Fugitive Dust, Particulate Matter, and Air Quality Regulations

Amanda Chapel Michigan Department of Environmental Quality (DEQ) AQD-Kalamazoo Office (269)567-3551 chapela@michigan.gov

March 21, 2017

Discussion Points 1. Definitions: Fugitive Emissions, Fugitive

Dust, and Particulate Matter 2. Types of emissions sources: Point

Sources and Fugitive Sources 3. Overview of Air Quality Regulations

concerning Fugitive Dust 4. Opacity Readings 5. Fugitive Dust Control Program and when

is it required? 6. Complaint Investigations

Fugitive Emissions and Fugitive Dust:

What’s the difference?

Fugitive Emissions

R 336.1106 Definitions; “F” (l) “Fugitive emissions” means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening.

Fugitive Dust

R 336.1106 Definitions; “F” (k) “Fugitive dust” means particulate matter that is generated from indoor air processes, activities, or operations and which is emitted into the outer air through building openings and general exhaust ventilation, except stacks. The term also means particulate matter that is emitted into the outer air from outdoor process, activities, or operations due to the forces of the wind or human activity.

Particulate Matter (PM)

R 336.1116 Definitions; “P” (c) “Particulate matter” means any air contaminant existing as a finely divided liquid or solid, other than uncombined water, as measured by a reference test specific in R 336.2004(5) or by an equivalent or alternate method.

Particulate Matter (PM)

So what is particulate matter exactly? • Air pollutions that comes in the form of fine

dust, smoke, soot, or liquid droplet particles.

• It is one of the 6 major pollutants regulated by the US EPA and DEQ. – Particle Pollution (PM10/2.5), Carbon Monoxide (CO), Lead (Pb),

Nitrogen Dioxide (NO2), Ozone (O3), Sulfur Dioxide (SO2)

• US EPA classifies PM by its particle diameter, measured in microns

Particulate Matter (PM)

Why Control Particulate Matter?

Health effects

Visibility reduction

Nuisances/Aesthetic damage

Three reasons the EPA and DEQ created rules and regulations to control fugitive dust are:

• Respiratory issues • Heart Problems • Premature Death

• Fine particles cause of haze • EPA monitors visibility

around National parks and wilderness areas

• Monitored areas in Michigan: Isle Royale and Seney National Wildlife refuge

• Dust on and in homes, cars, and property is a nuisance

• Particle pollution can stain and damage stone and other materials

• Provide protection of culturally important monuments and statues

Particulate Matter Emission Sources

Point Sources vs. Fugitive Emissions

Two types of emissions sources: • Point Sources – originate from definite

locations such as stacks, vents, or flares. • Fugitive Sources – originate from broad

areas such as storage piles, dusty lots, vehicular track-out, and material conveying systems.

Point Source Emissions

Fugitive Emissions

Sources of Particulate Matter: PM10 and PM2.5

PM2.5 40% PM10

60%

Particulate Matter

30%

5%

5%

25%

35%

PM 2.5 Breakdown

Ammonuim Sulfate

Elemental Carbon

Soil

Ammonium Nitrate

Organic Carbon

Unpaved Roadways

Unpaved, Non-Vegetated Areas

Trackout

Material Storage Piles

Construction-related Activities

Fugitive Dust Regulations

AQD Fugitive Dust Regulations

• Part 55, Public Act 451 of 1994 » 324.5524 Fugitive Dust Sources or

Emissions • Michigan Air Pollution Control Rules

» R336.1301 Standards for Density of Emissions

» R336.1371 Fugitive Dust Control programs other than areas listed in Table 36

» R336.1372 Fugitive Dust Control Program » R336.1901 Air Contaminant or Water

Vapor, when prohibited

Fugitive Dust Sources or Emissions (324.5524)

• Required by the Natural Resources and Environmental Protection Act (NREPA Act 451)

• Applies to facilities with a specific industrial classifications (SIC Codes) located in specific areas in Michigan.

• Requires dust suppression for certain on-site activities

Fugitive Dust Sources Subject to 324.5524

Facilities operating with the following SIC Codes: • 10 to 14 – Mining • 20 to 39 – Manufacturing • 40 – Railroad Transportation • 42 – Motor Freight and Warehousing • 491 – Electric Services • 495 – Sanitary Services • 496 – Steam Supply

County Area

Bay T14N, R5E, Sections 14 to 16 and 21 to 23.

Calhoun T2S, R4W, Section 34.

Delta T39N, R22W, Sections 19, 30, south one-half of 17, and south one-half of 18.

Genesee Starting on Industrial Avenue, north to Pierson Road, east to Dort Highway, south to Hitchcock Street, south to Olive Avenue (extended), south to Robert T. Longway Boulevard, west and southwest to Industrial Avenue.

Lapeer 7N, R12E, that portion of Section 17 which lies south of M-21 and east of Fairground Road. Macomb T4N, R14E,Sections 27, 28, 33, and 34.

Manistee T21N, R16W, sections 7, 18, and 19; T21N, R17W, Sections12 and 13.

Midland T14N, R2E, Sections 14 to 16, 21 to 23, 26 to 28, and 33 to 35.

Monroe Starting where Sandy Creek empties into Lake Erie, northwest to Maple Avenue (extended north-northeast), southwest to Elm Avenue, west to Herr Road, south to Dunbar Road and east to Plum Creek (which empties into Lake Erie).

Muskegon T9N, R16W, Sections 5 and 6; T10N, R16W, Sections 21, 22, and 27 to 34.

Saginaw Northeast section: starting on Tittabawassee Road, east to I-75, south to Wadsworth Avenue, west to I-675, west and north to Tittabawassee Road. Southwest section: T12N, R4E, the eastern half of Section 34 (that which is east of Maple Street) and Section 35.

St. Clair T6N, R17E, Sections 2 to 4, 9 to 11, 14 to 16, 21, 22, and 28.

Wayne Area included within the following (counter clockwise): Lake St. Clair to Moross Road to Seven Mile Road to Vandyke Road to Eight Mile Road to Wyoming Road to Seven Mile Road to Schaeffer Road to Fenkell Road to Greenfield Avenue to Joy Road to Southfield Expressway to Ford Road to Telegraph Road to Cherry Hill Road to Beech-Daly Road (extended) to Michigan Avenue to Inkster Road to Carlysle Street to Middle Belt Road to Vanborn Road to Wayne Road to Pennsylvania Road to Middle Belt Road to Sibley Road toTelegraph Road to King Road to Grange Road to Sibley Road to Jefferson Avenue to Bridge Street (Grosse Ile) extended to Detroit River. Also included is that portion of the City of Riverview which is south of Sibley Road and the City of Trenton.

Geographical Areas Covered in Section 5524

Opacity and Visible Emissions

Standards for Density of Emissions R 336.1301

R 336.1115 Definitions; “O” (a) “Opacity” means the degree to which anemission reduces the transmission of lightor obscures an observer’s view.

Visible Emissions – 0% Opacity

Visible Emissions – 10% Opacity

Visible Emissions – 50% Opacity

Visible Emissions – 100% Opacity

Reading Visible Emissions

• EPA Method 9 – Determines aquantitative value of opacity.

• EPA Method 22 – Provides a qualitativevalue.– Is there opacity present?– What is the duration?

R336.1371 Fugitive Dust Control Programs outside Table 36

• Applies to facilities located outside of thelocations listed in Table 36

• Need for control program may be basedon ambient air emission measurements orcitizen complains.

• If requested, facility has 6 months tosubmit a Fugitive Dust Plan to AQD forapproval and implementation.

Fugitive Dust Control Programs Section 5524 vs. Rule 371

• A source regulated by Section 5524 of Act 451 is required to develop and operate under an approved Fugitive Dust Control Program (FDCP)

• A source regulated by Rule 371 must develop and operate under an approved FDCP upon request, and only after the AQD has identified the source as the cause of complaints

AQD can request a person who is

responsible for the operation of any

facility which processes, uses,

stores, transports, or conveys bulk

materials submit a Fugitive Dust Control

Program (FDCP)

R 336.1371 Fugitive Dust Control Programs

R336.1372 Fugitive Dust Control Programs: Required Activities – Typical Sources

Fugitive Dust

Sources

Loading/ Unloading

Storage Piles

Bulk ‘ Material

Transport

Roads &

Lots Inactive Storage

Piles

Building Ventilation

Demolition/ Construction

Michigan Administrative Rule 901

Rule 901. Not withstanding the provisions of any other department rule, a person shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, alone or in reaction with other air contaminants, either of the following: (a) Injurious effects to human health or safety, animal

life, plant life of significant economic value, or property.

(b) Unreasonable interference with the comfortable enjoyment of life and property

Complaint Investigations

• Conducted in response to citizencomplaints of smoke, odors, fallout, orfugitive dust from the facility

• Fugitive dust and fallout complaintsreported to the AQD/DEQ in the State ofMichigan: what is the frequency ofoccurrence?

Complaints Received by District Office 2016

571

202

160

583

625

84 102

72 49

20 Detroit

SEMI

Grand Rapids

Jackson

Saginaw Bay

UP

Kalamazoo

Lansing

Cadillac

Gaylord

Complaints Received by Complaint Type 2016

2083

138

137

137 73 134

Odor

Opacity

Fallout

Fugitive Dust

Open Burning

Other

Fugitive Dust Complaints

Fugitive Dust Complaints

Fugitive Dust Complaints

Questions?

Michigan Department of Environmental Quality

800-662-9278www.michigan.gov/deq

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