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 ------- 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 ------- 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. ------- 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 i i i ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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. ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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). ------- 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 ------- 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.-' ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- :;iii:i i IIIK ir> i;M-IININC iiMir.vi D I ) i c ..< \ iii 1 ill _-nu. i ! > (rt^\ /yd'/:) l i) 1 1 l.i 1. i < ilV !\Ti i i O ( W.M 1 irr : r.lii-'iii ) • . , . . (Jr in u ul n VI--TI 1. or y ((j.^l /y.i:.') 0(1 r^D 'iir i oil (days ) ' USE Til Av(;-rarji- 1 U - 1 O Control C/. ) IG ------- win .-i SIIITI i IIK Di-: ii T "• > j 5^* / • (Jr in ii id nv«.-ri t. or y Qol /yii:.') Oil T4O ^k ^k « J *\ O.OtZ O.O83 ^ 1 O rfT* O. /2S _* >x •* O./fe 7 ^* •% ^h A O.2O& • ~ :'n-r i oil (d^ys ) 1 LIGE Til 31 3O 1 31 3O Avi^ra.jiv PH- 1 O Control (7.) 1C CCAIJL ! ^ AV 43 75 <•% *% 02 ^^\ x% BB — 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- Flow Direction Pile A Pile B1 Pile 82 Pile B3 Figure 4-3. Contours of normalized surface wind speeds, u./u . 4-14 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- • 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- • 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) ------- 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 ------- 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 ------- 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 5-18 ------- 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: 5-19 ------- 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 ------- 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 5-21 ------- 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 5-22 ------- • 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. 5-23 ------- 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 ------- 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 ------- 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. 5-26 ------- 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. 5-27 ------- 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 ------- • 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 ------- 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 ------- 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 ------- 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 5-32 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 10m — I >-l o iofn 0.5 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 ------- 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 ------- 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 ------- a: O (— a < LL CO CO ai z X O ^) O (T UJ O £ ------- LLL/dl401-7at, p. 4 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 ------- 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 ------- 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. ------- OJ +-> T3 "oJ O) LT) OJ 7-14 ------- 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 ------- I (—• cr> Figure 7-6. Effect of vegetative cover on relative emission rate. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX A. OPEN DUST SOURCE EMISSION FACTOR RATING AND CONTROL EFFICIENCY TERMINOLOGY ------- 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 ------- 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 ------- 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 ------- APPENDIX B. ESTIMATION OF CONTROL COSTS AND COST EFFECTIVENESS ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- REFERENCE FOR APPENDIX B 1. PEDCo Environmental, Inc. Cost Analysis Manual for Standards Support Document. U. S. Environmental Protection Agency. November 1978. B-10 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX C. METHODS OF COMPLIANCE DETERMINATION FOR OPEN SOURCES ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX D. PROCEDURES FOR SAMPLING SURFACE/BULK MATERIALS ------- 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 ------- 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. ------- 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 ------- -Okm (5 Mi.) of similar road type Increment I Figure D-3. Location of incremental sampling sites on a paved road. ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX E. PROCEDURES FOR LABORATORY ANALYSIS OF SURFACE/BULK SAMPLES ------- 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 ------- reed Chute Riffle Sampler - (a) Riffle Sucked and Separate Feed Chute Stand Co) Figure E-l. Sample dividers (riffles). E-2 ------- Figure E-2. Coning and quartering. E-3 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 CONTRACTOR N/A 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 CONTRACTOR MRI CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. 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 CONTRACTOR N/A CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. -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 EPA/QA-CFS 07/01/37 FecJs.ral Feaister CONTRACTOR N/A CONTACT N/A HARD COPY TITLE Air Foil'.;-: on Cont.-oi Teohn : sues t or. Nor.-Me~ a 1 1 i c '-linerais AUTHOR N/A SPONSOR EPA/CAQFS DATE 08/01/52 PUB. NO. EPA-450/~-31—M4 CONTRACTOR N/A CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. 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 SPONSOR DATE PUB. NO. 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 CONTRACTOR PEI CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. 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 ------- 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 CONTRACTOR N/A CONTACT N/A HARD .'COPY Y TITLE AUTHOR SPONSOR DATE PUB. NO. 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 AUTHOR 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.- HARD COPY Y TITLE AUTHOR SPONSOR DATE PUB. NO. Control Techniques for Particulate Emissions from Stationa. Sources - '.'olume 1 N/A EPA/OAQPS/EbED 09/01/32 E p A - 4 5 0 / 3-81- 0 0 5 -a CONTRACTOR N/A CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. Control : ecnni'quss -For Part i cul at'e Emi s si ons f r o.n Statior Sources - Volume '2 N/A EPA/OAGPS/ESED <~>9/<">i /32 EPA-450/3-e1-003b CONTRACTOR N/A CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE 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 CONTRACTOR MRI CONTACT El mere. W.L. HARD COPY Y TITLE AUTHOR SPONSOR DATE PUB. NO. National Air Pollution Control Techni c-ues Advisorv Minutes of Meeting - Decemcer 2 and 3, 193O N/A EPA/CAQPS/ESED 01/14/31 N/A CONTRACTOR N/A CONTACT Farmer. Jack HARD COPY TITLE AUTHOR SPONSOR DATE 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 CONTACT Wood. Gilbert H. HARD COPY Y F-3 ------- 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 CONTRACTOR PEI CONTACT Pace. Thomp-so; HARD .-COPY TITLE Ex amc 13 Mcceli.-ic: to Illustrate SIP Devel ooment -for the AUTHOR Anderson, Michael, et ?.l SPONSOR EPA/OAGPS/MD AD DATE 05/01/97 PUB. NO. EPA-450/--S7-012 CONTRACTOR TRC CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. Compilation ot Air Pollutant Emission Factors - Volume I: btarionar F'oint and Area Sources N/A EPA/QAGFS/MDAD (")9/O i /S* AP-42 CONTRACTOR N/A CONTACT Joyner, Whitmel HARD COPY TITLE AUTHOR SPONSOR DATE 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 CONTACT Pace, Thompson G. HARD COPY TITLE PMl'O" and Fugitive Dust in the Soutnwest - Ambient Impact. '=,01 and Femedies ' '- AUTHOR N/A SPONSOR EPA/QAQPS,hDAD DATE O7/01/35 PUB. NO. EPA-450/4-55-008 CONTRACTOR PEI CONTACT Pace. Thompson G. HARD COPY TITLE Dispersion of Airborne F'articulates in Surface Coal Mines. Data Analvsi s AUTHOR N/A SPONSOR DATE PUB. NO. EPA/QAGPS/MDAD 01/01/S5 EPA-450/4-65—'/Oi CONTRACTOR TRC CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. Receptor Model Technical Series - Summary ot Particle Identification Techniques: -'volume IV Weant, Gecrcs E., J. Calvin Thames EPA/QAGPS/rDAD 06/01 ,-83 EPA-450/ 4-S."-'."'IS CONTRACTOR Enaineeri na-S'ci ence CONTACT HARD COPY TITLE Particulate ^..-issicn Factors tor the Cons-ructio on rioc-recate ; - c .. = ~ r ••. AUTHOR SPONSOR DATE PUB. NO. Record. Frank. William T. Harnett EFA/CAGPS.T-'.'AD 02/01 /S.T N/A CONTRACTOR GCA CONTACT Soul HARD COPY nsr1 and. James F-4 ------- 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 PUB. NO. EPA-450/4-83-004 CONTRACTOR PEDCo i< TFC CONTACT Pace. Thompson HARD ;EOPY TITLE AUTHOR SPONSOR DATE PUB. NO. Receotor Model -ecnnical 3aries - Overview of F.eceptor Model Application to Particuiate source Apportionment: Volume I Core, John E. EPA/OAGP3/MDAD 07/01/31 EPA-45O/ 4-81-01 = 5. CONTRACTOR N/A CONTACT N/A HARD COPY TITLE Receotor Model Tecnnicsl Senas - Chemical Mass Balance: AUTHOR Cora. John E. SPONSOR EPA/CAQPS/MDAD DATE 07/01/31 PUB. NO. EPA-450/4-81-0 lib CONTRACTOR N/A CONTACT N/A HARD COPY TITLE AUTHOR SPONSOR DATE PUB. NO. Assessment of Fugitive Part i-rui at e Emission r-actors for Processes Zoller. .John M. . and -2. Thomas Ps-rnke, thomas A. Janszsn EPA/CAGPS/MDAD 09/0i/~g EPA1450/3-73-107 CONTRACTOR PEDCo CONTACT . Masser. Charles HARD COPY Y TITLE AUTHOR SPONSOR DATE PUB. NO. Guideline for Development of Control Strategies in.Areas Fuaitive Dust Problems • " . Richar 3. George EPA/CAGFS/MDAD 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 SPONSOR DATE PUB. NO. Cowherd, Chatten. and Christine M. Maxwell. Daniel W. ••Jelson EPA/OAGF3/MDAD 07/O1/77 EP A - 4 5 0 / 3-77-•:• 2 7 CONTRACTOR MRI CONTACT Mann. Char 1= = HARD COPY Y TITLE Performance Evaluation Guide for Laroe Flow Ventilation 3vsterns AUTHOR SPONSOR DATE PUB. NO. Kemner. W.F.. R.W. Gerstle. EPA/CAGPS/SSCD O 7 / O 1 / ft 4 EPA-340/1-34-012 CONTRACTOR PEDCo CONTACT HARD COPY Y Por 11 and Carrier, t P1 an t ! ns c< ec t i or. 3u i de Saunders. F'amel a TITLE AUTHOR SPONSOR DATE PUB. NO. Orf. D.J.. F:.W. Gerstle, D.J. Loud in EPA/ OAuF'S/SSCD 06/O1/S2 EPA-34O/1-32-007 CONTRACTOR PEE-Co CONTACT Saunders. Pamela HARD COPY F-5 ------- 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 SPONSOR EFA/OAGPS/SSCD DATE 01/01/92 PUB. NO. EPA-340/1-S1-003 CONTRACTOR MR I CONTA.CT Saunders. Ramsl HARD-COPY Y TITLE AUTHOR SPONSOR DATE 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 TITLE AUTHOR SPONSOR DATE PUB. NO. 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 TITLE AUTHOR SPONSOR DATE 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 " • TITLE AUTHOR SPONSOR DATE 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 TITLE AUTHOR SPONSOR DATE 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 HARD COPY Y TITLE AUTHOR SPONSOR DATE 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 TITLE AUTHOR SPONSOR DATE 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 ------- EXAMPLE - JOINT MEMORANDUM OF UNDERSTANDING (MOU) G-2 ------- [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 ------- 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 ------- 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 ------- 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 ------- EXAMPLE - PUBLIC PAVED ROAD REGULATION NUMBER 1 G-7 ------- 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 ------- 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 ------- EXAMPLE - INDUSTRIAL PAVED ROAD REGULATION G-10 ------- 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 ------- EXAMPLE - ROAD REGULATION 6-12 ------- 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 ------- 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 ------- EXAMPLE - STORAGE PILE REGULATION G-15 ------- 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 ------- 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 ------- 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 ------- EXAMPLE - CONSTRUCTION/DEMOLITION REGULATION G-19 ------- 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 ------- 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 ------- 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 ------- 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 ------- EXAMPLE - OPEN AREA REGULATION G-24 ------- 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 ------- 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 ------- 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 ------- EXAMPLE - OPEN AREA REGULATION (WATER MINING) G-28 ------- 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 ------- 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 ------- APPENDIX H. FOOD SECURITIES ACT ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 -------