Development of a Fugitive Dust Handbook for the WRAP Paper # 1134 Richard J. Countess Countess Environmental, 4001 Whitesail Circle, Westlake Village, CA 91361 Chatten Cowherd, Jr. Midwest Research Institute, 425 Volker Boulevard, Kansas City, MO 64111 ABSTRACT This paper describes the development of a comprehensive fugitive dust handbook prepared for the Western Regional Air Partnership’s (WRAP) Dust Emissions Joint Forum (DEJF). The handbook contains separate, stand-alone chapters for eight major fugitive dust source categories with the chapters grouped into two broad categories, as follows: (a) Mechanically Generated Fugitive Dust that include agricultural tilling, construction and demolition, materials handling, paved roads, and unpaved roads; and (b) Wind Generated Fugitive Dust that includes agricultural wind erosion, open area wind erosion, and storage pile wind erosion. The handbook addresses the estimation of uncontrolled fugitive dust emissions and emission reductions and costs associated with demonstrated control techniques. The methods for estimation of emissions draw primarily from AP-42 and secondarily from alternate methods adopted by state and local air control agencies in the WRAP region. Sources of data are identified and default values are presented for emission factor correction parameters, source extent/activity levels, and control efficiencies for natural mitigation and add-on control measures. Data sources for costs of add-on controls are also presented, along with step-by-step case studies for calculating control measure costeffectiveness. In addition, regulatory formats and compliance tools are discussed. Other items appended to the handbook include a discussion of test methods used to quantify fugitive dust emission rates; a summary of alternative emission estimation methods not addressed in the main body of the handbook, as well as methods that are still in the “developmental” stage and have not been approved by federal or state agencies; and a step-wise method to calculate the cost-effectiveness of different fugitive dust control measures. INTRODUCTION The Western Regional Air Partnership’s (WRAP) Dust Emissions Joint Forum (DEJF) selected Countess Environmental (CE) and Midwest Research Institute (MRI) to prepare a fugitive dust handbook and an associated website (www.wrapair.org/forums/dejf/fdh) for accessing the information contained in the handbook. The material presented in the handbook addresses the estimation of uncontrolled PM2.5 and PM10 fugitive dust emissions and emission reductions achieved by demonstrated control techniques for eight major 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 format of the handbook follows that included in two previous fugitive dust control measure guidance documents prepared by MRI (Cowherd et al., 1988; USEPA, 1992). The methods for estimating emissions draw (a) from established methods published by the USEPA, specifically AP-42: Compilation of Air Pollutant Emission Factors, and (b) from alternate methods adopted by state and local air control agencies in the WRAP region such as the California Air Resources Board, Clark County, Nevada, and Maricopa County, Arizona (Countess Environmental, 2001). 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 and associated website 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 eight fugitive dust source categories: agricultural tilling, construction and demolition, materials handling, paved roads, and unpaved roads as well as windblown dust emissions from agricultural fields, exposed open areas, and material storage piles. The material in the handbook and posted on the website will be updated at regular intervals as new information becomes available. The 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 western US. The information contained in the 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 the 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. FEATURES OF 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 contains a preface, executive summary, introduction and separate, stand-alone chapters for eight fugitive dust source with the chapters grouped into two broad categories, mechanically generated fugitive dust and wind generated fugitive dust. Mechanically generated fugitive dust sources include: Agricultural Tilling, Construction and Demolition, Materials Handling, Paved Roads, and Unpaved roads. Wind generated fugitive dust sources include: Agricultural Wind Erosion, Open Area Wind Erosion, and Storage Pile Wind Erosion. 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. An extensive glossary and a series of appendices are also included in the handbook. Appendix A contains a discussion of test methods used to quantify fugitive dust emission rates. Appendix B includes a summary of emission estimation methods developed by various groups for several fugitive dust source categories not addressed in the main body of the handbook, as well as a summary of emission estimation methods for categories addressed in the handbook that either are still in the developmental stage and have not been approved by federal or state agencies, or were developed many years ago and have fallen out of favor. Appendix C contains a step-wise method to calculate the cost-effectiveness of different fugitive dust control measures. Regulatory Formats Fugitive dust control options have been embedded in many regulations for state and local agencies in the WRAP region. Regulatory formats specify the threshold source size that triggers the need for control application. The handbook contains examples of regulatory format language obtained from local air quality districts within California, for Clark County, NV, and for Maricopa County, AZ. Compliance Tools A compliance plan is typically specified in local air quality rules addressing fugitive dust. Compliance tools such as record keeping, site inspection and on-site monitoring assure that the regulatory requirements, including application of dust controls, are being followed. The handbook identifies source-specific compliance tools for each of the fugitive dust source categories. Source(s) for Fugitive Dust Emission Factors The methods for estimation of fugitive dust emissions draw primarily from AP-42 and secondarily from alternate methods adopted by state and local air control agencies in the WRAP region. The sources for the uncontrolled PM2.5 and PM10 emission factors included in the handbook are summarized in Table 1. Table 1. Source(s) of Fugitive Dust Emission Factors* CATEGORY Agricultural Tilling Construction/Demolition AP-42 N/A N/A Materials Handling Paved Roads Unpaved Roads 13.2.4 (Jan. 1995) 13.2.1 |(Dec. 2003) 13.2.2 (Dec. 2003) Agricultural Wind Erosion Open Area Wind Erosion Storage Pile Wind Erosion N/A 13.2.5 (Jan. 1995) 13.2.5 (Jan. 1995) CARB 7.4 (Jan. 2003) Buildings: 7.7 (Sept. 2002) Roads: 7.8 (Aug. 1997) N/A 7.9 (July 1997) Non-farm roads: 7.10 (Aug. 1997) Farm roads: 7.11 (Aug. 1997) 7.12 (July 1997) N/A N/A OTHER MRI (1999) MacDougall (2002) * Includes section number from AP-42 or CARB’s Emission Inventory Procedural Manual and date that the information was last revised Agricultural Tilling The current version of AP-42 (i.e., the 5th edition) does not address agricultural tilling even though a PM10 emission factor for fugitive dust generated by agricultural tilling was developed by MRI in 1983 and adopted by the EPA in their 4th edition of AP-42. CARB’s emission estimation methodology includes emission factors for five distinct agricultural land preparation operations as well as monthly activity profiles for different crops. Construction and Demolition AP-42 contains a section (Section 13.2.3) on heavy construction operations. However, the emission factor methodology contained in AP-42 was not included in the handbook because it relies on a single-valued emission factor for total suspended particulate (TSP) based on only one set of field tests. MRI’s emission estimation methodology includes estimates for average as well as worst-case conditions for four different scenarios: (a) only area and duration are known, (b) amount of earth moved is known in addition to total project area and duration, (c) more detailed information is available on duration of earth moving and other material movement, and (d) detailed information on number of units and travel distances is available. Materials Handling Emissions from materials handling depend on the silt and moisture content of the material. Thus, the handbook contains a table of typical silt and moisture contents of materials at various industries that can be used as default values in the PM2.5 and PM10 emission factor equations. Paved Roads The handbook contains recommended default silt loadings (needed for the emission factor equations) for normal baseline conditions and for wintertime baseline conditions for public paved roads, as well as typical silt content and silt loading values for paved roads at industrial facilities. CARB estimates separate dust emissions for four classes of paved roads: (1) freeways/expressways, (2) major streets/highways, (3) collector streets, and (4) local streets. Unpaved Roads Dust emissions from unpaved roads have been found to vary directly with the fraction of silt (particles smaller than 75μm in physical diameter) in the road surface materials. Thus, the handbook contains recommended default silt values for industrial unpaved roads and for public unpaved roads. It should be noted that the ranges of silt content for public unpaved roads vary over two orders of magnitude. Therefore, the use of data obtained for the specific study area is strongly recommended. CARB includes separate emission estimation methods for non-farm roads and farm roads. Agricultural Wind Erosion Since AP-42 does not address agricultural wind erosion, the methodology adopted by CARB is presented as the primary emissions estimation methodology in the handbook. CARB’s methodology is based on major modifications to the wind erosion equation developed by the USDA in the 1960s for the estimation of wind erosion on agricultural land. Open Area and Storage Pile Wind Erosion The AP-42 emission estimation methodology for these two source categories relies on threshold friction velocities. Thus, the handbook includes published threshold friction velocities for several different barren surfaces. The MacDougall emission estimation method for open area wind erosion involves the following six steps: (a) categorizing vacant land based upon the potential of the parcels to emit fugitive dust during high winds; (b) identifying wind tunnel based emission factors for different vacant land categories; (c) developing a meteorological data set for the study area; (d) determining land type reservoirs, threshold wind velocities, wind events, and rainfall events; (e) developing emission inventory specific emission factors; and (f) applying emission inventory specific emission factors to each of the vacant land categories. Published Control Efficiencies An extensive compilation of fugitive dust control measures that have been implemented by jurisdictions designated by the USEPA as nonattainment for federal PM10 standards are presented in the handbook. A partial list of these control measures is presented in Table 2. The published PM10 control efficiencies for individual fugitive dust control measures vary over relatively large ranges as reflected in the table. This may reflect differences in the operations as well as the test methods used to determine control efficiencies. 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 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 control efficiency values for both size fractions. Table 2. Fugitive Dust Control Measures Applicable for the WRAP Region Source Category Control Measure Agricultural Tilling Reduce tilling during high winds Roughen surface Modify equipment Employ sequential cropping Increase soil moisture Use other conservation management practices Water unpaved surfaces Limit on-site vehicle speed to 15 mph Apply dust suppressant to unpaved areas Prohibit activities during high winds Implement wet suppression Sweep streets Minimize trackout Remove deposits on road ASAP Limit vehicle speed to 25 mph Apply water Apply dust suppressant Pave the surface Plant trees or shrubs as a windbreak Create cross-wind ridges Erect artificial wind barriers Apply dust suppressant or gravel Revegetate; apply cover crop Water exposed area before high winds Construction/Demolition Materials Handling Paved Roads Unpaved Roads Wind Erosion (agricultural, open area, and storage piles) Published PM10 Control Efficiency 1 – 5% 15 – 64% 50% 50% 90% 25 - 100% 10 – 74% 57% 84% 98% 50 – 70% 4 – 26% 40 – 80% >90% 44% 10 – 74% 84% >90% 25% 24 – 93% 4 – 88% 84% 90% 90% Control Measure Cost-Effectiveness A sample cost-effectiveness calculation is included in the handbook for each fugitive dust source category where a specific control measure is used to illustrate the basic calculation procedure. Each sample calculation includes the entire series of steps that are discussed below in the section addressing Appendix C. The steps include calculating uncontrolled emissions, controlled emissions, emission reductions, control costs, and control measure cost-effectiveness values for PM10 and PM2.5. In selecting the most advantageous control measure for a given real or hypothetical situation, the same calculation procedure is used to evaluate each candidate control measure (utilizing the control measure specific control efficiency and cost data), and the control measure with the most favorable costeffectiveness and feasibility characteristics is identified. The sample calculations included in the handbook contains estimates of capital costs and annual costs determined by Sierra Research for the San Joaquin Valley APCD’s 2004 PM10 SIP. The specific control measures used in the sample costeffectiveness calculation included in the handbook for each fugitive dust source category are presented in Table 3. Table 3. Control Measures Included in Sample Cost-Effectiveness Calculations Fugitive Dust Source Category Agricultural Tilling Construction/Demolition Materials Handling Paved Roads Unpaved Roads Agricultural Wind Erosion Open Area Wind Erosion Storage Pile Wind Erosion Control Measure Reduce number of tilling passes by 25% Install gravel apron at trackout egress points Continuous water spray at conveyor transfer point Use of a PM10 efficient street sweeper Watering roads twice a day at an industrial site Apply mulch to the barren field Apply gravel to dirt parking lot Erect 3-sided enclosure around the pile Appendix A: Emission Quantification Techniques This appendix contains a discussion of two basic test methods used to quantify fugitive dust emission rates, namely: (a) the upwind-downwind method that involves the measurement of upwind and downwind particulate concentrations, utilizing ground-based samplers under known meteorological conditions, followed by a calculation of the source strength (mass emission rate) with atmospheric dispersion equations; and (b) the exposure-profiling method that involves simultaneous, multipoint measurements of particulate concentration and wind speed over the effective cross section of the plume, followed by a calculation of the net particulate mass flux through integration of the plume profiles. Appendix B: Alternative Emission Estimation Methods This appendix includes a discussion of emission estimation methods developed by various groups for several fugitive dust source categories not addressed in the main body of the handbook. It also includes emission estimation methods for categories addressed in the main body of the handbook that are either still in the developmental stage and have not been approved by federal or state agencies, or were developed many years ago and have fallen out of favor. Because many of these methods have not been peer-reviewed, the reader is cautioned in the use of the emission factors included in these emission estimation methods. The emission estimation methods include: USEPA methods for agricultural tilling and harvesting, active storage pile wind erosion, and uncovered haul trucks; CARB methods for agricultural harvesting and for cattle feedlots; emission estimation methods developed by AeroVironment for miscellaneous minor fugitive dust sources (leaf blowers, equestrian centers, landfills, and truck wake turbulence of unpaved shoulders); a Desert Research Institute (DRI) method for unpaved shoulders; and four methods for open area wind erosion: the Draxler method, the UNLV method, the Great Basin Unified APCD method, and the DEJF method. Appendix C: Methodology for Calculating Cost-Effectiveness of Control Measures In compiling information on control cost-effectiveness estimates for the fugitive dust handbook, CE and MRI discovered that many of the estimates provided in contractor reports prepared for PM10 SIPs contain either hard to substantiate assumptions and/or unrealistic assumptions. Depending on which assumptions are used, the control cost-effectiveness estimates can range over one to two orders of magnitude. Rather than presenting existing cost-effectiveness estimates in the handbook, a detailed methodology to calculate cost-effectiveness of different control measures was developed. It is recommended that current cost data and assumptions that are applicable to the particular circumstances be used to calculate the cost-effectiveness of different control options. The steps necessary to calculate the cost-effectiveness for different fugitive dust control measures are listed below. This methodology was employed to calculate the cost-effectiveness for each sample control application published in the handbook for each of the eight fugitive dust source categories addressed in the main body of the handbook. Step 1: Select a specific control measure for the fugitive dust source category of interest. Step 2: Specify the basic parameters required to calculate uncontrolled and controlled emissions for the specific source (applicable emission factor equation, parameters used in the emission factor equation, source extent/activity level, characteristics of the source, control measure implementation schedule/frequency and application rate) Step 3: Calculate the annual uncontrolled emission rate as the product of the emission factor and the source extent (from Step 2). Step 4: Determine the control efficiency for the selected control measure. This may involve either (a) using a published value, (b) calculating the control efficiency based on comparing the controlled emissions estimate derived from the applicable emission factor equation with the uncontrolled emissions estimate derived from the same emission factor equation, or (c) specifying the desired control efficiency which then will entail determining the appropriate level of control to achieve the desired control efficiency. Step 5: Calculate the annual controlled emissions rate (if not already calculated in step 4) as the product of the annual uncontrolled emission rate (from Step 3) multiplied by the quantity 1 minus the fractional control efficiency (from Step 4). Step 6: Calculate the reduction in emissions as the difference between the annual uncontrolled emission rate (from Step 3) and the annual controlled emission rate (from Step 5). Step 7: Gather cost estimates for implementing the selected control measure (capital costs; annual operating, maintenance, overhead, and enforcement/compliance costs) Step 8: Calculate the annualized capital investment cost as the product of the annual capital cost and the capital recovery factor (CRF), where CRF is calculated as follows: CRF = [i (1 + i )n ] / [(1 + i)n – 1] where, i = annual interest rate (fraction), n = number of payment years Step 9: Calculate the total annualized cost by combining the annualized capital investment cost (from Step 8) with annual operating, maintenance, overhead, and enforcement/compliance costs (from Step 7). Step 10: Calculate the cost-effectiveness of the selected control measure by dividing the total annualized costs (from Step 9) by the emissions reduction. The emissions reduction is determined by subtracting the controlled emissions (from Step 5) from the uncontrolled emissions (from Step 3). REFERENCES CARB, 2003. Emission Inventory Procedural Manual Volume III: Methods for Assessing Area Source Emissions, California Air Resources Board, Sacramento, CA. November. Countess Environmental, 2001. Recommendations for Estimating Emissions of Fugitive Windblown and Mechanically Resuspended Road Dust Applicable for Regional Scale Modeling, final report prepared for the Western Governors’ Association, September Cowherd, C., et al., 1988. Control Of Open Fugitive Dust Sources, EPA-450/3-88-008, U.S. Environmental Protection Agency, Research Triangle Park, NC, September. MacDougall, C., 2002. Empirical Method for Determining Fugitive Dust Emissions from Wind Erosion of Vacant Land, memorandum prepared for Clark County Department of Air Quality Management, June. Midwest Research Institute, 1999. Estimating Particulate Matter Emissions From Construction Operations, Kansas City, Missouri, September. Sierra Research, 2003. Final BACM Technological and Economic Feasibility Analysis, prepared for the San Joaquin Valley Unified APCD, March. U.S. EPA, 1995. Compilation of Air Pollutant Emission Factors. AP-42. Fifth Edition, Research Triangle Park, NC, September. U.S. EPA, 1992. Fugitive Dust Background Document and Technical Information Document for Best Available Control Measures. U.S. Environmental Protection Agency, Office of Air and Radiation, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. September. KEY WORDS Fugitive Dust, Handbook, Control Measures, Control Efficiency, Cost-Effectiveness