Blue Skies Campaign – Dust Control Course Arizona (TPD0908025)

FACT SHEET #1:

Health Impacts of Particulate Air Pollution

Particulate air pollution is a mixture of dirt, soil dust, pollens, molds, ashes, soot and aerosols that remain suspended in the air that we breathe. Coarse particles such as soil dust under 10 microns in  diameter (PM10) are caused by human activities such as construction and earthmoving, vehicles driving on paved and unpaved roads, and agricultural tilling and harvesting. Fine particles, measuring less than 2.5 microns (PM2.5), are produced primarily by the exhaust from diesel and gasoline engines and other combustion processes.

FACT SHEET #2:

What Causes Particulate Air Pollution?

Human activities generate most of the airborne particles that we breathe. Some of the activities that create particulate air pollution are:

FACT SHEET #3:

Soil   Characteristics

• Clay or clay/silt mixture soils create much smaller particles that stay suspended in the air
• Sandy soils create heavier particles that are more quickly re- deposited on the ground

Before starting construction, a geotechnical analysis should determine the soil texture and the shrink/swell potential of soils that will be disturbed on the site and imported to the site

• If the soils have a high or moderate potential (as shown in the  soil texture triangle below) to create PM-10, then water and dust suppressants need to be applied before and during construction
• Similarly, if the soils have a high or moderate shrink/swell potential, then water and a dust suppressants need to be applied before and during construction

Federal air quality standards for particulate air pollution have been established to protect public health.   There are two federal  standards; one for PM-10 (particles smaller than 10 microns) and  one for PM-2.5 (particles  smaller than 2.5 microns).  Neither of these tiny particles would be visible to the naked eye; a PM-10 particle is about one-seventh the diameter of a human hair. Most of the PM-10 particles are produced by rocks and soils. The soil particles in PM-10 are usually silt and clay. PM-2.5 particles are usually emitted by combustion sources and are formed from gases.

Ten areas in Arizona have violated the federal air quality standards for particulate air pollution (PM-10). These are called PM-10 nonattainment or maintenance areas. No area in Arizona has exceeded the federal standards for the smaller particles (PM-2.5).

The Phoenix metropolitan area is the only serious nonattainment area for PM-10 in the state. Other PM-10 nonattainment or maintenance areas in Arizona include Ajo, Bullhead City, Douglas, Miami-Hayden, Nogales, Paul Spur, Payson, Rillito, and Yuma.

Take time to consider dust control issues before beginning your project in order    to save time, money, and project resources. Identify site-specific air quality and dust control issues up front and develop a consensus for addressing these issues. Phase your project and plan your site layout to minimize disturbance of the soil. Action items include:

• Make sure everyone working on the job knows who’s in charge and all the requirements for dust control. Encourage  a  proactive  and  continuous  focus on air quality issues on the job site.
• Evaluate dust control procedures periodically to identify additional issues that develop as the job progresses.
• Limit the amount of area graded at any one time. Lessening the amount of surface being disturbed at any one time reduces the amount of control required and the amount of water or dust suppressant needed.
• Install wind fences or barriers (less than 50 percent porosity). Place barriers around storage piles, parking, and equipment staging areas.
• Develop semipermanent staging areas to cut down on the amount of disturbed area.
• Restrict access on unpaved areas to vehicles and equipment that are necessary that day. Limit unnecessary travel on unpaved surface areas.
• Restabilize disturbed surfaces by paving permanent roads and restoring vegetation as soon as possible.

Material handling refers to many types of earthmoving activities on construction sites, including loading and hauling. These types of activities can be significant sources of fugitive dust. However, dust control during loading and hauling can be easily achieved through careful planning and proper implementation of controls.

Loading:

• Mist material with water while stacking.
• Mix excavated material with water prior to loading.
• Empty loader slowly and keep bucket close to the truck while dumping.

Hauling:

• Tarps are required on haul trucks to prevent windblown dust.
• Do  not  overload the truck!   Keep your load 3 to 6 in. below the freeboard to minimize spillage.
• Check belly-dump truck seals regularly and remove any trapped rocks to prevent spillage.

Trackout:

• Daily vacuuming or wet broom cleaning is required to control trackout.
• Install a gravel pad at the access point to your site.
• Use grizzlies to remove excess dirt from trucks.

• Water should be applied so the surface is kept visibly moist,
• Gravel or recycled asphalt should be applied and maintained,
• A suitable dust suppressant should be applied and maintained, or
• The haul or access road should be paved

To control dust from unpaved parking lots and staging areas on construction sites

• Apply and maintain surface gravel, recycled asphalt, or other suitable material,
• Apply and maintain a dust suppressant, or
• Pave the lot/staging area

To keep vehicles off of vacant areas not intended for travel

• Install no-trespassing signs or
• Install other physical barriers such as curbs, fences, gates, posts, shrubs or trees to prevent access

Wind barriers are placed along one or more sides of a job  site  to  reduce the amount of windblown dust leaving  the  site.  Creating  a wind barrier could involve installing wind fences, constructing berms,  or parking onsite equipment so that it blocks the wind. Alone, these barriers are not adequate for controlling dust. Wind barriers must be implemented together with the application of water or dust palliatives. These barriers increase the dust control effectiveness of water or palliative application.

Maricopa County Earthmoving Permits require that fugitive dust generated from all earthmoving activities be controlled.

Effective wind barriers/fences on the job site are:

• 3 to 5 feet high adjacent to roads and urban areas
• Made of material with a porosity of 50 percent or less.

Effective wind barriers / temporary enclosures for storage piles are:

• A three-sided structure as high as the pile
• Made of material with a porosity of 50 percent or less.

• Dirt, mud, or other debris tracked onto a paved public road by a vehicle leaving a  construction site.
• Dirt and mud adhering to the exterior or undercarriage of a vehicle leaving a construction site that falls onto a paved public road.
• Traces of dirt or other bulk material that spill onto a paved public road from an improperly loaded haul truck leaving a construction site.

Particulate matter (PM₁₀) is caused when the material deposited on  the pavement is lifted back into the atmosphere—or “reentrained”—by the tires of vehicles passing over it. A large portion of the PM₁₀ in the Valley’s air is caused by vehicle reentrainment.

Under Maricopa County Rule 310, control of trackout is required for all work sites having a disturbed surface area of at least five acres or from which 100 cubic yards of materials are hauled each day. Trackout can be controlled using any of the following at all exits onto paved public roads:

Gravel Pad – A stabilized construction entrance, designed to remove mud and dirt from the tires of vehicles as they leave the construction site. The gravel ft. long, and a minimum of 6 in. deep. One to 3-in. diameter, washed gravel or crushed rock should be used. It is important that the gravel pad be  properly graded.

Grizzly – A device using rails, pipes or grates to dislodge mud, dirt and debris from the tires and undercarriage of vehicles prior to leaving the work site. An example of a grizzly is the “shaker” invented by Jeff Lange for Kitchell Contracting. This device is reusable, transportable by pickup truck, easy to assemble, and can be expanded to accommodate various sizes of haul vehicles. More information about the shaker device can be obtained at www.trackoutcontrol.com.

Paving – The paved surface must extend from the point of intersection with a paved public roadway at least 100 ft. back onto the site and have a width of at least 20 ft.

In addition, cleanup of trackout must be done immediately if it extends 50 linear feet or more onto the paved public road. Otherwise, the trackout must be cleaned up by the end of the workday. Cleanup may be performed with a street sweeper or wet broom or by manually sweeping up the deposits.

A gravel pad is a stabilized construction entrance, designed to remove the mud and dirt from the tires of vehicles leaving a construction site.

Using gravel pads reduces fugitive dust caused by trackout onto paved roads and surfaces. The use of such pads may also reduce the need for street sweepers or laborers to remove trackout from paved surfaces, as well as help prevent storm water pollution.

Dust Control Plans require that stabilized construction entrances be installed at all access points if any material is to be hauled on or off the site, or if the site is larger than 5 acres.

GRAVEL PAD DESIGN:

Use one inch (1˝) to three inches (3”) in diameter, washed,  well-  graded gravel or crushed rock. The gravel pad should be at least 30 ft. wide by 50 ft. long, and a minimum of 6 in. deep. When installing the gravel pad, make sure that it is properly graded.

FACT SHEET #11:

Erosion Control

Measures to Reduce Erosion

The following temporary measures are useful for controlling soil erosion during construction:

• Vegetative Cover
• Mulch
• Surface Roughening
• Irrigation
• Spray-On Adhesives
• Calcium Chloride
• Stone
• Barriers

These same measures are also effective in reducing airborne dust particles that contribute to particulate air pollution.

Planting vegetative cover re-stabilizes disturbed surface areas that will not be brought to final grade for more than 30 days. Examples include trees, shrubs, vines or ground covers. Seeding reduces erosion and decreases sediment yield. These techniques also provide wildlife habitat and enhance the natural beauty of the area.

Mulch is applied to the soil surface to conserve a desirable soil property or to promote plant growth. A surface mulch is one of the most effective means of controlling runoff and erosion on disturbed land. Some organic mulches include straw, hay, corn stalks, bark chips, and fiber mulch.

Surface roughening during tillage reduces runoff, increases infiltration, and traps sediment.    This practice is designed to roughen and bring clods to the surface.

Plowing is done on the windward side of the site with chisel-type plows spaced 12 inches part. This is generally done as an emergency measure before wind erosion starts.

Irrigation is the most commonly used erosion and dust control practice. The site is sprinkled with water until the surface is wet and this is repeated, as needed. This offers fast protection for haul roads and other heavy traffic routes.

Spray-on adhesives are most effective in controlling erosion of mineral soils. Many are able to withstand heavy traffic loads. Some examples are asphalt emulsion, latex emulsion, resin in water, and acrylic emulsion.

Calcium chloride may be applied with a mechanical spreader as loose, dry granules or flakes at a rate that keeps the surface moist, but not so high as to cause water pollution or plant damage.

Stone applied to entrances and exits of a construction site will prevent tracking or flow  of mud onto paved public rights-of-way. This may require periodic top dressing with additional stone, the washing and reworking of stone, and repair of any structures used to trap sediment as conditions demand. Generally, 2-3 inch stone is applied.

Barriers that decrease erosion and dust include board, wind, and sediment fences. If placed perpendicular to prevailing air currents, these help to control blowing soil.

FACT SHEET #12:

Effective Watering

Watering is a very effective dust suppressant. When applied regularly, water provides  temporary stabilization to disturbed surface areas and reduces fugitive dust caused by earthmoving and driving on nonstabilized surface  areas.  Water also aids in compaction.

Maricopa County Earthmoving Permits require that fugitive dust generated from all earthmoving activities be controlled. Watering is one way to control fugitive dust (see your Dust  Control Plan).

How much watering is enough?

• Roads   and   disturbed   surfaces    visibly appear moist with minimal silt.
• Soil has a crusted surface and is  not  easily crumbled between your fingers.
• Soil moisture content is optimum for compaction.
• Visible emissions are less than 20 percent opacity.

SOME TECHNIQUES THAT MAY WORK

Prior to Any Activity on Site:

• Wet the area to depth of cuts or equipment penetration.

For Active Operations:

• Apply    water     15-30     minutes     before starting operations.
• Apply water at the end of the day (e.g. soak overnight the next day’s work area).
• During grading, water using  a  water truck.
• During trenching, water using  a  fine spray or mist.
• During screening, mist material after it drops from the screen.

After Clearing an Area:

• Apply water in sufficient frequency to prevent visible emissions (at least every 2 hours).
• Automatic sprinkler/spray bar  systems  are optimal in these areas.

For     Unpaved     Haul     Roads/Access     Roads/ Equipment Paths:

• Apply water in sufficient quantity to maintain a moist surface.
• Don’t over water—muddy conditions increase trackout.

Water Penetration

• Surfactants or palliatives added to water increase penetration.

If the area is inaccessible to water trucks due to slope conditions or other safety factors, watering should be conducted with water hoses or  sprinkler systems. Remember: many cities have restrictions for construction on sloped areas—be sure you comply with those as well.

Some dust suppressants are not designed for areas subject to daily disturbances, high volume traffic, or heavy equipment traffic—check  with  the product  vendor if these conditions exist at your site.

Maricopa County Earthmoving Permits require that fugitive dust generated from all earthmoving activities be controlled.  For many projects, dust palliatives can   be an effective and economical alternative to watering.

Be sure to ask the product vendor for  the  recommended  dilution,  application rate, and application frequency of the product you choose because these vary significantly by product. Before a weekend, holiday, or other inactive period of less than five days, a dust palliative that is diluted to not less than 1/20 of the concentration required to stabilize a surface for six months is recommended.

Maricopa County recommends the use of non-toxic, non-corrosive products. A contractor is responsible for assuring that its use of dust suppressants is in compliance with all applicable environmental laws.

FACT SHEET #14:

Visible Emissions and Opacity

What is Opacity?

Opacity is the reduction in visibility  caused by a cloud of dust.  The standard  limitation for visible emissions within Maricopa County is 20 percent opacity.

How Much is 20 Percent Opacity?

County inspectors are trained to read opacity, but there are ways that you can estimate opacity on the job. Twenty percent (20%) opacity is a faint cloud of dust through which you can readily see background details.

When Are Controls of Visible Emissions Required?

Measures controlling visible emissions must be implemented during all periods of dust generating operations. The specific dust control measures, including contingency measures, are contained in the Dust Control Plan which is part of each regulated site’s earthmoving permit.

A regulated site should implement contingency measures as necessary to prevent visible emissions from reaching 20% opacity, rather than waiting until emissions reach that level. Additional  precautions  should  be taken to prevent the dust cloud from crossing the property line.

When Does the Opacity Limitation Apply?

The 20 percent opacity limitation applies at  all times except when the average wind speed is greater than 25 miles per hour,  provided that all reasonably available control measures contained in the approved Dust Control Plan are in place.

Visible Emissions Testing

The Arizona Department of Environmental Quality (ADEQ) holds classes twice a year in various locations throughout the state to train and certify individuals in reading opacity. While not mandatory, all construction superintendents, project managers, and foremen are encouraged to attend. Becoming certified enables you to determine your project’s level of compliance with opacity guidelines or requirements.  Contact  ADEQ  at (602) 506-6700 for details on class times and locations.

A PM10 Plan for Maricopa County was approved by the U.S. Environmental Protection Agency on July 25, 2002. The plan shows  that the area will attain the Federal PM10 standards by the end of 2006. The Plan has 77 measures to reduce particulate air pollution from significant sources such as agriculture, wood burning,  driving  on  paved and unpaved roads, vacant lots, gasoline and diesel exhaust, and fast-food restaurants. The measure that is most effective in reducing particulate air pollution is Maricopa County’s Dust Control Rule 310.  By 2006, Rule 310 is expected to  reduce  airborne  particulates produced by construction sites and other earthmoving sources by 72 percent.

Compliance with Rule 310 is essential for the Valley to meet  the  federal air quality standards. If we don’t, there will be serious consequences, such as the loss of Federal dollars needed to build highways and light rail. And Maricopa County residents and visitors  will continue to breathe particulate air pollution. So it is important for every construction site to do its part to comply with  Rule  310  and “bust the dust.”

Part I.

Why Do We Need to Control Dust?

I-1. DUST CAN CREATE PARTICULATE AIR POLLUTION

Fine particulates are invisible solids or liquid droplets that remain suspended in the air. In addition to dust, fine particulates can be formed from pollen, mold, ash, soot, and gases. The federal government has set standards for fine particulates to protect public health: Particulate matter smaller than 10 microns in diameter are referred to as PM₁₀, and those smaller than 2.5 microns in diameter are referred to as PM_2.5.

PM₁₀ is primarily geologic materials such as rock and soils. Soil particles from 4 to 10 microns in diameter are typically silt, and those less than 4 microns in diameter are clay particles. The even smaller PM_2.5 particles are usually emitted by combustion sources and formed by gases. In addition, some clay soil particles are smaller than 2.5 microns in diameter.

I-2. PARTICULATE AIR POLLUTION CAN BE HARMFUL TO YOUR HEALTH

When inhaled, coarse particles (between 2.5 and 10 microns) are deposited in the upper respiratory tract. The smaller particles (less than 2.5 microns) can be deposited lower, in the pulmonary tissues, and invade the alveoli of the lungs. These more invasive particles can bond with toxins and other airborne chemicals before they are inhaled. It is difficult for the human body to eject the fine particles, once they are deposited in the lower lungs.

In the lungs, PM decreases breathing efficiency and alters the body’s natural defense systems. Highly sensitive groups include the elderly, asthmatics and children. Epidemiological studies have shown causal relationships between high particulate concentrations and increased mortality and morbidity.

Medical studies have shown that higher PM₁₀ concentrations can be linked to an increased number of premature deaths, asthma attacks, hospital admissions, and emergency room visits, and an overall decrease in lung functioning efficiency.

In 1995, the Arizona Comparative Environmental Risk Project ranked particulate pollution as one of the highest environmental risks in the state. This conclusion was based on increased hospital admissions for respiratory problems, asthma, and lower and upper respiratory symptoms, due to high annual PM₁₀ concentrations. In the same study, premature deaths due to PM₁₀ were estimated to approach 700 per year in Maricopa County and 1,000 per year statewide.

Construction Activities Can Create Crystalline Silica Dust

One particularly dangerous form of particulates found on construction sites is crystalline silica dust. Crystalline silica is found in common materials such as concrete, masonry, sand, quartz and granite rock. Inhaling dust produced from these materials can cause permanent lung damage, called silicosis. Silicosis is responsible for about 300 deaths per year in the U.S. OSHA and the Arizona Division of Occupational Safety and Health are so concerned about the non-reversible health effects of silicosis that they are providing local training on how to control silica dust at construction sites.

Other Impacts of Particulate Air Pollution

In addition to the health impacts, the smallest particulates (PM_2.5) are a constituent of the “brown cloud” that hangs over the Valley and obscures our blue skies on many mornings of the year. Scientific measurements by the Arizona Department of Environmental Quality indicate that visibility has not improved in the Phoenix metro area since 1994. PM_2.5 also contributes to the regional haze that reduces visibility at wilderness areas, parks, and other pristine areas located downwind of Maricopa County. On a more localized level, particulates from construction sites, vacant lots and fields, blowing across public or private roads can reduce visibility. As a secondary impact, high levels of dust are also responsible for soiling clothes, vehicles, buildings, and other public and personal property and the resultant cleaning and repair costs.

EXERCISE I-2. IMPACTS OF PARTICULATE AIR POLLUTION

I-3. WHAT CAUSES PARTICULATE AIR POLLUTION?

Particulates are emitted into the air by both natural events and human activities, including

• Construction and earthmoving operations
• Reentrainment of dust by vehicles traveling on paved roads
• Vehicles driving on unpaved roads, unpaved parking lots and vacant lots
• Agricultural activities
• Sustained winds greater than 15 mph
• Gusting winds greater than 25 mph
• Drought
• Excessive rainfall

Human Sources of Particulate Air Pollution

People are responsible for most of the particulates present in the air that we breathe; in urban areas, humans contribute at least 60 percent of the PM₁₀ air pollution problem.

Engine exhaust from on-road vehicles and off-road equipment emits a large proportion of the smallest particles (PM_2.5). About one-half of the PM_2.5 is emitted in gasoline exhaust; another 15% comes from diesel exhaust. Emissions from older, poorly tuned vehicles and engines starting up in the colder fall and winter mornings are the major sources of PM_2.5 in Maricopa County.

The major sources of the slightly larger, although still invisible, PM₁₀ particles in the Valley are construction and earthmoving operations, re-entrainment of fugitive dust by vehicles driving on paved roads (large trucks, in particular, can create a sizable “wake”), vehicles driving on unpaved roads (especially at high speeds), agricultural activities, and vacant lots. Winds greater than 15 mph can whip-up the human-disturbed dust and cause exceedances of the 24-hour PM₁₀ standard. Activities that cause persistently high PM₁₀ in the same location can cause violations  of the annual PM₁₀ standard. Agricultural tilling and vehicles on paved and unpaved roadways can contribute to high PM₁₀ concentrations.

Natural Sources of Particulate Air Pollution

Winds sweeping over the natural desert around us contribute some of the airborne particulates, although not as much as you might think. The vegetation in the desert and the crust that forms after rains tends to put a natural “lid” on fugitive dust. In addition, sustained high winds exceeding 15 mph only occur on a few days each year. PM measurements taken at the relatively pristine Organ Pipe Cactus National Monument in southeastern Arizona indicate that natural conditions represent about 20% of the standards. That is, about 10 µg/m3 of the 50 µg/m3  annual standard for PM₁₀ is prevalent in the atmosphere as a result of natural desert terrain. PM₁₀ emitted by natural sources (i.e. dust devils, pollen from plants) is generally higher in an urban environment, usually in the range of 30-40 percent of the standard. The remaining  concentrations can be attributed to human activities that have disturbed the soil or re-suspended the dust back into the air.

EXERCISE I-3. SOURCES OF PARTICULATE AIR POLLUTION

I-4. SOIL CHARACTERISTICS THAT PRODUCE PARTICULATE AIR POLLUTION

Some soil types are more conducive to the creation of particulate air pollution than others. When disturbed by human activities, for example, clay or clay/silt mixture soils create much smaller particles that stay suspended in the air. On the other hand, sandy soils create heavier particles that are more quickly re-deposited on the ground.

Before beginning any demolition or earthmoving activities, a geotechnical analysis should be performed to determine both the texture and the shrink/swell potential of the soil onsite. Such an analysis applies to both soils existing onsite that will be disturbed and soils being imported to the site.

Soil Texture and Shrink/Swell Potential

Soil texture refers to the relative amounts of sand, silt, and clay particles contained in the soil. These particles are defined as follows: Particles less than 2 microns in diameter are considered clay. Those between 2 and 50 microns in diameter are defined as silt, and those between 50 and 2,000 microns in diameter are sand. Anything over 2,000 microns (2 millimeters) in size is considered gravel.

The extent to which soil shrinks as it dries or swells when wet is affected by the amount of clay in the soil. Shrink/swell potential is defined as the relative change in volume anticipated in the soil material with changes in the moisture content. Clay soils retain  more water, while sandy soils drain water more easily.

This soil textural triangle depicts the different types of soils having the four different shrink/swell characteristics.

Source: Nebraska Earth Science Education Network (NESEN), University of Nebraska-Lincoln

EXERCISE I-4. SOIL CHARACTERISTICS

I-5. NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PARTICULATE AIR POLLUTION

There are two federal standards for PM₁₀ and PM_2.5: an annual and a 24-hour  standard.  Maricopa County does not violate either of the PM_2.5 standards, but violates both the annual and daily standards for PM₁₀.

The Arizona Department of Environmental Quality (ADEQ), in cooperation with county and local agencies, prepares air quality plans for most areas of the state, except Phoenix and Tucson. The ADEQ submits nonattainment and maintenance plans to EPA for approval. If a required  plan is disapproved or is not complied with, EPA may impose sanctions on the development of new industries likely to be sources of air pollution and on federal transportation funding.

Nonattainment and Maintenance Areas in Arizona

An area is designated “nonattainment” if it violates the National Ambient Air Quality Standards (NAAQS) for one or more pollutants. The EPA makes this designation on the basis of multiple years of air quality monitoring data that show a standard is consistently violated.             Nonattainment areas boundaries sometimes follow political boundaries (i.e. counties) or may be delineated on the basis of other factors (i.e. census urbanized areas), agreed upon by the Governor and EPA. Fourteen areas in Arizona have been designated by EPA as nonattainment or maintenance areas for carbon monoxide, ozone (one-hour standard), PM₁₀, or sulfur dioxide. No areas in Arizona violate the federal standards for PM2.5.

A nonattainment area may be classified as marginal, moderate, serious, severe, or extreme, depending upon the pollutant and the severity of the NAAQS violations.

Benefits of Controlling Construction Dust

Controlling construction dust

• Protects health of construction workers
• Improves health of the young, elderly and asthmatics
• Reduces dust complaints
• Enhances community “good will”

What is Particulate Matter?

• Tiny solids or liquid droplets that remain suspended in the air
• Dust, pollen, mold, ash, soot, aerosols
• PM10 =  particulates smaller than 10 microns
• PM2.5 =  particulates smaller than 2.5 microns
• A human hair is about 70 microns

• Primarily geologic materials; rock and soils
• Soil particles are typically silt (4-10 microns) and clay particles (<4 microns)
• Smaller PM2.5 particles represent about 25 – 30 percent of PM10 in urbanareas

PM2.5

• Usually emitted by combustion sources and formed by gases
• Small fraction made up of clay soil particles smaller than 2.5 microns in diameter

Soil Particle Sizes

National Ambient Air Quality Standards for PM10 and PM2.5

• Two federal standards for PM10 andPM2.5
  • –Annual
  • –24-hour or daily
• Maricopa County does not violate either of these standards for PM2.5
• But Maricopa County violates both the annual and 24-hour standards for PM10

How PM Is Monitored

• PM10 and PM2.5 are monitored using samplers sited near major sources
• In Maricopa County in 2000
  • –Seven PM2.5 monitors
  • –Nineteen PM10 monitors
• Collect PM over a 24-hour period, typically every 6 days
• Daily measurements are averaged over a calendar year to calculate annual concentrations

How Violations Are Measured

• AnnualStandard
  • –The three-year average of annual means at a monitor must be greater than the standard
  • 15 ug/m3 for PM2.5
  • 50 ug/m3 for PM10
• 24-HourStandard
  • –Expected number of exceedances of the standard when averaged over a three-year period is greater than 1.0
  • 35 ug/m3 for PM2.5
  • 150 ug/m3 for PM10]

Central Phoenix Air Monitoring Site

Source: Maricopa County Environmental Services Department

Trends in PM Concentrations

• PM2.5
  • –No violations of the PM2.5 standards have ever been recorded in Maricopa County
  • –Trend is likely to continue
• PM10
  • –The number of sites exceeding the annual standard and days exceeding the 24-hour standard have not declined in recent years

PM10 Trends

Sites Exceeding the Annual Standard

PM10 Trends

Days Exceeding the 24-Hour Standard

Where Do Violations Occur?

• Based on 1999-2001 data, five monitors violated the annual standard for PM10
  • –Chandler
  • –Durango Complex
  • –Greenwood
  • –Salt River Service Center
  • –South Phoenix
• These sites, as well as the Maryvale monitor, also violated the 24-hour standard for PM10
• Maricopa County will not achieve attainment until ALL monitors consistently meet both the annual and 24-hour PM10 standards

PM10 Monitoring Sites

Health Impacts of PM

• When inhaled, PM particles are deposited in the lungs
  • –Coarse particles (between 2.5 and 10 microns) stay in upper respiratory tract
  • –Fine particles (less than 2.5 microns) invade pulmonary tissues
• Once in the lungs, the particles decrease breathing efficiency and alter the body’s natural defense mechanisms
• High risk groups
  • –Elderly
  • –Asthmatics
  • –Young children

Medical Data for PM10

• Health Effects – For every 10 mg/m3 increase on a daily or multi-day basis
  • –       Mortality – +1.0%
  • –       Morbidity
  • •       Asthma – +3.0%
  • Hospital admissions for respiratory disease – +1.2%
  • Emergency room visits – +1.0%
  • FEV-1 (lung function) – -0.3%
• Premature deaths in Arizona due to PM10 approached 1,000 in 1995

Source: Pope, Dockery & Schwartz (1994)

Arizona Comparative Environmental Risk Project, 1995

Quality of Life Impacts of PM

• Contributes to the Valley’s “Brown Cloud”
• The Arizona Dept. of Environmental Quality has taken measurements indicating that visibility has been declining in Maricopa County since 1994
• Contributes to regional haze at wilderness areas & national parks (i.e. Grand Canyon)
• Dust blowing across roads can reduce visibility and cause traffic accidents
• Soils clothes, vehicles, buildings, other property

What Causes PM?

• Particulates are emitted into the air by both natural and human sources
  • –Natural Sources
    • Winds >15 mph; especially, wind gusts >25 mph
    • Pollen(PM2.5)
    • Natural desert with undisturbed vegetation and soil
    • Measurements at Organ Pipe Cactus National Monument = 20% of standard
  • –Human Sources
    • Human activities cause most of the PM that we breathe
    • In urban areas, humans are responsible for at least 60% of the PM10 problems

Dust Storm Development

Source: Arizona Department of Environmental Quality

Four photos © Jeff Jacobson, 1999

Organ Pipe Cactus National Monument

Copyright © 2001 Arizona State University College of Public Programs

Sources of PM2.5

• Engine exhaust from vehicles and equipment
• About one-half comes from gasoline exhaust
• Another 15%, from diesel exhaust
• Older, poorly-tuned vehicles and vehicles/engines starting up on colder mornings are the major sources of PM2.5 in MaricopaCounty

Major Sources of Coarse PM10 Particles

• Construction and earthmoving operations
• Reentrainment of dust by vehicles traveling on paved roads
• Vehicles driving on unpaved roads
• Agricultural activities
• Vacant lots

Sources of PM10

1995 Regional Emissions

Source:MAG 1999 Serious Area Particulate Plan for PM-10 for the Maricopa County Nonattainment Area, February 2000

Sources of PM10

• In Maricopa County, exceedances of the PM10 standards have been recorded near:

• –An elevated freeway (Greenwood)
• –Shopping center and freeway construction (West Chandler)
• –Industrial sources and unpaved haul roads (Salt River)
• –Agricultural fields (Higley)

Some Sources of PM10

Source: Guide to Agricultural PM10 Best Management Practices

Source: Maricopa County Environmental Services Department

PM10“Hot Spot”

• Highest concentrations in the Valley occur at the Salt River Service Center monitor near 22nd Ave and Lower Buckeye Rd

• Large number of potential sources

• • –Two landfills (one EPA Superfund site)
  • –Sand and gravel operations
  • –Pre-stressed concrete manufacturing yard
  • –Bus storage depot
  • –Unpaved haul roads and shoulders
  • –Vacant lots

• ADEQ & County are conducting study to determine sources of persistently high PM at Salt River site

Salt River Service Center Sources

Source: Maricopa County Environmental Services Department

Natural Conditions Contributing to PM10

• Lower annual rainfall usually leads to higher annual PM10 concentrations

• Wet years can also contribute to elevated PM10

–Mud tracked onto pavement dries and is subsequently ejected into the air by moving vehicles

• High winds, especially >25 mph, can cause exceedances of the 24-hour standard

–On August 22, 2000, six monitors exceeded standard

• However, most exceedances of the 24-hour standard happen on days that are not windy

• Elevated PM10 can occur at any time of year

Natural Conditions Contributing to PM10

• Some soil types can create more PM10 than others

–Sandy soils create heavier particles that are quickly re-deposited

–Soils that are clay or a clay mixture

• Tend to create much smaller particles, when disturbed

• Particles are more likely to stay suspended in the air

•   PM10 soils map based on NRCS survey data

–Shows general areas in Maricopa County that have soils most and least likely to generate PM10, if disturbed

PM10 Soils Map

Source: Maricopa Association of Governments

What is Being Done to Reduce PM10?

• EPA sets National Ambient Air Quality Standards (NAAQS)

–PM10, PM2.5, carbon monoxide, nitrogen dioxide, sulfur dioxide, lead, and ozone

–Fuel, vehicle tailpipe, and engine emission standards

• Federal emission control programs have been most effective in reducing air pollution in urban areas

• New standards announced in 1999 & 2000

–Will cut PM and NOx emissions by 90%

–Tier 2 light duty car and truck standards (2004)

–Low sulfur fuels (mid-2006)

–Heavy-duty vehicle and engine standards (2007)

National Air QualityTrends

Source: Federal Highway Administration, 2002

National Trends in PM10 Emissions – 1985-1999

Source: Federal Highway Administration

What is Being Done to Reduce PM10?

• Under the Clean Air Act, an area that does not meet the national air quality standards is designated a nonattainment area
• Nonattainment areas
  • –Receive classifications (i.e., Moderate, Serious) based on the severity of the problem
  • –Must submit plans showing that the standards will be attained & maintained
• If a plan is not submitted on time or is found to be inadequate, EPA can impose sanctions
  • –2-for-1 offsets on new & modified major industrial sources
  • –Highway sanctions – millions of federal $ in jeopardy

PM10 NonAttainment Area

MAG PM10 Plan

(7,000 pages high)

 

PM10 Control Measures in Maricopa County

• EPA-approved Plan contains 77 control measures
  • –Legally-binding commitments by the State, County, cities, towns, MAG and ADOT to reduce PM10
• To obtain a five-year extension to 2006, the Plan must include the most stringent control measures in the Country that could be feasibly implemented in Maricopa County
  • –Purchase PM10 efficient street sweepers
  • –Recognize PM10 episodes
  • –Require catalytic converters on chain-driven restaurant charbroilers

A PM-10 Efficient Street Sweeper.

Source: Kitchell Contracting

PM10 Control Measures in Maricopa County

• In the Plan EPA approved in January 2002, numeric emission reduction credit was taken for twelve of the 77 control measures
• Combined impact of 12 quantified measures was 39% reduction in 2006
• The most effective control measure in the Plan, by far, is the strengthening/better enforcement of Maricopa County’s Rule 310: Fugitive Dust Controls

2006 PM10 Emission Reductions from Committed Control Measures

Effectiveness of Rule 310

• Rule 310 reduces PM10 emissions from construction, vehicle track-out, and unpaved lots
• Rule 310 reductions represent 80% of the numeric credit assumed for all control measures in the Plan
• Impact of strengthening and better enforcement of Rule 310 on construction and earthmoving activities alone accounts for 19%, or nearly half, of the total emission reductions

Other Efforts to Reduce PM10

Clark County, Nevada (Las Vegas)

• Serious PM10 nonattainment area, like Maricopa Co.
• Submitted Serious Area PM10 Plan to EPA in July 200
• Requested a five-year extension (to Dec 31, 2006) to attain the 24-hour PM10 standard
• Unlike Maricopa Co., attained the annual PM10 standard in 2001
• Has implemented a construction dust control program, called Section 94

Clark County Section 94

• Contracts
  • –Requirements & conditions of dust control permit must be included in all construction contracts
  • –A monetary allowance for dust control must be provided in all contracts for primes and subcontractors
• DustMonitor
  • –Projects having > 50 acres of actively disturbed soil must have a dust control monitor on site at all times
  • –Monitor must have authority to implement dust control measures; be able to shut down operations, if necessary
  • –Must successfully complete a Dust Control Class and a Dust Monitor Class every three years and have at least two years of experience in the construction industry

Clark County Section 94

– Dust Control Card

• Awarded upon successful completion of a Dust Control Class every three years (must pass an exam)
• The construction site superintendent, foreman ,or other designated representative of the project developer must carry a current Dust Control Card

• All water truck/pull drivers must have a current Dust Control Card

• Half-day Dust Control Classes are offered by Clark County twice a week ($35 fee)

Regional Haze Planning

• EPA’s Regional Haze Rule requires states to restore visibility in 156 wilderness areas and national parks to natural conditions by 2064
  • –AZ has 12 Class I Areas, including the Grand Canyon
• Arizona and some other western states are preparing plans to submit to EPA by December 31, 2003
• Regional haze is made up of hydrocarbons, elemental and organic carbon, sulfur dioxides, nitrogen oxides, PM10 andPM2.5
• New controls implemented to improve visibility may also reduce PM in Maricopa County

Regional Haze Class I Areas in Arizona

1.              Grand Canyon NP
2.              Petrified Forest NP
3.              SycamoreCanyon
4.              Pine Mountain Wilderness
5.              MazatzalWilderness
6.              SuperstitionWilderness
7.              Sierra Ancha Wildernes

8.              GaliuroWilderness

9.              Mount Baldy Wilderness
10.            SaguaroNP
11.            Chiricahua NM
12.            Chiricahua Wilderness

Governor’s Brown Cloud Summit

• Recommended ways to improve visibility in the Valley
• “Blue Sky Days” > 6 hours with 25+ mile visibility
  • –250 Blue Sky Days by 2001
  • –260 Blue Sky Days by 2002
  • –275 Blue Sky Days by 2003

Blue Sky Day versus non-Blue Sky Day

Source: Arizona Department of Environmental Quality

Source Contributions to Fall and Winter Visibility Impairment in Phoenix

Source:       Arizona Department of Environmental Quality, Visibility Impairment in Phoenix,

ENSR Document 0493-018-23, March 2002

Measures Implemented by HB 2538

• VoluntaryMeasures
  • –         On-road diesel vehicle repair / retrofit
  • –         Ultra-low sulfur diesel fuel with oxidation catalysts and particulate filters for vehicle fleets
  • –         Encourage use of truck bypass routes on poor visibility days
• MandatoryMeasures
  • –          Vehicle idling restrictions
  • –          Expansion of Area A (area in which I/M, reformulated fuels, clean burning fireplaces, and other air pollution controls apply)
  • –          Roadside diesel testing
  • –          Electric powered generators at construction sites

Dust Control Training for Contractors

• The following Brown Cloud Summit recommendation was not included in H.B. 2538:
  • Develop a standardized dust control certification program for construction companies
  • Require participation in training and certification program in order to obtain a county permit
• Encourage construction superintendents, water truck/pull drivers, and subcontractors to attend a dust control course and receive certification
  • This training course and a certification program for Maricopa County have been developed to address the Brown Cloud Summit recommendation
  • Voluntary approach may be as effective as mandatory participation (i.e. Clark County, Nevada)

ADOT Initiatives to Reduce Construction Dust

• ADOT has funded a research project to develop:
  • –Outreach materials
  • –Training course
  • –Voluntary certification program
• Principalproducts
  • –Training course slide show and script
  • –Toolkit of materials that can be used at work sites
  • –Dust control guide for construction managers
  • –Brochure informing public of ongoing efforts by construction industry to reduce dust
• Goal – Make dust suppression a standard operating practice at all construction sites in Arizona

Why We Need to Control Dust

End of Training Module #1

• Questions?

Part II

How Can Construction Dust Be Controlled?

II-1. SITE PLANNING

Designing and Implementing a Construction Project to Minimize Dust

Addressing dust control issues before beginning a project can save time, money, and project resources. Site-specific air quality and dust control issues—and appropriate ways to tackle them—should be identified before work begins. Strategies for trackout prevention, the handling, storage, and transportation of bulk materials on and off-site, dust-minimizing procedures during construction, and site maintenance should all be discussed.

Disturbed surface area – pre-activity

To minimize dust generation from disturbed areas before beginning construction, plan ahead, pre-water work site to the depth of cuts, and proceed in stages to minimize amount of disturbed surface area present at any given time.

Phasing the project and planning site layout carefully will result in minimized soil disturbance. Lessening the amount of surface being disturbed at any one time reduces the amount of control required and the amount of water or dust suppressant needed. Evaluate dust control procedures periodically to identify additional issues that develop as the job progresses.

Install wind fences or barriers (less than 50 percent porosity). Place barriers around storage  piles, parking, and equipment staging areas. Develop semi-permanent staging areas to cut down on the amount of disturbed area. Restrict access on unpaved areas to vehicles and equipment that are necessary that day. Limit unnecessary travel on unpaved surface areas. Restabilize disturbed surfaces by paving permanent roads and restoring vegetation as soon as possible. Allow time for pre-wetting areas where excavation or trenching will occur.

Make sure everyone working on the job knows all the requirements for dust control and who is in charge. Encourage a proactive and continuous focus on air quality issues on the job site.

II-2. BULK MATERIAL HANDLING, STORAGE AND TRANSPORTATION

Material handling refers to many types of earthmoving activities on construction sites, including loading and hauling. These types of activities can be significant sources of fugitive dust. However, dust control during loading and hauling can be easily achieved through careful planning and proper implementation of controls. When planning a construction  project  involving earthmoving activity, strategies for bulk material handling, storage, and transportation that minimize dust generation must be developed. Strategies are needed for handling or hauling material off-site onto paved public roadways, completely within the boundaries of the work site, or when crossing a public roadway that is open during construction. Strategies for preventing open storage piles from creating dust are also needed.

Hauling On the Work Site

To control dust generated by hauling bulk material within the boundaries of the work site:

• Load all haul trucks so that the freeboard is 3 inches or more
• Prevent spillage or loss of material from holes or other openings in the cargo compartment floor, sides and tailgate
• Install a trackout control device that removes dirt from tires and exterior surfaces of haul trucks and motor vehicles that traverse the work site
• Empty loader bucket slowly and keep loader bucket close to the truck while dumping
• If soils are sand or loam, mix with water prior to loading and spray material with water while loading
• If soils are clay or silt, mix with water and surfactant mixture prior to loading and spray with water/surfactant mixture while loading
• Limit vehicle speeds to 15 mph on site
• Apply water to the top of the load so that 20 percent opacity is not exceeded
• Cover haul trucks with a tarp or other suitable closure

Hauling Off the Work Site

When hauling bulk material off-site, the loads on haul trucks should be covered with tarps to keep dust from escaping. Allow for a freeboard of 3 inches or more. Spillage or loss of material from holes or other openings in the cargo compartment floor, sides and tailgate should be prevented. Daily vacuuming, wet broom cleaning, or covering the cargo compartment interiors of empty trucks is important to prevent trackout.

Open Storage Piles (when not stacking, loading or unloading)

• Cover Open Storage piles with tarps, plastic or other material and secure so that the coverings will not be dislodged by wind
• Apply water as necessary to keep the soil moist
• Keep the soil stabilized
• Construct and maintain wind barriers, storage silos, or a three-sided enclosure with walls, at least as wide and tall as the pile, no farther away than twice the height of the pile, and no more than 50 percent porosity

EXERCISE II-2. BULK MATERIAL HANDLING

II-3. CONSTRUCTION OPERATIONS

Five areas that typically generate dust during construction work are:

• Demolition and blasting
• Disturbed surface area – during construction
• Earthmoving operations on disturbed surface areas 1/2 acre or larger
• Unpaved haul and access roads
• Unpaved parking areas

Demolition and Blasting

Stabilize demolition debris and surrounding area through watering immediately following demolition activity. Water all disturbed soil surfaces to establish a crust and prevent wind  erosion of soil. Thoroughly clean blast debris from paved and other surfaces following demolition activity. If the wind gusts above 25 mph, discontinue blasting.

Disturbed surface area – during construction

During construction, apply water or dust suppressant to work area and construct fences or 3 to 5 foot high wind barriers adjacent to roadways or urban areas. During grading, water using a water truck; during trenching, water using a fine spray or mist; and during screening, mist material after it drops from the screen.

Earthmoving operations on disturbed surface areas 1/2 acre or larger

When the area under construction is 1/2 acre or more, water should be applied during all earthmoving operations.

Unpaved haul and access roads

Vehicle speeds on unpaved haul and access roads should not exceed 15 mph. Also, the number of trips should not exceed 20 per day. If the number of trips exceeds 20 per day, then one of the following additional measures should be implemented:

• Apply water in sufficient quantity to maintain a moist surface
• Apply and maintain gravel, recycled asphalt, or other suitable material
• Use a dust suppressant as directed by the manufacturer, or
• Pave the access roads

Be sure not to over-water—muddy conditions will increase trackout.

Unpaved Parking Areas

Unpaved areas of a site that are going to be used for parking construction equipment, work trucks, or employee vehicles should be treated as follows:

• Apply and maintain surface gravel, recycled asphalt, or other suitable material
• Apply and maintain a suitable dust suppressant
• Pave the lot

Vehicles should not be allowed on unpaved areas of the work site unless they have been treated to reduce dust. Moreover, vehicle speeds over these areas should be limited to 15 mph or less and the number of daily trips kept to a minimum. “No Trespassing” signs or barriers such as curbs, fences, gates, posts, signs, shrubs or trees should be installed or planted to prevent access to non-treated work areas.

EXERCISE II-3. CONSTRUCTION OPERATIONS

II-4. SITE MAINTENANCE DURING CONSTRUCTION

Proper maintenance of the job site will reduce fugitive dust from unpaved parking lots, open areas and vacant lots, and disturbed surface areas. Surface areas that will be disturbed again during the current project should be temporarily stabilized during non-work days and after hours.

During non-work days, after hours, and on weekends, surface areas that have been disturbed during construction activity should be temporarily stabilized by treatments that will keep dust from exceeding 20 percent opacity. Effective treatments include establishing a  vegetative ground cover, paving, graveling, or applying a dust suppressant. Motorized vehicles should also be prevented from entering, driving across, or parking within the areas.

Appendix A of this Workbook includes methods of testing the soil type and characterizing the ground cover prior to determining the means of stabilization to be used.

EXERCISE II-4. SITE MAINTENANCE DURING CONSTRUCTION

II-5. SITE MAINTENANCE AFTER CONSTRUCTION

Those areas that will not be disturbed again must be permanently stabilized within eight months after dust-generating operations have ended. Within a reasonable time after dust-generating operations have been completed, construction areas that were disturbed should be permanently stabilized so that dust emitted from the site does not exceed 20 percent opacity. Efforts should  be made to restore these areas so that the vegetative ground cover and soil characteristics are similar to those of adjacent or nearby undisturbed native conditions. Alternatively, the areas could be graveled, paved, or treated with a dust suppressant.

Vehicular access to areas of the site that are not paved or otherwise made suitable for vehicles should be prevented through posting of signs and construction of fencing or barriers. If necessary, silt fences should be installed downstream from disturbed surfaces to prevent erosion or trackout until surface has crusted over or vegetative cover has taken hold. The site should be inspected periodically to ensure that it has not been disturbed or trespassed upon in ways that would destabilize the surface.

EXERCISE II-5. SITE MAINTENANCE AFTER CONSTRUCTION

II-6. DUST CONTROL MEASURES

Dust control measures used at construction sites include trackout control, erosion control, effective watering, and dust suppressants

Trackout Control

Control of trackout is required for all sites with disturbed area of 5 acres or more, or sites from which 100 yards or more of bulk materials are hauled on-site or off-site per day. Trackout is controlled through the use of gravel pads, grizzlies, paving, and appropriate watering.

Trackout that extends 50 linear feet or more onto a paved public road must be cleaned up immediately. Otherwise, the trackout must be cleaned up by the end of the workday. Cleanup may be performed with a street sweeper or wet broom with sufficient water, if applicable, at the speed recommended by the manufacturer or by manually sweeping up the deposits.

Trackout Control Devices

Dust Control Plans require that stabilized construction entrances be installed at all access points if 100 yards or more of bulk material per day is to be hauled on or off the site, or if the site is larger than 5 acres. A gravel pad is a stabilized construction entrance, designed to remove the mud and dirt from the tires of vehicles leaving a construction site. Using gravel pads reduce fugitive dust caused by trackout onto paved roads and surfaces. The use of such pads may also reduce the need for street sweepers or laborers to remove trackout from paved surfaces, as well as help prevent storm water pollution.

Gravel pads are typically made from one inch to three inches in diameter, washed, well graded gravel or crushed rock. The gravel pad should be at least 30 feet wide by 50 feet long, and a minimum of 6 inches deep. When installing the gravel pad, make sure that it is properly graded.

A Grizzly is a device using rails, pipes or grates to dislodge mud, dirt and debris from the tires and undercarriage of vehicles that drive over it prior to leaving the work site. An example of a grizzly is the “shaker” invented by Jeff Lange for Kitchell Contracting. This device is reusable, transportable by pick-up truck, easy to assemble, and can be expanded to accommodate various sizes of haul vehicles. More information about the shaker device can be obtained at www.trackoutcontrol.com.

Erosion Control

Temporary measures used to control erosion during construction include:

• Vegetative Cover
• Mulch
• Tillage
• Irrigation
• Spray-On Adhesives
• Stone
• Barrier
• Calcium Chloride

Erosion and sedimentation of soils from disturbed areas that will not be brought to final grade for a period of more than 30 days can be reduced by temporarily seeding these areas with appropriate rapidly growing annual plants. This seeding will also improve the natural attractiveness of the area awaiting construction activity. The area should be tilled immediately prior to seeding to promote the establishment of the vegetative cover and reduce water runoff.

Erosion can also be controlled by effective watering or by the application of a dust suppressant. Wind barriers such as board fences, wind fences, or sediment fences help to control air currents and blowing soil. These barriers should be placed perpendicular to the prevailing air currents. Fences also discourage trespassing and unauthorized vehicular use of erosion-prone areas.

Soil erosion onto paved public streets creates dust-generating conditions equivalent to trackout and must be cleaned up accordingly.

Effective Watering Strategies

Watering prior to excavation or earthmoving is an effective means of suppressing dust. When applied regularly, water provides temporary stabilization to disturbed surface areas and reduces fugitive dust caused by earthmoving and driving on non-stabilized surface areas.

Watering makes roads and disturbed surfaces appear moist with minimal silt, creates a crusted surface on the soil, provides soil moisture content optimal for compaction, and prevents visible emissions from exceeding 20 percent opacity. Adequately watered soil should have a crusted surface that is not easily crumbled between your fingers. The soil moisture content should be optimal for compaction.

Wet the area to the depth of cuts or equipment penetration 15 to 30 minutes prior to start of work. Apply water at the end of the day to soak the next day’s work area overnight. During grading, apply water in sufficient quantity to maintain a moist surface using a water truck.

Dust Suppressants

Dust Suppressants are products that are applied to soil surfaces in order to keep dust from being emitted into the air Chemical dust suppressants can reduce the need for watering and remain effective for up to 12 months in some cases. Some suppressants are not suitable for areas subject to high traffic volume or heavy equipment traffic. The product vendor should be consulted if these conditions exist at a particular site. The recommended dilution, application rate, and application frequency vary significantly by product. Before a weekend, holiday, or other  inactive period of less than 5 days, a dust palliative that is diluted to not less than 1/20 of the concentration required to stabilize a surface for 6 months is recommended.

Many counties require the use of environmentally compliant dust suppressants. Be sure to check with local authorities before choosing a dust suppressant. A contractor is responsible  for assuring that its use of dust suppressants is in compliance with all applicable environmental laws.

Water mixed with dust suppressants can increase the penetration of moisture into the soil. It is especially important to use a water/suppressant mixture if the soils being disturbed are predominately silt or clay. Use of dust suppressants can reduce the amount of water needed to keep the surface moist. Tackifiers and surfactants increase moisture penetration:

• Use water/tackifier mixture if soils are silt
• Use water/surfactant mixture if soils are clay

Use of chemical dust suppressants can reduce the amount of water needed

EXERCISE II-6. DUST CONTROL MEASURES

Requirements for Construction Activities in Maricopa County

• Firms or individuals planning activities involving 0.1 acre or more must
  • Obtain an Earthmoving Permit
  • Submit a Dust Control Plan
  • Comply with specific record-keeping, site maintenance, site signage, and other requirements

Earthmoving Permit

• Who must apply for a permit
• How to complete a permit form

Who Must Apply for a Permit

• An official responsible for any earthmoving operation that will disturb a total surface area of 0.10 acre or more
• ResponsibleOfficial
  • Corporation – Corporate officer or decision-maker
  • Partnership or sole proprietorship – partner or owner
  • Public sector agency – principal executive officer or ranking elected official

How to Complete a Permit Form

• Section 1 – Applicant Information
  • Submit the Appropriate Fee
    • 0.1 acre to less than 1 acre = $75.
    • 1 acre or more = $36/acre plus $110 per site
• Section 2 – Project Information – Drawing
  • Type of project
  • Address & legal description
  • Size of area, in acres, to be disturbed
  • Project start date
  • 8 1/2” x 11” or larger drawing
• Section 3 – Dust Control Plan

Elements of Earthmoving Permit Drawing

• Entire project site boundaries
• Acres to be disturbed with linear dimensions
• Nearest public roads
• Northarrow
• Planned exit locations onto paved public roadways

Dust Control Plan

• Requirements
• How to prepare a Dust Control Plan

Dust Control Plan Requirements

 

• ControlMeasures
  • One primary measure and one contingency measure
  • Stabilization plan for any unpaved haul or access roads
• Dust suppressants to be applied
  • Method, frequency, and intensity of application
  • Type, number and capacity of application equipment
• Plan to control trackout where unpaved or access points join paved public roadways

How to Prepare a Dust Control Plan

• Put a check ( Ö ) in the box in front of all the sources of fugitive dust that you anticipate
• Write the letters “NA” in the box in front of all the sources of fugitive dust that you do not anticipate implementing
• Write the letter “P” next to primary control measures that you will implement
• Write the letter “C” next to contingency control measures that you will implement

Example Fugitive Dust Source

Record-keeping Requirements

• Keep daily written log detailing use of control measures agreed to
• Keep copies of approved Dust Control Plans
  • At least 6 months from end of operations
  • At least 1 year total

How to Fill Out a Dust Control Log

General Standards

• 20% opacity limit
• Methods of testing for opacity

20% Opacity Limit

20% Opacity Limit

• Prevent visible emissions from reaching 20% opacity
• Prevent the dust cloud from crossing the property line
• 20% opacity limitation applies at all times except when the average wind speed is greater than 25 mph provided that all reasonably available control measures are in place
• Consider attending “Smoke School” to become certified in reading opacity levels Call (602) 506-6700 for details

Sign Requirements

For Sites of 5 Acres or Larger in Size

Control Measures Required for Construction Activities in Maricopa County

• Vehicleuse
• Disturbed surface areas
• Materialhauling
• Spillage and Trackout

Vehicle Use

• On open areas and vacant lots
  • Restrict trespassing with signs
  • Block access with barriers
• On unpaved parking lots
  • Water
  • Apply and maintain gravel, recycled asphalt, or other suitable material
  • Pave
  • Use dust suppressant
• On unpaved haul and access roads
  • Limit speed to 15 mph
  • Apply water, so that surface is visibly moist
  • Paveroad
  • Apply and maintain gravel, recycled asphalt, or other suitable material
  • Apply dust suppressant

Disturbed Surface Areas

• Before earthmoving operations
  • Pre-water site to the depth of cuts
  • Phase work to reduce the amount of disturbed surface area at any one time
• During earthmoving operations
  • Apply water or dust suppressants
  • Construct fences or wind barriers
  • Cease operations as a contingency
• Temporarystabilization
  • Apply water or dust suppressants
  • Establish vegetative ground cover
  • Restrict vehicular access
• After earthmoving operations
  • Restore area to resemble undisturbed conditions
  • Establish vegetative ground cover
  • Apply and maintain dust suppressants

Material Hauling – On-site

• Load trucks so that freeboard is at least three inches
• Prevent spillage from holes or other openings in the floor, sides, or tailgate of the cargo compartment
• Exit site over suitable trackout control device such as a gravel pad or a grizzly
• Load trucks so that freeboard is at least three inches
• Prevent spillage from holes or other openings in the floor, sides, or tailgate of the cargo compartment
• Cover load with tarp
• Cover or clean the interior of empty cargo compartment before leaving site
• Drive across gravel pad or grizzly when leaving site

Spillage and Trackout

• At all access points, install a gravel pad at least 30 feet wide, 50 feet long, and 6 inches deep
• Install a grizzly or wheel wash system at all access points
• Pave for a distance of at least 100 feet and a width of at least 20 feet
• Sweep up deposits

Part III

Opacity

And Other Test Methods At Construction Sites

For non-continuous dust plumes such as bulk material loading or unloading, the plume should be observed briefly every 5 seconds, and a minimum of 12 consecutive reading should be taken.  For continuous dust plumes such as those caused by graders, trenchers, and clearing operations, the plume should be observed briefly every 10 seconds, and at least 12 readings should be taken. The average of 12 readings is calculated to estimate the opacity of the plume.

Note that reading opacity levels accurately requires that the observer’s eyes be “calibrated” or conditioned to recognize the levels. Smoke school can provide this conditioning.

III-2. OTHER TEST METHODS

In addition to testing for the opacity of dust plumes, several other tests are performed at construction sites. These tests are designed primarily to determine the likelihood that an area to be disturbed at the site will generate dust when being disturbed, or as the result of wind occurring prior to or during earthmoving activities. Characteristics of the site such as the existence of vegetation or a visible soil crust will significantly reduce the amount of dust that is generated.

To ensure that work sites under construction or temporarily or permanently inactive do not emit dust during high winds, the disturbed surface should be stable. To be stable, the disturbed  surface should have a:

• Visible crust,
• Threshold friction velocity (TFV) of 100 centimeters per second (cm/s) or higher,
• Flat vegetative cover of at least 50 percent,
• Standing vegetative cover of at least 30 percent, or
• Cover of non-erodible elements greater than or equal to 10 percent.

The presence of sufficient visible crust is determined by performing the drop-ball test. If sufficient visible crust is not present, then a threshold friction velocity test should be performed. The TFV for a particular surface is the wind speed above which wind erosion of that surface will occur. A line transect test method is used to determine the percentage of flat vegetative cover, and a rock test method is used to determine the percentage of non-erodible elements (such as rocks). Summaries of these testing procedures are contained in Appendix A.

More Information on Opacity and Other Test Methods

Additional Information on opacity and other test methods for construction sites can be obtained from the ADEQ. The ADEQ Smoke School Information number is (602) 771-4851. Or visit their Smoke School Web page at: http://www.adeq.state.az.us/environ/air/compliance/smoke.html

EXERCISE III. OPACITY AND OTHER TEST METHODS

APPENDIX A – ADDITIONAL TEST METHODS

TEST METHOD FOR VISIBLE CRUST

The presence of sufficient visible crust is determined by performing the drop-ball test. For this purpose, a metallic ball 5/8 of an inch in diameter and weighing 16.33 grams is used. To  perform the test, follow these steps:

1. Clear away any blowsand (thin soil deposits, not originating on the site)
2. Drop the ball vertically from one-foot above the ground
3. Drop 3 times within a randomly-selected 1 foot by 1 foot area representative of disturbed conditions on the site
4. If the ball does not sink into the surface and when the ball is removed, the surface upon which it fell has not been pulverized, then there is sufficient crust
5. This must occur in two of the three drops

Repeat steps 1 through 5 in at least two other locations on the site. If sufficient crust is evident  in all tests, site passes the Visible Crust Determination Test.

TEST METHOD FOR THRESHOLD FRICTION VELOCITY

The threshold friction velocity (TFV) for a particular surface is the wind speed above which wind erosion of that surface will occur. Factors that affect the TFV of a site include the  existence of a visible crust, the average diameter of the surface particles, and the amount of non- erodible elements such as rocks present. Wherever a visible crust does not exist, testing should be conducted to estimate the TFV for the site.

The TFV tests are conducted using a set of sieves having openings of 4 mm, 2 mm, 1 mm, 0.5 mm, and 0.25 mm. The sieves should be stacked in order of opening sizes, with the sieve having the largest openings (4 mm) on the top and that having the smallest (0.25 mm) on the bottom. The TFV test consists of the following steps:

 

1. Place a collector pan below the stacked sieves
2. Collect a sample of loose material from a 1 foot by 1 foot area
   1. 1 cm in depth
   2. Use a broom and dustpan
   3. Collect dry material only
   4. Remove rocks greater than 1 cm
3. Place the loose material in the first stacked sieve (4 mm) and put a tight lid on the sieve/collector unit
4. With broad, circular, horizontal movements, shake the unit clockwise ten times, then counter-clockwise ten times
5. Remove the lid and estimate which sieve has the greatest volume
   1. If most material is in the 4 mm or 2 mm sieve, TFV is 100+ cm/s
6. Perform test at least three times on the site; average the resultant TFVs
7. Apply a correction factor based on the percent of non-erodible elements
8. 1. Larger than 1 cm, remain firmly in place, and inhibit soil loss during high winds
   2. Stones and bulk material, but not plants
   3. Sample a 1 meter by 1 meter representative area
9. If TFV corrected for non-erodibles is 100 cm/sec or higher, the area is considered to be stable

FLAT VEGETATIVE COVER

Flat vegetative cover is defined as both rooted vegetation and unattached vegetative debris lying on the surface in a predominantly horizontal position and not subject to movement by wind.

Line Transect Test Method for Flat Vegetative Cover

A line transect test method is used to determine the percentage of flat vegetative cover. The  steps of this method are:

1. Stretch 100 foot measuring tape across random representative area
2. Anchor tape at both ends; should be taut and close to the ground
3. View the vegetation below the 3/32 inch area from directly above
4. Count the number of times vegetation lies directly beneath a 3/32 inch diameter area spaced at one foot intervals on one side of the tape
5. To be counted, the vegetation should completely fill the 3/32 inch area
6. Conduct the test at least three times and average the results

If the percent of the area covered by flat vegetation is 50 percent or more, the area is considered to be stable.

STANDING VEGETATIVE COVER

Standing cover is defined as rooted vegetation in a predominantly vertical position and not subject to movement (re-location) by wind.

Test Method for Standing Vegetative Cover

The percentage of an area covered by standing vegetation is estimated by conducting the following steps:

1. For larger vegetation (shrubs or sagebrush), select a representative square area that is at least 10 times the average height of the vegetation
2. For smaller vegetation, chose an area 3 feet by 3 feet
3. Count the number of vegetative units
4. Select a unit that represents the average height and width of the vegetation
5. For larger vegetation, calculate the frontal silhouette area (height times width) and multiply by the number of vegetative units
6. For smaller vegetation, a vegetative density factor is derived by measuring the frontal silhouette relative to grids of 1 or ½ inch on paper
7. Divide by the survey area to determine the percent vegetative cover

If 30 percent of the area or more is covered by standing vegetation, the area is considered to be stable

NON-ERODIBLE ELEMENTS

Non-Erodible Elements are objects larger than 1 cm in diameter that remain firmly in place on windy days. Such elements include rocks, stones, glass fragments, and hard packed clumps of soil. Vegetation is not considered a non-erodible element.

Rock Test Method for Non-Erodible Elements

A rock test method is used to estimate the wind-resistance of non-erodible elements on disturbed surfaces. The steps of this method are:

1. Mark off a 1 meter by 1 meter area
2. Mentally group the elements greater than 1 cm (3/8 inch) into small, medium and large categories
3. Count the number of elements in the area in each group
4. Measure the length and width of an average element in each group
5. Multiply by the number of elements in each group and add groups results
6. Divide by two to get frontal area and then divide by the survey area.

If the percent of non-erodible elements in an area is at least 10 percent, the area is considered to be stable.

Enforcement Objectives

• Maricopa County Air Quality Violation Reporting and Enforcement Policy and Procedure
  • Provide consistent & reasonable process
  • Document potential air quality violations
  • Notify violators
  • Initiate enforcement action
• Ensure that violations are addressed in a timely and appropriate manner

Enforcement Resources

• Maricopa County Environmental Services Department (MCESD) – persons working on fugitive dust control
  • Air Compliance Section
    • Includes dust control inspectors
  • Air Enforcement Section
    • County Attorney’s Office has employees assigned to dust control matters including enforcement officers and attorneys
• Maricopa County Attorney’s Office
  • Prosecutes civil and criminal dust control cases referred by MCESD

How Violations Are Discovered and Documented

• County inspectors and enforcement officers may encounter potential violations of Rule 310
  • While conducting an inspection
  • While investigating a complaint
  • By other means including spot inspections by Special Unit teams
• A written report is prepared, documenting
  • Where, when, how the potential violation occurred
  • Name, affiliation, title, and statements of interviewees
  • Photos and analytical tests supporting failure to comply

How Violators are Notified

• Notification is provided in writing to an owner, operator, or other responsible official
• Mostcommon
  • Compliance Status Notification, or
  • Notice of Violation
• Less common, for more severe violations
  • Notice to Appear and Complaint or “Citation” – Class I Misdemeanor

Rule 310 Violations

• Knowingly failing to obtain an earthmoving permit
• Unpaved parking lots
  • Opacity >20% and
  • Silt loading and silt content limitations exceeded
• Unpaved haul/access roads
  • More than 20 vehicle trips per day or
• Vehicles exceeding 15 mph
• Disturbed surface areas on which no activity is occurring and none of the following standards can be met
  • Visible crust
  • Threshold friction velocity of at least 100 cm/sec
  • Flat vegetation covering at least 50 percent
  • Standing vegetation covering at least 30 percent
  • Standing vegetation covering at least 10 percent and erodible elements that can resist a light breeze
  • More than 10 percent non-erodible elements
• Test Methods for these standards: Rule 310, Appendix C, Sections 2.2 – 2.6
• Hauling

• • Freeboard on a truck is less than three inches or
  • Load of bulk material leaving site is not covered or
  • Material is being lost from holes or other openings in the cargo space or
  • Vehicles traversing a paved public road fail to pass over a trackout control device
• Trackout
  • For sites with disturbed surface area > five acres, vehicles are observed exiting onto a paved road without passing over a trackout control device
  • Deposits extending 50 feet or more from a work site exit are observed on a paved public road
  • Particulates are spilled or deposited from the cargo compartment, tires, or other exterior surfaces of a vehicle, extending 50 feet or more from the work site exit
• Earthmoving, when one acre or more is being disturbed
  • The Dust Control Plan designates water as the control measure, but none is being applied during operation
• Weedabatement
  • Discing or blading without application of water
• Unpaved parking lots with more than 100 vehicles
  • Opacity exceeds 20 percent, and
    • Silt loading exceeds 0.33 oz/ft2 or
    • Silt content exceeds eight percent
• Commercial feedlots and livestock areas
  • Opacity exceeds 20 percent, and
    • No evidence of dust suppressants or gravel, and
    • No trees within 100 feet of animal pens

After a Notice of a Rule 310 Violation is Issued

 

Penalties

• Maricopa County Air Quality Violation Penalty Policy, July 2000
• “The penalty must be high enough that it clearly convinces the violator and the regulated community that violators will be in a significantly worse position that those who comply with the law.”
• The penalty is calculated on the basis of the
  • Gravity of the Violation
  • Economic Benefit of Noncompliance
  • Cost Recovery of Enforcement Efforts
  • Other Mitigating Factors

Gravity of the Violation

• Potential for Harm
  • Level of violation
  • Toxicity of pollutant
  • Risk to environment
  • Risk to population
  • Size of the violator
  • Each of the above is rated on a 0-4 scale
  • Sum to determine “Potential for Harm” score: Major = 14-20, Moderate = 7-13, Minor = 0-6
• Extent of Deviation
  • Major – Failure to comply
  • Moderate – Incomplete or incorrect compliance
  • Minor – Late compliance

Gravity Penalty Matrix

Gravity Penalty Adjustments

• MultipleDays
  • Penalty is applied for each violation day with discounts for multiple days:

• • • 2-15 days = -15%
    • 16-30 days= -30%
    • >30 days = -50%
• Degree of Willfulness or Negligence (max +25%)
• Degree of Coordination & Good Faith (max -15%)
• History of Noncompliance
  • Previous violations were same or similar (+5%)
  • Most recent previous violation was within a year (+10%)
  • Foreach prior violation (+5%)
• Response to Violations (max +10%)

Economic Consequences of Noncompliance

• Put those violating the law at a competitive economic disadvantage
• Delayed costs + avoided costs + illegal profits
• Delayed costs – 5% x capital cost of compliance (interest earned on money not spent on compliance)
• Avoided costs – permanent expenditures avoided because of failure to comply
• Illegal profits – any made during time of non- compliance

Cost Recovery & Mitigating Factors

• Cost Recovery of Enforcement Efforts
  • Recoup special costs incurred in investigating, researching or analysis related to the violation
  • Costs must be “above the norm”
• MitigatingFactors
  • Ability to pay
  • Litigationrisks
  • ARS 49-513 – Total penalty can not exceed $10,000 per violation per day

Rule 310 Compliance Status

• In 2001, site compliance estimated to be 77%
  • 3,608 earthmoving permits
  • 7,941 earthmoving inspections
  • 1,346 complaints about earthmoving dust
  • 919 Notices of Violation
  • 523 Compliance Status Notifications
  • 402 cases referred to the Air Enforcement Section
• 251 referred to the County Attorney’s Office
• 186 cases settled
• $680K in penalties collected between May 2000 and December 31, 2001

Common Rule 310 Violations

• Soil not stabilized on non-working days or hours
• No earthmoving permit pulled or available on-site
• Failure to implement the Dust Control Plan
• No gravel pad at construction site exits
• Failure to pre-wet work areas and haul routes
• Insufficient number of water trucks
• Haul roads not stabilized or watered
• Trackout or deposits on paved public roads
• No tarps on haul trucks
• Failure to keep records on dust control measures

Frequently-Encountered Excuses

• The water truck or street sweeper…is on the way, broke down, got lost, etc.
• The soil at this site makes dust control impossible
• Give me a break, don’t we live in a desert?
• How could I know it would be windy today?
• I left my permit on my desk at the officeWhat a coincidence, I was going to get my permit today!
• One of the subs has the permit and you know how they are…

Part IV

Maricopa County Overview

IV-1. MARICOPA COUNTY NONATTAINMENT AREA

In the Phoenix and Tucson urban areas, lead responsibility for preparing air quality plans is vested in the metropolitan planning organizations (MPOs). The MPOs work closely  with ADEQ, counties, and local jurisdictions in developing nonattainment and maintenance plans. As is done with plans for other areas, the ADEQ submits nonattainment and maintenance plans to EPA for approval. If a required plan is disapproved or is not complied with, EPA may impose sanctions on the development of new industries likely to be sources of air pollution and on federal transportation funding.

Maricopa County is classified as a “Serious” nonattainment area for carbon monoxide, ozone and PM₁₀. This classification impacts the complexity of the planning requirements, the attainment dates, and stringency of the control measures required to attain the standards. Once air quality monitoring data over a number of consecutive years indicates that the standards are no longer violated and nonattainment and maintenance plans for the area have been approved by EPA, a nonattainment area can be redesignated to a “maintenance area.” EPA has recently designated Maricopa County as a nonattainment area based on the new eight-hour ozone standard.

Sources of PM₁₀ in Maricopa County

The major sources of PM₁₀ particles in the Valley are construction and earthmoving operations, re-entrainment of fugitive dust by vehicles driving on paved roads (large trucks, in particular, can create a sizable “wake”), vehicles driving on unpaved roads (especially at high speeds), agricultural activities, and vacant lots.  Winds greater than 15 mph can whip- up the human-disturbed dust and cause exceedances of the 24-hour PM₁₀ standard. Activities that cause persistently high PM₁₀ in the same location can cause violations of the annual PM₁₀ standard.

IV-2. MARICOPA COUNTY PM₁₀ PLAN

According to the EPA-approved Serious Area PM₁₀ Plan for Maricopa County, construction and earthmoving operations contribute the largest share of the annual PM₁₀ emissions in the Maricopa County nonattainment area (38%), followed by contributions from paved roads (18%), agriculture (14%), and unpaved roads (13%). Other minor sources of PM₁₀ include vacant disturbed land, residential woodburning, and industrial operations.

Rule 310 was enacted by the County to limit the emission of particulate matter from construction or earthmoving activities that may serve as a source of fugitive dust. Adherence to the  provisions of Rule 310 results in reduced emissions from construction, vehicle track-out, and unpaved lots. The strengthening and better enforcement of Rule 310 is expected to decrease PM₁₀ emissions from construction and earthmoving activities by 19 percent, nearly half of the total reduction required to show attainment of the annual standard by 2006. Since reductions in dust generated by construction and earthmoving operations represent such a large share of control measure efficacy in the PM₁₀ Plan, it is essential for these reductions to be realized, so that the PM₁₀ standards can be attained by 2006. If the standards are not met by this date, EPA could impose a Federal Implementation Plan that is likely to be far more onerous than the current Serious Area PM₁₀ Plan.

Measures to Reduce PM₁₀ in Maricopa County

The PM₁₀ Plan for the Maricopa County nonattainment area was approved by EPA in 2002. It contains 77 control measures that include PM₁₀ efficient street sweepers, PM₁₀ pollution alerts, and catalytic converters on charbroilers in fast food restaurants like Wendy’s and Burger King. – PM₁₀ emission reductions for twelve of the 77 measures were quantified in the Plan. The combined effect of these twelve measures is a 39 percent reduction in annual emissions by 2006.

IV-3. CONSTRUCTION DUST CONTROL REQUIREMENTS IN MARICOPA COUNTY

Rule 310 requires firms or individuals planning earthmoving activities involving 0.1 acre or more to obtain an Earthmoving Permit, submit a Dust Control Plan, and comply with specific record-keeping, site maintenance, site signage, and other requirements.

Who Must Apply for a Permit

The person responsible for any earthmoving operation that will disturb a total surface area of 0.10   acre or more must submit an Earthmoving Permit application. This “Responsible Official” could be an officer or decision-maker of a corporation, a partner of a partnership, the owner of a sole proprietorship, or the principal executive officer or ranking elected official of a public sector agency.

The Earthmoving Permit Application Form

The Earthmoving Permit application form consists of three sections, Applicant Information, Project Information, and Dust Control Plan. Three copies of the application must be submitted with the appropriate fee attached. For projects of between 0.1 acre and an acre in size, the fee is $75. For projects of greater than one acre, the fee is $36.00 per acre plus $110.00 per site.

Section 2 covers the project information including the type of project, the address and legal description, the size of area, in acres, to be disturbed, and a project start date. A schematic drawing of the project with dimensions of at least 8 1/2 inches by 11 inches must be included.

Section 3 contains the Dust Control Plan.

Dust Control Plan Requirements

The Dust Control Plan application contains a section for each of the activities that take place during a typical construction project that has the potential for generating fugitive dust. Included with each activity are several control measures; the applicant must identify which measure will be employed as the primary measure during the conduct of that activity, and which measures will be employed as contingency measures. For some activities, Rule 310 mandates the employment of a specific primary measure. In these cases, a pre-printed “P” appears next to the measure.  Note that the control measures must be employed so as to be effective at all times during the conduct of the project—on non-work days and after hours, as well as when construction activity is taking place.

Control measures to be identified by the applicant include a stabilization plan for any unpaved haul or access roads. Dust suppressants to be applied, if any, must be specified, including the method, frequency, and intensity of application, the type, number and capacity of application equipment. A plan to control trackout where unpaved or access points join paved public roadways must also be included.

Sign Requirements

Sites of 5 acres or larger in size must have a sign placed at or near the entrance to the job site where it can be clearly seen. The sign must be a minimum of 4 ft. high by 4 ft. wide and show the following information:

• Name of project
• Name and phone number of general contractor
• Include the phrase: “Dust Complaints? Call Maricopa County Environmental Services Department (602) 506-6616”

The information must be printed in block letters at least 4 in. high.

How Rule 310 Dust Control is Enforced in Maricopa County

The purpose of Maricopa County’s Enforcement Policies are to “provide a consistent reasonable process for documenting potential air quality violations, notifying alleged violators, and  initiating enforcement action to ensure that violations are addressed in a timely and appropriate manner.” By state law, the maximum fine per violation per day is $10,000.

The most common violation in recent  years has been a failure to have an earthmoving permit located on site.

Frequently-Encountered Excuses

• The water truck or the street sweeper…is on the way, broke down, got lost, etc.
• The soil at this site makes dust control impossible.
• Give me a break – we live in the desert!
• How could I know it would be windy today?
• I left my permit on my desk at the office.
• What a coincidence, I was going to get my permit today!
• One of the subs has the permit; you know how they are!

EXERCISE IV. SOURCES OF PM10 IN MARICOPA COUNTY

Designing and Implementing a Construction Project to Minimize Dust

• Siteplanning
• Trackout
• Bulk material handling, storage and transportation
• Constructionoperations
• Sitemaintenance

Site Planning