Phoenix clears the air
The high-tech world creates a vast array of exotic pollutants. However, plain old dust – the stuff kicked up by cars on unpaved roads and by workers on construction sites – continues to be one of the major problem pollutants for cities and counties. Also known as “particulate matter,” dust particles larger than 10 microns (PM-10 in the pollution vernacular) contribute significantly to the country’s pollution, particularly in western cities.
One western city – Phoenix – is taking aim at its dust problem. Its actions come not a moment too soon, since the U.S. EPA is putting its considerable might behind enforcement of PM-10 standards that have been on the books for years but for which enforcement money has rarely been available.
Part of the problem in the west stems from the area’s rapid growth. Growth means construction, and construction means dust. Consequently, many growing western cities find themselves out of compliance with federal PM-10 standards. Phoenix, which covers
When the city began implementing its solutions, the Phoenix area was not in compliance for either annual or 24-hour health-based PM-10 maximum concentration standards, despite the fact that Maricopa County, the local government responsible for regulating air quality in the area, has PM-10 regulations that are among the most stringent regulations in the nation. Those regulations require strict controls for construction, materials transport, vacant lots, parking lots and unpaved roads, but Phoenix continued to experience elevated PM-10 levels. (PM-10 airborne particles can cause lung and tissue damage.)
EPA steps in Because Maricopa County did not have the wherewithal to enforce its PM-10 standards, EPA stepped in. In chronic non-compliance situations, the Clean Air Act can require EPA to take over compliance efforts. Thus, in 1998, EPA created a Federal Implementation Plan (FIP) to supersede Maricopa County’s PM-10 regulations. Designed to force compliance without compromise, the FIP was entered into the Federal Register on Aug. 3, 1998.
The FIP defined minimum size criteria for several PM-10 sources. For each category, several Reasonably Available Control Measures (RACM) are required. The RACM plan categorizes unpaved roads, unpaved parking lots and vacant lots into specific implementation criteria.
Additionally, because agricultural activities contribute to the “fugitive dust” problem, farmers will have to comply with new Best Management Practices by June 2000. Those practices may include reducing tilling when it is windy, changing irrigation patterns and orienting furrows to resist wind erosion.
Phoenix takes action Rather than waiting for the EPA-set deadlines to start responding to the regulations, Phoenix officials decided to start their own aggressive dust control program. They investigated 300 sites within the 5000 acres of city-owned unpaved lots and deemed 65 to be unstable and to require action. Since Phoenix was working with a not-yet-adopted regulation, its staff hired consultants to help interpret the technical requirements, conduct the EPA test methods, and find answers to the dust problem that would be both workable and lasting.
At the same time, the city identified more than 60 miles of unpaved roads that needed attention. The roads received bituminous surface treatment – essentially chip seal with slurry. City engineers estimated that full curb and gutter streets for the entire project would have cost $32 million; the surface treatment was accomplished within a $6 million budget. To let residents know about the project, Phoenix officials placed captioned cartoon images on the “City Page” in the Arizona Republic newspaper.
In a city the size of Phoenix, unpaved parcels became a major concern. Before attempting to find dust- control solutions, the city had to identify the number and locations of its city-owned vacant lots. Those included undeveloped parks, buffer zones around utilities and treatment plants, homes where enforcement actions resulted in demolition, and vacant plots of land within the city’s land inventory. While they were taking an inventory of vacant lots, city personnel also were tracking city-owned parking lots.
“We had to create a new database for these properties so we could track the compliance status and assure the stabilization,” says Phoenix Environmental Programs Specialist Gaye Knight. “Because some of these properties had been in the city’s possession long before GIS was used, we had to review frail old maps and other records to find exact locations. It was challenging, but we were committed to PM-10 compliance.”
Once the city identified and categorized vacant lots, it evaluated potential fixes. “EPA had a very complex procedure to measure the level of disturbed dust that could be generated by a piece of land,” Knight says. “We estimated that 5,000 acres of city-owned vacant property spread all over our city would have to be tested. To be effective, we had to find a system to test soil stability and allow us to find the best solutions quickly.”
New EPA test procedures that had not been formally adopted were implemented. The city and its consultant developed a standardized protocol, incorporating the FIP test procedures so site investigators could handle their analysis quickly and begin the corrective process sooner.
After verifying city ownership, city personnel located each parcel on existing maps. The sites had to be inspected, and development status and legal boundaries had to be confirmed. Phoenix site investigators looked at a number of factors: * the size and character of each site; * the size and character of the areas to be stabilized; * the type and character of adjacent properties; * soil types; * current and future uses; * treatment options; * cost; * environmental impacts; * health concerns; and * performance desired.
In some cases, Phoenix simply added a barricade to prevent access to the site, thus preventing dust disturbances. Additionally, desert soils often form a natural crust or promote sufficient vegetation to meet EPA tolerance levels. That fact saved significant time and resources.
With potential problem sites identified, investigators began to conduct formal testing for stability. Three main tests were employed: 1. The Visible Crust Test uses a 3 mm (5/8-inch) round metal ball, which is dropped onto representative soil three times. If the crust is broken, the site fails.
2. The Site Vegetation Test is really two tests – the flat vegetation cover and the standing vegetation cover evaluations. Each determines the percentage of the site already “treated” with natural vegetation. If the site is covered 50 percent or more by flat vegetation or 30 percent or more by standing vegetation, no further action is required.
3. The Threshold Friction Velocity Test uses a stack of five sieves to determine the average soil particle size and its capacity to generate dust.
The right solution Selecting the best control method for each of the 65 lots presented a challenge. Four primary groups of solutions – watering and compaction, hydroseeding (in which damp, dense seed mixes are sprayed onto a site and covered with a protective material so they will germinate), rock mulch and chemical stabilization – were used.
Costs were tabulated for each process and weighed against other factors, such as the site’s location and potential uses. Water and compaction was the least expensive solution, at 59 cents per square yard.Chemical soil stabilization cost 69 cents per square yard; hydroseeding was $1.25 per square yard; and rock mulch ran as much as $2.35 a square yard. Berms (at $1.95 a linear foot) and barricades were used on many lots to prevent trespassing and future disturbances. The prices reflect the economy of scale available to large projects.
Hydroseeding, which involved adding native or arid-region vegetation to unpaved lots to create curb appeal, proved to be an “iffy” solution because some mixes would become fire hazards during dry weather. Consequently, the seed mix was adapted to reduce the fire risk, and hydroseeding was used primarily on remote sites.
Additionally, Phoenix was concerned that too many chemicals that are considered safe today might cause problems in the future or when they interact with other by-products in the waste stream. The PM-10 team reviewed a variety of chemical stabilizers for their initial and long-term costs, environmental and health risks, and performance. But, since chemical stabilization is an emerging dust control technology, test case research was limited, and what was available compared limited experiences to manufacturers’ claims.
In Phoenix, four types of chemical dust stabilizers were identified and studied. They included: * deliquescent and hygroscopic chemicals which are mostly used in industry and organic non-bituminous binders (industrial waste products like animal fats and vegetable oils); * bituminous binders, which are obtained from natural deposits or produced through crude oil distillation, and include asphalt and asphalt/petroleum emulsions (EPA specifically prohibits used oil as a dust palliative); and * acrylic polymers, synthetic soil stabilizers that bind the soil at the surface level and are generally sprayed as diluted liquid. (Because of their viscous nature, they can clog spreading equipment, so they were chosen when other products were not feasible.)
Success Phoenix’s commitment to clean air has made a difference. City property is stabilized, roads and parking lots are paved, and Phoenix can proclaim its dust-control solutions a success. “There is still more to be done by other cities and individuals,” Knight says. “Since the PM-10 problem comes from many sources, we have to work together toward the same goal. People think that, because we live in a desert, it’s just natural to have this dust.” Phoenix, however, is finding that it does not have to be a serious problem.
Ken Feyen is a senior associate for Brooks, Hersey & Associates, a Phoenix-based consulting firm.
Nine regional pollution prevention resource centers have joined together to establish the Pollution Prevention Resource Exchange (P2Rx), a clearinghouse of resources available to local businesses and technical assistance providers. Exchange services include technical publications, library resources, research, training and referrals.
Funded by the U.S. EPA, the centers provide information about pollution prevention (P2) – defined as reducing or eliminating pollution at the source so that it never enters the environment in the first place. P2 can be accomplished through product design, energy and water efficiency, materials substitution, materials reuse, process changes and better work practices.
Information about pollution prevention exists in libraries, databases and filing cabinets, but, until recently, no system was in place to provide efficient access to the information. Agencies, consultants and businesses often were unaware of P2 services and information available to assist them.
Through P2Rx, the nine centers are laying the foundation for a seamless, national network that will get P2 questions answered quickly and reliably. The exchange also is expected to reduce duplication of effort in preparing P2 materials, improve collaboration of assistance providers, and help create information distribution channels.
The exchange is the result of an EPA survey of more than 300 local and state government technical assistance providers. In thesurvey, respondents told EPA that an information network should synthesize and update technical information; include contacts where additional information can be obtained; and be easy to search. In 1997, EPA initiated a grant program to establish a national network of P2 information centers (four already existed; five were added).
The Pacific Northwest Pollution Prevention Resource Center serves as the initial coordinator for the exchange. The coordinator role will rotate among the centers. Over the past year, the nine regional centers have worked to establish common approaches to issues such as marketing the centers’ services, measuring service usage, assuring resource quality and developing a standard format for bibliographic references. They also have collaborated to develop pollution prevention materials for the hospitality and metal fabrication industries.
Together, the centers serve all 50 states and a number of territories. Each can be reached online at http://www. epa.gov/p2/p2rxdir.htm.
The individual centers and their contact information follow. * EPA Regions 1-2: CT, MA, ME, NH, NJ, NY, RI, VT Northeast Regional P2 Information Center Lisa Rector; New England Waste Management Officials Association, 129 Portland St., Suite 602, Boston MA 02214-2014; phone (617) 367-8558, ext. 304; e-mail [email protected]
* EPA Regions 3-4: AL, DC, DE, FL, GA, KY, MD, MS, NC, PA, SC, TN, VA, WV Waste Reduction Resource Center Mike Heaney; Waste Reduction Resource Center, P.O. Box 29569, Raleigh NC 27626-9569; phone (919) 715-6511; e-mail [email protected]
* EPA Region 5: IL, IN, MI, MN, OH, WI Great Lakes Regional Pollution Prevention Information Center Lisa Merrifield; Illinois Waste Management & Research Center, 1 E. Hazelwood Drive, Champaign IL 61820; phone (217) 244-6061; e-mail [email protected] hazard.uiuc.edu
* EPA Region 6: AR, LA, NM, OK, TX Southwest P2 Information Center Juan Maldonado; University of Texas, El Paso; 500 W. University, Burges Hall, Room 400; El Paso TX 79968; phone (915) 747-6273; e-mail [email protected] * EPA Region 7: IA, KS, MO, NE
Pollution Prevention Regional Information Center Richard Yoder; University of Nebraska, Omaha; 1135 M St., Suite 200, Lincoln NE 68508-2124; phone (402) 472-1183; e-mail [email protected]
* EPA Region 8: CO, MT, ND, SD, UT, WY Peaks to Prairies Pollution Prevention Information Center Michael Vogel; Montana State University Extension Service; Montana P2 Program, Bozeman MT 59717; phone (406) 994-3451; e-mail [email protected]
* EPA Region 9: AZ, CA, HI, NV Western Regional Pollution Prevention Network Isao Kobashi; 3120 DelaCruz Blvd., Santa Clara CA 95054; phone (408) 748-2178; e-mail [email protected] ucsc.edu
* EPA Region 10: AK, ID, OR, WA Northwest Pollution Prevention Network Catherine Dickerson; Pacific Northwest Pollution Prevention Resource Center, 1326 5th Ave., Suite 650; Seattle WA 98101; phone (206) 223-1151; e-mail cdick [email protected]
* American Samoa, Guam, Hawaii, Puerto Rico, Virgin Islands P2 Information Centers for Islands Peter Rappa; Sea Grant Extension, 2525 Correa Road, HIG 237; Honolulu HI 96822; phone (808) 956-2868; e-mail [email protected]
This article was written by Jim DiPeso, communications director for the Pacific Northwest Pollution Prevention Resource Center, Seattle.
Cities and counties caught an unexpected break on May 14 when the U.S. Circuit Court of Appeals in Washington, D.C., ruled that certain EPA air quality standards were arbitrary and could not be enforced. The ruling in American Trucking Associations, Inc., et al v. EPA, halted implementation of tighter standards for ozone and particulate matter 2.5 microns and smaller. It was the result of a lawsuit filed in 1997 when EPA announced the new rules.
The regulations regarding PM-2.5 were to have taken effect in 2004. Ozone standards would have been tightened by 2005. The new standards would have significantly affected western cities and counties; Maricopa County, Ariz., businesses estimated compliance costs atnearly $184 million.
The court ruled, 2-1, that EPA had arbitrarily set standards for permissible pollution levels and that the agency overstepped its authority in promulgating the standards. “Although the factors EPA uses in determining the degree of public health concern associated with different levels of ozone and PM are reasonable,” the court said, “EPA appears to have articulated no ‘intelligible principle’ to channel its application of these factors; nor is one apparent from the statute.”
The court also stated that EPA did not clearly define the point at which ozone and particulate matter become health threats. EPA Administrator Carol Browner has indicated that she will ask the Justice Department to appeal the ruling.
Houston Mayor Lee Brown has endorsed a set of principles designed to guide the Houston-Galveston region toward compliance with federal standards for ground ozone levels. Currently, the Houston-Galveston region, made up of Harris, Galveston, Fort Bend, Montgomery, Brazoria, Waller, Chambers and Liberty counties, is designated by EPA as a non-attainment area for ground level ozone.
“I am committed to improving the air quality in the entire region,” Brown says. “We are forging a partnership designed to improve our air quality, and I am pleased with the progress we are making. Our quality of life and the one we pass on to our children tomorrow depends on the actions we take today. “
Federal standards require the area to reduce ozone levels significantly by 2007. Last June, Brown convened an air quality summit to focus attention on the issue. Houston, Harris County, the Greater Houston Partnership, the Houston-Galveston Area Council, the Regional Air Quality Planning Committee and the Citizens Environmental Coalition participated.
According to the mayor, achievement of the standard will improve health conditions associated with ozone, particularly among children and adults with pre-existing respiratory disease. If an acceptable plan is not developed by 2000, EPA could halt all federally funded transportation projects, force the implementation of more intrusive emissions control measures and place restrictions on new or expanding businesses in the eight-county area.
The summit produced the following resolutions: * Contributions to ozone non-attainment must come from every segment of the region. Every person, government entity and business in the region should do its part to reduce nitrogen oxides and volatile organic compound emissions. * Control strategies should be implemented as expeditiously as practicable to realize health benefits and prevent imposition of sanctions upon the region. * The ozone standard should be attained at the lowest economic and social costs considering effects on the lifestyles of the citizens of the region. * Local flexibility in establishing and implementing solutions should be preserved to the greatest extent possible. * Some emission control strategies, such as those on automobiles and consumer goods, are best implemented at the national level and, hence, should be accelerated if they contribute to attainment at lower costs and with fewer adverse impacts than other controls. * Priorities for technically feasible control options should be set through relative benefit to cost. * Economic incentives should be explored as part of the area’s approach. * All reasonable efforts should be made to avoid State Implementation Plan disapproval by EPA. If ozone compliance cannot be reached by reducing ozone precursors to the maximum technically feasible and cost-efficient extent, other options will be explored. * A comprehensive air quality research strategy should be encouraged to provide additional scientific information necessary for design of ozone- control programs that can reasonably be expected to reduce ozone formation and public exposure.
For more information on the initiative, contact Pamela Berger, director of environmental policy for the city of Houston, at (713) 437-6168.