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United States      Office of Air Quality       EPA-450/4-83-004
Environmental Protection  Planning and Standards      August 1982
Agency         Research Triangle Park NC 27711

Air
• &EPA      Characterization Of
I             PIN/MOAndTSP
|             Air Quality Around
I             Western Surface
              Coal Mines

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      CHARACTERIZATION OF PM  10  AND  TSP
         AIR QUALITY AROUND WESTERN
             SURFACE COAL MINES
                     by


          PEDCo Environmental,  Inc.
             2420 Pershing Road
        Kansas City, Missouri   64108


                     and


        TRC Environmental Consultants
           8775 East Orchard Road
         Englewood, Colorado   80111


           Contract No. 68-02-3512
           Work Assignment No.  35
                 PN 3525-35
               Project Officer

              Thompson G. Pace
      AIR MANAGEMENT TECHNOLOGY  BRANCH
    U.S. ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NORTH CAROLINA  27711
                 August 1982
                . S.  Environment" 1 .:


                x' 5. r/Otti.'bo.r n Gi.
                    ,  IL   60GO'i

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This report has been reviewed by the Office Of Air Quality
Planning And Standards of the U. S. Environmental Protection
Agency and approved for publication as received from Pedco
Environmental, Inc.  Approval does not signify that the contents
necessarily reflect the views and policies of the U. S. Environ-
mental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation
for use.
                     EPA-450/4-83-004
                             ii

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                            CONTENTS
Figures                                                      v
Tables                                                       x

1.0  Executive Summary                                       1
     1.1  Introduction                                       1
     1.2  Conclusions                                        2

2.0  Characterization of PM 10 and TSP Air Quality around
       Western Surface Coal Mines using Monitoring Data      11
     2.1  Background                                         11
     2.2  Data collected                                     11
     2.3  Procedure to infer PM 10 concentrations from
            monitored TSP concentrations                     12
     2.4  Description of results                             23
     2.5  Error analysis and assumptions                     39

3.0  Characterization of PM 10 and TSP Air Quality around
       Western Surface Coal Mines using Previous Modeling
       Studies                                               43
     3.1  Background                                         43
     3.2  Previous modeling studies                          44
     3.3  Other descriptive models                           70
     3.4  Relationship of modeling results to possible
            ambient standards and the PSD permitting
            process                                          76

4.0  Characterization of PM 10 and TSP Air Quality around
       Western Surface Coal Mines using New Predictive
       Tools                                                 77
     4.1  Background                                         77
     4.2  Calculation of emissions                           77
     4.3  Calculation of concentrations                      92
     4.4  Potential sources of error in the prediction
            process                                          112
     4.5  Relationship of scenario results to possible
            regulatory options                               116
                               111

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                      CONTENTS (continued)
5.0  Synthesis of Three Approaches to Characterize PM 10
       and TSP Air Quality around Western Surface Coal
       Mines                                                 121
     5.1  Introduction                                       121
     5.2  Comparison of alternate approaches                 121

6.0  Need for Further Study                                  125
     6.1  Additional monitoring                              125
     6.2  Deficiencies in the predictive process             126
     6.3  Impact of additional control measures and
            alternate mine configurations on
            concentrations                                   126
     6.4  Standardized methods                               127
     6.5  Regulatory implications                            127

     References                                              128

Appendices
     A    Mass Fraction Calculations Derived for Section 2.0
            Procedure to Infer PM 10 Concentrations from
            Measured TSP Data                                130
     B    Computation of PM 10, PM 5, and PM 2.5 Mass
            Fractions at Various Downwind Distances
            for Section 2.0 Procedure                        137
     C    ICS Model Application to Three Mine Scenarios      147
                                IV

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                             FIGURES
Number                                                       Page
   1      Maximum Annual Geometric Mean Concentrations at
            Mine Boundary—TSP and PM 10                     9


   2      Maximum 24-Hour Concentrations at Mine
            Boundary--TSP and PM 10                          10


   3      Mass Fraction of TSP, Stability Class D, 4.3 m/s   21


   4      Mass Fraction of TSP, Stability Class D, 2.5 m/s   22


   5      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 1        26


   6      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 2        27


   7      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 3        28


   8      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 4        29


   9      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 5        30


  10      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 6        31


  11      Annual Average Monitored TSP and Calculated PM 10
            Concentrations, Northeast Wyoming, Mine 7        32


  12      Annual Average Monitored TSP and Calculated
            PM 10 Concentrations, Northeast Wyoming,
            Mine 8                                           33


  13      Annual Average Monitored TSP and Calculated
            PM 10 Concentrations, Southwest Wyoming,
            Mine 9                                           34

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                       FIGURES (continued)


Number                                                       Page

  14      Annual Average Monitored TSP and Calculated
            PM 10 Concentrations,  Northeast Colorado
            Mine 10                                          35

  15      Annual Average Monitored TSP and Calculated
            PM 10 Concentrations,  Southwest Montana
            Mine 11                                          36

  16      Annual Average Monitored TSP and Calculated
            PM 10 Concentrations,  Western North Dakota,
            Mine 12                                          37

  17      Sensitivity of the Procedure to Infer PM 10
            Concentrations to Windspeed Assumptions          40

  18      Sensitivity of the Procedure to Infer PM 10
            Concentrations to Stability Class Assumptions    42

  19      Geographical Areas of Interest                     45

  20      Annual Average Modeled TSP Concentrations
            Powder River Basin, Mine 1                       48

  21      Annual Average Modeled TSP Concentrations
            Powder River Basin, Mine 2                       49

  22      Annual Average Modeled TSP Concentrations
            Powder River Basin, Mine 3                       50

  23      Annual Average Modeled TSP Concentrations
            Powder River Basin, Mine 4                       51

  24      Annual Average Modeled TSP Concentrations
            Powder River Basin, Mine 5                       52

  25      Annual Average Modeled TSP Concentrations
            Green River/Hams Fork Basin, Mine 6              53

  26      Annual Average Modeled TSP Concentrations
            Green River/Hams Fork Basin, Mine 7              54

  27      Annual Average Modeled TSP Concentrations
            Green River/Hams Fork Basin, Mine 8              55
                                VI

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           29      Annual Average Modeled TSP Concentrations
•                   Green River/Hams Fork Basin, Mine 10             57
           30      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin, Mine 11             58
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                                FIGURES (continued)


         Number                                                       Page

           28      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin, Mine 9              56
           31      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin,  Mine 12             59

           32      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin,  Mine 13             60

           33      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin,  Mine 14             61

           34      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin,  Mine 15             62

           35      Annual Average Modeled TSP Concentrations
                     Green River/Hams Fork Basin,  Mine 16             63

           36      Existing and Anticipated Surface Coal Mining
                     Operations in Campbell County                    65

           37      Annual Average TSP Concentrations (pg/m3),
                     Total Dust Sources with Deposition, no
                     Background Added                                 67

           38      Annual Average TSP Concentrations (|jg/m3),
                     Coal Dust Sources with Deposition                68

           39      Annual Average TSP Concentrations (pg/m3),
                     Respirable Particulate £3 [jm without
                     Deposition                                       69

           40      Assumed Worst-Case Mine Configuration              71

           41      Nomograph Procedure for Predicting Worst-Case
                     Fenceline Concentration, TSP                     72

           42      Distance from Mine Center over which TSP
                     Class II Increment is Exceeded in the Powder
                     River Basin                                      74
                                        VI1

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                       FIGURES (continued)


Number                                                       Page

  43      Profile Presentation of a Powder River Basin
            Mine, Annual TSP Concentrations                  75

  44      Examples of Composite Particle Size Distributions
            from Coal Mining Particulate Sources             89

  45      Theoretical Impact of Incorrect Particle Size
            Distribution on Model-Predicted PM 10 or TSP
            Concentrations                                   91

  46      ISC Modeled Annual Geometric Mean TSP
            Concentrations, Powder River Basin               97

  47      ISC Modeled Annual Geometric Mean PM 10
            Concentrations, Powder River Basin               98

  48      ISC Modeled 24-Hour TSP Concentrations, Powder-
            River Basin                                      99

  49      ISC Modeled 24-Hour PM 10 Concentrations,
            Powder River Basin                               100

  50      ISC Modeled Annual Geometric Mean TSP Concentra-
            tions, San Juan Basin                            101

  51      ISC Modeled Annual Geometric Mean PM 10 Concen-
            trations, San Juan Basin                         102

  52      ISC Modeled 24-Hour TSP Concentrations, San
            Juan Basin                                       103

  53      ISC Modeled Annual Geometric Mean TSP Concentra-
            tions, Green River/Hams Fork Basin               104

  54      ISC Modeled 24-Hour PM 10 Concentrations,
            San Juan Basin                                   106

  55      ISC Modeled Annual Geometric Mean PM 10
            Concentrations, Powder River Basin               107

  56      ISC Modeled 24-Hour TSP Concentrations,
            Green River/Hams Fork Basin                      108

  57      ISC Modeled 24-Hour PM 10 Concentrations,
            Green River/Hams Fork Basin                      109
                               Vlll

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                       FIGURES (continued)




Number                                                       Page
m         58      Maximum Annual Geometric Mean Concentrations at
•                   Mine Boundary—TSP and PM 10                     122

           59      Maximum 24-Hour Concentrations at Mine
•                   Boundary—TSP and PM 10                          123




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                               IX

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                             TABLES
Number                                                       page

   1      Range of Measured TSP and Inferred PM 10
            Concentrations near Western Surface Coal Mines   3

   2      Maximum Concentration versus Distance by Scenario,
            |jg/m3 (No Background Concentration Added)        6

   3      Violations of the NAAQS and Class II PSD
            Increments                                       7

   4      Particulate Monitoring Information                 13

   5      Particle Size Distributions by Mass Fraction       16

   6      Computation of Settling Velocity                   16

   7      Reflection Coefficients                            17

   8      Groundlevel Concentrations at 1,000 Meters, "D"
            Stability, and 4.30 Meters/Second Windspeed      18

   9      Relative Groundlevel Concentrations at 1,000
            Meters, "D" Stability, and 4.30 Meters/Second
            Windspeed                                        19

  10      Inferred PM 10 Annual Average Concentrations       24

  11      Inferred PM 10 Second-Highest 24-Hour
            Concentrations                                   38

  12      Particulate Emission Factors and Control
            Efficiencies used in Previous Modeling Studies   47

  13      Surface Coal Mines Projected for the Campbell
            County Portion of the Powder River Basin         66

  14      Mining Operations that Generate Particulate
            Emissions                                        78
                                x

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                       TABLES (continued)



Number                                                       Page


  15      Hypothetical Mine Annual Activity Parameters       80


  16      Base Emission Factors                              81


  17      Independent Variable Values used in Emission
            Factor Equations                                 83


  18      Particulate Emission Factors for Hypothetical
            Mines                                            85


  19      Calculated Emissions                               86


  20      Distribution of Emissions by Particle Size         87


  21      Assumed Background Concentrations used in the
            Scenario Analysis                                95


  22      Annual Average Geometric/Arithmetic TSP
            Concentrations Measured by the Hi-Vol Method     96


  23      Maximum Concentration versus Distance by Scenario,
            |jg/m3 (No Background Concentration Added)        110


  24      Violations of the NAAQS and Class II PSD
            Increments                                       111


  25      Potential Sources of Error in the Predictive
            Process for Estimating Particulate Concentra-
            tions around Surface Coal Mines                  113


  26      Impact of Additional Particulate Controls on
            Emissions, Powder River Basin Scenario Example   117


  27      Impact of Additional Particulate Controls on
            Maximum Off-Site Concentrations                  119
                               XI

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                           SECTION 1.0

                        EXECUTIVE SUMMARY
1.1  INTRODUCTION

     Various regulatory changes that would impact the surface
coal mining industry are being considered.  These changes relate
to the ambient particulate standard and the Prevention of Sig-
nificant Deterioration (PSD) regulations.

     The Environmental Protection Agency (EPA) is currently
considering a new ambient particulate standard that would address
particulates less than 10 microns in diameter (termed PM 10).

     Additionally, there is considerable debate over whether
fugitive dust from surface mines should consume PSD increment.
Currently, federal PSD regulations dictate that fugitive and
nonfugitive dust consume increment.  These regulations may change
as a result of EPA's settlement agreement (Chemical Manufacturer's
Association, et al v. EPA) or as a result of changes in the Clean
Air Act.  The fugitive dust issue is critically important because
the vast majority of particulate emissions at surface mines are
fugitive.

     The objectives of this study are:  (1) to provide data on PM
10 concentrations and total suspended particulate (TSP) concentra-
tions around western surface coal mines sufficient to assess
their relationship to possible changes to ambient standards; (2)
to apply new emission factors and the new ISC model to predict PM
10 and TSP concentrations around hypothetical surface mines; and
(3) to assess the impact of the PM 10 and TSP concentrations on
the permitting process.

     The objectives of the study are addressed through analysis
of existing monitoring data (Section 2.0), previous modeling
studies (Section 3.0), and new modeling studies using recently
available improved techniques (Section 4.0).  The results of the
three approaches are synthesized in Section 5.0.  Recommendations
for further study are outlined in Section 6.0.

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1.2  CONCLUSIONS

1.2.1  Characterization of PM 10 and TSP Air Quality around
       Western Surface Coal Mines using Monitoring Data

     Particulate monitoring around western surface coal mines has
been almost exclusively for TSP.  To support the regulatory
decision making process, it is desirable to have a knowledge of
PM 10 concentrations.  Therefore, a theoretical procedure was
derived to infer PM concentrations from monitored TSP data.  The
procedure is subject to several uncertainties and a qualitative
error analysis has been performed.

TSP Concentrations—
     Monitoring data were collected from 12 mines with annual
coal production ranging from 0.7 to 16.0 million tons per year.
Maximum monitored concentrations were 86 and 324 |jg/m3 on an
annual and second-highest 24-hour basis (Table 1).  Six of the
twelve mines had monitors located outside the mine boundaries
facilitating comparison of the monitored values with National
Ambient Air Quality Standards (NAAQS) and PSD increments;.  TSP
concentrations outside the mine boundary did not exceed the
primary NAAQS on an annual or 24-hour basis.  The secondary
24-hour NAAQS were exceeded at two of the six mines.

PM 10 Concentrations—
     Maximum PM 10 concentrations calculated from TSP monitoring
data were 29 and 98 (jg/m3 on an annual and second-highest 24-hour
basis.  The calculated maximum PM 10 concentrations outside mine
boundaries and above background concentrations were 8 and 39
|jg/m3 on an annual and 24-hour basis.  If the PSD Class II incre-
ments remain the same, but the applicable particle size category
changes from TSP to PM 10, the data indicate that the 24-hour
increment may still be a restraint to obtaining a permit.  This
conclusion should be considered tentative due to uncertainties in
the calculation procedure.

1.2.2  Characterization of PM 10 and TSP Air Quality around
       Western Surface Coal Mines using Previous Modeling Studies

     Most previous modeling studies allow only a characterization
of annual average TSP concentrations.  Short-term TSP modeling
studies have been performed on a more limited basis and are
considered to be less accurate because of the difficulty in
predicting short-term activity patterns, emissions, and meteoro-
logical parameters.  Modeling for sub-TSP particle size ranges,
such as for PM 10, has been limited to a few theoretical studies.

TSP Concentrations—
     Previous modeling suggests that ambient concentrations
resulting from a given level of emissions vary considerably by

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    TABLE 1.  RANGE OF MEASURED TSP AND INFERRED PM 10 CONCENTRATIONS
                     NEAR WESTERN SURFACE COAL MINES3
                                 (jjg/m3)
Location
Within mine boundaries
concentration
above background
Outside mine boundaries
concentration
above background
Measured
TSP concentrations
Annual

17-86
2-68

18-42
3-27
Second-highest
24-hour

79-324
64-306

56-180
41-165
Inferred
PM 10 concentrations
Annual

9-29
0-20

10-17
1-8
Second-highest
24-hour

19-98
10-91

24-48
13-39
Based on monitoring at 12 mines.  The data may not represent the  full  range
of monitored values at all coal mines.

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air basin because of different dispersion conditions,  and because
of TSP background concentrations ranging from about 15 pg/m3 to
30 (jg/m3 .   However, for mines isolated from other particulate
sources (such as other mines), previous modeling indicates that
annual average ambient fenceline concentrations seldom exceed 50
(jg/m3.  At mines with an annual coal production of greater than
about 15 million tons, however, annual concentrations  may approach
the primary and secondary annual standards under worst-case mine
configurations.  In all cases examined, annual TSP concentrations
decreased to <_I ug/m3 within four miles of the mine boundary.

     Based on previous modeling studies, PSD Class II  increments
appear to be a much greater restraint than the NAAQS.   Even with
application of EPA Region VIII defined Best Available  Control
Technology (BACT),  the annual PSD Class II increment was predicted
to be violated up to 2 miles beyond the fenceline at mines with
an annual production of about 10 million tons a year or more.
The 24-hour PSD Class II increment would be an even greater
restraint with violations as distant as 5 miles beyond the fence-
line at isolated mines with greater than 10 million tons produc-
tion.

     Often mines are not isolated from other mines.  This is
particularly true in the Powder River Basin.  Fugitive dust
consumption of available PSD increment in that and other regions
may severely restrict the planned level of mining.

PM 10 Concentrations--
     Previous modeling studies of sub-TSP size fractions do not
allow adequate characterizations of PM 10 concentrations around
western surface coal mines.

1.2.3  Characterization of PM 10 and TSP Air Quality around
       Western Surface Coal Mines using New Predictive Tools

     Two new tools—improved emission factors and the  ISC disper-
sion model--are now available for assessing a western surface
coal mine's impact on air quality.

     In this report the new predictive tools were applied to
three hypothetical surface coal mines.  The mines were assumed to
have the following annual coal production rates:

     0    Powder River Basin  (near Gillette, Wyoming):  25 mil-
          lion tons per year.

     0    Green River/Hams Fork Basin  (near Craig, Colorado):
          3.6 million tons per year.

     0    San Juan Basin (near Four Corners area):  6.5 million
          tons per year.

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The hypothetical mines were chosen to represent a cross section
of mine size and mine location found in the west.

     Using the new emission factors coupled with the ISC model,
TSP and PM 10 concentrations were computed for annual average and
24-hour time periods.  The predicted concentrations are directly
comparable with existing TSP standards, with possible PM 10
standards, and with PSD increments.  The results of the modeling
are summarized in Tables 2 and 3.

     Based on the modeling work, several observations can be
made:

     0    TSP standards.  Only the largest mine, the Powder River
          Basin Mine, shows violations of the annual or 24-hour
          TSP NAAQS.

     0    PSD increments.  Presently, federal PSD regulations
          dictate that fugitive and nonfugitive dust consume PSD
          increment.  All three of the hypothetical mines exhibit
          TSP exceedances of the annual and 24-hour PSD Class II
          increment outside of the mine boundary.

     0    PM 10 concentrations.  The peak PM 10 concentrations
          estimated at the mines' fencelines are between 1/3 and
          2/3 the magnitude of the TSP concentrations.  PM 10
          concentrations consume all of the PSD Class II incre-
          ment at two of the three scenario locations.

     Several regulatory options were considered and applied to
the scenario analysis results.  Two of these options were:  (1)
requiring additional particulate control measures; and (2) ap-
plying the PSD increment consumption determination at some dis-
tance beyond the mine boundary.  All physically possible particu-
late control measures were applied to the scenarios, regardless
of their cost or other environmental consequences.  For the
Powder River Basin scenario, TSP concentrations were still twice
the annual Class II increment.  The PM 10 concentration also
exceeded the increment.

     If the PSD program is viewed as a resource allocation pro-
gram, it may be reasonable to apply the increment consumption
determination at some distance beyond the boundary.  Regarding
TSP concentrations, the 24-hour increment would still be a re-
straint for large mines at distances 5 miles beyond the mine
boundary.  However, if PM 10 concentrations were used to compute
increment consumption, a 2-mile buffer around a mine boundary
would allow even the Powder River Basin scenario mine to receive
a PSD permit.

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TABLE 2.  MAXIMUM CONCENTRATION VERSUS DISTANCE BY SCENARIO, |jg/m3
                (NO BACKGROUND CONCENTRATION ADDED)

Scenario
Annual concentrations
Powder River Basin
San Juan Basin
Green River/Hams
Fork Basin
Second-highest 24-hour
concentrations
Powder River Basin
San Juan Basin
Green River/Hams
Fork Basin
TSP

At
boundary

115
23
30


867
106
104

Distance from
boundary, miles
1

115
20
20


260
80
55

2

10
8
13


240
50
25

3

7
7
7


165
45
18

4

6
6
4


80
37
14

5

4
5
3


45
32
10

PM 10

At
boundary

51
16
23


289
35
30

Distance from
boundary, miles
1

40
11
15


200
30
16

2

7
7
5


45
20
11

3

6
4
4


25
18
7

4

4
3
3


16
16
4

5

3
2
2


12
12
1


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1.2.4  Synthesis

     Three approaches to characterizing PM 10 and TSP air quality
around western surface coal mines are utilized in this report.
These approaches are examination of monitoring data,  review of
previous modeling studies, and application of improved tools to
the predictive process.

     The data derived from the three methods are in relative
agreement.  The annual and 24-hour TSP NAAQS are restraining only
for large mines (probably greater than 15 million tons of annual
production) or in areas with several nearby mines.

     The PSD increments (particularly the 24-hour increment) are
much more restrictive than the NAAQS.  TSP concentrations from
mines producing as little as 5 million tons/year may consume all
of the Class II increment under worst-case site configurations
(Figures 1 and 2).  Inclusion of fugitive emissions in the PSD
process would severely restrict the ability of new mines to
obtain a PSD permit.

     Changing the pollutant of measurement from TSP to PM 10
would be less restrictive to the coal mining industry, but may
still prohibit large mines from obtaining a PSD permit.

1.2.5  Need for Additional Study

     The need for further research became apparent at several
points in the study.  Required further study can be divided into
five broad categories.  These are:

1.   Additional monitoring to gain particle size information and
     to attempt to validate the predictive process.

2.   Analysis of deficiencies in the predictive process, including,
     but not limited to particle deposition and pit retension.

3.   Impact of additional particulate control measures and alter-
     nate mine configurations on concentrations.

4.   Standardized methods.

5.   Regulatory implications.
                                8

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                           SECTION 2.0

  CHARACTERIZATION OF PM 10 AND TSP AIR QUALITY AROUND WESTERN
            SURFACE COAL MINES USING MONITORING DATA
2.1  BACKGROUND

     Over the last few years a base of air quality monitoring
data has been generated at proposed and operating western surface
mines.  However, the data from the individual mines has not been
compiled and analyzed in a comprehensive manner.  Ideally, the
compilation of these data would allow an immediate characteriza-
tion of particulate concentrations around western surface coal
mines.  However, a great amount of data is required to interpret
the monitoring results.

     Monitors are sited under highly varying conditions.  The
resulting concentration measurements are a function of a number
of variables.  These variables include:  production level, size
of mining area, production methods, types of sources, source-
receptor separation, terrain features, and meteorological pat-
terns.  Any rigorous interpretation of mine monitoring data
requires that monitor siting be considered in conjunction with
the concentration data.

     A review of available particulate monitoring data has indi-
cated that almost all of the reported data are for TSP, not
PM 10.  Since a knowledge of PM 10 concentrations is of primary
interest to support the regulatory process, a method to infer
PM 10 information from TSP monitoring data was developed, and is
described in Subsection 2.3.  This section contains a description
of data collected, a description of the process to infer PM 10,
PM 5, and PM 2.5 concentrations from monitored TSP concentrations,
and a tabular and graphical summary of the results.


2.2  DATA COLLECTED

     Several sources of monitoring siting data were considered.
These sources included file information in the PEDCo and TRC
offices, the coal industry as represented by members of the Tech-
nical Advisory Group, and public documents on file in state air
quality offices.
                               11

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     The form shown in Table 4 was used to compile the available
information.  The National Coal Association (NCA) sent letters
and the form to several of its members requesting monitoring/siting
data.  In addition, project resources (time and budget) allowed
the study team to visit the Colorado and Wyoming state agencies.

     During the visits to the state agencies,  and during the
review of contractor file data, a large amount of air quality
data were initially considered.  Certain data were rejected for
the following reasons:

1.   The data were obtained as part of a background or construc-
     tion phase air quality monitoring program.

2.   The data required to complete Table 4 could not be obtained
     from file information.

3.   The data were still classified as proprietary.

4.   Less than 45 data points were available (assumes monitoring
     every sixth day and EPA requirements for 75 percent data
     recovery).

5.   Monitoring data were collected within 100 meters of an
     identifiable source and were not representative of areawide
     air quality.  Only limited data were available to etpply this
     criteria.

     After application of the rejection criteria outlined above,
data from 12 surface coal mines remained.  These data were used
to develop the TSP to PM 10 concentration algorithm as described
in the next subsection.
2.3  PROCEDURE TO INFER PM 10 CONCENTRATIONS FROM MONITORED TSP
     CONCENTRATIONS

2.3.1  Description of Procedure

     This section describes the mechanics of the procedure used
to infer PM 10 (and PM 5 and PM 2.5) concentrations from measured
TSP concentrations.  The foundation of the procedure is to utilize
a dispersion model to calculate downwind concentrations of total
suspended particulate and concentrations of PM 10 from which the
PM 10 mass fraction can be determined.  Measured hi-vol TSP
concentrations are then multiplied by the appropriate mass frac-
tion to yield PM 10 concentrations.  For the purposes of explana-
tion, the procedure can be viewed as composed of five sequential
steps:
                               12

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                 TABLE 4.   PARTICULATE MONITORING INFORMATION
PART A—GENERAL MINE INFORMATION (ONE SHEET PER MINE)

1.    Name of mine


2.    Mine location, county and state


3.    Average coal production, tons per year

4.    Area disturbed per year for pit, acres
5.    Approximate quantity of overburden moved per year,
       cubic yards

6.    Method of overburden removal  - dragline
                                  - shovel/truck
                                  - scraper

7.    Dust control measures for haul roads - method
                                          - frequency

8.    Do you have a monitor quality assurance program - yes
                                                     - no
9.    Map or sketch (please attach) indicating north arrow and scale;  mine
     boundaries; location of pit during monitoring period,  permanent  haul
     roads, coal processing plant, and coal  storage, monitor locations and
     monitor number.

10.   Name and phone number of contact - name                   	
                                      - phone number           	
11.   Above information applicable to what year
(continued)
                                     13

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TABLE 4 (continued)
PART B—SPECIFIC MONITOR INFORMATION (ONE SHEET FOR EACH MONITOR LOCATION)

1.   Monitor number
2.   Instrument to measure TSP - hi-vol
                               - other

3.   Instrument to measure small particles,
                    Instrument
0
0
0
          Cascade impactor
          Size selective inlet
          Dichotomous
4.    Measured values
      No.  of
Year  samples
                      TSP
                Annual  Second    20th
                geom.   highest  highest     No.  of
                 mean  24-hour  24-hour*    samples
                                                 Particle size
                                                  cut-off,  |jm
                                                  Size specific

                                                 Annual  Second    20th
                                                 geom.   highest  highest
                                                  mean  24-hour  24-hour*
19
* Assumes monitoring every sixth day.

5.    If this is a source-impacted site as opposed to a background site,
  Source type
                           Approximate
                         source strength,
                       tons per year of TSP
                                                                Distance from
                                                                   monitor
                                     14

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     0    Collect measured TSP concentrations taken in the vi-
          cinity of western surface coal mines; estimate distance
          from each hi-vol to the major particulate sources at
          the mine.

     0    Adopt a universal particle size distribution reasonably
          expected to simulate the distribution found at the
          surface mines for which measured hi-vol concentrations
          are available.

     0    Using the universal size distribution, model the down-
          wind concentration of various size categories of par-
          ticulate.   Modeled concentrations must be computed at
          various downwind distances and under reasonably expected
          meteorological conditions.

     0    Calculate the ratio of PM 10/TSP concentration (and
          PM 5/TSP and PM 2.5/TSP) for several downwind distances.
          These ratios are the multipliers used to infer PM 10
          (and PM 5 and PM 2.5) concentrations from the measured
          TSP concentrations.

     0    Multiply the ratios by the measured concentrations,
          taking into account the effect of background concentra-
          tions .

Each of these five steps is discussed in more detail below.

Collect Data—
     The data collection criteria and procedures were described
in Subsection 2.2.  Data required for this analysis are the
measured TSP concentration, assumed background TSP concentration,
mean windspeed, and nominal source to hi-vol distance.  The
source to hi-vol distance was determined in some instances by
averaging the pit to hi-vol and the haul road to hi-vol distances
measured from maps;  in other instances where experience suggested
that one of the sources may be dominant, the source to hi-vol
distance was chosen.  In all cases the nominal source to hi-vol
distance is a representative distance over which particulate
matter contributed by the surface mine could be transported to
the hi-vol sampler.   Annual windspeeds correspond to the closest
midpoints of the standard default windspeed categories used in
the ISCST dispersion model.

Particle Size Distribution—
     The ISC model in its short-term mode (ISCST) simulates
gravitational settling and deposition by selectively removing
particle mass from the air as a function of downwind distance and
meteorological conditions.  Just as in the atmosphere, larger
particles settle out faster in the ISCST model than do smaller
particles.  As the dust plume moves downwind, the mass of airborne
                               15

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large particles  is  depleted sooner than the mass  of smaller
particles, with  the result that the overall particle size distri-
bution changes with distance.

     Derivation  of  particle size distributions by mass fraction
is discussed  in  Subsection 4.2.1.  The distributions are shown in
Table 5.

           TABLE 5.  PARTICLE SIZE DISTRIBUTIONS BY MASS FRACTION
                                   Fraction less than
Basin
Powder River
Green River/
Hams Fork
San Juan
Universal
2.5
0.020
0.020
0.024
0.021
5.0
0.096
0.082
0.103
0.094
10
0.287
0.234
0.289
0.270
15
0.447
0.365
0.442
0.418
20
0.567
0.474
0.557
0.533
30
1.000
1.000
1.000
1.000
Once the size  distribution had been established,  the settling
velocity and reflection coefficient were determined using stan-
dard methods described in the Industrial SourceComplex (ISC)
Dispersion Model  User's Guide.  These computations  are summarized
in Tables 6 and 7.

               TABLE 6.  COMPUTATION OF SETTLING VELOCITY3
Particle diameter
size range,
microns
0-2.5
2.5-5.0
5.0-10.0
10.0-15.0
15.0-20.0
20.0-30.0
Mean radius,
cm
6.25 x 10~;j
1.88 x 10"T
3.75 x 10~;
6.25 x 10 7
8.75 x 10"^
1.25 x IQ~*
Settling velocity,
m/s
0.000093
0.000837
0.. 003347
0,. 009297
0.018223
0.. 037189
   Settling velocity determined from the equation.
                                16

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     V  = £
2  p g r'
9    u
where g = acceleration due to gravity,  980 cm/s2

      p = particle  density,  2.0 gm/cm3

      H = air viscosity,  1.83 x 10 4 gm/cm-s



                    TABLE 7.   REFLECTION COEFFICIENTS
         Particle diameter size  range,
                  microns
                  0-2.5
                  2.5-5.0
                  5.0-10.0
                 10.0-15.0
                 15.0-20.0
                 20.0-30.0
                             Reflection coefficient
                                     1.0
                                     0.99
                                     0.86
                                     0.77
                                     0.73
                                     0.65
Model Concentrations—
     The most important step in the inferential method is to use
the ISCST model to  calculate the mass fraction of PM 10 to TSP
concentration.  The mass fraction of PM 10 particulate to TSP
concentration is  given  by:
          XPM  10
   PM10
            'TSP
where x = concentration

      F = mass  fraction

  PM 10 = particulate  smaller than 10 microns

    TSP = total suspended particulate

The mass fraction,  F „ ,Q,  is a function of initial particle size
distribution, windspeed,  stability class, and downwind distance.
The value of FpM  -Q is not a function of wind direction, cross-
wind distance,  or initial particle emission rate.  To compute the
values of FpM ,»  at various windspeeds,  stability classes, and
downwind distances, the ISCST model was  used to simulate coin-
cident groundlevel  area sources of 0.75  kilometers on a side.
Each source, representing a discrete particle size range,
assumed to emit 10  x  10
                           v                 - •  was
                grams/meter -second of particulate
matter within one of  the  six particle size categories shown in
                                17

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Table 6.  The ISCST model was exercised to simulate all possible
combinations of National Weather Service windspeed categories
(0-3, 4-6, 7-10, 11-16, 17-21, and greater than 21 knots)  and
atmospheric stability classes (A, B, C, and D); concentrations
within each of the six particle size categories were computed by
the ISCST model at downwind distances of 1,000, 1,500, 2,000,
3,000, 4,500, 7,000, 10,000, and 20,000 meters.  The tabular
output of the model is displayed in Appendix A.  Each entry in
Appendix A is the groundlevel concentration that would be  detected
downwind of an area source emitting 10 x 10   grams/ meter -second,
at the indicated windspeed, stability class, and downwind  distance.

Compute Mass Ratios--
     The next step was to weight the modeled concentrations by
the assumed universal particle size distribution by multiplying
each concentration within a given particle size range by its
appropriate emission mass fraction.  The computations involved in
this step for "D" stability and two windspeed categories are
included in Appendix B.  The rationale for this weighting  is
straightforward:  each area source used in the model was assumed
to emit at a constant 10 x 10~  grams/meter -second, but in fact
the emission rate of particulate matter within a given size range
is given by the universal distribution illustrated in Table 5.
Finally, the F   1Q, F   5, and F_M „ 5 ratios are calculated by
summing the total particulate mass witnin a given size range, and
dividing that by the TSP concentration.  These computations also
appear in Appendix B.

     As an example of how the inferential mass fraction method is
employed, consider the computation of FpM .._ at 1,000 meters
downwind distance, under "D" stability ar a windspeed of 4.30
meters/second.  The modeling results in Appendix A indicate that
the groundlevel concentrations induced by an emission rate of 10
x 10   grams/meter -second are as shown in Table 8.

    TABLE 8.  GROUNDLEVEL CONCENTRATIONS AT 1,000 METERS,  "D" STABILITY,
                   AND 4.30 METERS/SECOND WINDSPEED
Particle size range,
microns
0-2.5
2.5-5
5-10
10-15
15-20
20-30
Concentration,
(jg/m3
42.77
42.57
39.84
38.02
37.31
35.87
Note that the concentration for progressively larger particle
sizes decreases.  This result is as expected since more  of  the
                               18

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larger particles settle out before reaching the  receptor  1,000
meters away.

     Next, the relative frequency of occurrence  of  each of the
particle size categories at the source is  taken  into  account by2
dividing the concentrations in Table 8 by  10 x 10~  grams/meter •
second, and multiplying the concentration  by the previously
adopted universal particle size distribution.  This step  is
illustrated in Table 9.

       TABLE 9.  RELATIVE GROUNDLEVEL CONCENTRATIONS AT  1,000 METERS,
              "D" STABILITY, AND 4.30 METERS/SECOND WINDSPEED
Particle size,
microns
0-2.5
2.5-5
5-10
10-15
15-20
20-30
Modeled concentration,
X/Q, s/m
4.28
4.26
3.98
3.80
3.73
3.59
Universal mass
fraction
0.021
0.073
0.176
0.148
0.115
0.467
Relative concentration,
(jg/m3
0.090
0.311
0.700
0.562
0.429
1.676
Finally, the fraction of particulate mass  smaller  than  10  microns
can be determined by summing the relative  concentrations with
diameters less than 10 microns, and dividing  this  quantity by the
total concentration less than 30 microns.   Specifically, the
relative concentrations smaller than 10 microns  from Table 9  is
given by 0.090 + 0.311 + 0.700 = 1.101; the total  relative con-
centration is 3.768.  The ratio of these numbers,  1.101/3.768 =
0.292, represents the fraction of PM 10 particulate matter con-
tained in the total suspended particulate.  Ths  finding suggests
that at a distance of 1,000 meters from a  dust source,  under  "D"
stability and with a windspeed of 4.30 meters/second, 29 percent
of the TSP collected by a hi-vol is smaller than 10 microns in
diameter.  In a manner similar to the above computation, the
fraction of 2.5 micron and 5 micron diameter  particulate was
computed for a number of downwind distances.  Although  it  was
initially intended that a separate fraction would  be computed for
each possible combination of stability class  and windspeed, this
proved to be unnecessary since the annual  average  windspeeds  at
the candidate mines covered only two windspeeds  classes, namely
4-6 knots and 7-10 knots.  Furthermore, it was decided  that the
most prevalent stability class, "D", would adequately represent
stability conditions for the annual time periods (Turner 1969).
This is believed to be a reasonable approximation  for the  purposes
of this study.  The influence on the study results of assuming D
stability is examined in Subsection 2.5.
                               19

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Multiply Ratios by Measured Concentrations—
     The 2.5, 5.0, and 10 micron particle concentration fractions
of TSP are computed in Appendix B and are plotted in Figures 3
and 4 as a function of downwind distance.  As expected, the ratio
of small particle mass to total suspended particulate increases
with distance since the larger particles are removed from the
plume with distance.  Eventually, the mass fraction of small
particulate to TSP would equal 1.0,  but Figures 3 and 4 present
the mass fraction only as far as 20 kilometers.  Figures 3 and 4
provide the means to determine small particle concentrations
directly given downwind distance, meteorological conditions, and
measured TSP concentration.

2.3.2  Application of Inferential Method

     The ISCST model was configured so that the southwest corner
of the area sources coincided with origin of the grid system,
whereas the distances reported for each of the hi-vol concentra-
tions were measured from the nearest edge of the mine, pit, or
haul road.

     It was also necessary to account for background concentra-
tion.  Since the inferential method discussed so far only applies
to particulate matter contributed by the surface mine, measured
hi-vol concentrations must be corrected by first subtracting
background concentration.  Similarly, the final determination of
PM 10 (or PM 5 or PM 2.5) must also be corrected by adding a
representative background value of PM 10 (or PM 5 or PM 2.5).
Combining these corrections yields the following equations:

  PM 10 = [(Measured TSP- background TSP)(PM 10 fraction)] +
          PM 10 background

   PM 5 = [(Measured TSP- background TSP)(PM 5 fraction)] +
          PM 5 background

 PM 2.5 = [(Measured TSP- background TSP)(PM 2.5 fraction)] +
          PM 2.5 background

     The PM 10 background concentration assumed for all of the
mines was generated from preliminary data from the 1980-1981
Western Energy Resource Development Area (WERDA) study.  During
this 2-year study, 72-hour concentration measurements of PM 2.5
and PM 15 were taken twice a week.  Data were collected at 40
remote sites in 8 different states.  A limited data summary was
available for 22 of these sites.  However, there was insufficient
information in this summary to select a background concentration
specific to each mine.  Consequently, with the concurrence of the
EPA project officer, the mean PM 2.5 and PM 15 concentrations
were calculated for the limited data from the 22 sites.  Because
specific data were not available, it was necessary to use these
                               20

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1
1
1
1
1
1 0.5
0.4
1 0.3
I £ 0-2
u_
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1 1 o,
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1 °°
i 0.05
| 0.04
0.03
™ 0.02
1
0.01
1
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1 1 1 1 1 1 1 I 1 1 1 1 1 1 1 M_
-
-
	 	 pM5
-
-
	 _____ pM25
-
1 1 1 1 1 1 1 1 1 | III
2345 10 20 30 40 50 100
DOWNWIND DISTANCE, km
jure 3. Mass fraction of TSP, stability class D, 4.3 m/s.
1
1
1

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    1.0
T   i   i  n  r
                                            1     i   i    i  n  M_J
o

z
o
0.5


0.4



0.3



0.2






0.1
                                                   PM 10
                                                   PM 5
t/1
    0.05


    0.04


    0.03



    0.02
                                               PM 2.5
    0.01
                  2345        10       20    30  40  50


                          DOWNWIND DISTANCE, km
                                                                100
       Figure 4.  Mass fraction of TSP, stability class D, 2.5 m/s.
                                    22

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means as an approximation for use with the measured TSP back-
ground concentrations.   The average concentrations for PM 2.5 and
PM 15 were 4 pg/m3 and 11 pg/m3.  Background concentrations for
PM 5 and PM 10 of 6 pg/m3 and 9 |jg/m3 were obtained by inter-
polating between PM 2.5 and PM 15 and assuming a lognormal dis-
tribution of concentrations between 2.5 pm and 15 pm.
2.4  DESCRIPTION OF RESULTS

2.4.1  Annual Average Concentrations

     The application of the inferential method, using the two
corrections above, is detailed in Table 10.  The right-hand
columns in that table present the inferred PM 2.5, PM 5, and PM
10 concentrations.  The annual average TSP and inferred PM 10
concentrations are shown graphically on Figures 5 to 32.  Each
figure is drawn to the same scale and orientation and shows the
approximate location of the monitor, mine boundary, pit, main
haul road and coal preparation plant.  Limited production data
are also presented.

     The inferred concentrations of PM 10, PM 5, and PM 2.5
presented in Table 10 are generally very small, and only slightly
greater than the respective background concentrations.  At the
distances examined (938 m to 5605 m), the mine contribution
(inferred concentration - background concentration) of PM 10, PM
5 and PM 2.5 ranges from 0.2 to 19.8, 0.1 to 7.2, and <0.1 to 1.6
pg/m3 respectively.  Obviously, the background concentration is
the dominant factor in almost all cases.

2.4.2  Second-Highest 24-Hour Concentrations

     The procedure for inferring PM 10 concentrations from TSP
monitored values was also applied to second-highest 24-hour TSP
monitored values.  The background concentrations assumed in the
analysis of annual average concentrations were carried forward to
this analysis.  The results appear in Table 11.  The table indi-
cates the monitored TSP second-highest 24-hour concentration, the
70 and 90 percentile values, and the inferred PM 10 second-highest
24-hour concentration.  At the distances examined (938 m to 5605
m), the mine contribution (inferred contribution-background
concentration) of PM 10, PM 5, and PM 2.5 ranges from 9.9 to
89.4, 3.6 to 32.4, and 0.8 to 7.3 pg/m3, respectively.  In con-
trast to the annual average PM 10 concentrations where the back-
ground PM 10 concentration was usually the dominant factor, the
mine contribution is the dominant factor in the 24-hour averaging
period.  Also of note is that the short-term PSD Class II incre-
ment of 37 pg/m3 was violated by the inferred PM 10 concentration
outside mine boundaries.
                               23

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TABLE 10. INFERRED PM 10 ANNUAL AVERAGE CONCENTRATIONS
Inferred cone. ,
ug/m3
Assumed background
cone. , pg/m3
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•o E s:
CU \ 0-
S- O)
5- 3.
0) LD
14-
C CM
s:
CL
Assumed background
cone. , pg/m3
PM 2.5 PM 5 PM 10
•a
c
T3 3
CD 0 . «
E S- 0. (J E
in -^ r— O O)
in u U 3.
 •>» ^
C to 5 E
 •
•r- O
C Z
o
CU
c •
•p- O
z z
tjDCOCM CM rHCOrv'd-rHrH
ooop*- cn CO^OLO^'**'
CMCMrH rHrHrHrHrHrH
CMCMO rH LOCniDCOOOCn
ococn ID f^p^iDOOP~-r*.
rH rH
<7) *J3 f*1*" CD CO ^^ pH I/O ^f ^J°
^-LD^- <• «-<*«•«-«-«*
cn cn cn cn cn cn cn cn cn cn
IDIDID ID iDlDlDlDIDID.
000000 CM LDLDLDLDlDlD

cninr^ CM oocnvDcn^"cn
r)- in ID ID IDIDIDLDLDLD
1 — r~«-O ID rHOO
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  TSP = 16.7 pg/m3
PM 10 =  9.5 |jg/m3
         1 all*
                                    MINE BOUNDARIES

                                 [Jj PIT LOCATION

                                 — HAUL ROAD

                                  A PUWT LOCATION

                                  • MONITOR LOCATION
   Location:   Campbell County, Wyoming
   Coal production:   10.0 x 106  tons/year
   Area disturbed:   50 acres/year
   Method of  overburden removal:   shovel/truck
   Quantity of overburden moved:   16.0 x 106 yardVyear
   Method of  dust control for  haul  roads:  water
Figure 5.  Annual average  monitored TSP and calculated  PM 10
         concentrations, northeast Wyoming, Mine 1.
                             26

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     TSP
   PM 10

     TSP
   PM 10
32.7 ug/m3
14.2 ug/m3»

24.4 ug/m3.
11.8 ug/m3
         TSP = 27.8  H9/nv
       PM 10 = 12.8  ug/m3
41.8 ug/m3
16.8 ug/m3
                                     MINE BOUNDARIES

                                    ] PIT LOCATION

                                     HAUL ROAD

                                     PLANT LOCATION

                                     MONITOR LOCATION
   Location:   Campbell County,  Wyoming
   Coal  production:  8.0 x  106  tons/year
   Area  disturbed:  65 acres/year
   Method of overburden removal:   shovel/truck
   Quantity of overburden moved:   3.3 x 106 yardVyear
   Method of dust control for haul  roads:  water
Figure 6.  Annual average monitored  TSP and calculated PM 10
         concentrations, northeast Wyoming, Mine 2.
                             27

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      TSP  = 18.0 pg/m3.
    PM 10  =  9.9 ug/m3
                                           TSP =27.2  ug/m3
                                         PM 10 = 12.6  ug/m3
                                       MINE BOUNDARIES

                                    £~j PIT LOCATION

                                    — HAUL ROAD

                                     A PLANT LOCATION

                                     • MONITOR LOCATION
   Location:   Campbell County, Wyoming
   Coal production:   8.2 x 10s tons/year
   Area disturbed:   109 acres/year
   Method of  overburden removal:  shovel/truck
   Quantity of overburden moved:  5.8  x 106 yardVyear
   Method of  dust control for haul  roads:   water
Figure 7.  Annual average monitored  TSP and calculated PM 10
         concentrations, northeast Wyoming, Mine 3.
                              28

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  TSP
PM 10
                25.6  Ljg/n>3
                12.1
  TSP = 26.7
PM 10 = 12.4 ug/m3
   TSP = 21.5
 PM 10 = 10.9 ug/m3
         1 Hilt
                                      MINE BOUNDARIES

                                    ["] PIT LOCATION

                                    — HAUL ROAO

                                    A PLANT LOCATION

                                    • MONITOR LOCATION
   Location:  Campbell  County, Wyoming
   Coal  production:  2.0 x 10s tons/year
   Area  disturbed:  133 acres/year
   Method of overburden removal:  shovel/truck
   Quantity of overburden moved:  3.5 x 106  yardVyear
   Method of dust control  for haul roads:  water/coherex
Figure 8.  Annual average monitored TSP and calculated PM 10
         concentrations, northeast Wyoming, Mine 4.
                              29

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                                       TSP = 24.6 ug/m3
                                     PM 10 = 11.8 ug/m3
                                         TS*P
                                       PM 10
25.0 ug/m3
11.9 ug/m3
         1 mile
                                I j MINE BOUNDARIES

                                uJi PIT LOCATION

                                — HAUL ROAD

                                 A PLANT LOCATION

                                 • MONITOR LOCATION
  Location:   Campbell County, Wyoming
  Coal production:   4.5 x 106 tons/year
  Area disturbed:   98 acres/year
  Method of  overburden removal:   shovel/truck
  Quantity of overburden moved:   5.7 x 106 yardVyear
  Method of  dust control for haul  roads:   water


Figure 9.  Annual average monitored TSP and calculated PM 10
         concentrations, northeast Wyoming, Mine 5.
                             30

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      TSP
    PM 10

      TSP
    PM 10
33.2 ug/m3.
14.3 ug/m3

27.9 ug/m!
12.8 ug/m3
3-4-
  TSP = 51.7 ug/m3
PM 10 = 19.7 ug/m3
                                    MINE BOUNDARIES

                                  ("\ PIT LOCATION

                                  — HAUL ROAD

                                  A PLANT LOCATION

                                  • MONITOR LOCATION
Location:   Campbell County, Wyoming
Coal production:   6.5 x 106 tons/year
Area disturbed:   63 acres/year
Method of  overburden removal:   shovel/truck
Quantity of overburden moved:   9.6  x 106 yardVyear
Method of  dust control for haul  roads:   water
                     Figure 10.   Annual average monitored TSP  and  calculated PM 10
                              concentrations, northeast Wyoming, Mine 6.
 I
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                                     TSP = 38.2 yg/m3
                                   PM 10 = 15.8 yg/m3

                                         - TSP = 45.5  yg/m3
                                         PI^IO = 18.0  yg/m3

                                            TSP =  27.1  yg/m3
                                          PM  10 =  12.5 yg/m3
                                       MINE BOUNDARIES

                                     L'j PIT LOCATION

                                     — HAUL ROAD

                                     A PLANT LOCATION

                                     • MONITOR LOCATION
   Location:  Campbell County, Wyoming
   Coal production:   16.0 x 106 tons/year
   Area disturbed:   197 acres/year
   Method of overburden removal:  shovel/truck
   Quantity of overburden moved:  23.6  x 106  yardVyear
   Method of dust  control for haul roads:   water
Figure 11.  Annual average monitored TSP  and  calculated PM 10
         concentrations, northeast Wyoming, Mine  7.
                             32

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                                 TSP =37.5 ug/m3
                              *PM 10 = 15.6 ug/m3
                                 TSP =22.2 ug/m3
                               PM 10 = 11.1
                                   MINE BOUNDARIES


                                 ["I PIT LOC*TIOH

                                 — HAUL ROAD

                                 A PLANT LOCATION

                                 • MONITOR LOCATION
   Location:  Sheridan  County, Wyoming
   Coal  production:  4.3  x 106 tons/year
   Area disturbed:   58.6  acres/year
   Method of overburden removal:   scraper/shovel-truck
   Quantity of overburden moved:   13.7 x 106 yardVyear
   Method of dust control  for haul roads:  water
Figure 12.  Annual average monitored TSP and calculated PM 10
         concentrations, northeast  Wyoming, Mine 8.
                             33

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                       r
           TSP =57.7 ug/m3
  ,,,v  • PM 10 =  20.6 ug/m3
  \  \
   >''   TSP = 85.7 ug/m3
 / • PM 10 = 28.8 ug/m3

   TSP =46.0 ug/m3
*PM  10 = 17.2 ug/m3
                                    ( J PIT LOCATION

                                    — HAUL ROAD
                                    A PLANT LOCATION

       , ,1le      '                    * MONITOR LOCATION


      NOTE: MINE BOUNDARIES COULD NOT BE OBTAINED
  Location:   Sweetwater  County, Wyoming
  Coal  production:  2.4  x  106 tons/year
  Area  disturbed:  164 acres/year
  Method  of overburden removal:  dragline
  Quantity of overburden moved:  12.0 x 106 yardVyear
  Method  of dust control for haul roads:  water
Figure 13.  Annual  average monitored TSP and  calculated PM 10
         concentrations,  southwest Wyoming, Mine 9.
                             34

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                   TSP
                 PM 10
22.6 ug/m3
 9.2 ug/m3
                                   [~] MINE BOUNDARIES

                                   [ J PIT LOCATION

                                   — HAUL ROAD

                                   A PLANT LOCATION

                                   • MONITOR LOCATION
   Location:   Jackson  County, Colorado
   Coal  production:  0.7  x 106 tons/year
   Area  disturbed:  15 acres/year
   Method of overburden removal:  scraper
   Quantity of overburden moved:  4.5 x 106 yardVyear
   Method of dust control for haul roads:  water
Figure 14.  Annual average monitored TSP and calculated PM 10
         concentrations, northwest Colorado, Mine 10.
                             35

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  TSP =
PM 10 =
                TSP =20.6 ug/m3
              PM  10 =  10.7 pg/m3
                                 TSP = 36'7
                               PM10 = 15.4
                                              •— TSP = 32.1 pg/m3
                                                 PM 10 = 14.1 pg/m3
                                            TSP  =32.4 pg/m3
                                          PM 10  = 14.1 pg/m3
                           TSP = 29.1 pg/m3
                         PM 10 = 13.1 pg/m3
         H11*
        NOTE:  NINE BOUNDARIES COULD NOT BE OBTAINED
                                    [ J PIT LOCATION

                                    — HAUL ROAD

                                    A PLANT LOCATION

                                     • MONITOR LOCATION
   Location:  Big  Horn County, Montana
   Coal production:   13.9 x 106 tons/year
   Area disturbed:   4333 acres/year
   Method of overburden removal:  dragline/shovel-truck/scraper
   Quantity of overburden moved:  44.8  x 106 yardVyear
   Method of dust  control for haul roads:   water/1ignon  sulfonate
Figure 15.  Annual average monitored TSP and calculated PM  10
         concentrations,  southeast Montana, Mine 11.
                             36

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                        TSP =36.0  ug/m3
                      PM 10 = 14.6  ug/m3
                                          TSP =26.0  ug/m3
                                        PM 10 = 10.8
                                    TSP =39.0
                                  PM 10 = 13.7 |jg/m3
                                       MINE BOUNDARIES

                                     [~J PIT LOCATION

                                     — HAUL ROAD

                                     A PLANT LOCATION

                                     • MONITOR LOCATION
   Location:  McLean  County, North Dakota
   Coal production:   3.1 x 106 tons/year
   Area disturbed:  207 acres/year
   Method of overburden removal:  dragline
   Quantity of overburden moved:  19.5 x 106 yardVyear
   Method of dust control for haul roads:   water
Figure 16.  Annual average  monitored TSP and calculated  PM  10
       concentrations, western North Dakota, Mine 12.
                             37

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        TABLE 11.   INFERRED PM 10 SECOND-HIGHEST 24-HOUR  CONCENTRATIONS






County
Campbel 1
Campbell



Campbel 1

Campbell


Campbell

Campbel 1


Campbel 1


Sheridan

Sweetwater


Jackson
McLean








State
Wyo.
Wyo.



Wyo.

Wyo.


Wyo.

Wyo.


Wyo.


Wyo.

Wyo.


Colo.
N. Dak.







Mine
No.
1
2



3

4


5

6


7


8

9


10
12







Monitor
No.
I
1
2
3
4
I
2
1
2
3
1
2
1
2
3
1
2
3
1
2
1
2
3
1
1
2
3
Measured
TSP
second
highest
24-hour
cone. ,
HQ/m3
49
72a
79a
64a
119a
56a
149
75
92
59
93a
59a
103
150
97
149a
138
79
180a
76a
224
324
128
99
126a
133a
151a



Per-
centi le

70
32
48
43
32
53
30
42
37
38
32
39
37
48
76
42
56
73
37
56
27
93
127
59
b
b
b
b

90
44
66
63
51
82
44
74
65
71
45
67
56
76
114
70
123
106
55
103
55
165
259
102
b
b
b
b



Inferred cone. ,
|jg/m3

2.5
4.8
5.4
5.5
5.2
6.5
5.0
7.2
5.4
5.8
5.0
5.9
5.0
6.1
7.2
6.0
7.2
7.0
5.5
8.0
5.5
8.9
11.3
6.6
6.0
6.5
6.7
7.1

5.0
9.6
12.1
12.8
11.2
17.0
10.4
20.3
12.4
14.2
10.7
14.3
10.7
15.3
20.3
14.7
20.2
19.3
12.8
23.5
12.6
28.0
38.4
17.8
15.1
17.3
18.2
19.9

10
18.9
25.7
27.9
23.4
39.4
21.2
48.8
26.6
31.6
21.9
31.8
21.9
34.7
48.4
32.9
48.1
45.3
27.7
57.2
27.2
69.4
98.4
41.2
33.6
40.0
42.6
47.3
a
b
Outside mine boundary.
Data not provided.
                                     38

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2.5  ERROR ANALYSIS AND ASSUMPTIONS

     A number of assumptions were made in the derivation and
application of the inferential analysis method, and these should
be recognized and discussed along with the findings.  The fore-
most assumption, and one which has the greatest potential for
influencing inferred PM 10, PM 5, and PM 2.5 concentrations, is
the choice of background concentrations.  It is conceivable that
the background concentrations of PM 10 could be equal to the TSP
background, that is to say, it is possible that all of the mea-
sured background concentration could be comprised of particulate
matter smaller than 10 microns in diameter.  Where this is the
case, then inferred PM 10 concentrations in Table 10 could increase
by as much as 13 |jg/m3 over and above those reported.  Additionally,
the actual background TSP concentrations could be appreciably
higher than those assumed, particularly during worst-case short-
term periods, with the same effect of increasing the inferred
concentrations.  The magnitude of these background concentrations
is simply not known to the degree of accuracy desirable.  Addi-
tional monitoring is required to quantify background concentra-
tions by particle size under different conditions.

     A second major assumption in the inferential method is that
the ISCST model correctly describes the transport and deposition
of particulate matter.  If the model simulates different size
categories with varying degrees of accuracy, then the resulting
mass fractions would be altered.

     The adoption of the universal particle size distribution
could also have a pronounced impact on inferred concentrations.
While Table 5 suggests that the distribution of particle mass
within specific size categories is reasonably uniform, the mass
fraction of PM 10 assumed in the universal distribution could be
in error by 100 percent.  This error in turn would induce errors
in the inferred concentrations in Table 10 of roughly a factor of
two.

     In light of the uncertainties associated with the calcula-
tion of the inferred concentrations presented in Table 10, these
findings should be viewed as preliminary.

     Three of the assumptions employed in the procedure were
examined more closely.  These assumptions are the imposition of
fixed windspeeds, fixed D stability class, and the choice of
nominal receptor to source distances.

     The influence of windspeeds can be examined by comparing the
curves in previously cited Figures 3 and 4.  These curves have
been replotted on Figure 17.  The PM 10 fraction is higher at the
lower windspeed since the lower windspeed would cause comparitively
greater deposition of larger particles per unit of distance.  The
                               39

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1.0 t



0.5

0.4

0.3


0.2
2  0.1
0.05
0.04

0.03


0.02




0.01
                      MAXIMUM DISTANCE
                      USED IN ANALYSIS
                 I     I    I   I  I  I  I  I I
               PM 10
               PM 5
               PM 2.5
                 I     I    I   I  I  I  I  I
                                            I1III  I  M_
                                              2.5 m/s

                                              4.3 m/s
                                              2.5  m/s

                                              4.3  m/s
                                              2.5 m/s

                                              4.3 m/s
                 2345       10       20   30  40 50

                        DOWNWIND DISTANCE, km
                                                                100
         Figure  17.   Sensitivity of the procedure to  infer PM 10
                concentrations  to windspeed assumptions.
                                  40

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distance between the curves represents only a portion of the
possible range of values because extreme low or high windspeeds
would widen the range.  However, using an average annual wind-
speed would still cause the correct values to lie toward the
center of the range.  Assumption of a lower windspeed than 4.3
m/s would increase the PM 10 fraction of the TSP concentration.

     The influence of the D stability assumption was examined by
overlaying the curves from Figure 3 with curves derived assuming
A stability and 4.3 m/s windspeed.  For PM 10, one additional
curve was derived for B stability and 4.3 m/s windspeed.  These
curves are shown in Figure 18.

     The three curves for PM 10 exemplify one of the limitations
of the ISC model.  As discussed in the ISC user's manual, modeling
results for A stability are unreliable at distances greater than
3.0 kilometers.  As shown in Figure 18 the model overestimates
the amount of deposition at large downwind distances.  The PM 10
comparison of B and D stability classes demonstrates that less
deposition would occur in the unstable case (B stability).
However, at the maximum downwind distance considered in this
study (6 km), the results show that there is very little dif-
ference between the curves for B and D stability.

     The influence of the nominal receptor distance appears to be
slight.  The mass fractions change only slightly with downwind
distance, so that an error of many hundred meters in the distance
probably only has a negligible effect on concentrations.
                               41

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0.01
                    MAXIMUM DISTANCE
                    USED IN ANALYSIS
                          I  I  I  I M
                                               A STABILITY

                                               A STABILITY

                                               D STABILITY
                                               D STABILITY
                                               A STABILITY
                                                D  STABILITY
I
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                       45        10       20

                       DOWNWIND DISTANCE,  km
   30  40 50
               100
       Figure 18.   Sensitivity  of  the  procedure to infer PM 10
           concentrations  to  stability class assumptions.
                                42

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                           SECTION 3.0

  CHARACTERIZATION OF PM 10 AND TSP AIR QUALITY AROUND WESTERN
       SURFACE COAL MINES USING PREVIOUS MODELING STUDIES
3.1  BACKGROUND

     Particulate dispersion modeling for TSP has been performed
in support of the mine permitting process in many cases.  Unfor-
tunately, there are no standardized procedures for performing the
analyses.  Previous modeling efforts have utilized various lists
of sources, emission factors, and models.

     The two most common sets of emission factors used are from
the EPA Region VIII Interim Policy Paper (EPA 1978a) and from the
State of Wyoming (1979).  Each set of factors is a combination of
individual emission factors gathered from several references.
The Interim Policy Paper (IPP) considers more emission sources
than the Wyoming factors.  The IPP factors are intended for use
with a model particulate fallout function, whereas the Wyoming
factors are not.

     Two variations of the Climatological Dispersion Model (CDM)
have been predominately used for long-term modeling.  The State
of Wyoming had adapted CDM into a CDM-W model and specified its
use for permit work.  Therefore, all recent permit work in Wyoming
has been performed with the CDM-W model, and it has also found
some application in Colorado and Montana.  Over 40 modeling
studies have been performed for the Bureau of Land Management
(BLM) in connection with their tract leasing program.  For this
work, various modifications, including insertion of a fallout
function, have been made to the CDMQC model.

     Short-term modeling in support of the mine permitting process
is performed much less frequently.  The State of Wyoming does not
require short-term modeling.  Elsewhere, the PAL (EPA 1978b), RAM
(EPA 1978c), or Valley (EPA 1977) models have been used.  In
general, short-term modeling is considered less accurate than
long-term modeling because of the difficulty in defining short-
term activity patterns, emissions, and meteorological parameters.

     In all mine permitting cases, the analyses have been per-
formed for the Total Suspended Particulate (TSP) size range.
Modeling for <30 (jm particle sizes has been limited to a few
theoretical studies which are reviewed in Subsection 3.3.
                               43

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     This section describes several previous modeling studies and
illustrates TSP concentrations around surface coal mines with
concentration isopleths.  In a change from the original scope of
work, no effort was made to adjust or evaluate the previous
modeling studies.  This change was approved by the contract
officer.
3.2  PREVIOUS MODELING STUDIES

     Three geographical areas were selected for the study of
model applications in this section,  and the scenario analysis in
Section 4.0.  The three geographical areas are the Powder River
Basin (near Gillette, Wyoming); the San Juan Basin (near Farmington,
New Mexico); and the Green River/Hams Fork Basin (southern Wyoming,
and northwest Colorado).  These basins are shown in Figure 19.

     Reasons for selecting these basins are:

1.   The three areas are major coal producing areas with signifi-
     cantly different characteristics relating to total produc-
     tion level, mining methods, and meteorological conditions.

2.   The characteristics of the three areas are suitable for use
     in the scenario analysis described later in Section 4.0.
     The new EPA emission factors were derived from field testing
     in two of the three basins.  The factors are more accurate
     when applied to areas with emission factor correction para-
     meters in the same range over which testing occurred.

3.   The study team has a significant amount of file data for
     these three basins allowing for a more efficient use of
     project resources.

4.   Focusing on three areas allows the study team to reduce the
     number of variables involved in the task to a more manageable
     level.

The primary source for the modeling studies analyzed in this
section was the study team files.  Project resources allowed a
limited search for additional modeling studies from the Technical
Advisory Group and the State of Wyoming.

3.2.1  Single Mine Modeling

     The results of 16 previous modeling studies from the Powder
River Basin and the Green River/Hams Fork Basin were collected.
No previous San Juan modeling studies were available from the
resources listed above.
                               44

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     The mining sources and associated emission factors used in
the previous analyses are presented in Table 12 along with the
particulate control efficiencies applied.  The emission factors
and control efficiencies were taken from Region VIII Interim
Policy Paper (EPA 1978).  Utilizing the source list and emission
factors presented in Table 12, along with estimated activity
parameters, an emission inventory was prepared for each mine.
These data, along with spatial parameters, were entered into a
modified version of CDMQC.  The climatological data used for
input to the model were obtained from the nearest National Weather
Service station in the form of a stability rose (STAR) deck.

     Details of the CDMQC model and its application can be found
in the literature and are not repeated here.  However, the fol-
lowing modifications to the model were made for a more accurate
reflection of conditions in a surface coal mine.

1.   Insertion of a fallout function for point and area sources.

2.   Specification of a 10-meter release height.

3.   Removal of a model provision to alter stability classes in a
     manner that reflects urban conditions.

     The results of the modeling exercises were plotted on a
series of isopleth maps as shown in Figures 20 through 35.  Each
figure contains a variety of information.  All of the figures are
drawn to the same scale and orientation.  At the bottom of the
figures, the mine location, and limited activity data are pre-
sented along with the calculated annual TSP emissions.  Also
shown are the mine boundary, approximate locations of the coal
preparation facility, main haul road, and active pit.  The iso-
pleth concentrations represent TSP emissions including fugitive
dust.  Two concentrations are shown for each isopleth, the pre-
dicted concentration due to the mine and the predicted concentra-
tion plus a background concentration.

     The 16 mines presented in the figures represent annual coal
productions ranging from 225,000 tons to 23,200,000 tons.  Calcu-
lated emission estimates range from 154 tons to 4443 tons.  The
maximum TSP concentration predicted at the mine boundary varies
from 1 to 50 (jg/rn3.  As shown in the figures, this value is
highly dependent on the location of the mining activity with
respect to the mine boundary.

     In all cases, the predicted concentration decreases rapidly
as the distance from the mining activity increases.  The 1 (jg/rn3
isopleth is predicted to occur within 4 miles of all mine bounda-
ries.
                               46

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    TABLE 12.   PARTICULATE EMISSION FACTORS AND CONTROL EFFICIENCIES
                    USED IN PREVIOUS MODELING STUDIES
Mining activity
Topsoil removal - scraper
Scraper travel - topsoil
Truck dump - topsoil
Stockpile - topsoil
Overburden drilling
Overburden blasting
Overburden removal
Shovel/truck
Dragline
Haul trucks - overburden
Truck dump - overburden
Overburden stockpile
Dozer - overburden
Coal drilling
Coal blasting
Coal loading
Haul trucks - coal
Truck dump - coal
Crushing - coal
Screening - coal
Conveyor - coal
Coal storage
Open piles
Silos
Coal loadout
Road maintenance - grader
Access road travel
Exposed areas
Miscellaneous haul road travel
Powder River
Basin
Emission
factor
0.38
5.62
0.002
0.48
1.5
85.3

0.37
a
5.62
0.002
0.48
16
0.22
72.4
0.0035
9.37
0.007
0.08
0.10
0.20
32.9


0.0002
32
6.56
0.48
6.56
Percent
control

50

85





50

85




85
90
99
99
99


99
99
50
99
75
85
Green River/Hams Fork
Emission
factor
0.38
a
a
a
1.5
85.3

a
0.053
a
a
0.38
16
0.22
72.4
0.12
13.6
0.007
0.08
0.10
0.20
16.9-33.1


0.0002
32
5.3
0.38
a
Percent
control











85




85
85
99
99
90

50
99
95

99
40

Units
Ib/yd3
1 b/VMT
Ib/ton
ton/ac-yr
Ib/hole
Ib/blast

1 b/yd
Ib/yd3
1 b/VMT
Ib/ton
ton/ac-yr
Ib/h
Ib/hole
Ib/blast
Ib/ton
1 b/VMT
Ib/ton
Ib/ton
Ib/ton
Ib/ton
ton/ac-yr


Ib/ton
Ib/h
1 b/VMT
ton/ac-yr
1 b/VMT
Not applicable.
                                  47

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                          •1 ug/m3 (16 ug/m3)
                          •5 ug/m3 (20 ug/m3)
                         ,10 ug/m3 (25 ug/m3)
                          ?0 ug/m3 (35
                                         MINE BOUNDARIES

                                         PIT LOCATION

                                      — HAUL ROAD

                                      A PLANT LOCATION
                           mtUTU rnoiCTD
                 CMcurwtm nm vt*uou» cacuiurio*
Location:   Campbell County, Wyoming
Coal production:   23.2 x 106  tons/year
Area disturbed:   183 acres/year
Method of  overburden removal:  shovel/truck
Quantity of overburden moved:  29.5 x 106 yard3/year
Method of  dust control for haul  roads:  water/chemical
Annual TSP emissions:  2832 tons
   Figure 20.  Annual  average modeled  TSP concentrations
                 Powder River Basin,  Mine 1.
                             48

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   1 ug/m3 (16 ug/m3)
   5 pg/m3 (20 pg/m3
  10 pg/m3 (25 |jg/m3
  20 pg/m3 (35 pg/m3)
      1 Bill
                                      MINE BOUNDARIES

                                      PIT LOCATION

                                      HAUL ROAD

                                    A PLANT LOCATION

              	i in muKnwsti IWICAIU mmcra
             CMCUTUTIM run ucioou* COKUIUTIOI
Location:   Campbell County,  Wyoming
Coal production:   14.0 x  106 tons/year
Area disturbed:   91 acres/year
Method of  overburden removal:   dragline/shovel-truck
Quantity of overburden moved:   40.9 x 106 yard3/year
Method of  dust control for  haul roads:  water/chemical
Annual TSP emissions:  2126  tons
   Figure 21.   Annual average modeled TSP  concentrations
                Powder  River Basin, Mine 2.
                             49

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 1 (jg/m3  (16 ug/m3)
 5 ug/m3  (20 ug/m3)
10 ug/m3  (25 ug/m3)
20 ug/m3  (35 ug/m3)
50 |jg/m3  (65 ug/m3)
                 1 rile
                  NIT! HMM I> PUEHTHfUS IN01UTES HTCOlCTtO
                     a»ct«ii«iio« run wcuwua conce»tuiio«
MINE BOUNDARIES

PIT LOCATION

HAUL ROAD

PLAHT LOCATION
           Location:  Campbell  County, Wyoming
           Coal  production:   18.2 x 106 tons/year
           Area  disturbed:   190 acres/year
           Method of overburden removal:  shovel/truck
           Quantity of overburden moved:  61.3 x 106 yard3/year
           Method of dust  control for haul  roads:  water/chemical
           Annual TSP emissions:   4443 tons
             Figure  22.   Annual average modeled TSP  concentrations
                           Powder River Basin, Mine 3.
                                        50

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                                     1 ug/m3  (16  ug/m3)
                                    -5 ug/m3  (20  ug/m3)
                                    10 ug/m3  (25  ug/m3)
         1 ulle
                                      MINE BOUNDARIES

                                    ("I PIT LOCATION

                                    — • HAUL TOAD

                                    A PLANT LOCATION
               •MCI » MHOncSIS IWlCATti n(01CT(B
               coKwruri* MM wcuwuc co>e£«Tuiion
Location:   Campbell County,  Wyoming
Coal production:   12.8 x  106 tons/year
Area disturbed:   125 acres/year
Method of  overburden removal:   shovel/truck
Quantity of overburden moved:   23.9 x 106 yard3/year
Method of  dust control for  haul roads:  water/chemical
Annual TSP emissions:  1947  tons
  Figure 23.  Annual average modeled TSP  concentrations
                Powder  River Basin, Mine 4.
                            51

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 1 |jg/m3  (16 pg/m3)
 5 |jg/m3  (20 pg/m3)
10 pg/m3  (25 (jg/m3
20 pg/m3  (35 pg/m3
  5 pg/m3 (20 pg/m3)
 10 pg/m3 (25 pg/m3)
                                     MINE BOUNDARIES

                                   [~j PIT LOCATION

                                   — HAUL ROAD

                                   A PLANT LOCATION
            NIMER IN 'UtNTHCSES IIGICATES MfOlCTED
            rancepmuTieii mis ucunua CO«CE«HATIO«
  Location:   Campbell County,  Wyoming
  Coal production:  12.5  x  106 tons/year
  Area disturbed:   242 acres/year
  Method  of  overburden removal:   shovel/truck
  Quantity of overburden  moved:   39.9 x 106  yardVyear
  Method  of  dust control  for haul roads:   water/chemical
  Annual  TSP emissions:   3073  tons
    Figure  24.   Annual average modeled TSP  concentrations
                  Powder  River Basin, Mine 5.
                               52

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                3 (19 ug/m3)
          5  ug/m3 (23 ug/m3)'
         10  ug/m3 (28 ug/m3)
                                  [j| MINE BOUNDARIES

                                  [Jj PIT LOCATION

                                  —• HAUL ROAD

                                   A HA*T LOCATION
            WTt: WWI III MKHTMiai !ICIC*TtS ratDtCTtl
                   riM MM uaaatm oMU«rurio>
Location:   Carbon County,  Wyoming
Coal production:   4.0 x  106  tons/year
Area disturbed:   135 acres/year
Method of  overburden removal:   dragline
Quantity of overburden moved:   15.6 x 106 yardVyear
Method of  dust control for haul roads:  water/chemical
Annual TSP emissions:  1278  tons
   Figure 25.  Annual  average modeled  TSP concentrations
           Green River/Hams Fork Basin,  Mine 6.
                             53

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                                                1  ug/m3 (23 ug/m3)
                                                5  ug/m3 (27 ug/m3)
                                               10  ug/m3 (32 ug/m3)
                                               MINE BOUNDARIES
                                              • PIT LOCATION
                                            — HAUL ROAD
                                             A PLANT LOCATION
                   •art *uw« in 'uciiTHCSEs INOICATK
                      CDKEnrurioii run wcumw COCIHTUTIMI
Location:   Carbon County,  Wyoming
Coal production:   2.7 x  106  tons/year
Area disturbed:   117 acres/year
Method  of  overburden removal:   dragline
Quantity of overburden moved:   14.8 x  106  yard3/year
Method  of  dust control for haul roads:   water/chemical
Annual  TSP emissions:  1075  tons
   Figure 26.  Annual  average modeled TSP concentrations
           Green River/Hams Fork Basin,  Mine 7.
                             54

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                 1 pg/m3 (23 ug/m3)_
                 5 ug/m3 (27 M9/m3>
                                             MINE BOUNDARIES
                     X5 yg/m3 (28 yg/m3)  —MAUL ROAD
                                             PLANT LOCATION
                   WMCI » MMHTKUS IWIUfCS HtDICTtD
                       Tiai nus iKiunM cnccmurion
Location:   Carbon County, Wyoming
Coal production:   1.7 x 106 tons/year
Area disturbed:   134 acres/year
Method of overburden removal:  dragline
Quantity of overburden moved:  12.7  x 106 yardVyear
Method of dust  control for haul roads:   water/chemical
Annual TSP  emissions:   1179 tons
  Figure 27.   Annual  average modeled  TSP concentrations
           Green River/Hams Fork Basin,  Mine 8.
                            55

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1 ug/m3  (23  ug/m3)
                                       MINE BOUNDARIES

                                      J PIT LOCATION

                                       HAUL ROAD

                                     A PUNT LOCATION
              •DTI: KMCI 11 MI»T>*SES IW1CATES 1CDICTCO
                 CWKinTMTIO" nil! WCUMIM COCEKIUTI0>
      Location:   Carbon County, Wyoming
      Coal production:   1.0 x 106  tons/year
      Area disturbed:   44 acres/year
      Method of  overburden removal:   dragline
      Quantity of overburden moved:   5.6 x 106 yardVyear
      Method of  dust control for haul  roads:  water/chemical
      Annual TSP emissions:  632 tons
        Figure 28.   Annual average modeled TSP  concentrations
                Green River/Hams Fork Basin, Mine 9.
                                  56

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                                            ug/m3  (23  ug/m3)
                                            ug/m3  (27  ug/m3)
                                         MINE BOUNDARIES

                                       _"] PIT LOCATION

                                         HAUL ROAD

                                       A PLANT LOCATION
                    » nmrMscs natures
                 CONCENTUTiaH »1US tVg"?1"* COMCENTIUTiaM
Location:   Carbon County,  Wyoming
Coal production:  2.1 x  106  tons/year
Area disturbed:   91 acres/year
Method of  overburden removal:   dragline
Quantity of overburden moved:   11.6 x 106  yardVyear
Method of  dust control for haul roads:  water/chemical
Annual TSP emissions:  901 tons
 Figure  29.   Annual average modeled TSP  concentrations
          Green River/Hams  Fork Basin, Mine 10.
                            57

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   1 ug/m3 (23 ug/m3)
   5 ug/m3 (27 Mg/m3)
  20 ug/m3 (42 ug/m3)
          n1le
                                    MINE BOUNDARIES

                                 L"i PIT LOCAT1°N

                                 — HAUL ROAD

                                  A PLANT LOCATION
          •ore lumen in PUCKTHCICS IWIOHS "loicuo
             COHCtNtUIlOH rtUS UCKCKXM CONCENIUT10M
Location:   Moffat County,  Colorado
Coal production:  1.4  x 106 tons/year
Area disturbed:  27  acres/year
Method  of  overburden removal:  dragline
Quantity of overburden moved:  5.4  x 106 yard3/year
Method  of  dust control  for haul roads:   water/chemical
Annual  TSP emissions:   474 tons
   Figure 30.  Annual  average modeled TSP concentrations
           Green  River/Hams Fork Basin, Mine  11.
                             58

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                                     1 yg/m3  (23 yg/m3)
                                     5 yg/m3  (27 yg/m3)
                                    10 yg/m3  (32 yg/m3)
                                    30 yg/m3  (52 yg/m3)
  NINE BOUNDARIES

  PIT LOCATION

  HAUL ROAD

A PLANT LOCATION
                                   _
          •en «Mfi in Mmmus IWJOTII moicrto
             CMCMTMTIOII HIK IMUKIM CMCMTUT10II
Location:   Moffat County, Colorado
Coal production:   1.9 x 106 tons/year
Area disturbed:   60 acres/year
Method of  overburden removal:   draglines/truck-shovel
Quantity of overburden moved:   9.6  x 106 yardVyear
Method of  dust control for haul  roads:   water/chemical
Annual TSP emissions:  1039 tons
  Figure 31.  Annual  average modeled TSP  concentrations
          Green  River/Hams Fork Basin,  Mine  12.
                            59

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                             1 ug/m3 (23 ug/m3)
                             5 ug/m3 (27 ug/m3)-
                            10 ug/m3 (32 ug/m3)
         1 Bile
                                    [j MINE BOUNDARIES

                                    [  ] PIT LOCATION

                                    —— HAUL ROAD

                                    A PLANT LOCATION
            WTt IWKI in MMHTHtSCS IKIUTES HHUCTtD
               CWICtBTMTlOIC PLUS MCUttUW CWCEKTUTIW
Location:   Moffat County, Colorado
Coal production:   2.7 x 106  tons/year
Area disturbed:   114 acres/year
Method of  overburden removal:   dragline
Quantity of overburden moved:   18.1 x 106 yardVyear
Method of  dust control for haul  roads:  water/chemical
Annual TSP emissions:  1224  tons
 Figure  32.   Annual average  modeled TSP concentrations
          Green River/Hams  Fork Basin, Mine  13.
                           60

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     1 ug/m3 (23  ug/m3)
    10 ug/m3 (32  ug/m3
          1 Hi It
          ««t. m**a M MMHTWSU IM1UTIS MfOlCTO
             caKUTuri* KM uaaam cocnruTioi
                                 f_~j MINE BOUNDARIES

                                 [_"j PIT LOCATION

                                 — HAUL ROAD

                                  A PLANT LOCATION
Location:   Routt County,  Colorado
Coal production:  0.2 x  106 tons/year
Area disturbed:  17 acres/year
Method  of  overburden removal:   scrapers/truck-shovel
Quantity of overburden moved:   2.0 x 106  yardVyear
Method  of  dust control for haul roads:  water/chemical
Annual  TSP emissions:  154 tons
  Figure 33.  Annual  average modeled  TSP concentrations
          Green  River/Hams Fork Basin,  Mine 14.
                            61

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                                             |jg/m3 (23 ug/m3)
                                             ug/n>3 (27 ug/in3)
                                          10 ug/m3 (32 ug/m3)
                      N

                      I
I,  j MINE BOUNDARIES

(Tj PIT LOCATION

— MAUL ROAD

A PLANT LOCATION
                    D in nufiincsts imuns MKOICTED
                      TiM rua Mcnaouw COCUTUTIOI
Location:   Routt County, Colorado
Coal production:  2.8 x 106  tons/year
Area disturbed:   55 acres/year
Method of  overburden removal:   dragline
Quantity of overburden moved:   8.5 x 106 yardVyear
Method of  dust control for haul roads:  water/chemical
Annual TSP emissions:  775 tons
  Figure  34.   Annual average  modeled TSP concentrations
           Green River/Hams  Fork Basin, Mine  15.
                            62

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           1 ug/m3  (23 ug/m3)
           5 ug/m3  (27 ug/m3)
           1 milt
                                         MINE BOUNDARIES

                                         PIT LOCATION

                                         HAUL ROAO

                                         PLANT LOCATION
                «M» in numnfsu IWIUTU nKoicrn
                OKinwriiM run uetaam coctururioii
Location:   Routt County,  Colorado
Coal production:  1.3 x 106 tons/year
Area disturbed:   80 acres/year
Method  of  overburden removal:   dragline
Quantity of overburden moved:   24.4 x 106  yardVyear
Method  of  dust control for haul roads:   water/chemical
Annual  TSP emissions:  1134 tons
  Figure 35.  Annual  average modeled TSP concentrations
          Green  River/Hams Fork  Basin, Mine 16.
                            63

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     There are some limitations to the results presented in the
figures.  Various problems have been associated with the IPP and
Wyoming emission factors, and with CDM.  There are widely varying
terrain features that are associated with the mines in each area.
This is a particular problem in the Green River/Hams Fork Basin.
Neither the sketches nor the CDMQC model accurately represent the
effects of complex terrain.  Also, no consideration has been
given to the cumulative effect of mines located in close proximity.
This aspect is discussed in the next subsection.  Sources of
error in the concentration predictive process are discussed in
detail in Section 4.0.

3.2.2  Cumulative Impact from Multiple Mines in a Mining Region

     The modeling analyses presented in Subsection 3.2.1 were
examples of modeling studies performed for mines in isolation
from other particulate sources.  In actuality, mines are often
located in close proximity to other mines and ambient concentra-
tions are cumulative concentrations from more than one mine.

     This is particularly true in the Powder River Basin.  Envi-
ronmental Research & Technology (ERT) prepared a report for the
U.S. Department of Energy (ERT 1979) in which Powder River Basin
coal mines were modeled for three particle sizes and different
dust categories.  Figure 36 shows existing and anticipated sur-
face coal mining operations in the Campbell County portion of the
Powder River Basin.  Table 13 shows the anticipated production of
these mines used in the ERT study.  Region VIII IPP emission
factors were used in the analyses (EPA 1978).  These factors,
which are for TSP, were converted to 2.5 pm and 15 pm from com-
posite size distribution curves (PEDCo 1978).  The ERT air quality
(ERTAQ) model was used, which is a Gaussian model similar to CDM.

     The results are presented in a series of annual average
concentration isopleth maps.  Figure 37 shows TSP concentrations
from all dust sources.  Figure 38 shows TSP concentrations from
coal dust emissions only.  Deposition was assumed for both model
runs.  Inclusion of all dust sources results in TSP concentration
from the mines exceeding 50 pg/m3 without background added.  The
coal dust isopleths (current PSD interpretation) show maximum
concentrations of 2.0 pg/m3.

     Figure 39 shows concentrations of particles <3 pm.  All dust
sources were included but no deposition function was used in the
model.  At 3 pm particle size, the lack of a deposition function
had little impact on the results.  The 3 pm isopleths show a
maximum impact of 5 pg/m3.
                               64

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                                                      aero o*  '.J' ''•  «."*, p
                                                      ii* ^••A-:(->4'
                                                      T^     y .^ r"-*. I
                                                           Thunder'-4
                                                           r.   /r-i
Figure 36.  Existing and anticipated surface coal mining operations  in
                           Campbell County.
                                  65

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TABLE 13.   SURFACE COAL MINES PROJECTED FOR  THE  CAMPBELL  COUNTY  PORTION
                       OF THE POWDER RIVER BASIN
Mine
AMAX (Belle Ayr)
AMAX (Eagle Butte)
Carter (North Rawhide)
Carter (Cabal! o)
Cordero
Kerr-McGee (Jacobs Ranch)
Kerr-McGee (East Gillette No. 16)
ARCO (Black Thunder)
ARCO (Coal Creek)
Wyodak
Consolidation Coal Co. (Pronghorn)
ARCO (Black Thunder Expansion)
Shell Oil (Buckskin)
Kerr-McGee (East Gillette)
Carter (North Rawhide Expansion)
Carter (South Rawhide)
Mobil Oil (Rojo Cabal! o)
Other mines being planned:
Gulf Oil (Wildcat)
Peabody (North Antelope, Rochelle)
Status
Active
Under const.
Active
Under const.
Active
Active
Under const.
Active
Under const.
Active
Application
Application
Application
Application
Application
Application
Application



Projected maximum
production, million
tons per year
25
20
12
12
24
16
4
10
18
5
5
20
'4
11
12
7
15

10
5
                                 66

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                                »9 \ . 1 -" > ' • ~"    - -  ' \. ' .
                 ffia; --i^^
^H?S
J- "*•     • T v i
              ---  ^ — -_— j. -   X^* t*^-" I



             ^nv^yiJ3t5&.T"
Figure 37.  Annual average TSP concentrations (yg/m3), total dust sources
             with deposition, no background added.
                         67

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Figure 38.   Annual  average  TSP concentrations  (yg/m3),  coal
               dust sources with  deposition.
                           68

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              Si*-^ r \ t T !•'"« =V •"- - "—vi
              rf^^M ^ '•>",* - ^^
              m.€fe&^-.-vs
              ^Jf-^y^^-^f' i
              m$£*%*€*
              r^^f'.--A^'.^
Figure 39.  Annual average TSP concentrations (ug/m3), respirable
           particulate <3 ym without deposition.
                        69

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3.3  OTHER DESCRIPTIVE MODELS

     The model results presented in Subsection 3.2 were displayed
as a series of isopleth lines.  Other forms of presentation are
possible which can be more graphic in displaying certain charac-
terizations.

3.3.1  Nomograph Presentations

Emissions versus Concentrations by Air Basin—
     Two studies were performed by PEDCo Environmental (1981b;
1981c) which allow prediction of worst-case fenceline annual TSP
concentrations based on two data items likely to be available
during the preliminary planning stages of a mine.  The procedure
was developed for use as a screening tool to determine if more
detailed air quality studies were justified.  It can be applied
to surface coal mines where anticipated TSP emissions are 2500
tons/year or less.

     The dispersion component was summarized in a nomograph which
relates annual TSP emissions to maximum fenceline concentrations.
Worst-case conditions were simulated with the CDM model through
the use of air basin specific meteorological data in STAR deck
form, and the worst-case annual mine configuration over the mine
life shown in Figure 40.  Because the worst-case mine configura-
tion shown may never be realized over the mine life, overpredic-
tion may occur.  However,  this is commensurate with the proce-
dure 's intended use as a screening tool.  The methodology is
described in detail in the referenced reports.

     The results of the two PEDCo studies are summarized in
Figure 41.  The figure indicates the worst case fenceline TSP
concentrations in the three basins of interest in this report.
The solid line indicates the concentration increase from the mine
(no provision for background concentration).  The nomograph
indicates that dispersion conditions in the basin have ci strong
influence on the maximum fenceline concentration.  The dashed
lines on Figure 41 indicate the ambient concentration with the
mine in operation (increased concentration plus background con-
centration).  The great difference in background concentrations
(ranging from 15 [ig/m3 in the Powder River Basin to 32 (jg/m3 in
the San Juan Basin) further influence ambient concentrations
resulting from the same level of emissions.

Concentration Versus Distance by Mine Size—
     Nomographs have been prepared (Radian Corporation 1979)
which relate particulate concentrations to distance from the
center of the mine by mine size.  Powder River Basin mines of 2,
4, 12, and 20 million tons of coal produced per year were analyzed.
The mine configurations are not shown in the reference.  Emission
factors were derived from the EPA Region VIII Interim Policy
                               70

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                    PIT AREA
                  (1-YR PERIOD)
                        MINE
                      FACILITIES
                WORST-CASE
           WIND/STABILITY  CLASS
                 DIRECTION
                                             MINE
                                             BOUNDARY
Figure 40.   Assumed worst-case mine  configuration.
                       71

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      o>
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      CO
          80
          70
          60
          50
          40
      UJ

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          30
          20
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      x
                                                                SAN JUAN
                  X  POWDER RIVER-
                       BASIN
                                                                GREEN RIVER/
                                                                 HAMS FORK
                                                                POWDER RIVER
                                                                   BASIN
                     SAN JUAN
                                                                GREEN RIVER/
                                                                 HAMS FORK
CONCENTRATION INCREASE FROM MINE
                                     	 AMBIENT CONCENTRATION (INCREASE
                                           PLUS BACKGROUND CONCENTRATION)
                                            I
                                                       I
                      500       1000       1500       2000

                                  TSP EMISSIONS, tons/yr
                    2500
3000
Note:   Procedure not applicable when emissions  exceed  2500 tons/year.

            Figure 41.   Nomograph procedure for predicting worst-case
                           fenceline  concentration,  TSP.
                                          72

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Paper (EPA 1978).  An 85 percent control efficiency was assumed
for haul roads.  Annual emissions for the four mine sizes were
914, 1823, 4888, and 6991 tons, respectively.  Annual modeling
was performed with the CDM model modified with a source depletion
fallout function, and the RAM model with a fallout function was
used for 24-hour modeling.

     The results of the study are summarized in Figure 42.  The
figure indicates the distance from the mine center over which the
TSP Class II increment would be exceeded by mine production size.
Mine production size projected for the Powder River Basin ranges
from 4 to 25 million tons per year, averaging 12.3 million tons
per year.  Data are included for the annual Class II increment
(19 ng/m3) and the 24-hour Class II increment (37 (jg/m3).  Data
are also shown for two cases, i.e., with the inclusion of all
fugitive dust sources (same as remainder of this report), and
with the inclusion of only coal dust emissions (current inter-
pretation of existing PSD regulations).  The annual increment
would be violated at a distance from the mine center of 0.5 km to
1.8 km, depending on mine size and inclusion of only coal dust
emissions or all fugitive dust sources.  Violation of the 24-hour
increment would occur at much greater distances.  In the case of
inclusion of coal dust emissions over both averaging periods, the
distance of violation would range from less than 1.0 km to about
3.0 km.  With all fugitive emissions, violation distances from
the mine center would range from about 4.5 km to 16.0 km.  The
data indicate that inclusion of all fugitive dust emissions at
larger mines would routinely violate the 24-hour Class II incre-
ment at considerable distances beyond the mine boundary.  The
extent of violations of the annual increment and the short-term
increment with only coal dust emissions included would be depen-
dent on the location of the mine boundary.  However, the data
were derived for an isolated mine.  In the Wyoming portion of the
Powder River Basin, mines are almost never isolated and the Class
II increment would be a much greater restraint.

3.3.2  Profile Presentations

     Concentration data can also be displayed in profile form.
An example of a mine shown in Subsection 3.2 is shown in profile
format in Figure 43.  This presentation format is good for visu-
alizing the effect of distance from the source on concentrations,
as well as fenceline concentrations.  Unfortunately, it is subject
to several distortions if used improperly.  The results are
highly dependent on the cross-section used and the relationship
between the vertical and horizontal scales.

     In examination of Figure 43, it is apparent that the highest
concentrations center around the pit area.  Fenceline concentra-
tions range from 0 to 20 ug/m3.  The profile and fenceline con-
centrations are specific for the year analyzed.   They would both
change significantly during other periods of analysis.


                               73

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     18
     15
     12
              'ANNUAL CLASS II INCREMENT EXCEEDED
               24-HOUR CLASS II INCREMENT EXCEEDED
                                                     ALL FUGITIVE
                                                 .• DUST EMISSIONS
                                          __—-• COAL DUST EMISSIONS  _

                               . «"•"""                 fll I FIIRTTTur
                                                     ALL  FUGITIVE
                                                    DUST  EMISSIONS
                                                    COAL  DUST EMISSIONS
                            10
15
20
                                                            25
30
                         MINE SIZE, 10 tons coal per year
Figure 42.   Distance from mine center over which TSP  Class  II
       increment  is exceeded  in the  Powder River Basin.
                                  74

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NORTH/SOUTH CROSS SECTION
3           0

BOUNDARY    pll
     3           6

    BOUNDARY
                                                                km
                                    COAL PRODUCTION -  14 mm  tons/yr
                                    ANNUAL TSP EMISSIONS - 2126  tons/yr
EAST/WEST CROSS SECTION
            6            3

          BOUNDARY
                 6    km
        PIT
BOUNDARY
    Figure 43.  Profile presentation of a Powder River Basin mine,
                      annual TSP concentrations.
                                  75

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3.4  RELATIONSHIP OF MODELING RESULTS TO POSSIBLE AMBIENT
     STANDARDS AND THE PSD PERMITTING PROCESS

     The objectives of this study are to provide data on PM 10
and TSP concentrations around western surface coal mines suffi-
cient to assess their relationship to possible ambient standards,
and to assess the impact of the inclusion of fugitive dust and
PM 10 in the PSD permitting process.

     Most existing modeling studies allow a characterizcition of
only annual average TSP concentrations.  When mines are in isola-
tion from other particulate sources, the results suggest that
fenceline concentrations approach but would probably not violate
national or state ambient annual particulate standards.  On an
annual basis, concentrations decrease to 1 vg/m3 or less gener-
ally within 4 miles or less of the mine boundary.  However, even
with application of BACT as defined by Region VIII, the PSD Class
II annual increment of 19 ug/m3 would be violated in many cases
at the fenceline if all fugitive dust was included in the analysis.

     A study performed for hypothetical mines (Radian 1979)
suggests that the 24-hour Class II increment (with inclusion of
all dust sources) is much more restrictive than the annual incre-
ment.  Areas of exceedance of the short-term increment would be
as far as 10 miles from the mine center for a mine with an annual
production of 20,000,000 tons.

     When mines are not isolated from other particulate sources,
existing model results suggest that both the existing TSP ambient
standards and the Class II increments (with inclusion of all dust
sources) are restraining factors at the fenceline even with
application of BACT.

     A nomograph procedure (PEDCo 1981a) illustrates that ambient
concentrations resulting from a given level of emissions vary
considerably by air basin because of different dispersion condi-
tions and TSP background concentrations in western mining areas
ranging from 15 pg/m3 to 30 |jg/m3.
                               76

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                           SECTION 4.0

      CHARACTERIZATION OF PM 10 AND TSP AIR QUALITY AROUND
      WESTERN SURFACE COAL MINES USING NEW PREDICTIVE TOOLS
4.1  BACKGROUND

     Two new tools are available to improve the state-of-the-art
for predicting particulate concentrations around surface coal
mines.  The first tool is the new set of emission factors devel-
oped for EPA (PEDCo 1981a) and the second is the new Industrial
Source Complex (ISC) model (EPA 1979).  No modeling has been
performed to date using the new EPA emission factors.  However,
recent application of the ISC model to surface coal mines has
been made (TRC 1981).

     This section describes the application of these new tools to
three hypothetical mines representative of operations in three
distinct coal basins.  The three basins are the same as described
in Section 3.0 and are the Powder River, Green River/Hams Fork,
and San Juan Basins.  Annual coal production for these mines was
assumed to be 25.0, 3.6, and 6.5 million tons.  For each mine, a
detailed emission inventory was developed.  These data were then
used as input to the ISC model to predict ambient concentration
levels around the mines.
4.2  CALCULATION OF EMISSIONS

4.2.1  Annual Emissions

     The end result desired from the emission calculations was an
inventory of particulate emissions by mining operation and particle
size.

     The calculation of these data involved four sequential
steps.  First, a general checklist of mining operations expected
to generate particulate was developed as shown in Table 14.
Next, for each operation in the list, an activity parameter was
determined for each of the three hypothetical mines.  Not all of
the operations were expected to be found at each mine.  Although
the three mine scenarios were hypothetical, existing mine plans
for currently operating mines were used as examples so that the
resultant activity parameters would be physically realistic.
                               77

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TABLE 14.   MINING OPERATIONS THAT GENERATE PARTICULATE EMISSIONS
   Mining and Reclamation

        Topsoil removal
        Scraper travel - topsoil
        Topsoil dump
        Overburden drilling
        Overburden blasting
        Overburden removal
        Haul truck travel - overburden
        Overburden replacement
        Overburden shaping - dozers
        Coal drilling
        Coal blasting
        Coal loading
        Haul truck travel - coal
        Coal dump
        Dozers - coal
        Wind erosion from exposed areas
        Light- and medium-duty vehicle travel
        Road construction and maintenance - graders
        Access road travel

   Process and Transfer

        Crushing, screening, conveying
        Coal storage
        Coal loadout
                               78

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Consequently, the resulting data are representative of real world
data but should not be construed to be accurate for any particular
coal mine.  The activity parameters were developed in units
appropriate for application of the selected emission factors.
The data for each of the three hypothetical mines are shown in
Table 15.  As seen in the table, the activity parameters for the
three mines are vastly different, reflecting the different mining
and operating conditions in the three basins.

     The third step in the sequence was to develop emission
factors and control efficiencies to apply to the activity para-
meters.  The EPA 1981 emission factors were the primary reference
for factors.  These emission factors were supplemented with data
from the recent TRC study, (TRC 1981) IPP factors (EPA 1978) and
AP-42 (EPA 1980).  Base emission factors are shown in Table 16.
The independent variable values associated with these factors are
shown in Table 17.

     EPA Region VIII defined BACT practices and control efficien-
cies were also used.  Controls assumed were for access roads
(paved, 99 percent control),  haul roads (watered, 50 percent
control), coal storage (Wyoming only, enclosure, direct emission
factor), and various coal processing activities (enclosed, bag-
house, 90-99 percent control).

     The activity parameters were multiplied by the calculated
emission factors (Table 18) and control efficiencies to yield
controlled emissions (Table 19).  For sources for which EPA 1981
factors were available, emissions for TSP and 2.5 and 15 pm are
shown.  These sources constituted about half of the total number
of sources and about three quarters of the total TSP emissions.
For sources for which TRC, IPP, or AP-42 emission factors were
used, only TSP emissions are presented in Table 19.

     The fourth step was to compute the particle size distribu-
tion for each mine.  It was decided that one particle size dis-
tribution should be used for the entire mine in each basin rather
than to attempt to define a different distribution for each
operation.  This decision was made for three reasons:

1.   Particle size distribution data were not available for all
     sources.

2.   Particle size analysis of measured data in several studies
     suggest that the size distribution of the fugitive dust does
     not vary drastically from operation to operation.  Conse-
     quently, one average distribution for the entire mine was
     used.

3.   Assuming a single distribution for each mine greatly sim-
     plified the subsequent modeling analyses.
                               79

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            TABLE 15.   HYPOTHETICAL  MINE  ANNUAL ACTIVITY  PARAMETERS



Mining operation
Topsoil removal
Scraper travel - topsoil
Topsoil dump
Overburden drilling
Overburden blasting
Overburden removal

Haul truck travel
overburden
Overburden replacement
Overburden scraping - dozers
Coal drilling
Coal blasting
Coal loading
Haul truck travel - coal
Coal dump
Dozers - coal
Wind erosion
Light- and medium-duty vehicles
Graders
Access road
Crushing, screening
conveying
Coal storage
Coal loadout
Activity parameters
Powder
River
Basin
2.17
1.16
2.17
4.42
312
3.75

4.35

3.75
2.36
9.10
208
25.0
1.27
25.0
2320
310
4.58
1201
0.25
25.0

b
25.0
Green River/
Hams Fork
Basin
1.49
0.70
1.49
2.35
118
1.63

a

a
0.70
4.88
128
3.6
0.11
3.6
4640
165
0.21
327
0.15
3.6

1.0
a
San Juan
River
Basin
8.84
3.90
8.84
11.79
325
4.60

a

a
3.03
59.73
500
6.5
0.35
6.5
15167
1096
0.88
62000
2.00
6.5

5.0
a


Units per
year
wl yd3
10* VMI
ID, yd
10 holes
blasts-
lol yd6

105 VMT

ioj yd3
10!I hours
10 holes
blasts
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10* VMT
10 tons
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acr.es
10b VMT
VMT
10* VMT
10 tons

acres
10 tons
a
b
Not applicable.
Silo storage.
                                     80

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     For the purposes of this analysis it was  further  assumed
that the TSP emissions could be reasonably  approximated  as par-
ticles <30 pm in aerodynamic size.  This was a basic assumption
used to develop some of the EPA 1981 emission  factors.   Hence, it
was also used here.

     The first step in determining the distribution was  to sum
the <2.5, <15, and TSP emissions  for those  sources with  a particle
size breakdown.  Next, the <2.5,  and <15 emissions were  expressed
as a fraction of the TSP emissions.  Based  on  these fractions it
was possible to interpolate the fractions for  <5 pm and  <10  pm,
and to extrapolate the distribution to <20  pm  by assuming a
lognormal distribution.

     The mass distribution determined in this  manner was then
applied to the total TSP emissions from the mine based on the
lognormal relationship.  Table 20 presents  the final distribution
of emissions by particle size determined for each mine.

           TABLE 20.  DISTRIBUTION OF EMISSIONS BY PARTICLE SIZE
                     Cumulative emissions less than stated size, tons/year
Hypothetical mine
Powder River
Green River/Hams Fork
San Juan River
2.5 pm
166
26
157
5 pm
797
105
676
10 pm
2,383
301
1,896
15 pm
3,711
469
2,899
20 pm
4,708
610
3,653
30 pm
8,303
1,286
6,559
These distributions were used as input to the  ISCST and  ISCLT
models for predicting the annual and 24-hour mean concentrations.

     In further examination of Table 20, the emissions for the
San Juan Basin mine 6.5 million appear high when compared to the
Powder River Basin mine (25 million tons/year  of coal produced).
This is a direct result, however, of the activity parameters
assumed in the scenarios (Table 4-2).  Because of the lower coal
to overburden ratio in the San Juan Basin, it  is necessary to
disturb significantly more acres of land and cubic yards of
overburden per unit coal mine.

     The approach described above represents one possible way to
define the particle size distribution of the emissions.  Certainly
other methods could be used to produce a distribution composed of
more coarse particles or more fine particles.  The method selected
was based on the methodology used to develop the EPA 1981 emis-
sion factors.  The emissions defined by these  factors represent
about 75 percent of the total mine emissions.  As these  factors
were developed from field sampling for the particular particle
                               87

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sizes described (2.5, 15, TSP), using some other distribution
based on another type of analysis did not seem to be justified.

     In critical evaluation of the particle size distributions
shown in Table 20, these distributions are compared to particle
size distributions found by other researchers in Figure 44.  Only
a few such distributions are presented,  others are available.
All of the distributions shown in the figure represent the por-
tion of the material less than 30 (jm.  This change in the original
data was made so that the distributions could be compared directly.
A further simplification was to assume a lognormal distribution
of the data.

     The two upper curves represent the results of microscopic
analysis of open faced filters exposed near haul roads (EPA 1978;
TRC 1981).   The particle sizes represented by these two curves
are observed physical diameters.  There are four basic limita-
tions to the microscopy data that prevent their application to
measured TSP concentrations.

I.   The filters are exposed open faced.  Consequently larger
     particles are collected than would be collected with a
     hi-vol, thereby, biasing the distribution towards coarser
     particles.

2.   The distributions are based on physical rather than equiva-
     lent aerodynamic diameters.  This limitation conceivably
     creates a bias towards the finer particles.

3.   The distributions include the small sizes of particulate
     present in the background concentrations, adding an addi-
     tional bias towards the fine particles.

4.   Microscopy cannot accurately identify fine particulate (less
     than about 2 urn in physical diameter) because of the lack of
     optical resolution and because some of the fine particulate
     may be located out of view behind the larger particulate.
     Therefore, the distribution will be biased towards the
     larger, easier to perceive, particle sizes.

It is not known to what extent these biases affect the overall
distribution.

     The lower curve is a composite of ambient data obtciined with
a cascade impactor within 5 m of a haul road.  The data represent
the best attempt to correct measured data to account for one of
the serious limitations of this instrument, particle bounce
through.  Additionally, no consideration is usually given to the
density of the collected particulate or to the portion of the
distribution attributable to background.  The net effect of these
three problems is to bias the resulting distribution towards the
                               88

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3.

 ft

UJ
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    30
    20
    10
     9

     8

     7

     6

     5

     4
      1
             I   I   I     I   I    I       I

            DATA SOURCE

            '••• MICROSCOPY (EPA 1978)
                 MICROSCOPY (TRC 1981)
               STABLE 20  COMPOSITE
              —•CASCADE IMPACTOR (EPA 1981 a)
              — DICHOTOMOUS (EPA 1981a)
I    \    \    I
                I   i     II
I    I    I    I    I
     0.01     0.1     0.5  1          5   10                  50

           CUMULATIVE FREQUENCY OF OCCURRENCE, PROBABILITY, %
                                                                         80
      Figure 44.  Examples of composite particle size distributions
                  from coal mining particulate sources.
                                   89

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fine particle sizes,  drastically limiting the usefulness of data
collected with this instrument.

     The middle curve represents ambient data collected with a
dichotomous sampler near haul roads.  The virtual impaction
principle used in this instrument theoretically gives concentra-
tions for particulate with aerodynamic diameters <2.5 and <15 urn.
However, there are also several problems associated with this
instrument.  The inlet design of this device is sensitive to the
ambient windspeed requiring questionable corrections to obtain
the <15 |jm concentration.  Also, the mass of <2.5 pm particulate
routinely collected during field sampling is very near the detec-
tion limit of the gravimetric analysis method.  Additional prob-
lems are related to the filter media and handling procedures used
in fugitive dust testing.  One identifiable effect of these prob-
lems noted in a recent study (EPA 1981) was that the <2.5 pm
concentrations are artifically high by about 10 percent.  This
has the influence of biasing the 10 (jm data towards a finer
particle distribution by about 1 percent.

     In addition to the sampling biases outlined above there is
one underlying assumption that is critical to the analysis, the
assumption of the lognormal distribution.  This assumption is
especially appealing, as it greatly simplifies many aspects of
particle size analyses.  The fugitive dust generated by a single
mechanism can be approximated by the lognormal distribution,
especially for coarse (>2.5 jjm) particulate (EPA 1981).  However,
additional research needs to be performed in order to justify or
invalidate the use of this assumption.

     The sensitivity of coal mine modeling results to size dis-
tribution has not been critically analyzed.  It is an area where
additional research is needed.  Theoretically, assumption of a
distribution composed of more coarse particles than the true
distribution would result in lower initial emissions for the
smaller particle sizes and a greater amount of deposition over
distance.  The effect of this distribution would be to underesti-
mate downwind concentrations.  Conversely, assumption of a finer
distribution would be associated with greater emissions for the
smaller sizes, less particle deposition, and larger downwind
concentrations.  These concepts are displayed in Figure 45 for PM
10 or TSP.  Additional research is required in order to define
these curves.

4.2.2  Twenty-Four-Hour Emissions

     In addition to the annual emissions estimates, 24-hour emis-
sions were required for the modeling.  Unfortunately, there is no
standardized approach for determining short-term emission levels.
This has led to a wide variety of practices that further compromise
the accuracy of 24-hour modeling.  A simple procedure was developed
                               90

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                                                    FINER DISTRIBUTION
                                                    CORRECT DISTRIBUTION

                                                    COARSER DISTRIBUTION
 Figure 45.
                   DISTANCE
Theoretical impact of incorrect particle size distribution
on model-predicted PM 10 or TSP concentrations.
                                 91

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for this study to convert annual emissions to 24-hour emissions.
For all sources except blasting and wind erosion,  the annual
emissions were divided by 365 to obtain the daily average.  Then
the daily averages were increased by 25 percent to represent peak
24-hour emissions to represent worst-case activity parameters.
Other methods could have been used.  In general,  the procedure
should be standardized to facilitate a uniformity of short-term
modeling assumptions.

     For blasting it was assumed that the most blasts that would
occur in a given day were:  2 coal and 2 overburden (Powder
River); 1 coal and 1 overburden (Green River/Hams Fork);  3 coal
and 3 overburden (San Juan River).  The fraction of the annual
emissions for the 24-hour period was then calculated based on the
total number of blasts of each type for the year.

     Wind erosion emissions for 24-hours were based on the mean
number of days with <0.01 inch of precipitation.   These were 273,
275, and 285 for the three mines.  Annual wind erosion emissions
were simply divided by the number specific to scenario location.

     The same particle size distribution developed for the annual
modeling was used with the 24-hour emissions.


4.3  CALCULATION OF CONCENTRATIONS

     The ISC model was used to predict both PM 10 and TSP par-
ticulate concentrations, for annual average and 24-hour time
periods at each of the previously discussed hypothetical mines.
The goal of the simulation was to model each mine as if an air
quality permit application were being prepared.  All assumptions
and idealizations used in the modeling effort are those routinely
used by permit applicants, air quality consultants, and reviewing
agency personnel.

4.3.1  Fundamentals of the ISC Model

     The ISC dispersion model can be used to perform air quality
impact analyses for a wide variety of facilities,  including
surface coal mines.  It should be noted, however,  that certain
features of coal surface mines, such as pit retention and wet
deposition of particles, are not treated and that dry deposition
and particle reentrainment are handled somewhat simplistically.
The ISC model combines various analytical dispersion modeling
algorithms in two computer programs, a short-term version and
long-term version.  The ISC model short-term program (ISCST) is
an updated version of the EPA's CRSTER model.  The ISC model
long-term program (ISCLT), a sector-averaged model, utilizes some
of the features of two EPA UNAMAP models:  the Climatological
Dispersion Model (CDM) and the Air Quality Display Model  (AQDM).
Both programs (ISCST and ISCLT) of this comprehensive model offer


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some very useful features that are especially attractive for use
in simulating surface mines.  The feature options exercised for
this modeling task include:

     0    Emissions from a combination of area and volume sources
          with physical separation of the multiple sources.

     0    Application-defined receptor grid.

     0    Effects of gravitational settling and dry deposition.

     0    Dispersion coefficients and mixing depths for a rural
          environment.

     0    Simulation of site-specific atmospheric conditions.

The same basic dispersion model assumptions apply to both pro-
grams (ISCST and ISCLT).  The steady-state Gaussian plume equa-
tion for a continuous source is used to calculate groundlevel
particulate concentrations for point, area, and volume, sources.
The area source model is based on the dispersion equation for a
continuous and finite cross-wind line source.  This extremely
flexible model calculates particulate concentrations using se-
quential hourly meteorological data for the short-term (24-hour)
and a joint frequency distribution of windspeed, wind direction,
and Pasquill stability class for the long-term (annual) values.

     The ISC model offers some very real advantages over other
widely used dispersion models for simulating the air quality
impact of surface coal mines.  Most important, the ISC model
includes a treatment of particle settling and deposition which is
essential if concentrations of large particulate (including TSP)
are to be accurately predicted.  Secondly, the ISCLT and ISCST
programs permit a great deal of latitude in how the modeler
idealizes sources such as haul roads, coal handling facilities,
mine pits, etc., so that a surface coal mine can be approximated
more closely than with most other models.  The ability to employ
volume sources to simulate haul roads, for example, permits a
better representation of the road than do the line source or
sequential point source methods of other models.  Finally,  the
ISC's detailed meteorological input ensures that the convective
and diffusive parameters governing particulate transport will be
properly described.  A technical description of each of the
models features is contained in Appendix C.

4.3.2  Application of the ISC Model

Source Data—
     Calculation of emissions was described in Subsection 4.2.
Appendix C contains source apportionment data for the three
location scenarios (annual and 24-hour), and source characteris-
tics (number of sources, source type, source size,  a ,  and a ).


                               93

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Receptor Data—
     Model grid receptors used in the annual average ISCLT simu-
lations were placed in a uniform Cartesian coordinate system,
equally spaced at intervals of 0.5 kilometers over a range of 40
kilometers in both the N-S and E-W directions.  The hypothetical
mine sources were situated near the center of the grid array.

     Model receptors used in the 24-hour ISCST model runs were
located on Cartesian coordinates nodes confined to a 90 degree
wide sector in the predominant downwind direction of the mine.
Receptor spacing ranged from 0.5 to 2.0 kilometers in distance,
with additional random receptors situated near major mine sources
to better define peak concentrations.  The range of the receptor
array extended to roughly 30 kilometers in the downwind direction.

Meteorological Data--
     The meteorological data input to the ISCLT models included
joint frequency of occurrence of windspeed,  wind direction,  and
stability class (STAR deck) collected at surface stations in the
vicinity of the hypothetical mines:

     0    Craig, Colorado STAR data used to model Green River/Hams
          Fork Basin mine.

     °    Farmington, New Mexico STAR data used to model San Juan
          Basin mine.

     0    Moorcroft, Wyoming STAR used to model Powder River
          Basin mine.

Annual average ambient temperatures were set to 281 degrees
Kelvin for all three mines, and annual mixing heights were input
as 5,000 meters for stability classes A-D, and 10,000 meters for
stability classes E and F.  Values of vertical potential tempera-
ture gradient and wind profile power law exponents were set to
the ISCLT default values.

     For the 24-hour ISCST model runs, the combination of wind-
speed, wind direction, and stability class was chosen so as to
yield maximum groundlevel concentrations that could be reasonably
expected to occur twice in a one-year period.  Concentrations
predicted in this manner represent second-highest values, directly
comparable to existing ambient air standards.  The windspeeds and
stability classes were set equal to those identified by D. B.
Cabe as prompting peak 24-hour particulate concentrations down-
wind of surface coal mines, based on previous studies using the
RAM model (Radian 1979).  Wind directions were centered about a
mean coinciding with the major axis of each of the hypothetical
mines' sources so that as many sources as possible were in line
with the wind direction.  Individual hourly wind directions were
then randomized within a 22.5 degree sector about this mean wind
                               94

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direction.  The windspeeds, wind directions,  and  stability  classes
modeled at each of the three hypothetical mines are  shown in
Appendix C.  Like the long-term model runs,  air temperatures  were
set to 281 degrees Kelvin and mixing heights were assumed equal
to 5,000 meters.

Background Concentrations—
     The background concentrations used  in the analyses  are the
same as were used elsewhere in this report and are shown in Table
21.

               TABLE  21.  ASSUMED BACKGROUND CONCENTRATIONS
                     USED IN THE SCENARIO ANALYSIS
Bas i n
Powder River Basin
San Juan Basin
Green River/Hams
Fork Basin
Background
concentration, (jg/m3
TSP
15
32
22
PM 10
9
9
9
     Two items are of note.  First, the same background concen-
trations were used for the annual and 24-hour averaging periods.
This undoubtedly is an underestimate of the 24-hour level but no
data are available to determine a short-term background concen-
tration.  Secondly, for the reasons noted in Subsection 2.3.2,
the same background concentration for PM 10 had to be used  in all
basins.

Pit Retention—
     For all of the modeling runs, no terrain adjustments were
made to receptors or sources.  Emissions from the mine pits were
assumed to occur at groundlevel, and therefore, no correction was
made for retention of particulate matter within the pit.  These
procedures are common modeling practice.

     Lack of adjustment for pit retention is contrary to accepted
intuitive knowledge about surface coal mine particulate emission
and dispersion characteristics.  However, the technical ability
to accurately simulate the effect of pit retention is not avail-
able.  For example, while pit retention is known to occur, pre-
liminary estimates of pit retention range from about 25 to 90
percent under almost identical conditions.  Additional research
is required in order to gain the technical ability to account for
pit retention.
                               95

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Conversion of Arithmetic  Concentrations to Geometric Concentra-
tions—
     The long-term computer models  calculate arithmetic concen-
trations which, for comparison with annual geometric mean stan-
dards, must be corrected.  The commonly accepted means of con-
verting long-term modeled concentrations to geometric means is to
multiply the modeled arithmetic concentrations by a factor equal
to the ratio of measured  annual average geometric concentration
over measured annual average  arithmetic concentration.  Of course,
the value of this factor  differs according to geographic location.
A collection of characteristic factor values gathered from mea-
sured hi-vol networks  in  the  West are shown in Table 22 below:

            TABLE 22.  ANNUAL AVERAGE GEOMETRIC/ARITHMETIC TSP
               CONCENTRATIONS MEASURED BY THE HI-VOL METHOD
                    Location
                               Geom/arith
                                 factor
         Powder River Basin (Gillette, Wyo.)
         Powder River Basin (Colstrip, Mont.)
         Little America, Wyoming
         Sheridan, Wyoming
                                  0.75
                                  0.80
                                  0.86
                                  0.79
     The factor values  in  Table  22  do not differ greatly.  In
order to predict geometric mean  concentrations that are conserva-
tively high, it was decided  to use  the factor corresponding to
the Little America, Wyoming  area (0.86).   All annual average
arithmetic concentrations, both  TSP and PM 10, were multiplied by
0.86 to obtain annual geometric  means displayed in Figures 46
through 57.

4.3.3  Results

     The results of the long- and short-term modeling are dis-
played in Figures 46 through 57,  numbered as follows:
     Figure 46:

     Figure 47:

     Figure 48:

     Figure 49:

     Figure 50:

     Figure 51:

     Figure 52:

     Figure 53:
Powder River Basin, Annual  TSP

Powder River Basin, Annual  PM 10

Powder River Basin, 24-Hour TSP

Powder River Basin, 24-Hour PM 10

San Juan Basin, Annual  TSP

San Juan Basin, Annual  PM 10

San Juan Basin, 24-Hour TSP

San Juan Basin, 24-Hour PM 10
                                96

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                                                 1  yg/m3  (10 yg/m3)
                                                 5  yg/m3  (14 yg/m3)
                                                10  yg/m3  (19 yg/m3)
                                                20  yg/m3  (29 yg/m3)
                                                   yg/m3  (49 yg/m3)
                                                                  f J HIKE BOUNDARIES

                                                                  £j PIT LOCATION

                                                                  	HAUL ROAD

                                                                   A  PLANT LOCATION
NOTE:  NUMBER IN PARENTHESES INDICATES PREDICTED
       CONCENTRATION PLUS BACKGROUND CONCENTRATION

Location:   Powder River Basin
Coal production:   25 x 106 tons/year
Area disturbed:   130 acres/year
Method of overburden removal:  shovel/truck
Quantity of overburden removed:  37.5 x 106 yardVyear
Method of dust control:   water
TSP emissions:   8303 tons/year

                Figure 47.  ISC modeled annual  geometric mean PM 10
                        concentrations, Powder River Basin.
                                        98

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                        ,5 ug/m*  (16 pg/n»3)
                                               1 •
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            1  yg/m3  (33 yg/m3)
            5  yg/m3  (37 yg/m3)
           10  yg/m3  (42 yg/m3)
           20  yg/m3  (52 yg/m3)
                                                                      NINE BOUNDARIES

                                                                      f IT LOCATICH

                                                                   	HAUL ROAD

                                                                    A PLANT LOCATICK
                                                    I •«!•
NOTE:   NUMBER IN PARENTHESES INDICATES  PREDICTED
        CONCENTRATION PLUS BACKGROUND CONCENTRATION

Location:   San Juan Basin
Coal production:   6.5 x 106 tons/year
Area disturbed:   548 acres/year
Method  of  overburden removal:  dragline
Quantity of overburden removed:  46 x 106 yardVyear
Method  of  dust control:  water
TSP emissions:  6559 tons/year
               Figure 50.  ISC modeled annual geometric mean TSP
                        concentrations, San Juan Basin.
                                      101

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                                                       1  yg/m3
                                                     ^5  yg/m3
                                                     /lO  yg/m3
(10 yg/m3)
(14 yg/m3)
(19 yg/m3)
                                                                      [Tj MINE BOUNDARIES

                                                                      £j «T LOCATIOR

                                                                      —• HAUL ROW

                                                                       A PLANT LOCATION
NOTE:  NUMBER IN PARENTHESES  INDICATES  PREDICTED
       CONCENTRATION PLUS BACKGROUND  CONCENTRATION

Location:  San Juan Basin
Coal production:  6.5 x.  106 tons/year
Area disturbed:  548 acres/year
Method of overburden removal:  dragline
Quantity of overburden removed:  46 \ 106  yardVyear
Method of dust control:  water
TSP emissions:  6559 tons/year
               Figure  51.   ISC modeled annual geometric mean PM 10
                         concentrations, San Juan Basin.
                                       102

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                                                           - ug/m3
                                                          10 ug/m3
                                                          20 ug/m3
                                                          40 pg/m3
                                                          60 Lig/m3
                                                          80 Lig/m3
                              (33 Lig/m3)
                              (37 Lig/m3)
                              (52 Lig/m3)
                              (72 Lig/m3)
                              (92 ug/m3)
                              (102
                                               1 •
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                                                                ug/m» (23 ug/m3)
                                                              5 ug/m3 (27 ug/m3)
                                                             10 ug/m3 (32 ug/m3)
                                                             20 ug/m3 (42 ug/m3)
                                                                        NINE BOUNDARIES

                                                                     _J PH LOCATION

                                                                     — HAUL ROAD

                                                                     A PLANT LOCATION
NOTE:  NUMBER IN PARENTHESES  INDICATES PREDICTED
       CONCENTRATION  PLUS BACKGROUND CONCENTRATION

Location:  Green River/Hams Fork Basin
Coal production:  3.55 x 106 tons/year
Area disturbed:  70 acres/year
Method of overburden  removal:   dragline
Quantity of overburden removed:   16.3 x 106 yard3/year
Method of dust control:   water
TSP emissions:  1286  tons/year
                 Figure  53.   ISC  modeled annual geometric mean TSP
                   concentrations,  Green River/Hams Fork Basin.
                                       104

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     Figure 54:   Green River/Hams Fork Basin, Annual TSP

     Figure 55:   Green River/Hams Fork Basin, Annual PM 10

     Figure 56:   Green River/Hams Fork Basin, 24-Hour TSP

     Figure 57:   Green River/Hams Fork Basin, 24-Hour PM 10


     Table 23 indicates maximum concentration versus distance
from the mine boundary for the annual and 24-hour time periods.
Table 24 relates violations of the NAAQS and Class II PSD incre-
ments versus distance from the mine boundary.

     Total suspended particulate concentrations at the mine
boundary for the three scenarios all exceed the NAAQS and or PSD
Class II increments.  The Powder River Basin scenario violates
both the annual and 24-hour NAAQS, as well as consumes all PSD
Class II annual and 24-hour increment.  The San Juan and Green
River/Hams Fork Basin scenarios do not violate the primary or
secondary NAAQS, but do consume all of the annual and 24-hour
increment.

     PM 10 concentrations were compared only to PSD increments.
At the mine boundary, the Powder River Basin scenario consumes
all of the annual and 24-hour increment, while the Green River/
Hams Fork Basin scenario consumes all the annual increment.

     If surface mines were required to secure PSD permits, then
the TSP concentrations compated in this modeling study at all of
the scenario mines would exceed PSD increments.  Furthermore, the
modeling results suggest that PM 10 concentrations alone would
exceed PSD increments at the Powder River Basin mine and at the
Green River/Hams Fork Basin mine.

     Throughout this discussion, a key factor in judging whether
standards would be violated is the distance between the major
mine particulate matter sources and the mine boundary.  Because
concentrations of TSP, and to a lesser extent PM 10, decrease
dramatically with downwind distance, the proximity of pits and
haul roads to the mine boundary may dictate whether a violation
of standards is predicted off site.  It would be misleading to
assume that the problem of small separation distances between
pits and mine boundaries may never occur, or would occur only in
a small fraction of proposed surface coal mines, because just the
opposite is true.  Mineral recovery laws require that all of the
recoverable coal within a permit boundary be mined,  and to do
this pits and haul roads must be situated adjacent to mine bound-
aries at some point during the life of the mine.  The results of
the modeling work presented in this report suggest that mine
source and boundary configuration may be just as important a
determinant in predicting whether a mine will meet standards as
other factors such as annual production rate.
                               105

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                                                           5 pg/m3 (14 M9/«n3)
                                                          10 ng/m3 (19 pg/m3)
                                                          20 pg/m3 (29 pg/m3)
                                                          30 pg/m3 (39
                                              I •
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                                                    10 pg/m3 (19 pg/m3)
                                                    20 pg/m3 (29 pg/m3)
                                                                        NINE lOUNCMRfES

                                                                        PIT LOCATION
                                                                      w^

                                                                      — HAUL KOAO

                                                                      A nxcr LOCATION
NOTE:  NUMBER IN PARENTHESES  INDICATES PREDICTED
       CONCENTRATION  PLUS BACKGROUND CONCENTRATION

Location:  Green River/Hams Fork Basin
Coal production:   3.55  x 106 tons/year
Area disturbed:  70 acres/year
Method of overburden  removal:   dragline
Quantity of overburden  removed:   16.3 x 106 yardVyear
Method of dust control:   water
TSP emissions:  1286  tons/year
                Figure 55.  ISC modeled annual geometric mean PM 10
                       concentrations, Powder River Basin.
                                       107

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                                                           5 pg/m3 (27 pg/m3)
                                                          10 pg/m3 (32 pg/m3)
                                                          20 pg/m3 (42 pg/m3)
                                                          60 pg/ra3 (62 pg/m3)
                                               1 Bill

NOTE:  NUMBER IN PARENTHESES  INDICATES PREDICTED
       CONCENTRATION PLUS BACKGROUND CONCENTRATION

Location:  Green River/Hams Fork Basin
Coal production:   1.2 x 104 tons/day
Area disturbed:   165 acres
Method of overburden removal:  dragline
Quantity of  overburden removed:  0.56 x 10s yardVday
Method of dust control:  water
TSP emissions:   373 Ibs/h
                Figure 56.  ISC modeled 24-hour TSP concentrations,
                           Green River/Hams Fork Basin.
                                                                        HIKE IOUNOAHIES

                                                                        PIT LOCATION

                                                                        HAUL ROAD

                                                                        PLANT LOCATION
                                        108

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                                                         5 ug/m3 (14 ug/m3)
                                                        20 ug/m3 (29 M9/™3)
                                               I •
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TABLE 23.   MAXIMUM CONCENTRATION VERSUS  DISTANCE  BY  SCENARIO, pg/m3
                (NO BACKGROUND CONCENTRATION  ADDED)

Scenario
Annual concentrations
Powder River Basin
San Juan Basin
Green River/Hams
Fork Basin
Second-highest 24-hour
concentrations
Powder River Basin
San Juan Basin
Green River/Hams
Fork Basin
TSP

At
boundary

115
23
30


867
106
104

Distance from
boundary, miles
1

115
20
20


260
80
55

2

10
8
13


240
50
25

3

7
7
7


165
45
18

4

6
6
4


80
37
14

5

4
5
3


45
32
10

PM 10

At
boundary

51
16
23


289
35
30

Distance from
boundary, miles
1

40
11
15


200
30
16

2

7
7
5


45
20
11

3

6
4
4


25
18
7

4

4
3
3


16
16
4

5

3
2
2


12
12
1

                                110

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TABLE 24. VIOLATIONS OF THE NAAQS AND CLASS II PSD INCREMENTS
o
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Class II Increment
Class II Increment
Secondary NAAQS*
10
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111

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     while no direct comparisons of the new techniques (emission
factors and model) with the IPP/CDM (with fallout function) tools
could be made, it appears that the new techniques result in
higher concentrations over a larger area.  This comparison should
be studied further.  Certainly one reason for the difference is
that the EPA 1981 emission factors are higher than the IPP fac-
tors.  There is also probably a difference in fallout functions
that is also influencing comparative results.


4.4  POTENTIAL SOURCES OF ERROR IN THE PREDICTION PROCESS

     The purpose of this subsection is to identify and evaluate
sources of error in the predictive process of developing a par-
ticulate concentration.  Six error categories are presented in
Table 25.  Ideally, each potential source of error in each cate-
gory would be quantified with a ± error term.  The error cate-
gories would in turn be combined into a ± error term.  Unfor-
tunately, a complete statistical analysis has never been attempted,
and it is not within the scope of the present study.  It is an
area of recommended further research.  At this time, the sensi-
tivity of predicted concentrations to each error category is not
even known.  Therefore, this discussion will be limited to a
qualitative analysis of each error category.

     The first error category is the emission factors.  More
error analyses have been performed on this error category than
perhaps any other.  The average 80 percent confidence interval
for the 1981 EPA TSP emission factors was calculated to be -20 to
+24 percent when applied at western mines in the range of correc-
tion parameter conditions over which testing was conducted.
Error analyses for the IPP, TRC, and AP-42 emission factors have
not been performed.  As important as the uncontrolled emission
factor is the assumed control efficiency.  Since the uncontrolled
emission factor term is simply multiplied by a percentage control
term for use in the emissions calculations, each term is of equal
importance.  Control efficiency testing has been very limited and
the error band has not been comprehensively evaluated.  Other
sources of emission factor error are listed in Table 25.

     The second error category is activity parameters.  The
controlled emission factor is multiplied by an activity parameter
to estimate emissions.  The first source of error is identifying
all sources of particulate emissions.  The very different source
lists used in previous modeling exercises illustrate this problem.
The level of source activity can be extremely difficult to predict,
with predictions required for such parameters as vehicle miles
traveled, grader speed, dragline drop distance, etc.  Predictions
of activity are probably more accurate for longer averaging
periods.
                               112

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      TABLE 25.  POTENTIAL SOURCES OF ERROR IN THE PREDICTIVE PROCESS FOR
        ESTIMATING PARTICULATE CONCENTRATIONS AROUND SURFACE COAL MINES
    Error category
Emission factors
Activity parameters
Source location
Meteorological inputs
Model-related
(continued)
         Potential sources of error
Measurement error in derivation of factors
Errors in assumed values for independent
  variables
Not all factors are based on actual field
  testing
Applicability of factors to mines other
  than those tested
Assumptions in particle size distributions
Identification of independent variables
  affecting emission rates
Control effectiveness assumptions
Averaging time

Ability to predict source types
Ability to predict level of source activity
Averaging time

Ability to predict location
Ability to predict spatial extent of sources
Release height
Averaging time
Windspeed
Wind direction
Stability class
Dispersion parameters
Mixing height
Representativeness of
  area
                                                         data over entire mine
                                   Averaging time
Gaussian dispersion algorithm
Plume rise algorithm
Deposition algorithm
Effects of complex terrain
Source representation (point, area, line)
Effects of pit retention
Receptor locations relative to assumed
  source locations
Averaging time
                                     113

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TABLE 25 (continued)
    Error category
         Potential sources of error
Verification
Measurement error of ambient monitors
  vol,  particle sizing devices)
Source/receptor relationship
Representativeness of data
Quality assurance program
Conversion algorithm for model results
  (arithmetic to geometric mean)
Background concentration
Averaging time
(hi-
                                      114

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     Another error category is source location.  Sensitivity of
model results to errors in source location has not been quanti-
fied.  Overprediction or underprediction of concentrations is
possible, as well as errors in the location of predicted concen-
trations.

     Meteorological inputs are required by the dispersion model
and are the variables that determine dispersion.  There are at
least seven potential sources of error in this error category
that impact predicted concentrations to an unknown degree.

     Several semi-rigorous evaluations of model performance have
been performed.  Sources of error are listed in the table.  While
is was not possible to evaluate the overall accuracy of the model
results, it is possible to discuss the relative accuracy of
certain types of model applications.  For example:

          0    Relative versus Absolute Application:  Using
               a model as a predictive tool to project
               differences between two or more alternatives
               is inherently more accurate than attempting
               to calculate an absolute number.

          0    Magnitude versus Location:  Models generally
               predict the magnitude of a concentration more
               accurately than the precise location of that
               magnitude because of inaccuracies in the
               meteorological fields used by the models.

          0    Long-Term versus Short-Term Estimates:  The
               accuracy of calculated annual average con-
               centrations is better than calculated worst-
               case 1-, 3-, or 24-hour concentrations because
               mean value is more accurately determined than
               extreme values (National Commission on Air
               Quality 1980).

Other model-related problems that are particularly troublesome
are the inability to simulate the complex terrain often found in
surface coal mining areas, and the influence of pit retention.

     The final error category is verification.  There are two
problems that make it difficult to determine the accuracy of the
predictive process.  First, most air quality analyses are per-
formed for mine permitting.  The mine is not in operation and
therefore there are no data to use to compare predicted impact
versus actual monitored data.  The second problem relates to the
error in particulate measurement devices.  If the predictive
process were applied to an existing mine, it would still be
difficult to obtain an accurate actual term.  For example, col-
located hi-vols often yield differences of >10 percent.  Particle
                               115

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sizing instruments have equal or greater error.   The accuracy of
measured concentrations has its own associated error bounds.

     The preceding discussion illustrates that there are many
potential sources of error, any of which can be quite large.  In
order to keep the model results in proper perspective,  further
research is needed to define the uncertainty in the predicted
concentrations and the relationship of these uncertainties to the
various sources of error shown in Table 25.
4.. 5  RELATIONSHIP OF SCENARIO RESULTS TO POSSIBLE REGULATORY
     OPTIONS

     It is beyond the scope of this project to comprehensively
evaluate the relationship of the scenario results to possible
regulatory changes.  However, four regulatory options are con-
sidered briefly.  They are:

1.   Apply additional dust controls to particulate sources.

2.   Change PSD pollutant of measurement from TSP to PM 10.

3.   Apply NAAQS and/or PSD increments at some distance beyond
     the mine boundary.

4.   Change the period for comparison to standards from worst-
     case to a percentile or average period.

4.5.1  Additional Controls

     Application of additional dust controls would reduce emis-
sion levels, and consequently, concentrations.  Table 26 examines
the level of control assumed for certain sources at the Powder
River Mine and additional controls that could possibly be imple-
mented if cost and other environmental effects were totally
neglected.  For example, in the scenario analyses, controls were
assumed for only haul and access roads, and the coal preparation
facility.  Other sources are conceivably controllable, but are
usually not controlled due to the nature of the sources and the
costs associated with the controls.  The control methods and
efficiencies beyond those assumed in the scenario analysis shown
in Table 26 are purely theoretical and should not be construed as
being practical or accurate.  Additional research is needed to
determine whether or not the controls are feasible, and if fea-
sible what level of control could be achieved.  Table 26 is
included as an extreme example of the maximum level of emissions
control conceivable.

     Using a simple rollback technique, the effect of these
additional controls on predicted concentations was examined for
                               116

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117

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each of the three scenarios.  These results appear in Table 27.
Three very critical assumptions make the results only approxima-
tions:  (1) the controls, which are far greater than any in place
at an existing mine, are feasible, (2) the control efficiencies
are accurate, and (3) concentration reductions are directly
related to emission reductions.  Consequently, the results should
be considered with a high degree of skepticism.

     Even with the extreme level of control,  TSP concentrations
with the Powder River Basin scenario would be more than twice the
PSD Class II increment.  PM 10 concentrations would also consume
all of the PSD Class II increment.

4.5.2  Change PSD Pollutant of Measurement from TSP to PM 10

     Repeated reference throughout the report has been made to
the possibility of changing the PSD pollutant of measurement from
TSP to PM 10.  Because PM 10 concentrations are significantly
lower than TSP concentrations, this has the affect of making the
PSD increments less restrictive.

     Tables 23 and 24, which summarize the scenario analysis,
indicate that PM 10 at two of the three mines examined would
still consume all of the increment at the mine boundary, although
by a much smaller margin than if TSP concentrations were used for
the comparison.  Certainly, however, more mines could obtain PSD
permits if this change was made.

4.5.3  Apply NAAQS and/or PSD Increments at some Distance Beyond
       the Mine Boundary

     Another possible regulatory option is to apply the NAAQS
and/or PSD increments at some distance beyond the mine boundary.
Possible justifications are that high concentrations decrease
rapidly with distance, and that the worst-case conditions (where
major dust producing activities are adjacent to the boundary
resulting in maximum off-site concentrations) may not be indica-
tive of concentrations over the mine life.

     It would probably be difficult to use this concept, for
application of the NAAQS since they are health-related standards.
Public access would be possible to areas where concentrations
exceeded healthful concentrations.  Conversely, if the PSD pro-
gram is viewed as a resource allocation program (as opposed to
protecting human health), is may be reasonable to apply the
increment consumption determination at some distance beyond the
boundary.

     The consequences of applying the increment determination  at
distances beyond the mine boundary can be examined by refering to
the results of the scenario analysis summarized in previously
                               118

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             TABLE 27.   IMPACT OF ADDITIONAL PARTICIPATE CONTROLS
                      ON MAXIMUM OFF-SITE CONCENTRATIONS
Scenario
Powder River Basin
San Juan Basin
Green River/Hams
Fork Basin
Parameters from scenario
analysis
TSP
emissions,
tons/year
8303
6559
1286
Max. annual
off-site
concentration,
(jg/m3
TSP
115
23
30
PM 10
51
16
23
Parameters with additional
controls
TSP
emissions,
tons/year
3353
3752
764
Max. annual
off- site ,
concentration,
Mg/m3
TSP
46
13
18
PM 10
21
9
14
   Additional controls listed in Table 4-13.   Control  may be prohibitively
.   expensive or have adverse environmental  impacts.
   Based on rollback method, not dispersion modeling.   Results  should be
   regarded as preliminary and approximate.
                                     119

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cited Table 24.  Regarding TSP concentrations,  the 24-hour incre-
ment would still be a restraint as far as four to five miles
beyond the mine boundary.  However,  if PM 10 concentrations were
used to compare to increment consumption, a two mile buffer
around a mine boundary would allow even the Powder River Basin
scenario mine to receive a permit.

4.5.4  Change the Period for Comparison to Standards from Worst-
       Case to a Percentile or Average Period

     Several of the analyses in this report have shown that
worst-case off-site concentrations occur when the major dust-
producing activities are located adjacent to the mine boundary.
During this period, off-site concentrations can be two to three
times greater than when the major dust-producing activities are
not near the mine boundary.  Thus some period shorter than the
mine life dictates maximum concentrations that will be permitted
throughout the mine life.

     The percentage of the time that the major dust producing
activities, such as the pit, are adjacent to the mine boundary,
is a function of several parameters.  These include the shape of
the mine (square versus long and narrow), regularity of boundaries,
ratio of the pit area to the size of the mine,  and mining method.
Virtually no two mines would be the same, and many would not even
fall within the same range.

     After a very preliminary analysis, the system appears to be
impossible to implement during the preliminary mine planning
stages.  After the pit locations have been delineated, the com-
putational procedure would be extremely cumbersome.
                               120

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                           SECTION 5.0

   SYNTHESIS OF THREE APPROACHES TO CHARACTERIZE PM 10 AND TSP
          AIR QUALITY AROUND WESTERN SURFACE COAL MINES



5.1  INTRODUCTION

     Three approaches to characterizing PM 10 and TSP air quality
around western surface coal mines are utilized in this report.
ideally, a direct comparison of results from the three methods
would be applied to several existing identifiable mines, i.e.,
monitoring, IPP/CDM modeling results, and EPA 1981/ISC modeling
results could be directly compared.  Unfortunately, this could
not be accomplished with existing data.  No mine was found that
had coincident measured and modeled concentration data.  The
comparative study would be useful but additional monitoring data
are required before the comparisons could be made (see Section
6.0, Need for Further Study).  Some limited comparisons are made
below.
5.2  COMPARISON OF ALTERNATE APPROACHES

     A comparison of the three alternate approaches is presented
in Figures 58 and 59.  The data plotted in these figures repre-
sent maximum mine boundary concentrations as a function of annual
production.  Background concentrations have been removed from all
data so that the results could be compared.

     The results are in relative agreement when considering the
possible causes of data scatter.  These are:

1.   Maximum boundary concentrations vary over time and are only
     an approximate indicator of air quality impact since both
     total emissions and resulting concentrations are a function
     of a number of variables:  annual production,  mine configura-
     tion, acres disturbed per year, and other factors.

2.   Ambient monitors are seldom located to measure maximum
     fenceline concentrations.  This would cause the monitored
     data to appear lower than the model results.

3.   The previous modeling and scenario modeling used different
     emission factors and models.
                               121

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MAXIMUM ANNUAL CONCENTRATION AT MINE BOUNDARY, ANNUAL GEOMETRIC MEAN,
ug/m3 (NO BACKGROUND CONCENTRATION ADDED)
PM 10 TSP
rv> j> CTI INS J> 
-------
1
1
200
1
| 150
1
Q£ 0.
ISs £ 100
ig
0 Q
CD 
-------
     Figures 58 and 59 are a graphic summary of the conclusions
set forth in Sections 2.0 through 4.0.  The NAAQS are constraining
only for very large mines.  The PSD Class II increments are
considerably more constraining, particularly the 24-hour incre-
ments .
                               124

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                           SECTION 6.0

                     NEED FOR FURTHER STUDY



     The need for further research became apparent at several
points in the study.  The importance of the problem is related to
(1) the proximity of western surface coal mines to Class I lands
and other areas of relatively pristine air quality; and (2) the
importance of the surface coal mining industry to the nations
energy and economic welfare.

     Further study can be divided into five broad categories.
These are:

1.   Additional monitoring.

2.   Analysis of deficiencies in the predictive process.

3.   Impact of additional particulate control measures and alter-
     nate mine configurations on concentrations.

4.   Standardized methods.

5.   Regulatory implications.

6.   Development of better PM 10 measurement methods.

A brief outline of study for each category is presented in this
section.



6.1  ADDITIONAL MONITORING

     Additional monitoring and monitoring methods are required to
meet three objectives.  These are:

     0    Quantify pit retention.  The impact of pit retention,
          while acknowledged in principle by most investigators,
          has not been conclusively quantified.  No allowance for
          pit retention is allowed in the permitting process.  It
          is desirable to quantify pit retention so that impacts
          are not overpredicted.
                               125

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     0    Monitor PM 10 concentrations.   PM 10 sampling data are
          very limited.  Monitored PM 10 data are required at
          impacted and background sites  to adequately characterize
          PM 10 concentrations around surface coal mines.

     0    Measure the change in concentration with distance and
          model validation.  There are very little sampling data
          to measure the change in concentration over distance.
          Theoretical dispersion models  have been used to  simu-
          late deposition.  Measured particle size specific
          values could be used to validate dispersion models.

     Such a monitoring program could best be carried out in the
Powder River Basin where the largest monitored TSP data base
exists.  PM 10 monitors could be collocated at existing TSP
monitoring locations.  Other collocated  samplers could be  located
around pits, at mine boundaries, and beyond.  Such a sampling
array at one to three mines would allow  achievement of all three
objectives.
                          t


6.2  DEFICIENCIES IN THE PREDICTIVE PROCESS

     The predictive process for projecting particulate concen-
trations is a multistep process.  Six error categories are emis-
sion factors, activity parameters, source locations, meteorological
inputs, dispersion modeling (including deposition and pit  reten-
tion), and model verification.  Within each error category are
several sources of error (see previously cited Table 2l).   Ideally,
potential source of error in each category would be quantified
with a ± error term.  All sources of error would then be combined
into a ± error term which described the  reliability of the predic-
tive process.  This analysis has never been conceived of in this
comprehensive form.

     The error analysis should be undertaken for annual predic-
tions and for 24-hour predictions.  It is likely that short-term
predictions are considerably less accurate than annual predic-
tions.  The error associated with 24-hour predictions may invali-
date their legitimate use for determining compliance with stan-
dards .
6.3  IMPACT OF ADDITIONAL CONTROL MEASURES AND ALTERNATE MINE
     CONFIGURATIONS ON CONCENTRATIONS

     The scenario analysis in this report was performed based on
a specified level of control measures and assuming certain mine
configurations.  The sensitivity of concentrations to incremental
changes in particulate controls, and to changes in mine configura-
tion, has never been comprehensively analyzed.  The objective of
                               126

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this research would be to identify the principles that would
allow optimization of mine controls and layout from an air quality
perspective.


6.4  STANDARDIZED METHODS

     All new mines must apply for various air quality related
permits at the state and/or federal levels.  Issuance of the
permits is usually contingent upon prediction of air quality
levels and attainment of standards.  While the standards are
relatively uniform across the county, the method to predict
concentrations is not standardized.

     This is particularly critical for short-term predictions and
would be critical for PM 10 predictions if they were required.
To illustrate with 24-hour predictions, guidance is required on
how to define 24-hour meteorological conditions, 24-hour activity
parameters, and source locations.  Variation in practice for
these three parameters alone can result in differences in projected
concentrations by several orders of magnitude for the same mine.
This would nullify the creditibility of regulatory review.
Likewise, an initial particle size distribution is very important
to PM 10 predictions, as well as several other possible variations
in the analysis procedure.


6.5  REGULATORY IMPLICATIONS

     A number of regulatory changes are currently being explored
by EPA and others.  The changes revolve primarily around a par-
ticle size specific standard for the NAAQS and/or PSD process,
and fugitive emissions and the PSD process.  These regulatory
changes have high potential to drastically impact the ability of
a new mine to obtain the necessary permits, and may also influence
existing mines.

     The regulatory impact on the following parameters should be
investigated as a minimum.

     0    Coal production by region.

     0    Coal production costs

     0    Impact on ambient concentrations near mines.

     0    Impact on Class I lands.

     0    Economic impact.
                               127

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                           REFERENCES
Burt.  1977.  Valley Model User's Guide.

Environmental Protection Agency.  1978a.   Interim Policy Paper on
the Air Quality Review of Surface Mining Operations.   Environmental
Protection Agency, Region VIII,  Denver,  Colorado.

Environmental Protection Agency.  1978b.   User's Guide for PAL.
EPA-600/4-78-013.

Environmental Protection Agency.  1978c,   User's Guide for RAM.
EPA-600/8-78-016a.

Environmental Protection Agency.  1979.   Industrial Source Complex
(ISC) Dispersion Model User's Guide.  EPA-450/4-79-031.

Environmental Protection Agency.  1980.   Compilation of Air
Pollutant Emission Factors.  Third Edition,  AP-42.

Environmental Research & Technology, Inc.  1979.  A comparison of
Alternate Approaches for Estimation of Particulate Concentrations
Resulting from Coal Strip Mining Activities in Northeastern
Wyoming.  Prepared for U.S. Department of Energy.

National Commission on Air Quality.  1980.  Summary Report of the
NCAQ Atmospheric Dispersion Modeling Panel Volume 1,  Recommenda-
tions.  NTIS Publication No. PB80-174964.

PEDCo Environmental, Inc.  1978.  Survey of Fugitive Dust from
Coal Mines.  Prepared for Environmental Protection Agency, Region
VIII, Denver, Colorado.

PEDCo Environmental, Inc.  1981a.  Improved Emission Factors for
Fugitive Dust from Western Surface Coal Mining Sources.

PEDCo Environmental, Inc.  1981b.  Nomograph Method for Determining
Impact of TSP Concentrations Resulting from Surface Coal Mining
in Colorado.

PEDCo Environmental, Inc.  1981c.  Nomograph Method for Determining
Impact of TSP Concentrations Resulting from Surface Coal Mining
in Wyoming.
                               128

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I
I        Radian Corporation.  1979.  Influence of Alternate Definitions of
         Exempt Fugitive Dust Sources on the Impact of PSD Regulations on
.        Surface Coal Mines.

*        State of Wyoming, Division of Air Quality.  1979.  Guideline for
         Fugitive Dust Emission Factors for Mining Activities.
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         TRC Environmental Consultants, Inc.  1981.  Coal Mining Emission
         Factor Development and Modeling Study.

         Turner.  1969.  Workbook of Atmospheric Dispersion Etimates.  PHS
         Publication No. 999-AP-26.
                                        129

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                    APPENDIX A

MASS FRACTION CALCULATIONS DERIVED FOR SECTION 2.0
   PROCEDURE TO INFER PM 10 CONCENTRATIONS FROM
                 MEASURED TSP DATA
                        130

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ISCST RESULTS, 0-2.5
       (H9/m3)
STABILITY
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
WIND
SPEED (nips)
0.75



2.50



4.30



6.80 *



9.50



12.50



1000m
16.2
69.61
131.68
245.3
4.86
20.88
39.50
73.56
2.83
12.14
22.97
42.77
1.79
7.68
15.19
27.04
1.28
5.50
10.39
19.36
0.97
4.18
7.90
14.71
1500
4.98
32.28
^68.38
58.95
1.50
9.68
20.51
47.67
0.87
5.63
11.92
27.71
0.55
3.56
7.89
17.52
0.39
2.55
5.40
12.54
0.30
1.94
4.10
9.53
2000
2.47
21.19
46.16
115.08
0.74
6.36
13.85
34.51
0.43
3.70
8.05
20.06
0.27
2.34
5.33
12.69
0.19
1.67
3.64
9.08
0.15
1.27
2.77
6.90
3000
1.08
12.39
28.59
77.84
0.32
3.72
8.58
23.34
0.19
2.16
4.99
13.57
0.12
1.37
3.30
8.58
0.085
0.98
2.26
6.14
0.065
0.74
1.72
4.67
4500
0.84
6.90
18.24
56.16
0.25
2.07
5.47
16.84
0.15
1.20
3.18
9.79
0.092
0.76
2.10
6.19
0.066
0.54
1.44
4.43
0.050
0.41
1.09
3.37
7000
0.60
3.25
10.36
39.81
0.18
0.97
3.11
11.94
0.10
0.57
1.81
6.94
0.066
0.36
1.20
4.39
0.048
0.26
0.82
3.14
0.036
0.19
0.62
2.39
10,000
0.45
1.67
6.03
28.49
0.13
0.50
1.81
8.54
0.08
0.29
1.05
4.97
0.049
0.18
0.70
3.14
0.035
0.13
0.48
2.25
0.027
0.10
0.36
1.71
15,000
0.32
0.77
3.07
18.11
0.10
0.23
0.92
5.43
0.06
0.13
0.54
3.16
0.035
0.085
0.35
2.00
0.025
0.061
0.24
1.43
0.019
0.046
0.18
1.09
20,0
0.25
0.44
1.86
12.58
0.07
0.13
0.56
3.77
0.04
0.77
0.33
2.19
0.02;
0.04S
0.22
1.39
0.02Q
0.035
0.15
0.99
0.015
0.026
0.11
0.75
        131

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ISCST RESULTS,  2.5-5
       (pg/m3)
STABILITY

A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
WIND
SPEED (nips)

0.75



2.50


A. 30


6.80 *


9.50



12.50



1000m

16.13
69.28
131.09
244.53
4.84
20.78
39.31
73.24
2.81
12.08
22.86
42.57
1.78
7.64
15.12
26.91
1.27
5.47
10.34
19.26
0.97
4.16
7.86
14.64
1500

4.96
32.13
68.09
158.79
1.49
9.64
20.41
47.49
0.87
5.60
11.87
27.59
0.55
3.54
7.85
17.44
0.39
2.54
5.37
12.48
0.30
1.93
4.08
9.49
2000

2.45
21.09
45.97
115.02
0.74
6.33
13.78
34.39
0.43
3.68
8.01
19.98
0.27
2.33
5.30
12.63
0.19
1.66
3.63
9.04
0.15
1.27
2.76
6.87
3000

1.07
12.33
28.47
77.80
0.32
3.70
8.54
23.26
0.19
2.15
4.96
13.51
0.12
1.36
3.28
8.54
0.084
0.97
2.25
6.11
0.064
0.74
1.71
4.65
4500

0.83
6.87
18.16
56.11
0.25
2.06
5.44
16.78
0.14
1.20
3.17
9.75
0.091
0.76
2.09
6.16
0.065
0.54
1.43
4.41
0.050
0.41
1.09
3.35
7000

0.59
3.23
10.31
39.74
0.18
0.97
3.09
11.89
0.10
0.56
1.80
6.91
0.065
0.36
1.19
4.37
0.046
0.26
0.81
3.13
OJ035
0.19
0.62
2.38
10,000

0.43
1.66
6.00
28.41
0.13
0.50
1.80
8.51
0.07
0.29
1.05
4.95
0.047
0.18
0.69
3.13
0.034
0.13
0.47
2.24
OJ026
0.10
0.36
1.70
15,000

0.29
0.76
3.05
18.03
0.09
0.23
0.92
5.41
0.05
0.13
0.53
3.14
20,000
i
0.20
0.44
1.85
12.51
0.06
0.13
0.56
3.76:
0.0401
0.07
0.32
2.18
0.03U 0.02
0.081 0.04
0.35
1.99
0.02'
OJD6(
0.24
1.42
OJDI:
OJ04(
- 0.21
1.38
0.016
0.03.'
0.15
0.99
cm:
0.021
0.181 0.11
1.081 0.75
        132

-------
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ISCST RESULTS,  5-10  \*m

STABILITY
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
WIND
n .L^IX/
SPEED (ops)
0.75



2.50



4.30


6.80 '



9.50



12.50



1000m
15.08
64.79
122.76
230.10
4.52
19.43
36.7
68.60
2.63
11.29
21.37
39.84
1.66
7.14
14.13
25.18
1.19
5.11
9.67
18.02
0.90
3.88
7.34
13.69

1500
4.63
30.05
63.81
150.11
1.39
9.01
19.10
44.56
0.81
5.24
11.10
25.85
0.51
3.31
7.34
16.33
0.37
2.37
5.02
11.68
0.28
1.80
3.82
8.87

2000
2.29
19.72
43.05
108.69
0.69
5.91
12.89
32.28
0.40
3.44
7.49
18.72
0.25
2.17
4.95
11.82
0.18
1.56
3.39
8.46
0.14
1.18
2.58
6.43

3000
0.99
11.53
26.64
73.22
0.30
3.46
7.98
21.83
0.17
2.01
4.64
12.67
0.11
1.27
3.07
8.00
0.07J
0.91
2.10
5.72
0.05<
0.69
1.60
4.35

4500
0.73
6.42
16.97
52.42
0.22
1.93
5.09
15.74
0.13
1.12
2.96
9.14
0.08
0.71
1.96
5.77
0.057
0.51
1.34
4.13
0.044
0.39
1.02
3.14

7000
0.44
3.02
9.63
36.66
0.13
0.91
2.89
11.14
0.08
0.53
1.68
6.47
0.049
0.33
1.11
4.09
0.035
0.24
0.76
2.93
0.027
0.18
0.58
2.22

10,000
0.25
1.56
5.50
'5.85
0.07
0.47
1.68
7.96
0.04
0.27
0.98
4.63
0.028
0.17
0.65
2.93
0.020
0.12
0.44
2.09 -
0.015
0.093
0.34
1.59

15,000
0.10
0.71
2.85
16.0
0.03
0.21
0.86
5.05
0.018
0.12
0.50
2.94
0.011
0.079
0.33
1.86
0.0082
0.056
0.23
1.33
OJ3062
0.043
0.17
1.01

20,00
0.05
0.41
1.73
10.90
0.01
0.12
0.52
3.50
0.008
0.071
0.30
2.04
0.0054
0.045
0.20
1.29
0.0038
0.032
0.14
0.92
OJ0029
0.025
0.10
0.70
        133

-------
ISCST RESULTS, 10-15
       (M9/ni3)
STABILITY
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
WIND
SPEED (mps)
0.75



2.50



4.30



6.80 -



9.50


12.50


1000m
14.35
61.73
117.27
222.05
4.31
18.49
35.03
65.59
2.50
10.75
20.35
38.02
1.58
6.70
13.46
24.00
1.13
4.86
9.20
17.17
0.86
3.70
6.99
13.04
1500
4.41'
28.62
60.91
144.81
1.32
8.58
18.21
42.76
0.77
4.99
10.57
24.73
0.49
3.15
7.00
15.59
0.35
2.26
4.78
11.14
0.26
1.71
3.63
8.46
2000
2.18
18.77
40.97
103.38
0.65
5.63
12.29
30.97
0.38
3.27
7.14
17.92
0.24
2.07
4.72
11.20
0.17
1.48
3.23
8.07
0.13
1.13
2.45
6.13
3000
0.94
10.95
25.21
67.21
0.28
3.29
7.60
20.89
0.16
1.91
4.42
12.11
0.10
1.21
2.92
7.64
0.07'
0.87
2.00
5.46
0.05<
0.66
1.52
4.15
4500
0.66
6.09
L5.97
45.54
0.20
1.83
4.85
15.00
0.12
1.07
2.82
8.72
0.073
0.67
1.86
5.51
0.052
0.48
1.27
3.94
0.040
0.37
0.97
2.99
7000
0.37
2.87
9.01
29.22
O.lll
0.86
2.75
10.53
0.064
0.50
1.60
6.16
0.040
0.32
1.06
3.90
0.029
0.23
0.72
2.79
0.022
0.17
0.55
2.12
10,000
0.18
1.48
5.22
i8.73
0.05
0.44
1.60
7.46
0.032
0.26
0.93
4.40
0.020
0.16
0.62
2.79
0.014
0.12
0.42
2.00
0.011
0.089
0.32
1.52
15,000
0.07
0.68
2.65
9.92
0.02
0.20
0.81
4.66
0.011
0.12
0.47
2.78
OJ0073
0.075
0.31
1.77
0.0052
0.054
0.21
1.27
OD039
0.041
0.16
0.96
20.00C
0.03
0.39
1.60
5.80
0.01
0.12
0.49
3.19
0.00!
0.06*
0.29
1.92
OJ003
0.04:
0.19
1.23
o.oo:
0.03
0.13
0.88
OJOO
0.02
O.OS
0.6:
        134

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ISCST RESULTS,  15-20 pm
.
STABILITY
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
1 A
B
C
D
A
B
C
D
WIND
" JLtvU
SPEED (taps)
0.75



2.50


4.30


*
6.80



9.50



12.50




1000m
14.03
60.42
115.13
220.51
4.21
18.09
34.30
64.54
2.45
10.51
19.91
37.31
1.55
6.64
13.16
23.52
1.11
4.76
9.00
16.81
0.84
3.61
6.84
12.76

1500
4.31
27.95
59.33
139.50
1.29
8.39
17.83
42.18
0.75
4.88
10.35
24.34
0.48
3.08
6.84
15.31
0.34
2.21
4.68
10.93
0.26
1.68
3.55
8.29

2000
2.13
18.28
39.50
94.14
0.64
5.50
12.02
30.45
0.37
3.20
6.98
17.62
0.24
2.02
4.62
11.09
0.17
1.45
3.16
7.92
0.13
1.10
2.40
6.01

3000
0.91
10.64
23.93
54.22
0.27
3.22
7.43
20.34
0.16
1.87
4.32
11.88
0.10
1.18
2.86
7.50
0.072
0.85
1.95
5.35
0.055
0.64
1.49
4.06

4500
0.63
5.91
L4.93
30.64
0.19
1.79
4.72
L4.37
0.11
1.04
2.75
8.51
0.070
0.66
1.82
5.39
0.050
0.47
1.25
3.86
0.038
0.36
0.95
2.93

7000
0.34
2.78
8.31
14.85
0.10
0.84
2.68
9.83
0.059
0.49
1.56
5.96
0.037
0.31
1.03
3.80
0.027
0.22
0.71
2.73
0.020
0.17
0.54
2.07

10,000
0.16
1.43
4.76
7.00
0.05
0.43
1.55
6.77
0.028
0.25
0.91
4.21
0.018
0.16
0.60
2.71
0.013
0.11
0.41
1.95
0.0096
0.087
0.31
1.48

15,000
0.06
0.66
2.39
2,22
0.02
0.20
0.79
4.04
0.0097
0.12
0.46
2.62
0.0062
0.073
0.31
1.71
OJD044
0.052
0.21
1.23
OJ0033
0.040
0.16
0.94

20,00
0.02
0.38
1.43
0.79
0.01
0.11
0.48
2.64
OJ0043
0.066
0.28
1.78
0.0027
0.042
0.19
1.18
OJ0019
0.030
0.13
0.85
OJ0015
0.023
0.097
0.65
        135

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ISCST RESULTS, 20-30

STABILITY
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
WIND
SPEED (mps)
0.75



2.50



4.30



6.80 *



9.50



12.50




1000m
13.38
57.70
110.22
213.19
4.01
17.27
32.83
62.34
2.33
10.03
19.03
35.87
1.48
6.34
12.57
22.56
1.06
4.54
8.59
16.10
0.80
3.45
6.53
12.21

1500
4.11
26.38
54.47
112.25
1.23
8.00
17.04
40.51
0.72
4.65
9.89
23.45
0.45
2.94
6.53
14.73
0.32
2.10
4.47
10.50
0.25
1.60
3.39
7.95

2000
2.03
17.09
34.70
58.46
0.61
5.25
11.44
28.69
0.35
3.05
6.67
16.89
0.22
1.93
4.41
10.66
0.16
1.38
3.01
7.60
0.12
1.05
2.29
5.76

3000
0.86
9.84
19.71
19.87
0.26
3.06
7.02
18.31
0.15
1.78
4.12
11.22
0.095
1.13
2.73
7.16
0.068
0.81
1.86
5.13
0.062
0.61
1.42
3.89

4500
0.58
5.43
LI. 58
5.15
0.17
1.70
4.44
.2.06
0.10
0.99
2.62
7.85
0.064
0.63
1.74
5.11
0.046
0.45
1.19
3.68
0.035
0.34
0.90
2.80

7000
0.29
2.54
6.08
0.75
0.09
0.80
2.50
7.41
0.050
0.47
1.48
5.30
0.032
0.30
0.98
3.55
0.022
0.21
0.67
2.58
0.017
0.16
0.51
1.97

10,000
0.13
1.31
3.34
0.096
0.04
0.41
1.45
4.53
0.022
0.24
0.86
3.59
0..014
0..15
0.57
2.48
0.010
0.11
0.39
1.83
OJ0076
0.083
0.30
1.40

15,000
0.04
0.60
1.60
0.0034
0.01
0.19
0.73
2.21
OX)073
0.11
0.44
2.09
0.0046
0.070
0.29
1.52
OJ0033
0.050
0.20
1.14
0.0025
0.038
0.15
0.88

20,000
0.02 ,
0.35
0.94
OJ0001J
0.01
0.11
0.44
1.20
OJ0032
0.063
0.26
1.33
0.0020
0.040
0.18
1.02
0.0014
0.029
0.12
0.78
OJ0011
0.022
0.092
0.61
         136

-------
                 APPENDIX B


   COMPUTATION OF PM 10, PM 5, AND PM 2.5
MASS FRACTIONS AT VARIOUS DOWNWIND DISTANCES
          FOR SECTION 2.0 PROCEDURE
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I

-------
                      STABILITY; 4.30 m/s WINDS; 1000 m
 Size range
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5p
5. Op
10. Op
15. Op
20. Op
30. Op
I < 2.5p
 total

I < 5. Op
 total

I < 10.Op
  total
  0.090
  3.768

  0.401
  3.768

  1.101
  3.768
             X/QCsnf1)
                         4.28
                         4.26
                         3.98
                         3.80
                           73
                         3.59
0.024


0.106


0.292
                     Mass fraction

                         0.021
                         0.073
                         0.176
                         0.148
                         0.115
                         0.467
X (pg/m3)

  0.090
  0.311
  0.700
  0.562
  0.429
  1.676

  3.768
                      STABILITY; 4.30 m/s WINDS; 1500 m
 Size range
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5p
5. Op
10. Op
15. Op
20. Op
30. Op
I < 2.5p
 total

I < 5.Op
 total

I < 10.Op
  total
= 0.024


= 0.105


  0.291
             X/QCsnf1)

               2.77
               2.76
               2.59
               2.47
               2.43
               2.35
                     Mass fraction

                         0.021
                         0.073
                         0.176
                         0.148
                         0.115
                         0.467
X (pg/m3)

  0.058
  0.201
  0.456
  0.366
  0.279
  1.097

  2.457
                                     138

-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
 Size range

   0 - 2.5n
 2.5 - 5.OH
 5.0 - 10.OH
10.0 - 15.OH
15.0 - 20.OH
20.0 - 30.OH
  < 2.5M  _
 total

I < 5.OH
 total

i < 10.OH
  total
          = 0.024
= 0.106
= 0.292
 Size range
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5n
5. OH
10. OH
15. OH
20. OH
30. OH
                     D
                      STABILITY; 4.30 m/s WINDS; 2000 m
                       X/QCsm"1)
                         2.
                         2.
                         I.
                         I.
                         I.
                 01
                 00
                 87
                 79
                 76
                         1.69
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
                     D
                      STABILITY; 4.30 m/s WINDS; 3000 m
             X/QCsm"1)
                         1.
                         1.
                         1.
                         1.
                         1.
                 36
                 35
                 27
                 21
                 19
                         1.12
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
I < 2.5|j
 total

i < 5. OH
 total

i < IO.QIJ
  total
  0.024


  0.107


  0.295
                                     139
0.042
0.146
0.329
0.265
0.202
0.789

1.773
0.028
0.098
0.224
0.179
0.137
0.523

1.190

-------
                      'STABILITY; 4.30 m/s WINDS; 4500 m
 Size range

   0 - 2.5|j
 2.5 - 5.Op
 5.0 - 10.0(j
10.0 - 15. Op
15.0 - 20.OH
20.0 - 30.OH
I < 2.5n
 total

I < 5.OH
 total

I < 10.Op
  total
0.024


0.108


0.298
           X/QCsnf1)

             0.979
             0.975
             0.914
             0.872
             0.851
             0.785
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
0.020
0.071
0.161
0.129
0.098
0.367

0.846
                     D
                      STABILITY; 4.30 m/s WINDS; 7000 m
 Size range

   0 - 2.5n
 2.5 - 5. OH
 5.0 - 10.OH
10.0 - 15.OH
15.0 - 20.OH
20.0 - 30.OH
           X/QCsm"1)
             0.694
             0.691
             0.647
             0.616
             0.596
             0.530
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
0.014
0.050
0.114
0.091
0.068
0.248

0.586
 total
          = 0.025
I < 5. Op
total
I < 10. OH
01 ~i T
. ill
= n ^rm
                                     140

-------
I
 Size range

   0 - 2.5M
 2.5 - 5.0M
 5.0 - 10.OM
10.0 - 15.OM
15.0 - 20.OM
20.0 - 30.OM
              Size  range
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5M
S.OM
10. OM
15. OM
20.0|j
30.0(j
                                 'STABILITY; 4.30 ra/s WINDS;  10,000  m
                                   X/QCsnf1)

                                      0.497
                                      0.495
                                      0.463
                                      0.440
                                      0.421
                                      0.359
                    Mass fraction

                        0.021
                        0.073
                        0.176
                        0.148
                        0.115
                        0.467
                          0.010
                          0.036
                          0.081
                          0.065
                          0.048
                          0.168

                          0.409
I < 2.5u
total
I < 5. On
total
I < 10. On
total
— n noc
— U. U
-------
                    D
                     STABILITY; 4.30 m/s WINDS; 20,000 m
 Size range

   0 - 2.5|j
 2.5 - 5. Op
 5.0 - 10.Op
10.0 - 15.OM
15.0 - 20.0|j
20.0 - 30.0|j
I < 2.5p
 total

i < S.QM
 total

I < 10.Op
  total
0.027


0.122


0.337
           X/QCsm"1)
             0.219
             0.218
             0.204
             0.192
             0.178
             0.133
                  Mass fraction

                      0.021
                      0.073
                      0.176
                      0.148
                      0.115
                      0.467
                        X (pg/m3)

                          0.004
                          0.016
                          0.036
                          0.028
                          0.020
                          0.062

                          0.167
                     0
                      STABILITY; 2.50 m/s WINDS; 1000 m
 Size range

   0 - 2.5p
 2.5 - 5.Op
 5.0 - 10.Op
10.0 - 15.Op
15.0 - 20.Op
20.0 - 30.Op
           X/QCsm"1)
I < 2.5p
total
I < 5. Op
total
I < 10. Op _
total
0.024
0.106
0.291
             7.
             7.
 ,36
  32
6.86
6.56
6.45
6.23
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
X (pg/m3)

  0.154
  0.534
  1.207
  0.971
  0.742
  2.909

  6.518
                                     142

-------

                      'STABILITY;  2.50 m/s WINDS;  1500 m
  Size  range
           X/QCsnf1)
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5M
5. OH
lO.Ofj
15. OH
20. OH
so. OH
                          4.77
                          4.75
                            46
                           ,28
                          4.22
                          4.05
             4.
             4.
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
I < 2.5p .
total
I < 5. OH
total
I < 10. OH
total
Ono/i
. U£4
01 nc
. lUb
OOQrt
. zyu
                     0
                      STABILITY; 2.50 m/s WINDS; 2000 m
 Size range

   0 - 2.5n
 2.5 - 5.OH
 5.0 - 10. OH
10.0 - is. OH
15.0 - 20.OH
20.0 - 30.OH
           X/QCsirf1)
               45
               44
               23
               10
               05
             2.87
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
I < 2.5n
 total

I < 5. OH
 total

I < 10.OH _
  total
0.024


0.106
                                     143
  0.100
  0.347
  0.785
  0.633
  0.485
  1.891

  4.242
X (H9/m3)

  0.072
  0.251
  0.568
  0.459
  0.351
  1.340

  3.042

-------
                    'STABILITY;  2.50 m/s  WINDS;  3000 m
Size range
o -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5p
5. Op
10. Op
15. Op
20. Op
30. Op
I < 2.5p
total
I < 5. Op
total
I < 10. Op
— n n?d
— U. UcH
= 0.110
= n im
                       X/QCsnf1)

                         2.33
                         2.33
                          18
                          09
                          03
                        1.83
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
X (pg/m3)

  0.049
  0.170
  0.384
  0.309
  0.233
  0.855

  2.000
                    D
                     STABILITY;  2.50 m/s WINDS;  4500 m
Size range
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5p
5. Op
10. Op
15. Op
20. Op
30. Op
I < 2.5p
 total

I < 5.Op
 total

I < 10.Op _
  total
           0.025


           0.114


           0.313
                       X/QCsm"1)
                          68
                          68
                          57
                          50
                          44
                        1.21
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
X (pg/m3)

  0.035
  0.123
  0.276
  0.222
  0.166
  0.565

  1.387
                                    144

-------

                     D
                       STABILITY; 2.50 m/s WINDS;  7000 m
 Size range

   0 - 2.5M
 2.5 - S.OM
 5.0 - 10.OM
10.0 - is.OM
15.0 - 20.OM
20.0 - 30.OM
                       X/QCsm"1)

                         1.19
                         1.19
                         1.11
                         1.05
                         0.98
                         0.74
                                 Mass fraction

                                     0.021
                                     0.073
                                     0.176
                                     0.148
                                     0.115
                                     0.467
  < 10-
  total
          -0.121
          = o 334
            U'^4
                    D
                     STABILITY; 2.50 m/s WINDS; 10,000 m
 Size range

   0 - 2.5|j
 2.5 - 5.0(j
 5.0 - 10.OM
10.0 - 15.0(j
15.0 - 20.0|j
20.0 - 30.0(j
             X/QCsnf1)

               0.85
               0.85
               0.80
               0.75
               0.68
               0.45
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
I < 2.5M
 total

Z < S.OM
 total

I < 10.On
  total
= 0.029


= 0.129


  0.356
                                     145
                        X (M9/m3)

                          0.025
                          0.087
                          0.195
                          0.155
                          0.113
                          0.346

                          0.921
                                                                     0.018
                                                                     0.062
                                                                     0.141
                                                                     0.111
                                                                     0.078
                                                                     0.210

                                                                     0.620

-------
                    D
                     STABILITY; 2.50 m/s WINDS; 15,000 m
Size range

      2.5M
   0
 2.5
 5.0
10.0
15.0
20.0
      10. OM
      15. OM
      20. OM
      30. OM
1 < 2.5M
total
I < 5.0M
total
I < 10. OM
OD79
. \J3£
= 0.141
. - n 1Q9
                       X/QCsm"1)

                         0.54
                         0.54
                         0.51
                         0.47
                         0.40
                         0.22
                                 Mass fraction

                                     0.021
                                     0.073
                                     0.176
                                     0.148
                                     0.115
                                     0.467
                        X (pg/m3)

                          0.011
                          0.039
                          0.090
                          0.070
                          0.046
                          0.103

                          0.359
                    D
                     STABILITY; 2.50 m/s WINDS; 20,000 m
 Size range
0 -
2.5 -
5.0 -
10.0 -
15.0 -
20.0 -
2.5|j
5. Op
10. On
15.0(j
20.0|j
30. OM
I < 2.5M
 total

i < S.QM
 total

i < 10.OM
  total
= 0.
  0.155


  0.'
             X/QCsnf1)
                         0.38
                         0.38
                         0.35
                         0.32
                         0.26
                         0.12
Mass fraction

    0.021
    0.073
    0.176
    0.148
    0.115
    0.467
                                                                  X (pg/m3)

                                                                    0.008
                                                                    0.028
                                                                    0.062
                                                                    0.047
                                                                    0.030
                                                                    0.056

                                                                    0.231
                                     146

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       APPENDIX C


ICS MODEL APPLICATION TO
  THREE MINE SCENARIOS
           147

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MODEL FEATURES

     The ISC model programs (ISCST and ISCLT) accept the fol-
lowing source types:  point, area, and volume.  The line sources
are simulated by multiple volume sources.   The transport of
particulate emissions from stacks (point sources) are determined
using the steady-state Gaussian plume equation for a continuous
elevated source.  The area and volume source options are used to
simulate the impact of particulate emissions from a variety of
surface coal mining operations, such as reclaimed land and striped
overburden (area sources) and coal and overburden haul roads
(volume sources).  The area source model is based on the equation
for a continuous and finite cross-wind line source.  Since each
area source must be square, the effects of an irregularly-shaped
area source can be simulated by a series of multiple squares
approximating the source's actual geometry.  In general, no plume
rise exists with area sources; consequently, the effective emis-
sion height is equivalent to the physical height of the source of
particulate emissions, which for many surface mine sources will
be groundlevel.

     The steady-state Gaussian plume equation for a continuous
source is also used to calculate groundlevel particulate concen-
trations contributed by volume source emissions.  A coal or
overburden haul road (line source) is represented by a series of
multiple volume sources.  To represent a line source exactly, the
line source is divided into N volume sources, where N is deter-
mined by the length of the line source divided by its width.
Because this exact procedure is not always practical, a haul road
is often simulated by an approximate representation in which a
lesser number of equally spaced volume sources is used.  In
spacing a smaller number of volume sources at equal intervals, an
approximate representation of the line source is achieved.  The
initial lateral dispersion coefficient, a  , is set equal to the
distance between adjacent volume sources divided by 2.15 so that
the road is simulated by a series of overlapping Gaussian distri-
butions resulting from each discrete volume source.  As with area
sources, generally no plume rise occurs from volume sources.

Receptor Grid

     Selection of a Cartesian or a polar receptor grid system
allows the user to design the ISC model output for the specific
application.  Since a surface coal mine approximates a combina-
tion of multiple sources, not located at the same point, the
                               148

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Cartesian coordinate system is usually used to model mines.
Model receptors are generally placed outside what would normally
comprise the mine permit boundary for two reasons:  first, most
state and federal regulations do not require that ambient air
standards be met inside plant property, and second, the ISC model
itself ignores the source contribution induced by sources within
100 meters of the nearest receptor.

Settling and Deposition

     The effects of gravitational settling and dry deposition on
small particulates which tend to remain suspended in the atmo-
sphere for long distances is ignored by the ISC model.  The
larger particulates, however, are brought to the ground surface
by a combination of gravitational settling and deposition.
Additionally, small particulates are generally reflected from the
ground surface, whereas the large particulates that come in
contact with the surface are usually completely or partially
retained at the surface.  The ISC model includes the effects of
both dry deposition and gravitational settling.  The Dumbauld dry
deposition model, used in the ISC dispersion model, assumes that
a user specified fraction of the material that comes into contact
with the ground surface is reflected from the surface back into
the atmosphere.  The reflection coefficient is a function of the
gravitational settling velocity.  Gravitational settling of large
particulates result in a tilted plume with the plume axis inclined
to the horizontal.

     The particulate emissions from each modeled source are
subdivided into contiguous particle size categories so that the
full spectrum of particle sizes is represented by discrete cate-
gories.  For each category, the mass fraction of particulates,
the particle reflection coefficient, and the gravitational settling
velocity for the size range within the category are specified.

     The emission rates of particulate matter from each of the
three mine scenarios—Powder River Basin, San Juan Basin, and
Green River/Hams Fork Basin—have been computed in Subsection 4.2
of this report.  The first step in modeling these mines was to
collect or combine emission rates of coincident particulate
producing activities.  Haul roads, pit activities, and coal
handling facility sources were grouped together for subsequent
simulation as volume or area sources.  This source collection and
apportionment is summarized in Tables C-l through C-6, which
illustrate annual average emission rates and worst-case 24-hour
emission rates for each of the three mines.

     In all cases, haul roads and access roads were simulated as
spaced volume sources, emitting at groundlevel.  Coal handling
facilities and mine pits were idealized as groundlevel area
sources.  Details of source characteristics are summarized in
                               149

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Table C-7.  As  shown in Table C-7, the representation  of a mine
during an annual  time period and during a worst-case 24-hour
period sometimes  differ.   In a year's time, activities associated
with the mine pit cover a larger spatial area than they do during
a 24-hour period.   At the San Juan Basin hypothetical  mine,  for
example, the pit  can be idealized as five area sources,  while in
a 24-hour time  period,  activity may only take place in a spatial
area represented  by two area sources.  All computations of a
and a   in Table  C-7 are in keeping with standard modeling practice
     zo

     A very important input to the ISC model are the particle
deposition parameters,  summarized in Table C-8.  Each  of the
settling velocities and reflection coefficients was computed
using methods recommended in the ISC Dispersion Model  User's
Guide.  The distribution of mass within each particle  size range
for each of the three mines was discussed previously in Subsec-
tion 4.2 of this  report.

                TABLE C-l.  PARTICLE DEPOSITION PARAMETERS


         Particle diameter,      Settling velocity     Reflection
             microns                m/s           coefficient

             0-2.5                0.000093            1.0
           2.5-5.0                0.000837            0.99
           5.0-10.0               0.003347            0.86
          10.0-15.0               0.018223            0.73
          20.0-30.0               0.037189            0.65
                                150

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              TABLE C-2.  APPORTIONMENT OF EMISSIONS, POWDER RIVER BASIN MINE:  ANNUAL
                                                             TSP emissions
                              Source group                     tons/year
                                                151
I                        Coal  loading                               240.9
                        Wind  erosion                               117.8
                        Overburden  replacement                     391.5
                        Dozers  -  overburden                         43. 7
I                     Mine pit
                       Topsoil  removal                             9.7
                       Scraper  travel                             76.3
_                     Topsoil  dump                                3.2
•                     Overburden drilling                         2.9
•                     Overburden blasting                         1.2
                       Overburden removal                        693.8
I                       Dozers - coal                              14.2
                       Coal drilling                               1.0
                       Coal blasting                               2.1
                       Coal loading                              ""* "
                       Wind erosion
                       Overburden replacement
                       Dn7pr<; - nv/prhurripn




I


I


I


I


I


I


I


I


I
                                                                 1598.3
                      Haul  roads
                        Haul  trucks  -  coal                        3952.2
                        Lt.-  and med.-duty  vehicles                664.1
                        Graders                                      3.4
                        Access road                                  1.5
                        Haul  trucks  -  overburden                  1217.4

                                                                 5838.6
                      Facilities
                        Coal  dump                                  450.0
                        Crushing,  screening, conveying              65.7
                        Coal  loadout                               350.0

                                                                  865.7

-------
TABLE C-3.   APPORTIONMENT OF EMISSIONS,  POWDER RIVER BASIN MINE:   24-HOUR
                                               TSP emissions
                Source group                     pound/hour

       Mine pit
         Topsoil removal                            2.79
         Scraper travel                            21.93
         Topsoil dump                               0.92
         Overburden  drilling                       0.83
         Overburden blasting                        0.64
         Overburden removal                       199.37
         Dozers - coal                              4.18
         Coal drilling                              0.29
         Coal blasting                              1.68
         Coal loading                              69.22
         Wind erosion                              35.95
         Overburden replacement                   112.50
         Dozers - overburden                       12.60

                                                  462.90
       Haul roads
         Haul trucks - coal                      1135.69
         Lt.- and med.-duty vehicles              190.80
         Graders                                    0.98
         Access road                                0.81
         Haul trucks - overburden                 349.80

                                                 1678.08
       Facilities
         Coal dump                                129.31
         Crushing, screening, conveying           18.88
         Coal loadout                             100.57

                                                  248.76
                                  152

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TABLE C-4.   APPORTIONMENT OF EMISSIONS, SAN JUAN BASIN MINE:  ANNUAL
                                             TSP emissions
              Source group                     tons/year


     Mine pit
       Topsoil removal                            38.5
       Scraper travel                            117.0
       Topsoil dump                               13.3
       Overburden drilling                         7.7
       Overburden blasting                         8.8
       Overburden removal                       1293.0
       Dozers - coal                             280.2
       Coal drilling                               6.6
       Coal blasting                              46.3
       Coal loading                              173.6
       Wind erosion                             1063.0
       Dozers - overburden                       234.2


                                                3282.2
     Haul roads
       Haul trucks - coal                       2463.0
       Lt.- and med.-duty vehicles               386.1
       Graders                                   176.7
       Access road                                12.0

                                                3037.8
     Facilities
       Coal dump                                 117.0
       Crushing, screening, conveying             12.4
       Coal storage                              109.4
       Coal loadout                                 -

                                                 238.8
                                153

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TABLE C-5.   APPORTIONMENT OF EMISSIONS, SAN JUAN BASIN MINE:   24-HOUR
                                             TSP emissions
              Source group                     pound/hour

     Mine pit
       Topsoil removal                           11.06
       Scraper travel                            33.62
       Topsoil dump                               3.82
       Overburden drilling                        3.10
       Overburden blasting                        4.51
       Overburden removal                       371.55
       Dozers - coal                             80.52
       Coal drilling                              1.90
       Coal blasting                             23.15
       Coal loading                              49.88
       Wind erosion                             310.82
       Dozers - overburden                       67.30

                                                961.23
     Haul roads
       Haul trucks - coal                       707.76
       Lt.- and med.-duty vehicles              110.95
       Graders                                   50.78
       Access road                                3.45

                                                872.94
     Facilities
       Coal dump                                 33.62
       Crushing, screening, conveying             3.56
       Coal storage                              31.44

                                                 68.62
                                154

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 TABLE C-6.   APPORTIONMENT OF EMISSIONS, GREEN RIVER/HAMS
                    FORK MINE:   ANNUAL
                                        TSP emissions
         Source group                     tons/year


Mine pit
  Topsoil removal                             6.5
  Scraper travel                             45.9
  Topsoil dump                                2.2
  Overburden drilling                         1.5
  Overburden blasting                         0.6
  Overburden removal                        365.0
  Dozers - coal                              73.4
  Coal drilling                               0.5
  Coal blasting                               4.6
  Coal loading                               82.2
  Wind erosion                               62.7
  Dozers - overburden                        12.9

                                            658.0
Haul roads
  Haul trucks - coal
  Lt.- and med.-duty vehicles
  Graders
Mine facilities
  Coal dump
  Crushing, screening, conveying
  Coal storage
  Coal loadout
                           155
                                            494.4
                                            133.0
Access road
  Access road                                 0.9
                                              0.9

-------
 TABLE C-7.  APPORTIONMENT OF EMISSIONS, GREEN RIVER/HAMS
                 FORK BASIN MINE:  24-HOUR
                                        TSP emissions
         Source group                     pound/hour

Mine pit
  Topsoil removal                            1.87
  Scraper travel                            13.19
  Topsoil dump                               0.63
  Overburden drilling                        0.43
  Overburden blasting                        0.42
  Overburden removal                       104.88
  Dozers - coal                             21.09
  Coal drilling                              0.14
  Coal blasting                              2.99
  Coal loading                              23.62
  Wind erosion                              19.00
  Dozers - overburden                        3.71

                                           191.97
Haul roads
  Haul trucks - coal                       132.93
  Lt.- and med.-duty vehicles                8.88
  Graders                                    0.27

                                           142.08
Mine facilities
  Coal dump                                 18.36
  Crushing, screening, conveying             1.93
  Coal storage                               3.85
  Coal loadout                              14.28

                                            38.42
Access road
  Access road                                0.24
                                             0.24
                           156

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                                         TECHNICAL REPORT DATA
                                 (Please read Instructions on the reverse before completing)
       REPORT NO,
       EPA 450/4-83-004
                                   2.
                                                                 3. RECIPIENT'S ACCESSION NO.
      4. TITLE ANDSUBTITLE
       Characterization Of PM,jo And  TSP Air Quality Around
       Western Surface Coal Mines
                                   5. REPORT DATE
                                     August  1982
                                   6. PERFORMING ORGANIZATION CODE
      7. AUTHORIS)
                                                                 8. PERFORMING ORGANIZATION REPORT NO.
      9. PERFORMING ORGANIZATION NAME AND ADDRESS
       Pedco Environmental, Incorporated
       Kansas City, Missouri  64108      and
       TRC Environmental Consultants
       Englewood, Colorado  80111	
                                                                 10. PROGRAM ELEMENT NO.
                                   11. CONTRACT/GRANT NO.

                                     68-02-3512
      12. SPONSORING AGENCY NAME AND ADDRESS
        Monitoring And Data Analysis  Division
        Office Of Air Quality Planning And Standards
        Office Of Air, Noise And Radiation
        U.S.  Environmental Protection Agency	
                                                                 13. TYPE OF REPORT AND PERIOD COVERED
                                   14. SPONSORING AGENCY CODE
      15. SUPPLEMENTARY NOTES
        EPA Project Officer:
Thompson G. Pace
      16. ABSTRACT


               This document  is  directed to those managers and technical staff of coal
          industry and air pollution regulatory agencies needing information  on the
          general impact of surface mines on ambient particulate matter concentrations.
          The document addresses both PM10, which is a measure of particles generally
          smaller than 10 yra  by  a sampler with a 50% efficiency at 10 ym,  and Total
          Suspended Particulate  (TSP), as measured  by a high volume sampler.   Estimates
          of PMiQ and TSP concentrations are developed from actual measurements,  from
          previous dispersion modeling and from modeling three scenarios representing a
          range of mine sizes and configurations.   The results are compared to the
          Prevention of Significant Deterioration  (PSD) regulations and the National
          Ambient Air Quality Standards (NAAQS). . Both maximum controls and typical
          controls are considered, and distances from mine boundaries where PSD and/or
          NAAQS are exceeded  are discussed.
      17.
                                      KEY WORDS AND DOCUMENT ANALYSIS
                        DESCRIPTORS
                      b.IDENTIFIERS/OPEN ENDED TERMS  c. COSATI Held/Group
           Air Quality Maintenance
           Coal Mining
           Particulate - Size
           Control Strategies
      18. DISTRIBUTION STATEMENT

        Unlimited
                      19. SECURITY CLASS (This Report)
21. NO. OF PAGES
     170
                                                    20. SECURITY CLASS (This page)
                                                                               22. PRICE
      EPA Form 2220-1 (R«v. 4-77)   PREVIOUS EDITION is OBSOLETE
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