(FPMP)
Regulation VIII specifies two general control
methods for controlling fugitive dust: (1) limit Visible Dust Emissions and (2)
maintain a stabilized surface:
·
Visible
Dust Emissions (VDE):
Visible dust emissions may not exceed 20 percent opacity during periods
when soil or other dust-producing materials are being disturbed by vehicles,
equipment, or the forces of wind.
“Opacity” is a visual evaluation of the amount of one’s view that is obscured by
a dust plume. The VDE limit applies
to construction sites, the handling and storage of bulk materials, and to
unpaved roads and traffic areas.
Test methods for determining compliance with the VDE limit are found in Appendix
A of
Rule 8011 (General Requirements).
·
Stabilized Surface:
A stabilized surface is a treated surface that is resistant to wind effects.
This requirement applies to vacant open areas that have previously been
disturbed, unpaved roads and traffic areas, and outdoor bulk storage piles.
Methods for creating and maintaining a stabilized surface may include
applying chemical or organic stabilizers, road-mix or paving materials,
vegetative materials, or water for soaking the soil or forming a visible crust.
The test methods and applicable standards for determining whether a
surface is stable are found in Section 6.1 and Appendix B of Rule 8011.
For
unpaved roads and unpaved traffic areas,
a Fugitive PM10 Management Plan (FPMP) may be implemented as a compliance
alternative to the Visible Dust Emission standard and the requirement to
maintain a stabilized unpaved road surface, per section 7.0 of Rule 8011
and section 7.0 of
Rule 8081 (Agricultural Sources).
The FPMP identifies the control measures to be implemented whenever
vehicular traffic reaches and exceeds the applicable thresholds described in
section 4.1 of
Rule 8061 (Paved and Unpaved Roads), section 4.1 of
Rule 8071 (Unpaved Vehicle/Equipment Traffic Areas), and sections 4.4 and
4.7 of Rule 8081. Acceptable
control measures are those that have demonstrated to achieve at least 50 percent
PM10 control efficiency when properly applied to an unpaved surface.
A FPMP
may not be prepared for unpaved roads and traffic areas at construction
projects.
Unpaved
haul roads, access roads, and traffic areas at construction sites are subject to
the requirements of
Rule 8021 (Construction, Demolition, Excavation, Extraction, and Other
Earthmoving Activities). For
larger construction projects, a Dust Control Plan submitted in accordance with
section 6.3 of Rule 8021 will describe the fugitive dust control measures to be
implemented before, during, and after any dust generating activity at the
construction site, including on unpaved haul roads, access roads, and traffic
areas. Construction activities may
not commence until the District has approved or conditionally approved the Dust
Control Plan for that project.
A FPMP
may not be used in lieu of a
Conservation Management
Practice (CMP) Plan
for agricultural sources subject to
Rule 4550
(Conservation Management Practices).
The purpose of the CMP program is to reduce emissions through the
implementation of a variety of agricultural practices.
For unpaved roads and traffic areas, the CMPs are actually Regulation
VIII control measures for stabilizing unpaved road surfaces and reducing visible
dust and PM10 emissions. However,
the minimum thresholds for implementing a CMP on unpaved roads and traffic areas
is far below the Rule 8081 thresholds, which means that the CMP control measures
must be applied to those unpaved areas with fewer vehicle trips.
Non-agricultural sources
choosing to implement a FPMP are required to submit a plan to the District for
approval. Once approved, the owner
or operator is required to implement the District-approved FPMP on all days
where traffic exceeds the applicable minimum thresholds.
Failing to comply with the provisions of the District-approved FPMP is a
violation of Rule 8011. An approved
plan remains active until the District notifies the owner or operator that it is
no longer valid, or until the owner or operator notifies the District that plan
implementation has been permanently discontinued.
Agricultural sources
opting to implement a FPMP are to submit a proposed plan to the San Joaquin
Valley Region of the California Association of Resource Conservation Districts
(RCD). The RCD will evaluate and
verify whether the proposed plan meets the guidance and criteria established by
the District. The FPMP is not in
effect until the grower (owner or operator) receives written notice from the RCD
that the plan has been “verified”.
The RCD will forward the verified plans to the District.
The grower must implement the verified FPMP on all days when vehicle
traffic exceeds, or is expected to exceed, the applicable minimum thresholds
defined in Rule 8081. Failing to
comply with the provisions of the verified FPMP is a violation of Rule 8081.
The plan remains valid until the District notifies the grower or RCD that
plan needs to be revised, or until the grower notifies the RCD that
implementation has been permanently discontinued.
The RCD
does not accept any liability or responsibility for implementation or lack
thereof of the control methods proposed by the grower and is not responsible for
determining compliance in the field.
The role of the RCD is to verify that the plan meets the guidance and
criteria established by the District per Rule 8081.
Plan implementation is the responsibility of the owner or operator.
Determining compliance remains solely within the jurisdiction of the San
Joaquin Valley Air Pollution Control District.
A FPMP
may be submitted as an original document or on a District-approved form, such as
the FPMP template. A single FPMP
may cover multiple unpaved roads and traffic areas.
The District has the prerogative to invalidate a previously approved or
RCD-verified FPMP if it is determined that the plan is insufficient to meet the
50 percent PM10 control standard.
Upon such notice, the owner or operator would either revise and resubmit the
FPMP or comply with the VDE and stabilized unpaved surface requirements, when
applicable.
Section
6.2 of Rule 8011 and section 6.2 of Rule 8081 also require owners and operators
to maintain records and any other supporting documents to demonstrate compliance
for those days when control measures were implemented.
Records are to include the type of control measure implemented, the
location and extent of coverage, and the date, amount and frequency of applying
dust suppressants.
Record keeping forms developed by the District or a facsimile that provides
the necessary information may be used for record keeping purposes.
Records are to be kept for a minimum of one year following termination of
dust generating activities. Title V
stationary sources subject to
Rule 2520
(Federally Mandated Operating Permits) are required to keep the records for
a minimum of five years. Records
must be made available to the District inspector upon request.
For
non-agricultural sources, please submit your FPMP to:
Mr.
Daniel Martinez, Supervising Air Quality Inspector
San
Joaquin Valley Air Pollution Control District
1990 E
Gettysburg Avenue
Fresno,
CA 93726
(559)
230-5950
For
agricultural sources, please submit your FPMP to:
Mr.
Johnnie Siliznoff
USDA Natural Resources Conservation Service
4974 E
1907 N Gateway Blvd, Suite 101
Fresno,
CA 93727
(559)
252-2191
·
Fugitive PM10 Management Plan Template
·
·
Products Available for Controlling PM10 Emissions
·
Conservation Management
Practices
·
List of Conservation Management Practices