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Implementing a Successful Fugitive Dust Control Program

This workshop in Sacramento, CA on May 23-24, 2006, led by Karen Irwin from EPA Region 9, provides an overview of the history of fugitive dust controls in the region, their relevance to regional haze, and the key elements of an effective dust control program. The workshop includes descriptions of each element with examples and recommendations.

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Implementing a Successful Fugitive Dust Control Program

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  1. Implementing a Successful Fugitive Dust Control Program WRAP Workshop Sacramento, CA May 23-24, 2006 Karen Irwin, EPA Region 9

  2. Overview • History of fugitive dust controls in Region 9 • Relevance to regional haze • Elements of an effective dust control program • Description of each element with examples • Recommendations

  3. History of Fugitive Dust Controls in Region 9 • Fugitive dust sources dominate PM-10 in areas that do not meet federal standards • “Serious nonattainment areas” • Las Vegas, NV - Owens Lake, CA • Phoenix, AZ - Imperial Valley, CA • Coachella Valley, CA - Reno, NV • San Joaquin Valley, CA

  4. History of Fugitive DustControls in Region 9 • State Implementation Plans addressing PM-10 have been submitted to EPA • Several areas have adopted stringent fugitive dust control measures • Important related programmatic enhancements have been developed

  5. Relevance to Regional Haze • Many of the same sources • Examples of controls approved by EPA as “Best Available” are in place • Common implementation issues are experienced in multiple areas • Similar elements are needed to make programs effective • Their scope can be adjusted to suit the needs of a particular regional haze area

  6. Elements of an Effective Dust Control Program • Sufficiently detailed emissions inventory • Clear and enforceable control measures • Local/state air quality rules • Local/state/federal landowner resolutions

  7. Elements of an Effective Dust Control Program • Successful Enforcement • Identifying and prioritizing sources for proactive inspections • Adequate resources (e.g., inspectors) • Adequate methods to deter noncompliance • Successful Outreach and Training

  8. Emissions Inventory • To determine significant sources and their percentage emissions contribution • To target a subset of sources within each significant source category for regulatory purposes • Example: heavily trafficked unpaved roads • If “borrowing” a threshold, evaluate what its coverage would provide in the area at hand • To identify and prioritize source locations for compliance purposes

  9. Emissions Inventory • Resources for compiling information to develop a detailed emissions inventory • For publicly owned unpaved roads • check with city, county and state transportation agencies for traffic count estimates • request tube counts where feasible • For construction sites • check with the local permitting authority for numbers of permits issued

  10. Emissions Inventory • For disturbed vacant land and privately owned sources • check with the County Recorder’s office for lot size information • conduct field surveys • consider using satellite imagery or aerial photos • For paved road sources, such as trackout, conduct field surveys to estimate silt loading or use a mobile sampler

  11. Control Measures • Clear, stringent, enforceable rule requirements • Adopt specific control measures as opposed to “taking reasonable precautions to prevent dust” • Consider whether a measure is effective and enforceable as a stand-alone control option before including it as such

  12. Control Measures • Clear, stringent, enforceable rule requirements • Narrowly define rule exemptions • Incorporate multiple tools for gauging source compliance - An opacity test method tailored to intermittently- generated plumes - Surface stabilization standards/test methods - Specific measures in dust control plans

  13. Control Measures • City, county, and federal landowner agencies • Often have jurisdiction over many fugitive dust sources, e.g., unpaved roads, paved roads, vacant land - plans may need to rely on cities/counties for data collection • A fiscal commitment is required to pave roads, stabilize unpaved shoulders and vacant land, etc.

  14. Enforcement - Reactive vs. Proactive • Reactive enforcement program • Complaint-driven, some random observations en route to facility inspections • No assurance that most sources subject to regulation are being controlled • Emphasis on mitigating only gross or obvious offenses • Can only address a source after it has become a problem

  15. Enforcement - Reactive vs. Proactive • Proactive enforcement program • Targeted source inspections are routine, in addition to responding to complaints • Capable of citing both gross offenses and situations when some, but not enough, control is being applied • Emphasizes whether proper measures have been taken to prevent fugitive dust release, in addition to responding to existing problems

  16. Enforcement • Identify sources by location for proactive inspections • require Dust Control Plans for construction sites • determine locations of area sources subject to requirements (a detailed inventory is useful!) • Prioritize sources by developing an inspection plan • first target sources with the greatest potential for dust (e.g., larger sites, siltiest soils, more trafficked sources) • cover all geographic quadrants

  17. Enforcement Resources • Dedicate field inspectors to fugitive dust sources • Ensure an adequate number of inspectors for the size of the area/number of sources • Set target goal for # of annual or quarterly inspections

  18. Enforcement Methods • Effective process of issuing NOVs & CAOs • Eliminate multiple warnings prior to citations • Raise penalty rates to meaningful levels • Expedite processing citations • Secure management support for pursuing cases and fines as warranted • Conduct follow-up inspections

  19. Outreach and Training • Regularly offer dust control classes * require construction site supervisors and water truck drivers to attend and as a condition of a NOV • Require posting of dust control plans to improve awareness • Provide field manuals and sample recordkeeping forms • Provide web-accessible outreach brochures to regulated community • Develop television and radio ads

  20. Recommendations • Develop an emissions inventory that provides a means to identify and prioritize sources • Adopt fugitive dust rules with specific requirements and performance standards/ test methods • Work closely with city, county, and federal landowner agencies to gain their commitment in addressing fugitive dust sources

  21. Recommendations • Be willing to incorporate preventative approaches to dust control in addition to responding to visible dust episodes • Evaluate and ensure adequate enforcement resources and capability for proactive fugitive dust enforcement

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