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OAR Box 1837 

Prepped by Keeia Richards 

Document Number: 

169) IV-C-9 

Docket Number: 

A-84-33 

Printed 11/14/2008 3:48:11 PM Sheet 169 of 238 
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I/O • /- Cx.rr\ <xo O/ \ 

ItStl 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ^ — _ r Q 

% -^V|V^ " WASHINGTON, D.C. 20460 - J

 v

- » ^~ \ 

*•""< ^ 

NPRO ^ MAY I 1988 

OFFICE OF 

AIR AND RADIATION 

Mr. J. Steven Griles 

Assistant Secretary Hci.tiwu 

for Land and Minerals Management ENVIRONMENTAL PROTECTION 

Department of the Interior Ar.-cry 

18th 3 C Streets, Northwest , 

Washington, D.C. 20240

 J AN I 3 1989 

Dear Mr. Griles: ••<v. o'Jtj^t-. 

""A! 

We have reviewed your proposed rule on "Performance Standards for Roads 

at Surface and Underground Mining Operations and Coal Exploration Operations," 

as proposed in the Federal Register, November 3, 1987, (52 FR 42258-42266). 

We have several comments on the proposed rule with respect to air pollution 

impacts attendant to erosion [30 CFR 816.150(b)]. 

The proposed rule represents an excellent opportunity to protect national 

parklands and other natural areas in the vicinity of mining operations from 

air emissions caused by or attributed to wind or movement of equipment on 

roads and related exposed surfaces at the mine site. The Environmental 

Protection Agency (EPA) believes that employing effective control techniques 

could minimize a major portion of the particulate matter air pollution 

emanating from surface coal mine operations. It is our understanding based 

on the preamble to the proposal that, in addition to air emissions attributed 

to wind, the rule would cover erosion resulting from the movement of overburden and coal haul trucks, light and medium duty vehicles, and other 

equipment operating outside of the. mine pit using on-site roads and surfaces. 

The EPA believes that including the preamble's explanatory language in the 

regulatory language would help clarify the requirements under this performance 

standard. 

While we recognize the necessity of developing general regulations to 

accommodate the many different configurations of mining sites, we believe it 

would improve the effectiveness of the rule to specify reasonable control 

levels and techniques suitable under various conditions. For example, the 

decision to use watering or chemical dust suppressants will depend upon 

meteorological and hydrological conditions and other mine site characteristics. In addition, the level and effectiveness of control depends upon the 

rate of application and the frequency of application, given the variables 

cited above. Even the general use of chemical dust suppressants can be 

ineffective, unless specific guidance is provided on the method and frequency 

of application needed to maximize control effectiveness. Guidance on current 

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practices for control of fugitive emissions from erosion related to mine 

roads is particularly important for heavily used primary roads which are 

potentially the largest sources of fugitive dust from mining operations. 

Although paving these roads eliminates most of the particulate emissions, 

the costs are considerable and paving is often impractical. However, the 

alternative use of gravel and other loose material may cause vehicles 

traveling on these roads to entrain dust into the air. Dust reduction 

guidance for these situations would 'oe particularly valuable. Thus, the 

implementation and enforcement of dust control "in accordance with current 

prudent engineering practices" would be considerably enhanced with the 

addition of a technical guidance document that would address current 

practices and their effectiveness under varying conditions. 

Although we recognize the 

standards, the proposed rule of 

the potential impact of fugitiv 

on adjacent national parklands. 

ing more specific guidance that 

treatment and preferred treatme 

conditions and characteristics, 

rule but could be developed in 

regulation, hy reference, at a 

"current, prudent engineering o 

fugitive emissions from mining 

a guidance document, include be 

by EPA's Region VIII in Denver 

need for fie 

fers an impo 

e emissions 

Therefore, 

could addre 

nt .netiiods s 

This would 

the near fut 

later date, 

ractices." 

roads, which 

st available 

and the Stat 

xibility in setting performance 

rtant opportunity to minimize 

from surface coal mine operations 

we urge you to consider developss minimally acceptable levels of 

uitable for a given set of mine 

not have to be included in the 

ure and be incorporated into the 

as the Department's guidance on 

Some examples of guidance for 

you may find useful in developing 

control technology determinations 

e of Wyoming regulations. 

Questions concerning our comments can be directed to William Lamason, 

Moncriteria Pollutant Programs 3ranch, Air Quality Management Division, at 

FTS 629-5374. Thank you for the opportunity to comment. 

Sincerely,.. 

- ~7 y 

trai g Potter 

J. 

Assistant 

for Air 

Administrator 

and Radiation 

cc: G. Emison, OAQPS 

A. Eckert, OGC