R11034402 Western Regional Air Partnership.doc

wrap fugitive dust handbookprepared for:western governors association1515 cleveland place, suite 200denver, colorado 80202prepared by:countess environmental4001 whitesail circlewestlake village, ca 91361(wga contract no. 30204-111)september 7, 2006table of contentsprefaceexecutive summarychapter 1.introductionchapter 2.agricultural tillingchapter 3.construction and demolitionchapter 4.materials handlingchapter 5.paved roadschapter 6.unpaved roadschapter 7.agricultural wind erosionchapter 8.open area wind erosionchapter 9.storage pile wind erosionchapter 10.agricultural harvestingchapter 11mineral products industrychapter 12abrasive blastingchapter 13livestock husbandrychapter 14miscellaneous minor fugitive dust sourcesglossaryappendix a.emission quantification techniquesappendix b.estimated costs of fugitive dust control measuresappendix c.methodology for calculating cost-effectiveness of fugitive dust control measuresappendix d.fugitive pm10 management planprefacein 2004 the western regional air partnerships (wrap) dust emissions joint forum (dejf) selected countess environmental to prepare a fugitive dust handbook and an associated website (/forums/dejf/fdh) for accessing the information contained in the handbook. the material presented in the original handbook released on november 15, 2004 addressed the estimation of uncontrolled fugitive dust emissions and emission reductions achieved by demonstrated control techniques for eight major fugitive dust source categories. in 2006 wrap hired countess environmental to update the handbook. the updates included revising each chapter in the handbook to reflect the new pm2.5/pm10 ratios developed for wrap by the midwest research institute (mri) in 2005, addressing four additional major fugitive dust source categories as well as several minor source categories, and updating the existing chapters.the material in this handbook focuses on fugitive dust emissions “at the source” and does not evaluate factors related to the transport and impact of emissions on downwind locations where ambient air monitoring occurs. the methods for estimation of dust emissions rely primarily on ap-42 with additional references to alternative methods adopted by state and local control agencies in the wrap region. with regard to emission factor correction parameters, source extent/activity levels, control efficiencies for demonstrated control techniques, and emission reductions by natural mitigation and add-on control measures, sources of data are identified and default values are provided in tables throughout the handbook. graphs, charts, and tables are provided throughout the handbook to assist the end user.the handbook:(a)compiles technical and policy evaluations for the benefit of wrap members, stakeholders, and other interested parties when addressing specific air quality issues and when developing regional haze implementation plans;(b)incorporates available information from both the public (federal, state and local air quality agencies) and private sectors (e.g., reports addressing options to reduce fugitive dust emissions in areas of the country classified as nonattainment for pm10); and(c)serves as a comprehensive reference resource tool of currently available technical information on emission estimation methodologies and control measures for the following twelve fugitive dust source categories: agricultural tilling, agricultural harvesting, construction and demolition, materials handling, paved roads, unpaved roads, mineral products industry, abrasive blasting, livestock husbandry, and windblown dust emissions from agricultural fields, material storage piles, and exposed open areas.this handbook is not intended to suggest any preferred method to be used by stakeholders in preparation of sips and/or conformity analyses but rather to outline the most commonly adopted methodologies currently used in the us. the information contained in this handbook has been derived from a variety of sources each with its own accuracy and use limitations. because many formulae and factors incorporate default values that have been derived for average us conditions, area specific factors should be used whenever they are available. additionally, the input terms (commonly referred to as “correction factors”) used in any given emission factor equation presented in this handbook were obtained using a specific test methodology and are designed to give an estimate of the emission from a specific activity or source under specific conditions. as a result the emission estimate must be used appropriately in any downstream application such as dispersion modeling of primary pm emissions.it is important to note that epas criteria for exceedances, violations, and model calibration and validation are based on ambient data from the national ambient air monitoring sites. it should be further noted that estimates of the relative contribution of fugitive dust to ambient pm concentrations based on chemical analysis of exposed filters are usually much lower than that based on emission inventory estimates, in some cases by a factor of 4. part of this discrepancy between ambient measurements and emission estimates is due to the near source deposition losses of freshly generated fugitive dust emissions. it is not an objective of this handbook to resolve this modeling discrepancy issue. it is the role of modelers to incorporate deposition losses into their dispersion models and to account for the formation of secondary pm, which in many areas of the country are responsible for an overwhelming contribution to exceedances of the federal pm naaqs.applicability to tribesthe regional haze rule explicitly recognizes the authority of tribes to implement the provisions of the rule, in accordance with principles of federal indian law, and as provided by the clean air act 301(d) and the tribal authority rule (tar) (40 cfr 49.1 .11). those provisions create the following framework:1. absent special circumstances, reservation lands are not subject to state jurisdiction.2. federally recognized tribes may apply for and receive delegation of federal authority to implement caa programs, including visibility regulation, or reasonably severable elements of such programs (40cfr 49.3, 49.7). the mechanism for this delegation is a tribal implementation plan (tip). a reasonably severable element is one that is not integrally related to program elements that are not included in the plan submittal, and is consistent with applicable statutory and regulatory requirements. 3. the regional haze rule expressly provides that tribal visibility programs are “not dependent on the strategies selected by the state or states in which the tribe is located” (64. fed. reg. 35756), and that the authority to implement 309 tips extends to all tribes within the gcvtc region (40 cfr 51.309(d)(12).4. the epa has indicated that under the tar tribes are not required to submit 309 tips by the end of 2003; rather they may choose to opt-in to 309 programs at a later date (67 fed. reg. 30439).5. where a tribe does not seek delegation through a tip, epa, as necessary and appropriate, will promulgate a federal implementation plan (fip) within reasonable timeframes to protect air quality in indian country (40 cfr 49.11). epa is committed to consulting with tribes on a government-to-government basis in developing tribe-specific or generally applicable tips where necessary (see, e.g., 63 fed. reg.7263-64).it is our hope that the findings and recommendations of this handbook will prove useful to tribes, whether they choose to submit full or partial 308 or 309 tips, or work with epa to develop fips. we realize that the amount of modification necessary will vary considerably from tribe to tribe and we have striven to ensure that all references to tribes in the document are consistent with principles of tribal sovereignty and autonomy as reflected in the above framework. any inconsistency with this framework is strictly inadvertent and not an attempt to impose requirements on tribes which are not present under existing law.tribes, along with states and federal agencies, are full partners in the wrap, having equal representation on the wrap board as states. whether board members or not, it must be remembered that all tribes are governments, as distinguished from the “stakeholders” (private interest) which participate on forums and committees but are not eligible for the board. despite this equality of representation on the board, tribes are very differently situated than states. there are over four hundred federally recognized tribes in the wrap region, including alaska. the sheer number of tribes makes full participation impossible. moreover, many tribes are faced with pressing environmental, economic, and social issues, and do not have the resources to participate in an effort such as the wrap, however important its goals may be. these factors necessarily limit the level of tribal input into and endorsement of wrap products.the tribal participants in the wrap, including board members, forum and committee members and co-chairs, make their best effort to ensure that wrap products are in the best interest of the tribes, the environment, and the public. one interest is to ensure that wrap policies, as implemented by states and tribes, will not constrain the future options of tribes who are not involved in the wrap. with these considerations and limitations in mind, the tribal participants have joined the state, federal, and private stakeholder interests in approving this handbook as a consensus document.3executive summarythis fugitive dust handbook addresses the estimation of uncontrolled fugitive dust emissions and emission reductions achieved by demonstrated control techniques for twelve major and several minor fugitive dust source categories. the handbook focuses on fugitive dust emissions “at the source” and does not evaluate factors related to the transport and impact of emissions on downwind locations where ambient air monitoring occurs. the methods for estimating emissions draw (a) from established methods published by the usepa, specifically ap-42: compilation of air pollutant emission factors that are available from the internet (/ttn/chief/ap42), and (b) from alternate methods adopted by state and local air control agencies in the wrap region such as the california air resources board (/ei/areasrc/areameth.htm), clark county, nevada (www.co.clark.nv.us/air_quality), and maricopa county, arizona (/envsvc/air). sources of data are identified and default values for emission factor correction parameters, source extent/activity levels, control efficiencies, and emission reductions by natural mitigation and add-on control measures are provided in tables throughout the handbook. the handbook has several distinct features that give it a major advantage over the use of ap-42 or other resource documents. the handbook is a comprehensive document that contains all the necessary information to develop control strategies for major sources of fugitive dust. these features include:(a)extensive documentation of emission estimation methods adopted by both federal and state agencies as well as methods in the “developmental” stage;(b)detailed discussion of demonstrated control measures;(c)lists of published control efficiencies for a large number of fugitive dust control measures;(d)example regulatory formats adopted by state and local agencies in the wrap region;(e)compliance tools to assure that the regulations are being followed; and(f)a detailed methodology for calculating the cost-effectiveness of different fugitive dust control measures, plus sample calculations for control measure cost-effectiveness for each fugitive dust source category.the handbook and associated website (/forums/dejf/fdh) are intended to:(a)support technical and policy evaluations by wrap members, stakeholders, and other interested parties when addressing specific air quality issues and when developing regional haze implementation plans;(b)incorporate available information from both the public and private sectors that address options to reduce fugitive dust emissions in areas of the country classified as nonattainment for pm10; and(c)provide a comprehensive resource on emission estimation methodologies and control measures for the following twelve fugitive dust source categories: agricultural tilling, agricultural harvesting, construction and demolition, materials handling, paved roads, unpaved roads, minerals products industry, abrasive blasting, livestock husbandry, and windblown dust emissions from agricultural fields, material storage piles, and exposed open areas.the handbook contains separate, stand-alone chapters for each of the twelve major fugitive dust source categories identified above. because the chapters are meant to stand alone, there is some redundancy between chapters. each chapter contains a discussion of characterization of the source emissions, established emissions estimation methodologies, demonstrated control techniques, regulatory formats, compliance tools, a sample control measure cost-effectiveness calculation, and references. a separate chapter addressing several minor fugitive dust source categories and several appendices are also included in the handbook. appendix a contains a discussion of test methods used to quantify fugitive dust emission rates. appendix b contains cost information for demonstrated control measures. appendix c contains a step-wise method to calculate the cost-effectiveness of different fugitive dust control measures. appendix d contains a brief discussion of fugitive pm10 management plans and record keeping requirements mandated by one of the air quality districts within the wrap region.a list of fugitive dust control measures that have been implemented by jurisdictions designated by the usepa as nonattainment for federal pm10 standards is presented in the table below. the published pm10 control efficiencies for different fugitive dust control measures vary over relatively large ranges as reflected in the table. the user of the handbook is cautioned to review the assumptions included in the original publications (i.e., references identified in each chapter of the handbook) before selecting a specific pm10 control efficiency for a given control measure. it should be noted that midwest research institute (mri) found no significant differences in the measured control efficiencies for the pm2.5 and pm10 size fractions of unpaved road emissions based on repeated field measurements of uncontrolled and controlled emissions. thus, without actual published pm2.5 control efficiencies, the user may wish to utilize the published pm10 values for both size fractions.many control cost-effectiveness estimates were reviewed in preparation of this handbook. some of these estimates contain assumptions that are difficult to substantiate and often appear unrealistic. depending on which assumptions are used, the control cost-effectiveness estimates can vary by one to two orders of magnitude. thus, rather than presenting existing cost-effectiveness estimates, the handbook presents a detailed methodology to calculate the cost-effectiveness of different fugitive dust control measures. this methodology is presented in appendix c. the handbook user is advised to calculate the cost-effectiveness values for different fugitive dust control options based on current cost data and caveats that are applicable to the particular situation.fugitive dust control measures applicable for the wrap regionsource categorycontrol measurepublishedpm10 control efficiencyagricultural tillingreduce tilling during high winds1 5%roughen surface15 64%modify equipment50%employ sequential cropping50%increase soil moisture90%use other conservation management practices25 - 100%agricultural harvestinglimited activity during high winds5 70%modify equipment50%night farming10%new techniques for drying fruit25 60%construction/demolitionwater unpaved surfaces10 74%limit on-site vehicle speed to 15 mph57%apply dust suppressant to unpaved areas84%prohibit activities during high winds98%materials handlingimplement wet suppression50 90%erect 3-sided enclosure around storage piles75%cover storage pile with a tarp during high winds90%paved roadssweep streets4 26%minimize trackout40 80%remove deposits on road asap 90%unpaved roadslimit vehicle speed to 25 mph44%apply water10 74%apply dust suppressant 84%pave the surface90%mineral products industrycyclone or muliclone68 79%wet scrubber78 98%fabric filter99 99.8%electrostatic precipitator90 99.5%abrasive blastingwater spray50 93%fabric filter 95%livestock husbandrydaily watering of corrals and pens 10%add wood chips or mulch to working pens 10%wind erosion(agricultural, open area, and storage piles)plant trees or shrubs as a windbreak25%create cross-wind ridges24 93%erect artificial wind barriers4 88%apply dust suppressant or gravel84%revegetate; apply cover crop90%water exposed area before high winds90%3chapter 1. introduction1.1 background1-11.2 purpose of the handbook1-21.3 dust definition and categorization scheme1-21.4 factors affecting dust emissions1-51.5 use of satellite imagery to inventory erodible vacant land1-81.6 emission calculation procedure1-81.7 emission factors1-101.8 emission con