EPA-454/R-95-009
SURFACE COAL MINE
      STUDY PLAN
    Emission Factor And Inventory Group
  Emissions, Monitoring, And Analysis Division
  Office Of Air Quality Planning And Standards
    U. S. Environmental Protection Agency
     Research Triangle Park, NC 27711

            March 1992

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This report  has  been reviewed by  the  Office Of Air Quality  Planning  And  Standards, U. S.
Environmental Protection Agency, and has been approved for publication.  Any mention of trade
names or commercial products is not  intended to constitute endorsement or recommendation for use.
                                   EPA-454/R-95-009

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                              PREFACE

      This report was prepared by Midwest Research Institute under
U.S. Environmental Protection Agency (EPA) Contract No. 68-DO-0137, Work
Assignment Nos. 10 and 68.  The principal authors of this report are
Dr.  Gregory E. Muleski and Dr. Chatten Cowherd; they were assisted by
Mr. Robert Dobson and Ms. Karen Connery of MRI. Mr. Dennis Shipman and
Mr. Joe Touma of the Office of Air Quality Planning and Standards served as
the EPA's technical monitors of the work assignment.
                                                                    in

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                               CONTENTS
Preface	  H[
Figures	  vr
Tables	•	vil

      1.    Introduction	  1
      2.    Site Selection	  7
                  2.1  Screening activities	  7
                  2.2 Site  surveys	•	   1°
                  2.3 Final site selection	   11
      3.    Source Air Sampling Methodology	   13
                  3.1  General air sampling equipment
                        and techniques	   15
                  3.2 Testing procedures	   18
                  3.3 Emission factor calculation procedure  	   23
      4.    Ancillary Sample Collection and Analysis	   27
                  4.1  Source material  sample collection
                        and analysis	   28
                  4.2 Control application parameters	   36
                  4.3 Source activity monitoring	   38
                  4.4 Meteorological monitoring  	   39
                  4.5 Air quality monitoring	   4-2
       5.    References  	•	   49

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                           LIST OF FIGURES
Number                                                         Pa9e

   1        Sampling arrays U, D1, and D2	  16
   2        Cyclone preseparator	  17
   3        Two-dimensional sampling array	  T9
   4        Example surface sample data form for unpaved roads	  29
   5        Example data form for storage piles	  32
   6        Example moisture analysis form 	  34
   7        Example silt analysis form	  37
   8        Proposed sampling arrays at a stylized truck-shovel mine.
           Filled symbols represent primary sampling locations,
           hollow symbols represent saturation samples	  47
 VI

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                           LIST OF TABLES
Number                                                          Pa9e

   1        Summary of "representative" mine attributes	   8
   2        Emission sources recommended for evaluation	   14
   3        Quality assurance procedures for sampling media	   21
   4        Quality assurance procedures for sampling flow rates  ....   21
   5        Quality assurance procedures for sampling equipment  ....   22
   6        Criteria for suspending or terminating a test	22
   7        PM10 sampling options .	•	   45
                                                                    VII

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                              SECTION 1

                            INTRODUCTION
      At present, ambient paniculate matter (PM-10) impacts from surface
coal mining operations are assessed in the following ways:

      1.     The mine's operating plan is reviewed to identify major PM-10
            emission sources, such as blasting, overburden removal, haul
            trucks, etc.  The  plan is also reviewed to determine source
            activity rates—such as tons of coal mined or tons of overburden
            removed per year—over the effective life of the  mine.

      2.     An emission factor (mass emitted per unit source activity) is
            proposed for each major source. Factors are usually selected
            from Section 8.24 of AP-42.1

      3.     Values from items 1  and 2 above are combined  to estimate
            annual and worst-case-day PM-10 emission rates from the mine.

      4.     Dispersion models (such as the Industrial Source Complex [ISC]
  ,   '       model) are then used to simulate the atmospheric transport of
            the estimated emissions.  Resulting ambient air  concentration
            estimates are then compared against National Ambient Air
            Quality Standards (NAAQSs) or Prevention of Significant
            Deterioration (PSD) increments.

      The field study  described in this report addresses issues involving the
modeling process described above for surface coal mines.  Specifically, the
Clean Air Act Amendments (CAAA) require the Administrator to "analyze the
accuracy of. . . models and emission factors and make revisions as may be
necessary to eliminate any significant overprediction." The objectives of this
study are to:

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      I.     Improve available emission factors for surface coal mines.

      II.     Develop a comprehensive data base of source activity levels, on-
            site meteorological conditions, and air quality data.

      III.    Conduct a model evaluation study to assess how the current
            methodology predicts the ambient air quality impact from mines.

      In general terms, the study combines extensive long-term air quality,
source activity, and meteorological monitoring with intensive short-term,
source-directed testing to answer the following types of questions:

      •     Does the current methodology result in systematic overprediction
            of air concentrations?

      •     How well do ISC model results match measurements in time and
            space?

      No matter how sophisticated, long-term monitoring  of ambient "far-
field" concentrations alone cannot answer questions such  as the following:

      •     What portion or portions of the methodology  are most
            responsible for overprediction?

      •     Can the identified portions be modified so that systematic
            overprediction is effectively removed?

      •     What fraction of material emitted at the bottom  of the pit
            eventually escapes?

      To answer these types of questions, the long-term monitoring program
must be supplemented with the intensive short-term monitoring and pit
retention tracer programs that incorporate more  source-directed
measurements.  Quantitative examination of separate steps in the emission
factor/dispersion model methodology is necessary to answer the "how" and
"why" questions. Furthermore, the particulate tracer studies will provide a
quantitative basis for development of a pit retention algorithm.  This report
describes the field study plan designed to meet the above objectives.  The

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plan details the sampling methodology, data analysis, and quality assurance
(QA) procedures to be followed.

      The principal pollutant of interest in this report is "particulate matter"
(PM), with special emphasis placed on "PM-10"—particulate matter no greater
than 10 jc/mA (microns in aerodynamic diameter). PM-10 is the basis for the
current NAAQSs and thus represents the size range of the greatest regulatory
interest.  Nevertheless, formal establishment of PM-10 as the standard basis
is relatively recent, and almost all historical surface coal mine field
measurements reflect a particulate size other than PM-10.  Of these, the most
important is "TSP," or Total Suspended Particulate, as measured by the
standard high-volume (hi-vol)  air sampler. TSP is a relatively coarse size
fraction and was the basis for the previous NAAQSs and PSD increments.
While the capture characteristics of the hi-vol sampler are dependent upon
approach wind velocity, the effective D50 (i.e., 50% of the particles are
captured and 50% are not) varies roughly from 25 to 50 jumA.  To maintain
comparability and compatibility, some field measurements will be referenced
to TSP.

      The field sampling program consists of extensive long-term air quality
and meteorological monitoring combined with intensive, short-term source
testing.  In addition, pit retention will be studied  under a separate set of
experiments.  To avoid confusion about what is meant by terms such as
"ambient air" and "near-source," the following defines terms that are used
throughout this document.

     • "Source tests" refer to air quality/meteorological measurements made
in the immediate vicinity of an individual emission source (such as a road  or
material transfer operation) with the intention of characterizing that source.
Most of these measurements are required for "exposure profiling," which
relies on simultaneous multipoint concentration and  wind speed
measurements over the effective cross section of the dust plume to determine
source strength and thus  meet Objective I.

       "Near-field air monitoring"  refers to measurements made further away
than source tests, but still within the vicinity of an individual source.  A major
 difference is that near-field measurements do not normally span the plume
 cross section.  Rather, these measurements at a height of 1 to 2 m are

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usually made for comparison with ISC or other model-generated concentration
estimates.  Unless otherwise specified, near-field measurements will be made
within the pit.

      "Far-field air monitoring" will refer to measurements made at a
considerable downwind distance from the nearest emission source. As such,
these measurements focus on characterizing the air quality impact of the mine
as a whole rather than on any individual source or source category. Unless
specifically stated otherwise, far-field measurements will be made  beyond the
rim of the pit (i.e., at surrounding grade). In  this document, "ambient" and
"far-field" are equivalent terms.  These are the measurements that can be
compared against dispersion model predictions in an overall evaluation of the
current methodology (Objective III).

      The remainder of this report is structured as follows:  Section 2
describes how candidate test sites will be evaluated and how final sites will
be selected.  Section 3 describes the field emissions testing procedures to be
used to develop improved emission factors.  Section 4,  on the other hand,
describes the collection and analysis of other types  of samples—such  as
source activity, meteorology, and air quality—that are necessary to reach
objectives of this program. The proposed schedule  is provided in Section 5
and references are listed in Section 6.

      The sampling and analysis procedures  to be followed in this  field
testing program are subject to certain  quality assurance/quality control
(QA/QC)  guidelines.  These guidelines are discussed in conjunction with the
activities to which they apply.  These  procedures meet or exceed the
requirements specified in  the reports entitled "Quality Assurance Handbook
for Air Pollution Measurement Systems, Volume II —Ambient Air Specific
Methods" (EPA 600/4-77-027a)  and "Ambient Monitoring Guidelines for
Prevention of Significant Deterioration" (EPA 450/2-78-019).

      As part of the QC program for this study, routine audits of sampling
and analysis procedures will be performed. The purpose of the audits is to
demonstrate that measurements are made within acceptable control
conditions for paniculate  source sampling and to assess the source testing
data for precision and accuracy.  Examples of items to be audited include
gravimetric analysis, flow  rate calibration, data processing, and emission

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factor calculation.  The mandatory use of specially designed reporting forms
for sampling and analysis of data obtained in the field and laboratory aids in
the auditing procedure.  Further details on specific sampling and analysis
procedures are provided in the following sections.

      The field program represents an excellent opportunity for cooperative
agreements between agency and coal companies/trade groups.  A variety of
participation levels are available.

      •     At a minimum, industry will be asked to provide historical source
            activity data, such as production rates and maintenance records
            for mine  equipment. This information can be treated as "CBI" —
            confidential business information.

      •     Mines may also be asked to supply historical ambient air quality
            monitoring and meteorological data.

      •     With agreement from state and regional offices, minor
            modifications to some mine air quality or meteorological
            equipment operations may be useful to the study. This could
            range from requesting changes in practices (such as different
            sampling periods) to the relocation or even loaning of .equipment
            for use at another mine during the long-term monitoring program.

      •     For mines selected  that agree to act as test sites, higher levels of
            cooperation are possible, ranging from arranging for electrical
            power drops and for field laboratory space to providing
            technician  help who,  under direct supervision by the contractors,
            would assist in field team support.

 Coal company and trade group participation is discussed further in the next
 section.

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                               SECTION 2

                            SITE SELECTION
      Table 1 presents a list of surface coal mine test sites, all of which are
in the Powder River Basin.  At the time of this writing, a meeting has been
scheduled between mine and trade association representatives, EPA and
Wyoming Department of Environmental Quality (DEQ) personnel, and MRI.
The meeting will occur on March 5, 1992, in Gillette, Wyoming. As noted in
Table 1, six mines are currently interested in being considered as potential
test sites and will attend the March 5 meeting to learn more about the study.
2.1  SCREENING ACTIVITIES
                         •-.
      The contact person for each candidate mine will participate in one or
two telephone calls during which he/she will be asked to

      •     Provide an overview of mining operations (truck-shovel versus
            dragline, year in mine  plan, etc.) and equipment used at the
            mine.

      •     Discuss current and anticipated levels of overburden, topsoil, and
            coal-related activities.

      •     Discuss past and current dust control programs at the  mine.

      •     Provide a plot plan for the mine, showing current areas being
            worked and areas planned to  be worked in the future,
            topography of the mine and surrounding area, locations of any air
            quality (AQ) and meteorological ("met") monitors.

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      •     Describe and, if requested, supply historical emission inventory,
            source activity, dispersion modeling analyses, etc. (This woufcf
            probably take the form of response to a questionnaire.)

      Mine sites will be selected by comparing each candidate mine's
attributes against predetermined criteria of desired location, available data,
site configuration, etc. The criteria given below represent guidelines rather
than "hard and fast" rules. The process of site selection requires many
qualitative and subjective decisions.  Candidate mines will be judged on the
following criteria:

      •     General Location.  Although mines with existing PSD monitoring
            networks provide ready candidates, most PSD networks are not
            necessarily sited to provide the data  needed in this study.
            Furthermore, mines that are relatively isolated from other mines
            would be preferred.  While it may not be possible to find
            completely isolated mines, those located away from neighboring
            mines would be preferred over those in proximity to other mines.
            Finally, the site should be isolated from terrain features
            influencing local airflows.  That  is, the terrain immediately
            surrounding the  mine should  be  fairly flat.

      •     Mine Activity.  Quantification of the mining activity  (traffic
            volumes, amount of coal removed, amount of overburden
            disturbed, etc.) is  needed for the mine model validation effort.
            Candidate mines will  be judged  on the availability of historical
            data and on the ease with which these data could be collected
            during any field  study.

      •     Logistics. There is a need to locate  instruments  near
            dust-producing activities, at locations up and downwind of the
            mine, and at the top  of the mine pit highwall. The  candidate
            mines will be evaluated  on the basis of being able to
            accommodate the wide variety of sampling locations necessary.

      •     Representativeness.  Preference will be given to  mines that are
            neither at the start nor  near the end of operation according to the

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            mine plan.  Furthermore, geographic diversity of the test sites is
            a desired goal.

      Preliminary visits to the mine provide useful overview for the above
items.
2.2 SITE SURVEYS

      The site survey is expected to require a 1 - or 2-day visit by two MRI
representatives. At the start of the survey, the mine will provide a short
orientation describing operations. At the mine's discretion, the orientation
can include safety,  liability insurance, or other issues.  MRI will agree to
requirements made  by the mine, such as obeying all posted notices; using
eye, hearing, and other protective equipment; and personnel and vehicle
passes. Also at this meeting, MRI will describe the general sequence of
events anticipated for the testing and will reaffirm its intention to cause
minimal disruption to mine operations.

      The remainder of the survey is to be spent visiting and characterizing
potential emission test and monitoring sites in terms of orientation with
respect to prevailing wind direction and pit axis, distance to highwall,
observed level of activity, access to electrical power, proximity to other
emission sources, etc.

      For example, near-source measurements of traffic source generally
require long stretches of roads that are approximately perpendicular to the
prevailing wind. In  addition,  sources should be relatively isolated from other
important PM-10 emission sources within the mine. The following is  a list of
example criteria to be applied to a site for roadway  source testing.

      1.    There should be at least 10 m of flat, open terrain downwind of
            road.

      2.    There should be at least 30 m of flat, open terrain upwind of
            road.
10

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     3.    The height of nearest downwind obstruction should be less than
           the distance from the road to the obstruction.

     4.    The height of nearest upwind obstruction should be less than
           one-third the distance from the road to the obstruction.

     5.    A line drawn perpendicular to the road orientation should form an
           angle of 0° to 45° with the mean daytime prevailing wind
           direction.

     6.    The mean daytime wind speed should be greater than 4 mph.

     7.    The test road should have an adequate number of vehicle passes
           per hour enabling completion of a test in no  more than 3 h.

     8.    The traffic mix should be  representative of the type of vehicles
           that regularly use  the road.

     Analogous criteria have been established for nonroad sources, such as
material handling operations. These include isolation from other important
sources and wind obstructions, accessibility to the emission source, and
orientation of the  source to prevailing  winds.
2.3  FINAL SITE SELECTION

     ' As a result of site visits, it is expected that one or more mines will be
found to be suitable. Those mines will be reevaluated along the selection
criteria lines given above, and a final site will be selected.
                                                                      11

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                               SECTION 3

                 SOURCE AIR SAMPLING METHODOLOGY
      This section describes the procedures to be followed during the
emission source testing portion of the study. A review of emission factors
applicable to surface coal mines has been recently completed.3  This review
also presented recommendations for future source testing, which are
summarized in Table 2.  The proposed source testing program focuses on the
following major sources:

      •     Coal  and overburden
      •     Haul  roads
      •     General traffic (light- and medium-duty)
      •     Overburden material handling operations
      •     Coal  material handling operations

These sources typically account for 70%  or more of particulate emissions  at
surface coal mines.4 Similar findings were reported in a recent study of
Wyoming mines.5

     " The source-directed field sampling will employ the "exposure profiling"
concept to quantify source emission contributions and near-field
concentrations.

      As Table 2  indicates, there are two source types of interest here—
"point" sources (i.e., the material handling operations) and "line" sources (i.e.,
the roadway 'sources).  The differences between testing the two types are
described below.
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       Table 2. EMISSION SOURCES RECOMMENDED FOR EVALUATION

Line sources (travel-related) to be considered15
1 . Haul trucks
2. General mine traffic
3. Haul trucks (overburden)
"Grouped" approach to material handling emissions0
1 . Overburden removal and placement in trucksd
2. Overburden replacement by draglined
3. Misc. overburden handling operations'1
4. Misc. coal handling operations6
Recommended
number of
tests per
mine8

3-6U, 6-1 2C
3-6U, .6-1 2C
3-6U, 6-1 2C

3-6
3-6
3-6
3-6
Overall
priority

1
3
2

4T
4T
4T
8f
 Notes:
    U = uncontrolled, C = controlled.  Uncontrolled if not indicated.
    Depending on the road network at the mine, it may not be possible to
    separate various travel-related emissions.  In that case, because of the
    importance of travel-related emissions, additional roads or other line sources
    (such as scraper travel [see note f below] or road grading) will be tested.
    These tests are expected to be of uncontrolled emissions.
    Emission factor development will group operations with like materials
    • regardless of the equipment involved. This approach is expected to be
    particularly beneficial for overburden-related emissions from draglines, power
    shovels, truck dumps, etc.  It is further expected that test results will be
    combined with the generic materials handling emission factor data  base.
    Dependent upon the type of mine operation (i.e., dragline or shovel/truck).
    Including truck dumps, loadout for transit, etc.  Again, emission factor
    development will group across operations with the same material.
    Scrapers in travel mode rated as 7th overall priority.        	
14

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3.1 GENERAL AIR SAMPLING EQUIPMENT AND TECHNIQUES

      The "exposure profiling" technique for source testing of open
particulate matter sources is based on the isokinetic profiling concept that is
used in conventional (stack) testing.  The passage of airborne pollutant
immediately downwind of the source is measured directly by means of
simultaneous multipoint sampling over the cross section of the open dust
source plume.  This technique uses a mass flux measurement scheme similar
to EPA Method 5 stack testing rather than requiring indirect emission rate
calculation through the application of generalized atmospheric dispersion
model.

      For measurement of particulate emissions from roads, a vertical
network of samplers (Figure 1) is positioned just downwind and upwind from
the edge of the road.  (For point sources, a two-dimensional array is needed.)
The downwind distance of 5 m is far enough that interference with sampling
due to traffic-generated turbulence is minimal but close enough to the source
that the vertical plume extent can be adequately  characterized with a
maximum sampling height of 5 to 7 m. In a similar manner, the 15-m
distance upwind from the road's edge is far enough from the source that (a)
source turbulence does not affect sampling, and (b) a brief wind reversal
would not substantially impact the upwind samplers.  The 15-m distance is,
however, close enough to the road to provide the representative background
concentration values needed to determine the net (i.e., due to the source)
mass  flux.  As shown in  Figure 1, the deployment scheme is expected to use
two independent downwind vertical sampling arrays, D1 and D2.  Both
downwind arrays (as well as the upwind array  U) make use of high-volume
(hi-vol) air samplers with electronic flow controllers.

      The primary air sampling device in this program will be a standard
high-volume air sampler fitted with a cyclone preseparator (Figure 2).  The
cyclone exhibits an effective 50% cutoff  diameter (D50) of approximately
10 ji/mA when operated at a flow rate of 40 cfm  (68 m3/h).

      Samplers in the upwind and one of the two downwind arrays are fitted
with the cyclone preseparator to sample PM-10 emissions. During half the
test periods, samplers in the other downwind array will be fitted with  cyclone
preseparators; during the other test periods, standard hi-vol roofs will  be used
to sample TSP emissions. In this way, one TSP test will be conducted for
every

                                                                     15

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                                                         Back-up Fitter
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                Figure 2. Cyclone preseparator.
                                                                     17

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three PM-10 tests. TSP measurements provide a useful link to past surface
coal mine emission factor studies.

      For the material handling-related "point"  sources of PM emission, a
two-dimensional sampling array (Figure 3) is required. The cyclone
preseparator will serve as the primary air sampling device in this array as well.
Note that sampling locations employ colocated cyclone and standard hi-vol
samplers. In this way, a TSP emission factor can be estimated from the
measurement-based PM-10 factor.

      Throughout each test, wind speed will be monitored by warm-wire
anemometers (Kurz Model 465) at two heights and the vertical wind speed
profile determined by assuming a logarithmic distribution. An integrating
Biram's vane anemometer, wind odometer, or an equivalent system, will serve
as a backup.  Horizontal wind direction will be  monitored by a wind vane at a
single height, with 5- to 15-min averages determined electronically prior to
and during the test. The sampling intakes will  be adjusted for proper
directional orientation based on the monitored average wind direction.

      Additional meteorological equipment may be deployed as part of an air
quality monitoring program.  Details are provided in Section 4.
3.2  TESTING PROCEDURES

3.2.1  Preparation of Sample  Collection Media

    * Particulate samples will be collected on Type AE grade glass fiber
filters.  Prior to the initial weighing, the filters will be equilibrated for 24 h at
constant temperature and humidity in a special weighing room.  During
weighing, the balance is to be checked at frequent intervals with standard
(Class S) weights to ensure accuracy. The filters will remain in the same
controlled environment for another 24 h,  after which a second analyst will
reweigh them as a precision check. If a filter cannot pass audit limits, the
entire lot is to be reweighed.  Ten percent of the filters taken to the field will
be used as blanks.  The quality
 18

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                                                                                      19

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assurance guidelines pertaining to preparation of sample collection media are
presented in Table 3.
3.2.2 Pretest Procedures/Evaluation of Sampling Conditions

      Prior to equipment deployment, a number of decisions will be made as
to the potential for acceptable source testing conditions.  These decisions
shall be based on forecast information obtained from the local U.S. Weather
Service office.  If conditions are considered acceptable, the sampling
equipment deployment will be initiated.  At this time the sampling flow rates
will be set for the various air sampling instruments.  The quality control
guidelines governing this activity are found in Table  4.

      Once the source testing equipment is set up and the filters inserted, air
sampling will commence.  Information is recorded on specially designed
reporting forms and includes:

      a.    Air samples—Start/stop times, wind speed profiles, flow rates,
            and  wind direction relative to the roadway perpendicular (5- to
            15-min  average). See Table 5 for QA procedures.

      b.    Traffic count by vehicle type  and speed.

      c.    General meteorology—Wind speed, wind direction, and
            temperature.

      Sampling time will be long enough to provide sufficient particulate
mass and to  average over several cycles of the fluctuation in the emission
rate (i.e., vehicle passes on the road). Occasionally sampling may be
interrupted because  of the occurrence of unacceptable meteorological
conditions and then  restarted when suitable conditions return.  Table 6
presents the criteria used for suspending or terminating a source test.
 20

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Table 3. QUALITY ASSURANCE PROCEDURES FOR SAMPLING MEDIA
Activity
Preparation
Conditioning
Weighing
Auditing of weights
Correction for handling
effects
Calibration of balance
QA check/requirement
Inspect and imprint glass fiber media with
identification numbers.
Equilibrate media for 24 h in clean
controlled room with relative humidity of
less than 50% (variation of less than
±5%) and with temperature between 20°
and 25°C (variation of less than ±3%).
Weigh hi-vol filters to nearest 0.1 mg.
Independently verify final weights of 10%
of filters (at least four from each batch).
Reweigh batch if weights of any hi-vol
filters deviate by more than ±2.0 mg. For
tare weights, conduct a 1 00% audit.
Reweigh tare weight of any filters that
deviate by more than ± 1 .0 mg.
Weigh and handle at least one blank for
each 1 to 1 0 filters of each type for each
test.
Balance to be calibrated once per year by
certified manufacturer's representative.
Check prior to each use with laboratory
Class S weights.
       Table 4.  QUALITY ASSURANCE PROCEDURES FOR
                  SAMPLING FLOW RATES
Activity
• High volume air samplers
• Orifice and electronic calibrator
QA check/requirement
Calibrate flows in operating ranges
using calibration orifice upon arrival
and every 2 weeks thereafter at
each regional site prior to testing.
Calibrate against displaced volume
test meter annually.
                                                        21

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          Table 5.  QUALITY ASSURANCE PROCEDURES FOR
                       SAMPLING EQUIPMENT
Activity
Maintenance
• All samplers
Operation
• Timing
• Isokinetic sampling
(cyclones)
• Prevention of static
mode deposition
QA check/requirement8
Check motors, gaskets, timers, and flow
measuring devices at each plant prior to
testing.
Start and stop all downwind samplers during
time span not exceeding 1 min.
Adjust sampling intake orientation whenever
mean wind direction dictates.
Change the cyclone intake nozzle whenever the
mean wind speed approaching the sampler falls
outside of the suggested bounds for that
nozzle. This technique allocates no nozzle for
wind speeds ranging from 0 to 10 mph, and
unique nozzles for four wind speed ranges
above 10 mph.
Cap sampler inlets prior to and immediately
after sampling.
0 All means refer to 5- to 1 5-min averages.
     Table 6.  CRITERIA FOR SUSPENDING OR TERMINATING A TEST
 A test may be suspended or terminated if:a

 1.  Rainfall ensues during equipment setup or when sampling is in
    progress.

 2.  Mean wind speed during sampling moves outside the 1.3- to 8.9-m/s
    (2-  to 20-mph) acceptable range for more than 20% of the sampling
    time.

 3.  The angle between mean wind direction and the perpendicular to the
    path of the moving point source during sampling exceeds 45 degrees
    for two consecutive averaging periods.

 4.  Daylight is insufficient for safe equipment operation.

 5. Source condition deviates from predetermined criteria (e.g., occurrence
    of truck spill or accidental water splashing prior to uncontrolled testing).
   "Mean" denotes a 5- to 15-min average.
22

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3.2.3 Sample Handling and Analysis

      To prevent particulate losses, the exposed media will be carefully
transferred at the end of each run to protective containers for transportation. In
the field laboratory, exposed filters will be placed in individual glassine envelopes
and then into numbered file folders. When exposed filters and the associated
blanks are  returned to the MRI laboratory, they will be equilibrated under the
same conditions as the initial weighing. After reweighing, 10% will be audited to
check weighing accuracy.
3.3 EMISSION FACTOR CALCULATION PROCEDURE

      To calculate emission rates, a conservation of mass approach is used.
The passage of airborne particulate (i.e., the quantity of emissions per unit of
source activity) is obtained by spatial integration of distributed measurements of
exposure (mass/area) over the effective cross section of the plume.  Exposure is
the point value of the flux (mass/area-time) of airborne particulate integrated over
the time of measurement, or equivalently, the net particulate mass passing
through a  unit area normal to the mean wind  direction during the test. The steps
in the calculation procedure are described below.
3.3.1. Particulate Concentrations

      The concentration of particulate matter measured by a sampler is given
by:
                                        Qt
where:   C  =   particulate concentration (u.g/m3)
         m  =   particulate sample weight (mg)
         Q  =   sampler flow rate (m3/min)
         t   =   duration of sampling (min)
                                                                        23

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      To be consistent with the National Ambient Air Quality Standards, all
concentrations and flow rates are expressed in standard conditions (25°C and
101 kPa or 77°F and 29.92 inHg).

      The isokinetic flow ratio (IFR) is the ratio of a directional sampler's intake
air speed to the mean wind speed approaching the sampler. It is given by:
                                       aU
where:   Q  =   sampler flow rate (m3/min)
         a  =   intake area of sampler (m2)
         U  =   mean wind speed at height of sampler (m/min)

      This ratio is of interest in the sampling of total particulate, since isokinetic
sampling ensures that particles  of all sizes are sampled without bias. Note,
however, that because the primary interest in this program is directed to PM10
emissions, sampling under moderately nonisokinetic conditions poses no dif-
ficulty. It is readily agreed that  10 u.m (aerodynamic diameter) and smaller
particles have weak inertial characteristics at normal wind speeds and therefore
are relatively unaffected by anisokinesis.6

     • Exposure represents the net passage of mass through a unit area normal
to the direction  of plume transport (wind direction) and is calculated by:


                               E = 10-7 x CUt
where:   E   =  particulate exposure (mg/cm2)
         C   =  net concentration (u.g/m3)
         U   =  approaching wind speed (m/s)
         t   =  duration of sampling (s)
24

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      Exposure values vary over the spatial extent of the plume.  If exposure is
integrated over the plume effective cross section, then the quantity obtained
represents the total passage of airborne paniculate matter due to the source.

      For a line source, a one-dimensional integration is used:


                              A1 =  [" Edh
                                   Jo
where:   A1 =  integrated exposure (m-mg/cm2)
         E  =  paniculate exposure (mg/cm2)
         h  =  vertical distance coordinate (m)
         H  =  effective extent of plume above ground (m)

      For point sources, a two-dimensional integration is used:
                                  JV
                                      H Edhdy
where the quantities are the same as before and

where:   A2 =  integrated mass (m2-mg/cm2)
         W  =  effective plume width (m)
         y  =  horizontal crosswind coordinate (m)
                                                                        25

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3.3.2 Particulate Emission Factors

      The emission factor for participate generated by vehicular traffic on a
straight road segment expressed in grams of emissions per vehicle-kilometer
traveled (VKT) is given by:
where:   e  =   participate emission factor (g/VKT)
         A1 =   integrated exposure (m-mg/cm2)
         N  =   number of vehicle passes (dimensionless)

      For a point source, the emission factor is found as
where:   e  =   particulate emission factor (g/Mg)
         A2 =   integrated mass (m2-mg/cm2)
         T  =   mass of material handled (Mg)
26

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                               SECTION 4

           ANCILLARY SAMPLE COLLECTION AND ANALYSIS


      This section describes the collection and analysis of samples taken to
complement the air samples described in the last section. These samples
provide information essential to achieving the first two objectives stated in the
Introduction.

      •      Improve available emission factors.

      •      Develop a comprehensive data base of source activity levels,
            on-site meteorology, and air quality data.

      The types of samples and information to be collected fall into the broad
categories of:

      •      Roadway surface on aggregate material samples.

      •      Control application parameters.

      •      Source activity levels.

      •      Site-specific meteorology.

      •      Air quality monitoring data.

Each category is described in greater detail below.
                                                                       27

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4.1 SOURCE MATERIAL SAMPLE COLLECTION AND ANALYSIS

      In conjunction with the emissions tests, samples will be taken from the in-
place source material either covering the road surface or being handled as bulk
aggregate (coal, overburden, etc.).  These types of samples are needed not only
to evaluate the  performance of existing emission factor models but also to
develop improved models.

      The following describes the procedures used to collect unpaved road
samples.

      1.    Ensure that the site offers an unobstructed view of traffic and that
            sampling personnel are visible to drivers.  If the road is heavily
            traveled, use one person to "spot" and route traffic safely around
            another person collecting the surface sample (increment).

      2.    Using string or other suitable markers, mark a 0.3-m (1-ft) width
            across the road.  (WARNING:  Do not mark the collection area with
            a  chalk line or in anv other method likely to introduce fine material
            into the sample.)

      3.    With  a whisk broom and dustpan, remove the loose surface
            material from the hard road base. Do not abrade the base during
            sweeping.  Sweeping should be performed slowly so that fine
            surface material is not injected into the air. NOTE:  Collect material
            only from the portion of the road over which the wheels  and
            carriages routinely travel (i.e., not from berms or any "mounds"
            along the road centerline).

      4.     Periodically deposit the swept material into a clean, labeled
             container of suitable size (such as a metal or plastic 19-L [5-gal]
             bucket) with a sealable polyethylene  liner.  Increments may be
             mixed within this  container.

      5.     Record the required information on the sample collection sheet
             (Figure 4).
 28

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  Date Collected
 SAMPLING DATA FOR DHPAVED ROADS

	               Recorded by
  Road material (e.g.,  gravel,  slag,  dirt, etc.):*
  Site of sampling:

  METHOD:

    1. Sampling device:  whisk broom and  dustpan
    2. Sampling depth: loose  surface  material  (do  not abrade road
       base)
    3. Sample container:  bucket with sealable liner
    4. Gross sample specifications:

       a. Uncontrolled surfaces — 5 kg  (10 Ib) to 23 kg (50 Ib)
       b. Controlled surfaces  —  minimum of 400 g (1 Ib) is required
       for analysis

  Refer  to  procedure  described in Section  2  of "Open Source PM-10
  Method Evaluation" for more detailed instructions.
  Indicate any deviations from the above:
  SAMPLING DATA COLLECTED:
Sample
NO.







Time







Location +







Surf.
Area







Depth







Mass of
Sample







     * Indicate and give details if roads are controlled.
     + Use   code   given  on   plant  or  road   map  for
       identification.  Indicate sampling location on map.
                                         segment
Figure 4.  Example surface sample data form for unpaved roads.
                                                                       29

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For aggregate materials, the following steps are used to collect a sample.

      1.     Sketch plan and elevation views of the pile. Indicate if any portion
            is inaccessible.  Use the sketch to plan where the N increments will
            be taken by dividing the perimeter into N-1 roughly equivalent
            segments.

            a.    For a large pile, collect a minimum of 10 increments as near
                  to the mid-height of the pile as practical.

            b.    For a small pile, a sample should consist of a minimum of
                  6  increments evenly distributed among the top, middle, and
                  bottom.

            "Small"  or "large" piles, for practical purposes, may be defined as
            those piles which can or cannot, respectively, be scaled by a
            person carrying a shovel and pail.

      2.    Collect material with a straight-point shovel or a small garden
            spade, and store the increments in a clean, labeled container of
            suitable  size (such as a metal or plastic 19-L [5-gal] bucket) with a
            sealable polyethylene liner. Depending upon the ultimate goals of
            the sampling program, choose one of the following  procedures:

            a.    To characterize emissions  from material handling operations
                   at an active pile, take increments from the portions of the pile
                  which most recently had material added and removed.
                   Collect the material  with a  shovel to a depth of 10 to 15 cm
                   (4 to 6  in).  Do not deliberately avoid larger pieces of
                   aggregate present on the surface.

             b.     To characterize handling emissions from an inactive pile.
                   obtain increments of the core material from a 1-m (3-ft) depth
                   in the pile.  A 2-m (6-ft) long sampling tube with a diameter
                   at least 10 times the diameter of the largest  particle being
                   sampled is recommended for these samples. Note that, for
30

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                  piles containing large particles, the diameter recommendation
                  may be impractical.

            c.    If characterization of wind erosion (rather than material
                  handling) is the goal of the sampling program, collect the
                  increments by skimming the surface in an upwards direction.
                  The depth of the sample should be 2.5 cm (1 in) or the
                  diameter of the largest particle, whichever is less.  Do not
                  deliberately avoid collecting larger pieces of aggregate
                  present on the surface.

            In most instances, collection method (a) should be selected.

      3.    Record the required information on the sample collection sheet
            (Figure 5). Note the space for deviations from the summarized
            method.

      For any of the procedures, the sample mass collected should be at least
5 kg (10 Ib). When most materials are sampled with procedures 2.a or 2.b,
10 increments normally result in a sample of at least 23 kg (50 Ib). Note that
storage pile samples usually require splitting to a size more amenable to
laboratory analysis.

     . Regardless of origin, material samples undergo the same types of
laboratory analyses.  Upon return to MRI's main laboratories, samples undergo
moisture and silt content determination. Moisture content is determined by
weight loss upon oven drying.  Silt content refers to the fraction of material
smaller than 200 mesh, as determined by mechanical, dry sieving.  The following
steps describe the moisture content determination procedure:

      1.    Preheat the oven to approximately 110°C (230°F). Record oven
            temperature.

      2.    Record the make, capacity, and smallest division of the scale.
                                                                        31

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      Date Collected
                       SAMPLING DATA POR STORAGE PILES
Recorded by
      Type of material sampled 	:	

      Sampling location*	

      METHOD:

         1. Sampling  device:  pointed  shovel  (hollow  sampling tube  if
           inactive pile  is to be sampled)
         2. Sampling depth:
           For material handling of active piles: 10-15 cm (4-6 in)
           For material handling of inactive piles: 1m (3 ft)
           For  wind erosion  samples:  2.5  cm  (1 in)  or  depth  of the
           largest particle  (whichever is less)
         3. Sample container:  bucket with a sealable liner
         4. Gross sample specifications:
           For material handling of active or inactive piles: minimum of
           6  increments with total sample  weight of 5 kg  (10  Ib) [10
           increments totalling 23 kg  (50 Ib)  are recommended]
           For wind erosion samples: Minimum of  6 increments with total
           sample weight  of 5 kg  (10 Ib)

      Refer  to  procedure described in Section 4 of "Open Source PM-10
      Method Evaluation"  for more detailed  instructions.
       Indicate any deviations from the above:
       SAMPLING DATA COLLECTED:
Sample
No.






Time






Location* of
Sample Collection






Device
Used
S/T **






Depth






Mass
of Sample






         *  Use  code  given  on  plant  or  area  map  for  pile/sample
            identification.  Indicate each sampling location on .map.
               Figure 5. Example data form for storage piles.
32

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3.    Weigh the empty laboratory sample containers which will be placed
      in the oven to determine their tare weight. Weigh containers with
      the lids on if they have lids.  Record the tare weight(s). Check zero
      before each weighing.

4.    Weigh the laboratory sample(s) in the container(s).  For materials
      with high moisture content, ensure that any standing moisture is
      included in the laboratory sample container.  Record the combined
      weight(s). Check zero before each weighing.

5.    Place sample in oven and dry overnight.  Materials composed of
      hydrated minerals or organic material like coal and certain soils
      should be dried for only 114 h.

6.    Remove sample container from oven and (a) weigh immediately if
      uncovered, being careful of the hot container; or (b) place the
      tight-fitting lid on the container and let cool before weighing.
      Record the combined sample and container weight(s). Check zero
      reading on the balance before weighing.

7.    Calculate the moisture as the initial weight of the sample and
      container minus the oven-dried weight of the sample and container
      divided by the initial weight of the sample alone. Record the value.

8.    Calculate the sample weight to be used in the silt analysis as the
      oven-dried weight of the sample and container minus the weight of
      the container.  Record the value.  (See Figure 6.)

The oven-dried sample then undergoes silt analysis:

1.    Select the appropriate 20-cm (8-in) diameter, 5-cm (2-in) deep
      sieve sizes.  Recommended U.S. Standard Series sizes are 3/8 in,
      No. 4, No. 40, No.  100, No. 140, No. 200, and a pan.  Comparable
      Tyler Series sizes can also be utilized. The No. 20 and the
      No. 200 are mandatory. The others can  be varied if the
      recommended sieves are not available or if buildup on one
                                                                  33

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                           MOISTURE ANALYSIS
Date:	                 By:
Sample No:  	    Oven Temperature:  	
Material:	    Date In	__ Date Out
                                     Time  In     '	Time Out,
Split Sample Balance:                  Drying Time	
  Make
  Capacity	    Sample Weight (after drying)
  Smallest Division	    Pan + Sample:	
                                     Pan:    '  	
Total Sample Weight:	    Dry Sample:
(Excl. Container)
Number of Splits:	    MOISTURE CONTENT:
                                       (A) Wet Sample Wt
Split Sample Weight (before drying)         (B) Dry Sample Wt
Pan + Sample:   '	      (C) Difference Wt
                      Figure 6. Example moisture analysis form.
       34

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      participate sieve during sieving indicates that an intermediate sieve
      should be inserted.

2.    Obtain a mechanical sieving device such as vibratory shaker or a
      Roto-Tap without the tapping function.

3.    Clean the sieves with compressed air and/or a soft brush. Material
      lodged in the sieve openings or adhering to the sides of the  sieve
      should be removed  (if possible) without handling the screen
      roughly.

4.    Obtain a scale (capacity of at least 1,600 g or 3.5  Ib) and record
      make,  capacity,  smallest division, date of last calibration, and
      accuracy.

5.    Weigh the sieves and pan to determine tare weights. Check the
      zero before every weighing.  Record  weights.

6.    After nesting the sieves in decreasing order with pan at the bottom,
      dump dried laboratory sample (preferably immediately after
      moisture analysis) into the top sieve.  The sample should weigh
      between ~ 400 and 1,600 g  (0.9 to 3.5 Ib). This amount will vary
      for finely textured materials;  100 to 300 g may be  sufficient with
      90% of the sample passing a No. 8 (2.36 mm) sieve. Brush fine
      material  adhering to the sides of the  container into the top sieve,
      and cover the top sieve with a special lid normally purchased with
      the pan.

7.    Place nested sieves into the mechanical sieving device and sieve
      for 10  min.  Remove pan containing minus No. 200 and weigh.
      Repeat the sieving in 10-min intervals until the difference between
      two successive pan sample  weighings (where the tare weight of the
      pan has been subtracted) is less than 3.0%. Do not sieve longer
      than 40 min.
                                                                   35

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      8.    Weigh each sieve and its contents and record the weight.  Check
            the zero reading on the balance before every weighing.

      9.    Collect the laboratory sample and place the sample in a separate
            container if further analysis is expected.

      10.   Calculate the percent of mass less than the 200 mesh screen
            (75 u.m). This is the silt content. See Figure 7.
4.2 CONTROL APPLICATION PARAMETERS

      It is expected that the test mine will have an unpaved road dust control
program in place. Example programs include wet suppression by water truck or
"rainbird" system, or chemical treatment from periodic applications of petroleum
resins, acrylics, asphalt emulsions, or other commercially available products.  It is
important that any emission test conducted of a controlled road (or of a
controlled material-handling operation, for that matter) be associated with an
adequate description of the control measure.

      For unpaved roads treated chemically, this would include a history of
control applications, with "intensity" (as measured by the volume of solution
applied per unit area of road surface), the dilution ratio, and the date of each
application recorded. Analogous (but less detailed) information is needed for an
unpaved watering program.  Finally, for wet suppression of handling emissions,
flow rates and nozzle types need to be identified. MRI will work closely with
mine personnel to obtain the above types of information.

      To measure the application intensity of water or chemical suppressants,
MRI will place tared sampling pans at various locations on the test strips prior to
application.  Special attention is to be paid to the problem associated with the
chemical dust suppressant splashing off the bottom of the pan. To reduce this
potential source of error, an absorbent material will be used to line the bottom of
the pan.  Once the control is applied, the sample pans will be reweighed and the
density of the solution will be measured.  The application intensity measured by
each pan is given by
36

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                              SILT ANALYSIS
Date	
Sample No:
Material:
Split Sample Balance:
Make	
Capacity	
Smallest Division
           By 	
           Sample Weight (after drying)
           Pan + Sample:	.
           Pan:	
           Dry Sample:.

           Final Weight:
                                e/ o?u   Net Weioht <200 Me«h  ..-.-
                                %SlIt-   Total Net Weight     X1°°
               SIEVING
  nme: Start:
Weiant (Pan Only)
  Initial
 20 mm:
 30 min:
 40 mm:
Screen
3/8 in.
Tare Weight
(Screen)

4 mesh I
1 0 mesh
20 jnesh
40 mesh
100 mesh
140 mesh
200 mesh
Pan
Final Weight
(Screen + Sample)


I












Net Weight (Sample)









%









                   Figure 7. Example silt analysis form.
                                                                        37

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where:   a  =   application intensity (volume/area)
         m, =   final weight of the pan and solution (mass)
         m, =   tare weight of the pan (mass)
          p =   weight density of solution (mass/volume)
          A =   area of the pan  (area)

The individual application intensities obtained will be examined to determine any
significant spatial variations and to obtain an average  value.

      Note that the performance of unpaved road dust controls is strongly
dependent upon not only the service environment (such as the weight and
number of vehicles traveling the  road after control application) but also ambient
meteorological conditions (such as temperature, insolation, and freeze/thaw
cycles).  Service environment factors are described in the next section, while
on-site meteorology is discussed in Section 4.4.
4.3  SOURCE ACTIVITY MONITORING

     •  One potentially significant difference from the study described here and
past field studies at surface coal mines is the development of a "source activity
data base." As noted earlier, the impact of PM10 emissions from SCMs is
typically based on annual averages (of coal production, etc.) presented in a
mine's operating  plan or obtained from an active mine.  Worst-case emissions
are usually calculated under the assumptions (a) that natural moisture mitigation
is negligible and  (b) that the worst-case emissions from all sources under
consideration occur at the same time.  Worst-case activity levels are often scaled
from the annual average by an assumed factor (such as a factor of 2).

       In contract to this approach, a 'dynamic11  emissions inventory will be
obtained to accomplish  the goals of this program. Unlike most regulatory
modeling exercises, which  are interested  in "annual average" or "worst-case"

38

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conditions, this program will track actual source activity over time. Source
activity levels will be recorded during the entire period'that field test crews are
present at surface coal mines.

      Source extent activity data will be collected with a variety of tools.  For
example, in addition to visual observation and note taking, video cameras and/or
time-lapse photography may be used to determine activity on roads or at other
mining sources.  For roads and other travel-related sources (such as coal or
overburden truck dumps), pneumatic axle counters will be used to supplement
other approaches.

      This monitoring activity will make use of pneumatic and other types of
traffic counters; these  can  be removed for road grading, etc.  The monitoring also
calls for some videotaping, requiring two or three enclosed or sheltered areas in
which to set up equipment. The areas should have standard AC power and be
relatively clean and secure. At present it  is anticipated that approximately three
to six pneumatic counters and  two to three video cameras will be able to provide
the necessary information for the major emission sources.

      The use of a variety of data acquisition methods aids in resolving source
activity levels on an appropriate temporal basis. Source activity (both rate and
physical location) will be resolved to 4-h or shorter time  periods. The 4-h period
corresponds to one-half work shift at a mine.  It is likely that most emission
sources at a surface mine can be viewed as relatively constant in time and
space over a work shift. The use of a half-shift as the basic time averaging unit
provides a margin of safety.  In addition, at the start of each day, the field crew
chief will ask the mine superintendent or his designee to describe any unusual
events (equipment downtime, etc.) during the past 24 h.
4.4 METEOROLOGICAL MONITORING

      The collection of valid, applicable meteorological data is essential in
meeting the objectives of the proposed program. These data must be repre-
sentative of atmospheric dispersion conditions at the source and at locations
where the source may have a significant impact on air quality or where air quality
                                                                         39

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is monitored. The representativeness of the data is dependent upon (1) the
proximity of the meteorological monitoring site to the area under consideration,
(2) the complexity of the topography of the area, (3) the exposure of the
meteorological sensors, and (4) the period of time during which the data are
collected.

      According to the EPA's PSD guidelines, a data base representative of the
meteorological monitoring site should consist of at least the following data:

      1.     Hourly average wind speed and direction.

      2.     Hourly average atmospheric stability based on Pasquill stability
             category or wind fluctuations (09), or vertical temperature gradient
             combined with wind speed.

      3.     Hourly surface temperature at standard height for climatological
             comparisons and plume rise calculations.

      4.     Hourly precipitation amounts for climatological comparisons.

      Mines agreeing to serve as test sites may already have active PSD-type
meteorological monitoring programs. The suitability of any existing meteoro-
logical monitoring network will be reexamined once a mine has been selected as
a field test site.  In any event, at least a backup meteorological monitoring station
will be deployed during this field program.

      As with the particulate monitoring sites to be discussed in Section 4.5, it is
essential to ensure that microscale source, topographic, and meteorological
influences do not bias the data obtained with the weather station. This
consideration is critical because of the generally large areas which are to be
represented by the station.

       Following  PSD guidelines, the wind monitor should be sited:

       1.     To monitor representative wind field.
40

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      2.    Near the source of particulates.

      3.    Away from undesired microscale flows.

      4.    Away from the influence of trees and obstructions (at a distance
            from an obstacle approximately five times the obstacle's height).

      5.    At a height of 10 m.

      6.    Adjacent to particulate sampler if possible.

      Analogously, the ambient temperature sensor must be protected against
thermal radiation from the  sun, sky, earth, and any surrounding objects and must
be adequately ventilated.  The temperature sensor suggested for this study is
housed on the meteorological mast just below the wind sensors and is  protected
by a radiation shield.

      The rain gauge used in the study should be located at ground level in a
sheltered area to  prevent undue effects from atmospheric turbulence.  Ideally,
the gauge site should be carefully leveled and protected  in all directions by
objects of uniform height (trees, buildings, etc.).  If this cannot be accomplished,
an effort should be made to site the instrument where it will be shielded from up-
and down-valley flows. The heights of the surrounding objects should be
between one-half and one times their distance from the gauge.

       Because no site surveys have been done at the time of this writing, it is
not now possible  to completely define what meteorological monitoring equipment
will be employed. The following discussion represents a "best guess" at this
time.

       At present  it is anticipated that each "primary" air quality monitoring station
(as defined in  Section 4.5) will be equipped with at least  a recording
meteorological station, such as Meteorology Research Inc. Model 1077 or a
Climatronics bi-vane weather station.  Because the bi-vane unit stores  digitized
data, it would serve as the principal monitoring device. The Climatronics unit is
                                                                         41

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capable of providing a good indication of hourly gauge atmospheric stability class
as well as hourly wind speed and direction.

      The Model 1077 weather station, on the other hand, has been proven to
be a reliable field monitor for wind speed and direction, temperature, and
windfall.  This reliability makes the Model 1077 a good backup system. To be
sure, much of the reliability is due to the fact that a strip chart is used to record
data.  The choice of recording device, however,  makes the estimation of stability
class more tenuous.  In short, the standard deviation of azimuth wind direction is
estimated by a procedure developed by Markee.7
where:   a0 =  standard deviation of wind direction

         R0 =  hourly range of wind direction

The quantity a0 is then used to convert to the stability class as follows:
                                      Pasquill stability
                                           class
                        > 22.5              A
                      17.5 - 22.5            B
                      12.5 - 17.5            C
                       7.5 - 12.5            D
                       3.8 - 7,5             E
                         <3.8               F
 4.5  AIR QUALITY MONITORING

       Present discussions indicate that a model evaluation may be performed at
 a surface coal mine in later years. As such, some results from this study may be
 42

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used in that field evaluation. The following paragraphs describe the type of field
program anticipated at a later date.

      As was the case for meteorological monitoring, it is likely that mines
selected as field test sites will have active PSD-type air quality monitoring
programs.  Unlike the meteorological stations, however, it is improbable that
existing air quality monitoring networks will prove entirely suitable for model
evaluation purposes. For this reason, a flexible air quality monitoring program
has been included as part of this field program.

      Like the source activity monitoring, the air quality monitoring program will
differ from past studies in that finer time resolution is of interest. Past studies
have generally had to "make do" with available data.  Nevertheless, the time
period  over which ambient measurements are made, over which emission rates
are computed, and over which source locations are idealized should be as short
as practicable.  The performance of an air quality model should improve when
the input data have finer resolution.  Nevertheless, any analysis of a model's
performance in  predicting PM10 concentrations must consider 24-h time intervals
because many mines have more difficulty demonstrating compliance with 24-h
rather than annual increments or standards.

      Various time averaging periods are possible for PM10 concentrations. In
the regulatory sense, 24-h concentrations are m<••£• important because the
NAAQSs and PSD increments are based on tha;  me period.  On the other
hand, currently  available dispersion models typic.; *y use hourly meteorological
data to predict hourly concentrations. The  hourly predictions are then combined
to provide longer-period averages.

      Until recently,  ambient PM10 concentrations could only be sampled by
reference methods for periods on the order of 24 h.  Within the past year,
several equivalent PM10 measurement methods have become available, providing
far greater time resolution than the older high-volume  sampling methods.
Table 7 summarizes  the advantages and disadvantages of various field sampling
equipment that  could be used.
                                                                        43

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      If a network consisting of only continuous PM10 monitors were to be
established, concentration at each monitoring location can be averaged on a 1-h
basis.  Although these monitors provide the finest time resolution possible, they
typically require temperature-controlled enclosures and "clean" electric power.
The enclosure and power requirements accentuate the high purchase cost of
continuous samplers.  In summary, continuous monitors  provide a very high
degree of temporal resolution but can provide adequate  spatial coverage only at
a very high level of cost.

      The present field program, however, seeks to combine the best features of
the available PM10 sampling methods by combining two  or three continuous
monitors with 6 to 10 high-volume samplers and with 10 to 20 "saturation"
samplers.  In this way, a  high degree of temporal resolution is accomplished at a
few locations within a generally well-monitored geographic area.

      This combination is viewed as providing the greatest spatial coverage
possible at a reasonable  cost while still providing the type of data needed to
assess the scientific component of the dispersion model. Specifically, the
following types of equipment are proposed for the study.

       1.    Two or three primary monitoring stations, each station with:

            a.     A continuous PM10 monitor such as  a beta gauge or tapered
                   element oscillating microbalance.

            b.     At least one each Andersen size-selective-inlet (SSI) and
                   Wedding PM10 inlet mounted  on a high-volume sampler.

            c.     At least one saturation sampler.

            d.    A recording meteorological station.

            The different samplers will be colocated.  Furthermore, the "whole-
             air" (i.e., noncontinuous) samplers will be operated over the same
            time periods.  If only one set of high-volume samplers is available,
            then they will be operated on a 24-h schedule. If more than one of
 44

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45

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            each type is available, then shorter periods (such as 8 and 12 h)
            are recommended.

            Each of the primary sampling locations will be equipped with a
            trailer and either a power drop or a heavy-duty diesel generator to
            provide the "clean8 electrical power needed to operate the
            continuous monitors. (If generators are used, special precautions
            will be taken to avoid sample contamination by exhaust.)

      2.    Approximately 10 to 20 saturation samplers deployed throughout
            the geographic area downwind of the mine.

      The siting of air quality monitoring devices is highly dependent upon the
characteristics of the test site, factors such as the distances and orientation of
major PM10 sources, prevailing wind directions, mines, and surrounding
topography. Because site surveys have yet to be conducted,  monitor siting can
only be discussed in general terms.  For illustration purposes, a hypothetical
power shovel mine will be  used as an example (see Figure 8).

      At the example mine, the major sources are found to be coal haul trucks,
overburden haul trucks, overburden handling, and overburden dumping.  General
traffic is also important but is confined to the two roads shown in  the figure.

     • Mining activity rates and locations at the example mine have been
evaluated along with the site-specific meteorological data to determine prevailing
wind direction  and the sampler locations.  It is proposed that at least three
portable samplers be placed in an arc immediately downwind  of the major
sources.

      Significant mining emission sources are rarely grouped together; rather the
sources may be spread over distances on the order of miles.  To measure the
cumulative effect of separate sources, the model should be tested at not only the
points of maximum concentration from individual sources but also at points
where the combined effect is greatest.  A second set of samplers is placed at the
points where emissions from individual sources combine to produce a  secondary
maximum (see Figure 8),  To determine what the background contribution is,
46

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           TOPSOIL REMOVAL
     COAL BLASTING
     AND LOADING
      PREVAILING WIND

      DIRECTION
OVERBURDEN
BLASTING AND LOADING
               OVERBURDEN DUMPING
          TOPSOIL REPLACEMENT
                                                  OVERBURDEN
                                                  HAUL ROAD
                                               o
                                               o
 COAL HAUL- ROAD
   COAL
PROCESSING
                          Maximum concentration samplers (assumes four largest PM-10 sources are the two roads,
                          overburden blasting/loading, and overburden dumping
                          Cumulative concentration samplers
                     Q   Upwind/background concentration samplers

   Figure 8.  Proposed sampling arrays at a stylized truck-shovel mine.  Filled
              symbols  represent primary sampling locations, hollow symbols
              represent saturation samples.
                                                                                      47

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three additional locations are proposed, placed in upwind and crosswind
directions from the mining activities.  Roughly half of the saturation PM10
samplers will be sited to sample combined concentrations.

      The exact placement of samplers at the actual mines tested will be a
function of both the configuration of the mine and the local meteorology.  Until
the time that an actual test site is decided upon, exact placement of samplers
cannot be made.
 48

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                              SECTION 5

                             REFERENCES
1.     U.S. Environmental Protection Agency, Compilation of Air Pollutant
      Emission Factors (AP-42), Research Triangle Park, North Carolina,
      September 1985.

2.     Shearer, D. L, R. A.  Dougherty, C. C. Easterbrook, Coal Mining Emission
      Factor Development and Modeling Study, TRC Environmental
      Consultants, July 1981.

3.     Muleski, G. E., Review of Surface Coal Mining Emission Factors, EPA
      Contract No. 68-DO-0137, Assignment 10, July 1991.

4.     Cole, C. F., B. L. Murphy, J. S. Evans, A. Gards, Quantification of
      Uncertainties in EPA's Fugitive Emissions and Modeling Methodologies at
      Surface Coal Mines, TRC Environmental Consultants, February 1985.

5.     Vardiman,  S.,  and K. Winges, Powder River Basin Model Validation
      Analysis, TRC report prepared for Wyoming Department of Environmental
      Quality, August 1991.

6.     Davies, C. N., "The Entry of Aerosols  in Sampling  Heads and Tubes,"
      British Journal of Applied Physics, 2:921,  1968.

7.     Markee, E. H., Jr., "On the Relationships  of Range to Standard Deviation
      of Wind Fluctuations," Monthly Weather Review, 91(2), pp. 83-87, 1963.
                                                                      49

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                                     TECHNICAL REPORT DATA
                              fflease read Instructions on the reverse before completing!
  EPA-454/R95-009
                                                               3. R£C/Pf£NT'S ACCESSION A/O,
4. TITLE AND SUBTITLE
   Surface Coal Mine Study Plan
5. REPORT DATE
   March 4,  1992
                                                               6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                               8. PERFORMING ORGANIZATION REPORT NO.
g.^EHFORMINGJORGANIZATlptiLNAME AND ADDRESS
 Emission Tactor ancT Inventory TJroup  ,
 Emissions Monitoring and Analysis Division
 Office of Air Quality Planning  and Standards
 U.  S. Environmental  Protection  Agency
 Research Triangle Park. NC   27711	
                                                               10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                                13. TYPE OF REPORT AND PERIOD COVERED
                                                                14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
  This report outlines  the test protocols and plans to be used  for improving emission
  factors for western surface  coal mines in response to  the requirements  of Section
  234 of the  Clean Air  Act of  1990.
 7.
                                   KEY WORDS AND DOCUMENT ANALYSIS
                    DESCRIPTORS
                                                  b.lDENTIFIERS/OPEN ENDED TERMS
                                                                               c. COSATI Field/Group
 18. DISTRIBUTION STATEMENT
                                                  19. SECURITY CLASS (This Report/
                21. NO. Ol
                  53
                                                  20. SECURITY CLASS (This page)
                                                                               22. PRICE
 EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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