Breathing Easier in SW Detroit: Mitigating Fugitive Dust with Vegetation

7/28/2019 Breathing Easier in SW Detroit: Mitigating Fugitive Dust with Vegetation

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Breathing Easier in Southwest Detroit:Mitigating Fugitive Dust with Vegetation

University of Michigan: Urban and Regional PlanningApril 2008


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University of Michigan - Urban and Regional Planning Program

2007-2008 Capstone Project Team

Students

William Brodnax

Mark HansfordTyler Kinley

Carolyn Pivirotto

Shilpy Singh

Jeff Storrar

Benjamin Stupka

Erin Thoresen

Jonathan VanDerZee

Faculty

Eric Dueweke

Larissa Larsen


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Acknowledgements

The University of Michigan graduate student capstone wishes to extend our

appreciation to Southwest Detroit Environmental Vision and the Southeast

Michigan Council of Governments for providing support and direction for this

community project:

Lisa Goldstein, SDEV Executive Director

Angela Riess, Environmental Planner, SEMCOG

Joan Weidner, Senior Planner, Transportation Programs, SEMCOG

In addition, we wish to thank the following individuals and organizations for

the valuable assistance they provided toward the successful completion of

this project:

Ann Burns, SEMCOG

Jason Cousino, DTE Energy

Margaret Dewar, Urban and Regional Planning Program, University of

Michigan Christopher Dick, Department of Ecology and Evolutionary Biology,

University of Michigan

James Earl, Severstal North America

Billy Gallegos, City of Albuquerque

Roger Gaudette, Ford Motor Company

Jen Green, Spatial and Numeric Services Librarian, University of

Michigan

MaryCarol Hunter, School of Natural Resources and Environment,

University of Michigan

Susan Katsiyiannis, City of Dearborn

Jerry Krawiec, Michigan Department of Environmental Quality Frank Marsik, Department of Atmospheric, Oceanic, and Space

Sciences, University of Michigan

Kent Murray, Department of Natural Sciences, University of Michigan

Dearborn

David Nowak, Urban Forests, Human Health, and Environmental

Quality, State University of New York

Roberta Urbani, DTE Energy

U n i v e r s i t y o f M i c h i g a n : U r b a n + R e g i o n a l P l a n n i n g P r o g r a m


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B r e a t h i n g E a s i e r i n S o u t h w e s t D e t r o i t


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Table of Contents

Executive Summary..........................................................................................

Section 1: Introduction.....................................................................................

Section 2: Fugitive Dust and Particulate Matter............................................

Section 3: Context.............................................................................................

Geographic Description.........................................................................

History, Culture, and Community...........................................................

Detroit Metropolitan Area.........................................................

Southwest Detroit......................................................................

Southeastern Dearborn.............................................................

Project Area Demographics...................................................................Biophysical.............................................................................................

Health Implications.................................................................................

Section 4: Understanding Air Quality Regulations.......................................

National Regulations..............................................................................

State Regulation and Control.................................................................

Michigan Fugitive Dust Regulations.........................................

Natural Resource and Environmental Protection Act..............

Fugitive Dust Regulations in Michigans SIP............................

Additional Fugitive Dust Rules in Michigan..............................

Section 5: Fugitive Dust and Particulate Matter Sources.............................

Major Stationary Sources.......................................................................

National Regulations for Major Stationary Sources..................

Local Regulations for Major Stationary Sources......................

Stationary Source Inventory...................................................................

Major Mobile Sources............................................................................

National Regulations for Mobile Sources.................................

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Local Regulations for Mobile Sources......................................

Mobile Source Inventory........................................................................

New Bridges..............................................................................

Truck Routes............................................................................

Trucking Facilities..................................................................................

Fugitive Dust Sources............................................................................

Unregulated Facilities...............................................................

Source Selection.......................................................................

Additional Considerations.........................................................

Section 6: Strategies for Mitigating Fugitive Dust........................................

Mechanical Solutions and Standard Practice........................................

Bioengineering and Vegetation..............................................................

The Role of Vegetation in Removing Air Pollution.................................

Mechanisms of Pollution Removal............................................

Quantification of PM10

Removal by Vegetation.........................

Species Specific........................................................................Location Specific.......................................................................

Section 7: Implementation of Mitigation Strategies......................................

Site Characteristics................................................................................

Soil Characteristics................................................................................

Climate...................................................................................................

Plant Selection and Plant List................................................................

Site Selection Process...........................................................................

Site #1: Mellon/Dix................................................................................

Site #46: Ormond St/Luther St..............................................................

Site #47: Pleasant St/Beatrice St..........................................................Site #49: Marion Ave.............................................................................

Section 8: Conclusion.......................................................................................

Bibliography.......................................................................................................

Appendix A: Health Research..........................................................................

Appendix B: Plant List.....................................................................................

Appendix C: Invasive Species.........................................................................

Appendix D: Stormwater Research.................................................................

Appendix E: Site Inventory..............................................................................

Appendix F: Community Partners...................................................................

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Executive Summary

U n i v e r s i t y o f M i c h i g a n : U r b a n + R e g i o n a l P l a n n i n g P r o g r a m 1

This project focuses on mitigating the impact of coarse particulates such as

fugitive dust by using bioengineering strategies that incorporate the use of

vegetation. The use of vegetation is a practical and cost-effective land use

practice that can help suppress airborne particulates, thus improving local air

quality. Although this report makes frequent reference to particulate matter

(PM), the recommended bioengineering strategies center on mitigating the

impacts from unregulated sources of fugitive dust including industrial facilities

and activities, unpaved and barren land, or unwashed roadways.

Although much of the American landscape is now categorized as post-indus-

trial, pockets of intense industrial activity remain. One of the most concen-

trated pockets of heavy industrial manufacturing in the United States exists in

Southeast Michigan at the confluence of Southwest Detroit and SoutheasternDearborn. Fugitive dust is a prominent source of ambient air pollution in this

area and it emanates from numerous unpaved lots, storage piles, and rail

yards. In 2004, the United States Environmental Protection Agency desig-

nated the seven-county Southeast Michigan region as a non-attainment area

for the fine particulate matter (PM2.5

) standard. A three-mile airshed buffer

around each of the two air monitors recording the highest PM levels in the

area defines our project boundaries.

Public health studies increasingly warn that exposure to ambient particu-

late matter has significant health implications. In addition to employees of

industrial facilities, approximately 152,000 nearby residents are constantlyexposed to elevated particulate levels. Federal and state authorities are

working with the largest industries to implement technical solutions to miti-

gate stationary stack emissions and initiate fugitive dust management strate-

gies. However, within the project area there are many smaller industries

and transportation companies that contribute to the fugitive dust problem but

are not regularly monitored. The goal of this project is to identify long-term

interventions that will reduce fugitive dust with bioengineering techniques that


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B r e a t h i n g E a s i e r i n S o u t h w e s t D e t r o i t 2

can be used at large industrial sources as well as smaller and less regulated

sources. To achieve this, university students and faculty worked with the

Southeast Michigan Council of Governments, the Michigan Department of

Environmental Quality, and Southwest Detroit Environmental Vision, a local

grassroots environmental justice organization.

This report provides an overarching framework for mitigating fugitive dust

using vegetation. It demonstrates the effectiveness of vegetation as a long-

term strategy to manage fugitive dust. Vegetation may be used to supple-

ment shorter-term mechanical solutions that primarily block or suppress

dust. Specifically, vegetation reduces fugitive dust by absorbing and filtering

airborne particulates, reducing local temperature variability, and blocking

wind and airborne particles. In order to demonstrate these strategies in

practice, this report identifies a number of specific bioengineering techniques

that can be used on a variety of sites. Each of these techniques is designed

to maximize the effectiveness of vegetation in dust mitigation. They may be

used not only as described for particular sites within the study area, but canalso serve as templates for sites in areas where fugitive dust poses health

risks outside of Southeast Michigan.

This report is divided into several sections. The first is an overview that

describes particulate matter and fugitive dust and also provides a context for

the project by describing the history and demographics of Southwest Detroit

and Southeastern Dearborn. The second section discusses the health impli-

cations of exposure to fugitive dust, highlighting its effects on cardiovascular

and respiratory systems. Third, the report outlines particulate and fugitive

dust regulations, which provide an understanding of the legal framework that

governs particulate pollution. The fourth section includes an inventory ofparticulate matter sources in the project area. Fifth, the report describes spe-

cific mitigation strategies, including both mechanical and vegetative solution

and how they are effective. Finally, the last section includes area-specific

implementation plans. This section contains potential demonstration sites

and examples of vegetative strategies. It also references a comprehensive

plant list located in the appendix. Additionally, the plan identifies community

partners who are likely to fund, install, and maintain these initiatives and dis-

seminate information to residents and business owners.


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1 Introduction

Although much of the Ameri-

can landscape is now cat-

egorized as post-industrial,

pockets of intense industrial

activity remain. One of the

most concentrated pockets

of heavy industrial manufac-

turing in the United States

exists in Southeast Michigan

at the confluence of South-

west Detroit and Southeastern

Dearborn. Contrary to other

industrial pockets, facilities in this area are expanding. From an air quality

perspective, stationary sources and mobile source pollution from vehicles

are significant generators of air pollution, specifically particulate matter (PM)

and fugitive dust. While state and federal agencies regularly monitor and

regulate PM, fugitive dust is often overlooked. Fugitive dust and particulate

matter are environmental hazards with serious health implications for local

residents and employees.

Fugitive dust and PM are terms used to describe a group of solid particles

and liquid droplets of various size, shape, and chemical composition that can

be suspended in the lower atmosphere for days or weeks.1 These particu-

lates can originate from storage piles and unpaved roads or from stationaryand mobile sources in the form of stack and auto emissions. High concen-

tration levels in the area are caused by the clustering of industrial facilities,

transportation infrastructure, and an abundance of fugitive dust sources. In

addition, natural meteorological processes can further exacerbate air pollu-

tion, endangering human health and the environment.

Public health and environmental studies increasingly warn of the adverse

Salina Elementary School, Detroit

Source: salina-int.dearbornschools.org


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impacts associated with these pollutants. Statistics from the Detroit area

indicate that exposure to particulates can induce negative health effects in

the pulmonary, respiratory, and cardiovascular systems.2 Young children, in-

dividuals suffering from respiratory illnesses, and the elderly are most at risk

for pollution induced health complications, resulting in additional emergency

department visits, hospital admissions, and even death.3 Studies also show

that fugitive dust and PM negatively impact natural habitats and ecosystems.

Particles that settle on soil and water can alter the nutrient and chemical bal-

ance that plants and animals need to survive.

The project area is defined by 3-mile air-shed buffers around two Michigan

Department of Environmental Quality (MDEQ) air monitors located at De-

troits Southwestern High School and Salina Elementary School in Dearborn

(see Figure 1). Industrial facilities in the area include, but are not limited

to, coal-fired utilities, municipal waste incinerators, sewage sludge incinera-

tors, refineries, iron/steel manufacturers, coke ovens, and chemical plants.4

This is also the site of the busiest United StatesCanada border crossing fortrucks.5 With the addition of a proposed second bridge from Windsor to De-

troit in the area, traffic across the United States-Canada border at this loca-

tion is projected to increase.6 In addition, several local facilities are planning

expansion projects that will increase traffic volumes throughout the area and

4

Figure 1: 3-Mile Air-Shed Buffers Defining Project Area


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potentially generate additional mobile source pollution. The combination and

concentration of these activities will likely exacerbate the particulate pollution

problem, including fugitive dust. Federal and state authorities are work-

ing with the largest industries to implement technical solutions to mitigate

stationary stack emissions and initiate fugitive dust management strategies.

However, located within the project area are many smaller industries and

transportation companies that contribute to the fugitive dust problem but are

not regularly monitored.

Because of the adverse health and environmental effects, several forms of

PM are regulated by the United States Environmental Protection Agency

(EPA) to meet annual and daily National Ambient Air Quality Standards

(NAAQS) under the Clean Air Act. In 2004, the EPA designated the seven-

county Southeastern Michigan region as a non-attainment area for the fine

particulate matter (PM2.5

) standard. The Southwestern High School and

Salina Elementary School air monitoring stations exceed the PM2.5

annual

arithmetic mean standard of 15g/m3

(micrograms per cubic meter), withmeasurements of 16.4g/m3 and 18.2g/m3 respectively.7 Through traditional

regulatory processes and creative mitigation strategies, MDEQ and South-

east Michigan Council of Governments (SEMCOG) are working to bring the

region into attainment by 2010.8

Ensuring environmentally healthy neighborhoods is an important goal for

residents of Southeast Michigan.9 To this end, University of Michigan gradu-

ate students and faculty in collaboration with Southwest Detroit Environmen-

tal Vision (SDEV), a local grassroots environmental non-profit, and SEMCOG

propose supplementing current regulatory processes with a set of bioengi-

neering strategies to mitigate fugitive dust and particulate matter in South-west Detroit and Southeastern Dearborn. The use of vegetation is a practical

and cost-effective land use practice that can aid in suppressing airborne par-

ticulates, thus improving the local environment for all. This report provides

a framework for how to implement appropriate bioengineering strategies at

prioritized sites throughout the area.


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1Ahrens, D. (2003). Meteorology Today: An Introduction to Weather,Climate, and the Environment. Pacific Grove, CA: Thomson Learning, Inc.

2 Keeler G. J., Dvonch T., Yip F., Parker E. A., Israel B. A., Marsik F. J., et al. (2002) Assessmentof personal and community-level exposures to particulate matter among children with asthma

in Detroit, Michigan, as part of Community Action Against Asthma (CAAA). Environmental Health

Perspective 110(2),173181.

3 Michigan Department of Community Health. (2002). Preventable Hospitalizations and Rates

per 10,000 Population for Patients under 18 Years of Age by Selected Leading Diagnoses,

19962000. Lansing, MI: Division for Vital Records and Statistics.

4 United States Environmental Protection Agency (2007). Retrieved February 3, 2008 from

http://www.epa.gov/midwestcleandiesel/sectors/border/index.html.

5 United States Environmental Protection Agency (2007). Retrieved February 3, 2008from http://

www.epa.gov/midwestcleandiesel/sectors/border/index.html.

6 United States Environmental Protection Agency (2007). Retrieved February 3, 2008from http://

www.epa.gov/midwestcleandiesel/sectors/border/index.html.

7 Michigan Department of Environmental Quality (2006). Retrieved November 18, 2007 from

http://www.deq.state.mi.us/documents/deq-aqd-air-reports-05AQReport.pdf.

8 State of Michigan. Department of Environmental Quality (2008). State Implementation Plan

Submittal for Fine Particulate Matter (draft). Lansing, MI.

9 City of Detroit (2004). Retrieved February 21, 2008, from http://www.ci.detroit.mi.us/plandevl/

advplanning/pdfs/MPlan/MPlan_2004/Master%20Plan%20Revision%20-%20Citywide%20Poli-

cies.pdf.



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2 Fugitive Dust andParticulate Matter

Particulate matter is a term used to describe a group of solid particles and

liquid droplets of various size, shape, and chemical composition that can be

suspended in the lower atmosphere for days or even weeks. The EPA cat-

egorizes PM as pollution from both primary and secondary sources. Primary

particles are emitted directly from a source including dust and dirt from

unpaved roads, barren fields, wood burning stoves, or fires.1 Secondary

particles are formed through the reaction of chemicals, mainly sulfur dioxides

and nitrogen oxides, in the atmosphere. These are usually emitted from in-

dustrial smokestacks and automobiles, particularly diesel fueled commercial

vehicles. This project focuses on primary particles that form fugitive dust.

MDEQ defines fugitive dust in two ways. Section R336.1106(k) of the Michi-

gan Air Pollution Control Rules defines fugitive dust as particulate matter

which can originate from indoor or outdoor industrial or commercial process-

es, activities, or operations and is emitted into the outer air through building

openings and general exhaust ventilation.2 Fugitive dust is more broadly

defined as PM that comes from unintended activities including soil distur-

bances by wind or from human activities such as walking or driving through

an unpaved parking lot.3

Particle size is the determi-

nant for PM regulations be-

cause the size of particles is

directly linked to their poten-tial for causing health prob-

lems.4 Air quality regulations

regulate two sizes of PM (see

Figure 2): PM10

, particulate

matter that is 10 micrometers

in diameter or less, and PM2.5

,

particulate matter that is 2.5Source: EPA Office of Research and Development

Figure 2: Size of Particulate Matter



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micrometers in diameter or less. PM2.5

is generally considered fine particles,

while PM10

is generally considered inhalable coarse particles. This project

is focused on mitigating the impact of inhalable coarse particles, or PM10

and

higher, because they are the primary components of fugitive dust generated

by industrial facilities and unpaved or unwashed roadways.

Along with anthropogenic activities, natural meteorological processes such

as precipitation, wind patterns, and atmospheric stability influence particulate

pollution concentrations. Precipitation acts to cleanse the air of particulates

as cloud droplets and ice crystals form around airborne particulates and

fall to the ground in the form or rain or snow. Wind patterns determine how

quickly pollutants mix with the surrounding air and where they will settle on

the ground. Strong winds quickly dilute dirty air in the surrounding cleaner

air, while lighter winds lead to less atmospheric mixing and a greater concen-

tration of pollutants. Atmospheric stability determines whether air masses

will mix horizontally or vertically. Meteorological research suggests that

normal changing atmospheric stability, from stable in the early morning toconditionally unstable in the afternoon, can have a profound effect on the

daily concentrations of pollution.5 A stable atmosphere generally resists

vertical air movement, instead spreading pollutants horizontally in the lower

atmosphere. The worst air pollution often occurs in stable atmospheres

when atmospheric stagnation dominates, combining light winds with poor

vertical mixing.

8


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1 United States Environmental Protection Agency. (2007). Retrieved February 15, 2008 fromhttp://www.epa.gov/oar/particlepollution/basic.html.

2 Michigan Department of Environmental Quality. (2007). Retrieved February 16, 2008, fromhttp://www.michigan.gov/deq/0,1607,7-135-3310_4148-11396--,00.html.

3 Ibid.

4 United States Environmental Protection Agency. (2007). Retrieved February 16, 2008, from

http://www.epa.gov/oar/particlepollution/health.html.

5Ahrens, D. (2003). Meteorology Today: An Introduction to Weather, Climate, and the Environ-

ment. Pacific Grove, CA: Thomson Learning, Inc.


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3 Context

Geography

The project area is located in Southeast Michigan (see Figure 3). The seven-county region includes Livingston, Macomb, Monroe, Oakland, St. Clair,

Washtenaw, and Wayne Counties and is home to the majority of the states

population and economic activity. Interstates 94 and 75 and several rail lines

connect the area to northern Michigan and the Midwest. The eastern bound-

ary of the region is the Detroit River, which forms the international border with

Canada.

Detroit, located on the banks of the Detroit River in Wayne County, is the

states largest city. The city and its metropolitan area encompass many

diverse neighborhoods. The project area is located a few miles southwest of


Figure 3: Southeast Michigan Context Map


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downtown Detroit and is defined by 3-mile air-shed buffers surrounding two

MDEQ air monitoring stations located at Southwestern High School in Detroit

and Salina Elementary School in Dearborn. The air-shed buffers contain por-

tions of several municipalities, including Detroit, Dearborn, Melvindale, River

Rouge, and Windsor, Canada. The bioengineering strategies outlined in this

report are tailored to Southeastern Michigan neighborhoods.

History, Culture, and Community

Detroit Metropolitan Area

Settled by the French in 1701 and changing hands multiple times throughout

its early history, the City of Detroit was incorporated as the new capital of the

Michigan Territory in 1815. The Detroit region grew throughout the 19th cen-

tury as a shipping, shipbuilding, and manufacturing center.1 Detroit became

an immigrant city, attracting Germans, Irish, Greeks, Italians, Poles, Serbs,

Croats, and others with a variety of labor and trade opportunities. The popu-

lation and economic activity rapidly increased during the Industrial Revolutionand Detroit quickly became one of the busiest ports in the world.

Laborers from Europe and throughout America moved to the region as

Detroit expanded upward and outward. Population and economic growth

surged with the invention and success of the automobile, and Detroits

growth mirrored that success, incorporating automotive manufacturing

and associated heavy industrial plants into its economic base. Four major

automobile manufacturers including Ford Motor Company, General Motors,

Chrysler, and American Motors, established their headquarters in Detroits

metropolitan area in the early 20th century. By the mid-20th century Detroit

had become a major commercial center of the Midwest and, arguably, thetransportation center of the world.

As jobs became increasingly mobile and market competition increased, the

auto industry began to decline in the latter half of the 20th century. The

regions economic dependence on the automobile industry, coupled with

racial tensions, brought extensive unemployment, segregation, and crime

to the city. Population rapidly declined as people and businesses migrated

to suburban neighborhoods, leading to the physical, economic, and social

deterioration of Detroits central city. In recent years, the Big Three automak-

ers loss of market shares to foreign competition has led to further economic

hardship in the region.

The SEMCOG Economic and Demographic Outlook for SE Michigan

Through 2035describes the regions economy as being in the midst of an

economic crisisprobably the worst in our lifetime. The crux of Detroits

struggle is the recent restructuring of the auto makers, specifically Chrysler,

Ford, and General Motors, whose market share has dropped from a high of

72.6 percent in 1995 to the current 2008 level of 49.4 percent, with a mod-

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est downward drift as the most probable future. The location quotient, which

measures the concentration of a particular business sector in a local area

compared to that of the nation as a whole, shows that the areas auto manu-

facturing is 7.8, reflecting a concentration 7.8 times greater than the national

average. Although long considered a manufacturing center, the manufactur-

ing location quotient for Southeastern Michigan without the auto industrydrops to .78, which is far below the national average. This clearly highlights

the regions strong dependence on this industry.

Regional job growth within the past 10 years has also been weak, and SEM-

COG projects that this trend will continue in the coming years, but with cer-

tain areas of the economy showing modest promise. Employment in govern-

ment and health care surpassed that provided by the auto industry, and has

grown every year since 2001.2 The woes of the auto industry are projected

to continue in the near-term as economic restructuring continues, although

SEMCOG forecasts stabilization after 2012. Despite economic uncertainty,

the Southeast Michigan region continues to function as the economic centerof the state and remains home to nearly 4.5 million people. Communities

located within the project area, specifically Southwest Detroit, Southeastern

Dearborn, Melvindale, and River Rouge, are defined in large part by blue-

collar ethnic neighborhoods dependent upon the nearby manufacturing jobs

and local entrepreneurship.

Southwest Detroit

In the late 1800s Southwest Detroit was home to a wide array of industries

attracted by the easy access to the Detroit River and to the railroad lines

located in the district. Interestingly, salt (found in the subterranean salt beds

beneath Detroit) was a major factor in the rapid industrialization of this area,and sparked a salt-based chemical industry on and near Zug Island. During

this time, twelve of Detroits twenty largest manufacturing companies were

located in Southwest Detroit. Small industries and manufacturers supported

the larger manufacturing companies. Technical skills and knowledge gained

by employees at these companies were key elements in the early success of

the auto industry.

Despite Detroits economic decline over the past several decades, Southwest

Detroit continues to attract immigrants whose businesses spur economic

activity and contribute to a sense of community. Located two miles out-

side of downtown and reflecting the large, concentrated Latino population,

Southwest Detroit is home to a neighborhood often referred to as Mexican-

town. Attracted by an abundance of jobs and reasonably priced housing,

immigrants from the Jalisco region in Mexico have been making their way to

Detroit since the 1920s, with immigration rates increasing since the mid-

twentieth century. While the construction of an expressway through Mexican-

town during the 1970s would have split the neighborhood in two, additional

immigration during this time helped to maintain the areas economic vitality.

In the early 1900s, twelve

of Detroits twenty largest

manufacturing companies

were located in SouthwestDetroit.


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Estimates indicate that the most recent wave added 20,000 people to the

neighborhood.3 Mexicantown is home to some of the strongest neighbor-

hood commercial districts in the city and the Latino population is considered

the key economic force behind the neighborhoods strength, as indicated by

few empty storefronts and recent construction projects along Bagley Street

and West Vernor Highway, the two main commercial corridors.4

Southeastern Dearborn

Dearborn was incorporated as a city in 1927 and quickly merged with the

Springwells neighborhood to form its current boundaries. Starting in the

late 1940s, and influenced by Middle Eastern economic and political condi-

tions, Dearborn attracted Arabic immigrants with job opportunities offered

at Michigans automobile factories, particularly the Ford Motor Companys

Rouge River plant.5 Once a destination for families fleeing downtown Detroit

in the 1960s, Southeastern Dearborn experienced a rapid influx of Arab im-

migrants and is now home to the largest concentration of Arab-Americans in

the United States.6

Dearborns Arabic population maintains its cultural identity through steady

immigration, a strong sense of community, and cultural anchors such as the

Dearborn Mosque, which was the second mosque built in the United States.7

The city is also home to the Islamic Center of Americathe largest mosque

in North America. Much like Southwest Detroit, Southeastern Dearborn

relies on the strength of its immigrant community through tough economic

times. For instance, the Dearborn area witnessed a 6.9 percent increase in

employment from 1990 to 2000, and area forecasts estimate a 5.8 percent

increase through 2035.8

Demographics

The demographic composition of the project area is difficult to accurately

identify because it encompasses multiple neighborhoods in several cities.

Based on an analysis of 2000 U.S. Census data, the population in the project

area is approximately 152,977.9 Figure 4 illustrates the population density in

the project area. The populations that face the greatest health risks from ex-

posure to PM and fugitive dust are those under 5 and over 65 years of age,

as well as individuals that suffer from respiratory disease. About 20.5 per-

cent of the area population, or 31,332 residents, fall into this demographic.

A variety of races are represented within the study area. Approximately 56

percent of residents are white and about 20 percent are black. Additionally,

about 27 percent of the total population identifies themselves as Latino. It is

important to note that while 75 percent of Southeastern Dearborn is white,

this statistic belies the fact that about 30 percent of Dearborns population

is Arabic.10 It is also noteworthy that while the City of Detroit experienced

a consistent population decline since the 1950s, specific neighborhoods in

14

Southeastern Dearborn

is home to the largest

concentration of Arab-

Americans in the United

States

The populations that face

the greatest health risks

from exposure to PM and

fugitive dust are those un-

der 5 and over 65 years of

age, as well as individuals

that suffer from respiratory

disease.


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the study area have experienced population growth. Much of the Detroit

portion of the study area falls into Cluster 5, an area designated by the City

of Detroits Planning and Development Department. Within Cluster 5, the

Springwells neighborhood population increased about 10 percent from 1990

to 2000. The Latino population in Cluster 5 doubled from 4,432 to 9,858 resi-

dents during this period.11 Additionally, between 1990 and 2000, the Vernor-

Junction neighborhood (located in Cluster 5) experienced a population

increase of 0.04 percent, while the Latino population grew by 61.2 percent.12

Approximately 57,661 total housing units exist in the project area. Of these,

about 10 percent are vacant, 48 percent are owner-occupied, and 42 percent

are renter-occupied. Much of the housing stock was constructed during the

1940s and the subsequent post-WWII housing boom to accommodate an ex-

panding workforce. Today, approximately 35 percent of the jobs available in

the project area are in blue-collar professions such as construction, manufac-

turing, wholesale trade, transportation, and warehousing. Median household

income is $28,364, considerably lower than the state level of $47,182 and

the national level of $48,451.13

Biophysical Conditions

The 32-mile Detroit River forms the eastern boundary of the project area

and connects Lake Saint Clair and the upper Great Lakes with the lower

Great Lakes. The river provides an important commercial shipping link in the

Great Lakes and is a drinking water source for many Detroit Metro residents.

However, the EPA designates the 607-square mile Detroit River watershed,

including the 107-square mile City of Detroit sewershed, as an Area of

Figure 4: Population Density in Project Area


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Concern, citing eleven beneficial use impairments due to urban and indus-

trial development in the watershed, bacteria, PCBs, PAHs, metals, oils and

greases[from] sewer overflows, municipal and industrial dischargesand

stormwater runoff.14 The Rouge River and Ecorse River tributaries mean-

der westward through these highly urbanized watersheds in the metro area

before draining into the Detroit River.

In the early 1800s, coastal wetlands along the Detroit River shoreline were

contiguous and nearly one mile wide on both sides of the river. They were

described as a pristine paradise with abundant edible fruits, lush meadows,

forests, fish, and wildlife.15 Since then, the river ecosystem changed dra-

matically due to the level of development near the river and the hardening of

the shoreline by pilings and breakwalls. Development now claims over 99

percent of the coastal wetlands that were once present in the early 1800s,

resulting in the loss of habitat, natural flood control, erosion protection, and

sediment removal.16 Efforts to restore the remaining wetlands threatened by

development and pollution are ongoing.

Tree canopy and open space in the area are rapidly declining due to devel-

opment, disease, and poor maintenance, leading to an increase in storm-

water runoff and declining air and water quality. In addition, Dutch Elm

Disease and the Emerald Ash Borer destroyed much of the tree canopy over

the past half century. Urbanization of land in the Rouge and Ecorse River

Watersheds continues to increase faster than population.17 Isolated patches

of green space and vacant and abandoned land scattered throughout the

neighborhoods illustrate this trend.

Health Implications of Particulate Air Pollution

Epidemiological research shows that human exposure to PM has a number

of adverse health impacts. Studies dating back to the 1970s consistently

find that PM10

penetrates the defense mechanisms of the upper and middle

regions of the respiratory tract.18 More recent evidence shows that human

exposure to fine particles, such as PM2.5

, may be even more of a concern.

For instance, PM as large as 10 micrometers tends to impact the upper and

middle regions of the respiratory tract, while PM2.5

micrometers and smaller is

more likely to be inhaled deep into the lungs, making its way into the bodys

lower respiratory system where it stays for long periods of time.19&20 PM2.5

also tends to be a greater concern because it can be more toxic due to its

chemical composition. The health implications from exposure to PM include

decreased lung function, more frequent asthma symptoms, increased asth-

ma attacks, more frequent emergency department visits, additional hospital

admissions, and increased numbers of deaths.21 Table 1 includes the EPA

list of findings for health effects associated with exposure to fine and coarse

particles.

16

Development now claims

over 99 percent of the

coastal wetlands that were

once present along the

Detroit River, resulting in

the loss of habitat, natural

flood control, erosion

protection, and sediment

removal.


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Table 1:

Health Effects Associated with Exposure to Fine & Coarse Particles22

Short-term exposure to

PM2.5

Long-term exposure to

PM2.5

Short-term exposure to

PM10

Premature death in

people with heart and lung

disease

Premature death in

people with heart and lung

disease, including death

from lung cancer

Premature death for those

with heart or lung disease

Non-fatal heart attacks Reduced lung function Hospital admissions for

heart disease

Increased hospital admis-

sions, emergency room

visits and doctors visits

for respiratory diseases

Development of chronic

respiratory disease in

children


sions and doctors visits

for respiratory disease


sion and ER visits forcardiovascular diseases

Increased respiratory

symptoms in children

Increased respiratory

symptoms such as cough-

ing, wheezing and short-

ness of breath

Decreased lung function

Lung function changes,

especially in children and

people with lung disease

such as asthma

Changes in heart rate

variability

Irregular heartbeat

Research concludes that children are at greater risk from exposure to air pol-

lution, including fine particles. This is primarily because (1) their bodies are

still growing, (2) they take in a greater volume of air per pound of body weight

than adults, and (3) they spend more time outdoors doing physical activi-

ties.23 The elderly and individuals with asthma also are at greater risk than

middle-aged adults. Figures 5 and 6 illustrate the distribution of childern and

the elderly in the project area.

In addition to having adverse impacts on the human respiratory system,

recent research shows that PM may have adverse effects on the human

cardiovascular system. Studies consistently find an association between

cardiovascular hospital admissions, mortality, and outdoor air pollution, par-

ticularly concentrations of PM less than or equal to 2.5 or 10 micrometers in

diameter.24 These studies support associations between PM and the risk of

ischemia and arrhythmias, increased blood pressure, decreased heart rate

variability, and increased circulating markers of inflammation of thrombosis,


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all of which are markers of cardiovascular health.25 The components of PM

that adversely impact the cardiovascular system are not entirely known. As

a result, research has more recently focused on specific elements within PM

to identify which elementsor interactions between elementsare contribut-

ing factors associated with compromised cardiovascular health. A number

of these studies focus on the metals often found in PM. Using a popula-

tion of 39 boilermakers, a recent study examined the effects of those metal

Figure 5: Distribution of Population Age 5 and Under

Figure 6: Distribution of Population Age 65 and Over


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components used in industrial activities on the autonomic nervous system.

The metals studied included vanadium, nickel, chromium, lead, copper, and

manganese, all of which are common components of PM2.5

. The authors

observed a connection between exposure to the airborne metals and signifi-

cant discrepancy in cardiac autonomic function.26 Although the U.S. main-

tains ambient air standards for PM10

and PM2.5

, such health effects described

above are often observed at levels below current U.S. National Ambient Air

Quality Standards for particulate air pollution.27

Also of concern for the project area population are the chemical concentra-

tions found in PM. Research suggests that the driving force behind the

adverse cardiovascular health impacts may be the concentrations of airborne

metals found in PM, many of which are carcinogenic. According to Wayne

State Universitys database (detroitkidsdata.org), carcinogenic air discharges

for zip code 48209, which overlays a large portion of the project area, repre-

sent 69.6 percent of all carcinogenic discharges in the city.28

Health statistics for the City of Detroit clearly demonstrate the negative

effects of land use patterns in which residential homes are situated near con-

centrations of industrial facilities and activities. Fourteen percent of Detroits

children have been diagnosed with asthma while an additional 14.3 percent

go undiagnosed.29 According to the 2004 Detroit Health and Wellness Proj-

ect report, chronic lower respiratory disease was one of the top five causes

of death among children of all races/ethnicities ages 10 to 19 in Detroit

during the 2003-2004 year. Furthermore, the Michigan Department of Com-

munity Health reports that hospitalization rate for asthma among children in

Detroit is more than three times the statewide average.30 It is safe to say that

if local residents continue to be exposed to the current PM and fugitive dustlevels, their health and quality of life will continue to decline.

Please see Appendix A for more information about the health implications of

particulate matter exposure.

The Michigan Department

of Community Health

reports that hospitalization

rate for asthma among

children in Detroit is more

than three times the state-

wide average.


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1 The Columbia Encyclopedia. (2007). Detroit, City, United States. Sixth Edition.

2 Ibid.

3 Bonisteel, S. (2007) Fox News, January 11, 2007, Retrieved March 3, 2008, from www.fox-

news.com/story/0,2933,243180,00.html.

4 Ibid.

5 Belton, P. In the Way of the Prophet: Ideologies and Institutions in Dearborn, Michigan,

Americas Muslim Capitol, The Next American City, (3), Retrieved February 16, 2008, from http://americancity.org/magazine/article/in-the-way-of-the-prophet-ideologies-and-institutions-belton/.

6Arab American Institute, Retrieved February 16, 2008, from http://www.aaiusa.org/founda-tion/358/arab-americans.

7 Ibid.

8 SEMCOG. (2003). Regional Development Forecast Community Detail Report. Retrieved

March 2, 2008, from http://library.semcog.org/InmagicGenie/DocumentFolder/RegionalDevelopm

entForecast_2030CommunityDetail.pdf.

9 U.S. Census. (2000). Retrieved March 2, 2008, from www.census.gov.

10 U.S. Census. (2003). The Arab Population: 2000. Census 2000 Brief. December 2003, Re-

trieved February 16, 2008 from http://www.census.gov/prod/2003pubs/c2kbr-23.pdf.

11 City of Detroit, Master Plan. (2004). 5-11. Retrieved February 16, 2008 from http://www.

ci.detroit.mi.us/plandevl/advplanning/pdfs/MPlan/MPlan_2004/Cluster5.

12 City of Detroit, Master Plan. (2004). Table 5-6.

13 United States Census Bureau. (2006).


http://www.epa.gov/glnpo/aoc/detroit.html.


http://www.epa.gov/med/grosseile_site/indicators/wetlands.html.

16 Ibid.

17American Forests. (2006). Urban Ecosystem Analysis: SE Michigan and City of Detroit. Re-trieved February 3, 2008 from http://americanforests.org/downloads/rea/AF_Detroit.pdf.

18 United States Environmental Protection Agency. (2006). Retrieved November 28, 2007 from

http://www.epa.gov/eogapti1/module6/matter/character/character.htm.

19 Dockery, D., Pope, C., Xiping, X., Spengler, J. et al. (1993). An Association between Air Pol-

lution and Mortality in Six U.S. Cities. New England Journal of Medicine, 329,1753-1759.

20 United States Environmental Protection Agency. (2006). Retrieved November 28, 2007 from

http://www.epa.gov/eogapti1/module6/matter/character/character.htm.21 United States Environmental Protection Agency. (2004). Retrieved October 29, 2007 from

http://cfpub2.epa.gov/ncea/cfm/recordisplay.cfm?deid=87903.

22 Ibid.

23 Ritchie, I. (2007). Effects of PM2.5 on Childrens Health in Indiana. Issue Paper for: Summitfor Childrens Environmental Health at Indiana University-Purdue University Indianapolis. Re-

trieved November 1, 2007, from http://www.ceh.iu.edu/Documents/Fine%20Particles.pdf.



29/121

24 Delfino, R. J., Constantinos S., and Malik, S. (2005) Potential role of ultrafine particles inassociations between airborne particle mass and cardiovascular health. Environmental Health

Perspectives. 113.8(934),13.

25 Ibid.

26 Magari, S., Schwartz, J., Williams, P., Hauser, R., Smith, T., Christiani, D. (2002). The as-

sociation of particulate air metal concentrations with heart rate variability. Environmental HealthPerspectives, 110, 875-879.

27 Pope, C., Bates, D., and Raizenned, M. (1995). Health Effects of Particulate Air Pollution:Time for Reassessment? Environmental Health Perspectives, 103(5), 472-480.

28 Detroit Kids Data. Retrieved November 7, 2007, from detroitkidsdata.org.

29 Lewis, T. C., Robins, T. G., Dvonch, J. T., Keeler, G. J., Fuyuen, Y. (2005). Air PollutionAs-

sociated Changes in Lung Function among Asthmatic Children in Detroit. Environmental HealthPerspectives, 113(1068), 175.

30 Michigan Department of Community Health. (2002). Preventable Hospitalizations and Rates

per 10,000 Population for Patients under 18 Years of Age by Selected Leading Diagnoses,

19962000. Lansing, MI: Division for Vital Records and Statistics.



30/121



31/121

4 Understanding Air QualityRegulations for ParticulateMatter and Fugivtive Dust

National Regulations and Control

The 1990 amendments to the Clean Air Act established National Ambient AirQuality Standards for six criteria pollutants:

1. particulate matter

2. ozone

3. lead

4. sulfur dioxide

5. carbon monoxide

6. nitrogen oxide

Standards for these six pollutants were adopted because they are consid-

ered to be harmful to the public and environment. The Clean Air Act sets

primary and secondary standards for criteria pollutants (see Table 2).

Primary standards protect public health including sensitive populations,

while secondary standards protect public welfare in terms of visibility, agri-

cultural economy, and building stock. Regulations establish further distinc-

tions within the primary and secondary standards for PM, including annual

and 24-hour standards. The current standard for PM2.5

for a 24-hour period

is 35 micrograms/cubic meter (g/m3), while the annual standard is 15g/

m3. The current 24-hour standard for PM10

is 150g/m3; however, the an-

nual standard has been revoked because available evidence generally does

not suggest a link between long-term exposure to current levels of coarse

particles and health problems.1 Standards for PM are based on an average

of daily or yearly measurements. Annual PM2.5

standards are averaged over

a three-year period and must not exceed 15g/m3. 24-hour PM2.5

standards

are also averaged over three years. The 98th percentile of this three-year

average must not exceed 35g/m3. The Clean Air Act requires states to have

air quality monitoring stations that provide data used to produce air quality

statistics. Air quality statistics are used to determine whether a geographical

area complies with NAAQS.



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Table 2:

National Ambient Air Quality Standards for Particle Pollution2

Pollutant Primary

Standards

Averaging Times Secondary

Standards

Particulate

Matter (PM10)

Revoked Annual

(Arith. Mean)150 g/m3 24-hour

Particulate

Matter (PM2.5

)

15 g/m3 Annual

(Arith. Mean)

Same as Primary

35 g/m3 24-hour

State Regulation and Control

The Clean Air Act requires every state to adopt a State Implementation Plan

(SIP). An SIP contains the control measures and strategies to both attain

and maintain NAAQS, including particulate matter in the form of fugitivedust.4 Typical elements of an SIP include state-issued and EPA-approved

orders requiring pollution control at individual companies, federal air quality

regulations, and planning documents such as area-specific compilations of

emissions estimates and computer simulations demonstrating that the regu-

latory limits will provide timely compliance with NAAQS.5 The development

of an SIP must follow a specific process. Every state is required to provide

a public comment period for each proposed element within an SIP.6 Follow-

ing public input, control measures and strategies are submitted to the EPA.

Once submissions are approved by the EPA, they are incorporated into the

federally approved SIP. Given the number of air quality elements required in

an SIP by the Clean Air Act, the document is quite extensive. For example,

required elements for PM include: air pollution control regulations; emission

inventories; monitoring networks; attainment demonstrations; and enforce-

ment mechanisms.7 Thus, an SIP is not one comprehensive document ap-

proved on a regular basis by the EPA. Instead, it is a living document which

can be revised to address the unique air pollution problems in a given state.

It should be noted that states do adopt air quality legislation that is not incor-

Particulate Matter Levels in Dearborn and Detroit

MDEQs 2006 Annual Air Quality Report shows that the two monitoring sta-

tions in the study area measure at levels exceeding annual and 24-hour PM2.5

standards.

3

The Dearborn monitor shows the highest PM10readings in thestate at 31.3g/m3. Consequently, the State of Michigan is required by the

Clean Air Act to develop and adopt controls and strategies that will bring all

non-attainment areas into compliance. The methods by which controls and

strategies are identified for the EPA are incorporated in a State Implementation

Plan (SIP).


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porated into an SIP. For instance, several of Michigans fugitive dust control

rules are not incorporated in the states SIP.

Michigan Fugitive Dust Regulation

Michigan has specific rules associated with the generation and control of

fugitive dust, a number of which are incorporated into Michigans SIP. De-pending on the type of fugitive dust source, local air quality measurements,

or the level of public concern, fugitive dust sources may be required to devel-

op a fugitive dust program. A fugitive dust program is an operating program

[] designed to significantly reduce the fugitive dust emissions to the lowest

level that a particular source is capable of achieving by the application of

control technology that is reasonably available, based on technological and

economic feasibility.8 In addition to the fugitive dust provisions in Michigans

SIP, the Natural Resources and Environmental Protection Act and Michigan

Rule 336.1901 also provide specific rules associated with potential fugitive

dust generating facilities. The following rules apply to fugitive dust sources in

Wayne County:

Part 55 of the Natural Resources and Environmental

Protection Act, 1994, as Amended

Section 324.2424Fugitive Dust Sources & Emissions

Section 324.5525Definitions

Michigan Air Pollution Control Rules

Section R 336.1371Fugitive Dust Control Programs

Section R 336.1372Fugitive Dust Control Methods

Section R 336.1901Air Contaminants, prohibited

These rules define three ways a facility or site may be required to develop a

fugitive dust program. A fugitive dust program may be required if:

1. A potential fugitive dust generating activity is located within

a designated nonattainment area (Section 324.2424)

This rule targets air polluting industrial facilities that are

located in areas with excessive PM levels and that

must obtain air pollution permits through MDEQ.

2. MDEQ determines that an area has excessive PM

concentrations or receives a substantial number of com-

plaints regarding fugitive dust emissions (Rule 336.1371)

This rule targets facilities and activities that process,

use, store, transport, or convey bulk materials from a

highly emitting dust source.

Depending on the type of

fugitive dust source, local

air quality measurements,

or the level of public

concern, fugitive dust

sources may be required

to develop a fugitive dust

program.


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3. A fugitive dust source is determined to be a public

nuisance (Rule 336.1901)

This rule targets a person that causes or allows air

contamination in quantities that jeopardize the health

and welfare of the public.

Natural Resource and Environmental Protection Act Requirements

Section 324.5524, Part 55, of the Natural Resources and Environmental Pro-

tection Act (NREPA) includes requirements for potential fugitive dust generat-

ing activities in nonattainment areas. Specifically, it requires that potential fu-

gitive dust generating activities in designated nonattainment areas (1) adopt

and implement fugitive dust programs and (2) meet certain opacity limits.

The original intent of this measure was to help ensure areas that have been

determined to not meet PM10

air quality standards effectively address the re-

duction of local PM levels. Facilities required to have fugitive dust programs

include those with the following standard industrial classification (SIC) codes:

SIC 10-14Mining Operations

SIC 20-39Manufacturing Operations

SIC 40Railroad Transportation

SIC 42Motor Freight Transportation and Warehousing

SIC 491Electric Services

SIC 495Sanitary Services

SIC 496Steam Supply

Facilities that fall within one of these codes cannot cause or allow fugitive

dust from a road, lot, or storage pile to reach an opacity measurement great-

er than 5 percent, as measured by EPA Protocol Reference Method 9D.9 Inaddition, Section R 325.5524 (2) states that any facility falling within these

codes cannot cause or allow the emission of fugitive dust from any other fugi-

tive dust source that has an opacity greater than 20 percent, as determined

by test method 9D.10 This may include, for example, the handling of a bulk

material storage pile, which constitutes an active storage pile. The NREPA

also requires that these regulated facilities adopt suppression methods for

particular fugitive dust activities. Typical fugitive dust generating activities

and suppression methods recommended by MDEQ are outlined in Table 3.


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Table 3:

Fugitive Dust Generating Activities and Suppression Methods11

Source Suppression Method

Material Storage Pile Protect with cover, enclosed, sprayed

with water or a surfactant solution, ortreated by an equivalent method

Conveyor loading operations to storage

piles

Utilize spray systems, telescopic chutes,

stone ladders, or other equivalent

methods

Batch loading operations from storage

piles

Utilize spray systems, limit drop heights,

enclosures, or other equivalent methods

Unloading operations from storage piles Utilize rake reclaimers, bucket wheel

reclaimers, underpile conveying,

pneumatic conveying with baghouse,

water sprays, gravity-feed plow reclaim-

ers, front-end loaders with limited dropheight, or other equivalent method

Traffic pattern access areas surround-

ing storage piles and all traffic patterns

roads and parking facilities

Pave or treat with water, oils, or chemi-

cal dust suppressants

Unloading and transporting operations

of materials collected by pollution control

equipment

Utilize spraying, pelletizing, screw con-

veying, or other equivalent method

Crushers, grinding mills, screening

operations, bucket elevators, conveyor

transfer points, conveying bagging op-

erations, storage bins, and fine product

truck and railcar loading operations

Spray with water or a surfactant solu-

tion, utilize choke-feeding, or equivalent

method

Although Section 324.5524 of the NREPA was originally adopted to reduce

PM10

levels in nonattainment areas, its provisions are still used to control

fugitive dust generating activities in Wayne County. As a result, these re-

quirements are currently incorporated into the most commonly used method

to regulate fugitive dust sources: the Permit to Install or the New Source

Review process. For instance, compliance with NREPA is usually ad-

dressed during the air permitting process. In accordance with Michigan Rule

336.1201, a facility that has the potential to emit air pollution must go through

the New Source Review process and obtain a Permit to Install prior to the

installation, construction, reconstruction, relocation, or modification of equip-

ment that emits air contaminants.12 The Permit to Install is a state license

to emit air contamination into the ambient air. It provides a list of conditions

with which the responsible person or company must comply. Conditions

typically limit the emission of air contaminants, restrict hours of operation,

limit the amount and type of raw material used, and require the operation


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of air pollution control equipment.13 Based on the New Source Review, and

applicable NREPA provisions, a facility within a nonattainment (or previously

nonattainment) area may be required to include a fugitive dust program as a

condition of the Permit to Install.

Fugitive Dust Rules Included in Michigans SIP

Statewide fugitive dust provisions are included in Part 3, Emissions Limi-

tations and Prohibitions, of Michigans SIP. According to Michigan Rule

336.1371, in response to excessive PM measurements or a substantial

number of complaints, the MDEQ may request a fugitive dust suppression

program from a facility that processes, uses, stores, transports, or conveys

bulk materials from a highly emitting dust source.14 Highly emitting dust

sources include the loading and unloading of open storage piles, transporting

bulk materials, outdoor conveying, construction, renovation, and demolition,

inactive storage piles, building ventilations, roads and lots.

Requirements for a fugitive dust program under Michigan Rule 336.1371 areprovided in Michigan Rule 336.1372. The requirements are divided accord-

ing to the type of fugitive dust generating activity or source, including:

Open storage piles of bulk material

Transporting of bulk materials

Outdoor conveying

Roads and lots

Inactive storage piles

Building ventilation

Construction, renovation, or demolition

Fugitive dust programs under Michigan Rule 336.1371 are reviewed and

approved by MDEQ. After approval of the program, responsible parties must

maintain the control schedule documented in the program. Fugitive dust

programs can be revised if facility circumstances change.

Additional Michigan Fugitive Dust Rules

While not included in the fugitive dust section of Michigans SIP, Michigan

Rule 336.901 also applies to the control of fugitive dust. Michigan Rule

336.901 states that a person cannot cause or permit air contamination in

quantities that cause (a) injurious effects to human health or safety, animal

life, plant life of significant value, or property or (b) unreasonable interference

with the comfortable enjoyment of life and property.


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1 United States Environmental Protection Agency. (2006). Final Revisions to the National Ambi-ent Air Quality Standards for Particle Pollution (Particulate Matter).

2 United States Environmental Protection Agency. (2008). Retrieved January 31, 2008 fromhttp://www.epa.gov/air/particlepollution/standards.html.

3 Michigan Department of Environmental Quality. (2006) Annual Air Quality Report. 27-35.

Retrieved November 18, 2007 from http://michigan.gov/documents/deq/deq-aqd-air-reports-06AQReport_216544_7.pdf.

4 United States Environmental Protection Agency. (2006). Approval and Promulgation of AirQuality Implementation Plans. Retrieved December 12, 2007, from http://www.epa.gov/fedrgstr/

EPA-AIR/2006/September/Day-06/a14708.htm.

5 Michigan Department of Environmental Quality. (n.d.). State Implementation Plan Overview.

Retrieved November 12, 2007, from http://www.michigan.gov/deq/0,1607,7-135-3310_30151_3

0154---,00.html.

6 United States Environmental Protection Agency. (2006). Approval and Promulgation of Air

Quality Implementation Plans; Michigan; Revised Format of 40 CFR Part 52 for Materials Being

Incorporated by Reference. Retrieved January 12, 2008, from http://www.epa.gov/fedrgstr/EPA-AIR/2006/September/Day-06/a14708.htm.

7 Michigan Department of Environmental Quality. (2008). State Implementation Plan Submittalfor Particulate Matter2.5. Retrieved February 11, 2008, from http://michigan.gov/documents/

deq/deq-aqd-air-aqe-sip-pm25-1-14-08_223446_7.pdf.

8 Michigan Department of Environmental Quality. (2005). Managing Fugitive Dust: A Guide for

Compliance with the Air Regulatory Requirements for Particulate Matter Generation.

9 Ibid.

10 Ibid.

11 Ibid.

12 Michigan Department of Environmental Quality. (2007). Air Quality Regulations. Re-trieved January 23, 2008, from http://www.michigan.gov/documents/deq/deq-ess-p2tas-

FVGuidech1_199604_7.pdf.

13 Ibid

14 Michigan Department of Environmental Quality. (2005).


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5 Fugitive Dust and ParticulateMatter Sources

Fugitive dust pollution can come from a variety of sources. Consequently,

it is often difficult to identify the direct source of fugitive dust because it canconsist of any activity, process, or unintended consequence that produces

unaccounted for PM. Examples of these unintended emissions include an

automobile driving on an unpaved or dirt-covered roadway, a strong wind

blowing uncontrolled soil from a large bulk material storage pile, or a heavy

commercial vehicle exiting a construction or unpaved industrial site. In addi-

tion, emission can occur from a variety of land uses including major industrial

sites, public roadways, or private residential properties. While some of the

largest major sources in Michigan are required to implement fugitive dust

programs, a significant number of dust generating facilities and activities go

unmonitored and untreated. This report identifies many of these facilities and

activities in the project area and suggests mitigation strategies to help reducePM levels. This report also identifies major stationary and mobile sources of

PM in the area. This is a necessary step in mitigating fugitive dust because it

helps identify facilities that are likely to have implemented a fugitive dust pro-

gram required by Michigan air quality provisions. Additionally, a clear under-

standing of current PM generation in the area helps guide the most effective

long-term mitigation strategies. For instance, a number of industrial facili-

ties in the area plan to expand their operations over the next several years.

Focusing mitigation strategies in close proximity to these areas may prove

ineffective once expansion projects take place and facilities and surrounding

landscape are altered.

It is important to acknowledge that state and federal air quality regulations

provide the framework for monitoring and mitigating PM2.5

and PM10

from ma-

jor stationary and mobile sources. Consequently, this report does not specifi-

cally recommend or solicit amendments to existing air quality regulations for

these facilities. However, because it is important to understand the rules

that apply to the generation of PM in relation to fugitive dust, the changes to

these regulations are outlined in the following section.



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In February 2008, MDEQ issued a draft version of the State Implementation

Plan Submittal for Fine Particulate Matter (PM2.5).1 The draft outlines both

national and local controls designed to ensure that PM2.5

in the region and,

particularly in the project area, will meet the 24-hour and annual NAAQS

standards. The document states that the controls will contribute to a down-

ward trend in PM emissions in the entire region, and particularly the monitors

in the project area. Using air quality monitoring data, MDEQ and SEMCOG

reviewed local conditions, evaluated the implementation of adopted controls,

and have determined that the area will meet NAAQS for PM2.5

by 2010.

The following section provides an overview of the major PM stationary

sources, mobile sources, and the significant changes taking place, as well as

the efforts currently underway to reduce PM levels in the project area. Most

importantly, it identifies potential fugitive dust sources.

Major Stationary Sources

There are 42 major stationary

sources of PM in the project area

(see Figure 7 and associated

table). These sources are gener-

ally industrial facilities, including

large facilities like the Marathon

Oil Refinery and Severstal Steel.

Currently, 29 percent of the land

in the project area is classified as

industrial activity, equivalent to ap-

proximately 20,600 acres. While industrial facilities in the area emit a varietyof chemicals, including known air toxics that result in the formation of sec-

ondary PM (sulfur dioxides and nitrogen oxides), they also emit a substantial

amount of primary PM. According to MDEQ, the major stationary facilities

who have obtained air pollution permits in the area contributed to at least

1,234,392 pounds of PM10

and 323,551 pounds of PM2.5

in 2004.2

National Regulations for Major Stationary Sources

The Clean Air Interstate Rule (CAIR) is a national level program that works to

significantly reduce sulfates and nitrates through the use of a cap-and-trade

pollution reduction approach. Adopted in 2004, CAIR requires states to make

major reductions in air pollution from all major stationary sources by 2015.The two options that a state has to comply with CAIR regulations are to re-

quire power plants to participate in an EPA administered interstate cap-and-

trade program, or to allow power plants to meet an individual state emis-

sions budget through measures of the states own design.3 According to the

EPA, CAIR will produce $85 to $100 billion in annual health benefits, prevent

17,000 premature deaths annually, reduce millions of lost work and school

days, and reduce tens of thousands of non-fatal heart attacks and hospital

Currently, 29 percent of

the land in the project area

is classified as industrial

activity, equivalent to ap-

proximately 20,600 acres.


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Figure 7: Point Source Map

Key for Point Source Map

Site # Source Site # Source

1 Comprehensive Environmental Solutions 22 Sunoco Inc

2 Darling International Inc 23 Marathon Ashland Petroleum

3 Dearborn Industrial Generation 24 US Gypsum Company

4 BP Products North America 25 BASF Corporation

5 DTE River Rouge Power Plant 26 Crown Plating Co

6 US Steel Great Lakes Works 27 Honeywell

7 Carmeuse/River Rouge 28 National Steel Corp

8 Detroit WWTP 29 Fritz Products

9 Ford Motor Co 30 Fabricon Products

10 Ford Motor River Rouge Complex 31 EDW C Levy DO Plant 6

11 Ford Elm St Boiler House 32 Detroit Salt

12 Ford Motor Company - R&E and Elm St PP 33 Detroit Electro-Coatings Company

13 Severstal 34 IPMC Aquisition LLC

14 DTE Delray Power Plant 35 EDW C Levy Plant 1

15 St Marys Cement 36 Reily Plating/Mlok Incorporated

16 Detroit Public Lighting - Mistersky Power 37 Kasle Steel Corp

17 Magni Industries 38 Ferrous Environmental Recycling Corp

18 Spartan Industrial 39 Coca Cola Bottling Co

19 Equilon Enterprises 40 Hispanic MFG/Gonzalez MFG

20 Owens Corning Trumbull Div 41 Carmeuse/Detroit Lime

21 Cadillac Asphalt Products 42 Daimler Chrysler - McGraw


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admissions by year 2015.4 According to MDEQs draft version of the State

Implementation Plan Submittal for Fine Particulate Matter (PM2.5), the imple-

mentation of CAIR will result in major reductions of sulfates and nitrates, two

of the most significant contributors to PM2.5

at monitors showing violations of

the standards throughout the nonattainment area.5

Local Regulations for Major Stationary Sources

The strategy in the State Implementation Plan Submittal for Fine Particulate

Matter (PM2.5) to bring the project area into attainment for PM

2.5includes local

controls for specific facilities. Three facilities, Severstal Steel, U.S. Steel, and

the Marathon Petroleum Company, will be required to undergo local controls

to reduce PM2.5

production. MDEQ chose these facilities because they emit

the highest levels of PM and because they are especially close to the air

quality monitors reporting levels that exceed NAAQS standards. Data from

MDEQs draft version of the State Implementation Plan Submittal for Fine

Particulate Matter (PM2.5) indicates that significant amounts of PM2.5 likely

come predominantly from local upwind industrial sources, and that control of

these sources, primarily the nearby steel mill (Severstal), will bring the area

into attainment of the annual PM2.5

standard by 2010.6

Consequently, Severstal Steel will be installing several baghouses, eliminat-

ing torch cutting on-site, reducing the opacity of emissions from scarfing

operations, and reducing the smoking of torpedo cars. Severstal will also

take the following actions to offset their PM2.5

emissions: retrofit local school

buses, retrofit diesel equipment on-site, and plant trees around their facility.

U.S. Steel has already replaced a baghouse that has decreased its PM2.5

emissions. Marathon Oil will add nitrogen oxide controls to their facilities, as

well an electrostatic precipitator to catch PM before it is emitted. Marathon

has also recently applied for a permit to build a new coking unit and as a re-

sult has agreed to several voluntary community benefits to help offset its PM

output. The community benefits include retrofitting school buses, enhancing

street sweeping on public roads near the plant, installing air monitors near

the facility, installing PM controls on the trucks that will transport the pro-

cessed coke, and purchasing PM10

off-sets from retired plants. The area will

also benefit from the retrofitting of 40 diesel switch engines.

Stationary Source Inventory

Table 4 on the following pages lists major facilities in the project area, the pri-

mary industrial activity they engage in, the amount of land they occupy, and

the amount of PM they reported emitted in 2004.


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Table 4:

Stationary Source Inventory

Name

Land Area

(acres) Activity

2002 Emissions (in tons)

NOX

SO2

PM10

VOC

BP Products North America -

River Rouge

29 Stores and loads BP gas 0 0 0 52

Cadillac Asphalt Products 14.6 Produces asphalt products fro highway con-

struction projects

7 0 1 10

Carmeuse/Detroit Lime 3.5 Produces stone, clay, lime, and glass products 556 47 29 0

Carmeuse/River Rouge 4.8 Serves as a delivery terminal for stone, clay,

lime and glass products

327 55 111 0

City of Detroit: Waste Water

Treatment Plant

125 Processes the waste-water for the entire

Metro-Detroit region, largest single-site waste-

water treatment facilities in the United States

276 42 52 52

Coca Cola Bottling Company 9.1 Markets, distributes, and produces bottled and

canned beverage products for The Coca-Cola

Company

2 0 0 0

Comprehensive Environmental

Solutions

19 Processes industrial waste oils, oil-contami-

nated waste, wastewater, waste sludge, and

other solid waste

0 0 0 0

Crown Plating Company 0.5 Plates and polishes electrical equipment 0 0 0 0

Daimler Chrysler - McGraw 38 "Cuts, shapes, and tempers glass since for

clear and tinted windshields,

side glass, backlights, and liftgates"

8 0 0 5

Darling International 9 Processes animal and food waste products

into useful commercial goods, including tallow,

protein meals, and yellow grease

19 17 5 12

Dearborn Industrial Genera-

tion

11 Generates 550 megawatts of power with

natural gas

484 78 870 5

Detroit Edision - River Rouge

Power Plant

101.9 Generates 527 megawatts of electr icity with

coal-burning

5143 38 1619 45

Detroit Edison - Delray Power

Plant

37.9 Generates 350 megawatts of power with coal-

burning, Detroits first power plant

17 0 0 1

Detroit Electro-Coatings Com-

pany LLC

23.1 Coats, packages, assembles, warehouses and

distributes electric equipment

1 0 0 6

Detroit Public Light - Mistersky

Power Station

18 Generates 160 megawatts of electricity with

coal-burning

208 11 2 4

Detroit Salt 26.8 Mines rock salt from under the city of Detroit

and distributes the product in bulk as road

deicing salt to governments and other entities

in Michigan

0 1 0 0

EDW C Levy DO Plant 1 26.8 Produces, quarries, and stores stone and

other aggregate materials

0 1 0 0

EDW C Levy DO Plant 6 10.3 Produces, quarries, and stores stone and

other aggregate materials