example, some facilities may be forced to install new
storage tanks while others may only need to refurbish unused tanks in the
plant.  Still others may find it more efficient to  retain an outside
contractor to store and apply the suppressants.  Extensive discussions,
comparing rental and capital expenses, have been prepared; one is shown in
Appendix B.
     In order to provide preliminary estimates of costs associated with
chemical dust suppressants, the reader may employ the following average
costs:
                  Chemical suppressant cost, 1985 $/ga1

Salts
Other
Small lot
0.70a
2.60b
Bulk
0.46a
1.48C
aCost includes delivery and application.
°FOB costs for 55-gal drums.
CFOB; note that at the time this manual was prepared, bulk costs of
 suppressants are slightly lower than that stated.
Delivery and contracted application costs may be estimated by increasing
bulk costs by 10 and 15 percent, respectively.
     At application intensities and dilution ratios common in the iron and
steel industry, an adequate estimate of applied unit costs for chemical
suppressants is $3,000 per treatment per mile of unpaved road.10  For
treatments at the higher intensities recommended by the chemical supplier,
the corresponding unit cost is approximately $5,000 per treatment per
mile.11  Note that in the iron and steel industry,  lighter application
                                 3-21

-------
intensities have been found to be more cost-effective over  typical time
intervals between treatments.10
     Enforcement of a chemical dust control program would ideally consist
of two complementary approaches.  The first facet would require the owner
to maintain adequate records that would document to agency  personnel's
satisfaction that a regular program is in place.  (See Appendix C for a
suggested recordkeeping format.)  The second approach would involve agency
spot checks of controlled roads by taking a material sample from the
road.  The latter approach is discussed in Section 3.4.  The sampling
method should be essentially the same as that used in the development of
the current AP-42 predictive equations.
     Records must be kept that document the frequency of chemicals applied
to unpaved surfaces.  Pertinent parameters to be specified  in a control
plan and to be regularly recorded include the following.
     General Information to be Specified in the Plan
     1.  All road segments and parking locations referenced on a map
available to both the responsible party and the regulatory agency
     2.  Length .of each road and area of each parking lot
     3.  Type of chemical applied to each road/area, dilution ratio,
application intensity, and planned frequency of application
     4.  Provisions for weather.
     Specific Records for Each Road Segment/Parking Area Treatment
     1.  Date of treatment
     2.  Operator's initials (note that the operator may keep a separate
log of whose information is transferred to the environmental staff's  data
sheets)
     3.  Start and stop times on a particular segment/parking lot,  average
speed, number of passes, amount of solution applied
     4.  Qualitative description of road  surface condition.
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological  log (to the extent that weather  influences  the
control program—see above)
     3.  Any equipment malfunctions or  downtime.
                                 3-22

-------
     In addition to those items related to control  applications,  some  of
the regulatory formats suggested in Section  3.4  require  that  additional
records be kept.  These records may include  surface material  samples
(following the sampling/analysis procedures  given  in Appendices D  and  E)
or traffic counts.  Traffic counts may be recorded  either manually or
using automatic devices.
3.4  EXAMPLE DUST CONTROL PLAN
     As an illustration of the use of material given earlier, this section
considers an example dust control plan.  In  this example, it  is assumed
that a minimum of 75 percent average control is required on an
uncontrolled unpaved road.  Traffic and meteorological parameters  for  the
road are given below:
     Hours of operation:                   9 h/day, 250 days/yr
     Traffic volume:                      25 vehicle passes/h
     Average daylight evaporation rate:   0.2 mm/h
3.4.1  Example Water Program
     If the above assumptions are substituted, Equation (3-2) may be used
to estimate the necessary hourly watering requirements:

      75 < 100 - °-8<°
or,

        > 0.16
Thus, any watering program that applies at least 0.16 L/m2 of water for
every hour between applications would result in an estimated average
control of at least 75 percent.  Some example programs are presented
below.
     -  0.48 L/m2 (0.11 gal/yd2) every 3 h
     •  0.40 L/m2 (0.088 gal /yd 2) every 2 1/2 h
     •  0.72 L/m2 (0.16 gal/yd2) every 4 1/2 h
3.4.2  Example Chemical Dust  Suppressant Program
     Figure 3-3 may be used to design a chemical suppressant program
resulting in a minimum of 75  percent average control.   The figure
                                 3-23

-------
indicates that 75 percent average control is achieved over 2 weeks with  a
ground inventory of 0.41 L/m2 (0.09 gal/yd2) and over 1 month with a
0.56 L/m2 (0.125 gal/yd2) ground inventory.  Thus, any of the following
programs would result in a minimum of 75 percent average control:
     •  0.45 gal/yd2 of 4 parts water to 1 part chemical applied with any
        reapplication every 2 weeks, monthly reapplications after ground
        inventory is at least 0.125 gal/yd2
     •  0.88 gal/yd2 of a 6:1 solution applied initially, token reapplica-
        tions every following month
     •  1.0 gal/yd2 of 10:1 solution applied initially, 0.38 of 10:1 solu-
        tion 2 weeks later, token reapplications every following 30 days
Note that many other plans meeting the 75 percent minimum could also be
formu1ated.
3.5  POTENTIAL REGULATORY FORMATS
     There are numerous regulatory formats possible for unpaved roads.
For example, some state rules have been developed using opacity readings
to determine compliance.  The Tennessee and Ohio visible emission methods
are discussed in detail in Appendix C.  Michigan and Illinois formulated
rules based on opacity, and both resulted in considerable debates of
merit.
     It is important to note that opacity has yet to be related to
emission levels from roads.  (As discussed in Appendix C, Indiana has a
current program which will attempt to correlate mass emission levels with
opacity readings.)  One often-raised question deals with prevailing wind
speeds during opacity readings;  ambient air concentrations  (and hence,
opacity levels) tend to be greater under lower wind speeds.   Consequently,
for a road with even a constant  emission rate, opacity readings would vary
indirectly with wind speed.
     Recordkeeping offers another compliance tool  for unpaved road dust
controls.  The level of detail  needed varies with  the control  option
employed.  Table 3-4 summarizes  the level  of detail  required  for the
various controls discussed in Section 3.3.
     Recordkeeping, together with traffic  records  as  required,  will  allow
the regulator to estimate control  performance for  a variety of  control
programs.  For example, use of  the watering  model  presented as
                                 3-24

-------
                                TABLE 3-4.  RECORDKEEP-ING REQUIREMENTS FOR UNPAVED ROADS
        Control
                      Level of detail
                                        Comments
OJ
I
ro
Paving


Gravel ing



Vegetation


Watering




Chemicals (salts)


Chemicals
                              Minimal level, starting date of
                                paving, type, etc.

                              Minimal level, starting date of
                                graveling, gravel specifications
                                grading/reapplication dates

                              See comment
Extensive, covering each day/
  time of application, meteoro-
  logical conditions, amount of
  water applied, traffic records

Fairly extensive, dates of applica-
  tions and subsequent waterings

Moderate, dates and operating
  parameters for each application
                                        Additional records required if paved road
                                          controls employed (see Section 2.0)

                                        Before and after measurements of silt
                                          content recommended
Not generally applicable for traffic
  sources

Collection of grab samples for moisture
  recommended
                                                                      Collection of grab samples for moisture
                                                                        recommended

                                                                      Field samples recommended to bound
                                                                        control efficiency (see text)

-------
 Equation  (3-2),  together with traffic,  application, and  meteorological
 records,  would allow one to estimate average control efficiency.
 Moreover,  use of Figure 3-4, together with the form shown  as  Figure 3-5,
 allows  estimation of chemical suppressant efficiency between
 applications.  Figure 3-6 shows a completed form corresponding  to  the
 example in Section 3.3.3.2.
     While recordkeeping affords a convenient method of  assessing  long-
 term control performance, it is important that regulatory  personnel  have
 "spot-check" compliance tools at their  disposal.  One such tool was
 mentioned  earlier in connection with Figure 3-3.  Rules  could be written
 specifying a minimum surface moisture content (thus, corresponding  to a
 minimum control  efficiency) to be maintained on an unpaved surface which
 is watered or treated with salts.  Inspection personnel would then collect
 grab samples for moisture analysis to determine compliance following  the
 procedures in Appendices 0 and E.
     For  chemically (other than salts)  controlled surfaces, it has been
 found that Equation (2-3) tends to overestimate the controlled emission
 factor  (and thus, underestimate instantaneous control  efficiency).10   In
"this way,  an inspector could collect an unpaved sample with a whisk broom
 and dustpan, and  after laboratory analysis for silt content, have a
 conservatively low estimate of control  efficiency due  to the chemical
 treatment.  .If a  rule is written to maintain a certain level of
 efficiency, the  inspector could then instruct the responsible party to
 reapply the chemical or use paved road controls (if feasible).
                                 3-26

-------
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                                        Figure 3-6.   Example'  completed  log.

-------
3.4  REFERENCES FOR SECTION 3

 1.  Environmental Protection Agency.  Compilation of Air Pollution
     Emission Factors (AP-42).  Research Triangle Park, North Carolina.
     September 1985.

 2.  Climatic Atlas of the United States.  U.S. Department of Commerce,
     Washington, D.C.  June 1968.

 3.  Final Report, MRI Project No. 8162-L.  Industrial Client.  December
     1985.

 4.  Rosbury, K. D.  1984.  Fugitive Dust Control Techniques at Hazardous
     Waste Sites.  Interim Technical Report No. 1—Proposed Field Sampling
     Plan, Contract No. 68-02-3512, WA 61, U. S. Environmental Protection
     Agency, Municipal Environmental Research Laboratory, Cincinnati,
     Ohio.  March 1984.

 5.  Turner, J. H., et al.  1984.  Fugitive Particulate Emissions From
     Hazardous Waste Sites.  Prepared for the U. S.  Environmental
     Protection Agency, Cincinnati, Ohio.  September 1984.

 6.  Kinsey, J. S., et al.  1985.  Control Technology for Sources of
     PM10.  Draft Final Report, EPA Contract No. 68-02-3891,  WA 4.
     September 1985.

 7.  Cuscino, T., Jr., 6. E. Muleski, and C. Cowherd, Jr.   Iron and Steel
     Plant Open Source Fugitive Emission Control Evaluation.   EPA-600/2-
     83-110, U. S. Environmental  Protection Agency,  Research  Triangle
     Park, North Carolina.  October 1983.

 8.  Cowherd, C., Jr., and J.  S.  Kinsey.   1986.  Identification,
     Assessment and Control of Fugitive Particulate  Emissions.
     EPA-600/8-86-023, U. S. Environmental Protection Agency,  Research
     Triangle Park, North Carolina.

 9.  Russell, D., and S.  C. Caruso.  1984.  The Relative  Effectiveness of
     a Dust Suppressant for Use on Unpaved Roads Within the  Iron  and  Steel
     Industry.  Presented at EPA/AISI Symposium on  Iron and Steel
     Pollution Abatement, Cleveland, Ohio.  October  1984.

10.  Muleski, G. E., and  C. Cowherd, Jr.   Evaluation  of the Effectiveness
     of Chemical Dust Suppressants on Unpaved  Roads.   EPA-600/2-87-102,
     U. S. Environmental  Protection Agency,  Research  Triangle  Park, North
     Carolina.  November  1987.

11.  Muleski, G. E., T.  Cuscino,  Jr., and C.  Cowherd,  Jr.   1984.   Extended
     Evaluation of Unpaved Road Dust Suppressants in  the  Iron  and  Steel
     Industry.  EPA-600/2-84-027,  U. S.  Environmental  Protection Agency,
     Research Triangle Park, North Carolina.   February 1984.
                                 3-29

-------
                            4.0  STORAGE  PILES

     Inherent in operations that use minerals in aggregate  form  is  the
maintenance of outdoor storage piles.  Storage piles are usually  left
uncovered, partially because of the need for frequent material transfer
into or out of storage.
     Dust emissions occur at several points in the storage  cycle, during
material loading onto the pile, during disturbances by strong wind
currents, and during loadout from the pile.  The movement of trucks and
loading equipment in the storage pile area is also a substantial  source of
dust.
4.1  ESTIMATION OF EMISSIONS
     The quantity of dust emissions from aggregate storage operations
varies with the volume of aggregate passing through the storage cycle.
Also, emissions depend on three correction parameters that characterize
the condition of a particular storage pile:  age of the pile, moisture
content, proportion of aggregate fines, and friability of the material.
     When freshly processed aggregate is loaded onto, a storage pile, its
potential for dust emissions is at a maximum.   Fines are easily -
disaggregated and released .to the atmosphere'upon exposure to air currents
from transfer operations or high winds.  As the aggregate weathers,
however, potential for dust emissions is greatly reduced.  Moisture causes
aggregation and cementation of fines to the surfaces of larger particles.
     Field investigations have shown that emissions from certain aggregate
storage operations vary in direct proportion to the percentage of silt
(particles <75 urn in diameter)  in the aggregate material.'--7  The silt
content is determined by measuring  the proportion of dry aggregate
material that passes through a 200-mesh screen,  using  ASTM-C-136 method.
Table 4-1 summarizes measured  silt  and moisture values  for  industrial
aggregate materials.
     Total  dust emissions from aggregate storage piles  are  contributions
of several  distinct source activities within the storage  cycle:
                                  4-1

-------
               TABLE 4-1.  TYPICAL SILT AND MOISTURE CONTENT VALUES OF MATERIALS AT VARIOUS  INDUSTRIES
i
ro'


Industry
Iron and steel production3





~


Stone quarrying and processing
Taconite mining and processing0

Western surface coal mining


^References 2 through 5. NA = not
Reference I.
cReference 6.
Reference 7.


Material
Pel let ore
Lump ore
Coal
Slag
Flue dust
Coke breeze
Blended ore
Sinter
Limestone
Crushed 1 imestone
Pellets
Tai 1 ings
Coal
Overburden
Exposed ground
appl icable.



No. of
test
samples
10
9
7
3
2
1
1
1
1
2
9
2
15
15
3






Silt, percent
Range
1.4-13
2.8-19
2-7.7
3-7.3
14-23




1.3-1.9
2.2-5.4
NA
3.4-16
3.8-15
5.1-21




Mean
4.9
9.5
5
5.3
18.0
5.4
15.0
0.7
0.4
1.6
3.4
11.0
6.2
7.5
15.0




No. of
test
samples
8
6
6
3
0
1
1
0
0
2
7
1
7
0
3






Moisture, percent
Range
0.64-3.5
1.6-8.1
2.8-11
0.25-2.2
NA


NA
NA
0.3-1 .1
0.05-2.3

2.8-20
NA
0.8-6.4




Mean
2.1
5.4
4.8
0.92
NA
6.4
6.6
NA
NA
0.7
0.96
0.35
6.9
NA
3.4





-------
     1.  Loading of aggregate onto storage piles  (batch  or  continuous  drop
operations).
     2.  Equipment traffic in storage area.
     3.  Wind erosion of pile surfaces and ground areas  around  piles.
     4.  Loadout of aggregate for shipment or for return to the process
stream (batch or continuous drop operations).
4.1.1  Materials Handling
     Adding aggregate material to a storage pile or removing  it usually
involves dropping .the material onto a receiving surface.  Truck dumping  on
the pile or loading out from the pile to a truck with a front-end loader
are examples of batch drop operations.  Adding material to the  pile by a
conveyor stacker is an example of a continuous drop operation.
     The following equation is recommended for estimating emissions from
transfer operations (batch or continuous drop):
                    E = k(0.0016)  •  .  4  (kg/Mg)
                                  /M* i<4   .
                                  (?)
                                                                     (4-1)

                                  U  l'3
                                 (5)
                    E = k(0.0032) - — r-j- (Ib/ton) .
                                  M  -1- «^
                                 (?)

where:  E = emission factor
        k = particle size multiplier (dimensionless)
        U = mean wind speed, m/s (mph)
        M = material moisture content,  percent
The particle size multiplier k varies with aerodynamic particle diameter
as shown below:
                  Aerodynamic  Particle Size Multiplier, k
     <30 um        <15 urn        
-------
     For emissions from equipment traffic (trucks, front-end  loaders,
dozers, etc.) traveling between or on piles, it is recommended  that  the
equations for vehicle traffic on unpaved surfaces be used  (see
Section 3-0).  For vehicle travel between storage piles, the  silt  value(s)
for the areas among the piles (which may differ from the silt values for
the stored materials) should be used.
4.1.2  Wind Erosion
     Dust emissions may be generated by wind erosion of open aggregate
storage piles and exposed areas within an industrial facility.  These
sources typically are characterized by nonhomogeneous surfaces  impregnated
with nonerodible elements (particles larger than approximately  1 cm  in
diameter).  Field testing of coal piles and other exposed materials  using
a portable wind, tunnel has shown that (a) threshold wind speeds exceed
5 m/s (11 mph) at 15 cm above the surface or 10 m/s (22 mph) at 7 m  above
the surface, and (b) particulate emission rates tend, to decay rapidly
(half life of a few minutes) during an erosion  event.  In other words,
these aggregate material  surfaces are characterized by finite availability
of erodible material (mass/area) referred to as the erosion potential.
Any natural crusting of the surface binds the erodible material, thereby
reducing the erosion potential.
     4.1.2.1  Emissions and Correction Parameters.   If typical values for
threshold wind speed at 15 cm are corrected  to  typical  wind sensor height
(7-10 m), the resulting values exceed the upper extremes of hourly mean
wind speeds observed in most areas of the country.   In other words, mean
atmospheric wind speeds are not  sufficient to sustain wind  erosion from
aggregate material  surfaces.  However,  wind  gusts may quickly deplete a
substantial portion of the erosion potential.   Because  erosion potential
has been found to increase rapidly with increasing  wind  speed,  estimated
emissions should be related to the gusts  of  highest  magnitude.
     The routinely  measured meteorological variable  which best reflects
the magnitude of wind gusts is the fastest mile.  This  quantity  represents
the wind speed corresponding to  the whole mile  of wind movement  which has
passed by the 1-mi  contact anemometer in  the  least  amount of  time.   Daily
measurements of the fastest mile are presented  in the monthly  Local
Climatological Data (LCD)  summaries.   The LCD summaries  can be obtained
                                 4-4

-------
from the National Climatic Center, Asheville, North  Carolina.   The
duration of the fastest mile, typically about 2 min  (for  a  fastest mile  of
30 mph), matches well with the half life of the erosion process, which
ranges between 1 and 4 min.  It should be noted, however, that  peak winds
can significantly exceed the daily fastest mile.
     The wind speed profile in the surface boundary  layer is found to
follow a logarithmic distribution:
                        u(z)  = fa In(f-)   (z  >  zQ)                   (4-2)
                                       o
where:    u = wind speed, cm/s
         u* = friction velocity, cm/s
          z = height above test surface, cm
         z0 = roughness height, cm
        0.4 = von Karman's constant, dimensionless
     The friction velocity (u*) is a measure of wind shear stress on the
erodible surface, as determined from the slope of the logarithmic velocity
profile.  The roughness height (ZQ) is a measure of the roughness of the
exposed surface as determined from the y-intercept of the velocity
profile, i.e., the height at which the wind speed is zero.  These
parameters are illustrated in Figure 4-1 for a roughness height of 0.1 cm.
     Emissions generated by wind erosion are also dependent on the
frequency of disturbance of the erodible surface because each time that a
surface is disturbed, its erosion potential  is restored.  A disturbance is
defined as an action which results in the exposure of fresh surface
material.  On a storage pile, this would occur whenever aggregate material
is either added to or removed from the old surface.   A disturbance of  an
exposed area may also result from the turning  of surface material to  a
depth exceeding the size of the largest pieces of  material  present.
     4.1.2.2  Predictive Emission Factor Equations.   The emission factor
for wind-generated particulate emissions  from  mixtures of  erodible  and
nonerodible surface material  subject to disturbance  may be expressed  in
units of g/m2-yr as follows:
                                            N
                       Emission factor =  k  £   P.                   (4-3)
                                  4-5

-------
                                                         lotn
                                                                      o.s
                                                SPEED AT Z
                                                           IOm
Figure 4-1.   Illustration of logarithmic  velocity profile.

-------
where:   k =  particle size multiplier
         N =  number of disturbances per year
        P^ =  erosion potential corresponding  to  the  observed  (or  probable)
              fastest mile of wind for the  ith period between  disturbances,
     The particle size multiplier  (k) for  Equation 4-3 varies with
aerodynamic particle size, as follows:

          AERODYNAMIC PARTICLE SIZE MULTIPLIERS  FOR  EQUATION 4-3
                 <30 ym    <15 ym    <10  ym    <2.5  ym
                    1.0       0.6       0.5       0.2

     This distribution of particle size within the <30 ym fraction is
comparable to the distributions reported  for other fugitive dust sources
where wind speed is a factor.  This is illustrated,  for example, in the
distributions for batch and continuous drop operations encompassing a
number of test aggregate materials (see AP-42 Section 11.2.3).
     In calculating emission factors, each area of an erodible surface
that is subject to a different frequency of disturbance should be treated
separately.  For a surface disturbed daily, N = 365/yr, and for a surface
disturbance once every 6 mo, N = 2/yr.
     The erosion potential function for a dry, exposed surface has the
following form:

                      P = 58 (u* - u*)z + 25 (u* -  u*)
                                                                     (4-4)
                      P = 0 for u* < u*

where:  u* = friction velocity (m/s)
        u£ = threshold friction velocity (m/s)
     Table 4-2 presents the erosion potential  function in  matrix  form.
Because of the nonlinear form of the erosion potential function,  each
erosion event must be treated separately.
                                  4-7

-------
TABLE 4-2.  EROSION POTENTIAL FUNCTION
"*• *
m/s u. =
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0

0.2
0
7
19
36
57
83
114
149
188
233
282
336
394
457
525

0.4
0
0
7
19
36
57
83
114
149
188
233
282
336
394
457

0.6
0
0
0
7
19
36
57
83
114
149
188
233
282
336
394

0.8
0
0
0
0
7
19
36
57
83
114
149
188
233
282
336

1.0
0
0
0
0
0
7
19
36
57
83
114
149
188
233
282
P 
-------
     Equations 4-3 and 4-4 apply only  to  dry,  exposed  materials  with
limited erosion potential.  The resulting calculation  is  valid only for a
time period as long or longer than the period  between  disturbances.
Calculated emissions represent intermittent  events  and should not  be  input
directly into dispersion models that assume  steady  state  emission  rates.
     For uncrusted surfaces, the threshold friction velocity is  best
estimated from the dry aggregate structure of  the soil.   A  simple  hand
sieving test of surface soil (adapted  from a laboratory procedure
published by W. S. Chepil9) can be used to determine the  mode of the
surface aggregate size distribution by inspection of relative sieve catch
amounts, following the procedure specified in  Section  6.  The threshold
friction velocity for erosion can be determined from the  mode of the
aggregate size distribution, as described by Gillette.10  This conversion
is also described in Section 6.
     Threshold friction velocities for several surface types have  been
determined by field measurements with  a portable wind  tunnel.10-^  These
values are presented in Tables 4-3 and 4-4 for industrial aggregates and
Arizona sites.  Figure 4-2 depicts these data graphically.
     The fastest mile of wind for the  periods between disturbances may be
obtained from the monthly LCD summaries for  the nearest reporting weather
station that is representative of the  site in question.11*  These summaries
report actual fastest mile values for  each day of a given month.   Because
the erosion potential is a highly nonlinear  function of the fastest mile,
mean values of the fastest mile are inappropriate.  The anemometer heights
of reporting weather stations are found in Reference 15, and should be
corrected to a 10 m reference height using Equation 4-2.
     To convert the fastest mile of wind (u+) from a reference  anemometer
height of 10 m to the equivalent friction velocity  (u*), the logarithmic
wind speed profile may be used to yield the following equation:

                    (4-5)      u* = 0.053 u|o

where:    u* = friction velocity (m/s)
         uto = fastest mile of reference anemometer  for period between
               disturbances (m/s)
                                  4-9

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     TABLE  4-3.   THRESHOLD  FRICTION  VELOCITIES—INDUSTRIAL AGGREGATES
Threshold wind


Material
Overburdena
Scoria (roadbed
Threshold
friction
velocity,
m/s
1.02
1.33
velocity at
Roughness
height,
cm
0.3
0.3
10 m
actual
21
27
(m/s)
0?5 cm
19
25

Ref.
7
7
  material)d

Ground coala
  (surrounding coal
  pile)

Uncrusted coal pilec

Scraper tracks on
  coal -pile3'0
Fine coal dust on
  concrete pad
0.55



1.12

0.62


0.54
0.01



0.3

0.06


0.2
16



23

15


11
10



21

12


10
 7

 7


12
^Western surface coal mine.
DLightly crusted.
cEastern power plant.
                                   4-10

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         TABLE 4-4.  THRESHOLD FRICTION VELOCITIES—ARIZONA SITES1
Location
Threshold
 friction
velocity,
  m/sec
Roughness
 height,
   (cm)
  Threshold
wind velocity
   at  10 m,
    m/sec
Mesa - Agricultural site          0.57
Glendale - Construction site      0.53
Maricopa - Agricultural site      0.58
Yuma - Disturbed desert           0.32
Yuma - Agricultural site          0.58
Algodones - Dune flats            0.62
Yuma - Scrub desert               0.39
Santa Cruz River, Tucson          0.18
Tucson - Construction site        0.25
Ajo - Mine tailings               0.23
Hayden - Mine tailings            0.17
Salt River, Mesa                  0.22
Casa Grande - Abandoned           0.25
  agricultural land
               0.0331
               0.0301
               0.1255
               0.0731
               0.0224
               0.0166
               0.0163
               0.0204
               0.0181
               0.0176
               0.0141
               0.0100
               0.0067
                   16
                   15
                   14
                   8
                   17
                   18
                   11
                   5
                   7
                   7
                   5
                   7
                   8
                                   4-11

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For narrowly sized, finely divided materials only
1 -_,
Aggregate size
(distribution' mode U*, Measured
(in) (mm) (cm/s)
1
Gravel >



	 	

Coarse
Sand "<
	
Fine
Sand ~*
— — — 	 	 	
r-
0.3
0.2


0.1
"
0.05

, 001

<-
8
7
6
4
3
-
2
__
1
0.5
-
0.1
0.02
-
""*

~" n-.

-

—
p
|-
—
150
Undisturbed coal pila
Scoria
Undisturbed coal pila
Uncrusled coal pile
IflA 1 W/<* Overburden
Disturbed coal pile


Coal pila (scraper IracKs)
Ouna Hals
Agricultural sites
Ground coal
tn AI CW) / c""sl«iclion sila
OU— O-'-y '/$ Finucoaldusl
Scrub dosed
Oisluibud desorl
Construction site and disluibud prairiu soil
Abandoned agricultural land
Huvlal channels
Mine liiilirujs
0
                 Figure 4-2.  Scale  of threshold friction  velocities.

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     This assumes a typical roughness height of 0.5  cm  for  open  terrain.
Equation 4-5 is restricted to  large relatively flat  piles or  exposed  areas
with little penetration into the surface wind layer.
     If the pile significantly penetrates the surface wind  layer  (i.e.,
with a height-to-base ratio exceeding 0.2), it is necessary to divide  the
pile area into subareas representing different degrees  of exposure to
wind.  The results of physical modeling show that the frontal face of  an
elevated pile is exposed to wind speeds of the same  order as  the  approach
wind speed at the top of the pile.
     For two representative pile shapes (conical and oval with flat-top,
37 degree side slope), the ratios of surface wind speed  (us)  to approach
wind speed (ur) have been derived from wind tunnel studies.11  The results
are shown in Figure 4-3 corresponding to an actual pile  height of 11 m, a
reference (upwind) anemometer height of 10 m, and a pile surface roughness
height (ZQ) of 0.5 cm.  The measured surface winds correspond to a height
of 25 cm above the surface.  The area fraction within each  contour pair is
specified in Table 4-5.
     The profiles of us/ur in Figure 4-3 can be used to estimate the
surface friction velocity distribution around similarly shaped piles,
using the following procedure:                    -
     1.  Correct the fastest mile value (u+) for the period of interest
         from the anemometer height (z)  to a reference height of 10 m
         (uto) using a variation of Equation 4-2,  as follows:

                          n+  -  + In (10/0.005)                     ,   .
                          Uio - u   in (z/0.005)                     (4'6)

         where a typical  roughness height  of 0.5 cm  (0.005 m)  has been
         assumed.  If a site specific roughness  height is available,  it
         should be used.
     2.  Use the appropriate part of Figure  4-3  based on the pile shape
         and orientation  to the fastest  mile of  wind, to obtain  the
         corresponding surface wind speed  distribution (u*), i.e.,
                                 4-13

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  Flow
Direction
                   Pile A
Pile B1
                    Pile 82
                                                             Pile B3
           Figure 4-3.   Contours of normalized surface wind speeds,  u./u  .
                                      4-14

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          TABLE 4-5.  SUBAREA DISTRIBUTION FOR REGIMES OF  Uj/u,.

                       Percent of pile surface area (Figure 4-3)
Pile subarea       Pile A       Pile 81       Pile B2       Pile 83
0.2a
0.2b
0.2c
0.6a
0.6b
0.9
1.1
5
35
-
48
-
12
_
5
2
29
26
24
14
_
3
28
-
29
22
15
3
3
25
-
28
26
14
4
                                   4-15

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     3.  For any subarea of the pile surface having a narrow  range  of
         surface wind speed, use a variation of Equation 4-2  to  calculate
         the equivalent friction velocity (u*), as follows:
                                0.4 u+
                           u* =	^ -0.10 u+                      (4-8)
                                1n 0^
     From this point on, the procedure is identical to that used for  a
flat pile, as described above.
     Implementation of the above procedure is carried out in  the following
steps:
     1.  Determine threshold friction velocity for erodible material  of
interest (see Tables 4-3 and 4-4 or Figure 4-2 or determine from mode of
aggregate size distribution).
     2.  Divide the exposed surface area into subareas of constant
frequency of disturbance (N).
     3.  Tabulate fastest mile values (u+) for each frequency of
disturbance and correct them to 10 m (u*o) using Equation 4-6.
     4.  Convert fastest mile values (uto) to equivalent friction
velocities (u*), taking into account (a) the uniform wind exposure of
nonelevated surfaces, using Equation 4-5, or (b) the nonuniform wind
exposure of elevated surfaces (piles), using Equations 4-7 and 4-8.
     5.  For elevated surfaces (piles), subdivide areas  of constant N into
subareas of constant u* (i.e., within the isopleth values of us/ur in
Figure 4-3 and Table 4-5) and determine the  size of each subarea.
     6.  Treating each subarea (of constant  N and u*)  as a separate
source, calculate the erosion potential (Pj)  for each  period between
disturbances using Equation 4-4 and the emission factor  using
Equation 4-3.
     7.  Multiply the resulting emission factor  for each subarea  by  the
size of the subarea, and add the emission contributions  of  all subareas.
Note that the highest 24-h emissions would be expected to occur on  the
windiest day of the year.  Maximum emissions  are calculated  assuming a
single wind event with the highest fastest mile  value for the  annual
period.
                                 4-16

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     The  recommended  emission  factor  equation presented  above assumes that
.all of  the  erosion  potential corresponding to the  fastest  mile of wind is
 lost during the  period  between disturbances.   Because  the  fastest mile
 event typically  lasts only  about  2  min,  which corresponds  roughly to the
 half-life for the decay of  actual erosion potential,  it  could be  argued
 that the  emission factor overestimates particulate emissions.   However,
 there are other  aspects of  the wind erosion process which  offset  this
 apparent  conservatism:
     1.   The fastest  mile event contains. peak winds which  substantially
 exceed  the  mean  value for the  event.
     2.   Whenever the fastest  mile  event occurs, there are usually a
 number  of periods of  slightly  lower mean wind speed which  contain peak
 gusts of  the same order as  the fastest mile wind speed.
     Of greater  concern is  the likelihood of  overprediction of wind
 erosion emissions in  the case  of  surfaces disturbed infrequently  in
 comparison  to the rate  of crust formation.
 4.1.3  Wind Emissions From  Continuously  Active Piles
     For  emissions  from wind erosion  of  active storage piles, the
 following total  suspended particulate (TSP) emission factor equation  is
 recommended:

                    E  =  l'9  (I75)  (^Sr}   (H) (k9/d/hectare)
                                                                      (4-9)
                    E  =  1.7  (L)  (H)   () (Ib/d/acre)
where:   E =  total suspended particulate emission factor
         s =  silt content of aggregate, percent
         p =  number of days with >0.25 mm  (0.01 in.) of precipitation per
             year
         f =  percentage of time that the unobstructed wind speed exceeds
             5.4 m/s (12 mph) at the mean pile height
     The fraction of TSP which is PM10 is estimated at 0.5 and is
consistent with the PM10/TSP ratios for materials handling (Section 4.1.1)
and wind erosion (Section 4.1.2).  The coefficient in Equation (4-9) is
taken from Reference 1, based on sampling of emissions from a sand and
                                  4-17

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gravel storage pile area during periods when transfer and maintenance
equipment was not operating.  The factor from Reference 1, expressed  in
mass per unit area per day, is more reliable than the factor expressed  in
mass per unit mass of material placed in storage, for reasons stated  in
that report.  Note that the coefficient has been halved to adjust for the
estimate that the wind speed through the emission layer at the test site
was one half of the value measured above the top of the piles.  The other
terms in this equation were added to correct for silt, precipitation, and
frequency of high winds, as discussed in Reference 2.  Equation (4-9) is
rated in AP-42 as C for application in the sand and gravel industry and D
for other industries (see Appendix A).
     Worst case emissions from storage pile areas occur under dry windy
conditions.  Worst case emissions from materials handling (batch and
continuous drop) operations may be calculated by substituting into
Equation (4-9) appropriate values for aggregate material moisture content
and for anticipated wind speeds during the worst case averaging period,
usually 24 h.  The treatment of dry conditions for vehicle traffic
(Section 3.0) and for wind erosion (Equation 4-9), centering around
parameter p, follows the methodology described in Section 3.0.   Also, a
separate set of nonclimatic correction parameters and source extent values
corresponding to higher than normal storage pile activity may be justified
for the worst case averaging period.
4.2  DEMONSTRATED CONTROL TECHNIQUES
     The control techniques applicable to storage piles  fall  into  distinct
categories as related to materials handling operations (including  traffic
around piles) and wind erosion.   In both cases,  the  control  can  be
achieved by (a) source extent reduction, (b)  source  improvement  related to
work practices and transfer equipment (load-in and load-out  operations),
and (c) surface treatment.  These control  options are summarized  in
Table 4-6.  The efficiency of these controls  ties back to  the emission
factor relationships presented earlier in this section.
     In most cases, good work practices  which  confine freshly exposed
material provide substantial  opportunities  for emission  reduction  without
the need for investment in a control  application  program.  For example,
pile activity, loading and unloading,  can be confined to  leeward
(downwind) side of the pile.   This statement also applies  to  areas around

                                 4-18

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             TABLE 4-6.   CONTROL TECHNIQUES FOR STORAGE PILES
Material handling
  Source extent reduction
  Source improvement

  Surface treatment
Wind erosion
  Source extent reduction

  Source improvement

  Surface treatment
Mass transfer reduction
Drop height reduction
Wind sheltering
Moisture retention
Wet suppression
Disturbed area reduction
Disturbance frequency reduction
Spillage cleanup
Spillage reduction
Disturbed area wind exposure
  reduction
Wet suppression
Chemical stabilization
                                   4-19

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the pile as well as the pile itself.  In particular, spillage of material
caused by pile load-out and maintenance equipment can add a large  source
component associated with traffic-entrained dust.  Emission inventory
calculations show, in fact, that the traffic dust component may easily
dominate over emissions from transfer of material and wind erosion.  The
prevention of spillage and subsequent spreading of material by vehicle
tracking is essential to cost-effective emission control.  If spillage
cannot be prevented because of the need for intense use of mobile
equipment in the storage pile area, then regular cleanup should be
employed as a necessary mitigative measure.
     The evaluation of preventative methods which change the properties or
exposure of transfer streams or surface material are discussed in the
following section.
4.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES
     Preventive methods for control of windblown emissions from raw
material storage piles include chemical  stabilization,  enclosures, and
wetting.  Physical stabilization by covering the exposed surface with less
erodible aggregate material and/or vegetative .stabilization are seldom
practical control methods for raw-material  storage piles.
     To test the effectiveness of chemical  stabilization controls for wind
erosion of storage piles and tailings piles, wind tunnel measurements have
been performed.  Although most of this work has been carried  out in
laboratory wind tunnels, portable wind tunnels  have been used  in the field
on storage piles and tailings piles.16,17   Laboratory wind tunnels have
also been used with physical models to measure  the effectiveness of wind
screens in reducing surface wind velocity.11
4.3.1  Chemical Stabilization
     A portable wind tunnel has been used to measure the control  of coal
pile wind erosion emissions by a 17 percent solution of  Coherex® in water
applied at an intensity of 3.4 L/m2 (0.74 gal/yard2), and a 2.8  percent
solution of Dow Chemical M-167 Latex Binder in  water applied at  an  average
intensity of 6.8 L/m2 (1.5 gal/yard2).16  The control efficiency of
Coherex® applied at the above intensity  to  an undisturbed steam  coal
surface approximately 60 days before the test,  under a wind of  15.0 m/s
(33.8 mph) at 15.2 cm (6 in.)  above the  ground,  was  89.6 percent  for TP
                                 4-20

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and approximately 62 percent for IP and FP.  The control  efficiency  of the
latex binder on a low volatility coking coal is shown  in  Figure  4-4.
     Cost elements for chemical stabilization are presented  in
Table 4-7.  The cost of a system for application of surface  crusting
chemicals to storage piles is $18,400 for the initial  capital cost and
$0.006 to $0.Oil/ft2 for annual operating expenses based  on  April 1985
dollars.18  Tables 4-8 and 4-9 provide recordkeeping forms for application
of chemical dust suppressants.
4.3.2  Enclosures
     Enclosures are an effective means by which to control fugitive
particulate emissions from open dust sources.  Enclosures can either fully
or partially enclose the source.  Included in the category of partial
enclosures are porous wind screens or barriers.  This particular type  of
enclosure is discussed in detail below.
     With the exception of wind fences/barriers, a review of available
literature reveals no quantitative information on the effectiveness of
enclosures to control fugitive dust emissions from open sources.  Types of
passive enclosures traditionally used for open dust control  include three-
sided bunkers for the storage of bulk materials, storage silos for various
types of aggregate material  (in lieu of open piles), -open-ended buildings,
and similar structures.  Practically any means that reduces wind
entrainment of particles produced either through erosion of a dust-
producing surface (e.g., storage silos) or by dispersion of a dust plume
generated directly by a source (e.g.,  front-end loader in a three-sided
enclosure) is generally effective in controlling fugitive particulate
emissions.  However, available data are not sufficient to quantify
emission reductions.
     Partial enclosures used  for reducing  windblown dust from large
exposed areas and storage piles include porous  wind fences and similar
types of physical barriers (e.g.,  trees).   The  principle of the  wind
fence/barrier is to provide  an area of  reduced  wind velocity  which  allows
settling of the large particles (which  cause saltation) and reduces  the
particle flux from the exposed surface  on  the leeward  side of the fence/
barrier.  The control efficiency of wind  fences  is dependent  on  the
physical dimensions of the fence relative  to the source being
                                 4-21

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  100
   80
o
c
CD
"o
   60
LLJ
o 40
"c
o
o
   20
                                       6.8    /m2(l.5 gal/yd2) of
                                       2.8% Solution in Water
Tunnel Wind
Speed = 17 m/s (38 mph)
at 15 cm (6.0 in)
Above the Test Surface
Key:

o
D-
                  •OTP
                  •a IP

                  I	
                    1
1
      0           12            3            4

                      Time After Application (Days)


        Figure 4-4. Decay in control efficiency of latex binder applied to
                           coal  storage piles.LS
                                4-22

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 TABLE 4-7.   CAPITAL AND O&M ITEMS FOR CHEMICAL STABILIZATION
                     OF OPEN AREA SOURCES
Capital equipment

  •  Storage equipment
       Tanks
       Railcars
       Pumps
       Piping

  •  Application equipment
       Trucks
       Spray system
       Piping (including winterizing)

O&M expenditures

  •  Utility or fuel costs
       Water
       Electricity
       Gasoline or d'iesel fuel

  •  Supplies
       Chemicals
       Repair parts

  •  Labor
       Application time
       Road conditioning
       System maintenance
                             4-23

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            TABLE 4-8.   TYPICAL FORM  FOR RECORDING CHEMICAL DUST SUPPRESSANT  CONTROL  PARAMETERS

                                        Application
                Type of      Dilution     intensity,                        Equipment     Operator
Date     Time    chemical     ratio       gal/yd         Area(s) treated     used          initials    Comments

-------
                          TABLE 4-9.  TYPICAL  FORM FOR RECORDING DELIVERY OF CHEMICAL  DUST  SUPPRESSANTS

                            Chemical      Quantity      Delivery
           Date    Time     delivered     delivered     agent       .Facility destination3     Comments
i
IX)
ui
           aDenote  whether suppressant will  be applied immediately upon  receipt or placed  in storage.

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controlled.  In general, a porosity (i.e., percent open area)  of
50 percent seems to be optimum for most applications.  Wind fences/
barriers can either be man-made structures or vegetative in nature.
     A number of studies have attempted to determine the effectiveness  of
wind fences/barriers for the control  of windblown dust under field
conditions.  Several of these studies have shown both a. significant
decrease in wind velocity as well  as  an increase in sand dune  growth on
the lee side of the fence.19-22
     Various problems have been noted with the sampling methodology used
in each of the field studies conducted to date.   These problems tend to
limit an accurate assessment of the overall  degree of control  achievable
by wind fences/barriers for large  open sources.   Most of this work has
either not thoroughly characterized the-velocity profile behind the
    •
fence/barrier or adequately assessed  the particle flux from the exposed
surface.
     A 1988 laboratory wind tunnel  study of  windbreak effectiveness for
coal storage piles showed area-averaged wind speed reductions of -50 to
70 percent for a 50 percent porosity  windbreak with height  equal to the.
pile height and length equal  to the pile base.   The windbreak was located
three pile heights upwind from the  base of the pile.   This  study also
suggested "that fugitive dust emissions on the top of the pile may be
controlled locally through the use  of a windbreak at  the top of the pile."
     Based on the 1.3 power given  in  Equation (4-1),  reductions of -50 to
70 percent would correspond to -60  to 80 percent  control of material
handling PM10 emissions.  Estimation  of wind erosion  control  requires
source-specific evaluation because  of the  interrelation of  ut  and u* (for
both controlled and uncontrolled conditions)  in  Equation (4-14).
     This same laboratory study showed  that  a storage  pile  may  itself
serve as a wind break by reducing wind  speed  on  the  leeward face
(Figure 4-3).  The degree of  wind sheltering  and  associated wind erosion
emission reduction is dependent on  the  shape  of the pile and on the
approach angle of the wind to an elongated pile.
     One of the real  advantages of  wind  fences for the control  of  PM10
involves the low capital  and  operating  costs.21,23  These involve  the
following basic elements:
                                 4-26

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     •  Capital equipment:
        —  Fence material and supports
        ~  Mounting hardware
     •  Operating and maintenance expenditures:
        —  Replacement fence material and hardware
        —  Maintenance labor
     The following cost estimates (in 1980 dollars)  were  developed for
wind screens applied to aggregate storage piles:24
     •  Artificial wind guards:
        --  Initial capital cost = $12,000 to $61,000
     •  Vegetative wind breaks
        —  Initial capital costs = $45 to $425 per  tree
     Due to the lack of quantitative data on costs associated with wind
screens, it is recommended that local vendors be contacted to obtain more
detailed data for capital and operating expenses.  Also,  since wind fences
and screens are relatively "low tech" controls, it may be possible for the
site operator to construct the necessary equipment using  site personnel
with less expense.
     As with other options mentioned above, the main regulatory approach
involved with wind fences and screens would involve recordkeeping  by the
site operator.  Parameters to be specified in the dust control plan and
routinely recorded are:
     General Information to be Specified in Plan
     1.  Locations of all materials  storage and handling operations to be
controlled with wind fences referenced on a plot plan available to the
site operator and regulatory personnel
     2.  Physical dimensions of each source to be controlled and
configuration of each fence or screen to be installed
     3.  Physical characteristics  of material  to be handled  or stored  for
each operation to be controlled by fence(s)  or screen(s)
     4.  Applicable prevailing meteorological  data (e.g.,  wind speed and
direction) for site on an annual  basis
     Specific Operational  Records
     1.  Date of installation of wind fence or screen and  initials of
installer
                                 4-27

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      2.   Location of installation relative to source  and  prevailing winds
      3.   Type of material being handled and stored and  physical  dimensions
of  source controlled
      4.   Date of removal of wind fence or screen and  initials  of personnel
involved
      General Records to be Kept
      1.   Fence or screen maintenance record
      2.   Log of meteorological conditions for each day  of  site operation
4.3.3 Wet Suppression Systems
      Fugitive emissions from aggregate materials handling  systems  are
frequently controlled by wet suppression systems.  These systems use
liquid sprays or foam to suppress the formation of airborne dust.   The
primary control mechanisms are those that prevent emissions through
agglomerate formation by combining small  dust particles with larger
aggregate or with liquid droplets.  The key factors that affect the degree
of  agglomeration and, hence, the performance of the system are the
coverage  of the material by the liquid and the ability of the  liquid  to
"wet" small particles.   This section addresses two types of wet
suppression systems--liquid sprays which  use water or water/surfactant
mixtures  as the wetting agent and systems  which  supply foams as the
wetting agent.
      Liquid spray wet suppression systems  can  be used  to control  dust
emissions from materials handling at conveyor  transfer points.   The
wetting agent can be water or a combination  of water  and a chemical
surfactant.  This surfactant,  or surface active  agent, reduces  the surface
tension of the water.   As  a result,  the quantity of liquid  needed to
achieve good control is reduced.   For systems  using water  only, addition
of  surfactant can reduce the quantity of water necessary to achieve a good
control by a ratio of 4:1  or more.25,26
     The design specifications  for wet suppression systems  are  generally
based on the experience of  the  design engineer rather  than  on established
design equations  or handbook  calculations.  Some general design guidelines
that have been reported in  the  literature as successful  are  listed  below:
     1.  A variety of nozzle  types have been used on wet suppression
systems,  but recent  data suggest that  hollow cone nozzles produce the
greatest control  while  minimizing clogging.27

                                 4-28

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     2.  Optimal droplet size for surface  impaction  and fine particle
agglomeration is about 500 urn; finer droplets  are  affected by drift and
surface tension and appear to be less effective.28
     3.  Application of water sprays to the underside  of a conveyor belt
improves the performance of wet suppression systems  at belt-to-belt
transfer points.29
     Micron-sized foam application is an alternative to water spray
systems.  The primary advantage of foam systems is that they provide
equivalent control at lower moisture addition rates  than spray
systems.29  However, the foam system is more costly  and requires  the  use
of extra materials and equipment.  The foam system also achieves  control
primarily through the wetting and agglomeration of fine particles.  The
fol-lowing guidelines to achieve good particle agglomeration  have  been
suggested:30
     1.  The foam can be made to contact the particulate material by  any
means.  High velocity impact or other brute force means  are  not
required.
     2.  The foam should be distributed throughout the  product material.
Inject the foam into free-falling material  rather than cover the product
with foam.
     3.  The amount applied should allow all of the foam to dissipate.
The presence of foam with the product indicates that either too much foam
has been used or it has not been adequately dispersed within the
material.
     Available data for both water spray and foam wet suppression systems
are presented in Tables 4-10 and 4-11,  respectively.   The data primarily
included estimates of control  efficiency based  on concentrations of total
particulate or respirable dust in  the workplace atmosphere.  Some data on
mass emissions reduction are also  presented.  The  data  should be viewed
with caution in that test data ratings  are  generally  low and only minimal
data on process or control  system  parameters  are presented.
     The data in Tables 4-10 and 4-11 do indicate  that  a wide range of
efficiencies can be obtained from wet suppression  systems.   For conveyor
transfer stations,  liquid spray  systems  had efficiencies ranging from  42
to 75 percent, while foam systems had efficiencies  ranging  from 0  to
                                 4-29

-------
                      TABLE  4-10   SUMMARY  OF  AVAILABLE CONTROL  EFFICIENCY  DATA FOR  WATER  SPRAYS
Ref.
No. Type of process Type of material
25 Chain feeder to Coal
belt transfer



Belt-to-belt Coal
transfer


27 Grizzly transfer Run of mill sand
to the bucket
elevator
•F*
CO
o

28 Conveyor trans- Coal
port and
transfer
Process design/
operating parameters Control system parameters
3 ft drop, 8 tons coal per load 8 sprays, 2.5 gal/min, above
belt only
8 sprays. 2.5 gal/min and one
one spray on underside of
belt
Not specified 8 sprays, 2.5 gal/min above
belt only8
8 sprays, 2.5 gal/min and one
one spray on underside of
belt3
Not specified Liquid volume 757 ml

Liquid volume 1,324 ml
Liquid volume 1,324 mLe
Liquid volume 1.324 mLf

1 belts 0.91 m and 1.07 m 3 spray bars/belt, underside
widths, "500 m length of tall pulley, 5-10 cc
H 0/s per bar, Delevan
"Fanjet" sprays
Measurement technique3
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme

Personnel samplers,
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme^

Test
No. of data
tests rating
10 C

4 C


10 C
4 C

NA C

NA C
NA C
NA C

NA D

Control
effi-
ciency,
percent1"
RP 56
TP 59
RP 81
TP 87

RP 53
RP H2

RP 46

RP 58
RP 54
RP 54

RP-65-76

 RAM samples are from Realtime Aerosol Monitors, light scattering type instruments.  Type 1 tests  include measurements of  a single source with and without control.
"Test rating scheme defined  in Section 4.4.
'IP = Total particulate; RP  = respirable paniculate.
 Control applied at a point  five transfers upstream.
^Water+1.5 percent surfactant.
 Water*2.5 percent surfactant.
^Individual test values not  specified; no airflow data or QA/QC data.

-------
TABLE 4-11.  SUMMARY OF AVAILABLE CONTROL EFFICIENCY DATA FOR FOAM SUPPRESSION  SYSTEMS
Ref. Process design/
No. Type of process Type of material operating parameters
27 Belt-to-belt 30-nesh glass sand Sand temp. ~120°F
transfer
Belt-to-bin 30-»esh glass sand Sand temp. "120°F
transfer
Bulk loadout 30-mesh glass sand Sand temp. ~120°F

Screw-to-belt Cleaned run-of- 174 tons/h, sand temp. ~190°F
transfer mine sand
Bucket elevator Cleaned run-of- 179 tons/h, sand temp. "190°F
discharge mind sand
^ Belt-to-belt Cleaned run-of- 193 tons/h. sand temp. "190°F
1 transfer mine sand
CO
I—"
Feeder bar Cleaned run-of- 191 tons/h, sand temp. "WF
discharge mine sand
Grizzley transfer Dried run of mine Hot specified
to bucket sand
elevator



25 Cnain feeder to Coai 3-ft drop, 8 tons coal per load
belt transfer

Belt-to-belt Coal Not specified
transfer

Control system parameters
Not specified

Nqt specified

Not specified
.
Moisture = 0.25 percent

Moisutre = 0.18 percent

Moisture = 0.18 percent


Moisutre - 0. 19 percent

Foam rate - 10.5 ft /ton sand
Liquid rate * 0.38 gal/min
Foam rate = 8.2 ft3/ton sand
Liquid rate - 0.34 gal/min
Foam rate - 7.5 ft /ton sand
Liquid rate - 0.20 gal/min
50 psi HO, 2.5 percent
reagent, four nozzles 15 to
20 ft3 foam applied1*
50 psi HO, 2.5 percent
reagent, four nozzles 15 to
20 ft3 foam applied6
Measurement technique3
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Grav/RAM samplers,
Type 1 scheme
RAM/personnel samplers.
Type 1 test scheme
RAM/personnel samplers.
Type 1 test scheme

RAM/personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel sampler*.
Type 1 test scheme




Test
No. of data
tests rating
NA C

NA C

NA C

4 C

5 C

8 C


6 C

2 C

1 C

1 C

9 C





Control
effi-
ciency,
percent1
RP 20d

RP 33d

RP 65d

RP 10d

RP Bd

RP ?d


RP 2d

RP 92

RP 74

RP 68

RP 9f.
TP 9?

RP 71


                                                                                            (continued)

-------
TABLE 4-11.  (continued)


Ref. Process design/



No. Type of process Type of material operating parameters Control system parameters
27 Grizzley Dried run-of-mine Not specified Foam rate « 4.
sand Liquid rate -
Foam rate = 2.
Liquid rate -
Liquid volume

Liquid volume

Liquid volume

8 ft3/ton sand
0.18 gal/mi n
6 ft3/ton sand
0.13 gal/min
1,420 mL

1,330 mL

764 mL




Measurement technique3
Personnel samplers.
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
Personnel samplers,
Type 1 test scheme
Personnel samplers,
Type 1 test scheme
Personnel samplers.
Type 1 test scheme
J'RAM samples are from Realtime Aerosol Monitors, light scattering type instruments. Type 1 tests include measurements of a single source with
Test rating scheme defined in Section -1.4.
'RP = respirable particulate.
Efficiency based on concentrations only.
1
OJ
ro










Control
Test effi-
No. of data ciency,
tests rating percent0
2 C RP 0

NA C RP 0

NA C RP 91

NA C RP 73

NA C RH tfi

and without control.






-------
92 percent.  The data are not sufficient  to  develop  relationships between
control or process parameters and control  efficiencies.   However, the
following observations relative to the data  in Tables  4-10  and  4-11  are
noteworthy:
     1.  The quantity of foam applied to  a system does have an  impact on
system performance.  On grizzly transfer  points, foam  rates of  7.5 ft3  to
10.5 ft3 of foam per ton of sand produced  increasing control  efficiencies
ranging from 68 to 98 percent.31  Foam rates below 5 ft3  per ton  produced
no measurable control.
     2.  Material temperature has an impact on foam performance.   At  one
plant where sand was being transferred, control efficiencies  ranged from
20 to 65 percent when 120T sand was handled.  When sand  temperature  was
increased to 190°F, all control efficiencies were below 10  percent.31
     3.  Data at one plant suggest that underside belt sprays increase
control efficiencies for respirable dust  (56 to 81 percent).2<*
     4.  When spray systems and foam systems are used to  apply equivalent
moisture concentrations, foam systems appear to provide greater control.31
On a grizzly feed to a crusher, equivalent foam and spray applications
provided 68 percent and 46 percent control efficiency, respectively.
Capital and O&M cost elements for wet suppression are shown  in Table 4-12.
     In estimating the wind erosion control effectiveness of wet
suppression, it can be assumed that emissions are inversely proportional
to the square of the surface moisture content.   The emission/moisture
dependence is embedded in the agricultural wind erosion equation as
described in Section 7.  It also appears in the observed  relationship
between the role of emissions from an unpaved road  and the surface
moisture content, as illustrated in Figure 3-3.
     In addition, a relationship between surface moisture content and
daily moisture addition has been developed from field studies of storage
piles exposed to natural precipitation.   The  results  of that research are
illustrated in the example problem to be presented  at the end of this
section.
     Costs associated with wet suppression systems  include the following
basic elements:
                                 4-33

-------
      TABLE 4-12.   WET SUPPRESSION SYSTEM CAPITAL AND O&M
                        COST ELEMENTS

Capital equipment

  •  Water spray system
       Supply pumps
       Nozzles
       Piping (including winterization)
       Control system
       Filtering units

  •  Water/surfactant and foam systems only
       Air compressor
       Mixing tank
       Metering or proportioning unit
       Surfactant storage area

O&M expenditures

  •  Utility costs
       Water
       Electricity          -

  •  Supplies
       Surfactant
       Screens

  •  Labor
       Maintenance
       Operation
                             4-34

-------
     •  Capital equipment:
        —  Spray nozzles or other distribution  equipment
        —  Supply pumps and plumbing  (plus  weatherization)
        —  Water filters and flow control equipment
        —  Tanker truck (if used)
     •  Operating and maintenance expenditures:
        —  Water and chemicals
        —  Replacement parts for nozzles, truck,  etc.
        —  Operating labor
        —  Maintenance labor
     Reference 6 estimates the following costs (in  1985 dollars):
     •  Regular watering of storage piles:
        —  Initial capital cost = $18,400 per system
     •  Watering of exposed areas:
        —  Initial capital cost = $1,053 per acre
        —  Annual operating cost = $25 to 67 per acre
     The costs associated with a stationary wet  suppression system using
chemical surfactants for the unloading of limestone from  trucks at
aggregate processing plants (in 1980 dollars)-have been estimated at:
capital = $72,000; annual = $26,000.  Typical costs for wet suppression of
materials transfer operations are listed in Table 4-13.
     As with watering of unpaved surfaces, enforcement of a wet
suppression control program would consist of two complementary
approaches.  The first would be record keeping to document that the
program is being implemented and the other would be spot-checks and grab
sampling.  Both were discussed previously above.
     Records must be kept that document the control plan and its
implementation.  Pertinent parameters to be specified in a plan and to be
regularly recorded include:
     General Information to be Specified in Plan
     1.  Locations of all  materials  storage and handling operations
referenced on plot plan of the site  available to the site operator and
regulatory personnel
     2.  Materials delivery or transport flow sheet which indicates the
type of material, its handling and storage,  size  and composition of
storage piles, etc.

                                 4-35

-------
        TABLE 4-13.  TYPICAL COSTS FOR WET SUPPRESSION OF MATERIAL
                             TRANSFER POINTS
Source method
Initial  cost,
 April  1985
  dollars5
Unit operating cost,
April 1985 dollars5
Railcar unloading station       48,700
  (foam spray)

Railcar unloading station      168,000
  (charged fog)

Conveyor transfer point         23,700
  (foam spray)

Conveyor transfer point         19,800
  (charged fog)
                NR
                NR
                0.02 to 0.05/ton material
                  treated

                NR
^Reference 18.  NR = not reported.
 January 1980 costs updated to April  1985 cost  by  Chemical  Engineering
 Index.  Factor = 1.315.
^Based on use of 16 large devices  at  $10,500 each.
 Based on use of three small  devices  at  $6,600  each.
                                   4-36

-------
     3.  The method  and  application  intensity of water,  etc., to be
applied to the various materials  and  frequency of application,  if not
continuous
     4.  Dilution ratio  for chemicals  added  to water supply,  if any
     5.  Complete specifications  of equipment used to handle  the various
materials and for wet suppression
     6.  Source of water and chemical(s),  if  used
     Specific Operational Records
     1.  Date of operation and operator's  initials
     2.  Start and stop time of wet suppression  equipment
     3.  Location of wet suppression equipment
     4.  Type of material being handled-and number of loads (or  other
measure of throughput) loaded/unloaded between start  and stop time  (if
material is being pushed, estimate the volume or  weight)
     5.  Start and stop times for tank filling
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological log of general conditions
     3.  Records of equipment malfunctions and downtime
4.4  EXAMPLE DUST CONTROL PLAN—WATERING OF .COAL" STORAGE-PILE .
     Description of Source
     •  Conically shaped pile (uncrusted coal)
     •  Pile height of 11 m; 29.2 m base diameter; 838 m2 surface area
     •  Daily reclaiming of downwind face of pile; pile replenishment
        every 3 d affects entire pile surface (Figure 4-5)
     •  LCD as shown in Figure 4-6 for a typical month
     •  Coal  surface moisture content of 1.5 percent      <
     Calculation of Uncontrolled Emissions
     Step 1;   In the absence of field data for estimating the  threshold
friction velocity,  a value of 1.12 m/s is obtained from Table  4-3.
     Step 2:   Except for a small  area near the base of the  pile  (see
Figure 4-5),  the entire pile surface is disturbed every 3 d, corresponding
to a value of N = 120/yr.  It will be shown that the contribution of the
area where daily activity occurs  is negligible so that it does not need  to
be treated separately in the calculations.
                                 4-37

-------
Prevailing
Wind
Direction
                                                                      Circled  values
                                                                      refer  to us/ur
 * A portion of Cg is disturbed daily by reclaiming activities,
                  Area
                   ID
                A

                B
"s
ur

0.9

0.6

0.2
  Pile Surface

_%_     Area (m2)

12         101

48         402
             i
40         335

           838
    Figure 4-5.  Example 1:   Pile  surface areas within each wind speed regime,
                                      4-38

-------
         Local Climatological  Data     .X>*«
                  MONTHLY SUMMARY
30 I 3.3 IM
                         3
                       •IOA1L:  I

tr
o
z
ex
13
30
0
10
13
12
20
29
29
22
29
I 7
2 1
10
10
0 I
33
27
32
24
22
32
29
07
34
1
30
30
33
29


— a.
5 c
_l C
t . i Q_
C (./l
5.3
10.5
2.4
I I .0
11.3
M.I
19.6
10.9
3.0
14.6
22.3
7.9
7.7
4 . 5
6.7
13.7
M.2
4 . 3
9.3
7.5
0.3
17.1
2.4
5.9
1 .3
2. 1
8.3
3.2
5.0
3 . l
4.9
WIND
0
Q.
c: a.
>• £
15
6.9
10.6
6.0
M . 4
M . 9
19.0
19.3
M.2
a. i
15.1
23.3
3.5
5.5
9.5
3:8
3.3
1 .5
5.3
0.2
7.8
0.5
7.3
8.5
3.8
M.7
12.2
3.5
8.3
6.6
5.2
5.5

FA
H
^
o ""
UJ
c. s
IS
10
16
1 7
1 5
23
13
•13.
12
1 4
1 S
15
16
15
9
3

STEST
HE
z
0
c:
o
17
35
01
02
1 3
I 1
30
30
30
1 3
12
29
! 7
13
1 3
! 1
35
34
31
35
24
20
32
13
02
32
32
25
32
32
3 1
25 1


^
C
2
i
2
3
c
c
7
a
9
l 0
! 1
t
5
5
7
2
9
2C
21
22
23
24
2?
25
27
29
30
1 3 '•
Figure 4-6. Daily fastest miles of wind for periods of interest.
                        4-39

-------
     Step 3;  The calculation procedure involves determination  of  the
fastest mile for each period of disturbance.  Figure 4-6 shows  a
representative set of values (for a 1-mo period) that are assumed  to be
applicable to the geographic area of the pile location.  The values have
been separated into 3-d periods, and the highest value in each  period  is
indicated.  In this example, the anemometer height is 7 m, so that a
height correction to 10 m is needed for the fastest mile values.
     From Equation (4-6)

                      ,,+    „+ In (10/0.005)
                      ui° ~ U7 In (7/0.005)

                      uto = 1.05 ut

     Step 4;  The next step is to convert the fastest mile value for each
3-d period into the equivalent friction velocities for each surface wind
regime (i.e., us/ur ratio) of the pile, using Equations 4-7 and 4-8.
Figure 4-5 shows the surface wind speed pattern (expressed as a fraction
of the approach wind speed at a height of 10 m).  The surface areas lying
within each wind speed regime are tabulated below the figure.
     The calculated friction velocities are presented in  Table 4-14.  As
indicated, only three of the periods contain a friction velocity which
exceeds the threshold value of 1.12 m/s for an uncrusted  coal pile.  These
three values all occur within the us/ur = 0.9 regime  of the pile surface.
     Step 5;  This step is not necessary because there  is only one
frequency of disturbance used in the calculations.   It  is clear that the
small area of daily disturbance (which lies entirely  within the us/ur  =
0.2 regime) is never subject to wind speeds exceeding the threshold value.
     Steps 6 and 7;  The final  set of calculations  (shown in  Table 4-15)
involves the tabulation and summation of emissions  for  each  disturbance
period and for the affected subarea.  The erosion  potential  (P)  is
calculated from Equation (4-4).
                                 4-40

-------
       TABLE 4-14.  EXAMPLE  1:  CALCULATION OF FRICTION  VELOCITIES
3-day
period
1
2
3
4
5
6
7
8
9
10

mph
14
29
30
31
22
21
16
25
17
13
uj
m/s
6.3
13.0
13.4
13.9
9.8
9.4
7.2
11.2
7.6
5.8
uto
mph
15
31
32
33
23
22
17
26
18
14

m/s
6.6
13.7
14.1
14.6
10.3
9.9
7.6
11.8
8.0
6.1
u* =
us/ur { 0.2
0.13
0.27
0.28
0.29
0.21
0.20
0.15
0.24
0.16
0.12
0.1 u+
0.6
0.40
0.82
0.84
0.88
0.62
0.59
0.46
0.71
0.48
0.37
(m/s)
0.9
0.59
1.23
1.27
1.31
0.93
0.89
0.68
1.06
0.72
0.55
          TABLE  4-15.   EXAMPLE  1:   CALCULATION OF  PM10  EMISSIONS3
Pile Surface
3-Day
period
2
3
4

u*, m/s
1.23
1.27
1.31

u* - ut ,
m/s
0.11
0.15
0.19

P, g/m
3.45
5.06
6.84
Total PM10
ID
A
A
A
emissions
Area,
m
101
101
101
= 780
kPA,
g
170
260
350

aWhere uJ = 1.12 m/s for uncrusted coal  and  k  =  0.5  for PM10.
                                   4-41

-------
     For example, the calculation for the  second  3-d  period  is:

          P2 = 58(1.23-1.12)2+25(1.23-1.12)

             = 0.70+2.75 = 3.45 g/m2

     The PM10 emissions generated by each  event are found  as  the  product
of the PM10 multiplier (k = 0.5), the erosion potential  (P),  and  the
affected area of the pile (A).
     As shown in Table 4-15, the results of these calculations indicate a
monthly PM10 emission total of 780 g.
     Target Control Efficiency:  60 percent
     Method of Control:  Daily watering of erodible surfaces  of coal  pile
(2 gal/m2)
     Demonstration of Control Program Adequacy:  Wind-generated dust
emissions are known to be strongly dependent (inverse square) on moisture
content as described in Section 4.3.3.   In addition, coal storage pile
surface moisture, M, is correlated with weighted precipitation, Pw, as
follows:3

                           Mc  = 0.13 Pw +  1.41                      (4-10)

where:   M = surface moisture content (percent)

             4 d
        pw =  I   pn exp[-(n  -  0.5)]  (mm)
             n=l
        Pn = daily precipitation or watering  amount  (mm)  for  the  nth day
             in the past
     For uniform daily water  application,  Pw  -  Pn.
     Uncontrolled PM10 wind erosion emissions,  EU, from the storage  pile
were shown to be 780 g for the  month.   To achieve  a  control efficiency of
60 percent,  calculate the controlled  emissions,  EC,  using the  following
relationship.
                                 4-42

-------
                    Ec = Eu  (1 - 0.60)

                       = 312 g

     The inverse square relationship of wind emissions with  surface
moisture content can be written as follows:

                                    (M)2
E
                                ~ =
     Solving for the controlled surface moisture content, MC, using an
uncontrolled moisture content, MU = 1.5 percent, produces:

                        MC = MU   ^  = 2.4 percent
                                   c
     To achieve this moisture content, use Equation 4-10 to determine the
daily water application rate.
                                   .M,.  - 1.41
                              p  - _i=	
                              . w     0.13
                                 = 7.4 mm
     Convert this daily watering amount to gal/m2 of erodible pile surface
to obtain a recommended daily water application rate of 1.95 gal H20/m2.
     The upper pile area where Us/Ur > 0.9 is the only surface which needs
to be controlled in the example month since this area has been shown to
produce virtually all the emissions.  In this instance, it is only
necessary to water the pile surface impacted by winds producing Us/Ur
values > 0.9.  This area can be estimated from Figure 4-5 if the 0.9
subarea is rotated about the pile center to represent the possible
360 degree impact of winds on the pile.
     The surface area to be controlled is equivalent to the area of a cone
with base diameter of about 21.3 m.  This upper cone has an area of
53 percent of the entire coal pile surface, e.g., about 450 m?.
Consequently, 900 gal of water applied daily to the 450 m2 of erodible
surface will achieve a control efficiency of 60 percent.
                                 4-43

-------
4.5  POTENTIAL REGULATORY FORMATS

     There are several possible regulatory formats for control of dust

emissions from storage piles.  Opacity standards are suitable for a

standard observed at the point of emissions, such as continuous drop from

a stacker; however, they may not be legally applied at the property line.

     For wet suppression and chemical  stabilization, suitable

recordkeeping forms, such as those provided above, would provided evidence

of control plan implementation.  In addition, simple measurements of

moisture level in transferred material or of the crust strength of the

chemically treated surface could be used to verify compliance.  In

addition, the loading as well as the texture of material deposited around

the pile could be used to check whether good work practices are being

employed relative to pile reclamation  and maintenance operations.  The

suitability of these measurements of surrogate parameters for source
emissions stems from the emission factor models which relate the

parameters directly to emission rate.

4.6  REFERENCES FOR SECTION 4

 1.  Cowherd, C., Jr., et al.  Development of Emission Factors for. Fugi-
     tive Dust Sources.  EPA-450/3-74-037.  U. S. Environmental  Protection
     Agency, Research Triangle Park, North Carolina.   June 1974.

 2.  Bonn, R., et al.  Fugitive Emissions from Integrated Iron and Steel
     Plants.  EPA-600/2-78-050.  U.  S. Environmental  Protection  Agency,
     Research Triangle Park, North Carolina.   March 1978.

 3.  Cowherd, C., Jr., et al.  Iron and and Steel  Plant Open Dust Source
     Fugitive Emission Evaluation.   EPA-600/2-79-103.   U. S.  Environmental
     Protection Agency, Research Triangle Park,  North  Carolina.   May 1979.

.4.  Bohn, R.  Evaluation of Open Dust Sources in the  Vicinity of Buffalo,
     New York.  U. S. Environmental  Protection Agency,  New York,  New
     York.  March 1979.

 5.  Cowherd, C., Jr., and T. Cuscino, Jr.   Fugitive  Emissions Evaluation.
     Equitable Environmental Health,  Inc.,  Elmhurst,  Illinois.   February
     1977.

 6.  Cuscino, T., et al.   Taconite  Mining Fugitive  Emissions  Study.
     Minnesota Pollution Control  Agency,  Roseville, Minnesota.  June  1979.

 7.  Axetell, K., and C.  Cowherd,  Jr.   Improved  Emission  Factors  for  Fugi-
     tive Dust from Western Surface  Coal  Mining  Sources.   2 Volumes.  EPA
     Contract No. 68-03-2924, PEDCo  Environmental,  Inc.,  Kansas City,
     Missouri.  July 1981.
                                 4-44

-------
 8.  Cowherd, C., Jr.  "Background Document for AP-42 Section 11.2.7 on
     Industrial Wind Erosion."  EPA Contract No. 68-02-4395, Midwest
     Research Institute.  July 1988.

 9.  Chepil, W. S.  "Improved Rotary Sieve for Measuring State and
     Stability of Dry Soil Structure."  Soil Science Society of America
     Proceedings., 16:113-117.  1952.

10.  Gillette, D. A., et al.  "Threshold Velocities for Input of Soil
     Particles into the Air by Desert Soils."  Journal of Geophysical
     Research. 54(C10):5621-5630.

11.  Studer, B. J. 8., and S. P. S. Arya.  "Windbreak Effectiveness for
     Storage Pile Fugitive Dust Control:  A Wind Tunnel Study."  Journal
     of the Air Pollution Control Association.  38:135-143.  1988.

12.  Muleski, G. E.  "Coal Yard Wind Erosion Measurements.  Final Report
     prepared for Industrial Client of Midwest Research Institute, Kansas
     City, Missouri.  March 1985.

13.  Nicking, W. G., and J. A. Gillies.  "Evaluation of Aerosol  Production
     potential of Type Surfaces in Arizona."  Submitted to Engineering-
     Science.  Arcadia, California, for EPA Contract No. 68-02-388.  1986.

14.  Local Climatological Data.  Monthly Summary Available for each U.S.
     Weather Station from the National Climatic Center.  Asheville, North
     Carolina 28801.

15.  Changery, M. J.  National Wind Data Index Final Report.   National
     Climatic Center, Asheville, North Carolina, HCO/T1041-01 UC-60.
     December 1978.

16.  Cuscino, T., Jr., G. E. Muleski,  and C.  Cowherd,  Jr.   Iron  and Steel
     Plant Open Source Fugitive Emission Control Evaluation.
     EPA-600/2-83-110, NTIS No. PB84-1110568.   U.  S. Environmental  Protec-
     tion Agency, Research Triangle Park, North Carolina.   October 1983.

17.  Bohn, R. R., and J.  D. Johnson.   Dust Control  on  Active  Tailings
     Ponds.  Contract No. J0218024.  U.S. Bureau of Mines,  Minneapolis,
     Minnesota.  February 1983.

18.  U. S. Environmental  Protection Agency.   Control Techniques  for
     Particulate Emissions From Stationary Sources—Volume  1.
     EPA-450/3-81-005a.  Emission Standards  and Engineering Division,
     Research Triangle Park, N.C.   September  1982.

19.  Chepil, N. S., and N. P.  Woodruff.   "The  Physics  of Wind  Erosion and
     Its Control."  In Advances in Agronomy,  Vol.  15,  Academic Press, New
     York.  1963.
                                 4-45

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20.  Carries, D., and D. C. Drehmel.  "The Control of Fugitive  Emissions
     Using Windscreens."  In Third Symposium on the Transfer and
     Utilization of Particulate Control Technology (March 1981),
     Volume IV, EPA-600/9-82-005d, NTIS No. PB83-149617.  April 1982.

21.  Larson, A. G.  Evaluation of Field Test Results on Wind Screen Effi-
     ciency.  Fifth EPA Symposium on Fugitive Emissions:  Measurement  and
     Control, Charleston, South Carolina.  May 3-5, 1982.

22.  Westec Services, Inc.  Results of Test Plot Studies at Owens Dry
     Lake, Inyo County, California.  San Diego, California.  March 1984.

23.  Radkey, R. L., and P. B. MacCready.  A Study of the Use of Porous
     Wind Fences to Reduce Particulate Emissions at the Mohave Generating
     Station.  AV-R-9563, AeroVironment, Inc., Pasadena, California.
     1980.

24.  Ohio Environmental Protection Agency.  1980.  Reasonably Available
     Control Measures for Fugitive Dust Sources.  Columbus, Ohio.
     September 1980.

25.  U. S. Environmental Protection Agency.  Non-Metallic Processing
     Plants, Background Information for Proposed Standards.
     EPA-450/3-83-001a, NTIS No.  PB83-258103.   Research Triangle Park,
     North Carolina.  March 1983.

26.  JACA Corporation.  Control of Air Emissions from Process Operations
     in the Rock Crushing Industry.  EPA-340/1-79-002.   U.  S. Environ-
     mental Protection Agency, Washington, D.C., p.  15.  January 1979..

27.  U.S. Bureau of Mines.  Dust  Knockdown Performance  of Water Spray
     Nozzles.  Technology News, No. 150.  July 1982.

28.  Courtney, W., and L. Cheng.   Control  of Respirable Dust by Improved
     Water Sprays.  Published in  Respirable Dust Control  Proceedings,
     Bureau of Mines Technology Transfer Seminars,  Bureau of Mines
     Information Circular 8753, p. 96.   1978.

29.  Seibel, R.  Dust Control  at  a Conveyor Transfer  Point  Using Foam  and
     Water Sprays.  Bureau of Mines,  Technical  Progress Report  97.
     May 1976,

30.  Cole, H.  Microfoam for the  Control  of Source  and  Fugitive Dust  Emis-
     sions.  Paper 81-55.2.   Presented  at  the  74th Annual Meeting  of  the
     Air Pollution Control Association,  Philadelphia, Pennsylvania.  June
     1981.

31.  Volkwein, J.  C., A.  B.  Cecala,  and  E.  D.  Thimons.   Use  of  Foam  for
     Dust Control  in Minerals  Processing.   Bureau of Mines RI 8808.   1983.
                                 4-46

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                5.0  CONSTRUCTION AND DEMOLITION ACTIVITIES

     Construction and demolition activities are temporary but  important
sources of PM10 in urban areas.  These activities involve a number of
separate dust-generating operations which must be quantified to determine
the total emissions from the site and thus its impact on ambient air
quality.  Also, the specific type of activities which are conducted onsite
will depend of the nature of the construction or demolition project taking
place.
     In the case of construction, a project may involve the erection of a
building(s), single- or multifamily homes, or the installation of a road
right-of-way.  Operations commonly found in these types of construction
projects consist of:  land clearing, drilling and blasting, excavation,
cut-and-fill operations (i.e., earthmoving), materials storage and
handling, and associated truck traffic on unpaved surfaces.
     In addition, secondary impacts associated with construction sites
involve mud/dirt carryout onto paved surfaces.  The additional loading
caused by carryout can substantially increase PM10 emissions on city
streets over the life of the project.
     With regard to demolition, a particular project may involve the
razing and removal of an entire building(s), a major interior renovation
of a structure, or a combination of the two.  Dust-producing operations
associated with demolition are:  mechanical or explosive dismemberment;
debris storage, handling, and transport operations;  and truck traffic over
unpaved surfaces onsite.
     Like construction, demolition activities can also create mud/dirt
carryout onto paved surfaces with its associated increase in emissions.
Also, since building debris is usually being removed from the site,
spillage from trucks can also be of concern in increasing the amount  of
surface loading deposited on the paved street(s)  providing access  to  the
site.  The generic sources of PM10 involved in construction and demolition
sites are shown in Table 5-1.1
                                  5-1

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           TABLE 5-1.   GENERIC OPEN DUST SOURCES ASSOCIATED WITH
                    CONSTRUCTION AND DEMOLITION  SITES


     Construction Sites

          Pushing (land clearing and earthmoving)
          Drilling and blasting
          Batch drop operations (loader operation)
          Storage piles (soil and construction aggregates)
          Exposed areas
          Vehicle traffic on unpaved surfaces
          Mud/dirt carryout onto paved surfaces

     Demolition Sites

       •  Explosive and mechanical  dismemberment (blasting and wrecking
          ball operations)
          Pushing (dozer operation)
          Batch drop operations (loading debris into trucks)
          Stprage piles (debris)
          Exposed areas
          Vehicular traffic on unpaved surfaces
          Mud/dirt/debris carryout  onto paved surfaces


     This section presents a discussion of available emission factors,

demonstrated control techniques, alternative control measures, and

possible formats for determining compliance for controlled construction

and demolition sites.   It must be cautioned, however, that the information
presented is for generic sites and  site-specific analyses will be

necessary for compliance determination.

5.1  ESTIMATION OF EMISSIONS

5.1.1  Construction Emissions

     At present, the only emission  factor available in AP-42 is 1.2 tons/

acre/month (related to particles <30 urn Stokes1  diameter) for an entire
construction site.  No factor has been  published  for demolition in

AP-42.  However, PM10  emission factors  have been  developed for

construction site preparation using test data from  a study conducted in

Minnesota for topsoil  removal, earthmoving (cut-and-fill), and truck

haulage operations.2  For these operations, the  PM10 emission factors

based on the level of  vehicle activity  (i.e., vehicle kilometers  traveled
or VKT) occurring onsite are:3
                                  5-2

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     •  Topsoil removal:   5.7 kg/VKT  for  pan scrapers
     •  Earthmoving:       1.2 kg/VKT  for  pan scrapers
     •  Truck  haulage:     2.8 kg/VKT  for  haul  trucks
PM10 emissions due to materials handling  and wind  erosion  of  exposed  areas
can be calculated using the emission  factors presented  in  Sections  4.0  and
6.0, respectively.
5.1.2  Demolition Emissions
     For demolition sites, the operations  involved  in demolishing and
removing structures from a site are:
     •  Mechanical or explosive dismemberment
     •  Debris loading
     •  Onsite truck traffic
     •  Pushing (dozing) operations
     5.1.2.1  Dismemberment.  Since no emission factor data are available
for blasting or wrecking a building,  the first operation is addressed
through the use of the revised AP-42  materials handling equation:3,"

                                  •      ,,  1.3
                                      ( "  )
                       En = k(0.0016)  Z7? ,  ,                       (5-1).
                                       /MX

where   Eg = PM10 emission factor in  kg/Mg of material
         k = particle size multiplier = 0.35 for PM10
         U = mean wind speed in m/s (default =2.2 m/s)
         M = material moisture content in percent (default = 2 percent)
and     Eg = 0.00056 kg/Mg (with default parameters)
     The above factor can be modified for waste tonnage  related to
structural floor space where 1 m^  of floor space represents 0.45 Mg  of
waste material (0.046 ton/ft2).3  The revised emission  factor  related  to
structural floor space (using default parameters)  can be obtained by:

                     En = 0.00056  kg/Mg •   °'45 Mg
                        = 0.00025 kg/m2
                                  5-3

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     5.1.2.3  Debris Loading.  The emission factor for debris loading  is
based on two tests of the filling of trucks with crushed limestone using  a
front-end loader which is part of the test basis for the batch drop
equation in AP-42, § 11.2.3.5  The resulting emission factor for debris
loading is:3
                     E,  = k(0.029) kg/Mg - °'45 Mg
                        = 0.0046 kg/m2
where 0.029 kg/Mg is the average measured TSP emission factor and k is the
particle size multiplier (0.35 for PM10).
     5.1.2.4  Ons ite Truck Traffic.   Emissions from onsite truck traffic
is generated from the existing AP-42 unpaved road equation presented in
Section 3.0 above.5

      E - 1-7 k (fa) C|i) (577)°' 7 ^°'5(^s^)                     (5-2)
where    E = PM10 emission factor in kg/vehicle kilometer traveled (VKT)
         k = particle size multiplier = 0.36 for  PM10  .
         s = silt content in percent (default = 12 percent)
         S = truck speed in km/h (default = 16 km/h)
         W = truck weight in Mg  (default =20 Mg)
         w = number of truck wheels  (default = 10 wheels)
         p = number of days with measurable precipitation
             (default = 0 days)

and     ET = 1.3 kg/VKT (with default values)
     The above factor is converted from kg/VKT to  kg/in* of  structural
floor space by:3
     E  =   0.40 km   . 1 m3 waste  .    7.65  m3  volume     .  1.3  kg
          23 m3 waste   4 m3 volume    0.836 m2 floor space      VKT
         = 0.052 kg/m2
     5.1.2.5  Pushing Operations.  For pushing (bulldozer) operations,  the
AP-42 emission factor equation for overburden  removal at Western  surface
                                  5-4

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coal mines can be used.5  Although  this  equation  actually relates  to  par-
ticulate <15 ymA, it would be expected that  the PM10  emissions  from such
operations would be generally comparable.  The AP-42  dozer equation is:

                            Ep . 0.45 (S)|'|                         (5.3)

where   E_ = PM10 emission rate in  kg/h
         S = silt content of surface material in  percent
             (default = 6.9 percent)
         M = moisture content of surface material  in  percent
             (default = 7.9 percent)
and     Ep = 0.45 kg/h (with default parameters)

     Finally, PM10 emissions due to wind erosion  of exposed areas can be
calculated as discussed in Section  6.0.  In  general,  these emissions are
expected to be minor as compared to other sources.
5.1.3  Mud/Dirt Carryout Emissions
     Finally, the increase in emissions on paved  roads due to mud/dirt
carryout have been developed based on surface loading measurements at
eight sites.s  Tables 5-2 and 5-3 provide these emission factors in terms
of gm/vehicle pass which represent PM10 generated over and above the
"background" for the paved road sampled.   Table 5-2 expresses the emission
factors according to the volume of traffic entering and leaving the site
whereas Table 5-3 expresses the same data according to type of
construction.
5.2  DEMONSTRATED CONTROL TECHNIQUES
     As discussed above, similar generic  open dust sources exist at both
construction and demolition sites.   Therefore, similar types of controls
would also apply.  In this, section, a discussion  is provided on the
various techniques available for the control  of open dust sources
associated with construction and demolition.   Detailed information  on
control efficiency,  implementation  cost,  etc., will be presented in
Section 5.3 below.
                                  5-5

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TABLE 5-2.   EMISSIONS  INCREASE (aE)  BY SITE TRAFFIC VOLUMEa
Sites with >25 vehicle/d
Particle Standard
size Mean, devia-
fractionb x tion, a Range
<~30 ym 52 28 15-80
<10 urn 13 6.7 4.4-20
<2.5 urn 5.1 2.6 1.7-7.8
aAE expressed in g/vehicle pass.
Aerodynamic diameter.
TABLE 5-3. EMISSIONS INCREASE (A£)
Commercial
Particle Standard
size . Mean, devia-
fractionb x tion, a Range
<~30 urn 65 39 15-110
<10 urn 16 9.3 4.2-25
<2.5 um 6.3 3.6 1.6-9.7
Sites with <25 vehicle/d
Standard
Mean, devia-
x tion, a
19 7.8
5.5 2.3
2.2 0.88

BY CONSTRUCTION TYPEa
Residential
Standard
Mean, devia-
x tion, o
39 22
10 5.4
3.9 . 2.1
Range
14-28
4.2-8.1
1.6-3.2



Range
10-72
2.8-19
1.1-7.3
j*AE expressed in g/vehicle pass.
Aerodynamic diameter.
                            5-6

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5.2.1  Work Practice Controls
     Work practice controls  refer  to  those  measures  which reduce either
emissions potential and/or source  extent.   These will  be discussed  below
for both construction and demolition  activities.
     For construction activities,  a number  of work practice controls  can
be applied to reduce PM10 emissions from the site.   These include paving
of roads and access points early in the project, compaction or  stabiliza-
tion (chemical or vegetative) of disturbed  soil, phasing of earthmoving
activities to reduce source  extent, and reduction of mud/dirt carryout
onto paved streets.  Each of these techniques is pretty  much site-
specific.  However, subdivisions,  for example, can be  constructed in
phases (or plats) whereby the amount of land disturbed is  limited to  only
a selected number of home sites.  Also, subdivision  streets can  be
constructed and paved when the utilities are installed,  thus reducing the
duration of land disturbance.
     Finally, increased surface loading on  paved city  streets due to
mud/dirt carryout can be reduced to mitigate secondary site impacts.  This
may involve the installation of a truck wash at access points to remove
mud/dirt from the vehicles prior to exiting the site or  periodic cleaning
of-the street near site entrances..  All of  these techniques require
preplanning for implementation without substantially interfering with the
conduct of the project.
     In the case of demolition sites, the work practice controls which can
be employed are far more limited than is the case of construction.
Normally, demolition is an intense activity conducted over a relatively
short time frame.  Therefore, measures to limit emissions potential  or
source extent are not usually possible.  The only technique which seems
feasible is the control of carryout onto paved city streets.  This could
be conducted by installing a truck wash and grizzly to remove mud and
debris from the vehicles as they leave the site.   Also the use of
freeboard over the load will  reduce blow-off dust from the truck beds.  It
should also be remembered that asbestos removal  is  also of concern at some
sites which involve additional  controls not normally necessary for most
demolition activities.
                                  5-7

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     As a final note, there are no quantitative control efficiency  values
for any of the above work practices.  Estimates can be obtained by  a  site-
specific analysis of alternative site preparation schemes based on  the
planned level of activity for the entire project using the emission
factors provided in Section 5.1 above.  For mud/dirt carryout, a
quantitative value for control efficiency could be obtained if street
surface loading data for uncontrolled (i.e., those which do not employ  any
measures to reduce carryout) and controlled sites were collected.  Also,
alternative methods for reducing mud/dirt carryout could be explored by a
properly designed study of available techniques.
5.2.2  Traditional Control Technology
     In addition to work practices, a.number of open source controls are
also available for reducing PM10 emissions from construction and
demolition sites.  These traditional controls are:  watering of unpaved
surfaces; wet suppression for materials  storage, handling, and transfer
operations; wind fences for control of windblown dust; and water injection
and filters for drilling operations.  Each will be discussed briefly with
detailed information included in Section 5.3 below.
     The use of water is probably the most widely used method  to control
open source emissions.   However, very little quantitative  data are
available on the efficacy of wet suppression for the control  of fugitive
PM10.  This is especially true for materials storage and handling
operations.  Some limited data are available for watering  of unpaved
surfaces, but estimation of control efficiency (and  thus a watering
control plan) is difficult.  Those data  which are available are presented
below.
     It should be noted that wet suppression of unpaved surfaces  using
chemical dust palliatives has not been included in the list  of available
controls for construction/demolition.  This  is due to  the  fact that  the
temporary nature of these operations generally preclude their  use.   The
same travel surface is  not used  for extended periods which  is  usually
required for cost-effective application  of  chemical  suppressants.  The
only possibility that might be considered  is the use of hydroscopic  salts
which require only one  application at  the  beginning of the  project.
Therefore, the use of chemical suppressants  will  not be discussed  further
in this section.

                                  5-8

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     With regard to wind fences,  only  three  studies  have  been  identified
for this particular control technique  which  attempt  to quantify  the  degree
of control achieved.  Wind fences (and other types' of barriers)  are
extremely cost effective in that  they  incur  little or no  operating and
maintenance costs.  For this reason wind fences are  an attractive control
alternative for windblown PM10 emissions.
     Finally, both water injection and fabric filters have been  used  to
control dust generation during drilling operations.  Since this  is a
relatively minor source associated with construction operations, these
controls do not offer significant emissions  reductions.   It should be
noted, however, that drilling may be important at certain sites.
5.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES
     In this section, the various alternative control measures for
fugitive PM10 at construction and demolition sites will be discussed  in
some detail.  Included in this discussion will  be the manner in which each
technique controls emissions, methods  for estimating control efficiency.,
an identification of cost elements to  be considered,  and available cost
estimates for each in terms of capital and operating expenditures.   Each
control will be presented in the  order shown previously in Section 5.2.
5.3.1  Watering of Unpaved Surfaces
     5.3.1.1  Control Efficiency.  Watering of  unpaved roads is one form
of wet dust suppression.  This technique prevents (or suppresses) the fine
particulate from leaving the surface and becoming airborne through  the
action of mechanical disturbance or wind.   The  water  acts  to bind the
smaller particles to the larger material  thus reducing emissions
potential.
     The control  efficiency of watering of unpaved surfaces  is  a  direct
function of the amount of water applied per unit  surface area  (liters per
square meter), the frequency of application (time between  reapplication),
the volume of traffic traveling over the  surface  between applications, and
prevailing meteorological  conditions (e.g., wind  speed,  temperature,
etc.).   As stated previously,  a number of  studies  have been  conducted with
regard to the efficiency of watering to control dust, but  few have
quantified all parameters listed above.
                                  5-9

-------
     The only specific control efficiency data which are available  for
construction and demolition involve the use of watering to control  truck
haulage emissions for a road construction project in Minnesota.2  Using
the geometric means of the important source characteristics (i.e.,  silt
content, traffic volume, and surface moisture) and the regression equation
developed from the downwind concentration data, a PM10 control efficiency
of approximately 50 percent was obtained for a water application intensity
of approximately 0.2 gal/yd2/hour.
     It should be noted that truck travel at road construction sites  is
only somewhat similar to travel on unpaved roads.  The road bed surface is
generally not as compacted as a well-constructed unpaved road.  There are
also subtle differences in surface composition.  Care should be taken,
therefore, in estimating control efficiency for noncompacted surfaces.
     For more compacted unpaved surfaces found in construction and
demolition sites, an empirical model for the performance of a watering as
a control technique has been developed.  The supporting data base consists
of 14 tests performed in four states during five different summer and fall
months.  The model is:1
                               100 - °'8 ? d *                       (5-4)
where   C = average control  efficiency,  in percent
        p = potential average hourly daytime evaporation rate in rnm/h
        d = average hourly daytime traffic rate in vehicles per hour
        i = application intensity in l/m2
        t - time between applications in h

The term p in the above equation is determined  using  Figure 5-1 and the
relationship:

            rO.0049 e (annual  average)                               (5-5a)
        p = 10.0065 e (worst case)                                   (5-5b)
where   p = potential average hourly daytime evaporation rate (mm/h)
        e = mean annual  pan  evaporation  (inches)  from Figure 5-1
     An alternative approach (which is potentially suitable for a
regulatory format)  is shown  as Figure 5-2.   This  figure  was presented
earlier in Section  3.0.
                                 5-10

-------
                                                              /;>?\    \in
                        ased on period 1946
Figure  5-1.  flean evaporation for the United States.

-------
        100%
o
z
fs,

b

Cd
O
ca
H
z
£-
o
IS
z
<:
H
en
z
7578
                                                               ,  957.
257,
               RATIO OF CONTROLLED TO UNCONTROLLED

                    SURFACE MOISTURE CONTENTS
 Figure 5-2.  PM-10 control efficiency for watering unpaved  roads.
                                 5-12

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     Figure  5-2  shows  that,  between  the  average uncontrolled moisture
content and  a  value of twice  that, a small  increase  in  moisture content
results in a large increase  in control efficiency.   Beyond  this point,
control efficiency grows  slowly with increased  moisture content.
Furthermore, this relationship is applicable-toall  size ranges
considered:                                      ^\
               75 (M-l)        1 
-------
     3.  Application intensity (gal/sq yd) and frequency  (a minimum
         moisture content may be specified as an alternative)
     4.  Type of application vehicle, capacity of tank, and source of
         water
     Specific Records to be Kept by Truck Operator
     1.  Date and time of treatment
     2.  Equipment used (this should be referred back to dust  control  plan
         specifications)
     3.  Operator's initials (a separate operators log may  be  kept and
         transferred later to permanent records by site operator)
     4.  Start and stop time, average speed, and number passes
     5.  Start and stop time for filling of water tank
     Specific Records to be Kept by Site Operator
     1..  Equipment maintenance logs
     2.  Meteorological log of general  conditions (e.g., sunny and warm
         vs. cloudy and cold)
     3.  Records of equipment breakdowns and downtime
An example permanent record form which  may be. used to record the above
information is shown in Figure 5-3.
     In addition to the above, some of  the regulatory formats suggested  in
Section 5.4 require that records of surface samples  or traffic counts also
be kept.  A suggested format for recording surface samples  is shown in
Figure 5-4.  Traffic data may be recorded either manually  or by automated
counting devices.
5.3.2  Wet Suppression for Materials Storage and Handling
     5.3.2.1  Control Efficiency.   Wet  suppression of materials storage
and handling operations is similar  to that used  for  unpaved surfaces.
However, in addition to plain water this technique can also use water plus
a chemical  surfactant or micronized foam to control  fugitive PM10.
     Surfactants added to the water supply allow particles  to more  easily
penetrate the water droplet and  increase the  total number  of droplets,
thus increasing total surface area  and  contact potential.   Foam is
generated by adding a chemical  (i.e., detergent-like  substance)  to  a
relatively small quantity of water  which is  then  vigorously mixed to
produce small  bubble, high energy foam  in  the 100  to  200-um size  range.
                                 5-14

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                                                            ClImalic parameters	
                       Application                         Ainli.  temp.     Dalo7amt.  of     Equipment     Operator
    Dale    Time     intensity (gal/yd2)    Area(s) treated       (°f)       last rainfall     usetl       initials             Comments
en
i
en
                            Figure 5-3.   Typical form for  recording watering program control  parameters.
                                      (Sources:   Unpavecl  surfaces, exposed areas, storage piles)

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                                    icmoiinc -cr~
                                    Unocved .-,occs
                                                                  --ere.
3ecorceo ;•,
 SAMPLING DATA
1
| Scmcia
1 No
Time
i • *
Surface i-
Area I -esrn
j sjtucrtr : ''.• '•
.59  ::ce c-ver o
                       zs *cr segment
                                                          'CSte S
                     Figure 5-4.  Unpaved road sample log.
                                       5-16

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The foam uses very little  liquid volume, and when applied  to  the  surface
of the bulk material, wets the fines more effectively  than untreated
water.
     As with watering of unpaved surfaces, the control  efficiency of  wet
suppression for materials  storage and handling is dependent on the same
basic application parameters.  These include:  the amount  of  water, water
plus surfactant, or foam applied per unit mass or surface  area of material
handled (i.e., liters per metric ton or square meter);  if  not continuous,
the time between reapplications; the amount of surfactant  added to the
water (i.e., dilution ratio), if any; the method of application including
the number and types of spray nozzles used; and applicable  meteorological
conditions occurring onsite.
     Wet suppression can be applied to material storage and handling
operations by a variety of methods depending on the material  and  how  it  is
being handled.  For construction sites, soil and construction aggregates
may be batch transferred to or from storage using loaders or  by truck
dumping.  In these cases, water (with or without chemicals) could  be
applied with a water cannon or spray bar to the material prior to  or
during load-in or load-out.  Foam may be a good alternative in such
instances when the material is handled repeatably over the period of a
day.  Foam can be applied once in the handling process (e.g.,  as  it is
initially loaded into trucks) and the binding action of the bubbles will
carry through subsequent handling operations.
     For demolition sites, water, etc., can be applied with a  cannon to
wrecking operations as well as to building debris being moved  (pushed)
with dozers and transferred into trucks by end-loaders.  Control  of
transfer operations can also be augmented using portable wind  fences to
provide a wind break to reduce dust generation and  improve  application of
water to the load during transfer to haul  trucks.  Wind fences are
discussed later in this discussion.
     Available control  efficiency data for wet dust  suppression  for
materials handling and storage are practically nonexistent.  However,
certain limited information was compiled by Cowherd  and Kinsey which can
be used to estimate control efficiencies.1
                                 5-17

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     For suppression using plain water, the most applicable efficiency
information available is for feeder to belt transfer of coal in mining
operations.  Control efficiencies of 56 to 81 percent are reported for
respirable particulate (particles <~ 3.5vmA) at application- intensities  of
6.7 to 7.1 L/Mg (1.6 to 1.7 gal/ton), respectively.  Assuming that respir-
able particulate is essentially equivalent to PM10, the above control
efficiencies would be representative of similar controls for construction/
demolition.  (The above application intensities were estimated assuming
5 min to discharge 7 Mg of coal and 1.4 L/min/spray nozzle.)
     In the case of foam suppression, the most appropriate data available
are for the transfer of sand from a grizzly.  Using the respirable
particulate control efficiencies at various foam application intensities
(and assuming respirable particulate is equivalent to PM10), the following
equation was developed by simple linear regression of the data compiled  by
Cowherd and Kinsey:1

                            C = 8.51  +  7.96  (A)                       (5-7)

where:  C = PM10 control  efficiency in  percent
        A = application intensity in ft3  foam/ton  of material

A coefficient of determination  (r?)  of  99.97 percent was  obtained  for the
above equation based on the three data  sets  used  in its  derivation.
     An alternate approach (which is  potentially  suitable  for  regulatory
formats) involves the use of the recently developed materials  handling
equation soon to be published in AP-42.   This  equation was presented  as
Equation 5-1 above.  By determining  the "uncontrolled" moisture  content  of
the material and again after wet suppression,  the  control  efficiency  can
be determined by:

                            CE  = 100(EU-EC)/EU                       (5-8)

where   CE = PM10  control  efficiency  in percent
        Eu = "uncontrolled"  PM10  emission  factor
        EC = "controlled"  PM10  emission factor
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The above calculations would necessitate the  determination of the amount
of water added to the material by  laboratory  analysis.   This could be
accomplished by taking grab samples of the material  before and after
application of the wet suppression technique  being employed.
     5.3.2.2  Control Costs.  Costs associated with  wet  suppression
systems include the following basic elements:
     •  Capital equipment:
        —  Spray nozzles or other distribution equipment
        --  Supply pumps and plumbing (plus weatherization)
        —  Water filters and flow control equipment
        —  Tanker truck (if used)
     •  Operating and maintenance expenditures:
        —  Water and chemicals
        —  Replacement parts for nozzles, truck, etc.
        -.-  Operating labor
        —  Maintenance labor
Reference 6 estimates the following costs (in 1985 dollars):
     •  Regular watering of storage piles:
        ~  Initial  capital cost = $18,400 per system
     •  Watering of  exposed areas:
        —  Initial  capital cost = $1,053 per acre
        —  Annual operating cost = $25 to 67 per acre
     The costs associated with a wet suppression system using chemical
surfactants for the  unloading of limestone from trucks at aggregate
processing plants (in 1980 dollars) have been estimated at:  capital =
$72,000; annual = $26,000.   These costs are based on  a stationary system
and may not be indicative of those used at construction and demolition
sites.
     5.3.2.3  Enforcement Issues.  As  with  watering of unpaved surfaces,
enforcement of a wet suppression control  program would consist of two
complementary approaches.   The first would  be record  keeping to document
that the program is  being implemented  and  the other would be spot-checks
and grab sampling.  Both  were  discussed  previously above.
     Records must be kept that document  the control plan  and its
implementation.  Pertinent  parameters  to  be specified in  a  plan and to be
regularly recorded include:

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     General  Information to be Specified in  Plan
     1.  Locations of all materials storage  and handling operations
         referenced on plot plan of the site available  to the site
         operator and regulatory personnel
     2.  Materials delivery or transport flow sheet which indicates the
         type of material, its handling and  storage,  size and composition
         of storage piles, etc.
     3.  The method and application intensity of water,  etc,  to  be applied
         to the various materials and frequency of application,  if not
         continuous
     4.  Dilution ratio for chemicals added  to water  supply,  if  any
     5.  Complete specifications of equipment used to handle  the various
         materials and for wet suppression
     6.  Source of water and chemical(s),  if used
     Specific Operational Records
     1.  Date of operation and operator's  initials
     2.  Start and stop time of wet suppression equipment
     3.  Location of wet suppression equipment
     4.  Type of material being handled and. number of loads (or  other
         measure of throughput) loaded/unloaded between start and  stop
         time (if material  is  being pushed,  estimate the volume  or  weight)
     5.  Start and stop times  for tank  filling
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological  log of general  conditions
     3.  Records of equipment  malfunctions  and downtime
     In addition to the above, some of  the  regulatory  formats suggested  in
Section 5.4 below require that records  of material  samples be kept.  A
suggested format for this purpose is shown  in Figure  5-5.
5.3.3  Portable Wind Screens or Fences
     5.3.3.1  Control  Efficiency.   The  principle of wind screens  or fences
is to provide a sheltered region  behind  the  fenceline  to allow
gravitational  settling of larger  particles as well as  a  reduction in wind
erosion potential.   Wind  screens  or fences reduce  the  mechanical
turbulence  generated by  ambient winds in an  area the length of which is
many times  the physical  height of the fence.

                                 5-20

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                                      Storage Pile  Data
                                                                      Date.
                                                                      Recorded by.
   AGGREGATE  CHARACTERISTICS
                            I—f
       Type:  Coal I	|; Coke I	|; Iron Orel	I;  Other
       Nominal Size:	in.
       Weight Density:	tons/cu. yd.
       Silt Cantent;      '.	%

   PILE CONFIGURATION
       Total Volume: Ground Area.
                    Average Height.
 acres
	ft.
       Configuration:
       Location within Plant  Boundaries:.

Avg. Quantity On Hand (tons;cu. yd. )
Avg. Quantity Put Through
Storage (tons;cu. yd. )
Avg. Duration of Storage (days)
WINTER



SPRING



SUMMER



FALL



ANNUAL



  MATERIALS HANDLING EQUIPMENT

      Stationary:	
      Mobile:
  MITIGATIVE MEASURES
3/76
                   Figure  5-5.  Storage  pile sampling  sheet

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     As stated previously, wind fences and screens are applicable  to a
wide variety of fugitive dust sources.  They can be used to  control  wind
erosion emissions from storage piles or exposed areas as well  as providing
a sheltered area for materials handling operations to reduce entrainment
during load-in/load-out, etc.  Fences and screens can be portable  and thus
capable of being moved around the site, as needed.
     The control efficiency of wind fences is dependent on the physical
dimensions of the fence relative to the source being controlled.   In
general, a porosity (i.e., percent open area) of 50 percent  seems  to be
optimum for most applications.  Note that no data directly applicable to
construction/demolition activities were found.  According to a recent
field study of small soil storage piles, a screen length of  five times the
pile diameter, a screen-to-pile distance of twice the pile height, and a
                                                      g
screen height equal to the pile height was found best.   Various problems
were noted with the sampling methodology used, however, and  it is doubtful
that the study adequately assessed the particle flux from the exposed
surface.  These problems tend to limit an accurate assessment of the
overall degree of control achievable by wind fences/barriers for large
open sources.
     While not entirely applicable to construction/demolition activities,
results of a laboratory wind tunnel  study were used to estimate 60 percent
to 80 percent control  efficiencies for materials handling emissions.
     5.3.3.2  Control  Costs.  As stated above, one of  the real  advantages
of wind fences for the control  of PM10 involves the low capital and
operating costs.  These involve the  following basic elements:
     •  Capital equipment:
        ~  Fence material and  supports
        —  Mounting hardware
     •  Operating and  maintenance expenditures:
        —  Replacement fence material  and  hardware
        —  Maintenance labor
     The following cost estimates (in 1980  dollars) were  developed  for
wind screens applied to aggregate storage  piles:10
     •  Artificial wind guards:
        —  Initial  capital  cost  = $12,000  to 61,000
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     •  Vegetative wind breaks:
        ~  Initial capital cost =  $45 to  425  per  tree
     Due to the lack of quantitative data  on costs associated  with  wind
screens, it is recommended that local vendors  be contacted  to  obtain more
detailed data for capital and operating expenses.  Also,  since wind fences
and screens are relatively "low tech" controls, it may be possible  for the
site personnel to construct the necessary  equipment with  less  expense.
     5.3.3.3  Enforcement Issues.   As with other options  mentioned  above,
the main regulatory approach involved with wind fences and  screens  would
involve recordkeeping by the site operator.  Parameters to  be  specified  in
the dust control plan and routinely recorded are:
     General Information to be Specified in Plan
     1.  Locations of all materials storage and handling  operations  to be
         controlled with wind fences referenced on a plot plan available
         to the site operator and regulatory personnel
     2.  Physical  dimensions- of each source to be controlled and
         configuration of each fence or screen to be installed
     3.  Physical  characteristics of material.to be handled or stored for
         each operation to be controlled by fence(s)  or screen(s)
     4.  Applicable prevailing meteorological  data (e.g.,  wind speed and
         direction) for site on an annual  basis
     Specific Operational  Records
     1.  Date of installation of wind fence or screen and  initials of
         installer
     2.  Location  of installation relative to  source  and prevailing  winds
     3.  Type of material  being handled  and stored  and physical dimensions
         of source controlled
     4.  Date of removal  of  wind fence  or  screen and  initials of  personnel
         i nvo1ved
     General Records to be Kept
     1.  Fence or  screen  maintenance record
     2.  Log of meteorological  conditions  for  each  day of  site  operation
5.3.4  Drilling Control  Technology
     5.3.4.1  Control  Efficiency.   Another type of  control to be  discussed
is the  use  of water injection or fabric  filters for drilling operations.
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Both of these controls are generally directly associated with  the  drilling
equipment when it is purchased and is an integral part of the  system.
     As might be expected, water injection used on rock drills  involves
the application of water either into the hole being drilled by  a piston
pump or to a ring around the top of the hole to control dust generation.
Also, dust ejector systems equipped with small fabric filters or water
sprays use compressed air to eject dust particles from the hole into a
tube for removal from the drilled area.
     At present, there are no data available for the PM10 control
efficiency associated with either system used to reduce emissions  from
drilling operations.  It might be expected, however, that a fabric filter-
based system should be more efficient than wet suppression in most cases.
     5.3.4.2  Control Costs.  Cost elements associated with drilling
control systems are as follows:
     •  Capital equipment:
        —  Spray nozzles, pumps, and distribution plumbing for wet
            suppression system
        ~  Air compressor, air lines,  and filter components for dry
            ejection system                ;
        --  Water filters and flow control  equipment,  as  required
        ~  Water tank,  if needed
     •  Operating and maintenance expenditures:
        --  Water and chemicals,  if used
        —  Replacement  bags, etc.  for  dry systems
        —  Replacement  parts for nozzles,  pumps,  etc.
        —  Operating labor
        —  Maintenance  labor
     Jutze et al. estimate the following costs  (in 1980 dollars) for
drilling operations in aggregate  processing facilities:10
     •  Water injection  systems:
        —  Initial  capital  cost  =  $4,700
     •  Dust ejection to fabric filter:
        ~  Initial  capital  cost  =  $14,600
Specific cost data should be obtained from  manufacturers relative to  the
capital costs associated with the  above  systems to update the above.  No
information is available at  present for  O&M costs  for such systems.

                                 5-24

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     5.3.4.3  Enforcement Issues.  As with  the  other methods  discussed
previously, the regulation of drilling emissions would  involve  at  least
some recordkeeping as part of the overall emissions control plan for  the
site.  The parameters to be specified in the plan and subsequently
recorded by onsite personnel include:
     General Information to be Specified in Plan
     1.  Location of all drilling operations to be conducted  referenced to
         a plot plan of the site available to the site operator and
         regulatory personnel
     2.  Schedule for all drilling operations to be conducted onsite,
         number of holes to drilled, equipment used and hours of operation
     3.  Complete specifications of drilling and dust control equipment
         for each rock drill to be used
     4.  Amount of water to be used per unit time for wet systems  or
         airflows for dry systems
     5.  Source of water and chemical(s), if used, and tank(s)
         capacity(ies)
     Specific Operational Records
     1.  Date of operation and operator's initials
     2.  Start and stop time of drilling and control  equipment
     3.  Number of holes drilled between start and stop  time
     4.  Start and stop time for tank filling
     General Records to be Kept
     1.  Equipment maintenance records
     2.  Meteorological  log of general conditions
     3.  Records of equipment malfunctions  and downtime
     Because of the relatively confined  nature of  drilling operations,
regulatory formats different from those  discussed  previously may be
possible.  For example,  opacity as a measure of performance could  be a
viable approach.  This is discussed further in Section 5.4 below.
5.3.5  Control  of Mud/Dirt Carryout
     5.3.5.1  Control  Efficiency.   Mud and  dirt carryout  from  construction
and demolition sites often accounts for  a temporary but  substantial
increase in paved road emissions in many  areas.  Elimination of  carryout
can thus significantly reduce increases  in  paved road emissions.
                                 5-25

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     At present, the efficacy of various methods to prevent  or  reduce
mud/dirt carryout have not been quantified.  These techniques include both
methods to remove material from truck underbodies and tires  prior  to
leaving the site (e.g., a temporary grizzley with high pressure water
sprays) as well as techniques to periodically remove mud/dirt carryout
from paved streets at the access point(s).  The following method has  been
developed, however, to conservatively estimate the reduction in mass
emissions due to carryout using the data contained in Reference 6.
     As noted earlier, quantification of control efficiencies for
preventive measures is essentially impossible using the standard
before/after measurement approach.  The methodology described below
results in conservatively high control estimates in terms of emissions
prevention.  That is, the control  afforded cannot be easily described  in
terms of a percent reduction but rather is discussed in terms of mass
emissions prevented.  Furthermore, tracking of material  onto a  paved  road
results in substantial spatial variation in loading about the access
point.  This variation may complicate the modeling of emission  reductions
as well as their estimation.
     For an individual access point from a paved road to a typical
construction or demolition site, let N represent the number of vehicles
entering or leaving the area on a  daily basis.   Let E be given by:
           5.5 g/vehicle for N < 25
     E = {
           13 g/vehicle for N > 25
where E is the unit PM10 emission  increase in g/vehicle  pass  (see
Section 5.1).  Finally, if M represents the daily number of vehicle passes
on the paved road,  then the net daily emission  reduction (g/day) is given
by ExM, assuming complete prevention.
     The emission reduction calculated above assumes  that  essentially  all
carryout from the unpaved area is  either prevented  or  removed periodically
from the paved surface and,  as such,  i's viewed  as  an  upper limit.   In  use,
a regulatory agency may choose to  assign an effective  level of carryout
control by using some fraction of  the  E values  given  above to calculate an
emission reduction.
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     Finally, field measurements of  the  increased  paved  silt  loadings
around unpaved areas may also be used to  gauge  the effectiveness  of
control programs.  A discussion of this  is  found  in Section 2.4.
     5«,3o5o2  Control Costs.  The individual  cost  elements associated  with
the prevention of mud/dirt carryout  will  vary with the method  used.  For
traditional street cleaning, the costs elements discussed in Section 2.0
would apply to construction and demolition  sites as well.  In  this case,
however, only the amount of surface  to be cleaned  would  be limited to  the
area(s) near access point(s).  For an onsite  grizzley/water spray system,
the cost elements are as follows:
     •  Capital equipment:
        —  Grizzley, catch basin, and clarifier (as needed)
        —  Spray nozzles, pumps, and distribution plumbing
        —  Water tank, filters, and flow controllers, as required
     •  Operating and maintenance expenditures:
        —  Water and replacement nozzles, plumbing, etc.
        —  Removal of wastewater or residues, as  required
        ~  Operating labor
        —  Maintenance labor
     At present, no cost data are available for the prevention of mud/dirt
carryout.
     5.3.5.3  Enforcement Issues.  As with some other techniques,  two
complimentary approaches can be used for enforcement of mud/dirt carryout
control.  These are recordkeeping and grab sampling.  The later would
include the sampling of the paved surface loading  near access  points to
determine the level of prevention being achieved by the method(s)
employed.  Surface sampling is discussed in more detail  above.
     Adequate records must be kept to document the types  and  level  of
preventative measures being taken to control mud/dirt carryout  from the
site.  Appropriate parameters to be specified in the control plan  and
rigorously recorded are:
     General Information to be Specified
     1.  A detailed plot plan available to both the site  operator  and
         regulatory personnel  showing site access  points  and  impacted
         paved city streets.
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     2.  Details on the control method to be applied at each  access  point
         including the amount and types of vehicles entering  and  exiting
         the site on a daily basis at each.
     3.  For mitigative control techniques (i.e., surface cleaning),  a
         description and schedule for implementation of the control  method
         to be employed (see Section 2.0 above).
     4.  For preventive control techniques (e.g., onsite grizzley),
         specifications on the type(s) of equipment to be used  and
         operation and maintenance of the system.
     5.  Source of water, if used.
     Specific Records to be Kept by Site Operator (Mitigative Controls)
     1.  Date of cleaning operation and operator's initials.
     2.  Other applicable cleaning parameters as specified in Section  2.0
         above.
     General Records to be Kept
     1.  Equipment maintenance records.
     2.  Meteorological log of general conditions.
     3.  Records of equipment malfunctions and  downtime.
     In addition to the above, some of the regulatory formats suggested  in
Section 5.4 require that records of material  samples also be kept.  A
suggested format for this purpose has been shown previously in
Section 2.4.
5.4  EXAMPLE DUST CONTROL PLAN
     To illustrate the development of an appropriate dust control  plan for
construction and demolition sites, Figure 5-6 provides  example calcula-
tions for the demolition of a 167,200 m2 (200,000 ft2)  building located on
a one acre site in an urban area.   These calculations  include  the
determination of uncontrolled PM10 emissions, methods used  for control,
and demonstration of the adequacy of  the various  methods  to  achieve a
target control  efficiency of 90 percent.
5.5  POTENTIAL REGULATORY FORMATS
     In this section,  regulatory formats will be  discussed relative to the
control of fugitive PM^Q emissions at construction and  demolition  sites.
This section discusses a permit system,  recordkeeping,  measures  of control
performance, and enforcement as well  as  an example rule which  implements
                                 5-28

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     •  Source Description:
          167,200 m2 (floor space) building on  a one  acre  site
          1 access point to a paved city street (2,000 ADT)
          30 vehicles/day removing building debris
          30 days project duration

     •  Assumptions:
          No detailed data are available for debris removal activities
          No dozing will be performed onsite
          Negligible exposed areas
          8 h/day operation

     •  Calculation of Uncontrolled Emissions:
          From Section 5.1.2 the uncontrolled PM10 emissions from
          dismemberment, debris loading, and onsite traffic are calculated
          as:

          EQLJ = (Eg + EL + Ej) kg/m2 x m2 floor space

               = (0.00025 + 0.0046 + 0.052) kg/m2 x 167,200 m2

               = 9.5 Mg PM10

For mud/dirt carryout from haul trucks entering and leaving the site, the
mean increase in paved road emissions is calculated using Table 5-2 for
sites with greater than 25. vehicles/day:

        EMQ = 13 g/vehicle pass x 2,000 vehicles/day x 30 days

            = 780 Mg PMlo emissions

        Therefore, the total emissions over the duration of the project
        are:

        ET = EDLT + EMD = 9'5 M9 + 78° M9

           = 789.5 Mg total PMi0 emissions

     •  Target Control  Efficiency:  90%

     •  Methods of Control:

        — Wet suppression of debris handling and  transfer (6.7 L/Mg
           application intensity)
        — Watering of unpaved travel  surfaces (2  L/m2/h application)
        ~ Broom sweeping/flushing for removal of  mud/dirt carryout


      Figure 5-6.   Example  PM10  control  plan  for building demolition.
                                   5-29

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Demonstration of Control Program Adequacy:

As stated in Section 5.3.2.1, an efficiency of 56%  is typical  for
wet suppression of debris transfer.  Thus, the controlled
emissions would be:

ECL = 0.0046 kg PM10/m2 x 167,200 m* x (1 - 0.56) = 0.34 Mg  PM10

Using water for dust control from unpaved surfaces, Equations  5-4
and 5-5 as well as Figure 5-1 will allow calculation of controlled
emissions (assuming the site is located in Los Angeles,
California):

p = 0.0049 e = 0.0049 (60 inches) = 0.29 mrn/h

and

 c . 100 -
           0.8(0.29K30/8H1)


   = 99.6%
Therefore, the controlled PM10 emissions for haul truck traffic
would be:

ECT = 0.052 kg/m2 x 167,200 m2 x (1 - 0.996)

    = 0.035 Mg PMm from haul trucks

Finally, for removal of mud/dirt carryout using a combination of
broom sweeping and flushing, no prevention efficiency data are
available.  However, if it is assumed that the emissions increase
on the paved road for this source is reduced by 90 percent,
78 Mg PMi0 from mud/dirt carryout (see Section 5.3.5.1).

From the above calculations, the overall  reduction in PMlo due to
the various controls employed would be:

EC = ECL + ECT + ECMD

   = 0.34 + 0.035 + 78

   = 78 Mg PMiQ after control
                 Figure 5-6.  (continued)
                           5-30

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Thus,


    CE =  T E  CT x 100% = 789789"578 x 100 = 90.1%

As shown, the target control efficiency of 90 percent has not only
been achieved but exceeded.
                    Figure 5-6.  (continued)
                              5-31

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the permit system.  Example regulatory formats are provided  for  the
following sources associated with construction/demolition:   unpaved  roads,
haul roads, disturbed soil, mud carryout.  These example formats  provide a
starting point for development of construction rules in a specific area.
5.5.1  Permit System
     The first regulatory approach involves the implementation and
enforcement of a permit program for construction and demolition  sites.
This has been used to some extent in the Denver metropolitan area for
large construction projects and offers promise as a general regulatory
format.
     A permit system would require the site owner or operator to  file an
application with the appropriate regulatory agency having jurisdiction.
This permit application would include the specific dust control plan to  be
implemented at the site which would involve the individual elements
discussed in Section 5.3.
     The air permit for construction and demolition sites would be coupled
to the standard building or demolition permit process whereby no  permit  to
conduct such activity would be issued by the county or city until such     :
time that the air permit is approved.  To reduce the burden of processing
large numbers of such permits, a de minimus level  would be established
whereby construction and demolition projects below a certain cut-off size
would not require an air permit.  This de minimus  level would depend on
local factors such as the amount of emissions reduction required  to meet
the applicable PMi0 NAAQS.  For the sake of further discussion,  a
de minimus level of <25 vehicles entering and leaving the site per day for
construction was used to determine the emissions  increase associated  with
mud/dirt carryout and thus might be used for this  purpose.5
     As part of the permit application,  recordkeeping should be one-of the
main conditions for approval.   Records of site activity and  control  should
be submitted to the regulatory agency on a monthly  basis  as  indicated
above..  These records must be  certified  by a responsible  party  as to  their
completeness and accuracy.  All  site  records should  be  maintained by  the
local agency for the duration  of the  project.
     To enforce the dust control  plan submitted as  part of the permit
application, field audits of key control  parameters  should be made by
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regulatory personnel.  The results of  these audits would then  be  compared
to site records for that period to determine compliance with permit
conditions.  If differences are found  between application of the
control(s) observed onsite and those recorded by site operating personnel,
this would constitute a violation and  would be grounds for further
enforcement action.  An example form to be used by regulatory  personnel
during inspection of the site is shown in Figure 5-7.  .To illustrate this
process an abbreviated example will be given.
     Assume a large demolition project consisting of the demolishing of a
block of buildings is to be conducted  in a large metropolitan  area.  The
site dust control plan calls for watering of all truck routes  to  and from
the active demolition every two hours  as well as cleanup of mud/dirt
carryout from the access point on a twice daily basis.  Also, watering of
debris during demolition and load-out  to haul trucks is to be conducted on
days without measurable rainfall.  An  agency inspector observes the site
activity from the public street for a  period of 3 hours..  During  this
period, no water truck is observed to  be in operation and debris  are not
watered prior to loading into trucks.
     At the end of the month, the inspector checks-the submittal from the
site operators and finds start and stop times for the water truck operator
which indicates operation during the observation period.   The inspector
also notes that the water cannon used  for debris control  was broken down
and was in a repair shop.  It is clear from this analysis that the
operator is in clear violation of the dust control  plan for watering of
unpaved surfaces.  In this case, a citation or other enforcement action
could be taken against the site operator.
     As noted by the above example, no quantitative data  are required for
enforcement of the dust control  plan.  This eliminates  the  need for a set
performance standard (e.g., opacity limits)  against which the site
operator is evaluated.  This approach  is,  however,  predicated on the fact
that strict implementation of the dust control  plan will  achieve certain
reductions in PM10 emissions associated with site  operation.
                                  5-33

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 1.   Type of construction activity  (check one)

     a.   Residential  	
     b.   Commercial   	
     c.   Industrial   	

     Additional  description  (i.e.,  multi  unit,  residential  or suburban
     commercial, etc.)

 2.   How long have you  worked  at  this
     location?       	
     Note:   In the case of a multi-year project,  we  are only interested in
     the current season.

 3.   How long is the job projected  to
     last?            	
 4.   What percentage of the work  is  completed,
     percent?  	

 5.   What construction  activities are  you  currently  performing?

 6.   What construction  activities have you been  performing  over the past
     week to 10 days?

 7.   What is the construction  activity's  source  extent  which is currently
     being performed (e.g., tons  of  earth  moved/day  or  yards of concrete
     poured/day)?

 8.   Estimate the number-of daily vehicle  passes through  the site entrance
     (check 1).

 9.   What types of vehicle enter  the site  daily  and  what  percentage of the
     traffic is of each type?

         Vehicle type       Percent

     a.   Cars               	
     b.   Pickups/vans       	
     c.   Medium duty trucks 	
     d.   Other
10.   Do you employ control  measures  to  keep dust down?   If yes,  what type?

11.   What is the usual  frequency and  intensity of application?   When was
     the most recent  application?
        Figure 5-7.  Questionnaire for construction site personnel.
                                   5-34

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5.5.2  Opacity Standards
     Another regulatory format which could  be used  is the use of  visible
emissions (i.e., opacity) as a semi quantitative measure of the performance
of the dust control measure being employed.  One state, Tennessee,  has
developed a formalized procedure for reading and recording of visible
emissions (VE) from fugitive sources which  is the basis for enforcement of
a VE standard.
     The use of visible emissions for determination of compliance for
fugitive.dust sources has been discussed previously in this document and
thus will not be belabored here.  In general, fugitive sources are
extremely diffuse in nature and the plume generated is dependent on a
number of factors including wind speed and  the physical dimensions of the
source.  Therefore, it is difficult, if not impossible, to derive even
semiquantitative relationships between particulate mass and visible
emissions for most source types and thus a measure of control  performance.
     There is one particular source at construction sites where observa-
tion of visible emissions might be used with some degree of confidence as
an enforcement tool.  This source is rock drills which emit dust from one
confined area (i.e., the hole being drilled) and thus might be considered
as a point emissions source under traditional definitions.  Additional
work will be necessary, however, to determine appropriate visible emis-
sions limits for rock drills based on the control  techniques  currently
available.
5.5.3  Other Indirect Measures of Control Performance
     The final regulatory format to be presented in this section  relates
to various indirect measures of control  performance.  These could be used
in conjunction with or in lieu of the other approaches discussed  above.
They will, however, require more effort  and expense to implement  but
should be at least somewhat defensible as measures  of control  efficiency.
     The most obvious approach to indirectly measuring control  performance
involves the collection and analysis of  material  samples  from  various
sources operating onsite.  For mud/dirt  carryout, collection of  surface
samples at site access points and analysis  of these samples for  silt con-
tent would indicate the efficacy of control  for  this particular source.
The silt loadings obtained could be compared with "typical" surface
                                 5-35

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loading values for similar uncontrolled sites to determine the degree  of

loading (and thus emissions) reductions achieved.  This would, of course,

necessitate the availability of a data base of "uncontrolled" silt  load-

ings due to mud/dirt carryout for a wide variety of construction and demo-

lition sites for comparison with site-specific data.  An example form  to

be used for collection of paved surface loading samples has been provided

previously in Section 2.4 above which has been reproduced as Figure 5-8.

     Another indirect measure of control efficiency is the collection  and

analysis of material samples from unpaved surfaces and materials handling

and storage operations.  In this case, analysis of the moisture content  of

these samples would indicate the amount of water applied and thus the

degree of control achieved by wet suppression.  Appropriate equations  pre-

sented in Section 5.3 would be used to determine control efficiency based

on the. sample data.
5.5.4  Example Rule

     The following is a discussion of an example regulatory format for

construction activities.  A more detailed discussion is presented in

Appendix G.

     5.5.4.1  Conditions for Construction.

     Conditions for Construction;   No person shall  engage in  any
     construction-related activity at any work site unless  all  of the
     following conditions are satisfied:

     (1)  Oust control  implements  in good working condition are available
          at the site,  including water supply and distribution  equipment
          adequate to wet any disturbed surface  areas  and any building
          part up to a height of 60 feet  above grade.

     (2)  A dust control plan is approved by the  APCO  which demonstrates
          that an overall x percent (e.g.,  75 percent)  reduction  of  PMiQ
          emissions from construction/demolition  and related activities
          will be achieved by applying reasonably available control  mea-
          sures.   Such  measures  may include,  but  need  not be limited  to,
          the following:  application of  water or other  liquids during
          dust-producing mechanical  activities including  earth moving and
          demolition operations; application of water  or  other  liquids  to
          or chemical  stabilization of, disturbed  surface areas;  surround-
          ing the work  site with wind breaks  to reduce  surface erosion;
          restricting  the access of motor vehicles  on  the work site;
          securing loads and cleaning vehicles leaving the work site;
          enclosing spraying operations;  and  other  means  as specified by
          the APCO.
                                 5-36

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                                         "OCC '_3OC:nc
    No.
MR I Project  No.
                                                           Dare 	
                                                           Recorcea 3v
Typ« of Mcferiai Samoied:
iife of Samciino: _
Type of rcvemer:::
               sohair/Concrete
           No. of Traffic Lanes
           Surface Condition —
Samp i a No.
                 Vac. Sag
rime
Location'
Sample Area
                                                                        5 room
                                                                        Sweot?
               Figure  5-8.   Example  paved  road  sample  log.

                                                5-37

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     (3)  The owner and/or operator is in possession of a currently  valid
          permit which has been issued by the APCO.  (Example  permit
          attached, see Figures 5-9 and 5-10).

     5.5.4.2  Control Mud/Dirt Carryout.

     Street Cleaning;  No person shall engage in any dust-producing
     construction related activity at any work site unless the paved
     streets (including shoulders) adjacent to the site.where  the  con-
     struction-related activity occurs are cleaned at a frequency  of not
     less than x (e.g., once) a day unless,

     (1)  vehicles do not pass from the work site onto adjacent paved
          streets, or

     (2)  vehicles that do pass from the work site onto adjacent paved
          streets are cleaned and have loads secured to effectively  pre-
          vent the carryout of dirt or mud onto paved street surfaces.

     The measures used to clean paved roads may include, but are not
                                           •
limited to:  water flushing, vacuum sweeping, and manual cleaning  of the

access point.

     5.5.4.3  Control of Haul Road Emissions.

     Construction Site Haul Roads:  No person shall allow the operation,
     use, or maintenance of any unpaved or unsealed haul road of more than
     x (e.g., 50) feet in .length at any work site engaged in any construe--
     tion-related activity, unless no more than x (e.g.,.10) vehicular-
     trips are made on such haul road per day and vehicular speeds do not
     exceed x (e.g.,10) miles per hour.

     5.5.4.4  Stabilize Soils at Work Sites.
     Stabilization of Soils at Completed  Work Sites:   No owner and/or
     operator shall allow a disturbed surface site to remain subject to
     wind erosion for a period in excess  of x (e.g.,  6)  months after
     initial disturbance of the soil  surface or construction-related
     activity without applying all reasonably available  dust control  mea-
     sures necessary to prevent the transport of dust or jdirt beyond the
     property line.  Such measures may include,  but neeaAto  be limited to:
     sealing, revegetating, or otherwise  stabilizing  the soil  surface.

     5.5.4.5  Record Control Application.   The owner  and or  operator shall

record the evidence of the application of  the control measures.  Records

shall be submitted upon request from  APCO  and shall be open  for inspection
during unscheduled audits.

     5.5.4.5  Modification of Permit  Provisions

     The provisions of this permit may be  modified  after sufficient

construction is completed by the mutual consent  of  the APCO  and the

permittee; or,  by the APCO if it determines  that  the  stipulated controls
                                 5-38

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             THIS PERMIT WILL BE  PROMINENTLY  DISPLAYED  IN  THE
                        ONSITE CONSTRUCTION OFFICE
Location:	 No. of Acres:
Name of Project:  	
PERMITTEE:  	 Telephone No.  	
Address:  	
Prime Contractor:  	 Telephone No.  	
Subcontractor:	 Telephone No.  	
Issue Date of Permit:  	 Expiration Date of Permit:  	
PERMIT NO:  	 FEE $	 RECEIPT NO.  	
THE PERMITTEE SHALL COMPLY WITH THE FOLLOWING CONDITIONS:
1.  (Reference to local APCD regulation for construction/demolition-
    related activities)
2.  The PERMITTEE is responsible for dust control from commencement of
    project to final completion.  Areas which will require particular
    ATTENTION:

    a.  Unimproved access roads used for entrance to or exit from
        construction site.                                       .
    b.  Areas in and around building(s) being constructed.
    c.  Dirt and mud deposited on adjacent improved streets and roads.

3.  If wind conditions are such that PERMITTEE cannot control dust,
    PERMITTEE shall  shut down operations (except for equipment used for
    dust control).

4.  The PERMITTEE is responsible for ensuring his contractor(s) and/or
    subcontractor(s) and all other persons abide by the conditions of the
    permit from commencement of project to final completion.

5.  The PERMITTEE also is subject to compliance with all  applicable State,
    county, and local ordinances and regulations.  Issuance of this permit
    shall not be a defense to violation of above-referenced statutes,
    ordinances, and  regulations.

6.  Onsite permit conditions (attached)
Air Pollution Control Division    (date)
                     Figure 5-9.   Example  dust permit.
                                   5-39

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                                                    ONSITE PERMIT  CONDITIONS
Condition
number
6a.
Source Minimum
category3 control efficiency
(e.g., unpaved (e.g., 80 percent)
roads)
Control measure
(e.g., chemical stabi-
lization, 39 percent
cal 1 in water and
supplemental water-
ing)
Appl i cat ion
level (frequency
amount, etc.)
(e.g., sufficient
to maintain an
average surface
moisture content
of 2 times the
the of f road soi 1
moisture)
Recordkeeping
(e.g. , log of salt
solution and
supplemental
water volume,
time, and date)
Report i ng
requirements
Records submitted
upon request (in
writing) and
open for inspec-
tion during un-
scheduled
audits)
        Other source categories that also could be regulated with permit conditions include open areas, grading, streets, and haul

        trucks.
en
i
                            Figure  5-10.   Example permit for  construction/demolition activities.

-------
are inadequate.  Deviations from the dust control plan  (e.g.,  increased

source activity) may result in modifications to the permit.

5.6  REFERENCES FOR SECTION 5

 1.  Cowherd, C., Jr., and J. S. Kinsey.  1986.  Identification,
     Assessment and Control of Fugitive Particulate Emissions.
     EPA-600/8-86-023, U. S. Environmental Protection Agency, Research
     Triangle Park, North Carolina.

 2.  Kinsey, J. S., et al.  1983.  Study of Construction Related Dust.Con-
     trol.  Contract No. 32200-07976-01, Minnesota Pollution Control
     Agency, Roseville, Minnesota.  April 19, 1983.

 3.  Grelinger, M. A.  1988.  Gap Filling PM10 Emission Factors for
     Selected Open Area Dust Sources.  EPA-450/4-88-003, U.S.
     Environmental Protection Agency, Research Triangle Park, North
     Carolina.

 4.  Muleski, G. E.  1987.  Update of Fugitive Dust Emission Factors in
     AP-42 Section 11.2.  Final Report, U. S. Environmental Protection
     Agency, Contract 68-02-3891, Work Assignment 19.

 5.  U. S. Environmental Protection Agency.   1985.   Compilation of Air
     Pollution Emission Factors, AP-42.  U.  S. Environmental Protection
     Agency, Research Triangle Park, North Carolina.

 6.  Englehart, P. J., and J'.  S. Kinsey.  1983.   Study of Construction
     Related Mud/Dirt Carryout.  EPA Contract 68-02-3177, Assignment 21.
     July 1983.

 7.  Kinsey, J. S., et al.  1985.  Control Technology  for Sources of
     PM10.  Draft Final Report, EPA Contract 68-02-3891, Assignment 4.
     September 1985.

 8.  Zimmer, R. A., et al.  1986.  Field Evaluation of Wind Screens as  a
     Fugitive Dust Control Measure for Material  Storage Piles.
     EPA-600/7-86-027, U. S. Environmental Protection  Agency,  Research
     Triangle Park, North Carolina.   July 1986.

 9. ' Struder, B. J. 8., and S.  P. S.  Arya.  1988.   Windbreak Effectiveness
     for Storage Pile Fugitive  Dust Control:   A  Wind Tunnel  Study.
     Journal of the Air Pollution Control  Association,  38;135-143.

10.  Ohio Environmental Protection Agency.  1980.   Reasonably Available
     Control Measures for Fugitive Dust Sources.  Columbus,  Ohio.
     September 1980.
                                 5-41

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                        6.0  OPEN AREA WIND EROSION

     Dust emissions may be generated by wind erosion of open agricultural
land or exposed ground areas on public property or within  an industrial
facility.
     With regard to estimating particulate emissions from  wind erosion of
exposed surface material, site inspection can be used to determine the
potential for continuous wind erosion.  The two basic requirements for
wind erosion are that the surface be dry and exposed to the wind.  For
example, if the contaminated site lies in a swampy area or is covered by
unbroken grass, the potential for wind erosion is virtually nil.  If, on
the other hand, the vegetative cover is not continuous over the exposed
surface, then the plants are considered to be nonerodible  elements which
absorb a fraction of the wind stress that otherwise acts to suspend the
intervening soil.
     For estimating emissions from wind erosion, either of two emission
factor equations are recommended depending on the credibility of the
surface material.  Based on the site survey, the exposed surface must be
placed in one of two erodibility classes described below.   The division
between these classes is best defined in terms of the threshold wind speed
for the onset of wind erosion.
     Nonhomogeneous surfaces impregnated with nonerodible elements
(stones, clumps of vegetation, etc.) are characterized by the finite
availability ("limited reservoir") of erodible material.   Such  surfaces
have high threshold wind speeds for wind erosion, and particulate emission
rates tend to decay rapidly during an erosion event.   On the other hand,
bare surfaces of finely divided material  such as sandy agricultural  soil
are characterized by an "unlimited reservoir" of erodible  particles.   Such
surfaces have low threshold wind speeds for wind erosion,  and particulate
emission rates are relatively time independent at a given  wind  speed.
     For surface areas not covered by continuous vegetation,  the
classification of surface material as either having a "limited  reservoir"
or an "unlimited reservoir" of erodible surface particles  is  determined by
estimating the threshold friction velocity.   Based on analysis  of wind
erosion research, the dividing line for the two erodibility classes  is a
                                  6-1

-------
threshold friction velocity of about 50 cm/s.  This somewhat arbitrary
division is based on the observation that highly erodible surfaces,
usually corresponding to sandy surface soils that are fairly deep, have
threshold friction velocities below 50 cm/s.  Surfaces with friction
velocities larger than 50 cm/s tend to be composed of aggregates too  large
to be eroded mixed in with a small  amount of erodible material or of
crusts that are resistant to erosion, i
     The cutoff friction velocity of 50 cm/s corresponds to an ambient
wind speed of about 7 m/s (15 mph), measured at a height of about 7 m.   In
turn, a specific value of threshold friction velocity for the erodible
surface is needed for either wind erosion emission factor equation
(model).
     Crusted surfaces are regarded  as having a "limited reservoir" of
erodible particles.  Crust thickness and strength should be examined
during the site inspection, by testing with a pocket knife.   If the crust
is more than 0.6 cm thick and not easily crumbled between the fingers
(modulus of rupture >1 bar), then the soil  may be considered hon-
erodible.  If the crust thickness is less than 0.6 cm or is  easily
crumbled, then the surface should be'treated as having a limited reservoir
of erodible particles.  If a crust  is found beneath a loose  deposit,  the
amount of this loose deposit, which constitutes the limited  erosion
reservoir, should be carefully estimated.
     For uncrusted surfaces, the  threshold  friction velocity is best
estimated from the dry aggregate  structure  of the soil.   A simple hand-
sieving test of surface soil is highly desirable to determine  the mode of
the surface aggregate size distribution by  inspection  of relative sieve
catch amounts, following the procedure specified in Figure 6-1.   The
threshold friction velocity for erosion can be determined from  the  mode of
the aggregate size distribution,  following  a relationship derived by
Gillette (1980) as shown in Figure  6-1.'
     A more approximate basis for determining threshold  friction  velocity
would be based on hand sieving with just  one sieve,  but  otherwise follows
the procedure specified in Figure 6-2.   Based on  the relationship
developed by Bisal and Ferguson (1970),  if  more  than 60  percent of  the
                                 6-2

-------
                       IOOO
C1


CO
                  o
                  
                  *
                  u
                  o
                  OJ
                  c
                  o
o
•r—
u
                 x»

                  o
                  01
                  i.
      IQQ ,
                         10
                                           4  567891
                            O.I
                                                         10
|OO
                                        Aggregate Size Distribution Mode (inn)
                  Figure 6-1.  Relationship of  threshold friction velocity to size distribution mode,

-------
     FIELD  PROCEDURE  FOR  DETERMINATION OF  THRESHOLD  FRICTION  VELOCITY*

1.  PREPARE A NEST OF SIEVES  WITH  THE FOLLOWING OPENINGS:   4 mm, 2 mm,
    1 mm, 0.5 mm, 0.25 mm.  PLACE  A COLLECTOR PAN BELOW THE BOTTOM SIEVE
    (0.25-mm OPENING).

2.  COLLECT A SAMPLE  REPRESENTING  THE SURFACE LAYER  OF LOOSE PARTICLES
    (APPROXIMATELY 1  cm IN  DEPTH FOR AN  UNCRUSTED SURFACE), REMOVING ANY
    ROCKS LARGER THAN ABOUT 1 cm IN AVERAGE PHYSICAL DIAMETER.  THE AREA
    TO BE SAMPLED SHOULD  NOT  BE LESS THAN  30 cm x 30 cm.

3.  POUR THE SAMPLE INTO  THE  TOP SIEVE  (4-mrn OPENING), AND PLACE A LID ON
    THE TOP.

4.  ROTATE THE COVERED SIEVE/PAN UNIT BY HAND USING  BROAD  SWEEPING ARM MO-
    TIONS IN THE HORIZONAL  PLANE.   COMPLETE 20 ROTATIONS AT A SPEED JUST
    NECESSARY TO ACHIEVE  SOME RELATIVE HORIZONTAL MOTION BETWEEN THE SIEVE
    AND THE PARTICLES.                     .        .

5.  INSPECT THE RELATIVE  QUANTITIES OF CATCH  WITHIN  EACH SIEVE AND
    DETERMINE WHERE THE MODE  IN THE AGGREGATE SIZE DISTRIBUTION LIES,
    I.E., BETWEEN THE OPENING SIZE  OF THE  SIEVE  WITH  THE LARGEST CATCH AND
    THE OPENING SIZE  OF THE NEXT LARGEST SIEVE.
*ADAPTED FROM A LABORATORY  PROCEDURE  PUBLISHED BY W. S. CHEPIL  (1952). s
                              Figure 6-2,
                                   6-4

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soil passes a 1-mrn sieve, the "unlimited reservoir" model will  apply;  if
not, the "limited reservoir" model will apply.3  This relationship  has
been verified by Gillette (1980) on desert soils.2
     If the soil contains nonerodible elements which are too  large  to
include in the sieving (i.e., greater than about 1 cm in diameter),  the
effect of these elements must be taken into account by increasing the
threshold friction velocity.  Marshall (1971) has employed wind tunnel
studies to quantify the increase in the threshold velocity for differing
kinds of nonerodible elements.1*  His results are depicted in  terms  of a
graph of the rate of corrected to uncorrected friction velocity versus LC
(Figure 6-3), where LC is the ratio of the silhouette area of the
roughness elements to the total area of the bare loose soil.  The
silhouette area of a nonerodible element is the projected frontal area
normal to the wind direction.
     A value for l_c is obtained by marking off a 1-m x 1-m surface  area
and determining the fraction of area, as viewed from directly overhead,
that is occupied by nonerodible elements.  Then the overhead area should
be corrected to the equivalent frontal area; for examp.le, if a spherical
nonerodible element is half embedded in the surface, the frontal area is
one-half of the overhead area.  Although it is difficult-to estimate Lc
for values below 0.05, the correction-to-friction velocity becomes  less
sensitive to the estimated value of Lc.
     The difficulty in estimating LC also increases for small nonerodible
elements.  However, because small nonerodible elements are more likely to
be evenly distributed over the surface, it is usually acceptable to
examine a smaller surface area, e.g., 30 cm x 30 cm.
     Once again, loose sandy soils fall into the high credibility
("unlimited reservoir") classification.  These soils do not promote crust
formation, and show only a brief effect of moisture addition by
rainfall.  On the other hand, compacted soils with  a tendency for crust
formation fall into the low ("limited reservoir") credibility group.  Clay
content in soil, which tends to promote crust formation,  is  evident from
crack formation upon drying.
                                  6-5

-------
cr>
     
 

 U
 QJ
 S-

 o
 U
              10
                                                                                3   4 5 6 7 U 0 I
 -K
ID
                      3   4  567891
         2    3  4567891
                  10
            -4
10
-3
                                                          10
-2
10
                                                      L
                              Figure 6-3.  Increase.in threshold friction velocity with LC.

-------
     The roughness height, ZQ, which  is related  to  the  size and  spacing  of
surface roughness elements,  is needed to convert the  friction velocity to
the equivalent wind speed at the typical weather station sensor  height of
7 m above the surface.  Figure 6-4 depicts the roughness height  scale for
various conditions of ground cover.6  The conversion  to the 7-m  value is
discussed below.
6.1  ESTIMATION OF EMISSIONS
6.1.1  "Limited" Erosion Potential
     In the case of surfaces characterized by a  "limited reservoir" of
erodible particles, even the highest mean atmospheric wind speeds are
usually not sufficient to sustain wind erosion.   However, wind gusts may
quickly deplete a substantial portion of the erosion potential.  Because
erosion potential has been found to increase rapidly with increasing wind
speed, estimated emissions should be related to  the gusts of highest
magnitude.
     The routinely measured meteorological variable which best reflects
the magnitude of wind gusts is the fastest mile.  This quantity represents
the wind speed corresponding to the whole mile of wind movement which has
passed by the 1-mi contact anemometer in the least amount of time.   Daily
measurements of the fastest mile are presented in the monthly Local Clima-
tological Data (LCD) summaries.  The LCD summaries may be obtained  from
the National Climatic Center, Asheville, North Carolina.  The duration of
the fastest mile, typically about 2 min (for a fastest mile of 30 mph),
matches well with the half life of the erosion process,  which ranges
between 1 and 4 min.  It should be noted,  however, that  peak winds  can
significantly exceed the daily fastest mile.
     The wind speed profile in the surface boundary layer is found  to
follow a logarithmic distribution:
                        u'z> - o ln r  (2 > V                   (6-D
                                       o
where:    u = wind speed,  cm/s
         u* = friction velocity,  cm/s
          z = height above test surface, cm
         ZQ = roughness height, cm
        0.4 = von Karman's constant,  dimensionless
                                  6-7

-------
          High Rise Buildings.
          (30+Floors)
           Suburban
           Medium Buildings*
           (Institutional )
  I
  O
LU
z
x
O
D
O-
ae.
      Suburban
      Residential Dwellings
              Wheat Field
              Plowed Field
                                  Zo ( cm)
                                    1000
             Natural Snow
	800-
—600-

-—400-
                                  I—200-

                                     100
  -80.0-
  -60.0-
—40.0—
  -20.0-

   10.0
  •8.0-
  -6.0-
  -4.0-
                                    • 2.0-

                                     1.0
                                   -0.8-
                                   -0.6-
                                  —0.4.
                                    -0.2-

                                     0.1
                                              Urban Area
                                              Woodland Forest
                                              Grassland
Figure 6-4. Roughness  heights  for various surfaces,
                       6-8

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     The friction velocity (u*) is a measure of wind  shear  stress on  the
erodible surface, as determined from the slope of the logarithmic velocity
profile.  The roughness height (ZQ) is a measure of the roughness of  the
exposed surface as determined from the y-intercept of the velocity
profile, i.e., the height at which the wind speed is  zero.  These
parameters are illustrated in Figure 6-5 for a roughness height of 0.1 cm.
     Emissions generated by wind erosion are also dependent on the
frequency of disturbance of the erodible surface because each time that a
surface is disturbed, its erosion potential is restored.  A disturbance is
defined as an action which results in the exposure of  fresh surface
material.  On a storage pile, this would occur whenever aggregate material
is either added to or removed from the old surface.  A disturbance of an
exposed area may also result from the turning of surface material to a
depth exceeding the size of the largest pieces of material present.
     The emission factor for wind-generated particulate emissions from
mixtures of erodible and nonerod.ible surface material  subject to
disturbance may be expressed in units of g/m2-yr as follows:
                                       .      N
                       Emission factor = k   I   P.       .           (6-2)

where:   k = particle size multiplier
         N = number of disturbances per year
        P.J = erosion potential  corresponding to the observed (or probable)
             fastest mile of wind  for the ith period between disturbances,
             g/m2
     The particle size multiplier  (k)  for Equation 6-2 varies  with
aerodynamic particle size, as follows:

          AERODYNAMIC PARTICLE SIZE MULTIPLIERS FOR EQUATION 6-2
                   <30 um    <15 urn    <10 urn    <2.5 ym
                     1.0       0.6       0.5       0.2
                                  6-9

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                                                10m —
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                                                                          SPEED  AT Z
                                                                   WlND  -5f££D  AT lOrn
                               Figure 6-5.  Illustration of  logarithmic  velocity  profile.

-------
     This distribution of particle size within the <30  urn  fraction  is
comparable to the distributions reported for other fugitive dust  sources
where wind speed is a factor.  This is illustrated, for example,  in  the
distributions for batch and continuous drop operations encompassing  a
number of test aggregate materials (see AP-42 Section 11.2.3).
     In calculating emission factors, each area of an erodible surface
that is subject to a different frequency of disturbance should be treated
separately.  For a surface disturbed daily, N = 365/yr, and for a surface
disturbance once every 6 mo, N = 2/yr.
     The erosion potential function for a dry, exposed surface has the
following form:

              P = 58 (u* - u*)2 + 25 (u* - u*)                       (6-3)
              P = 0 for u* < u*

where:    u* = friction velocity (m/s)
        ut = threshold friction velocity (m/s)
     Because of the nonlinear form of the erosion potential function, each
erosion event must be treated separately.
     Equations 6-2 and 6-3 apply only to dry,  exposed  materials with
limited erosion potential.  The resulting calculation  is valid only for a
time period as long or longer than the period  between  disturbances.
Calculated emissions represent intermittent events and should  not  be input
directly into dispersion models that  assume steady state emission  rates.
     For uncrusted surfaces, the threshold  friction velocity  is best
estimated from the dry aggregate structure  of  the soil.   A  simple  hand
sieving test of surface soil (adapted  from  a laboratory  procedure
published by W. S.  Chepil5)  can be used  to  determine the  mode  of the
surface aggregate size distribution by inspection of relative  sieve  catch
amounts, following the procedure specified  in  Figure 6-2.   The threshold
friction velocity for erosion can  be  determined from the  mode  of the
aggregate size distribution, as described by Gillette.5   This  conversion
is presented in Figure 6-1.
                                 6-11

-------
     Threshold friction velocities for several  surface types have been
determined by field measurements with a portable wind tunnel.  These
values are presented in Tables 6-1 and 6-2 and  Figure 6-6.
     The fastest mile of wind for the periods between disturbances may  be
obtained from the monthly LCD summaries for the nearest reporting weather
station that is representative of the site in question.7  These summaries
report actual fastest mile values for each day  of a given month.  Because
the erosion potential is a highly nonlinear function of the fastest mile,
mean values of the fastest mile are inappropriate.   The anemometer heights
of reporting weather stations are found in Reference 8, and should be
corrected to a 10 m reference height using Equation 6-1.
     To convert the fastest mile of wind (u+) from  a reference anemometer
height of 10 m to the equivalent friction velocity  (u*), the logarithmic
wind speed profile may be used to yield the following equation:
                              u* = 0.053 uto                         (6-4)

where:   u* = friction velocity (m/s)
        uto = fastest mile of reference anemometer-for period between
              disturbances (m/s)
     This assumes a typical roughness  height of 0.5 cm for open terrain.
Equation 6-4 is restricted to large relatively  flat areas  with  little
penetration into the surface wind layer.
     Implementation of the above  procedure is carried out  in the following
steps:
     1.  Determine threshold friction  velocity  for  erodible material  of
         interest (see Tables 6-1 and  6-2 and Figure  6-6 or determine from
         mode of aggregate size distribution).
     2.  Divide the exposed surface area  into subareas  of  constant
         frequency of disturbance (N).
     3.  Tabulate fastest mile values  (u+)  for  each frequency of
         disturbance and correct  them  to  10  m (uT0) using  Equation 6-5.
                                 6-12

-------
                   TABLE 6-1.   THRESHOLD  FRICTION VELOCITIES
Material
Overburden3
Scoria (roadbed
Threshold
friction
velocity
(m/s)
1.02
1.33
Roughness
height
(cm)
0.3
0.3
Threshold wind
velocity at 10 m (m/s)
z0 = Actual z0 = 0.5 cm
21 19
27 25
Ref.
2
2
  material)3
Ground coal3
  (surrounding coal
  pile)
Uncrusted coal pilec
Scraper tracks on
  coal pile3'5
Fine coal dust on
  concrete padc
0.55
1.12
0.62

0.54
0.01
0.3
0.06

0.2
16
23
15

11
10
21
12

10
2
2
^Western surface coal mine.
 Lightly crusted.
GEastern power plant.
                                        5-13

-------
           TABLE  6-2.   THRESHOLD FRICTION  VELOCITIES—ARIZONA  SITES
Location
Threshold
 friction
velocity,
  m/sec
Roughness
 height,
   cm
  Threshold
wind velocity
   at  10 m,
    m/sec
Mesa - Agricultural site          0.57
Glendale - Construction site      0.53
Maricopa - Agricultural site      0.58
Yuma - Disturbed desert           0.32
Yuma - Agricultural site          0.58
Algodones - Dune flats            0.62
Yuma - Scrub desert               0.39
Santa Cruz River, Tucson          0.18
Tucson - Construction site        0.25
Ajo - Mine tailings               0.23
Hayden - Mine tailings            0.17
Salt River, Mesa                  0.22
Casa Grande - Abandoned           0.25
  agricultural, land
               0.0331
               0.0301
               0.1255
               0.0731
               0.0224
               0.0166
               0.0163
               0.0204
               0.0181
               0.0176
               0.0141
               0.0100
               0.0067
                   16
                   15
                   14
                   8
                   17
                   18
                   11
                   5
                   7
                   7
                   5
                   7
                   8
                                       6-14

-------
For narrowly sized, finely divided materials only
1 1
Aggregate size
distribution rpode y't Measured
(in) (mm) (cm/s)



Gravel ^



	 	 	

Coarse
Sand "<
	
Fine
Sand "
— — — 	 — — — — —
0.3


0.2


0.1
>
0.05

0.01

*•-
a
7
6
5
4
3
-
2
_
1
0.5
-
0.1
0.02
-
-
-
-
-
-

-


_
-
—
150

Undisturbed coal pile
Scoria
Undisturbed coal pile
Uncrusled coal pile
j nn Overburden
Disturbed coal pile


Coal pile (scraper tracks)
Dune llala
Agricultural sites
Ground coal
cn Construction sila
t>U Finn coal dust
Scrub dusoil
Oisltirbod dusuM
Construction sila and disturbed pruiiie soil
Abandonud ngiicullurul land
Fluvial channels
Mine tailings
0
                 Figure 6-6.   Scale of threshold  friction velocities.

-------
     4.  Convert fastest mile values (ut0)  to equivalent friction
         velocities (u*), using Equation 6-4.
     5.  Treating each subarea (of  constant N and u*) as a separate
         source, calculate the erosion potential  (P.j) for each period
         between disturbances using Equation 6-3  and the emission factor
         using Equation 6-2.
     6.  Multiply the resulting emission factor for each subarea by the
         size of the subarea, and add  the emission contributions of all
         subareas.  Note that the highest 24-h emissions would be expected
         to occur on the windiest day  of the year.  Maximum emissions are
         calculated assuming  a single  wind  event  with the highest fastest
         mile value for the annual  period.
     The recommended emission factor equation presented above assumes that
all of the erosion potential  corresponding  to the fastest mile of wind is
lost during the period between disturbances.  Because the fastest mile
event typically lasts only about 2  min,  which corresponds roughly to the
half-life for the decay of actual erosion potential,  it could be argued
that the emission factor overestimates particulate emissions.  However,
there'are other aspects of the wind erosion process which offset this
apparent conservatism:
     1.  The fastest mile event contains  peak winds which substantially
         exceed the mean value for  the event.
     2.  Whenever the fastest mile  event  occurs,  there  are  usually a
         number of periods of slightly lower  mean  wind  speed  which contain
         peak gusts of the same order  as  the  fastest  mile wind  speed.
     Of greater concern is the likelihood of  overprediction of  wind
erosion emissions in the case of surfaces disturbed infrequently in
comparison to the rate of crust formation.
6.1.2  "Unlimited" Erosion Potential
     For surfaces characterized by  an  "unlimited reservoir" of  erodible
particles, particulate emission rates  are relatively  time independent  at  a
given wind speed.  The technology currently used for  predicting
agricultural wind erosion in  the United States is  based on variations  of
the Wind Erosion Equation.11,12  This  prediction system uses  erosion  loss
estimates that are integrated  over  large  fields and long-time scales to
                                 6-16

-------
produce average annual values.  A simplified version of the  agricultural
wind erosion equation is presented in Section 7.1.2.
6.2  DEMONSTRATED CONTROL TECHNIQUES
     Wind erosion of exposed areas is a recognized source of particulate
air pollution associated with the mining and processing of metallic  and
nonmetallic minerals.  Preventive methods for control of windblown
emissions from open areas consist of wetting, chemical stabilization,  and
enclosures.  Physical stabilization by covering the exposed surface  with
less erodible aggregate material and/or vegetative stabilization are also
practical control methods for certain categories of open areas.
     Wind erosion control of soil surfaces is accomplished by stabilizing
erodible soil particles.  The stabilization process is accomplished  in
three major successive stages:  (a) trapping of moving soil particles,
(b) consolidation and aggregation of trapped soil  particles, and
(c) revegetation of the surface.13
     The trapping of eroding soil is termed "stilling" of erosion.   This
may be effected by roughening the surface, by placing barriers in the path
of the wind,.or by burying the erodible particles  during tillage.
Trapping is accomplished naturally by soil crusting resulting from rain
followed by a slow process of revegetation.  It should be stressed that
the stilling of erosion is only temporary; to effect a permanent control,
plant cover must be established or plant residues  must be maintained.
     In bare soils containing a mixture of erodible and nonerodible
fractions, the quantity of soil  eroded by the wind is limited by the
height and number of nonerodible particles that become exposed  on the
surface.  The removal of erodible particles continues until  the height  of
the nonerodible particles that serve as barriers to the wind  is increased
to a degree that affords complete shelter to the erodible  fractions.   If
the nonerodible barriers are low,  such as fine  gravel,  a relatively large
number of pieces are needed for protection of soil  from wind  erosion.  The
gravel  in such a case would protect  the erodible portion more  by  covering
than by sheltering from the wind.   Thus all  nonerodible materials on  the
ground that control  erosion have an  element of  cover  in addition  to the
barrier principle which protects the  soil.   The  principles of  surface
barriers and cover are, therefore,  inseparable.
                                 6-17

-------
     The above principles extend to almost all elements used  in  wind
erosion control.  All of these control methods are designed to  (a)  take up
some or all of the wind force so that only the residual force,  if  any,  is
taken up by the erodible soil fractions; and (b) trap the  eroded soil,  if
any, on the lee side or among surface roughness elements or barriers,
thereby reducing soil avalanching and intensity of erosion.
     In the sections that follow, various control methods  are discussed
with respect to their characteristics and effectiveness in controlling
open area wind erosion.  Methods include vegetative cover, soil  ridges,
windbreaks, crop strips, chemical stabilizers, and irrigation.
6.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES
     This section evaluates alternative controls for open  area wind
erosion.  Relevant control cost information is presented in Section  4.3.
6.3.1  Chemical Stabilization
     A portable wind tunnel has been used to measure the control of  coal
surface wind erosion emissions by a 17 percent solution of Coherex®  in
water applied at an intensity of 3.4 L/m2 (0.74 gal/yd2), and a
2.8 percent solution of Dow Chemical M-167 Latex Binder in water applied
at an average .intensity of 6.8 L/m2 (1.5 gal/yd2).11*  The control
efficiency of Coherex® applied at the above intensity to an undisturbed
steam coal surface approximately 60 d before the test,  under a wind of
15.0 m/s (33.8 mph) at 15.2 cm (6 in) above the ground,  was 89.6 percent
for TP and approximately 62 percent for IP and FP.   The  control  efficiency
of the latex binder on a low volatility coking coal  is  shown in
Figure 6-7.
6.3.2  Wind Fences/Barriers
     Wind fences/barriers are an effective means  by  which  to control
fugitive particulate emissions from open dust  sources.   The principle of
the wind fence/barrier is to provide an area of reduced  wind velocity
which allows settling of the large  particles  (which  cause  saltation) and
reduces the particle flux from the  exposed  surface on the  leeward side  of
the fence/barrier.   Wind fence/barriers  can either be man-made structures
or vegetative in nature.
     Windbreaks consist of trees  or shrubs  in  1 to 10 rows,  wind  and snow
fences, solid wooden or rock walls,  and  earthen banks.   The effectiveness
                                 6-18

-------
   100
    80
o
c
CD
"o
   60
LLJ
o 40
"c
o
o
   20
                                       6.8   /m2(i.5 gal/yd2)of
                                       2.8% Solution in Water
Tunnel Wind
Speed = 17 m/s (38 mph)
at 15 cm (6.0 in)
Above the Test Surface

Key:
                   I
                     I
I
                  1             2            3            4

                      Time After Application (Days)


        Figure 6-7. Decay  in control efficiency of latex binder applied to
                           coal  storage piles.13
                                6-19

-------
of any barrier depends on the wind velocity and direction, shape, width,
height, and porosity of the barrier.
     Nearly all barriers provide maximum reduction in wind velocity  at
leeward locations near the barrier, gradually decreasing downwind.
Percentage reductions in wind velocities for rigid barriers remain
constant no matter what the wind velocity.^
     Direction of wind influences the size and location of the protected
areas.  Area of protection is greatest for perpendicular winds to the
barrier length and least for parallel winds.
     The shape of the windbreak indicates that a vertically abrupt barrier
will provide large reductions in velocity for relatively short leeward
distances, whereas porous barriers provide smaller reductions in velocity
but for more extended distances.
     Height of the barrier is, perhaps, the most important factor
influencing effectiveness.  Expressed in multiples of barrier height, the
zone of wind velocity reduction on the leeward side may extend to 40 to
50 times the height of the barrier; however, such reductions  at those
distances are insignificant for wind erosion control.  If complete control
is desired, then barriers must be placed at close intervals.
     Tree windbreaks and various artificial  barriers  are discussed below.
     Tree windbreaks.  One-,  two-, three-, and five-row barriers of trees
are found to be the most effective arrangement for planting to control
wind erosion.  The type of tree species planted also  has a considerable
influence on the effectiveness of a windbreak.   The rate of growth governs
the extent of protection that can be realized in later  years.
     Artificial barriers.  Snow fences, fences  constructed of  board  or
lath, bamboo and willow fences,  earthen banks,  hand-inserted  straw rows,.
and rock walls have been used for wind erosion  control  on a rather limited
scale.  Because of the high cost of both material  and labor required  for
construction, their use has been limited to  where  high  value crops are
grown or where overpopulation requires intensive  agriculture.
     In the United States, the application of artificial  barriers  for wind
erosion control has been limited.   Snow fences  constructed  from  strips of
lath held together with wire  have been used  for  protecting  vegetable
crops.  Such fences provide only a relatively short zone  of protection
against erosion, approximately 10 times the  height  of the  barrier.

                                 6-20

-------
     Effectiveness.  A number of studies have attempted to determine  the
effectiveness of wind fences/barriers for the control of windblown dust
under field conditions.  Several of these studies have shown both a
significant decrease in wind velocity as well as an increase in sand  dune
growth on the lee side of the fence.13,15-17  The degree of emissions
reduction varied from study to study ranging from 0 to a maximum of about
90 percent depending on test conditions.is,ia  A summary of available test
data contained in the literature on the control achieved by wind fences/
barriers is provided in Table 6-3.
     Various problems have been noted with the sampling methodology used
in each of the studies conducted to date.   These problems tend to limit an
accurate assessment of the overall degree  of control achievable by wind
fences/barriers for large, open sources.  Most of this work has either not
thoroughly characterized the velocity profile behind the fence/barrier or
adequately assessed the particle flux from the exposed surface.
6.3.3  Vegetative Cover
     Natural vegetative cover is the most  effective, easiest, and most
economical way to maintain an effective control of wind erosion.  In
addition to the crops such as grasses, wheat sorghum,  corn legumes,  and
cotton, crop residues are often placed on  fallow fields until a permanent
crop is started.  All of these methods can remove 5 to 99  percent of the
direct wind force from the soil surface.^
     Effectiveness.  Grasses and legumes are most effective because  they
provide a dense, complete cover.  Wheat and other small  grains  are
effective beyond the crucial 2 or 3 mo after planting.   Corn, sorghum, and
cotton are only of intermediate effectiveness because  they are  planted in
rows too far apart to protect the soil.
     After harvesting,  vegetative residue  should be anchored  to the
surface.20  Duley found that legume residues  decay rapidly, while  corn and
sorghum stalks are durable.21  He found  wheat and rye  straw more resistant
to decay than oat straw.2"-
     Maintenance.  Excessive tillage,  tillage with improper implements,
and overgrazing are the major causes of  crop  cover destruction.   Effective
land management practices must be instituted  if wind erosion  is  to be
controlled.
                                 6-21

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                      TABLE 6-3.   SUMMARY OF AVAILABLE CONTROL EFFICIENCY DATA  FOR WIND  FENCES/BARRIERS
        Material or control parameter
                                                      Reference No. 16
                                                                                                       Reference No. 18
cr>
i
ro
ro
Type of fence/barrier
Porosity of fence/barrier
Height/length of  fence/barrier
Type of erodable  material
Material characteristics

Incident wind speed

Lee-side wind speed

Parti cut ate measurement technique9
Test data rating
Measured particulate control  efficiency0
Textile fabric
50 percent
1.8 (n/50 m
Flyash
Percent H20 = 1.6
Percent <30 pro = 14.7
Percent <45 pm = 4.6
Average (no screen)  =  4.3 m/s  (9.7 mph)
Average (upwind) = 5.32 m/s  (11.9 mph)
Average = 2 m/s (4.0 mph) or 64 percent
  reduction
U/0 = hi-vol and hi-vol w/SSI  (11 tests)
C
TP = 64 percent (average)
TSP = 0 percent (average)
Mood cyclone fence
50 percent
3 ra/12 m
Mixture of topsoil and  coal
Unknown

Maximum 27 m/s (60 mph)

Unknown

U/D - Bagnold catchers  (one test)
C
TP = 88 percent (average)
         ?Hi-vol  = high volume air sampler; hi-vol  w/SSI  =  high volume air sampler with 15 umA size-selective inlet, SSI.
         DData  rated  using criteria specified in Section  4.4.
         CTP =  total  particulate matter, TSP = total  suspended particulate matter (particles <~30 jjmA).

-------
     For grazing, the number of animals per acre  should  be  controlled to
maximize the use of grass and still maintain sufficient  vegetative  cover.
     Stubble mulching and minimum tillage or plow-plant  systems  of  farming
tend to maintain vegetative residues on the surface when the  land is
fallow.  Stubble mulching is a year-round system  in which all  tilling,
planting, cultivating, and harvesting operations  are performed to provide
protection from erosion.  This practice requires  the use of tillage
implements which undercut the residue without soil inversion.
6.3.4  Limited Irrigation of Barren Field
     The periodic irrigation of a barren field controls blowing  soil  by
adding moisture which consolidates soil particles and creates a  crust upon
the soil surface when drying occurs.23  The amount of water and  frequency
of each irrigation during fallow to maintain a desired level of  control
would be a function of the season and of the crusting ability of the  soil.
6.4  EXAMPLE OUST CONTROL PLAN—COVERING UNPAVED PARKING LOT WITH LESS
     ERODIBLE SURFACE MATERIAL
     Description of Source                          ;
     •  Dirt parking lot of dimensions 100 m x 100 m
     •  Uniform daily disturbance by traffic
     •  Sample of surface material shows size distribution of 0.56 mm
     •  LCD as shown in Figure 6-8 for example month
     Calculation of Uncontrolled Emissions:   Wind erosion emissions  from
the parking lot can be calculated using the procedure described in AP-42
Section 11.2.7.  Implementation of this procedure for a uniformly
distributed area is carried out in the following steps:
     1.  Determine threshold friction velocity for surface material  from
         the mode of the size distribution.   As seen from Figure 6-1,  a
         mode of 0.56 mm corresponds to a threshold friction velocity  of
         52 cm/s (ut).
     2.  Divide the exposed surface area into  subareas  of constant
         frequency of disturbance, N.   In this  instance,  N  = 365/yr
         applies to the entire lot.
     3.  Convert the daily fastest mile values  as shown in  Figure 6-8  at
         7 m above the surface,  to equivalent  friction  velocities, u*,
         using the following variations of Equation 6-1:
                                 6-23

-------
    Local Ciimatoiogical  Data
              MO.'MHLY SUMMARY
HIND
s
0
z
=>
cr
i:
30
0
0
13
12
20
29
29
22
• 1 4
29
1 7
21
0
0
01
33
27
32
24
22
32
29
07
31
30
30
33
34
29
_ nCSJJLlANI
SPCfO M.P.il.
5.3
10.5
2.4
1 1 .0
1 . 3
I ! . 1
19.6
10.9
3.0
14.6
22.3
7.'7
4.' 5
6.7
13.7
1 1 .2
4.3
9.3
7.5
10.3
17. 1
2.4
5.9
1 1 .3
2. 1
8.3
8.2
5..0
3. 1
4.9
o
a.
0 3
<= a
» X
15
6.
10.6
6.0
M.4
11.9
19.0
9.8
1 i .2
8. 1
15. 1
23.3
13.5
15.5
9.6
8.8
13.3
1 1 .5
5.8
0.2
7.8
0.6
7.3
8.5
8.8
.7
2.2
8.5
8.3
6.6
5.2
5.5
FASTEST
MILE
i —
• o
1_|0
• It s
15
c
10
16
oil
1 7
15
fi
19
41
1 4
f
6
16
9
8
. UJ
• £
0
17
36
01
02
13
1 1
30
30
30
13
12
29
17
13
13
M
35
34
31
35
24
20
32
13
02
32
32
26
32
32
31
25
FOS THE MONTH: 1
30 | 3.3 1
— 	 -
i . I
31
29
	 ICUTf: 1 1

•
5
a
22
i
2
3
4
e
6
7
g
9
12
I
12
13
1 4
15
16
7
19
' 9
20
21
22
23
24
26
27
23
29
30
^ J

Figure 6-8.
Daily fastest miles of wind at 7 meters for
    periods of interest.
                     6-24

-------
                              u0 - 1.05 u

                               u* = 0.053 u"["0

     4.  Calculate the erosion potential, P.,-, for each  day  (period between
         disturbances) using the following equation  (see  Table  6-4):

                     Pi  = 58 (u* - u*)2 + 25 (u* - u*)
                                 *    *
                     P.  = 0 for u  < u.
where:   u* = friction velocity (m/s)
         ut = threshold friction velocity (m/s)
     5.  Sum all P.,- for the 31 days of interest, and multiply by the wind
         erosion PM10 multiplier, 0.5, and the affected surface area,  A.
         This can only be done when the disturbance pattern is uniform
         over the entire erodible surface for each period between
         disturbances.  The resulting uncontrolled emissions are:
                       E = kPA
                         =0.5 (32.81)(10,000)
                         = 164 kg
     Target Control Efficiency:  70 percent
     Method of Control;   Cover parking lot with any material having a  high
enough u£ to achieve 70 percent control efficiency.
     Demonstration of Control Program Adequacy:   Resulting control
efficiencies for different ut values can be calculated as shown in
Table 6-5.  From these calculations, it can be seen 'that the parking lot
must be covered with a material having a u^ of greater than 0.64 m/s,
after the loose surface  material  reaches an equilibrium state  under the
daily influence of traffic.
6.5  POTENTIAL REGULATORY FORMATS
     Potential regulatory formats for control  of open area wind  erosion
are listed in Table 6-6.   These focus on appropriate  measures  for compli-
ance determination.  An  example regulation is  presented in Appendix G.
                                 6-25

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TABLE 6-4.  CALCULATION OF DAILY EROSION POTENTIALS
          FOR UNIFORMLY DISTURBED SURFACE
Day
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Total
ut.
mph
9
14
10
16
15
29
30
17
15
23
31
23
18
22
13
21
15
12
14
16
16
25
14
15
17
16
16
13
10
9
8

utot
mph
9.4
14.7
10.5
16.8
15.8
30.4
31.5
17.8
15.8
24.2
32.6
24.2
18.9
23.1
13.6
22.0
15.8
12.6
14.7
16.8
16.8
26.2
14.7
15.8
17.8
16.8
16.8
13.6
10.5
9.4
8.4

u*.
m/s
0.22
0.35
0.25
0.40
0.37
0.72
0.75
0.42
0.37
0.57
0.77
0.57
0.45
0.55
0.32
0.52
0.37
0.30
0.35
0.40
0.40
0.62
0..35
0.37
0.42
0.40
0.40
0.32
0.25
0.22
0.20

*
uf
m/s
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0.52
0;52
'
Erosion
potential,
g/m2
0.00
0.00
0.00
0.00
0.00
7.32
8.82
0.00
0.00
1.40
9.88
1.40
0.00
0.80
0.00
0.00
0.00
0,00
0.00
0.00
0.00
3.08-
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
32.7
                          6-26

-------
TABLE 6-5.  EROSION POTENTIAL (g/m2) FOR DIFFERENT VALUES OF u£ (m/s)
Day
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Totals
u*,
m/s
0.22
0.35
0.25
0.40
0.37
0.72
0.75
0.42
0.37
0.57
0.77
0.57
0,45
0.55
0.32
0.52
0.37
0.30
0.35
0.40
0.40
0.62
0.35
0.37
0.42
0.40
0.40
0.32
0.25
0.22
0.20

Control

0.520
0.00
0.00
0.00
0.00
0.00
7.39
8.63
0.00
0.00
1.46
9.94
1.46
0.00
0.72
0.00
0.06
0.00
0.00
0.00
0.00
0.00
3.15
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
32.81
0

0.550
0.00
0.00
0.00
0.00
0.00
5.99
7.14
0.00
0.00
0.58
8.36
0.58
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
2.10
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
24.76
25

0.580
0.00
0.00
0.00
0.00
0.00
4.69
5.76
0.00
0.00
0.00
6.90
0.00
0.00
"0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.15
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
18.50
44
+
ut
0.610
0.00
0.00
0.00
0.00
0.00
3.50
4.48
0.00
0.00
0.00
5.53
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.31
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
13.83
58

0.640
0.00
0.00
0.00
0.00
0.00
2.42
3.31
0.00
0.00
0.00
4.28
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
' 0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
10.01
69

0.670
0.00
0.00
0.00
0.00
0.00
1.44
2.24
0.00
0.00
0.00
3.12
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
o.bo
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
6.80
79

0.700
0.00
0.00
0.00
0.00
0.00
0.56
1.28
0.00
0.00
0.00
2.07
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
3.91
88

0.730
0.00
0.00
0.00
• 0.00
0.00
0.00
0.42
0.00
0.00
0.00
1.13
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
.0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.55
95
efficiency,
percent
                                6-27

-------
                                           TABLE  6-6.   METHODS  FOR  COMPLIANCE DETERMINATION
        Source types
                           Permits
                                  Field audits
                                                                            Work  practices
                                                                            (recordkeeping)
                                                                                                     Emission measurement
CT>
i
ro
00
        Construction
          areas

        Vacant  lots
         Unpaved  parking
           lots

         Feed  lots
         Staging  area
                   Yes

                   Yes-cond.
                   on area  dist.

                   Yes
                   Yes-cond.
                   on size-
                   where alloned
                   Yes
Off-road           Yes
  recreation area
         Land fills
         Land disposal
           (spreading)

         Retired farm
           land
         HpO mining

         Dry washes 4
           river beds
         Unpaved air
           strip
                   Yes



                   Yes


                   No

                   Yes

                   No

                   Yes
Threshold friction velocity
Moisture content
Visible erosion (scouring)
Threshold friction velocity
Moisture content
Visible erosion (scouring)
Threshold friction velocity
Moisture content

Moisture content
Threshold friction velocity
Moisture content
Visible erosion (scouring)
 Threshold  friction velocity
 Moisture content
 Visible erosion
 Threshold friction  velocity
 Moisture content
 Visible erosion
 Wet stabiIization
 Chemical  stabilization
 Wind fences
 Chemical  stabilization
 vegetation cover
 1% ground cover)
 Graveling
 Chemical  stabilization

 Wet suppression (sprinklers)
 Wind fences

 Wet stabiIization
 Chemical  stabilization
 Wind fences
 Limit area disturbed
 Limit vehicles (activity
   emissions)
 Limit working face
 Wet suppression access
   and working area
• Vegetation cover
 Chemical stabilization
 Vegetative cover
 Wind fences
 Vegetative cover
    -perennial (% ground cover)
 Vegetative cover
  .  -perennial (% ground cover)
 Prohibit motor vehicles

 Set stabiIIzation
 Chemical stabilization
% V.E. at property line/source
PM.Q/TSP concentration at
  property 11ne
% V.E. at property line/source
PM.Q/TSP concentration at
  property line
% V.E. at property line/source
PM]0/TSP concentration at
  property line
% V.E. at property line/source
PM)0/TSP concentration at
  property Iine
% V.E. at property line/source
PM.Q/TSP concentration at
  property line
                                                           % V.E.  at property line/source
                                                           PM.Q/TSP concentration at
                                                             property line
 %  V.E.  at  property  line/source
 PM)0/TSP concentration  at
   property line

-------
6.6  REFERENCES TO SECTION 6

 1.  Gillette, 0. A., J. Adams, D. Muhs, and R. Kilh.  1982.  Threshold
     Friction Velocities and Rupture Moduli for Crusted Desert Soil for
     the Input of Soil Particles into the Air.  Journal of Geophysical
     Research, 87, 9003-9015.

 2.  Gillette, D. A., et al.  1980.  Threshold Velocities for Input of
     Soil Particles Into the Air by Desert Soils.  Journal of Geophysical
     Research, 85(C10), 5621-5630.

 3.  Bisal, F., and W. Ferguson.  1970.  Effect of Nonerodible Aggregates
     and Wheat Stubble on Initiation of Soil Drifting.  Canadian Journal
     of Soil Science, 50, 31-34.

 4.  Marshall, J.  1971.  Drag Measurements in Roughness Arrays of Varying
     Density and Distribution.  Agricultural Meteorology, 8, 269-292.

 5.  Chepil, W. S.  1952.  Improved Rotary Sieve for Measuring State and
     Stability of Dry Soil Structure.  Soil Science Society of America
     Proceedings. 16, 113-117.

 6.  Cowherd, C., and C. Guenther.  1976.  Development of a Methodology
     and Emission Inventory for Fugitive Dust for the Regional Air
     Pollution Study.  EPA-450/3-76-003.  Prepared for U.S. EPA, Office of
     Air and Waste Management, Office of Air Quality Planning and
     Standards, Research Triangle Park, North Carolina.

 7.  Gillette, D. A., et al.  Threshold Velocities for Input of Soil
     Particles Into the Air by Desert Soils.  Journal of Geophysical
     Research, 85(C10), 5621-5630.

 8.  Axetell, K., and C. Cowherd, Jr.  1984.  Improved Emission Factors
     for Fugitive Dust From Surface Coal Mining Sources.   Volumes I and
     II, EPA-600/7-84-048.  U.S. Environmental  Protection Agency,
     Cincinnati, Ohio.  March 1984.

 9.  Muleski, G. E.  1985.  Coal Yard Wind Erosion Measurement.   Final
     Report.  Prepared for Industrial Client of Midwest Research
     Institute, Kansas City, Missouri.  March 1985.

10.  Changery, M. J.  1978.  National Wind Data Index Final  Report.
     HCO/T1041-01 UC-60.  National Climatic Center,  Asheville, North
     Carolina.  December 1978.

11.  Woodruff, N. P., and F. H.  Siddoway.  1965.   A Wind  Erosion
     Equation.  Soil Sci. Soc. Amer.  Proc,  29(5),  602-608.

12.  Skidmore, E. L., and N. P.  Woodruff.  1968.   Wind Erosion Forces  in
     the United States and Their Use  in Predicting Soil  Loss.   USDA,  ARS,
     Agriculture Handbook No. 346.  42 pp.
                                 6-29

-------
13.  Chepil, N. S., and N. P.  Woodruff.  1963.   The Physics of Wind
     Erosion and Its Control.   In Advances in Agronomy. Vol. 15,
     A. G. Norman, Ed., Academic Press, New York,  New York.

14.  Cuscino, T., Jr.,  et al.   1983.   Iron and  Steel  Plant Open Source
     Fugitive Emission  Control  Evaluation.  EPA-600/2-83-110.  U.S.
     Environmental Protection  Agency,  Research  Triangle Park, North
     Carolina.  October 1983.

15.  Carnes, D., and D. C. Drehmel.   1982.  The Control of Fugitive
     Emissions Using Windscreens.   In  Third Symposium on the Transfer and
     Utilization of Participate Control Technology (March 1981). Vol. IV,
     EPA-600/9-82-005d, NTIS No.  PB83-149617.  April  1982.

16.  Larson, A. G.  1982.  Evaluation  of Field  Test Results on Wind Screen
     Efficiency.  In Fifth EPA  Symposium on Fugitive  Emissions:
     Measurement and Control,  Charleston, South Carolina.  May 3-5, 1982.

17.  Westec Services, Inc.  1984.   Results of Test Plot Studies at Owens
     Dry Lake, Inyo County, California.  San Diego, California.
     March 1984.

18.  Radkey, R. L., and P. B. MacCready.   1980.  A Study of the Use of
     Porous Wind Fences to Reduce  Particulate Emissions at the Mohave
     Generating Station.   AV-R-9563, AeroVironment, Inc., Pasadena,
     California.

19.  Zingg, A. W.  1954.   The Wind  Erosion Problem in  the Great. Plains.
     Trans Geophysics Union. 35,  252-258.

20.  Chepil, N. S., N.  P. Woodruff, F.  H.  Siddoway, and L.  Lyles.   1960.
     Anchoring Vegetative Mulches.  Agricultural Engineering,  41,
     754-755.

21.  Duley, F. L.  1958.   U.S.  Department  of  Agriculture  Agronomy
     Handbook, 136, 1-31.

22.  Lyles, L., and N.  P. Woodruff.  1962.  How Moisture  and Tillage
     Affect Soil Cloddiness for Wind Erosion  Control.   Agricultural
     Engineering, 43, 150-153,  159.

23.  Guideline for Development of Control  Strategies in Areas With
     Fugitive Dust Problems.  1977.  OAQPS No. 1.2-071.   U. S.
     Environmental  Protection Agency, Research Triangle Park, North
     Carolina.  October 1977.

24.  Jutze, G., and K.  Axetell.  1974.   Investigation of  Fugitive Dust,
     Volume I—Sources,  Emissions, and  Control.  EPA-450/3-74-036a. U.  S.
     Environmental  Protection Agency, Research Triangle Park, North
     Carolina.  June 1974.
                                 6-30

-------
                              7.0  .AGRICULTURE

     Fugitive dust from agricultural operations  is  suspected  of
contributing significantly to the ambient particulate  levels  of  many
agricultural counties.  Such agricultural operations include  (a)  plowing,
(b) disking, (c) fertilizing, (d) applying herbicides  and  insecticides,
(e) bedding, (f) flattening and firming beds,  (g) planting, (h)  culti-
vating, and (i) harvesting.  These operations  can be generically
classified as soil preparation, soil maintenance, and  crop harvesting
operations.  As discussed in Section 6, dust emissions are also generated
by wind erosion of bare or partially vegetated soil.   This section will
focus on emissions from both wind erosion and  agricultural tilling opera-
tions that are designed to (a) create the desired soil structure  for the
crop seed bed and (b) to eradicate weeds.
7.1  ESTIMATION OF EMISSIONS
7.1.1  Tilling
     The mechanical  tilling of agricultural  land injects dust particles
into the atmosphere as the soil  is loosened or turned under by plowing,
disking, harrowing,  one-waying,  etc.  AP-42 presents a predictive emission
factor equation for the estimation of dust emissions from agricultural
tilling:!

                          E  =  k(5.38)(s)°-s  kg/ha
                         E = k(4.80)(s)°-s lb/acre

where:  s = silt content (percent) of surface soil  (default value of
            18 percent)
        k = particle size multiplier (dimensionless)
The particle size multiplier,  k  is given as  0.21  for PM10.   The above
equations are based  solely on  field testing  information cited  in AP-42.
Silt content of tested soils ranged from 1.7 to 88  percent.
                                  7-1

-------
7.1.2  Hind Erosion
     The technology currently used for predicting agricultural wind
erosion in the United States is based on variations of the Wind  Erosion
Equation.1,2  This prediction system uses erosion loss estimates  that  are
integrated over large fields and long time scales to produce average
annual values.
     7.1.2.1  Simplified Version of Wind Erosion Equation.  Presented
below is a procedure for estimating windblown or fugitive dust emissions
from agricultural  fields.  The overall approach and much of the data have
been adapted from the wind erosion equation,  which was developed  as the
result of nearly 40 yr of research by the U.S.  Department of Agriculture
to predict-topsoil losses from agricultural  fields.
     Several simplifications have also been  incorporated during the
adaptation process.  The simplified format is not expected to affect
accuracy in its present usage,, since wind erosion estimates using the
simplified equation are almost always within  5% of those obtained with  the
original USOA equation.  Most of the input data are not accurate to ±5%.
     7.1.2.1.1  Windblown dust equation.  .The modified equation is of the
form:

                              E = kalKCL'V                           (7-1)

where:   E = PM10  wind erosion losses of  tilled  fields, tons/acre/yr
         k = 0.5,  the estimated fraction  of TSP  which  is  PM10
         a = portion of total  wind erosion losses  that would  be measured
             as suspended particulate,  estimated to  be 0.025
         I = soil  erodibility,  tons/acre/yr
         K = surface roughness  factor,  dimension!ess
         C = climatic factor,  dimensionless
        I'  = unsheltered field  width  factor,  dimensionless
        V  = vegetative cover  factor,  dimensionless
     As an aid in  understanding the mechanics of  this  equation,  "I"  may be
thought of as the  basic erodibility of  a  flat, very  large,  bare  field  in a
climate highly conducive to  wind  erosion  (i.e.,  high wind speeds  and
temperature with little precipitation)  and K, C,  L' , and V as  reduction
                                 7-2

-------
factors  for  a  ridged  surface, a climate  less  conducive  to  wind  erosion,
smaller-sized  fields, and vegetative  cover, respectively.
     The same  equation can be used to estimate  emissions from:   (1)  a
single field,  (2) a medium-sized area such as a valley  or  county,  or
(3) an entire  AQCR or state.  Naturally, more generalized  input data must
be used  for  the  larger land areas, and the accuracy  of  the resulting
estimates decreases accordingly.
     7.1.2.1.2  Procedures for compiling input  data.  Procedures for
quantifying  the  five variable factors in Equation  (7-1) are explained in
detail below.
     Soil Erodibility, I.  Soil credibility by  wind  is  a function  of the
amount of credible fines in the soil.  The largest soil aggregate  size
normally considered to be erodible is approximately 0.84 mm equivalent
diameter.  Soil  credibility, I, is related .to the percentage of dry
aggregates greater than 0.84 mm as shown in Figure 7-1.  The percentage  of
nonerodible  aggregates (and by difference the amount of fines)  in  a  soil
sample can be  determined experimentally by a  standard dry  sieving
procedure, using a No. 20 U.S. Bureau of Standards sieve with 0.84-mm
square openings.
     For areas larger than can be field sampled  for soil aggregate size  '
(e.g., a county) or in cases where soil  particle size distributions  are
not available, a representative value of I  for use in the windblown  dust
equation can be obtained from the predominant  soil type(s)  for farmland  in
the area.  Measured credibilities of  various  soil textural  classes  are
presented in Table 7-1.
     If  an area  is too large to be accurately  represented  by a soil class
or by the weighted average of several  soil  classes, the  map in Figure 7-2
and the  legend in Table  7-2  can be used  to  identify major  soil  deposits
and average soil erodibility on a national  basis.  Other soil  maps  are
available from the Soil  Conservation  Service branch of  the  U.S.  Department
of Agriculture.
     Values of I obtained from Figure  7-1,  from  Table 7-1,  or  from  soil
maps can be substituted  directly  into  Equation (7-1).
                                  7-3

-------
100
                                                      ..u.
                                            -.1....
50
                                         7D    a3
                          DRY1  JCIL  AGGIEGATE3
   Figure  7-1.  Soil erodibility as a function  of  particle  size.
                             7-4

-------
LLL/dl401-7at, p. 1-
                    TABLE 7-1.  SOIL ERODIBILITY FOR VARIOUS
                              SOIL TEXTURAL CLASSES
Predominant soil textural class
Sanda
Loamy sanda
Sandy loamd
Clay
Silty clay
Loam
Sandy clay loama
Sandy claya
Silt loam
Clay loam
Silty clay .loam-
Silt
Erodibil ity, I,
tons/acre/yr
220
134
36
86
86
56
56
56
47
47
: 38
38
            aVery fine, fine, or medium sand.
                                      7-5

-------
        U. 1. DfPAHIUINT OF AGRICULTURE
                                                     GENERAL SOIL MAP OF THE UNITED STATES
                                                                                                                        SOU CONSERVATION SIKVICI
 I
cn
                                       Figure  7-2.   Generalized soil  map  of the United  States.

-------
LLL/dl401-7at, p. 2
                  TABLE 7-2.  LEGEND FOR SOIL MAP IN FIGURE i-i
   Al,  A2            Seasonally  wet  soils  with  subsurface  clay  accumulation
   A3-  A5            Cool  or  cold  soils  with  subsurface  clay  accumulation
   A6-  A8            Clays
   A9,  A10           Burnt clay  soils
   All- A13          Dry  clay soils  with some cementation
   01-  D6            Arid  soils  with clay  and alkali or  carbonate
                     accumulation
   El                Poorly-drained  loamy  sands
   E2                Loamy or clayey alluvial deposits
   E3-  E8            Shallow  clay  loam deposits on  bedrock
   E9                Loamy sands in  cold regions
   E1Q, E12          Loamy sands in  warm regions
   Ell, E13,  E14    Loamy sands in  warm,  dry regions
   HI,  H2            Wet  organic soils.;  peat  and muck
   II                Ashy  or  amorphous soils  in cold regions
   12                Infertile soils with  large amounts  of  amorphous material
   13                Fertile  soils of weathered volcanic ash
   14                Tundra;  frozen  soils
   15,  16            Thin  loam surface horizon  soils
   17                Clay  loams  in cool  regions
   18-  110           Wide  varying  soil material with some  clay  horizons
   111               Rocky soils shallower than 20  in, to  bedrock
   112               Clay  loams  in warm, moist  regions
   113               Clay  loams  in cold  regions

                                   (continued)
                                      7-7

-------
LLL/dl401-7at,  p.  3
                              \iBLE 7-2 'Continued'
    114                Clay  loams  in  temperate climates
    Ml- M4             Surface  loam horizon underlain by  clay
    M5                 Shallow  surface  loams with  no underlying  clays
    M6- MS             Surface  loamy  soils
    M9- M14            Semiarid loams or clay  loams .
    M15,  M16           Dry  loams
    01, 02             Clays  and sandy  clays
    SI- S4             Sandy, clay, and sandy  clay loams
    Ul                 Wet  silts with some subsurface clay  accumulation
    U2- U6             Silty  loams with subsurface clay  accumulation
    U7                 Dry  silts with thin subsurface clay  accumulation
    VI- V2             Clays  and clay loams
    V3- VS.        .    Silty  clays                        ,
    XI- X5             Barren areas,  mostly rock with some  included soils
                                      7-8

-------
     Surface Roughness Factor, K.  This factor  accounts  for the  resistance
to wind erosion provided by ridges and furrows  or  large  clods  in the
field.  The surface roughness factor, K,  is a function of  the  height and
spacing of the ridges, and varies from 1.0 (no  reduction)  for  a  field with
a smooth surface to a minimum of 0.5 for  a field with the  optimum ratio of
ridge height (h) to ridge spacing (w).
     The relationship between K and h2/w  is shown  in Figure 7-3.   The
value of K to be used in Equation (7-1) should  be  rounded  to the  nearest
0.1 because of the large variations inherent in ridge measurement  data.
In cases where there are extreme variations of  h or w within a field,
determination of the K value should be limited  to either 0.5 for  a ridge
surface or 1.0 for an unridged surface.
     For county or regional areas, K can best be determined as a  function
of crop type, since field preparation techniques are relatively uniform
for a specific crop.  Average K values of common field crops are shown  in
Table 7-3.   When the K (or L1  or V)  factors  are based on crop type,
separate calculations of windblown dust emissions must be made for each
major crop  in the survey area.   This  procedure is explained and
demonstrated later in this presentation.
   •  Climatic Factor,  C.   Research has indicated that the fate of soil
movement by wind varies  directly as  the cube  of  wind velocity and
inversely as the square  of soil  surface moisture.   Surface  moisture is
difficult to measure directly,  but precipitation-evaporation indices can
be used to  approximate the amount of  moisture  in soil  surface particles.
Therefore,  readily available  climatic data can provide  a  quantitative
indicator, of relative  wind erosion potential at  any geographic  location.
     The C  factor has  been calibrated  using the  climatic  conditions at the '
site  of much of the research—Garden  City, Kansas—as  the standard base
(C =  1.00).   At any other geographic  location, the  C factor for use in
Equation (7-1)  can be  calculated  as:
                              C  = 0.345 -V—j                        (7-2)
                                         (PE)
                                 7-9

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             TABLE 7-3.   VALUES  OF  K,  L.  AND V FOR  COMMON  FIE_D  CROPS
Crop
Alfalfa
Barley
Beans
Corn
Cotton
Grain hays
Oats
Peanuts
Potatoes
Rice
Rye
Safflower
Sorghum
Soybeans
Sugar beets
Vegetables
Wheat
K
1.0
0.6
0.5
0.6
0.5
0.8
0.8
0.6
0.8
0.8
0.6
1.0
0.5
0.6
0.6
0.6
0.6
L, ft
1000
2000
1000
2000
2000
2000
2000
1000
1000
1000
2000
2000 •
2000'
2000
1000
500
200C
V, Ib/acre
3000
1100
. 250 •
SCO
250
1250
1250
250
400
1000
1250
• 1500
900
250
100
100
1350
                                     7-11

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where:   W = mean annual wind velocity, in mph, corrected to  a  standard
             height of 30 ft
        PE = Thornthwaite's precipitation-evaporation index
           = 0.83 (sum of 12 monthly ratios of precipitation  to  actual
             evapotranspiration)
     Monthly or seasonal climatic factors can be estimated from
Equation (7-2) by substituting the mean wind velocity of the  period  of
interest for the mean annual wind velocity.  The annual PE value  is  used
for all calculations of C.
     Climatic factors have been computed from Weather Bureau  data for many
locations throughout the country.  Figure 7-4 is a map showing annual
climatic factors for the USA.  C  values for use in Equation (7-1) may be
taken from appropriate maps like  this when preparing regional emission
surveys.  For emission estimates  covering smaller areas, Equation (7-2)
may be used to obtain C.
     Unsheltered Field Width Factor.  L'.  Soil  erosion across a field is
directly related to the unsheltered width along the prevailing wind
direction.  The rate of erosion is zero at the  windward, edge of the  field
and increases approximately proportionately with distance downwind until,
if the field is large enough, a maximum-rate of soil  movement is reached.
     Correlation between the width of a field and its rate of erosion is
also affected by the soil  credibility of its surface:  the more erodible
the surface, the shorter the distance in which  maximum soil  movement is
reached.  This relationship between the unsheltered width of a field (L),
its surface credibility (IK), and its relative  rate of soil  erosion  (L1)
is shown graphically in Figure 7-5.   If the curves  of Figure 7-5 are used
to obtain the L1  factor for the windblown dust  equation,  values for the
variables I and K must already be known and an  appropriate  value for L
must be determined.
     L is calculated as the distance  across the  field in  the  prevailing
wind direction minus the distance from  the windward edge  of  the field that
is protected from wind erosion by a barrier.  The distance  protected by a
barrier is equal  to  10 times the  height of the barrier, or  10  H.   For
example, a row of 30-ft high trees  along the  windward side of  a field
reduces the effective width of the  field by 10 x  30 or 300 ft.  If the
                                 7-12

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I NOTE:  ISOPI.ETHS FOR SEVERAL WESTERN AND NORTH EASTERN STATES WERE NOT AVAILABLE AT THE TIME THIS FIGURE WAS PREPARED.  FACIOk,
(OR THESE  AREAS CAN BE CALCULATED FROM EQUATION 7-2.
  ANNUAL CLIMATIC FACTOR  C
  ORIGINAL DRAWING 4-17-68,  D. V. ARMBRUST.
  ARK., IA.,  KY., LA., TENN., W. VA.  ADDED
  11-24-71, N.  P. WOODRUFF.
                              Figure 7-4.   Climatic  factor used  in wind erosion equation.

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                                                                    OJ
                                                                   +->
                                                                    
                                                                   T3

                                                                   "oJ
                                                                   O)
                                                                  LT)
                                                                   OJ
7-14

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prevailing wind direction differs significantly (more than 25 degrees)
from perpendicularity with the field, L should be increased to  account  for
this additional distance of exposure to the wind.  The distance across  the
field, L is equal to the field width divided by the cosine of the  angle
between the prevailing wind direction and the perpendicularity  to  the
field:
     For multiple fields or regional surveys, measurement and calculation
of L values become unwieldy.  In region-wide emission estimates, average
field widths should be used.  Field width is generally a function of the
crop being grown, topography of the area, and the amount of trees and
other natural vegetation in or adjacent to the farming areas that would
shelter fields from erosive winds.  Since the windblown dust calculations
are already split into individual crop type to accurately consider
variations in K by crop, average L values have also been developed by
crop; they are presented in Table 7-3.  These values are representative of
field sizes in relatively flat terrain devoid of tall natural  vegetation,
such as found in laege areas of the Great Plains.  The L values in
Table 7-3 should be divided by 2 in areas with moderately uneven terrain
and by 3 in hilly areas.  Additionally, the average field width factors
should be divided by 2 to account for wooded areas and fence thickets
interspersed with farmland.
     Vegetative Cover Factor, V.  Vegetative cover on agricultural  fields
during periods other than the primary crop season greatly reduces wind
erosion of the soil.  This "cover most commonly is crop residue,  either
standing stubble or mulched into the soil.  The effect of various amounts
of residue, V, in reducing erosion is shown quantitatively in  Figure 7-6,
where IKCL1 is the potential annual  soil  loss (in tons/acre/yr)  from a
bare field, and V  is the fractional amount of this potential  loss  which
results when the field has a vegetative cover of V, in Ib of air-dried
residue/acre.  Obviously, the other four variables in Equation (7-1) — I,
K, C, and L'—must be known before V  can be determined  from Figure  7-6.
                                 7-15

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I
(—•
cr>
                             Figure 7-6.  Effect of vegetative  cover  on  relative emission rate.

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     The amount of vegetative cover on a single field can be ascertainec
by collecting and'weighing clean residue from a representative plot or by
visual comparison with calibrated photographs.  The weight obtained by
either measuring method must then be converted to an equivalent weight of
flat small-grain stubble before entering Figure 7-6, since different crop
residues vary in their ability to reduce wind erosion.  Detailed
descriptions of the measuring methods or conversion procedures are too
complex for this presentation.  Interested readers are referred to the
USDA for these descriptions.
     The residue left on a field when using good soil conservation
practices is closely related to the type of crop.  Table 7-3 presents
representative values of V for common field crops-when stubble or mulch is
left after the crop.  These values should be used in calculating windblown
dust emissions unless a knowledge of local farming practices indicates
that some increase or decrease is warranted.  Note that three of the five
variables in the windblown dust equation are determined as functions of
the crop grown on the field.
     7.1.2.1.3  Summary.  The estimated emissions in. tons/acre/yr may now
be calculated for each field or group of fields as the product of the five
variables times the constant "a".estimated to be 0.025, and the particle
size multiplier for PM10 estimated to be 0.5.
     For regional emission estimates, the acreage in agriculture should be
determined for each jurisdiction (e.g., county) by crop.  "I" and "C"
values can be determined for individual jurisdiction, with the remaining
three variables being quantified as functions of crop type.  The emission
calculations are best performed in a tabular format such as the one shown
in Table 7-4.  The calculated emissions from each crop are summed to get
agricultural wind erosion emissions by jurisdiction and these are totaled
to get emissions for this source category for the entire region.
     7.1.2.1.4  Appropriate Usage of Results.  Inherent variabilities in
the many parameters used in the windblown dust equation cause the results
to be less accurate than emission estimates for most other sources.
However, the rough estimates provided by the proposed procedure are better
than not considering this source at all in particulate emission inventory
                                  7-17

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                      TABLE 7-4.  CALCULATION SHEET FOR ESTIMATION OF DUST FROM WIND EROSION
Juris-     I,          C,                          K,        L,      V,     L1,     V,     E,  =  Total
diction    Based on    Climatic                   Surface   Field   Veget. Length  Veget.  alKC-  Kmins lout
(County)   Soil Type   Factor    Crop    Acres	Roughness Length  Cover  Factor  Factor  I.' V'   By Cro[i

                                Alfalfa
                                Barley
                                Beans
                                Corn
                                Cotton
                                Potatoes
                                Sorghum
                                Soybeans
                                Sugar
                                 Beets
                                Vegets.
                                Wheat
	.	Etc.	
	Total.  	"__""."'"

                               (List of
                                Crops
                                Grown in
                                Juris-
                                diction)
                                                                                          Total

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work.  Inclusion of this source category, possibly with some qualifying

statement as to its relative accuracy, gives an indication of  its

contribution to regional air quality.

     The estimation procedure is not intended for use in predicting

emissions for short time periods, nor can it be used in determining

emission rates for enforcement purposes.
     7.1.2.2  New Wind Erosion Prediction Technology.  New technology for

prediction of agricultural wind erosion is currently being developed by

the U.S. Department of Agriculture.  This undertaking was recently

described by L. J. Hagen as follows.3

      Currently, the U.S. Department of Agriculture is taking a
      leading role in combining erosion science with data bases and
      computers to develop what should be a significant advancement
      in wind erosion prediction technology.  In 1986 an initial
      group composed of Agricultural Research Service (ARS) and Soil
      Conservation Service (SCS) scientists was formed to begin
      development of a new Wind Erosion Prediction System (WEPS).
      Additional scientists are now being added to the group to
      strengthen specific research and technology development
      areas.  The objective of the project is to develop replacement
      technology for the Wind Erosion Equation.

           The primafy user of wind erosion prediction technology is
      the USDA Soil Conservation Service, which has several major
      applications.  First, as a part of the periodic National
      Resource Inventory, it collects data at 300,000 primary
      sampling points, and at central locations, calculates the
      erosion losses occurring under current land  use practices.
      The analyzed results are used to aid in developing regional
      and national policy.

           Second, SCS does conservation planning  of wind  erosion
      control practices to assist farmers and ranchers  in  meeting
      erosion tolerances.  Implementation of adequate conservation
      plans preserves land productivity and  reduces both  onsite and
      offsite damages.  Conservation planning requires  a  prediction
      system that will operate on a personal  computer and  produce
      answers in a relatively short time.   In addition,  WEPS  must
      serve as a communication tool  between  conservation  planners
      and those who implement the plans.

           Various users also undertake project planning  in which
      erosion prediction is used to evaluate  erosion  and deposition
      in areas impacted by the project.   In  this application, more
      time and resources may be  expended  than in conservation
      planning to collect input  data and  make analyses.  Project
                                 7-19

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      planning Is typically carried out by multidisciplinary teams
      including field personnel  who collect needed input data.

           Other users of wind erosion prediction technology
      represent a wide range of problem areas.   Often their problems
      will require development of additional models to supplement
      WEPS in order to obtain answers of interest.  Some of these
      diverse problem areas include evaluating  new erosion control
      techniques, estimating long-term soil productivity changes,
      calculating onsite and offsite economic costs of erosion,
      finding deposition loading of lakes and streams, computing the
      effects of dust on acid rain processes, determining impact of
      management strategies on public lands, and estimating
      visibility reductions near airports and highways.

           From the preceding survey of user needs, it is apparent
      that the prediction technology must deal  with a wide range of
      soil types and management  factors.  Wind  erosion prediction
      technology also must caver a broad range  of climatic and
      geographic regions in the  United States.   The major impact of
      wind erosion is in the Great Plains, but  erodible  areas in the
      Great Lakes region, the semiarid western  United States, and
      windy coastal regions are  all  affected.

7.2  DEMONSTRATED CONTROL TECHNIQUES

7.2.1  Tilling

     Operational modifications to tilling of the soil  include the use of

novel implements or the alteration of cultural  techniques to eliminate

some operations altogether.  All  operational  modifications  will  affect

soil preparation or seed planting operations.  Furthermore,  the  suggested

operational modifications are crop specific.  Estimated  PM10  efficiencies

for agricultural controls are presented  in Table 7-5.

     The punch planter is a novel  implement which  might  have  applications

for emissions reduction from planting cotton, corn,  and  lettuce.   The
punch planter is already being used  in sugar beet  production.  The punch

planter punches a hole and places  the seed  into  it,  as opposed to

conventional  planters which make  a trough  and drop  the seeds  in  at a

specified spacing.   The advantage  is  that  punch  planters  can  leave much of

the surface soil  and surface crop  residues  undisturbed.   Large-scale use

of the punch  planters would require  initial  capital  investments  by the
farming industry for new equipment.
                                 7-20

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                     TABLE 7-5.   ESTIMATED PM-10 EFFICIENCIES  FOR  AGRICULTURAL CONTROLS3
Control technique
Punch planter
Herbicides
Sprinkler irrigation
Laser-directed land
pi ane
Develop high qual ity
alfalfa
Double crop corn
with wheat
Aerial seeding
Estimated control
Operation
affected Cotton .• Barley
Planting 50
Cultivation or 100 25a
soi 1 preparation
Land planing 90 90
Land planing 30 30
or floating
All soil preparation
operations
Disking or plowing
Planting
ef f iciency
Alfalfa

25a
90
30
75

50
(percent) by crop
Rice Corn
50
b 100
c 90
30 30

50d
3
for applicable techniques
Process
Wheat tomatoes

25a 100
90 90
30 30


50
Lettuce
50
100
90
30



^Eliminates only some soil  preparation operations, whereas in other cases, all cultivation operations are eliminated.
 Herbicides already applied by airplane for majority of acreage.
^Flood irrigation necessary.
 Fifty percent control  only for double-cropped  acreage.
eSeeding  already performed  by airplane for majority of acreage.

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     Herbicides for weed control is a cultural practice which could  reduce
emissions from cultivation for most new crops with wide enough spacing  for
cultivation and for some close-grown crops like wheat.  Much of the
preplant tillage of wheat soil is for weed control.  The use of
herbicides, however, must be balanced against potential increased
herbicide emissions caused by wind and by water runoffs.
     Sprinkler irrigation is an existing cultural  technique which could
produce fugitive emission control for any crop which is currently
irrigated by surface watering systems.  Sprinkler  irrigation eliminates
the need for extensive land planing operations which surface irrigation
requires.  However, the capital investment for sprinkler irrigation
equipment and the increased costs of pumping the water are major
deterrents.
     The laser-directed land plane is a novel implement which might yield
some emissions controls for surface-irrigated crops.  Laser-guided grading
equipment has been used in construction for years  and can be expected to
reduce the amount of land planing required due to  its more precise
leveling blade.  This device might be retrofitted  to existing land planes,
but capital investment funds are required.
     The development of long lasting varieties of  alfalfa with high leaf
protein content would help to reduce emissions,  because present practices
require replanting every 3 to 5 yr.   New varieties already exist which can
last up to 20 yr, but the protein content is low.   If longevity and
quality could be combined, the soil  would not have to be prepared  so
often, thus yielding a subsequent reduction in emissions.
     Double-cropping corn with wheat or other grain instead of corn with
corn might reduce fugitive emissions.   Since corn  provides so much
stubble, it must be plowed or disked under.   The beds must then be formed
and shaped for the next corn seed planting.  . If wheat or another grain
were grown on a bedded field,  then corn could be planted on the  beds after
the wheat harvest and stubble  removal.   The  beds would  require  only
reshaping.  This would eliminate a plowing or disking operation  and a bed-
forming operation while adding a less  dusty  wheat  stubble  removal
operation.
                                 7-22

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     Finally, aerial seeding, which  is already  used  in  rice  production,
would probably reduce emissions somewhat from alfalfa and  wheat
production.  However, at least in the case of wheat, the aerially  applied
seed must be covered.  This covering operation  will  produce  dust,  but  it
may be less dust than a ground planting operation would produce.
7.2.2  Wind Erosion
     Agricultural wind erosion control is accomplished  by  stabilizing
credible soil particles.  The stabilization process  is  accomplished  in
three major successive stages:  (a) trapping of moving  soil  particles,
(b) consolidation and aggregation of trapped soil particles, and
(c) revegetation of the surface.3
     The trapping of eroding soil is termed "stilling"  of  erosion.   This
may be effected by roughening the surface, by placing barriers in  the path
of the wind, or by burying the erodible particles during tillage.
Trapping is accomplished naturally by soil crusting resulting from rain
followed by a slow process of revegetation.  It should  be  stressed that
the stilling of erosion is only temporary; to effect a  permanent control,
plant cover must be established or plant residues must  be.maintained.
     In bare soils containing a mixture of erodible and nonerodible
fractions, the quantity of soil eroded by the wind is limited by the
height and number of nonerodible particles that become  exposed on the
surface.  The removal of erodible particles continues until the height of
the nonerodible particles that serve as barriers to the wind is 'increased
to a degree that affords complete shelter to the erodible fractions.   If
the nonerodible barriers are low, such as fine gravel,  a relatively  large
number of pieces are needed for protection of soil  from wind erosion.  The
gravel in such a case would protect the erodible portion more by covering
than by sheltering from the wind.  Thus all  nonerodible  materials on  the
ground that control  erosion have an element of cover in  addition to the
barrier principle which protects the soil.   The  principles  of surface
barriers and cover are, therefore, inseparable.
     The above principles extend to almost all  elements  used in wind
erosion control.  All of these control  methods are  designed to  (a)  take up
some or all of the wind force so that only the residual  force,  if any,  is
taken up by the erodible soil  fractions;  and  (b) trap the eroded  soil,  if
                                 7-23

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any, on the lee side or among surface roughness elements or barriers,
thereby reducing soil avalanching and intensity of erosion.
     In the sections that follow, various control methods are discussed
with respect to their characteristics and effectiveness in controlling
erosion.  Methods include vegetative cover, soil ridges, windbreaks, crop
strips, chemical stabilizers, and irrigation.
7.3  EVALUATION OF ALTERNATIVE CONTROL MEASURES
7.3.1  Tilling
     The estimates of emission control efficiency for each tillage control
technique discussed above are given in Table 7-5.  These estimates are
derived from consideration of the reduced level of soil disturbance
associated with the specified control technique.
     As evidenced by the discussion in Section 7.2, many of the
demonstrated control techniques are capital-intensive.  In other words,
identified cost elements typically include the capital expense to purchase
a new implement.
     O&M costs are assumed to be equal to those with the older equipment
and, as such, need not be considered in assessing cost effectiveness.
     Based on the fact that control of tillage practices.would fall under
soil conservation rather than environmental regulations (as discussed
below), no cost data for control of tillage practices are presented in
this section.
7.3.2  Wind Erosion
     7.3.2.1  Vegetative Cover.  Natural  vegetative cover is the most
effective, easiest, and most economical  way to maintain an effective
control of wind erosion.  In addition.to the crops such as grasses, wheat
sorghum, corn legumes, and cotton, crop  residues are often placed on
fallow fields until a permanent crop is  started.  All  of these methods can
remove 5 to 99 percent of the direct wind force from the soil  surface.1*
     Effectiveness.  Grasses and legumes  are most effective  because they
provide a dense, complete cover.  Wheat  and other small  grains are
effective beyond the crucial 2 or 3 mo after planting.  Corn,  sorghum,  and
cotton are only of intermediate effectiveness because  they are planted in
rows too far apart to protect the soil.
                                 7-24

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      After harvesting, vegetative residue should be anchored to the
 surface.s  Duley found that legume residues decay rapidly, while corn and
 sorghum stalks are durable.6  He found wheat and rye straw more resistant
 to decay than oat straw.
      Maintenance.  Excessive tillage, tillage with improper implements,
 and overgrazing are the major causes of crop cover destruction.  Effective
 land management practices must be instituted if wind erosion is to be
 controlled.
      For grazing, the number of animals per acre should be controlled to
 maximize the use of grass and still  maintain sufficient vegetative
     , N
 cover.
      Stubble mulching and minimum tillage or plow-plant systems of farming
 tend to maintain vegetative residues on the surface when the land is
 fallow.  Stubble mulching is a year-round system in which all  tilling,
 planting, cultivating, and harvesting operations are performed to provide
 protection from erosion.   This practice requires the use of tillage
 implements which undercut the residue without soil  inversion.
      7.3.2.2  Tillage Practices.   The soil  surface  can  be made cloddy and
 rough in order to control  erosion by developing a surface barrier.   Such
 practices include:  '(&) regular tillage processes to prepare seedbeds and
 to control weeds for  crop production; and (b)  emergency tillage practices
 used specifically to  bring clay to the surface for  possible increased
 cloddiness and to roughen the land to prevent wind  erosion.
      Regular tillage.   It is important that  all  tillage operations  be
 conducted sparingly because tillage  leads to soil surface smoothing and
•clod pulverization.   Soil  moisture at time of tillage has an effect on
 cloddiness.  Different soils have differing  moisture contents  at which
 soil pulverization  is  most severe.   More  clods  are  produced  if  the  soil  is
 either  extremely dry  or moist than if it  contains an  intermediate moisture
 content.7
      The type of tillage  implement used, also has  an  influence on soil
 cloddiness and surface roughness.7   A study  conducted with  a moldboard
 plow, a one-way disk,  and  a subsurface sweep in controlled  soil moisture
 conditions demonstrated that cloddiness is more dependent on the type  of
 machinery than soil moisture content.   The moldboard plow produced  a
                                  7-25

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rougher, more cloddy surface with higher mechanical stability of  clods
than the one-way disk or subsurface sweeps.   Tillage implements used  in
stubble mulch farming, with the exception of chisel cultivators,  usually
do not leave a ridged, rough surface.   Subsurface sweeps provide  a smooth
surface and are advantageous insofar as they allow the vegetation to
remain erect.
     It is important that planting and seeding equipment preserve as  much
residue as possible, keep the soil surface rough and cloddy, and also,
place the seed in moist, firm soil to  promote rapid germination.  Major
types of planters available for small  grains include hoes, single and
double disks, deep furrow drills, and  seeding attachments on one-ways and
cultivators.
     Emergency tillage.   Emergency tillage to provide a rough, cloddy
surface is a temporary measure, and its only purpose is to create an
erosion-resistant soil surface in a short period of time.  It is a last
resort measure to be implemented when  vegetative cover is depleted by
excessive grazing, drought, improper or excessive tillage, or by growing
crops that produce little or no residue or when  potentially severe erosive
conditions are expected.
     The most common implements used are listers,  duckfoot cultivators,
and narrow-tooth chisel  cultivators.   The effectiveness of any of the
above in creating cloddiness depends upon soil moisture,  texture,  and
density.  Cloddiness of  soil  is increased markedly by increasing density;
also, the cloddiness potential  of soils with  a high  clay  content is
greater than for sandy soils.   Speed of travel,  depth of  tillage,  spacing
between tillage point carriers,  and  type of  part also influence  the  degree
of cloddiness.  Speeds of 5.6  to 6.4 km/h (3.5 to  4.0 mph)  provide the
optimum degree of cloddiness.
     As for depth, 7.6 to 15.2  cm (3 to 6 in) brings  up compact  clods.
Spacing of lister and chisel must  be governed by  severity of  erosion  and
the presence or absence  of crops.  Close  spacing creates  a  rougher
surface.  However, if a  crop  is  involved  and there  is  a possibility of
saving part of it, then  wide spacings of  122 to  137 cm  (48  to  54  in)
should be used to both provide  roughness  for control  and  permit  the crop
to grow.
                                 7-26

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     Listers and narrow chisels are most: effective  types of  tillage
points.  Listers produce a high degree of  roughness  and are  especially
effective in sandy soils where clods can be produced by deep  tillage.
Chisel cultivators require less power and  destroy less crop  than  do
listers.
     7.3.2.3  Windbreaks and Wind Barriers.  Windbreaks consist of trees
or shrubs in 1 to 10 rows, crops in narrow rows, snow fences, solid wooden
or rock walls, and earthen banks.  Windbreaks function as surface barriers
to control wind erosion; i.e., they take up or deflect a sufficient amount
of the wind force to lower the wind velocities to the leeward below the
threshold required to initiate soil movement.  The effectiveness of any
barrier depends on the wind velocity and direction, shape, width, height,
and porosity of the barrier.
     Nearly all barriers provide maximum reduction in wind velocity at
leeward locations near the barrier, gradually decreasing downwind.
Percentage reductions in wind velocities for rigid barriers remain
constant no matter what the wind velocity.5
     Direction of wind influences the size and location of the protected
areas.  Area of protection is greatest for perpendicular winds to the
barrier length and least for parallel winds.
     The shape of the windbreak indicates  that a vertically abrupt barrier
will provide large reductions in velocity  for relatively short leeward
distances, whereas porous barriers provide smaller reductions in velocity
but for more extended distances.
     Height of the barrier is, perhaps, the most important  factor
influencing effectiveness.  Expressed in multiples of barrier height,  the
zone of wind velocity reduction on the leeward side may extend to 40  to
50 times the height of the barrier; however,  such reductions  at  those
distances are insignificant for wind erosion  control.  If  complete control
is desired, then barriers must be placed at close intervals.
     One-, two-, three, and five-row barriers of trees  are  found to  be the
most effective arrangement for planting to control  wind  erosion.   The  type
of tree species planted also has a considerable  influence on  the
effectiveness of a windbreak.   The rate of growth governs the extent of
protection that can be realized in later years.
                                 7-27

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     7.3.2.4  Strip-Cropping.   The practice of strip-cropping consists  of
dividing a field into alternate strips of erosion-resistant crops and
erosion-susceptible crops or fallow.   Erosion-resistant crops are the
small grains and other crops that cover the ground rapidly.  Erosion-
susceptible crops are cotton,  tobacco, sugar beets, peas, beans, potatoes,
peanuts, asparagus, and most truck crops.
     Strip-cropping controls erosion  by reducing soil  avalanching, which
increases with width of eroding field..  Since avalanching depends on field
credibility, the appropriate width of strips required  varies with factors
that influence erodibility,  such as soil  texture,  wind velocity and
direction, quantity of crop  residue,  and  degree  of soil cloddiness and
surface roughness.
     Available data indicate that directional  deviation of erosive winds
from the perpendicular requires narrower  strips,  and that required width
of the strip increases as soil  texture becomes finer,  except for clays and
silty clays subject to granulation.
     Strip-cropping alone will  not fully control wind  erosion;  it must be
used in conjunction with other  measures,  such  as  stubble mulching,  to be
fully effective.  In combination with strip-cropping,  the supplementary
practices need not  be as intensive as they would have  to be for large
fields.
     Row crop spacing.  The  relative  effectiveness  of  different row
spacings for wind erosion control  has not been fully evaluated.   In
theory, the closer  the row spacing, the more effective is  the protection
afforded against erosion.  Most closely spaced crops are erosion resistant
once they are established.   Sorghum,  corn, cotton,  and other crops
normally planted in rows 102 to 107 cm (40 to  42 in) apart  are  not  as
resistant.  Experiments  have shown  that some of these  crops  can  be  grown
in more closely spaced rows  without being detrimental  to crop yield.
     Orientation of crop rows to  the  prevailing erosive  winds has an
effect on erosion.   The  relative  amount of erosion  from  soil planted  to
wheat in rows 25.4  cm (10  in) apart is 6 times greater when  the  wind  is
blowing parallel  to rows than when  it  blows perpendicular to the rows.3
     7.3.2.5  Limited Irrigation  of Fallow Field.   The periodic  irrigation
of a barren field controls blowing  soil by adding moisture which
                                 7-28

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consolidates soil particles and creates a crust upon  the  soil  surface when
drying occurs.a  The amount of water and frequency  of each  irrigation
during fallow to maintain a desired level of control  would  be  a  function
of the season and of the crusting ability of the soil.  The drawback  to
irrigation control concerns the availability of water, cost of water, and
interference with farming activities on the cropland.9
7.4  POSSIBLE REGULATORY FORMATS
     The Food Security Act (FSA) contains two provisions which may
significantly reduce dust emissions from agricultural tilling.   The first
provision requires a conservation plan on all land which is designated as
"highly erodible" for either wind or water erosion.   Plans must  be filed
by 1990 and implemented by 1995 in order for the land owner to be eligible
for government (USDA) program benefits such as insurance and subsidies.
The second provision is the 45-mi11 ion-acre Conservation Reserve Program
(CRP), a procedure for taking highly erodible cropland out of production
and establishing a vegetative cover upon it.
     The EPA is beginning to work with the U.S. Department of Agriculture
(USDA) to explore ways in which reduction of PM10 in populated areas  can
be accomplished in part by the provisions of the FSA.  The following
information relative to rural  fugitive dust-has been obtained:
     1.  Many farms with highly erodible land (HEL) are already practicing
wind erosion control but almost all  HEL will need to make  changes to
comply with the FSA.
     2.  The air in cities (and smaller towns)  surrounded  by agricultural
land should be cleaner because of both the CRP  and  HEL controls required
by the FSA.
     3.  Towns and cities do care about reducing the impact  of dust
storms.  There is perhaps less concern in  the small, agriculturally
oriented towns.
     4.  The CRP could provide substantial  additional  reductions  in PM10
in populated areas if more of  the farmland  near cities were  incorporated
into the CRP (buffer zone).   This buffer could  be accomplished  through
zoning or by increasing the  acceptable bid  in the buffer area.  The legal
aspects of such  approaches are being  investigated.
                                 7-29

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REFERENCES TO SECTION 7

 1.  Woodruff, N.  P., and F.  H.  Siddoway.   1965.   A Wind Erosion
     Equation.  Soil  Sci. Soc. Amer.  Proc,  29(5),  602-608.

 2.  Skidmore, E.  L., and N.  P.  Woodruff.   1968.   Wind Erosion Forces  in
     the United States and Their Use  in Predicting Soil Loss.  USDA, ARS,
     Agriculture Handbook No. 346.  42 pp.

 3.  Hagen, L. J.   1988.   New Wind  Erosion  Model Developments in the
     USDA.  In Proceedings of the 1988 Wind Erosion Conference, Texas  Tech
     University, Lubbock, Texas.  April  11-13,  1988.

 4.  Cuscino, T. H. Jr.,  J. S. Kinsey and R.  Hackney.   1981.  The Role of
     Agricultural  Practices in Fugitive Dust  Emissions.  Final Report
     prepared by Midwest  Research Institute for the California Air
     Resources Board, Sacramento, California.

 5.  Chepil, N. S., and N. P. Woodruff.  1963.  The Physics of Wind
     Erosion and Its  Control.  In Advances  in Agronomy, Vol. 15,
     A. G. Norman,  Ed., Academic  Press,  New York,  New  York.

 6.  Zingg, A. W.   1954.   The Wind  Erosion  Problem in  the  Great Plains.
     Trans Geophysics Union,  35,  252-258.

 7.  Chepil, N. S., N.  P. Woodruff, F.  H. Siddoway,  and L.  Lyles.   1960.
     Anchoring Vegetative Mulches.  Agricultural Engineering, 41,
     754-755.

 8.  Duley, F. L.   1958.   U.S. Department of Agriculture Agronomy
     Handbook, 136, 1-31.

 9.  Lyles, L., and N.  P. Woodruff.   1962.  How Moisture and Tillage
     Affect Soil Cloddiness for Wind  Erosion Control.   Agricultural
     Engineering, 43,  150-153, 159.

10.  Guideline for Development of Control Strategies in Areas With
     Fugitive Dust Problems.  1977.   OAQPS  No.  1.2-071.  U.S.
     Environmental Protection Agency,  Research Triangle Park,  North
     Carolina.  October 1977.

11.  Jutze, G., and K.  Axetell.    1974.   Investigation of Fugitive Dust,
     Volume I—Sources, Emissions, and Control.   EPA-450/3-74-036a.   U.S.
     Environmental Protection Agency,   Research Triangle Park,  North
     Carolina.  June  1974.
                                7-30

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                    APPENDIX A.

OPEN DUST SOURCE EMISSION FACTOR RATING AND CONTROL
              EFFICIENCY TERMINOLOGY

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     APPENDIX A.  OPEN DUST SOURCE  EMISSION  FACTOR  RATING AND CONTROL
                          EFFICIENCY TERMINOLOGY

A.I  EMISSION FACTOR RATING TERMINOLOGY
     In AP-42, the reliability of emission factors  is indicated  by  an
overall Emission Factor Rating ranging from A (excellent)  to  E  (poor).
These ratings take into account the type and amount of data from which  the
factors were calculated.   Note that measurements underlying each emission
factor are rated on a similar scale of A to D.
     The use of a statistical  confidence interval may seem desirable  as a
more quantitative measure of the reliability of an emission factor.
Because of the way an emission factor data base is generated, however,
prudent application of statistical procedures precludes the use  of
confidence intervals unless the following conditions are met:
     •  The sample of sources  from which the emission factor was
        determined' is representative of the total population of  such
        sources.
     •  The data collected at  an individual source are representative of
        that source (i.e., no  temporal  variability resulting from source
        operating conditions could have biased the data).
     •  The method of measurement was properly applied at each source
        tested.
Because of the almost impossible task of assigning a meaningful confidence
limit to the above variables and to other industry-specific variables, the
use of a statistical  confidence interval  for an  emission factor is not
practical.
     The following emission  factor ratings  are applied to the emission
factors:
     A - Excellent.   Developed only from A-rated test data taken from many
     randomly chosen  facilities in the  industry  population.  The source
     category is specific enough to minimize variability within the  source
     category population.
     B - Above average.   Developed only from A-rated test data from  a
     reasonable  number of facilities.   Although  no  specific bias is
     evident, it is  not clear  if the facilities  tested represent a random
                                 A-l

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     sample of the industry.   As in the A-rating, the source category  is
     specific enough to minimize variability within the source category
     population.
     C - Average.  Developed  only from A- and B-rated data from a
     reasonable number of facilities.   Although no specific bias is
     evident, it is not clear if the facilities tested represent a random
     sample of the industry.   As in the A rating, the source category  is
     specific enough to minimize variability within the source category
     population.
     D - Below average.  The  emission  factor was developed only from A-
     and B-rated test data from a small number of facilities, and there
     may be reason to suspect that these facilities do not represent a
     random sample of the industry.  There also may .be evidence of
     variability within the source category population.   Limitations on
     the use of the emission  factor are footnoted in the emission factor
     table.
     E - Poor.  The emission  factor was developed from C- and D-rated test
     data, and there may be reason to  suspect that the facilities tested
     do not represent a random sample  of the industry.   There may be
     evidence of variability  within  the source category  population.
     Limitations on the use of these factors are always  footnoted.
Because the application of these factors is somwhat subjective,  the
reasons for each rating are documented in the background files  maintained
by the Office of Air Quality  Procedures and Standards  (OAQPS).
A.2  CONTROL EFFICIENCY TERMINOLOGY
     Some control techniques  often used for open dust  sources begin  to
decay in efficiency almost immediately after implementation.   The most
extreme example of this is the watering of  unpaved  roads where  the
efficiency decays from nearly 100  percent to 0  in  a matter  of hours  (or
minutes). The control  efficiency for broom  sweeping  and  flushing  applied
in combination on a paved  road  may decay to  zero  in  1 or 2  days.  Chemical
dust suppressants applied  to  unpaved roads  can yield control  efficiencies
that will decay to zero in several months.   Consequently, a single-valued
control efficiency is  usually  not  adequate  to describe the  performance  of
most intermittent control  techniques for open dust  sources.   The  control
                                 A-2

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efficiency must be reported along with  a  time  period  over which  the  value
applies.  For continuous control systems  (e.g., wet suppression  for
materials transfer), a single control efficiency  is usually  appropriate.
     Certain terminology has been developed to aid in describing  the time
dependence of open dust control efficiency.  These terms are:
     1.  Control lifetime is the time period (or  amount of source
activity) required for the efficiency of  an open  dust control measure to
decay to zero.
     2.  Instantaneous control efficiency is the  efficiency  of an open
dust control at a specific point in time.
     3.  Average control efficiency is  the efficiency of an  open  dust
source control averaged over a given period of time (or number of vehicle
passes).
     From the above definitions, it is  clear that average control
efficiency is related to instantaneous  control  efficiency by the  following
general equation:
C(X) =
                                       C(x)dx
where:  x = tJme (or number of vehicle passes) after application
        X = time (or number of vehicle passes) over which an average
            efficiency is desired
        c = instantaneous control efficiency
        C = average control efficiency
Field tests of certain paved and unpaved road dust controls indicate that
instantaneous control efficiency may be adequately represented as a linear
function of time (or vehicle passes):

                                c(x)  =  a-bx

where a and b are constants, and b>0.  In that case, average control
efficiency is given by

                             c(X) = a 5x
                                  A-3

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                   APPENDIX B.





ESTIMATION OF CONTROL COSTS AND COST EFFECTIVENESS

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                                APPENDIX B.
            ESTIMATION OF CONTROL COSTS AND COST EFFECTIVENESS

     Development and evaluation of particulate fugitive emissions control
strategies require analyses of the relative costs of alternative control
measures.  Cost analyses are used by control agency personnel to develop
overall strategies for an air pollution control district or to evaluate
plant specific control strategies.  Industry personnel perform cost
analyses to evaluate control alternatives for a specific source or to
develop a plant-wide emissions control strategy.  Although the- specifics
of these analyses may vary depending upon the objective of the analysis
and the availability of cost data, the general format is similar.
     The primary goal of any cost analysis is to provide a consistent
comparison of the real costs of alternative control measures.  The
objective of this section is to provide the reader with .a methodology that
will allow such a comparison.  It will describe the overall structure of a
cost analysis and provide the resources for conducting the analyses.
Because cost data are continuously changing, specific cost data are not
provided.  However, sources of cost information and mechanisms for cost
updating are provided.
     The approach outlined in this section will focus on cost effectiveness
•as the primary comparison tool.  Cost effectiveness is simply the ratio of
the annualized cost of the emissions control to the amount of emissions
reduction achieved.  Mathematically, cost effectiveness is defined by:


                                 C* • XR                              ^
                                  3-1

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where:  C* = cost effectiveness,  S/mass of  emissions reduction
        Ca = annualized cost  of  the control  measure, S/year
        AR = reduction (mass/year)  in annual  emissions
This general methodology was  chosen because it  is equally applicable to
different controls that achieve  equivalent  emissions reduction on a single
source and to measures that achieve varied  reductions over multiple
sources.
     The discussion is divided into three sections.   The first section
describes the general  cost analysis methodology,  including the various
types of costs that should be considered and presents methods for
calculating those costs.  The second identifies the  primary cost elements
associated with each of the fugitive emissions  control systems.  The final
section identifies sources of cost data and discusses methods for updating
cost data to constant dollars, and includes example  calculation cases for
estimating costs and cost effectiveness.
B.I  GENERAL COST METHODOLOGY
     Calculation of cost effectiveness for comparison of control measures
or control strategies can be accomplished in four steps.  First, the
alternative control/cost scenarios are selected.   Second, the capital
costs of each scenario is.calculated.  Third, the annualized costs for
each of the alternatives is developed.  Finally,  the cost effectiveness  is
calculated, taking into consideration the level of emissions reduction.
     The general approach for performing each of  the above steps is
described below.  This approach  is intended to  provide general guidance
for cost comparison.  It should  not be viewed as  a rigid procedure that
must be followed in detail for all analyses.  The reader may choose or may
be forced through resource or informational constraints to omit some
elements of the analysis.  However, for comparisons  to be valid, cautions
that should be observed are:   (1) all control scenarios should be treated
in the  same manner; and (2) cost elements that  vary  radically between cost
scenarios should not be omitted.
B.I.I   Select Control/Cost Scenarios
     Prior to the cost analysis  general control measures or strategies
will have been identified.  These measures or strategies will fall into
one of  the major classes of fugitive emission control techniques that were
                                  B-2

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identified.  The first step in the cost analysis is to select a set of
specific control/cost scenarios from the general techniques.  The specific
scenarios will include definition of the major cost elements and identifi-
cation of specific implementation alternatives for each of the cost
elements.
     Each of the general  control techniques identified in Chapter 4 has
several major cost elements.  These elements include capital equipment
elements and operation/maintenance elements.  For example, the major cost
elements for chemical stabilization of an unpaved road include:
(a) chemical acquisition; (b) chemical storage; (c) road preparation;
(d) mixing the chemical with water; and (e) application of the chemical
solution.  The first step in any cost analysis is definition of these
major cost elements.  Information is provided in Section B.2 on the major
cost elements associated with each of the general techniques.
     For each major cost element, several implementation alternatives can
be chosen.  Options within each cost element include such choices as
buying or renting equipment; shipping chemicals by railcar, truck tanker,
or in drums via truck; alternative sources of power or other utilities;
and use of plant personnel or contractors for construction and main-
tenance.  The major cost elements and the implementation alternatives for
each of these elements for the chemical stabilization example described.
above are outlined in Table B-l.
B.I.2  Develop Capital Costs
     The capital costs of a fugitive emissions control system are those
direct and indirect expenses incurred up to the date when the control
system is placed in operation.  These capital costs include actual
purchase expenses for capital equipment, labor and utility costs
associated with installation of the control system, and system startup and
shakedown costs.  In general, direct capital costs are the costs of
control equipment and the labor, material, and utilities needed to install
the equipment.  Indirect costs are overall costs to the facility incurred
by the system but not directly attributable to specific equipment items.
     Direct costs cover the purchase of equipment and auxiliaries and the
costs of installation.  These costs include system instrumentation and
interconnection of the system.  Capital costs also include any cost of
                                  B-3

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site development necessitated  by  the  control  system.   For  example,  if a
fabric filter on a capture/collection system  requires  an access road for
removal  of the collected  dust,  this access  road  is  included  as  a capital
expense.  The types of  direct  costs typically associated with  fugitive
emissions control  systems include:
     •  Equipment  costs            •   Painting
     •  Equipment  installation     •   Insulation
        Instrumentation            •   Structural  support
     •  Duct work                   •   Foundations
     •  Piping                     •   Supporting  administrative structures
     •  Electrical                 •   Control panels
     •  Site development            •   Access  roads  or  walkways
     •  Buildings
     Indirect costs cover the  expenses not  attributable  to specific
equipment items.  Items in this category  are  described below^:
     1.   Engineering costs—includes  administrative, process,  project, and
general; design and related functions for specifications;  bid  analysis;
special  studies; cost analysis; accounting; reports; purchasing; procure-
ment; travel expenses;  living  expenses; expediting;  inspection; safety;
communications; modeling; pilot plant studies;  royalty payments during
construction; training  of plant personnel;  field  engineering;  safety
engineering; and consultant services.
     2.   Construction and field expenses—includes  costs for temporary
field offices; warehouses; craft sheds; fabrication shops; miscellaneous
buildings; temporary utilities; temporary sanitary  facilities;  temporary
roads; fences; parking  lots; storage  areas; field computer services;
equipment fuel and lubricants; mobilization and demobilization; field
office supplies; telephone and telegraph; time-clock  system; field-
supervision; equipment  rental; small  tools; equipment  repair;  scaffolding;
and freight.
     3.   Contractor's fee—includes costs for field-labor  payroll;
supervision field office; administrative  personnel;  travel expenses;
permits; licenses; taxes; insurance;  field  overhead;  legal liabilities;
and labor relations.
                                  B-4

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     4.  Shakedown/startup—includes costs associated with system startup
and shakedown.
     5.  Contingency costs—the excess account set up to deal with
uncertainties in the cost estimate, including unforeseen escalation in
prices, malfunctions, equipment design alterations, and similar sources.
     The values for these items will vary depending on the specific
operations to be controlled and the types of control systems used.
Typical ranges for indirect costs based on the total installed cost of the
capital equipment are shown in Table B-2.
B.I.3  Determine Annualized Costs
     The most common basis for comparison of alternative control system is
that of annualized cost.  The annualized cost of a fugitive emission
control system includes operating costs such as labor, materials,
utilities, and maintenance items as well as the annualized cost of the
capital equipment.  The annualization of capital costs is a classical
engineering economics problem, the solution of which takes into account
the fact that money has time value.  These annualized costs are dependent
on the interest rate paid on borrowed money or collectable by the plant as
interest (.if available-capital is used), the useful life of the equipment
and depreciation rates of the equipment.
     The components of the annualized cost of implementing a particular
control technique are depicted graphically in Figure B-l.  Purchase and
installation costs include freight, sales tax, and interest on borrowed
money.  The operation and maintenance costs reflect increasing frequency
of repair as the equipment ages along with increased costs due to infla-
tion for parts, energy, and labor.  On the other hand, costs recovered by
claiming tax credits or deductions are considered as income.  Mathe-
matically the annualized costs of control equipment can be calculated
from:
                       Ca = CRF (Cp) + CQ + 0.5 CQ                    (B-2)
where:   Ca = annualized costs of control equipment, $/year
        CRF = Capital Recovery Factor, I/year
         Cp = installed capital costs, $
         CQ = direct operating costs, $/year
                                  B-5

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        0.5 = plant  overheac  factor
The various components  of  this equation  are  briefly  described  below.
     The annualized  cost of capital  equipment  is  calculated  by using  a
capital  recovery factor (CRF).   The  capital  recovery factor  combines
interest on borrowed funds and depreciation  into  a single  factor.   It is a
function of the interest rate and  the  overall  life of the  capital
equipment and can be estimated by  the  following equation:

                          CFR = l(1"'n                             (B-3)
where:  i  = interest rate,  annual  percent  as  a  fraction)
        n  = economic life of  the  control system (year)
The other  major components  of the  annualized  cost  are  operation and
maintenance costs (direct operating  costs)  and  associated  plant overhead
costs.  Operation and maintenance  costs  generally  include  labor, raw
materials, utilities, and. by-product costs  or credits  associated with day-
to-day operation of the control  system.  Elements  typically included in
this category, are: 1
     1.  Utilities—includes  water for process  use and  cooling; steam;
electricity to operate controls,  fans, motors,  pumps,  valves,  and
lighting;  and fuel, if required.
     2.  Raw materials — includes  any chemicals  needed  to  operate the
system.
     3.  Operating labor — includes supervision  and the  skilled and
unskilled  labor needed to operate, monitor,  and control  the system.
     4.  Maintenance and repairs — includes  the  manpower and materials to
keep the system operating efficiently.   The function of maintenance is
both preventive and corrective,  to keep  down-time  to a  minimum.
     5.  By-product costs— in systems producing a  salable  product, this
would be a credit for that product;  in systems  producing  a product for
disposal,  this would be the cost  of  disposal.
     6.  Fuel costs — includes the  incremental cost of  the  fuel, where more
than the normal supply is used.
                                  B-6

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     Another component of the operating cost is overhead, which is a
business expense not charged directly to a particular part of the process
but allocated to it.  Overhead costs include administrative, safety,
engineering, legal,  and medical  services; payroll, employee benefits;
recreation; and public relations.   As suggested by Eq. B-2, these charges
are estimated to be  approximately  50 percent of direct operating costs.
B.I.4  Calculate Cost Effectiveness
     As discussed in the introduction to this section the most informative
method for comparing control measures or control strategies for particulate
fugitive emissions sources is on a cost-effectiveness basis.  Mathemati-
cally, cost effectiveness is defined as:


                                  c* = s                            
where:  C* = cost effectiveness, $/mass of emissions reduced
        Ca = annualized cost of control equipment, $/year
        AR = annual  reduction in particulate emissions, mass/year
     The annualized  cost of control equipment can be calculated using
Equation B-2.  The annual reduction in particulate emissions can be
calculated from the  following equation:                       •         .
                                AR = M e c                           (B-4)
where:  M = annual source extent
        e = uncontrolled emission  factor (i.e., mass of uncontrolled
            emissions per unit of  source extent)
        c = average  control efficiency expressed as a fraction
     The methodology for calculating annualized costs and sources of data
on costs of fugitive emissions control systems are contained- in this
section.
B.2  COST ELEMENTS OF FUGITIVE EMISSIONS CONTROL SYSTEMS
     The cost methodology outlined in Section B.I requires that the analyst
define and select alternative control/cost scenarios and develop costs for
the major cost elements within these scenarios.  The objective of this
subsection is to assist the reader in identifying the implementation
alternatives and major cost elements associated with the emission reduction
                                  B-7

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techniques.   For open  dust  sources,  the  control  techniques addressed are:
wet dust suppression;  surface  cleaning;  and  paving.
     Implementation alternatives  for open  dust  source  emission control
measures are presented in Tables  B-3 through B-5.   Table 8-3 presents
implementation alternatives for water and  chemical  dust suppressant
systems.  Table B-4 presents alternatives  for three types of street
cleaning systems—sweeping, flushing, and  a  combination of flushing and
broom sweeping.  Table B-5  presents  alternatives for streets or parking  lot
paving.
     After the control scenarios  are selected,  the  analyst must estimate
the capital  cost of the installed system and the operating and maintenance
costs.  The indirect capital costs elements  are common to all systems and
were identified in Table 8-2.  The direct  capital cost elements and direct
operation and.maintenance cost elements  which are unique to each type of
fugitive emission control system  are identified in  Tables 8-6 through
8-11.  These costs are provided  for  dust suppressant programs for open dust
sources in Table 8-6,  street cleaning programs  in Table 8-7, paving in
Table 8-8, and wet suppression systems, for process  sources in Table 8-9.
B.3  SOURCES OF COST DATA         ...
     Collection of the data to conduct a cost analysis can sometimes be
difficult.  If a well  defined  system is  being costed,  the best sources of
accurate capital costs are  vendor estimates.. However, if the system is  not
sufficiently defined to develop  vendor estimates, published cost data can
be used.  Table B-10 presents  sources of cost data  for both paved and
unpaved roads.
     Often published cost estimates  are  based on different time-valued
dollars.  These estimates must be adjusted for  inflation so that they
reflect the most probable capital investments for a current time and can be
consistently compared.  Capital  cost indices are the techniques used for
updating costs.  These indices provide a general method for updating
overall costs without having to  complete in-depth studies of individual
cost elements.  Indices that typically are used for updating control system
costs are the Chemical Engineering Plant Cost Index, the Bureau of Labor
Statistics Metal Fabrication Index,  and  the  Commerce Department Monthly
Labor Review.
                                  B-8

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     Operation and maintenance cost estimates typically are based on vendor
or industry experience with similar systems.  In the absence of such data,
rough estimates can be developed from sources 3 and 6 in Table 3-10.
                                  B-9

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REFERENCE FOR APPENDIX  B

1.  PEDCo Environmental,  Inc.   Cost  Analysis Manual  for  Standards Support
    Document.  U.  S.  Environmental Protection Agency.  November 1978.
                                 B-10

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      TABLE  B-l.   IMPLEMENTATION  ALTERNATIVES FOR STABILIZATION OF AN
                               UPAVED  ROAD

Cost elements/implementation alternatives

  I.  Purchase and Ship Chemical

      A.  Ship in railcar tanker (11,000 to 22,000 gal/tanker)
      B.  Ship in truck tanker (4,000 to 6,000 gal/tanker)
      C.  Ship in drums via truck (55 gal/drum)

 II.  Store Chemical

      A.  Store on plant property
          1.  In new storage tank
          2.  In existing storage tank
              a.  Needs refurbishing
              b.  Needs no refurbishing
          3.  In railcar tanker
              a.  Own railcar
              b.  Pay demurrage
          4.  In truck tanker
              a.  Own truck
              b.  Pay demurrage
          5.  In drums
      B.  Store in contractor tanks

III. . Prepare Road

      A.  Use plant-owned grader to minimize ruts and low spots.
      B.  Rent contractor grader
      C.  Perform no road preparation

 IV.  Mix Chemical and Water in Application Truck

      A.  Put chemical in spray truck
          1.  Pump chemical from storage tank or drums into application
              truck
          1.  Pour chemical from drums into application truck, generally
              using forklift
      B.  Put water in application truck
          I.  Pump from river or lake
          2.  Take from city water line

  V.  Apply Chemical Solution via Surface Spraying

      A.  Use plant owned application truck
      B.  Rent contractor application truck
                                  B-ll

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Cost item
          TABLE B-2.   TYPICAL  VALUES  FOR  INDIRECT  CAPITAL COSTS
Ranges of values
Engineering



Construction and  field
  expenses

Contractor's fee

Shakedown/startup

Contingency
8 to 20 percent of installed cost.  High
  value for small  projects; low value for
  large projects

7 to 70 percent of installed cost
10 to 15 percent of installed cost

1 to 6 percent of installed cost

10 to 30 percent of total direct and indirect
  costs dependent upon accuracy of estimate.
  .Generally, 20 percent is used in a study
  estimate
                                 8-12

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  TABLE  3-3.   IMPLEMENTATION  ALTERNATIVES  FOR  OUST  SUPPRESSANTS APPLIED TO
                              AN  UNPAVED  ROAD
Program implementation alternative
      Dust
suppressant type
Chemicals   Water
   I.  Purchase  and Ship Dust Suppressant

      A.  Ship  in railcar tanker  (11,000  to                   X
             22,000 gal/tanker)
      B.  Ship  in truck tanker  (4,000  to  6,000  gal/           X
             tanker)
      C.  Ship  in drums via truck  (55  gal/drum)

  II.  Store  dust suppressant

      A.  Store on plant property
      1.  In new storage tank                                 X
      2.  In existing storage tank                            X
          'a.  Needs refurbishing                              X
          b.  Needs no refurbishing                           X
      3.  In railcar tanker
          a.  Own railcar                                     X
          b.  Pay demurrage                                   X

•III.  Prepare Road

    '  "A. ' Use plant-owned grader  to minimize  ruts  and  low    X
             spots
      B.  Rent  contractor grader                              X
      C.  Perform no road preparation                         X

  IV.  Mix Dust  Suppressant/Water  in Application Truck

      A.  Put suppressant in spray truck
          1. Pump suppressant  from storage  tank or  drums    X
                into application  truck
          2. Pour suppressant  from drums' into  application    X
                truck, generally  using forklift
      3.  Put water  in application truck
          1. Pump from river or  lake                         X
          2. Take from city water line                      X

   V.  Apply  suppressant solution  via  surface  spraying

      A.  Use plant owned application  truck                   X
      B.  Rent  contractor application  truck                   X
               X
               X
               X
               X
               X
               X
                                  B-13

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TABLE 8-4.   IMPLEMENTATION  ALTERNATIVES  FOR  STREET CLEANING
Broom-
Program implementation alternative sweeping
I. Acquire Flusher and Driver
A. Purchase flusher and use
plant driver
B. Rent flusher and driver
C. Use existing unpaved road
watering truck
II. Acquire Broom Sweeper and Driver
A. Purchase broom sweeper and X
use plant driver
B. Rent broom sweeper and X
driver
III.. Fill Flusher Tank with Water
A. Pump water from river or lake
B. Take water from city line
IV. Maintain purchased flusher
V. Maintain purchased broom sweeper X
Flushing
and
broom-
Flushing sweeping

. X X
X X
X X

X
X

X' X
X X
X X
X
                          B-14

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      TABLE B-5.  IMPLEMENTATION ALTERNATIVES FOR PAVING

Program implementation alternative


  L.   Excavate Existing Surface to Make Way for Base and
       Surface Courses

       A.  2-in. depth
       B.  4-in. depth
       C.  6-in depth

 II.   Fine Grade and Compact Subgrade

III.   Lay and Compact Crushed Stone Base Course

       A.  2-in. depth
       B.  4-in. depth
       C.  6-in depth

 IV.   Lay and Compact Hot Mix Asphalt (Probably AC1-20-150)
       Surface Course

       A.  2-in. depth
       B.  4-in. depth
       C.  6-in depth
                            B-15

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  TABLE  3-6.   CAPITAL EQUIPMENT  AND  O&M  EXPENDITURE ITEMS FOR
                   DUST SUPPRESSANT  SYSTEMSa
                        (Open Sources)

Capital  equipment

  •  Storage equipment

       Tanks
       Railcar
       Pumps
       Piping

  •  Application equipment

       Trucks
       Spray system
       Piping (including  winterizing)

Q&M expenditures

  •  Utility or fuel costs

       Water
       Electricity
       Gaso.line or diesel fuel

  •  Supplies

       Chemicals
       Repair parts

  •  Labor

       Application time
       Road conditioning
       System maintenance

aNot all items are necessary for all systems.  Specific  items
  are dependent on the control scenario selected.
                            B-16

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  TABLE  8-7.   CAPITAL EQUIPMENT AND O&M EXPENDITURE ITEMS FOR
                       STREET  CLEANING

Capital  equipment

  •  Sweeping
       Broom
       Vacuum system
  •  Flushing
       Piping
       Flushing truck
       Water pumps

O&M expenditures

  •  Utility and fuel costs
       Water
       Gasoline or diesel fuel
  •  Supplies
       Replacement brushes
  •  Labor
       Sweeping or flushing operation
       Truck maintenance
  •  Waste disposal  •
 TABLE B-8.  CAPITAL  EQUIPMENT AND O&M  EXPENDITURES  ITEMS  FOR
                             PAVING

Capital equipment

  •  Operating equipment
       Graders
       Paving application equipment
       Materials
       Paving material (asphalt or concrete)
       Base material

O&M expenditures

     Supplies
       Patching material
     Labor
       Surface preparation
       Paving
       Road maintenance
       Equipment maintenance
                            B-17

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  TABLE  B-9.   CAPITAL  EQUIPMENT  AND  O&M EXPENDITURE ITEMS FOR
          WET SUPPRESSION SYSTEMS (PROCESS SOURCES)

Capital  equipment

  •  Water spray systems
       Supply pumps
       Nozzles
       Piping (including winterization)
       Control system
       Filtering units
     Water/surfactant and foam systems only
       Air compressor
       Mixing tank
       Metering or proportioning unit
       Surfactant storage area
O&M expenditures

  •  Utility costs
       Water .
       Electricity

  •  Supplies
       Surfactant
       Screens

  •  Labor
       Maintenance
       Operation
                            B-18

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        TABLE  B-10.   PUBLISHED  SOURCES  OF  FUGITIVE  EMISSION  CONTROL
                             SYSTEM  COST DATA

1.  Cuscino, Thomas,  Jr.,  Gregory E. Muleski,and Chatten Cowherd, Jr. Iron
    and Steel  Plant Open Source Fugitive  Emission Control  Evaluation.
    EPA-600/2-83-110, NTIS No.  PB84-110568,  U.  S. Environmental  Protection
    Agency, Research  Triangle Park,  North  Carolina.  October 1983.

2.  Muleski, Gregory  E., Thomas Cuscino,  Jr.,  and Chatten  Cowherd, Jr.
    Extended Evaluation of Unpaved Road Oust Suppressants  in the Iron, and
    Steel Industry.  EPA-600/2-84-027,  NTIS  No. PB84-154350, U.  S.
    Environmental  Protection Agency, Research  Triangle Park, North
    Carolina.   February 1984.

3.  Cuscino, Thomas,  Jr.  Cost  Estimates  for Selected Dust Controls
    Applied to Unpaved and Paved Roads  in  Iron and Steel Plants.  EPA
    Contract No. 68-01-6314, Task 17, U.  S.  Environmental  Protection
    Agency, Region V, Chicago,  Illinois.   April 1984.

4.  Richardson Engineering Services, Inc.   The Richardson  Rapid
    Construction Cost Estimating System:   Volume I-Process Plant
    Construction Estimating Standards.   1983-84 Edition.

5.  Robert Snow Means Company,  Inc.   Building  Construction Cost  Data.
    1979.         '

6.  Neveril, R, V.  Capital and Operating  Costs of Selected Air  Pollution
    Control Systems.   EPA-450/5-80-002.  GARD,  Inc.  December 19-78.
                                  8-19

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             TABLE S-ll.   EXAMPLE  CALCULATION  CASE:   COST AND COST-EFFECTIVENESS
                          ESTIMATE FOR  TYPICAL OPEN  SOURCE CONTROL

     This table lists the steps  necessary  to calculate  the cost effectiveness for two control
alternatives for stabilizing unpaved  travel surfaces.   Following the list of nine steps  is  an
example problem illustrating the calculations.  Table B-12 through  B-16 are referenced  in the
calculations in Table B-11.


     Step 1—Specify Desired Average  Control Efficiency (e.g., 50,  75, or 90 percent)


     Step 2—Specify Basic Vehicle, Road  and Cl imatologicaI  Parameters for the Particular
Road of Concern'                                                                    '     '•


     Required venicle characteristics include:


     1.  Average Daily Traffic (ADT)—this is  the number of vehicles using the road
regardless of direction of travel  (e.g.,  on a  two lane  road in an iron and steel plant,  100
vehicles in one direction, and 100 in the other direction during a  single day yields 200
ADT);
     2.  Average vehicle weight  in short  tons;
     3.  Average number of vehicle wheels;  and
     4.  Average vehicle speed in  mph.


     Required road characteristics include:


     1.  Actual length of roadway  to  be controlled in miles;
     2.  Width of road to be controlled;
     3.  Silt content (in percent)—for an existing  road, these values should be measured;
however, for a proposed plant, average values  shown  in  AP-42 can be used;
     4.  Surface  loading (for paved roads)  in  Ib/mile—this is the  total   loading on a I I
traveled lanes rather than the average lane  loading;  and
     5.  Bearing strength of the road-At  this  time,  just a visual estimate of low, moderate,
or high  is required.  '                     '                  '       _
     Required cIimatologicaI characteristics  (applicable 'on Iy to watering of unoaved '
roads):  potential evaporation in  mm/h—the value depends on both the  location and the  rnonrh
of concern.  Control efficiency  data  in this  report  for watering unpaved  roads assume a
location in Detroit, Michigan, in  the summer.


     Step 3—Calculate the Uncontrolled Annual Emission Rate as the'Product of the Emission
Factor and the Source Extent


     The emission factor (E) should be calculated using the equations  from AP-42.


     The annual source extent (SE) is calculated as  365 x ADT x average one way trip
distance.


     Step 4—Consult the Appropriate  Control  Program Design Table to Determine  the 7irne
Between  Applications and the Application  intensity


     Select the approoriate taole
                                                                                    Taol e
                                                                                  conta i n i ng
Control  technique                                                                  i nformat ion

Coherex® applied  to unpaved roads                                                 Tabie 3-'2
Petro  Tac applied to unpaved roads                                                Taoie 3-13


                                                                                   (cont i nuea)
                                          B-20

-------
                               TABLE B-ll.   (continued)
     Verify that the vehicle and road character i ST i cs listed in Step 2 are similar to those
listed in the footnotes of the selected table.   If they are significantly different, the
table cannot be used.


     Step 5 — Calculate the Number of  Annual  Applications Necessary by Dividing 365 by the
Days Between Application (from Step 4T


     Step 6 — Calculate the Number of  Treated Miles Per Year by Multiplying the Actual Miles
of Road to be Controlled (from Step 2) by the Number of Annual  Applications (from Step 5)


     Step 7— Consult the Appropriate  Program Implementation Alternatives Table and Select the
Desired Program Implementation Plan"
                                                                                    Table
                                                                                  conta i n i ng
Control technique                                                                 i nf or-Tiat ion

Coherex* applied to unpaved roads                                                 Table B-15
Petro Tac applied to unpaved roads                                                Table 9-'6
     Step 8 — -Calculate Tota1  Annual  Cost by Annual izing Capital Costs and Adding to Annual
OperaFion and Maintenance Costs                                          '


     To annualize capital investment, the capital  cost is multiplied by a capital recovery
factor which is calculated as follows:

                             CRF  = •   [ i ( 1  H ) n ] /  ( ( 1  t-  i ) n  - 1 ]

where   CRF = capital  recovery  factor
          i  = annual interest rate fraction
          n = number of payment years

     Scale total annual cost by rat-io of actual  road width in feet  divided by 40 ft.


     Step 9--Calculate Cost Effectiveness by Dividing Total Annual COSTS
(from Step 8) by the Annual  Uncontrolled Emission  Rate (from Step 5) and
by Desired Control  Efficiency Fraction (from. Step  1)


     Example calculation.  The  following is an example cost-effectiveness calculation for
controlling PM-IO using Coherex® on an unpaved road -in a Detroit, Michigan, plant.


     Step 1 — Specify Desired Average Control Efficiency


     Desired average control, efficiency = 90 percent


     Step 2 — Specify Bas ic' Veh ic I e, Road, and Cl imatologi ca I  Parameters
for tine Particular Road of Concern


     Required vehicle characteristics:


     1.  Average daily traffic  =  100 vehicles per  day;
     2.  Average venicle weight = 40 ST;
     3.  Average number of vehicle wheels = 6; and
     4.  Average vehicle speed  = 20 mpn


                                                                                  (continued)
                                          B-21 '

-------
                               TABLE B-ll.   (continued)
     Required road characteristics


     1.  Actual  length of roadway to be controlled = 6.3 miles;
     2.  Width of  roadway = 30 ft;
     3.  Silt content = 9.1 percent
     4.  Bearing strength of road = moderate


     Step 3—Calculate Uncontrolled Annual  Emission Rate as the Product
of theTEmission Factor and the Source Extent

                                    0.7  0.5
                              s  S W    w     365-p

                             72 30 3    4      365

where   E = emission factor
        k = 0.36 for PM-10 (from Section 3.0 of  this manual)
        s = 9.1  percent (given in Step 2)
        S = 20 mph (given in Step 2)
        W = 40 ST (given in Step 2)
        w = 6 (given in Step 2)
        p = 140 (as per Figure-3-I  for Detroit,  Michigan)

     E = 4.98 Ib/VMT

     SE = 365xADTxaverage one-way trip distance

              days     vehicles 6.3  miles
     SE = 365 	xlOO —i	x	
              year        day   2 veh i cIe

     SE = 115,000  VMT/year

Emission rate = ExSE               .

                                                  1  short  ton   •
     Emission  rate = 4.98 lb/VMTx115,000  VMT/yearx-
                                                  2,000  Ib

     Emission rate = 286 tons of  P^IQ  per  year

     Step 4—Consult the Appropriate Control Program Design  Table  To Determine the Times
Between Applications and the Application  Intensity


     Use Table B-12.


     The vehicle and road characteristics  listed  in Step  2 are similar  to those in the
footnotes of  Table 2-1.


     From Table 8-12:

     Application intensity = 0.83 gal. of  20 percent solution/yd
                             (initial  application)


                           = 1.0  gal.  of  12 percent solution/yd
                             (reapplications)
     Application frequency = once every 47 days
                                                                                  (continued)
                                         8-22

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                               TABLE B-ll.   (continued)
     Step 5—CalcuiaTe the Number of Annual  Applications Necessary by
Dividing 565 by the Days Between Apol  cations (from Step 4)

                                  365        appl ications
     'lo. of annual  appl ications = —- = 77.7 	
                                   47            year


     Step 6—Calculate the Number of Treated Miles Per Year  by Multiplying the Actual  Miles
of Road to Be Controlled (from Step 2)  by the Number of Annual Applications (from Step 5)


                                                      appl ications
     No. of treated miles per year = 6.3 miles x 7.77 	
                                                         year

     = 49 treated miles/year


     Step 7—Consult the Appropriate Program Implementation  Alternatives
Table~and Select the Desired Program Implementation Plan


     From Table B-14, the following implementation plan and  associated costs are anticipated:

                                                     	COST	
                                                                              Lin i t cost
                                                       Capital          5/TreatedS/Actual
         Selected alternative                        investment, £        mile        mile

     !.  Purchase Coherex® and ship in truck tanker                       4,650
     2.  Store in newly purchased storage tank          30,000
     3.  Prepare road with plant owned grader                                           630
     4.  Pump water from river or lake                   5,000              135
     5.  Apply chemical with plant owned           •     70,000
           application truck (includes labor      •                                 .
           to pump water and Coherex® and
           apply solution)"	 -   .        	
                                                       105,000  -          4',785         6"30~


     Step 8—Calculate Total Annual  Cost by Annual izing Capital  Costs and Adding rp Annual
Operation and-Maintenance Costs •


     Calculate annual capital investment (PI) = capital investmentxCRF


     CRF = [i(1vi)nl/[(1+i)n-1l
     CRF = capital- recovery factor
        i = 0.15
        n = 10 years
     CRF = 0.199252
      PI = 105,000x0.199252 = 520,900/year
     Calculate annual operation and maintenance costs  (MO)
     MO = 54,785/treated milex49 treated miles/year *


                            actua I  mi Ies
     5630/actual mile x 6.3 	
                                year
     =  5238,000/year
                                                                                  (continued)
                                          B-23

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                              TABLE 8-11.   (continued)
     Calculate  total cosr  (0) = PUMO

     D =  J20,900/year+$238,000/year
       =  S258,900/year

     Scale total  cost by actual road width:
                                                          30 ft
     Actual  total  cost  for a 30-ft wide road = $258,900/yrx-
                                                          40 ft

                                            = $194,200/yr

     Step 9—Calculate Cost Effectiveness by Dividing Total  Annual  Costs (from Step 8) by the
Annual  Uncontrolled  Emission Rate (from Step 3) and by the Desired Control  Efficiency
Fraction (from  Step  1)

                          $194,200/year
     Cost effectiveness  =
                         286  ST/yearxO.9
                        = $754/short ton of PM1Q reduced
                                         B-24

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 TABLE B-12.  ALTERNATIVE CONTROL PROGRAM DESIGN FOR COHEREX*
                APPLIED TO TRAVEL SURFACES3 b
Average
percent
control
desired
50
75
90
Vehicle
passes between
applications
23,300
11,600
4,650
Days
as
100
233
116
47
between appli
a function of
300
78
39
16
cations
ACT
500
47
23
9
 Calculated time and vehicle passes between application are
 based on the following conditions:

   Suppressant application:
   •  3.7 L of 20 percent solution/m2 (0.83 gallon of
      20 percent solution/yd2) initial application
   •  4.5 L of 12 percent solution/m2 (1.0 gal. of 12 percent
      solution/yd2);  reapplications
   Vehicular.traffic:
   •  Average weight—Mg (43 tons) -.-
   •  Average wheels—6
   •  Average speed--29 km/h (20 mph)
,   Road structure:  bearing strength—low to moderate
DPM-10 = Particles <10 umA.
cFor reapplications that span time periods greater than
 365 days, the effects of the freeze-thaw cycle are not
 incorporated in the reported values.
                            8-25

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       TABLE B-13.  COST ESTIMATES FOR IMPROVEMENT OF PAVED  TRAVEL
                                SURFACES

                                                           Annual  operating
                                   Initial                 cost (April 1985
Source/control  method        (April 1985 dollars)a            dollars)3 D


Paved road-sweeping         6,580-19,700/truck              27,600/truck

Paved road-vacuuming        36,800/truck                    34,200/truck

Paved road-flushing         18,400/truck                    27,600/truck

aJanuary  1980 costs updated  to  April  1985  cost by  Chemical  Engineering
.Index Factor = 1.315.   Reference  20.
 Cost per mile  depends  on nature of  process  and  the  site.
                                 8-26

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 TABLE  B-14.   ALTERNATIVE  CONTROL  PROGRAM DESIGN  FOR PETRO TAG
                APPLIED TO TRAVEL SURFACES'1 °
Average
percent
control
desired
50
75
90
Vehicle
passes between
applications
92,000
47,800
21,200
Days
as
100
920
478
212
between applications
a function of ACT
. 300
307
159
71
500
184
96
42
Calculated time and vehicle passes between application are
 based on   the following conditions:
   Suppressant application:  3.2 L of 20 percent solution/m2
   (0.7 gal of 20 percent solution/yd2); each application
   Vehicular traffic:
   •  Average weight—Mg (30 tons)
   •  Average wheels—9.2
   •  Average speed--22 km/h (15 mph)
,   Road structure:  bearing strength—low to moderate
DPM-10 = particles <10 umA.
GFor reapplications that span time periods greater than
 365 days, the effects of the freeze-thaw cycle are not
 incorporated in the reported values.
                            B-27

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       TABLE  B-15.   IDENTIFICATION AND COST  ESTIMATION  OF  COHEREX:
                          CONTROL ALTERNATIVES
Program implementation alternatives
Cost
  I.   Purchase and ship Coherex®

      A.   Ship in railcar tanker  (11,000-22,000
            gal/tanker)
      B.   Ship in truck tanker  (4,000-6,000
            gal/tanker)
      C.   Ship in drums via truck (55 gal/drum)

 II.   Store Coherex®

      A.   Store on plant property
          1.  In new storage tank
          2.  In existing storage tank
              a..  Needs refurbishing
              b.  Needs no refurbishing
          3.  In railcar tanker
              a.  Own railcar
              b.  Pay demurrage

          4.  In truck tanker
              a.  Own truck
              b.  Pay demurrage
          5.  In drums
      B.   Store in"contractor tanks

III.   Prepare road

      A.   Use plant-owned grader  to minimize
            ruts and low spots
      B.   Rent contractor grader
      C.   Perform no road preparation

 IV.   Mix Coherex® = and water  in application
        truck

      A.   Load Coherex®= into spray truck
          1.  Pump Coherex® = from storage tank
                or drums into application truck
      2.  Pour Coherex® = from drums into
            application truck, using forklift
$4,650/treated mile

$4,650/treated mile

$7,040/treated mile




$30,000 capital

$5,400 capital
         -0-

         -0-
$20, $30, $60/treated
  mi le

         -0-
$70/treated mile
       .  -0-
$140/treated jnile



$630/actual mile

$l,200/actual mile
         -0-
Tank—0  (included  in
  price  of storage
  tank)
Drums—$1,000 capital
$l,000/treated mile
                                                                (continued)
                                 B-28

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                         TABLE B-15.  (continued)
Program implementation alternatives
Cost
      8.  Load water into application truck
          1.  Pump from river or lake
          2.  Take from city water line

  V.  Apply Coherex® = solution via surface
        spraying

      A.  Use plant owned application truck
      B.  Rent contractor application truck
$5,000 capital
$40/treated mile
$70,000 capital+$135/
  treated mile for
  tank or $270/treated
  mile for drums

Tank—$500/treated
  mile
Drums—$l,000/treated
  mile
                                  B-29

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       TABLE B-16.
IDENTIFICATION  AND COST ESTIMATION OF PETRO TAG
      CONTROL ALTERNATIVES
Program implementation  alternatives
                                Cost
  I.   Purchase and  ship  Petro  Tac

      A.   Ship in truck  tanker (4,000-6,000  gal/
            tanker)
      B.   Ship in drums  via truck  (55  gal/drum)

 II.   Store Petro Tac

      A.   Store on  plant property
          1.  In new storage tank
          2.  In existing storage  tank
              a.  Needs  refurbishing
              b.  Needs  no refurbishing
          3.  In railcar tanker
              a.  Own railcar
              b.  Pay demurrage

          4.  In truck tanker
              a.  Own truck
              b.  Pay demurrage
          5.  In drums
      B.   Store in contractor  tanks

III.   Prepare road

      A.  . Use plant owned grader to minimize
            ruts and low spots
      B.   Rent contractor grader
      C.   Perform no road preparation

 IV.   Mix Petro Tac and  water  in application

        truck

      A.   Load Petro Tac into  spray truck
          1.  Pump Petro Tac from storage tank
                or drums into  application truck
          2.  Pour Petro Tac. from drums into
                application truck, generally using
                forklift
          Load water into application truck
          1.  Pump from river or lake
          2.  Take from city water line
                                $5,400/treated mile

                                $ll,500/treated mile



                                $30,000 capital

                                $5,400 capital
                                        -0-

                                        -0-
                                $20,  $30, $60/treated
                                  mile

                                        -0-
                                $70/treated mile
                                        -0-
                                $140/treated mile


                                $630/actual mile  .

                                $l,200/actual mile
                                        -0-
                                Tank - 0 (included in
                                  price of storage
                                  tank)
                                Drums--$l,000 capital
                                $l,000/treated mile
                                $5,000 capital
                                $40/treated mile
                                                               (continued)
                                 B-30

-------
                         TABLE  8-16.   (continued)
Program implementation alternatives
Cost
  V.  Apply Petro Tac solution via surface
        spraying

      A.  Use plant-owned application truck
      B.  Rent contractor application truck
$70,000 capital+$135/
  treated mile for
  tank or $270/treated
  mile for drums
Tank--$500/treated
  mile
Drums—$1,000/treated
  mile
                                 3-31

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                    APPENDIX C.




METHODS OF COMPLIANCE DETERMINATION FOR OPEN SOURCES

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     APPENDIX C.  METHODS OF COMPLIANCE DETERMINATION FOR OPEN SOURCES

     Once a specific PM10 control strategy has  been  developed  and
implemented, it becomes necessary for either the  control  agency or
industrial concern to assure that it is achieving the desired  level of
control.  As stated previously, the control efficiency  actually attained
by a particular technique depends on its proper implementation.  This
section will discuss methods for determining compliance with various
regulatory requirements relating to PM10 control  strategies.   These
methods include visual observations and recordkeeping of  key control
parameters.
C.I  METHOD FOR DETERMINING VISIBLE EMISSIONS
     Visible emission methods have been adopted by a number of states as a
tool for compliance.  Although opacity observations at  the property line
have commonly been employed in earlier fugitive dust control regulations,
recent court decisions in Colorado and Alabama  have found that rules of
that type are unconstitutional (failing to provide equal protection).   It
is strongly recommended that property-line opacity observations serve only
as an indicator of a potential problem, thus "triggering" further
investigation.  Source-specific opacity determinations, on the other hand,
have long been a court-tested approach to regulation.   The following
section describes two states' approach to fugitive dust regulation using
visible emission methods.
C.I.I  Tennessee Visible Emission Method
     The State of Tennessee has developed a method (TVEE Method 1)  for
evaluating visible emissions (VE) from roads and parking lots.1  The
following discussion focuses on TVEE Method 1 (Ml) in the technical
areas:  (1) reader position/techniques; and (2)  data reduction/evaluation
procedures.  Table C-l summarizes the relevant  features of TVEE Ml.
     C.I.1.1  Reader Position/Techniques.   As indicated in Table C-l,  TVEE
Method 1 specifies an observer location of 15 ft from the source.   In  most
cases, this distance should allow an unobstructed  view,  and  at  the  same
time meet observer safety requirements.
                                  C-l

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         TABLE  C-l.  SUMMARY OF TVEE METHOD  1 REQUIREMENTS (Ml)


Reader position/techniques

•  Sun in 140°  sector behind  the  reader.

•  Observer position -15 ft from  source.

•  Observer line of sight should  be as  perpendicular as possible to both
   plume and wind direction.

•  Only one plume thickness read.

•  Plume read at ~4 ft  directly above emitting  surface.

••  Individual opacity readings  taken each 15 s,  recorded to nearest
   5 percent opacity.

•  Readings.terminated  if vehicle  obstructs line of sight.

•  Readings terminated  if vehicles passing in opposite direction creates
   intermixed plume.

Data reduction

•  2-min time-averages  consisting'of eight consecutive 15  s. readings.

Certification

•  Per Tennessee requirements
                                 C-2

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     Ml also specifies that the plume be read at ~4 ft directly above the
emitting surface.  This specification presumably results from field
experiments conducted to support the method.   It is probably intended to
represent the point (i.e., location) of maximum opacity.  While there is
no quantitative supporting evidence, it seems likely that the height and
location of maximum opacity relative to a passing vehicle will  vary
depending upon ambient factors (wind speed and direction) as well as
vehicle type and speed.
     Implied in the Ml specification that the plume be read ~4  ft above
the emitting surface, is the fact that observations will be made against a
terrestrial (vegetation) background.  The results of one study  using a
conventional smoke generator modified to emit horizontal plumes, indicated
that under these conditions observers are likely to underestimate opacity
levels.  More specifically, the study found that as opacity levels
increased, opacity readings showed an increasing negative bias.  For
example, at 15 percent opacity, the observers underestimated opacity by
about 5 percent, and at 40 percent opacity, observations averaged about
11 percent low.2  Black plumes were underestimated at all opacity levels..
  ...  Ml specifies that only one plume thickness 'be read.  It includes
qualifying provisions that:  (1) readings terminate if vehicles passing in
opposite directions create an intermixed plume; but (2) readings continue
if intermixing occurs as a result of vehicles moving in the same direc-
tion.  Unlike (1), the latter condition is considered representative of
the surface.  The intent here is probably to minimize the influence of
increasing plume density which results from "overlaying" multiple plumes.
     C.I.1.2  Data Reduction/Evaluation Procedures.  There are  two basic
approaches that can be used to reduce opacity readings for comparison with
VE regulations.  One approach involves the time-averaging of consecutive
15-s observations over a specified time period to produce an average
opacity value.
     In the development of Ml, the State of Tennessee concluded that a
short averaging period—2 min (i.e., eight consecutive 15-s readings) was
appropriate for roads and parking lots, as these sources typically produce
brief, intermittent opacity peaks.
                                  C-3

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     Although not specified  in Ml, VE  from open  sources  could  be evaluated
using time-aggregating techniques.   For  example,  the  discrete  15-s
readings could be employed  in the  time-aggregating  framework.   In this
case, the individual  observations  are  compiled into a histogram from which
the number of observations  (or equivalent percent of  observation time) in
excess of the desired opacity may  then be ascertained.   The  principal
advantage of using the time-aggregate  technique  as  a  method  to reduce VE
readings is that the  resultant indicator of  opacity conditions is then
compatible with regulations  that  include a time  exemption  clause.  Under
time exemption standards, a  source is  permitted  opacity  in excess of the
standard for a specified fraction  of the time  (e.g.,  3 min/h).  The
concept of time exemption was originally developed  to accommodate
stationary source combustion processes.
     Without more detailed  supporting  information,  it is difficult to
determine which of the two  approaches  is most  appropriate  for  evaluating
VE from open sources.  With  respect  to time-averaging, statistics of
observer bias in reading plumes from a smoke generator do  indicate at
least a slight decrease in  the "accuracy" of the mean observed opacity
value as averaging time decreases.   In Ml (2-min average), this is
reflected in the inclusion  of an  8.8 percent buffer for  observational
error.  This buffer is taken into  account before issuing a Notice of
Violation.i
     One potential problem with applying time-averaging  to opacity from
roads and parking lots, is  that the  resulting  average will be  sensitive to
variations in source  activity.  For  example, interpreting  one  conclusion
offered in support of Method 1, it is  likely that under  moderate wind
conditions a single vehicle  pass will  produce  only  two opacity readings
> 5 percent.1  Averaging-these with  six  zero (0) readings  yields a 2-min
value below any reasonable opacity standard.  Yet,  under the same
conditions with two or more  vehicle  passes,  the  average  value  will suggest
elevated opacity levels.  While there  is no  information  available on the
use of time aggregation for open  source  opacity,  it appears  that this
approach would more easily accommodate variations in  level of  source
activity.  For this reason alone,  it may be  the  evaluation approach better
suited to roads and parking  lots.
                                  C-4

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C.I.2  Ohio  Draft Rule 3745-17-(03)(B)
     The State  of Ohio submitted  a  fugitive  dust  visible  emission
measurement  technique which the EPA proposed to approve  in  the Federal
Register on  January 2, 1987.  Unlike the Tennessee  method,  the Ohio draft
rule contains provisions for sources other than roads  and parking lots.
Average opacity values are based  on 12 consecutive  readings.   Table C-2
summarizes the  Ohio method; as can  be seen from the table,  many features
of the Ohio  draft rule are similar  to TVEE Method 1.   Consequently,  the
remarks made earlier in this section are equally applicable here.
C.I.3.  Correlation of Mass Emissions with Opacity  Measurements
     A current  program conducted  by the State of Indiana is intended  to
establish the correlation between the opacity of a  plume generated  by
vehicles traveling on the road, and the PM10/TSP mass  emission
measurements.   The desired end-product is a  PM10 mass  estimation  tool
using silt content and opacity as input values.  Visible emission readings
(VE) will be taken by 12 readers currently certified in EPA Method 9.  All
VE readings will be performed in accordance with the techniques described
in Ohio Draft Rule 3745-17-(03)(B), as far as. practical.   To assure that
all the .readers view the same area, the receiving area boundaries shall  be
clearly indicated by flags, stakes, or other indicating devices.  The
highest and  lowest readings from each set shall be discarded leaving
10 sets of readings for evaluation.
     It is anticipated that the results of this study will  be available  in
the fall of  1988.
C.2  RECORDKEEPING AND OPEN DUST SOURCE CONTROLS
     Parameter monitoring and associated  recordkeeping may play important
roles in determining open dust  source  compliance.   Detailed  records are
particularly important for periodic dust  control  measures  (as  discussed in
Appendix A) because effectiveness  must  be averaged over the  periods
between applications.   The following discussion presents  recordkeeping
requirements for the six  source  categories  presented in Chapters 1.0
through 6.0.  Each discussion builds upon the regulatory  formats suggested
earlier in the body of this manual.
                                  C-5

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          TABLE C-2.  SUMMARY OF OHIO DRAFT RULE 3745-17-(03)(B)

Reader position/techniques

          Roadways and parking lots:
               Line of vision approximately perpendicular to plume
               direction.
               Plume read  at  ~4 ft  above  surface.
               Readings suspended if  vehicle obstructs  line of  sight;
               subsequent  readings  considered consecutive to that taken
               before the  obstruction.
               Readings suspended if  vehicles passing  in opposite
               direction create an  intermixed plume; subsequent readings
               considered  consecutive to  that taken  before intermixing.
               If unusual  condition (e.g.,  spill)  occurs, another set of
               readings must  be conducted.

          All other sources:    .    .
               Sun behind  observer.
               Minimum of  15  ft from  source.
               Line of sight  approximately  perpendicular to flow of
               fugitive dust  and to longer  axis  of the  emissions.
               Opacity observed for point of highest opacity.
                                  C-6

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C.2.1  Paved Roads and Parking Lots
     Records must be kept that document the frequency of mitigative
measures applied to paved surfaces.  Pertinent parameters to be specified
in a control plan and to be regularly recorded include:
     C.2.1.1  General Information to be Specified in Plan.
     1.  All road segments and parking locations referenced on a map
available to both the responsible party and the regulatory agency:
     2.  Length of each road and area of each parking lot;
     3.  Type of control applied to each road/area and planned frequency
of application; and
     4.  Any provisions for weather (e.g., % in. of rainfall will be
substituted for one treatment).
     C.2.1.2  Specific Records for Each Road Segment/Parking Area
Treatment
     1.  Date of treatment;
     2.  Operator's initials (note that the operator may keep a separate
log whose information is transferred to the environmental staff's data
sheets);
     3.  Start and stop times on a particular segment/parking lot, average
speed, number of passes;
     4.  For flushing programs, start and stop times for refilling tanks;
     5.  Qualitative description of loading before and after treatment;
and
     6.  Any areas of unusually high loadings from spills, pavement
deterioration, etc.
     C.2.1.3  General Records to be Kept.
     1.  Equipment maintenance records;
     2.  Meteorological log (to the extent that weather influences the
control program—see above); and
     3.  Any equipment malfunctions or downtime.
     In addition to those items related to control applications,  some of
the regulatory formats may require that additional records be kept.  These
records may include surface material samples or traffic counts.   A
suggested format for recording paved surface samples (following the
sampling/analysis procedures given in Appendices 0 and E) is presented as
                                  C-7

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Figure D-4 in Appendix D.  Traffic counts  may  be  recorded either manually
or using automatic devices; suggested  formats  are given as Figures C-l and
C-2, respectively.
C.3  UNPAVED ROADS
     Recordkeeping requirements for unpaved  roads were summarized in
Table 3-5.  The following lists pertinent  parameters  to be monitored.
     General Information to be Specified  in  the  Plan
     1.  All road segments and parking locations  referenced on a map
available to both the responsible party and  the  regulatory agency;
     2.  Length of each road and area  of  each  parking lot;
     3.  Type of chemical applied to each  road/area,  dilution ratio,
application intensity, and planned frequency of  application; and
     4.  Provisions for weather.
     Specific Records for Each Road Segment/Parking Area Treatment
     1.  Date of treatment;
     2.  Operator's initials (note that the  operator  may keep a separate
log of whose information is transferred to the environmental staff's data
sheets);
     3.  Start and stop times on a particular  segment/park ing lot, average
speed, number of passes, amount of so-lution  applied;  and
     4.  Qualitative description of road  surface  condition.
     General Records to be Kept
     1.  Equipment maintenance records;
     2.  Meteorological log (to the extent that  weather influences the
control program—see above); and
     3.  Any equipment malfunctions or downtime.
     In addition, material samples may be  taken  as well as traffic counts
as part of the regulatory formats given- in Section 3.4.  Unpaved road
sampling is discussed in Appendix D; traffic samples  may be recorded on
Figures C-l and C-2.
                                  C-8

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Rood Location:	
Road Type:	
Sampling  Start Time:	   Srop Time:
Vehicle  Type     Axles./V/heels     1   23456739    10    Tofci
                  Figure  C-l.   Manual  traffic count log.
                                        C-9

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Counter
ID No.














Site Location














Start Count














Oate/TJme














Stoo Count














Oa re/7; me














Secorce-- ,
ay • i




1









Figure C-2.   Example pneumatic traffic count log,
                       C-10

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C.3  REFERENCES FOR APPENDIX C

1.  Telecon.  Englehart, P., Midwest Research Institute,  with Walton,  J.
    Tennessee Division of Air Pollution Control.   Nashville,  Tennessee.
    September 1984.

2.  Rose, T. H.  Evaluation of Trained Visible Emission Observers for
    Fugitive Opacity Measurement.  EPA-60/3-84-093,  U.  S. Environmental
    Protection Agency, Research Triangle Park, NC, October 1984.
                                 C-ll

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                 APPENDIX D.



PROCEDURES FOR SAMPLING SURFACE/BULK MATERIALS

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        APPENDIX D.   PROCEDURES  FOR  SAMPLING  SURFACE/BULK MATERIALS

     The starting point for development of the recommended procedures for
collection of road dust and aggregate material samples was a review of
American Society of Testing and Materials (ASTM) Standards.  When
practical, the recommended procedures were structured identically to the
ASTM standard.  When this was not possible, an attempt was made to develop
the procedure in a manner consistent with the intent of the majority of
pertinent ASTM Standards.
D.I UNPAVED ROADS
     The main objective in sampling the surface material from an unpaved
road is to collect a minimum gross sample of 23 kg (50 Ib) for every
3.8 km  (3 miles) of unpaved road.  The incremental samples from unpaved
roads should be distributed over the road segment, as shown in
Figure  D-l.  At least four incremental samples should be collected and
composited to form the gross sample.
     The loose surface material is removed from the hard road base with a
whisk broom and dustpan.  The material should be swept carefully so that
the fine dust is not injected into the atmosphere.  The hard road base
below the loose surface material should not be abraded so as to generate
more fine material than exists on the road in its natural state.
     Figure D-2 presents a data form to be used for the sampling of
unpaved roads.
D.2  PAVED ROADS
     Ideally, for a given paved road, one gross sample per every 8 km
(5 miles) of paved roads should be collected.  For industrial roads, one
gross sample should be obtained for each road segment in the plant.  The
gross sample should consist of at least two separate increments per travel
lane, or each 0.5 mile length should have a separate sample.
     Figure D-3 presents a diagram showing the location of incremental
samples for a four-lane road.  Each incremental sample should consists of
a lateral strip 0.3 to 3 m (1 to 10 ft) in width across a travel lane.
The exact width is dependent on the amount of loose surface material on
the paved roadway.  For a visually dirty road, a width of 0.3 m (1 ft) is
sufficient; but for a visually clean road, a width of 3 m  (10 ft)  is
needed  to obtain an adequate sample.

                                  0-1

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                          H-
                                                    = 4.0tm (3 Mi.)
-H
                      O
                      ro
ro
                                  -Sample  Slrip  20cm (0 in.) Wide
                                L= 1.6km (I Mi.)
                       Figure D-l.  Location of incremental  sampling sites  on  an  unpaved road.

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  Sc.-npie
  No.
iurrcca
Area
"Jse code g^ven  on plant map for segment  identification and indicate sample
  iocaf.cn on map.
              Figure 0-2.   Sampling  data  form  for unpaved  roads.
                                        D-3

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                                     -Okm (5 Mi.) of similar  road type
Increment I
               Figure  D-3.   Location of incremental  sampling sites on a paved road.

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     The above sampling procedure may be considered as the preferred
method of collecting surface dust from paved roadways.  In many instances,
however, the collection of eight sample increments may not be feasible due
to manpower, equipment, and traffic/hazard limitations.  As an alternative
method, samples can be obtained from a single strip across all the travel
lanes.  When it is necessary to resort to this sampling strategy, care
must be taken to select sites that have dust loading and traffic
characteristics typical of the entire roadway segment of interest.  In
this situation, sampling from a strip 3 to 9 m (10 to 30 ft) in width is
suggested.  From this width, sufficient sample can be collected, and a
step toward representativeness in sample acquisition will be accomplished.
     Samples are removed from the road surface by vacuuming, preceded by
broom sweeping if large aggregate is present.  The samples should be taken
from the traveled portion of the lane with the area measured and recorded
on the appropriate data form.  With a whisk broom and a dust pan, the
larger particles are collected from the sampling area and.placed in a
clean, labeled container (plastic jar or bag).  The remaining smaller
particles are then swept from the road with an electric broom-type vacuum
sweeper.  The sweeper must be equipped with a preweighed, prelabeled,
disposable vacuum bag.  Care must be taken when installing the bags in the
sweeper to avoid torn bags which can result in loss of sample.  After the
sample has been collected, the bag should be removed from the sweeper,
checked for leaks and stored in a prelabeled, gummed envelope for
transport.  Figure D-4 presents a data form to be used for the sampling of
paved roads.
     Values for the dust loading on only the traveled portion of the
roadway are needed for inclusion in the appropriate emission factor
equation.   Information-pertaining to dust loading on curb/beam and parking
areas is necessary in estimating carry-on potential to determine the
appropriate industrial road augmentation factor.
0.3  STORAGE PILES
      In sampling the surface of a pile to determine representative
properties  for use in the wind erosion equation, a gross sample made up of
top, middle, and bottom incremental samples should ideally be obtained
since the wind disturbs the entire surface of the pile.  However, it is
                                  D-5

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Type of Mcteric.  Scrnoiec:
Site of ic.T.oii": 	
                                    No. oi T.-cffic -cnes
Tvoe of ?averr.e-r:  iiana.t/Cmcret
                                    Surface   oncirior.
 Sarap",a NC.   ;Vac.Sag;   Ti-.a ;
"Use  code  jiven on plant map for segment identification and indicate sample
  location on map.
        Figure 0-4.   Sampling  data form  for  paved roads.
                                    D-6

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impractical to climb to the top or even middle of most industrial storage
piles because of the large size.
     The most practical approach in sampling from large piles is to
minimize the bias by sampling as near to the middle of the pile as
practical and by selecting sampling locations in a random fashion.
Incremental samples should be obtained along the entire perimeter of the
pile.  The spacing between the samples should be such that the entire pile
perimeter Is traversed with approximately equidistant incremental
samples.  If small piles are sampled, incremental samples should be
collected from the top, middle, and bottom.
     An incremental sample (e.g., one shovelful) is collected by skimming
the surface of the pile in a direction upward along the face.  Every
effort must be made by the person obtaining the sample not to purposely
avoid sampling larger pieces of raw material.  Figure 0-5 presents a data
form to be used for the sampling of storage piles.
     In obtaining a gross sample for the purpose of characterizing a
loadin or load-out process, incremental samples should be taken from the
portion of the storage pile surface:  (1) which has been formed by the
addition of aggregate material; or (2) from which aggregate material is
being reclaimed.
                                  0-7

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Type or Material Sampled:.
Si^e or Sampling:
SAMPLING METHOD
  i. Sampling device:  pointed shovel
  2. Scmpling depth: 10 - 15 cm ( 4- -6 inches )
  3. Sample container:' metal or plastic bucket with sealed poly liner
  -. Gross sample specifications:
     (a)  ! sample of 23kg (50 ib .) minimum  for every pile sampled
     (b) composite of  10 increments
  5. Minimum sortion of stored material (at one site) to be sampled:  25%


SAMPLING DATA
Scrrcie
No.

•

'- -








T'rr*-


.








!
Lccsricn (Refer ra .-res)










i

Surface
Area








-


i
Oeorh





•






Qucnri ry
of Scmcie

! _ i

j
i







i
                 Figure D-5.   Sampling data form for  storage piles.
                                        D-8

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                       APPENDIX E.



PROCEDURES FOR LABORATORY ANALYSIS OF  SURFACE/BULK SAMPLES

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  APPENDIX E.  PROCEDURES FOR LABORATORY  ANALYSIS OF  SURFACE/BULK SAMPLES

E.I  SAMPLES FROM SOURCES OTHER THAN PAVED ROADS
E.I.I  Sample Preparation
     Once the 23 kg (50 Ib) gross sample is brought to the laboratory, it
must be prepared for silt analysis.  This entails dividing the sample to a
workable size.
     A 23 kg (50 Ib) gross sample can be divided by using:  (1) mechanical
devices; (2) alternative shovel method; (3) riffle; or (4) coning and
quartering method.  Mechanical division devices are not discussed in this
section since they are not found in many laboratories.  The alternative
shovel method is actually only necessary for samples weighing hundreds of
pounds.  Therefore, this appendix discusses only the use of the riffle and
the coning and quartering method.
     ASTM standards describe the selection of the correct riffle size and
the correct  use of the riffle.  Riffle slot widths should be at least
three times  the size of the largest aggregate in the material being
divided.  The following quote describes the use of the riffle.1

           "Divide the gross, sample by using a riffle.  Riffles
      properly used will reduce sample variability but cannot
      eliminate it.  Riffles are shown in Figure E-l, (a) and (b).
      Pass the material through the riffle from a feed scoop, feed
      bucket, or riffle pan having a lip or opening the full length
      of the riffle.  When using any of the above containers to feed
      the riffle, spread the material evenly in the container, raise
      the container, and hold it with its front edge resting on top
      of the.feed chute, then slowly tilt it so that the material
      flows  in a uniform stream through the hopper straight down
      over the center of the riffle into all the slots, thence into
      the riffle pans, one-half of the sample being collected in a
      pan.   Under no circumstances shovel the sample into the riffle
      .riffle, or dribble into the riffle from a small-mouthed
      container.  Do not allow the material to build up in or above
      the riffle slots.  If it does not flow freely through the
     - slots, shake or vibrate the riffle to facilitate even flow."
     The procedure for coning and quartering is best illustrated in
Figure E-2.  The following is a description of the procedure:  (1) mix the
material and shovel it into a neat cone; (2) .flatten the cone by pressing
the top without further mixing; (3) divide the flat circular pile into
equal quarters by cutting or scraping out two diameters at right angles;

                                  E-l

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reed Chute
     Riffle Sampler


      -   (a)
    Riffle Sucked and
Separate Feed Chute Stand

         Co)
         Figure  E-l.   Sample  dividers (riffles).
                          E-2

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Figure E-2.   Coning and quartering.
                E-3

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(4) discard two opposite quarters;  (5)  thoroughly  mix  the two remaining
quarters, shovel them into a cone,  and  repeat  the  quartering and
discarding procedures until  the  sample  has  been  reduced  to 0.9 to 1.8 kg
(2 to 4 Ib).  Samples likely to  be  affected by moisture  or drying must be
handled rapidly, preferably in an area  with a  controlled atmosphere, and
sealed in a container to prevent further  changes during  transportation and
storage.  Care must be taken that the material is  not  contaminated by
anything on the floor or that a  portion is  not lost  through cracks or
holes.  Preferably, the coning and  quartering  operation  should be
conducted on a floor covered with clean paper.   Coning and quartering is a
simple procedure which is applicable to all powdered materials and to
sample sizes ranging from a few  .grams to  several hundred pounds.-
     The size of the laboratory  sample  is important—too little sample
will not be representative and too  much sample will  be unwiekily.
Ideally, one would like to analyze  the  entire  (jross  sample in batches, but
this is not practical-  While all ASTM  standards acknowledge this
impracticality, they disagree on the exact  size, as  indicated by the range
of recommended samples, extending from:  0.05 to 27  kg (0.1 to 60 Ib).
     The main principle in sizing the laboratory sample  is to have
sufficient coarse and fine portions to  be representative of the material
and to allow sufficient mass on  each sieve  so  that the weighing is
accurate.  A recommended rule of thumb  is to have  twice  as much coarse
sample as fine sample.  A laboratory sample of 800 to  1,600 g is
recommended since that is the largest quantity that  can  be handled by the
scales normally available (1,600-g  capacity).  Also, more sample than this
can produce screen blinding for  the 8 in. diameter screens normally
available.
E.I.2  Laboratory Analysis of Samples for Silt Content
     The basic recommended procedure for  silt  analysis is mechanical, dry
sieving after moisture analysis.  A step-by-step procedure is given in
Tables E-l and E-2.  The sample  should  be oven dried for 24 h at 230°F
before sieving.  The sieving time is variable; sieving should be continued
until the net sample weight collected in  the pan increases by less than
3.0 percent of the previous net  sample  weight  collected  in the pan.  A
minor variation of 3.0 percent is allowed since  some sample grinding due
to interparticle abrasion will occur, and consequently,  the weight will

                                  E-4

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                  TABLE  E-l.   MOISTURE  ANALYSIS  PROCEDURE
1.  Preheat the oven to approximately 110°C (230°F).  Record oven
    temperature.

2.  Tare the laboratory sample containers which will be placed in the
    oven.  Tare the containers with the lids on if they have lids.  Record
    the tare weight(s).  Check zero before weighing.

3.  Record the make, capacity, smallest division, and accuracy of the-
    scale.

4.  Weigh the laboratory sample in the container(s).  Record the combined
    weight(s).  Check zero before -yeighing.

5.  Place sample in oven and dry overnight.*

6.  Remove sample container from oven and (a) weigh immediately if
    uncovered, being careful of the hot container; or (b) place tight-
    fitting lid on the container and let cool before weighing.  Record the
    combined sample and container weight(s).  Check zero before weighing.

7.  Calculate the moisture as the initial weight of the sample and
    container minus the oven-dried weight of the sample and container
    divided by the initial weight of the sample alone.  Record the value.

8.  Calculate the sample weight to be used in the silt, .analysis as the
    oven-dried weight of the sample and container minus the weight of the
    container.  Record the value.

aOry materials composed of hydrated minerals or organic materials like
 coal and certain soils for only 1-1/2 h.  Because of this short drying  .
 time, material dried for only 1-1/2 h must not be more than 2.5 cm
 (1 in.) deep in the container.
                                  E-5

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                  TABLE E--2.  SILT ANALYSIS PROCEDURES
1.   Select the  appropriate  8-in. diameter,  2-in.  deep  sieve sizes.  Recom-
    mended U.S.  Standard  Series  sizes  are:   3/8  in., No.  4, No.  20,
    No.  40, No.  100,  No.  140,  No.  200,  and  a pan.   Comparable Tyler Series
    sizes can also be utilized.  The No.  20 and  the No.  200 are  mandatory.
    The  others  can be varied  if  the recommended  sieves are not available
    or if buildup on  one  particulate sieve  during  sieving indicates that
    an intermediate sieve should be inserted.

2.   Obtain a mechanical  sieving  device  such as vibratory  shaker  or a Roto-
    Tap.

3.   Clean the sieves  with compressed air  and/or  a soft brush.  Material
    lodged in the sieve  openings or adhering to  the sides of the sieve
    should be removed (if possible) without handling the  screen  roughly.

4.   Obtain a scale (capacity  of  at least  1,600 g)  and  record make,
    capacity, smallest division, date  of  last calibration, and accuracy
    (if  available).

5.   Tare sieves and pan.   Check  the zero  before- every  .weighing.   Record
    weights.

6.   After nesting the sieves  in  decreasing  order with  pan at the bottom,
    dump dried laboratory sample  (probably  immediately after moisture
    analysis) into the top sieve.   Brush  fine material adhering  to the
    sides of the container into  the top sieve and" cover the top  sieve with
    a special lid normally purchased with the pan.

7.   Place nested sieves  into  the mechanical device and sieve for 20 min.
    Remove pan containing minus  No. 200 and weigh.   Replace pan-beneath
    the  sieves and sieve for  another  10 min. Remove pan and weigh.  When
    the  differences between two  successive  pan  sample  weighings  (where the
    tare of the pan has  been  subtracted)  is less than  3.0 percent, the
    sieving is complete.

8.   Weigh each sieve  and its  contents  and record the weight.  Check the
    zero before every weighing.

9.   Collect the laboratory sample  and  place the  sample in a separate
    container if further analysis  is  expected.
                                  E-6

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continue to increase.  When the change reduces to 3.0 percent, it is
thought that the natural silt has been passed through the No. 200 sieve
screen and that any additional increase is due to grinding.
     Both the sample preparation operations and the sieving results can be
recorded on Figures E-3 and E-4.
E.2  SAMPLES FROM PAVED ROADS
E.2,1  Sample Preparation and Analysis for Total Loading
     The gross sample of paved road dust will arrive at the laboratory in
two types of containers:  (1) the broom swept dust will be in plastic
bags; and (2) the vacuum swept dust will be in vacuum bags.
     Both the broom swept dust and the vacuum swept dust are weighed on a
beam balance.  The broom swept dust is weighed in a tared container.  The
vacuum swept dust is weighed in the vacuum bag which was tared and
equilibrated in the laboratory before going to the field.  The vacuum bag
and its contents should be equilibrated again in the laboratory before
weighing.
     The total surface dust loading on the traveled lanes of the paved
road is then calculated in units of kilograms of dust on the traveled
lanes per kilometer of road.  When only one strip of length is taken
across the traveled lanes, the total dust loading on the traveled lanes is
calculated as follows:
                                  rn -HTI
                              L . Ji-1                              .(Z-l)

where:  m^ = mass of the broom swept dust, kg
        mv = mass of the vacuum swept dust, kg
         i = length of strip as measured along the center!ine of the road,
             km
     When several incremental samples are collected on alternate roadway
halves as shown in Figure Y-3, the total surface dust loading is
calculated as follows:
                               m , -HTI ,+m  .-mi
                                51  vl  bb  vb
                                  E-7

-------
 Sample No:
 Mate.'iai:
Split Sample Balance:
  Make      	
  Smallest1 Division
Total Sample Weight:
(Excl.  Container)
Number of Splits: 	
Split Sample Weight (before drying)
Pan •*• Sample:	
Pan: 	
Wet Sample:	
Oven Temperature:
Date In	
Time In	
Drying Time _
Dare Our
Tirr.e Out
Marerial Weigh: (crr-3.- drying)
Pan - Material: 	
Pan:
Dry Sample:
MOISTURE  CONTENT:
 (A) Wet Sample Wf._
 (B) Dry Sample Wt. _
 (C) Difference Wf.
    C X  100-
                                                                             % Moisture
                Figure E-3.   Example moisture,  analysis  form
                                          E-8

-------
Sample No:
Material:
Split Sample Salance:
Make 	
Capaciry	
Srr.cilesf Division 	
Maferial Weight (after drying)
Pan T Maferial:
Pan:
Dry Sample:
Final Weight:
% s;ir -
                                                        Weigh t< 200 Mesh
                                                       Total Net Weignf
X 100 =
                 SIEVING
Time: Srarf:
Initial (Tare):
20 min:
30 min:
40 min:

Weight (Pan Only)





                                    SIZE DISTRIBUTION
Screen
3/8 in.
4 mesh
10 mesh
20 mesh
&Q mesh
Tare Weight
(Screen)





Final Weight
(Screen + Sample)




Net Weight (Sample)



%



!
1 i
!  !00 mesh  !
UO mesh
200 mesh
Pan












                      Figure E-4.   Example silt analysis form.
                                            E-9

-------
                               m 0+m   +m  +m
                                b2  v2  b6  v6
                               -
                                     0 -j-0
                                      2 *6
where:  m.   = mass of broom sweepings for increment i,  kg
         bi
        m   = mass of vacuum sweepings for increment i, kg
         v
          i
          i = length of increment i  is measured  along the road center! ine,
              km
E.2.2  Sample Preparation and Analyses for Road  Dust Silt Content
     After weighing the sample to calculate total  surface dust loading on
the traveled lanes, the broom swept  and vacuum swept dust is composited.
The composited sample is usually small and requires no  sample splitting  in
preparation for sieving.  If splitting is necessary to  prepare a
laboratory sample of 800 to 1,600 g,  the techniques discussed in
Section E.I.I can be used.  The laboratory sample  is then sieved using the
techniques described in Section E.I. 2.
E.3  REFERENCES FOR APPENDIX E
1.  D2013-72.  Standard Method of Preparing Coal Samples for Analysis.
    Annual Book of ASTM Standards, 1977.
2.  Silverman, L., et al .  Particle  Size Analysis  in Industrial Hygiene,
    Academic Press, New York, 1971.
                                 E-10

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                   APPENDIX F.



FUGITIVE EMISSIONS PUBLICATIONS CURRENTLY ON FILE

-------
      APPENDIX F.  FUGITIVE EMISSIONS PUBLICATIONS CURRENTLY ON  FILE
          The  following  pages  present  the  results  of  an  EPA  literature
search of fugitive PM10 emissions.
                                 F-l

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 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB.  NO.
CA Air  Fesou.-03-:
12/01/37
N/A
                               ": ~ z  o f  N e w = r. d  f*i oa : f i e a  3 * r> ~ : z ~. ^. ••
                               nd t'ev

                               os re

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                                           CONTACT     Meneoroker ,
                                           HARD COPY
                                                                    .- a\ men
 TITLE

 AUTHOR    Cusoinc.
SPONSOR    CA Air Fesourzes r:oard
DATE       06/01,31
PUB. NO.   AFP/F-31/133

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                                           CONTACT    N/A
                                           HARD  COPY
TITLE
AUTHOR

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           Measurement aria  Control of  Air Pollution Frodu.c = c b'.-  Hioni-ja
           Cor, = iruo- i on

           Sundcui.st. Carl  P.. Kenneth D. Pi r,k sr.Tian .  Earl  C. :=hirlev
           CA Deot. o-r  Tr ansoort At i on
           04/01/30
           TL-60414O
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               -sn i   ir  uuai-v    anwaro=  -or  ar i o_:  a = ;""ait=r:  ;-r.a
           and Air :- roor aiTi-=-: Fu-^i 1 1 '•• 5 Dus^  Fclic'-/ and  (-.sview  cr N.^ r i -n
           Secor.dar.-  Amoien~ Air  Guality  Stanoarc's  tor Part i cui ate .'•1r."
           P'r o p o sea  .- o 1 i o v 3 1 s t e m em  a n d  N o 1 1 o e o +  F' r c p o sad P u 1 e m a ^ : n a
                                                                            i=r
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           07/01/37
           FecJs.ral Feaister
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SPONSOR   EPA/CAQFS
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           Evaluation of  Contribution of Wind  Blown  Dust from  the De
           Levels of F'artioulate Matter in  Desert communities

          Reczrd.  Frank  A..  Lisa  A.  Bac:
          EPA/CAQFS
          OS/01/SO
          E F' A - 4 5 0 / 2 - 3 0 - O 7 3
                                          CONTRACTOR GCA
                                          CONTACT    N/A
                                          HARD  COPY
TITLE
AUTHOR

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          Air  Pollutant  Control Tsohnioues  for Crusr.eo Stone  and Br
          Industry

          Kothari. Atul.  and Fichard Gerstle
                                                                          cxsn 31 o ns
          EPA/OAQPS
          05/01/SO
          E P A - J. 3 0 / 7 - S 0 - 01 9
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                                          HARD  COPY
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          Development of  a Methodol oay and  Emission  Inventor-.'  for F-.
          Dust  for the  Regional Air  Pollution  Study

          Cowherd. Chatten.  and Christine Guenther
          EF'A/C'AOPS
          01/01/7C
          E p A - 4 3 O / - - 7 A — .-> O ~
                                          CONTRACTOR MRI
                                          CONTACT    N/A
                                          HARD  COPY
                                          F-2

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  V4/13.33
                            FUGITIVE  =.'.•'• I '•-• -= I C-r.:'r.  .- LrL !:.. AT l:
                                   -• >C - CT,,:-!  .-  -V I  - 7 ! CT
 TITLE
 PM1O '= I .= Development •.: u i c e 1 i r: e
 AUTHOR     NA

 SPONSOR    EPA/QAQFS/CFDD
 DATE       06/01/37
 PUB. NO.   EPA-450/2-5i-001
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                                HARD .'COPY   Y
 TITLE
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 SPONSOR
 DATE
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 Invest i gat i on  of  F'j.citi -.5  Dust: Volume  I  - '••Eources,  im: s
 Control
                                              =ione.  =nc
 Jutze,  Georse  and Kenneth  Axtsll
 EPA/OAQFS/CFDD
 06/01/74
 EPA-430/3-7 4-036-a
                CONTRACTOR PEDCo
                CONTACT    Dune ar.  Da.ii•F.
                HARD COPY  Y
 TITLE
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 SPONSOR
 DATE
 PUB. NO.
 Invest:cation  ot  Fucitivs  Dust:  Volume  II - Control  Str
 Regulatory Approach"

 J utre.  Get
anc! Kenneth Axetell
EPA/OAQPS/CFDD
06/01/74
EPA-430/3-74-03cb
                CONTRACTOR PEDCo
                CONTACT    Dunosr,  David P.-
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TITLE
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Control Techniques for Particulate Emissions from  Stationa.
Sources - '.'olume  1
N/A

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09/01/32
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Control  : ecnni'quss -For Part i cul at'e Emi s si ons f r o.n  Statior
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N/A

EPA/OAGPS/ESED
<~>9/<">i /32
EPA-450/3-e1-003b
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PUB.  NO.
Assessment and Control ot Chrvsotile Asbestos.Emissi ons
Poads

Serra.  Robert K. ,  and Michael  A.  Connor.  Jr.
                                             from U noa ve c
EPA/OAGPS/E5ED
OS/01/SI
EPA-4-o/.j.-.i 1 -006
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National  Air Pollution Control  Techni c-ues  Advisorv
Minutes of Meeting  - Decemcer  2 and 3,  193O
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01/14/31
N/A
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                CONTACT     Farmer.  Jack
                HARD COPY
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PUB.  NO.
Technical  Guidance  -for Control  of Industrial  Process  i-'j.c:
Particulars Emissions
Jutze,  George A. et  al

EPA/OAGFS/EEED
O3/01 ,'77
EPA-430/7-77-010
                CONTRACTOR PEDCo
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                HARD COPY  Y
                                          F-3

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  04.' 15'S3
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB.  NO.
           r^. _ _ —> —*.—_-  -M.—. .-.-_•}
                                      •E=r:=3 -  CfB User's  Manual
           A::etsll, Kenneth.  Jo-fin b. Watson,  Thompson  u-.  Face
           EPA/OAGFS/MDAD
           O5/01/S7
           EPA-450/4-33-014P
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                               CONTACT    Pace.  Thomp-so;
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           Ex amc 13 Mcceli.-ic:  to Illustrate  SIP Devel ooment -for  the
 AUTHOR    Anderson,  Michael, et ?.l

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 DATE      05/01/97
 PUB.  NO.   EPA-450/--S7-012
                                          CONTRACTOR TRC
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 PUB.  NO.
           Compilation ot Air  Pollutant Emission Factors - Volume  I:  btarionar
           F'oint and Area Sources
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           (")9/O i /S*
           AP-42
                               CONTRACTOR N/A
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                               HARD COPY
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PUB. NO.
R'eceotor  Mocel  :echnical  Series - A  Guide to the  Use of hac'Or
Analysis  ana Multiole Regression  (FA/MP)  seohniaues in Source
Apportionment
Kiov. Paul  J..  Theo.J. Kneio.  Joan.M.  Daisev
           EPA, OAQPS .  hD AD
           07/01/35
           EPA-450/ 4-S5-007
                               CONTRACTOR NYU Medical  Center
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                               HARD COPY
TITLE     PMl'O" and Fugitive Dust in  the Soutnwest  - Ambient  Impact. '=,01
           and Femedies          '            '-
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           Analvsi s
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          Receptor  Model Technical  Series -  Summary ot  Particle  Identification
          Techniques:  -'volume  IV

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          06/01 ,-83
          EPA-450/ 4-S."-'."'IS
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          Particulate ^..-issicn Factors tor  the Cons-ructio
                                                             on rioc-recate  ; - c .. = ~ r ••.
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          02/01 /S.T
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                               CONTACT     Soul
                               HARD COPY
nsr1 and.  James
                                         F-4

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                            FUr-iT:!. E EM IrSICN'S F L'BL I'I AT I ONS
                                  CL'RF.Er-J7LY  0:J FILE
 TTTLE     Characterization  cf  FM10 ?.no  i SF1 -ir Quality .-round  '.'.'-s = t =rn -zu
           Coal  Mines
AUTHOR     N/A

SPONSOR    EPA/OAGPS/MDAD
DATE       08/01/82
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                                           HARD ;EOPY
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           Receotor  Model  -ecnnical  3aries - Overview of F.eceptor Model
           Application  to  Particuiate  source Apportionment:   Volume I
           Core, John  E.

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           Assessment  of  Fugitive Part i-rui at e Emission r-actors  for
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           Zoller. .John M. .  and -2. Thomas Ps-rnke,  thomas A.  Janszsn
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           09/0i/~g
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           Guideline  for  Development  of  Control  Strategies  in.Areas
           Fuaitive Dust  Problems     •                  " .
          Richar 3.  George

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          10/01/77
          EPA-450/2-77-02=
                               CONTRACTOR TRW
                               CONTACT    Safriet.  -Dallas
                               HARD COP'-''
TITLE
           Quantification  o-f  Dust Entrainment -from F'aved Foacwavs
AUTHOR

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          Cowherd, Chatten.  and Christine M. Maxwell.  Daniel  W.  ••Jelson
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          07/O1/77
          EP A - 4 5 0 / 3-77-•:• 2 7
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          Performance  Evaluation Guide  for Laroe  Flow Ventilation 3vsterns
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          O 7 / O 1 / ft 4
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                               CONTACT
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AUTHOR

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          Orf.  D.J.. F:.W.  Gerstle, D.J.  Loud in
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          06/O1/S2
          EPA-34O/1-32-007
                               CONTRACTOR PEE-Co
                               CONTACT    Saunders.  Pamela
                               HARD  COPY
                                          F-5

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                           FUG IT I'. 'E  E:
                             Z C T .- f < O  C 1_l p j_

                             :TLr"~N  FILE
 TITLE
 Ferrous F o LI n d r y  I n •= o = c ~ : o n G LI i c e
 AUTHOR    Shah. P.,  A.  Trenholm

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PUB.  NO.
 Summary of Factors  Af-fsctina Compliance by Ferrous Foundries.
 Volume I - Text:  Final  Report

 Wallace, D. .  P. Quarles.  .= .  Kielty,  A.  Trenholm          .'  -
EPA/QACPS/SSCD
i.') 1 / 01 / S 1
EPA-340/1-50-O20
                                         CONTRACTOR MRI
                                         CONTACT    Saunaers.  Pamela
                                         HARD  COPY
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Contrcl  of Air E;7i:
Crushing Industry

N/A

EPA/OAQPS/'SSCD
O1/01/79
EPA-34O/1-79-002
                              ssi on 3 from Process Ocerations in tne  t-ock
                                          CONTRACTOR  JACA
                                          CONTACT     Saundsrs.  Pamela
                                          HARD COPY
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PUB.  NO.
Guidelines tor Evaluation  or Visible  Emissions  L=rtitication,
Field  Procedures. Legal  Aspects, and  Background Material

Missen.  Robert and  Arnold  Stein
EEPA/OAQFS/SSCD
04/01/75
EPA-340/1-73-007
                                         CONTRACTOR PES
                                         CONTACT    Malmbera,  'Kenneth  B.
                                         HARD COPY  Y       "   •
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PUB.  NO.
Eva.1 Liat i on' of. the Ef.f set i ve'ness .of Chemical Dust  Suppressants  on
Unpaved  Roads
Muleski.  G.E.. and C.  Cowherd

EPA/GRD/AEERL
11/01/37
E P A-6 00/2-37-102
                                         CONTRACTOR MRI
                                         CONTACT     McCr i11i s,  Rob ert  C.
                                         HARD COPY  Y
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PUB.  NO.
Project  Summary:  Pilot  Demonstration  of  th<
Fugitive Particle Control

Williams.  R.  Lockwood, and  Michael Duncan
ur t a i
                                                                          s t em -for
EPA/ORD/AEERL
03/01/S7
E F' A — 6 00 / S 7 — 3 6 — O 4 1
                                         CONTRACTOR A.P.T..  Inc.
                                         CONTACT     Harmon.  Dale
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PUB. NO,
Lime and  Cement Industrv Particuiate Emissions:
Report  -  Volume II.  Cement  Industry
                                                                   ce L,ate
Kinsey.

EPA/DRD/AEERL
02/01/37
EPA-600/7-S7-007
                                         CONTRACTOR  MRI
                                         CONTACT     Harmon.  Dale L.
                                         HARD COPY   Y
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PUB. NO.
Project  Summary:
Contrcl  Measure -for Material  Storage Piles

Zimmer,  Robert A., and Kenneth  A.-:etell.  Thomas C.  Ponder
EPA/OPD/AEERL
11/01/86
EPA-600/S7-86-027
                                         CONTRACTOR  REI
                                         CONTACT     Harmon.  Dale L.
                                         HARD COPY   Y
                                         F-6

-------
  r>4/ 1 3/98
                            FUGITIVE  "MISS I CMS c '- 'fL T C AT I QMS
                                  CURRENTLY  ON FILE
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
 Iron find cteei  Industry h'ar 11 cul ate tmissions:   Source  Latecorv
 Report
 Jeftery, John  and Joseph Vay

 EFA/CRD/AEERL
 10/O1/S6 •
 E P A-600/7-56-036
 CONTRACTOR GCA
 CONTACT    Harmon.  Dale L.
 HARD .'COPY  Y
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
 Critical F.'eyi ew  of  Goen Source F'articulate  Emission Measur ement s:
 Part II - .uield  Comparison

 P'yle,  Bobby E. and  Joseph D.  McCain                      .' .
 EPA/OPD/AEERL
 08/01/56
 ER'A-600/2-36-0/2
CONTRACTOR Southern  Research  I.nst.
CONTACT    McCrillis.  Pober-.C.
HARD COPY  Y
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
 Identification.  Assessment,  and Control of  Fugitive Particula~e
 tmissions

 Cowhera. Chatten.  and John  S.  Kinsey
 EPA/ORD/AEEPL
 08/01/36
 EPA-600/3-36-023
CONTRACTOR MRI
CONTACT    Harmon.  Dale L.
HARD  COPY  Y
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
Project Summary:   Technical  Manual  - Hood System Capture  c-f  Process
fugitive Particulate Emissions

K'ashdan. E.R..  and D.W. Coy.  J.H.  Spivey, T.  Cesta, H.D.  Goodfsilow
tPA/QPD/AEEPL
06/01/56
EPA-600/3 7-56-016
CONTRACTOR RTI
CONTACT    Harmon.  Dale L.
HARD  COPY  Y
 TITLE
 AUTHOR

 SPONSOR
•DATE
 PUB. NO.
F'roject Summary:   Size Specific  F'art i cul ate  Emi ssi on Factors  fcr
Industrial and Rural  Roads:   Source Cateoory F:eport
Cowherd.  Chatten  and Fhillio  J. -Enclehart
                                                                    i
EPA/CRD/AEEPL
<:> 1 / 01/56
EPA-60O/S7-S5-O51
CONTRACTOR MRI
CONTACT    Har.T.0,-.  Dale L.
HARD  COPY  Y
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB.  NO.
Project  Summary:   Performance  evaluation o-f  an  Improved 3t.-=e~
Sweeper

Duncan.  Michael, and  Poop Jain.  Shui-Chow Yung,  Por.ald Patterson
EPA/OPD/AEERL
O5/01/35
E P1 A - 6 0 0 / S 7 - a 3 - 0'!' 3
CONTRACTOR A.P.T..  Inc.  •
CONTACT     Harmon.  Dale  L
HARD  COPY  Y
TITLE
Paved  Road F'articulate Emissions. -  Source Category Pepor-
AUTHOR

SPONSOR
DATE
PUB.  NO.
Cowherd.  Chatten.  and  Phillip J.  Ena 1 ehart
EPA/CPD/AEERL
O7/O1/34
EPA-6OO/7-S4-O-7
CONTRACTOR MRI
CONTACT     Harmon. Dale L.
HARD COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
F'ro.iect  Summary;   Improved Street  Sweepers for  Controlling 'JrD
Innal ab 1 e F'articulate  Matter
Calvert,  Seymour, et  al

EPA/CPD/AEEPL
O4/01/S4
EPA-cOO/S7-S4-O2l
CONTRACTOR A.P.T..  Inc.
CONTACT     Kuykendal.  William »
HARD COPY   Y
                                          F-7

-------
  04.' 13/88
                                 "C'JRF.'ENTLr' ON FILE*
 TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Extended Evaluation  cf  Unoavsd F'oad  D
and  Steel In a u s t r y

Muleski, G.E., ana  Thomas Cuscino. Jr.,  Chatten  Cowherd.
EPA/ORD/AEERL
O2/01/84
EPA-iOO/2-34-O2/
          CONTRACTOR MRI
          CONTACT    McCr i 1 1 i s .  Robert:  C
          HARD -'COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
 I^ron  and Steel Plant  CD en source Fugitive Emission Control
 tvaluation

 Cuscino. Thomas and Grecory E. Muleski,  Chatten  Cowherd
EPA/ORD/AEERL
08/01/33
EPA-600/ 2 - 9 3 - 1 10
         CONTRACTOR MRI
         CONTACT    McCrillis.  RoPert
         HARD COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Demonstration ci the Use of charged  Poo  in Controllina Fuciti
•from Larae-Soale Industrial Sources
                                             -e Lust
Brook/nan,  Edward

ERA/ORD/AEERL
06/01/33
EPA-600/2-3 3-04 4
and Kevin
    Kelly

CONTRACTOR  TRC
CONTACT     N/A
HARD COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Third  Svmcosium on  the  iransfer and  Utilization  of  Farticulate
Control  Technology  -  Volume IV:  Atyoioal  Applications

Vanditti.  F.R. and  J.A.  Armstronc, M.  Durham
EPA/ORD/AEERL
07/01/82
EPA-600/9-S2—:>05d
         CONTRACTOR Denver  Research  Institute
         CONTACT    N/A
         HARD  COPY        .                ."
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Project  Summary:  Spray  Charging an
Particle b..r.i=sicn Control
                a  Traoping  Scrubber for  Fugitive
Yuna,  ShLii-Chcw, and  Julie Cur ran. Seymour Calvert-'
EPA/ORD/AEERL
12/01/31
EPA-600/S7-31-125
                                _.
         CONTACT    Drehmel,  Dennis C.
         HARD  COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
F'roceedi n cs :   Fourth Symposium on t-ucitive Emissions:
and Control (New Orleans,  LA,  May 1930)
Wibberley,  C.S., Compiler

EPA/CRD/'AEERL
12/01 /£•<:.'
E P A - A 0 0 / 9 - 3 0 - O 4 1
         CONTRACTOR TRC
         CONTACT    Harris.  D.  Bruce
         HARD COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Evaluation  of  Road Carpet  for Control of  Fuc-itive Emissions from
Unpaved  F:oads

Tackett.  K.M.,  and T.R. Elackwocd. W.H. Hedlsy
EPA/ORD/AEERL
]_ (') /('i 1 / .j('i
N/A"
         CONTRACTOR Monsanto  Research
         CONTACT     Drehmel.  Dennis C.
         HARD COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Second  Symposium on the Transfer and Utilization of  Particulate
Control  Technolcay:  Volume  IV - Special  Aoplications  for Air
Pollution  Measurement and  Control
Venditti,  F.R..  and J.A. Armstrona, Michael  Durham
EPA/ORD/AEERL
09/<"?! /£0
EPA-cOO/9-SO—:>3?d
         CONTRACTOR Denver Research Institute
         CONTACT     N/A
         HARD COPY
                                        F-8

-------
                                     cr M T c c j n f-15 F
                                     :•£• —IMTI  -^  MM tr
                                       J P!_ 7 I
 TITLE
           En v i r on merit si t-. = = = = SiT.>=nt ; f  Iron Castino
 AUTHOR    Baldwin,  V.H.

 SPONSOR   EP A / ORD /AEERL
 DATE      01/01/30
 PUB. NO.  EPA-600/2-30-021
                                CONTRACTOR  RTI
                                CONTACT     Hencriks. Pooert  '.'.
                                HARD -COPY
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
 Assessment of  Methods for  Control of Fugitive Emissions  from
 Roads

 Brookman, Edwars  T. .  ar,2 Deborah K. Martin
 EPA/ORD/AEERL
 11/01/79
 EPA-600/7-7 ?-2 39
CONTRACTOR TRC
CONTACT    Drehmel.  Denni's C.
HARD COPY
 TITLE
 Fuaitive Emi =3i on-B trom Iron  Foundries
 AUTHOR

 SPONSOR
 DATE
 PUB.  NO.
 Wallace. Dennis.   Chatter. Cowherd. Jr.
EPA/OPD/AEERL
08/01/7?
EPA-AOO/7-79-195
CONTRACTOR MRI
CONTACT    Hendriks.  Robert V.
HARD COPY
TITLE
Third SyiTipcsi urn  on  i-ucitive  Emissicns Measurement and Control
AUTHOR    King,  J..  Compi1er

SPONSOR   EPA/ORD/AEERL
DATE      08/01/79
PUB.  NO.  EPA-AOO/7-79-182
                                CONTRACTOR TRC
                                CONTACT    Harris.' D. Bruce
                                HARD COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Setting Priorities .-for Control  of Fugitive  Particu.iate tmi = sions
from  C5en. Sources

Cooper,  D.W.. and J. £.  Sullivan,  et al             •'
EPA/CPD/AEERL
08/01/79
EPA-cOO .'7-79-196
CONTRACTOR Harvard  Universitv
CONTACT    Drehmel .  Dennis C.
HARD  COPY
TITLE
Iron  and Steel Plant  Open Source Fugitive  Emission Evaluation
AUTHOR

SPONSOR
DATE
PUB.  NO.
Cowherd.  Chatten and  Russel Bonn,  Thomas Cuscino.  Jr.
EPA/QRD/AEERL
05/0i/79
EPA — iO<".'/ ^ — 79~ 1 O."\
CONTRACTOR MR I
CONTACT    Hendriks.  Robert '.'.
HARD  COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Assessment o-f Road  Carpet tor  Control of Fucitive Emissions  from
Unoaved  Roads
B1ac kwood.  T.R.

EPA/ORD/AEEFL
O5/01/79
E P A-60O/7-79-113
CONTRACTOR Monsanto  Fesearcn
CONTACT    Drehmel.  Dennis C.
HARD COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Symposium on the Transfer and Utilization of  Particulate Control
Techncl ogv:   '.'olume  4  - Fuaitive  Dusts and  Sampling.  Analv = :=  and
Characterization of  Aerosols
Vendditti, F.R., and J.A.  Armstrona,  Michael  Durham
EPA/ORD/AEERL
O-i'/01 / , 9
E F' A - 60 'I1 / 7 - 7 9 - 0 4 4 d
CONTACT
HARD COPY
                           h In
            Drehmel.  Dennis C.
                                          F-9

-------
   4/ 15/88
                           FUGITIVE EMISS
                               ICr:S FL'&LICATI
                               Y OM FILE
 TITLE
Assessment  of t~e L!3=  rr  i-ugitive Emission  control lev. ess
AUTHOR

SPONSOR
DATE
PUB.  NO.
Daugherty.  D.P. arid D.W.  Coy

EFA/ORD/AEERL
"><"'
EPA-600/7-79-O45

Particulate Control for Fuaitive Dust
CONTRACTOR RTI
CONTACT    Drenmel.
HARD .'COPY  Y
Dsnnis C
TITLE
AUTHOR    N/A

SPONSOR   EPA/ORD/AEEPL
DATE      04/01/78
PUB.  NO.   EFA-600/7-73-071
                               CONTRACTOR N/A
                               CONTACT    N/A
                               HARD COPY  Y
TITLE
Particulate Control for Fuaitive Dust
AUTHOR
Weant.  Georae E..  and Ben H.  Caroentsr
SPONSOR   EPA/ORD./AEERL
DATE      04/01/73
PUB.  NO.   EPA-600/7-73-O71
                               CONTRACTOR RTI
                               CONTACT    N/A
                               HARD COPY
TITLE
Fuaitive  Emissions from  Intscrated Iron and  Steel  Plants
AUTHOR

SPONSOR
DATE
PUB.  NO.
Bohn, Pussel  -and ihomas CO.scino,  Jr..  Chatten  Cowherd. Jr.
EPA/ORD/AEERL
03/01/73
EPA-600/2-78-O50
CONTRACTOR MRI
CONTACT    ' Hen dr i k s .  Rot sr t '.-'.
HARD COPY   Y
TITLE
 Second Symposium on. Pugiti've  Emissions:  Measurement and Control
AUTHOR     King,  J. ,  Commpiler

SPONSOR    ERA/GRD/AEERL
DATE       12/01/77
PUB.  NO.   EPA-600/7-77-148
                               CONTRACTOR TRC
                               CONTACT    Harris.  D.  Brucs
                               HARD COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Use of Electrostatically Cnarcsd  Foa for Control  of Fugitive  Dus-
Emissions
Hoenig, Stuart  A.

EPA/ORD/AEERL
11/01/77
EPA-600/7-77-131
CONTRACTOR  Arizona University
CONTACT     N/A
HARD COPY
TITLE
Development  of  F'roceduras for the  Measurement  of  Fugitive Emissions
AUTHOR

SPONSOR
DATE
PUB. NO.
Kalika. P.W.,  and P.E.  Kenson. P.T.  Bartlstt
EPA/ORD/AEEPL  •
12/01/7a
EPA-600/2-7A-284
CONTRACTOR  TRC
CONTACT     N/A
HARD COPY
TITLE
Symposium on  Fuaitive Emissions  Measurement and  Contro
AUTHOR     Helming,  E.M.. Compiler

SPONSOR    EPA/ORD/AEERL
DATE       09/01/76
PUB. NO.   EPA-600/2-76-246
                              CONTRACTOR TRC
                              CONTACT    Statnick.  Rc-Dsrt M.
                              HARD  COPY  Y
                                        F-10

-------
  04.* 13/33
                           FUGITIVE EMISSIONS PUBLICATIONS
                                 CURRENTLY  UN FILE
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
 Technical  Manual fcr  the  Measurement of  Fugitive Emission;
 Moni.tor Samolina Method for Inaustrial Fuaitive Emissions
 Kenson.  R.E. and R.T.  Partlett
 EFA/CRD/AEEF:L
 OS/'"'I /76
 EPA-600/2-76-OS9b
 CONTRACTOR TRC
 CONTACT    Statnick.  Robert M.
 HARD -'COPY  Y
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB. NO.
 Technical  Manual -for the  Measurement of Fucitive Emissions:
 Quasi-Stack Sampling Method  for Industr i al ~ Fu.gi t i ve Emissions

 Kolnsbero,  H.J. and P.M.  Kalika.  R.E. Kenscn,  W.A.  Marrone'
EPA/CRD/AEERL
05/01/76
E P A - & 0 0 / 2 - 7 i - 0 8 9 c
CONTRACTOR TRC
CONTACT    Statnick,  Robert M.
HARD  COPY  Y
 TITLE
 AUTHOR

 SPONSOR
 DATE
 PUB.  NO.
Technical  Manual for the  Measurement of Fugitive Emissions:
Upwind/Downwind Sampling  Method for Industrial  Emissions
Kolnsberg,  Henry J.

EPA/GRD/AEEFL.
04/01/76
EPA-600/2-76-089a
CONTRACTOR TRC
CONTACT    Statnick,  Robert M.
HARD  COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Windbreak Effectiveness  for  Storage Rile Fugitive Dust Control:
A  Wind  Tunnel Study

Bill man.  Barbara J., and  S.P.£.  Arva
EPA/ORD/ASRL
06/01/85
EPA-600/3-95-OS9
CONTRACTOR North Carolina  State Univ
CONTACT    Snyder, William H.     .  - •
HARD  COPY  Y                   • '
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Development of Measurement  Methodology for'Evaluating Fugitive
Particulate Emissions

Uthe.  Edward E. .  and John M Livinaston, et ai      /  -4
EPA/ORD/ASRL
05/01/91
EPA-600/2-81-07O
CONTRACTOR SRI International
CONTACT    N/A
HARD  COPY
TITLE
Dust  Transport in Maricopa  County,  Arizona
AUTHOR

SPONSOR
DATE
PUB.  NO.
Suck,  S.,  and E.  Upchurch,  J.  Erock
EPA/ORD/ASRL
09/01/79
EPA—60O/7—79—082
CONTRACTOR Universitv of  Texas
CONTACT     N/A
HARD COPY
TITLE
Regional  Air  Pollution Study:   Fugitive Dust Survey and Inventory
AUTHOR     Griscorn. Robert W.

SPONSOR    EPA/ORD/ASRL
DATE       O4/01/7S
PUB. NO.   EPA-cOO/4-73-020
                              CONTRACTOR Rockwell  International
                              CONTACT    N/A
                              HARD  COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
User's Guide:   Emission Control  Technologies and  Emission Factors
for Unpaved  Road  Fugitive Emissions
N/A

EPA/ORD/CERI
09/01/87
EPA-625/5-S7/022
CONTRACTOR  JACA
CONTACT     Kuluiian, Norman
HARD COPY   Y
                                        F-ll

-------
  04/15/33
                          FUGTTIVE  EMISS IONS F'L'E-L I CAT I
                                 CURRENTLY QN FILE
 TITLE
 User's  LTLUCS:   Fugitive Dust  Control  Demons" r at i en bturies
 AUTHOR    Beggs, Thomas W.

 SPONSOR   EFA/CRD/CERI
 DATE      01/01/85
 PUB.  NO.   EPA-600/8-S4-032
                               CONTRACTOR JACA
                               CONTACT    N/A
                               HARD .'COPY  Y
 TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
A  Method  tor Estimating Fugitive F'art i c.ul ate Emi ssi ons From
Hazardous Waste Sites
Turner,  James H.,  Marvin

EPA/ORD/CI
O9/01/S4
N/A
Branscome.  et  si

 CONTRACTOR RTI
 CONTACT     dePercin. Raul  P.
 HARD COPY   Y
TITLE
AUTHOR

SPONSOR
DATE
PUB.  NO.
Project  Summary:   Improved Emission Factors -for  Fugitive Dus
Western  Surface Coal Mining Sources

Axetell.  Kenneth,  and Chatten  Cowhers,  Jr.
                                  t  from
EPA/GRD/IEFL - CI
07/01/84
EPA-600/S7-34-048
 CONTRACTOR  MR I.
 CONTACT     N/A
 HARD COPY
TITLE
F'roject  Summary:   Fugitive Dust  -from Western Surface Coal Mines
AUTHOR

SPONSOR
DATE
PUB.  NO.
Cook.  Frank  and Ar1o Hendrikson,  L.  David Maxim.  Paul  R.. Saundsrs
EPA/ORD/IERL - CI
10/01/80
EPA-600/FS7-80-133
 CONTRACTOR Mathematics.  Inc.
 CONTACT    Bates,  Edward R.
 HARD COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Demonstration  o-f  Nonpoint Pollution  Abatement Throu.ah Improved-
Street Cleaning  Practices
Pitt. Robert

EPA/OPD/MERL
08/01/79
EPA-600/2-79-161
                                                                 i
 CONTRACTOR Woodward-Clvde
 CONTACT    N/A
 HARD COPY
TITLE
RACT Determination for Five Industrv Categories  in  Florida
AUTHOR

SPONSOR
DATE
PUB. NO.
Hawks. Ron  L.,  and  Steve P. Schlesser.  et al
EPA/Peaion  IV
11/Ol/SO
EFA-904/9-S1-O67
 CONTRACTOR PEI
 CONTACT    N/A
 HARD COPY
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
RACT-Level Control  Opacity Data for  Procsss and Non-Process
Fugitive Dust  Sources

Spawn, F'eter and  Matthew Sutton, Je-ftery E-ibeau. Tern  Fitzgerald
EPA/Pec ion V
07/01/S4
N/A
 CONTRACTOR GCA
 CONTACT    Dewey,  James A.
 HARD COPY  Y
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
Cost Estimates  -for  Selected Fuaitive  Dust Controls  Applied to
Unoaved and Paved Roads in Iron and Steel F'lants
N/A

EPA/Peaion V
04/26/34
N/A
 CONTRACTOR MRI
 CONTACT    MacDCwe11,  Wi11iam
 HARD COPY
                                       F-12

-------
  04 / 13/88
                                ii'T''E EMI c-£ I r'NS F UEL I CAT I CNS
                              !l    CURRENTLY ~ON FILE

 AUTHOR

 SPONSOR
 DATE
 TITLE
 AUTHOR
            ^n ''-'Deer.-,'  .  rnP'* i^r f-'-'-Qltiv- Dust  Emission  Sources:
            i-cm | n^  -j-   ''-• S  ^3.  Recommendations  and t;;amoles

            N/A

            EPA'. I'-eaion vv                   CONTRACTOR N/A
                                            CONTACT    Torres.  Lucien
                                            HARD -'COPY   Y
                nation o-f process Fuaitive Emissions in the  Major Non-Attai nms
               at- c.j:  Region y:   Volume  I

            Bh*< 1 a.  Vinod
 SPONSOR    EPA,f--:eQlon
 DATE       <-)._•./i M ,<=j-r~
 PUB. NO.   N/A   ' ""'
                                            CONTRACTOR RES
                                            CONTACT     N/A
                                            HARD COPY  Y
TITLE   '   Fugitive  Dust Emission Study


AUTHOR     Wil=on? A.L>

SPONSOR    EPA,-|:-s,n' -3n VI
DATE       02/i;.i/^°n  l
.PUB. NO.'. •EPA-'3r)£/o_7o_,.xj2
                                            CONTRACTOR Enaineerina-5cisnc=
                                            CONTACT     N/A
                                            HARD COPY
TITLE
           Con 1
                        Reentrai nsd Dust  -from R.aved Streets
AUTHOR
                    .  Kenneth  and Joan  Zel 1
SPONSOR    EA/|:-eaion.VII.
DATE
PUB.NQ.
                                            CONTRACTOR PEDCo
                                            CONTACT     Durst,  Dewayne
                                            HARD COPY   Y
TITLE


AUTHOR
TITLE
DATE
AUTHOR
            Sur\ pv- Q.f  i-uoitive  Dust -from  Coal Mines
                                            CONTRACTOR RE I
                                            CONTACT     N/A
                                            HARD COPY
           Axet=ll, Kenneth

           ,^£;A-M-eaion  VIII
           «Ji/».> j /7Q
       	EP'A-or.g/ 1-73-003

           Fugitive Dust  Emission  Inventory,  Wasatch.  Utah


AUTHOR    N/A

SPONSOR   EPA, |t
                                            CONTRACTOR REI
                                            CONTACT     N/A
                                            HARD COPY
                 eaion  VIII
           '.' / .' i.' ] _/ — tr

           E^~ ^'-'S/ 1 -76-001

           Fugihive Dust  Emissions  trom the. Proposed  Vienna  Unit No. ?
                 ^  Edw
-------
 04/15/33
                          FUGITIVE  EMI££IQN£ FUPLICATICNi
                                 CURRENTLY Of I FILE
TITLE
AUTHOR

SPONSOR
DATE
PUB. NO.
 Fort Carson Fugitive  Dust.  Generation and  transport •-•
 Learned

 Schanche, Garv W. .  and  Martin J. Sas'oi e
 U.S.  Army CERL
 1 1 / 01 / 9 1
 CERL-TR-N-117
CONTRACTOR N/A
CONTACT     N/A
HARD -COPY
TITLE
 Fuaitive Dust Emissions  -from Construction  Haul  Roses
AUTHOR     Struss.  3.R. and W.J. Mikucki

SPONSOR    U.S.  Army CERL
DATE       O2/01/'^
PUB. NO.   CERL-SB-N-17
                               CONTRACTOR N/A
                               CONTACT    N/A
                               HARD COPY
TITLE
 Dust Control tor Haul  Roads
AUTHOR

SPONSOR
DATE
PUB. NO.
 Bohn.  Russel. and Thomas  Cuscinc. Dennis Lane,  st al
 U.S.  Bureau of Mines
 O2/01/91
 BUM!NES-OFR-130-81
CONTRACTOR  MR I
CONTACT     N/A
HARD COPY
TITLE
 Fuaitivs Dust Studv  of  an  Ooen
      Coal  Mine
AUTHOR

SPONSOR
DATE
PUB. NO.
Marple.  Virgil, and Kenneth  Rubow.  Orville  Lantto
U.S.  Bureau of Mines
•O9/O1/3O
BUMINES-OFR-24-82
CONTRACTOR  Minnesota University
CONTACT     N./A
HARD COPY
  END OF REPORT

  Total Records  Printed =
                                         F-14

-------
    APPENDIX G.



EXAMPLE REGULATIONS

-------
                     APPENDIX G.  EXAMPLE REGULATIONS
     This appendix presents example regulations for the source categories
presented in Sections 2.0 through 7.0 of this manual.  Examples are
provided for:
     •  Joint Memorandum of Understanding
     •  Public Paved Roadways
     •  Industrial Paved Roadways
     •  Unpaved Roadways
     •  Storage Pile
     •  Construction/Demolition
     •  Open Areas
     •  Water Mining
                                 G-l

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EXAMPLE - JOINT MEMORANDUM OF UNDERSTANDING (MOU)
                     G-2

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[Note:  This MOU contains example  regulatory  language to supplement  that
        found  in the example  public  paved  road  regulation (page  G-8
        through 6-11.)]

                 EXAMPLE MOU TO CONTROL WINTERTIME SANDING
               AND OTHER PM10 EMISSIONS FROM PUBLIC ROADWAYS
                     JOINT MEMORANDUM OF UNDERSTANDING

     This JOINT MEMORANDUM OF UNDERSTANDING,  executed  this 	th
day 	198	  , by and between the CITY OF	, a municipal
corporation located in 	 County, State  of 	,
and the STATE OF 	.     DEPARTMENT OF ENVIRONMENTAL PROTECTION,
an agency of the State of 	  having  its principal office
in 	, County of 	, State of 	,
                                WITNESSETH;

     WHEREAS, recurring violations of the  Federal ambient air quality
standard for particulate matter having an  aerodynamic diameter less than
or equal to 10 microns (PM10) in the City  of 	•     the City
of      ^       and the State of     '	 Department of Environmental
Protection (DEP) have agreed to enter into a Joint Memorandum of
Understanding which will provide for attainment with Federal and State
PM10 standards as expeditiously as practicable, but not later
than      .	 198	  ; and

     WHEREAS, as a"result of monitoring done by the Department of
Environmental Protection showing violations of the State's ambient air
quality standards for PM10  (reference, e.g. Appendix A), the City
of 	 has agreed to develop  a control strategy to reduce
PM10 levels by implementing a downtown revitalization project (reference,
e.g. Appendix.B), by using coarse grained abrasive materials for the
wintertime road sanding operations, by vacuum sweeping streets to achieve
PM10 emission reductions; by controlling nearby erodible surfaces; and by
controlling mud/dirt carryout onto paved roads from unpaved parking lots
in the area.

     WHEREAS, both parties agree to operate and conduct said program in
accordance with the understandings expressed herein,

     NOW, THEREFORE, the City of 	 and the State
of 	 Department of Environmental  Protection,  through
their authorized representatives, enter into this Memorandum of
Understanding, as follows:

  I.  PURPOSE
      The purpose of this Memorandum is to:

      A.  Establish and set forth procedures and responsibilities for  each
          party to be followed in the implementation of the  agreed upon
          control strategy for the City of 	;  and


                                  G-3

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     B.   Establish and set  forth procedures  for  making a determination as
         to the effectiveness  of said control  strategy program.

II.  PROCEDURES AND RESPONSIBILITIES

     The procedures and responsibilities  of  the  parties under this
     Memorandum are as follows:

     A.   The City of 	 will,  beginning with the (year) winter
         season, restrict the  use of sand used for antiskid operations to
         a material with greater than x percent  (e.g.,  95 percent) grit
         retained by a number  100 mesh sieve screen  and a degradation
         factor of x.

         The material  will  be  tested in conjunction  with Department of
         Transportation, Division of Materials  and  Research,  to
         determine the degradation value  using standardized methods and
         the results will be reported to  the [DEP] no  later
         than 	,  198_.

         The City of 	 will provide  alternative traffic flow
         patterns, such as  a bypass plan  to  reduce vehicular traffic
         (especially truck  traffic),  in the  central  business district to
         reduce the effects of vehicular  reentrainment.

     B.   The City of 	 will  use the material  described in
         II.A.  on streets  within	 (area description,  e.g. one-
       , half mile radius of the  Main/State  Street intersection)  which
         include, as a minimum,  the following areas  (street names are
         shown for example  purposes):

          1.  Main Street - from  Maple Street to North  Street.

          2.  State Street  - from Third Street to State  Street  Place.

          3.  Mechanic Street  - from  State Street to include
              Industrial/Street.

          4.  Academy  Street - from Main  Street to Third Street.

          5.  Riverside Street -  from  Main Street to Chapman Street.

          6.  Chapman  Street - from Main  Street to Riverside Street.

          7.  Parsons  Street - from State Street to Park Street.

          8.  Dyer Street - from  State Street to Park Street.

          9.  Second Street -  from Academy Street to Blake  Street.

         10.  Third Street  - from  Academy Street to Blake Street.
                                G-4

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C.  The City of 	 will revegetate, pave, or treat by using
    water, calcium chloride, or acceptable equivalent materials  the
    following:  paved road shoulders and approach aprons for unpaved
    roads and parking areas that connect to paved roads, which are
    within the City's right-of-ways or under the City's control  and
    within X feet (e.g., 25) of roadways [specify location or entire
    roads by name], in amounts and frequencies as is necessary to
    effectively control PM10 emissions to a level of x percent
    control efficiency (e.g., paving—90 percent; vegetation per
    specified requirements—50 percent; chemical treatment per .   .
    specified requirements—70 percent).  [Include list of roads in
    memorandum of understanding and specify whether those areas will
    be revegetated, paved, or treated.]

D.  The City of 	will conduct its vacuum street
    sweeping throughout the year with wintertime sweeping done
    whenever shaded pavement temperatures as determined by the use
    of infrared thermometer—allow for the application of water
    spray from the vacuum sweeper.  The City of 	
    shall, based upon the expertise of 	 Department of
    Transportation Materials and Research Division Personnel,  gear
    the wintertime sweeping program to the pavement temperatures
    which will allow water spray on the streets without jeopardizing
    the safety of pedestrian and vehicular traffic on the swept
    areas.

    The street vacuuming program will  be designed to provide for
    maximum sweeping efforts throughout the winter and spring  months
    with less frequent sweeping done as the streets become  cleaner
    into the summer and fall  periods.   Street  sweeping shall  require
    cleaning the entire street, including the  driving lanes,  for  the
    removal of street sand from winter sanding and road  sealing,  and
    the removal of heavy street loadings due to other sources  of
    dirt and debris.

    As soon as temperature conditions  permit (melt periods), the
    City will begin vacuuming the  roads and/salt  loadings from
    streets listed under II.B.   The period  for completing vacuuming
    of said streets shall  not exceed x  days  (e.g.  2  days).   Street
    sweeping shall be done no less than x (e.g, monthly)  during the
    summer and fall  periods,  and shall  include  daily  cleaning  near
    areas where soil  material  is deposited  onto streets  from
    activities such as—but not limited to—construction  and
    excavation projects.

    The City of	  shall  submit 	  (e-g«,
    monthly) reports  to the [DEP],  due  30 days  from  the  end of the
    (month), which documents  the implementation of  the street
    sweeping requirements.   Reports  shall satisfy  the quality
    control provisions  for recordkeeping  and reporting requirements
    as identified in  Section  2.3.2.2 and  Appendix  C.2.1 of the
    Control of Open Fugitive  Dust  Sources.
                           G-5

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      E.  The City of 	 will,  upon the failure to reduce
          particulates to acceptable levels,  develop contingency plans of
          importing a better quality material  for wintertime sanding
          operations.

      F.  During the period of the program,  the [DEP]  will  maintain a
          particulate monitoring network—including TSP and Inhalable
          Particulates—designed to reflect  the status of ambient air
          quality and the effectiveness of the control strategy.

      G.  During the period of the program,  the [DEP]  will  provide the
          City of 	 with a 	 (e-9-  monthly)  summary of
          its air quality monitoring results,  including basic  findings
          which it construes to violate Federal ambient air quality
          standards.

      H.  Staff representatives of both the  City of	 and the [DEP]
          will meet at least once every 2 months to evaluate the
          effectiveness of the control  strategy and to determine whether
          alternative controls are needed.
                                              CITY OF  	

Date 	                 By 	
                                              STATE  OF 	
                                              DEPARTMENT  OF  ENVIRONMENTAL
                                              PROTECTION
Date 	.                           By
                                 6-6

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EXAMPLE - PUBLIC PAVED ROAD REGULATION



               NUMBER 1
               G-7

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                       PAVED  ROADS  AND  PARKING  AREAS
General Description
Description;  The purpose of  this rule is to reduce the amount of
particulate matter, especially the amount of fine particulate matter
(PM10), reentrained in the ambient air as a result of motor vehicle
traffic on paved roadways and to control  sources that are contributing to
particulate matter loadings on the roadways.
Definitions
a.  Dust:  Particulate matter, excluding  any material emitted directly in
    the exhaust of motor vehicles and other internal combustion engines.
b.  Particulate matter:  Any  material emitted or entrained into the air as
    liquid solid particles or gaseous material  which becomes liquid or
    solid particles at ambient temperatures.
c.  PM10:  Particulate matter with  an aerodynamic diameter of a nominal
    10 micrometers or less as measured  by reference or equivalent methods
    that meet the requirements specified  for PMlo in 40 CFR Part 50,
    Appendix J.
d.  Silt:  Fine particulate matter  that will pass through  a No.  200 sieve
    as measured using the "Procedures for Sampling Surface/Bulk  Materials"
    in Appendix D of the Control  of Open  Fugitive Dust Sources.
Requirements
a.  Mud/Dirt carryout:  No person shall cause or permit the handling or
    transporting or storage of any  material  in  a manner which  allows or
    may allow controllable particulate  matter to become airborne.   Dust
    emissions from the transportation of  materials must be  minimized by
    covering stock loads in openbodied  trucks or other equivalently
    effective controls.
b.  Motor vehicle parking areas:  Effective  	,  no  person  shall
    cause, permit, suffer, or allow the operation,  use,  or  maintenance  of
    an unsealed or unpaved motor  vehicle  parking  area.
    Low use parking area exemption:   Motor vehicle  parking  area
    requirements shall not apply  to  any parking  area from which  less
    than 	 (e.g., 10) vehicles  exit on each  day.  Any person  seeking
    such an exemption shall:   (1) submit  a petition to  the  Control  Officer
                                 G-8

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in writing identifying the location, ownership, and person(s)
responsible for control of the parking area, and indicating  the  nature
and extent of daily vehicle use; and (2) receive written approval  from
the regulating agency that a low use exemption has been granted.
Spills;  Earth or other material that is deposited by trucking and
earth-moving equipment on paved streets shall be reported to the
(local Department of Sanitation at 	) and removed within 	
 hours (example 8 hours) subject to safety considerations by the party
or person responsible for such deposits.
Erosion and entrainment from nearby areas:  If loose sand, dust, or
dust particles are found to contribute to excessive silt loadings on
nearby paved roads, the Control Officer shall notify the owner,
lessee, occupant, operator, or user of said land that said situation
is to be corrected within a specified period of time, dependent upon
the scope and extent of the problem, but in no case may such a period
of time exceed x days (e.g., 3 days).
The Control Officer, or a designated agent, after due notice, may
enter upon the subject land where said sand or dust problem exists,
and take such remedial and corrective action as may be deemed
appropriate to relieve, reduce, or remedy the existent dust condition,
where the owner, occupant, operator, or any tenant, lessee, or holder
of any possessory interest or right in the subject  land,  fails to do
so.
Any cost incurred in connection with any such remedial  or corrective
action by the Control Officer shall be assessed against  the owner of
the involved property, and failure to pay the full  amount of such
costs shall result in a lien against said real  property,  which lien
shall remain in full force and effect until  any and all  such costs
shall have been fully paid,  which shall  include,  but  not  be limited
to, costs of collection and reasonable attorney's fee  therefore.   (In
addition to recovering the costs of the  corrective  action,  the
regulatory agency may also want to have  the  ability to access a
penalty such as the ones listed in Table 1-2).
                              G-9

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EXAMPLE - INDUSTRIAL PAVED ROAD REGULATION
                G-10

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Regulation
     Paved roadway emissions shall be controlled to a level reflecting
x percent reduction of uncontrolled PM10 emissions.
Compliance Techniques
     Compliance with this regulation shall be determined using the
following:
     1.  Control efficiencies as given in Table 2-4; or
     2.  Silt sampling to establish the level of control performance
obtained for paved roadway controls.
     2a.  Silt sampling shall be performed in the manner described in
Appendix D, Section D.2 of this manual.  Analyses shall  comply with the
requirements of Appendix E of this manual.
     2b.  Level of control performance shall be established by silt
loading sampling as follows:
     i.    Sampling shall be taken of the source in its  uncontrolled state
     ii.   Sampling shall be taken after control  application (sL2);
     iii.  Sampling, shall be taken prior to reapplication of control
(sL3); and
     iv.   Average control  efficiency (in %) shall  be  calculated  as
follows:

                   100% x  i-4
1
1 l
1 2 '
^*
•H
SL,
;
0.3
+
sL31
[SLlJ
1
[Note that if this rule was applied  to  urban  roadways,  a 0.8  (rather  than
0.3) power would be used in the calculation.]
                                 G-ll

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EXAMPLE - ROAD REGULATION
        6-12

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                      REGULATION  4—PARTICULATE MATTER
                            RULE—UNPAVED ROADS

General Description
a.  Description;  The purpose of this rule  is  to  reduce the  amount  of
    particulate matter, especially the amount  of  fine particulate  (PM10)
    entrained  in the ambient air as a result of emissions from  unpaved
    roads.
Definitions
a.  For the purpose of this rule, public unpaved  roads shall be defined as
    an unsealed or unpaved open way used by motor vehicles maintained for
    general public travel.
b.  For the purpose of this rule, Haul Road shall be defined as an  open
    way used by motor vehicles to transport materials to, from, and/or
    within a work site that is not covered with one of the following:
    concrete, asphaltic concrete, asphalt, or other materials, as
    specified by the air pollution control officer (APCO).
c.  Dust;  Particulate matter, excluding any materials emitted directly in
    the exhaust of motor vehicles and other internal combustion engines,
    from portable brazing, soldering  or.welding equipment, and from
    piledrivers.
d..  Particulate matter;  Any material  emitted or entrained into the air as
    liquid or solid particles.
e.  PM10:  Particulate matter with an aerodynamic diameter of a nominal
    10 micrometers or less as measured by reference or equivalent methods
    that meet the requirements specified  for PM10  in 40  CFR  Part 50,
    Appendix J.
f.  Reasonably available dust control  measures:  Techniques  used to
    prevent the emission and/or airborne  transport of dust and  dirt from
    an unpaved road including:   application of  water or  other liquids,
    covering, paving, enclosing,  shrouding,  compacting,  stabilizing,
    planting, cleaning, or such other  measures  the APCO  may  specify  to
    accomplish equal  or greater control.
                                 G-13

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Requirements
a.  Public unpaved roads:
    1.  The APCO may require any person to undertake reasonably  available
        dust control measures to mitigate mass PM10 emissions from  public
        unpaved roads.  The dust control measures may only be required  or
        amended on the basis of substantial  evidence that the mass
        emissions from the public unpaved roads causes or contributes to
        violations of the Federal ambient air quality standard for  PM10.
    2.  Upon making the determination that dust control measures are
        required, the APCO shall require any person who maintains public
        unpaved roads of more than x (e.g.,  50) feet in length, unless  no
        more than x (e.g., 10)  vehicular trips are made on such unpaved
        roads and vehicular speeds do not exceed x (e.g., 35) miles per
        hour, to submit a dust  control  plan  which demonstrates an
        overall x percent (e.g., 75 percent) reduction of PM10 emissions
        by applying reasonably  available control  measures.
b.  Haul roads:
    1.  No person shall allow the operation, use, or maintenance of any
        unpaved or unsealed haul road of more than x (e.g.,  50)  feet in
        length at any work site engaged in any manufacturing or
        commercial-related activity,  unless  no more than  x (e.g., 10)
        vehicular trips are made on such haul  road per day and vehicular
        speeds do not exceed x  (e.g., 10)  miles per hour.
    2.  The owner and/or operator is  in possession of a currently valid
       • permit which has been issued  by the  APCO.
Record Control Application
The owner and/or operator shall  record  the evidence of  the application of
the control measures.   Records  shall  be submitted  upon  request from  the
APCO, and shall be open for inspection  during  unscheduled  audits.
                                 G-14

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EXAMPLE - STORAGE PILE  REGULATION
            G-15

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                     REGULATION 4—PARTICULATE MATTER
                     RULE-STORAGE OF  BULK  MATERIALS
General
a.  The purpose of this Rule is  to reduce the amount of particulate
    matter, especially the amount of fine particulate matter (PM10),
    entrained in the ambient air related to the loading or unloading of
    open storage piles of bulk materials.
Definitions
a.  For the purpose of this rule, open storage piles of bulk materials,
    hereinafter referred to as "storage piles",  are  defined as follows:
    1.  All storage piles of the material at a manufacturing or commercial
        location which have a total  volume of more than x (e.g., 100)
        cubic meters,  or,
    2.  Any storage piles at a manufacturing or  commercial  location having
        a total  annual volumetric throughput of  all  stored  material of
        more than x (e.g., 10,000)  cubic meters, or,
    3.  Any single storage pile  at  a manufacturing or commercial location
        having a volume of x (e.g.,  42)  cubic meters.
b.  Storage pile related activities:   Defined as the  loading,  unloading,
    conveyance or transporting of bulk materials at  a manufacturing or
    commercial location.
c.  Disturbed surface:  A portion of  the earth's surface, or materials
    placed thereon, which has been physically moved,  uncovered,
    destabilized, subdivided, or otherwise  modified,  thereby increasing
    the potential for  e'mission of dust and  dirt.
d.  Dust:  Particulate matter, excluding any  materials  emitted directly in
    the exhaust  of motor vehicles and  other  internal   combustion  engines,
    from portable brazing,  soldering  or  welding equipment, and from
    piledrivers.
e.  Dust control  implements:  Tools,  machines, and supplies  adequate  to
    prevent entrainment  of  dust  in ambient air, and to prevent dirt or
    other material  from  being tracked  or  dropped onto public roads  from
    motor vehicles leaving  the work site.
                                G-16

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f.  Particulate matter;  Any material emitted or entrained  into  the air as
    liquid or solid particles.
g.  PM10:  Participate matter with an aerodynamic diameter  of  a  nominal
    10 micrometers or less as measured by reference or equivalent  methods
    that meet the requirements specified for PM10 in 40 CFR Part 50,
    Appendix J.
h.  Reasonably available dust control measures:  Techniques used to
    prevent the emission and/or airborne transport of dust  and dirt from
    storage piles including:  application of water or other liquids,
    covering, paving, enclosing, shrouding, compacting, stabilizing,
    planting, cleaning, or such other measures the Air Pollution Control
    Officer (APCO) may specify to accomplish equal  or greater control.
i.  Unsealed or unpaved haul road:  An open way used by motor vehicle to
    transport materials to, from, and/or within a work site that is not
    covered with one of the following:  concrete,  asphaltic concrete,
    asphalt, or other materials as specified by the  APCO.
Requirements
a.  No person shall  engage in the storing,  loading,  unloading,  conveying
    or transporting  of bulk materials unless a dust  control  plan is
    approved by the  APCO which demonstrates  that an  overall  x percent
    (e.g.,  75 percent) reduction of  PM10  emissions from storage piles and
    related activities will  be achieved  by  reasonably  available
    measures.  Such  measures may include, but are not  limited to, the
    following:   application of water  or  chemical  suppressants,  application
    of wind breaks or wind fences, enclosure of  the  storage  piles,
    enclosure of conveyor belts,  minimizing  material drop  at transfer
    point,  securing  loads and  cleaning vehicles  leaving worksite, and
    other means  as specified  by  the APCO.
b.  The owner/operator is in  possession of a currently  valid permit which
    has been  issued  by the APCO.
Control Mud/Dirt Carryout
a.  Street  cleaning:   No  person  shall engage in any dust-producing  storage
    pile related activity at  any work  site unless the paved  streets
    (including  shoulders)  adjacent to the site where the storage pile-
    related activity  occurs  are cleaned at a frequency of  not less  than  x
    (e.g.,  once)  a day unless:
                                 6-17

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    1.  Vehicles do not pass from the work site onto adjacent paved
        streets, or
    2.  Vehicles that do pass from the work site into adjacent paved
        streets are cleaned and have loads secured to effectively prevent
        the carryout of dirt or mud onto paved street surfaces.
Haul Roads
No personal shall allow the operation, use, or maintenance of any unpaved
or unsealed haul road of more than x (e.g., 50) feet in length at any work
site engaged in any storage pile-related activity, unless no more than x
(e.g., 10) vehicular trips are made on such haul  road per day and
vehicular speeds do not exceed x (e.g.,  10) miles per hour.
Stabilization of Soils at Work Sites
No owner and/or operator shall allow a disturbed  surface site to remain
subject to wind erosion for a period is  excess of x (e.g., 1) months after
initial disturbance of the soil  surface  or construction related activity
without applying all reasonably available dust control  measures necessary
to prevent the transport  of dust or dirt beyond  the property line.   Such
measures may include,  but need not be limited  to:   sealing, revegetating,
or otherwise stabilizing the soil  surface.      -
Record Control Application                                     .
The owner and/or operator shall  record the  evidence of  the application of
the control measures.   Records shall  be  submitted  upon  request  from  APCO,
and shall  be open for  inspection during  unscheduled audits.
                                G-18

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EXAMPLE - CONSTRUCTION/DEMOLITION REGULATION
                  G-19

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                     REGULATION 4—PARTICULATE MATTER
               RULE—CONSTRUCTION AND DEMOLITION ACTIVITIES

General Description
a.  Description;   The purpose of this Rule is to reduce the amount  of
    particulate matter, especially the amount of fine particulate matter
    (PM10) entrained in the ambient air as a result of construction and/or
    demolition related activities.
Exemptions
The following projects and activities are exempt from the requirements  of
this Rule:
a.  Buildings or  other improvements with combined floorspace less than  x
    (e.g., 3,000) square feet.
b.  Disturbed surface areas less than x (e.g.,  4,000)  square feet.
c.  Any construction-related activity occurring entirely within an
    enclosure from which no visible particulate matter escapes.
Definitions
a.  Construction  and/or demolition-related activity;   Any onsite
    mechanical activity preparatory to or related to  the building,
    alteration, maintenance, or  demolition of an  improvement on real
    property, including:  grading,  excavation,  filling,  transport and
    mixing of materials, loading,  crushing,  cutting,  planning,  shaping,
    breaking, or  spraying.
b.  Disturbed surface:   A portion  of  the earth's  surface,  or materials
    placed thereon, which has been  physically moved, uncovered,
    destabilized, subdivided, or otherwise modified, thereby increasing
    the potential for emission of  dust  and dirt.
c.  Dust;   Particulate  matter, excluding any  materials emitted  directly in
    the exhaust of motor vehicles  and other  internal combustion engines,
    from portable brazing,  soldering or  welding equipment,  and  from
    piledrivers.
d.  Dust control  implements:  Tools, machines,  and supplies  adequate to
    prevent entrainment  of  dust  in ambient air, and to prevent  dirt  or
    other  material  from  being tracked or dropped onto public roads from
    motor  vehicles  leaving  the work site.

                                G-20

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e.  Particulate matter;  Any material emitted or  entrained  into  the air as
    liquid or  solid particles.
f.  PMi0:  Participate matter with an aerodynamic diameter  of  a  nominal
    10 micrometers or less as measured by reference or equivalent  methods
    that meet  the requirements specified for PM10 in 40 CFR  Part 50,
    Appendix J.
g.  Reasonably available dust control measures;   Techniques  used to .
    prevent the emission and/or airborne transport of dust and dirt from  a
    site including:  application of water or other liquids,  covering,
    paving, enclosing, shrouding, compacting, stabilizing, planting,
    cleaning, or such other measures the Air Pollution Control Officer
    (APCO) may specify to accomplish equal or greater control.
h.  Site;  The real property upon which construction and/or demolition
    related activity occurs.
i.  Unsealed or unpaved haul road;  An open way used by motor vehicle to
    transport materials to, from, and/or within a work site that is not
    covered with one of the following:  concrete, asphaltic concrete,
    asphalt, or other materials as specified by the APCO.
Conditions for Construction and/or Demolition                   .
No person shall engage in any construction-related activity at any  work
site unless all of the following  conditions  are  satisfied:
a.  Dust control  implements in good working  condition  are  available at the
    site, including water supply  and distribution equipment adequate to
    wet any disturbed surface areas and  any  building part  up to a height
    of 60 feet above grade.
b.  A dust control  plan  is  approved by the APCO  which demonstrates  that an
    overall x percent (e.g.,  75 percent)  reduction of PM10  emissions from
    construction/demolition and related  activities will be  achieved by
    applying reasonably  available  control measures.  Such measures  may
    include,  but  need not be  limited  to  the  following:  application of
    water or other  liquids  during  dust-producing mechanical  activities
    including earth  moving  and  demolition operations; application of water
    or other liquids  to  or  chemical  stabilization  of, disturbed surface
    areas;  surrounding the  work site  with wind breaks to reduce surface
    erosion;  restricting  the  access of motor vehicles on the  work site;

                                 G-21

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    securing loads and cleaning vehicles leaving the work  site;  enclosing
    spraying operations; and other means, as specified  by  the APCO.
c.  The owner and/or operator is in possession of a currently valid  permit
    which has been issued by the APCO.  (Example permit attached,  see
    Figure 5-9).
Control Mud/Dirt Carryout
a.  Street cleaning:  No person shall engage in any dust-producing
    construction related activity at any work site unless  the paved
    streets (including shoulders) adjacent to the site where  the
    construction-related activity occurs are cleaned at a  frequency  of not
    less than x (e.g., once) a day unless:
    1.  Vehicles do not pass from the work site onto adjacent paved
        streets, or
    2.  Vehicles that do pass from the work site onto adjacent paved
        streets are cleaned and have loads  secured to effectively  prevent
        the carryout of dirt or mud onto paved  street surfaces.
Haul Roads
No person shall allow the operation, use or maintenance of any unpaved  or
unsealed haul road of more than x (e.g., 50) feet in length at any work
site engaged in any construction-related activity,  unless  no more than  x
(e.,g., 10) vehicular trips are made on such  haul  road per  day and
vehicular speeds do not exceed x (e.g.,  10)  miles per hour.
Stabilization of Soils at Work Sites
No owner and/or operator shall  allow a disturbed  surface site to remain
subject to wind erosion for a period in  excess  of x  (e.g.,  1)  months after
initial disturbance of the soil  surface  or construction  related activity
without applying all  reasonably available dust  control measures necessary
to prevent the transport of dust or dirt beyond the  property line.   Such
measures may include,  but need  not  be  limited to:  sealing, revegetating,
or otherwise stabilizing the soil surface.
Record Control  Application
The owner and/or operator shall  record the evidence  of the  application of
the control  measures.   Records  shall be  submitted upon request from APCO,
and shall  be open  for  inspection  during  unscheduled  audits.
                                 G-22

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Modifications of Permit Provisions
The provisions of this permit may be modified after sufficient
construction is completed by the mutual consent of the APCO and the
permittee; or, by the APCO if it determines that the stipulated controls
are inadequate.  Deviations from the dust control  plan (e.g., increased
source activity) may result in modifications to the permit.
                                G-23

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EXAMPLE - OPEN AREA REGULATION
           G-24

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                     REGULATION  4—PARTICULATE  MATTER
                     RULE—OPEN AREAS OF FUGITIVE DUST

General
a.  The purpose of this Rule is to reduce the amount  of particulate
    matter, especially the amount of fine particulate matter  (PM10),
    entrained in the ambient air as a result of emissions from open areas.
Definitions
a.  For the purposes of this rule, an open area is an exposed ground area
    on public property, private real  property or within an industrial or
    commercial facility subject to wind erosion, which causes particulate
    matter emissions.
b.  Dust;  Particulate matter,  excluding any materials emitted directly in
    the exhaust of motor vehicles and other internal combustion engines,
    from portable brazing, soldering  or welding equipment, and from
    piledrivers.
c.  Particulate matter;  Any material emitted or entrained into the air as
    liquid or solid particles.
d.  PM10:  Particulate matter with an aerodynamic diameter of  a nominal
    10 micrometers or less as measured by reference or equivalent methods
    that meet the requirements  specified for PM10 in 40 CFR Part  50,
    Appendix J.
e.  Reasonably available dust control measures;   Techniques  used  to
    prevent the emission and/or airborne transport of  dust and dirt from
    an open area including;  application of  water or other liquids,
    covering, paving, enclosing,  shrouding,  compacting,  stabilizing,
    planting, cleaning, or such other measures  the Air Pollution  Control
    Officer (APCO)  may  specify  to accomplish  equal  or  greater  control.
Requirements
a.  Parking lots,  truck stops,  driving,  etc.;
    1.  No person shall operate,  maintain, use,  or permit  the  use  of any
        area larger than x (e.g.,  5,000)  square  feet for the parking
        storage, or servicing of  more than x  (e.g.,  6). vehicles in  any one
        day, unless a dust control plan  is approved  by the APCO which
        demonstrates an overall  x  (e.g.,  75)  percent reduction of  PMlo

                                 G-25

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        emissions from such  an  area will  be achieved by reasonably
        available measures.   Such  measures may include, but are not
        limited to,  adequate use of chemical  dust suppressants,
        application  of water, paving and  other means,  as specified by the
        APCO.
b.  Vacant lots;
    1.   No person shall  disturb or removal soil  or natural  cover from any
        area larger  than x  (e.g.,  5)  acres and cause or permit the area to
        remain undeveloped for  a period  in excess of x (e.g.,  1) months,
        unless a dust control plan is approved by the  APCO  which
        demonstrates an  overall x  (e.g.,  75)  reduction of PM10 emissions
        from such an area will  be  achieved by reasonable available
        measures. Such  measures may include, but are  not limited to,
        application  of adequate chemical  dust suppressants, enclosures,
        revegetation and other  means,  as  specified by  the APCO.
    2.   No person shall  cause,  suffer, allow  or  permit a vacant lot,  or an
        urban or suburban open  area,  to be driven over or used by motor
        vehicles, trucks, cars, cycles, bikes, or buggies,  unless a dust
        control plan is  approved by -the APCO, which  demonstrates an
        overall x (e.g., 75)  percent  reduction of PM10  emissions from such
        an open area will be achieved  by  reasonably  available  measures.
        Such measures may include,  but are not limited  to,  adequate use of
        chemical dust suppressants,  application  of water, paving,  barring
        access, and  other means, as  specified by the APCO.
c.  Off-road vehicles;   No person  shall cause, permit,  or allow  the
    conduct of off-road  vehicle racing.or  motorcross racing within  the
    designated boundaries of the Group I  area unless adequate  dust  control
    measures are provided and approved in  advance  by the Control
    Officer.  Motorcross racing will only  be  permitted  at a permanent
    motorcross race  course within  the nonattainment area.   Permanent
    motorcross race  courses  shall  be registered with and permitted  by the
    Control Officer.
                                G-26

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d.  Industrial, manufacturing and commercial staging areas:
    1.  No personal shall allow the operation, use or maintenance of an
        industrial, manufacturing or commercial staging area larger than x
        (e.g., 5,000) square feet, unless a dust control plan is approved
        by the APCO which demonstrates an overall x (e.g., 75 percent)
        reduction of PM10 emissions from the staging area will be achieved
        by reasonably available measures.  Such measures may include,, but
        are not limited to, adequate use of chemical suppressants,
        application of water, paving and other means,  as specified by the
        APCO.
Record Control Application
The owner and/or operator shall  record the evidence of the application of
the control measures.  Records shall be submitted upon request from APCO,
and shall  be open for inspection during unscheduled audits.
                                 G-27

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EXAMPLE - OPEN  AREA REGULATION (WATER MINING)
                  G-28

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                      REGULATION  4—PARTICULATE  MATTER
                       RULE—WATER MINING ACTIVITIES

General
a.  The purpose of this Rule is  to reduce the amount  of particulate
    matter, especially fine particulate matter  (PM10) entrained  in the
    ambient air related to water mining activities.                  .
Definitions
a.  For the purpose of this Rule, water mining  activities are defined as
    those activities related to  the production, diversion, storage or
    conveyance of water which has been developed for  export purposes.
b.  Dust:  Particulate matter, excluding any materials emitted directly in
    the exhaust of motor vehicles and other internal  combustion  engines,
    from portable brazing, soldering or welding equipment, and from
    piledrivers.
c.  Particulate matter;  Any material emitted or entrained into  the air as
    liquid or solid particles
d.  PMioJ  Particulate matter with an aerodynamic diameter of a  nominal
    10 micrometers or less as measured by reference or equivalent methods
    that meet the requirements specified for PM10 in 40 CFR Part 50,
    Appendix J.
e.  Reasonably available dust control measures:   Techniques used to
    prevent the emission and/or airborne transport of dust and dirt from
    water mining activities including:  application of water or other
    liquids, covering, paving,  enclosing,  shrouding, compacting,
    stabilizing, planting, cleaning,  or such other measures the Air
    Pollution Control Officer (APCO)  may specify to accomplish equal  or
    greater control.
Requirements
No person shall engage in any water mining  activity unless all  of the
following conditions  are satisfied:
a.  A dust control plan is approved by the  APCO  which  demonstrates that  an
    overall  x (e.g.,  75)  percent  reduction  from  water  mining  activities
    will be achieved  by applying  reasonably  available  control  measures.
    Such measures may include,  but are not  limited  to, revegetation,

                                 G-29

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    chemical stabilization,  application of wind fences and other means as
    specified by the APCO.
b.  The owner/operator is in possession of a currently valid permit which
    has been issued by the APCO.
Record Control  Application
The owner and/or operator shall  record  the evidence of the application of
the control  measures.  Records  shall  be submitted  upon request from APCO,
and shall be open for inspection  during unscheduled audits.
                                G-30

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    APPENDIX H.



FOOD SECURITIES ACT

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                      APPENDIX H.  FOOD SECURITY ACT

     Several provisions of the Food Security Act of 1985 encourage the
reduction of soil erosion on highly erodible cropland.  The provisions are
known as the Conservation Reserve, Conservation Compliance and
Sodbuster.  Under the Conservation Reserve, the Agricultural Stabilization
and Conservation Service (ASCS) will share costs of retiring highly erod-
ible cropland by establishing permanent ground cover and making annual
rental payments on the converted cropland.
     Conservation Compliance and Sodbuster are provisions that discourage
the production of crops on highly erodible land if the land is not
protected from erosion.  Conservation Compliance asks farmers to develop a
soil conservation plan by January 1, 1990, to remain eligible for certain
U.S. Department of Agriculture (USDA) program benefits not just on the
highly erodible part, but on all the land farmed.  Under the Sodbuster
provision, a farmer will lose USDA program benefits unless he follows a
conservation plan if he plows highly erodible land not recently used for
crop production.
     More than one in every four U^S. cropland acres is considered highly
erodible by water and wind.  The Soil Conservation Service (SCS) estimates
there are 344 million acres of "highly erodibVe" land.  Of this total, 118
million acres are cropland.  In all, almost 25 percent of the agricultural
land total in the U.S. is considered "highly erodible."  See Table H-l for
a summary.  Of these, more than 70 percent currently have annual water and
wind erosion rates higher than the natural rate of soil replacement.
     For land to be considered "highly erodible," potential  maximum
erosion must be more than eight times the rate at which the  soil can main-
tain continued productivity.  For individual  farm fields, one-third or at
least 50 acres must be rated "highly erodible" for the entire field to be
classified as such.  The SCS determines if a field is  "highly erodible" by
consulting soil maps or by visiting the site.   SCS representatives predict
potential erosion using the Universal Soil Loss Equation for water and the
Wind Erosion Equation for wind.
                                  H-l

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TABLE H-l.   HIGHLY ERODIBLE LAND IN THE UNITED STATES (EXCLUDING ALASKA)
            Source:  SCS  1982  National Resources  Inventory


STATE
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
. . Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
TOTAL
HIGHLY
ERODIBLE
CROPLAND
1,406,800
1,103,500
724,600
756,400
6,124,800
69,900
22,600
202,500
1,083,100
130,600
2,649,500
4,108,800
2,203,200
8,214,800
10,594,600
3,140,800
288,100
248,800
641,500
101,200
617,800
1,636,100
1,786,100
6,298,900
9,558,100
6,632,200
75,900
3-5,100
214,400
1,593,000
1,994,300
1,717,200
2,271,500
2,347,700
4,699,200
969,000
3,780,800
256,800
3,900
469,700
1,703,400
2,513,100
13,903,000
615,000
196,100
1,612,900
2,396,100
605,900
3,421,800
174,500
117,915,600
HIGHLY ERODIBLE AGRICULTURAL
LAND WITH POTENTIAL
FOR
CONVERSION TO CROPLAND
6,150,400
5^237,900
6,719,900
4,493,700
8,019,100
373,800
85,900
860,700
5,632,800
460,800
2,258,000
2,229,300
1,836,300
2,704,300
5,665,200
4,501,100
4,072,400
4,891,300
981,900
405,900
1,902,400
1,721,700
3,443,600
8,161,900
12,524,500
12,853,500
759,000 .
792,500
292,500
5,879,100
4,793,900
5,527,000
3,317,500 .
3,064,800
9,368,700
3,158,100
4,829,300
259,000
123,600
2,388,000
6,383,100
6,001,900
35,589, 100
1,077,600
1,166,600
5,813,200
3,649,100
3,202,800
3,179,000
6,943,300
225,747,000





































                                H-2

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     Potential crop acreage eligible for the Conservation Reserve Program
is illustrated in Figure H-l for 1986.  A conservation reserve of 40 to
45 million acres will be established by 1990.  Highly erodible cropland
acreage will be placed into the reserve at the rates shown in Table H-2.
Where practicable, at least one-eighth of the total conservation reserve
acreage should be devoted to trees.  Priority will be given, where appro-
priate, to the establishment of shelterbelts, windbreaks, stream borders,
filter strips of permanent grass, or trees that significantly reduce
erosion.  By June 1988, over 25 million acres of U.S. cropland had been
committed to the Conservation Reserve Program.  Table H-3 presents number
of CRP contracts, contracted acreages, and erosion reduction figures by
state.  However, these figures do not distinguish between wind and water
erosion.
                                 H-3

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Share of State's
Total Cropland
          0  -
     5  percent
5-10  percent
10. - 15 percent
15-20 percent
20 - 30 percent
30 percent and over
           Figure H-l.  Cropland eligible  for the Conservation Reserve,  1986.

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       TABLE  H-2.   CONSERVATION  RESERVE  ACREAGE,  CROP YEARS 1986-90

  Range           1986         1987         1988         1989         1990

                   	Million acres	

Minimum*            5           15           25           35           40
Maximum            45           45           45           45           45

aThe Secretary may reduce the number of acres placed in the reserve by up
 to 25 percent if rental payments are expected to be significantly lower
 in the following year.
                                 H-5

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TABLE  H-3.  CONSERVATION RESERVE PROGRAM:  ALL  SIGNUPS  (1-6)
           EROSION  REDUCTION  ON CRP  ACRES  BY  STATE*
State
ALABAMA
ALASKA
ARKANSAS
CALIFORNIA
COLORADO
DELAWARE
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
. NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
CARIBBEAN
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
CRP
Contraccs
7,057
36
2,068
402
5,015
16
1,620
10,398
I
2,758
9,013
5,313
2', 371
22,137
6,227
998
623
242
2
3,123
'20,315
3,742
15,958
5,401
9,912
4 '
16
1,'422
1,083
4,093
10,098
3,439
6,565
1,736
1,579
5
4,709
6,137
7,73.9
13,951
872
3
1,930
3,373
25
11,232
645
Contracted
Acres
435,153
24,374
155,673
157,574
1,674,322
i52
92,353
511,737
85
668,250
395,954
215,543
1,494,625
2,227,709
358,924
78,512
27,152
7,091
25
128,663
1,530,997
543,323
1,303,269
1,982,517
1,057,945
1,448
364
459.J054
' 40,317
104,374
1,761,762
143,767
943,169
489,443
58,634
240
206,472
993,058
349,464
3,157,612
218,574
184
49,534 •
342, 503
498
412,882
214,551
Erosion
Reduced
Tons/year
7,916,994
117,197
2,554,347
2;215,125
42,516,794
5, 453
1,496,895
6,694,^67
340
10,764,212
8,733,713
3,842,287
28,927,241
37,766,457
12,784,253
L, 227, 611
202,102
91,356. ,
. 190
1,600,888
26,341,367
13,029,389
25,286,409
26,302,958
24,957,020
18,852
• 3/734
19,019,292 ••
530,612
1,808,723 •
27,633,624
2, 193,068
22,266,135
5,528,071
1,067,529
11,216
2,825,790
12,673,077
8,383,186
115,523,541
3,682,163
2,101
371, 146
U,466, 364
4,492
6,570,939
2,840,518
   U.S. Total
239,409
                                  25,525,393
                                530,304,735
*Arlzona, Conneccicuc,  New Hampshire,  and Rhode  Island do not have any
participation  in CRP chus far.
                              H-6

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