How to Plan for Fugitive Dust Control and Particulate Matter
December 9th, 2014 by Fiedler Group
Fiedler Group recently successfully completed permit acquisition in support of a project in Southern California’s Riverside County. One of the County’s many requirements for permit issuance was the development of a Fugitive Dust Control Plan and evidence of Particulate Matter (PM10) training by both the project owner and contractor.
While Fugitive Dust Control has been the focus of both Federal and State regulation for several years, we were surprised to learn neither our client nor contractor had received this mandatory training. Provided below is a high-level overview the fugitive dust control regulations:
What is Particulate Matter (PM10)?
The California Air Quality Resources Board (CARB) defines particulate matter PM10 pollution as consisting of very small liquid and solid particles floating in the air.
These particles are less than 10 microns in diameter -– about 1/7th the thickness of a human hair — and are small enough to be inhaled into the deepest part of the lung, thus threatening both human health and the environment.
Major sources of PM10 include motor vehicles, wood burning stoves and fireplaces, dust from construction, wildfires, and windblown dust from open lands.
Regulatory Response to PM10 Pollution
The Federal Clean Air Act of 1990 established air quality standards for PM 10, specifically directing Congress to require that serious PM-10 nonattainment areas, like California’s South Coast Air Basin (SCAB) and Coachella Valley implement all reasonably available control measures (RACM), and subsequently, all best available control measures (BACM).
At the State level, in 2003, California passed Senate Bill 656, establishing a process to complement and support those regulations, compliance directives, implementation schedules and sequencing of control measures intended to reduce public exposure and attain compliance with Federal standards.
South Coast Air Quality Management District (SCAQMD) studies indicated approximately 20 to 40 percent of ambient PM10 concentrations were a result of soil dust entrainment or “fugitive dust,” therefore fugitive dust from paved road dust, unpaved road dust, construction and demolition, and motor vehicles were identified as significant contributors of PM emissions.
Consequently, air districts exceeding the State’s PM10 standard (San Joaquin Valley, South Coast, and several desert area) were required to implement identify and prioritize control measures, and implement all BACM.
Fugitive Dust Control Plan
The Fugitive Dust Control Plan identifies the dust sources at the construction site and describes all the dust control measures to be implemented before, during, and after any dust generating activity for the duration of the project.
Fugitive dust control strategies are composed of a balance of available dust mitigation techniques applied on as need basis to prevent:
- Dust from exiting the property
- Visible emissions from exceeding opacity regulations, and
- Public nuisance
Site-specific considerations include time of year, length of project, amount of vegetation removal, excavation, backfilling, hauling, grading, digging of foundations, site vehicle traffic, and landscape activities.
Basic elements of the Plan include:
- Identification of fugitive PM10 sources
- Project Phases
- Control actions
- Best Available Control Measures (BACM)
- Daily Inspection Recordkeeping forms
- Dust Suppressant Recordkeeping forms
Dust Control Training – Fugitive PM10 Prohibitions
- Training typically consists of a 3-hour training class
- Owner / operator of the project, and anyone who prepares or implements the Dust Control Plan are required to attend
- Training includes a comprehensive overview of district dust control requirements and current strategies for preventing, mitigating, and controlling release of airborne particulate matter (dust) emissions
Please contact Fiedler Group today to learn more about a Fugitive Dust Control Plan for your project.
