Best Practices for Creating a Fugitive Dust Control Plan

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In a perfect world, every site and/or project that can potentially produce dust emissions should have a Fugitive Dust Management Plan (FDMP).  Several factors might spark the need for one: preemptive action by management for compliance, a local/state permit provision, or a condition from a government inspector as part of a violation.

Fugitive dust control plans are important because dust can reduce air quality to nearby communities miles away, causing a nuisance and inflaming symptoms in people with pre-existing conditions such as COPD or asthma. Along with human receptors, dust can impact ecological receptors as well. For example, airborne particulates deposit in terrestrial and aquatic habitats, possibly resulting in contamination of additional areas outside of the site line. Heavy metal or contaminant uptake may adversely affect healthy ecosystems.

Complaints from surrounding communities and conservation groups to local media and government entities can also lead to bad press, inspections, fines, and unscheduled downtime. Anticipating potential issues and preemptively addressing them is the first step in fugitive dust control plan best practices. So, by reading this article, you are already well on your way.

Experienced environmental managers will tell you that the inclusion of modern atomized mist technology is an essential part of an effective FDMP. The dust specialists at BossTek are trained in identifying where DustBoss® technology is best applied and can offer support in the creation of the plan.

demolition-and-reconstruction-firm-project

WHAT IS A DUST CONTROL PLAN?

Testing and compliance standards have moved far beyond having a person with a hose standing next to dust-generating activities, spraying them down in the hope that the dust does not travel too far and irritate the neighbors. An FDMP is a comprehensive document that states the causes, compliance requirements, testing measures, control methods, and policies for a specific operation site.

Although dust that is large enough to be visible (approx. 100 μm [microns] in size) may inspire complaints from the local community, regulators are focused on much smaller invisible particulates that can penetrate the body’s natural defenses and reduce the overall health of the community. Inspectors test for particulate matter (PM) of 10μm or smaller. Measurements of PM10 and PM2.5 are very common in permits and government regulatory standards.

The dust control plan is not just for regulators to read but is also an internal resource to inform and track all environmental air quality aspects of a project or site. The creation and administration of the FDMP require ongoing contributions from many stakeholders within the organization that is managing and operating the site.

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PARTS OF A DUST CONTROL PLAN

In the range of 10-50 pages long, depending on the size of the site and scope of the project, the dust control plan is a report directed by an environmental specialist and maintained by internal resources. It is comprised of several different parts.[1]

  • Summary – This is a big picture overview of the findings and solutions in approximately two paragraphs.
  • Acknowledgments – A list of contributors and external resources used to create the report.
  • Contents – An index of the entire report with page numbers.
  • Introduction – The introduction creates the narrative for the report and frames the thinking around the approach, collection of data, and chosen solutions. It states the nature of the operations done on the site and the organization’s air quality goals.
  • Project/Site Contacts – The names and contact information for whom regulators direct questions.
  • Project/Site Introduction – This introduction is specific to the site from a particulate and air quality perspective. It is comprised of a short history, a description of the surrounding area, nearby communities, obstacles, and industrial activities around the site that may contribute to lower air quality.
  • Environmental Assessment – This is generally sourced from the larger environmental assessment of the site. That report touches on air quality but also covers several topics such as geology, soil quality, ecology, water quality, seismology, weather, and an environmental impact statement. From an air quality standpoint, the FDMP expands on the report and offers more detailed fugitive particulate data and assessment methodology.
  • Dust Control Measures – A wide range of industries refer to the Hierarchy of Control Methods, which are listed from least effective to most effective, when determining what methods and measures to implement.
  • Monitoring – This section covers what is being tested, the testing methods, and frequency. It also provides the results of testing and either shows or speculates upon the effectiveness of the measures.
  • Conclusion – Closing thoughts and results.
  • References – Any other links or source materials used to create the report.
  • Glossary – A glossary of terms or abbreviations.
Identifying Strategies to Minimize Water and Monitior Fugitive Dust

DUST CONTROL PLAN BEST PRACTICES

Best practices are not just practical, but they help frame the thinking and the approach to the entire plan. Along with the steps and structure, consider these recommendations.

Hire an independent local environmental expert to create the report. Check to see that they are in good standing with the local and state governments. Confirm that they have the academic background and proper certifications. Review prior reports and references to ensure that this is their area of expertise.

Accept the findings and adjust the project scope to compensate. The findings in the report are data-driven, and since neither weather nor geography can change, the only option is finding a new location or applying the proper control measures.

Use several measures based on the findings and recommendations when possible. Some projects have limited options based on available space, resources, and scope. For example, an urban demolition project may only have a quarter block area and three months to implement dust control measures, so they may only have space for a single mist cannon, whereas a quarry may have the time and space to install a tree-lined natural wind barrier, tower mounted dust cannons, etc.

Be budget conscious but not budget driven. Generally, water is required for most dust solutions. Water can be distributed by an automated machine such as an atomized mist cannon or it can be labor intensive, such as a person holding a hose or driving a tanker truck. Field tests have shown that automated solutions create a safer workplace and offer a better long term ROI.

FDMP HIERARCHY OF CONTROL METHODS

Using this established method is important because it is a standard that spans nearly all industries. This is applied to everything from workplace safety to healthcare.

Hierarchy of Dust Control Methods

Personal protective equipment (PPE) is considered the least effective option because it only protects staff, is uncomfortable and unwieldy for personnel to wear, and it is hard to monitor consistent usage. Plus, it does not control or prevent emissions.

The FDMP is an “administrative control” and does no good if it is merely put on a shelf with no measures implemented that actively control dust.

Signage and markings posted around the work area, or throughout the community, do not stop emissions and are easily ignored.

Engineering controls are changes in workflows and schedules to mitigate dust. This includes lower truck speeds, smaller stockpiles, limiting outdoor operations during windy weather, etc.

Substituting a better solution is preferred because it generally eliminates several issues at once. For example, replacing a worker holding a hose who is spraying down a material pile with 100 gallons per minute (gpm) (378.5 lpm) of water with a DustBoss® DB-60 accomplishes several things. One, it eliminates labor costs, two, it increases workplace safety by reducing the worker’s exposure to large equipment and outside environments, and three, it uses less than a quarter of the water (12 gpm [45.4 lpm] to 26.7 gpm [101.1 lpm]), which reduces pooling and runoff.

Eliminated by design is the best option, because it takes dust into account for the construction or retrofit of the entire operation to stop fugitive dust emissions from affecting both workers and surrounding communities. This includes paving surfaces, using strategically placed areas for material storage surrounded by tower-mounted dust cannons, enclosing conveyors along the entire length of the system, etc.

BEST PRACTICES FOR CHOOSING DUST MEASURES

These suggested measures are fairly specific to bulk handling, raw material mining, and construction/demolition based upon the most effective parts of the Hierarchy of Control Methods.

  1. Limit surface disturbance and use atomized mist to capture and pull down airborne particulates at the point of emission.
  2. Locate site infrastructure outside of high wind or wind channeling areas.
  3. Enforce low speed limits for vehicular traffic.
  4. Decontaminate trucks leaving work areas.
  5. Cover truck loads leaving the facility.
  6. Set height limits for debris/waste or gravel stockpiles and use misting machines with large areas of coverage like the DB-60 (up to 125,000 sq/ft [11,612 sq/m])
  7. Treat active areas such as loading, unloading, demolition, outdoor blasting, and digging using a DustBoss DB-30 to offer both surface and airborne dust suppression.
  8. Spray conveyor transfer points using misting heads such as a DustBoss DB-M Mini.
  9. Application of dust suppressants or crusting agents on storage piles or at conveyor transfer points using the DB-30 Injektor™.
  10. Minimize drop heights from stacker conveyors and use a DustBoss DB-Ring and a sock chute.
  11. Install bag houses on conveyor settling zones.
  12. Minimize or cease dust-generating activity during periods of high wind.
  13. Wet large open, unpaved areas with no ground cover using a wide area misting machine such as a DB-100 (337,000 sq ft [31,000 sq m] of coverage).
  14. Cover or enclose stockpiles and storage areas.
  15. Establish vegetation, other groundcover, or wind breaks.
  16. Pave high traffic areas.

CHOOSING THE RIGHT DUST CONTROL EQUIPMENT

Once the dust control plan is written using the best practices, it does no good unless the recommendations are implemented. Likely this is going to involve dust suppression and airborne particulate mitigation using water. When considering the correct equipment choice for the operation’s needs, there are some questions you might want to ask:

What is my water source for dust suppression?

If it is from a hydrant, pressure isn’t the problem, but volume control and safety can be. If the hose is handheld, the pressure may be hard to control for long periods. Low pressure municipal water or non-pressurized potable/non-potable water may not deliver the coverage area for adequate surface suppression and require a booster pump. DustBoss cannons and sprayers are available with an optional booster pump that offers the reach and coverage area for superior dust control over hoses.

Does the dust control equipment cover the emission area?

To cover an area, the water must be distributed by pressure through a handheld hose, a tanker truck driven on a route through the site, or with a high-powered fan filling the area with millions of tiny droplets. When using pressure to propel the water, reach is determined by volume and pressure. The more water that is used, and the higher the pressure, the farther the stream goes. A hydrant at 20 psi in pressure can use more than 500 gpm[3], but needs 200 psi and more than 1600 gpm to equal the reach of a DB60 at 200 ft (60 m).[4] The water cost, let alone the wastewater runoff, far exceeds reasonable consideration.

Check out the solutions from DustBoss in this video!

THE DUST CONTROL PLAN IS A LIVING DOCUMENT

Once the dust control plan is written using the best practices, it does no good unless the recommendations are implemented. Likely this is going to involve dust suppression and airborne particulate mitigation using water. When considering the correct equipment choice for the operation’s needs, there are some questions you might want to ask:

What is my water source for dust suppression?

If it is from a hydrant, pressure isn’t the problem, but volume control and safety can be. If the hose is handheld, the pressure may be hard to control for long periods. Low pressure municipal water or non-pressurized potable/non-potable water may not deliver the coverage area for adequate surface suppression and require a booster pump. DustBoss cannons and sprayers are available with an optional booster pump that offers the reach and coverage area for superior dust control over hoses.

Does the dust control equipment cover the emission area?

To cover an area, the water must be distributed by pressure through a handheld hose, a tanker truck driven on a route through the site, or with a high-powered fan filling the area with millions of tiny droplets. When using pressure to propel the water, reach is determined by volume and pressure. The more water that is used, and the higher the pressure, the farther the stream goes. A hydrant at 20 psi in pressure can use more than 500 gpm[3], but needs 200 psi and more than 1600 gpm to equal the reach of a DB60 at 200 ft (60 m).[4] The water cost, let alone the wastewater runoff, far exceeds reasonable consideration.

CONCLUSION

Fugitive dust control plans are time-consuming and expensive to create, but the expenditure in time and money far outweighs the cost of fines, public scrutiny, downtime and potential lawsuits. In fact, a good FDMP is an opportunity for positive PR and press coverage, improved community relations, and a display of transparency for regulators.

By integrating modern mist cannon technology that is field tested and proven to maximize dust suppression, a company shows that it cares about the health of employees, the community, and the environment. Our BossTek reps can work with your team to show where and how you can integrate DustBoss technology into your operations to control airborne fugitive emissions and improve suppression.

CREATE A FUGITIVE DUST CONTROL PLAN TODAY!

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