Fugitive Dust Management

March 21,2017

Nathan Hude

Michigan Department of Environmental Quality AQD-Lansing Office (517)284.6779 huden@michigan.gov

Discussion Points • What is Fugitive Dust and What is

the Concern – Natural and Man Made Sources

• Quick Permit Discussion • Fugitive Dust Control Program

– Definition and Benefits – Developing and Implementing a Cost-

effective Fugitive Dust Control Program • Steps to develop a effective plan • Best Management Practices • Plan Examples

• Keys to effective management

Result of Fugitive Dust

Result of Fugitive Dust

Permits

• Depending on the site or facility, you may already have a permit (or not) – Permits to Install (PTI) are generally

associated with smaller sites or operations; example, concrete crusher

– Renewable Operating Permits (ROP); associated with large sites or operations; example, coal power plant

• May have fugitive dust requirements in your permit

If no permit, Does that mean FD rules don’t

apply? • No • Dependent on the location of your

facility, you may have more restrictive rules based on PM of the area (Tables 33, 34, 36 of rules)

Sites that Fugitive Dust Control Applies yet may

not have a permit • Certain sized

– Grain elevators – Landscaping supply dealers – Concrete batch plants – Etc.

Fugitive Dust Control Program

Definition: “A fugitive dust control program is an operating program that is designed to significantly reduce the fugitive dust emissions to the lowest level that a particular source is capable of achieving by the application of control technology that is reasonably available, based on technological and economic feasibility”

Benefits of Effective Dust Management

To the Environment, Neighbors and Community • Reduction in air pollution • Reduction in water pollution from runoff • Reduction of health risks resulting from

air pollution • Reduced risk of damage to property and

belongings

Benefits of Effective Dust Management

To the Owner of the Facility • Reduced risk of damage to property and

equipment. • Improved relationships with neighbors and

with regulatory authorities • Better working conditions for staff • Enhanced business reputation • Knowledge of contribution to environmental

protection in compliance with the law • Conservation of material

Developing and Implementing a Cost-effective Fugitive Dust

Control Program

Steps to develop a Fugitive Dust Control Plan

• Identify your Fugitive Dust Sources – Internal building sources; internal conveyers,

uncovered storage bins, receiving pits, exterior building vents, etc.

– External sources; storage piles, roadways, conveyers, load out chutes, etc.

• Write a plan that will implement best management practices (BMP’s)

• Observe and monitor results of BMP’s • Record your efforts • Revise Plan as needed

BMP’s Internal Building Sources

• Legs and chutes- cover and seal

BMP’s Internal Building Sources

• Conveyers- cover and seal

BMP’s Internal Building Sources

• Building openings, vents, and windows - Establish and maintain operating procedures and internal housekeeping practices (specify details) - Install removable filter media across the vent openings - Exhaust the entire building to dust collection system - Use local hoods connected to a dust collection system to capture emissions within the building

BMP’s External Building Sources

• Receiving pits- tarps, enclose

BMP’s External Building Sources

• Receiving pits- minimize drop distance

BMP’s External Building Sources

• Load out chutes and conveyers

BMP’s External Building Sources

• Load out chutes and conveyers

BMP’s External Building Sources

• Bulk material by truck- is the material being loaded dusty?

BMP’s External Building Sources

• Bulk material by truck- require carriers to cover load

BMP’s External Building Sources

• Bulk material by truck- require carriers to cover load; if no tarp use suppressant

BMP’s External Building Sources

• Bulk material by truck- end state goal is to prevent this…

BMP’s External Building Sources

• Storage Piles- water spray control

BMP’s External Building Sources

• Storage Piles- enclosure

BMP’s External Building Sources

• Storage Piles- fail

BMP’s External Building Sources

• On-site Roadways and Yard- dictate traffic routes and no driving areas

Reduce vehicle speed on unpaved roads to 10 mph or less Apply dust suppressants. Several applications per day may be necessary Frequent mechanical cleaning of paved surfaces (vacuum sweeping, wet sweeping, or flushing)

Periodically maintain off-road surfaces with gravel/stone where trucks have frequent access

Pave haul roads / lot with concrete, asphalt or equivalent (at least entrance and exit)

BMP’s External Building Sources

• On-site Roadways and Yard

BMP’s External Building Sources

• On-site Roadways and Yard

BMP’s External Building Sources

• On-site Roadways and Yard

Dust Suppressants Authorized per Part 22 - Groundwater Quality Rule 2210(b):

- Water - Calcium Chloride - Lignin (pulp/paper by-product) - Vegetable-based products - Polymer solutions - Emulsified asphalt or resin stabilizers

– Typically cheapest dust control method– Only provides temporary control– Weather conditions dictate

reapplication frequency– Application method is key– Will cause trackout, thus sweeping

must be incorporated

BMP’s- Dust Suppressants • On-site Roadways and Yard- Use of

water

• On-site Roadways and Yard- effectivewatering, right tool for the job

BMP’s- Dust Suppressants

• On-site Roadways and Yard- less effective watering

BMP’s- Dust Suppressants

PLAN MUST CONSIDER TRACKOUT

Water used as a suppressant and from rain

works great, yet causes mud, and mud causes trackout

BMP’s- Trackout

BMP’s- Trackout Prevention

BMP’s- Trackout Prevention

BMP’s- Trackout Reactionary Control

BMP’s- Trackout Control • In combination with on-site Roadways

and Yard BMP’s, street sweeping may still be needed

BMP’s- Conclusion

• No single BMP will prevent or resolve fugitive dust issues

• The combination of BMP’s and timing of how they are applied

• Remember to control trackout • Revise BMP’s as needed • Revise Plan as needed

Dust Control Plan Examples

Dust Control Plan Records

Keys to Effective Dust Management

• Develop a plan using BMP’s and be proactive

• If dust management is neglected, it will easily get out of control – Man hours – Cost – Staff stress

• Use caution on suppression using water • Ensure that employees know the plan • Ensure external contractors are aware of

their requirements- speed limit, signage, etc.

Questions?